IL&FS ENVIRONMENTAL INFRASTRUCTURE & SERVICES 2013 … · 2 Page 33 3 15.03.2017 Section VI (D) –D(a) Training Need updated 3 Page 40 3 15.03.2017 Business Process mapping for C

2013

IL&FS ENVIRONMENTAL INFRASTRUCTURE & SERVICES

LTD.

ENVIRONMENTAL AND SOCIAL

POLICY AND FRAMEWORK

IL&FS Environmental Infrastructure & Services Ltd.

ENVIRONMENTAL AND SOCIAL POLICY FRAMEWORK

VERSION 05

May 2018

Page 3 of 111

ESPF Document Revision No.: ESPF/IEISL/Rev/2015/04

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Date Brief description of revision and reason for change

1 Page 25 5 03.05.2018

Transfer of risk monitoring from ESPF to IMS is reverted

back to ESPF. Risk monitoring frequency reduced to once

a year after IMS is established

2 Page 38 5 03.05.2018

Training and awareness generation made subject to

intensity of business activity

3 Page 39 5 03.05.2018

Intensity of corporate review reduced for High and

Moderate risk rated PTAs and site visit made subject to

management approval

4 Page 84 5 03.05.2018

Sr no. 15 & 16 added to provide additional options for

spatial examination of E&S risk

1 Page 43 5 04.05.2018

Risk assessment criteria point no. 4 in the ESPF manual

has been updated to include compliance risks related to

new regulations such as e-waste rules 2016, plastic waste

rules 2016, MSW rules 2016, hazardous waste rules 2016,

etc.

2 Page 47 5 04.05.2018

Risk assessment criteria no. 18 and 19 in the ESPF manual

have been updated to include ‘Not applicable’ and its

associated risk rating of ‘Low.’

3 Page 44 5 05.05.2018

Risk assessment criteria no. 3 in the ESPF manual has

been updated to include ‘Not applicable’ and its

associated risk rating of ‘Low.’

4 Page 5 05.05.2018

For some projects which have been commissioned,

covenants based on RRCs have not been updated in Form

1 and the covenant section in Form 1 has been left blank.

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1 Page 26 4 1.11.2017 V. Institutional arrangement, D. Role of project manager

is updated during project transition from ESPF to EMS

2 Page 45 4 1.11.2017

Annexure A: Table A) E&S Risk Rating for Project

Implementation; formation of a separate question related

to ISO 14001 certification

3 Page 90 4 27.02.2017 Form V a column is added to understand the stage of

the project

Page 4 of 111

Changes as suggested in Corporate Review 28.02.2017

1 Page 33 3 15.03.2017 Section VI (C)- Point F inserted about continuing ESPF

scope after implementation of IMS

2 Page 33 3 15.03.2017 Section VI (D) –D(a) Training Need updated

3 Page 40 3 15.03.2017 Business Process mapping for C & T Project inserted in

Annexure A- E & S Risk assessment for C & T Projects

4 Page 64 3 15.03.2017 Annexure D- point II inserted conditions for change in

format of ESPF Form I

Changes dated 31.08.2016

1 Page 33 03 31.08.2016

VI (c)- Operational Mechanism- Points (d), (e), (f), (g)

added about conversion of Project from ESPF to IMS

2 Page 10 03 31.08.2016 Section 1 (B)- Process for Adaptation of ESPF- Introduced

adaptation process from ESPF to IMS

Changes as suggested in Corporate review findings dated 19-01-2016

1 Page 11, in

Figure 1, 03 08.03.2016 SPV name ‘DDSIL’ added

2 Page 22, VA(I) 03 08.03.2016 Corporate sustainability cell replaced with E&S Cell

3 Page 22 V B

(c) 03 08.03.2016 Conduct replaced with facilitate or Assist

4 Page 23 V C(l),

and V D (k) 03 08.03.2016

Status of E&S compliance of all ongoing project shall be

submitted on quarterly basis to CSC as and when required

- point is not applicable and to be removed

5 Page 25, Fig 3 03 08.03.2016 Institutional Structure- Internal Review replaced with

Corporate review

6 Page28,

Figure 5 03 08.03.2016

Project Cycle Mapping with ESPF – Sole Sourced (Project

Implementation) to be modified - Step 1 for Form-1

generation should be prior/at the time of BAM

7 Page 33, VI (D 03 08.03.2016 Points (a) to (f) in section deleted

8 Page no. 48,

Annexure A 03 08.03.2016

Environmental and Social Risk Rating; Table C) E&S Risk

matrix for Advisory Project is not inline with criteria

specified in table B and modified as per risk rating criteria

specified

9 Page 58 &59 ,

Para C 03 08.03.2016 Reporting format for Project site monitoring to be

modified as format for Project site monitoring during

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the project










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bidding stage and Audit Report table of Content to be

replaced with Site Monitoring Report Table of Content

10

Page 61,

Annexure C

03 08.03.2016

clause/table for E&S Risk Monitoring Periodicity for

Advisory projects ( i) Development of Project and Tender

Documentation ; (ii) during PMC ) is added/modified

11 Page 75 ( I ),

Page 83 (III) : 03 08.03.2016

Clause added "Risk rating will become 'High' for any P/T/A

that becomes sub judicial on E&S aspects"

12 Page 81

section VI 03 08.03.2016

Monitoring periodicity to be modified for advisory projects

( development and PMC period)

13 Page no. 95,

Annexure N 03 08.03.2016 Not applicable and hence deleted

14

Page 33

Section VI (E)-

2

03 05.05.2016 Text modified to bring clarity on Corporate Review

15 Annexure K :

Page 90 03 05.05.2016

Risk Assessment and Monitoring:

Previous column titled “Investment size” replaced with

two columns: one column on “Total Project/Investment

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Size (Rs. Mn)” and another on “Group Company’s

Investment size (Rs. Mn)”

Additional columns added: “Litigation pertaining to

E&S issues”, “Incident of Social Unrest” - Column on

“Remarks” re-worded: “Other Remarks ('Live'/ 'On

Hold')

16

Annexure F:

Page 81

03 05.05.2016 Environmental Sensitivities and Sources of Information for

India: added for Water stress index

17

Annexure D

Form I: page

64

03 05.05.2016

ESPF Form I - Environmental and Social Risk Assessment for

Projects:

Within E&S Sensitivities section, point xiv. added:Water

stress index

Within Risk Assessment section, ‘Remarks’ column re-

labeled to ‘Remarks/ Details/ Justification to be given’

Changes as suggested in Corporate review findings in 2015

1

Section V:

Institutional

Arrangement-

C: Role of

IEISL E & S

03 23-06-2015

Point (q) inserted:-ESPF form-I has to be finalized by ESPF

coordinator.

Point (j)- Nomenclature for documents changed to –

‘Final Form X short project name Date.abc’

Point (k,i,o)-

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Cell

2

“Figure 6-

Project Cycle

Mapping with

ESPF-

Advisory

Services

03 23-06-2015 MD Approval Inserted

3

Annexure C:

A: E&S Risk

Monitoring

Periodicity

Depending on

E&S Risk

Rating

03 23-06-2015

A column added for periodicity, prescribed due date for

monitoring in Form II

4 Annexure D:

Form I 03 23-06-2015

Few Additional points added for CSC review of High Risk

Projects

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5 Annexure E:

Form II 03 23-06-2015 Few Additional points added regarding RRC in Form II

6

Annexure K:

Form V

Master

Database

03 23-06-2015

Risk Assessment and Monitoring column updates:

▫Investment size

▫Revised Risk Rating, if any. With date (under revisions)

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7

Operationaliz

ation of ESPF

at IEISL:

Section D

03 23-06-2015

(i) Section D: Title changed to Training and Awareness

Generation (ii) Few Points inserted

8

Operationaliz

ation of ESPF

at IEISL:

Section E

03 23-06-2015 Few Points Inserted

9

Document

Control:

Section B


10

Annexure H:

Scope of

Corporate

Review

03 23-06-2015 Inserted scope of review matrix

Page 10 of 111

Table of Contents

I. Environmental and Social Policy and Principles of IL&FS ......................................... 13

A. Background of ESPF ........................................................................................... 13

B. Process for Adaption of ESPF at Associate Companies ................................. 13 II. The IEISL ESPF .................................................................................................................... 14

A. Business Canvas of IEISL ................................................................................... 14

B. Relevance of ESPF to IEISL ................................................................................ 15 III. Environmental and Social Policy for IEISL .................................................................... 15

A. IEISLs E&S Policy Statement ............................................................................. 18

B. IEISL ESPF Principles ......................................................................................... 18

C. Guiding Principles .............................................................................................. 19

D. Operational Principles ........................................................................................ 20

E. Engagement Principles ....................................................................................... 21 IV. E&S Risk Identification and Management Process ....................................................... 21

A. Step 1 – Determine E&S Rating ......................................................................... 24

B. Step 2 – Apply E&S Risk Reduction Controls ................................................. 22

C. Step 3 – Monitor E&S Risk ................................................................................. 22 V. INSTITUTIONAL ARRANGEMENT .............................................................................. 24

A. Composition of the IEISL E&S Cell .................................................................. 24

B. Role of Corporate Sustainability Cell (CSC) .................................................... 25

C. Role of IEISL E&S Cell ........................................................................................ 26

D. Role of Project Manager ..................................................................................... 27 VI. Operationalization of ESPF at IEISL ................................................................................ 30

A. Mapping ESPF Steps to IEISL’S Business Cycle ............................................. 30

B. Integration of ESPF into workflow of IEISL – Project Implementation

andAdvisory Services ................................................................................................... 30

C. Operational Mechanism ..................................................................................... 36

D. Training and Awareness Generation ................................................................ 37

E. Corporate Review and External Audit ............................................................. 38 VII. Document Control ............................................................................................................... 40

A. Information Management .................................................................................. 40

B. Updates and Document Control ....................................................................... 41 Annexure A: Environmental and Social Risk Rating .................................................................. 43 Annexure B: E&S Risk Reduction and Controls ......................................................................... 53 Annexure C: Environmental and Social Monitoring and Periodicity ...................................... 65 Annexure D: ESPF Form I - Environmental and Social Risk Assessment ............................... 67 Annexure E: ESPF Form II - Environmental and Social Action Planning and Monitoring .. 80 Annexure F: Guidance Procedure for E&S Risk Assessment of a Project in ESPF Form I .. 82 Annexure G: Procedure for Monitoring a project in ESPF Form II ........................................... 87 Annexure H: Scope of Corporate Review ..................................................................................... 89 Annexure I: ESPF Form III - Findings of Corporate Review ..................................................... 91 Annexure J: ESPF Form IV - Format for Training Record .......................................................... 92 Annexure K: ESPF Form V - Master Database on Status Implementation of ESPF ............... 93 Annexure L: ESPF Form IIA - Monthly Monitoring from Project Site during Construction96 Annexure M: ESPF Form IIIA - Format for Project Site Review Report .................................. 99 Annexure O: Former Revision Page .............................................................................................. 100

Page 11 of 111

List of Figures

Figure 1: IEISL Organizational Structure based on Business Services ................................. 15

Figure 2: Steps involved in E&S Risk Identification and Management ................................ 24

Figure 4: Project Cycle Mapping with ESPF – Bid Projects (Project Implementation) ....... 29

Figure 5 : Project Cycle Mapping with ESPF – Sole Sourced(Project Implementation) ..... 33

Figure 6: Project Cycle Mapping with ESPF - Advisory Services ........................................ 33

Page 12 of 111

Abbreviations

BAM Bid Approval Memorandum

CRZ Coastal Regulation Zone

DPR Detailed Project Report

EC Environmental Clearance

EIA Environmental Impact Assessment

E&S Environmental and Social

EHS Environmental, Health and Safety

EMP Environmental Management Plan

EPC Engineering, Procurement & Construction

ESPF Environmental and Social Policy Framework

H High E&S Risk

IEISL IL&FS Environmental Infrastructure and Services Limited

IL&FS Infrastructure Leasing and Financial Services Limited

L Low E&S Risk

M Moderate E&S Risk

MSW Municipal Solid Waste

O&M Operation and Maintenance

P Project

RAP Resettlement Action Plan

R&R Resettlement and Rehabilitation

SIA Social Impact Assessment

TAM Transaction Approval Memorandum

Page 13 of 111

I. ENVIRONMENTAL AND SOCIAL POLICY AND PRINCIPLES OF IL&FS

A. Background of ESPF

(a) IL&FS has adopted an Environmental and Social Policy Framework

(ESPF). The IL&FS ESPF was approved by its Board on May 5, 2008

and is applicable to IL&FS, its subsidiaries and associate companies

as suitably adapted to reflect each individual business unit’s

processes in a phased approach of implementation.

(b) The IL&FS ESPF is founded on the concept of Sustainable

Development and recognizes Environmental and Social (E&S)

considerations in its business operations to add value, and minimize

adverse impacts and risks.

(c) The ESPF is being extended to subsidiaries in a phased manner and

IL&FS Environmental Infrastructure and Services Limited

(IEISL)and nine other associate companies are included in phase I

and II of the ESPF implementation.

(d) For overall guidance, advice and coordination related to the ESPF, a

Corporate Environmental and Social (E&S) Cell has been created.

The Corporate Sustainability Cell will take up the responsibilities of

knowledge management, communication and outreach, training (and

workshops) and compliance monitoring for the IL&FS ESPF.

(e) To ensure quality of E&S related services, IL&FS has also empanelled

E&S consultants and Environmental Laboratories. There are ten E&S

consultants and nine Environmental laboratories spread across India

that have been empanelled. The empanelment will be a dynamic

process and the list of empanelled consultants and laboratories will

be updated from time to time. This list of empanelled consultants

and laboratories shall be used to engage in various services as

required by different companies of IL&FS.

B. Process for Adaption of ESPF at Associate Companies

(a) A coordinator was identified in each Subsidiary to coordinate

activities related to the ESPF.

(b) A series of meetings were organized by the Corporate Sustainability

Cell with the Coordinators to understand the business operations

and workflows. The business processes for the various operations in

practice at the Subsidiaries were mapped.

(c) The relevance of the ESPF to the Subsidiary based on its operations

and business perspective was identified. The relevance was

demonstrated through application of the ESPF to live Projects.

Page 14 of 111

All projects where IEISL has ownership of more than 50% will gradually get their site

operations certified for Environmental Management System (EMS) ISO 14001 and

Occupational Hazard and Safety Aspects System (OHSAS) 18001 certification. In preparation

of EMS and OHSAS documentation, RRCs identified by ESPF shall be converted into

Standard Operating Procedures to be followed in the implementation of the project. Once the

project site is certified for both these standards, ESPF monitoring will continue in the form of

EMS/ OHSAS audit conducted by external auditors. All outstanding RRCs will be handed

over to the EMS system. All the details of the projects which have been converted in to EMS

shall be communicated to CSC.

II. The IEISL ESPF

A. Business Canvas of IEISL

(a) IEISL is a developer, operator and advisor on waste management

and urban environmental infrastructure projects, operating from

conceptualization through commissioning to operations and

maintenance. The portfolio includes new waste treatment facilities as

well as up-gradation, operation and maintenance expansion of

existing facilities and marketing of compost.

(b) IEISL has been involved in providing consulting and advisory

services as well as designing and implementing projects in

multimedia waste management in the Public Private Partnership

(PPP) framework in various parts of the country. IEISL has been

assisting urban local bodies in developing integrated waste

management systems.

(c) The key services offered under Advisory and Consulting are:

i. Geographical Information Systems (GIS) based services

ii. Environmental advisory services such as

o environmental impact assessment / management

plans including facilitation for prior environmental

clearance

o preparation of guidance and training manuals

o energy efficiency audits and conservation

o Clean Development Mechanism (PDDs, facilitation

for verification, validation, facilitation in transaction

and trading of CERs / VERs / ERPAs) for own waste

projects as well as other external clients

(d) The key services offered under Waste Management Infrastructure

are:

i. Design, development and execution of integrated municipal

solid waste (MSW) management facilities

ii. Solid waste processing and recycling (composting, bio-

methanation, waste to energy / refuse derived fuels,

Page 15 of 111

construction and demolition waste recycling, e-waste

recycling)

iii. Design and development of engineered sanitary landfills

iv. Dumpsite rehabilitation including closure and landfill

capping

v. Door to door collection, segregation and transportation of

Municipal Solid Waste (MSW)

vi. Waste to energy projects

vii. Clean Development Mechanism (CDM) implementation for

waste management projects of IEISL

(e) The present organizational structure based on the business services

of IEISL is presented in Figure 1.

IWMUST - Integrated Waste Management and Urban Services Company (Tamil Nadu) Ltd; EDWPCL –

East Delhi Waste Processing Company Ltd.; CDM –Clean Development Mechanism; IEWMCL –

Indraprastha Energy and Waste Management Company Pvt. Ltd. ; UWPCL – Unique Waste Processing

Company Ltd.; KRML- Kanak Resource Management Limited; DDSIL- DakshinDilliSwachh Initiatives

ltd.

Figure 1: IEISL Organizational Structure based on Business Services

B. Relevance of ESPF to IEISL

(a) Advisory and Consulting Services. The ESPF provides a framework

to identify risks faced by the services, terms of reference and

checklists for review of outputs for various services aimed towards

maintaining quality and consistency in deliverables. This framework

would support IEISL in delivery of E&S advisory services and

provide a base outline that could be customized to meet client’s

requirements. Depending on the scope of the advisory services, the

formats and checklists provided in the risk management framework

could be utilized in delivering outputs. Any advisory project such as

a DPR prepared for the benefit of environment management is not

within the purview of IEISL’s ESPF policy, as it is a short term project

of 3-5 months. Exposure to the project itself is minimized and as

DDSIL

Page 16 of 111

such, these types of advisory activities do not pose financial and

reputational risks. The complete list of risk prevention and control

measures in ESPF would be applicable to such projects IEISL in their

advisory services based on context and scope of services.

(b) Design and implementation of waste management infrastructure.

The MSW, C&D projects at IEISL could potentially pose significant

risks to environment as well as community and occupational health

& safety. These MSW and C&D management projects are regulated

and mandated under various environmental legal requirements in

India. The land required for construction of new MSW and C&D

treatment and disposal facilities or expansion and modernization of

existing facilities has to be acquired for the purpose. For instance,

i. Environmental Clearance is necessary for all new and

expansion of MSW management Projects. Additionally the

General Conditions1 based on proximity to ecological sensitive

or polluted areas etc. are also applicable.

ii. MSW and C&D Project development also includes land

acquisition which is regulated through the Right to Fair

Compensation and Transparency in Land Acquisition,

Rehabilitation and Resettlement Act, 2013 As per the Act, a

Social Impact Assessment would need to be conducted and

compensation, resettlement and rehabilitation would have to

be undertaken as per the entitlement framework of the Act,

which now also takes into account loss of livelihood in

addition to loss of property.

iii. If funding for the project is being sought from banks that

adhere to an environmental and social policy such as multi-

lateral development banks (MDBs) like World Bank/ Asian

Development Bank or Equator Principles there are additional

requirements on environment, occupational health & safety

and social (EHSS) issues to be conformed with. In the event

IEISL wishes to participate in Projects funded by such MDBs

either in India or abroad, it would benefit from knowledge of

such practices.

iv. Generation of gas and leachates mainly due to microbial

decomposition, climatic conditions, and self characteristics of

the waste, are inevitable consequences of the disposal in

landfills. The risks for the public health due to the potential

exposure to pathogenic agents, toxic substances, and gases,

together with the annoyances derived from the bad odours, the

migration of gases and leachates outside the limits of the

landfill, and their release to the surrounding environment,

1 General Condition (GC) as per EIA Notification 2006 and amendment in 2009: Any project or activity specified in

Category ‘B’ will be treated as Category A, if located in whole or in part within 10 km from the boundary of:

(i) Protected Areas notified under the Wild Life (Protection) Act, 1972;

(ii) Critically Polluted areas as notified by the Central Pollution Control Board from time to time;

(iii) Eco-sensitive areas as notified under Section 3 of the Environment (Protection) Act, 1986;

(iv) Inter-State boundaries and international boundaries.

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raise a number of important environmental questions

including the possibility of fire and explosions, damages to the

vegetation, groundwater contamination and atmospheric

pollution.

v. Dumpsite rehabilitation projects that concern open dumpsites

located in close proximity to developed areas are pressurized

to implement stringent closure and post-closure measures.

Along with technical feasibility and financial viability,

environmental soundness with respect to compliance to the

legal requirements as well as acceptability to the society has to

be addressed.

vi. MSW and C&D contains a number of chemical and biological

agents that may expose different populations to health

hazards, ranging from the composting plant workers to the

consumers of vegetable products grown in soils treated with

compost.

vii. Waste-to-energy projects using refuse derived fuels (RDF)

involve segregation of combustible and non-combustible waste

which may be a manual or mechanical or a combined process.

These facilities have to meet regulatory air quality standards.

The fly ash and bottom ash as a by product of the combustion

process has to be disposed as per the regulations and care

should be taken during classification whether they are

hazardous or non-hazardous. The location of these facilities

could conflict with surrounding land uses. The facility could

lead to transportation impacts from numerous truck trips from

the refuse source. The waste-to-energy facility requires sound

planning so as to prevent public opposition due to

uncertainties over health, safety, odour, and traffic impacts;

and avoid possible hazardous materials leakage that may

necessitate site cleanup after facility closure.

viii. E-wasteManagement and Handling Rules 2011 specify

requirements to be fulfilled by collectors, dismantlers and

recyclers. Authorization is to be obtained from the State

Pollution Control Board for such activities. The processes for

dismantling and recycling can pose severe impacts on

environment and health & safety of workers and community

as it required working with hazardous substances.

(c) The tenure of MSW and C&D projects is long term and attracting

liabilities on environment, health, safety and social issues could

indirectly create a risk as they would threaten timely repayment and

damage the company goodwill should such liabilities result in

stalling or closure of projects.

(d) During IEISL’s association with the project, ESPF will provide a

system that checks and plans for environmental compliance of

projects along with risks related to environmental pollution and

health and safety.

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III. ENVIRONMENTAL AND SOCIAL POLICY FOR IEISL

A. IEISLs E&S Policy Statement

IEISL has adopted the following E&S policy approved by its Board of Directors in

November 2011:

IL&FS Environmental Infrastructure & Services Limited (IEISL) is driven by its mission to

advise, develop, implement, operate, finance and participate in urban environmental

infrastructure projects, including waste management.

The IL&FS Environmental and Social Policy and Framework (ESPF) is founded on the

concept of Sustainable Development and thereby recognizes Environmental and Social

(E&S) considerations in its business operations to add value, minimize impacts and risks to

increase effectiveness of IEISL’s services on environmental infrastructure projects.

To achieve this, IEISL will establish and implement mechanisms to conserve natural

resources, protect the environment and provide safe and healthy workplace for their

employees and contractual staff, wherever relevant and necessary.

The ESPF applies to the business canvas of IEISL including its subsidiaries.

IEISL is committed to comply with its E&S policy, applicable laws of the land and be

responsive to existing and emerging global E&S concerns on a proactive basis.

Managing Director

Date: __________

B. IEISL ESPF Principles

The E&S policy of IEISL is to be implemented through the application of

Guiding, Operational and Engagement Principles.

(a) The Guiding, Operational and Engagement Principles form the core

of IEISL’s E&S Policy.

(b) IEISL is committed to comply with E&S regulations and legal

requirements with due credence to local, national and global

concerns.

(c) IEISL will also endeavor to move beyond compliance by

incorporating suitable technologies and practices as far as their use is

technically and financially feasible, and cost-effective.

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(d) IEISL will reflect the E&S principles followed by its

lenders and partners in its operational procedures in a harmonious

manner.

(e) IEISLrecognizes the importance of ensuring the proper management

of E&S risks for each project. Major E&S problems could adversely

affect operations, earnings of SPV’s and hence returns from

investments. Consequently, IEISL places significant emphasis on not

only E&S impacts, but also on E&S risks identification, assessment,

allocation and management at the project level.

(f) The following sections outline the Guiding Principles, Operational

Principles and Engagement Principles for IEISL’s projects.

C. Guiding Principles

(a) The Guiding Principles embody the spirit of IEISL’s ESPF. They are

non-negotiable and shall apply to IEISL, its subsidiaries and associate

companies. Through its Guiding Principles, IEISL commits to (a)

adding value to projects it undertakes, (b) integrating E&S concerns

into the decision-making process, and (c) minimizing exposure to

E&S risks.

(b) The Guiding Principles (i) through (iii) below are designed such that

they follow an imperative hierarchy. The measures and actions to

address identified impacts/risks will favor the avoidance and

prevention of impacts over minimization, mitigation, or

compensation, wherever technically and financially feasible.

(c) The Guiding Principles (iv) through (vi) below concern the elements

of engagement, compensation, and restoration, and are common to

all projects undertaken by IEISL.

The ESPF commits each project to the following guiding principles

(i) The Precautionary Principle or “do no harm” principle; when an

activity raises threats of harm to human health or the environment,

precautionary measures will be taken even if some cause and effect

relationships may not be fully established on scientific grounds.

(ii) The Preventive Principle; excluding activities which are regulated or

prohibited under International Agreements and by National Laws,

preventing adverse E&S situations by revisiting the project concept,

minimizing the release of polluting wastes to amounts that do not

affect the environment adversely, avoiding or minimizing

resettlement of people due to land acquisition, conserving natural

resources and protecting biodiversity and/or minimizing health and

safety hazards.

(iii) The Mitigative Principle; mitigating adverse E&S impacts by meeting

required State/National Policies and Legislations, incorporating

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EMPs and SMPs into the Project Cycle, and following best practices

without affecting the financial viability of the project. This principle

also extends to evaluating the impacts/risks that may result from the

implemented mitigation measures themselves.

(iv) The Participatory Principle; ensuring public participation and

community consultation, which will be free of external manipulation,

interference, or coercion, and intimidation, and conducted on the

basis of timely, relevant, understandable and accessible information.

(v) The Compensatory Principle; assisting project-affected persons in

improving or at least restoring their livelihoodds and standards of

living in real terms relative to pre-displacement levels or to levels

prevailing prior to the beginning of project implementation,

whichever is higher, wherever relevant and within the scope of the

project.

(vi) The Restoration Principle, restoring the natural condition of the

project site after completion of construction and decommissioning,

wherever relevant and within the scope of the project.

D. Operational Principles

1. The Operational Principles provide guidance to IEISL and its

subsidiaries as well as third parties involved in project execution in

enacting the ESPF. They are intended to provide appropriate focus

on E&S viability in projects.

2. These principles are flexible and adaptable; the manner of their

application will be commensurate with the nature of the activities of

IEISL, its services, and the locations and conditions in and under

which it operates.

3. Following steps are to be followed for risk identification, assessment,

categorization and determination of risk control and management

measures by IEISLduring planning and execution of the project:

(a) Examine the likely E&S risks and impacts of the project, by referring

to the E&S risk rating in Annexure A. It determines the typical level of

inherent E&S risk related to a particular business activity and location,

to assist IEISL in judging the appropriate levels of E&S investigation

that should be carried out, suitability of risk prevention and control

measures to be applied, and intensity of E&S risk control and

monitoring to be invoked.

(b) Depending on the outcome of the E&S Risk Rating process and the

impacts/risks involved, conduct an E&S assessment to address the

relevant E&S impacts/risks of the project, and propose suitable

preventive, mitigative, compensatory and restorative measures post

analysis of the impacts/risks of all project alternatives, including the

mitigation measures themselves.

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(c) Depending on the outcome of the E&S assessment, where

relevantprepare/implement Environmental Management Plan (EMP)/

Resettlement Action Plan (RAP) drawing on the conclusions of the

E&S assessment, describe and prioritize the actions needed to

implement mitigation measures, corrective actions and/or monitoring

measures necessary to manage the impacts/risks identified in the

assessment, including the provision of safe and healthy working

conditions for project labour.

(d) Depending on the outcome of the E&S Risk Rating process, where

relevant ensure engagement of project-affected persons in a structured

and culturally appropriate manner wherever relevant:

(i) their free, prior and informed consultation and facilitating

their informed participation as a means to establish whether

a project has reasonably incorporated affected peoples’

concerns within the framework of applicable legislation,

(ii) that the process and results of the consultation, including

any actions agreed resulting from the consultation are

documented,

(iii) that information disclosure takes place in a culturally

appropriate manner and in the local language, of requisite

documents at appropriate stages of the project cycle, and

(iv) that depending on the outcome of the categorization, scaled

to the impact/risks of the project, a grievance mechanism is

established as part of the engagement process, to ensure that

consultation, disclosure and community engagement

continues throughout IEISL’s association with that project.

(e) Where relevant, ensure that compensation to project-affected persons

will conform to the applicable National legislations [i.e. Right to Fair

Compensation and Transparency in Land Acquisition, Rehabilitation

and Resettlement Act, 2013. IEISL will factor the same into the Social

Entitlement Framework.

(f) Where relevant, ensure that Indigenous People are suitably recognized

wherever applicable, conforming to the spirit of National legislations

[Draft Tribal Development Plan (2006), Forest Rights Act (2006) and

Right to Fair Compensation and Transparency in Land Acquisition,

Rehabilitation and Resettlement Act, 2013]. An Indigenous People’s

Plan will be prepared to ensure their inclusion and active participation

in project benefits in a culturally appropriate manner. Further,

international good practices will be referred to where gaps exist in the

policies at National and State levels in the area of Indigenous People.

(g) Commensurate with the impact/risks of the project/transaction and its

applicable regulatory requirements, to monitor its compliance and

progress towards desired outcomes on a regular basis throughout its

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lifetime or till the end of IEISL’s association with the project, whichever

is earlier.

(h) Where relevant, ensure the preparation and implementation of a

decommissioning /closure plan, which must address:

(i) an analysis of impacts/risks at this particular stage of the

Project Cycle,

(ii) where appropriate, application of pollution prevention and

control technologies and practices (techniques) that are best

suited to avoid or where avoidance is not feasible, minimize

or reduce adverse impacts on human health and the

environment while remaining technically and financially

feasible and cost-effective, and

(iii) compensatory and/or restorative measures to be undertaken

for ecological enhancement.

(i) Incorporate E&S covenants in the contract documentation to ensure

that E&S considerations in EMPs and RAPs are duly implemented

and to insulate IEISL against all E&S risks associated with the project.

(j) Comply with all relevant national E&S policies, laws, regulations and

permit requirements. Where a project is not in compliance, work with

the Corporate ESPF Cell of IL&FS to achieve compliance levels.

(k) Periodically update procedures and guidance documents to

incorporate relevant developments in the arena of E&S management.

E. Engagement Principles

(a) In projects where IEISL does not have majority control, IEISL has

devised Engagement Principles for the organization to observe.

(b) The Engagement Principles mirror the ideology of the IEISL ESPF.

They serve to further IEISL’s aspiration to inspire and encourage all

stakeholders, including partners and co-investors towards continual

improvement in their areas of operation.

(c) Accordingly, IEISL while engaging in business with organizations will

encourage them to observe the following:

(i) Comply with national E&S, health and safety-related local

laws, as a minimum,

(ii) Take account of the E&S impact of their operations (through

an E&S Assessment in cases involving loss of biodiversity or

habitat, climate change, deterioration in land, water and/or

air quality, substantial displacement, and other issues where

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the negative E&S impacts could be significant) and take steps

to mitigate any E&S risks, and

(iii) Take account of their impact on employees, contractors, the

local community and all others affected by their operations

(through appropriate consultation, and through a Social

Assessment in cases involving involuntary resettlement,

religious/cultural property, vulnerable groups, and other

issues where the negative E&S impacts could be significant)

and take steps to mitigate any E&S risks.

(d) IEISL shall use an E&S risk categorization process for each proposed

project as early as possible, to examine broadly its likely E&S risks

and impacts. This will determine the typical level of inherent E&S risk

related to a particular project, and will assist Project Manager in

judging the appropriate levels of E&S investigation that should be

carried out, and suitability of procedures to be applied, and intensity

of E&S risk control and monitoring (if any) to be invoked.

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IV. E&S RISK IDENTIFICATION AND MANAGEMENT PROCESS

The methodology for E&S Risk Identification and Management comprises of the four

steps as shown in Figure 2.

Figure 2: Steps involved in E&S Risk Identification and Management

A. Step 1 – Determine E&S Rating

(a) The process for assigning risk rating involves reviewing Project

details, understanding environmental and social impacts, assessing

exposure and liabilities related to environmental and social non-

compliance. The E&S risk ratings define the extent of follow up

actions and monitoring required for the project to avoid or mitigate

E&S risks.

(b) Based on such assessment, a Project will be assigned any one of the

following E&S Risk Ratings:

(i) L; i.e. the Project poses low E&S risk and can be addressed

through good practices.

(ii) M; i.e. the Project poses moderate E&S risk which can be

prevented and/or mitigated by execution of appropriate

procedures and good practices as guided by the ESPF

followed by periodic monitoring.

(iii) H; i.e. the Project poses high E&S risk requiring application

of more involved procedures (field visits) with good

practices followed by rigorous monitoring.

(c) Risk in ESPF, is interpreted as the extent of obligations to be fulfilled

/ due diligence to be conducted, the absence of which could lead to

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liabilities or adverse impacts for the company in the form of legal /

scope unfulfilled, monetary and/or reputational damage.

(d) The E&S risk rating methodology developed for projects at IEISL is

given in Annexure A. Table A gives E&S risk rating criteria for waste

management implementation projects and Table B gives criteria for

advisory services.

(e) The E&S risk rating is a dynamic process which can be elevated or

lowered based on the project’s performance evaluated through

periodic monitoring.

B. Step 2 – Apply E&S Risk Reduction Controls

(a) Depending on the E&S Risk Rating assigned to a particular project,

IEISL/ project proponent / client will need to undertake certain

responsibilities towards managing the identified E&S risks and their

impacts. This will be made possible through the application of

appropriate E&S risk reduction controls.

(b) The contributing criteria to the E&S risk rating will indicate the

application of appropriate E&S risk reduction controls to be applied.

(Refer Annexure B). The applicable risk reduction controls will be

executed by review of environmental, health & safety legal

compliance; conducting E&S studies; incorporating relevant E&S

aspects in detailed project reports; insertion of covenants to this effect

in contract agreements drawn; and communication to client.

(c) Elevated E&S Risk Ratings will attract E&S risk reduction controlsof

a more advanced nature as compared to E&S Risk Ratings lower

down the hierarchy.

C. Step 3 – Monitor E&S Risk

(a) By monitoring E&S risk, IEISL intends to ensure that its E&S risk

reduction controls for each proposed project facility continue to

remain effective and safeguard IEISL against perceived E&S risks

throughout its tenure. E&S risk monitoring periodicity depending on

the risk rating is detailed in Annexure C.

(b) The E&S Risk Reduction Controls Action Planning and Monitoring is

undertaken based on the ESPF Form II attached in Annexure E.

(c) Transfer of risk monitoring from ESPF to IMS is reverted back to ESPF.

Risk monitoring frequency reduced to once a year after IMS is

established

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V. INSTITUTIONAL ARRANGEMENT

A. Composition of the IEISL E&S Cell

1. A Corporate Sustainability Cellhas been instituted at IL&FS Corporate

for implementation of ESPF at the holding company level. AnE & S Cell

has also been instituted at IEISL for implementation of ESPF.

2. The IEISL E&S Cell will comprise of an E&S Coordinator supported by

technical expertise (environmental and social specialists), where

required.

3. Technical expertise in environmental and social domains is currently

being built within IEISL and the Corporate Sustainability Cell at IL&FS

will provide this support to the E&S Coordinator in the transition

period.

4. The institutional structure with indicative functions for implementation

of ESPF at IEISL is given in Figure 3. The operational procedure for

implementing (the functions indicated in Figure 3) ESPF in IEISL during

bidding, project development, construction and operation phase is

given in Section VII.

5. The entities as part of the institutional arrangement comprise of; the

Corporate Sustainability Cell, the IEISL E&S Cell, the various teams at

IEISL, client, Special Purpose Vehicle (SPV) created for projects and the

Independent Auditing Agency.

6. The IEISL E&S Cell is the hub of ESPF activities at IEISL. The cell

coordinates with the project managers from different teams at IEISL on

E&S risk assessments and monitoring. It further presents periodic

updates on ESPF implementation to the IEISL Board.

7. The Project Managers are responsible for conducting E&S risk

assessment and monitoring for their respective projects. The role of the

main stakeholders has been listed in the following sections.

B. Role of Corporate SustainabilityCell (CSC)

The role of the Corporate SustainabilityCell (CSC) in implementation of ESPF

at IEISL will be as follows:

(a) Communicate the requirements for establishment of ESPF in IEISL

(b) Assist IEISL in customization and establishment of ESPF

(c) Conduct periodic corporate review of ESPF implementation

(d) Facilitate training sessions for capacity building

(e) Coordinate the conduct of external audit

(f) Assist IEISL in any matter related to Environmental initiatives of the

IL&FS Group and ESPF implementation

C. Role of IEISL E&S Cell

The role of theIEISL E&S Cell will be as follows:

(a) Act as IEISL’s focal point for all ESPF activities

(b) Organize and review required documentation for assessment of

environmental and social impacts

(c) Coordinate corporate reviews and annual external audits

(d) Coordinate training for IEISL staff

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(e) Update the ESPF based on operational experience

(f) Prepare a Master database on the status of implementation of ESPF

captured in ESPF Form V attached as Annexure LThe master list in the

excel file format will include all P/T/A assignments irrespective of ESPF

applied to the same.

(g) The ESPF coordinator is required to maintain a master list of all live

P/T/A assignments of the company. The coordinator will send an

updated master list to CSC in the first fortnight of every quarter. The

email communication containing the master list must also be sent to the

CEO of the Group Company.

(h) The ESPF coordinator will give final approval for all forms

(i) Coordinator should ensure that all file names are in the standard

format: ‘Final Form X short project name Date.abc’ abc’ (Applicable for

Form I, II and IIA). Other forms (Forms III, IV & V) are to be

maintained with the word “final” and date but would not have a

project name.

(j) Present findings of corporate review to the Risk Committee for

consideration as per format prescribed in Annexure O

(k) Present findings of external audit to the Board of Directors for appraisal

(l) Coordinators can volunteer as ‘Reviewers’ to conduct review of other

group companies.

(m) The ESPF coordinator has to finalize the ESPF Form I- Environmental

and Social Risk Assessment as per the attached as Annexure D. If

required, CSC review comments are to be discussed by ESPF coordinator

with CSC. Accordingly, comments are to be incorporated in the Final

Form I.

D. Role of Project Manager

The role of Project Manager in implementation of ESPF at IEISL will be to:

(a) Inform IEISL’s ESPF to clients/partners whenever required

(b) Conduct E&S risk assessment of the P/T/A

(c) Monitor the implementation of E&S risk reduction controls

(d) Update the E&S risk assessment in case of modifications in the project

on award of project.

(e) Prepare covenants to reduce environmental and social risks

(f) Engage E&S specialists as required

(g) Appear for corporate reviews and external audits

(h) Assist the E&S Coordinator in any manner as required for

implementing ESPF at IEISL

(i) Attend training sessions conducted by IL&FS CSC and IEISL E&S

Coordinator

(j) Review the periodic modifications carried out in the ESPF document

(k) Regarding projects that are temporarily stopped due to a technical or

financial reason from the client side, will prompt the Manager of that

project, to write a letter to the client asking for clarification of the same

and explaining the problems that may arise due to this action. In such a

case, the project is considered to be ‘on hold’. T respective P/A managers

will be required to send an email to the Vice President of the Project,

E&Scoordinators, Vice –President of Environmentrequesting that the

Master Database and associated forms reflect this.The E&S coordinator

can then consult the MD and other members of senior

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managementabout how to proceed with such projects.A project will be

termed ‘closed’, once all deliverables (technical works/support) have

been submitted by IEISL to the client and have received approval for the

same from the client. On the closure of a project, the manager of the

respective project will write an email to the Vice-President of the project,

E&S Coordinator and Vice-President of Environment informing them of

thesame.

(l) During project transition from ESPF to EMS;

a. The project manager will update all the points mentioned in EMS to

EHS sheets

b. The project manager will incorporate all the suggested points before and

after audit

c. The project manager will send the audit report to ESPF coordinator

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(m) ESPF activity will only be reinstated for these projects once communication is received from the manager about the revival of the

projects.

Figure 3 : Institutional Structure

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VI. OPERATIONALIZATION OF ESPF AT IEISL

A. Mapping ESPF Steps to IEISL’S Business Cycle

(a) The ESPF Steps are mapped to every stage of the project cycle as

applicable (See Figure 4, 5 and 6).

(b) The mapping of Procedures to different stages of the project cycle is

an indicative list of which only some will be applicable at a time

based on the E&S risk rating, scope of project and features of project.

(c) ESPF is mapped for two project cycles of the Project Implementation

Services - projects obtained through answering bids and sole sourced

projects; and one project cycle for the advisory services.

(d) The ESPF is not applicable to GIS services provided by IEISL as no

E&S risks are perceived in these projects.

(e) InCDM services provided by IEISL, the scope of work is limited to

project registration and assistance in monitoring and CER issuance.

Though the project to which IEISL is providing CDM services may

pose E&S risks, however due to their limited scope in these projects,

the E&S risk rating for CDM services has been identified as ‘Low’.

Hence,ESPF will not be applied for each CDM project.

(f) ESPF is also not applicable to energy efficiency projects as the

projects pose very less risk and IEISL has a very limited scope in

these projects. These projects are usually have a low risk rating

(g) Any short term (less than 6 months) advisory project such EIA, DPR

etc. is not within the purview of IEISL’s ESPF policy, , these types of

advisory activities do not pose any E & S risks.

B. Integration of ESPF into workflow of IEISL – Project Implementation and

Advisory Services

The integration of the ESPF into the workflow of Project

Implementation and Advisory Services is shown in Figures4, 5 and

6for IEISL.

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Figure 4: Project Cycle Mapping with ESPF – Bid Projects (Project Implementation)

Step 1: Identification of E&S Risk & Risk Rating

(Generate ESPF Form I and Annexe to BAM)

Step 2: Application of E&S Risk Reduction Control

List risk reduction controls for bid stage/studies

Including cost of conduct of E&S studies, EMP and

R&R, and implementation of management measures

Step 3:

Revision of Form I

Conduct of Monitoring (ESPF Form II) and Reporting

Monitoring execution of risk reduction controls in ESPF Form II

EHSS Internal Audit/review EHS performance

Monitoring of implementation and effectiveness of EMP and

corrective actions.

Conduct EIA and obtain EC

Set up EHSS Management System

Include additional covenants on

environmental, health & safety requirements

(as per the risk reduction controls) and EMP in

contract documents

Conduct ESPF Monitoring Reporting

Implement EMP including post EC monitoring

Obtain & comply with applicable

clearance/consent/approval conditions

EHSS Internal Audit

Covenants on EHS of labour in the labour

contract.

Step 2: Application of E&S Risk Reduction

Controls (Revise ESPF Form I) Generate Action

Plan for risk reduction controls in Form II

Request for

Qualification (RFQ)

MD Approval

Business Approval

Memorandum (BAM)

Request for Proposal

(RFP)

Technical and

Financial Bid

Concession

Agreement

Detailed Project

Report

Contractor’s

Agreement

Financial Close

Construction

Labour

Contract

Operation &

Maintenance

Transfer

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Figure 5 : Project Cycle Mapping with ESPF – Sole Sourced (Project Implementation)

Step 1: Identification of E&S Risk & Risk Rating

(Generate ESPF Form I and Annexe to BAM)

Step 2: Application of E&S Risk Reduction Control

List risk reduction controls for bid stage/studies

Including cost of conduct of E&S studies, EMP and

R&R, and implementation of management measures

Influencing the client to incorporate measures on

environmental protection; health & safety; & social

acceptance

Step 3: Conduct of Monitoring (ESPF Form II) and

Reporting

Revision of Form I

Monitoring execution of risk reduction controls in

ESPF Form II

EHSS Internal Audit/review EHS performance

Monitoring of implementation and effectiveness

of EMP and corrective actions.

Business

Development

MD Approval

Business Approval

Memorandum (BAM)

Proposal Submission

Letter of Intent

Concession

Agreement

Detailed Project

Report

Contractor’s

Agreement

Financial Close

Construction

Labour

Contract

Operation &

Maintenance

Transfer

Conduct EIA and obtain EC

Set up EHSS Management System

Include additional covenants on

environmental, health & safety requirements

(as per the risk reduction controls) and EMP in

contract documents

Conduct ESPF Monitoring Reporting

Implement EMP including post EC monitoring

Obtain & comply with applicable

clearance/consent/approval conditions

EHSS Internal Audit

Covenants on EHS of labour in the labour

contract.

Step 2: Application of E&S Risk Reduction

Controls (Revise ESPF Form I) Generate Action

Plan for risk reduction controls in Form II

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Figure 6: Project Cycle Mapping with ESPF - Advisory Services

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Bidding Phase/ proposal development phase

1. In case of a project to be developed through bidding route, on receipt of a

Request for Proposal (RFP), while preparing the technical and financial bid, a

preliminary E&S risk assessment will be carried out and recorded in ESPF

Form I given in Annexure D (A)along with the Bid Approval Memorandum.

2. In case of a project to be developed and sole sourced, a preliminary E&S risk

assessment will be carried out and recorded in ESPF Form I given in

Annexure D (A) and with Transaction Approval Memorandum.

3. When the TAM is being generated for an advisory project, a preliminary E&S

risk assessment will be carried out and recorded in ESPF Form I given in

Annexure D (B).

4. The project manager will enter the information required for carrying out E&S

risk assessment and assign an E&S risk rating (refer Annexure A) based on

the criteria. The project manager will also populate a list of applicable risk

reduction controls (Refer Annexure B) during project proposal submissionor

at bid stage on the basis of the project context and scope.

5. The E&S risk assessment results will be notified by the project manager to

IEISL E&S Cell through an email notification. IEISL E&S Cell will review the

E&S risk assessment results. The risk rating can be modified justifying

reasons for the same. The list of risk reduction controls will be finalized by

the IEISL E&S Cell based on project/ advisory context and scope.

6. A guidance procedure for assessment of a project in ESPF Form I is given in

Annexure F.

7. The entire ESPF Form I will be annexed with the TAM.The risk analysis point

in the TAM will include the (i) risk rating and (ii) risk reduction controls

(RRCs) so that risk perception is easily available to the approver or decision

maker.

8. The ESPF Form I would be revised in case of the following conditions;

(i) Award of project.

(ii) Change in project manager, project location, components, allied

activities and scope of work which render the existing risk rating

and risk reduction controls inappropriate.

(iii) Modification/s for closing corporate review or external audit

findings.

(iv) Revision of E&S risk rating.

(v) Amendments in legal requirements and introduction of new

regulations

Award, Design & Tendering Phase

9. Once the project/ advisory is awarded to IEISL, the ESPF Form I for the

project will be revised to include E&S risk reduction controls for design,

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construction and operation phases of the project (refer Annexure B). The

requirements for E&S clearances, approvals, permits applicable to the project

will also be noted at this stage.

10. IEISLE&S Cell will develop an action plan for implementation of risk

reduction controls identified in ESPF Form I. The action plan will include

details on tasks, outputs, responsibility and timelines for each risk reduction

control in ESPF Form II given in Annexure E. The controls applicable on a

one time basis and those requiring periodic action will be identified.

11. The E&S covenants recommended in ESPF Form I will be included in

contractual (tender) documents.

12. Monitoring will be conducted as per the action plan in ESPF Form II before

release of contractual (tender) documents for bidding, to check and record

whether E&S risk reduction controls have been incorporated.

13. The guidance procedure for monitoring of a project using ESPF Form II is

given in Annexure G.

Construction Phase(Applicable to Advisories only if the scope includes

Supervision of Construction/ Project Management Consultancy PMC)

14. IEISL will ensure implementation of all environmental, health & safety

measures specified in various documentation (but not limited to) such as

project legal clearances/ approvals, ESPF Form I and IL&FS construction

environmental management plan manual.

15. The monitoring in ESPF Form II will be conducted as per the periodicity

defined for the project. Any new risks identified during monitoring will be

captured in ESPF Form II with an action plan for subsequent monitoring in

the next cycle. For each monitoring cycle, ESPF Form II will be revised as

per the new format instead of creating a new form II each time.

16. Based on the monitoring results, the E&S risk rating may be elevated as per

the guidance given in Annexure C to ensure close monitoring of the project.

The revised E&S risk rating will be captured in ESPF Form I as a revision

with appropriate justification.

17. IEISL will obtain a monthly reporting on environmental, health & safety

parameters from the project site in ESPF Form IIA ( Refer Annexure L)to

identify new risks. A major incident or fatality occurring at site during

construction will also trigger incident investigation and reporting from the

project site. Similarly, any litigation filed on the company with respect to E&S

issues will also trigger a monitoring and reporting.

18. IEISL may provide the contractor/s with specifications and procedures for

implementation of environmental mitigation measures given in the

IL&FSConstruction EMP Manual, where required.

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19. A project-specific legal checklist of clearances and approvals granted as well

as those required at a later stage when the project progresses, will be

maintained at the project site or at IEISL’s Corporate office. For clearances/

approvals granted, the checklist will include reference number, date of issue,

validity and date of renewal (if required). IEISL will ensure that conditions of

clearances and approvals applicable in the construction phase are

implemented at site.

Operation Phase(Applicable to Advisories only if the scope includes Supervision

of O&M)

20. IEISL will ensure implementation of all environmental, health & safety

measures specified in various documentation (but not limited to) such as

project legal clearances/ approvals and ESPF Form I for the operation phase.

21. The monitoring in ESPF Form II will be conducted as per the periodicity

defined for the project. Any new risks and risk reduction controls identified

during monitoring will be captured in ESPF Form II with an action plan for

subsequent monitoring in the next cycle. For each monitoring cycle, a new

ESPF Form II will be created capturing risk reduction controls that need

continuous monitoring. A major incident or fatality occurring at site during

operation will also trigger incident investigation and reporting from the

project site. Similarly, any litigation filed on the company w.r.t. E&S issues

will also trigger a monitoring and reporting.

22. Where required, the E&S risk rating may be elevated or lowered during

monitoring based on the guidance given in Annexure C& E and captured in

ESPF Form II. The revised E&S risk rating will be captured in ESPF Form I

as a revision with appropriate justification.

23. The clearances and approvals granted to the project for commissioning will

be added to the legal checklist along with thereference number, date of issue,

validity and date of renewal (if required). IEISL will ensure that conditions of

clearances and approvals applicable in the operation phase are implemented

at site.

C. Operational Mechanism

(a) The ESPF will be applicable to all projects and advisory services

awarded and ongoing after the date of E&S policy approval by IEISL.

For waste management implementation projects, ESPF will also be

applied at the bidding stage.

(b) E&S issues will be identified for all projects considering the scope of

IEISL in the project. If a significant issue is identified, IEISL will take

suitable actions to address the issue itself or by influencing the client.

(c) In the initial stages CorporateSustainability Cell will play a major

role. The IEISL E&S Cell will be trained to carry out its functions by

the Corporate Sustainability Cell. With time as ESPF matures and

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integrates in the operations of IEISL, the role of Corporate

Sustainability Cell will gradually reduce and finally be phased out.

(d) IEISL shall also endeavor to get relevant certifications such as ISO

9000, ISO 14001 and OHSAS 18001 certifications for Environmental

Management System for projects where it has ownership of more

than 50% and can exercise management control. In the event of the

certification of a project site for Environmental Management System,

the ESPF shall cease to be apply to that particular project

(e) Projects / project companies that are commencing operations or have

achieved sustainable operations shall / project companies obtain the

IMS / EHS certification, the ESPF shall be replaced with the

applicable EMS and OHSAS documentation and these shall become

the governing framework for E&S related matters of the respective

projects for the operations phase.

(f) Even after transfer of a project or transaction from ESPF to EMS,

Project Manager continues to report on following aspects on

quarterly basis:

I. Legal notices, fines and litigation - Litigation information is

shared with the CSC.

II. Accidents and safety events - Fatalities if any should be

reported to CSC.

III. Social Unrest - Any event of social unrest against the project

should be reported to CSC

(g) The RRC’s (as per the ESPF) identified and untreated / open on the

date of transition from ESPF to IMS/EHS system will be monitored as

perunder IMS/EHS system through either of the three registers

namely Hazard Identification and Risk Assessment, Aspect Impact

Register, and Legal register as per the project nomenclature

(h) Once a project is transferred to IMS/EHS, it will be subject to

verification in the immediately upcoming internal audit and external

audit only

D. Training and Awareness Generation

(a) IEISL ESPF Cell will conduct a maximum of 1 full day training

sessions customized to train the staff in E&S Risk Rating,

Environment Health and Safety (EHS), Environment Management

System (EMS), Introduction of IMS system and application of risk

reduction controls to their projects.

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(b) ESPF will also be introduced into the training organized during

induction of staff at IEISL.

(c) ESPF coordinator shall frame training program/ schedule as per

mandatory online training modules conducted by the CSC ESPF

coordinator shall communicate the training program/ schedule to the

HRD of IEISL.

(d) The records of training conducted will be maintained in the format

attached in Annexure J.

(e) Training and awareness generation to be made subject to intensity of

business activity

E. Corporate Review and External Audit

1. The purpose of the audit includes but is not limited to determining

continued conformance with the requirements of the IEISL’s ESPF. The

audits will take two forms – Corporate Review and External Audit.

2. The Corporate Review will be conducted by the Corporate

Sustainability Cell (CSC).The CSC will conduct Corporate Review

twice a year. The review will comprise of two components- Office

based system review and site inspections where (applicable). The

corporate review shall be presented to the Risk committee.

3. External Audits will be conducted by a third party agency such as

audit firms.

4. Select projects under the purview of the IEISL ESPF will be subjected

to both Corporate Review and External Audits. External audits will

also be conducted at subsidiaries where ESPF is under

implementation. Depending on the risk rating of P/T/A, Corporate

Review will be conducted as per the scheme given in the following

metrics:

HIGH MODERATE LOW

PROJECTS

Form I should be sent to CSC

for review. 100% Corporate

Review with Site Visits at least

once a year

Corporate Review of 100%

cases twice a year

Corporate Review of

25% cases selected at

random twice a year

TRANSACT

IONS

Corporate Review of 100% cases

once a year

- 50% cases at every Corporate

Review


cases selected at random

twice a year

Corporate Review of


random twice a year

Page 39 of 111

ADVISORY Corporate Review of 25% cases

selected at random once a year


cases selected at random

once a year

Only reported in

quarterly Master List

updates. Not

monitored by CSC

5. The scope of the corporate review is given in Annexure H. The findings

from the corporate review will be reported in ESPF Form III designed

for the purpose and is attached in Annexure I. The updated Form III

and IIIA (where applicable) will be shared with CSC & the same will be

discussed by the respective Group Company Coordinator

With the CEO of the CEO of the Group Company

6. A Site Review would also be part of the scope of the corporate review

and will be reported in ESPF Form IIIA and is attached in Annexure

M.

7. Site inspection by CSC will be discontinued in case particular project

site gets certified for ISO 14001 and OHSAS 18001 standards with

RRCsincorporated in the EMS & OHSAS documentation. Exception to

this issites where there is an ongoing litigation on E&S aspects, or

ongoing social unrest or a fatal accident has taken place in the

preceding 12 months. Social unrest refers to ‘an agitation against the

project/ project SPV/ IL&FS or any of its subsidiary/ associate

companies by more than 10 people gathering in one place. It could be a

peaceful protest or sloganeering or any other form of protest’.

8. External audits at IEISL will be conducted before the close of each

financial year. The corporate review will be carried out semi-annually.

9. The scope of external audit will be to review IEISL’s ESPF document to

assess whether design of ESPF is well mapped, relevant and beneficial

to the business canvas of the company.

10. The findings of the Corporate Review and External Audit should be

closed within 4 weeks of the finalization of Review Report.

11. The findings of the Corporate Review to be placed forth the Risk

Committee of the Group Company in immediate next meeting of the

Risk Committee. The findings of the External Audit are to be placed

forth the Board of the Group Company

12. A snapshot of all live P/T/A and details of High rated P/T/A will also

be provided to the Risk Committee as per Annexure

13. Intensity of corporate review reduced for High and Moderate risk

rated PTAs and site visit made subject to management approval

Page 40 of 111

VII. DOCUMENT CONTROL

A. Information Management

1. Records based on formats proposed in the ESPF will be created for

internal approvals and communication. As part of its project

development and E&S due diligence; IEISL will collect large amount of

data and information in the form of reports. It is therefore necessary that

IEISL establishes an information management mechanism to keep

proper records in various forms (hard copies and soft copies) and

maintain controlled copies of all process documents.

2. Final version of all forms shall be maintained by the ESPF coordinator.

If these forms are maintained in print (hard copies), the final version

shall be signed by the coordinator with the date. If they are in electronic

format, each file shall be named as: Final Form X short project name

date.abc. Deviations from this standard format of form names shall only

be done in consultation with CSC.

3. All formats and information that IEISL will maintain in ESPF has been

listed in Table 1.

Table 1: List of Formats and Documents to be recorded

Type Sub Type Stage of Collection

A ESPF Format

ESPF Form I – E&S Risk

Assessment

Before

AAM/BSAM/CIAM

approval

ESPF Form II – E&S Monitoring

and Action Plan

Action Plan part to be

completed after

approval for project

Status on

implementation

during Quarterly/

Semi-Annual/ Annual

Monitoring

ESPF Form IIA –Site Visit EHS

Checklist during construction

Monthly during

construction for

project

implementation

ESPF Form III – Corporate

Review

Semi-Annual

Corporate Review

ESPF Form III A –Project Site

Review Report

As part of the Semi-

Annual Corporate

Review

ESPF Form IV –Training

Records

Conduct of training

sessions

ESPF Form V – Master database Regularly updated on

new projects and at

Page 41 of 111

Type Sub Type Stage of Collection

the time of monitoring

The Master database

will include all LIVE

projects, and

transactions and

advisory assignments,

irrespective of

whether ESPF has

been applied to such

projects, and

transactions and

advisory assignments.

It will also include all

projects and

transactions that are

‘on hold’/ ‘under

suspension’

Annual E&S external audit

report

Annual External

Audit

B

Documents

provided by

client/ self

obtainedfrom

Regulatory

Authority for

waste

management

implementation

projects

Environmental Impact

Assessment Report

Before Financial

Close/ during

preparation of DPR

Environmental Clearance

Before

Commencement of

Construction

Post Environmental Clearance

Monitoring Reports

Construction and

Operation

Consent to Establish

Before

commencement of

construction

Consent to Operate

Before

commencement of

operations

Authorization under Municipal

Solid Waste Rules

Authorization for disposal of

hazardous waste

Other permits/ approvals

Before

commencement of

construction and

operation

B. Updates and Document Control

(a) The findings from the corporate reviews will be presented in the

immediate next Risk Committee meeting after each Corporate

Review and the findings of the external audit will be presented to

the board meeting immediately after the external audit. The ESPF

Page 42 of 111

will be updated to reflect the lessons learnt at planned intervals, to

ensure continuing suitability, adequacy and effectiveness.

(b) The updates to the Policy, Principles and Risk Prevention and

Control measures could also be done in the light of external changes

such as the national laws and regulations and lender’s requirements

or a need to update internal principles and procedures.

(c) The responsibility for updates will lie with the Coordinator in the

IEISL E&S Cell. IEISL shall update the ESPF manual which will then

be reviewed by the Corporate Sustainability Cell. The revised

document shall be submitted back to IEISL E&S Coordinators who

will review the revisions and also be responsible for its circulation

within IEISL.

(d) The ESPF coordinator is required to maintain a master list of all live

P/T/A assignments of the company. The coordinator will send an

updated master list to CSC through the CEO in the first fortnight of

every quarter.

(e) The IEISL ESPF document shall be revised atleast after corporate

reviews and external audit based on corrective and preventive

actions planned to close the findings. The revision carried out in the

document shall be summarized on the ‘Revision Page’, stating

reasons for the same.

(f) The latest revisions would be captured as a separate revision page in

the beginning of the document. The older revisions would be placed

at the end of the document.

(g) A document will have a minimum of review for1revision ina year

with any amount of changes..

(h) Revisions made in a particular version are to be recorded in a table

Page 43 of 111

Annexure A: Environmental and Social Risk Rating

Table A) E&S Risk Rating for Project Implementation

Criteria

No. E&S Risk Rating criteria

Yes/

No E&S risk assigned

Remarks (reasoning for assigning

risk rating)

1.

Does the project involve

Collection and/or transportation

services?

The E&S risk ratings

are as follows:

For projects involving collection and

transportation of waste, the Health and

Safety issues for workers will require

attention. Also, environmental issues

related to spillage, odor and vehicular

emissions will need attention.

Hence, more the possibility of waste

contact “Higher” the Risk Rating

The workers will be required to wear

PPE such as gloves, mask etc. while

handling the waste.

Hence, the risk rating assigned will be

moderate.

a) Collection (Specify

community bins or door to

door collection )

a) Moderate

b) Collection and

Transportation

b) Moderate

c) Only Transportation c) Low

d) None of the above

d) Low

For projects restricted to collection and/or transportation services, Question No.s (2), (3), (9), (10) from the below

mentioned questions need not to be answered.

2.

Does the project pose any

environmental pollution, health

and safety risks due to the

following processing activities:


are as follows:

Assigned by potential to cause

environmental pollution; and health and

safety risk

a) Composting a) Moderate

b) Bio-methanation b) Moderate

c) Construction and

Demolition waste

c) Moderate

d) Waste to energy (power

generation)

d) Moderate (<20MW)

e) High (>20MW)

e) Refuse Derived Fuel

(producing RDF) f) Moderate

f) Rubber and plastic waste g) High

g) E-waste

h) Moderate

(receiving, auditing,

dismantling,

segregation, resale)

i) High (Processing

and precious metal

recovery)

h) MSW Landfilling g) Moderate

i) Dumpsite closure h) High

j) Hazardous waste treatment

and disposal

i) High

k) Incineration j) High

l) Common Effluent

Treatment Plant

k) Moderate

A. The Highest of the above risk rating in Q 1 to Q 2 will be used.

3.

Is the project included in the

Schedule of Environmental

Impact Assessment Notification

2006?

(Please specify status of

Environmental Clearance)


are as follows:

a) Common Municipal Solid Waste

Management Facility (Cat. B),

b) Common Effluent Treatment Plants

(Category B),

c) Common Hazardous Waste

Treatment Storage, and Disposal

Facilities (Integrated facility with

incineration and landfill or a) Category A a) High

Page 44 of 111

Criteria


Yes/



risk rating)

b) Category B

c) Not Applicable

b) Moderate

c) Low

incineration: Category A; Landfills:

Category B)

d) Thermal Power Plants based on non

hazardous municipal waste (≥20MW:

Category B; <20 and >15 MW:

Category B)

The above require environmental

clearance as per the Schedule in the EIA

Notification. The clearance is granted

with some conditions that have to be

fulfilled by the project proponent. In case

it is found that there have been serious

violations of the clearance granted, the

same could be suspended/revoked by

the MoEF.

Though projects categorized as B would

have to go through the complete EIA

process, the number of conditions

attached would be lesser and hence a

‘Moderate’ risk rating has been assigned.

If a project does not require EIA or does

not fall under EIA Notification then the

project rating would be Low.

4.

Does the location, design and/or

operational management of the

project facility take into account

the specifications provided by

the MSW (M&H) Rules, 2016 and

C & D Waste management rules

2016 in case of C & D Waste

Management Projects

If ‘Yes’, E & S risk

rating for any type of

project site shall be

‘Low’

If ‘No’, E&S risk rating

for any type of project

site shall be ‘High’

The site location being most critical in

case of landfill sites, and MSW/ C & D

rules compliance in case of design and

operations specification of facilities are

important that would determine

subsequent risks to public health have to

be managed for the project facility.

5.

Is the project located in/traverse

through or is in proximity to any

eco-sensitive zone (ESZ) notified

by MoEF?

If ‘Yes’ and within 10

km of ESZ then E&S

risk rating is ‘High’

If ‘No’then E&S risk

rating is ‘Low’

For projects where Eco-Sensitive zones

exist within the project, clearances from

respective authorities are required as per

the particular ESZ notification are

required and hence rated ‘High’.

6.

Does the proposed project

traverse through or within 10 km

buffer of Protected Areas

(National Parks, Wildlife

Sanctuaries, and Biosphere

Reserves)?

If ‘Yes’ and is within or

traverses through

Protected Areas or in

10 km proximity then

E&S risk rating is

‘High’

If ‘No’then E&S risk

rating is ‘Low’

A 10 km buffer from National parks,

marine parks, sanctuaries, reserve

forests, wildlife habitats and other

protected areas under the provisions of

Wild Life (Protection) Act, 1972

including Biosphere Reserves; have been

declared as eco-fragile areas and these

are regulated by the National Board for

Wildlife.

For projects where clearance from

wildlife board has to be taken, higher

due diligence efforts are required and

hence rated ‘High’.

7.

Is the project site located within

or close to CRZ areas?

If ‘No’, then E&S risk

rating is ‘Low’

If Yes, then the E&S

risk ratings are as

follows:

The risk rating is based on the extent of

the sensitivity to the CRZ / IPZ areas as

defined by the Notification of 2011 is as

follows:

a) Land area from HTL to 500mts on the

landward side

b) Land area between HTL to 100 mts or a) CRZ I a) High

Page 45 of 111

Criteria


Yes/



risk rating)

b) CRZ II b) Moderate width of the creek whichever is less on

the landward side along the tidal

influenced water bodies connected to

the sea

c) Land area between HTL and LTL ‐

intertidal zone

d) Water and the bed area between the

LTL to the territorial water limit (12

nm) in case of sea

e) Water and the bed area between LTL

at the bank to the LTL on the opposite

side of the bank, of tidal influenced

water bodies.

c) CRZ III c) Moderate

d) CRZ IV d) High

e) CRZ for Greater Mumbai e) Moderate

f) Island Protection Zone (IPZ)

f) High

8.

Does the project pass through/

located in tribal areas/scheduled

areas2 or affects their livelihoods?

If ‘Yes’, then E&S risk

rating is ‘High’

If ‘No’ then E&S risk

rating is ‘Low’

Projects passing through /located in

tribal areas/scheduled areas or affecting

their livelihood have to obtain their

consent and share project profits for

tribal development. Obtaining their

consent is a long drawn process and

requires employment of social

development specialists and hence

‘High’ risk rating has been assigned.

9.

Does the proposed project or any

associated activity/component

invoke the provisions of LARR3?

If ‘Yes’ and cause

involuntary

displacement of people

or affect livelihood,

then risk rating “High”

If No then risk rating is

“Low”

LARR provisions are invoked where

land is to be acquired by the government

or private party for public purpose. The

provisions are for land acquisition,

consent, compensation, rehabilitation

and resettlement of persons interested.

The provisions include physical as well

as economic displacement and prescribes

a host of actions to be undertaken based

on nature of land acquisition.

These projects have a greater social risk

and may affect the project development

cycle. Determining public purpose,

conducting Social Impact Assessment

and preparing rehabilitation &

resettlement schemes & plans are key

requirements of the Act.

10.

Does the proposed project lie in

close proximity to archaeological

sites?

If ‘Yes’ and within

100m, then E&S risk


If ‘Yes’and between 100

meters and 1km then

E&S risk rating is

‘Moderate’


rating is ‘Low’

100m around an archaeological site is

considered a prohibited zone and

permission from the

ArchaeologicalSurvey of India or from

State Archaeology Department/Office

will be required, hence, a ‘High’ risk

rating has been assigned. And if within

proximity of 1 km considered ‘Moderate’

2 Tribal areas and Scheduled areas mean areas having preponderance of tribal population. These are declared as

under the Fifth and Sixth Schedule of the Constitution of India. 3The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Rehabilitation Act

Page 46 of 111

Criteria


Yes/



risk rating)

11.

Is the proposed project located in

an area susceptible to natural

hazards (earthquake-seismic

zones: IV & V, history of floods,

cyclones, other natural hazards)?

If ‘Yes’, then E&S risk



rating is ‘Low’

The sensitivities due to natural hazards

have to be factored in the project design

and planning.

12.

What is the major landuse

around 500m radius of project

site?


are as follows:

Assigned by sensitivity of the receptors

and potential to cause health and safety

risk

In case of C&T of MSW project, the risk

rating would be assigned low to all a-d

sections, only in case of forest or any

other eco- sensitive zones the risk rating

will be hight.

a) Residential/ Commercial a) High

b) Industrial b) Moderate

c) Institutional (Educational/

Medical) c) High

d) Agricultural

d) High to Moderate

(depending on

topography,

geological

condition, ground

water table and

cultivation)

e) Forest e) High

f) Any other (please specify)

13. Is the project site located in low

lying areas or flood prone areas?

If ‘Yes’, E&S risk rating

assigned is ‘Moderate’

to ‘High’ depending on

the water logging in

rainy season

In case of a site being a low lying area,

any reclamation and filling would alter

the drainage pattern in the area. This

would need to be taken into account

during construction.

14. Is the project site located within

200m of a water body?


assigned is ‘High’ to

‘Moderate’ depending

on the use and

sensitivity of the water

body.

In case of the project site being located

close to water bodies, may lead to water

pollution and health impacts. Thus the

risk rating is ‘High’ to ‘Moderate’

depending on its use and sensitivity.

15. Is the project site located in water

scarce/ drought prone regions?




rating is ‘Low’

In case project is in areas where;

a) Ground water status Critical and over

exploited

b) Low rainfall areas

c) Non‐perennial rivers/ nallahs as

source of water.

The water withdrawal due to the project

would create further pressure on the

scarce resources.

16.

Is the project site within an

existing dumping site or other

infrastructure facility

(STP/CETP)?

If it is Composting

Facility:

If ‘Yes’ and existing

dumping site, and

The management of activities other than

the project specific ones would

potentially create environmental, health

and safety risks. a) Greater than 300

Ton per Day- “High” b) Less than or equal

to 300 Ton Per Day-

“Moderate”

Page 47 of 111

Criteria


Yes/



risk rating)

If it is C & D

Processing Facility:

If ‘Yes’ and existing

dumping site, and

a) Greater than 500 Ton

per Day- “High”

b) Less than or equal to

500 Ton Per Day-

“Moderate”

If within existing

dumpsite and

STP/CETP, E&S risk

rating assigned is

‘Moderate’

If ‘No’ or “Not

applicable’ then E&S

risk rating is ‘Low’

17.

Is there any electrical

transmission line or electrical

sub-station or gas pipe lines

passing through or adjacent to

project site?




rating is ‘Low’

The project activities and fire hazards

would be a safety risk to the installation

and hence need attention.

18.

Does the project involve

segregation of waste within the

scope of activities?


are as follows: This determines the waste and hazard

exposure to the workers and would lead

to health concerns. Hence, in case

segregation is within the scope and done

manually would mean ‘Higher’ health

risks to the workers.

a) Manual a) Moderate

b) Automated

b) Low

c) Not Applicable c) Low

19.

Are existing rag pickers

integrated within the project

operations?



If ‘Yes’or “Not

applicable’ then E&S


Private party involvement for waste

management services is a perceived

threat to livelihood of existing rag

pickers. Hence, inclusion of the rag

pickers within the project would ensure

protection of livelihood and mitigate

risks of conflict. Hence, in case rag

pickers are not involved with the project

there are ‘Higher’ reputational risks due

to potential of conflicts.

20.

Does the project site have an

environmental, health & safety

management system established

and required human resources to

implement the system?


assigned is ‘Low’.



Implementation of the projects involves

several impacts on environment and

health and safety of workers and

community. A sound management

system is required to manage these

impacts during construction and

operation of the sites.

Page 48 of 111

Criteria


Yes/



risk rating)

21. Is the project certified under ISO

14001?


assigned is ‘Low’.



Implementation of the projects involves

several impacts on environment and

health and safety of workers and

community. A sound management

system is required to manage these

impacts during construction and

operation of the sites.

22. Any litigation concerning E&S

issues?

If ‘Yes’ then E&S risk

rating is will be ‘High’

or ‘Moderate’ on case

to case basis.


rating is ‘Low’

Litigation on E&S aspects should be

checked through web search on the

project or verified from the National

Green Tribunal (NGT) Website4.

Litigations may lead to project delays

and hence, details of the same need to be

sort along with orders if passed by the

Court or the NGT. Depending on the

criticality of the issues and the court

orders passed, the risk rating would be

determined as ‘High’ or ‘Moderate’

B. (i) In case any of the Q3 to Q22 is High, the risk rating arrived at Step A will be elevated to High;

(ii) In case any Five(5)of the Q3 to Q22 will be ‘Moderate’, the risk rating will be elevated to ‘High’

(iii) In case none of the conditions of (i) and (ii) follows then the Highest of the risk rating of Q3 to Q22 shall be

assigned.

(iv) The composting facility less than or equal to300 TPD & C & D Waste Processing Facility less than or equal

to 500 TPD will be kept moderate, despite high rating due to the risk rating arrived from Q3 to Q22 ,until any

eco-sensitive or court issue is not there. If any such things occur, it will be elevated to high.

(v) If the Composting facility & C & D Facility are greater that 300TPD & 500 TPD Capacity respectively then

the risk rating as derived by evaluating Q3 to Q22 will be assigned.

4http://www.greentribunal.in/

http://www.greentribunal.in/

Page 49 of 111

Table B) E&S Risk Rating for Advisory Services

Criteria


Yes/

No

E&S risk

assigned

Remarks (reasoning for

assigning risk rating)

1.

Is the project for which

advisory being provided

included in the Schedule of

Environmental Impact

Assessment Notification

2006?

The E&S risk

ratings are as

follows:

If the project is a part of the Schedule

in the EIA Notification, an

Environmental Clearance has to be

obtained. IEISL accordingly needs to

safeguard their clients by informing

them of the compliance requirements

and assistance on the same.

a) Category A a) High

b) Category B b) Moderate

c) None of the above c) Low

2.

What is the type of sector the

project is dealing with?

The E&S risk

ratings are as

follows:

Assigned to the sector as per the

potential to cause environmental

pollution; health and safety risk

a) Municipal Solid Waste

Management a) Moderate

b) Any other waste

management

(Hazardous Waste,

biomedical, e-waste)

b) High

c) E-waste refurbishing c) Moderate

d) E-waste processing d) High

e) Waste to Energy e) High

f) Water Supply and

Waste water f) Moderate

g) Surface Transport and

Transportation Systems g) Moderate

h) Special Economic Zones

& Cluster Development h) Moderate

i) Industries and

Industrial parks i) Moderate

j) Building Construction j) Low

k) Tourism k) Low

l) Ports l) High

m) Power and Hydro

Power m) High

n) Any other (Please

Specify)

n) Assigned as

per EHS issues

3.

What is the type of advisory

service being provided?

The E&S risk

ratings are as

follows: IEISL shall face reputational risk

depending on the criticality of the

advisory project. Hence, risk rating

assigned as per advisory service

provided by potential to cause

reputational risk in case of an issue

with the project

a) Environmental Impact

Assessment a) Moderate

b) Social Impact

Assessment b) Moderate

c) Detailed Project Report c) Moderate

d) Environment

Improvement Plans d) Low

Page 50 of 111

Criteria


Yes/

No

E&S risk

assigned



e) Environment

Management Plans/

Master Plans

e) Low

f) Energy Efficiency

Audits

f) Low

g) Clean Development

Mechanism

g) Low

h) Project Management

Consultancy

h) Moderate

i) Establishing

Environmental

Management System

(OHSAS and ISO)

i) Low

j) Research, Training and

Awareness j) Low

4.

Is the project site located

within or close proximity (0-

10km) to E&S Sensitive

areas?

The E&S risk

ratings are as

follows:

Assigned by sensitivity of the

receptors and potential to cause

environmental impacts, as also the

legal compliance requirements.

a) Protected areas a) High

b) Eco-Sensitive Zones b) High

c) Important Bird Areas c) Moderate

d) CRZ areas

d) High for CRZ I

& IV, Moderate

for CRZ II & III

e) ASI Sites e) Moderate

f) Reserved /Protected

Forests

f) High for >40ha

and Moderate

for <40ha

g) Scheduled / Tribal

Areas g) High

h) None of the above h) Low

5.

Does the proposed project or

any associated

activity/component invoke

the provisions of LARR5?

If ‘Yes’ and cause

involuntary

displacement of

people or affect

livelihood, then risk

rating “High”

If No then risk

rating is “Low”

LARR provisions are invoked where

land is to be acquired by the

government or private party for

public purpose. The provisions are

for land acquisition, consent,

compensation, rehabilitation and

resettlement of persons interested.

The provisions include physical as

well as economic displacement and

prescribes a host of actions to be

undertaken based on nature of land

acquisition.

These projects have a greater social

risk and may affect the project

development cycle. Determining

public purpose, conducting Social

Impact Assessment and preparing

5The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act

Page 51 of 111

Criteria


Yes/

No

E&S risk

assigned



rehabilitation & resettlement schemes

& plans are key requirements of the

Act.

6.

Is the proposed project

located in an area susceptible

to natural hazards

(earthquake-seismic zones:

IV & V, history of floods,

cyclones, other natural

hazards)?

If ‘Yes’, then E&S

risk rating is ‘High’

to ‘Moderate’ based

on zoning

If ‘No’, then E&S


The sensitivities due to natural

hazards have to be factored in the

project design and planning.

7. Any litigation concerning

E&S issues?

If ‘Yes’ then E&S

risk rating is will be

‘High’ or

‘Moderate’ on case

to case basis.

If ‘No’ then E&S


Litigation on E&S aspects should be

checked through web search on the

project or verified from the National

Green Tribunal (NGT) Website6.

Litigations may lead to project delays

and hence, details of the same need to

be sort along with orders if passed by

the Court or the NGT. Depending on

the criticality of the issues and the

court orders passed, the risk rating

would be determined as ‘High’ or

‘Moderate’

A. The Highest of the above risk rating in Q 1 to Q 7 will be used.

8.

What type of compliance

management is included

within the project scope?

The E&S risk

ratings are as

follows:

IEISL shall face higher risks in case of

legislative requirements to be

obtained and monitored for

compliance.

If project requires land purchases

more than limit stipulated by State

Govt., risk rating will be high. If

project requires land acquisition less

than threshold by State Govt. then it

will be rated low.

a) Environmental

Clearance

a) Moderate

b) Coastal Regulation

Zone Clearance

b) High for CRZ I

& IV, Moderate

for CRZ II & III

c) Wildlife Clearance c) High

d) ESZ Clearance d) High

e) Forest Clearance e) High

f) Facilitation for Land

Acquisition f) High

g) Post EC monitoring g) Moderate

h) Consent to Establish/

Consent to Operate

h) Moderate

i) None of the above i) Low

B. Highest of the risk rating in Question 8 will be taken up along with risk rating at Part A to

arrive at the final risk rating based on the risk rating matrix in Table C below.

C. In case of any court case on that project, the rating will be stepped up to high.

Note:

Once the E&S risk rating has been assigned to a project (implementation or finance) in the

planning stage, it may be revisited during construction or operation phase.

The E&S risk rating may be elevated under any of the following conditions:

a) Consecutive defaults on implementation of E&S risk reduction controls

b) Observations coming to light that have a substantial impact on potential E&S risks

and implications thereof.

6http://www.greentribunal.in/


Page 52 of 111

The E&S risk rating may be lowered under any of the following conditions:

a) A review of the project in the operation phase shows that all legal and administrative

requirements on the E&S front have been fulfilled and regular project activities do

not demand close monitoring.

Table C) E&S Risk Rating Matrix (* Applicable Only for Advisory Projects)

Risk Rating based on answers to criteria in Part A

(Q 1 to 7)

High Moderate Low

Par

t B

(Q 8

)

High High High Moderate

Moderate High Moderate Moderate

Low Moderate Low Low

Special Instructions on Risk Rating:

The risk rating worked out by applying the criteria may be elevated in case some project

sensitivity based on nature, scale, location is identified that is not part of the criteria; citing

reasons for the same. Similarly the risk rating may also be lowered.

Page 53 of 111

Annexure B: E&S Risk Reduction and Controls

I. E&S Risk Reduction Controls for Projects at IEISL based on risks identified

(Advisory or Implementation)

7 NABET – National Accreditation Board for Education and Training

# Project Context/ E&S

Risk E&S Risk Reduction Control

1.

Require Environmental

Clearance, Categorized as

Category ‘A’ or ‘B’ under

EIA Notification, 2006

A. If IEISL is responsible for obtaining Environmental

Clearance for the Client/Project

a) Hire environmental consultants with required

NABET7 accreditation for the relevant sector.

b) Include the cost of implementing the EMP in project

costing.

c) Insert special and general conditions applicable

during construction from the Environmental

Clearance for the project in the Contractors

Agreement for implementation.

d) Incorporate the measures given in the EMP for

planning and design stage in the DPR.

e) The project developer/operator shall implement all

measures recommended in the Environmental

Management Plan attached in Schedule (No.) for the

construction/operation phase

f) Ensure implementation of EMP during project

construction and operation and conduct periodic

monitoring for the same.

g) Refer to the E&S Impacts for municipal waste

management projects and hazardous waste

management projects given in this Annexure B

under Section III A & B.

h) Refer to the IL&FS EMP construction manual

prepared for Construction phase to outline

procedure for implementation of mitigation

measures to be included in Construction Contracts.

B. If IEISL is providing advisory services for a project:

a) IEISL could suggest the use of Green guidelines in

the preparation of DPR such as energy efficiency in

buildings; low energy consuming electrical fixtures;

water efficient fixtures; wastewater treatment

facilities, treated wastewater reuse; waste

management, use of indigenous plantation

b) IEISL should communicate to the developer about

referring to the Zoning atlas prepared by the SPCB

for zoning of industries

c) IEISL should ensure that the Environmental

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Clearance conditions for the project applicable to

design are suitably included in the DPR.

2. Project located in CRZ

A. If IEISL is responsible for obtaining CRZ Clearance

for the Client / Project

a) Obtain clearance from MOEF by submitting form

and required information to State Coastal Zone

Management Authority (SCZMA)

b) Implement the recommendations of the MoEF as

applicable during design, construction and

operation of the project.

c) If the project is located in proximity to CRZ I,

incorporate measures during design, implement

measures during construction & operation to

prevent damage to the protected resource.

d) During construction and operation, take measures

to prevent occurrence of prohibited activities in the

CRZ like drawl of ground water, altering sand

dunes/ hills and mining of sand/ rocks.

3.

Project is located within

forest areas and requires

Reserve/ Protected Forest

land

A. If IEISL is responsible for site selection and obtaining

Forest Clearance for the Client / Project

a) For project located in Reserve Forest, identify an

alternative location. Only site specific projects

would receive clearance from the Forest

Department.

b) For projects that have received Stage-I Forest

Clearance, implement all the recommendations to

receive the Stage –II Forest Clearance.

4.

Project Located within or

in 10km proximity to

Protected Areas


Clearance for the Client / Project

a) Obtain approval from National Board for Wildlife if

project is located in proximity to protected areas (10

km from outer boundary termed as eco-sensitive

zone). Follow the conditions put forward by the

Board.

5.


in 10km proximity to Eco-

sensitive Zones



a) Obtain approval from respective Eco-Sensitive Zone

Authority. Follow the conditions put forward by the

Board.

6.


in 10km proximity of

Important Bird Areas



a) Verify from local forest department, if there is any

particularly significant areas (bird nesting areas or

bird flight paths) that need to be taken into

consideration while planning the project.

7. Project is located in tribal A. If the project is located in proximity to tribal areas

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areas/scheduled area or

affects their livelihoods

and IEISL is responsible for facilitation of land

procurement:

a) It should be verified whether their livelihoods are

affected by obtaining land in the particular location

or conduct of project activity through sample

surveys and focus group discussions.

b) A ‘No Objection Certificate’ should be obtained

from Gram Panchayats or any other documentation

as directed by the Tribal Affairs Department or

under the Forest Rights Act.

c) Where project location/ activities have an impact on

tribal lifestyle or livelihoods, a project-specific

Tribal Development Plan should be prepared.

8. Project requires land

acquisition

A. For projects where the Client is providing land or

IEDCL is investing in equity for a project:

a) Check whether provisions of LARR for land

acquisition, consent, compensation, rehabilitation

and resettlement of persons interested have been

complied with and the land is free of encumbrances.

B. Where IEDCL or its SPV where IEDCL has majority/

management control is responsible for land acquisition:

a) Conduct a Social Impact Assessment and prepare

Rehabilitation &Resettlement Schemes/ Plan for the

project as per LARR Act 2013.

b) If the project is located in a place which has a

history of public objection to infrastructure projects,

conduct a social acceptability study for the project.

c) Ensure that compensation, rehabilitation and

resettlement measures have been satisfactorily

implemented as per the entitlement matrix

approved by the appropriate authority.

C. E&S Risk Reduction controls applicable to both

scenarios, ’A’ & ‘B’

a) Setup a grievance redress cell during construction

with the Contractor and during operation at the

Project Implementation Unit (PIU).

9.

Project is located near

ancient monument or

archaeological site


all Clearances for the Client / Project

a) Obtain permit from Archaeological Survey of India

(ASI) or State Department of Archaeology

b) Follow the guidelines of ASI for activities in

proximity to designated sites.

- Prohibited area - 100 meters area around

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surrounding the ASI site wherein no

development, and construction activities

including mining, quarrying, excavation,

blasting are allowed.

- Regulated area - 200 meters

- Buffer Area - 1km beyond core zone boundary

c) In case of a heritage site not designated by ASI,

identify and implement local bye-laws as

applicable.

10.

Project is located in a

hazard prone area

(earthquake, wind,

floods)

Where IEISL is engaged in project development:

a) Elimination of high risk Earthquake, wind &

cyclone and flood prone zones should form part of

site selection criteria.

b) The emergency response plan or disaster

management plan prepared for the project should

include measures to ensure preparedness and

response mechanisms to deal with these natural

hazards.

c) Incorporate design consideration for floods, wind

hazards and earthquakes and in DPR and include

contingency funds for combating such situations.

d) IEISL may evaluate feasibility of constructing wind

barriers on the site.

11.

Litigation filed on the

project on E&S grounds,

show cause notice issued


all Clearances for the Client / Project

a) Identify the subject matter of the litigation and

current status.

b) Follow the directions given by the Court in the

litigation filed.

c) Ensure that the required penalty is paid and

corrective measures are taken to rectify the activity

causing non-compliance to the said regulation.

Achieve the required compliance and report to the

concerned authority to appraise them of the

situation.

12.

Water Stress Index Aqueduct Water Risk tool, WRI: http://bit.ly/1SToFDz

13.

Project involves

Collection and/or

transportation services.

1. IEISL should periodically check the following for

the vehicles:

a) All vehicles have Pollution under Control

Certificates (PUCs)

b) Compliance to Central Motor Vehicles Rules

(CMVR), 1989

c) All drivers have valid driving licenses

d) Renewal of vehicle Fitness Certificates

e) Whether there is any adulteration of fuel

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f) Drivers to be covered in ESI scheme

g) Conduct periodic health inspection of all

drivers

h) Incidents related to vehicular accidents

2. IEISL should ensure that no ground water is

extracted for vehicle workshops

3. IEISL should ensure the use of personal protective

equipment by all drivers

4. IEISL should ensure that all vehicles in operation

should be registered and regularly maintained to

mitigate vehicular emissions and cleaned to avoid

odor while leaving the workshop.

5. IEISL Ensure waste oil is treated as Hazardous

waste, obtain authorization from SPCB and dispose

to authorize recyclers/handlers.

14. Project located close to

sensitive land uses

IEISL should ensure no dumping into adjacent

agricultural and residential areas so that ground water

is not impacted.

15.

Project site located in low

lying areas or flood prone

areas.

1. IEISL should ensure no dumping into adjacent low

lying areas.

2. IEISL should provide for storm water drainage

around the site is a must to ensure the highest flood

levels are taken care of. Also, composting pad area

should be an appropriate level and should have a

protective boundary to avoid spillage into drains

during floods(Considering that it is a flood prone

area)

16. Project located within

200m of a water body.

IEISL should take into consideration the proximity of

the water body and accordingly ensure that that the

leachate and waste does not affect the water bodies.

17.

Project located in a water

scare in water scarce/

drought prone region.

IEISL should obtain NOC from State Ground Water

Board in case of water being abstracted from the ground

18. Existence of rag pickers

around project site.

IEISL should endeavor to employ the existing waste

pickers operating in the area within the project activities

to ensure the project does not affect the existing

livelihood of the waste pickers

Page 58 of 111

II. E&S risk reduction controls based on Project Sector and Role of IEISL in the Project

A. IEISL as Project Developer – Waste Management

1. IEISL should ensure the following;

a. Incident reporting related to Environment, Occupational Health and Safety

b. Implementation of the CTE / CTO Conditions

c. Implementation of Environmental Clearance Conditions

d. Implementation of EHS management plan. The contractor/ concessionaire shall

ensure the implementation EHS measures

e. Monitoring Noise, Air, water quality, groundwater & soil parameters;

f. Use of Personal protective equipment (Gum boots, hand gloves) by all workers

g. Conduct periodic health inspection of all workers

h. Prepare a disaster management plan and an onsite and offsite emergency

preparedness & Response Plan for firefighting and natural hazards.

i. Hire a registered contractor and the workers should be registered with the State

Government during construction.

j. Not use banned chemicals and unbonded asbestos during construction and

operation.

k. Ensure health and safety standards for construction labour and staff at all times

as per Building and Other Construction Workers (Regulation of Employment and

Conditions of Service) Act, 1996 and industry best practice.

l. Harmful or exploitative forms of forced labour or child labour will not be

practiced during construction or operation of the proposed project.

m. Maintain records and file reports for purchase of any ozone depleting substances

for servicing, maintenance of fire extinguishers, transformers, air conditioning.

2. IEISL should obtain and comply with following legal requirements

depending on the project activities;

a. Consent to Establish and Operate from State Pollution Control Board (SPCB)

b. Obtain authorization and compliance as per MSW Rules, 2016/ C & D Waste

Management rules 2016 from SPCB

c. The RDF production facility should comply with conditions of Consent to

Establish, Consent to Operate and Environmental Clearance.

d. The C & D Waste Processing facility should comply with conditions of Consent

to Establish, Consent to Operate, Authorization as per C & D rules 2016 and

Environmental Clearance.

e. Water allocation/approval letter

f. Hazardous Waste handling authorization (waste oil)

g. Approval/license for storage of diesel, lube oil from Chief Controller of

Explosives

h. Approval from SPCB and Chief Inspector of Factories for Chlorine gas and other

chemicals storage and handling (used for maintaining cooling water quality)

i. License from Chief Inspector of Factories

Page 59 of 111

j. Compliance to Central Motor Vehicles Rules, 1989 (Driving License, Vehicle

Registration fitness certificates and PUC)

3. IEISL should ensure the following for waste composting sites;

a. Measures to control manage; treat leachate and runoff from waste storage and

processing areas.

b. Provision of an impermeable base in composting and waste area

c. Provision of storm water drainage around the site is a must to ensure the

highest flood levels are taken care of. Also, composting pad area should be an

appropriate level and should have a protective boundary to avoid spillage into

drains during floods(Considering that it is a flood prone area)

d. Provide for fire-fighting equipment

e. Proper management of waste storage should be undertaken to avoid littering

and clandestine dumping

f. Ensure composting area is demarcated and separated from the main dumping

site area so as to avoid spillage and not affect the composting activities.

g. Measures to mitigate air emissions like dust, bio- aerosols and odors.

h. All vehicles in operation should be registered and regularly maintained to

mitigate vehicular emissions and cleaned to avoid odor while leaving the site.

i. Hazardous sludge storage, handling and disposal take places as per regulations.

j. Measures to reduce odour nuisance to neighboring communities during

dumpsite excavation, composting etc.

B. IEISL providing Advisory Services – Waste Management

a. IEISL should communicate the key legal requirements applicable to the project

during various stages are as follows:

Legal Requirement Project Stage

i. Environmental Clearance Project Development

ii. CRZ Clearance Project Development

iii. Wildlife Clearance Project Development

iv. Land title Project Development

v. MSW Authorization Prior to Operation

vi. Consent to Establish Prior to Construction

vii. Consent to Operate Prior to Operation

viii. Hazardous waste authorization Prior to Operation

ix. License from Chief Inspector of Factories Prior to Operation

b. For projects where IEISL is handling bid process management, incorporate the

following in tender documents:

i. Environmental Management Plan (EMP)

ii. Cost of implementation of EMP, RAP in project cost

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iii. Special and general conditions from the Environmental Clearance, Forest

Clearance, Wildlife board Clearance, CRZ Clearance as applicable and

granted to the project

iv. E&S safeguards of international partners of the project, where applicable

III. Checklist of E&S Risk prevention/mitigation measuresto be planed for

Implementation Projects

A. E&S Impacts to be addressed in Municipal Solid WasteProjects

Process Checklist

1. Collection and

Transport

Adequate number of litter bins and refuse collection services to

prevent littering and clandestine dumping

Appropriate measures to mitigate air emissions like dust, bio-

aerosols, odors, and vehicle emissions

2.

Waste Receipt,

Unloading,

Processing, and

Storage

Adequate measures to prevent migration of leachate into soil,

surface water and groundwater

Measures taken to prevent, minimize, and control litter

Adequate measures to mitigate noise and vibration from truck

traffic, loading equipment (e.g., cranes, wheeled loaders),

stationary compactors, balers, grinders, and other treatment and

conveyance systems

3.

Biological

treatment

(Composting)

Adequate measures to control leachate and runoff from waste

storage and processing areas

Take measures to maintain ideal composting conditions i.e.

carbon: nitrogen (C:N) ratio between 25:1 and 35:1, moisture

content of 50 to 60% of total weight, void space to achieve a 10 to

15% oxygen level, temperature levels rangingbetween 32 and 60 oC, pH between 6 and 8.

Measures to mitigate adverse impacts on ambient air quality due

to direct stack emissions, fugitive emissions and emissions from

burning of biogas. The emissions should meet country and

sponsors standards for ambient air emissions

Appropriate measures to prevent combustion of waste during

aerobic degradation or anaerobic digestion.

4. MSW Incineration

Facilities

Emissions from incinerators should meet country and sponsors

standards

Adequate measures to mitigate adverse impacts on ambient air

quality due to emissions from incinerators

Measures taken to prevent, minimize, and control solid waste

from incineration

Ash and other residuals should be disposed in accordance to

country and sponsors specifications

Flue gas from incineration should be treated and disposed in

accordance to country and sponsors specifications

Appropriate measures to mitigate adverse impacts on ambient

noise levels by exhaust fans, cooling system and turbine

generators

5. Land filling The landfill site should be located in accordance to country and

sponsors specifications

Page 61 of 111

Process Checklist

Adequate measures for collection, treatment and disposal of

leachate from landfill

The quantity of leachate generated should be regularly monitored

A landfill gas collection system should be designed and operated

in accordance with applicable national requirements and sponsors

standards

Adequate measures to prevent, minimize, and control dispersal of

litter

Buffer zone should be maintained around the landfill to alleviate

nuisances

6. Health and Safety

Adequate measures to minimize and mitigate health and safety

hazards to workers from toxic gases and hazardous materials on

site

Measures to protect the public and neighborhood from odor,

smoke from fire, diseases transmitted by flies, rodents, insects and

birds etc

B. E&S Impacts to be addressed in Industrial Hazardous Waste Projects

Process Checklist

1. Collection and

Transport

Measures to prevent spills and releases

National and sponsors standards should be followed for

packaging, labeling, and transport of hazardous materials and

wastes

2.

Waste Receipt,

Unloading,

Processing, and

Storage

The incoming waste should be adequately identified and classified

for storage, treatment and disposal

Adequate measures should be taken to prevent spills and releases

during waste storage and handling

Measures should be taken to prevent and control releases of

particulate matter and VOCs from storage vessels and waste

processing equipment

3.

Biological and

Physico-Chemical

Treatment

The facility should be designed and operated in accordance with

applicable national and sponsors requirements

Adequate measures should be taken to control leachate and runoff

from waste storage and processing areas

The ambient air quality to be adversely affected by direct stack

emissions, fugitive emissions and emissions from burning of

biogas should be adequately mitigated. The emissions should

meet country and sponsors standards for ambient air emissions

4. Incineration

Facilities

Measures should be taken to reduce the generation and emission

of polychlorinated dibenzo-dioxins and - furans (PCDDs and

PCDFs

Ash and other residuals should be disposed in accordance to

country and sponsors specifications

The flue gas from incineration should be treated and disposed in


5. Land filling

The landfill site should be located, designed and operated in


Adequate measures should be taken for collection, treatment and

Page 62 of 111

Process Checklist

disposal of leachate from landfill

The quantity of leachate generated should be regularly monitored

A landfill gas collection system should be designed and operated

in accordance with applicable national requirements and sponsors

standards

6. Health and Safety

Adequate measures to minimize and mitigate health and safety

hazards to workers from toxic gases and hazardous materials on

site

Measures to protect the public and neighborhood from odor,

smoke from fire, diseases transmitted by flies, rodents, insects and

birds etc

Note – ‘Sponsor’ means finance obtained for the project from Multilateral/ Bilateral

Development Banks like World Bank/ Asian Development Bank or finance obtained from

Equator Principle Financing Institutions

C. Reporting Format for Project Site monitoring during Bidding Stage

Task-1:- Preparation of a screening checklist

i. Review all the existing and potential requirements in the environmental, health and

safety (EHS) areas applicable to the project as far as compliance are concerned.

ii. Prepare a screening checklist for the purposes of scoping based on the desk research.

Task-2:– Sensitivity Analysis

i. Conduct sensitivity analysis based on analytical tools to map environmental and social

sensitivity of the said project and in the adjoining areas (to be determined by the type,

scale and location of the project). Should be based on available secondary data and

primary data collected through field visit.

Task-3:– Conduct of site visits

i. Collect information on the environmental settings, locations of the project elements,

present land-use, and environmental components (such as biodiversity, natural

resources, soil, health and safety, etc.) likely to be affected because of the project and

community profile required to prepare EHS Assessment.

Task-4:– Review of legal and other related documentation

i. Identify requirements with State and Central Environmental, Occupational Health &

Safety and Social regulations.

Task-5:– Identify requirements as per IEISL’s ESPF

i. Identify IEISL’s ESPF requirements on screening, risk rating, risk management and

monitoring.

Task-6:– Analysis and Reporting

i. To analyze data/ information accessed during the field studies, interactions and review

for identifying the EHS hazards/ issues.

ii. To determine the risk related to each hazard/ issue.

iii. Incorporate key environmental issues related to the sector

iv. Recommend additional measures, plans and programs required for adequacy and

completeness

v. Identify any further investigations and studies required.

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Site Monitoring Report Table of Content

I. Background

General project Information (Site Location and History)

Regulatory Contacts

II. Environmental Setting and Sensitivity Analysis

Environmental Setting

Spatial understanding of surrounding area

Sensitivity of the area for proposed activities

III. EHS Management Plan review

Solid and Hazardous Waste Management

Water (surface and ground) Pollution Control

Air Pollution Control (Including expected/ modeled SOx, NOx, PM and other

pollutants)

Noise Pollution Control (Including expected/ modeled)

Potential Soil and Ground Water Contamination

Occupational health and safety

Occupant / labour welfare & management activities

Emergency Preparedness and Response

IV. Preparedness for compliance with any national/ international/ sector specific guidelines

Comparison of environmental issues with the guidelines

Comparison of the Health and Safety issues with the guidelines

Compliance/ Requirements as per IEISL’s ESPF

V. Findings and conclusions

EHS hazards/ issues identified and the associated risks

Proposed measures / preparedness to control, reduce and monitor these risks

Compliance statements

Suggestions and recommendations

Corrective Action Plan

Appendices

i. Photographs

ii. Documents collated during survey and field visits related to the site/ its occupants and

or nature of liability

iii. Other external origin reports as collected / referred to by the consultant (say external

communiqué from SPCB/SPCC)

IV. E&S Covenants

1. The following clauses should be inserted into the contract for construction, operation and

maintenance additionally among others, as applicable -

a) The Contractor shall not use banned chemicals and unbonded asbestos during the

course of construction

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b) The Contractor shall implement all measures recommended in the EMP for the

construction phase

c) The Contractor shall implement the special and general conditions stated in the

Environmental Clearance, Forest Clearance granted for the project

d) The Contractor shall comply with all applicable conditions stated in the Consent to

Establish and Consent to Operate from State Pollution Control Board

e) The Contractor shall provide amenities and follow health and safety standards for

construction labour and staff at all times as per Building and Other Construction

Workers (Regulation of Employment and Conditions of Service) Act, 1996 and

industry best practice

f) The Contractor shall not indulge in harmful or exploitative forms of forced8 labor or

child9 labor

g) The Contractor shall furnish to IEISL immediate notice of information on any major

incident or fatality relating to the project and likely to have a highly adverse effect on

the environment or worker health and safety

h) The Contractor shall furnish immediate notice to IEISL in case any show cause notice

or litigation is filed on the Contractor concerning the project.

i) The Contractor shall provide amenities to the labour hired for the project as per

Contract Labour Act 1970 and amendments thereafter.

j) The Project developer/operator shall follow health and safety practices as per the

State Factories Rules during construction and operation.

k) The contractor shall furnish immediate notice to the Client in case of any major

incident/fatality relating to the Project and likely to have a highly adverse effect on

the environment or worker health and safety.

l) The Project developer/operator shall furnish all documentation submitted to

regulatory agencies/State Pollution Control Boards including Environmental

Statements and periodic monitoring reports to the Project Proponent.

8 Forced labor means all work or services not voluntarily performed, that is, extracted from individuals under threat

of force or penalty. http://www.ilo.org/ilolex/english/convdisp1.htm (scroll down for Convention No. 29)

9 Child labor means the employment of children whose age is below the host country’s statutory minimum age of

employment or employment of children in contravention of International Labor Organization Convention No. 138

“Minimum Age Convention” http://www.ilo.org/ilolex/english/convdisp1.htm (scroll down for Convention No. 138)

Page 65 of 111

Annexure C: Environmental and Social Monitoring and Periodicity

A. E&S Risk Monitoring Periodicity Depending on E&S Risk Rating

I.E&S Risk Monitoring Periodicity for Implementation Projects:

Assigned E&S

Risk Rating

Monitoring Periodicity in the Project Cycle

Planning Construction Operation

H

Once in 6 months or as project

documents/ studies are completed,

whichever is lesser

Once in 3 months Once in 3

months

M



whichever is lesser


months

L



whichever is lesser


months

II. E&S Risk Monitoring Periodicity for Advisory Projects:

Assigned E&S

Risk Rating

Monitoring Periodicity in the Project Cycle

Development of Project & Tender

Documentation During PMC

H

Once in 6 months or as project documents/

studies are completed, whichever is lesser Once in 3 months

M Once in 6 months or as project documents/


L Once in 12 months or as project documents/


Based on applicability of periodicity, monitoring in Form II will be conducted in the 15 days

preceding the following prescribed due dates::

Every 3 months: May 31, August 31, November 30 and February 28;

Every 6 months: August 31 and February 28;

Every 12 months: February 28

A major incident or fatality occurring at site during construction or operation will also

trigger incident investigation and reporting from the project facility.

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The monitoring frequency and scope can be revised on the basis of the findings of the above

reviews during the tenure of the project.

Projects that have an E&S risk rating above ‘L’ may be reviewed on a case to case basis for

requirement of third party E&S audits for checking compliance / conformance with various

E&S requirements as included in the covenants in agreements.

B. Revisiting the E&S risk rating during monitoring

Once the E&S risk rating has been assigned to a project (implementation, advisory or finance)

in the planning stage, it may be revisited during construction or operation phase.







requirements on the E&S front have been fulfilled and regular project activities do

not demand close monitoring.

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Annexure D: ESPF Form I - Environmental and Social Risk Assessment

A checklist can be used for advisory projects, instead of form I. The checklist will

determine whether the Form I is required to be completed for the advisory project.

Form I shall be created for internally awarded assignments (P/T/A) as soon as it is

internally assigned to a person responsible for that assignment.

Form I for High risk rated projects is to be sent to CSC for review for both new projects as

well as any revision in the ongoing High risk rated projects

I. Guidance for Revision of ESPF FormI

The conditions under which ESPF Form I needs revision are:

a) Award of project.

b) Change in project manager, project location, components, allied activities and scope

of work, role, establishment of SPV, change of stake which render the existing risk

rating and risk reduction controls inappropriate.

c) Modification/s for closing corporate review or external audit findings.

d) Revision of E&S risk rating.

e) Amendments in legal requirements and introduction of new regulations

II. Guidance for the revision in Format of ESPF Form I

The conditions under which the format of the ESPF form I shall be revised are:

a) Addition or deletionof E & S Sensitivities b) Addition or deletion in Risk assessment criteria c) Change in rules/government acts etc.

(A) - ENVIRONMENTAL AND SOCIAL RISK ASSESSMENT FORMAT – PROJECT

IMPLEMENTATION

Form No: ESPF/IEISL/P/ (No.)

Revision No.: 00 Date: (DD/MM/YY)

Revision No.: 01 Date:



Reason for revision:

A. Project information

Project Title:

Project start date: DD/MM/YY

Date of Bidding:

Date of Award:

Start date of Construction:

Location, State, Country:

Client :

Responsible officer at IEISL:

Period of engagement: (months/years)

Total: _____years

Construction: _____years_____ months

Operation : _____ years_____months

Project Organizational Structure:

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Project Proponent:

Concessionaire:

EPC Contractor:

Short project description: (project scale, type, status/stage, scope, components etc.)

Role of IEISL: (Implementation, Construction, Project Management, Finance)

Mention whether IL&FS / IFIN / or any other IL&FS company is investing?

B. Environmental and Social Assessment

1. Land Acquisition

i. Ownership

ii. Type of land

iii. Status of land acquisition

iv. Dependence of livelihood on land acquired

v. Any other related information

2. Does the responsibility for land acquisition lie with an IL&FS entity?

3. Location Features

i. Coordinates:

ii. Village/Town/City, District, State, Country:

iii. Other locational details (Spatial extent, alignment, area, length, proximity to important

features/ locations etc.)

iv. Please attach a map as annexure or a .kml file of the project

4. E&S Sensitivities

S.N. E&S Sensitivities Details

i. 1 Notified Protected Areas (National Parks/ Wildlife

Sanctuaries, Eco-Sensitive Zones, Biosphere

Reserves, Ramsar Sites, Mangrove forests, etc.)

ii. 2 Important Bird Areas

iii. 3 Coastal Regulation Zone

iv. 4 Scheduled Areas

v. 5 State and/or International borders

vi. 6 Hazard Prone Areas (Floods, earthquakes,

wind/cyclones, etc.)

vii. 7 Critically polluted areas

viii. 8 Landuse (e.g. water bodies, reservoirs, natural

drainage, creeks, agriculture, forests, barren lands,

industries, settlements, fishing villages, etc.)

ix. 9 Archeological Survey of India (ASI) site

x. 1

0

Socio-Cultural- Economic activities

(religious/heritage/ cultural sites, tourist interests,

etc.)

xi. Any litigation concerning E&S issues?

xii. Any other sensitivity w.r.t. project activities, sector

and the location

xiii. Identify the tentative number of

Page 69 of 111

villages/towns where displacement may

be caused through spatial analysis.

xiv. Water stress index

(Ref: Aqueduct Water Risk tool, WRI:

http://bit.ly/1SToFDz)

5. Risk Assessment

S.N. E&S Risk Rating Criteria

Yes/

No/

Risk

Rating

(H/ M/ L)

‘Remarks/Details/

Justification to be given

i. 1

a) Does the project involve Collection

and/or transportation services?

a) Collection (Specify community

bins or door to door collection )

b) Collection and Transportation

c) Only Transportation

d) None of the above

ii. 5

Does the project pose any

environmental pollution, health and

safety risks due to the following

processing activities:

a) Composting

b) Bio-methanation

c) Construction and Demolition

waste

d) Waste to energy (power

generation)

e) Refuse Derived Fuel (producing

RDF)

f) Rubber and plastic waste

g) E-waste

h) Landfilling

i) Dumpsite closure

j) Hazardous waste treatment and

disposal

k) Incineration

l) Common Effluent Treatment

Plant

iii.

Is the project included in the Schedule

of Environmental Impact Assessment

Notification 2006?

(Please specify status of

Environmental Clearance)

a) Category A

b) Category B

iv. 1

0

Does the location, design and/or

operational management of the

project facility take into account the

specifications provided by the MSW

Page 70 of 111

(M&H) Rules, 2016? In case of C & D

waste Processing Plant does the

location, design and/or operational

management of the project facility

take into account the specifications

provided by the C & D waste

Management &Handling rules 2016?

v.

Is the project located in/traverse

through or is in proximity to any eco-

sensitive zone (ESZ) notified by

MoEF?

vi.

Does the project is within or in 10 km

proximity to Protected Areas

(national park, wildlife sanctuary and

biospehere reserves)?

vii.

Is the project located within

protected/reserved forests?

a) >40ha

b) <40ha

c) No

viii.

Is the project site located within or

close to CRZ areas?

a) CRZ I

b) CRZ II

c) CRZ III

d) CRZ IV

e) CRZ for Greater Mumbai

f) Island Protection Zone

ix.

Does the project pass through/ located

in tribal areas/scheduled areas or

affects their livelihoods?

x. 1

1

Does the proposed project or any

associated activity/component invoke

the provisions of LARR10?

xi. Does the proposed project lie in close

proximity to archaeological sites?

xii.

Is the proposed project located in an

area susceptible to natural hazards

(earthquake-seismic zones: IV & V,

history of floods, cyclones, other

natural hazards)?

xiii.

What is the major landuse around

1km radius of project site?

g) Residential/ Commercial

h) Industrial

i) Institutional (Educational/

Medical)

j) Agricultural

10The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Rehabilitation Act

Page 71 of 111

k) Forest

l) Any other (please specify)

xiv. Is the project site located in low lying

areas or flood prone areas?

xv. Is the project site located within 200m

of a water body?

xvi.

Is the project site located in a water

scare in water scarce/ drought prone

regions?

xvii.

Is the project site within an existing

dumping site or other infrastructure

facility (STP/CETP)?

xviii.

Is there any electrical transmission

line or electrical sub-station or gas

pipe lines passing through or adjacent

to project site?

xix.

Does the project involve segregation

of waste within the scope of activities?

a) Manual

b) Automated

xx. Are existing rag pickers integrated

within the project operations?

xxi.

Does the project site have an

environmental, health & safety

management system established and

required human resources to

implement the system?

xxii. Is it ISO 14001 certified?

xxiii. Any litigation concerning E&S issues?

The E&S Risk

Rating

by Project Manager

by IEISL E&S Cell

6. Risk Reduction Controls (RRC)

S.N. RRC Remarks

5a.

Covenants based on

RRC (wherever

applicable)

7. Monitoring Periodicity

i. a At Planning Stage

ii. b At Construction Stage

iii. c At Operation Stage

C. Document Management

Prepared by:

Name:

Project Manager

Date:

Assessed By:

Name:

E& S Coordinator

Date:

Page 72 of 111

Instructions: This form shall be attached to PAM/TAM/AAM (depending on the information known

and required) and copies forwarded by the Project Manager to ESPF coordinator and IL&FS Corporate

ESPF Cell. This form will be maintained by ESPF coordinator.

Page 73 of 111

Advisory projects will require the followingchecklistto be filled, which will

determine whether the Advisory Form I is required to be completed.

Any short term (less than 6 months) advisory project such EIA, DPR etc. is not

within the purview of IEISL’s ESPF policy, these types of advisory activities do

not pose any E & S risks.

Environmental Clearance: If IEISL is consulting on environmental clearance

procedures, but not responsibility for getting EC does not lie on IEISL, then Form I

does not have to be filled.

Preparation of EIA: If simply reviewing EIA, then Form I does not have to be

filled. Form I will be applicable only if IEISL is conducting EIA.

Other projects such as collection of primary data from site and representing a

client at National Green Tribunal hearings will not require the filling of Form I.

Criteria

No.

Questions to be

considered Yes/No Reason/Remarks

1.

What is the type of sector

the project is dealing

with?

a) Municipal Solid

Waste Management

b) Other waste

management (bio-

medical, e-waste,

hazardous waste)

c) Waste to energy

d) Water supply &

wastewater

e) Surface transport &

transport systems

f) Special economic

zones & cluster

development

g) Industries &

industrial parks

h) Building construction

i) Tourism

j) Ports

k) Power & Hydro

Power

l) Any other (please

specify)

2.

What is the type of

advisory service being

provided?

Page 74 of 111

a) Environmental

Impact Assessment

b) Social Impact

Assessment

c) Detailed Project

Report

d) Environment

Improvement Plans

e) Environment

Management

Plans/Master Plans

f) Energy Efficiency

Audits

g) Clean Development

Mechanism


Consultancy

i) Establishing EMS

(ISO & OHSAS)

j) Research, Training &

Awareness

3.

Is the project site located

within or close (0 to 10

km) to E&S sensitive

areas

a) Protected Areas

b) Eco-sensitive Zones

c) Important Bird Areas

d) CRZ Areas

e) ASI Sites

f) Reserved/Protected

Sites

g) Scheduled/Tribal

Areas

h) None of the above

4.

Is the proposed project

located in an area

susceptible to natural

hazards (earthquake –

seismic zones: IV & V,

floods, cyclones, other

natural hazards)

5.

Is the advisory project

included in any of the

categories listed in the

Schedule of EIA

Page 75 of 111

6The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and

Resettlement Act.

Notification, 2006?

a) Category A

b) Category B

6.

Does the proposed

project or any associated

activity/component

invoke the provisions of

the LARR6 act?

7. Is there any litigation

concerning E&S issues?

8.


management is included

in the project scope?

a) Environmental

Clearance

b) Coastal Regulation

Zone Clearance

c) Wildlife Clearance

d) ESZ Clearance

e) Forest Clearance

f) Facilitation for land

acquisition

g) Post EC monitoring

h) Consent to Establish

i) Consent to Operate

j) None of the above

Page 76 of 111

ESPF Form-I

(B) - ENVIRONMENTAL AND SOCIAL RISK ASSESSMENT FORMAT – ADVISORY SERVICES

Form No: ESPF/IEISL/A/(No.)

Revision No.: 00 Date: (DD/MM/YY)




Reason for revision:

A. Advisory Service information

Advisory Service Title:

Start date: DD/MM/YY

Responsible officer at IEISL:

Client :

Short project description (for which Advisory is being provided):

Current Status of the Project:

Scope (in bullet points) of advisory service : (e.g. to project development, technical and financial

close, project management)

Mention whether any other IL&FS company is involved including financing:

B. Environmental and Social Assessment

1. Land Acquisition

i. Ownership

ii. Type of land

iii. Status of land acquisition

iv. Dependence of livelihood on land acquired

v. Any other related information

2. Does the responsibility for land acquisition lie with an IL&FS entity?

3. Location Features

i. Coordinates:

ii. Village/Town/City, District, State, Country:

iii. Other locational details (Spatial extent, alignment, area, length, proximity to important

features/ locations etc.)

iv. Please attach a map as annexure or a .kml file of the project

4. E&S Sensitivities

S.N. E&S Sensitivities Details

i. 1 Notified Protected Areas (National Parks/ Wildlife

Sanctuaries, Eco-Sensitive Zones, Biosphere

Reserves, Ramsar Sites, Mangrove forests, etc.)

ii. 2 Important Bird Areas

iii. 3 Coastal Regulation Zone

Page 77 of 111

iv. 4 Scheduled Areas

v. 5 State and/or International borders

vi. 6 Hazard Prone Areas (Floods, earthquakes,

wind/cyclones, etc.)

vii. 7 Critically polluted areas

viii. 8 Landuse (eg. water bodies, reservoirs, natural

drainage, creeks, agriculture, forests, barren lands,

industries, settlements, fishing villages, etc.)

ix. 9 Archeological Survey of India (ASI) site

x. 1

0

Socio-Cultural- Economic activities

(religious/heritage/ cultural sites, tourist interests,

etc.)

xi. 1

1

Any other sensitivity w.r.t. project activities, sector

and the location

5. Risk Assessment

S.N. E&S Risk Rating Criteria

Yes/

No/

Risk

Rating

(H/ M/ L)

Remarks

i.

Is the project for which advisory

being provided included in the

Schedule of Environmental Impact

Assessment Notification 2006?

a) Category A

b) Category B

c) None of the above

ii.

What is the type of sector the project

is dealing with?

a) Municipal Solid Waste

Management

b) Any other waste management

(Hazardous Waste, biomedical,

e-waste)

c) Waste to Energy

d) Water Supply and Waste water

e) Surface Transport and

Transportation Systems

f) Special Economic Zones &

Cluster Development

g) Industries and Industrial parks

h) Building Construction

i) Tourism

j) Ports

k) Power and Hydro Power

l) Any other (Please Specify)

iii. 1

What is the type of advisory service

being provided?

a) Environmental Impact

Assessment

b) Social Impact Assessment

c) Detailed Project Report

Page 78 of 111

d) Environment Improvement

Plans

e) Environment Management

Plans/ Master Plans

f) Energy Efficiency Audits

g) Clean Development Mechanism


Consultancy

i) Establishing Environmental

Management System (OHSAS

and ISO)

j) Research, Training and

Awareness

iv. 3

7

Is the project site located within or

close proximity (0-10km) to E&S

Sensitive areas?

a) Protected areas

b) Eco-Sensitive Zones

c) Important Bird Areas

d) CRZ areas

e) ASI Sites

f) Reserved /Protected Forests

g) Scheduled / Tribal Areas

h) None of the above

v.

Does the proposed project cause

displacement of project affected

people/ families?

vi.

Is the proposed project located in an

area susceptible to natural hazards

(earthquake-seismic zones: IV & V,

history of floods, cyclones, other

natural hazards)?

vii. 8 Any litigation concerning E&S

issues?

viii.


management is included within the

project scope?

a) Environmental Clearance

b) Coastal Regulation Zone

Clearance

c) Wildlife Clearance

d) ESZ Clearance

e) Forest Clearance

f) Facilitation for Land Acquisition

g) Post EC monitoring

h) Consent to Establish/ Consent to

Operate

i) None of the above

The E&S

Risk Rating

by Project Manager

by IEISL E&S Cell

Page 79 of 111

6. Risk Reduction Controls (RRC)

S.N. RRC Remarks

5 a.

Covenants based on

RRC (wherever

applicable)

7. Monitoring Periodicity

i. Development of

Project and Tender

documentation

ii. During PMC

C. Document Management

Prepared by:

Name:

Project Manager

Date:

Assessed By:

Name:

E& S Coordinator

Date:

Instructions: This form shall be attached to PAM/TAM/AAM (depending on the information known

and required) and copies forwarded by the Project Manager to ESPF coordinator and IL&FS Corporate

ESPF Cell. This form will be maintained by ESPF coordinator.

Page 80 of 111

Annexure E: ESPF Form II - Environmental and Social Action Planning and

Monitoring

ESPF Form II shall be used to carry out monitoring of ongoing projects. The format shall

be filled within an excel sheet and then updated within the same excel sheet as per

required periodicity. The sheet be split into two parts within the same form:

a) Action plan on implementation of RRCs.

b) Monitoring

Form II excel file shall include all RRCs identified in Form I.

(Risk Reduction Controls)RRCs that are closed will continue to exist on the excel file with

comment for ‘closed/ completed’ as applicable with reference to supporting

documentation, if any.

I. Guidance for Elevation or Lowering of E&S Risk Rating during Monitoring

Once the E&S risk rating has been assigned to a project (implementation or finance) in the

planning stage, it may be revisited during construction or operation phase.



b) Observations coming to light that have a substantial impact on potential E&S risks and

implications thereof.

c) "Risk rating will become 'High' for any P/T/A that becomes sub judicial on E&S aspects"



requirements on the E&S front have been fulfilled and regular project activities do not

demand close monitoring.

II. Guidance for Revision of ESPF Form II

The conditions under which ESPF Form II needs revision are:

a) Change in project context leading to revision in risk reduction controls in ESPF Form I.

b) Modification/s for closing corporate review or external audit findings.

c) Amendments in legal requirements and introduction of new regulations.

d) Existing format of Form II shall be used in electronic form only. For every monitoring

cycle, three relevant columns will be added without creating a new file for each form.

Page 81 of 111

Environmental and Social Risks Action Planning and Monitoring

Title: Revision

No.

Scheduled date of

monitoring:

No. ESPF/Company/(P/T/A)/No. Risk Rating Date of Actual

Monitoring

Progress of Project

ACTION PLAN MONITORING

Sr.

No. Risk Reduction Controls

Actions to be taken

for implementation of

RRCs

Primary

Responsibility

Time Line

(Project

Cycle)

Status

RRCs/Actions

Corrective

Actions (if

pending)

Remarks

Monitored by:

(Project Manager)

Reviewed by:

(E&S Coordinator)

This section will be added as additional

columns to the right as per the monitoring

Page 82 of 111

Annexure F: Guidance Procedure for E&S Risk Assessment of a Project in ESPF

Form I

I. Study Project Information

Study the nature, scale and location of the project along with the scope of IEISL’s services

including environmental and social responsibilities. Details on period of project engagement,

organizational structure. The point of entry of IEISL into the project should also be noted.

Further details such as involvement of any group IL&FS group companies and

investment/stake of IEISL in the project and other IL&FS companies.

Fill the above information in the various fields given under Section A: Project Information of

the ESPF Form I.

II. Undertake Environmental and Social Sensitivities Assessment

A. Land Acquisition

Note details on land acquisition aspects to include;

(i) Land ownership,

(ii) Type of land (Such as waste land or fertile land, etc.),

(iii) Status of land acquisition (Complete or partially complete no not initiated, number of

families affected/displacement,

(iv) Dependence of livelihood on land acquired

B. Location Specifics

Note further details on location features of the project such as;

(i) Coordinates,

(ii) Village, district, State, Country

(iii) Locational details ( Spatial extent, area, length, alignment, proximity to features)

(iv) A reference map needs to be attached as an image or as a .kml file.

C. E&S Sensitivities

Conduct a spatial analysis through desk review using freeware tools like Google Earth or

Wikimapia to study the project location and it surrounding area.

Identify and note the following E&S Sensitivities in ESPF Form I;

Project located outside India - For the sensitivities listed below check the aspects on the

website of Ministry of Environment or its equivalent; check for regulations regarding EIA/

CRZ/ tribals/ forests

Projects located in India – check the sources of information given for each aspect

Sensitivities Source of Information

1. Notified Protected Areas

(National Parks/ Wildlife

Sanctuaries, Eco-Sensitive

Zones, Biosphere Reserves,

Ramsar Sites, etc.)

Notified Protected areas can be accessed from the

websites :

http://www.kolkatabirds.com/sanctuaries.htm

http://envfor.nic.in/downloads/public-

information/protected-area-network.pdf

http://www.kolkatabirds.com/sanctuaries.htm

http://envfor.nic.in/downloads/public-information/protected-area-network.pdf

http://envfor.nic.in/downloads/public-information/protected-area-network.pdf

Page 83 of 111

http://envfor.nic.in/division/environment-protection

http://moef.nic.in/division/ramsar-convention-

wetland?theme=moef

http://www.moef.nic.in/sites/default/files/Notificatio

n%20for%20Wetland%20Rules.pdf

2. Important Bird Sites

Important bird sites can be found from the book

entitled “Important Bird Areas in India: Priority sites

for conservation” by BNHS. It can be downloaded

from the link: http://ibcn.in/?page_id=593

3. Coastal Regulation Zone

Coastal Regulation Zone guidelines can be accessed

from http://envfor.nic.in/rules-regulations/crz-

notifications

4. Scheduled Areas or Tribal

Areas

Scheduled areas can be found at

http://tribal.nic.in/Content/StatewiseListofScheduleA

reasProfiles.aspx

Tribal areas can be found at

http://tribal.nic.in/Content/TribalAreasProfiles.aspx

5. State and/or International

borders Check project overlay on State Map

6. Hazard Prone Areas (Floods,

earthquakes, wind/cyclones,

landslides)

Hazard prone areas maps have been prepared and

published as “Vulnerability Atlas of India” by

Building Materials & Technology Promotion Council

and lower scale maps can be accessed from;

Hazard prone areas maps have been prepared and

published as “Vulnerability Atlas of India” by

Building Materials & Technology Promotion Council

and lower scale maps can be accessed from;

(i)Floods:

http://www.bmtpc.org/DataFiles/CMS/file/map%20o

f%20india/flood.pdf

(ii)Earthquakes:

http://www.bmtpc.org/DataFiles/CMS/file/map%20of

%20india/eq-india.pdf

(iii)Wind & cyclones:

http://www.bmtpc.org/DataFiles/CMS/file/map%20of

%20india/wind-india.pdf

(iv)Landslides:

http://www.bmtpc.org/topics.aspx?mid=56&Mid1=18

6

7. Critically polluted areas

CPA sites can be accessed from:

: http://cpcb.nic.in/technical_ess.php or

http://cpcb.nic.in/divisionsofheadoffice/ess/NewItem

_152_Final-Book_2.pdf

8. Landuse Landuse can be studied from Google earth or

Wikimapia

9. Ancient Monuments and (i) World Heritage Sites

http://envfor.nic.in/division/environment-protection

http://moef.nic.in/division/ramsar-convention-wetland?theme=moef

http://moef.nic.in/division/ramsar-convention-wetland?theme=moef

http://www.moef.nic.in/sites/default/files/Notification%20for%20Wetland%20Rules.pdf

http://www.moef.nic.in/sites/default/files/Notification%20for%20Wetland%20Rules.pdf

http://ibcn.in/?page_id=593

http://envfor.nic.in/rules-regulations/crz-notifications

http://envfor.nic.in/rules-regulations/crz-notifications

http://tribal.nic.in/Content/StatewiseListofScheduleAreasProfiles.aspx

http://tribal.nic.in/Content/StatewiseListofScheduleAreasProfiles.aspx

http://www.bmtpc.org/DataFiles/CMS/file/map%20of%20india/flood.pdf

http://www.bmtpc.org/DataFiles/CMS/file/map%20of%20india/flood.pdf

http://www.bmtpc.org/DataFiles/CMS/file/map%20of%20india/eq-india.pdf

http://www.bmtpc.org/DataFiles/CMS/file/map%20of%20india/eq-india.pdf

http://www.bmtpc.org/DataFiles/CMS/file/map%20of%20india/wind-india.pdf

http://www.bmtpc.org/DataFiles/CMS/file/map%20of%20india/wind-india.pdf



http://cpcb.nic.in/technical_ess.php

http://cpcb.nic.in/divisionsofheadoffice/ess/NewItem_152_Final-Book_2.pdf

http://cpcb.nic.in/divisionsofheadoffice/ess/NewItem_152_Final-Book_2.pdf

Page 84 of 111

Archaeological sites http://asi.nic.in/asi_monu_whs.asp

(ii) List of Protected Monuments

http://asi.nic.in/asi_protected_monu_list.asp (State

Level)

http://asi.nic.in/asi_monu_alphalist.asp (National)

(iii) Excavations http://asi.nic.in/asi_excavations.asp

10. Socio-Cultural- Economic

activities (religious/heritage/

cultural sites, tourist interests,

etc.)

Census and web search

11. Any litigations concerning

E&S issues

National Green Tribunal website

http://www.greentribunal.in/ and google search on

client and project site.

12. Water stress index Aqueduct Water Risk tool, WRI:

http://bit.ly/1SToFDz

13. Any other sensitivity w.r.t

project activities, sector and

the location

Identify as applicable such as proximity to mines etc

14. Identify the tentative number

of villages/towns where

displacement may be caused

through spatial analysis.

Use Geo Database or Google Earth or Wikimapia

15. Bhuvan is software

application which allows users

to explore a 2D/3D

representation of the surface of

the Earth. The browser is

specifically tailored to view

India, offering the highest

resolution in this region and

providing content in four local

languages

http://bhuvan.nrsc.gov.in/gis/thematic/index.php

16. Many of the development

challenges and solutions

require professionals to

visualize data in a spatial

perspective. World Bank

Group is presenting a new

paradigm for easy and

intuitive access to

development data—

highlighting public-domain

online data services from

sources around the world

https://olc.worldbank.org/about-olc/spatial-agent-

world-data-your-fingertips

The items can also be identified using the web-based Geodatabase created for the purpose. The project

http://asi.nic.in/asi_monu_whs.asp

http://asi.nic.in/asi_protected_monu_list.asp

http://asi.nic.in/asi_monu_alphalist.asp

http://asi.nic.in/asi_excavations.asp


Page 85 of 111

has to be created in the system using its latitude and longitude and various attributes linked to the

location is populated in a report format.11

The above links are applicable only to projects located in India. A similar process should be

used for projects located outside India.

III. Assigning an E&S Risk Rating to the project based on the designed criteria

Derive the risk rating for the project using the criteria given in IEISL’s ESPF manual

Annexure A.

The criteria may refer to location in CRZ, EIA Notification or other regulations. Refer to these

regulations while answering the queries and identifying the risk rating.

Use the information identified through the above sources on E&S sensitivities to answer

questions determining the E&S risk rating.

Refer to the combination criteria specified at the end of the list of individual criteria while

deriving the risk rating.

The risk rating worked out by applying the criteria may be elevated in case some project sensitivity

based on nature, scale, location is identified that is not part of the criteria; siting reasons for the same.

Similarly the risk rating may also be lowered.

IV. Identifying risk reduction controls and applying procedures

For each risk identified for a proposed project, identify risk reduction controls given in

Annexure B.

Identify sector specific E&S risks and management measures by referring to additional

sources such as EIA Sectoral Manuals12by MoEF; IFC EHS Sector Guidelines13; Environmental

and Social Risk briefings by UNEP FI14

Where risk reduction controls require implementation by contractors, include those as

covenants in contractual agreements.

Identify the significant impacts that should be avoided/ tracked/mitigated during project

design, construction and operation.

Procedures:

1. Refer the IL&FS EMP Manual for Construction to identify procedures for implementation

of environmental management measures at site. The procedures could be communicated

to Contractors.

2. Use the IL&FS EHSS legal checklist to identify details of regulations applicable to the

project located in India.

V. Identifying Covenants to be inserted in Contractual Agreements

11 The web-based geo-database has been prepared with access currently limited to the IL&FS Corporate E&S cell. 12 EIA sectoral guidance manuals can be accessed at http://environmentclearance.nic.in/ ,

http://environmentclearance.nic.in/writereaddata/Form-

1A/HomeLinks/ommodel2.html&http://environmentclearance.nic.in/writereaddata/Form-1A/HomeLinks/ommodel3.html 13IFC EHS Sector Guidelines can be accessed at

http://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/IFC+Sustainability/Sustainability+Framewor

k/Environmental,+Health,+and+Safety+Guidelines/ 14Environmental and Social Risk briefings by UNEP FI can be accessed at http://www.unepfi.org/signatories/toolkit/

http://164.100.194.5:8081/ssdn1/jspfiles/doc/ommodel3.html

http://moef.nic.in/manuals.htm

http://www.ifc.org/ifcext/sustainability.nsf/Content/EHSGuidelines

http://www.unepfi.org/signatories/toolkit/


http://environmentclearance.nic.in/

http://environmentclearance.nic.in/writereaddata/Form-1A/HomeLinks/ommodel2.html



http://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/IFC+Sustainability/Sustainability+Framework/Environmental,+Health,+and+Safety+Guidelines/

http://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/IFC+Sustainability/Sustainability+Framework/Environmental,+Health,+and+Safety+Guidelines/


Page 86 of 111

Specify the covenants identified that should be inserted in various contractual agreements.

Refer to Annexure B for a general set of covenants.

The covenants should be referred to the company legal department before insertion to contractual

agreements.

VI. Monitoring Periodicity

Specify the monitoring periodicity in the field assigned in ESPF Form I based on E&S risk

rating derived for the project.

I. The monitoring periodicity for Implementation Projects :

a) ‘High’ risk projects during planning phase is 6 months or as project documents are prepared,

construction phase is 3 months, and operation phase is 3 months;

b) ‘Moderate’ risk projects during planning phase is 6 months or as project documents are prepared,

construction and operation phase is 6 months;

c) ‘Low’ risk projects is 12 months or as project documents/ studies are completed, whichever is

lesser

II. The Monitoring Periodicity for Advisory Projects:

a) ‘High’ risk projects during Development of Project and Tender Documentation period is 6 months

or as project documents are prepared & during PMC Phase is 3 months;

b) ‘Moderate’ risk projects during Development of Project and Tender Documentation period is 6

months or as project documents are prepared,& during PMC Phase is 6 months;

c) ‘Low’ risk projects is 12 months or as project documents/ studies are completed, whichever is

lesser

Page 87 of 111

Annexure G: Procedure for Monitoring a project in ESPF Form II

I. Tasks to be carried out immediately after completing project assessment in ESPF Form I

1. List the risk reduction controls specified in ESPF Form I as separate rows in Column 2

of ESPF Form II (in the same excel sheet, using MS excel format for monitoring after

February 2014).

2. Specify the following for each operational control:

a. Mode of Execution: actions to be taken for implementing the risk reduction

controls (e.g. email communication to client; checklist of NABET accredited EIA

consultants, insertion in contractors agreement, terms of reference, etc)

b. name of the person primarily responsible for implementing the risk reduction

control

c. timeline with respect to the project cycle i.e. development/ construction/

operation, where the specified risk reduction control will be applicable

II. Tasks to be carried out during Monitoring of the Project as per the periodicity

1. Obtain a status on the stage of project at the time of monitoring and state the same in

the space provided in the form.

2. Identify risk reduction controls listed in ESPF Form II applicable at that stage and the

previous stages.

3. Identify whether the risk reduction control has been executed based on the stage of

the project.

4. If the risk reduction control has been executed, write ‘Executed’ in the status field.

5. If the risk reduction control has not been executed, inquire about the cause and list it

in the Remarks column.

6. Identify the corrective action/ next steps required for execution of pending risk

reduction control, where applicable. Identify new risk reduction controls for the

same, and add them in the ESPF Form II.

7. During monitoring, check whether any new risks are posed in the project which were

not identified in ESPF Form I. Identify risk reduction controls for the new risks in

ESPF Form II and add them as a separate row in the form. Mention the date of adding

the RRC above it. Prepare an action plan for the RRC (as explained in sub-section I of

this Annexure) and check its status of implementation during the next monitoring

cycle.

8. While monitoring a project for the second or third time and during all subsequent

instances based on the periodicity, check whether the corrective actions and new risk

reduction controls that were recommended during previous monitoring have been

executed.

9. Check whether the E&S risk rating needs to be elevated or lowered.

10. During the course of the project, if any particular RRC becomes ‘not applicable’ due

to change in scope or any other reason, the same should be stated in the ‘Remarks’

column. Such RRCs need not be monitored during subsequent monitoring cycles.

Page 88 of 111

11. In case any risk reduction control has been modified/ revised based on monitoring or

corporate review findings/ observations, the modified RRC should be added as a

separate row in ESPF Form II. The new RRC should be referred to in the remarks of

the old RRC found not applicable. Prepare an action plan for the RRC (as explained in

sub-section I of this Annexure) and check its status of implementation during the

next monitoring cycle.

III. Guidance for Elevation or Lowering of E&S Risk Rating during Monitoring

1. Once the E&S risk rating has been assigned to a project (implementation or finance) in

the planning stage, it may be revisited during construction or operation phase.

2. The E&S risk rating may be elevated under any of the following conditions:




3. The E&S risk rating may be lowered under any of the following conditions:

a) A review of the project in the operation phase shows that all legal and

administrative requirements on the E&S front have been fulfilled and regular

project activities do not demand close monitoring.

4. "Risk rating will become 'High' for any P/T/A that becomes sub judicial on E&S

aspects"

Page 89 of 111

Annexure H: Scope of Corporate Review

High Moderate Low

PROJECTS

Form I should be sent

to CSC for review.

100% Corporate

Review with Site Visits

at least once a year

Corporate Review

of 100% cases

twice a year

Corporate Review

of 25% cases

selected at

random twice a

year

TRANSACTIONS

Corporate Review of

100% cases once a

year - 50% cases at

every Corporate

Review

Corporate Review

of 25% cases

selected at

random twice a

year

Corporate Review

of 25% cases

selected at

random twice a

year

ADVISORY

Corporate Review of


random once a year

Corporate Review

of 25% cases

selected at

random once a

year

Only reported in

quarterly Master

List updates. Not

monitored by CSC

I. Office-Based Review

1. The ‘Corporate Review’, will be conducted by the Corporate Sustainability Cell

(CSC). The corporate review report shall be presented to the Risk committee.

2. Review of IEISL ESPF to assess whether design of ESPF is well mapped, relevant and

beneficial to the business canvas of the company

3. Assessment of ESPF coordinators of IEISL on their awareness of E&S issues relevant

to their business. For example, answers to questions on understanding of the

company ESPF document and its application will be reviewed

4. Interview with key project managers to check their awareness and knowledge of

application of ESPF related to their function. For example answers to questions about

business canvas, E&S concerns, mapping between the two and how ESPF system

addresses to safeguard risk will be reviewed

5. Random sampling of ongoing and new projects at IEISL and checking of documents /

records as evidence where ESPF has been applied and E&S risk reduction controls

implemented

6. Review of requirements with respect to previous reviews/audits is fulfilled; namely,

implementation of prescribed corrective / preventive actions which arise as a result of

non-conformances with the ESPF requirements brought to light during the review/

audit.

Page 90 of 111

II. Site-Based Review

1. All projects with a ‘High’ risk rating shall undergo a Site Review.

2. Site visits shall review E&S compliance documentation, safety aspects, emergency

preparedness and status of E&S issues that were faced by projects in the vicinity.

3. Reconnaissance visit of the project and its associated facilities.

4. Review of documents on national environmental and social regulations; and

evidences of implementation of conditions.

5. Review of documents on environmental, health and safety (EHS) systems at site.

6. Interviews on a random sample basis with workers at site, safety stewards, site

supervisors (contractors) to assess their awareness on EHS procedures and practices.

7. Inspection of EHS procedures and practices at site.

8. Site Reviews will not be conducted after the project site is certified for ISO & OHSAS

certificates. However if some litigation with respect to the site occurs the site review

shall be re-continued.

Page 91 of 111

Annexure I: ESPF Form III - Findings of Corporate Review

ESPF Form III: Corporate Review Format

Company Name: Date:

S.

No. Observations/ Findings

Category

Finding or

Observation

Application

of

Observations/

Findings

Root

Cause

Analysis

Corrective

Action

Planned

with time

schedule

Responsibility

Action Taken

Status of

Observation/

Finding

If

Pending,

provide

reason Action Date Status Date

1

2

3

4

5

6

IL&FS Corporate Sustainability Cell Corporate Reviewer: Company E&S Coordinator/s:

Signature: Signature:

Page 92 of 111

Annexure J: ESPF Form IV - Format for Training Record

Company Name:

Venue: Date:

Time Topic (with annotation) Trainer

# List of Participants Signature

S.No. Summary of Feedback Received Action Taken

Page 93 of 111

Annexure K: ESPF Form V - Master Database on Status Implementation of ESPF

1. Risk Assessment and Monitoring

Project ID Project/Transactio

n Title

Name of the

Counterpart/

Client/Partner/Inv

estee

Company scope in the

project (Project/Transation/Advi

sory)

Total Project

Investment Size (in

Mn)

Group Company's Investment

Size (in RsMn) (IEISL

Equity in Project)

Project Manager

Location Bid

Date

Date of E&S Risk Assessme

nt in ESPF

Form I

E&S Risk

Rating

(Current)

Stage of Project

Revision(s) in ESPF Form I

Monitoring

Periodicity

(months)

Award Date

Monitoring Date(s)

Cognizable Safety Events (in nos.) (NA for Advisory)

N/A for Advisory

Other

Remarks ("Live"/

"on- Hold

")

Date Rev No

Revised Risk Rating if any with date

Scheduled

Actual Date

Major

Incidents

Fatalities

Specify Affected

Party (workers/ employees

/public)

Litigation

pertaining

to E & S

issues

Incident of

Social

Unrest

Page 94 of 111

2. Training

Date Location Topics Trainer(s) No. of Participants Business

Vertical

3. Corporate Review

Date Location Reviewer(s) No. of Findings No. of Observations

No. of Findings

/ Observations

Closed before

next Review

No. of Findings

/ Observations

Pending before

next Review System Implementation System Implementation

Page 95 of 111

4. External Audit

Date Location

No. of Observations No. of Findings /

Observations

Closed before

next Review

No. of Findings /

Observations

Pending before

next Review System Implementation

Page 96 of 111

Annexure L: ESPF Form IIA - Monthly Monitoring from Project Site during Construction

ESPF Form IIA - Monthly Reporting from Project Site during Construction

Project Title: Project ID:

Project Site Manager: Date of Monitoring:

# Category # Item Yes

()

No

()

Specific details of when conducted/

reasons why not conducted

1. Regulatory

Requirements 1. Does the project site have all valid clearances/ approvals / permits/ licenses

including those to be obtained by the EPC Contractor?

2. Are the conditions specified in clearances/ approvals / permits being

complied with at site?

3. Have any show cause notices been issued by regulatory authorities for non-

conformance to host country/ local regulations?

2. Environment 4. Are appropriate measures taken to reduce fugitive dust emissions?

5. Is the ambient air quality at site monitored as per host country regulations?

6. Is the noise level at site periodically monitored as per host country

regulations?

7. Have corrective measures been taken to reduce the noise levels at site?

8. Are all wastes generated at site being safely disposed and in conformance

to host country/ local regulations (like construction spoil, excess excavated

material, waste oil, oil soaked cotton etc)?

9. Do the diesel generator sets deployed at site have noise enclosures and

appropriate stack height as per host country regulations?

10. Has the diesel generator sets stack emission been monitored periodically?

Page 97 of 111


()

No

()



11. Are measures being implemented to optimize water consumption during

construction?

3. Occupational

Health and

Safety

12. Is the labour camp provided with amenities like ventilated living spaces;

drinking water; sanitation facilities; fuel for cooking/ common cooking

facility/canteen; waste collection and disposal system; crèche (if female

workers employed); and medical facility?

13. Are all construction equipments and vehicles deployed at site regularly

inspected for proper working condition of all safety devices (like reversing

horn, backlights etc)?

14. Have any major incidents or fatalities occurred at site requiring absence of

work for more than days specified in host country regulations?

15. Has incident investigation been conducted and necessary actions taken to

prevent such incidents?

16. Is a work permit system in operation at site for carrying out hot works,

work at height and work in confined spaces?

17. Are all the construction equipment/ vehicles operators trained for defensive

driving and have appropriate heavy vehicle driving license?

18. Do all construction equipments deployed at site have valid fitness

certificates?

19. Are all workers at site provided personnel protective equipments

appropriate to their job?

20. Are all workers trained in use of safe practices to prevent/reduce incidents

w.r.t. their job work?

Page 98 of 111


()

No

()



4. Emergency

preparedness

and Response

21. Have measures been taken to deploy necessary infrastructure (like fire

extinguishers based on nature of fire, ambulance etc) to handle emergencies

(manmade and natural)?

22. Have the workers and supervisors at site been trained to handle various

emergencies (like fire, natural hazards like cyclone etc) at site?

23. Are mock drills conducted at site to test the functioning of the emergency

response plan?

5. Public Health

and Safety 24. Have any grievances been lodged by the neighboring community due to

ongoing construction activities?

25. Is the traffic on roads adjacent to the site affected due to project

construction managed appropriately to avoid jams, accidents and

inconvenience to other commuters?

6. Institutional

Capacity 26. Is a team on EHS deployed at site adequate in number with defined roles

and responsibilities, competent commensurate to the nature of work?

27. Have health & safety supervisors been deployed at site?

28. Have the workers and supervisors at site been trained to handle various

emergencies (like fire, natural hazards like cyclone etc) at site?

Name:

Signature:

Date:

Page 99 of 111

Annexure M: ESPF Form IIIA - Format for Project Site Review Report

ESPF Form IIIA - Project Site Review Report

IL&FS Company: Project Title:

Project ID: Date of Review: E&S Risk Rating:

Business Vertical: Project Site Manager: Reviewer:

A. Name & Designation of Persons Interviewed:

B. The following list of legal documents were reviewed and found to be in order:

C. The following list of system documents were reviewed and found to be in order:

D. The following EHSS measures implementation were reviewed and found to be in order:

E. Findings/ Observations Corrective and Preventive Action Plan

a) In Legal Documents Corrective & Preventive Actions

Recommended

Responsibility Planned

Timeline

Action Taken Date of

Closing

b) In System Documents Corrective & Preventive Actions

Recommended


Timeline


Closing

c) In Implementation of

EHSS Measures

Corrective & Preventive Actions

Recommended


Timeline


Closing

F. Recommendation on elevation/ lowering/ maintaining E&S Risk Rating:

Page 100 of 111

Annexure O: Former Revision Page

#

Section /

Clause

Revised

Re

v.

no

.

Revision



1 Page 33 03 31.08.2016





Changes as suggested in Corporate review findings dated 19-01-2016

1 Page 11, in

Figure 1, 03 08.03.2016 SPV name ‘DDSIL’ added

2 Page 22, VA(I) 03 08.03.2016 Corporate sustainability cell replaced with E&S Cell

3 Page 22 V B

(c) 03 08.03.2016 Conduct replaced with facilitate or Assist

4 Page 23 V C(l),

and V D (k) 03 08.03.2016

Status of E&S compliance of all ongoing project shall be

submitted on quarterly basis to CSC as and when required

- point is not applicable and to be removed

5 Page 25, Fig 3 03 08.03.2016 Institutional Structure- Internal Review replaced with

Corporate review

6 Page28,

Figure 5 03 08.03.2016

Project Cycle Mapping with ESPF – Sole Sourced (Project

Implementation) to be modified - Step 1 for Form-1

generation should be prior/at the time of BAM

7 Page 33, VI (D 03 08.03.2016 Points (a) to (f) in section deleted

8 Page no. 48,

Annexure A 03 08.03.2016

Environmental and Social Risk Rating; Table C) E&S Risk

matrix for Advisory Project is not inline with criteria

specified in table B and modified as per risk rating criteria

specified

9 Page 58 &59 ,

Para C 03 08.03.2016

Reporting format for Project site monitoring to be

modified as format for Project site monitoring during

bidding stage and Audit Report table of Content to be

Page 101 of 111


1 Page 33 03 31.08.2016





replaced with Site Monitoring Report Table of Content

10

Page 61,

Annexure C

03 08.03.2016

clause/table for E&S Risk Monitoring Periodicity for

Advisory projects ( i) Development of Project and Tender

Documentation ; (ii) during PMC ) is added/modified

11 Page 75 ( I ),

Page 83 (III) : 03 08.03.2016

Clause added "Risk rating will become 'High' for any P/T/A

that becomes sub judicial on E&S aspects"

12 Page 81

section VI 03 08.03.2016

Monitoring periodicity to be modified for advisory projects

( development and PMC period)

13 Page no. 95,

Annexure N 03 08.03.2016 Not applicable and hence deleted

14

Page 33

Section VI (E)-

2

03 05.05.2016 Text modified to bring clarity on Corporate Review

15 Annexure K :

Page 90 03 05.05.2016

Risk Assessment and Monitoring:

Previous column titled “Investment size” replaced with

two columns: one column on “Total Project/Investment

Size (Rs. Mn)” and another on “Group Company’s

Investment size (Rs. Mn)”

Additional columns added: “Litigation pertaining to

E&S issues”, “Incident of Social Unrest” - Column on

“Remarks” re-worded: “Other Remarks ('Live'/ 'On

Hold')

16

Annexure F:

Page 81

03 05.05.2016 Environmental Sensitivities and Sources of Information for

India: added for Water stress index

17

Annexure D

Form I: page

64

03 05.05.2016

ESPF Form I - Environmental and Social Risk Assessment for

Projects:

Within E&S Sensitivities section, point xiv. added:Water

stress index

Within Risk Assessment section, ‘Remarks’ column re-

labeled to ‘Remarks/ Details/ Justification to be given’

Changes as suggested in Corporate review findings in 2015

Page 102 of 111


1 Page 33 03 31.08.2016





1

Section V:

Institutional

Arrangement-

C: Role of

IEISL E & S

Cell

03 23-06-2015

Point (q) inserted:-ESPF form-I has to be finalized by ESPF

coordinator.

Point (j)- Nomenclature for documents changed to –

‘Final Form X short project name Date.abc’

Point (k,i,o)-

2

“Figure 6-

Project Cycle

Mapping with

ESPF-

Advisory

Services

03 23-06-2015 MD Approval Inserted

3

Annexure C:

A: E&S Risk

Monitoring

Periodicity

Depending on

E&S Risk

Rating

03 23-06-2015

A column added for periodicity, prescribed due date for

monitoring in Form II

4 Annexure D:

Form I 03 23-06-2015

Few Additional points added for CSC review of High Risk

Projects

5 Annexure E:

Form II 03 23-06-2015 Few Additional points added regarding RRC in Form II

6

Annexure K:

Form V

Master

Database

03 23-06-2015

Risk Assessment and Monitoring column updates:

▫Investment size

▫Revised Risk Rating, if any. With date (under revisions)

Page 103 of 111


1 Page 33 03 31.08.2016





7

Operationaliz

ation of ESPF

at IEISL:

Section D

03 23-06-2015

(iii) Section D: Title changed to Training and Awareness

Generation (iv) Few Points inserted

8

Operationaliz

ation of ESPF

at IEISL:

Section E


9

Document

Control:

Section B


10

Annexure H:

Scope of

Corporate

Review

03 23-06-2015 Inserted scope of review matrix

#

Section /

Clause

Revised

Re

v.

no

.

Revision


Revisions carried out to incorporate suggestions received during ESPF coordinators’

workshop conducted on 24th June, 2014

1. Overall

document 01 07-07-14 Corporate E&S Cell changed to ‘Corporate Sustainability Cell’

2. Figure 4 & 5 01 07-07-14 Bid submission flowchart modified for implementation and

advisory projects

3. Section V C.

h), i), j), l), o) 01 07-07-14

ESPF coordinator’s responsibilities added to ‘Role of IEISL

E&S Cell’

4. Section V D.

(l) 01 07-07-14 Responsibility of project manager regarding projects on hold

5. Section VI B.

(7) 02 07-07-14 Added points to be included in TAM

6. Section VI D. 01 07-07-14 Specified that CSC will conduct a maximum of 2 full day

training sessions at IEISL

7. Section VI E. 01 07-07-14

Mentioned that CSC will conduct the ‘Corporate Review’ and

EMC will conduct only 1 internal review. The external review

will be conducted by a third party e.g. EY or Deloitte

8. Section VII A. 01 07-07-14

Added point on maintenance of ESPF forms. Final version of

all forms to be maintained and signed by ESPF coordinator.

Each form to be saved as: Final Form X short project name

date.abc

Page 104 of 111

#

Section /

Clause

Revised

Re

v.

no

.

Revision


9. Section VII B. 01 07-07-14 ESPF coordinator to maintain master list & send it to CSC

through CEO in first fortnight of every quarter.

10. Annexure A 03 07-07-14 Addition of few points and modification in risk rating criteria

11. Annexure O 01 07-07-14 Annexure O was removed

12 Section II B

(a) 01 20 – 02 -15

Inclusion of Advisory related Risks (Financial and

Reputational) in accordance with Corporate Review dated 20

– 02 -15

13 Section V(D) 02 20 – 02 -15

Inclusion of Description of ‘On-hold’ and ‘Closed’ projects

and Measures of Communication in accordance with

Corporate Review dated 20 – 02 -15

14 Section VI A

(g) 01 20 – 02 -15

Inclusion of clause regarding filling of Form I for Preparation

of DPRs

15 Section VI B

fig 4 and fig 5 02 20 – 02 -15

Updating Project Cycle Mapping in accordance with

Corporate Review dated 20 – 02 -15, i.e. inclusion of ESPF

Monitoring during Construction Stage and Revision of Form I

during Operation

16

Annexure D:

ESPF Form I

(5)

01 20 – 02 -15 Replacement of ‘ by Project Manager’ and ‘by IEISL E&S Cell’

17

Annexure K:

ESPF Form V

01 20 – 02 -15 Replacement of Master Database into new format as per

IL&FS ESPF Document (Vol II)

18

Annexure D:

Advisory

Projects

Checklist

01 20-02-2015

Inclusion of projects that do not require completion of Form I

depending on IEISL Responsibility and removal of E&S

Column

19

Annexure E:

Environmenta

l and Social

Planning

Form II

03 20-02-2015 Outlining procedure for updating of Form II within the same

excel sheet

20

Annexure G:

Environmenta

l and Social

Planning

Form II

03 20-02-2015 Outlining procedure for updating of Form II within the same

excel sheet

ESPF Document Revision No.: ESPF/IEISL/Rev/2013/01

# Section

Revised

Rev.

No.

Rev.

Date

Brief description of revision and reason for change

1. Section III A 01 13-02-13 Inserted date of approval of E&S Policy by IEISL

Board

2. Section III C

(vi)

01 13-02-13 Changed word ‘habitat’ to ‘condition’ as once project is

implemented restoring natural habitat is practically

not possible and attempt to restore natural condition

is possible

Page 105 of 111

# Section

Revised

Rev.

No.

Rev.

Date


3. Entire

Document

01 13-02-13 Reworded ‘Risk Prevention and Controls’ to ‘Risk

Reduction Controls’ as the controls specified for

projects are mainly reducing risks rather than

preventing

4. Section IV A

(d)

01 13-02-13 Revised the application of Exclusion List based on

discussion with IL&FS Top Management

5. Section IV B 01 13-02-13 (c) Inserted explanation on ‘Risk in ESPF’ to enhance

clarity

(d) Inserted specific reference to risk rating criteria for

project implementation and advisory services to

enhance clarity

(e) Inserted statement on dynamic nature of risk

rating as per operational experience

6. Section IV C

(b)

01 13-02-13 Inserted method of identifying risk reduction controls

as is being practiced in companies

7. Section V B

& D

01 13-02-13 Inserted ‘Role of Corporate Sustainability Cell and Project

Manager’ to bring clarity on the roles played by these

in implementation of ESPF in response to Internal

Review finding in another group company

8. Section VI

A&B of Rev

00

01 13-02-13 Deleted sections on ‘Dovetailing of ESPF in Business

Processes of IEISL’ and ‘Integration Mechanism’ as these

were found to be repeated in the sub-sections that

followed

9. Figure 4, 5&

6

01 13-02-13 Revised the ESPF Integration in the workflow based

on operational experience

10. Section VI A

(d & e)

01 13-02-13 Inserted justification for excluding GIS and CDM

services from application of ESPF based on Internal

Review observation September 2012 and operational

experience

11. Section VI B

(h)

01 13-02-13 Inserted explanation on monitoring of risk reduction

controls to improve clarity of procedure. Also

inserted trigger for monitoring in case of major

incident or fatality based on Internal Review finding

in another group company

12. Section VI B

(i)

01 13-02-13 Inserted reference to guidance procedures for risk

assessment and monitoring given in the annexures

which was generated as a tool for project managers

13. Section VI C

(g & h)

01 13-02-13 Inserted instructions for preparing action plan and

monitoring of advisory services in ESPF Form II to

complete the procedure

14. Section VI D

(b)

01 13-02-13 Inserted para on applicability of ESPF to projects

awarded to IEISL after board approval based on

external audit comments in March 2012 for another

group company

15. Section VI F 01 13-02-13 Inserted Section on ‘Internal Review and External

Audit’ based on revisions carried out in other group

companies

16. Section VII 01 13-02-13 Inserted Section on ‘Information Management’ to

Page 106 of 111

# Section

Revised

Rev.

No.

Rev.

Date


A and Table

1

streamline documentation and records

17. Section VII

B (a)

01 13-02-13 Inserted the process of presenting internal review and

external audit findings to top management based on

revisions carried out in other group companies

18. Section VII

B (c & d)

01 13-02-13 Inserted statements defining line of authority and

frequency for updating ESPF documents based on

external audit comments in March 2012 for other

group companies

19. Annexure A 01 13-02-13 Revised the application of Exclusion List based on

discussion with IL&FS Top Management

Note 3 – inserted exception for projects involving

transportation of hazwaste within India based on

discussion during ESPF Corporate Training in

September 2012

20. Annexure B 01 13-02-13 Revised footnote in item 3 on Protected Areas as

‘Refer to websites of respective State Forest

Department for list of wildlife sanctuaries and

national parks’. The urls of the websites that were

given are not in use now

21. Annexure A 01 13-02-13 Revised the E&S risk rating criteria for

implementation projects and advisory services based

on feedback received during training conducted in

January 2013 and operational experience

22. Annexure B 01 13-02-13 Deleted Section I (Rev 00) based on revisions carried

out across other group companies to improve clarity

on implementation of risk reduction controls

Deleted Section II A (Rev 00) as the risk reduction

controls were found to be not applicable to advisory

services

Section II Inserted E&S Covenants based on

operational experience

Section III – Inserted introduction to the list of E&S

studies to improve clarity on application

23. Annexure C 01 13-02-13 Inserted trigger for monitoring in case of major

incident or fatality based on Internal Review finding

in another group company

24. Annexure D 01 13-02-13 Revised the ESPF Form I based on operational

experience

25. Annexure G 01 13-02-13 Inserted fields for Corrective Actions required and

Additional Operational controls in ESPF Form III

required to capture the changes during subsequent

monitoring. Also inserted field on ‘Current Status’ to

enable review at later stages

26. Annexure H 01 13-02-13 Inserted ‘Procedure for Assessment of a Project in ESPF

Form I’ as a guidance to Project Managers

27. Annexure I 01 13-02-13 Inserted ‘Procedure for Monitoring a Project in ESPF

Form II’ as a guidance to Project Managers

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28. Annexure J 01 13-02-13 Inserted format for training records in response to

Internal Review observation in another group

company

29. Annexure L 01 13-02-13 Replaced the format which recorded individual

findings and observations with a tabular format that

records all observations and findings to enable ease of

maintaining records ate the Company

(Signature of IEISL E&S Coordinator)

Name:

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Revisions carried out to incorporate External Audit March 2013 observations, Internal

Review February 2013 findings and overall ESPF system modifications

1. Overall

Document 01 26-07-13

IL&FS Corporate E&S Cell to IL&FS Corporate

Sustainability Cell due to change in title

2. Overall


Change in Annexure numbers due to deletion of Annexure

containing Exclusion & Referral list and addition of new

formats.

3. Overall


Deletion of Exclusion List form ESPF

All P/T/As taken up by IL&FS and its companies are activities

that are as such within the national legal jurisdiction. The

exclusion list is indicative of the value based choice exercised

by IL&FS, beyond the legally allowed activities. Based on the

application of ESPF in these companies over the last few

years, it has been observed that the items under Exclusion list

have rarely been encountered in the P/T/As assessed. Hence

the Exclusion List has been deleted from the framework.

4. Overall


Deletion of Referral List from ESPF

This list had been designed on the assumption that most of

the ESPF application will primarily be carried out at the

company level and only select few involving E&S sensitive

issues / business implications will be escalated to IL&FS

Corporate for advice and direction. However over the past

few years, the referral list is not being operated in practice, as

IL&FS Corporate is conducting the entire assessment. The

practice of referral list will be discontinued till such a capacity

is built in companies of IL&FS. However, the elements of the

list have been considered in the E&S risk rating criteria of the

companies. Hence, the Referral List has been currently

deleted.

5. Section III

D, 3 (a) 02 12-07-13 Deleted reference to Exclusion and Referral List

6. Figure 2 01 12-07-13 Modified to accommodate deletion of the ‘Screening’ step

which included Exclusion and Referral List

7. Section IV

A 01 12-07-13

Deleted ‘Screening’ step which included Exclusion and

Referral List

8. Figure 3 01 26-07-13

Revised the Institutional Structure to include role of SPV and

teams within the Company based on external audit

observations

9. Section V

A (4,5,6,7) 01 26-07-13

Inserted brief description of various entities in the

institutional structure such as SPVs, project managers due to

revision in institutional structure for ESPF implementation

10. Section V B 02 26-07-13

(b) – Deleted ‘Advise IEISL regarding E&S risks and risk

reduction controls for projects where E&S Referral List is triggered’

due to deletion of Referral List

(g) – Inserted function ‘Obtain monthly/periodic review of ESPF

implementation’ based on revision in institutional structure

11. Section V

C

01

12-07-13

Deleted function of IEISL E&S Cell ‘Explain IEISL’s ESPF to

clients whenever required ; Engage E&S specialists as required;

Prepare covenants related to environmental and social safeguards

Page 109 of 111

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00

26-07-13

requirements’ as these are functions to be implemented by the

respective Project Managers

Inserted functions based on revision in institutional functions

and new formats introduced–

(g) Prepare a Master database on the status of

implementation of ESPF captured in ESPF Form V attached as

Annexure L

(h)All activities related to ESPF shall be communicated to

IL&FS Corporate Sustainability Cell

(j)Submit a status on E&S compliance for IEISL ongoing

projects as provided by the Project Managers on a quarterly

basis (refer Annexure O for the format) to IL&FS Corporate

Sustainability Cell

12. Section V

D 02 26-07-13

Inserted additional functions of the Project manager based on

revision on institutional functions for ESPF –

(a) Inform IEISL’s ESPF to clients/partners whenever required

(e) Prepare covenants to reduce environmental and social

risks

(f) Engage E&S specialists as required

(k)Submit an undertaking on E&S compliance for their

projects on a quarterly basis (refer Annexure N for the format)

to IEISL E&S Cell

13. Section VI

B 02 26-07-13

Revision in operational procedure to include specific actions

during bidding, award & design, construction and operation

phase specific for project implementation and advisory

services (scope based specific steps mentioned) based on

Internal review observation and comments received from

Corporate Sustainability Cell

Deleted VI C- Operational procedures for advisory

mentioned in Sec VI B as the ESPF steps are similar.

14. Figure 4, 5

& 6 02 26-07-13

Revised integration of ESPF in business cycle based on

revision in operational procedure and understanding of

business work flows

15. Section VI

E (5-7) 02 12-07-13

Inserted requirement on site reviews as part of internal

review based on Corporate Sustainability Cell direction.

Insert scope of external audit.

16. Section VII

A Table 1 02 26-07-13

Deleted reference to Exclusion and Referral List

Inserted reference to Form IIA, Form IIIA, Form IV, Form V

based on insertion of new formats in the operational

procedure

17. Annexure

A 02 15-07-13

Revision in E&S risk rating criteria to bring more objectivity

based on internal review observations and overall review of

Company ESPF documents across companies

18. Annexure

B 02 15-07-13

Deleted list of E&S studies as they were found to be not

utilized in the last three years

Revision of E&S risk reduction controls –

Item I, II, II - addition and modification of risk reduction

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controls based on operational experience and new risk rating

criteria.

19. Annexure

D 02 12-07-13

Revision in ESPF Form I based on operational experience and

overall review of Company ESPF documents across

companies

20. Annexure

E 02 12-07-13

Revision in ESPF Form II based on operational experience and

overall review of Company ESPF documents across

companies

Insertion of guidance for revision of Form II and revision of

E&S risk rating based on observation by Corporate Cell

during External Audit March 2013

21. Annexure

F 02 12-07-13

Revision in Guidance procedure for filling ESPF Form I owing

to revision in operational procedure

22. Annexure

G 02 12-07-13

Insertion of guidance for revision of E&S risk rating based on

observation by Corporate Cell during External Audit March

2013

23. Annexure

H 00 12-07-13

Insertion in scope of internal review to include site review

and reference to additional forms to be filled.

24. Annexure I 02 12-07-13 Revision of ESPF Form III for internal revoew based on

operational experience

25. Annexure

K 00 28-07-13

Inserted Master database format being used by companies as

a system format based on operational experience and overall

review of Company ESPF documents across companies

26. Annexure

L 00 12-07-13

Inserted ESPF Form II A for reporting from project site during

construction as part of revision of operational procedure

27. Annexure

M 00 12-07-13

Inserted ESPF Form IIIA - Format for Project Site Review

Report to be generated by reviewers during internal review of

ESPF in the Company based on Corporate Cell direction

28. Annexure

N 00 26-07-13

Inserted format for E&S Compliance certificate from Project

Manager to Company E&S Cell based on Corporate Cell

direction

29. Annexure

O 00 26-07-13

Inserted format for E&S Compliance status from Company

E&S Cell to Corporate Sustainability Cell based on latter’s

direction


Name:

Page 111 of 111

Revisions carried out to incorporate suggestions received during training conducted on 16 th

January, 2014 and Internal Review on 30th January 2014

No.

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1 Overall

document

0

1 10-03-14

Reference to Land Acquisition Act 1894 and NRRP (2007)

deleted and replaced with Right to Fair Compensation and

Transparency in Land Acquisition, Rehabilitation and

Resettlement Act, 2013

2 Annexure

A

0

3 10-02-14

Rewording and Revision in E&S risk rating criteria based on

training workshop suggestions and legal changes and

addition of a risk rating matrix table for further clarity.

3 Annexure

B

0

3 10-02-14

Revision in E&S risk reduction control based on legal

changes

4 Annexure

E

0

3 10-03-14

Changes in columns for implementation of Risk reduction

control limited to column on mode of execution based on

internal review suggestion

5 Annexure

F

0

2 10-03-14

Update in Guidance procedure for filling ESPF Form I on

reference links

6 Annexure

G

0

1 10-03-14 Modification of guidance for filling ESPF Form II.

7 Annexure

H

0

1 10-03-14

Insertion in scope of internal review to include site review

and reference to additional forms to be filled.


Name: