Environmental and Social Due Diligence Report

Project Number: 47083-004 December 2019

INDIA: Accelerating Infrastructure Investment

Facility in India – Tranche 3 Mytrah Vayu (Krishna) Private Limited (Part 10 of 10)

Prepared by India Infrastructure Finance Company Limited for the India Infrastructure Finance

Company Limited and the Asian Development Bank.

This environmental and social due diligence report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Satrple description D.idkiry Wrr.r Colhct d.t Vii.ypu.r CE6t Hoot.

Our RefNo TC5064 I 8000003980

Tesr \letbod Uniis Test Resul(sS.No Ch..rcarristic

27 IS:1025 Pan37 1988, RA-2001 ,J:,dL <0 0l 0 0l28 Zinc as Zn lS 3025 Pan 49 1994 fi94L <0 00t 5, 1529 ISr 1025 Pan 24 2006 ,I.EJL .000t

.10 - t00t0 Copper as Cu IS 302J Pan 42 1992

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ll Nickel as Ni IS lo25 Part 54 2003 n].s/L .:0.001 3.0- 5 032 Boron IS 3025 Pan 57 2005 Il:,E/L 0 065 I0033 lS 11428 Amex K mdL { 00t 02034 MineralOil APHA 23'd Edition 2012 n,c,JL <0 00t 0 0l35. Aluminiumas Al IS 1025 Pan 55 2003 ms/L <0.00t 00116. IS 3025 Pan 48 1994 ,il,ell- <0.0002 00037 Pesticides USEPA !s,lL <000t r0.00t3li. IS:5402 :2012 CFU/mL

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AD€drlnce of he Sunplc Color Liquid SlmDle condition of r6rinc |ound otSlrplc collectror date (J6 lr)t8 SamplcQun!uy I ltr

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S.No 'I esr Mrrhod tirits lS:2296 Chss C

I pH ar25 dcg C lS:1025 pan I I 1983 RA-2012 l{ 44 65 852 lS:]025 Pan4 lr8l RA 2m6 100

l Cordu.tivity at 25 dcs C lS:1025 Pafl 141984 RA-2011

I IS:102s Panl8 1989 RA-2u01 "c 26.2

Turbidity IS 1015 Pnn l0 1984 RA-7m? NTU ll.rDssolved Oxysc! IS:1025 PanlS 1989 RA-2001 Dg'L {lChemical Oryacn D.l@d IS:3025 Pan 58 2006 n/L 8{}

8 Total SusDendcd Solids IS: 3025 Pan I7 1984 RA-2012 t9 2Tolal Dissolved Solids IS: 302 5 Pan 16 I 984 RA-2006 t5ql

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Total Hardncr !s C!COr lS:1025Pal212009 n0tl Chloddc as Cl Is. ]0:5 Pan12 1988, RA-2009 m,f L

lS:10:5 Pan 60 2008 m!r[ 051 t5I.l Sulphrlc as SOi lSr J025 Pan 24 I986.RA'2003 614l5 Alknlinty IS:1025 Part 21 1986. RA'2001 ll0

IS:1025 Pan 341988. RA-2003 2.4

t1 Cva dcsls CN IS:3025 Pan 27 1986, RA-2009 <0.001 0.05

ll{ IS:1025 Pan 40 1991. PrA-21)1)) t24

lS: 3025 Pan46 1994, RA-2C03 ngLMP/Ll0 Sodium rc Na IS: 302 5 Pa.t 45 1993, RA-2{D9

212t IS: 3025 Pan45 1993 RA-2009

IS:3025 Pan 53 2001, RA-2003 mgL 012 50

2) IS 3025 Part 47 1994 mgL <{t.001 0.1

IS l0?5 Parl 42 I 992 ms/L 0 02ll 1.514 Capcr as Cu

IS:3025 Pan 17 1988. RA-2003 ngl- <0.02 0.225

mgL <0.{t0l16 Phcnolics as (;HtOH APHA 2ld Edidon5330D

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FSSAI, NABET{CI,lS0 9001 :2015 & oHSAS 18001 :2007.

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Issued to:M!'trrh Vry! (Kri!or) PrivIe Limited.# 80O I , Q-City, S. No: I 09, Na.akarEud4 GachibowliHlderabsd- 50O 032, India.

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Your RefDate 26_1O.2018

Sarnplc description Mode ofPackins

Appearance of lhe Sarple Clear Lquid Sarple coodition of lesting Found OkSarple collection daie 06.l1.2018 S.rple Qua iry I ltr$nple Collection Tirne l:10 pn Anallsis sraniDa date 08. t I 20t8SanDle Registration date 08.1I 2018 Amllsis Conpletion date 12 I I 20t8Satrple collect4 by VISON LABS

s.\o (hrrrcrerisric Tesr l\lethod l:nits T€sl Results

I pH ar 25oC IS:1025 pan I I 1983 RA-2012 8.02 6.5 -1(.52. Turbidny IS:1025 Pan l0 1984 RA,2lXl2 NTU <1.0 5-t03. Conducrivily at 2 Joc IS:3025 Pan 14 1984 R1-2013 60:l4 Tolol Suspcnded Solids ISi3025 Parl l7 l9li4 RA-2012 <t.05 Total D6solvcd Solids IS:3025 Pari 16 lr84 RA-201)(, nr.ylL :l l4 500-2000

LS:3025 Pan 4 l9Bl RA-2fl)6 <05

IS:3025 pan oli l9E4 RA-21n2

8 Odor lS:1025 $n 05 1983

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t2 Nirrares as No, IS:1025 Pan 34 l98li. RA-2{xJl In'I,/L 1.0 40 - 100

l3 Phosphates a5 PO. IS:3025 Pan ll 1988. P!4-2m3 n]ctL 0.0:8

l4 Toial Ilardness a5 CaCOr IS:1025 Pan2l 2009 N?JL 80 200 600

l5 Calciumas Ca IS:1025 Pan 40 ltrl. RA-2lxL M,&/L t0 15 2(nl6 Magn.sium as Mg lS:3025 Pafi 46 l9X. RA-2lnl n,PJL '1.2 t0 100

t1 Sodium as Na lS:1025 Pan 15 1993. RA-20'$) m,vL 975l8 Porassium as K lS:1025 Pan 45 1993. RA-2m9 ms/L 231g Fluondes as F- IS:3025 Pdn 60 2008 n,qq- o74 t- 1.5

20 IS:3025 Pan 53 2001. RA-2m3 ms/L o_24 0.1-t2t Phenolic Compounds APHA 23d Ednion 5ll0D ms,/L <0.001 0.00t - 0.002

22 Cvanide as CN' IS 1025 Prn 2? 19,16 n,c,lL <0.ool 0 005

23. Residual Chlorine as Cl- IS 3025 Pan 26 1986 ms/L <0.00r 0.2

IS 3025 P'n 4l 1992 miy'L <0.001 0.0124 Cadmium as Cd

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Vrsox LensEnvironmental Consultants & Analyrical Services

Recognised by lSo/lEC 17025:2005 (NABL), itoEF t CC,

FSSAI, IIABET{CI, lS0 9001 :2015 & oHSAS 18001 : 2007.

TEST RIS(]LTSPHYSICAL PARAMETERS

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H .No. 1 6, Flat No. 205, 2nd Floor, opp R Otlice, Musaram bagh, Malakpet, Hyderabad

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27 IS:3025 PartlT 1988, RA-2(nl mc/L <0 0l 0.01

2a_ Z.tnc d5 7.n IS 3025 Pan 49 1994 0 098 5 - l529 Manlanese as Mfl IS: 3025 Pan 24 2006 m,r/L <0.00r 30 - 100l0 Copper as Cu lS 1025 Parl 42 1992 ms,L 0.120 0.05 - 1.5ll Nrkel as Ni lS 3025 Pan 54 2001 T'PIL <0 00t 3.0 - 5.032 Boron IS 3025 Pan 57 2t)05 m.slL 0.052 t00ll IS 11428 Annex K mP/L <0.001 020

Mineral Oil APHA 23'n Edition 2012 mql, <0.001 00tAluminium as Al IS 3025 Pan 55 2ool mc/L <o oot 001

36 Mercury as Ha IS 1025 Psn 48 1994 mP,/L <0.0002 00031 USEPA t\tlL <0.00 t <0.00l18. lS:5402:2012 CFU/mL

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Relognised by ISoIEC 17025:2005 (ilABL), MoEF E CC,

tSSAl, NABET{CI,lS0 9001 :20.|5E oHSAS 18001 :2007.

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H.No. 16-11'23/37lA, Flat No. 205, 2nd Floor' Opp- R.T A. Otlice, Musarambagh' Malakpet' Hyderabad - 500 036'

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35

GOVERNMENT OF ANDHRA PRADESH

ABSTRACT Lands – Kurnool District – Lease of Govt. land totaling an extent Ac. . cts., ie., an extent of Ac. . cts. in Sy.No. to of Racherla village, Peapully Mandal, and an extent of Ac. . cents in Sy.No. etc. of Kunukuntla village, Owk Mandal in favour of NREDCAP for establishment of Wind Power Project, for a period of Years, duly collecting lease rent basing on the market value @ , /- per acre, as per the norms issued in GO. Ms. No. , Rev Assn.) Dept., dt. . . . The NREDCAP in turn will allot the land to the third party as per the existing norms of Energy Department on lease basis and monitor the utilization of land- Orders – )ssued. ------------------------------------------------------------------------------------------------------------ Revenue (Assignment .V) Department

GO. Ms. No. 511 Dated: 27-09-2013

Read the following; Ref : . G.O.Ms.No. . Rev Assn ) Department, dated. . . . . From the Collector, Kurnool Lr. No. E / / , dated . . . . From the Collector, Kurnool Lr. No. E / / , dated . . . From the Spl.CS & CCLA., AP. (yderabad Lr. No. BB / / , dt. . . . -: :- ORDER

)n the references nd & rd read above, the District Collector, Kurnool has submitted proposals for allotment of Government lands in Racherla village of Peapully Mandal, and Kunukuntla village of Owk Mandal on lease basis for the period of years in favour of M/s. Mytrah Wind Developers Private Limited, (yderabad for establishment of Wind Power Project. The details of lands are as follows : Sl. No. Name of the Village Name of the Mandal Extent Ac. Cts. Sy.Nos Racherla Peapully . Sy.Nos. - each Ac. . cts. . Kunukuntla Owk . Sy.Nos. , - , - , and - each Ac. . cts. Sy. No. Ac. . cts , Sy.No. Ac. . cts Sy.No. Ac. . cts 2. The District Collector, Kurnool has reported that the proposed lands are situated on the edge of hill top and covered with rocks and bushes. The lands are unfit for cultivation. There are no permanent structures on the proposed lands. A notices have been published in the villages and no objection were received within stipulated time. The Joint Collector has inspected the proposed lands along with concerned officials and reported that the proposed lands are table land on the hill and suitable for establishment of Wind power project. The lands under proposal are not covered by the prohibitive provisions for assignment etc., under Acts and Rules. With regard to fixation of market value, the District Collector, Kurnool has reported that taking into consideration of the nature of the lands i.e, (ill rock and unfit for cultivation , he has proposed the Market value at Rs. , /- Rupees fifty thousand only per acre. contd. P.

:: ::

3. )n the reference th read above, the Special Chief Secretary & Chief Commissioner of Land Administration, AP. (yderabad has reported that, the Energy Dept., has submitted the vetting/justification report in the prescribed check list and recommended to allot the land to an extent of Ac. . cts. on lease basis jointly to the NREDCAP and M/s. Mytrah Wind Developers Private Limited, for developing the Wind Power Project. (e has also informed that as per their departmental norms and MNRE guidelines one hectare of land Acs. . cts. is required for one MW Turbine. The requirement of the applicant for development of . MW is Acs . which is less than norms. . x . = Acs. . cts. is actual requirement . . The Special Chief Secretary & Chief Commissioner of Land Administration, AP. (yderabad has further reported that proposals were placed before the A.P Land Management Authority Meeting held on - - , the APLMA has examined the proposal and after detailed deliberations, the Authority has “recommended to

Government for alienation of Government land on lease basis in favour of NREDCAP. The

NREDCAP in turn will allot the land to the third party as per the Energy Department

existing norms on lease basis and monitor the utilization of land”. The Special Chief Secretary & Chief Commissioner of Land Administration, AP. (yderabad has finally requested the Government to take appropriate action in the matter.

5. )n the circumstance reported by the District Collector, Kurnool/ the Special Chief Secretary and Chief Commissioner of Land Administration, (yderabad, and as recommended by the APLMA, the Government after careful examination of the matter hereby direct that the Government land to an extent of Ac. . cts., i.e., an extent of Ac. . cts. in Sy.No. to each Ac. . cts of Racherla village, Peapully Mandal and an extent of Ac. . cents in Sy.No. , - , - , and - each Ac. . cts. , Sy. No. Ac. . cts , Sy.No. Ac. . cts Sy.No. Ac. . cts of Kunukuntla village, Owk Mandal, Kurnool District be alienated on lease basis, for a period of Years, duly collecting lease rent basing on the market value @ . /- per acre, as per the norms issued in GO. MS. No. , Rev Assn.) Dept., dt. . . , in favour of NREDCAP. for establishment of Wind Power Project, the NREDCAP in turn will allot the land to the third party as per the existing norms of Energy Department on lease basis and monitor the utilization of land.

6. The Special Chief Secretary & Chief Commissioner of Land Administration, AP. (yderabad and the Collector, Kurnool District shall take necessary action accordingly. BY ORDER AND )N T(E NAME OF T(E GOVERNOR OF AND(RA PRADES( B.R. MEENA PR)NC)PAL SECRETARY TO GOVERNMENT To The Collector, Kurnool District. The Special Chief Secretary & Chief Commissioner of Land Administration, AP. (yderabad, The VC&MD., NREDCAP., Nampally, (yderabad. Copy to: The GA Cabinet Department, w.r.t. their CR.No. / , dt. . . . The Energy Department. The P.S. to Principal Secretary to CM. The P.S.to Minister Revenue . The P.S. to Principal Secretary Revenue . Sf/Sc. //FORWARDED :: BY ORDER // SECT)ON OFF)CER

Page 1 of 2

Photoplate I : Site Visit Photographs

Mytrah Vayu (Krishna) Private Limited (MVKPL)

Safety Signage at MVKPL First Aid Box at Site

Tips for Handling Emergency on Display Onsite Emergency Plan on Display

Hazardous Waste Storage Waste Storage at Site

Page 2 of 2

Substation Emergency Plan on Display Switchyard

Fire Extinguisher Ball at substation Switchyard

Display Boards at Hazardous Waste Storage Waste Storage Containers

Page 1 of 7

Reply to the ADB’s Observations on ESDDR of Mytrah Vayu Krishna Pvt Ltd (MVKPL)

S.No. Observations from ADB IIFCL Reply to Observations Updated ESDDR reference

1. We note that the sub-project under

consideration comprises of 118 wind

turbine generators spread

over nine villages in Bijapur District

that was commissioned in April 2014

(almost 5 years back). The sub-project

was implemented by MVKPL not in

anticipation of finance from ADB. The

ESDDR has confirmed that no

environmental impact assessment

study was undertaken for this sub-

project. As a result, there is every

likelihood that MVKPL might not

have followed ADB’s environmental safeguards related requirements during

construction and operation &

maintenance stages.

MVKPL engaged a consulting firm to

undertake a due diligence in 2016

from environmental (and social)

safeguards related considerations of

multi-lateral development banks

(MDB) such as ADB. The ESDDR

was submitted by a team of

consultants in July 2016 (about 2.67

years back) to MVKPL. The

consultants carried out review of

associated documents made available

Updation of the ESDDR prepared by third party

consultant is under preparation. Information related

to corrective measures implementation has already

been shared by the developer. Status of

implementation of the corrective measures

identified in the ESDDR will be reported in the

updated ESDDR.

It is noted that the updated ESDDR will be signed

by IIFCL staff.

Status of implementation of the corrective

measures identified in the ESDDR (July 2016)

are reported in Table 5 & 6 of the updated

ESDDR.

ESDDR is signed by IIFCL staff.

Page 2 of 7

by MVKPL and undertook a field visit

during 30 May – 2 June 2016 for

assessment of implementation of

environmental safeguards. This team

held consultations with villagers and

other stakeholders. Based on its

review, the ESDDR had identified

certain gaps in the implementation vis-

à-vis the requirements of the MDBs

and India’s environmental regulations; and recommended corrective measures

(tables 5.1 and 6.3).

The ESDDR submitted to ADB by

IIFCL is not signed by the IIFCL

officials (signed by the team of

consultants engaged by MVKPL).

IIFCL is requested to follow the

practice of endorsing the ESDDRs as

has been done in the past.

Further, given that this ESDDR was

prepared in July 2016, IIFCL is

requested to provide an updated

version of the ESDDR as on date that

would also include the status of

implementation of the corrective

measures identified in the ESDDR

(dated July 2016) to achieve

compliance.

2. It is noted that the ESDDR has

confirmed that none of the

Table-3.12 provides the details of possible

occurrence of avifauna in the region. Data was

Already replied

Page 3 of 7

components of the sub-project were

located within or close to (i) core,

buffer and eco-sensitive areas of

national parks, sanctuaries or bio-

sphere reserves; (ii) forests; (iii)

wetlands; (iv) areas of ecological

sensitives; and (v) protected

monuments of archeological, cultural

or historical importance. While

the ESDDR has confirmed absence of

endangered species of flora and fauna

in the study area, table 3.12 has

reported presence of five critically

endangered bird species in study area.

This may please be verified and

reconfirmed. The ESDDR shall clearly

define the study area considered for

environmental impact assessment.

incorporated by third party consultant namely

Voyants Solutions Pvt ltd. However, developer has

confirmed that till date no such critically

endangered species were observed and evident by

local stakeholders.

Developer has informed that WTGs and associated

facilities with 2 km buffer area were considered as

study area for impact assessment under ESDD.

3. The ESDDR has also confirmed that

the sub-project area and its

surroundings do not fall under any

major flyway or migratory routes.

Therefore, no significant impacts on

bird and bat life were anticipated in

terms of mortality caused due to

collision of birds and/or bats with

wind turbine rotor blades. However, in

the ESDDR a periodic bird and bat

study has been recommended to assess

the risk on bird and bats.

IIFCL is requested to share a copy of

such monitoring study for this sub-

ESDDR suggested to undertake a periodic bird/bat

carcass survey in the project by site personal in the

core study area. Developer has confirmed that till

date no bird carcass was observed / reported in the

project area.

IIFCL would report its assessment in the updated

ESDDR.

Bird and Bat carcass survey is being conducted

at the project and records maintained at site.

Details are included in Section 14 Para 19

(Page 14) of the updated ESDDR. The updates

are included in Table 5 (Page 31-32) and Table

6 (page 51-52).

Page 4 of 7

project. IIFCL is further requested to

provide its assessment on the findings

of such study in the updated ESDDR

requested.

4. IIFCL shall also submit a duly signed

REA checklist by its environmental

experts and head of its Environment

and Social Management Unit (ESMU).

Noted. --

5. It is further noted from ESDDR that

the wind power projects required to

obtain the consents to establish and

operate in the year 2014 as per the

then prevailing environmental

regulations of India. IIFCL shall

confirm that MVKPL had obtained the

requisite regulatory permissions and

provide copies of such permissions in

the ESDDR.

Considering the fact that Wind power

projects under renewable energy have very

negligible negative impact on environment.

Ministry of Environment Forests & Climate Change

(earlier MoEF) has exempted these projects from

obtaining Environment Clearance through EIA

notification 2006. In general, Consents under Air

(Prevention and Control of Pollution) Act, 1981 and

Water (Prevention and Control of Pollution) Act,

1974 are required for the industries which cause air

and water pollution, whereas wind farm operations

do not result in air and water pollution. Ministry of

New & Renewable Energy (MNRE), GOI has also

propagated the fact that wind energy is a green

energy and doesn’t cause any pollution. However, in the initial stages of evolution of the wind energy

sector, there was no uniform policy across different

States in the matter of treatment of the sector from

pollution perspective. This resulted in multiple

views and practises in that regard and lead the wind

developers to continuously represent to the

MoEFCC, Central Pollution Control Board

(CPCB), State Pollution Control Board (SPCB) for

specifically exempting Wind Power Projects from

The status of all regulatory clearances and

other information in included in Table 3 of the

revised ESDDR.

Page 5 of 7

the requirement of obtaining any consent from the

SPCBs for establishment or operation. Eventually

MoEFCC declared Wind industry as Green Industry

in line with MNRE and subsequently changed it to

White category status vide circular dated 7.3.2016,

which was circulated to all SPCBs.

Developer has informed that, there was neither a

practice of obtaining Consent from SPCBs by the

Wind Developers nor did the SPCB insist such

consents at that time. It is pertinent to note that all

the wind power projects are setup pursuant to

Power Purchase Agreements signed with State /

Central Utilities.

Developer has further informed and shared

acknowledgement copy of request for issue of NOC

in respect to CTE/CTO from Karnataka State

Pollution Control Board.

The status of all regulatory permissions will be

provided in the updated ESDDR.

6. The ESDDR had recommended that

MVKPL should establish an

environmental and social management

system (ESMS) for the sub-project.

IIFCL to confirm whether an ESMS

has been established by MVKPL and

the status of its functionality as on

date while submitting the copy of

ESMS with updated ESDDR as

requested above.

Environmental and Social Management System

covering the Environmental, Health, Safety and

Social requirements throughout the project life

cycle, has been developed by Mytrah Energy

(India) Private Limited (MEIPL) which is

implemented at MVKPL also.

Copy of ESMS will be submitted with updated

ESDDR.

Copy of ESMS is enclosed as Annexure IX of

the revised ESDDR.

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7. It is also noted from the REA checklist

that MVPPL has developed detailed

environmental, health and safety

guidelines to handle community health

& safety related risks during

construction and operation phase of

the sub-project. A copy of such

guidelines and the status of its

implementation may please be

included in the updated ESDDR.

Community health and safety management plan is

available for the sub-projects. Copy of the plan and

status of its implementation will be included in the

updated ESDDR.

Copy of Community Health and Safety

Management Plan is attached with the revised

ESDDR as Annexure XXII and status of its

implementation is given in Table 8 in updated

ESDDR.

8. Based on the information furnished,

the proposed sub-project appears to

qualify as of environment category B,

subject to the responses from IIFCL as

requested above.

Noted Categorization of sub-project is given in para

19 of the revised ESDDR.

9. The sub-project was commissioned in

2014 without the knowledge of ADB

financing, and therefore, it is unlikely

to have followed ADB’s SPS 2009 related requirements during

construction as well as operation and

maintenance stages.

Agreed ---

10. During due diligence study performed

by the team of consultants engaged by

MVKPL in 2016, certain safeguard

related gaps including lack of

adherence with India’s environmental regulations were identified and

corrective actions have been

recommended to achieve compliance.

IIFCL needs to confirm that those

Noted Status of gap identification is given in Table 5

& 6 of the revised ESDDR. Section 12 of the

revised ESDDR explains the compliance of the

sub-project to IIFCL’s ESSF.

The sub-project is financed by IIFCL under

Takeout scheme. It is in compliance to the

ESSF and ADB’s SPS, 2009.

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corrective actions have been taken by

MVKPL to bridge the identified gaps,

achieved regulatory compliance, and

that the sub-project is now in

compliance with the agreed safeguards

related requirements (as per IIFCL’s ESSF 2013 and SPS 2009 applicable

for this loan) for take-out financing.

11. IIFCL shall also undertake a field visit

to verify and confirm that there are no

residual environmental impacts as on

date due to implementation of the sub-

project (given that the ESDDR is

dated 2016), and prepare an updated

ESDDR with requested details, and

submit its duly signed copy by

IIFCL’s ESMU for ADB’s review.

Noted.

Updation of ESDDR based on information shared

by developer is under process. Field visit is to be

undertaken by IIFCL to verify and confirm that

there are no residual impacts as on date. Since

elections going on in India, therefore, site visit

could not be undertaken and will be taken up

shortly.

Updated ESDDR has been prepared on the

basis of site visit undertaken by IIFCL staff.