assessment of three solar parks, including internal

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The business of sustainability Rewa Ultra Mega Solar Limited (RUMSL) Environmental and Social Impact Assessment of three Solar Parks, including internal evacuation infrastructure and associated transmission lines, of aggregate capacity of 1500 MW in the state of Madhya Pradesh, India FPIC Approach, Draft Discussion and Decision Making Framework May 2021 Project No.: 0528741 www.erm.com

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The business of sustainability

Rewa Ultra Mega Solar

Limited (RUMSL)

Environmental and Social Impact Assessment of three Solar Parks including internal evacuation infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the state of Madhya Pradesh India

FPIC Approach Draft Discussion and Decision Making Framework

May 2021

Project No 0528741

wwwermcom

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wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

Document details The details entered below are automatically shown on the cover and the main page footer

PLEASE NOTE This table must NOT be removed from this document

Document title Environmental and Social Impact Assessment of three Solar Parks including internal

evacuation infrastructure and associated transmission lines of aggregate capacity of

1500 MW in the state of Madhya Pradesh India

Document subtitle FPIC Approach Draft Discussion and Decision Making Framework

Project No 0528741

Date 5 May 2021

Version 04

Author ERM India Private Limited

Client Name Rewa Ultra Mega Solar Limited

Document history

ERM approval to issue

Version Revision Author Reviewed by Name Date Comments

Draft 01 Swayam

Panda

Neena Singh Neena Singh 20 Sep 2020

Draft 02 Swayam

Panda

Neena Singh Neena Singh 12 Dec 2020

Final Draft 03 Swayam

Panda

Ajay Pillai 30 Mar 2021

Final

Draft-2

04 Swayam

Panda

Ajay Pillai 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

Signature Page

05 May 2021

Environmental and Social Impact Assessment of three Solar Parks including internal evacuation infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the state of Madhya Pradesh India

FPIC Approach Draft Discussion and Decision Making Framework Draft Final Report

Name Dr Swayam Panda

Job title Technical Director

Name Ajay Pillai

Job title Partner

ERM India Private Limited Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

copy Copyright 2021 by ERM Worldwide Group Ltd andor its affiliates (ldquoERMrdquo)

All rights reserved No part of this work may be reproduced or transmitted in any form

or by any means without the prior written permission of ERM

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page i

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

CONTENTS

1 INTRODUCTION 1

11 Project Background 1 12 Timeline of Various EampS Studies 3 13 Scope amp key deliverables related to FPIC for MP Solar Project 4 14 Structure of the Report 11 15 Limitations 11

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS 12

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in

2018 12 22 International Social Safeguard Policies Applicable to the Project 16

221 IFC Performance Standards 16 222 World Bank Operation Manual OP 410 16

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard

Policies of IFC and WB 17

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION 22

31 Affected Villages Government land used by ST Population 22

311 Neemuch Solar Park (Unit 1-3) 22 312 Agar Solar Park (Unit 4 amp 5) 26 313 Shajapur Solar Park (Unit 6-8) 30

32 Selection of FPIC Villages 36 33 Impact on Nomadic Pastoral Communities 37 34 Impact on Government and Grazing Land 38 35 Impact on Cultural Sites affiliated to STs 39 36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure 40

361 Use of Government Land in TLs Associated With Neemuch Solar Park 41 362 Use of Government Land in TLs Associated With Agar Solar Park 42 363 Use of Government Land in TLs Associated With Shajapur Solar Park 43 364 Conclusion on FPIC Trigger for Transmission Lines 45

4 DESK BASED INFORMATION COMPILATION 46

41 Information Collection and Compilation 46 42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks 46

421 Government Land Allotment for Neemuch Solar Park 46 422 Government Land Allotment for Agar Solar Park 46 423 Government Land Allotment for Shajapur Solar Park 47

43 Review of Previous Community Consultations for Allotment of Government Land 47

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER 49

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020) 49

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park 49 512 Disclosure of Intention to Conduct FPIC Agar Solar Park 49 513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park 50

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises

with STs (Aug 2020) 50

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village) 52 522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village) 55 523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages) 58

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL 62

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page ii

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

6 INDEPENDENT FACILITATOR AGENCY 63

61 Need for FPIC Process Facilitation Agency 63 62 Screening of FPIC Process Facilitation Agency 63 63 Roles and Responsibility for FPIC Process Facilitation Agency 65 64 Terms of Reference for FPIC FA 65

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS 66

71 Use of Language 66 72 Use of Customary Decision Making Process and Traditional Leaders 66 73 Promoting Participation of Women and Youths 67 74 Expectation on Material Information Prior to Discussion 67 75 Need for Capacity Building of IP Representatives 68 76 Need for a Mediation Mechanism 68 77 Following Principles of Good Faith Negotiation 69 78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and

Supportive Environment 70

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK 73

81 Introduction 73 82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo 73

821 Appointment of FPIC Facilitation Agency and Orientation 73 822 Introducing FPIC FA to RUMSL and FPIC Villages 73 823 Formation of ST Committees 74 824 Capacity Building of ST Committees 74

83 The Draft Discussion amp Decision Making Framework 74

831 Formation of Committees 75 832 Acceptance of Draft Discussion and Decision Framework 76 833 Disclosure of Draft IPPIPDP to ST Committee 77 834 Explaining Draft IPPIPDPTDP to ST Committee 78 835 Internal Consultation Process by ST Committee 78 836 First RUMSL and ST Committee Meeting 78 837 Second RUMS and STs Committee 79 838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee

(MC) 79 839 Informing Community on Draft FPIC Agreement by ST Committee 79 8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and

Ratification of Final IPP and FPIC Agreement 80 8311 FPIC Process Documentation Report 81

84 Tentative Time-line 81 85 Responsibility Matrix 83

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT

FPIC

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE

FPIC FACILITATOR

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Tables

Table 11 Villages to be covered in FPIC Process 1

Table 12 Salient Features of the Project 2

Table 13 The status of ESIA Study Components and Community Engagement 3

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables 5

Table 21 Key Provisions of Land Revenue Code 12

Table 22 Comparison of Provisions of Consent Process in Applicable Indian Regulations vis-agrave-

vis Provisions in IFC PS-7 17

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land

Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

19

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected

Villages 22

Table 32 Agar Solar Park- Government Land- Land Use Category 26

Table 33 Shajapur Solar Park- Government Land- Land Use Category 30

Table 34 Villages to be covered in FPIC Process 36

Table 35 Designated grazing land (Charnoi) and Remaining Government Land 38

Table 36 Impact on Cultural Sites Affiliated to STs 39

Table 37 List of Power Evacuation Infrastructure 40

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of

STs 41

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST

Population 42

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs 43

Table 41 Dates of Government Land Allotment for Neemuch Solar Park 46

Table 42 Dates of Government Land Allotment for Agar Solar Park 46

Table 43 Dates of Government Land Allotment for Shajapur Solar Park 47

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha

Resolution 47

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park 49

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park 50

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park 50

Table 54 Site visit Dates and Site Activities 51

Table 55 Names of Potential Representatives in Ladwan Village 54

Table 56 Names of Potential Representatives in Parsula Village 57

Table 57 Names of Potential Representatives in Badi and Kawai Village 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency 63

Table 62 Roles and Responsibilities of FPIC FA 65

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context 69

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages 71

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Figures

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages 24

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages 25

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages 28

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages 29

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages 33

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages 34

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages 35

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments 56

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process 74

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Acronyms and Abbreviations

Name Description

CSO Civil Society Organizations

DDMF Discussion and Decision Making Framework

DPR Detail Project Report

DREO District Renewable Energy Officer

ESIA Environment and Social Impact Assessment

ESS Environment and Social Standards

FA Facilitation Agency

FPIC Free Prior Informed Consent

FPIC-FA FPIC Facilitation Agency

FPICon Free Prior Informed Consultation

GAP Gender Action Plan

GFN Good Faith Negotiation

GN Guidance Note

GoMP Government of Madhya Pradesh

GP Gram Panchayats

HO Head Office

ICP Informed Consultation and Participation

IFC International Finance Corporation

IPDP Indigenous Peoples Development Plan

IPP Indigenous Peoples Plan

Ips Indigenous Peoples

JV Joint Venture

LRP Livelihood Restoration Plan

MC Mediation Committee

MNRE Ministry of New and Renewable Energy

MPLRC Madhya Pradesh Land Revenue Code

MPUVNL Madhya Pradesh Urja Vikas Nigam Limited

MW Mega Watt

NGO Non-Government Organizations

NOC No Objection Certificate

OBC Other Backward Castes

OP Operation Policy

PPP Public Private Partnership

PRA Participatory Rural Appraisal

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Name Description

PS Performance Standard

RAP Resettlement Action Plan

RPO Renewable Purchase Obligation

RUMSL Rewa Ultra Mega Solar Limited

SC Scheduled Caste

SEP Stakeholder Engagement Plan

SHG Self Help Group

SPD Solar Park Developer

SPO Solar Purchase Obligation

ST Scheduled Tribe

TDP Tribal Development Plan

ToR Terms of Reference

WB ESF World Bank Environment and Social Framework

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 1

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

1 INTRODUCTION

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Impact Assessment (ESIA) including Resettlement and

Rehabilitation Action Plan (RAP) of three solar parks including internal evacuation infrastructure and

associated transmission lines of aggregate capacity of 1500 MW in the Neemuch Agar and Shajapur

Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work ERM is required to assess the impacts of the Project on the Indigenous

Peoples (IPs) or Scheduled Tribe (ST) and develop an approach and implement the process of Free

Prior Informed Consent (FPIC) The villages in Table 11 were identified to be covered in the FPIC

process during the scoping stage The intention of conducting FPIC process involving ST families in

these identified villages was communicated to the Sarpanch1 and a project information sheet (in

Hindi) was shared around Dec 2019

Table 11 Villages to be covered in FPIC Process

Solar Park Selected ST

villages for FPIC

Number of

Households

Name of ST

Community

Date on which Gram

Panchayat was informed

about FPIC Process

Agar Solar Park Ladwan 12 Bhilala 19th Dec 2019

Shajapur Solar Park Parsula 41 Bhilala 30th Jan 2020

Neemuch Solar Park Badi and Kawai 61 Bhil and Bhilala 5th and 6th Dec 2019

The Covid-19 pandemic brought restrictions for finalizing the project boundary and preparation of

ESIA Reports between Mar 2020 and Jun 2020 ERM initiated the FPIC related works and submitted

a Memo on selection of FPIC villages dated 29th Jun 2020 which reviewed the government land

allotment and triggers for FPIC

The FPIC Approach Paper (current document) is based on the understanding of the socio-political

context within which the affected STIPs population lives and suggestions received from the

prominent ST representatives with whom a preliminary round of discussions was held The Discussion

and Decision Making Framework (see Section 8) is accepted by RUMSL and was planned to be taken

back to the affected ST community for discussion and acceptance in Apr 2021 (see Section 832)

This has been delayed due to second wave of Covid-19 which started in Apr 2021 and decision on

further visits and consultations will be undertaken based on how situation unfolds in the coming

weeks The FPIC Approach paper will be finalized after the Discussion and Decision Making

Framework is discussed with ST Committees representing affected ST communities and agreed by

them

11 Project Background

The Government of India has identified the solar power sector as one of the critical components for

infrastructure development and overall economic growth The Government of Madhya Pradesh

(GoMP) through Ministry of New and Renewable Energy (MNRE) is developing ground mounted grid

connected solar power projects in Madhya Pradesh International Finance Corporation (IFC) is

providing investment advisory services to RUMSL thereby enabling Government of Madhya Pradesh

(GoMP) to develop the project on Public Private Partnership (PPP) mode and to support GoMP in

1 The rural local self-government bodies in India are known as Gram Panchayat which comprises of several wards Each ward

elects a ward member to represent them The Gram Panchayat thus comprises of multiple elected Ward Members The Chair Person of these elected local body is known as Sarpanch The vice chairperson of the Gram Panchayat is known as Upsarpanch or Naibsarpanch All adult electorate of a Gram Panchayat constitute Gram Sabha or General Assembly of the Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

meeting its energy requirements and in the process meet its Renewable Purchase Obligation (RPO)

and Solar Purchase Obligation (SPO)

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) Its primary objective is to develop

and facilitate development of large scale solar power projects in the state of Madhya Pradesh

RUMSL is planning to develop three solar parks (see details in Table 12) and their associated

internal evacuation infrastructure and transmission lines The World Bank had agreed to provide

financial support for the Project

Table 12 Salient Features of the Project

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Capacity and Configuration

3 Units (Units 1 2 3) adding up to 500 MW

2 Units (Units 4 and 5) adding up to 550 MW across Susner (Unit 4) and Agar (Unit 5)

3 Units adding up to 450 MW across Moman Badodiya (Units 6 and 7) and South Shajapur (Unit 8)

Total Land Area as of 24 June 2020

Unit 1 3515 ha Unit 2 34713 ha Unit 3 36701 ha Total 106573 ha

Unit 4 60809 ha Unit 5- 79918 ha Total 140758 ha

Unit 6- 2462 ha Unit 7 4859 ha Unit 8 2551 Total 9872 ha

Government Land (ha) allotted as of 24 Jun 2020

67819 ha

Allotment of additional 28979ha is under process Thus the total government land area is 962949 ha

127338 ha 931 ha allotted and additional 14ha to be allotted

Date of Government Land allotment

Allotment Date

Area in Ha

17-01-2018 23868

30-05-2017 43951

Total 67819

Allotment Date

Area in Ha

28022019 5633

28022019 7053

21062019 1495

20-06-2019 15925

28022019 283

20062019 19714

280202019 1683

21012019 3492

04012018 602

09082018 2669

30112016 5562

02012018 5699

02012018 16116

06012018 17663

09082018 15583

Total 127137

Allotment Date

Area in ha

26-05-2017 914

26-05-2017 3052

26-05-2017 2011

11-12-2017 11261

11-12-2017 1171

11-12-2017 171

11-12-2017 1386

11-12-2017 4015

11-12-2017 4596

11-12-2017 9545

11-12-2017 1763

26-05-2017 16461

28-06-2019 2675

28-06-2019 6134

Total 931

Private Land 1862 ha 1342 ha 9951 ha

Patta land 7572 ha 0 515 ha

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 3

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Proposed Commissioning Date

Tender and bid process tasks completed

- Start of registration downloading of the RFP access to Data Room on 26th Jan 2020

- Facilitation of site visit 26 to 28th Feb 2020

- Issue of Draft Project Agreements on 15th Jun 2020

- First pre-bid meeting was held on 30th Jun 2020

- ESIA Reports was issued on 16th Oct 2020

Tender and bid process schedule ahead

- Second pre-bid meeting on 30th Mar 2021

- Proposal due date for 3 sites between 3rd Jun 2021 and 18th Jun 2021

- Financial proposal opening between 14th Jun and 28th Jun 2021

- Reverse Auction Process 17th Jun and 30th Jun 2021

Purchase of Private land between Apr and Jun 2021

Target date for providing SPD land access June 2021

Indicative construction time of 19 months

Target date for commissioning of Solar Park Nov 2022 It is understood that RUMSL will initiate a process of hand over of balance government land to revenue department no longer required for the project

12 Timeline of Various EampS Studies

The allotment letters of the government land were issued at different points of time between 2017 and

2019 The boundary demarcation (tarmeem2) of these allotted government land for the 3 solar parks

was completed in October 2020 RUMSL is planning to initiate private and patta land procurement to

start in Apr 2021 and all sale agreements are signed by Jun 2021

The timeline of ESIA studies of these 3 Solar Parks is provided in Table 13 below

Table 13 The status of ESIA Study Components and Community Engagement

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

ESIA Field

visits

December 2019 December 2019-

January 2020

January ndash February

2020

September 2020

Report Final ESIA

submitted in

October 2020

Final ESIA

submitted in

October 2020

Final ESIA submitted

in October 2020 Draft ESIAs for

Neemuch TL and

Agar- Shajapur

TL submitted in

November 2020

RAP-

LRP

Field

visits

November-

December 2020

August 2020 August 2020 December 2020

Report Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-WB

Draft RAP-LRP is

reviewed by IFC-

2 Tarmeem ground verification process to confirm land ownership and to demarcate any patta land andor private land that

may have been identified within a government khasra This process is done by Revenue Department from time to time in the normal course of action (with or without any project) As an outcome of this process following can be achieved Revisions in the Patwari maps Khasra books Digital database other revenue records preparation of survey reports etc This process is undertaken by Officials from the Revenue Department usually inclusive of the Tehsildar RI Patwari etc

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 4

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

WB and ready for

Public Disclosure in

Mar 2021

WB and ready for

Public Disclosure

in Mar 2021

and ready for Public

Disclosure in Mar

2021

WB and ready for

Public Disclosure in

Mar 2021

IPP Field

Visits

Initiation 5-6th Dec 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and Draft IPP 13-16th Aug 2020

HH Survey 7-14th Sep 2020

Initiation 19th December 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 6-7th Aug 2020

HH Survey Not done

Initiation 30th Jan 2020

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 8-12th Aug 2020

HH Survey 13-14th Aug 2020

No IPP to be prepared for Transmission Line

Report Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure in

Mar 2021

Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure

in Mar 2021

Draft IPP is reviewed

by IFC-WB and

ready for Public

Disclosure in Mar

2021

The ERM ESIA team has held several consultation meetings in project affected villages covering a

cross-section of stakeholders in a sequential manner The broad understanding of the socio-economic

and livelihood practices was carried out in Dec 2019 and Jan 2020 as part of collection of baseline

information The detailed study for RAP-LRP and IPP subsequently took place in Aug 2020 The details

of the consultations held for ESIA RAP-LRP are part of those reports and details of field visits and

consultation activities carried out for preparation of this FPIC Approach Paper and Draft IPP is described

in Section 4 below

13 Scope amp key deliverables related to FPIC for MP Solar Project

ERM as a part of the FPIC requirement for the project is expected to support the elaboration and

implementation of a robust FPIC process for the MP Solar Park project to be developed in 2 Phases

Phase I the overall principles and engagement process and criteria for obtaining FPIC should be

agreed on with the affected Indigenous People (IP) communities potentially before bidding

Phase II the focus of the proposed FPIC process will then be on seeking consent from affected

IP communities for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior

to the main construction phase) In phase II it is likely that the PPP concessionaire will also

play a role and as such the Social Expert will continue to advise RUMSL but also monitor the

activities of the concessionaire

The Table 14 below summarises the key deliverables tasks involved and expectations against each

of these tasks in terms as per the scope The current status progress of these tasks and timeline for

future activities is also proposed It should be noted that these timelines may change in keeping with

evolving health and safety situation in context of COVID-19

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 5

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

I OBJECTIVE AS PER RFP The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities before bidding ie the submission of proposal for solar parks by concessionaire

Guidance to RUMSL (ONGOING)

Provide guidance to RUMSL on the most appropriate sequencing of steps vis-agrave-vis the FPIC process as per IFC PS 7 requirements

eg agreement and verification of legitimate IP representatives to represent affected communities in FPIC negotiations

agreement with IPs and their representatives on the FPIC engagement process and next steps including disclosure and consultation of draft updated project impact mitigation benefits package documentation

share of responsibilities between RUMSL and PPP concessionaire etc

This will also include advise on broader stakeholder analysis and engagement strategy

to build support for the FPIC approach and implementation of the project and

to participate in agreed outreach to influential local and international stakeholders andor additional sources of adviceinput

ERM has been providing handholding support to the client in terms of meetings and calls where the requirements of IFC PS 7 are discussed and possible implications of project decisions on the FPIC applicability are discussed

The training for RUMSL team on ICP (SEP) PS-7 and FPIC process on 27th Aug 2020

Sharing of Draft FPIC Approach Paper 1st Sep 2020

Discussion on Draft IPP and Formation of Committees for FPIC Process 16th Mar 2021

Submission of Note on FPIC budget FPIC Process

Responsibilities of PPP concessionaire submitted as part of Draft IPPs (Appendix-F)

A meeting with facilitating agency and their ToR was held in 1st Week of Apr 2021

A Joint field trip with RUMSL FPIC Team will be held after Covid-19 Second Wave is over to

- Verify the IP representatives and formation of ST committees

- To agree with ST committee on Draft Discussion and Decision Making Framework

Draft FPIC approach paper

Desk-based Information Compilation and Assessments

Review national applicable law to identify any gaps with IFC PS7 and ways to bridge them

While developing the FPIC approach leverage as much as possible the requirements of applicable law and the consent process usually applied when IP are affected

The FPIC approach should also ensure that affected IP communities are involved

ERM did not get access to documentation of community consultation as part of seeking

NOC3 from Gram Panchayats

Conversation with Sarpanch of villages with ST population revealed that consultation was

A field trip for a joint meeting between RUMSL and ST communities is proposed to be held after Covid-19 Second Wave is over The field trip will include the following

3 The allotment of unused Government land within any revenue village needed a resolution of concerned local government body (Gram Panchayat) under S 234 (4) till Nov 2018 See more details in

Section 21 below The Solar Parks does not require any EIA studied in India

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Identification of affected IP individuals and communities and representatives as well as project impacts mitigation measures and potential benefits related to them (ongoing process during ESIA)

Initial Meeting with Gram Panchayats (GPs) and Informing them on FPIC

Social MappingSite walk-through

Preparation of Draft FPIC Approach Paper which builds on key elements of IFC PS7 FPIC requirements is prepared in consultation with RUMSL IP representatives and other stakeholders and could be acceptable to each party

Internal Discussion and Consensus on FPIC Approach Paper

Sharing of Draft FPIC Approach with IP and Consensus Building

in the identification of impacts and provide input on the development of mitigation and benefit plans

The FPIC approach should be cognizant that impacts on vulnerable groups within the Affected Communities of IP if any should be adequately addressed during negotiation and in relevant documentation

It should be based on the engagement with local IP community decision-making authoritiesrepresentatives (and taking into account gender and other IFC PS 7 related prerogatives) to discuss the FPIC process with input from support organization

The draft approach paper should reflect a mutually acceptable engagement and negotiation framework for the FPIC process based on the principles of Good Faith Negotiations It should include a clear agreed indication on what constitutes consent in the project context

Ensure through revision and feedback that all other components under this assignment (ifwhen available) are aligned with the defined FPIC approach ndash including the Environmental and Social Impact Assessment (ESIA) Resettlement Action Plan (RAP) Stakeholder Engagement Plan (SEP) Gender Action Plan (GAP) and develop the Indigenous People Development Plan (IPDP)

restricted to Gram Panchayat members Though they initially reluctant to sign on the NOC after persuasion of District Collector they finally signed

PRA exercises which includes participatory mapping of social relationship livelihood and natural resources was held between 6th to 15th Aug 2020

The social mapping during 6-15th Aug collected information on existence of traditional decision making process and gender representation aspect

The proposed FPIC process as part of this FPIC approach paper (Refer Chapter-8) reflect GFN principles

The FPIC approach paper was discussed with RUMSL prior to sharing it with WB-IFC

The ESIA disclosure was done as part of the PRA exercises for IPP in Aug 2020The RAP survey was done in these villages around the same time to address their concerns over loss of privatepatta land

Consultations during RAP and Draft IPP preparation included PRA process where STs participated to identify impacts and expressed their expectation on project benefits

The feedbacks and key issues in ESIA (including GAP SEP) and RAP is synchronised in Draft IPP

- Introduce FPIC Facilitation Agency

- Facilitate formation of ST representative committees

- Inform them their rights in the context of FPIC process

- Consult and build mutual agreement on the lsquoengagement and negotiation frameworkrsquo (as in Chapter-8 of this report) which will include a clear agreed indication on what constitutes consent

- The STs Representatives will be asked about time they require for internal discussion and a tentative date for the first discussion on benefits proposed in IPP will be fixed

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Independent FPIC Facilitator Agency

Assess the need for Independent FPIC Facilitator Agency

Screening of IPOsCSOs for Independent FPIC Facilitator Agency possible facilitator options to determine how they can play a role in the process - who what how

Provide a list of names of key advocacy groupsNGOsCSOs considered SWOT (or similar) analysis of each organization considered identification of preferred organization and

Terms of Referencersquo for the role of the same in the FPIC process and its relevance for the FPIC process in that area and for that specific group

To be discussed in next call FA brings credibility of an independent agency (other than RUMSL and ESIA consultant) Considering the project context their position can be reviewed

The review and assessing the need for a FA is discussed in section 6 of this report The Scope of work for the FA is provided in Appendix-F

Preparation of IPDPIPPTDP

Note ESIA RAP SEP and other management plans should be prepared by this stage Infact the FPIC process report should also draw input from the engagement undertaken as part of the ESIA process

Indigenous People Plan (or

Community Development Plan

Stakeholder Engagement Plan) or

similar management documents

aimed at ensuring ongoing and

adequate engagement with IPs

The collection of baseline

information through PRA

exercises and a sample

household survey was done

in Aug 2019 The IPP draws

inputs from consultations for

ESIA RAP-LRP and

benefits are also

synchronised

Three Draft IPPs one for

each Solar Parks with a

package of benefits for

affected STs is ready and

disclosed in May 2021

These will be shared with

affected STs as part of the

FPIC negotiation process

subsequently for their

considerations and

acceptance

Preparation of Draft FPIC Process Report

FPIC Process Report will include (but not be limited to)

identification of IPs IP representatives and decision-making authorities

assessment of capacity of IPs IP representatives to undertake good faith negotiations

summary of any capacity building undertaken

agreed engagement and negotiation framework (including the process undertaken to agree upon the framework)

This document will be further updated and finalised once the whole process is completed

Note The FPIC process should incorporate key considerations contained in IFC PS 7 and GN 7 eg the need for free prior and informed engagement inclusion of differentiated measures to allow the effective participation of those identified as particularly disadvantaged or vulnerable including analysis of the legitimacy and representativeness of IP leaders and the role responsibilities and participation of

To be initiated once FPIC Process starts

The process of identification of IPs representatives and decision making authorities (ST RUMSL and Mediation Committees) which will take place once Covid-19 second wave is over and will be documented as Draft FPIC Process Report This will be a living document which will be updated after every round of field activities and negotiation meetings

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

detailed summary of consultations meetings engagement undertaken as part of the FPIC process

expert opinion on the process and outcomes

share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to complete the FPIC process

external stakeholders with vested interests in the outcome

Input to the bidding document

For the bidders in terms of FPIC amp IPDP requirements

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc

The Draft IPP for each Solar Park has Annexure-F providing roles and responsibilities and scope of work for the Solar Park Developer (SPD)

All 3 Draft IPPs with Annexure-F are ready for disclosure in May 2021

II OBJECTIVE AS PER RFP Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Preparation of communication Material

Communication material to be based on IPDP ESIA and RAP This should include culturally appropriate document on impacts and mitigation to be used during FPIC engagement and negotiation

All preparation including translation of FPIC-related materials including communication material summaries of relevant EampS documentation local benefits plans etc (printing arrangement to be agreed with RUMSL)

A Project Profile Fact Sheet was shared in Dec 2019

A summary of ESIA was shared in Aug 2020

The communication material based on Draft IPP will be prepared and used during FPIC process The Draft communication material will be shared with IFC-WB for their approval prior to its use in field

A parallel information disclosure process of RAP-LRP would also take place

Culturally Appropriate Information Disclosure Campaign

Share accurate and up to date information on project impacts proposed mitigation measures and proposed benefit streams in a culturally appropriate manner (ie in local language (as appropriate following discussion with IP representatives) in written and oral format)

The information disclosure should especially ensure that following are achieved

provide sufficient time for capacity building and

support to affected communities to understand these matters and their rights

The affected ST population speaks Malwi dialect The FPIC FA will have facilitators who would be familiar with this local dialect used

The FPIC FA will carry out the capacity building activities

The FPIC FA will spend 2 days at each Solar Park to do the capacity building workshops with local ST Representatives who would participate in FPIC discussion with RUMSL

The FPIC FA will do this once Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Consent from the Indigenous communities

Meetings for Negotiation and Decision Making

Participate in and offer expert support to key FPIC-related meetings involving affected IP representatives RUMSL and other relevant authorities etc during the FPIC process

Support RUMSL in the organization of these meetings and in recording their outcome including the collection of comments and concerns of those attending

Measuring Consent and Signing of FPIC Agreement

Note This include also support the RUMSL in designing undertaking and collecting evidence of Good Faith Negotiations (GFN) resulting in Consent which involves (i) willingness to engage in a process and availability to meet at reasonable times and frequency (ii) provision of information necessary for informed negotiation (iii) exploration of key issues of importance (iv) use of mutually acceptable procedures for negotiation (v) willingness to change initial position and modify offers where possible and (vi) provision of sufficient time for decision making

Present updated materials and seek consent from affected IP communities and their leaders

Document the consent process in a mutually agreed written format including an agreed mechanism for monitoring of key commitments in future and grievance redress as well as identifying share of responsibilities between the RUMSL SPDs and other relevant parties

Evidence of representativeness and involvement of Indigenous Peoples representative bodies and organizations (eg councils of elders or village councils)

Evidence of agreement between the parties as the outcome of GFN (eg FPIC agreement MOU a letter of intent and a joint statement of principles agreed mitigation plans collective land agreements etc)

Other documents may include Client records photographs media reports personal letters or third-party accounts etc regarding eventsdemonstrations other activities for the project undertaken by project-affected IP communities with high relative levels of participation by (i) the affected community as a whole or (ii) by sub-groups particularly affected by the project

ERM will work alongside FPIC FA and RUMSL to help the FPIC process taking right direction

Final FPIC Process Document

Throughout the FPIC process (Phase I and Phase II) ERM should help documenting the FPIC process and provide an opinion and direction about the process and outcome vis-agrave-vis IFC PS7

The whole set of activity in Phase II need to be updated as part of the Final FPIC Process Document

The tentative timeline for the FPIC Process was scheduled between Jun 2021 and Sep 2021 The timeline will be revised after the ongoing Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

The Draft FPIC Process Report will be submitted within 2 weeks of completion of FPIC process

Advise RUMSL but also monitor the activities of the concessionaire in phase II

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INTRODUCTION

14 Structure of the Report

This report is organized into following sections

Section 1 Introduction (this section)

Section 2 Applicable law and gaps assessment against IFC PS7 requirements

Section 3 Affected IPs population project impacts and mitigation

Section 4 Desk-based information compilation

Section 5 Engagement leading up to FPIC Approach Paper

Section 6 Independent facilitator agency

Section 7 Key elements in FPIC Process

Section 8 Draft Discussion and Decision Making Framework

15 Limitations

This Report is prepared after multiple field visits and interactions with affected ST community elected

leaders of Gram Panchayat and other key informants The assessments are based on information

received from RUMSL and other secondary information at some places The public health concerns

due to Covid-19 pandemic has prevented large community gatherings and communityrsquos willingness to

allow people from outside to spend much time with them

ERM team communicated with community members over telephone to seek clarifications and know

their views However it was not always possible to keep the discussion focused and definitive as it

could have been in case of a face to face discussion ERM has made efforts to build trust among

affected STs by sharing relevant information and answering their queries with clarity As FPIC process

is an itinerant process this relationship is expected to further evolve in future

The Draft Discussion and Decision Making Framework described in Chapter 83 though has been

accepted by RUMSL and reviewed by IFC and WB it would be discussed with committees formed by

affected STs and their feedbacks will be incorporated The FPIC process described in Chapter-8

therefore would undergo necessary changes

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan could not

be ascertained as nomadic tribes did not visit these sites when ERM conducted field visits The general

migration pattern of pastoral nomads is expected to have faced constraints of Covid-19 restrictions If

pastoral nomads or their representatives will be identified during the FPIC process an appropriate

decision on their participation will be taken

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

This section provides an understanding of the applicable national regulations that pertain to the process

of land procurement and the rights of the Indigenous Peoples and a comparison between the provisions

of the same against the IFC PS 7 requirements

It should be noted that the Environmental and Social Impact Assessment (ESIA) Reports4 and the

Resettlement Action Plans (RAP) provide a detailed understanding of applicable regulations This

section is focused on the government land procurement process and its impacts on the collective rights

of the Indigenous Peoples identified in the project

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in 2018

The allotment of government land for these three solar parks is done under provisions of the MP Land

Revenue Code 1959 The Chapter-XVIII of this Code deals with rights in abadi5 (habitation area) and

un-occupied land and its produce

The Madhya Pradesh Land Revenue Code (MPLRC) was enacted in 1959 and has undergone several

amendments since then It was recently amended in 2018 and 2019 These recent amendments along

with other changes changed the procedure for allotment of unoccupied government land Some of the

land allotment letters were prior to this amendment and others after this amendment (see details in

Section 42) Table 21 below provides a comparison of key provisions in pre and post 2018

amendment

Table 21 Key Provisions of Land Revenue Code

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

Collective (Nistar) Rights on Unoccupied Government Land

Section 114- Land recordsmdash In addition to the map and

Bhoo Adhikar Pustikas there shall be prepared for each

village a khasra or field book and such other land records as

may be prescribed

Section 233- Record of unoccupied landmdash A record of

unoccupied land shall in accordance with rules made in this

behalf be prepared and maintained for every village

showing separatelymdash (a) unoccupied land set apart for

exercise of nistar rights under Section 237

Section 114 (e) (i) (ii) requires

the details of all unoccupied land

be maintained as described in

Section 233 One Such

document is the Nistar Patrak

under Section 234 Section 233 A record of all unoccupied land shall be prepared for every village and urban area in accordance with rules made in this behalf

Preparation of

Nistar Patrak

and change in

entries in

Nistar Patrak

Section 234 (1)- The Sub-Divisional Officer shall in

accordance with the provisions of this Code and the rules

made thereunder prepare a Nistar Patrak for every village

embodying a scheme of management of all unoccupied land

in the village and all matters incidental thereto and more

particularly matters specified in section 235

Section 234- same as 1959 Sub

section (2) (3) (4) have been

removed

4 Three separate ESIA Reports for Solar Parks one for each Solar Park one for the Neemuch Transmission Lines (Units 12

and 3) and another for the Transmission Lines for Agar and Shajapur Solar Parks (for Units 4 to 8) have been prepared 5 According to the MP Land Revenue Code 1959 abadi means the area reserved from time to time in a village for the residence

of the inhabitants thereof or for purposes ancillary thereto and any other cognate variation of this expression such as village site or gaonsthan shall also be construed accordingly No change was made to this definition in the subsequent amendments to the code

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(2) A draft of the Nistar Patrak shall be published in the

village and after ascertaining the wishes of the Gram Sabha

it shall be finalised by Sub-Divisional Officer

(3) A copy of the Nistar Patrak so finalised shall be kept in

the office of the Gram Panchayat

(4) On a resolution passed by the Gram Sabha by a majority

of not less than two-thirds of the members present and

voting the Sub-Divisional Officer with the prior sanction of

the Collector and also after making any such inquiry as he

deems fit inter se change the entries in the Nistar Patrak

(b) Record additional unoccupied land under any entry in the

Nistar patrak for fulfilment of further Nistar rights of villagers

Matters to be provided for in Nistar Patrak

Section 235- The matter which shall be provided for in the

Nistar Patrak shall be as follows namely

(a) terms and conditions on which grazing of cattle in the

village will be permitted

(b) the terms and conditions on which and the extent to

which any resident may obtain-

(i) wood timber fuel or any other forest produce

(ii) mooram6 kankar7 sand earth clay stones or any other

minor mineral

(c) instructions regulating generally the grazing of cattle and

the removal of the articles mentioned in paragraph (b)

(d) any other matter required to be recorded in the Nistar

Patrak by or under this Code

Section 235- same as previous provision of Land Revenue Code

Provision in

Nistar Patrak

for certain

matters

Section 236 - In preparing the Nistar Patrak as provided in

Section 235 the Collector shall as far as possible make

provision for-

(a) free grazing of the cattle used for agriculture

(b) removal free of charge by the residents of the village for

their bona fide domestic consumption of-

(i) forest produce

(ii) minor minerals

(c) the concessions to be granted to the village craftsmen for

the removal of the articles specified in clause (b) for the

purpose of their craft

Section 236 - same as previous

provision of Land Revenue Code

Collector to

set apart land

for exercise of

Nistar rights

Section 237 (1) Subject to the rules made under this Code

the Collector may set apart unoccupied land for the following

purposes namely-

(a) for timber or fuel reserve

(b) for pasture grass bir or fodder reserve

(c) for burial ground and cremation ground

(d) for gaothan

(e) for encamping ground

Section 237 (1) remains same

6 Soil used particularly for road paving 7 In India an impure concretionary carbonate of lime usually occurring in nodules in alluvial deposits and especially in the

older of these formations

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(f) for threshing floor

(g) for bazar

(h) for skinning ground

(i) for manure pits

(j) for public purposes such as schools play grounds parks

road lanes drains and the like and

(k) for any other purposes which may be prescribed for the

exercise of right of Nistar

237 (2) Lands set apart specially for any purpose mentioned

in sub-section (1) shall not otherwise be diverted without the

sanction of the Collector

Section 237 (3) Subject to the rules made under this Code

the Collector after securing the land mentioned in clause (b)

of subsection (1) to minimum two percent of the total

agriculture land of that village may divert such unoccupied

land as mentioned in sub-section (1) into abadi or for

construction of roads state highways national highways

canals tanks hospitals schools colleges Goshalas and

any other public utility projects as may be determined by the

State Government

Provided that the land set apart for the purposes mentioned

in subsection (1) shall not be diverted and allotted to any

person for agriculture purpose

Section 237 (4) When it becomes indispensable to divert the

land set apart for the purposes mentioned in sub-section (1)

for such development and infrastructural projects which are

owned or approved by the State Government but not

covered under sub-section (3) the Collector after satisfying

himself on alternatives available and also on obtaining land

of equivalent area for fulfilling the same nistar rights from the

concerned project may divert the land for such purposes by

passing a reasoned order to this effect Thus in case Nistar

land needs to be diverted for the project the project needs to

make available an equivalent area for the replacement of the

same nistar rights

The section 237 (2) is removed

Section 237 (3) remained same

Section 237 (4) remains same

Rights in Fruit Bearing Trees and other trees in Un-Occupied Government Land

Section 239 (1) Where before coming into force of this

Code any fruit bearing tree was planted by any person in the

unoccupied land of any village and is so recorded then

notwithstanding that such land vests in the State

Government such person and his successor in interest

shall from generation to generation be entitled to possession

and usufruct of such trees without payment of any royalty or

other charge whatsoever therefore

Section 239 (6) the State Government may make rules for

carrying out the purposes of this section

Section 239 (1) same as 1959

Section 239 (6) The unoccupied

land on which any tree planting

permit or tree patta has been

given prior to the commencement

of MP Land Revenue Code

(Amendment) Act 2018 may be

used for any public purpose by

the order of Collector If any

interest of the holder of such tree

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

planting permit or tree patta is

adversely affected due to such

use the holder shall be entitled

for such compensation which

shall be calculated in such

manner as may be prescribedrdquo

Exclusive jurisdiction of revenue authorities

Section 257 - Except as otherwise provided in this Code or

in any other enactment for the time being in force no Civil

Court shall entertain any suit instituted or application made

to obtain a decision or order on any matter which the State

Government the Board or any Revenue Officer is by this

Code empowered to determine decide or dispose of and in

particular and without prejudice to the generality of this

provision no Civil Court shall exercise jurisdiction over any

of the following matters - (w) any claim to modify any entry

in the Nistar Patrak

Section 258 (1) The State Government may make rules

generally for the purpose of carrying into effect the

provisions of this Code

(2) In particulars and without prejudice to the generality of

the foregoing powers such rules may provide for (lviii) the manner in which the wishes of the villagers shall be ascertained under Section 234 (2)

Section 257 - same as 1959

Section 258 (1) and (2) (lviii)

same as 1959 it should be noted that the Section 234 (2) was removed in 2018 Amendment

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers Diverting the un-occupied

government land8 categorised as grazing land that is recorded in Nistar Patrak (there may be other

grazing land available) and such other Nistar rights9 including the right in fruit bearing trees and other

trees in unoccupied government land after the amendment in 2018 does not require any consent

process with concerned village community

Hence it is expected that the government land allotted for the project prior to the 2018 Amendment of

MP Land Revenue Code is expected to have involved a resolution of concerned Gram Sabha As per

Sec-6 of the Madhya Pradesh Panchayat Raj Act 1993 the quorum of every meeting of Gram Sabha

shall not be less than one-tenth of the total number of members of the Gram Sabha or five hundred

members of the Gram Sabha whichever is less The Act does not specify presence of women in

Gram Sabha to be mandatory

Other Indian laws which has provisions for consent process are not applicable to this project and an

overview of them is provided in Box 31 below

8 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands 9 Nistar rights refer to collective rights of a revenue village to use specified government land for the purposes mentioned in

S235 of MP Land Revenue Code This includes right to free grazing cattle collecting minor minerals construction materials burialcremation grounds for religious and cultural events etc

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Box 21 Other Indian Laws with provisions for consent process and their applicability

22 International Social Safeguard Policies Applicable to the Project

221 IFC Performance Standards

The part of PS1 dealing with Management Program envisages an Indigenous Peoples Plan (IPP) as a

thematic plan and should be developed by qualified experts with substantive experience For projects

with adverse impacts to Indigenous Peoples the client is required to engage them in a process of

Informed Consultation and Participation (ICP) and in certain circumstances the client is required to

obtain their Free Prior and Informed Consent (FPIC)

The FPIC from the affected communities of Indigenous Peoples is required when the following special

circumstances (in paragraphs 13ndash17 of Performance Standard 7) are present

Impacts on lands and natural resources subject to traditional ownership or under customary use

Relocation of Indigenous Peoples from lands and natural resources subject to traditional

ownership or under customary use

Significant impacts on critical cultural heritage that is essential to the identity andor cultural

ceremonial or spiritual aspects of IPs lives

Where a project proposes to use the cultural heritage including knowledge innovations or

practices of Indigenous Peoples for commercial purposes

IFC PS7 requires to avoid adverse impacts on Indigenous People and if adverse impacts are

unavoidable the project should prepare an Indigenous Peoples Plan outlining the actions to minimize

andor compensate for adverse impacts in a culturally appropriate manner Some of the key

provisions with respect to IPP are

A free-standing IPP may be prepared or it may be a component of a broader community

development plan

The IPP should detail actions to minimize andor compensate for adverse social and economic

impacts and identify opportunities and actions to enhance positive impacts of the project on the

Indigenous Peoples

Where appropriate the IPP may also include measures to promote conservation and sustainable

management of the natural resources on which the Indigenous Peoples depend

The IPP should include a clear statement of roles and responsibilities funding and resource

inputs a time-bound schedule of activities and a budget

The IPP shall be regular monitored and should be flexible to allow for it to be adapted as needed

if circumstances change

222 World Bank Operation Manual OP 410

The World Bankrsquos Operational Policy on Indigenous Peoples (OP 410) aims at ensuring that the

development process fosters full respect for the dignity human rights and cultures of IPs thereby

In Indian context the constitutionally recognized Scheduled Tribes are usually considered as Indigenous Peoples

while determining their entitlements under international social safeguards systems

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006( FRA) is not

relevant as no forestland was diverted The Provisions of the Panchayat (Extension to the Scheduled Areas) Act

1996 (PESA) acts is not applicable for the project as the project site is not in a schedule V area There are no

specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement

consultation and consent

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

contributing to the Bankrsquos mission of poverty reduction and sustainable development To achieve this

objective Bank-assisted projects which affect IPs provide them a voice in design and implementation

avoid adverse impacts where feasible or minimize and mitigate them and ensure that benefits

intended for them are culturally appropriate

The Bank recognizes that IPs are commonly among the poorest and most vulnerable segments of

society and in many countries they have not fully benefited from the development process It also

recognizes that the identities cultures lands and resources of indigenous peoples are uniquely

intertwined and especially vulnerable to changes caused by development programs Because of this

issues related to indigenous peoples and development are complex and require special measures to

ensure that IPs are not disadvantaged and that they are included in and benefit from these programs

as appropriate

Under the OP 410 the Bank requires the borrower to undertake a social assessment to evaluate

projectrsquos potential positive and adverse effects on the IPs and to examine project alternatives A

project that affects Indigenous Peoples the borrower engages affected IPs in a free prior and

informed consultation (FPICon) process

Note The World Bank adopted Environment and Social Framework (ESF) which comprises of ten Environment

and Social Standards (ESS) The ESS-7 deals with Indigenous PeoplesSub-Saharan African Historically

Underserved Traditional Local Communities which requires FPIC to be obtained in special circumstances where

customary rights on natural resources used by IPs is impacted The WB has financed the renewable projects to

MNRE prior to adoption of the new ESF in Dec 2019 The Shajapur Solar Park is under the old WB safeguards

and therefore the new ESF is not applicable

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard Policies of IFC and WB

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers The diversion of the un-

occupied government land10 categorised as grazing land that is recorded in Nistar Patrak (there may

be other grazing land available) and such other Nistar rights including the right in fruit bearing trees

and other trees in unoccupied government land after the amendment in 2018 does not require any

consent process with concerned village community A comparison of key provisions of PS-7 vis-agrave-vis

legal provisions in Indian context is provided in Table 22

Table 22 Comparison of Provisions of Consent Process in Applicable Indian

Regulations vis-agrave-vis Provisions in IFC PS-7

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Assessment of Impact on Indigenous People

The client will identify through a process of Social and Environmental Assessment all communities of Indigenous Peoples who may be affected by the project within the projects area of influence The client will assess the nature and degree of the expected social cultural (including cultural heritage) and environmental impacts (direct and indirect) on them and avoid adverse impacts whenever feasible

There is no requirements for environment impact assessment (EIA) for Solar Park Projects There are no specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement consultation and consent

10 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands Such usages will be confirmed only through the Tarneem process for each site

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Preparation of IPP

The clients actions will be developed with the informed consultation and participation of affected Indigenous Peoples and contained in a time-bound plan such as an Indigenous People Plan or a broader community development plan with separate components for Indigenous Peoples

There is no legal requirement for an Indigenous Peoplersquos development plan

Consultation and Consent from affected IPs

In projects with adverse impacts on affected communities of Indigenous Peoples the consultation process will ensure their free prior and informed consultation and process of community engagement will be culturally appropriate and commensurate with the risks and potential impacts to the Indigenous Peoples

The acquisition of the private land owned by ST will be done through MP Consent Policy 2014 and the RAP addresses the impact on individual ST land ownersoccupiers The impact on customary rights (such as Nistar rights) over collectively used unoccupied government land is dealt under the provisions of MP Land Revenue Code 1959 There is no consultationconsent process for diversion of grazingNistar lands under MP Land Revenue Code 1959 (As amended up to 2019) The consent process in other Indian laws such as FRA or PESA which has consent process is not relevant to the project

Land Revenue Code had a requirement for Gram Sabha consent to be taken prior to diversion of

Nistar rights as part of the 2018 Amendment the same provision was removed As most of the

government land for Shajapur Solar Park was allotted in 2017 Table 23 below provides a

comparison of provisions of the consent process under MP Land Revenue Code 1959 (prior to Nov

2018 amendment) vis-agrave-vis requirements under IFC PS-7

The key elements of FPIC process as per IFC PS (including Guidance Notes- GN) identified for

comparison includes

1 Requirements of information disclosure (as in PS-129) 2 Informed consultation and participation (as in PS-130-31 and PS-710) 3 Good Faith Negotiation (as in GN-725) and 4 Consent and documentation (as in PS-712)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Information Disclosure

Relevant project information must be disclosed to Affected

Communities and other stakeholders to enable them to

understand the risks impacts and opportunities of the project

The Project will provide Affected Communities with access to

relevant information on

the purpose nature duration and scale of the project

risks and potential impacts and relevant mitigation measures

the envisaged stakeholder engagement process and

the grievance mechanism

Information disclosed must be relevant transparent objective

meaningful and easily accessible and in a culturally appropriate

local language(s) and format and is understandable to Affected

Communities

Under MP Revenue Code 1959 and MP

Panchayat Raj Act 1993 the information

disclosure to affected communities (including

Schedule Tribes) is limited to the intended

purpose of the allotment of unoccupied

government land

The disclosed information and proceedings are

recorded using the language of the State

The information disclosure to affected communities

prior to the meeting does not disclose all relevant

information particularly potential risks The

information disclosed is not easily accessible to STs

and other vulnerable communities

The process does not involve any grievance

mechanism

Informed consultation and participation

Where a Project has potentially significant adverse impacts on

affected communities an ldquoinformed consultation and

participationrdquo (ICP) process should take place ICP is an

organised and iterative consultation that involves a more in-

depth exchange of views and information leading to the Project

incorporating the views of those affected into project decision-

making on matters that affect them directly

The consultation process should capture both menrsquos and

womenrsquos views and their different concerns and priorities The

process should be documented in particular the measures taken

Section 234 of MP Revenue Code 1959 (Prior to

Nov 2018 Amendment) required the draft Nistar

Patrak of every village and any changes in therein

to be published by Sub-Divisional Officer with

prior sanction of the District Collector only after

ascertaining wishes of the Gram Sabha

(expressed through a resolution passed in Gram

Sabha held for this purpose)

As per Section 6 of the MP Panchayat Raj Act

1993 the Gram Sabha can be held with a quorum

of one-tenth of the total member of Gram Sabha

The MP Revenue Code does not require any

iterative consultation that involves in-depth

exchange of views

The participation of women and other vulnerable

sections is not mandatory

The quorum of the meeting is only ten percent of the

total members of the Gram Sabha The notice for

holding a special Gram Sabha is only 7 days and

there is limited information shared in terms of the

agenda of the meeting Hence a resolution passed

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

to avoid or minimise risks to and adverse impacts on the

Affected Communities and should inform those affected about

how their concerns have been considered

In addition the process should Involve Indigenous Peoplesrsquo representative bodies and

organisations as well as members of the Affected Communities of IPs and

Provide sufficient time for IPs decision-making processes

or five hundred members whichever is less

There is no specific requirement on presence of

women to fulfil quorum requirements

A special meeting of the Gram Sabha is held

within seven days of receiving the requisition

by a Gram Sabha with a bare minimum presence

does not reflect majority decision

The process does not require representative bodies

of IPs to represent their interests

Good Faith Negotiation

FPIC will be established through good faith negotiation between

the Project and the Affected Communities of IPs Good faith

negotiation generally involves (i) Willingness to engage in a process and availability

to meet at reasonable times and frequency (ii) Provision of information necessary for informed

negotiation (iii) Exploration of key issues of importance (iv) Mutually acceptable procedures for the negotiation (v) Willingness to change initial position and modify

offers where possible and (vi) Provision for sufficient time for decision making

The MP Revenue Code require neither iterative

prior consultation nor exchange of views with

administration

The administrative process for allotment of

unoccupied government land does not involve a

negotiation process through which their feedback

and concerns are incorporated or addressed

Consent

In certain circumstances the client is required to obtain the Free

Prior and Informed Consent (FPIC) of affected IPs FPIC does

not necessarily require unanimity and may be achieved even

when individuals or groups within the community explicitly

disagree The measurement of consent is expected to be

included in the lsquomutually accepted processrsquo for FPIC decision

making

Consent

Section 234 (4) required the Gram Sabha to pass

a resolution with support of a majority not less than

two-thirds of the members present and voting As

per Section 6 of the MP Panchayat Raj Act 1993

the Gram Sabha can be held with a quorum of one-

tenth of the total member of Gram Sabha or five

hundred members whichever is less There is no

specific requirement on presence of women to fulfil

quorum requirements

Consent

The FPIC process in IFC PS-1amp7 recognizes that

consent is not necessarily a unanimous decision

yet there has to be a mutually agreed threshold of

consent in an FPIC process that can vary from

project to project The threshold defined in MP

Panchayat Raj Act 1993 is one-tenth of the total

members of Gram Sabha passing a resolution with

support by two third majority present and voting

Thus the consent threshold for a resolution is 66

of the total members of Gram Sabha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Documentation

The client will document

The mutually accepted process (FPIC Decision Process Framework Document) between the client and Affected Communities of Indigenous Peoples and

Evidence of agreement between the parties as the outcome of the negotiations

Documentation

The documentation is limited to the entries in Gram

Sabha minutes book The entire set of

documentation is kept by Administration and not

shared with Gram Panchayat

Considering this low threshold as per legal

requirements the FPIC process requires a mutually

accepted threshold for decision making

Documentation

The documentation of the process carried out during

the Gram Sabha meetings leading to the resolution

though is written down in the Gram Sabha minutes

book however there is no guideline on what should

be covered Therefore a mutual agreement on

documentation requirement is necessary

As described in GN62ndash65 where government processes involve project-level decision and actions the client should review these processes in relation to the requirements of the Performance Standard and address identified gaps where feasible

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

The FPIC was triggered at the scoping stage on account of impact on grazing land and other natural

resources within the allotted government land on which STs have claims of customary use which is also

recognized under MP Land Revenue Code as Nistar rights The statement of different categories (which

are part of the Nistar rights of village community) of government land to be used for the proposed Solar

Parks from different villages and percentage of ST population in these villages is provided below

31 Affected Villages Government land used11 by ST Population

311 Neemuch Solar Park (Unit 1-3)

The Neemuch Solar Park is comprised of 3 units and the land is acquiredpurchased from 3 villages

The land category (classification in revenue records as per their currentintended use) is provided in

Table 31 below

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected Villages

Village Name

Govt Land Category in Hindi

Govt Land Category in English Sum of Area (Ha)

ST Population in of Total Village Population

Unit -1

Bardavada Chargah Grazing land 2271 55

Charnoi KamdalKK (Kabil Kast)

Grazing land 4013

DathaKamdal Land with stone outcrops and shallow soil

1655

Gair mumkinCharnoi Uncultivable waste land grazing land

492

Kabil Kast Cultivable 2

Kamdal Land with stone outcrops 169

KamdalDathaDahar Grazing land 4641

KamdalDathaKaKa Grazing land 4279

PK 052

NA 2053

Sub-Total (Bardawada) 25774

Kawai Datha Land with stone outcrops and shallow soil

8962 1992

NA 425

Sub-Total (Kawai) 9388

Total Unit 1 351615

Unit -2

Badi Datha 052 2292

Kabil Kast 11568

NA 5835

Sub-Total (Badi) 17455

Kawai NA 17846 1992

Sub-Total (Kawai) 17846

Total Unit 2 35301

Unit -3

Badi Charnoi (grazing) Grazing land 355 2292

Datha 3805

Gairmumkin Charagah

(grazing)

Uncultivable waste land

grazing land

4184

11 The MP Land Revenue Code recognizes the right to use for grazing collection of timber fire-wood earth morums and other

products (see Section 235 of MP Land Revenue Code)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

KaKa (Kabil Kast) Culturable wasteland 5

Kamdal 11179

NA 13727

Badi total 36945

Total Unit 3 3694557

Grand Total (Unit-1 2 and 3) 107408

Note land category for the units is as per the Allotment Letters NA= Not Available

The screening of the Census 2011 data shows that there is presence of ST population in all three

villages In Badi and Bardawada villages the land categories such as Charnoi Charagah are clearly

recorded as grazing lands The map below shows the location of village settlements and their area

designated as Grazing Land

The ST families in Badi and Kawai live in several small cluster of satellite settlements The Bardawada

had only 22 ST population with 4-5 families Bardawada is part of Dhardi Gram Panchayat and the ST

households live farther from the Solar Park boundary Their households are scattered and dependency

on the allotted government land for Bardawada village could not be established In terms of

concentration of ST population Badi and Kawai are considered as major ST settlements

Thus ~100 ST households in Badi and Kawai have a claim on customary use of ~18938 ha of

designated grazing land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

312 Agar Solar Park (Unit 4 amp 5)

The Table 32 provides a break-up of the designated land categories of government land as per revenue

records in Agar Solar Park

Table 32 Agar Solar Park- Government Land- Land Use Category

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Agar Solar Park (unit 4)

Bijnakhedi Germumkin Uncultivable waste land 5598 0

Sub-Total (Bijnakhedi) 5598

Dudhpura Agriculture Agriculture 2243 0

Bardi NA 6631

Gothan Livestock rearing land 2

Khadar The floodplains formed by

yonger alluvium

018

Tree Plantation NA 1495

NA NA 5082

Sub Total (Dudhpura) 15669

Karwa Khedi Chragha Grazing land 251 0

K K NA 475

Khachar Grazing land 068

Pahad Hilly terrain 12392

NA 216

Sub Total (Karwa Khedi) 15346

Keasi Dehariya Gochar Grazing land 283 0

Sub Total (Keasi Dehariya) 283

Ladwan Bardi 7963 579

Charnoi Grazing land 947

Gochar Grazing land 2749

Kavil Kast 609

Khachar Grazing land 238

Pahad Hilly terrain 3062

Waterbody Water body 094

NA 475

Sub Total (Ladwan) 16137

Madhopur Germumkin Uncultivable waste land 1558 0

Sub Total (Madhopur) 1558

Pipalia Kumar Bardi 3492 0

Agriculture land Agriculture 506

Sub Total (Pipalia Kumar) 3998

Total Unit 4 611381

Susner Solar Park (Unit 5)

Palda Germumkin Uncultivable waste land 5689 036

NA 6928

Sub Total (Palda) 12617

Naharkheda Germumkin KaKa Uncultivable waste land 4125 0

Germumkin Uncultivable waste land 1868

NA NA 8908

Sub Total (Naharkheda) 14901

Umariya Charnoi Grazing land 3660 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Charokhar Grazing land 416

Chragha Grazing land 9114

Germumkin Uncultivable waste land 147

Kadim NA 011

Shaskiye Government land 218

Sheda NA 01

NA NA 20907

Sub Total (Umariya) 35806

Pipaliya Nankar NA NA 1822805 0

Total Unit 5 8161745

Note land category for the unit 4 is as per the kml file provided by RUMSL on 30012020 as the allotment letters did not carry

the land use details

Ladwan village has 579 of ST population (~12 households) who have claim on customary use of

3934 ha of designated grazing land Palda was found to have only 1 ST family Moreover no Charnoi

Chargah Gochar land is acquired from Palda Hence ST families in Ladwan were selected to be in

focus for FPIC process

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

313 Shajapur Solar Park (Unit 6-8)

The Table 33 provides a break-up of the land categories of government land as per revenue records

in Shajapur Solar Park In Shajapur Solar Park (Unit 6-8) five villages have ST population They are

Jawadi (034 STs) Parsula (1768 STs) Dehripal (018 STs) Fawaka (238 STs) and

Chouma (072 STs) Of these Dehripal Fawaka and Surajpur do not have any Charnoi Chargah

Gochar land impacted

Table 33 Shajapur Solar Park- Government Land- Land Use Category

Village Name Govt Land

Category in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Moman Badodiya-Unit6

Burlay Agriculture Agriculture 813 0

Germumkin Uncultivable waste land 224

Nala Stream Drain 138

Burlay Total 3191

Jawadi Agriculture Agriculture 198 034

(1 Household with

3 persons)

Gochar Grazing land 4189

Idhan Hetu For fuelenergy 209

Kabil Kast 316

Muram Hetu For Murram (fine aggregate) 063

Pahad Hilly terrain 339

Shivir Camping ground 041

NA 2011

Jawadi total 3596

Dhatrawada Agriculture Agriculture 338 0

Charnoi Grazing land 058

Chragha Grazing land 4058

Germumkin Uncultivable waste land 10638

Gothan Livestock rearing land 128

K Kast 557

Kabil Kast 1217

Kadim 074

Khadan Quarry 291

Khalihan Threshinggrain storage etc 167

Murum Hetu

Khadan

For Murram 125

Nala StreamDrain 042

Road Road 117

NA 6

Dhatrawada total 1841

Total (Unit 6) 25197

Momain Badodiya-Unit 7

Parsula Agriculture Agriculture 515 1768

(~41 households) Barda Rockyhilly 847

Barda Nistar

Chragha

Grazing land 947

Charnoi Grazing land 1064

Idhan Hetu

Surakshit

Secured for fuelenergy-

firewood

209

KK 137

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Khchar Grazing land 311

Nala Streamdrain 146

Nistar Chragha Grazing land 393

Parsula Total 12192

Dehripal Agriculture Agriculture 124 018

(1 Household with

5 populaiton)

Birdi GM 295

Brda 8054

Brda Lala 055

Chuna Hetu 105

Germumkin Uncultivable waste land 2015

Kankad Chuna

Hetu

For coarse aggregate and

lime

105

Khad ke Gadde 15

Muram Hetu For Murram (fine aggregate) 042

Watershed

Planning

Watershed planning 027

NA 1916

Dehripal Total 14004

Bijanakhedi Agriculture Agriculture 2199 0

Bardi 4101

Bardi Charnoi Grazing land 1274

Bardi 385

Chamdi Sthan 042

Charagah Grazing land 035

Charnoi Grazing land 018

Chragha Grazing land 1404

Germumkin Uncultivable waste land 858

Idhan Hetu 209

Khad ke gadhe Manure collection 084

Khalihan Hetu Threshinggrain storage etc 143

Mitti Hetu 063

Muram Hetu For Murram 063

Nala Streamdrain 36

Pathar Hetu For Stone 105

Road Road 203

Shivir Bhumi Camping ground 042

NA 288

Bijanakhedi total 11876

Fawaka Agriculture Agriculture 016 238

(4 Households with

28 population)

Brda Hilly terrain 863

Idhan Hetu Secured for fuelenergy-

firewood

25

Kakkad 418

Muram Hetu For Murram (fine aggregate) 179

Fawaka Total 1726

Chouma Agriculture Agriculture 392 072

(3 Households with

19 population)

Brdi Hilly terrain 562

Chamda Sthan For de-skinning 021

Charnoi Grazing land 989

GM 2943

Gothan Livestock rearing land 5

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Muram Pathar

Khadan

Murram (fine aggregate) 041

Nala Streamdrain 015

Chouma total 5463

Burlay Germumkin Uncultivable waste land 1543 0

Nala Streamdrain 019

NA 2604

Burlay Total 4166

Total (unit 7) 49427

Shajhapur (unit 8)

Surajpur Bardi Hill Terrain 898 203

(3 Households with

16 population)

Germumkin Bardi Uncultivable hill terrain 1170

Nala Streamdrain 597

NA 1894

Surajpur total 4559

Lalpur Beed 023 0

Beed Gair Mumkin 053

Brdi 2333

Charagrah Grazing land 18

Charnoi Grazing land 115

Gair Mumkin Brdi 1608

Kadim 115

Nala Streamdrain 055

NA 1684

Lalpur Total 6166

Hanoti NA 16291 0

Total (unit 8) 27024

Note land category for the units is as per the excel sheet received on 18062020 from RUMSL

Hence 41 ST households in Parsula who have a claim of customary use on ~3134 ha of

designated grazing land was selected to be the focus for FPIC Process The map below shows

the location of Parsula and the area designated as Grazing Land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

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Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

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Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

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Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

32 Selection of FPIC Villages

The assessment of the relevance of the four special circumstances that requires free prior informed

consent (FPIC) to be obtained from affected ST population was undertaken On the basis of the detailed

assessment undertaken as part of ESIA RAP along with targeted consultations with the IP

communities three circumstances are assessed to be not relevant to the project context

Relocation of STs was avoided while determining Solar Park boundary for all the three solar

parks and therefore no relocation of STs is anticipated from lands and natural resources subject

to traditional ownership or under customary use

The physical impact on cultural heritage sites with affiliation to STs is avoided in the three Solar

Park lay out and there is no potential significant impact on critical cultural heritage that is

essential to the identity andor cultural ceremonial or spiritual aspects of local STs community

The Solar Park does not propose to use the cultural heritage including knowledge innovations or

practices of STs for commercial purpose

Table 34 provides the list of villages where the FPIC process will focus covering ST households living

within it The assessment concludes that affected ST families have been living in these villages for

generations and have been using the government land (which was assessed to be subject to

traditional ownership or under customary use of the ST communities) allotted for Solar Park Project

for free grazing their cattle collection of fire-wood and collect edible fruits and plants mostly for self-

consumption The diversion of these land for the solar park will result in impacts on lands and natural

resources It was noticed that 7 other project affected villages had less than 5 ST households the

impact on their customary use of land acquired for the project was assessed and included in this table

too

Table 34 Villages to be covered in FPIC Process

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

Neemuch

Solar Park

Badi

(including 2

satellite

settlements)

80 (~450) Bhill Bardawada which is part of Dhardi Gram

Panchayat has only 4 ST families The location

of these ST households and consultations did

not indicate the government land allotted to

Neemuch Solar Park were under customary use

by them Kawai 17 (~100) Bhill

Agar Solar

Park

Ladwan 12 (~50) Bhill Palda village has 1 ST household and no

grazing (designated as Charnoi Chargah

Gochar) land is acquired from Palda

Palda village has 276ha of designated grazing

land and 28735ha of unoccupied government

land which they will continue to use for free

grazing their cattle and collection of fire wood

Hence the customary use of land by ST

household will continue with a negligible impact

Shajapur

Solar Park

Parsula 41 (~250) Bhill

Bhilala

Apart from Parsula 5 other affected villages

have less than five ST households These

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

villages (with the number of ST households)

are Jawadi (1) Dehripal (1) Fawaka (4)

Chouma (3) and Surajpur (3) The remaining

designated grazing land and total government

land for these 5 villages is provided below

Village Remain-

ing Desig-nated Grazing land (ha)

Total govern-ment land after Project allotment (ha)

Designated Grazing Land in percentage total Govern-ment land

Jawadi 2125 2705 786

Dehripal 241 8116 03

Fawaka 5032 5703 882

Chouma 2278 8167 279

Surajpur 1224 2592 472

The consultation with STs at Parsula informed

that unlike them these ST families do not keep

livestock in large number and mostly work as

construction workers Hence the land allotted to

Solar Park was not under customary use by

them for their livelihood

Note The ST families in these 7 villages will have access to the Grievance Mechanism to register their claims to

participate in the FPIC process In such a case their demands will be shared with concerned ST Committee (or

referred to Mediation Committee) and decision to include them in the process will be taken and an appropriate

mechanism for their representation and participation will be adopted

33 Impact on Nomadic Pastoral Communities

The seasonal use of the grazing and government land by nomadic pastoral communities was noticed

in scoping stage However further consultations with local villagers revealed that they do not visit

regularly and rarely camp on the land allotted to Solar Park These nomadic pastoral communities are

from the neighbouring state Rajasthan and are not recognized as STs in Madhya Pradesh

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan and

consultation with any pastoral nomadic tribes was not held as they did not visit these sites when ERM

conducted field visits The general migration pattern of pastoral nomads is expected to have faced

constraints of Covid-19 restrictions If pastoral nomads or their representatives will be identified during

the FPIC process an appropriate decision on their participation will be taken

ERM will consult GoMP to obtain records of grazing permits issued to pastoral nomads of other states

and determine if any of the villages impacted by Solar Parks figure in it More information on their

migration routes and pattern of seasonal use of forest and revenue land for grazing (which would help

assessing their collective attachment to impacted land) will be collected

Due to C-19 restrictions the regular migration patterns by pastoral nomads are affected in 2020 The

next migration season will be in Nov-Dec 2021 In absence of the particular pastoral nomads the

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

GoMP data on pastoral nomad communities who are issued permit will be used and their IPs status

will be screened through secondary ethnographic literature

FPIC is an iterative process If nomadic pastoral communities could not be consulted the rights of

pastoral nomads will be recognized in TDP and a provision for engagement with them to identify

adequate mitigation measures will be kept in TDP

34 Impact on Government and Grazing Land

The total geographical area of these selected FPIC villages grazing land (Charnoi) available after

allotment remaining government land after allotment percentage of the government land remaining is

given in Table 35 below As per provisions of the MP Land Revenue Code a minium of 2 of the

total private land in a revenue village is reserved as Charnoi or grazing land It is observed that

Ladwan and Parsula have more than this recommended minimum

Table 35 Designated grazing land (Charnoi) and Remaining Government Land

Solar Park Unit

Village Name

Geo

gra

ph

ical

Are

a o

f V

illa

ge

(h

a)

To

tal

Pri

vate

La

nd

To

tal

Go

vern

men

t L

an

d P

rio

r to

All

otm

en

t (

of

To

tal

Geo

gra

ph

ic

Are

a)

To

tal

Go

vern

men

t L

an

d R

eq

uir

ed

for

So

lar

Park

(

of

To

tal

Go

vern

men

t L

an

d)

Rem

ain

ing

Go

vern

men

t L

an

d a

fter

All

otm

en

t to

So

lar

Pa

rk

Perc

en

tag

e o

f G

overn

men

t L

an

d o

f

To

tal

Geo

gra

ph

ical

Are

a

( d

ecre

as

e o

r In

cre

as

e)

()

Desig

nate

d G

razin

g L

an

d

avail

ab

le a

fte

r P

roje

ct

all

otm

en

t (h

a)

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g

Lan

d)

of

the R

em

ain

ing

Go

ve

rnm

en

t

La

nd

()

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g)

Lan

d o

f th

e T

ota

l P

rivate

La

nd

Neemuch Solar Park Unit 1 amp2

Kawai 82698 20132 62566 (76)

24572 (39)

37994 (61)

46 (-30)

397 104 2

Neemuch Solar Park Unit 2 amp3

Badi 130055 33599 96456 (74)

51499 (53)

44957 (47)

35 (-39)

646 144 2

Agar Solar Park Unit 4

Ladwan 59076 31913 27163 (46)

16832 (62)

10331 (38)

17 (-29)

6682 6468 21

Shajapur Solar Park Unit 7

Parsula 69061 51439 17622 (26)

1162 (66)

6002 (34)

9 (-17)

1802 3002 4

Note () As per requirement under MP Land Revenue Code a minimum of 2 of the private land area within a

revenue village is to be reserved as Charnoi or grazing land for collective use by villagers

() Total Charnoi or grazing land prior to the allotment of Government land available in secondary sources

(Census 2011) is old as the land allotment took place between 2017 and 2019 Some Government Land

Allotment Letters mentioned the pre-allotment land category classifications (see Table 31 32 and 33) but this

data was not available for all vilalges to calculate the proportionate reduction of Charnoi land

The percentage of government land in some of the villages was high prior to the allotment of land for

Solar Parks For example the government land in Kawai formed 76 and that of Badi 74 of the

total geographical area Allotment of government land for Solar Parks has reduced the proportion of

the government land in these villages but the percentage of reduction varies from village to village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

For Kawai the percentage of government land after allotment has reduced from 76 to 46 (-30)

and for Badi it changed from 74 to 35 (-39) In Ladwan village the percentage of government

land changed from earlier 46 to 17 (-29) Similarly in Parsula the percentage of government

land changed from earlier 26 to 9 (-17)

The revenue department has designated some part of the remaining government land as Charnoi or

grazing land as per current Nistar Patrak The designated grazing land area meets the minimum

requirement of 2 of the total private land of that particular revenue village The designated grazing

land area forms 104 and 144 of the remaining government land for Kawai and Badi respectively

The designated grazing land in Ladwan forms 6682 of the remaining government land and in

Parsula it forms 1002 of the remaining government land

35 Impact on Cultural Sites affiliated to STs

The physical impact on all cultural sites (both for ST and Non-ST communities) was avoided by

excluding them from the Solar Park lay-outs However some of the cultural sites will be in close

proximity or access to some of them would be possible only through the Solar Park boundary An

overview of the cultural sites affiliated to STs for each of the Solar Parks is provided below

Table 36 Impact on Cultural Sites Affiliated to STs

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

Shajapur

Parsula

Gwalon ka

Mandi

Located within Solar

Park boundary

Adequate area (as agreed during FPIC

consultations) around the Gwalon-ka-Mandi to

be left unused in Solar Park lay-out

A road of sufficient width to be provided to

reach Gwalon-ka-Mandi

SPD will carry out improvements of the cultural

site after discussion with STs and other

communities using it

SPD will provide adequate civic amenities

(parking space drinking water lighting public

toilets etc) as per discussion with STs and

other community using it

Agar Solar

Park Ladwan

Gwaal Dev

Shrine

Located at the

margin of Solar Park

boundary

The SPD should leave the shrine and

adequate space around it in its lay out plan

Will ensure that access to the shrine by

community is maintained

The SPD will consult community to improve the

shrine Or build a new shrine for Gowals in the

new grazing area

Neemuch

Solar

ParkBadi and

Kawai

None The shrines and

cremation grounds

used by Bhils in

Kawai and Badi are

None

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

avoided in project

layout plan

No cultural sites or shrines with cultural significance for STs as a community was found during RAP

survey

36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure

The power evacuation infrastructures associated with these 3 Solar Parks are listed below The Pooling

Sub Stations (PSS) are located within the Solar Park boundary There will be 8 transmission line (TL)

sections whose footprint will be outside of the solar park boundary

Table 37 List of Power Evacuation Infrastructure

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

Neemuch

Solar Park

33kV220 kV Pooling Substation Unit-1 258 ha Located within the Solar Park

boundary 33kV220 kV Pooling Substation Unit-1 296 ha

33kV220 kV Pooling Substation Unit-1 887 ha

PGICL ISTS Station Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Neemuch

Solar Park

220 kV SC Line - 1 (From Unit 1 to Unit 2)

Transmission Line (TL) 1

332 km TL footprint is outside of the MP

Solar Park boundary includes

28 Towers (04 ha 144sqm

for each tower base) and RoW

of 13m width of 920ha

220 kV SC Line - 2 (From Unit 2 to PGCIL

ISTS substation)

Transmission Line (TL) 2

157 km

220 kV SC Line - 3 (From Unit 3 to PGCIL

ISTS substation)

Transmission Line (TL) 3

251km

Agar and

Shajapur

Solar

Parks

33kV220 kV PSS 4 in Unit 4 158 ha Located inside Solar Park

boundary 33kV220 kV PSS 5 in Unit 5 539 ha

33kV220 kV PSS 6 in Unit 6 513 ha

33kV220 kV PSS 7 in Unit 7 143 ha

33kV220 kV PSS 8 in Unit 8 196 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

PGCIL ISTS substation 830 ha Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Agar and

Shajapur Solar Parks

220 kV SC Line - 4 (From Agar Solar Park Unit 4 to interconnecting point with TL 7) Transmission Line (TL) 4

121 km TL footprint is outside of the MP

Solar Park boundary includes

372 Towers (536 ha

144sqm for each tower base)

and RoW of 13m width for

11914kms with 14951ha

220 kV SC Line - 5 (From Agar Solar Park Unit 5 to PGCIL ISTS substation) Transmission Line (TL) 5

2932 km

220 kV DC Line - 6 (From Shajapur Solar Park Unit 6 to Shajapur Solar Park Unit 7) Transmission Line (TL) 6

667 km

220 kV SC Line - 7 (From Shajapur Solar Park Unit 7 to PGCIL ISTS substation) Transmission Line (TL) 7

1646 km

220 kV DC Line - 8 (From Shajapur Solar Park Unit 8 to PGCIL ISTS substation) Transmission Line (TL) 8

6548 km

361 Use of Government Land in TLs Associated With Neemuch Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 38 below

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of STs

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

1 Arnya 088 958 007 784

Kheda Moka Ka Dol 223 1807 055 83

Bardawada 009 5651 002 55

Kawai 112 8265 016 20

2

Kawai 104

Badi 102 13004 012 23

3 Badi 285

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

Chaksodijhar12 043 4475 012 0

Grand Total 966 42782 011

The transmission line RoW comes from six revenue villages out of which 5 are Solar Park affected

villages There are 2 additional villages coming under TL RoW ie Arnya (088ha) and Kheda Moka

Ka Dol (223ha)

The population of Arnya in 2011 (as per census) was 969 out of which 784 were ST population

The Kheda Moka Ka Dol is comparatively a smaller village with total population of 348 and 83 of it

belong to STs

The proposed RoW of the transmission line will use 007 and 055 of the unused government land

in Arnya and Kheda Moka Ka Dol respectively The RoW of the Transmission Line does not pass

through any reserved or protected forest land The vegetation cover in the transmission line RoW is

mostly shrubs and grassland There would be no restriction on current use of the RoW for free grazing

of cattle Hence the transmission line will not impact customary use of the RoW land by ST

population in Arnya and Kheda Moka Ka Dol

362 Use of Government Land in TLs Associated With Agar Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 39 below

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST Population

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

4 Ladwan 068 13311 051 6

4 Pachora 089 273 033 0

5 Chkali Parmar 093 1567 059 0

5 Jhikadiya 266 13514 197 0

5 Pipalya kumar 229 13328 172 0

5 Chikali goyal 287 20523 140 0

5 Bhanpura 152 17482 087 0

5 Nipaniya Baijnath 381 29047 131 0

5 Tola Khed 095 3757 253 0

5 Kashi Bardiya 219 5362 408 2

5 Tola Khedi 042 3757 112 0

5 Kankariya 105 13354 079 0

5 Bhimlod 026 22564 012 0

12 Chaksodijhar is part of Badi Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

5 Bapcha agar 266 26778 099 0

5 Karadiya 144 23584 061 0

5 Mangwalia 24 15397 156 0

5 Gaysari 219 5293 414 0

5 Dehrinana 314 29331 107 0

5 Pharaspuri 142 16955 084 0

5 Bingaya Agar 112 150 075 0

5 Ralayti 267 2365 1129 0

5 Piplaya ghata 212 12811 165 0

RoW area passing through Kashi Bardiya village constitute 4 of the total government

The vegetation cover in the transmission line RoW is mostly shrubs and grassland There would be no

restriction on current use of the RoW for free grazing of cattle The RoW of the Transmission Line

does not pass through any reserved or protected forest land and therefore does not involve any

potential use of forest produce Hence the transmission line will not impact customary use of the

RoW land by ST population in Kashi Bardiya

363 Use of Government Land in TLs Associated With Shajapur Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 310 below

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

6 Burlay 494 2876 172 0

6 Bijnakhedi 158 14668 108 0

6 Dehripal 215 27508 078 0

7 Fawaka 237 6083 390 2

7 Dehripal 296 27508 108 0

7 Parsula 219 5891 372 18

7 Megha Khedi 098 3537 277 0

7 Singhwad 071 3118 228 24

7 Palakhi 072 1185 608 0

7 Baigaon 27 2387 1131 11

7 Bagwad 335 14239 235 13

7 Karkadiya 111 8267 134 0

7 Pipalya Kumar 101 13328 076 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

7 Pachora 306 13311 230 0

7 Shivgarh 024 13353 018 0

8 Abhaypur 026 7633 034 0

8 Alampura 337 12006 281 0

8 Arniya 233 9019 258 0

8 Bada Beed Jagatpura 32 49327 065 0

8 Barandwa 646 258 250 1

8 Batawada 022 5854 038 0

8 Bhadoni 096 1672 057 4

8 Bordagujar 217 120 181 0

8 Chachakhedi 155 482 322 0

8 Chandangaon 409 5711 716 0

8 Chikali Parmar 299 1567 191 0

8 Dhakadi 174 467 373 0

8 Dupada 181 3624 050 6

8 Fanya 349 22 1586 0

8 Gujar Khedi 02 0

8 Gurdadiya 188 1279 1470 2

8 Hanoti 004 34035 001 0

8 Harangaon 005 3034 016 0

8 Jadmi 371 3597 1031 0

8 Jhonkar 572 13653 419 0

8 Kadiya 06 13653 044 8

8 Kalmoi 009 3916 023 0

8 Kanasiya 109 40642 027 0

8 Karedi 003 16944 002 0

8 Kareli 197 16944 116 0

8 Katwariya 458 9312 492 33

8 Khajuri Kanad 085 3138 271 3

8 Kharkhadi 071 310 023 0

8 Khutpala 016 2359 068 0

8 Kundla Khurd 23 1507 1526 3

8 Merkhedi 26 26 1000 1

8 Mirapura 068 3767 181 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

8 Murdawan 292 101 289 0

8 Nanukhedi Mana 054 12851 042 0

8 Nanya Khedi Ahir 156 19092 082 0

8 Palasi 028 203 138 21

8 Pipalya Kumar 163 13328 122 0

8 Pipalya Naulay 28 8117 345 25

8 Rojwas 138 10 1380 0

8 Samgi 454 9921 458 2

8 Samgimanda 086 2578 334 0

8 Shankarpur 327 5782 566 0

8 Siroliya 003 10446 003 0

8 Surajpur 249 6912 360 2

8 Suwagaon 092 17558 052 9

The RoW of the transmission lines associated with Shajapur Solar Park passes through 60 villages

and 19 villages have ST population Out of these one village ie Parsula is covered in FPIC process

for Shajapur Solar Park

The RoW of the Transmission Line does not pass through any reserved or protected forest land and

therefore does not involve any potential use of forest produce The vegetation cover in the

transmission line RoW is mostly shrubs and grassland There would be no restriction on current use

of the RoW for free grazing of cattle Hence the transmission line will not impact customary use of the

RoW land by ST population in these 18 villages with ST population

364 Conclusion on FPIC Trigger for Transmission Lines

Based on the details of the presence of STs in Transmission Line corridors and assessment

of current land use and land classifications following inferences can be drawn

1 The TL Tower base and RoW corridor does not have any reserved or protected forest Hence potential customary use of forest produce is not relevant

2 The vegetation within TL RoW is mostly shrubs and grassland which is potentially used by local community for free grazing If any of this land under the ROW has been used for free grazing the people (including the ST families) will have other unused government land available to graze The disruption during construction and stringing will be very temporary and people can continue grazing under the ROW as before The few villages where the impact on unused land was higher than 10 either had no or very small (lt5) of ST population

3 The RAP survey has not identified any cultural site within TLs RoW or Tower Base area 4 There will be no physical displacement of any ST family for TLs

Therefore the circumstances requiring to obtain FPIC is not relevant for transmission lines

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DESK BASED INFORMATION COMPILATION

4 DESK BASED INFORMATION COMPILATION

41 Information Collection and Compilation

ERM has undertaken a desk based review of the information available This step involved collecting

and compilation of relevant information from following sources

Review of Detail Project Report (DPR) prepared by PwC dated October 04 2019

Detailed Project Report for the Project Dec 2019

The Project boundary map provided by RUMSL dated 19 Jun 2020

Collection of digitised maps of village boundaries

Compilation of demographic data using census 2011 data

Review of drone imagery for the project shared by RUMSL to identify EampS sensitivities in the

proposed project boundary

42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks

This section provides the timeline of land allotment process which is compiled from the allotment letters

of the land shared by RUMSL

421 Government Land Allotment for Neemuch Solar Park

Government land is being procured through allotments under the provisions of the Madhya Pradesh

Land Revenue Code 1959 (and its subsequent amendments) Table 41 provides details of the land

allotment for the Neemuch Solar Park

Table 41 Dates of Government Land Allotment for Neemuch Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Village

17-01-2018 7A-20(3)2017-2018 23868 Bardawada Kawai and Badi

30-05-2017 26A-20(3)2016-2017 43951 Kawai and Badi

Total 67819

Source RUMSL

67819 Ha (out of total 96894 Ha) is allocated to RUMSL through two allotment letters in the year 2017

and 2018 respectively out of the 96894 Ha of the required Government Land Both these allotment

letters predates the MP Revenue Code Amendment Act 2018 Allotment of additional 28979ha is under

process

422 Government Land Allotment for Agar Solar Park

Table 42 provides details of the land allotment for the Agar Solar Park which has been undertaken

between Nov 2016 and Jun 2019

Table 42 Dates of Government Land Allotment for Agar Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

28022019 7A-19(3)2017-2018 5633 Bijnakhedi

28022019 6A-19(3)2017-2018 7053 Dudhpura

21062019 31B-1212019-20 1495 Dudhpura

20-06-2019 5A-19(3)2017-18 15925 Karwakhedi

28022019 4A-19(3)2017-2018 283 Kasaidehriya

20062019 3B-1212019-20 19714 Ladwan

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

280202019 2A-19(3)2017-18 1683 Madhopur

21012019 1A-19(3)2017-18 3492 Piplya Kumar

04012018 9A-19(3)2017-18 602 Naharkheda

09082018 9A-19(3)2017-18 2669 Naharkheda

30112016 4819(3)2015-16 5562 Palda

02012018 8A-19(3)2017-18 5699 Palda

02012018 11A-19(3)2017-18 16116 Pipliya Nankar

06012018 10A-19(3)2017-18 17663 Umariya

09082018 10A-19(3)2017-18 15583 Umariya

Total 127137

Source RUMSL

127137 Ha is so far allocated to the project over 2016-2019 and 5106 Ha was allocated prior to MP

Revenue Code Amendment Act 2018

423 Government Land Allotment for Shajapur Solar Park

Table 43 provides details of the land allotment for Shajapur Solar Park which took place between May

2017 and Jun 2019

Table 43 Dates of Government Land Allotment for Shajapur Solar Park

Timeline

Allotment Letter

Number

Area

Allotted

Villages

26-05-2017 03A-19(3)2016-2017 14991 Dehripal Parsula Kadula MalyaHedi Burlay Jaawdi

Bhandedi Saagdiya Baandahedi Peepalkheda Dopada

Bijana Kheriyaema Kumhariyakhas Dangicha Jaaman

11-12-2017 26A-19(3)2016-17 618 Dehripal Parsula Favka Jaavdi Burlay Chooma

Bijnakhedi Dhatravada

26-05-2017 02A-19(3)2016-17 320969 Kukdeshwar Baamniyakhedi Bordi Khakri Majhniya

Rehli Rulki Dhanda Pidoniya Goyla Aakya Chauhani

Palsaavad Son Desrapur Khokriya Tonk Hanoti

28-06-2019 03A-19(3)2019-2020 8809 Kukdeshwar Bamniyakhedi Bodi Khakri Majhaniya

Rehli Rulki Tanda Pindoniya Goyla Aakya Chauhani

Palsawaad Son Besrapur Khokriya Tonk Hanoti

Total 117697

Source RUMSL

117697 Ha is allocated to the project over 2017-2019 and 108888 ha was allocated prior to MP

Revenue Code Amendment Act 2018

43 Review of Previous Community Consultations for Allotment of Government Land

The summary of the review of the timeline of the government land allotments in FPIC villages is provided in Table 44

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha Resolution

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Allotment prior to

Nov 2018

Amendment

67819 Ha 5106 Ha 108888 Ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

After Nov 2018

Amendment

28979ha 76077 Ha 8809 Ha

Total government

land in Ha

96894 Ha 127137 Ha 117697 Ha

Was the government

land allotted in FPIC

Villages pre or post

Nov 2018

Amendment in MP

Land Revenue Code

Government land allotted in

Badi and Kawai was prior to

Nov 2018 Amendment in MP

Land Revenue Code

Government land allotted

from Ladwan was on 20th

Jun 2019 which is after

Nov 2018 Amendment in

MP Land Revenue Code

Government land allotted

from Parsula was on 26th

May 2017 and 11th Dec

2017 was prior to Nov

2018 Amendment in MP

Land Revenue Code

Was Gram Sabha

resolution required

for FPIC villages

Yes No Yes

Thus as per legal provision (see section 31) the allocation of government land in BadiKawai from Neemuch Solar Park and Parsula in Shajapur Solar Park required a resolution of their respective Gram Sabha and an NOC by Gram Panchayat ERM did not get access to documentation of community consultation as part of seeking NOC from Gram Panchayats Conversation with Sarpanch of villages with ST population revealed that consultation was restricted to Gram Panchayat members Though they were initially reluctant to sign on the NOC after persuasion of District Collector they finally signed It is significant to note that the demarcation of the allotted land took place only recently (Jun to Aug

2020) and the construction process has not started yet13 The FPIC process in compliance to IFC PS-7 requirement is planned to be carried out prior to the construction works of these Solar Parks

13 The process for purchasing private land through consent process has been started in Neemuch

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

An overview of field visits and community engagement is provided in Section 12 above This section

provides details of the consultation carried out with affected STs in the process of preparation of this

FPIC Approach Paper The process involved following three steps

Step-1 Disclosure of intention of conducting FPIC process with affected STs in villages with

significant ST population

Step-2 Disclosure of final solar park boundary and key environment and social impacts (covered

in ESIA) and Participatory Rural Appraisal exercises with affected STs and meeting potential

representatives

Step-3 Identification of ST Representatives and formation of ST Committees and build mutual

agreement between them and RUMSL on Discussion and Decision Making Framework

The Step-1 was carried out in Dec 2019 and Jan 2020 The Step-2 was carried out in Aug 2020 The

details of the process followed during each of these steps are described in sub-sections below

Note The Step-3 is planned to take place in first week of April 2021 and the Draft Discussion and Decision Making

Framework described in Section 83 will be updated accordingly

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020)

The concerned Gram Panchayats identified with STs Population in previous sections were contacted

to inform them about the overall project and intention to conduct a FPIC process involving affected ST

families along with ESIA process The process included preparing a project profile in Hindi (See

Appendix A-B and photo documentation in Appendix C) and handed this over to the elected

representatives of concerned Gram Panchayats These meetings were attended by local RUMSL

personnel The project overview was explained during the meeting and their queries answered

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 51 below

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Badi 1 Sarpanch of Badi Village

2 Kalam Singh (Traditional Head

of Bhil Community in Mama basti)

3 Government Teacher in Bhil

Community

10-12 men from the village

6-7 women from ST (Bhil)

community

5th of December

2019

Kawai 1 Ghasilal (Ward Member in

Kawai Village)

2 Local communitypeople of

Kawai Village

20-25 persons from Kawai

Village were present

4-5 women

6th of December

2019

512 Disclosure of Intention to Conduct FPIC Agar Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Agar Solar Park

The details of the people contacted during this stage is provided in Table 52

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided-

Number of other community

members present during the

meeting

Date of the

Meeting

Ladwan (two

villages covered-

Ladwan and

Kerwa Khedi)

Mohan Singh (Sarpanch for

both villages)

10 persons in Ladwan and

Kerwa Khedi each

No female members were

present in Kerwa Khedi

In Ladwan seven (7) women

members were present in an

FGD that largely included

women

19th December

2019

Repeat visit on

29th January

2020

513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 53

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park

Name of Gram

Panchayat

Name of Person to whom Project

Information Sheet was Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Parsula Since there was no Sarpanch or

Gram Panchayat member present

during meeting one project

information sheet was provided to the

entire community which was

circulated within everyone present

during the consultation and signature

of 1 person from group (Mr Sujit

Singh) was taken

~15 persons in Parsula

Shajapur were present during

consultation also one separate

consultation was held with

women group having ~10

participants

30th January

2020

One common feedback during the consultations undertaken with the community in general and STs in

particular was they were not aware about the solar park boundary to judge which land will be used by

Solar Park and what will be left out for them The ESIA process was working on avoidance and

minimization measures Therefore they were informed that once the boundaries are fixed by the

design team the details will be shared with them

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises with STs (Aug 2020)

The solar park boundaries were finalized and provided to ERM in the last week of June 2020 by the

design team The draft environment and social impact assessment was completed in the month of

Aug 2020 The field-based activities remained suspended from Mar to Jun 2020 due to strict

restrictions imposed on travel and group activities due to Covid-19 pandemic Therefore the next

round of information disclosure and community consultations took place only in Aug 2020 at the time

of the RAP survey

Meeting Sarpanch and a few available Panchayat members

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village level Introductory amp Project disclosure meeting

PRA exercises with STs and information collection for IPP

- livelihood resource mapping

- mapping of social relations and influence and

- village profile

Identifying prominent persons from STs as potential representatives in FPIC process

Understanding the traditional decision-making system and existence of IPOs through key-

informant interviews

The schedule of field visits carrying out these activities is provided in Table 54 and details of these

activities are provided in subsequent sub-sections

Table 54 Site visit Dates and Site Activities

Solar Prak and FPIC Village

Date Site Activities

Agar Solar Park- Ladwan Village

06082020 Visited Ladwan and contacted Patwari Sarpanch and Panchayat Secretary and Fixed a Project Disclosure Meeting (a common meeting including all communities) for next day

07082020 Village level Project Disclosure Meeting at Ladwan

Participatory social mapping and information collection for IPP

Preliminary discussion with 2 Bhil families

08082020 ERM team met Sarpanch of Parsula to brief him and fix a meeting on 10th Aug

ERM team collected land details and village revenue map from Patwari of Ladwan

Shajapur Solar Park- Parsula Village

10082020 ERM team met Sarpanch and a few Panchayat members at Parsula

Shared Project Disclosure note and fixed a meeting with Bhil households of Parsula on 11th Aug

Mapping of social structure of Parsula village and village profiling

11082020 PRA exercise with Bhil community of Parsula resource mapping at Parsula mapping of social relations and influence

Discussion on impact of the Project on grazing land

Understanding the internal decision-making system amongst Bhil

Identifying prominent persons among Bhil families

12082020 Travelled to Neemuch Site from Agar

Neemuch Solar Park- Badi and Kawai village

13082020 Meeting with Sarpanch Badi and sharing of the Project Disclosure Note with Badi community (including all communities)

Social and resource mapping with Bhils in Badi

Understanding the internal decision-making system among Bhils at Badi

Identifying prominent persons among Bhil families

14082020 PRA at Mama Vasti Badi Resource mapping at Badi and Mama Vasti

Filling of village profile form for Badi and Kawai

Discussion on Impact of the Project on grazing land

Understanding the internal decision-making system at Kawai

Mapping the list of tribal leadership in village

Introductory visit to Kawai and sharing of Project Disclosure Note

15082020 PRA at Kawai with Bhil households

Identification of village leaders for Bhil of Kawai

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village)

5211 Meeting with Sarpanch

ERM team met Sarpanch of Ladwan Gram Panchayat at his residence in Karwakhedi village It was

learnt that Ladwan GP had submitted a letter to District Collector earlier expressing their unwillingness

to give away the government land for Solar Park The key concerns of the villagers included

Whether government has gone ahead on issuing tender for the Solar Park site Especially

without replying to their concerns

Whether the land identified by GP for establishing a Gaushala (shelter for abandon and old cows)

is allotted to the proposed Solar Park

How would the Solar Park address long term un-employment and livelihood issue in the village

ERM informed on its intention to conduct FPIC process covering the ST families in Ladwan village

and some of these questions will be answered during a structured process of discussion

5212 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch

Ladwan consists of two revenue villages Karwakhedi and Ladwan The Gram Panchayat office is at

Ladwan and the current Sarpanch is from Karwakhedi The village is dominated by the Gujjar

Community that is the second largest community in terms of population Scheduled caste is the

largest social group of village comprised of Banchhda Charmkaar Balai and Beldar

A community meeting was held where the Talati (village land revenue officer who keeps the land

records) was present The Talati informed them on the status of land allocation for the Solar Park

ERM showed the map showing the optimised project boundary with khasra numbers of the allotted

land ERM team informed them on the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The community expressed their

key concern about the impact on their livestock which forms an integral part of their livelihood

Community Meeting at Ladwan Explaining potential impacts and benefits

5213 PRA Exercises with STs

ERM held a meeting at a settlement cluster (nai-vasti or new settlement) where STs and SCs lived A

general discussion on their village history and livelihood issues were discussed The participation

level in this discussion was good A cross section of people from various age-groups and gender

participated in this discussion and shared relevant information and expressed their opinion A

separate meeting was held with women too (see Photos below)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

According to the elders of the Bhils their generation is the 9th generation residing in Ladwan village

Prior to the three families (Gujjar Bhil and Charmakaar) establishing this village the village had

Muslim population in medieval times and they deserted the village as some epidemic broke out Three

people from Gujjar Schedule Caste and Bhil community first came from another village and settled in

the village As time passed other families from Banchada-Nat Sondhiya Balai and other started

settling in the village

The discussion also involved their religious and cultural practices and shrines There are three

Chabutarascaffold in the village which are their main place of worship There are two shrines ie

Gowal ka Devta close to the grazing lands and Nagdevta adjacent to the new colony outside the

village

A village corner meeting with men Participation of women in group discussion

The Shrine of Nag Devta at Ladwan Meeting with women at Ladwan

After the general PRA exercise involving a larger group a few active participants were picked up to

have more focused discussion on a few aspects Through participative discussions in these smaller

groups the social hierarchy and livelihood resources used by STs (and SCs living in the village) were

mapped

Creating the map of social hierarchy and influence The map drawn by community showing their

livelihood resources

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Social Groups and Influence Map

Most of the families in Ladwan have cattle that includes cow buffalo and goat Approximately 650 cattle that includes 450 cows and 200 buffalos exists in the village There are about 44 cows kept by Bhil households which is about 4 (on an average) cow per family Bhil households own about 100 goats which is about eight (on an average) goats per family Only one family (Chander Singh) owns two buffaloes Few individuals work as grazier for a cluster of houses and are paid 150 per cattle per month by the owners of cattlersquos The cattle owners hire women and youths for bringing fodder feeding and cleaning of cattle sheds collecting cow dung Payment is done on the monthly basis or the basis of hours of work The common land situated at the Right hand side of the main approach road to Ladwan village from Agar is used by the ST community for grazing their livestock ST families bring fodder firewood and fruits from the same portion This is the only place during rainy season where fodder is available for four months as rest of the area is under crops ST families cannot accesses any other commons which is encroached by the dominant familiescommunity According to the ST community if the village commons is taken by solar park then they do not have any option but to sell their livestock as they cannot afford to buy fodder for the livestock unlike the richer families in the village

Free grazing of a mixed herd of cattle and

buffaloes

A grazier bringing back cattle home at evening

5214 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 55 Names of Potential Representatives in Ladwan Village

Section of Representation Sl No Name of Representative Contact Number

Clan Representative 1 DevSingh-Kanhayialal

2 Mangushanker-Amar Singh

Gujjar

Sondhiya

Other OBC

SC

Bhil

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of Representation Sl No Name of Representative Contact Number

Youth Representatives 3 Babulal-Gangaram

4 Anandilal-Lalsingh

Traditional leader or Mukhia 5 DevSingh-Kanhayialal

522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village)

5221 Meeting with Sarpanch

The ERM team for this field visit was led by the IPs Expert comprised of four members including a

woman to facilitate participation of women The ERM team first met the Sarpanch of Parsula who was

not present in initial meeting held earlier in January 2020 The objective of this meeting with Sarpanch

was to share the project information with him and appraise him of the intention of the ERM team to

hold a meeting and participatory appraisals with ST families

5222 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch The Disclosure note had a map showing the

optimised project boundary with khasra numbers of the acquired land It included the key potential

environment and social impacts and what mitigation measures are proposed in ESIA report prepared

by ERM

5223 Joint Site-visit with Sarpanch and Other Leaders

Sarpanch wanted to visit the proposed project site along with the Patwari to explain him the project

boundary based on the land allotment records available with him ERM team facilitated a site visit by

Sarpanch Naib Sarpanch and Kotwar in presence of Patwari to explain him the proposed project

boundaries He shared his observations and concerns over the allocation for the Solar Park which is

used for grazing domestic livestock by villagers including ST households However he agreed to

facilitate an exclusive meeting with ST families next day

5224 PRA Exercises with STs

The Kotwar of Parsula village belongs to ST community He played a significant role in inviting the ST

families to participate in the meeting as well as shared crucial information on their social and cultural

aspects The meeting with ST families included approximately 40 people both men and women from

various age-groups ERM team showed them the map of Solar Park and explained them locations of

key components The community was divided into two to three groups to hold participatory

assessments

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments

Site visit with Sarpanch and explaining Project boundary

Participatory mapping of livelihood and natural resources within Project boundary

Community meeting with ST from Parsula village at Project site

Identification of a medicinal plant during site walk through

Facilitation of discussions with ST women from Parsula village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gwalon-Ka- Mandi within Solar Park Boundary

Grazing lands used by Bhils Mapping

Rajputs are the dominant caste in the village and a person from the Rajput community is the Patel

(traditional leader) of Parsula village Rajputs control all village resources including sources of drinking

water and the irrigation

There are four religious places (Devsthan) of Bhils in Parsula village At all these places the priest is

from the Bhil community One platform is situated within the land allocated to the Project which is

called Gwalon ka Mandi It is recognised by all the community as the women worship at this place to

have good rains for better crop yield or agriculture Community gatherings are organized at this place

on few occasions in the year

The Bhil households reported to own about 2-3 (maximum 10) cows on an average per family and

about 2-3 goats Some families manage to sell three to five goats in a year ₹3000 to ₹ 8000 per

goat depending on the quality of the goat Families who rear cows manage to sell about 4 to 6 litre of

milk ₹40 per litre to private dairy at Chouma village The Bhil community uses the lsquoBirdirsquo hillock

adjacent to the northern side of the Parsula village for grazing their livestock along with other

communities residing in the village

5225 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 56 Names of Potential Representatives in Parsula Village

Section of

Representation

Sl No Name of Representative Contact Number

ClanHouse Cluster

Representatives

1 Meherbaan Singh 7970187292

2 Goverdhan Sigh 8718098704

3 Rahul 9098266244

4 Maakan 6162432391

5 Dheeraj Singh 8871384373

6 Rambabu 9752340827

7 Ballu 9399263367

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Sl No Name of Representative Contact Number

8 Bheru 7725027924

Youth Representatives 9 Kamal 6267658647

10 Rajesh 9009278550

Woman Representatives 11 Payal NA

Traditional leader or

Mukhia

12 Bhawanlal NA

523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages)

5231 Meeting with Sarpanch

Gram Panchayat Badi has 3 villages namely Badi Kawai and Sucharoki The ERM team met

Sarpanch of Badi on 13th Aug 2020 and explained the intention of holding meetings with ST families to

inform them about the FPIC process He advised that we should brief the community members on the

current status of the project first As most of the ST families work as wage labour he advised the

team to come early in the morning He assured to inform the ST families and ask them to cooperate

5232 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for a sample

Hindi version and Annexure-D for sample English version) to Sarpanch and other people present in

the meeting The Disclosure note had a map showing the optimised project boundary with khasra

numbers of the acquired land It included the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The meeting was held at the

center of the village

The community believes that Badi village is 1150 years old calculated based on the date inscribed on

a stone slab in the oldest house in the village It is a common belief that Bhil community came to the

village along with Rajputs The living memory of the community members goes at least six

generations back Badi has ~300 households and there are ~80 ST households Rajputs are the most

dominant community in the village Brahmins and Gujjars also influence the decisions of the village

Gujjars are the largest social group of the village followed by Bhils There are around 30 Muslim

families and they also have some influence on decision-making of the village Apart from Gujjar there

are three other OBC groups that are Sutar Kumhar and Nath

The STs live in three separate habitation clusters The first is in the main village habitation second is

roughly around 05 kilometres away and is called Khari ka Jhopda The third is located further away

around 25 kilometres Both are not connected through roads and one has to walk to reach them The

third habitation is further away where a group of recent migrants form Jhabua (referred as Mama Bhils

by villagers) live and is referred as Mama Basti These Bhil families came here to work as labourers in

the stone mines almost two decades back

At Kawai a meeting with village elders was held prior to discussion with ST families Rajput Gujjar

and Dhakad are the three dominant castes There are only 17 Bhil households in Kawai village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village disclosure meeting at Badi Meeting village elders at Kawai

5233 Site-visit and Walkthrough

The ERM team walked through the site to visit different clusters of ST settlements in Badi and Kawai

Some of the photographs of the main village and satellite smaller settlements where STs live is

provided below

A typical ST house in Badi main settlement The Platform where STs hold their community

meeting

The Khari ka Jhopda Mama Vasti

5234 PRA Exercises with STs

As ST households were found scattered in several small satellite settlements multiple meetings were

held involving a small group of 7 to 12 participants Every ST settlement or cluster of households

usually has a platform under a tree which is used for community meetings and decision making This

space was used for holding PRA exercises Participants were engaged in conversation on their social

relationship and decision making process The understanding gained from these discussions were

then demonstrated in diagrams They were asked if the diagram portrays the right picture or not

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Livelihood and resource mapping in Badi A smaller cluster level meeting at Badi

The village livelihood resource mapping- Kawai Participatory process of understanding

livelihood resources in Kawai

The social relationship and influence map for

Kawai

The social relationship and influence map for

Badi

Similarly a map of the village and surrounding area was created using the information shared by

participants in these meetings They were asked to show where they carry out their livelihood

activities such as farming and grazing etc They were asked to indicate those areas and identify

natural resources or cultural sites located in those locations

Some of the information important for deciding on the FPIC approach collected from these participatory

exercises are as follows

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gram Panchayat Badi has total 16 wards out of which Badi has 9 wards Out of these 9 Wards 2

are reserved for the STs (Bhil)

There are about 250-300 cows kept by Bhil households which is about 4 (on an average) cow

per family Bhil households own about 450 goats which is about 5-6 (on an average) goats per

family Hence for ST families goat is a more popular livestock than cows

Almost all the houses have used locally available stone in constructing the walls of the houses

Pucca houses have used cement and sand as mortar whereas kuchha houses have used mud

The communities fear the loss of access to these stones will make house construction costly and

people who earn from stone quarrying will be impacted

The traditional leader (Mukhia) of Bhils decide on disputes related to marriage and other social

issues Women do not play an active role in decision-making process

Each household cluster of Bhil households have a number of cultural sites where local deities are

worshiped For example in Khera-ka Majra has four cultural sites Ghadiya Bheruji Bhut Maharaj

Bhut Babaji and Dungri Balaji Similarly there are a few cultural sites for goddesses like Leva ki

Mata and Dahana Mataji are located within the Project boundary In all these shrines the priests

belong to Bhil community

STs (Bhils) worship Devnarayan Khejara Mata and Sawria jee in Nimbaheda in Rajasthan The

religious leaders from these places are held with respect and are accepted as mediators or

decision makers for important matters

5235 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table 57

They will be considered for nomination to the representative committee and contacted for capacity

building on FPIC process

Table 57 Names of Potential Representatives in Badi and Kawai Village

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Clan Tola

Representative

Badi Main 1 Gheesalal-Nathulal 9575486482

2 Basantilal-Mangilal 7354345531

3 Motilal-Hiralal 9109003022

4 Nanalal-Ratanlal

Khaira Ka Jhopda 5 Lalu ndashRamlal

6 Tulsi-Devilal

7 Tawarlal-Vardaji

Kawai 9 Ramlal-Hajarilal

Ratanlal

Bherulal(Teacher)

Bherulal- Bhawani

Shantilal

Fargulal

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Youth

Representatives

Badi 10 Omkaar ndashKailaji 8718057436

11 Shyamlal-Mangali 9302086906

Mama Vasti 12 Dinesh ndashThawar Singh

13 Prakash-Ramesh

Woman

Representatives

Badi 14 Kesarbai-Devilal

15 Kavita-Dhanraj

Mama Vasti 16 Shanti-Ramesh

17 Mamta -Naklesh

Kawai 18 Sunder Bai-Bherulal

(Sudibai-Devilal Shimla bai-

Chandrulal LeelaBai-

Chittarmal Prem bai-Gopilal)

19 Kanyabai-Bhuvaniram

Traditional leader or

Mukhia

Badi 20 Bhawani-Laxmi

21 Amar singh-Ramlal 7354325923

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL

A key element in designing a FPIC Process is a mutually agreed and appropriate lsquoengagement and

consultation process14rsquo The lsquoFirst Draft FPIC Approach Paperrsquo was prepared and shared with RUMSL

for their review and comment A virtual workshop was held with RUMSL team on 27th Aug 2020 In

this workshop PS-7 requirements of ICP and FPIC in general and the specific FPIC process designed

for Solar Parks was presented and discussed After their feedbacks were incorporated the lsquoDraft

FPIC Approach Paperrsquo was shared with IFC-WB for review and comments

The objective of these internal discussions are to build an internal institutional consensus on the

appropriateness of the designed engagement and consultation process to comply with the

requirements under IFC PS-7 The subsequent steps for consultations with affected STs and finalizing

a mutually agreed lsquoDiscussion and Decision Making Frameworkrsquo is discussed in Section 81

14 GN-ampGN22 emphasizes to have a shared view of the FPIC process between Project proponent and affected IPs The Project

proponent and affected IPs to agree on an appropriate engagement and consultation process as early as possible and commensurate with the scale of impact and vulnerability of the communities

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INDEPENDENT FACILITATOR AGENCY

6 INDEPENDENT FACILITATOR AGENCY

61 Need for FPIC Process Facilitation Agency

An independent agencyexpert to facilitate the FPIC process is required for the following reasons

There is a strong likelihood of other dominant communities in the village intervening and trying to

influence the internal discussion and decision making by IP The presence of the FA will help

documenting such attempts of external intervention and the presence of the FA may act as

deterrence and help avoid such attempts to interfereinfluence the process

The IP representatives need an intensive process of orientation and capacity building It will be

more effective if this is conducted using the Malvi dialect instead of Hindi Therefore a good

community facilitator with familiarity on Malvi dialect will be helpful

The women and youth will need capacity building and facilitation of their internal discussions prior

to the community level meetings

The facilitation support to IP community in general and IP representatives in particular will require

proficiency in the local dialect Malvi and knowledge of local livelihoods and alternative options

Involvement of a local agencyexpert who also speaks the local dialect and with a good

understanding of local livelihoods (particularly grazing and livestock keeping) will demonstrate

fairness and transparency in the process

62 Screening of FPIC Process Facilitation Agency

ERM identified Institutions (Universities Government Departments and Research Institutes etc)

NGOs and INGOs located and active in Madhya Pradesh state After a preliminary screening selected

potential individualsorganizations were approached to find out their availability and willingness for the

assignment The criteria used for screening included qualification profile affiliation with the type of

institutionsorganizations nature of worksprojects completed working experience with IPsTribes in

Madhya Pradesh conducting meaningful consultation community mobilization and stakeholder

engagement familiarity with World Bank Group safeguardsrsquo policies and procedures comfort with

written and spoken English and local dialects etc The list of independent experts and organizations

screened for the role of facilitation agency is provided in Table 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

1 University of MP Bhopal

Department of Sociology

Dr Arvind Chauhan

Professoramp Head

7999345226

Two candidates with post-PhD and PhD

qualifications from Department of

Sociology interested in working but having

no experience were not considered

2 Dr BR Ambedkar

University MHOW MP

Professor RD Maurya

Former Dean amp Head

Department of Sociology

Old AB Road Gram

Dongargaon Dr

Ambedkar Nagar Madhya

Pradesh 453441

07324 274 377

The retired Professor amp Dean

recommended a college lecturer

belonging to BhilIP from Govt college

Neemuch may be considered as a

resource person in future as appropriate

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

3 Tribal Research and

Development Institute

Bhopal

Rita Singh

35 Shyamla Hills Rd

Bhopal Madhya Pradesh

0755-25570882551257

This institute of MP government is

involved in administration and research

aspects of tribes in Madhya Pradesh

There are full time staff and the person

required for the assignment is not

available However the Government

functionaries may be the resource persons

in sharing information and performing

advisory roles during implementation as

appropriate

4 Institute of Social

Sciences Ujjain

Dr Tapas Faculty

7342510978

Berasiya Rd Navi Bagh

Bhopal Madhya Pradesh

462038

0755 273 0946

The faculty suggested to contact the

Bhopal based NGO (Samarthan)

5 The Samarthan NGO

Bhopal

Shradha kumar

Bhopal Madhya Pradesh

shrdhasrigmailcom

9826912948

The Program Director reported no work

being undertaken by the NGO in proposed

project area and was reluctant to

undertake the assignment She however

mentioned to help coordinating with the

local NGO if available in Neemuch area

and has not responded so far

6 Xavier Institute of

Development and Action

and Studies Jabalpur

Dr Mehul Chauhan

Former Faculty

9977064882

The former faculty suggested two NGOs

(Concept Society and Gramodyog

Sansthan)

7 The Concept Society

Indore

Ms Hemal Kamat Director

9425350272

The candidate appeared for interview has

preferred to be engaged independently

instead of as a NGO

8 Gramodyog Sansthan

Mandala MP

Mr Hariom Shukla

Manager

7999064147

Even after agreeing no one finally

appeared for personal discussion and

interview

9 Balram Sewa Samaj

Neemuch

Mr Kamla Shankar

Manager

7838960968

The only NGO reported to working on

legal aspects in Neemuch area has not

expressed interest to work as FA

10 UNICEF office Bhopal Nagesh Patidar Project

Officer WASH

97525 98212

The staff of UNICEF suggested the name

of suitable candidates and all of them

have appeared for interview and have

expressed the interest in proposed project

work

11 Debate Trust (Referred

by Action Aid Bhopal

Amitav Singh and Leena

Singh

Debate Trust

Duplex C-22 Alkapuri

Near DRM Office

Habibganj Bhopal-462024

Action Aid India had prepared a brief

manual on FPIC (published in 3 Indian

Languages including Hindi in 2018)

reflecting the Indian context and its related

legal system The manual was intended to

help CSOs for their ready reference and

larger reach out Mr Narendra Sharma

who was based in Actionaidrsquos office at

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

0755-2985007 0755-

2417656 9425018144

9425004556

debateindiagmailcom

Bhopal played a key role in preparing the

Manual in Hindi version

Mr Narendra Sharma referred the NGO

Debate Trust who had experiences in

working with Panchayats

A screening using preferred criteria was undertaken of the shortlisted agencies and details are

available in Appendix-F None of these agenciesindividuals have worked for a FPIC process earlier

Hence an agency which was available and willing to undertake the activity was taken on a trial basis

to help in conducting PRA exercises and sample household survey required for preparation of IPP

63 Roles and Responsibility for FPIC Process Facilitation Agency

The role and responsibilities of the FPIC FA will be as follows

Table 62 Roles and Responsibilities of FPIC FA

Phase Responsibilities

I Formation of local committees with STs Representatives

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Hindi (Malwi dialect) Translation of TDPIPP and designing Information sharing tools

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs (particularly women and youth groups) and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation of the FPIC Process and Preparation of FPIC Process Report

Documents of outcome of the FPIC Process including FPIC AgreementMOUJoint Statement of PrinciplesAgreed Mitigation Plans etc

64 Terms of Reference for FPIC FA

The terms of reference for FPIC FA covering villages to be covered specific responsibilities

deliverables personnel requirement and organizational profile and experience is provided in

Appendix-G

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The PS-7 recommends to have a lsquoshared view15 of achieving ICP or FPICrsquo mutually agreed ldquoFPIC

Decision Process Framework Documentrdquo which is based on principles of Good Faith Negotiation

(GFN) The Designing a lsquodiscussion and decision making frameworkrsquo to achieve the FPIC as per GN

on PS-7 should considers the socio-political context within which the affected IPs households live as

well as impacts of the Project This section deals with key-elements considered for designing the

FPIC process as per requirements in IFC PS-7 and GN-7

71 Use of Language

The PS-7 emphasizes use of the IPs language in the FPIC process It was found that BhilsBhilala in

Ladwan and Parsula are relatively small community and they have been living with close socio-

cultural ties with other communities Hence they use Bhilli (their traditional language) very little The

proficiency of the current generation in the Bhilli vocabulary is too limited to use this in discussion of

the Project and its impact Hence their preference is the use of local (Malvi) dialect of Hindi which

they speak along with other communities in the village The Bhils in Badi and Kawai speak Malvi

dialect with some influence of Rajasthani language as it is at the border of Madhya Pradesh and

Rajasthan

In general the written material on the project is expected to be in Devnagri script using the vocabulary

consistent with Malvi dialect to the extent possible The FPIC FA will have community facilitator who

is conversant with Malvi and explain the written material using the conversational Malvi dialect

72 Use of Customary Decision Making Process and Traditional Leaders

The Bhils in Ladwan reported that they resolve disputes between families through intervention of the

elderly member of the familyclan (Baijwal and Dalodia) or go to other prominent people in the village

such as the priest in the local temple or the landlord on whose land they work The customary leader

of Bhils who covered a cluster (~10 to 12) of Bhil settlements existed earlier (at least 3 generations

back) and the current generation has not sought their help in dispute resolution in their living

memory

The BhilBhilala of Parsula belong to a number of clans (Dalodia Paretia Renkewal Vasunia etc)

and the elder member of the clan is usually approached to resolve any internal disputes There used

to be a collective council (panchayat) covering 5 to 10 villages but these have been non-functional

over the years They also approach the village Sarpanch and prominent personalities from other

communities in the village to resolve disputes involving land and livestock The matters related to land

are finally referred to the Tehsildar (land revenue officer) for resolution The local administration also

plays a significant role in resolving inter-community disputes

In Badi-Kawai they still have a traditional Mukhia (leader) who wields influence in community

matters Each Bhil village has an elder who is considered the mukhia or leader There are designated

places where elders hold community meetings to discuss conflicts among Bhils and matters related to

their social norms and customary laws governing marriage and inheritance etc If matters are not

resolved at the village level community elders (Biradari Panchayat) then the matter is escalated to a

forum of community elders from 5 or 10 villages with Bhil population The highest level of escalation in

the customary decision making system is to refer the matter to a Biradari Panchayat of community

elders from 25 Bhil villages16 These traditional leaders residing outside of the villages directly

impacted by the Project are accommodated as member of the proposed Mediation Committee

15 Refer GN-7 GN22 which mentions that lsquothis should ideally be done through a framework document or plan and client should

document support for the agreed process from the affected population 16 GN-7GN36(i) acknowledges that there may be circumstances where formal and informal leaders of the Indigenous Peoples

reside outside of the Projectrsquos area of influence

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

In general the affected IPs communities use familyclan elders to resolve minor disputes and involve

prominent people from other communities like the priest Sarpanch or other prominent personalities in

the village for resolving their conflicts The matters related to land is resolved by intervention from

local administration (Tehsildar and District Collector) If the matters are related to their customary laws

on marriage social relationship or inheritance the unresolved matters can be escalated to a council

that comprises of elders from 5 10 or 25 villages The traditional Biradari Panchayat has been losing

its power as the younger community members considers their decisions regressive and approach

Gram Panchayat leaders (Sarpanch) or take help from the Police and Court of law Considering the

preference of new generation to go to non-ST Gram Panchayat leaders and local administration they

are considered for the Mediation Committee

73 Promoting Participation of Women and Youths

Women specifically stated during consultation that they do not participate in decision making in their

traditional community meetings which are convened for resolving disputes Though the women come

to attend the community meetings they hardly ever participate and express their views

The BhilBhilala youths do not have traditional or customary forums at which they express their views

They accept the decisions taken in the family or at the clan-level However there are a few educated

young people in the village who have distinct views about their future

As free expression of the views by youths and women in BhilBhilala community meetings is not a

social norm separate meetings of these groups where they are able to express their views openly is

proposed as part of their internal decision making process The FPIC FA will facilitate these separate

meetings and keep external interventions in these meetings to the minimum The views expressed by

them in these meetings should be tabled in joint meetings of the community for consideration

74 Expectation on Material Information Prior to Discussion

It is understood from the preliminary round of discussions with ST communities that they expect the

following information to be shared with them

Details of the Project (lay-out plan) and the related activities that are going to be implemented

Schedule of starting of the possession of allotted government land and purchase of pattaprivate

land

Details of land khasra numbers proposed to be taken for the project

Amount of paymentcompensation consideration amount of the land and assets (including on the

government land) that will be taken by the project

What economic and other entitlements and benefits will be provided to the families dependent on

the allotted government land

If private land is purchased then they will lose the source of income generation or livelihood (as

they are hired for a year on contract basis daily wages take land on lease for cultivation and

take care of the cattlersquos etc) what will their entitlements (economic package) be

What options will the Government or the Solar Park Company provide as alternative to the

common grazing land as cattle and goat breeds they keep require free open grazing and not stall

feeding

What alternative livelihoods will be offered to those Bhil families who will be landless after losing

the governmentpatta land they currently use (though owned by others)

It was expressed that the Project proponents share many documents but the community wants

confirmation that the content is authentic Hence community expects that signed and verified

documents should be shared as part of the FPIC process which can be referred in case of conflict or

contradiction

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The relevant information is scattered in ESIA RAP and IPPIPDP A concise information disclosure

dossier will be prepared by ERM and used by FA during the FPIC process

75 Need for Capacity Building of IP Representatives

The interaction with potential ST representatives from these FPIC villages shows that convening a

community meeting and steering the internal discussion to reach consensus will be a new experience

for them Most of them are semi-literate and will face challenges in understanding the Project details

on their own such that they can then explain it to other community members Therefore following

activities are required

A capacity building workshop for the potential IP representatives to explain the Project its impact

and mitigation measures in the Draft IPPIPDPTDP in detail Although the RAP-LRP disclosure

will happen at the community level and ST families will attend those meetings the Draft

IPPIPDPTDP will also explain these entitlementsbenefits in simple language

Presence of experienced community meeting facilitators (from FPIC FA) for community meetings

will help these ST representatives to have focused discussions documentation of views

expressed and decisions made in those meetings

The women and youths usually do not participate in taking decisions on community issues

Hence the women and youth representatives need orientation through separate sessions

In addition to formal trainingorientation sessions the IP representatives may be taken on

exposure visits to nearby solar parks for improving their understanding

76 Need for a Mediation Mechanism

The ST Committee will hold meetings with the representatives of the Project (RUMSL) to discuss

relevant points and reach a mutual agreement While such discussions are likely to result in reaching

mutual agreements on a number of agenda items the discussions may hit dead-end on some issues

All such unresolved issues will be documented as a dissent note for their reconsideration in the second

round of meeting

If the discussion between ST Committee and the representatives of the Project on any significant issue

reaches a deadlock the matter will be referred to a mediation mechanism The mediation will be done

by a high level committee which will comprise of 4 members

An IP representative nominated from the larger tribal leadership of the area (from their customary

council of 10 or 25 villages) but not belonging to the Project village

The elected representative of the concerned Gram Panchayat or a person nominated from GP

and acceptable to the ST Committee

A senior officer from the District Tribal Welfare Department

District Collector or an officer nominated by them

This Mediation Committee will be constituted at the beginning of the FPIC process and will be activated

only in the case of a significant deadlock This Mediation Committee will be involved to read the Final

FPIC Agreement (even when no matter is referred to them for mediation) and satisfy themselves that it

reflects mutual agreements reached through a fair and credible process17

17 This is proposed in order to provide an external validation of a free and fair FPIC process prior to signing of the FPIC

Agreement

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

77 Following Principles of Good Faith Negotiation

Good faith negotiation generally involves 6 principles (see Table 71) The proposed FPIC Discussion

and Decision Making Framework (DDMF) adheres to these principles with slight modifications

keeping the public health concerns associated with the Covid-19 pandemic

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

1 Willingness to engage in

a process and availability

to meet at reasonable

times and frequency

Both parties need to agree to avoid large gatherings and un-necessary

physical meetings A mechanism for tele-consultations will be explored to

keep the physical meetings to the minimum

The internal discussion meetings of STs will be in smaller groups (in the

open rather than in closed rooms) to avoid large gatherings

There will be two meetings between RUMSL and ST Committee and

similarly number of proceedings by Mediation Committee will be limited

The meeting schedules will be finalized beforehand and Covid-19 public

health protocols as applicable at that time will be followed

2 Provision of information

necessary for informed

negotiation

The basic information on the Project and its potential environment and

social impacts are already provided in state language (Hindi)

The essential information requirement by ST Committee is identified and

these information will be provided in simple information dissemination

tools The FA will further explain them for their better understanding

3 Exploration of key issues

of importance

The likely key issues of importance are grazing and cultural sites located

within Solar Park boundary A small task-force comprising of

representatives of RUMSL as well as ST Committee will carry out a field

inspection prior to their first meeting The task force will observe Covid-

19 protocols issued by Government

4 Mutual acceptable

procedures for the

negotiation

The lsquoDiscussion and Decision Making Frameworkrsquo signed by both parties

will have a commitment to hold all meetings and activities complying the

Covid-19 protocols and advisory issued by Government

5 Willingness to change

initial position and modify

offers where possible

The first meeting will resolve issues where both parties can reach

agreement easily The positions of both parties on contentious issues will

be recorded during first meeting The FPIC FA will record the written

positions of both parties on these contentious issues and share with

them The FPIC FA and ERM will hold separate meetings with both ST

Committee and RUMSL Team after 15 days to understand any changes

in the stated position The FPIC FA and ERM will take a decision on

holding the second and final meeting on these contentious issues when

both parties agree to modify their offers and a meaningful discussion is

possible

6 Provision for sufficient

time for decision making

The ST Committee will benefit from the capacity building and assistance

through FPIC FA to conclude their internal decision making The first

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

meeting between ST Committee and RUMSL Team will be held after a

sufficient gap As the number of ST families participating in the FPIC

Process is small it is expected that it will not take them long to reach

internal consensus However STs will be encouraged to have more

meetings internally to be able to discuss within themselves

78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and Supportive Environment

In these FPIC villages the Project requires to achieve both ICP for mainstream communities and

FPIC for ST The existing and past relationship between RUMSL and affected communities plays a

significant role in FPIC process It is learnt from the news report as well as from consultations that

some villages (particularly Ladwan) have decided to protest against the Solar Park as loss of grazing

land is not acceptable to them The protesters had organised a demonstration and also submitted

letters to the District Collector regarding their objections Ladwan village has a strong network of

women self-help groups (SHGs) who are interested in a dairy development program Thus reduction

in grazing land is perceived by them to have a detrimental impact on their long term employment

opportunity and income generation These SHGs have members from SC OBC as well as ST

families

In other FPIC villages ie Parsula Badi and Kawai though there is a concern for loss of grazing

land yet opposition to Solar Parks is passive There are some specific interest groups among the

non-ST communities who would seek answers to their specific concerns For example in Parsula

village the non-ST families (both in Parsula as well as neighbouring villages) have informally

purchased the patta land Their main concern is whether and how they get the compensation for

these land parcels which will be paid to patta owners In Badi and Kawai the number of people who

have encroached on the government land is comparatively more Also there are few influential

people who earn from selling stones (the most popular building material in that area) extracted from

the allotted government land Thus a range of RAP-LRP issues are expected to crop up during

community engagement In all these villages the affected ST communities though would consider

the compensation and benefits offered to them yet it would be difficult for them to disregard the

collective decisions made by other communities in their village

Thus considering different interest groups involved existing social relationship influence of STs in

decision making it would be a challenge to hold a single engagement process18 for both STs and

mainstream communities Therefore we recommend a parallel or concurrent engagement process for

ST and mainstream (non-ST) communities The comparison of the ICP process for mainstream (non-

ST) and FPIC process for ST is provided in Table 72

18 GN-7 GN31 recommends a single engagement process complying to the higher standard (GFN and FPIC Agreement) where

a Project requires to achieve ICP for mainstream and FPIC for IP It reads ldquoSince the achievement of ICP and FPIC as separate processes with different groups within a community or between proximate communities may be difficult and in some cases be a cause of division within the community a single engagement process resulting in one agreement is generally recommended In such cases the process and agreement should reference the higher standard (ie GFN and agreement demonstrating FPIC) Whether the agreement entails different benefits for the differently affected groups will depend on the project context the Affected Communities and the nature of project impactsrdquo

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages

Aspect Engagement Process with non-ST

(ICP)

Engagement Process with ST (FPIC)

Management Plan ESMP + RAP-LRP IPPIPDPTDP

Representative

Body

Gram Panchayat (existing body) ST Committee (specifically constituted for

this process)

Provision of

information

necessary for

informed

negotiation

Executive summary of Draft ESMP

RAP-LRP in Hindi

Abridged Draft IPPIPDPTDP in Hindi (use

of Malwi vocabulary as much as possible)

Capacity building by FPIC FA

Help from FPIC FA to understand issues

Willingness to

engage in a

process and

availability to meet

at reasonable times

and frequency

One public meeting for receiving

feedback on Draft ESMP RAP-LRP

One round of internal discussion by STs

assisted by FPIC FA

Two rounds of meetings between RUMSL

and ST Committee

Mediation Committee meetings (if required)

Exploration of key

issues of

importance

Key issues covered in ESIA RAP-LRP

will be discussed

Key issues covered in Draft IPPIPDPTDP

will be discussed

Mutual acceptable

procedures for the

negotiation

Informal agreement A formal lsquoDiscussion and Decision Making

Framework Agreementrsquo is signed by both

parties

Willingness to

change initial

position and modify

offers where

possible

Demonstrated through incorporations of

feedbacks received from public

disclosure and consultation

Structured engagement process

documenting (signed by both parties at the

end of the meeting) points agreeddisagreed

and demonstrating the flexibility in their

respective positions

Provision for

sufficient time for

decision making

The time for public meeting for

receiving feedback will be decided in

consultation with Gram Panchayat

Sufficient time for capacity building by FPIC

FA internal discussions and gap between

first and second meeting between RUMSL

and ST Committee

Outcome The public meeting for receiving

feedback on Draft ESMP RAP-LRP is

held peacefully and satisfactory

explanationresponse to

feedbackqueries is provided

Incorporating response to all key issues

raised in public meeting in Final ESMP

RAP-LRP

The Final IPPIPDPTDP incorporates points

mutually agreed between RUMSL and ST

Committee

The FPIC Process Documentation Report-

(vetted by independent FPIC FA and

Mediation Committee) provides an overview

of the FPIC process

FPIC Agreement signed by RUMSL and ST

Committee

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Note The FPIC Process Documentation Report prepared by FA under ERM guidance will cover the

whole process (including all meetings by ST and Non-STs decisions key issues discussed etc)

The use of impacted land for free grazing is practiced by both ST and Non-ST communities The ESIA

and RAP-LRP also address impacts on grazing and have prepared a framework for Grazing Resource

Management Plan The engagement with non-ST population will highlight the mitigation measures

with regard to grazing issue (particularly Grazing Resource Management Plan) in ESIA and RAP-

LRP The feedback from non-ST population on mitigation of impact on grazing will be subsequently

incorporated into Grazing Resource Management Plan in particular and relevant sections in ESIA and

RAP-LRP The non-ST population will be clarified that TDP will have some additional benefit for STs

and therefore will be consulted separately

Thus the separate ST committees will not be perceived to take any decision that affects collective

interest of all villagers particularly the powerful non-ST communities The Gram Panchayat and

Sarpanch is provided a place in Mediation Committee and will be involved in resolving key-issues

referred to them

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

81 Introduction

This lsquoDraft Discussion and Decision Making Framework19rsquo is prepared after field visits and

consultations with affected STs and a workshop with RUMSL (see Section-5 for details) This Draft

DDMF will be shared with ST Committees on behalf of RUMSL and after appropriate modifications

(without diluting the key-elements for compliance to PS-7 requirements) the final version will be

signed by representatives of both parties Section 814 provides subsequent steps in this regard

The three proposed solar parks are located in three different Districts and each one will have an

independent Solar Park Developer (SPD) or Concessionaire The impact of each solar park and the

social context of the affected STs also differ in these three locations Hence three ESIA reports as

well as three IPPIPDPTDP are prepared The Draft IPPIPDPTDP prepared for each Solar Park has

a specific package of benefits for the STs in FPIC villages This will be discussed during the proposed

FPIC process and the outcome of this process will be a written lsquoFPIC Agreementrsquo that adopts the Draft

IPPIPDPTDP and agrees to cooperate in its implementation

82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo

The subsequent steps for discussing this Draft Discussion and Decision Making Framework with STs

in the selected FPIC villages (grouped at each Solar Park level) is discussed in this section

821 Appointment of FPIC Facilitation Agency and Orientation

The requirement of a FPIC Facilitation Agency (FA) and their roles and responsibilities are discussed

in Section-6 above The FA will play a key role in forming the ST Committees (at each Solar Park

level) and informing them on their rights to FPIC their legal rights on natural resources prior to their

acceptance of this lsquoDraft Discussion and Decision Making Frameworkrsquo Hence one of the agencies

screened for this role will be appointed and brought on board

After on-boarding them ERM will carry out their orientation by holding a series of virtual workshops with

them The orientation program will include the following

The ICP and FPIC requirements as per IFC PS-7 and WB OP 410

Key findings of the ESIA-ESMP including Draft RAP-LRP

An overview of consultations in FPIC Villages

The Draft IPPIPDPTDPs

The Draft Discussion and Decision Making Framework

The Capacity Building of ST Committees on FPIC and their customary rights on natural

resources

822 Introducing FPIC FA to RUMSL and FPIC Villages

After the orientation of the FPIC FA the key persons will be introduced to the RUMSL team through a

physical meeting Subsequently a field trip will be planned to introduce the FPIC FA in FPIC villages

The RUMSL and ERM will introduce the FPIC FA to the contact persons from earlier field visits and

inform them about their role

19 The term lsquoengagementrsquo and lsquonegotiationrsquo was avoided to keep the language less confrontational and positive for both parties

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

823 Formation of ST Committees

ERM and FPIC FA will jointly discuss the structure and composition of the ST Committee at each

Solar Park20 with affected ST community As per suggestions from them ST Committees will be

formed and their nominations will be ratified through a group meeting21 The composition of the ST

Committee is described further in Section 8311 below

824 Capacity Building of ST Committees

The FPIC FA will discuss with the ST Committee on the time and venue for holding a capacity building

workshop The capacity building workshop will cover the following

The recognition of FPIC as their rights

Specific provisions of FPIC as per IFC PS-7 and WB OP 410

Applicable India Laws and recognition of their customary rights on natural resources

The Draft Discussion and Decision Making Framework (Draft DDMF)

The participation of RUMSL in this capacity building workshop will be optional and as per mutual

agreement by both parties The FPIC-FA will note down the suggestions of the ST Committee on the

Draft DDMF and share them with RUMSL

83 The Draft Discussion amp Decision Making Framework

The proposed discussion (engagement) and negotiation (decision making) framework will include 11

steps as illustrated in the Figure 81 below

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process

These steps are described in sections below

20 Agar and Shajapur Solar Park have only one FPIC village Hence the ST Committee will be selected from within the same

village Neemuch Solar Park has two FPIC village with several satellite ST habitations The ST Committee for Neemuch Solar Park will be larger to accommodate representation of different ST groups 21 The FPIC village level group meetings will be held keeping the Covid-19 public health guideline ERM will use professional

judgement on the acceptability of the selected committee for most ST households if the ratification of the ST Committee is not possible by a large public meeting

Formation of Committees

Acceptance of Draft Discussion and Decision Making

Framework

Disclosure of Draft IPP to ST Committee

Explaining Draft IPP to ST Committee

Internal Consultations by ST Committee

First RUMS and ST Committee Discussion

Second RUMSL and ST Committee Discussions

Reference to Mediation Committee

(if any)

Informing Community about Draft FPIC

Agreement

Final Community Meeting for Expression

of ConsentDissent

FPIC Agreement Signing

FPIC Process Documentation Report

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

831 Formation of Committees

The FPIC process will involve three committees for each Solar Park One representing the affected

ST community the other presenting the Project proponent (RUMSL) and the third a committee to

mediate between the two if the need be The composition of these committees are explained in sub-

sections below

8311 Formation of ST Committee for each Solar Park

Each Solar Park will have a ST Committee which includes representatives from all FPIC villages of

that Solar Park Each ST Committee will comprise of 7 to 13 members (or any odd number22) who

represent different sections of the ST community The principle for selecting the members of this ST

Committee will be as follows

One representative from each clanhabitation cluster (tola)

The clans which have more population may select 2 representatives

Two representatives from youths (18-25 years)

Two women representatives

One traditional leader (Mukhia) or ST community head from each FPIC village

Gowal (cow-herder) who takes othersrsquo cattle for grazing and earns livelihood from this

The ST Committee will select a chairperson to coordinate and conduct their internal meetings The

representative from the youth and women will hold separate group discussions within their sub-groups

and share their concerns preference and feedback The FPIC FA facilitating these internal meetings

will ensure that these points are tabled at the joint committee meetings The ST Committee will

prepare a list of households and the adult members (gt18 years) who will be part of the FPIC process

8312 Formation of RUMSL Teams

RUMSL will form three site level teams (one for each Solar Park) which will include the District

Renewable Energy Officer (DREO) of the concerned district and a staff member to assist him They

will report to RUMSL Managing Director (MD) The names and designation of the RUMSL Team are

as follows

Level Designation Name Contact Number

Head office MDCEO Deepak Saxena

Social Development

Specialist

TBD

Site Level (Agar) DREO Deepak Bulani +91-9229924836

DREO- Staff TBD

Site Level (Shajapur) DREO- Prakash Salunke +91- 9926440877

DREO- Staff

Site Level (Neemuch) DREO- Sohanlal Bajaj +91-9827222217

DREO- Staff Balaram Rathod +91-9827323612

22 To avoid a deadlock on decisions

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The site level RUMSL Team will attend the meetings with ST Committee discuss the issues raised by

them sign on minutes of meetings and report to MD where prior approval is necessary The MD or

his authorised representative will take part in important meetings including meetings with the

Mediation Committee if required

8313 Formation of Mediation Committee

There will be a Mediation Committee for each Solar Park The Mediation Committee will comprise of

three members which will be chaired by the District Collector

Member Selection Process

STs Representative from the

Area Biradari Panchayat

The ST Committee after internal discussion will nominate a prominent person of their community outside of their village who is accepted as a member of Biradari Panchayat or similar bodies

Member from Gram

Panchayat

The ST Committee will nominate a member (or ex-GP member) who is known for his role in resolving local disputes

District Tribal Welfare

Department

A senior Tribal Welfare officer will be nominated by District Collector or the Head of Department of Tribal Welfare

District Collector (or his

representative)

The District Collector of the district within which the particular solar

If District Collector is not available she should decide on who can act as his representative

The ERM FPIC-FA ST Committee and RUMSL Team jointly visit these MC members and brief them

on their role in FPIC Process The formation of the MC should be completed prior to the first meeting

between ST Committee and RUMSL Team

832 Acceptance of Draft Discussion and Decision Framework

After the capacity building of ST Committees FPIC FAERM will coordinate with both parties to fix a

date and time for a joint meeting to discuss the Draft Discussion and Decision Making Framework and

ratify it after making necessary modifications

The composition of the committees mentioned in Section 831 and the steps mentioned in Figure 81

will be explained to ST Committee during their capacity building process (described in Section 824)

A Hindi (with Malwi words used to the extent possible) version of the lsquoDraft Discussion and Decision

Frameworkrsquo (Section 83) will be provided to ST Committee during the capacity building Thus the

affected IPs will get adequate time to discuss and come prepared for any suggestions from their side

to this meeting The

Both parties will discuss on a code of conduct commit to follow this during their meetings The code of

conduct will be based on following principles of good faith negotiation

(i) both parties will be available to meet at reasonable time and frequency

(ii) both parties to share information23 necessary for informed negotiation

(iii) both parties will be willing to change initial position and modify offers where possible

23 The Project will disclose information as per Information Disclosure Plan discussed in Section 513 of the Draft

IPPIPDPTDP The disclosure will include at minimum (i) project boundary (ii) impacts of the project (iii) entitlements and other benefits The information will be shared in a culturally appropriate manner and in a form and language easily understandable to the ST communities The FPIC FA will help the ST community understand and process this information prior to the joint meetings with RUMSL

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

(iv) both parties will give each other reasonable time24 for decision making

(v) both parties will put their view peacefully and will not resort to violence and threat and

(vi) both parties will not engage in discussion when they are under influence of any intoxicants

Both parties will discuss and agree on the quorum required for their meetings and how proceedings of

their meetings will be documented Some suggestions for discussion in this regard are

(i) The quorum for the meeting to be physical presence (or virtual participation) of at least 75 of

the ST Committee and RUMSL Team The FPIC FA will check the quorum of the meeting prior

to starting the proceedings

(ii) The Documentation Assistant in FPIC FA will have the responsibility to record the audiovidoe

of the meeting proceedings

(iii) The FPIC FA will write down the key decisions taken during the discussion and the MoMs will

be read out prior to taking their signature

(iv) The FPIC FA will ensure that ST Committee and RUMSL Team understand the decisions made

If any party express that they need more time (to discuss internally or take approvals) such

information will be recorded

(v) The FPIC FA will also document any dissent expressed by any individual member while

supporting the collective decision of the group she represent in the MoM

The agreed Discussion and Decision Making Framework will have a target time-frameschedule for

completion of each step in the FPIC process Both parties will put their best efforts to complete the

process within t(his time-frame ERM will keep a track of the progress of FPIC process as per this

time-frame and help both parties to avoid unnecessary delays FA will draft the Agreement on Final

Discussion and Decision Making Framework (in Hindi) in consultation with RUMSL and ST

Committee

The final (after ratification) lsquoDiscussion and Decision-making Frameworkrsquo the FPIC-FA will hand over a

signed copy to both parties (ST Committee and RUMSL Team) A pamphlet or poster on accepted

code of conduct will be prepared and displayed at the meeting venue FPIC-FA will request all

members attending the meeting to follow these rules

833 Disclosure of Draft IPPIPDP to ST Committee

ERM will prepare Draft IPPIPDPTDP (in English) for each Solar Park A Summary Draft IPPIPDPTDP

will be translated to Hindi (with use of Malwi as much as possible) ERM will share following documents

to both parties as soon as they ratify the lsquoDiscussion and Decision Making Frameworkrsquo

The Draft IPPIPDPTDP (in English)

Summary Draft IPPIPDPTDP25 (in Hindi)

A simple 4-6 page brochure describing (illustrations where possible) the benefit package

proposed in Draft IPPIPDPTDP

The ST Committee members will be given one week to go through the documents shared with them

and fix a date to explain the Draft IPPIPDPTDP Report

The RUMSL will be provided soft copies of these documents to upload them in their web-site from

where external stakeholders can access these documents

24 The time provided should be adequate to read verify and consult (internally or any external expert on the subject matter)

The FPIC-FA will consult both parties to decide what is reasonable and acceptable to both 25 The Summary Draft IPPIPDPTDP will be 20-25 page It will follow the structure of the IPPIPDPTDP but provide a non-

technical description of the content for easy understanding by ST Committee

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

834 Explaining Draft IPPIPDPTDP to ST Committee

ERM and the FPIC-FA will organize a workshop for ST Committee of each Solar Park at a suitable

location on an agreed date (at least after 7 days from sharing of the documents with ST Committee

The workshop will explain the impacts of the Solar Park and the range of mitigation measures and

project benefits mentioned therein

The FPIC-FA will orient them on how to hold consultations with different sections within their

community and document their views The ST Committee will be provided adequate copies of the

brochure describing the benefit package project boundary maps (in large flex prints) to help them

explain the Solar Project to their community members and hold internal discussions

ERMFPIC-FA will consult ST Committee and RUMSL Team to fix the date for first meeting between

RUMSL and ST Committee

835 Internal Consultation Process by ST Committee

FPIC-FA will help each ST Committee to prepare a tentative schedule for internal discussions The

women representatives will hold meetings with women and youths representatives will hold meetings

among young people The FPIC-FA will make itself available to facilitate and document these internal

meetings

After a round of internal discussion of each sub-group the ST Committee will have the final meeting

to discuss the comments and concerns raised by different sub-groups of the community The ST

Committee will finalize a list of issuesdemands for further discussion with RUMSL The FPIC-FA

prepare the Agenda for First RUMSL-ST Committee Meeting and share it with RUMSL at least a week

before the meeting

The Agenda of the first RUMSL and ST Committee will be shared with the Mediation Committee to

keep them informed about the initiation of discussion between both parties

836 First RUMSL and ST Committee Meeting

The FPIC-FAERM will confirm the quorum prior to starting the proceedings The points mentioned in

the Agenda circulated earlier will be taken up for discussion The RUMSL Team will respond on these

pointsissues The ST Committee will consider these responses and decide if they are satisfied Once

the discussion is concluded the FPIC-FA will write-down the decision made with respect to the

specific Agenda items If any additional points to be discussed by any party those points will be

discussed at the end of the meeting with mutual agreement The FPIC-FA will document the

proceedings of the meeting as per the Discussion and Decision Making Framework (see section 832

above)

If all issues are resolved through discussion in this meeting then another round of discussion is not

required If there will be unresolved issue they will be included in the Agenda for the second meeting

While preparing the Agenda for the second meeting FPIC-FA will record the positions of both parties

with respect to these un-resolved issues The Agenda for the second meeting will be prepared listing

these unresolved issues with an appendix stating the views of each party on these unresolved

issues

RUMSL Team will brief about the mutual agreements and unresolved issues listed for second meeting

with their MD and seek approval if required The ST Committee will similarly brief their community

members on what is agreed after they return

The FPIC FA and ERM will prepare a Draft FPIC Agreement (in Hindi) reflecting the points of mutual

agreements and dissents if any The Draft FPIC Agreement will be shared with both parties

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

837 Second RUMS and STs Committee

The second and subsequent meetings between RUMS Team and IPs Committee will be held on

points where both parties do not agree and it requires further discussion ERMFPIC-FA will consult

both parties to reconsider their views and think about solutions acceptable to them Once ERMFPIC-

FA see both parties are prepared for the next round of discussion date for the second meeting will be

fixed

In this second round of meeting it is expected that a few more points will be mutually agreed The

Draft FPIC Agreement will be updated mentioning these points on which there are mutual agreement

and points of dissentdisagreements

Although it is expected to resolve all issues in two rounds of discussion there is a possibility of

additional rounds of discussion Both RUMSL and ST Committee will discuss on additional meetings

and decide a mutually agreed time-frame to complete the on-going discussion process

If both parties feel canrsquot be resolved through further discussions they will decide if the issue should be

referred to the Mediation Committee or set aside for discussion at a later date26 ERMFPIC-FA will

check if both parties are committed to accept the decision of the Mediation Committee and take the

final decision in consultation with both parties

838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee (MC)

If all issues are resolved through mutual discussion between the RUMSL Team and ST Committee

the Draft FPIC Agreement will be forwarded to MC of the respective Solar Park The MC will be then

requested to be available to chair over the final community meeting (see 8310) to measure the

consent expressed by affected ST in FPIC villages

The MC of the respective Solar Park will consider any issue which was not resolved by mutual

discussion between ST Committee and RUMSL Team and referred to it with an understanding that its

decision will be acceptable to both parties The FPIC-FAERM will hand over documentation of

previous discussion related to the issue and stated positions of both parties with respect to the matter

under consideration to MC

The MC will convene a meeting where it hears the arguments from both sides After considering views

on the matter from both sides MC will offer a solution for consideration If the MC thinks they need to

consult subject experts they will inform both parties and reconvene the meeting after they have

obtained views from such subject experts

Both parties if required will be given time (not more than a week) to consider the resolution offered by

the MC and come back with their final views

After considering the views of both parties on the solutions offered by it the MC will give its final

decision on the matter The MC will try making its decision on consensus and if it is not possible the

decision will be on majority Both parties will be bound by this final decision pronounced by MC The

final decision by MC will be incorporated into the Draft FPIC Agreement

839 Informing Community on Draft FPIC Agreement by ST Committee

The FPIC-FA will provide the Draft FPIC Agreement to the ST Committee The ST Committee

members will inform community members in smaller the sub-groups on the decisions taken during

FPIC discussion with RUMSL The ST Committee will explain their decisions on each issue and ask

26 Particularly matters which are uncertain or may happen in future These issues can be listed as unresolved issues to be

monitored by an agreed mechanism and discussed later

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 80

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

each adult member of the community to attend the final community meeting to voice their views and

acceptreject the Draft FPIC Agreement

8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and Ratification of Final IPP and FPIC Agreement

The ST Committee will take decision to hold the final community meeting to express their

consentdissent and fix a date after consulting RUMSL and MC members It will invite RUMS Team

and Mediation Committee to participate and witness the expression of consentdissent by affected

STs

FPIC-FA will ensure that all households in the community are informed about this meeting at least 7

days in advance FPIC-FA will prepare the list of all adult members with support from ST Committee

The IPs Committee will take the responsibility of the invitation and FPIC FA will monitor and document

the process The quorum for holding the final community meeting of affected ST families will be as

follows

Presence of at least 50 of the affected ST families in FPIC village

Presence of at least 60 of the total adult members of these affected ST families

Presence of at least 33 of the total adult women members

Presence of at least 33 of the total youths (between 18 and 25 years)

The FPIC-FA will coordinate with ST Committee members representing women and youth to ensure

that these quorum requirements are met during the final community meeting

The FPIC-FA will set-up a mechanism for recording the presence of eligible ST adult members and

hand over a copy of the Draft FPIC Agreement as they arrive at the meeting venue The Mediation

Committee will preside over this final community meeting The FPIC-FA will inform MC if quorum

requirements for the meeting is achieved After verifying the quorum required and the people

gathered for the meeting are from the affected ST households from FPIC villages the MC will initiate

the meeting proceeding

A representative from RUMSL Team will read out the agreed points mentioned in the Draft FPIC

Agreement and request for their acceptance A representative from the ST Committee will express

their views on points of mutual consensus as well as any unresolved issue that will be discussed and

resolved at a later stage of the project

The MC will then provide opportunities to ST community members present in the meeting to express

their views ST Committee will facilitate community members to express their opinions and

suggestions

The MC will consult with RUMSL and ST Committee if any additional points of agreement and dissent

to be incorporated in the Draft FPIC Agreement After confirming their final positions request the

community members present in the meeting to express their consentdissent and ratifyreject the Draft

FPIC Agreement

The consentdissent will be expressed by raising hands when the members of the Mediation

Committee puts the proposal of ratification to vote If more than 75 of the community members

attending this meeting votes in favour of the Draft FPIC Agreement it would be regarded as

expression of collective consent

The MC will inform the assembled community members about the outcome of the voting and if Draft

FPIC Agreement is ratified or rejected After the Draft FPIC Agreement is ratified by a collective

expression of consent the ST Committee members and RUMSL Team will sign the Final FPIC

Agreement This Agreement will be counter signed by members of the Mediation Committee as

witnesses

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The IPs community may be allowed to carry out any customary ritual on the day of the completion of

the FPIC process and express their support to the proposed Project This FPIC Agreement will be

taken up for implementation and a monitoring committee will oversee its effective implementation

8311 FPIC Process Documentation Report

The FPIC-FA will prepare a FPIC Process Documentation Report summarizing each stage of the

FPIC process It will hand-over all audio-visual records of the FPIC process The process document

report will cover all stages of the FPIC process documenting the following

Process of identification of STs ST representatives and decision-making authorities

Process of assessment of capacity of ST representatives to undertake good faith negotiations

Summary of any capacity building undertaken

Agreed engagement and negotiation framework (including the process undertaken to agree upon

the framework)

Summary of consultations meetings engagement undertaken as part of the FPIC process and

Opinion of FPIC-FA on the process and outcomes

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to

complete the FPIC process

84 Tentative Time-line

The Phase-I FPIC activities was scheduled to be held in Apr 2021 Due to the outbreak of second

wave of Covid-19 in Apr 2021 the field activities are suspended The decision to initiate these

activities will be taken once Covid-19 second wave gets over The schedule for Phase-II activities to

will be discussed with ST Committees of the three Solar Parks and will be decided accordingly As the

progress of FPIC process requires cooperation from affected ST community and the level of

cooperation varies in these three Solar Parks Hence the schedule for Phase-II FPIC activities will be

updated in discussion with respective ST Committees while finalizing the Discussion and Decision

Framework with them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Section Activity Month-1^ Month-2 Month-3 Month-4 Month-5

821 Appointment of FPIC FA and Orientation

822 Introducing FPIC-FA to RUMSL and FPIC Villages

823 Formation of ST Committees

824 Capacity building of ST Committees

8313 Formation of Mediation Committee

832 Acceptance of Draft DDMF

833 Disclosure of Draft IPPIPDPTDP to ST Committee

834 Explaining Draft IPPIPDPTDP to ST Committee

835 Internal Consultation Process by ST Committee

836 First RUMSL and ST Committee Meeting

837 Second RUMSL and ST Committee Meeting

838 Refer Unresolved Matters to MC

839 Inform Community about Draft FPIC Agreement

8310 Final Community Meeting for expression of ConsentDissent

8311 FPIC Process Document Report

Phase-I Activities

Phase-II Activities

Activities to start and complete

OptionalConditional Activity

^ The commencement of these activities will be determined once second wave of Covid-19 gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW

IN THE STATE OF MADHYA PRADESH INDIA

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

85 Responsibility Matrix

The FPIC process will require a collective effort and coordination between ERM RUMSL ST

Committee Mediation Committee and the FPIC FA The roles and responsibilities of these entities are

described in Section 82 and 83 above ERM will play an active role in coordination and provide

information required for a meaningful discussion The key responsibilities and accountabilities are

summarized below for clarity

Activity ERM FPIC-

FA

ST-

Committee

RUMSL-

F

RUMSL-

HO

Mediation

Committee

IFC-

WB

Formation of ST Committee S P P A

Formation of RUMS Team P A

Formation of Mediation

Committee

P P S P A P

Acceptance of Discussion

and Decision Making

Framework

S P P P A C C

Disclosure of Draft IPP to ST

Committee

P S S A C A

Explaining of Draft IPP to ST

Committee

P S

Internal consultation process

by ST Committee

S P P

First RUMSL and ST

Committee Meeting

S P P P A

Second RUMSL and ST

Committee Meeting

S P P P A

Mediation Committee

Proceedings

P P P S P P

Informing Community on Draft

FPIC Agreement by ST

Committee

S P P A

Final ST community meeting-

expression of consent

dissent

S P P P A A C

FPIC Process Documentation

Report

P P S S S S A

P= Primary Responsibility S= Secondary Responsibility C= Must be Consulted A= Approval

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

PROJECT INFORMATION DOCUMENT SHAJAPUR SOLAR PARK

Background

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) The primary objective of RUMSL

is to develop and facilitate the development of large-scale solar projects in the State of Madhya

Pradesh In line with the governmentrsquos ambition to boost solar power in State RUMSL is developing

Solar Park of capacity of 450 MW at Shajapur Madhya Pradesh

The World Bank had agreed to provide financial support for the Project International Finance

Corporation (IFC) is providing investment advisory services to Government of Madhya Pradesh to

develop the project on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards for the Project

Project Details

The proposed 450 MW Solar Park is located in two Tehsils ndashMoman Badodiya and Shajapur of

Shajapur District Out of 450 MW capacity 325 MW will be developed at Moman Badodiya tehsil

(termed as Unit 1 amp 2) and 125 MW will be developed at Shajapur tehsil (termed as Unit 3) of

Shajapur district Madhya Pradesh Almost 89 of the land area is Government land and remaining is

private land The salient feature of the Project are given below

Solar Park

The Solar Park will be developed as two units spread across these lands and the details of the same

ae captured in the table belowndash

Table A1 Details of Land parcels identified for the project Unit Number Area in ha Capacity Tehsil Villages

Unit 1 72048 220 MW Moman

Bododiya

Proposed to span 6 villages - Bijanakhedi

Burlay Chauma Dehripal Fawaka and

Parsula

Unit 2 105 MW Proposed to span Burlay Dhatrawada and

Jawadi whereas

Unit 3 26964 125 MW Shajapur

Tehsil

Hanoti Surajpur and Shajapur

Total 99012 450 MW

Land

Out of the total land requirement of 99012 hectares 86937 hectare is Government land 11074

hectare is private land and 1001 hectare is government patta land The Government land required for

the Solar Park which accounts for almost 89 of the total land required will be leased by the

government of Madhya Pradesh to SPPDs and the private land will be purchased from the land

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

owners for the development of Solar Park as per the prevailing laws and policies in the State of

Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP

Transmission Line

The transmission infrastructure is planned to evacuate power generated from the units to the STU

grid Each unit will have a 33200 kV internal pooling substation The internal pooling substation will

be connected to the proposed MPPTCL 220400 kV substation at Agar through 220 kV transmission

line For cost optimization the single circuit line from unit 1 will be laid till unit 2 towers and there on a

double line circuit of 220 kV shall be connected till the gird substation The Unit 3 internal pooling

substation shall be evacuated through single circuit 220 kV transmission line till the existing MPPTCL

220400 kV substation at Ujjain

The 33220 kV substation at each unit and 220 kV connectivity to the MPPTCL substation will be

developed by RUMSL MPPTCL will establish 220400 kV proposed grid substation at Agar in

connection with the existing 220400 kV MPPTCL substation at Ujjain Madhya Pradesh MPPTCL will

establish 220400 kV proposed grid substation at Agar along with the associated line till 400220 kV

Ujjain substation The solar project developer in the park shall be responsible for laying the 33 kV

cable and 33 kV ring unit as required at each unit to connect its plant to the 33220 kV internal pooling

substations

Road Infrastructure

The road infrastructure requirements is planned to access the Shajapur Solar Park Ms RUMSL shall

carry out road wideningrepairing of existing roads wherever required The road widening repairing of

existing roads is proposed for a length of 65 km which shall be undertaken by RUMSL The

development of internal roads within each unit shall be in the scope of individual Project Developer

Water Requirement

Water requirements for all purposes shall be met by digging bore-wells within each unit and shall be in

the scope of project developer Also the arrangement of construction water shall be in the scope of

contracting agencies and Solar Power Project developer

Common facilities planned

For 450 MW Shajapur solar park the utility area is proposed adjacent to the Unit 1 and Unit 3 -

33220 kV internal substation The other facilities such as RUMSL office fire-fighting equipment

telecommunication infrastructure medical dispensary etc will be located at the pooling substation

area

Project Implementation

The 450 MW Shajapur Solar Park will be implemented in a period of ~21 months

Operation and Maintenance

It is envisaged that different developers may occupy individual units and will be responsible for OampM

The operations and maintenance of common facilities provided like pooling substation intermediate

substations shall be undertaken by RUMSL

Environment and Social Impact Study and Management Plans

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Assessment (ESIA) of three solar parks including internal

evacuation infrastructure and associated transmission lines ESIA carried out for the project will meet

the requirements of Environment and Social Safeguard Policies and Standards of WB and IFC in

addition to applicable environmental and social regulations and policies in India and the State of

Madhya Pradesh

Based on final land footprint and georeferenced site boundaries of the project the ESIA will include a

Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) ERM will share relevant

information and consult with affected local communities to understand their viewsconcerns The

consultation will cover a wide range of people to take into account perspectives from different social

groups women and men young and old and seek their participation in mitigation of adverse impact

as well as enhancement of project benefits

As the project will impact a number of ST families ERM will assess impacts on them and prepare a

Tribal Development Plan (TDP) which will contain a package of proposed impact mitigation measures

and project benefits ERM will implement a Free Prior Informed Consent (FPIC) process covering

affected Scheduled Tribe population The negotiation process leading to obtain FPIC will be agreed

on with the affected ST communities

Free Prior Informed Consent (FPIC) Process for STs

The FPIC Process will be taken up for Surajpur Parsula and Jawadi villages of Shajapur Site for the impacts on tribal population in given villages on the land under traditional ownership and customary use The process will also involve any nomadic tribes who may have claims of using the project site for grazing their livestock and camping during their annual migration The FPIC process will be divided into two phases as described below

Phase What to Do When to Do

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Before inviting bids for solar parks by concessionaire

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Contacts

Further information and queries related to the project can be obtained from RUMSL site office in

Shajapur and head office at Bhopal The information is also available at website of RUMSL

(httpwwwrumslcom)

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

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wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT FPIC

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

NEEMUCH SOLAR PARK

Badi village Kawai Village

Mama Basti Badi village Bardawada village

AGAR SOLAR PARK

Ladwan village Bijnakhedi village

SHAJAPUR SOLAR PARK

Chauma village Parsula village

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

BACKGROUND

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) RUMSL is facilitating developing

Solar Park of capacity of 450 MW at Shajapur on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards (International Finance Corporation and World Bank) for the Project

Project Details The proposed 450 MW Solar Park is located in Moman Badodiya and South Shajapur tehsils of

Shajapur District collectively referred to as Shajapur Solar Park The Shajapur Solar Park will be

spread across 11 villages in Shajapur amp Moman Badodiya Tehsil of Shajapur District comprising the

villages of Burlay Jawadi and Dhatrawada (for Unit 6) Parsula Dehripal Bijnakhedi Fawaka

Chauma Burlay (for Unit 7) and Surajpur Lalpur and Hanoti (for Unit 8) The land required for 450

MW Solar Park including solar fields roads and transmission and distribution network is 9872

hectares The Shajapur Solar Park plot comprises of three non-contiguous land parcels

The solar park will have three (3) units It is understood that each unit will have a different developer

Unit 6 of 105 MW capacity to be developed on an area of 2461 hectares of Private and

Government land

Unit 7 of 220 MW capacity to be developed on an area of 4859 hectare and

Unit 8 of 125 MW capacity to be developed on an area of 2552 hectare

Land Requirement and Status The Solar Park will largely use GoMP land (approx 88) and the remaining land is either private

land or Patta land The Government land required for the Solar Park will be leased by the government

of Madhya Pradesh and the private land will be purchased from the land owners as per the prevailing

laws and policies in the State of Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th

November 2014 of Government of MP)

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

1 Burlay 237 00 64 00 00 00 301

2 Jawadi 322 00 20 00 00 00 342

3 Dhatrawada 1722 00 97 00 00 00 1819

Sub- Total (unit

6)

2281 00 181 00 00 00 2462

4 Parsula 1162 00 00 52 00 00 1214

5 Dehripal 1111 00 124 00 94 00 1329

6 Bijanakhedi 954 00 226 00 00 00 1180

7 Fawaka 171 00 02 00 00 00 173

8 Chouma 327 00 95 00 00 124 546

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

9 Burlay 417 00 00 00 00 00 417

Sub- Total (Unit

7)

4142 0 447 52 94 124 4859

10 Surajpur 227 07 182 00 00 00 416

11 Lalupura 497 08 00 00 00 00 505

12 Hanoti 1319 125 185 00 00 00 1629

Sub- Total (Unit

8)

2043 140 367 00 00 00 2551

Grand Total 8466 140 995 52 94 124 9872

Source Land Data provided by RUMSL 18th June 2020

Transmission Line Each Solar Park Unit will have 33220 kV substations and the power generated from each unit (Unit 6

7 and 8) will be pooled to the 220 kV switching pooling substation The utility area is proposed near

the internal pooling substation located at the Unit 6 and Unit 8

Road Infrastructure Access to Unit 6 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The existing village road has a width of ~4-5 meter and existing

State highways has a width of ~75 meter The road length of ~25 km will be strengthened and

repaired to suit the need during the construction phase

Access to Unit 7 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The road length of ~2 km will be strengthened and repaired to

suit the need during the development phase

Access to Unit 8 The Unit is connected with village road from Jhonkar to Hanoti at a distance 0f ~6

km from Jhonkar The existing road is a two-lane bituminous concrete road with width ~7-75 meters

and a new bituminous road with width ~75 meters and length ~500 meters is proposed to connect

33220 kV plant substation The road length of ~2 km will be strengthened and repaired to suit the

need during the development phase

Water Requirement The total requirement for water is estimated as 323 kL day Developers shall establish bore-wells per

block with required approvals and directions to meet their requirements The entire water supply

system including provision for bore-wells within individual blocks shall be in the scope of the Project

Developer The water requirement for the green belt is estimated to be 7000 litres per day

Common facilities planned The common facilities such as RUMSL office fire-fighting equipment telecommunication

infrastructure medical dispensary weather monitoring station etc will be located at the pooling

substation area located at the Unit 6 The operations and maintenance of common facilities provided

like pooling substation intermediate substations shall be undertaken by RUMSL Ms RUMSL will

establish two Weather Monitoring Station at internal pooling substation (at each unit)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Project Implementation

The 450 MW Shajapur Solar Park will be constructed a time frame of ~21 months with construction

proposed to started in November 2020

Project Impacts Benefits and Mitigation Measures

RUMSL will identify stakeholders and prepare a schedule for consulting them on a regular basis in

construction phase It will also establish a grievance redress mechanism through which local

community can register their grievances and seek redress to any adverse impacts on them The

project through its ESIA process has identified a range of potential impacts and has planned to

implement appropriate mitigation measures The key impactsbenefits and proposed mitigation

measures are discussed below for your knowledge and suggestions for making them more effective

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D1 Moman Badodiya Unit 6

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D2 Moman Badodiya Unit 7

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D3 South Shajapur Unit 8

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact from Land Acquisition

Type of land impacted How Impacts will be addressed

Private Land (Purchased through MP

Mutual Consent Policy 2014

Adequate compensation at twice the value of land and assets as

per MP Mutual Consent Policy 2014

Benefits of Resettlement Action Plan-Livelihoods restoration Plan

Preference to households (rendered landless or with sub-optimal

holdings) of the families post selling land to the project for

employment opportunitiessmall contracts in the

Constructionoperation phase

Pattta Land (Negotiated purchase

through MP Mutual Consent Policy)

Patta is being treated at par with ownership for the land

procurement process and would have same benefits as of private

land owners

Government Land Used for Grazing

easements cultural heritage sites

water sources fuel wood collection and

collection of other resources

Provision for alternate grazing land for cattle near the project

village or confirmation of adequacy of remaining grazing land

Development of community fodder lots in available unoccupied

government land may be explored and covered in Resettlement

Action Plan

Provision of easements shall be maintained in order to not sever

the access to CPRs for the community

Government Land Informally

occupied Capturedencroached for

agriculture or grazing prohibiting use

by other people

RUMSL shall serve a three months advance notice to the project

affected persons (PAPs) to harvest standing crops andor avoid

growing fresh crops

In case the advance notice is not given RUMSL shall pay

compensation for crops at full replacement cost

ImpactsBenefits in Construction Phase

Impact Mitigation Measures

Temporary occupation of land

for construction phase activities

such as Labour Camps Safety

Setbacks Storage areas

Parking areas Other

construction related temporary

land requirements etc

Adequate lease rents to the land owners

Restoration of land to its original state or better at the time of handing it

back to the owners

Compensation for the loss of livelihoods to the users of the land required

for temporary use as this will temporarily economically displace them

Community Health and Safety

including accident risks for

domestic animals

The Contractor shall prepare Traffic Management Plan Workers Code of

Conduct and Health and Safety Plan and implement it after approval of

RUMSL

Stress on Community resources

- Water and Roads

There will be a worker Code of Conduct defined by RUMSL that prevents

workers and contractors from using the local resources like water forest

The contractor shall be asked to use Tanker water supply during the

summer months which are dry months in which water scarcity issues are

reported by the community

Noise Nuisance and Dust Install enclosures around construction area in order to reduce the extent

of noise and dust

Limit construction related activities to day time

Employment and

entrepreneurship opportunities

during construction

The sourcing of local labour wherever possible will be obligatory for the

Solar Project Developers and sub-contractors

Employment of members of SC-STs and vulnerable households will be

at a minimum of 30 of total workers or person-days of employment

Engagement of local vendors to the extent possible for the goods and

services required for the project during construction phase

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact Mitigation Measures

The RUMSL will establish a mechanism to audit subcontractors and

suppliers with respect to compliance of utilizing local labour and

resources

Impacts in Operation Phase

Impact Mitigation Measures

Community Health and

Safety

Community engagement and sensitization sessions should be re-organised at

the beginning of Operations phase in order to mention about the new

developments in the area and provide an understanding of the precautions to

be taken for safety

Impact on Employment RUMSL shall ensure that the Solar project developers (SPDs) advertise the

roles of Technical staff required during operations phases in the local

newspapers to enable hiring of competent people from nearby areas to the

extent feasible

Preference shall be given (to the extent feasible) to hire competent members

from PAHs for semi-skilled jobs like housekeeping or Security Guards

Impacts on Vulnerable Sections Women and Scheduled Tribes

Impact Mitigation Measures

Impacts on Indigenous

Communities Vulnerable

Groups

To Prepare an Indigenous Peoples PlanTribal Development Plan with special

benefits for Scheduled Tribes

Recognizing their right to Free Prior Informed Consent process and its

implementation

As part of the stakeholder engagement ensure adequate representation and

participation of the Scheduled Tribes

Impact on Women A Gender Action Plan will be prepared for the Project to assess and mitigate

gender specific impacts

Ensure that the employment of women from vulnerable households is

prioritised for the project

Efforts are made to support development of women owned enterprises in the

area through the LRP from where procurement for project related may be

prioritised

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

Page 1

शाजापर सोलर पारक रा पररयोजना वििरण दसतािज़

पषठभवि

नवीन और नवीकरणीय ऊरजा मतरजलय क सहयोग स मधय परदश सरकार मधय परदश म जमीनी गरिड स रडी

सौर ऊजाा पररयोजना का गरिकगरसत कर रही ह रीिा अलटर ा मगा सोलर गरलगरमटड (RUMSL) का एक

सािाजगरनक उपकरम िरा 2015 म सथागरपत हआ ह यह उपकरम सोलर एनरी कारपोरशन आफ इगरडया गरलगरमटड

(SECI) तथा मधयपरदश ऊजाा गरिकास गरनगम गरलगरमटड (MPUVNL) क साथ सयकत उपकरम क रप म सथागरपत

हआ ह शाजापर सोलर पाका की कल कषमता 450 मगा िाट होगी और इस सौर ऊजाा पाका को गरनजी -

सािाजगरनक साझदारी क तहत गरनमााण गरकया जाना परसतजववत ह

रीवज अलटर ज मगज सोलर वलवमटड (RUMSL) दवजरज ईआरएम इवडयज परजइवट वलवमटड (ERM) को अतरााषटर ीय

मानको (अतरााषटर ीय गरितत वनगम एि गरिशवबक) क अनसजर सौर पजका क पयजावरणीय और सजमजवरक परभजव

मलजकन (ESIA) क सजथ सजथ पनगरिासथापन कजया योरनज (RAP) और सवततर रप स समदाय की पिा

सगरित सहमगरत (FPIC) परवियज क वलए अनबगरित गरकया गया ह

पररयोजना री परिख जानरारी

450 मगा िाट का परसतागरित सोलर पाका शाजापर गरजल क मोहन बड़ोगरडया और शाजापर तहसील क अतगात

शाजापर सोलर पाका क नाम स जाना जाएगा यह सौर ऊजाा पाका 11 गाािो क कषतर म बनगा यह 11 गााि इस

परकार ह बल जिादी और ितिादा (इकाई 6) पारसला दहरीपल बीजनखड़ी फिाका िौमा बल (इकाई

7) और सरजपर लालपर तथा हनोती (इकाई 8)

इस 450 मगा िाट सोलर पाका हत कल 9872 हकटर जमीन की आियशकता होगी गरजसम सोलर फीलड

सड़क टर ासगरमशन एि गरितरण नटिका शागरमल होगा पाका तीन अलग इकाईयो म गरिकगरसत होगा ऐसा

अनमान ह गरक परतयक इकाई का गरनमााण अलग-अलग गरनमााताओ दवारा गरकया जाएगा

105 मगा िाट कषमता िाली इकाई 62461 हकटर कषतर पर सरकारी तथा गरनजी जमीन पर गरिकगरसत

होगी

220 मगा िाट कषमता िाली इकाई 74859 हकटर कषतर पर गरिकगरसत होगी तथा

125 मगा िाट कषमता िाली इकाई 82552 हकटर कषतर पर गरिकगरसत होगी

Page 2

जिीन री सथिवि एि अविगरहण

सौर ऊजाा पजका लगभग 88 मधय परदश की सरकारी भवम कज उपयोग करगज और शष भवम यज तो वनरी यज

पटटज भवम रहगी सोलर पजका क वलए आवशयक रजरसव भवम मधय परदश सरकजर दवजरज पटट पर दी रजएगी और

वनरी भवम मधय परदश रजजय म परचवलत कजननो और नीवतयो क अनसजर भवम मजवलको स खरीदी रजएगी

(Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP)

कर

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सरर

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हकट

1 बल 237 00 64 00 00 00 301

2 जािादी 322 00 20 00 00 00 342

3 ितरािदा 1722 00 97 00 00 00 1819

योग (इराई 6 ) 2281 00 181 00 00 00 2462

4 परसला 1162 00 00 52 00 00 1214

5 दहरीपल 1111 00 124 00 94 00 1329

6 बीजनखड़ी 954 00 226 00 00 00 1180

7 फािक 171 00 02 00 00 00 173

8 िौमा 327 00 95 00 00 124 546

9 बल 417 00 00 00 00 00 417

योग (इराई 7) 4142 0 447 52 94 124 4859

10 सरजपर 227 07 182 00 00 00 416

11 लालपर 497 08 00 00 00 00 505

12 हनोती 1319 125 185 00 00 00 1629

योग (इराई 8) 2043 140 367 00 00 00 2551

Page 3

रल 8466 140 995 52 94 124 9872

सदभक रीिा अलटर ा मगा सोलर गरलगरमटड दवारा गरदया गया जमीन का डाटा 18 जन 2020

िासविशन लाइन

परतयक सोलर पाका इकाई क 33220 किी क सब सटशन होग तथा परतयक इकाई (6 7 8) स 220 गरकलो

िाट की ऊजाा सब सटशन एकतर गरकया जाएगा आतररक पगरलग सब सटशन इकाई 6 और 8 क समीम

सथागरपत करना परसतागरित ह

सड़र वनिाकण

इराई 6 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रोवक आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

गााि क रासत की िौड़ाई लगभग 4-5 मीटर तथा राजयमगा की िौड़ाई 75 मीटर ह सौर ऊजाा पाका क

गरनमााण हत 25 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 7 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रो की आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 8 िर पहाि

इकाई 8 िाम झोकर स 6 गरकलोमीटर दर िाम झोकर स िाम गरहनोती को जान िाली सड़क स जड़ी ह यह

रासता डबल लन डामर रासता ह गरजसकी लबाई 7-75 मीटर ह एक नई डामर रोड गरजसकी लबाई 500

मीटर तथा िौड़ाई 75 मीटर ह और जो 33220 किी क सब सटशन को जोड़न क गरलए बनाई जाना

परसतागरित ह सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया

जाएगा

पानी री आिशयरिा

यह अनमान ह की परगरत गरदन लगभग 323 गरकलो लीटर पानी आिशयकता होगी पानी की पगरता क गरलए ठकदार

दवारा परगरत बलॉक बोररग की रजएगी सौर ऊजाा पाका क गरनमााण क दौरान परतयक बलॉक क पानी की सपलाइ

की वयिसथा का परा खाका गरजसम बोररग करना भी शागरमल ह ठकदार अपन परसताि म द ग हररत पटटी क

गरलए परगरत गरदन अदाजन कल 700 लीटर पानी की आियशकता होगी

Page 4

सािानय सवििाओ री उपलबधिा

RUMSL का ऑगरफस अगरि शमन सटशन टली कमयगरनकशन (फोन) गरिगरकतसालय गरडसपनसरी मौसम की

जानकारी सटशन इतयागरद इकाई 6 क समीप पलीग सब सटशन पर सथागरपत हाागी पगरलग सबसटशन तथा

मधयमिती सबसटशन गरक तमाम सगरििाओ का सिालन एि दखरख RUMSL दवारा गरकया जाएगा RUMSL

आतररक पलीग सटशन पर दो मौसम अनशरिण सटशन सथागरपत करगा

पररयोजना रा वकरयानवयन

450 मगा िाट का शाजापर सोलर पाका का गरनमााण निमबर 2020 स शरिात कर अगल 21 महीनो म परा

होना अपगरकषत ह

पररयोजना र परभाि लाभ ििा शिन उपाय

सौर ऊजाा पाका क गरनमााण क दौरान RUMSL गरिगरभनन गरहतसािको की पहिान कर उनस गरनयगरमत ििाा और

सलाह मशिरा करतज रहगज पाका गरनमााण क दौरान िामीणो की गरशकायतो को समझन एि उनह दर करन क

गरलए गरशकायत गरनिारण ततर की वयिसथा RUMSL करगा तागरक गरशकायतो का गरनपटारा शीघर हो सक और

लोगो पर हो रह नकारातमक परभाि को दर कर सक पररयोजना दवारा ESIA की परगरकरया क माधयम स सभागरित

परभािो को गरिनहनहतकर उनक गरनपटार हत उगरित और परभकारी उपाय करगा अपगरकषत परभािलाभ और शमन

क उपाय गरनमन गरलनहखत ह तागरक आपक सझािो क आिार पर उनह और परभािी बनाया जा सक

Page 5

नकशा 1 िोहन बदोवदया इराई 6

Page 6

नकशा 2 िोहन बदोवदया इराई 7

Page 7

नकशा 3 शाजापर इराई 8

Page 8

जिीन अविगरहण रा परभाि

परभाविि जिीन रा पररार परभाि रा वनिारण

वनजी जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत 2014 क तहत

खरीदी गरनजी जमीन)

मधय परदश आपसी सहमगरत भगरम करय नीगरत 2014 क तहत

पयाापत मआिजा जमीन या सपगरत क मलय स दगना

पनिासन कायायोजना ndash आजीगरिका पनजीिन योजना स लाभ

पररयोजना हत अगरििहण क बाद पररिार गरजनक पास बहत ही

कम जमीन बिी ह या भगरमहीन पररिारो को पराथगरमकता

गरनमााण क दौरान गरकरयानवयन क समय उनक गरलए काम क

अिसर छोट काया अनबि काटर कट म पराथगरमकता दना

पटटिाली जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत2014 क तहत

तय कर खरीदी गए जमीन)

जमीन क अगरििहण क दौरान पटटा िारको को गरनजी मागरलक की

तरह समझत हए उनक गरलए गरनिााररत सार फायद दना

सररारी जिीन िरनोई सासकगरतक

िरोहर जल शरोत जलाऊ लकड़ी

सिहण गरनसतार की जमीन

अनयससािनो का सिहण क उपयोग म

आन िाली जमीन

पररयोजना क समीप क गााि म िरनोई क गरलए जमीन की

िकनहिक वयिसथा करिाना या अगरििहण क बाद शर जमीन म

गााि क गरलए पयाापत िरनोई की जमीन सगरनगरित करना

खाली पड़ी सरकारी जमीन पर सामदागरयक िारागाह की खप

गरिकगरसत करन हत पनिासनकाया योजना म सभािना खोजना

समदाय क सामदागरयक ससािनो तक पहाि बनी रह उस सगरनगरित

करन क गरलए भारतीय सख भोग अगरिगरनयम 1882 क पराििानो

का पालन गरकया जाएगा

सररारी जिीन अिि कबजिाली

जमीन खती या िराई क गरलए कबजा

अगरतकरमण गरकया गया हो लोगो दवारा

सािाजगरनक उपयोग बागरित गरकया गया

हो

RUMSL पररयोजना स परभागरित लोगो को तीन महीन का पिा

नोगरटस दगा तागरक ि अपनी लगी हई फसल काट सक या नई

फसल न बोए

यगरद गरकसी कारण िश पिा नोगरटस नही दी गयी तो RUMSL परी

फसल की कीमत मआिज क तौर पर द ग

Page 9

वनिाकण र दौरान परभािफायद

परभाि शिनवनपिार र उपाय

गरनमााण क िरण क दौरान गरिगरभनन गगरतगरिगरियो

क गरलए जस मजदर रहिास (क प) सरकषा

वयिसथा भडारण वयिसथा िाहन पागरकि ग कषतर

तथा गरनमााण सबिी अनय जमीन की असथायी

आिशयकता पड़ना आगरद

जमीन मागरलको को पयाापत लीजगरकराए की वयिसथा करना

जमीन मागरलको को उनकी जमीन लौटन क समय वयिनहसथत

रप स सिार कर परानी अिसथा या उसस भी अचछी करक

लौटाना

जमीन मागरलको को उनक जमीन स असथायी रप स हटान एि

उनकी आजीगरिका क नकसान क एिज म मआिजा दना

सामदागरयक सवासथय एि सरकषा तथा घरल

उपयोगी पशओ की दघाटनाका जोनहखम

ठकदार सभी की सरकषा क गरकए आिागमन परबिन पलान

तयार कर ग मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयिहार क गरनयम) और सवासथय एि सरकषा की योजना

बनाकर RUMSL स अनमोदन क पिात ही गरकरयानवयन कर ग

सामदागरयक ससािनो पर दबाि ndash पानी एि

सड़क

RUMSL दवारा मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयहार क गरनयम) गरनिााररत गरकए जाएग गरजसस

कमािारी तथा ठकदार सथानीय ससािनो जस पानी जगल

आगरद का नयायोगरित उपयोग कर पाएग

गगरमायो क समय पानी की गरकललत को दखत हए ठकदार को

यह गरनदश होग की िह पानी क टकर स पानी गरक पगरता कर

शोर बािा एि िल गरनमााण सथल पर दीिार लगानासथागरपत करना तागरक शोर एि

िल कम फल

गरनमााण काया किल गरदन क समय ही करनागरनमााण काया रात

क समय परगरतबगरित करना

गरनमााण क दौरान रोजगार तथा वयिसाय क

अिसर

यथासभि सोलर पाका गरिकगरसत कतााओ तथा ठकदारो आगरद

क गरलए सथानीय लोगो एिम मजदरो को काया दन की

अगरनिायाता होगी

कल रोजगार गरदिस या कल कमािाररयो म कम स कम 30

परगरतशत मजदरकमािारी अनसगरित जागरत - जनजागरत या िगरित

पररिार स होग

सोलर पररयोजना गरनमााण क समय गरकसी भी मालसामिी या

सिा की जररत यथासभि सथानीय गरिकरताओ क माधयम स

की जाएगी

RUMSL गरनमााण क दौरान एक अककषण ततर की वयिसथा

करगा तागरक ठकदार गरिकरता सिा परदाता सथानीय ससािनो

तथा मजदरो का यथोगरित उपयोग कर सक

Page 10

वकरयानवयन र सिय परभाि

परभाि शिन वनपिार र उपाय

सामदागरयक सवासथय एि

सरकषा

सोलर पाका क गरनमााण की परगरकरया क दौरान गरनमााण स होन िाल नए

बदलाि क सबि म समदाय को सिदनशील बनाना हत बठको का

आयोजन करना और सरकषा क गरलए एहगरतयात बरतन हत समय समय पर

गरििार गरिमशा और ििााए करना

रोजगार पर परभाि RUMSL यह सगरनगरित करगा की पररयोजना क गरनमााण क दौरान

तकनीकी कमािाररयो की भती का गरिजञापन सथानीय अखबारो म छप

तागरक योगय सथानीय लोगो को भती गरकया जा सक

अिा कौशल कषमता िाल काम जस कायाालय की दखरख सरकषा गाडा

आगरद पररयोजना स परभागरित पररिारो को पराथगरमकता क आिार पर

गरदय जाए

िविि िगक पर परभाि िवहलाए एि अनसविि जनजावि र सदभक ि

परभाि शिन वनपिार र उपाय

अनसगरित जनजागरत एि

िगरित िगा पर परभाि

अनसगरित जनजागरत समदाय क लाभ को धयान म रखत हए मलगरनिासी

समदाय क गरलए योजना आगरदिासी गरिकास की योजना बनाई जाएगी

सवततर पिा सगरित सहमगरत क आिार पर FPIC की परगरकरया का

गरकरयानवयिन गरकया जाएगा

गरिगरभनन गरहतसािको को शागरमल करत समय अनसगरित जनजागरत समदाय

का पणा रप स परगरतगरनगरितव और भागीदारी को सगरनगरित गरकया जाएगा

मवहलजओ पर परभाि जडर एकशन पलान का गरनमााण गरकया जाएगा तागरक पररयोजना की िजह

स जडर गरिगरशषट परभािो का आकलन कर उनह गरनपटा या कम करन का

परयास हो सक

पररयोजना म िगरित िगा की मगरहलाओ को रोजगार पराथगरमकता गरमल यह

सगरनगरित गरकया जाएगा

पररयोजना कषतर म मगरहला उदयमी गरिकरता सिा परदाताओ को सहयोग

करन क परयास गरकए जायग गरजसस पररयोजना म काम आन सामिी

समान की खरीदी उनस की जा सक

Page 11

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE FPIC FACILITATOR

Page 12

Screening of Facilitating AgencyIndividual Expert for FPIC

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to

undertake an Environmental and Social Impact Assessment (ESIA) of three solar parks

including internal evacuation infrastructure and associated transmission lines of aggregate

capacity of 1500 MW in the Neemuch Agar and Shajapur Districts of Madhya Pradesh India

(hereinafter referred to as the lsquoProjectrsquo) one of the key tasks as part of this assignment is to

secure Free Prior Informed Consent in keeping with the provisions of IFC PS 7 For this

purpose ERM has undertaken the task of identifying a Facilitation AgencyIndividual (FA) to

assist with the FPIC process This document presents the results of the screening and

shortlisting process for the FPIC FA

Approach and Methodology

The approach and methodology followed for shortlisting of FPIC FAs is presented below

1 Two stage approach was followed for the selection of FPIC Facilitation

AgencyIndividual Initially desk research was carried out to identify Institutions (Universities

Government Departments and Research Institutes etc) NGOs and INGOs located in

Madhya Pradesh state In parallel the ERM team also identified the criterion which will be

used to shortlist the potential Facilitating Agencies The criteria used for screening included

qualification profile affiliation with the type of institutionsorganizations nature of

worksprojects completed working experience with Bhils in MP experience in natural

resource management and rural livelihoods conducting meaningful consultation community

mobilization and stakeholder engagement familiarity with World Bank Group safeguardsrsquo

policies and procedures comfort with written and spoken English and local dialects etc

2 In the second stage the potential candidates from these institutions were individually

approached to further assess their suitability and find out their availability for the assignment

Convenient date and time for the personal discussion and interview with them was sought

Accordingly the ERM team organized interview with the available candidates at Bhopal

3 The team27 of Environmental Resource Management (ERM) New Delhi visited

Bhopal during 6-8 January 2020 in order to undertake face to face meetings with these

organizations and individuals identified

Screening

4 The screening against the preferred criteria was undertaken for the potential

candidates available to work as FA for FPIC None of these agenciesindividuals reported to

have worked for a FPIC process earlier Also the candidates interviewed are not familiar

with the World Bank and IFC safeguards related policies and procedure applicable for IPs in

energy and other infrastructure development sectors They are however interested in

working and learning from the project The candidates also had limited experience in the

field of natural resource management and rural livelihoods Details of the screening of

potential candidates is given below

27 Team comprised of Ramesh Swarankar Freelance Consultant and Akshita Mishra Senior Consultant ERM

Page 13

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Amitav Singh

and Leena

Singh

Debate Lok

Nyas (DEBATE)

Duplex C-22

Alkapuri Near

DRM Office

Habibganj

Bhopal-462024

0755-2985007

0755-2417656

9425018144

9425004556

debateindiag

mailcom

MA Social

Works

The key persons are active for

last 3 decades in Social Work

The Debate Trust was

incorporated in 2002-03 and has

more than 15 years of experience

in working with PRIs in Madhya

Pradesh with an focus in Tribal

(Schedule-V) Areas Mr Amitav

Singh is a member of National

Committee for Monitoring of

MNREGA

Ms Leena Singh has also

experience of working with rural

women for more than 15 years

Have

worked

with Bhils

of

Jhabua

Yes Yes Yes

Mr Amitav

Singh is a

leading trainer

for PRA and

Social Audits

by Panchayat

Raj Ministry

No

But was

part of the

FPIC

training

provided

by

ActionAid

Yes

(requires

support in

Reporting)

Score 18 3 2 3 3 3 2 2

Dr Jose

Payyappilly

Address 142

Nyay Nagar

Sukhliya

Indore

Contact-

7828355557

PhD MA

in Social

Work amp

Sociology

About three decades experience

of working on Health HIVAIDS

CSR Literacy Adult education

minority education related

projects and programs funded by

GoI GoM Clinton Foundation Bill

amp Melinda Gate Foundation

UNAIDCARE World Action

Forum VHAI Christian Aid NGO

such as Samarthan in MP

Chhattisgarh and other states It

Has

worked

with Bhils

as part of

a larger

communi

ty in

Jabhua

No No Yes

Trained in

traditional

communicatio

n systems

folklore

folktale

Familiar with

planning

strategy and

community

Associated

with the

network of

NGOs CSOs

and village

level

functionaries

Worked with

local

governments

and elected

No Yes

Page 14

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Email Id

payyappillyjose1

6gmailcom

jose_soolyaho

ocoin

includes the districts in MP with

IPs population

Dr Jose has worked as team

leader director executive director

and other positions Also worked

as Local Governance and BCC

Advisor to DANIDA for Health

Services Program State Media

Coordinator State Resource

centre Adult Education MP

Program Producer Radio Veritas

Asia Manila Philippines

stakeholder

engagement

panchayat

representative

s

Score 14 2 1 1 3 3 1 3

Parushram

Tiwari

Address- C-443

Sarvdharm

Colony Kolar

Road Bhopal

Contact-

09425065132 amp

8319540266

Email Id

drpram42gma

ilcom

PhD

MPhil MA

( Sociology

More than 20 year experience of

working as consultant at different

positions in Public health

HIVAIDS literacy education

nutrition urban development and

governance projects and

programs in MP including Malwa

area and other states

These projects were funded by

UNICEF UNFPA ADB Clinton

Foundation Women amp Child

Development Rural

Development Urban

Administration amp Development

No No Yes Has

worked as

the State

Project

Manager

for Sanjhi

Sehat

project of

MP State

Rural

Livleihood

Mission

Yes Is good

with

coordination

and

communicatio

n

Yes has

experience in

Planning

management

and execution

capacity

building

training and

Networking

and advocacy

Liaison

support and

team building

No Will need

support in

documentatio

n

Page 15

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

State AIDS Control Society of

GoMP and the NGO partners

Dr Tiwari was the Project Director

and District Program officer under

National Literacy Mission at

District Collector offices at Dhar

and Indore MP respectively

during 1991-1998

Score 13 1 1 2 3 3 1 2

Mr Sandip Naik

Adddress-C-55

Kalani Bagh

Dewas MP

Pin Code

455001 India

Contact- +91-94

2591 9221

Email id

naiksandigmai

lcom

Diploma in

Developm

ent

Facilitation

from TISS

Mumbai

MPhil

MA in

Rural

Developm

ent and

English

Literature

About 20 year experience of

working on health nutrition

education governance and

women empowerment with

governments of MP

Worked with NGOs International

agencies and MP government on

senior positions

Since 2014 working with CRY

and TDH on issues of malnutrition

and preparing booklets

brochures pamphlets on nutrition

adolescents issues and childrenrsquos

health Also written textbooks

teachers learning material and

manuals for state govt for SCERT

etc

Yes No No Yes Yes No Yes

Page 16

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Score 14 2 1 1 3 3 1 3

Dr Rahul Dev

Bahawsar

Address Block

No 14 Flat No

5 Shalimar

Enclave E-3

Arera Colony

Bhopal ndash

Madhya

Pradesh

Contact-

08223015124

Email

rbhawsarrediff

mailcom

rahuldevbhawsa

rgmailcom

PhD amp

MPhil in

Population

Studies

from IIPS

Mumbai

MSC

Statistics

24 years experience in

monitoring evaluation and

implementation of programs in

health and social development

sectors in MP Rajasthan and

Gujarat states

Engaged in nutrition assessment

survey in 18 districts of MP states

including IPs dominated districts

such as Dhar Jhabua with Bhil

population and coordinated with

state health women amp child

development and rural

development departments during

the study period

Involved in conducting health

surveys at national level

Worked as a staff with Health

Management Research Institute

Jaipur and IPE Global Consulting

Firm New Delhi etc These

projects were funded by DFID

UNICEF UNFPA GoI GoMP

etc

Yes has

worked

in

Jhabhua

and Dhar

No Yes Has

worked

with State

Rural

Livelihood

Mission

Somewhat

His strengths

lie more

towards

quantitative

research

Somewhat No Yes

Page 17

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Working as freelance expert and

has a registered consultancy firm

that is inactive

Score 12 2 1 2 2 2 1 2

Ms Aastha

Anuragi

Address 173

Sanjay

Complex

Phase-2

Geetanjaly

Square Bhopal-

462003

Contact-

9425365216

8160123726

Email

aasthaanuragi

gmailcom

MBA Rural

Manageme

nt amp MSC

in Physics

More than 15 year experience of

working particularly imparting

training to different stakeholders

in drinking water and sanitation

Swachh Bharat ODF missions

WASH livelihood menstrual

hygiene etc Master trainer for

total sanitation program

Worked as consultant in MP

Chhattisgarh West Bengal UP

Gujarat Jharkhand Bihar states

These projects were funded by

World Bank Water Aid UNICEF

DFID GoI State governments

and ICIMOD Nepal

No No Yes has

worked as

a project

facilitator

with MP

livelihood

project

Yes Yes No No

Score 12 1 1 2 3 3 1 1

Note The scoring for each criterion was as follows 0- Not applicable 1- Not Meeting the Requirement 2- Partially meeting the requirement 3- Completely fulfilling the requirement

Page 18

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

Page 19

TERMS OF REFERENCE FOR FPIC FACILITATION AGENCY

Background

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake an

Environmental and Social Impact Assessment of three solar parks including internal evacuation

infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch

Agar and Shajapur Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work for the project ERM is required to assess the impacts on the indigenous

marginalized communities within the site and its influence area prepare an Indigenous Peoples Plan

(IPP) apart from other ESIA amp RAP deliverables The project is also required to conduct a FPIC process

covering affected Scheduled Tribe (ST) population

Villages to be covered in FPIC Process

The project area has a few small ST settlements and in few others a small number of ST households

live along with a majority non-ST population Following 5 villages are identified for carrying out FPIC

process

Solar Park Selected ST villages

for FPIC

Number of

Households

Name of ST

Community

Agar Solar Park Ladwan 12 Bhil

Shajapur Solar Park Parsula 41 BhilBhilala

Neemuch Solar Park Badi and Kawai 97 BhilBhilala

Note Additional ST families in neighbourhood villages of the same Solar Park will be made part of this

process to a limited extent

Phases in FPIC Process

The FPIC process will be divided into two phases as described below

Phase What to Do Schedule

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Apr 2021^

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

May-Aug 2021^

^ Activities were suspended in April 2021 due to break out of the second wave of Covid-19 in India These

activities will be re-scheduled once Covid-19 second wave gets over

Deliverables and Responsibilities

Phase Responsibilities Deliverable

I Identification of STs Representatives and formation of committees

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Documentation of capacity building of STs Representatives on FPIC

Mutually agreed FPIC Process and composition of local ST Representative committees

Page 20

Phase Responsibilities Deliverable

Hindi Translation of TDPIPP and designing Information sharing tools

Participatory mapping of all natural resources and cultural sites to be impacted

Participatory assessment of impacts on Tribal population

Identification of Livelihood and Welfare programs to be included in Draft TDP

Inventory of natural resource and cultural sites

Documentation of participatory process of impact assessment

Note on livelihood and welfare programs

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation (Photos Video MoMs for each meetingsevents) of FPIC process

The revised package in Draft TDP and a mutually agreed Draft FPIC Agreement

Personnel Requirement

The FPIC Facilitation Agency will require to mobilize following key personnel for completing these tasks

Designation Desired Qualification and Experience

Coordinator The coordinator to be a post-graduate in social sciencessocial work with at

least 15 years of experience in ruraltribal development Prior involvement in

FPIC related work with prominent civil society organizations or multilateral

development finance organizations will be preferred

Facilitator (Male) The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in facilitation of participatory rural appraisals The

facilitator needs to have sound knowledge of livelihood issues in Malwa

region of Madhya Pradesh and must have worked with Panchayati Raj

Institutions for their capacity building The facilitator should be familiar with

the local dialect (Malwi) spoken in Malwa region

Facilitator

(Female)

The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in working with rural women She should have

knowledge of livelihood and social context of women in Malwa region She

should have prior experience in facilitating participatory rural appraisal

processes involving rural women

Documentation

Assistant

The documentation assistant should be a Graduate in social sciencesmass

communication She should have at least 5 years of experience in ruraltribal

development and have carried out process documentation of development

projects She should have a good command over Hindi and should be

familiar with Malwi dialect

Community

Mobilizer

The community mobilizer should have passed higher secondary and have

experience of working with any NGO for at least 2 years She should have

good communication skills She will provide all logistical support necessary

to ensure participation of maximum number of people She also helps

Documentation Assistant in photo and video documentation of the FPIC

process

Organization Profile

The organization should have at least 10 years of experience in working in rural and tribal

development issues in Madhya Pradesh The organization should have a reputation of successfully

implementing projects related to community mobilization and capacity building They should have

Page 21

prior experience of working with tribes and should be known for their dedication and commitment

towards tribal rights and promoting their development

The business of sustainability

ERM has over 160 offices across the following

countries and territories worldwide

Argentina

Australia

Belgium

Brazil

Canada

Chile

China

Colombia

France

Germany

Ghana

Guyana

Hong Kong

India

Indonesia

Ireland

Italy

Japan

Kazakhstan

Kenya

Malaysia

Mexico

Mozambique

Myanmar

The Netherlands

New Zealand

Norway

Panama

Peru

Poland

Portugal

Puerto Rico

Romania

Russia

Senegal

Singapore

South Africa

South Korea

Spain

Sweden

Switzerland

Taiwan

Tanzania

Thailand

UAE

UK

US

Vietnam

ERM India Private Limited

Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

wwwermcom

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

Document details The details entered below are automatically shown on the cover and the main page footer

PLEASE NOTE This table must NOT be removed from this document

Document title Environmental and Social Impact Assessment of three Solar Parks including internal

evacuation infrastructure and associated transmission lines of aggregate capacity of

1500 MW in the state of Madhya Pradesh India

Document subtitle FPIC Approach Draft Discussion and Decision Making Framework

Project No 0528741

Date 5 May 2021

Version 04

Author ERM India Private Limited

Client Name Rewa Ultra Mega Solar Limited

Document history

ERM approval to issue

Version Revision Author Reviewed by Name Date Comments

Draft 01 Swayam

Panda

Neena Singh Neena Singh 20 Sep 2020

Draft 02 Swayam

Panda

Neena Singh Neena Singh 12 Dec 2020

Final Draft 03 Swayam

Panda

Ajay Pillai 30 Mar 2021

Final

Draft-2

04 Swayam

Panda

Ajay Pillai 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

Signature Page

05 May 2021

Environmental and Social Impact Assessment of three Solar Parks including internal evacuation infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the state of Madhya Pradesh India

FPIC Approach Draft Discussion and Decision Making Framework Draft Final Report

Name Dr Swayam Panda

Job title Technical Director

Name Ajay Pillai

Job title Partner

ERM India Private Limited Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

copy Copyright 2021 by ERM Worldwide Group Ltd andor its affiliates (ldquoERMrdquo)

All rights reserved No part of this work may be reproduced or transmitted in any form

or by any means without the prior written permission of ERM

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page i

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

CONTENTS

1 INTRODUCTION 1

11 Project Background 1 12 Timeline of Various EampS Studies 3 13 Scope amp key deliverables related to FPIC for MP Solar Project 4 14 Structure of the Report 11 15 Limitations 11

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS 12

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in

2018 12 22 International Social Safeguard Policies Applicable to the Project 16

221 IFC Performance Standards 16 222 World Bank Operation Manual OP 410 16

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard

Policies of IFC and WB 17

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION 22

31 Affected Villages Government land used by ST Population 22

311 Neemuch Solar Park (Unit 1-3) 22 312 Agar Solar Park (Unit 4 amp 5) 26 313 Shajapur Solar Park (Unit 6-8) 30

32 Selection of FPIC Villages 36 33 Impact on Nomadic Pastoral Communities 37 34 Impact on Government and Grazing Land 38 35 Impact on Cultural Sites affiliated to STs 39 36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure 40

361 Use of Government Land in TLs Associated With Neemuch Solar Park 41 362 Use of Government Land in TLs Associated With Agar Solar Park 42 363 Use of Government Land in TLs Associated With Shajapur Solar Park 43 364 Conclusion on FPIC Trigger for Transmission Lines 45

4 DESK BASED INFORMATION COMPILATION 46

41 Information Collection and Compilation 46 42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks 46

421 Government Land Allotment for Neemuch Solar Park 46 422 Government Land Allotment for Agar Solar Park 46 423 Government Land Allotment for Shajapur Solar Park 47

43 Review of Previous Community Consultations for Allotment of Government Land 47

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER 49

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020) 49

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park 49 512 Disclosure of Intention to Conduct FPIC Agar Solar Park 49 513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park 50

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises

with STs (Aug 2020) 50

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village) 52 522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village) 55 523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages) 58

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL 62

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page ii

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

6 INDEPENDENT FACILITATOR AGENCY 63

61 Need for FPIC Process Facilitation Agency 63 62 Screening of FPIC Process Facilitation Agency 63 63 Roles and Responsibility for FPIC Process Facilitation Agency 65 64 Terms of Reference for FPIC FA 65

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS 66

71 Use of Language 66 72 Use of Customary Decision Making Process and Traditional Leaders 66 73 Promoting Participation of Women and Youths 67 74 Expectation on Material Information Prior to Discussion 67 75 Need for Capacity Building of IP Representatives 68 76 Need for a Mediation Mechanism 68 77 Following Principles of Good Faith Negotiation 69 78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and

Supportive Environment 70

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK 73

81 Introduction 73 82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo 73

821 Appointment of FPIC Facilitation Agency and Orientation 73 822 Introducing FPIC FA to RUMSL and FPIC Villages 73 823 Formation of ST Committees 74 824 Capacity Building of ST Committees 74

83 The Draft Discussion amp Decision Making Framework 74

831 Formation of Committees 75 832 Acceptance of Draft Discussion and Decision Framework 76 833 Disclosure of Draft IPPIPDP to ST Committee 77 834 Explaining Draft IPPIPDPTDP to ST Committee 78 835 Internal Consultation Process by ST Committee 78 836 First RUMSL and ST Committee Meeting 78 837 Second RUMS and STs Committee 79 838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee

(MC) 79 839 Informing Community on Draft FPIC Agreement by ST Committee 79 8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and

Ratification of Final IPP and FPIC Agreement 80 8311 FPIC Process Documentation Report 81

84 Tentative Time-line 81 85 Responsibility Matrix 83

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT

FPIC

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE

FPIC FACILITATOR

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

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CONTENTS

List of Tables

Table 11 Villages to be covered in FPIC Process 1

Table 12 Salient Features of the Project 2

Table 13 The status of ESIA Study Components and Community Engagement 3

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables 5

Table 21 Key Provisions of Land Revenue Code 12

Table 22 Comparison of Provisions of Consent Process in Applicable Indian Regulations vis-agrave-

vis Provisions in IFC PS-7 17

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land

Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

19

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected

Villages 22

Table 32 Agar Solar Park- Government Land- Land Use Category 26

Table 33 Shajapur Solar Park- Government Land- Land Use Category 30

Table 34 Villages to be covered in FPIC Process 36

Table 35 Designated grazing land (Charnoi) and Remaining Government Land 38

Table 36 Impact on Cultural Sites Affiliated to STs 39

Table 37 List of Power Evacuation Infrastructure 40

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of

STs 41

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST

Population 42

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs 43

Table 41 Dates of Government Land Allotment for Neemuch Solar Park 46

Table 42 Dates of Government Land Allotment for Agar Solar Park 46

Table 43 Dates of Government Land Allotment for Shajapur Solar Park 47

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha

Resolution 47

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park 49

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park 50

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park 50

Table 54 Site visit Dates and Site Activities 51

Table 55 Names of Potential Representatives in Ladwan Village 54

Table 56 Names of Potential Representatives in Parsula Village 57

Table 57 Names of Potential Representatives in Badi and Kawai Village 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency 63

Table 62 Roles and Responsibilities of FPIC FA 65

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context 69

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages 71

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CONTENTS

List of Figures

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages 24

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages 25

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages 28

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages 29

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages 33

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages 34

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages 35

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments 56

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process 74

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CONTENTS

Acronyms and Abbreviations

Name Description

CSO Civil Society Organizations

DDMF Discussion and Decision Making Framework

DPR Detail Project Report

DREO District Renewable Energy Officer

ESIA Environment and Social Impact Assessment

ESS Environment and Social Standards

FA Facilitation Agency

FPIC Free Prior Informed Consent

FPIC-FA FPIC Facilitation Agency

FPICon Free Prior Informed Consultation

GAP Gender Action Plan

GFN Good Faith Negotiation

GN Guidance Note

GoMP Government of Madhya Pradesh

GP Gram Panchayats

HO Head Office

ICP Informed Consultation and Participation

IFC International Finance Corporation

IPDP Indigenous Peoples Development Plan

IPP Indigenous Peoples Plan

Ips Indigenous Peoples

JV Joint Venture

LRP Livelihood Restoration Plan

MC Mediation Committee

MNRE Ministry of New and Renewable Energy

MPLRC Madhya Pradesh Land Revenue Code

MPUVNL Madhya Pradesh Urja Vikas Nigam Limited

MW Mega Watt

NGO Non-Government Organizations

NOC No Objection Certificate

OBC Other Backward Castes

OP Operation Policy

PPP Public Private Partnership

PRA Participatory Rural Appraisal

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CONTENTS

Name Description

PS Performance Standard

RAP Resettlement Action Plan

RPO Renewable Purchase Obligation

RUMSL Rewa Ultra Mega Solar Limited

SC Scheduled Caste

SEP Stakeholder Engagement Plan

SHG Self Help Group

SPD Solar Park Developer

SPO Solar Purchase Obligation

ST Scheduled Tribe

TDP Tribal Development Plan

ToR Terms of Reference

WB ESF World Bank Environment and Social Framework

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

1 INTRODUCTION

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Impact Assessment (ESIA) including Resettlement and

Rehabilitation Action Plan (RAP) of three solar parks including internal evacuation infrastructure and

associated transmission lines of aggregate capacity of 1500 MW in the Neemuch Agar and Shajapur

Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work ERM is required to assess the impacts of the Project on the Indigenous

Peoples (IPs) or Scheduled Tribe (ST) and develop an approach and implement the process of Free

Prior Informed Consent (FPIC) The villages in Table 11 were identified to be covered in the FPIC

process during the scoping stage The intention of conducting FPIC process involving ST families in

these identified villages was communicated to the Sarpanch1 and a project information sheet (in

Hindi) was shared around Dec 2019

Table 11 Villages to be covered in FPIC Process

Solar Park Selected ST

villages for FPIC

Number of

Households

Name of ST

Community

Date on which Gram

Panchayat was informed

about FPIC Process

Agar Solar Park Ladwan 12 Bhilala 19th Dec 2019

Shajapur Solar Park Parsula 41 Bhilala 30th Jan 2020

Neemuch Solar Park Badi and Kawai 61 Bhil and Bhilala 5th and 6th Dec 2019

The Covid-19 pandemic brought restrictions for finalizing the project boundary and preparation of

ESIA Reports between Mar 2020 and Jun 2020 ERM initiated the FPIC related works and submitted

a Memo on selection of FPIC villages dated 29th Jun 2020 which reviewed the government land

allotment and triggers for FPIC

The FPIC Approach Paper (current document) is based on the understanding of the socio-political

context within which the affected STIPs population lives and suggestions received from the

prominent ST representatives with whom a preliminary round of discussions was held The Discussion

and Decision Making Framework (see Section 8) is accepted by RUMSL and was planned to be taken

back to the affected ST community for discussion and acceptance in Apr 2021 (see Section 832)

This has been delayed due to second wave of Covid-19 which started in Apr 2021 and decision on

further visits and consultations will be undertaken based on how situation unfolds in the coming

weeks The FPIC Approach paper will be finalized after the Discussion and Decision Making

Framework is discussed with ST Committees representing affected ST communities and agreed by

them

11 Project Background

The Government of India has identified the solar power sector as one of the critical components for

infrastructure development and overall economic growth The Government of Madhya Pradesh

(GoMP) through Ministry of New and Renewable Energy (MNRE) is developing ground mounted grid

connected solar power projects in Madhya Pradesh International Finance Corporation (IFC) is

providing investment advisory services to RUMSL thereby enabling Government of Madhya Pradesh

(GoMP) to develop the project on Public Private Partnership (PPP) mode and to support GoMP in

1 The rural local self-government bodies in India are known as Gram Panchayat which comprises of several wards Each ward

elects a ward member to represent them The Gram Panchayat thus comprises of multiple elected Ward Members The Chair Person of these elected local body is known as Sarpanch The vice chairperson of the Gram Panchayat is known as Upsarpanch or Naibsarpanch All adult electorate of a Gram Panchayat constitute Gram Sabha or General Assembly of the Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

meeting its energy requirements and in the process meet its Renewable Purchase Obligation (RPO)

and Solar Purchase Obligation (SPO)

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) Its primary objective is to develop

and facilitate development of large scale solar power projects in the state of Madhya Pradesh

RUMSL is planning to develop three solar parks (see details in Table 12) and their associated

internal evacuation infrastructure and transmission lines The World Bank had agreed to provide

financial support for the Project

Table 12 Salient Features of the Project

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Capacity and Configuration

3 Units (Units 1 2 3) adding up to 500 MW

2 Units (Units 4 and 5) adding up to 550 MW across Susner (Unit 4) and Agar (Unit 5)

3 Units adding up to 450 MW across Moman Badodiya (Units 6 and 7) and South Shajapur (Unit 8)

Total Land Area as of 24 June 2020

Unit 1 3515 ha Unit 2 34713 ha Unit 3 36701 ha Total 106573 ha

Unit 4 60809 ha Unit 5- 79918 ha Total 140758 ha

Unit 6- 2462 ha Unit 7 4859 ha Unit 8 2551 Total 9872 ha

Government Land (ha) allotted as of 24 Jun 2020

67819 ha

Allotment of additional 28979ha is under process Thus the total government land area is 962949 ha

127338 ha 931 ha allotted and additional 14ha to be allotted

Date of Government Land allotment

Allotment Date

Area in Ha

17-01-2018 23868

30-05-2017 43951

Total 67819

Allotment Date

Area in Ha

28022019 5633

28022019 7053

21062019 1495

20-06-2019 15925

28022019 283

20062019 19714

280202019 1683

21012019 3492

04012018 602

09082018 2669

30112016 5562

02012018 5699

02012018 16116

06012018 17663

09082018 15583

Total 127137

Allotment Date

Area in ha

26-05-2017 914

26-05-2017 3052

26-05-2017 2011

11-12-2017 11261

11-12-2017 1171

11-12-2017 171

11-12-2017 1386

11-12-2017 4015

11-12-2017 4596

11-12-2017 9545

11-12-2017 1763

26-05-2017 16461

28-06-2019 2675

28-06-2019 6134

Total 931

Private Land 1862 ha 1342 ha 9951 ha

Patta land 7572 ha 0 515 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Proposed Commissioning Date

Tender and bid process tasks completed

- Start of registration downloading of the RFP access to Data Room on 26th Jan 2020

- Facilitation of site visit 26 to 28th Feb 2020

- Issue of Draft Project Agreements on 15th Jun 2020

- First pre-bid meeting was held on 30th Jun 2020

- ESIA Reports was issued on 16th Oct 2020

Tender and bid process schedule ahead

- Second pre-bid meeting on 30th Mar 2021

- Proposal due date for 3 sites between 3rd Jun 2021 and 18th Jun 2021

- Financial proposal opening between 14th Jun and 28th Jun 2021

- Reverse Auction Process 17th Jun and 30th Jun 2021

Purchase of Private land between Apr and Jun 2021

Target date for providing SPD land access June 2021

Indicative construction time of 19 months

Target date for commissioning of Solar Park Nov 2022 It is understood that RUMSL will initiate a process of hand over of balance government land to revenue department no longer required for the project

12 Timeline of Various EampS Studies

The allotment letters of the government land were issued at different points of time between 2017 and

2019 The boundary demarcation (tarmeem2) of these allotted government land for the 3 solar parks

was completed in October 2020 RUMSL is planning to initiate private and patta land procurement to

start in Apr 2021 and all sale agreements are signed by Jun 2021

The timeline of ESIA studies of these 3 Solar Parks is provided in Table 13 below

Table 13 The status of ESIA Study Components and Community Engagement

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

ESIA Field

visits

December 2019 December 2019-

January 2020

January ndash February

2020

September 2020

Report Final ESIA

submitted in

October 2020

Final ESIA

submitted in

October 2020

Final ESIA submitted

in October 2020 Draft ESIAs for

Neemuch TL and

Agar- Shajapur

TL submitted in

November 2020

RAP-

LRP

Field

visits

November-

December 2020

August 2020 August 2020 December 2020

Report Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-WB

Draft RAP-LRP is

reviewed by IFC-

2 Tarmeem ground verification process to confirm land ownership and to demarcate any patta land andor private land that

may have been identified within a government khasra This process is done by Revenue Department from time to time in the normal course of action (with or without any project) As an outcome of this process following can be achieved Revisions in the Patwari maps Khasra books Digital database other revenue records preparation of survey reports etc This process is undertaken by Officials from the Revenue Department usually inclusive of the Tehsildar RI Patwari etc

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

WB and ready for

Public Disclosure in

Mar 2021

WB and ready for

Public Disclosure

in Mar 2021

and ready for Public

Disclosure in Mar

2021

WB and ready for

Public Disclosure in

Mar 2021

IPP Field

Visits

Initiation 5-6th Dec 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and Draft IPP 13-16th Aug 2020

HH Survey 7-14th Sep 2020

Initiation 19th December 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 6-7th Aug 2020

HH Survey Not done

Initiation 30th Jan 2020

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 8-12th Aug 2020

HH Survey 13-14th Aug 2020

No IPP to be prepared for Transmission Line

Report Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure in

Mar 2021

Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure

in Mar 2021

Draft IPP is reviewed

by IFC-WB and

ready for Public

Disclosure in Mar

2021

The ERM ESIA team has held several consultation meetings in project affected villages covering a

cross-section of stakeholders in a sequential manner The broad understanding of the socio-economic

and livelihood practices was carried out in Dec 2019 and Jan 2020 as part of collection of baseline

information The detailed study for RAP-LRP and IPP subsequently took place in Aug 2020 The details

of the consultations held for ESIA RAP-LRP are part of those reports and details of field visits and

consultation activities carried out for preparation of this FPIC Approach Paper and Draft IPP is described

in Section 4 below

13 Scope amp key deliverables related to FPIC for MP Solar Project

ERM as a part of the FPIC requirement for the project is expected to support the elaboration and

implementation of a robust FPIC process for the MP Solar Park project to be developed in 2 Phases

Phase I the overall principles and engagement process and criteria for obtaining FPIC should be

agreed on with the affected Indigenous People (IP) communities potentially before bidding

Phase II the focus of the proposed FPIC process will then be on seeking consent from affected

IP communities for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior

to the main construction phase) In phase II it is likely that the PPP concessionaire will also

play a role and as such the Social Expert will continue to advise RUMSL but also monitor the

activities of the concessionaire

The Table 14 below summarises the key deliverables tasks involved and expectations against each

of these tasks in terms as per the scope The current status progress of these tasks and timeline for

future activities is also proposed It should be noted that these timelines may change in keeping with

evolving health and safety situation in context of COVID-19

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

I OBJECTIVE AS PER RFP The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities before bidding ie the submission of proposal for solar parks by concessionaire

Guidance to RUMSL (ONGOING)

Provide guidance to RUMSL on the most appropriate sequencing of steps vis-agrave-vis the FPIC process as per IFC PS 7 requirements

eg agreement and verification of legitimate IP representatives to represent affected communities in FPIC negotiations

agreement with IPs and their representatives on the FPIC engagement process and next steps including disclosure and consultation of draft updated project impact mitigation benefits package documentation

share of responsibilities between RUMSL and PPP concessionaire etc

This will also include advise on broader stakeholder analysis and engagement strategy

to build support for the FPIC approach and implementation of the project and

to participate in agreed outreach to influential local and international stakeholders andor additional sources of adviceinput

ERM has been providing handholding support to the client in terms of meetings and calls where the requirements of IFC PS 7 are discussed and possible implications of project decisions on the FPIC applicability are discussed

The training for RUMSL team on ICP (SEP) PS-7 and FPIC process on 27th Aug 2020

Sharing of Draft FPIC Approach Paper 1st Sep 2020

Discussion on Draft IPP and Formation of Committees for FPIC Process 16th Mar 2021

Submission of Note on FPIC budget FPIC Process

Responsibilities of PPP concessionaire submitted as part of Draft IPPs (Appendix-F)

A meeting with facilitating agency and their ToR was held in 1st Week of Apr 2021

A Joint field trip with RUMSL FPIC Team will be held after Covid-19 Second Wave is over to

- Verify the IP representatives and formation of ST committees

- To agree with ST committee on Draft Discussion and Decision Making Framework

Draft FPIC approach paper

Desk-based Information Compilation and Assessments

Review national applicable law to identify any gaps with IFC PS7 and ways to bridge them

While developing the FPIC approach leverage as much as possible the requirements of applicable law and the consent process usually applied when IP are affected

The FPIC approach should also ensure that affected IP communities are involved

ERM did not get access to documentation of community consultation as part of seeking

NOC3 from Gram Panchayats

Conversation with Sarpanch of villages with ST population revealed that consultation was

A field trip for a joint meeting between RUMSL and ST communities is proposed to be held after Covid-19 Second Wave is over The field trip will include the following

3 The allotment of unused Government land within any revenue village needed a resolution of concerned local government body (Gram Panchayat) under S 234 (4) till Nov 2018 See more details in

Section 21 below The Solar Parks does not require any EIA studied in India

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Identification of affected IP individuals and communities and representatives as well as project impacts mitigation measures and potential benefits related to them (ongoing process during ESIA)

Initial Meeting with Gram Panchayats (GPs) and Informing them on FPIC

Social MappingSite walk-through

Preparation of Draft FPIC Approach Paper which builds on key elements of IFC PS7 FPIC requirements is prepared in consultation with RUMSL IP representatives and other stakeholders and could be acceptable to each party

Internal Discussion and Consensus on FPIC Approach Paper

Sharing of Draft FPIC Approach with IP and Consensus Building

in the identification of impacts and provide input on the development of mitigation and benefit plans

The FPIC approach should be cognizant that impacts on vulnerable groups within the Affected Communities of IP if any should be adequately addressed during negotiation and in relevant documentation

It should be based on the engagement with local IP community decision-making authoritiesrepresentatives (and taking into account gender and other IFC PS 7 related prerogatives) to discuss the FPIC process with input from support organization

The draft approach paper should reflect a mutually acceptable engagement and negotiation framework for the FPIC process based on the principles of Good Faith Negotiations It should include a clear agreed indication on what constitutes consent in the project context

Ensure through revision and feedback that all other components under this assignment (ifwhen available) are aligned with the defined FPIC approach ndash including the Environmental and Social Impact Assessment (ESIA) Resettlement Action Plan (RAP) Stakeholder Engagement Plan (SEP) Gender Action Plan (GAP) and develop the Indigenous People Development Plan (IPDP)

restricted to Gram Panchayat members Though they initially reluctant to sign on the NOC after persuasion of District Collector they finally signed

PRA exercises which includes participatory mapping of social relationship livelihood and natural resources was held between 6th to 15th Aug 2020

The social mapping during 6-15th Aug collected information on existence of traditional decision making process and gender representation aspect

The proposed FPIC process as part of this FPIC approach paper (Refer Chapter-8) reflect GFN principles

The FPIC approach paper was discussed with RUMSL prior to sharing it with WB-IFC

The ESIA disclosure was done as part of the PRA exercises for IPP in Aug 2020The RAP survey was done in these villages around the same time to address their concerns over loss of privatepatta land

Consultations during RAP and Draft IPP preparation included PRA process where STs participated to identify impacts and expressed their expectation on project benefits

The feedbacks and key issues in ESIA (including GAP SEP) and RAP is synchronised in Draft IPP

- Introduce FPIC Facilitation Agency

- Facilitate formation of ST representative committees

- Inform them their rights in the context of FPIC process

- Consult and build mutual agreement on the lsquoengagement and negotiation frameworkrsquo (as in Chapter-8 of this report) which will include a clear agreed indication on what constitutes consent

- The STs Representatives will be asked about time they require for internal discussion and a tentative date for the first discussion on benefits proposed in IPP will be fixed

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Independent FPIC Facilitator Agency

Assess the need for Independent FPIC Facilitator Agency

Screening of IPOsCSOs for Independent FPIC Facilitator Agency possible facilitator options to determine how they can play a role in the process - who what how

Provide a list of names of key advocacy groupsNGOsCSOs considered SWOT (or similar) analysis of each organization considered identification of preferred organization and

Terms of Referencersquo for the role of the same in the FPIC process and its relevance for the FPIC process in that area and for that specific group

To be discussed in next call FA brings credibility of an independent agency (other than RUMSL and ESIA consultant) Considering the project context their position can be reviewed

The review and assessing the need for a FA is discussed in section 6 of this report The Scope of work for the FA is provided in Appendix-F

Preparation of IPDPIPPTDP

Note ESIA RAP SEP and other management plans should be prepared by this stage Infact the FPIC process report should also draw input from the engagement undertaken as part of the ESIA process

Indigenous People Plan (or

Community Development Plan

Stakeholder Engagement Plan) or

similar management documents

aimed at ensuring ongoing and

adequate engagement with IPs

The collection of baseline

information through PRA

exercises and a sample

household survey was done

in Aug 2019 The IPP draws

inputs from consultations for

ESIA RAP-LRP and

benefits are also

synchronised

Three Draft IPPs one for

each Solar Parks with a

package of benefits for

affected STs is ready and

disclosed in May 2021

These will be shared with

affected STs as part of the

FPIC negotiation process

subsequently for their

considerations and

acceptance

Preparation of Draft FPIC Process Report

FPIC Process Report will include (but not be limited to)

identification of IPs IP representatives and decision-making authorities

assessment of capacity of IPs IP representatives to undertake good faith negotiations

summary of any capacity building undertaken

agreed engagement and negotiation framework (including the process undertaken to agree upon the framework)

This document will be further updated and finalised once the whole process is completed

Note The FPIC process should incorporate key considerations contained in IFC PS 7 and GN 7 eg the need for free prior and informed engagement inclusion of differentiated measures to allow the effective participation of those identified as particularly disadvantaged or vulnerable including analysis of the legitimacy and representativeness of IP leaders and the role responsibilities and participation of

To be initiated once FPIC Process starts

The process of identification of IPs representatives and decision making authorities (ST RUMSL and Mediation Committees) which will take place once Covid-19 second wave is over and will be documented as Draft FPIC Process Report This will be a living document which will be updated after every round of field activities and negotiation meetings

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

detailed summary of consultations meetings engagement undertaken as part of the FPIC process

expert opinion on the process and outcomes

share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to complete the FPIC process

external stakeholders with vested interests in the outcome

Input to the bidding document

For the bidders in terms of FPIC amp IPDP requirements

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc

The Draft IPP for each Solar Park has Annexure-F providing roles and responsibilities and scope of work for the Solar Park Developer (SPD)

All 3 Draft IPPs with Annexure-F are ready for disclosure in May 2021

II OBJECTIVE AS PER RFP Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Preparation of communication Material

Communication material to be based on IPDP ESIA and RAP This should include culturally appropriate document on impacts and mitigation to be used during FPIC engagement and negotiation

All preparation including translation of FPIC-related materials including communication material summaries of relevant EampS documentation local benefits plans etc (printing arrangement to be agreed with RUMSL)

A Project Profile Fact Sheet was shared in Dec 2019

A summary of ESIA was shared in Aug 2020

The communication material based on Draft IPP will be prepared and used during FPIC process The Draft communication material will be shared with IFC-WB for their approval prior to its use in field

A parallel information disclosure process of RAP-LRP would also take place

Culturally Appropriate Information Disclosure Campaign

Share accurate and up to date information on project impacts proposed mitigation measures and proposed benefit streams in a culturally appropriate manner (ie in local language (as appropriate following discussion with IP representatives) in written and oral format)

The information disclosure should especially ensure that following are achieved

provide sufficient time for capacity building and

support to affected communities to understand these matters and their rights

The affected ST population speaks Malwi dialect The FPIC FA will have facilitators who would be familiar with this local dialect used

The FPIC FA will carry out the capacity building activities

The FPIC FA will spend 2 days at each Solar Park to do the capacity building workshops with local ST Representatives who would participate in FPIC discussion with RUMSL

The FPIC FA will do this once Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Consent from the Indigenous communities

Meetings for Negotiation and Decision Making

Participate in and offer expert support to key FPIC-related meetings involving affected IP representatives RUMSL and other relevant authorities etc during the FPIC process

Support RUMSL in the organization of these meetings and in recording their outcome including the collection of comments and concerns of those attending

Measuring Consent and Signing of FPIC Agreement

Note This include also support the RUMSL in designing undertaking and collecting evidence of Good Faith Negotiations (GFN) resulting in Consent which involves (i) willingness to engage in a process and availability to meet at reasonable times and frequency (ii) provision of information necessary for informed negotiation (iii) exploration of key issues of importance (iv) use of mutually acceptable procedures for negotiation (v) willingness to change initial position and modify offers where possible and (vi) provision of sufficient time for decision making

Present updated materials and seek consent from affected IP communities and their leaders

Document the consent process in a mutually agreed written format including an agreed mechanism for monitoring of key commitments in future and grievance redress as well as identifying share of responsibilities between the RUMSL SPDs and other relevant parties

Evidence of representativeness and involvement of Indigenous Peoples representative bodies and organizations (eg councils of elders or village councils)

Evidence of agreement between the parties as the outcome of GFN (eg FPIC agreement MOU a letter of intent and a joint statement of principles agreed mitigation plans collective land agreements etc)

Other documents may include Client records photographs media reports personal letters or third-party accounts etc regarding eventsdemonstrations other activities for the project undertaken by project-affected IP communities with high relative levels of participation by (i) the affected community as a whole or (ii) by sub-groups particularly affected by the project

ERM will work alongside FPIC FA and RUMSL to help the FPIC process taking right direction

Final FPIC Process Document

Throughout the FPIC process (Phase I and Phase II) ERM should help documenting the FPIC process and provide an opinion and direction about the process and outcome vis-agrave-vis IFC PS7

The whole set of activity in Phase II need to be updated as part of the Final FPIC Process Document

The tentative timeline for the FPIC Process was scheduled between Jun 2021 and Sep 2021 The timeline will be revised after the ongoing Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

The Draft FPIC Process Report will be submitted within 2 weeks of completion of FPIC process

Advise RUMSL but also monitor the activities of the concessionaire in phase II

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INTRODUCTION

14 Structure of the Report

This report is organized into following sections

Section 1 Introduction (this section)

Section 2 Applicable law and gaps assessment against IFC PS7 requirements

Section 3 Affected IPs population project impacts and mitigation

Section 4 Desk-based information compilation

Section 5 Engagement leading up to FPIC Approach Paper

Section 6 Independent facilitator agency

Section 7 Key elements in FPIC Process

Section 8 Draft Discussion and Decision Making Framework

15 Limitations

This Report is prepared after multiple field visits and interactions with affected ST community elected

leaders of Gram Panchayat and other key informants The assessments are based on information

received from RUMSL and other secondary information at some places The public health concerns

due to Covid-19 pandemic has prevented large community gatherings and communityrsquos willingness to

allow people from outside to spend much time with them

ERM team communicated with community members over telephone to seek clarifications and know

their views However it was not always possible to keep the discussion focused and definitive as it

could have been in case of a face to face discussion ERM has made efforts to build trust among

affected STs by sharing relevant information and answering their queries with clarity As FPIC process

is an itinerant process this relationship is expected to further evolve in future

The Draft Discussion and Decision Making Framework described in Chapter 83 though has been

accepted by RUMSL and reviewed by IFC and WB it would be discussed with committees formed by

affected STs and their feedbacks will be incorporated The FPIC process described in Chapter-8

therefore would undergo necessary changes

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan could not

be ascertained as nomadic tribes did not visit these sites when ERM conducted field visits The general

migration pattern of pastoral nomads is expected to have faced constraints of Covid-19 restrictions If

pastoral nomads or their representatives will be identified during the FPIC process an appropriate

decision on their participation will be taken

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

This section provides an understanding of the applicable national regulations that pertain to the process

of land procurement and the rights of the Indigenous Peoples and a comparison between the provisions

of the same against the IFC PS 7 requirements

It should be noted that the Environmental and Social Impact Assessment (ESIA) Reports4 and the

Resettlement Action Plans (RAP) provide a detailed understanding of applicable regulations This

section is focused on the government land procurement process and its impacts on the collective rights

of the Indigenous Peoples identified in the project

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in 2018

The allotment of government land for these three solar parks is done under provisions of the MP Land

Revenue Code 1959 The Chapter-XVIII of this Code deals with rights in abadi5 (habitation area) and

un-occupied land and its produce

The Madhya Pradesh Land Revenue Code (MPLRC) was enacted in 1959 and has undergone several

amendments since then It was recently amended in 2018 and 2019 These recent amendments along

with other changes changed the procedure for allotment of unoccupied government land Some of the

land allotment letters were prior to this amendment and others after this amendment (see details in

Section 42) Table 21 below provides a comparison of key provisions in pre and post 2018

amendment

Table 21 Key Provisions of Land Revenue Code

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

Collective (Nistar) Rights on Unoccupied Government Land

Section 114- Land recordsmdash In addition to the map and

Bhoo Adhikar Pustikas there shall be prepared for each

village a khasra or field book and such other land records as

may be prescribed

Section 233- Record of unoccupied landmdash A record of

unoccupied land shall in accordance with rules made in this

behalf be prepared and maintained for every village

showing separatelymdash (a) unoccupied land set apart for

exercise of nistar rights under Section 237

Section 114 (e) (i) (ii) requires

the details of all unoccupied land

be maintained as described in

Section 233 One Such

document is the Nistar Patrak

under Section 234 Section 233 A record of all unoccupied land shall be prepared for every village and urban area in accordance with rules made in this behalf

Preparation of

Nistar Patrak

and change in

entries in

Nistar Patrak

Section 234 (1)- The Sub-Divisional Officer shall in

accordance with the provisions of this Code and the rules

made thereunder prepare a Nistar Patrak for every village

embodying a scheme of management of all unoccupied land

in the village and all matters incidental thereto and more

particularly matters specified in section 235

Section 234- same as 1959 Sub

section (2) (3) (4) have been

removed

4 Three separate ESIA Reports for Solar Parks one for each Solar Park one for the Neemuch Transmission Lines (Units 12

and 3) and another for the Transmission Lines for Agar and Shajapur Solar Parks (for Units 4 to 8) have been prepared 5 According to the MP Land Revenue Code 1959 abadi means the area reserved from time to time in a village for the residence

of the inhabitants thereof or for purposes ancillary thereto and any other cognate variation of this expression such as village site or gaonsthan shall also be construed accordingly No change was made to this definition in the subsequent amendments to the code

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(2) A draft of the Nistar Patrak shall be published in the

village and after ascertaining the wishes of the Gram Sabha

it shall be finalised by Sub-Divisional Officer

(3) A copy of the Nistar Patrak so finalised shall be kept in

the office of the Gram Panchayat

(4) On a resolution passed by the Gram Sabha by a majority

of not less than two-thirds of the members present and

voting the Sub-Divisional Officer with the prior sanction of

the Collector and also after making any such inquiry as he

deems fit inter se change the entries in the Nistar Patrak

(b) Record additional unoccupied land under any entry in the

Nistar patrak for fulfilment of further Nistar rights of villagers

Matters to be provided for in Nistar Patrak

Section 235- The matter which shall be provided for in the

Nistar Patrak shall be as follows namely

(a) terms and conditions on which grazing of cattle in the

village will be permitted

(b) the terms and conditions on which and the extent to

which any resident may obtain-

(i) wood timber fuel or any other forest produce

(ii) mooram6 kankar7 sand earth clay stones or any other

minor mineral

(c) instructions regulating generally the grazing of cattle and

the removal of the articles mentioned in paragraph (b)

(d) any other matter required to be recorded in the Nistar

Patrak by or under this Code

Section 235- same as previous provision of Land Revenue Code

Provision in

Nistar Patrak

for certain

matters

Section 236 - In preparing the Nistar Patrak as provided in

Section 235 the Collector shall as far as possible make

provision for-

(a) free grazing of the cattle used for agriculture

(b) removal free of charge by the residents of the village for

their bona fide domestic consumption of-

(i) forest produce

(ii) minor minerals

(c) the concessions to be granted to the village craftsmen for

the removal of the articles specified in clause (b) for the

purpose of their craft

Section 236 - same as previous

provision of Land Revenue Code

Collector to

set apart land

for exercise of

Nistar rights

Section 237 (1) Subject to the rules made under this Code

the Collector may set apart unoccupied land for the following

purposes namely-

(a) for timber or fuel reserve

(b) for pasture grass bir or fodder reserve

(c) for burial ground and cremation ground

(d) for gaothan

(e) for encamping ground

Section 237 (1) remains same

6 Soil used particularly for road paving 7 In India an impure concretionary carbonate of lime usually occurring in nodules in alluvial deposits and especially in the

older of these formations

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(f) for threshing floor

(g) for bazar

(h) for skinning ground

(i) for manure pits

(j) for public purposes such as schools play grounds parks

road lanes drains and the like and

(k) for any other purposes which may be prescribed for the

exercise of right of Nistar

237 (2) Lands set apart specially for any purpose mentioned

in sub-section (1) shall not otherwise be diverted without the

sanction of the Collector

Section 237 (3) Subject to the rules made under this Code

the Collector after securing the land mentioned in clause (b)

of subsection (1) to minimum two percent of the total

agriculture land of that village may divert such unoccupied

land as mentioned in sub-section (1) into abadi or for

construction of roads state highways national highways

canals tanks hospitals schools colleges Goshalas and

any other public utility projects as may be determined by the

State Government

Provided that the land set apart for the purposes mentioned

in subsection (1) shall not be diverted and allotted to any

person for agriculture purpose

Section 237 (4) When it becomes indispensable to divert the

land set apart for the purposes mentioned in sub-section (1)

for such development and infrastructural projects which are

owned or approved by the State Government but not

covered under sub-section (3) the Collector after satisfying

himself on alternatives available and also on obtaining land

of equivalent area for fulfilling the same nistar rights from the

concerned project may divert the land for such purposes by

passing a reasoned order to this effect Thus in case Nistar

land needs to be diverted for the project the project needs to

make available an equivalent area for the replacement of the

same nistar rights

The section 237 (2) is removed

Section 237 (3) remained same

Section 237 (4) remains same

Rights in Fruit Bearing Trees and other trees in Un-Occupied Government Land

Section 239 (1) Where before coming into force of this

Code any fruit bearing tree was planted by any person in the

unoccupied land of any village and is so recorded then

notwithstanding that such land vests in the State

Government such person and his successor in interest

shall from generation to generation be entitled to possession

and usufruct of such trees without payment of any royalty or

other charge whatsoever therefore

Section 239 (6) the State Government may make rules for

carrying out the purposes of this section

Section 239 (1) same as 1959

Section 239 (6) The unoccupied

land on which any tree planting

permit or tree patta has been

given prior to the commencement

of MP Land Revenue Code

(Amendment) Act 2018 may be

used for any public purpose by

the order of Collector If any

interest of the holder of such tree

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

planting permit or tree patta is

adversely affected due to such

use the holder shall be entitled

for such compensation which

shall be calculated in such

manner as may be prescribedrdquo

Exclusive jurisdiction of revenue authorities

Section 257 - Except as otherwise provided in this Code or

in any other enactment for the time being in force no Civil

Court shall entertain any suit instituted or application made

to obtain a decision or order on any matter which the State

Government the Board or any Revenue Officer is by this

Code empowered to determine decide or dispose of and in

particular and without prejudice to the generality of this

provision no Civil Court shall exercise jurisdiction over any

of the following matters - (w) any claim to modify any entry

in the Nistar Patrak

Section 258 (1) The State Government may make rules

generally for the purpose of carrying into effect the

provisions of this Code

(2) In particulars and without prejudice to the generality of

the foregoing powers such rules may provide for (lviii) the manner in which the wishes of the villagers shall be ascertained under Section 234 (2)

Section 257 - same as 1959

Section 258 (1) and (2) (lviii)

same as 1959 it should be noted that the Section 234 (2) was removed in 2018 Amendment

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers Diverting the un-occupied

government land8 categorised as grazing land that is recorded in Nistar Patrak (there may be other

grazing land available) and such other Nistar rights9 including the right in fruit bearing trees and other

trees in unoccupied government land after the amendment in 2018 does not require any consent

process with concerned village community

Hence it is expected that the government land allotted for the project prior to the 2018 Amendment of

MP Land Revenue Code is expected to have involved a resolution of concerned Gram Sabha As per

Sec-6 of the Madhya Pradesh Panchayat Raj Act 1993 the quorum of every meeting of Gram Sabha

shall not be less than one-tenth of the total number of members of the Gram Sabha or five hundred

members of the Gram Sabha whichever is less The Act does not specify presence of women in

Gram Sabha to be mandatory

Other Indian laws which has provisions for consent process are not applicable to this project and an

overview of them is provided in Box 31 below

8 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands 9 Nistar rights refer to collective rights of a revenue village to use specified government land for the purposes mentioned in

S235 of MP Land Revenue Code This includes right to free grazing cattle collecting minor minerals construction materials burialcremation grounds for religious and cultural events etc

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Box 21 Other Indian Laws with provisions for consent process and their applicability

22 International Social Safeguard Policies Applicable to the Project

221 IFC Performance Standards

The part of PS1 dealing with Management Program envisages an Indigenous Peoples Plan (IPP) as a

thematic plan and should be developed by qualified experts with substantive experience For projects

with adverse impacts to Indigenous Peoples the client is required to engage them in a process of

Informed Consultation and Participation (ICP) and in certain circumstances the client is required to

obtain their Free Prior and Informed Consent (FPIC)

The FPIC from the affected communities of Indigenous Peoples is required when the following special

circumstances (in paragraphs 13ndash17 of Performance Standard 7) are present

Impacts on lands and natural resources subject to traditional ownership or under customary use

Relocation of Indigenous Peoples from lands and natural resources subject to traditional

ownership or under customary use

Significant impacts on critical cultural heritage that is essential to the identity andor cultural

ceremonial or spiritual aspects of IPs lives

Where a project proposes to use the cultural heritage including knowledge innovations or

practices of Indigenous Peoples for commercial purposes

IFC PS7 requires to avoid adverse impacts on Indigenous People and if adverse impacts are

unavoidable the project should prepare an Indigenous Peoples Plan outlining the actions to minimize

andor compensate for adverse impacts in a culturally appropriate manner Some of the key

provisions with respect to IPP are

A free-standing IPP may be prepared or it may be a component of a broader community

development plan

The IPP should detail actions to minimize andor compensate for adverse social and economic

impacts and identify opportunities and actions to enhance positive impacts of the project on the

Indigenous Peoples

Where appropriate the IPP may also include measures to promote conservation and sustainable

management of the natural resources on which the Indigenous Peoples depend

The IPP should include a clear statement of roles and responsibilities funding and resource

inputs a time-bound schedule of activities and a budget

The IPP shall be regular monitored and should be flexible to allow for it to be adapted as needed

if circumstances change

222 World Bank Operation Manual OP 410

The World Bankrsquos Operational Policy on Indigenous Peoples (OP 410) aims at ensuring that the

development process fosters full respect for the dignity human rights and cultures of IPs thereby

In Indian context the constitutionally recognized Scheduled Tribes are usually considered as Indigenous Peoples

while determining their entitlements under international social safeguards systems

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006( FRA) is not

relevant as no forestland was diverted The Provisions of the Panchayat (Extension to the Scheduled Areas) Act

1996 (PESA) acts is not applicable for the project as the project site is not in a schedule V area There are no

specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement

consultation and consent

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

contributing to the Bankrsquos mission of poverty reduction and sustainable development To achieve this

objective Bank-assisted projects which affect IPs provide them a voice in design and implementation

avoid adverse impacts where feasible or minimize and mitigate them and ensure that benefits

intended for them are culturally appropriate

The Bank recognizes that IPs are commonly among the poorest and most vulnerable segments of

society and in many countries they have not fully benefited from the development process It also

recognizes that the identities cultures lands and resources of indigenous peoples are uniquely

intertwined and especially vulnerable to changes caused by development programs Because of this

issues related to indigenous peoples and development are complex and require special measures to

ensure that IPs are not disadvantaged and that they are included in and benefit from these programs

as appropriate

Under the OP 410 the Bank requires the borrower to undertake a social assessment to evaluate

projectrsquos potential positive and adverse effects on the IPs and to examine project alternatives A

project that affects Indigenous Peoples the borrower engages affected IPs in a free prior and

informed consultation (FPICon) process

Note The World Bank adopted Environment and Social Framework (ESF) which comprises of ten Environment

and Social Standards (ESS) The ESS-7 deals with Indigenous PeoplesSub-Saharan African Historically

Underserved Traditional Local Communities which requires FPIC to be obtained in special circumstances where

customary rights on natural resources used by IPs is impacted The WB has financed the renewable projects to

MNRE prior to adoption of the new ESF in Dec 2019 The Shajapur Solar Park is under the old WB safeguards

and therefore the new ESF is not applicable

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard Policies of IFC and WB

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers The diversion of the un-

occupied government land10 categorised as grazing land that is recorded in Nistar Patrak (there may

be other grazing land available) and such other Nistar rights including the right in fruit bearing trees

and other trees in unoccupied government land after the amendment in 2018 does not require any

consent process with concerned village community A comparison of key provisions of PS-7 vis-agrave-vis

legal provisions in Indian context is provided in Table 22

Table 22 Comparison of Provisions of Consent Process in Applicable Indian

Regulations vis-agrave-vis Provisions in IFC PS-7

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Assessment of Impact on Indigenous People

The client will identify through a process of Social and Environmental Assessment all communities of Indigenous Peoples who may be affected by the project within the projects area of influence The client will assess the nature and degree of the expected social cultural (including cultural heritage) and environmental impacts (direct and indirect) on them and avoid adverse impacts whenever feasible

There is no requirements for environment impact assessment (EIA) for Solar Park Projects There are no specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement consultation and consent

10 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands Such usages will be confirmed only through the Tarneem process for each site

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Preparation of IPP

The clients actions will be developed with the informed consultation and participation of affected Indigenous Peoples and contained in a time-bound plan such as an Indigenous People Plan or a broader community development plan with separate components for Indigenous Peoples

There is no legal requirement for an Indigenous Peoplersquos development plan

Consultation and Consent from affected IPs

In projects with adverse impacts on affected communities of Indigenous Peoples the consultation process will ensure their free prior and informed consultation and process of community engagement will be culturally appropriate and commensurate with the risks and potential impacts to the Indigenous Peoples

The acquisition of the private land owned by ST will be done through MP Consent Policy 2014 and the RAP addresses the impact on individual ST land ownersoccupiers The impact on customary rights (such as Nistar rights) over collectively used unoccupied government land is dealt under the provisions of MP Land Revenue Code 1959 There is no consultationconsent process for diversion of grazingNistar lands under MP Land Revenue Code 1959 (As amended up to 2019) The consent process in other Indian laws such as FRA or PESA which has consent process is not relevant to the project

Land Revenue Code had a requirement for Gram Sabha consent to be taken prior to diversion of

Nistar rights as part of the 2018 Amendment the same provision was removed As most of the

government land for Shajapur Solar Park was allotted in 2017 Table 23 below provides a

comparison of provisions of the consent process under MP Land Revenue Code 1959 (prior to Nov

2018 amendment) vis-agrave-vis requirements under IFC PS-7

The key elements of FPIC process as per IFC PS (including Guidance Notes- GN) identified for

comparison includes

1 Requirements of information disclosure (as in PS-129) 2 Informed consultation and participation (as in PS-130-31 and PS-710) 3 Good Faith Negotiation (as in GN-725) and 4 Consent and documentation (as in PS-712)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Information Disclosure

Relevant project information must be disclosed to Affected

Communities and other stakeholders to enable them to

understand the risks impacts and opportunities of the project

The Project will provide Affected Communities with access to

relevant information on

the purpose nature duration and scale of the project

risks and potential impacts and relevant mitigation measures

the envisaged stakeholder engagement process and

the grievance mechanism

Information disclosed must be relevant transparent objective

meaningful and easily accessible and in a culturally appropriate

local language(s) and format and is understandable to Affected

Communities

Under MP Revenue Code 1959 and MP

Panchayat Raj Act 1993 the information

disclosure to affected communities (including

Schedule Tribes) is limited to the intended

purpose of the allotment of unoccupied

government land

The disclosed information and proceedings are

recorded using the language of the State

The information disclosure to affected communities

prior to the meeting does not disclose all relevant

information particularly potential risks The

information disclosed is not easily accessible to STs

and other vulnerable communities

The process does not involve any grievance

mechanism

Informed consultation and participation

Where a Project has potentially significant adverse impacts on

affected communities an ldquoinformed consultation and

participationrdquo (ICP) process should take place ICP is an

organised and iterative consultation that involves a more in-

depth exchange of views and information leading to the Project

incorporating the views of those affected into project decision-

making on matters that affect them directly

The consultation process should capture both menrsquos and

womenrsquos views and their different concerns and priorities The

process should be documented in particular the measures taken

Section 234 of MP Revenue Code 1959 (Prior to

Nov 2018 Amendment) required the draft Nistar

Patrak of every village and any changes in therein

to be published by Sub-Divisional Officer with

prior sanction of the District Collector only after

ascertaining wishes of the Gram Sabha

(expressed through a resolution passed in Gram

Sabha held for this purpose)

As per Section 6 of the MP Panchayat Raj Act

1993 the Gram Sabha can be held with a quorum

of one-tenth of the total member of Gram Sabha

The MP Revenue Code does not require any

iterative consultation that involves in-depth

exchange of views

The participation of women and other vulnerable

sections is not mandatory

The quorum of the meeting is only ten percent of the

total members of the Gram Sabha The notice for

holding a special Gram Sabha is only 7 days and

there is limited information shared in terms of the

agenda of the meeting Hence a resolution passed

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

to avoid or minimise risks to and adverse impacts on the

Affected Communities and should inform those affected about

how their concerns have been considered

In addition the process should Involve Indigenous Peoplesrsquo representative bodies and

organisations as well as members of the Affected Communities of IPs and

Provide sufficient time for IPs decision-making processes

or five hundred members whichever is less

There is no specific requirement on presence of

women to fulfil quorum requirements

A special meeting of the Gram Sabha is held

within seven days of receiving the requisition

by a Gram Sabha with a bare minimum presence

does not reflect majority decision

The process does not require representative bodies

of IPs to represent their interests

Good Faith Negotiation

FPIC will be established through good faith negotiation between

the Project and the Affected Communities of IPs Good faith

negotiation generally involves (i) Willingness to engage in a process and availability

to meet at reasonable times and frequency (ii) Provision of information necessary for informed

negotiation (iii) Exploration of key issues of importance (iv) Mutually acceptable procedures for the negotiation (v) Willingness to change initial position and modify

offers where possible and (vi) Provision for sufficient time for decision making

The MP Revenue Code require neither iterative

prior consultation nor exchange of views with

administration

The administrative process for allotment of

unoccupied government land does not involve a

negotiation process through which their feedback

and concerns are incorporated or addressed

Consent

In certain circumstances the client is required to obtain the Free

Prior and Informed Consent (FPIC) of affected IPs FPIC does

not necessarily require unanimity and may be achieved even

when individuals or groups within the community explicitly

disagree The measurement of consent is expected to be

included in the lsquomutually accepted processrsquo for FPIC decision

making

Consent

Section 234 (4) required the Gram Sabha to pass

a resolution with support of a majority not less than

two-thirds of the members present and voting As

per Section 6 of the MP Panchayat Raj Act 1993

the Gram Sabha can be held with a quorum of one-

tenth of the total member of Gram Sabha or five

hundred members whichever is less There is no

specific requirement on presence of women to fulfil

quorum requirements

Consent

The FPIC process in IFC PS-1amp7 recognizes that

consent is not necessarily a unanimous decision

yet there has to be a mutually agreed threshold of

consent in an FPIC process that can vary from

project to project The threshold defined in MP

Panchayat Raj Act 1993 is one-tenth of the total

members of Gram Sabha passing a resolution with

support by two third majority present and voting

Thus the consent threshold for a resolution is 66

of the total members of Gram Sabha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Documentation

The client will document

The mutually accepted process (FPIC Decision Process Framework Document) between the client and Affected Communities of Indigenous Peoples and

Evidence of agreement between the parties as the outcome of the negotiations

Documentation

The documentation is limited to the entries in Gram

Sabha minutes book The entire set of

documentation is kept by Administration and not

shared with Gram Panchayat

Considering this low threshold as per legal

requirements the FPIC process requires a mutually

accepted threshold for decision making

Documentation

The documentation of the process carried out during

the Gram Sabha meetings leading to the resolution

though is written down in the Gram Sabha minutes

book however there is no guideline on what should

be covered Therefore a mutual agreement on

documentation requirement is necessary

As described in GN62ndash65 where government processes involve project-level decision and actions the client should review these processes in relation to the requirements of the Performance Standard and address identified gaps where feasible

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

The FPIC was triggered at the scoping stage on account of impact on grazing land and other natural

resources within the allotted government land on which STs have claims of customary use which is also

recognized under MP Land Revenue Code as Nistar rights The statement of different categories (which

are part of the Nistar rights of village community) of government land to be used for the proposed Solar

Parks from different villages and percentage of ST population in these villages is provided below

31 Affected Villages Government land used11 by ST Population

311 Neemuch Solar Park (Unit 1-3)

The Neemuch Solar Park is comprised of 3 units and the land is acquiredpurchased from 3 villages

The land category (classification in revenue records as per their currentintended use) is provided in

Table 31 below

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected Villages

Village Name

Govt Land Category in Hindi

Govt Land Category in English Sum of Area (Ha)

ST Population in of Total Village Population

Unit -1

Bardavada Chargah Grazing land 2271 55

Charnoi KamdalKK (Kabil Kast)

Grazing land 4013

DathaKamdal Land with stone outcrops and shallow soil

1655

Gair mumkinCharnoi Uncultivable waste land grazing land

492

Kabil Kast Cultivable 2

Kamdal Land with stone outcrops 169

KamdalDathaDahar Grazing land 4641

KamdalDathaKaKa Grazing land 4279

PK 052

NA 2053

Sub-Total (Bardawada) 25774

Kawai Datha Land with stone outcrops and shallow soil

8962 1992

NA 425

Sub-Total (Kawai) 9388

Total Unit 1 351615

Unit -2

Badi Datha 052 2292

Kabil Kast 11568

NA 5835

Sub-Total (Badi) 17455

Kawai NA 17846 1992

Sub-Total (Kawai) 17846

Total Unit 2 35301

Unit -3

Badi Charnoi (grazing) Grazing land 355 2292

Datha 3805

Gairmumkin Charagah

(grazing)

Uncultivable waste land

grazing land

4184

11 The MP Land Revenue Code recognizes the right to use for grazing collection of timber fire-wood earth morums and other

products (see Section 235 of MP Land Revenue Code)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

KaKa (Kabil Kast) Culturable wasteland 5

Kamdal 11179

NA 13727

Badi total 36945

Total Unit 3 3694557

Grand Total (Unit-1 2 and 3) 107408

Note land category for the units is as per the Allotment Letters NA= Not Available

The screening of the Census 2011 data shows that there is presence of ST population in all three

villages In Badi and Bardawada villages the land categories such as Charnoi Charagah are clearly

recorded as grazing lands The map below shows the location of village settlements and their area

designated as Grazing Land

The ST families in Badi and Kawai live in several small cluster of satellite settlements The Bardawada

had only 22 ST population with 4-5 families Bardawada is part of Dhardi Gram Panchayat and the ST

households live farther from the Solar Park boundary Their households are scattered and dependency

on the allotted government land for Bardawada village could not be established In terms of

concentration of ST population Badi and Kawai are considered as major ST settlements

Thus ~100 ST households in Badi and Kawai have a claim on customary use of ~18938 ha of

designated grazing land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages

wwwermco Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 26

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

312 Agar Solar Park (Unit 4 amp 5)

The Table 32 provides a break-up of the designated land categories of government land as per revenue

records in Agar Solar Park

Table 32 Agar Solar Park- Government Land- Land Use Category

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Agar Solar Park (unit 4)

Bijnakhedi Germumkin Uncultivable waste land 5598 0

Sub-Total (Bijnakhedi) 5598

Dudhpura Agriculture Agriculture 2243 0

Bardi NA 6631

Gothan Livestock rearing land 2

Khadar The floodplains formed by

yonger alluvium

018

Tree Plantation NA 1495

NA NA 5082

Sub Total (Dudhpura) 15669

Karwa Khedi Chragha Grazing land 251 0

K K NA 475

Khachar Grazing land 068

Pahad Hilly terrain 12392

NA 216

Sub Total (Karwa Khedi) 15346

Keasi Dehariya Gochar Grazing land 283 0

Sub Total (Keasi Dehariya) 283

Ladwan Bardi 7963 579

Charnoi Grazing land 947

Gochar Grazing land 2749

Kavil Kast 609

Khachar Grazing land 238

Pahad Hilly terrain 3062

Waterbody Water body 094

NA 475

Sub Total (Ladwan) 16137

Madhopur Germumkin Uncultivable waste land 1558 0

Sub Total (Madhopur) 1558

Pipalia Kumar Bardi 3492 0

Agriculture land Agriculture 506

Sub Total (Pipalia Kumar) 3998

Total Unit 4 611381

Susner Solar Park (Unit 5)

Palda Germumkin Uncultivable waste land 5689 036

NA 6928

Sub Total (Palda) 12617

Naharkheda Germumkin KaKa Uncultivable waste land 4125 0

Germumkin Uncultivable waste land 1868

NA NA 8908

Sub Total (Naharkheda) 14901

Umariya Charnoi Grazing land 3660 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Charokhar Grazing land 416

Chragha Grazing land 9114

Germumkin Uncultivable waste land 147

Kadim NA 011

Shaskiye Government land 218

Sheda NA 01

NA NA 20907

Sub Total (Umariya) 35806

Pipaliya Nankar NA NA 1822805 0

Total Unit 5 8161745

Note land category for the unit 4 is as per the kml file provided by RUMSL on 30012020 as the allotment letters did not carry

the land use details

Ladwan village has 579 of ST population (~12 households) who have claim on customary use of

3934 ha of designated grazing land Palda was found to have only 1 ST family Moreover no Charnoi

Chargah Gochar land is acquired from Palda Hence ST families in Ladwan were selected to be in

focus for FPIC process

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

313 Shajapur Solar Park (Unit 6-8)

The Table 33 provides a break-up of the land categories of government land as per revenue records

in Shajapur Solar Park In Shajapur Solar Park (Unit 6-8) five villages have ST population They are

Jawadi (034 STs) Parsula (1768 STs) Dehripal (018 STs) Fawaka (238 STs) and

Chouma (072 STs) Of these Dehripal Fawaka and Surajpur do not have any Charnoi Chargah

Gochar land impacted

Table 33 Shajapur Solar Park- Government Land- Land Use Category

Village Name Govt Land

Category in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Moman Badodiya-Unit6

Burlay Agriculture Agriculture 813 0

Germumkin Uncultivable waste land 224

Nala Stream Drain 138

Burlay Total 3191

Jawadi Agriculture Agriculture 198 034

(1 Household with

3 persons)

Gochar Grazing land 4189

Idhan Hetu For fuelenergy 209

Kabil Kast 316

Muram Hetu For Murram (fine aggregate) 063

Pahad Hilly terrain 339

Shivir Camping ground 041

NA 2011

Jawadi total 3596

Dhatrawada Agriculture Agriculture 338 0

Charnoi Grazing land 058

Chragha Grazing land 4058

Germumkin Uncultivable waste land 10638

Gothan Livestock rearing land 128

K Kast 557

Kabil Kast 1217

Kadim 074

Khadan Quarry 291

Khalihan Threshinggrain storage etc 167

Murum Hetu

Khadan

For Murram 125

Nala StreamDrain 042

Road Road 117

NA 6

Dhatrawada total 1841

Total (Unit 6) 25197

Momain Badodiya-Unit 7

Parsula Agriculture Agriculture 515 1768

(~41 households) Barda Rockyhilly 847

Barda Nistar

Chragha

Grazing land 947

Charnoi Grazing land 1064

Idhan Hetu

Surakshit

Secured for fuelenergy-

firewood

209

KK 137

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Khchar Grazing land 311

Nala Streamdrain 146

Nistar Chragha Grazing land 393

Parsula Total 12192

Dehripal Agriculture Agriculture 124 018

(1 Household with

5 populaiton)

Birdi GM 295

Brda 8054

Brda Lala 055

Chuna Hetu 105

Germumkin Uncultivable waste land 2015

Kankad Chuna

Hetu

For coarse aggregate and

lime

105

Khad ke Gadde 15

Muram Hetu For Murram (fine aggregate) 042

Watershed

Planning

Watershed planning 027

NA 1916

Dehripal Total 14004

Bijanakhedi Agriculture Agriculture 2199 0

Bardi 4101

Bardi Charnoi Grazing land 1274

Bardi 385

Chamdi Sthan 042

Charagah Grazing land 035

Charnoi Grazing land 018

Chragha Grazing land 1404

Germumkin Uncultivable waste land 858

Idhan Hetu 209

Khad ke gadhe Manure collection 084

Khalihan Hetu Threshinggrain storage etc 143

Mitti Hetu 063

Muram Hetu For Murram 063

Nala Streamdrain 36

Pathar Hetu For Stone 105

Road Road 203

Shivir Bhumi Camping ground 042

NA 288

Bijanakhedi total 11876

Fawaka Agriculture Agriculture 016 238

(4 Households with

28 population)

Brda Hilly terrain 863

Idhan Hetu Secured for fuelenergy-

firewood

25

Kakkad 418

Muram Hetu For Murram (fine aggregate) 179

Fawaka Total 1726

Chouma Agriculture Agriculture 392 072

(3 Households with

19 population)

Brdi Hilly terrain 562

Chamda Sthan For de-skinning 021

Charnoi Grazing land 989

GM 2943

Gothan Livestock rearing land 5

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Muram Pathar

Khadan

Murram (fine aggregate) 041

Nala Streamdrain 015

Chouma total 5463

Burlay Germumkin Uncultivable waste land 1543 0

Nala Streamdrain 019

NA 2604

Burlay Total 4166

Total (unit 7) 49427

Shajhapur (unit 8)

Surajpur Bardi Hill Terrain 898 203

(3 Households with

16 population)

Germumkin Bardi Uncultivable hill terrain 1170

Nala Streamdrain 597

NA 1894

Surajpur total 4559

Lalpur Beed 023 0

Beed Gair Mumkin 053

Brdi 2333

Charagrah Grazing land 18

Charnoi Grazing land 115

Gair Mumkin Brdi 1608

Kadim 115

Nala Streamdrain 055

NA 1684

Lalpur Total 6166

Hanoti NA 16291 0

Total (unit 8) 27024

Note land category for the units is as per the excel sheet received on 18062020 from RUMSL

Hence 41 ST households in Parsula who have a claim of customary use on ~3134 ha of

designated grazing land was selected to be the focus for FPIC Process The map below shows

the location of Parsula and the area designated as Grazing Land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

32 Selection of FPIC Villages

The assessment of the relevance of the four special circumstances that requires free prior informed

consent (FPIC) to be obtained from affected ST population was undertaken On the basis of the detailed

assessment undertaken as part of ESIA RAP along with targeted consultations with the IP

communities three circumstances are assessed to be not relevant to the project context

Relocation of STs was avoided while determining Solar Park boundary for all the three solar

parks and therefore no relocation of STs is anticipated from lands and natural resources subject

to traditional ownership or under customary use

The physical impact on cultural heritage sites with affiliation to STs is avoided in the three Solar

Park lay out and there is no potential significant impact on critical cultural heritage that is

essential to the identity andor cultural ceremonial or spiritual aspects of local STs community

The Solar Park does not propose to use the cultural heritage including knowledge innovations or

practices of STs for commercial purpose

Table 34 provides the list of villages where the FPIC process will focus covering ST households living

within it The assessment concludes that affected ST families have been living in these villages for

generations and have been using the government land (which was assessed to be subject to

traditional ownership or under customary use of the ST communities) allotted for Solar Park Project

for free grazing their cattle collection of fire-wood and collect edible fruits and plants mostly for self-

consumption The diversion of these land for the solar park will result in impacts on lands and natural

resources It was noticed that 7 other project affected villages had less than 5 ST households the

impact on their customary use of land acquired for the project was assessed and included in this table

too

Table 34 Villages to be covered in FPIC Process

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

Neemuch

Solar Park

Badi

(including 2

satellite

settlements)

80 (~450) Bhill Bardawada which is part of Dhardi Gram

Panchayat has only 4 ST families The location

of these ST households and consultations did

not indicate the government land allotted to

Neemuch Solar Park were under customary use

by them Kawai 17 (~100) Bhill

Agar Solar

Park

Ladwan 12 (~50) Bhill Palda village has 1 ST household and no

grazing (designated as Charnoi Chargah

Gochar) land is acquired from Palda

Palda village has 276ha of designated grazing

land and 28735ha of unoccupied government

land which they will continue to use for free

grazing their cattle and collection of fire wood

Hence the customary use of land by ST

household will continue with a negligible impact

Shajapur

Solar Park

Parsula 41 (~250) Bhill

Bhilala

Apart from Parsula 5 other affected villages

have less than five ST households These

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

villages (with the number of ST households)

are Jawadi (1) Dehripal (1) Fawaka (4)

Chouma (3) and Surajpur (3) The remaining

designated grazing land and total government

land for these 5 villages is provided below

Village Remain-

ing Desig-nated Grazing land (ha)

Total govern-ment land after Project allotment (ha)

Designated Grazing Land in percentage total Govern-ment land

Jawadi 2125 2705 786

Dehripal 241 8116 03

Fawaka 5032 5703 882

Chouma 2278 8167 279

Surajpur 1224 2592 472

The consultation with STs at Parsula informed

that unlike them these ST families do not keep

livestock in large number and mostly work as

construction workers Hence the land allotted to

Solar Park was not under customary use by

them for their livelihood

Note The ST families in these 7 villages will have access to the Grievance Mechanism to register their claims to

participate in the FPIC process In such a case their demands will be shared with concerned ST Committee (or

referred to Mediation Committee) and decision to include them in the process will be taken and an appropriate

mechanism for their representation and participation will be adopted

33 Impact on Nomadic Pastoral Communities

The seasonal use of the grazing and government land by nomadic pastoral communities was noticed

in scoping stage However further consultations with local villagers revealed that they do not visit

regularly and rarely camp on the land allotted to Solar Park These nomadic pastoral communities are

from the neighbouring state Rajasthan and are not recognized as STs in Madhya Pradesh

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan and

consultation with any pastoral nomadic tribes was not held as they did not visit these sites when ERM

conducted field visits The general migration pattern of pastoral nomads is expected to have faced

constraints of Covid-19 restrictions If pastoral nomads or their representatives will be identified during

the FPIC process an appropriate decision on their participation will be taken

ERM will consult GoMP to obtain records of grazing permits issued to pastoral nomads of other states

and determine if any of the villages impacted by Solar Parks figure in it More information on their

migration routes and pattern of seasonal use of forest and revenue land for grazing (which would help

assessing their collective attachment to impacted land) will be collected

Due to C-19 restrictions the regular migration patterns by pastoral nomads are affected in 2020 The

next migration season will be in Nov-Dec 2021 In absence of the particular pastoral nomads the

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

GoMP data on pastoral nomad communities who are issued permit will be used and their IPs status

will be screened through secondary ethnographic literature

FPIC is an iterative process If nomadic pastoral communities could not be consulted the rights of

pastoral nomads will be recognized in TDP and a provision for engagement with them to identify

adequate mitigation measures will be kept in TDP

34 Impact on Government and Grazing Land

The total geographical area of these selected FPIC villages grazing land (Charnoi) available after

allotment remaining government land after allotment percentage of the government land remaining is

given in Table 35 below As per provisions of the MP Land Revenue Code a minium of 2 of the

total private land in a revenue village is reserved as Charnoi or grazing land It is observed that

Ladwan and Parsula have more than this recommended minimum

Table 35 Designated grazing land (Charnoi) and Remaining Government Land

Solar Park Unit

Village Name

Geo

gra

ph

ical

Are

a o

f V

illa

ge

(h

a)

To

tal

Pri

vate

La

nd

To

tal

Go

vern

men

t L

an

d P

rio

r to

All

otm

en

t (

of

To

tal

Geo

gra

ph

ic

Are

a)

To

tal

Go

vern

men

t L

an

d R

eq

uir

ed

for

So

lar

Park

(

of

To

tal

Go

vern

men

t L

an

d)

Rem

ain

ing

Go

vern

men

t L

an

d a

fter

All

otm

en

t to

So

lar

Pa

rk

Perc

en

tag

e o

f G

overn

men

t L

an

d o

f

To

tal

Geo

gra

ph

ical

Are

a

( d

ecre

as

e o

r In

cre

as

e)

()

Desig

nate

d G

razin

g L

an

d

avail

ab

le a

fte

r P

roje

ct

all

otm

en

t (h

a)

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g

Lan

d)

of

the R

em

ain

ing

Go

ve

rnm

en

t

La

nd

()

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g)

Lan

d o

f th

e T

ota

l P

rivate

La

nd

Neemuch Solar Park Unit 1 amp2

Kawai 82698 20132 62566 (76)

24572 (39)

37994 (61)

46 (-30)

397 104 2

Neemuch Solar Park Unit 2 amp3

Badi 130055 33599 96456 (74)

51499 (53)

44957 (47)

35 (-39)

646 144 2

Agar Solar Park Unit 4

Ladwan 59076 31913 27163 (46)

16832 (62)

10331 (38)

17 (-29)

6682 6468 21

Shajapur Solar Park Unit 7

Parsula 69061 51439 17622 (26)

1162 (66)

6002 (34)

9 (-17)

1802 3002 4

Note () As per requirement under MP Land Revenue Code a minimum of 2 of the private land area within a

revenue village is to be reserved as Charnoi or grazing land for collective use by villagers

() Total Charnoi or grazing land prior to the allotment of Government land available in secondary sources

(Census 2011) is old as the land allotment took place between 2017 and 2019 Some Government Land

Allotment Letters mentioned the pre-allotment land category classifications (see Table 31 32 and 33) but this

data was not available for all vilalges to calculate the proportionate reduction of Charnoi land

The percentage of government land in some of the villages was high prior to the allotment of land for

Solar Parks For example the government land in Kawai formed 76 and that of Badi 74 of the

total geographical area Allotment of government land for Solar Parks has reduced the proportion of

the government land in these villages but the percentage of reduction varies from village to village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

For Kawai the percentage of government land after allotment has reduced from 76 to 46 (-30)

and for Badi it changed from 74 to 35 (-39) In Ladwan village the percentage of government

land changed from earlier 46 to 17 (-29) Similarly in Parsula the percentage of government

land changed from earlier 26 to 9 (-17)

The revenue department has designated some part of the remaining government land as Charnoi or

grazing land as per current Nistar Patrak The designated grazing land area meets the minimum

requirement of 2 of the total private land of that particular revenue village The designated grazing

land area forms 104 and 144 of the remaining government land for Kawai and Badi respectively

The designated grazing land in Ladwan forms 6682 of the remaining government land and in

Parsula it forms 1002 of the remaining government land

35 Impact on Cultural Sites affiliated to STs

The physical impact on all cultural sites (both for ST and Non-ST communities) was avoided by

excluding them from the Solar Park lay-outs However some of the cultural sites will be in close

proximity or access to some of them would be possible only through the Solar Park boundary An

overview of the cultural sites affiliated to STs for each of the Solar Parks is provided below

Table 36 Impact on Cultural Sites Affiliated to STs

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

Shajapur

Parsula

Gwalon ka

Mandi

Located within Solar

Park boundary

Adequate area (as agreed during FPIC

consultations) around the Gwalon-ka-Mandi to

be left unused in Solar Park lay-out

A road of sufficient width to be provided to

reach Gwalon-ka-Mandi

SPD will carry out improvements of the cultural

site after discussion with STs and other

communities using it

SPD will provide adequate civic amenities

(parking space drinking water lighting public

toilets etc) as per discussion with STs and

other community using it

Agar Solar

Park Ladwan

Gwaal Dev

Shrine

Located at the

margin of Solar Park

boundary

The SPD should leave the shrine and

adequate space around it in its lay out plan

Will ensure that access to the shrine by

community is maintained

The SPD will consult community to improve the

shrine Or build a new shrine for Gowals in the

new grazing area

Neemuch

Solar

ParkBadi and

Kawai

None The shrines and

cremation grounds

used by Bhils in

Kawai and Badi are

None

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

avoided in project

layout plan

No cultural sites or shrines with cultural significance for STs as a community was found during RAP

survey

36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure

The power evacuation infrastructures associated with these 3 Solar Parks are listed below The Pooling

Sub Stations (PSS) are located within the Solar Park boundary There will be 8 transmission line (TL)

sections whose footprint will be outside of the solar park boundary

Table 37 List of Power Evacuation Infrastructure

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

Neemuch

Solar Park

33kV220 kV Pooling Substation Unit-1 258 ha Located within the Solar Park

boundary 33kV220 kV Pooling Substation Unit-1 296 ha

33kV220 kV Pooling Substation Unit-1 887 ha

PGICL ISTS Station Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Neemuch

Solar Park

220 kV SC Line - 1 (From Unit 1 to Unit 2)

Transmission Line (TL) 1

332 km TL footprint is outside of the MP

Solar Park boundary includes

28 Towers (04 ha 144sqm

for each tower base) and RoW

of 13m width of 920ha

220 kV SC Line - 2 (From Unit 2 to PGCIL

ISTS substation)

Transmission Line (TL) 2

157 km

220 kV SC Line - 3 (From Unit 3 to PGCIL

ISTS substation)

Transmission Line (TL) 3

251km

Agar and

Shajapur

Solar

Parks

33kV220 kV PSS 4 in Unit 4 158 ha Located inside Solar Park

boundary 33kV220 kV PSS 5 in Unit 5 539 ha

33kV220 kV PSS 6 in Unit 6 513 ha

33kV220 kV PSS 7 in Unit 7 143 ha

33kV220 kV PSS 8 in Unit 8 196 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

PGCIL ISTS substation 830 ha Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Agar and

Shajapur Solar Parks

220 kV SC Line - 4 (From Agar Solar Park Unit 4 to interconnecting point with TL 7) Transmission Line (TL) 4

121 km TL footprint is outside of the MP

Solar Park boundary includes

372 Towers (536 ha

144sqm for each tower base)

and RoW of 13m width for

11914kms with 14951ha

220 kV SC Line - 5 (From Agar Solar Park Unit 5 to PGCIL ISTS substation) Transmission Line (TL) 5

2932 km

220 kV DC Line - 6 (From Shajapur Solar Park Unit 6 to Shajapur Solar Park Unit 7) Transmission Line (TL) 6

667 km

220 kV SC Line - 7 (From Shajapur Solar Park Unit 7 to PGCIL ISTS substation) Transmission Line (TL) 7

1646 km

220 kV DC Line - 8 (From Shajapur Solar Park Unit 8 to PGCIL ISTS substation) Transmission Line (TL) 8

6548 km

361 Use of Government Land in TLs Associated With Neemuch Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 38 below

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of STs

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

1 Arnya 088 958 007 784

Kheda Moka Ka Dol 223 1807 055 83

Bardawada 009 5651 002 55

Kawai 112 8265 016 20

2

Kawai 104

Badi 102 13004 012 23

3 Badi 285

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

Chaksodijhar12 043 4475 012 0

Grand Total 966 42782 011

The transmission line RoW comes from six revenue villages out of which 5 are Solar Park affected

villages There are 2 additional villages coming under TL RoW ie Arnya (088ha) and Kheda Moka

Ka Dol (223ha)

The population of Arnya in 2011 (as per census) was 969 out of which 784 were ST population

The Kheda Moka Ka Dol is comparatively a smaller village with total population of 348 and 83 of it

belong to STs

The proposed RoW of the transmission line will use 007 and 055 of the unused government land

in Arnya and Kheda Moka Ka Dol respectively The RoW of the Transmission Line does not pass

through any reserved or protected forest land The vegetation cover in the transmission line RoW is

mostly shrubs and grassland There would be no restriction on current use of the RoW for free grazing

of cattle Hence the transmission line will not impact customary use of the RoW land by ST

population in Arnya and Kheda Moka Ka Dol

362 Use of Government Land in TLs Associated With Agar Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 39 below

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST Population

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

4 Ladwan 068 13311 051 6

4 Pachora 089 273 033 0

5 Chkali Parmar 093 1567 059 0

5 Jhikadiya 266 13514 197 0

5 Pipalya kumar 229 13328 172 0

5 Chikali goyal 287 20523 140 0

5 Bhanpura 152 17482 087 0

5 Nipaniya Baijnath 381 29047 131 0

5 Tola Khed 095 3757 253 0

5 Kashi Bardiya 219 5362 408 2

5 Tola Khedi 042 3757 112 0

5 Kankariya 105 13354 079 0

5 Bhimlod 026 22564 012 0

12 Chaksodijhar is part of Badi Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

5 Bapcha agar 266 26778 099 0

5 Karadiya 144 23584 061 0

5 Mangwalia 24 15397 156 0

5 Gaysari 219 5293 414 0

5 Dehrinana 314 29331 107 0

5 Pharaspuri 142 16955 084 0

5 Bingaya Agar 112 150 075 0

5 Ralayti 267 2365 1129 0

5 Piplaya ghata 212 12811 165 0

RoW area passing through Kashi Bardiya village constitute 4 of the total government

The vegetation cover in the transmission line RoW is mostly shrubs and grassland There would be no

restriction on current use of the RoW for free grazing of cattle The RoW of the Transmission Line

does not pass through any reserved or protected forest land and therefore does not involve any

potential use of forest produce Hence the transmission line will not impact customary use of the

RoW land by ST population in Kashi Bardiya

363 Use of Government Land in TLs Associated With Shajapur Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 310 below

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

6 Burlay 494 2876 172 0

6 Bijnakhedi 158 14668 108 0

6 Dehripal 215 27508 078 0

7 Fawaka 237 6083 390 2

7 Dehripal 296 27508 108 0

7 Parsula 219 5891 372 18

7 Megha Khedi 098 3537 277 0

7 Singhwad 071 3118 228 24

7 Palakhi 072 1185 608 0

7 Baigaon 27 2387 1131 11

7 Bagwad 335 14239 235 13

7 Karkadiya 111 8267 134 0

7 Pipalya Kumar 101 13328 076 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

7 Pachora 306 13311 230 0

7 Shivgarh 024 13353 018 0

8 Abhaypur 026 7633 034 0

8 Alampura 337 12006 281 0

8 Arniya 233 9019 258 0

8 Bada Beed Jagatpura 32 49327 065 0

8 Barandwa 646 258 250 1

8 Batawada 022 5854 038 0

8 Bhadoni 096 1672 057 4

8 Bordagujar 217 120 181 0

8 Chachakhedi 155 482 322 0

8 Chandangaon 409 5711 716 0

8 Chikali Parmar 299 1567 191 0

8 Dhakadi 174 467 373 0

8 Dupada 181 3624 050 6

8 Fanya 349 22 1586 0

8 Gujar Khedi 02 0

8 Gurdadiya 188 1279 1470 2

8 Hanoti 004 34035 001 0

8 Harangaon 005 3034 016 0

8 Jadmi 371 3597 1031 0

8 Jhonkar 572 13653 419 0

8 Kadiya 06 13653 044 8

8 Kalmoi 009 3916 023 0

8 Kanasiya 109 40642 027 0

8 Karedi 003 16944 002 0

8 Kareli 197 16944 116 0

8 Katwariya 458 9312 492 33

8 Khajuri Kanad 085 3138 271 3

8 Kharkhadi 071 310 023 0

8 Khutpala 016 2359 068 0

8 Kundla Khurd 23 1507 1526 3

8 Merkhedi 26 26 1000 1

8 Mirapura 068 3767 181 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

8 Murdawan 292 101 289 0

8 Nanukhedi Mana 054 12851 042 0

8 Nanya Khedi Ahir 156 19092 082 0

8 Palasi 028 203 138 21

8 Pipalya Kumar 163 13328 122 0

8 Pipalya Naulay 28 8117 345 25

8 Rojwas 138 10 1380 0

8 Samgi 454 9921 458 2

8 Samgimanda 086 2578 334 0

8 Shankarpur 327 5782 566 0

8 Siroliya 003 10446 003 0

8 Surajpur 249 6912 360 2

8 Suwagaon 092 17558 052 9

The RoW of the transmission lines associated with Shajapur Solar Park passes through 60 villages

and 19 villages have ST population Out of these one village ie Parsula is covered in FPIC process

for Shajapur Solar Park

The RoW of the Transmission Line does not pass through any reserved or protected forest land and

therefore does not involve any potential use of forest produce The vegetation cover in the

transmission line RoW is mostly shrubs and grassland There would be no restriction on current use

of the RoW for free grazing of cattle Hence the transmission line will not impact customary use of the

RoW land by ST population in these 18 villages with ST population

364 Conclusion on FPIC Trigger for Transmission Lines

Based on the details of the presence of STs in Transmission Line corridors and assessment

of current land use and land classifications following inferences can be drawn

1 The TL Tower base and RoW corridor does not have any reserved or protected forest Hence potential customary use of forest produce is not relevant

2 The vegetation within TL RoW is mostly shrubs and grassland which is potentially used by local community for free grazing If any of this land under the ROW has been used for free grazing the people (including the ST families) will have other unused government land available to graze The disruption during construction and stringing will be very temporary and people can continue grazing under the ROW as before The few villages where the impact on unused land was higher than 10 either had no or very small (lt5) of ST population

3 The RAP survey has not identified any cultural site within TLs RoW or Tower Base area 4 There will be no physical displacement of any ST family for TLs

Therefore the circumstances requiring to obtain FPIC is not relevant for transmission lines

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

4 DESK BASED INFORMATION COMPILATION

41 Information Collection and Compilation

ERM has undertaken a desk based review of the information available This step involved collecting

and compilation of relevant information from following sources

Review of Detail Project Report (DPR) prepared by PwC dated October 04 2019

Detailed Project Report for the Project Dec 2019

The Project boundary map provided by RUMSL dated 19 Jun 2020

Collection of digitised maps of village boundaries

Compilation of demographic data using census 2011 data

Review of drone imagery for the project shared by RUMSL to identify EampS sensitivities in the

proposed project boundary

42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks

This section provides the timeline of land allotment process which is compiled from the allotment letters

of the land shared by RUMSL

421 Government Land Allotment for Neemuch Solar Park

Government land is being procured through allotments under the provisions of the Madhya Pradesh

Land Revenue Code 1959 (and its subsequent amendments) Table 41 provides details of the land

allotment for the Neemuch Solar Park

Table 41 Dates of Government Land Allotment for Neemuch Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Village

17-01-2018 7A-20(3)2017-2018 23868 Bardawada Kawai and Badi

30-05-2017 26A-20(3)2016-2017 43951 Kawai and Badi

Total 67819

Source RUMSL

67819 Ha (out of total 96894 Ha) is allocated to RUMSL through two allotment letters in the year 2017

and 2018 respectively out of the 96894 Ha of the required Government Land Both these allotment

letters predates the MP Revenue Code Amendment Act 2018 Allotment of additional 28979ha is under

process

422 Government Land Allotment for Agar Solar Park

Table 42 provides details of the land allotment for the Agar Solar Park which has been undertaken

between Nov 2016 and Jun 2019

Table 42 Dates of Government Land Allotment for Agar Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

28022019 7A-19(3)2017-2018 5633 Bijnakhedi

28022019 6A-19(3)2017-2018 7053 Dudhpura

21062019 31B-1212019-20 1495 Dudhpura

20-06-2019 5A-19(3)2017-18 15925 Karwakhedi

28022019 4A-19(3)2017-2018 283 Kasaidehriya

20062019 3B-1212019-20 19714 Ladwan

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

280202019 2A-19(3)2017-18 1683 Madhopur

21012019 1A-19(3)2017-18 3492 Piplya Kumar

04012018 9A-19(3)2017-18 602 Naharkheda

09082018 9A-19(3)2017-18 2669 Naharkheda

30112016 4819(3)2015-16 5562 Palda

02012018 8A-19(3)2017-18 5699 Palda

02012018 11A-19(3)2017-18 16116 Pipliya Nankar

06012018 10A-19(3)2017-18 17663 Umariya

09082018 10A-19(3)2017-18 15583 Umariya

Total 127137

Source RUMSL

127137 Ha is so far allocated to the project over 2016-2019 and 5106 Ha was allocated prior to MP

Revenue Code Amendment Act 2018

423 Government Land Allotment for Shajapur Solar Park

Table 43 provides details of the land allotment for Shajapur Solar Park which took place between May

2017 and Jun 2019

Table 43 Dates of Government Land Allotment for Shajapur Solar Park

Timeline

Allotment Letter

Number

Area

Allotted

Villages

26-05-2017 03A-19(3)2016-2017 14991 Dehripal Parsula Kadula MalyaHedi Burlay Jaawdi

Bhandedi Saagdiya Baandahedi Peepalkheda Dopada

Bijana Kheriyaema Kumhariyakhas Dangicha Jaaman

11-12-2017 26A-19(3)2016-17 618 Dehripal Parsula Favka Jaavdi Burlay Chooma

Bijnakhedi Dhatravada

26-05-2017 02A-19(3)2016-17 320969 Kukdeshwar Baamniyakhedi Bordi Khakri Majhniya

Rehli Rulki Dhanda Pidoniya Goyla Aakya Chauhani

Palsaavad Son Desrapur Khokriya Tonk Hanoti

28-06-2019 03A-19(3)2019-2020 8809 Kukdeshwar Bamniyakhedi Bodi Khakri Majhaniya

Rehli Rulki Tanda Pindoniya Goyla Aakya Chauhani

Palsawaad Son Besrapur Khokriya Tonk Hanoti

Total 117697

Source RUMSL

117697 Ha is allocated to the project over 2017-2019 and 108888 ha was allocated prior to MP

Revenue Code Amendment Act 2018

43 Review of Previous Community Consultations for Allotment of Government Land

The summary of the review of the timeline of the government land allotments in FPIC villages is provided in Table 44

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha Resolution

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Allotment prior to

Nov 2018

Amendment

67819 Ha 5106 Ha 108888 Ha

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DESK BASED INFORMATION COMPILATION

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

After Nov 2018

Amendment

28979ha 76077 Ha 8809 Ha

Total government

land in Ha

96894 Ha 127137 Ha 117697 Ha

Was the government

land allotted in FPIC

Villages pre or post

Nov 2018

Amendment in MP

Land Revenue Code

Government land allotted in

Badi and Kawai was prior to

Nov 2018 Amendment in MP

Land Revenue Code

Government land allotted

from Ladwan was on 20th

Jun 2019 which is after

Nov 2018 Amendment in

MP Land Revenue Code

Government land allotted

from Parsula was on 26th

May 2017 and 11th Dec

2017 was prior to Nov

2018 Amendment in MP

Land Revenue Code

Was Gram Sabha

resolution required

for FPIC villages

Yes No Yes

Thus as per legal provision (see section 31) the allocation of government land in BadiKawai from Neemuch Solar Park and Parsula in Shajapur Solar Park required a resolution of their respective Gram Sabha and an NOC by Gram Panchayat ERM did not get access to documentation of community consultation as part of seeking NOC from Gram Panchayats Conversation with Sarpanch of villages with ST population revealed that consultation was restricted to Gram Panchayat members Though they were initially reluctant to sign on the NOC after persuasion of District Collector they finally signed It is significant to note that the demarcation of the allotted land took place only recently (Jun to Aug

2020) and the construction process has not started yet13 The FPIC process in compliance to IFC PS-7 requirement is planned to be carried out prior to the construction works of these Solar Parks

13 The process for purchasing private land through consent process has been started in Neemuch

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

An overview of field visits and community engagement is provided in Section 12 above This section

provides details of the consultation carried out with affected STs in the process of preparation of this

FPIC Approach Paper The process involved following three steps

Step-1 Disclosure of intention of conducting FPIC process with affected STs in villages with

significant ST population

Step-2 Disclosure of final solar park boundary and key environment and social impacts (covered

in ESIA) and Participatory Rural Appraisal exercises with affected STs and meeting potential

representatives

Step-3 Identification of ST Representatives and formation of ST Committees and build mutual

agreement between them and RUMSL on Discussion and Decision Making Framework

The Step-1 was carried out in Dec 2019 and Jan 2020 The Step-2 was carried out in Aug 2020 The

details of the process followed during each of these steps are described in sub-sections below

Note The Step-3 is planned to take place in first week of April 2021 and the Draft Discussion and Decision Making

Framework described in Section 83 will be updated accordingly

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020)

The concerned Gram Panchayats identified with STs Population in previous sections were contacted

to inform them about the overall project and intention to conduct a FPIC process involving affected ST

families along with ESIA process The process included preparing a project profile in Hindi (See

Appendix A-B and photo documentation in Appendix C) and handed this over to the elected

representatives of concerned Gram Panchayats These meetings were attended by local RUMSL

personnel The project overview was explained during the meeting and their queries answered

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 51 below

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Badi 1 Sarpanch of Badi Village

2 Kalam Singh (Traditional Head

of Bhil Community in Mama basti)

3 Government Teacher in Bhil

Community

10-12 men from the village

6-7 women from ST (Bhil)

community

5th of December

2019

Kawai 1 Ghasilal (Ward Member in

Kawai Village)

2 Local communitypeople of

Kawai Village

20-25 persons from Kawai

Village were present

4-5 women

6th of December

2019

512 Disclosure of Intention to Conduct FPIC Agar Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Agar Solar Park

The details of the people contacted during this stage is provided in Table 52

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided-

Number of other community

members present during the

meeting

Date of the

Meeting

Ladwan (two

villages covered-

Ladwan and

Kerwa Khedi)

Mohan Singh (Sarpanch for

both villages)

10 persons in Ladwan and

Kerwa Khedi each

No female members were

present in Kerwa Khedi

In Ladwan seven (7) women

members were present in an

FGD that largely included

women

19th December

2019

Repeat visit on

29th January

2020

513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 53

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park

Name of Gram

Panchayat

Name of Person to whom Project

Information Sheet was Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Parsula Since there was no Sarpanch or

Gram Panchayat member present

during meeting one project

information sheet was provided to the

entire community which was

circulated within everyone present

during the consultation and signature

of 1 person from group (Mr Sujit

Singh) was taken

~15 persons in Parsula

Shajapur were present during

consultation also one separate

consultation was held with

women group having ~10

participants

30th January

2020

One common feedback during the consultations undertaken with the community in general and STs in

particular was they were not aware about the solar park boundary to judge which land will be used by

Solar Park and what will be left out for them The ESIA process was working on avoidance and

minimization measures Therefore they were informed that once the boundaries are fixed by the

design team the details will be shared with them

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises with STs (Aug 2020)

The solar park boundaries were finalized and provided to ERM in the last week of June 2020 by the

design team The draft environment and social impact assessment was completed in the month of

Aug 2020 The field-based activities remained suspended from Mar to Jun 2020 due to strict

restrictions imposed on travel and group activities due to Covid-19 pandemic Therefore the next

round of information disclosure and community consultations took place only in Aug 2020 at the time

of the RAP survey

Meeting Sarpanch and a few available Panchayat members

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village level Introductory amp Project disclosure meeting

PRA exercises with STs and information collection for IPP

- livelihood resource mapping

- mapping of social relations and influence and

- village profile

Identifying prominent persons from STs as potential representatives in FPIC process

Understanding the traditional decision-making system and existence of IPOs through key-

informant interviews

The schedule of field visits carrying out these activities is provided in Table 54 and details of these

activities are provided in subsequent sub-sections

Table 54 Site visit Dates and Site Activities

Solar Prak and FPIC Village

Date Site Activities

Agar Solar Park- Ladwan Village

06082020 Visited Ladwan and contacted Patwari Sarpanch and Panchayat Secretary and Fixed a Project Disclosure Meeting (a common meeting including all communities) for next day

07082020 Village level Project Disclosure Meeting at Ladwan

Participatory social mapping and information collection for IPP

Preliminary discussion with 2 Bhil families

08082020 ERM team met Sarpanch of Parsula to brief him and fix a meeting on 10th Aug

ERM team collected land details and village revenue map from Patwari of Ladwan

Shajapur Solar Park- Parsula Village

10082020 ERM team met Sarpanch and a few Panchayat members at Parsula

Shared Project Disclosure note and fixed a meeting with Bhil households of Parsula on 11th Aug

Mapping of social structure of Parsula village and village profiling

11082020 PRA exercise with Bhil community of Parsula resource mapping at Parsula mapping of social relations and influence

Discussion on impact of the Project on grazing land

Understanding the internal decision-making system amongst Bhil

Identifying prominent persons among Bhil families

12082020 Travelled to Neemuch Site from Agar

Neemuch Solar Park- Badi and Kawai village

13082020 Meeting with Sarpanch Badi and sharing of the Project Disclosure Note with Badi community (including all communities)

Social and resource mapping with Bhils in Badi

Understanding the internal decision-making system among Bhils at Badi

Identifying prominent persons among Bhil families

14082020 PRA at Mama Vasti Badi Resource mapping at Badi and Mama Vasti

Filling of village profile form for Badi and Kawai

Discussion on Impact of the Project on grazing land

Understanding the internal decision-making system at Kawai

Mapping the list of tribal leadership in village

Introductory visit to Kawai and sharing of Project Disclosure Note

15082020 PRA at Kawai with Bhil households

Identification of village leaders for Bhil of Kawai

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village)

5211 Meeting with Sarpanch

ERM team met Sarpanch of Ladwan Gram Panchayat at his residence in Karwakhedi village It was

learnt that Ladwan GP had submitted a letter to District Collector earlier expressing their unwillingness

to give away the government land for Solar Park The key concerns of the villagers included

Whether government has gone ahead on issuing tender for the Solar Park site Especially

without replying to their concerns

Whether the land identified by GP for establishing a Gaushala (shelter for abandon and old cows)

is allotted to the proposed Solar Park

How would the Solar Park address long term un-employment and livelihood issue in the village

ERM informed on its intention to conduct FPIC process covering the ST families in Ladwan village

and some of these questions will be answered during a structured process of discussion

5212 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch

Ladwan consists of two revenue villages Karwakhedi and Ladwan The Gram Panchayat office is at

Ladwan and the current Sarpanch is from Karwakhedi The village is dominated by the Gujjar

Community that is the second largest community in terms of population Scheduled caste is the

largest social group of village comprised of Banchhda Charmkaar Balai and Beldar

A community meeting was held where the Talati (village land revenue officer who keeps the land

records) was present The Talati informed them on the status of land allocation for the Solar Park

ERM showed the map showing the optimised project boundary with khasra numbers of the allotted

land ERM team informed them on the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The community expressed their

key concern about the impact on their livestock which forms an integral part of their livelihood

Community Meeting at Ladwan Explaining potential impacts and benefits

5213 PRA Exercises with STs

ERM held a meeting at a settlement cluster (nai-vasti or new settlement) where STs and SCs lived A

general discussion on their village history and livelihood issues were discussed The participation

level in this discussion was good A cross section of people from various age-groups and gender

participated in this discussion and shared relevant information and expressed their opinion A

separate meeting was held with women too (see Photos below)

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

According to the elders of the Bhils their generation is the 9th generation residing in Ladwan village

Prior to the three families (Gujjar Bhil and Charmakaar) establishing this village the village had

Muslim population in medieval times and they deserted the village as some epidemic broke out Three

people from Gujjar Schedule Caste and Bhil community first came from another village and settled in

the village As time passed other families from Banchada-Nat Sondhiya Balai and other started

settling in the village

The discussion also involved their religious and cultural practices and shrines There are three

Chabutarascaffold in the village which are their main place of worship There are two shrines ie

Gowal ka Devta close to the grazing lands and Nagdevta adjacent to the new colony outside the

village

A village corner meeting with men Participation of women in group discussion

The Shrine of Nag Devta at Ladwan Meeting with women at Ladwan

After the general PRA exercise involving a larger group a few active participants were picked up to

have more focused discussion on a few aspects Through participative discussions in these smaller

groups the social hierarchy and livelihood resources used by STs (and SCs living in the village) were

mapped

Creating the map of social hierarchy and influence The map drawn by community showing their

livelihood resources

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Social Groups and Influence Map

Most of the families in Ladwan have cattle that includes cow buffalo and goat Approximately 650 cattle that includes 450 cows and 200 buffalos exists in the village There are about 44 cows kept by Bhil households which is about 4 (on an average) cow per family Bhil households own about 100 goats which is about eight (on an average) goats per family Only one family (Chander Singh) owns two buffaloes Few individuals work as grazier for a cluster of houses and are paid 150 per cattle per month by the owners of cattlersquos The cattle owners hire women and youths for bringing fodder feeding and cleaning of cattle sheds collecting cow dung Payment is done on the monthly basis or the basis of hours of work The common land situated at the Right hand side of the main approach road to Ladwan village from Agar is used by the ST community for grazing their livestock ST families bring fodder firewood and fruits from the same portion This is the only place during rainy season where fodder is available for four months as rest of the area is under crops ST families cannot accesses any other commons which is encroached by the dominant familiescommunity According to the ST community if the village commons is taken by solar park then they do not have any option but to sell their livestock as they cannot afford to buy fodder for the livestock unlike the richer families in the village

Free grazing of a mixed herd of cattle and

buffaloes

A grazier bringing back cattle home at evening

5214 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 55 Names of Potential Representatives in Ladwan Village

Section of Representation Sl No Name of Representative Contact Number

Clan Representative 1 DevSingh-Kanhayialal

2 Mangushanker-Amar Singh

Gujjar

Sondhiya

Other OBC

SC

Bhil

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of Representation Sl No Name of Representative Contact Number

Youth Representatives 3 Babulal-Gangaram

4 Anandilal-Lalsingh

Traditional leader or Mukhia 5 DevSingh-Kanhayialal

522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village)

5221 Meeting with Sarpanch

The ERM team for this field visit was led by the IPs Expert comprised of four members including a

woman to facilitate participation of women The ERM team first met the Sarpanch of Parsula who was

not present in initial meeting held earlier in January 2020 The objective of this meeting with Sarpanch

was to share the project information with him and appraise him of the intention of the ERM team to

hold a meeting and participatory appraisals with ST families

5222 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch The Disclosure note had a map showing the

optimised project boundary with khasra numbers of the acquired land It included the key potential

environment and social impacts and what mitigation measures are proposed in ESIA report prepared

by ERM

5223 Joint Site-visit with Sarpanch and Other Leaders

Sarpanch wanted to visit the proposed project site along with the Patwari to explain him the project

boundary based on the land allotment records available with him ERM team facilitated a site visit by

Sarpanch Naib Sarpanch and Kotwar in presence of Patwari to explain him the proposed project

boundaries He shared his observations and concerns over the allocation for the Solar Park which is

used for grazing domestic livestock by villagers including ST households However he agreed to

facilitate an exclusive meeting with ST families next day

5224 PRA Exercises with STs

The Kotwar of Parsula village belongs to ST community He played a significant role in inviting the ST

families to participate in the meeting as well as shared crucial information on their social and cultural

aspects The meeting with ST families included approximately 40 people both men and women from

various age-groups ERM team showed them the map of Solar Park and explained them locations of

key components The community was divided into two to three groups to hold participatory

assessments

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments

Site visit with Sarpanch and explaining Project boundary

Participatory mapping of livelihood and natural resources within Project boundary

Community meeting with ST from Parsula village at Project site

Identification of a medicinal plant during site walk through

Facilitation of discussions with ST women from Parsula village

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gwalon-Ka- Mandi within Solar Park Boundary

Grazing lands used by Bhils Mapping

Rajputs are the dominant caste in the village and a person from the Rajput community is the Patel

(traditional leader) of Parsula village Rajputs control all village resources including sources of drinking

water and the irrigation

There are four religious places (Devsthan) of Bhils in Parsula village At all these places the priest is

from the Bhil community One platform is situated within the land allocated to the Project which is

called Gwalon ka Mandi It is recognised by all the community as the women worship at this place to

have good rains for better crop yield or agriculture Community gatherings are organized at this place

on few occasions in the year

The Bhil households reported to own about 2-3 (maximum 10) cows on an average per family and

about 2-3 goats Some families manage to sell three to five goats in a year ₹3000 to ₹ 8000 per

goat depending on the quality of the goat Families who rear cows manage to sell about 4 to 6 litre of

milk ₹40 per litre to private dairy at Chouma village The Bhil community uses the lsquoBirdirsquo hillock

adjacent to the northern side of the Parsula village for grazing their livestock along with other

communities residing in the village

5225 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 56 Names of Potential Representatives in Parsula Village

Section of

Representation

Sl No Name of Representative Contact Number

ClanHouse Cluster

Representatives

1 Meherbaan Singh 7970187292

2 Goverdhan Sigh 8718098704

3 Rahul 9098266244

4 Maakan 6162432391

5 Dheeraj Singh 8871384373

6 Rambabu 9752340827

7 Ballu 9399263367

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Sl No Name of Representative Contact Number

8 Bheru 7725027924

Youth Representatives 9 Kamal 6267658647

10 Rajesh 9009278550

Woman Representatives 11 Payal NA

Traditional leader or

Mukhia

12 Bhawanlal NA

523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages)

5231 Meeting with Sarpanch

Gram Panchayat Badi has 3 villages namely Badi Kawai and Sucharoki The ERM team met

Sarpanch of Badi on 13th Aug 2020 and explained the intention of holding meetings with ST families to

inform them about the FPIC process He advised that we should brief the community members on the

current status of the project first As most of the ST families work as wage labour he advised the

team to come early in the morning He assured to inform the ST families and ask them to cooperate

5232 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for a sample

Hindi version and Annexure-D for sample English version) to Sarpanch and other people present in

the meeting The Disclosure note had a map showing the optimised project boundary with khasra

numbers of the acquired land It included the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The meeting was held at the

center of the village

The community believes that Badi village is 1150 years old calculated based on the date inscribed on

a stone slab in the oldest house in the village It is a common belief that Bhil community came to the

village along with Rajputs The living memory of the community members goes at least six

generations back Badi has ~300 households and there are ~80 ST households Rajputs are the most

dominant community in the village Brahmins and Gujjars also influence the decisions of the village

Gujjars are the largest social group of the village followed by Bhils There are around 30 Muslim

families and they also have some influence on decision-making of the village Apart from Gujjar there

are three other OBC groups that are Sutar Kumhar and Nath

The STs live in three separate habitation clusters The first is in the main village habitation second is

roughly around 05 kilometres away and is called Khari ka Jhopda The third is located further away

around 25 kilometres Both are not connected through roads and one has to walk to reach them The

third habitation is further away where a group of recent migrants form Jhabua (referred as Mama Bhils

by villagers) live and is referred as Mama Basti These Bhil families came here to work as labourers in

the stone mines almost two decades back

At Kawai a meeting with village elders was held prior to discussion with ST families Rajput Gujjar

and Dhakad are the three dominant castes There are only 17 Bhil households in Kawai village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village disclosure meeting at Badi Meeting village elders at Kawai

5233 Site-visit and Walkthrough

The ERM team walked through the site to visit different clusters of ST settlements in Badi and Kawai

Some of the photographs of the main village and satellite smaller settlements where STs live is

provided below

A typical ST house in Badi main settlement The Platform where STs hold their community

meeting

The Khari ka Jhopda Mama Vasti

5234 PRA Exercises with STs

As ST households were found scattered in several small satellite settlements multiple meetings were

held involving a small group of 7 to 12 participants Every ST settlement or cluster of households

usually has a platform under a tree which is used for community meetings and decision making This

space was used for holding PRA exercises Participants were engaged in conversation on their social

relationship and decision making process The understanding gained from these discussions were

then demonstrated in diagrams They were asked if the diagram portrays the right picture or not

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Livelihood and resource mapping in Badi A smaller cluster level meeting at Badi

The village livelihood resource mapping- Kawai Participatory process of understanding

livelihood resources in Kawai

The social relationship and influence map for

Kawai

The social relationship and influence map for

Badi

Similarly a map of the village and surrounding area was created using the information shared by

participants in these meetings They were asked to show where they carry out their livelihood

activities such as farming and grazing etc They were asked to indicate those areas and identify

natural resources or cultural sites located in those locations

Some of the information important for deciding on the FPIC approach collected from these participatory

exercises are as follows

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gram Panchayat Badi has total 16 wards out of which Badi has 9 wards Out of these 9 Wards 2

are reserved for the STs (Bhil)

There are about 250-300 cows kept by Bhil households which is about 4 (on an average) cow

per family Bhil households own about 450 goats which is about 5-6 (on an average) goats per

family Hence for ST families goat is a more popular livestock than cows

Almost all the houses have used locally available stone in constructing the walls of the houses

Pucca houses have used cement and sand as mortar whereas kuchha houses have used mud

The communities fear the loss of access to these stones will make house construction costly and

people who earn from stone quarrying will be impacted

The traditional leader (Mukhia) of Bhils decide on disputes related to marriage and other social

issues Women do not play an active role in decision-making process

Each household cluster of Bhil households have a number of cultural sites where local deities are

worshiped For example in Khera-ka Majra has four cultural sites Ghadiya Bheruji Bhut Maharaj

Bhut Babaji and Dungri Balaji Similarly there are a few cultural sites for goddesses like Leva ki

Mata and Dahana Mataji are located within the Project boundary In all these shrines the priests

belong to Bhil community

STs (Bhils) worship Devnarayan Khejara Mata and Sawria jee in Nimbaheda in Rajasthan The

religious leaders from these places are held with respect and are accepted as mediators or

decision makers for important matters

5235 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table 57

They will be considered for nomination to the representative committee and contacted for capacity

building on FPIC process

Table 57 Names of Potential Representatives in Badi and Kawai Village

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Clan Tola

Representative

Badi Main 1 Gheesalal-Nathulal 9575486482

2 Basantilal-Mangilal 7354345531

3 Motilal-Hiralal 9109003022

4 Nanalal-Ratanlal

Khaira Ka Jhopda 5 Lalu ndashRamlal

6 Tulsi-Devilal

7 Tawarlal-Vardaji

Kawai 9 Ramlal-Hajarilal

Ratanlal

Bherulal(Teacher)

Bherulal- Bhawani

Shantilal

Fargulal

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Youth

Representatives

Badi 10 Omkaar ndashKailaji 8718057436

11 Shyamlal-Mangali 9302086906

Mama Vasti 12 Dinesh ndashThawar Singh

13 Prakash-Ramesh

Woman

Representatives

Badi 14 Kesarbai-Devilal

15 Kavita-Dhanraj

Mama Vasti 16 Shanti-Ramesh

17 Mamta -Naklesh

Kawai 18 Sunder Bai-Bherulal

(Sudibai-Devilal Shimla bai-

Chandrulal LeelaBai-

Chittarmal Prem bai-Gopilal)

19 Kanyabai-Bhuvaniram

Traditional leader or

Mukhia

Badi 20 Bhawani-Laxmi

21 Amar singh-Ramlal 7354325923

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL

A key element in designing a FPIC Process is a mutually agreed and appropriate lsquoengagement and

consultation process14rsquo The lsquoFirst Draft FPIC Approach Paperrsquo was prepared and shared with RUMSL

for their review and comment A virtual workshop was held with RUMSL team on 27th Aug 2020 In

this workshop PS-7 requirements of ICP and FPIC in general and the specific FPIC process designed

for Solar Parks was presented and discussed After their feedbacks were incorporated the lsquoDraft

FPIC Approach Paperrsquo was shared with IFC-WB for review and comments

The objective of these internal discussions are to build an internal institutional consensus on the

appropriateness of the designed engagement and consultation process to comply with the

requirements under IFC PS-7 The subsequent steps for consultations with affected STs and finalizing

a mutually agreed lsquoDiscussion and Decision Making Frameworkrsquo is discussed in Section 81

14 GN-ampGN22 emphasizes to have a shared view of the FPIC process between Project proponent and affected IPs The Project

proponent and affected IPs to agree on an appropriate engagement and consultation process as early as possible and commensurate with the scale of impact and vulnerability of the communities

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INDEPENDENT FACILITATOR AGENCY

6 INDEPENDENT FACILITATOR AGENCY

61 Need for FPIC Process Facilitation Agency

An independent agencyexpert to facilitate the FPIC process is required for the following reasons

There is a strong likelihood of other dominant communities in the village intervening and trying to

influence the internal discussion and decision making by IP The presence of the FA will help

documenting such attempts of external intervention and the presence of the FA may act as

deterrence and help avoid such attempts to interfereinfluence the process

The IP representatives need an intensive process of orientation and capacity building It will be

more effective if this is conducted using the Malvi dialect instead of Hindi Therefore a good

community facilitator with familiarity on Malvi dialect will be helpful

The women and youth will need capacity building and facilitation of their internal discussions prior

to the community level meetings

The facilitation support to IP community in general and IP representatives in particular will require

proficiency in the local dialect Malvi and knowledge of local livelihoods and alternative options

Involvement of a local agencyexpert who also speaks the local dialect and with a good

understanding of local livelihoods (particularly grazing and livestock keeping) will demonstrate

fairness and transparency in the process

62 Screening of FPIC Process Facilitation Agency

ERM identified Institutions (Universities Government Departments and Research Institutes etc)

NGOs and INGOs located and active in Madhya Pradesh state After a preliminary screening selected

potential individualsorganizations were approached to find out their availability and willingness for the

assignment The criteria used for screening included qualification profile affiliation with the type of

institutionsorganizations nature of worksprojects completed working experience with IPsTribes in

Madhya Pradesh conducting meaningful consultation community mobilization and stakeholder

engagement familiarity with World Bank Group safeguardsrsquo policies and procedures comfort with

written and spoken English and local dialects etc The list of independent experts and organizations

screened for the role of facilitation agency is provided in Table 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

1 University of MP Bhopal

Department of Sociology

Dr Arvind Chauhan

Professoramp Head

7999345226

Two candidates with post-PhD and PhD

qualifications from Department of

Sociology interested in working but having

no experience were not considered

2 Dr BR Ambedkar

University MHOW MP

Professor RD Maurya

Former Dean amp Head

Department of Sociology

Old AB Road Gram

Dongargaon Dr

Ambedkar Nagar Madhya

Pradesh 453441

07324 274 377

The retired Professor amp Dean

recommended a college lecturer

belonging to BhilIP from Govt college

Neemuch may be considered as a

resource person in future as appropriate

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

3 Tribal Research and

Development Institute

Bhopal

Rita Singh

35 Shyamla Hills Rd

Bhopal Madhya Pradesh

0755-25570882551257

This institute of MP government is

involved in administration and research

aspects of tribes in Madhya Pradesh

There are full time staff and the person

required for the assignment is not

available However the Government

functionaries may be the resource persons

in sharing information and performing

advisory roles during implementation as

appropriate

4 Institute of Social

Sciences Ujjain

Dr Tapas Faculty

7342510978

Berasiya Rd Navi Bagh

Bhopal Madhya Pradesh

462038

0755 273 0946

The faculty suggested to contact the

Bhopal based NGO (Samarthan)

5 The Samarthan NGO

Bhopal

Shradha kumar

Bhopal Madhya Pradesh

shrdhasrigmailcom

9826912948

The Program Director reported no work

being undertaken by the NGO in proposed

project area and was reluctant to

undertake the assignment She however

mentioned to help coordinating with the

local NGO if available in Neemuch area

and has not responded so far

6 Xavier Institute of

Development and Action

and Studies Jabalpur

Dr Mehul Chauhan

Former Faculty

9977064882

The former faculty suggested two NGOs

(Concept Society and Gramodyog

Sansthan)

7 The Concept Society

Indore

Ms Hemal Kamat Director

9425350272

The candidate appeared for interview has

preferred to be engaged independently

instead of as a NGO

8 Gramodyog Sansthan

Mandala MP

Mr Hariom Shukla

Manager

7999064147

Even after agreeing no one finally

appeared for personal discussion and

interview

9 Balram Sewa Samaj

Neemuch

Mr Kamla Shankar

Manager

7838960968

The only NGO reported to working on

legal aspects in Neemuch area has not

expressed interest to work as FA

10 UNICEF office Bhopal Nagesh Patidar Project

Officer WASH

97525 98212

The staff of UNICEF suggested the name

of suitable candidates and all of them

have appeared for interview and have

expressed the interest in proposed project

work

11 Debate Trust (Referred

by Action Aid Bhopal

Amitav Singh and Leena

Singh

Debate Trust

Duplex C-22 Alkapuri

Near DRM Office

Habibganj Bhopal-462024

Action Aid India had prepared a brief

manual on FPIC (published in 3 Indian

Languages including Hindi in 2018)

reflecting the Indian context and its related

legal system The manual was intended to

help CSOs for their ready reference and

larger reach out Mr Narendra Sharma

who was based in Actionaidrsquos office at

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

0755-2985007 0755-

2417656 9425018144

9425004556

debateindiagmailcom

Bhopal played a key role in preparing the

Manual in Hindi version

Mr Narendra Sharma referred the NGO

Debate Trust who had experiences in

working with Panchayats

A screening using preferred criteria was undertaken of the shortlisted agencies and details are

available in Appendix-F None of these agenciesindividuals have worked for a FPIC process earlier

Hence an agency which was available and willing to undertake the activity was taken on a trial basis

to help in conducting PRA exercises and sample household survey required for preparation of IPP

63 Roles and Responsibility for FPIC Process Facilitation Agency

The role and responsibilities of the FPIC FA will be as follows

Table 62 Roles and Responsibilities of FPIC FA

Phase Responsibilities

I Formation of local committees with STs Representatives

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Hindi (Malwi dialect) Translation of TDPIPP and designing Information sharing tools

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs (particularly women and youth groups) and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation of the FPIC Process and Preparation of FPIC Process Report

Documents of outcome of the FPIC Process including FPIC AgreementMOUJoint Statement of PrinciplesAgreed Mitigation Plans etc

64 Terms of Reference for FPIC FA

The terms of reference for FPIC FA covering villages to be covered specific responsibilities

deliverables personnel requirement and organizational profile and experience is provided in

Appendix-G

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The PS-7 recommends to have a lsquoshared view15 of achieving ICP or FPICrsquo mutually agreed ldquoFPIC

Decision Process Framework Documentrdquo which is based on principles of Good Faith Negotiation

(GFN) The Designing a lsquodiscussion and decision making frameworkrsquo to achieve the FPIC as per GN

on PS-7 should considers the socio-political context within which the affected IPs households live as

well as impacts of the Project This section deals with key-elements considered for designing the

FPIC process as per requirements in IFC PS-7 and GN-7

71 Use of Language

The PS-7 emphasizes use of the IPs language in the FPIC process It was found that BhilsBhilala in

Ladwan and Parsula are relatively small community and they have been living with close socio-

cultural ties with other communities Hence they use Bhilli (their traditional language) very little The

proficiency of the current generation in the Bhilli vocabulary is too limited to use this in discussion of

the Project and its impact Hence their preference is the use of local (Malvi) dialect of Hindi which

they speak along with other communities in the village The Bhils in Badi and Kawai speak Malvi

dialect with some influence of Rajasthani language as it is at the border of Madhya Pradesh and

Rajasthan

In general the written material on the project is expected to be in Devnagri script using the vocabulary

consistent with Malvi dialect to the extent possible The FPIC FA will have community facilitator who

is conversant with Malvi and explain the written material using the conversational Malvi dialect

72 Use of Customary Decision Making Process and Traditional Leaders

The Bhils in Ladwan reported that they resolve disputes between families through intervention of the

elderly member of the familyclan (Baijwal and Dalodia) or go to other prominent people in the village

such as the priest in the local temple or the landlord on whose land they work The customary leader

of Bhils who covered a cluster (~10 to 12) of Bhil settlements existed earlier (at least 3 generations

back) and the current generation has not sought their help in dispute resolution in their living

memory

The BhilBhilala of Parsula belong to a number of clans (Dalodia Paretia Renkewal Vasunia etc)

and the elder member of the clan is usually approached to resolve any internal disputes There used

to be a collective council (panchayat) covering 5 to 10 villages but these have been non-functional

over the years They also approach the village Sarpanch and prominent personalities from other

communities in the village to resolve disputes involving land and livestock The matters related to land

are finally referred to the Tehsildar (land revenue officer) for resolution The local administration also

plays a significant role in resolving inter-community disputes

In Badi-Kawai they still have a traditional Mukhia (leader) who wields influence in community

matters Each Bhil village has an elder who is considered the mukhia or leader There are designated

places where elders hold community meetings to discuss conflicts among Bhils and matters related to

their social norms and customary laws governing marriage and inheritance etc If matters are not

resolved at the village level community elders (Biradari Panchayat) then the matter is escalated to a

forum of community elders from 5 or 10 villages with Bhil population The highest level of escalation in

the customary decision making system is to refer the matter to a Biradari Panchayat of community

elders from 25 Bhil villages16 These traditional leaders residing outside of the villages directly

impacted by the Project are accommodated as member of the proposed Mediation Committee

15 Refer GN-7 GN22 which mentions that lsquothis should ideally be done through a framework document or plan and client should

document support for the agreed process from the affected population 16 GN-7GN36(i) acknowledges that there may be circumstances where formal and informal leaders of the Indigenous Peoples

reside outside of the Projectrsquos area of influence

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

In general the affected IPs communities use familyclan elders to resolve minor disputes and involve

prominent people from other communities like the priest Sarpanch or other prominent personalities in

the village for resolving their conflicts The matters related to land is resolved by intervention from

local administration (Tehsildar and District Collector) If the matters are related to their customary laws

on marriage social relationship or inheritance the unresolved matters can be escalated to a council

that comprises of elders from 5 10 or 25 villages The traditional Biradari Panchayat has been losing

its power as the younger community members considers their decisions regressive and approach

Gram Panchayat leaders (Sarpanch) or take help from the Police and Court of law Considering the

preference of new generation to go to non-ST Gram Panchayat leaders and local administration they

are considered for the Mediation Committee

73 Promoting Participation of Women and Youths

Women specifically stated during consultation that they do not participate in decision making in their

traditional community meetings which are convened for resolving disputes Though the women come

to attend the community meetings they hardly ever participate and express their views

The BhilBhilala youths do not have traditional or customary forums at which they express their views

They accept the decisions taken in the family or at the clan-level However there are a few educated

young people in the village who have distinct views about their future

As free expression of the views by youths and women in BhilBhilala community meetings is not a

social norm separate meetings of these groups where they are able to express their views openly is

proposed as part of their internal decision making process The FPIC FA will facilitate these separate

meetings and keep external interventions in these meetings to the minimum The views expressed by

them in these meetings should be tabled in joint meetings of the community for consideration

74 Expectation on Material Information Prior to Discussion

It is understood from the preliminary round of discussions with ST communities that they expect the

following information to be shared with them

Details of the Project (lay-out plan) and the related activities that are going to be implemented

Schedule of starting of the possession of allotted government land and purchase of pattaprivate

land

Details of land khasra numbers proposed to be taken for the project

Amount of paymentcompensation consideration amount of the land and assets (including on the

government land) that will be taken by the project

What economic and other entitlements and benefits will be provided to the families dependent on

the allotted government land

If private land is purchased then they will lose the source of income generation or livelihood (as

they are hired for a year on contract basis daily wages take land on lease for cultivation and

take care of the cattlersquos etc) what will their entitlements (economic package) be

What options will the Government or the Solar Park Company provide as alternative to the

common grazing land as cattle and goat breeds they keep require free open grazing and not stall

feeding

What alternative livelihoods will be offered to those Bhil families who will be landless after losing

the governmentpatta land they currently use (though owned by others)

It was expressed that the Project proponents share many documents but the community wants

confirmation that the content is authentic Hence community expects that signed and verified

documents should be shared as part of the FPIC process which can be referred in case of conflict or

contradiction

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The relevant information is scattered in ESIA RAP and IPPIPDP A concise information disclosure

dossier will be prepared by ERM and used by FA during the FPIC process

75 Need for Capacity Building of IP Representatives

The interaction with potential ST representatives from these FPIC villages shows that convening a

community meeting and steering the internal discussion to reach consensus will be a new experience

for them Most of them are semi-literate and will face challenges in understanding the Project details

on their own such that they can then explain it to other community members Therefore following

activities are required

A capacity building workshop for the potential IP representatives to explain the Project its impact

and mitigation measures in the Draft IPPIPDPTDP in detail Although the RAP-LRP disclosure

will happen at the community level and ST families will attend those meetings the Draft

IPPIPDPTDP will also explain these entitlementsbenefits in simple language

Presence of experienced community meeting facilitators (from FPIC FA) for community meetings

will help these ST representatives to have focused discussions documentation of views

expressed and decisions made in those meetings

The women and youths usually do not participate in taking decisions on community issues

Hence the women and youth representatives need orientation through separate sessions

In addition to formal trainingorientation sessions the IP representatives may be taken on

exposure visits to nearby solar parks for improving their understanding

76 Need for a Mediation Mechanism

The ST Committee will hold meetings with the representatives of the Project (RUMSL) to discuss

relevant points and reach a mutual agreement While such discussions are likely to result in reaching

mutual agreements on a number of agenda items the discussions may hit dead-end on some issues

All such unresolved issues will be documented as a dissent note for their reconsideration in the second

round of meeting

If the discussion between ST Committee and the representatives of the Project on any significant issue

reaches a deadlock the matter will be referred to a mediation mechanism The mediation will be done

by a high level committee which will comprise of 4 members

An IP representative nominated from the larger tribal leadership of the area (from their customary

council of 10 or 25 villages) but not belonging to the Project village

The elected representative of the concerned Gram Panchayat or a person nominated from GP

and acceptable to the ST Committee

A senior officer from the District Tribal Welfare Department

District Collector or an officer nominated by them

This Mediation Committee will be constituted at the beginning of the FPIC process and will be activated

only in the case of a significant deadlock This Mediation Committee will be involved to read the Final

FPIC Agreement (even when no matter is referred to them for mediation) and satisfy themselves that it

reflects mutual agreements reached through a fair and credible process17

17 This is proposed in order to provide an external validation of a free and fair FPIC process prior to signing of the FPIC

Agreement

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

77 Following Principles of Good Faith Negotiation

Good faith negotiation generally involves 6 principles (see Table 71) The proposed FPIC Discussion

and Decision Making Framework (DDMF) adheres to these principles with slight modifications

keeping the public health concerns associated with the Covid-19 pandemic

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

1 Willingness to engage in

a process and availability

to meet at reasonable

times and frequency

Both parties need to agree to avoid large gatherings and un-necessary

physical meetings A mechanism for tele-consultations will be explored to

keep the physical meetings to the minimum

The internal discussion meetings of STs will be in smaller groups (in the

open rather than in closed rooms) to avoid large gatherings

There will be two meetings between RUMSL and ST Committee and

similarly number of proceedings by Mediation Committee will be limited

The meeting schedules will be finalized beforehand and Covid-19 public

health protocols as applicable at that time will be followed

2 Provision of information

necessary for informed

negotiation

The basic information on the Project and its potential environment and

social impacts are already provided in state language (Hindi)

The essential information requirement by ST Committee is identified and

these information will be provided in simple information dissemination

tools The FA will further explain them for their better understanding

3 Exploration of key issues

of importance

The likely key issues of importance are grazing and cultural sites located

within Solar Park boundary A small task-force comprising of

representatives of RUMSL as well as ST Committee will carry out a field

inspection prior to their first meeting The task force will observe Covid-

19 protocols issued by Government

4 Mutual acceptable

procedures for the

negotiation

The lsquoDiscussion and Decision Making Frameworkrsquo signed by both parties

will have a commitment to hold all meetings and activities complying the

Covid-19 protocols and advisory issued by Government

5 Willingness to change

initial position and modify

offers where possible

The first meeting will resolve issues where both parties can reach

agreement easily The positions of both parties on contentious issues will

be recorded during first meeting The FPIC FA will record the written

positions of both parties on these contentious issues and share with

them The FPIC FA and ERM will hold separate meetings with both ST

Committee and RUMSL Team after 15 days to understand any changes

in the stated position The FPIC FA and ERM will take a decision on

holding the second and final meeting on these contentious issues when

both parties agree to modify their offers and a meaningful discussion is

possible

6 Provision for sufficient

time for decision making

The ST Committee will benefit from the capacity building and assistance

through FPIC FA to conclude their internal decision making The first

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

meeting between ST Committee and RUMSL Team will be held after a

sufficient gap As the number of ST families participating in the FPIC

Process is small it is expected that it will not take them long to reach

internal consensus However STs will be encouraged to have more

meetings internally to be able to discuss within themselves

78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and Supportive Environment

In these FPIC villages the Project requires to achieve both ICP for mainstream communities and

FPIC for ST The existing and past relationship between RUMSL and affected communities plays a

significant role in FPIC process It is learnt from the news report as well as from consultations that

some villages (particularly Ladwan) have decided to protest against the Solar Park as loss of grazing

land is not acceptable to them The protesters had organised a demonstration and also submitted

letters to the District Collector regarding their objections Ladwan village has a strong network of

women self-help groups (SHGs) who are interested in a dairy development program Thus reduction

in grazing land is perceived by them to have a detrimental impact on their long term employment

opportunity and income generation These SHGs have members from SC OBC as well as ST

families

In other FPIC villages ie Parsula Badi and Kawai though there is a concern for loss of grazing

land yet opposition to Solar Parks is passive There are some specific interest groups among the

non-ST communities who would seek answers to their specific concerns For example in Parsula

village the non-ST families (both in Parsula as well as neighbouring villages) have informally

purchased the patta land Their main concern is whether and how they get the compensation for

these land parcels which will be paid to patta owners In Badi and Kawai the number of people who

have encroached on the government land is comparatively more Also there are few influential

people who earn from selling stones (the most popular building material in that area) extracted from

the allotted government land Thus a range of RAP-LRP issues are expected to crop up during

community engagement In all these villages the affected ST communities though would consider

the compensation and benefits offered to them yet it would be difficult for them to disregard the

collective decisions made by other communities in their village

Thus considering different interest groups involved existing social relationship influence of STs in

decision making it would be a challenge to hold a single engagement process18 for both STs and

mainstream communities Therefore we recommend a parallel or concurrent engagement process for

ST and mainstream (non-ST) communities The comparison of the ICP process for mainstream (non-

ST) and FPIC process for ST is provided in Table 72

18 GN-7 GN31 recommends a single engagement process complying to the higher standard (GFN and FPIC Agreement) where

a Project requires to achieve ICP for mainstream and FPIC for IP It reads ldquoSince the achievement of ICP and FPIC as separate processes with different groups within a community or between proximate communities may be difficult and in some cases be a cause of division within the community a single engagement process resulting in one agreement is generally recommended In such cases the process and agreement should reference the higher standard (ie GFN and agreement demonstrating FPIC) Whether the agreement entails different benefits for the differently affected groups will depend on the project context the Affected Communities and the nature of project impactsrdquo

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages

Aspect Engagement Process with non-ST

(ICP)

Engagement Process with ST (FPIC)

Management Plan ESMP + RAP-LRP IPPIPDPTDP

Representative

Body

Gram Panchayat (existing body) ST Committee (specifically constituted for

this process)

Provision of

information

necessary for

informed

negotiation

Executive summary of Draft ESMP

RAP-LRP in Hindi

Abridged Draft IPPIPDPTDP in Hindi (use

of Malwi vocabulary as much as possible)

Capacity building by FPIC FA

Help from FPIC FA to understand issues

Willingness to

engage in a

process and

availability to meet

at reasonable times

and frequency

One public meeting for receiving

feedback on Draft ESMP RAP-LRP

One round of internal discussion by STs

assisted by FPIC FA

Two rounds of meetings between RUMSL

and ST Committee

Mediation Committee meetings (if required)

Exploration of key

issues of

importance

Key issues covered in ESIA RAP-LRP

will be discussed

Key issues covered in Draft IPPIPDPTDP

will be discussed

Mutual acceptable

procedures for the

negotiation

Informal agreement A formal lsquoDiscussion and Decision Making

Framework Agreementrsquo is signed by both

parties

Willingness to

change initial

position and modify

offers where

possible

Demonstrated through incorporations of

feedbacks received from public

disclosure and consultation

Structured engagement process

documenting (signed by both parties at the

end of the meeting) points agreeddisagreed

and demonstrating the flexibility in their

respective positions

Provision for

sufficient time for

decision making

The time for public meeting for

receiving feedback will be decided in

consultation with Gram Panchayat

Sufficient time for capacity building by FPIC

FA internal discussions and gap between

first and second meeting between RUMSL

and ST Committee

Outcome The public meeting for receiving

feedback on Draft ESMP RAP-LRP is

held peacefully and satisfactory

explanationresponse to

feedbackqueries is provided

Incorporating response to all key issues

raised in public meeting in Final ESMP

RAP-LRP

The Final IPPIPDPTDP incorporates points

mutually agreed between RUMSL and ST

Committee

The FPIC Process Documentation Report-

(vetted by independent FPIC FA and

Mediation Committee) provides an overview

of the FPIC process

FPIC Agreement signed by RUMSL and ST

Committee

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Note The FPIC Process Documentation Report prepared by FA under ERM guidance will cover the

whole process (including all meetings by ST and Non-STs decisions key issues discussed etc)

The use of impacted land for free grazing is practiced by both ST and Non-ST communities The ESIA

and RAP-LRP also address impacts on grazing and have prepared a framework for Grazing Resource

Management Plan The engagement with non-ST population will highlight the mitigation measures

with regard to grazing issue (particularly Grazing Resource Management Plan) in ESIA and RAP-

LRP The feedback from non-ST population on mitigation of impact on grazing will be subsequently

incorporated into Grazing Resource Management Plan in particular and relevant sections in ESIA and

RAP-LRP The non-ST population will be clarified that TDP will have some additional benefit for STs

and therefore will be consulted separately

Thus the separate ST committees will not be perceived to take any decision that affects collective

interest of all villagers particularly the powerful non-ST communities The Gram Panchayat and

Sarpanch is provided a place in Mediation Committee and will be involved in resolving key-issues

referred to them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

81 Introduction

This lsquoDraft Discussion and Decision Making Framework19rsquo is prepared after field visits and

consultations with affected STs and a workshop with RUMSL (see Section-5 for details) This Draft

DDMF will be shared with ST Committees on behalf of RUMSL and after appropriate modifications

(without diluting the key-elements for compliance to PS-7 requirements) the final version will be

signed by representatives of both parties Section 814 provides subsequent steps in this regard

The three proposed solar parks are located in three different Districts and each one will have an

independent Solar Park Developer (SPD) or Concessionaire The impact of each solar park and the

social context of the affected STs also differ in these three locations Hence three ESIA reports as

well as three IPPIPDPTDP are prepared The Draft IPPIPDPTDP prepared for each Solar Park has

a specific package of benefits for the STs in FPIC villages This will be discussed during the proposed

FPIC process and the outcome of this process will be a written lsquoFPIC Agreementrsquo that adopts the Draft

IPPIPDPTDP and agrees to cooperate in its implementation

82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo

The subsequent steps for discussing this Draft Discussion and Decision Making Framework with STs

in the selected FPIC villages (grouped at each Solar Park level) is discussed in this section

821 Appointment of FPIC Facilitation Agency and Orientation

The requirement of a FPIC Facilitation Agency (FA) and their roles and responsibilities are discussed

in Section-6 above The FA will play a key role in forming the ST Committees (at each Solar Park

level) and informing them on their rights to FPIC their legal rights on natural resources prior to their

acceptance of this lsquoDraft Discussion and Decision Making Frameworkrsquo Hence one of the agencies

screened for this role will be appointed and brought on board

After on-boarding them ERM will carry out their orientation by holding a series of virtual workshops with

them The orientation program will include the following

The ICP and FPIC requirements as per IFC PS-7 and WB OP 410

Key findings of the ESIA-ESMP including Draft RAP-LRP

An overview of consultations in FPIC Villages

The Draft IPPIPDPTDPs

The Draft Discussion and Decision Making Framework

The Capacity Building of ST Committees on FPIC and their customary rights on natural

resources

822 Introducing FPIC FA to RUMSL and FPIC Villages

After the orientation of the FPIC FA the key persons will be introduced to the RUMSL team through a

physical meeting Subsequently a field trip will be planned to introduce the FPIC FA in FPIC villages

The RUMSL and ERM will introduce the FPIC FA to the contact persons from earlier field visits and

inform them about their role

19 The term lsquoengagementrsquo and lsquonegotiationrsquo was avoided to keep the language less confrontational and positive for both parties

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

823 Formation of ST Committees

ERM and FPIC FA will jointly discuss the structure and composition of the ST Committee at each

Solar Park20 with affected ST community As per suggestions from them ST Committees will be

formed and their nominations will be ratified through a group meeting21 The composition of the ST

Committee is described further in Section 8311 below

824 Capacity Building of ST Committees

The FPIC FA will discuss with the ST Committee on the time and venue for holding a capacity building

workshop The capacity building workshop will cover the following

The recognition of FPIC as their rights

Specific provisions of FPIC as per IFC PS-7 and WB OP 410

Applicable India Laws and recognition of their customary rights on natural resources

The Draft Discussion and Decision Making Framework (Draft DDMF)

The participation of RUMSL in this capacity building workshop will be optional and as per mutual

agreement by both parties The FPIC-FA will note down the suggestions of the ST Committee on the

Draft DDMF and share them with RUMSL

83 The Draft Discussion amp Decision Making Framework

The proposed discussion (engagement) and negotiation (decision making) framework will include 11

steps as illustrated in the Figure 81 below

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process

These steps are described in sections below

20 Agar and Shajapur Solar Park have only one FPIC village Hence the ST Committee will be selected from within the same

village Neemuch Solar Park has two FPIC village with several satellite ST habitations The ST Committee for Neemuch Solar Park will be larger to accommodate representation of different ST groups 21 The FPIC village level group meetings will be held keeping the Covid-19 public health guideline ERM will use professional

judgement on the acceptability of the selected committee for most ST households if the ratification of the ST Committee is not possible by a large public meeting

Formation of Committees

Acceptance of Draft Discussion and Decision Making

Framework

Disclosure of Draft IPP to ST Committee

Explaining Draft IPP to ST Committee

Internal Consultations by ST Committee

First RUMS and ST Committee Discussion

Second RUMSL and ST Committee Discussions

Reference to Mediation Committee

(if any)

Informing Community about Draft FPIC

Agreement

Final Community Meeting for Expression

of ConsentDissent

FPIC Agreement Signing

FPIC Process Documentation Report

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

831 Formation of Committees

The FPIC process will involve three committees for each Solar Park One representing the affected

ST community the other presenting the Project proponent (RUMSL) and the third a committee to

mediate between the two if the need be The composition of these committees are explained in sub-

sections below

8311 Formation of ST Committee for each Solar Park

Each Solar Park will have a ST Committee which includes representatives from all FPIC villages of

that Solar Park Each ST Committee will comprise of 7 to 13 members (or any odd number22) who

represent different sections of the ST community The principle for selecting the members of this ST

Committee will be as follows

One representative from each clanhabitation cluster (tola)

The clans which have more population may select 2 representatives

Two representatives from youths (18-25 years)

Two women representatives

One traditional leader (Mukhia) or ST community head from each FPIC village

Gowal (cow-herder) who takes othersrsquo cattle for grazing and earns livelihood from this

The ST Committee will select a chairperson to coordinate and conduct their internal meetings The

representative from the youth and women will hold separate group discussions within their sub-groups

and share their concerns preference and feedback The FPIC FA facilitating these internal meetings

will ensure that these points are tabled at the joint committee meetings The ST Committee will

prepare a list of households and the adult members (gt18 years) who will be part of the FPIC process

8312 Formation of RUMSL Teams

RUMSL will form three site level teams (one for each Solar Park) which will include the District

Renewable Energy Officer (DREO) of the concerned district and a staff member to assist him They

will report to RUMSL Managing Director (MD) The names and designation of the RUMSL Team are

as follows

Level Designation Name Contact Number

Head office MDCEO Deepak Saxena

Social Development

Specialist

TBD

Site Level (Agar) DREO Deepak Bulani +91-9229924836

DREO- Staff TBD

Site Level (Shajapur) DREO- Prakash Salunke +91- 9926440877

DREO- Staff

Site Level (Neemuch) DREO- Sohanlal Bajaj +91-9827222217

DREO- Staff Balaram Rathod +91-9827323612

22 To avoid a deadlock on decisions

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The site level RUMSL Team will attend the meetings with ST Committee discuss the issues raised by

them sign on minutes of meetings and report to MD where prior approval is necessary The MD or

his authorised representative will take part in important meetings including meetings with the

Mediation Committee if required

8313 Formation of Mediation Committee

There will be a Mediation Committee for each Solar Park The Mediation Committee will comprise of

three members which will be chaired by the District Collector

Member Selection Process

STs Representative from the

Area Biradari Panchayat

The ST Committee after internal discussion will nominate a prominent person of their community outside of their village who is accepted as a member of Biradari Panchayat or similar bodies

Member from Gram

Panchayat

The ST Committee will nominate a member (or ex-GP member) who is known for his role in resolving local disputes

District Tribal Welfare

Department

A senior Tribal Welfare officer will be nominated by District Collector or the Head of Department of Tribal Welfare

District Collector (or his

representative)

The District Collector of the district within which the particular solar

If District Collector is not available she should decide on who can act as his representative

The ERM FPIC-FA ST Committee and RUMSL Team jointly visit these MC members and brief them

on their role in FPIC Process The formation of the MC should be completed prior to the first meeting

between ST Committee and RUMSL Team

832 Acceptance of Draft Discussion and Decision Framework

After the capacity building of ST Committees FPIC FAERM will coordinate with both parties to fix a

date and time for a joint meeting to discuss the Draft Discussion and Decision Making Framework and

ratify it after making necessary modifications

The composition of the committees mentioned in Section 831 and the steps mentioned in Figure 81

will be explained to ST Committee during their capacity building process (described in Section 824)

A Hindi (with Malwi words used to the extent possible) version of the lsquoDraft Discussion and Decision

Frameworkrsquo (Section 83) will be provided to ST Committee during the capacity building Thus the

affected IPs will get adequate time to discuss and come prepared for any suggestions from their side

to this meeting The

Both parties will discuss on a code of conduct commit to follow this during their meetings The code of

conduct will be based on following principles of good faith negotiation

(i) both parties will be available to meet at reasonable time and frequency

(ii) both parties to share information23 necessary for informed negotiation

(iii) both parties will be willing to change initial position and modify offers where possible

23 The Project will disclose information as per Information Disclosure Plan discussed in Section 513 of the Draft

IPPIPDPTDP The disclosure will include at minimum (i) project boundary (ii) impacts of the project (iii) entitlements and other benefits The information will be shared in a culturally appropriate manner and in a form and language easily understandable to the ST communities The FPIC FA will help the ST community understand and process this information prior to the joint meetings with RUMSL

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

(iv) both parties will give each other reasonable time24 for decision making

(v) both parties will put their view peacefully and will not resort to violence and threat and

(vi) both parties will not engage in discussion when they are under influence of any intoxicants

Both parties will discuss and agree on the quorum required for their meetings and how proceedings of

their meetings will be documented Some suggestions for discussion in this regard are

(i) The quorum for the meeting to be physical presence (or virtual participation) of at least 75 of

the ST Committee and RUMSL Team The FPIC FA will check the quorum of the meeting prior

to starting the proceedings

(ii) The Documentation Assistant in FPIC FA will have the responsibility to record the audiovidoe

of the meeting proceedings

(iii) The FPIC FA will write down the key decisions taken during the discussion and the MoMs will

be read out prior to taking their signature

(iv) The FPIC FA will ensure that ST Committee and RUMSL Team understand the decisions made

If any party express that they need more time (to discuss internally or take approvals) such

information will be recorded

(v) The FPIC FA will also document any dissent expressed by any individual member while

supporting the collective decision of the group she represent in the MoM

The agreed Discussion and Decision Making Framework will have a target time-frameschedule for

completion of each step in the FPIC process Both parties will put their best efforts to complete the

process within t(his time-frame ERM will keep a track of the progress of FPIC process as per this

time-frame and help both parties to avoid unnecessary delays FA will draft the Agreement on Final

Discussion and Decision Making Framework (in Hindi) in consultation with RUMSL and ST

Committee

The final (after ratification) lsquoDiscussion and Decision-making Frameworkrsquo the FPIC-FA will hand over a

signed copy to both parties (ST Committee and RUMSL Team) A pamphlet or poster on accepted

code of conduct will be prepared and displayed at the meeting venue FPIC-FA will request all

members attending the meeting to follow these rules

833 Disclosure of Draft IPPIPDP to ST Committee

ERM will prepare Draft IPPIPDPTDP (in English) for each Solar Park A Summary Draft IPPIPDPTDP

will be translated to Hindi (with use of Malwi as much as possible) ERM will share following documents

to both parties as soon as they ratify the lsquoDiscussion and Decision Making Frameworkrsquo

The Draft IPPIPDPTDP (in English)

Summary Draft IPPIPDPTDP25 (in Hindi)

A simple 4-6 page brochure describing (illustrations where possible) the benefit package

proposed in Draft IPPIPDPTDP

The ST Committee members will be given one week to go through the documents shared with them

and fix a date to explain the Draft IPPIPDPTDP Report

The RUMSL will be provided soft copies of these documents to upload them in their web-site from

where external stakeholders can access these documents

24 The time provided should be adequate to read verify and consult (internally or any external expert on the subject matter)

The FPIC-FA will consult both parties to decide what is reasonable and acceptable to both 25 The Summary Draft IPPIPDPTDP will be 20-25 page It will follow the structure of the IPPIPDPTDP but provide a non-

technical description of the content for easy understanding by ST Committee

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

834 Explaining Draft IPPIPDPTDP to ST Committee

ERM and the FPIC-FA will organize a workshop for ST Committee of each Solar Park at a suitable

location on an agreed date (at least after 7 days from sharing of the documents with ST Committee

The workshop will explain the impacts of the Solar Park and the range of mitigation measures and

project benefits mentioned therein

The FPIC-FA will orient them on how to hold consultations with different sections within their

community and document their views The ST Committee will be provided adequate copies of the

brochure describing the benefit package project boundary maps (in large flex prints) to help them

explain the Solar Project to their community members and hold internal discussions

ERMFPIC-FA will consult ST Committee and RUMSL Team to fix the date for first meeting between

RUMSL and ST Committee

835 Internal Consultation Process by ST Committee

FPIC-FA will help each ST Committee to prepare a tentative schedule for internal discussions The

women representatives will hold meetings with women and youths representatives will hold meetings

among young people The FPIC-FA will make itself available to facilitate and document these internal

meetings

After a round of internal discussion of each sub-group the ST Committee will have the final meeting

to discuss the comments and concerns raised by different sub-groups of the community The ST

Committee will finalize a list of issuesdemands for further discussion with RUMSL The FPIC-FA

prepare the Agenda for First RUMSL-ST Committee Meeting and share it with RUMSL at least a week

before the meeting

The Agenda of the first RUMSL and ST Committee will be shared with the Mediation Committee to

keep them informed about the initiation of discussion between both parties

836 First RUMSL and ST Committee Meeting

The FPIC-FAERM will confirm the quorum prior to starting the proceedings The points mentioned in

the Agenda circulated earlier will be taken up for discussion The RUMSL Team will respond on these

pointsissues The ST Committee will consider these responses and decide if they are satisfied Once

the discussion is concluded the FPIC-FA will write-down the decision made with respect to the

specific Agenda items If any additional points to be discussed by any party those points will be

discussed at the end of the meeting with mutual agreement The FPIC-FA will document the

proceedings of the meeting as per the Discussion and Decision Making Framework (see section 832

above)

If all issues are resolved through discussion in this meeting then another round of discussion is not

required If there will be unresolved issue they will be included in the Agenda for the second meeting

While preparing the Agenda for the second meeting FPIC-FA will record the positions of both parties

with respect to these un-resolved issues The Agenda for the second meeting will be prepared listing

these unresolved issues with an appendix stating the views of each party on these unresolved

issues

RUMSL Team will brief about the mutual agreements and unresolved issues listed for second meeting

with their MD and seek approval if required The ST Committee will similarly brief their community

members on what is agreed after they return

The FPIC FA and ERM will prepare a Draft FPIC Agreement (in Hindi) reflecting the points of mutual

agreements and dissents if any The Draft FPIC Agreement will be shared with both parties

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

837 Second RUMS and STs Committee

The second and subsequent meetings between RUMS Team and IPs Committee will be held on

points where both parties do not agree and it requires further discussion ERMFPIC-FA will consult

both parties to reconsider their views and think about solutions acceptable to them Once ERMFPIC-

FA see both parties are prepared for the next round of discussion date for the second meeting will be

fixed

In this second round of meeting it is expected that a few more points will be mutually agreed The

Draft FPIC Agreement will be updated mentioning these points on which there are mutual agreement

and points of dissentdisagreements

Although it is expected to resolve all issues in two rounds of discussion there is a possibility of

additional rounds of discussion Both RUMSL and ST Committee will discuss on additional meetings

and decide a mutually agreed time-frame to complete the on-going discussion process

If both parties feel canrsquot be resolved through further discussions they will decide if the issue should be

referred to the Mediation Committee or set aside for discussion at a later date26 ERMFPIC-FA will

check if both parties are committed to accept the decision of the Mediation Committee and take the

final decision in consultation with both parties

838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee (MC)

If all issues are resolved through mutual discussion between the RUMSL Team and ST Committee

the Draft FPIC Agreement will be forwarded to MC of the respective Solar Park The MC will be then

requested to be available to chair over the final community meeting (see 8310) to measure the

consent expressed by affected ST in FPIC villages

The MC of the respective Solar Park will consider any issue which was not resolved by mutual

discussion between ST Committee and RUMSL Team and referred to it with an understanding that its

decision will be acceptable to both parties The FPIC-FAERM will hand over documentation of

previous discussion related to the issue and stated positions of both parties with respect to the matter

under consideration to MC

The MC will convene a meeting where it hears the arguments from both sides After considering views

on the matter from both sides MC will offer a solution for consideration If the MC thinks they need to

consult subject experts they will inform both parties and reconvene the meeting after they have

obtained views from such subject experts

Both parties if required will be given time (not more than a week) to consider the resolution offered by

the MC and come back with their final views

After considering the views of both parties on the solutions offered by it the MC will give its final

decision on the matter The MC will try making its decision on consensus and if it is not possible the

decision will be on majority Both parties will be bound by this final decision pronounced by MC The

final decision by MC will be incorporated into the Draft FPIC Agreement

839 Informing Community on Draft FPIC Agreement by ST Committee

The FPIC-FA will provide the Draft FPIC Agreement to the ST Committee The ST Committee

members will inform community members in smaller the sub-groups on the decisions taken during

FPIC discussion with RUMSL The ST Committee will explain their decisions on each issue and ask

26 Particularly matters which are uncertain or may happen in future These issues can be listed as unresolved issues to be

monitored by an agreed mechanism and discussed later

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

each adult member of the community to attend the final community meeting to voice their views and

acceptreject the Draft FPIC Agreement

8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and Ratification of Final IPP and FPIC Agreement

The ST Committee will take decision to hold the final community meeting to express their

consentdissent and fix a date after consulting RUMSL and MC members It will invite RUMS Team

and Mediation Committee to participate and witness the expression of consentdissent by affected

STs

FPIC-FA will ensure that all households in the community are informed about this meeting at least 7

days in advance FPIC-FA will prepare the list of all adult members with support from ST Committee

The IPs Committee will take the responsibility of the invitation and FPIC FA will monitor and document

the process The quorum for holding the final community meeting of affected ST families will be as

follows

Presence of at least 50 of the affected ST families in FPIC village

Presence of at least 60 of the total adult members of these affected ST families

Presence of at least 33 of the total adult women members

Presence of at least 33 of the total youths (between 18 and 25 years)

The FPIC-FA will coordinate with ST Committee members representing women and youth to ensure

that these quorum requirements are met during the final community meeting

The FPIC-FA will set-up a mechanism for recording the presence of eligible ST adult members and

hand over a copy of the Draft FPIC Agreement as they arrive at the meeting venue The Mediation

Committee will preside over this final community meeting The FPIC-FA will inform MC if quorum

requirements for the meeting is achieved After verifying the quorum required and the people

gathered for the meeting are from the affected ST households from FPIC villages the MC will initiate

the meeting proceeding

A representative from RUMSL Team will read out the agreed points mentioned in the Draft FPIC

Agreement and request for their acceptance A representative from the ST Committee will express

their views on points of mutual consensus as well as any unresolved issue that will be discussed and

resolved at a later stage of the project

The MC will then provide opportunities to ST community members present in the meeting to express

their views ST Committee will facilitate community members to express their opinions and

suggestions

The MC will consult with RUMSL and ST Committee if any additional points of agreement and dissent

to be incorporated in the Draft FPIC Agreement After confirming their final positions request the

community members present in the meeting to express their consentdissent and ratifyreject the Draft

FPIC Agreement

The consentdissent will be expressed by raising hands when the members of the Mediation

Committee puts the proposal of ratification to vote If more than 75 of the community members

attending this meeting votes in favour of the Draft FPIC Agreement it would be regarded as

expression of collective consent

The MC will inform the assembled community members about the outcome of the voting and if Draft

FPIC Agreement is ratified or rejected After the Draft FPIC Agreement is ratified by a collective

expression of consent the ST Committee members and RUMSL Team will sign the Final FPIC

Agreement This Agreement will be counter signed by members of the Mediation Committee as

witnesses

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The IPs community may be allowed to carry out any customary ritual on the day of the completion of

the FPIC process and express their support to the proposed Project This FPIC Agreement will be

taken up for implementation and a monitoring committee will oversee its effective implementation

8311 FPIC Process Documentation Report

The FPIC-FA will prepare a FPIC Process Documentation Report summarizing each stage of the

FPIC process It will hand-over all audio-visual records of the FPIC process The process document

report will cover all stages of the FPIC process documenting the following

Process of identification of STs ST representatives and decision-making authorities

Process of assessment of capacity of ST representatives to undertake good faith negotiations

Summary of any capacity building undertaken

Agreed engagement and negotiation framework (including the process undertaken to agree upon

the framework)

Summary of consultations meetings engagement undertaken as part of the FPIC process and

Opinion of FPIC-FA on the process and outcomes

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to

complete the FPIC process

84 Tentative Time-line

The Phase-I FPIC activities was scheduled to be held in Apr 2021 Due to the outbreak of second

wave of Covid-19 in Apr 2021 the field activities are suspended The decision to initiate these

activities will be taken once Covid-19 second wave gets over The schedule for Phase-II activities to

will be discussed with ST Committees of the three Solar Parks and will be decided accordingly As the

progress of FPIC process requires cooperation from affected ST community and the level of

cooperation varies in these three Solar Parks Hence the schedule for Phase-II FPIC activities will be

updated in discussion with respective ST Committees while finalizing the Discussion and Decision

Framework with them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Section Activity Month-1^ Month-2 Month-3 Month-4 Month-5

821 Appointment of FPIC FA and Orientation

822 Introducing FPIC-FA to RUMSL and FPIC Villages

823 Formation of ST Committees

824 Capacity building of ST Committees

8313 Formation of Mediation Committee

832 Acceptance of Draft DDMF

833 Disclosure of Draft IPPIPDPTDP to ST Committee

834 Explaining Draft IPPIPDPTDP to ST Committee

835 Internal Consultation Process by ST Committee

836 First RUMSL and ST Committee Meeting

837 Second RUMSL and ST Committee Meeting

838 Refer Unresolved Matters to MC

839 Inform Community about Draft FPIC Agreement

8310 Final Community Meeting for expression of ConsentDissent

8311 FPIC Process Document Report

Phase-I Activities

Phase-II Activities

Activities to start and complete

OptionalConditional Activity

^ The commencement of these activities will be determined once second wave of Covid-19 gets over

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 83

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW

IN THE STATE OF MADHYA PRADESH INDIA

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

85 Responsibility Matrix

The FPIC process will require a collective effort and coordination between ERM RUMSL ST

Committee Mediation Committee and the FPIC FA The roles and responsibilities of these entities are

described in Section 82 and 83 above ERM will play an active role in coordination and provide

information required for a meaningful discussion The key responsibilities and accountabilities are

summarized below for clarity

Activity ERM FPIC-

FA

ST-

Committee

RUMSL-

F

RUMSL-

HO

Mediation

Committee

IFC-

WB

Formation of ST Committee S P P A

Formation of RUMS Team P A

Formation of Mediation

Committee

P P S P A P

Acceptance of Discussion

and Decision Making

Framework

S P P P A C C

Disclosure of Draft IPP to ST

Committee

P S S A C A

Explaining of Draft IPP to ST

Committee

P S

Internal consultation process

by ST Committee

S P P

First RUMSL and ST

Committee Meeting

S P P P A

Second RUMSL and ST

Committee Meeting

S P P P A

Mediation Committee

Proceedings

P P P S P P

Informing Community on Draft

FPIC Agreement by ST

Committee

S P P A

Final ST community meeting-

expression of consent

dissent

S P P P A A C

FPIC Process Documentation

Report

P P S S S S A

P= Primary Responsibility S= Secondary Responsibility C= Must be Consulted A= Approval

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

PROJECT INFORMATION DOCUMENT SHAJAPUR SOLAR PARK

Background

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) The primary objective of RUMSL

is to develop and facilitate the development of large-scale solar projects in the State of Madhya

Pradesh In line with the governmentrsquos ambition to boost solar power in State RUMSL is developing

Solar Park of capacity of 450 MW at Shajapur Madhya Pradesh

The World Bank had agreed to provide financial support for the Project International Finance

Corporation (IFC) is providing investment advisory services to Government of Madhya Pradesh to

develop the project on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards for the Project

Project Details

The proposed 450 MW Solar Park is located in two Tehsils ndashMoman Badodiya and Shajapur of

Shajapur District Out of 450 MW capacity 325 MW will be developed at Moman Badodiya tehsil

(termed as Unit 1 amp 2) and 125 MW will be developed at Shajapur tehsil (termed as Unit 3) of

Shajapur district Madhya Pradesh Almost 89 of the land area is Government land and remaining is

private land The salient feature of the Project are given below

Solar Park

The Solar Park will be developed as two units spread across these lands and the details of the same

ae captured in the table belowndash

Table A1 Details of Land parcels identified for the project Unit Number Area in ha Capacity Tehsil Villages

Unit 1 72048 220 MW Moman

Bododiya

Proposed to span 6 villages - Bijanakhedi

Burlay Chauma Dehripal Fawaka and

Parsula

Unit 2 105 MW Proposed to span Burlay Dhatrawada and

Jawadi whereas

Unit 3 26964 125 MW Shajapur

Tehsil

Hanoti Surajpur and Shajapur

Total 99012 450 MW

Land

Out of the total land requirement of 99012 hectares 86937 hectare is Government land 11074

hectare is private land and 1001 hectare is government patta land The Government land required for

the Solar Park which accounts for almost 89 of the total land required will be leased by the

government of Madhya Pradesh to SPPDs and the private land will be purchased from the land

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

owners for the development of Solar Park as per the prevailing laws and policies in the State of

Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP

Transmission Line

The transmission infrastructure is planned to evacuate power generated from the units to the STU

grid Each unit will have a 33200 kV internal pooling substation The internal pooling substation will

be connected to the proposed MPPTCL 220400 kV substation at Agar through 220 kV transmission

line For cost optimization the single circuit line from unit 1 will be laid till unit 2 towers and there on a

double line circuit of 220 kV shall be connected till the gird substation The Unit 3 internal pooling

substation shall be evacuated through single circuit 220 kV transmission line till the existing MPPTCL

220400 kV substation at Ujjain

The 33220 kV substation at each unit and 220 kV connectivity to the MPPTCL substation will be

developed by RUMSL MPPTCL will establish 220400 kV proposed grid substation at Agar in

connection with the existing 220400 kV MPPTCL substation at Ujjain Madhya Pradesh MPPTCL will

establish 220400 kV proposed grid substation at Agar along with the associated line till 400220 kV

Ujjain substation The solar project developer in the park shall be responsible for laying the 33 kV

cable and 33 kV ring unit as required at each unit to connect its plant to the 33220 kV internal pooling

substations

Road Infrastructure

The road infrastructure requirements is planned to access the Shajapur Solar Park Ms RUMSL shall

carry out road wideningrepairing of existing roads wherever required The road widening repairing of

existing roads is proposed for a length of 65 km which shall be undertaken by RUMSL The

development of internal roads within each unit shall be in the scope of individual Project Developer

Water Requirement

Water requirements for all purposes shall be met by digging bore-wells within each unit and shall be in

the scope of project developer Also the arrangement of construction water shall be in the scope of

contracting agencies and Solar Power Project developer

Common facilities planned

For 450 MW Shajapur solar park the utility area is proposed adjacent to the Unit 1 and Unit 3 -

33220 kV internal substation The other facilities such as RUMSL office fire-fighting equipment

telecommunication infrastructure medical dispensary etc will be located at the pooling substation

area

Project Implementation

The 450 MW Shajapur Solar Park will be implemented in a period of ~21 months

Operation and Maintenance

It is envisaged that different developers may occupy individual units and will be responsible for OampM

The operations and maintenance of common facilities provided like pooling substation intermediate

substations shall be undertaken by RUMSL

Environment and Social Impact Study and Management Plans

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Assessment (ESIA) of three solar parks including internal

evacuation infrastructure and associated transmission lines ESIA carried out for the project will meet

the requirements of Environment and Social Safeguard Policies and Standards of WB and IFC in

addition to applicable environmental and social regulations and policies in India and the State of

Madhya Pradesh

Based on final land footprint and georeferenced site boundaries of the project the ESIA will include a

Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) ERM will share relevant

information and consult with affected local communities to understand their viewsconcerns The

consultation will cover a wide range of people to take into account perspectives from different social

groups women and men young and old and seek their participation in mitigation of adverse impact

as well as enhancement of project benefits

As the project will impact a number of ST families ERM will assess impacts on them and prepare a

Tribal Development Plan (TDP) which will contain a package of proposed impact mitigation measures

and project benefits ERM will implement a Free Prior Informed Consent (FPIC) process covering

affected Scheduled Tribe population The negotiation process leading to obtain FPIC will be agreed

on with the affected ST communities

Free Prior Informed Consent (FPIC) Process for STs

The FPIC Process will be taken up for Surajpur Parsula and Jawadi villages of Shajapur Site for the impacts on tribal population in given villages on the land under traditional ownership and customary use The process will also involve any nomadic tribes who may have claims of using the project site for grazing their livestock and camping during their annual migration The FPIC process will be divided into two phases as described below

Phase What to Do When to Do

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Before inviting bids for solar parks by concessionaire

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Contacts

Further information and queries related to the project can be obtained from RUMSL site office in

Shajapur and head office at Bhopal The information is also available at website of RUMSL

(httpwwwrumslcom)

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

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wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT FPIC

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

NEEMUCH SOLAR PARK

Badi village Kawai Village

Mama Basti Badi village Bardawada village

AGAR SOLAR PARK

Ladwan village Bijnakhedi village

SHAJAPUR SOLAR PARK

Chauma village Parsula village

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

BACKGROUND

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) RUMSL is facilitating developing

Solar Park of capacity of 450 MW at Shajapur on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards (International Finance Corporation and World Bank) for the Project

Project Details The proposed 450 MW Solar Park is located in Moman Badodiya and South Shajapur tehsils of

Shajapur District collectively referred to as Shajapur Solar Park The Shajapur Solar Park will be

spread across 11 villages in Shajapur amp Moman Badodiya Tehsil of Shajapur District comprising the

villages of Burlay Jawadi and Dhatrawada (for Unit 6) Parsula Dehripal Bijnakhedi Fawaka

Chauma Burlay (for Unit 7) and Surajpur Lalpur and Hanoti (for Unit 8) The land required for 450

MW Solar Park including solar fields roads and transmission and distribution network is 9872

hectares The Shajapur Solar Park plot comprises of three non-contiguous land parcels

The solar park will have three (3) units It is understood that each unit will have a different developer

Unit 6 of 105 MW capacity to be developed on an area of 2461 hectares of Private and

Government land

Unit 7 of 220 MW capacity to be developed on an area of 4859 hectare and

Unit 8 of 125 MW capacity to be developed on an area of 2552 hectare

Land Requirement and Status The Solar Park will largely use GoMP land (approx 88) and the remaining land is either private

land or Patta land The Government land required for the Solar Park will be leased by the government

of Madhya Pradesh and the private land will be purchased from the land owners as per the prevailing

laws and policies in the State of Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th

November 2014 of Government of MP)

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

1 Burlay 237 00 64 00 00 00 301

2 Jawadi 322 00 20 00 00 00 342

3 Dhatrawada 1722 00 97 00 00 00 1819

Sub- Total (unit

6)

2281 00 181 00 00 00 2462

4 Parsula 1162 00 00 52 00 00 1214

5 Dehripal 1111 00 124 00 94 00 1329

6 Bijanakhedi 954 00 226 00 00 00 1180

7 Fawaka 171 00 02 00 00 00 173

8 Chouma 327 00 95 00 00 124 546

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

9 Burlay 417 00 00 00 00 00 417

Sub- Total (Unit

7)

4142 0 447 52 94 124 4859

10 Surajpur 227 07 182 00 00 00 416

11 Lalupura 497 08 00 00 00 00 505

12 Hanoti 1319 125 185 00 00 00 1629

Sub- Total (Unit

8)

2043 140 367 00 00 00 2551

Grand Total 8466 140 995 52 94 124 9872

Source Land Data provided by RUMSL 18th June 2020

Transmission Line Each Solar Park Unit will have 33220 kV substations and the power generated from each unit (Unit 6

7 and 8) will be pooled to the 220 kV switching pooling substation The utility area is proposed near

the internal pooling substation located at the Unit 6 and Unit 8

Road Infrastructure Access to Unit 6 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The existing village road has a width of ~4-5 meter and existing

State highways has a width of ~75 meter The road length of ~25 km will be strengthened and

repaired to suit the need during the construction phase

Access to Unit 7 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The road length of ~2 km will be strengthened and repaired to

suit the need during the development phase

Access to Unit 8 The Unit is connected with village road from Jhonkar to Hanoti at a distance 0f ~6

km from Jhonkar The existing road is a two-lane bituminous concrete road with width ~7-75 meters

and a new bituminous road with width ~75 meters and length ~500 meters is proposed to connect

33220 kV plant substation The road length of ~2 km will be strengthened and repaired to suit the

need during the development phase

Water Requirement The total requirement for water is estimated as 323 kL day Developers shall establish bore-wells per

block with required approvals and directions to meet their requirements The entire water supply

system including provision for bore-wells within individual blocks shall be in the scope of the Project

Developer The water requirement for the green belt is estimated to be 7000 litres per day

Common facilities planned The common facilities such as RUMSL office fire-fighting equipment telecommunication

infrastructure medical dispensary weather monitoring station etc will be located at the pooling

substation area located at the Unit 6 The operations and maintenance of common facilities provided

like pooling substation intermediate substations shall be undertaken by RUMSL Ms RUMSL will

establish two Weather Monitoring Station at internal pooling substation (at each unit)

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Project Implementation

The 450 MW Shajapur Solar Park will be constructed a time frame of ~21 months with construction

proposed to started in November 2020

Project Impacts Benefits and Mitigation Measures

RUMSL will identify stakeholders and prepare a schedule for consulting them on a regular basis in

construction phase It will also establish a grievance redress mechanism through which local

community can register their grievances and seek redress to any adverse impacts on them The

project through its ESIA process has identified a range of potential impacts and has planned to

implement appropriate mitigation measures The key impactsbenefits and proposed mitigation

measures are discussed below for your knowledge and suggestions for making them more effective

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D1 Moman Badodiya Unit 6

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D2 Moman Badodiya Unit 7

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D3 South Shajapur Unit 8

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact from Land Acquisition

Type of land impacted How Impacts will be addressed

Private Land (Purchased through MP

Mutual Consent Policy 2014

Adequate compensation at twice the value of land and assets as

per MP Mutual Consent Policy 2014

Benefits of Resettlement Action Plan-Livelihoods restoration Plan

Preference to households (rendered landless or with sub-optimal

holdings) of the families post selling land to the project for

employment opportunitiessmall contracts in the

Constructionoperation phase

Pattta Land (Negotiated purchase

through MP Mutual Consent Policy)

Patta is being treated at par with ownership for the land

procurement process and would have same benefits as of private

land owners

Government Land Used for Grazing

easements cultural heritage sites

water sources fuel wood collection and

collection of other resources

Provision for alternate grazing land for cattle near the project

village or confirmation of adequacy of remaining grazing land

Development of community fodder lots in available unoccupied

government land may be explored and covered in Resettlement

Action Plan

Provision of easements shall be maintained in order to not sever

the access to CPRs for the community

Government Land Informally

occupied Capturedencroached for

agriculture or grazing prohibiting use

by other people

RUMSL shall serve a three months advance notice to the project

affected persons (PAPs) to harvest standing crops andor avoid

growing fresh crops

In case the advance notice is not given RUMSL shall pay

compensation for crops at full replacement cost

ImpactsBenefits in Construction Phase

Impact Mitigation Measures

Temporary occupation of land

for construction phase activities

such as Labour Camps Safety

Setbacks Storage areas

Parking areas Other

construction related temporary

land requirements etc

Adequate lease rents to the land owners

Restoration of land to its original state or better at the time of handing it

back to the owners

Compensation for the loss of livelihoods to the users of the land required

for temporary use as this will temporarily economically displace them

Community Health and Safety

including accident risks for

domestic animals

The Contractor shall prepare Traffic Management Plan Workers Code of

Conduct and Health and Safety Plan and implement it after approval of

RUMSL

Stress on Community resources

- Water and Roads

There will be a worker Code of Conduct defined by RUMSL that prevents

workers and contractors from using the local resources like water forest

The contractor shall be asked to use Tanker water supply during the

summer months which are dry months in which water scarcity issues are

reported by the community

Noise Nuisance and Dust Install enclosures around construction area in order to reduce the extent

of noise and dust

Limit construction related activities to day time

Employment and

entrepreneurship opportunities

during construction

The sourcing of local labour wherever possible will be obligatory for the

Solar Project Developers and sub-contractors

Employment of members of SC-STs and vulnerable households will be

at a minimum of 30 of total workers or person-days of employment

Engagement of local vendors to the extent possible for the goods and

services required for the project during construction phase

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact Mitigation Measures

The RUMSL will establish a mechanism to audit subcontractors and

suppliers with respect to compliance of utilizing local labour and

resources

Impacts in Operation Phase

Impact Mitigation Measures

Community Health and

Safety

Community engagement and sensitization sessions should be re-organised at

the beginning of Operations phase in order to mention about the new

developments in the area and provide an understanding of the precautions to

be taken for safety

Impact on Employment RUMSL shall ensure that the Solar project developers (SPDs) advertise the

roles of Technical staff required during operations phases in the local

newspapers to enable hiring of competent people from nearby areas to the

extent feasible

Preference shall be given (to the extent feasible) to hire competent members

from PAHs for semi-skilled jobs like housekeeping or Security Guards

Impacts on Vulnerable Sections Women and Scheduled Tribes

Impact Mitigation Measures

Impacts on Indigenous

Communities Vulnerable

Groups

To Prepare an Indigenous Peoples PlanTribal Development Plan with special

benefits for Scheduled Tribes

Recognizing their right to Free Prior Informed Consent process and its

implementation

As part of the stakeholder engagement ensure adequate representation and

participation of the Scheduled Tribes

Impact on Women A Gender Action Plan will be prepared for the Project to assess and mitigate

gender specific impacts

Ensure that the employment of women from vulnerable households is

prioritised for the project

Efforts are made to support development of women owned enterprises in the

area through the LRP from where procurement for project related may be

prioritised

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

Page 1

शाजापर सोलर पारक रा पररयोजना वििरण दसतािज़

पषठभवि

नवीन और नवीकरणीय ऊरजा मतरजलय क सहयोग स मधय परदश सरकार मधय परदश म जमीनी गरिड स रडी

सौर ऊजाा पररयोजना का गरिकगरसत कर रही ह रीिा अलटर ा मगा सोलर गरलगरमटड (RUMSL) का एक

सािाजगरनक उपकरम िरा 2015 म सथागरपत हआ ह यह उपकरम सोलर एनरी कारपोरशन आफ इगरडया गरलगरमटड

(SECI) तथा मधयपरदश ऊजाा गरिकास गरनगम गरलगरमटड (MPUVNL) क साथ सयकत उपकरम क रप म सथागरपत

हआ ह शाजापर सोलर पाका की कल कषमता 450 मगा िाट होगी और इस सौर ऊजाा पाका को गरनजी -

सािाजगरनक साझदारी क तहत गरनमााण गरकया जाना परसतजववत ह

रीवज अलटर ज मगज सोलर वलवमटड (RUMSL) दवजरज ईआरएम इवडयज परजइवट वलवमटड (ERM) को अतरााषटर ीय

मानको (अतरााषटर ीय गरितत वनगम एि गरिशवबक) क अनसजर सौर पजका क पयजावरणीय और सजमजवरक परभजव

मलजकन (ESIA) क सजथ सजथ पनगरिासथापन कजया योरनज (RAP) और सवततर रप स समदाय की पिा

सगरित सहमगरत (FPIC) परवियज क वलए अनबगरित गरकया गया ह

पररयोजना री परिख जानरारी

450 मगा िाट का परसतागरित सोलर पाका शाजापर गरजल क मोहन बड़ोगरडया और शाजापर तहसील क अतगात

शाजापर सोलर पाका क नाम स जाना जाएगा यह सौर ऊजाा पाका 11 गाािो क कषतर म बनगा यह 11 गााि इस

परकार ह बल जिादी और ितिादा (इकाई 6) पारसला दहरीपल बीजनखड़ी फिाका िौमा बल (इकाई

7) और सरजपर लालपर तथा हनोती (इकाई 8)

इस 450 मगा िाट सोलर पाका हत कल 9872 हकटर जमीन की आियशकता होगी गरजसम सोलर फीलड

सड़क टर ासगरमशन एि गरितरण नटिका शागरमल होगा पाका तीन अलग इकाईयो म गरिकगरसत होगा ऐसा

अनमान ह गरक परतयक इकाई का गरनमााण अलग-अलग गरनमााताओ दवारा गरकया जाएगा

105 मगा िाट कषमता िाली इकाई 62461 हकटर कषतर पर सरकारी तथा गरनजी जमीन पर गरिकगरसत

होगी

220 मगा िाट कषमता िाली इकाई 74859 हकटर कषतर पर गरिकगरसत होगी तथा

125 मगा िाट कषमता िाली इकाई 82552 हकटर कषतर पर गरिकगरसत होगी

Page 2

जिीन री सथिवि एि अविगरहण

सौर ऊजाा पजका लगभग 88 मधय परदश की सरकारी भवम कज उपयोग करगज और शष भवम यज तो वनरी यज

पटटज भवम रहगी सोलर पजका क वलए आवशयक रजरसव भवम मधय परदश सरकजर दवजरज पटट पर दी रजएगी और

वनरी भवम मधय परदश रजजय म परचवलत कजननो और नीवतयो क अनसजर भवम मजवलको स खरीदी रजएगी

(Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP)

कर

गााि

रा

नाि

सरर

ारी

जि

ीन आ

िवि

ि

(NR

ED

) ह

कटर

सरर

ारी

जि

ीन व

िसि

ि प

आि

विि

नह

हकट

वनज

ी ज

िीन

कटर

पटट

री

जि

ीन

हकट

उदय

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री

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कटर

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सरर

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हकट

1 बल 237 00 64 00 00 00 301

2 जािादी 322 00 20 00 00 00 342

3 ितरािदा 1722 00 97 00 00 00 1819

योग (इराई 6 ) 2281 00 181 00 00 00 2462

4 परसला 1162 00 00 52 00 00 1214

5 दहरीपल 1111 00 124 00 94 00 1329

6 बीजनखड़ी 954 00 226 00 00 00 1180

7 फािक 171 00 02 00 00 00 173

8 िौमा 327 00 95 00 00 124 546

9 बल 417 00 00 00 00 00 417

योग (इराई 7) 4142 0 447 52 94 124 4859

10 सरजपर 227 07 182 00 00 00 416

11 लालपर 497 08 00 00 00 00 505

12 हनोती 1319 125 185 00 00 00 1629

योग (इराई 8) 2043 140 367 00 00 00 2551

Page 3

रल 8466 140 995 52 94 124 9872

सदभक रीिा अलटर ा मगा सोलर गरलगरमटड दवारा गरदया गया जमीन का डाटा 18 जन 2020

िासविशन लाइन

परतयक सोलर पाका इकाई क 33220 किी क सब सटशन होग तथा परतयक इकाई (6 7 8) स 220 गरकलो

िाट की ऊजाा सब सटशन एकतर गरकया जाएगा आतररक पगरलग सब सटशन इकाई 6 और 8 क समीम

सथागरपत करना परसतागरित ह

सड़र वनिाकण

इराई 6 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रोवक आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

गााि क रासत की िौड़ाई लगभग 4-5 मीटर तथा राजयमगा की िौड़ाई 75 मीटर ह सौर ऊजाा पाका क

गरनमााण हत 25 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 7 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रो की आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 8 िर पहाि

इकाई 8 िाम झोकर स 6 गरकलोमीटर दर िाम झोकर स िाम गरहनोती को जान िाली सड़क स जड़ी ह यह

रासता डबल लन डामर रासता ह गरजसकी लबाई 7-75 मीटर ह एक नई डामर रोड गरजसकी लबाई 500

मीटर तथा िौड़ाई 75 मीटर ह और जो 33220 किी क सब सटशन को जोड़न क गरलए बनाई जाना

परसतागरित ह सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया

जाएगा

पानी री आिशयरिा

यह अनमान ह की परगरत गरदन लगभग 323 गरकलो लीटर पानी आिशयकता होगी पानी की पगरता क गरलए ठकदार

दवारा परगरत बलॉक बोररग की रजएगी सौर ऊजाा पाका क गरनमााण क दौरान परतयक बलॉक क पानी की सपलाइ

की वयिसथा का परा खाका गरजसम बोररग करना भी शागरमल ह ठकदार अपन परसताि म द ग हररत पटटी क

गरलए परगरत गरदन अदाजन कल 700 लीटर पानी की आियशकता होगी

Page 4

सािानय सवििाओ री उपलबधिा

RUMSL का ऑगरफस अगरि शमन सटशन टली कमयगरनकशन (फोन) गरिगरकतसालय गरडसपनसरी मौसम की

जानकारी सटशन इतयागरद इकाई 6 क समीप पलीग सब सटशन पर सथागरपत हाागी पगरलग सबसटशन तथा

मधयमिती सबसटशन गरक तमाम सगरििाओ का सिालन एि दखरख RUMSL दवारा गरकया जाएगा RUMSL

आतररक पलीग सटशन पर दो मौसम अनशरिण सटशन सथागरपत करगा

पररयोजना रा वकरयानवयन

450 मगा िाट का शाजापर सोलर पाका का गरनमााण निमबर 2020 स शरिात कर अगल 21 महीनो म परा

होना अपगरकषत ह

पररयोजना र परभाि लाभ ििा शिन उपाय

सौर ऊजाा पाका क गरनमााण क दौरान RUMSL गरिगरभनन गरहतसािको की पहिान कर उनस गरनयगरमत ििाा और

सलाह मशिरा करतज रहगज पाका गरनमााण क दौरान िामीणो की गरशकायतो को समझन एि उनह दर करन क

गरलए गरशकायत गरनिारण ततर की वयिसथा RUMSL करगा तागरक गरशकायतो का गरनपटारा शीघर हो सक और

लोगो पर हो रह नकारातमक परभाि को दर कर सक पररयोजना दवारा ESIA की परगरकरया क माधयम स सभागरित

परभािो को गरिनहनहतकर उनक गरनपटार हत उगरित और परभकारी उपाय करगा अपगरकषत परभािलाभ और शमन

क उपाय गरनमन गरलनहखत ह तागरक आपक सझािो क आिार पर उनह और परभािी बनाया जा सक

Page 5

नकशा 1 िोहन बदोवदया इराई 6

Page 6

नकशा 2 िोहन बदोवदया इराई 7

Page 7

नकशा 3 शाजापर इराई 8

Page 8

जिीन अविगरहण रा परभाि

परभाविि जिीन रा पररार परभाि रा वनिारण

वनजी जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत 2014 क तहत

खरीदी गरनजी जमीन)

मधय परदश आपसी सहमगरत भगरम करय नीगरत 2014 क तहत

पयाापत मआिजा जमीन या सपगरत क मलय स दगना

पनिासन कायायोजना ndash आजीगरिका पनजीिन योजना स लाभ

पररयोजना हत अगरििहण क बाद पररिार गरजनक पास बहत ही

कम जमीन बिी ह या भगरमहीन पररिारो को पराथगरमकता

गरनमााण क दौरान गरकरयानवयन क समय उनक गरलए काम क

अिसर छोट काया अनबि काटर कट म पराथगरमकता दना

पटटिाली जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत2014 क तहत

तय कर खरीदी गए जमीन)

जमीन क अगरििहण क दौरान पटटा िारको को गरनजी मागरलक की

तरह समझत हए उनक गरलए गरनिााररत सार फायद दना

सररारी जिीन िरनोई सासकगरतक

िरोहर जल शरोत जलाऊ लकड़ी

सिहण गरनसतार की जमीन

अनयससािनो का सिहण क उपयोग म

आन िाली जमीन

पररयोजना क समीप क गााि म िरनोई क गरलए जमीन की

िकनहिक वयिसथा करिाना या अगरििहण क बाद शर जमीन म

गााि क गरलए पयाापत िरनोई की जमीन सगरनगरित करना

खाली पड़ी सरकारी जमीन पर सामदागरयक िारागाह की खप

गरिकगरसत करन हत पनिासनकाया योजना म सभािना खोजना

समदाय क सामदागरयक ससािनो तक पहाि बनी रह उस सगरनगरित

करन क गरलए भारतीय सख भोग अगरिगरनयम 1882 क पराििानो

का पालन गरकया जाएगा

सररारी जिीन अिि कबजिाली

जमीन खती या िराई क गरलए कबजा

अगरतकरमण गरकया गया हो लोगो दवारा

सािाजगरनक उपयोग बागरित गरकया गया

हो

RUMSL पररयोजना स परभागरित लोगो को तीन महीन का पिा

नोगरटस दगा तागरक ि अपनी लगी हई फसल काट सक या नई

फसल न बोए

यगरद गरकसी कारण िश पिा नोगरटस नही दी गयी तो RUMSL परी

फसल की कीमत मआिज क तौर पर द ग

Page 9

वनिाकण र दौरान परभािफायद

परभाि शिनवनपिार र उपाय

गरनमााण क िरण क दौरान गरिगरभनन गगरतगरिगरियो

क गरलए जस मजदर रहिास (क प) सरकषा

वयिसथा भडारण वयिसथा िाहन पागरकि ग कषतर

तथा गरनमााण सबिी अनय जमीन की असथायी

आिशयकता पड़ना आगरद

जमीन मागरलको को पयाापत लीजगरकराए की वयिसथा करना

जमीन मागरलको को उनकी जमीन लौटन क समय वयिनहसथत

रप स सिार कर परानी अिसथा या उसस भी अचछी करक

लौटाना

जमीन मागरलको को उनक जमीन स असथायी रप स हटान एि

उनकी आजीगरिका क नकसान क एिज म मआिजा दना

सामदागरयक सवासथय एि सरकषा तथा घरल

उपयोगी पशओ की दघाटनाका जोनहखम

ठकदार सभी की सरकषा क गरकए आिागमन परबिन पलान

तयार कर ग मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयिहार क गरनयम) और सवासथय एि सरकषा की योजना

बनाकर RUMSL स अनमोदन क पिात ही गरकरयानवयन कर ग

सामदागरयक ससािनो पर दबाि ndash पानी एि

सड़क

RUMSL दवारा मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयहार क गरनयम) गरनिााररत गरकए जाएग गरजसस

कमािारी तथा ठकदार सथानीय ससािनो जस पानी जगल

आगरद का नयायोगरित उपयोग कर पाएग

गगरमायो क समय पानी की गरकललत को दखत हए ठकदार को

यह गरनदश होग की िह पानी क टकर स पानी गरक पगरता कर

शोर बािा एि िल गरनमााण सथल पर दीिार लगानासथागरपत करना तागरक शोर एि

िल कम फल

गरनमााण काया किल गरदन क समय ही करनागरनमााण काया रात

क समय परगरतबगरित करना

गरनमााण क दौरान रोजगार तथा वयिसाय क

अिसर

यथासभि सोलर पाका गरिकगरसत कतााओ तथा ठकदारो आगरद

क गरलए सथानीय लोगो एिम मजदरो को काया दन की

अगरनिायाता होगी

कल रोजगार गरदिस या कल कमािाररयो म कम स कम 30

परगरतशत मजदरकमािारी अनसगरित जागरत - जनजागरत या िगरित

पररिार स होग

सोलर पररयोजना गरनमााण क समय गरकसी भी मालसामिी या

सिा की जररत यथासभि सथानीय गरिकरताओ क माधयम स

की जाएगी

RUMSL गरनमााण क दौरान एक अककषण ततर की वयिसथा

करगा तागरक ठकदार गरिकरता सिा परदाता सथानीय ससािनो

तथा मजदरो का यथोगरित उपयोग कर सक

Page 10

वकरयानवयन र सिय परभाि

परभाि शिन वनपिार र उपाय

सामदागरयक सवासथय एि

सरकषा

सोलर पाका क गरनमााण की परगरकरया क दौरान गरनमााण स होन िाल नए

बदलाि क सबि म समदाय को सिदनशील बनाना हत बठको का

आयोजन करना और सरकषा क गरलए एहगरतयात बरतन हत समय समय पर

गरििार गरिमशा और ििााए करना

रोजगार पर परभाि RUMSL यह सगरनगरित करगा की पररयोजना क गरनमााण क दौरान

तकनीकी कमािाररयो की भती का गरिजञापन सथानीय अखबारो म छप

तागरक योगय सथानीय लोगो को भती गरकया जा सक

अिा कौशल कषमता िाल काम जस कायाालय की दखरख सरकषा गाडा

आगरद पररयोजना स परभागरित पररिारो को पराथगरमकता क आिार पर

गरदय जाए

िविि िगक पर परभाि िवहलाए एि अनसविि जनजावि र सदभक ि

परभाि शिन वनपिार र उपाय

अनसगरित जनजागरत एि

िगरित िगा पर परभाि

अनसगरित जनजागरत समदाय क लाभ को धयान म रखत हए मलगरनिासी

समदाय क गरलए योजना आगरदिासी गरिकास की योजना बनाई जाएगी

सवततर पिा सगरित सहमगरत क आिार पर FPIC की परगरकरया का

गरकरयानवयिन गरकया जाएगा

गरिगरभनन गरहतसािको को शागरमल करत समय अनसगरित जनजागरत समदाय

का पणा रप स परगरतगरनगरितव और भागीदारी को सगरनगरित गरकया जाएगा

मवहलजओ पर परभाि जडर एकशन पलान का गरनमााण गरकया जाएगा तागरक पररयोजना की िजह

स जडर गरिगरशषट परभािो का आकलन कर उनह गरनपटा या कम करन का

परयास हो सक

पररयोजना म िगरित िगा की मगरहलाओ को रोजगार पराथगरमकता गरमल यह

सगरनगरित गरकया जाएगा

पररयोजना कषतर म मगरहला उदयमी गरिकरता सिा परदाताओ को सहयोग

करन क परयास गरकए जायग गरजसस पररयोजना म काम आन सामिी

समान की खरीदी उनस की जा सक

Page 11

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE FPIC FACILITATOR

Page 12

Screening of Facilitating AgencyIndividual Expert for FPIC

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to

undertake an Environmental and Social Impact Assessment (ESIA) of three solar parks

including internal evacuation infrastructure and associated transmission lines of aggregate

capacity of 1500 MW in the Neemuch Agar and Shajapur Districts of Madhya Pradesh India

(hereinafter referred to as the lsquoProjectrsquo) one of the key tasks as part of this assignment is to

secure Free Prior Informed Consent in keeping with the provisions of IFC PS 7 For this

purpose ERM has undertaken the task of identifying a Facilitation AgencyIndividual (FA) to

assist with the FPIC process This document presents the results of the screening and

shortlisting process for the FPIC FA

Approach and Methodology

The approach and methodology followed for shortlisting of FPIC FAs is presented below

1 Two stage approach was followed for the selection of FPIC Facilitation

AgencyIndividual Initially desk research was carried out to identify Institutions (Universities

Government Departments and Research Institutes etc) NGOs and INGOs located in

Madhya Pradesh state In parallel the ERM team also identified the criterion which will be

used to shortlist the potential Facilitating Agencies The criteria used for screening included

qualification profile affiliation with the type of institutionsorganizations nature of

worksprojects completed working experience with Bhils in MP experience in natural

resource management and rural livelihoods conducting meaningful consultation community

mobilization and stakeholder engagement familiarity with World Bank Group safeguardsrsquo

policies and procedures comfort with written and spoken English and local dialects etc

2 In the second stage the potential candidates from these institutions were individually

approached to further assess their suitability and find out their availability for the assignment

Convenient date and time for the personal discussion and interview with them was sought

Accordingly the ERM team organized interview with the available candidates at Bhopal

3 The team27 of Environmental Resource Management (ERM) New Delhi visited

Bhopal during 6-8 January 2020 in order to undertake face to face meetings with these

organizations and individuals identified

Screening

4 The screening against the preferred criteria was undertaken for the potential

candidates available to work as FA for FPIC None of these agenciesindividuals reported to

have worked for a FPIC process earlier Also the candidates interviewed are not familiar

with the World Bank and IFC safeguards related policies and procedure applicable for IPs in

energy and other infrastructure development sectors They are however interested in

working and learning from the project The candidates also had limited experience in the

field of natural resource management and rural livelihoods Details of the screening of

potential candidates is given below

27 Team comprised of Ramesh Swarankar Freelance Consultant and Akshita Mishra Senior Consultant ERM

Page 13

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Amitav Singh

and Leena

Singh

Debate Lok

Nyas (DEBATE)

Duplex C-22

Alkapuri Near

DRM Office

Habibganj

Bhopal-462024

0755-2985007

0755-2417656

9425018144

9425004556

debateindiag

mailcom

MA Social

Works

The key persons are active for

last 3 decades in Social Work

The Debate Trust was

incorporated in 2002-03 and has

more than 15 years of experience

in working with PRIs in Madhya

Pradesh with an focus in Tribal

(Schedule-V) Areas Mr Amitav

Singh is a member of National

Committee for Monitoring of

MNREGA

Ms Leena Singh has also

experience of working with rural

women for more than 15 years

Have

worked

with Bhils

of

Jhabua

Yes Yes Yes

Mr Amitav

Singh is a

leading trainer

for PRA and

Social Audits

by Panchayat

Raj Ministry

No

But was

part of the

FPIC

training

provided

by

ActionAid

Yes

(requires

support in

Reporting)

Score 18 3 2 3 3 3 2 2

Dr Jose

Payyappilly

Address 142

Nyay Nagar

Sukhliya

Indore

Contact-

7828355557

PhD MA

in Social

Work amp

Sociology

About three decades experience

of working on Health HIVAIDS

CSR Literacy Adult education

minority education related

projects and programs funded by

GoI GoM Clinton Foundation Bill

amp Melinda Gate Foundation

UNAIDCARE World Action

Forum VHAI Christian Aid NGO

such as Samarthan in MP

Chhattisgarh and other states It

Has

worked

with Bhils

as part of

a larger

communi

ty in

Jabhua

No No Yes

Trained in

traditional

communicatio

n systems

folklore

folktale

Familiar with

planning

strategy and

community

Associated

with the

network of

NGOs CSOs

and village

level

functionaries

Worked with

local

governments

and elected

No Yes

Page 14

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Email Id

payyappillyjose1

6gmailcom

jose_soolyaho

ocoin

includes the districts in MP with

IPs population

Dr Jose has worked as team

leader director executive director

and other positions Also worked

as Local Governance and BCC

Advisor to DANIDA for Health

Services Program State Media

Coordinator State Resource

centre Adult Education MP

Program Producer Radio Veritas

Asia Manila Philippines

stakeholder

engagement

panchayat

representative

s

Score 14 2 1 1 3 3 1 3

Parushram

Tiwari

Address- C-443

Sarvdharm

Colony Kolar

Road Bhopal

Contact-

09425065132 amp

8319540266

Email Id

drpram42gma

ilcom

PhD

MPhil MA

( Sociology

More than 20 year experience of

working as consultant at different

positions in Public health

HIVAIDS literacy education

nutrition urban development and

governance projects and

programs in MP including Malwa

area and other states

These projects were funded by

UNICEF UNFPA ADB Clinton

Foundation Women amp Child

Development Rural

Development Urban

Administration amp Development

No No Yes Has

worked as

the State

Project

Manager

for Sanjhi

Sehat

project of

MP State

Rural

Livleihood

Mission

Yes Is good

with

coordination

and

communicatio

n

Yes has

experience in

Planning

management

and execution

capacity

building

training and

Networking

and advocacy

Liaison

support and

team building

No Will need

support in

documentatio

n

Page 15

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

State AIDS Control Society of

GoMP and the NGO partners

Dr Tiwari was the Project Director

and District Program officer under

National Literacy Mission at

District Collector offices at Dhar

and Indore MP respectively

during 1991-1998

Score 13 1 1 2 3 3 1 2

Mr Sandip Naik

Adddress-C-55

Kalani Bagh

Dewas MP

Pin Code

455001 India

Contact- +91-94

2591 9221

Email id

naiksandigmai

lcom

Diploma in

Developm

ent

Facilitation

from TISS

Mumbai

MPhil

MA in

Rural

Developm

ent and

English

Literature

About 20 year experience of

working on health nutrition

education governance and

women empowerment with

governments of MP

Worked with NGOs International

agencies and MP government on

senior positions

Since 2014 working with CRY

and TDH on issues of malnutrition

and preparing booklets

brochures pamphlets on nutrition

adolescents issues and childrenrsquos

health Also written textbooks

teachers learning material and

manuals for state govt for SCERT

etc

Yes No No Yes Yes No Yes

Page 16

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Score 14 2 1 1 3 3 1 3

Dr Rahul Dev

Bahawsar

Address Block

No 14 Flat No

5 Shalimar

Enclave E-3

Arera Colony

Bhopal ndash

Madhya

Pradesh

Contact-

08223015124

Email

rbhawsarrediff

mailcom

rahuldevbhawsa

rgmailcom

PhD amp

MPhil in

Population

Studies

from IIPS

Mumbai

MSC

Statistics

24 years experience in

monitoring evaluation and

implementation of programs in

health and social development

sectors in MP Rajasthan and

Gujarat states

Engaged in nutrition assessment

survey in 18 districts of MP states

including IPs dominated districts

such as Dhar Jhabua with Bhil

population and coordinated with

state health women amp child

development and rural

development departments during

the study period

Involved in conducting health

surveys at national level

Worked as a staff with Health

Management Research Institute

Jaipur and IPE Global Consulting

Firm New Delhi etc These

projects were funded by DFID

UNICEF UNFPA GoI GoMP

etc

Yes has

worked

in

Jhabhua

and Dhar

No Yes Has

worked

with State

Rural

Livelihood

Mission

Somewhat

His strengths

lie more

towards

quantitative

research

Somewhat No Yes

Page 17

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Working as freelance expert and

has a registered consultancy firm

that is inactive

Score 12 2 1 2 2 2 1 2

Ms Aastha

Anuragi

Address 173

Sanjay

Complex

Phase-2

Geetanjaly

Square Bhopal-

462003

Contact-

9425365216

8160123726

Email

aasthaanuragi

gmailcom

MBA Rural

Manageme

nt amp MSC

in Physics

More than 15 year experience of

working particularly imparting

training to different stakeholders

in drinking water and sanitation

Swachh Bharat ODF missions

WASH livelihood menstrual

hygiene etc Master trainer for

total sanitation program

Worked as consultant in MP

Chhattisgarh West Bengal UP

Gujarat Jharkhand Bihar states

These projects were funded by

World Bank Water Aid UNICEF

DFID GoI State governments

and ICIMOD Nepal

No No Yes has

worked as

a project

facilitator

with MP

livelihood

project

Yes Yes No No

Score 12 1 1 2 3 3 1 1

Note The scoring for each criterion was as follows 0- Not applicable 1- Not Meeting the Requirement 2- Partially meeting the requirement 3- Completely fulfilling the requirement

Page 18

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

Page 19

TERMS OF REFERENCE FOR FPIC FACILITATION AGENCY

Background

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake an

Environmental and Social Impact Assessment of three solar parks including internal evacuation

infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch

Agar and Shajapur Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work for the project ERM is required to assess the impacts on the indigenous

marginalized communities within the site and its influence area prepare an Indigenous Peoples Plan

(IPP) apart from other ESIA amp RAP deliverables The project is also required to conduct a FPIC process

covering affected Scheduled Tribe (ST) population

Villages to be covered in FPIC Process

The project area has a few small ST settlements and in few others a small number of ST households

live along with a majority non-ST population Following 5 villages are identified for carrying out FPIC

process

Solar Park Selected ST villages

for FPIC

Number of

Households

Name of ST

Community

Agar Solar Park Ladwan 12 Bhil

Shajapur Solar Park Parsula 41 BhilBhilala

Neemuch Solar Park Badi and Kawai 97 BhilBhilala

Note Additional ST families in neighbourhood villages of the same Solar Park will be made part of this

process to a limited extent

Phases in FPIC Process

The FPIC process will be divided into two phases as described below

Phase What to Do Schedule

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Apr 2021^

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

May-Aug 2021^

^ Activities were suspended in April 2021 due to break out of the second wave of Covid-19 in India These

activities will be re-scheduled once Covid-19 second wave gets over

Deliverables and Responsibilities

Phase Responsibilities Deliverable

I Identification of STs Representatives and formation of committees

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Documentation of capacity building of STs Representatives on FPIC

Mutually agreed FPIC Process and composition of local ST Representative committees

Page 20

Phase Responsibilities Deliverable

Hindi Translation of TDPIPP and designing Information sharing tools

Participatory mapping of all natural resources and cultural sites to be impacted

Participatory assessment of impacts on Tribal population

Identification of Livelihood and Welfare programs to be included in Draft TDP

Inventory of natural resource and cultural sites

Documentation of participatory process of impact assessment

Note on livelihood and welfare programs

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation (Photos Video MoMs for each meetingsevents) of FPIC process

The revised package in Draft TDP and a mutually agreed Draft FPIC Agreement

Personnel Requirement

The FPIC Facilitation Agency will require to mobilize following key personnel for completing these tasks

Designation Desired Qualification and Experience

Coordinator The coordinator to be a post-graduate in social sciencessocial work with at

least 15 years of experience in ruraltribal development Prior involvement in

FPIC related work with prominent civil society organizations or multilateral

development finance organizations will be preferred

Facilitator (Male) The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in facilitation of participatory rural appraisals The

facilitator needs to have sound knowledge of livelihood issues in Malwa

region of Madhya Pradesh and must have worked with Panchayati Raj

Institutions for their capacity building The facilitator should be familiar with

the local dialect (Malwi) spoken in Malwa region

Facilitator

(Female)

The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in working with rural women She should have

knowledge of livelihood and social context of women in Malwa region She

should have prior experience in facilitating participatory rural appraisal

processes involving rural women

Documentation

Assistant

The documentation assistant should be a Graduate in social sciencesmass

communication She should have at least 5 years of experience in ruraltribal

development and have carried out process documentation of development

projects She should have a good command over Hindi and should be

familiar with Malwi dialect

Community

Mobilizer

The community mobilizer should have passed higher secondary and have

experience of working with any NGO for at least 2 years She should have

good communication skills She will provide all logistical support necessary

to ensure participation of maximum number of people She also helps

Documentation Assistant in photo and video documentation of the FPIC

process

Organization Profile

The organization should have at least 10 years of experience in working in rural and tribal

development issues in Madhya Pradesh The organization should have a reputation of successfully

implementing projects related to community mobilization and capacity building They should have

Page 21

prior experience of working with tribes and should be known for their dedication and commitment

towards tribal rights and promoting their development

The business of sustainability

ERM has over 160 offices across the following

countries and territories worldwide

Argentina

Australia

Belgium

Brazil

Canada

Chile

China

Colombia

France

Germany

Ghana

Guyana

Hong Kong

India

Indonesia

Ireland

Italy

Japan

Kazakhstan

Kenya

Malaysia

Mexico

Mozambique

Myanmar

The Netherlands

New Zealand

Norway

Panama

Peru

Poland

Portugal

Puerto Rico

Romania

Russia

Senegal

Singapore

South Africa

South Korea

Spain

Sweden

Switzerland

Taiwan

Tanzania

Thailand

UAE

UK

US

Vietnam

ERM India Private Limited

Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

wwwermcom

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

Signature Page

05 May 2021

Environmental and Social Impact Assessment of three Solar Parks including internal evacuation infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the state of Madhya Pradesh India

FPIC Approach Draft Discussion and Decision Making Framework Draft Final Report

Name Dr Swayam Panda

Job title Technical Director

Name Ajay Pillai

Job title Partner

ERM India Private Limited Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

copy Copyright 2021 by ERM Worldwide Group Ltd andor its affiliates (ldquoERMrdquo)

All rights reserved No part of this work may be reproduced or transmitted in any form

or by any means without the prior written permission of ERM

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page i

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

CONTENTS

1 INTRODUCTION 1

11 Project Background 1 12 Timeline of Various EampS Studies 3 13 Scope amp key deliverables related to FPIC for MP Solar Project 4 14 Structure of the Report 11 15 Limitations 11

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS 12

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in

2018 12 22 International Social Safeguard Policies Applicable to the Project 16

221 IFC Performance Standards 16 222 World Bank Operation Manual OP 410 16

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard

Policies of IFC and WB 17

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION 22

31 Affected Villages Government land used by ST Population 22

311 Neemuch Solar Park (Unit 1-3) 22 312 Agar Solar Park (Unit 4 amp 5) 26 313 Shajapur Solar Park (Unit 6-8) 30

32 Selection of FPIC Villages 36 33 Impact on Nomadic Pastoral Communities 37 34 Impact on Government and Grazing Land 38 35 Impact on Cultural Sites affiliated to STs 39 36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure 40

361 Use of Government Land in TLs Associated With Neemuch Solar Park 41 362 Use of Government Land in TLs Associated With Agar Solar Park 42 363 Use of Government Land in TLs Associated With Shajapur Solar Park 43 364 Conclusion on FPIC Trigger for Transmission Lines 45

4 DESK BASED INFORMATION COMPILATION 46

41 Information Collection and Compilation 46 42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks 46

421 Government Land Allotment for Neemuch Solar Park 46 422 Government Land Allotment for Agar Solar Park 46 423 Government Land Allotment for Shajapur Solar Park 47

43 Review of Previous Community Consultations for Allotment of Government Land 47

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER 49

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020) 49

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park 49 512 Disclosure of Intention to Conduct FPIC Agar Solar Park 49 513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park 50

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises

with STs (Aug 2020) 50

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village) 52 522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village) 55 523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages) 58

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL 62

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page ii

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

6 INDEPENDENT FACILITATOR AGENCY 63

61 Need for FPIC Process Facilitation Agency 63 62 Screening of FPIC Process Facilitation Agency 63 63 Roles and Responsibility for FPIC Process Facilitation Agency 65 64 Terms of Reference for FPIC FA 65

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS 66

71 Use of Language 66 72 Use of Customary Decision Making Process and Traditional Leaders 66 73 Promoting Participation of Women and Youths 67 74 Expectation on Material Information Prior to Discussion 67 75 Need for Capacity Building of IP Representatives 68 76 Need for a Mediation Mechanism 68 77 Following Principles of Good Faith Negotiation 69 78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and

Supportive Environment 70

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK 73

81 Introduction 73 82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo 73

821 Appointment of FPIC Facilitation Agency and Orientation 73 822 Introducing FPIC FA to RUMSL and FPIC Villages 73 823 Formation of ST Committees 74 824 Capacity Building of ST Committees 74

83 The Draft Discussion amp Decision Making Framework 74

831 Formation of Committees 75 832 Acceptance of Draft Discussion and Decision Framework 76 833 Disclosure of Draft IPPIPDP to ST Committee 77 834 Explaining Draft IPPIPDPTDP to ST Committee 78 835 Internal Consultation Process by ST Committee 78 836 First RUMSL and ST Committee Meeting 78 837 Second RUMS and STs Committee 79 838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee

(MC) 79 839 Informing Community on Draft FPIC Agreement by ST Committee 79 8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and

Ratification of Final IPP and FPIC Agreement 80 8311 FPIC Process Documentation Report 81

84 Tentative Time-line 81 85 Responsibility Matrix 83

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT

FPIC

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE

FPIC FACILITATOR

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page iii

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Tables

Table 11 Villages to be covered in FPIC Process 1

Table 12 Salient Features of the Project 2

Table 13 The status of ESIA Study Components and Community Engagement 3

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables 5

Table 21 Key Provisions of Land Revenue Code 12

Table 22 Comparison of Provisions of Consent Process in Applicable Indian Regulations vis-agrave-

vis Provisions in IFC PS-7 17

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land

Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

19

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected

Villages 22

Table 32 Agar Solar Park- Government Land- Land Use Category 26

Table 33 Shajapur Solar Park- Government Land- Land Use Category 30

Table 34 Villages to be covered in FPIC Process 36

Table 35 Designated grazing land (Charnoi) and Remaining Government Land 38

Table 36 Impact on Cultural Sites Affiliated to STs 39

Table 37 List of Power Evacuation Infrastructure 40

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of

STs 41

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST

Population 42

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs 43

Table 41 Dates of Government Land Allotment for Neemuch Solar Park 46

Table 42 Dates of Government Land Allotment for Agar Solar Park 46

Table 43 Dates of Government Land Allotment for Shajapur Solar Park 47

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha

Resolution 47

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park 49

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park 50

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park 50

Table 54 Site visit Dates and Site Activities 51

Table 55 Names of Potential Representatives in Ladwan Village 54

Table 56 Names of Potential Representatives in Parsula Village 57

Table 57 Names of Potential Representatives in Badi and Kawai Village 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency 63

Table 62 Roles and Responsibilities of FPIC FA 65

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context 69

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages 71

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page iv

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Figures

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages 24

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages 25

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages 28

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages 29

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages 33

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages 34

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages 35

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments 56

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process 74

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Acronyms and Abbreviations

Name Description

CSO Civil Society Organizations

DDMF Discussion and Decision Making Framework

DPR Detail Project Report

DREO District Renewable Energy Officer

ESIA Environment and Social Impact Assessment

ESS Environment and Social Standards

FA Facilitation Agency

FPIC Free Prior Informed Consent

FPIC-FA FPIC Facilitation Agency

FPICon Free Prior Informed Consultation

GAP Gender Action Plan

GFN Good Faith Negotiation

GN Guidance Note

GoMP Government of Madhya Pradesh

GP Gram Panchayats

HO Head Office

ICP Informed Consultation and Participation

IFC International Finance Corporation

IPDP Indigenous Peoples Development Plan

IPP Indigenous Peoples Plan

Ips Indigenous Peoples

JV Joint Venture

LRP Livelihood Restoration Plan

MC Mediation Committee

MNRE Ministry of New and Renewable Energy

MPLRC Madhya Pradesh Land Revenue Code

MPUVNL Madhya Pradesh Urja Vikas Nigam Limited

MW Mega Watt

NGO Non-Government Organizations

NOC No Objection Certificate

OBC Other Backward Castes

OP Operation Policy

PPP Public Private Partnership

PRA Participatory Rural Appraisal

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CONTENTS

Name Description

PS Performance Standard

RAP Resettlement Action Plan

RPO Renewable Purchase Obligation

RUMSL Rewa Ultra Mega Solar Limited

SC Scheduled Caste

SEP Stakeholder Engagement Plan

SHG Self Help Group

SPD Solar Park Developer

SPO Solar Purchase Obligation

ST Scheduled Tribe

TDP Tribal Development Plan

ToR Terms of Reference

WB ESF World Bank Environment and Social Framework

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

1 INTRODUCTION

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Impact Assessment (ESIA) including Resettlement and

Rehabilitation Action Plan (RAP) of three solar parks including internal evacuation infrastructure and

associated transmission lines of aggregate capacity of 1500 MW in the Neemuch Agar and Shajapur

Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work ERM is required to assess the impacts of the Project on the Indigenous

Peoples (IPs) or Scheduled Tribe (ST) and develop an approach and implement the process of Free

Prior Informed Consent (FPIC) The villages in Table 11 were identified to be covered in the FPIC

process during the scoping stage The intention of conducting FPIC process involving ST families in

these identified villages was communicated to the Sarpanch1 and a project information sheet (in

Hindi) was shared around Dec 2019

Table 11 Villages to be covered in FPIC Process

Solar Park Selected ST

villages for FPIC

Number of

Households

Name of ST

Community

Date on which Gram

Panchayat was informed

about FPIC Process

Agar Solar Park Ladwan 12 Bhilala 19th Dec 2019

Shajapur Solar Park Parsula 41 Bhilala 30th Jan 2020

Neemuch Solar Park Badi and Kawai 61 Bhil and Bhilala 5th and 6th Dec 2019

The Covid-19 pandemic brought restrictions for finalizing the project boundary and preparation of

ESIA Reports between Mar 2020 and Jun 2020 ERM initiated the FPIC related works and submitted

a Memo on selection of FPIC villages dated 29th Jun 2020 which reviewed the government land

allotment and triggers for FPIC

The FPIC Approach Paper (current document) is based on the understanding of the socio-political

context within which the affected STIPs population lives and suggestions received from the

prominent ST representatives with whom a preliminary round of discussions was held The Discussion

and Decision Making Framework (see Section 8) is accepted by RUMSL and was planned to be taken

back to the affected ST community for discussion and acceptance in Apr 2021 (see Section 832)

This has been delayed due to second wave of Covid-19 which started in Apr 2021 and decision on

further visits and consultations will be undertaken based on how situation unfolds in the coming

weeks The FPIC Approach paper will be finalized after the Discussion and Decision Making

Framework is discussed with ST Committees representing affected ST communities and agreed by

them

11 Project Background

The Government of India has identified the solar power sector as one of the critical components for

infrastructure development and overall economic growth The Government of Madhya Pradesh

(GoMP) through Ministry of New and Renewable Energy (MNRE) is developing ground mounted grid

connected solar power projects in Madhya Pradesh International Finance Corporation (IFC) is

providing investment advisory services to RUMSL thereby enabling Government of Madhya Pradesh

(GoMP) to develop the project on Public Private Partnership (PPP) mode and to support GoMP in

1 The rural local self-government bodies in India are known as Gram Panchayat which comprises of several wards Each ward

elects a ward member to represent them The Gram Panchayat thus comprises of multiple elected Ward Members The Chair Person of these elected local body is known as Sarpanch The vice chairperson of the Gram Panchayat is known as Upsarpanch or Naibsarpanch All adult electorate of a Gram Panchayat constitute Gram Sabha or General Assembly of the Gram Panchayat

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INTRODUCTION

meeting its energy requirements and in the process meet its Renewable Purchase Obligation (RPO)

and Solar Purchase Obligation (SPO)

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) Its primary objective is to develop

and facilitate development of large scale solar power projects in the state of Madhya Pradesh

RUMSL is planning to develop three solar parks (see details in Table 12) and their associated

internal evacuation infrastructure and transmission lines The World Bank had agreed to provide

financial support for the Project

Table 12 Salient Features of the Project

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Capacity and Configuration

3 Units (Units 1 2 3) adding up to 500 MW

2 Units (Units 4 and 5) adding up to 550 MW across Susner (Unit 4) and Agar (Unit 5)

3 Units adding up to 450 MW across Moman Badodiya (Units 6 and 7) and South Shajapur (Unit 8)

Total Land Area as of 24 June 2020

Unit 1 3515 ha Unit 2 34713 ha Unit 3 36701 ha Total 106573 ha

Unit 4 60809 ha Unit 5- 79918 ha Total 140758 ha

Unit 6- 2462 ha Unit 7 4859 ha Unit 8 2551 Total 9872 ha

Government Land (ha) allotted as of 24 Jun 2020

67819 ha

Allotment of additional 28979ha is under process Thus the total government land area is 962949 ha

127338 ha 931 ha allotted and additional 14ha to be allotted

Date of Government Land allotment

Allotment Date

Area in Ha

17-01-2018 23868

30-05-2017 43951

Total 67819

Allotment Date

Area in Ha

28022019 5633

28022019 7053

21062019 1495

20-06-2019 15925

28022019 283

20062019 19714

280202019 1683

21012019 3492

04012018 602

09082018 2669

30112016 5562

02012018 5699

02012018 16116

06012018 17663

09082018 15583

Total 127137

Allotment Date

Area in ha

26-05-2017 914

26-05-2017 3052

26-05-2017 2011

11-12-2017 11261

11-12-2017 1171

11-12-2017 171

11-12-2017 1386

11-12-2017 4015

11-12-2017 4596

11-12-2017 9545

11-12-2017 1763

26-05-2017 16461

28-06-2019 2675

28-06-2019 6134

Total 931

Private Land 1862 ha 1342 ha 9951 ha

Patta land 7572 ha 0 515 ha

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INTRODUCTION

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Proposed Commissioning Date

Tender and bid process tasks completed

- Start of registration downloading of the RFP access to Data Room on 26th Jan 2020

- Facilitation of site visit 26 to 28th Feb 2020

- Issue of Draft Project Agreements on 15th Jun 2020

- First pre-bid meeting was held on 30th Jun 2020

- ESIA Reports was issued on 16th Oct 2020

Tender and bid process schedule ahead

- Second pre-bid meeting on 30th Mar 2021

- Proposal due date for 3 sites between 3rd Jun 2021 and 18th Jun 2021

- Financial proposal opening between 14th Jun and 28th Jun 2021

- Reverse Auction Process 17th Jun and 30th Jun 2021

Purchase of Private land between Apr and Jun 2021

Target date for providing SPD land access June 2021

Indicative construction time of 19 months

Target date for commissioning of Solar Park Nov 2022 It is understood that RUMSL will initiate a process of hand over of balance government land to revenue department no longer required for the project

12 Timeline of Various EampS Studies

The allotment letters of the government land were issued at different points of time between 2017 and

2019 The boundary demarcation (tarmeem2) of these allotted government land for the 3 solar parks

was completed in October 2020 RUMSL is planning to initiate private and patta land procurement to

start in Apr 2021 and all sale agreements are signed by Jun 2021

The timeline of ESIA studies of these 3 Solar Parks is provided in Table 13 below

Table 13 The status of ESIA Study Components and Community Engagement

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

ESIA Field

visits

December 2019 December 2019-

January 2020

January ndash February

2020

September 2020

Report Final ESIA

submitted in

October 2020

Final ESIA

submitted in

October 2020

Final ESIA submitted

in October 2020 Draft ESIAs for

Neemuch TL and

Agar- Shajapur

TL submitted in

November 2020

RAP-

LRP

Field

visits

November-

December 2020

August 2020 August 2020 December 2020

Report Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-WB

Draft RAP-LRP is

reviewed by IFC-

2 Tarmeem ground verification process to confirm land ownership and to demarcate any patta land andor private land that

may have been identified within a government khasra This process is done by Revenue Department from time to time in the normal course of action (with or without any project) As an outcome of this process following can be achieved Revisions in the Patwari maps Khasra books Digital database other revenue records preparation of survey reports etc This process is undertaken by Officials from the Revenue Department usually inclusive of the Tehsildar RI Patwari etc

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INTRODUCTION

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

WB and ready for

Public Disclosure in

Mar 2021

WB and ready for

Public Disclosure

in Mar 2021

and ready for Public

Disclosure in Mar

2021

WB and ready for

Public Disclosure in

Mar 2021

IPP Field

Visits

Initiation 5-6th Dec 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and Draft IPP 13-16th Aug 2020

HH Survey 7-14th Sep 2020

Initiation 19th December 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 6-7th Aug 2020

HH Survey Not done

Initiation 30th Jan 2020

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 8-12th Aug 2020

HH Survey 13-14th Aug 2020

No IPP to be prepared for Transmission Line

Report Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure in

Mar 2021

Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure

in Mar 2021

Draft IPP is reviewed

by IFC-WB and

ready for Public

Disclosure in Mar

2021

The ERM ESIA team has held several consultation meetings in project affected villages covering a

cross-section of stakeholders in a sequential manner The broad understanding of the socio-economic

and livelihood practices was carried out in Dec 2019 and Jan 2020 as part of collection of baseline

information The detailed study for RAP-LRP and IPP subsequently took place in Aug 2020 The details

of the consultations held for ESIA RAP-LRP are part of those reports and details of field visits and

consultation activities carried out for preparation of this FPIC Approach Paper and Draft IPP is described

in Section 4 below

13 Scope amp key deliverables related to FPIC for MP Solar Project

ERM as a part of the FPIC requirement for the project is expected to support the elaboration and

implementation of a robust FPIC process for the MP Solar Park project to be developed in 2 Phases

Phase I the overall principles and engagement process and criteria for obtaining FPIC should be

agreed on with the affected Indigenous People (IP) communities potentially before bidding

Phase II the focus of the proposed FPIC process will then be on seeking consent from affected

IP communities for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior

to the main construction phase) In phase II it is likely that the PPP concessionaire will also

play a role and as such the Social Expert will continue to advise RUMSL but also monitor the

activities of the concessionaire

The Table 14 below summarises the key deliverables tasks involved and expectations against each

of these tasks in terms as per the scope The current status progress of these tasks and timeline for

future activities is also proposed It should be noted that these timelines may change in keeping with

evolving health and safety situation in context of COVID-19

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INTRODUCTION

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

I OBJECTIVE AS PER RFP The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities before bidding ie the submission of proposal for solar parks by concessionaire

Guidance to RUMSL (ONGOING)

Provide guidance to RUMSL on the most appropriate sequencing of steps vis-agrave-vis the FPIC process as per IFC PS 7 requirements

eg agreement and verification of legitimate IP representatives to represent affected communities in FPIC negotiations

agreement with IPs and their representatives on the FPIC engagement process and next steps including disclosure and consultation of draft updated project impact mitigation benefits package documentation

share of responsibilities between RUMSL and PPP concessionaire etc

This will also include advise on broader stakeholder analysis and engagement strategy

to build support for the FPIC approach and implementation of the project and

to participate in agreed outreach to influential local and international stakeholders andor additional sources of adviceinput

ERM has been providing handholding support to the client in terms of meetings and calls where the requirements of IFC PS 7 are discussed and possible implications of project decisions on the FPIC applicability are discussed

The training for RUMSL team on ICP (SEP) PS-7 and FPIC process on 27th Aug 2020

Sharing of Draft FPIC Approach Paper 1st Sep 2020

Discussion on Draft IPP and Formation of Committees for FPIC Process 16th Mar 2021

Submission of Note on FPIC budget FPIC Process

Responsibilities of PPP concessionaire submitted as part of Draft IPPs (Appendix-F)

A meeting with facilitating agency and their ToR was held in 1st Week of Apr 2021

A Joint field trip with RUMSL FPIC Team will be held after Covid-19 Second Wave is over to

- Verify the IP representatives and formation of ST committees

- To agree with ST committee on Draft Discussion and Decision Making Framework

Draft FPIC approach paper

Desk-based Information Compilation and Assessments

Review national applicable law to identify any gaps with IFC PS7 and ways to bridge them

While developing the FPIC approach leverage as much as possible the requirements of applicable law and the consent process usually applied when IP are affected

The FPIC approach should also ensure that affected IP communities are involved

ERM did not get access to documentation of community consultation as part of seeking

NOC3 from Gram Panchayats

Conversation with Sarpanch of villages with ST population revealed that consultation was

A field trip for a joint meeting between RUMSL and ST communities is proposed to be held after Covid-19 Second Wave is over The field trip will include the following

3 The allotment of unused Government land within any revenue village needed a resolution of concerned local government body (Gram Panchayat) under S 234 (4) till Nov 2018 See more details in

Section 21 below The Solar Parks does not require any EIA studied in India

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Identification of affected IP individuals and communities and representatives as well as project impacts mitigation measures and potential benefits related to them (ongoing process during ESIA)

Initial Meeting with Gram Panchayats (GPs) and Informing them on FPIC

Social MappingSite walk-through

Preparation of Draft FPIC Approach Paper which builds on key elements of IFC PS7 FPIC requirements is prepared in consultation with RUMSL IP representatives and other stakeholders and could be acceptable to each party

Internal Discussion and Consensus on FPIC Approach Paper

Sharing of Draft FPIC Approach with IP and Consensus Building

in the identification of impacts and provide input on the development of mitigation and benefit plans

The FPIC approach should be cognizant that impacts on vulnerable groups within the Affected Communities of IP if any should be adequately addressed during negotiation and in relevant documentation

It should be based on the engagement with local IP community decision-making authoritiesrepresentatives (and taking into account gender and other IFC PS 7 related prerogatives) to discuss the FPIC process with input from support organization

The draft approach paper should reflect a mutually acceptable engagement and negotiation framework for the FPIC process based on the principles of Good Faith Negotiations It should include a clear agreed indication on what constitutes consent in the project context

Ensure through revision and feedback that all other components under this assignment (ifwhen available) are aligned with the defined FPIC approach ndash including the Environmental and Social Impact Assessment (ESIA) Resettlement Action Plan (RAP) Stakeholder Engagement Plan (SEP) Gender Action Plan (GAP) and develop the Indigenous People Development Plan (IPDP)

restricted to Gram Panchayat members Though they initially reluctant to sign on the NOC after persuasion of District Collector they finally signed

PRA exercises which includes participatory mapping of social relationship livelihood and natural resources was held between 6th to 15th Aug 2020

The social mapping during 6-15th Aug collected information on existence of traditional decision making process and gender representation aspect

The proposed FPIC process as part of this FPIC approach paper (Refer Chapter-8) reflect GFN principles

The FPIC approach paper was discussed with RUMSL prior to sharing it with WB-IFC

The ESIA disclosure was done as part of the PRA exercises for IPP in Aug 2020The RAP survey was done in these villages around the same time to address their concerns over loss of privatepatta land

Consultations during RAP and Draft IPP preparation included PRA process where STs participated to identify impacts and expressed their expectation on project benefits

The feedbacks and key issues in ESIA (including GAP SEP) and RAP is synchronised in Draft IPP

- Introduce FPIC Facilitation Agency

- Facilitate formation of ST representative committees

- Inform them their rights in the context of FPIC process

- Consult and build mutual agreement on the lsquoengagement and negotiation frameworkrsquo (as in Chapter-8 of this report) which will include a clear agreed indication on what constitutes consent

- The STs Representatives will be asked about time they require for internal discussion and a tentative date for the first discussion on benefits proposed in IPP will be fixed

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Independent FPIC Facilitator Agency

Assess the need for Independent FPIC Facilitator Agency

Screening of IPOsCSOs for Independent FPIC Facilitator Agency possible facilitator options to determine how they can play a role in the process - who what how

Provide a list of names of key advocacy groupsNGOsCSOs considered SWOT (or similar) analysis of each organization considered identification of preferred organization and

Terms of Referencersquo for the role of the same in the FPIC process and its relevance for the FPIC process in that area and for that specific group

To be discussed in next call FA brings credibility of an independent agency (other than RUMSL and ESIA consultant) Considering the project context their position can be reviewed

The review and assessing the need for a FA is discussed in section 6 of this report The Scope of work for the FA is provided in Appendix-F

Preparation of IPDPIPPTDP

Note ESIA RAP SEP and other management plans should be prepared by this stage Infact the FPIC process report should also draw input from the engagement undertaken as part of the ESIA process

Indigenous People Plan (or

Community Development Plan

Stakeholder Engagement Plan) or

similar management documents

aimed at ensuring ongoing and

adequate engagement with IPs

The collection of baseline

information through PRA

exercises and a sample

household survey was done

in Aug 2019 The IPP draws

inputs from consultations for

ESIA RAP-LRP and

benefits are also

synchronised

Three Draft IPPs one for

each Solar Parks with a

package of benefits for

affected STs is ready and

disclosed in May 2021

These will be shared with

affected STs as part of the

FPIC negotiation process

subsequently for their

considerations and

acceptance

Preparation of Draft FPIC Process Report

FPIC Process Report will include (but not be limited to)

identification of IPs IP representatives and decision-making authorities

assessment of capacity of IPs IP representatives to undertake good faith negotiations

summary of any capacity building undertaken

agreed engagement and negotiation framework (including the process undertaken to agree upon the framework)

This document will be further updated and finalised once the whole process is completed

Note The FPIC process should incorporate key considerations contained in IFC PS 7 and GN 7 eg the need for free prior and informed engagement inclusion of differentiated measures to allow the effective participation of those identified as particularly disadvantaged or vulnerable including analysis of the legitimacy and representativeness of IP leaders and the role responsibilities and participation of

To be initiated once FPIC Process starts

The process of identification of IPs representatives and decision making authorities (ST RUMSL and Mediation Committees) which will take place once Covid-19 second wave is over and will be documented as Draft FPIC Process Report This will be a living document which will be updated after every round of field activities and negotiation meetings

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

detailed summary of consultations meetings engagement undertaken as part of the FPIC process

expert opinion on the process and outcomes

share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to complete the FPIC process

external stakeholders with vested interests in the outcome

Input to the bidding document

For the bidders in terms of FPIC amp IPDP requirements

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc

The Draft IPP for each Solar Park has Annexure-F providing roles and responsibilities and scope of work for the Solar Park Developer (SPD)

All 3 Draft IPPs with Annexure-F are ready for disclosure in May 2021

II OBJECTIVE AS PER RFP Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Preparation of communication Material

Communication material to be based on IPDP ESIA and RAP This should include culturally appropriate document on impacts and mitigation to be used during FPIC engagement and negotiation

All preparation including translation of FPIC-related materials including communication material summaries of relevant EampS documentation local benefits plans etc (printing arrangement to be agreed with RUMSL)

A Project Profile Fact Sheet was shared in Dec 2019

A summary of ESIA was shared in Aug 2020

The communication material based on Draft IPP will be prepared and used during FPIC process The Draft communication material will be shared with IFC-WB for their approval prior to its use in field

A parallel information disclosure process of RAP-LRP would also take place

Culturally Appropriate Information Disclosure Campaign

Share accurate and up to date information on project impacts proposed mitigation measures and proposed benefit streams in a culturally appropriate manner (ie in local language (as appropriate following discussion with IP representatives) in written and oral format)

The information disclosure should especially ensure that following are achieved

provide sufficient time for capacity building and

support to affected communities to understand these matters and their rights

The affected ST population speaks Malwi dialect The FPIC FA will have facilitators who would be familiar with this local dialect used

The FPIC FA will carry out the capacity building activities

The FPIC FA will spend 2 days at each Solar Park to do the capacity building workshops with local ST Representatives who would participate in FPIC discussion with RUMSL

The FPIC FA will do this once Covid-19 second wave gets over

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Consent from the Indigenous communities

Meetings for Negotiation and Decision Making

Participate in and offer expert support to key FPIC-related meetings involving affected IP representatives RUMSL and other relevant authorities etc during the FPIC process

Support RUMSL in the organization of these meetings and in recording their outcome including the collection of comments and concerns of those attending

Measuring Consent and Signing of FPIC Agreement

Note This include also support the RUMSL in designing undertaking and collecting evidence of Good Faith Negotiations (GFN) resulting in Consent which involves (i) willingness to engage in a process and availability to meet at reasonable times and frequency (ii) provision of information necessary for informed negotiation (iii) exploration of key issues of importance (iv) use of mutually acceptable procedures for negotiation (v) willingness to change initial position and modify offers where possible and (vi) provision of sufficient time for decision making

Present updated materials and seek consent from affected IP communities and their leaders

Document the consent process in a mutually agreed written format including an agreed mechanism for monitoring of key commitments in future and grievance redress as well as identifying share of responsibilities between the RUMSL SPDs and other relevant parties

Evidence of representativeness and involvement of Indigenous Peoples representative bodies and organizations (eg councils of elders or village councils)

Evidence of agreement between the parties as the outcome of GFN (eg FPIC agreement MOU a letter of intent and a joint statement of principles agreed mitigation plans collective land agreements etc)

Other documents may include Client records photographs media reports personal letters or third-party accounts etc regarding eventsdemonstrations other activities for the project undertaken by project-affected IP communities with high relative levels of participation by (i) the affected community as a whole or (ii) by sub-groups particularly affected by the project

ERM will work alongside FPIC FA and RUMSL to help the FPIC process taking right direction

Final FPIC Process Document

Throughout the FPIC process (Phase I and Phase II) ERM should help documenting the FPIC process and provide an opinion and direction about the process and outcome vis-agrave-vis IFC PS7

The whole set of activity in Phase II need to be updated as part of the Final FPIC Process Document

The tentative timeline for the FPIC Process was scheduled between Jun 2021 and Sep 2021 The timeline will be revised after the ongoing Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

The Draft FPIC Process Report will be submitted within 2 weeks of completion of FPIC process

Advise RUMSL but also monitor the activities of the concessionaire in phase II

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

14 Structure of the Report

This report is organized into following sections

Section 1 Introduction (this section)

Section 2 Applicable law and gaps assessment against IFC PS7 requirements

Section 3 Affected IPs population project impacts and mitigation

Section 4 Desk-based information compilation

Section 5 Engagement leading up to FPIC Approach Paper

Section 6 Independent facilitator agency

Section 7 Key elements in FPIC Process

Section 8 Draft Discussion and Decision Making Framework

15 Limitations

This Report is prepared after multiple field visits and interactions with affected ST community elected

leaders of Gram Panchayat and other key informants The assessments are based on information

received from RUMSL and other secondary information at some places The public health concerns

due to Covid-19 pandemic has prevented large community gatherings and communityrsquos willingness to

allow people from outside to spend much time with them

ERM team communicated with community members over telephone to seek clarifications and know

their views However it was not always possible to keep the discussion focused and definitive as it

could have been in case of a face to face discussion ERM has made efforts to build trust among

affected STs by sharing relevant information and answering their queries with clarity As FPIC process

is an itinerant process this relationship is expected to further evolve in future

The Draft Discussion and Decision Making Framework described in Chapter 83 though has been

accepted by RUMSL and reviewed by IFC and WB it would be discussed with committees formed by

affected STs and their feedbacks will be incorporated The FPIC process described in Chapter-8

therefore would undergo necessary changes

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan could not

be ascertained as nomadic tribes did not visit these sites when ERM conducted field visits The general

migration pattern of pastoral nomads is expected to have faced constraints of Covid-19 restrictions If

pastoral nomads or their representatives will be identified during the FPIC process an appropriate

decision on their participation will be taken

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

This section provides an understanding of the applicable national regulations that pertain to the process

of land procurement and the rights of the Indigenous Peoples and a comparison between the provisions

of the same against the IFC PS 7 requirements

It should be noted that the Environmental and Social Impact Assessment (ESIA) Reports4 and the

Resettlement Action Plans (RAP) provide a detailed understanding of applicable regulations This

section is focused on the government land procurement process and its impacts on the collective rights

of the Indigenous Peoples identified in the project

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in 2018

The allotment of government land for these three solar parks is done under provisions of the MP Land

Revenue Code 1959 The Chapter-XVIII of this Code deals with rights in abadi5 (habitation area) and

un-occupied land and its produce

The Madhya Pradesh Land Revenue Code (MPLRC) was enacted in 1959 and has undergone several

amendments since then It was recently amended in 2018 and 2019 These recent amendments along

with other changes changed the procedure for allotment of unoccupied government land Some of the

land allotment letters were prior to this amendment and others after this amendment (see details in

Section 42) Table 21 below provides a comparison of key provisions in pre and post 2018

amendment

Table 21 Key Provisions of Land Revenue Code

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

Collective (Nistar) Rights on Unoccupied Government Land

Section 114- Land recordsmdash In addition to the map and

Bhoo Adhikar Pustikas there shall be prepared for each

village a khasra or field book and such other land records as

may be prescribed

Section 233- Record of unoccupied landmdash A record of

unoccupied land shall in accordance with rules made in this

behalf be prepared and maintained for every village

showing separatelymdash (a) unoccupied land set apart for

exercise of nistar rights under Section 237

Section 114 (e) (i) (ii) requires

the details of all unoccupied land

be maintained as described in

Section 233 One Such

document is the Nistar Patrak

under Section 234 Section 233 A record of all unoccupied land shall be prepared for every village and urban area in accordance with rules made in this behalf

Preparation of

Nistar Patrak

and change in

entries in

Nistar Patrak

Section 234 (1)- The Sub-Divisional Officer shall in

accordance with the provisions of this Code and the rules

made thereunder prepare a Nistar Patrak for every village

embodying a scheme of management of all unoccupied land

in the village and all matters incidental thereto and more

particularly matters specified in section 235

Section 234- same as 1959 Sub

section (2) (3) (4) have been

removed

4 Three separate ESIA Reports for Solar Parks one for each Solar Park one for the Neemuch Transmission Lines (Units 12

and 3) and another for the Transmission Lines for Agar and Shajapur Solar Parks (for Units 4 to 8) have been prepared 5 According to the MP Land Revenue Code 1959 abadi means the area reserved from time to time in a village for the residence

of the inhabitants thereof or for purposes ancillary thereto and any other cognate variation of this expression such as village site or gaonsthan shall also be construed accordingly No change was made to this definition in the subsequent amendments to the code

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(2) A draft of the Nistar Patrak shall be published in the

village and after ascertaining the wishes of the Gram Sabha

it shall be finalised by Sub-Divisional Officer

(3) A copy of the Nistar Patrak so finalised shall be kept in

the office of the Gram Panchayat

(4) On a resolution passed by the Gram Sabha by a majority

of not less than two-thirds of the members present and

voting the Sub-Divisional Officer with the prior sanction of

the Collector and also after making any such inquiry as he

deems fit inter se change the entries in the Nistar Patrak

(b) Record additional unoccupied land under any entry in the

Nistar patrak for fulfilment of further Nistar rights of villagers

Matters to be provided for in Nistar Patrak

Section 235- The matter which shall be provided for in the

Nistar Patrak shall be as follows namely

(a) terms and conditions on which grazing of cattle in the

village will be permitted

(b) the terms and conditions on which and the extent to

which any resident may obtain-

(i) wood timber fuel or any other forest produce

(ii) mooram6 kankar7 sand earth clay stones or any other

minor mineral

(c) instructions regulating generally the grazing of cattle and

the removal of the articles mentioned in paragraph (b)

(d) any other matter required to be recorded in the Nistar

Patrak by or under this Code

Section 235- same as previous provision of Land Revenue Code

Provision in

Nistar Patrak

for certain

matters

Section 236 - In preparing the Nistar Patrak as provided in

Section 235 the Collector shall as far as possible make

provision for-

(a) free grazing of the cattle used for agriculture

(b) removal free of charge by the residents of the village for

their bona fide domestic consumption of-

(i) forest produce

(ii) minor minerals

(c) the concessions to be granted to the village craftsmen for

the removal of the articles specified in clause (b) for the

purpose of their craft

Section 236 - same as previous

provision of Land Revenue Code

Collector to

set apart land

for exercise of

Nistar rights

Section 237 (1) Subject to the rules made under this Code

the Collector may set apart unoccupied land for the following

purposes namely-

(a) for timber or fuel reserve

(b) for pasture grass bir or fodder reserve

(c) for burial ground and cremation ground

(d) for gaothan

(e) for encamping ground

Section 237 (1) remains same

6 Soil used particularly for road paving 7 In India an impure concretionary carbonate of lime usually occurring in nodules in alluvial deposits and especially in the

older of these formations

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(f) for threshing floor

(g) for bazar

(h) for skinning ground

(i) for manure pits

(j) for public purposes such as schools play grounds parks

road lanes drains and the like and

(k) for any other purposes which may be prescribed for the

exercise of right of Nistar

237 (2) Lands set apart specially for any purpose mentioned

in sub-section (1) shall not otherwise be diverted without the

sanction of the Collector

Section 237 (3) Subject to the rules made under this Code

the Collector after securing the land mentioned in clause (b)

of subsection (1) to minimum two percent of the total

agriculture land of that village may divert such unoccupied

land as mentioned in sub-section (1) into abadi or for

construction of roads state highways national highways

canals tanks hospitals schools colleges Goshalas and

any other public utility projects as may be determined by the

State Government

Provided that the land set apart for the purposes mentioned

in subsection (1) shall not be diverted and allotted to any

person for agriculture purpose

Section 237 (4) When it becomes indispensable to divert the

land set apart for the purposes mentioned in sub-section (1)

for such development and infrastructural projects which are

owned or approved by the State Government but not

covered under sub-section (3) the Collector after satisfying

himself on alternatives available and also on obtaining land

of equivalent area for fulfilling the same nistar rights from the

concerned project may divert the land for such purposes by

passing a reasoned order to this effect Thus in case Nistar

land needs to be diverted for the project the project needs to

make available an equivalent area for the replacement of the

same nistar rights

The section 237 (2) is removed

Section 237 (3) remained same

Section 237 (4) remains same

Rights in Fruit Bearing Trees and other trees in Un-Occupied Government Land

Section 239 (1) Where before coming into force of this

Code any fruit bearing tree was planted by any person in the

unoccupied land of any village and is so recorded then

notwithstanding that such land vests in the State

Government such person and his successor in interest

shall from generation to generation be entitled to possession

and usufruct of such trees without payment of any royalty or

other charge whatsoever therefore

Section 239 (6) the State Government may make rules for

carrying out the purposes of this section

Section 239 (1) same as 1959

Section 239 (6) The unoccupied

land on which any tree planting

permit or tree patta has been

given prior to the commencement

of MP Land Revenue Code

(Amendment) Act 2018 may be

used for any public purpose by

the order of Collector If any

interest of the holder of such tree

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

planting permit or tree patta is

adversely affected due to such

use the holder shall be entitled

for such compensation which

shall be calculated in such

manner as may be prescribedrdquo

Exclusive jurisdiction of revenue authorities

Section 257 - Except as otherwise provided in this Code or

in any other enactment for the time being in force no Civil

Court shall entertain any suit instituted or application made

to obtain a decision or order on any matter which the State

Government the Board or any Revenue Officer is by this

Code empowered to determine decide or dispose of and in

particular and without prejudice to the generality of this

provision no Civil Court shall exercise jurisdiction over any

of the following matters - (w) any claim to modify any entry

in the Nistar Patrak

Section 258 (1) The State Government may make rules

generally for the purpose of carrying into effect the

provisions of this Code

(2) In particulars and without prejudice to the generality of

the foregoing powers such rules may provide for (lviii) the manner in which the wishes of the villagers shall be ascertained under Section 234 (2)

Section 257 - same as 1959

Section 258 (1) and (2) (lviii)

same as 1959 it should be noted that the Section 234 (2) was removed in 2018 Amendment

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers Diverting the un-occupied

government land8 categorised as grazing land that is recorded in Nistar Patrak (there may be other

grazing land available) and such other Nistar rights9 including the right in fruit bearing trees and other

trees in unoccupied government land after the amendment in 2018 does not require any consent

process with concerned village community

Hence it is expected that the government land allotted for the project prior to the 2018 Amendment of

MP Land Revenue Code is expected to have involved a resolution of concerned Gram Sabha As per

Sec-6 of the Madhya Pradesh Panchayat Raj Act 1993 the quorum of every meeting of Gram Sabha

shall not be less than one-tenth of the total number of members of the Gram Sabha or five hundred

members of the Gram Sabha whichever is less The Act does not specify presence of women in

Gram Sabha to be mandatory

Other Indian laws which has provisions for consent process are not applicable to this project and an

overview of them is provided in Box 31 below

8 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands 9 Nistar rights refer to collective rights of a revenue village to use specified government land for the purposes mentioned in

S235 of MP Land Revenue Code This includes right to free grazing cattle collecting minor minerals construction materials burialcremation grounds for religious and cultural events etc

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Box 21 Other Indian Laws with provisions for consent process and their applicability

22 International Social Safeguard Policies Applicable to the Project

221 IFC Performance Standards

The part of PS1 dealing with Management Program envisages an Indigenous Peoples Plan (IPP) as a

thematic plan and should be developed by qualified experts with substantive experience For projects

with adverse impacts to Indigenous Peoples the client is required to engage them in a process of

Informed Consultation and Participation (ICP) and in certain circumstances the client is required to

obtain their Free Prior and Informed Consent (FPIC)

The FPIC from the affected communities of Indigenous Peoples is required when the following special

circumstances (in paragraphs 13ndash17 of Performance Standard 7) are present

Impacts on lands and natural resources subject to traditional ownership or under customary use

Relocation of Indigenous Peoples from lands and natural resources subject to traditional

ownership or under customary use

Significant impacts on critical cultural heritage that is essential to the identity andor cultural

ceremonial or spiritual aspects of IPs lives

Where a project proposes to use the cultural heritage including knowledge innovations or

practices of Indigenous Peoples for commercial purposes

IFC PS7 requires to avoid adverse impacts on Indigenous People and if adverse impacts are

unavoidable the project should prepare an Indigenous Peoples Plan outlining the actions to minimize

andor compensate for adverse impacts in a culturally appropriate manner Some of the key

provisions with respect to IPP are

A free-standing IPP may be prepared or it may be a component of a broader community

development plan

The IPP should detail actions to minimize andor compensate for adverse social and economic

impacts and identify opportunities and actions to enhance positive impacts of the project on the

Indigenous Peoples

Where appropriate the IPP may also include measures to promote conservation and sustainable

management of the natural resources on which the Indigenous Peoples depend

The IPP should include a clear statement of roles and responsibilities funding and resource

inputs a time-bound schedule of activities and a budget

The IPP shall be regular monitored and should be flexible to allow for it to be adapted as needed

if circumstances change

222 World Bank Operation Manual OP 410

The World Bankrsquos Operational Policy on Indigenous Peoples (OP 410) aims at ensuring that the

development process fosters full respect for the dignity human rights and cultures of IPs thereby

In Indian context the constitutionally recognized Scheduled Tribes are usually considered as Indigenous Peoples

while determining their entitlements under international social safeguards systems

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006( FRA) is not

relevant as no forestland was diverted The Provisions of the Panchayat (Extension to the Scheduled Areas) Act

1996 (PESA) acts is not applicable for the project as the project site is not in a schedule V area There are no

specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement

consultation and consent

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

contributing to the Bankrsquos mission of poverty reduction and sustainable development To achieve this

objective Bank-assisted projects which affect IPs provide them a voice in design and implementation

avoid adverse impacts where feasible or minimize and mitigate them and ensure that benefits

intended for them are culturally appropriate

The Bank recognizes that IPs are commonly among the poorest and most vulnerable segments of

society and in many countries they have not fully benefited from the development process It also

recognizes that the identities cultures lands and resources of indigenous peoples are uniquely

intertwined and especially vulnerable to changes caused by development programs Because of this

issues related to indigenous peoples and development are complex and require special measures to

ensure that IPs are not disadvantaged and that they are included in and benefit from these programs

as appropriate

Under the OP 410 the Bank requires the borrower to undertake a social assessment to evaluate

projectrsquos potential positive and adverse effects on the IPs and to examine project alternatives A

project that affects Indigenous Peoples the borrower engages affected IPs in a free prior and

informed consultation (FPICon) process

Note The World Bank adopted Environment and Social Framework (ESF) which comprises of ten Environment

and Social Standards (ESS) The ESS-7 deals with Indigenous PeoplesSub-Saharan African Historically

Underserved Traditional Local Communities which requires FPIC to be obtained in special circumstances where

customary rights on natural resources used by IPs is impacted The WB has financed the renewable projects to

MNRE prior to adoption of the new ESF in Dec 2019 The Shajapur Solar Park is under the old WB safeguards

and therefore the new ESF is not applicable

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard Policies of IFC and WB

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers The diversion of the un-

occupied government land10 categorised as grazing land that is recorded in Nistar Patrak (there may

be other grazing land available) and such other Nistar rights including the right in fruit bearing trees

and other trees in unoccupied government land after the amendment in 2018 does not require any

consent process with concerned village community A comparison of key provisions of PS-7 vis-agrave-vis

legal provisions in Indian context is provided in Table 22

Table 22 Comparison of Provisions of Consent Process in Applicable Indian

Regulations vis-agrave-vis Provisions in IFC PS-7

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Assessment of Impact on Indigenous People

The client will identify through a process of Social and Environmental Assessment all communities of Indigenous Peoples who may be affected by the project within the projects area of influence The client will assess the nature and degree of the expected social cultural (including cultural heritage) and environmental impacts (direct and indirect) on them and avoid adverse impacts whenever feasible

There is no requirements for environment impact assessment (EIA) for Solar Park Projects There are no specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement consultation and consent

10 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands Such usages will be confirmed only through the Tarneem process for each site

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Preparation of IPP

The clients actions will be developed with the informed consultation and participation of affected Indigenous Peoples and contained in a time-bound plan such as an Indigenous People Plan or a broader community development plan with separate components for Indigenous Peoples

There is no legal requirement for an Indigenous Peoplersquos development plan

Consultation and Consent from affected IPs

In projects with adverse impacts on affected communities of Indigenous Peoples the consultation process will ensure their free prior and informed consultation and process of community engagement will be culturally appropriate and commensurate with the risks and potential impacts to the Indigenous Peoples

The acquisition of the private land owned by ST will be done through MP Consent Policy 2014 and the RAP addresses the impact on individual ST land ownersoccupiers The impact on customary rights (such as Nistar rights) over collectively used unoccupied government land is dealt under the provisions of MP Land Revenue Code 1959 There is no consultationconsent process for diversion of grazingNistar lands under MP Land Revenue Code 1959 (As amended up to 2019) The consent process in other Indian laws such as FRA or PESA which has consent process is not relevant to the project

Land Revenue Code had a requirement for Gram Sabha consent to be taken prior to diversion of

Nistar rights as part of the 2018 Amendment the same provision was removed As most of the

government land for Shajapur Solar Park was allotted in 2017 Table 23 below provides a

comparison of provisions of the consent process under MP Land Revenue Code 1959 (prior to Nov

2018 amendment) vis-agrave-vis requirements under IFC PS-7

The key elements of FPIC process as per IFC PS (including Guidance Notes- GN) identified for

comparison includes

1 Requirements of information disclosure (as in PS-129) 2 Informed consultation and participation (as in PS-130-31 and PS-710) 3 Good Faith Negotiation (as in GN-725) and 4 Consent and documentation (as in PS-712)

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Information Disclosure

Relevant project information must be disclosed to Affected

Communities and other stakeholders to enable them to

understand the risks impacts and opportunities of the project

The Project will provide Affected Communities with access to

relevant information on

the purpose nature duration and scale of the project

risks and potential impacts and relevant mitigation measures

the envisaged stakeholder engagement process and

the grievance mechanism

Information disclosed must be relevant transparent objective

meaningful and easily accessible and in a culturally appropriate

local language(s) and format and is understandable to Affected

Communities

Under MP Revenue Code 1959 and MP

Panchayat Raj Act 1993 the information

disclosure to affected communities (including

Schedule Tribes) is limited to the intended

purpose of the allotment of unoccupied

government land

The disclosed information and proceedings are

recorded using the language of the State

The information disclosure to affected communities

prior to the meeting does not disclose all relevant

information particularly potential risks The

information disclosed is not easily accessible to STs

and other vulnerable communities

The process does not involve any grievance

mechanism

Informed consultation and participation

Where a Project has potentially significant adverse impacts on

affected communities an ldquoinformed consultation and

participationrdquo (ICP) process should take place ICP is an

organised and iterative consultation that involves a more in-

depth exchange of views and information leading to the Project

incorporating the views of those affected into project decision-

making on matters that affect them directly

The consultation process should capture both menrsquos and

womenrsquos views and their different concerns and priorities The

process should be documented in particular the measures taken

Section 234 of MP Revenue Code 1959 (Prior to

Nov 2018 Amendment) required the draft Nistar

Patrak of every village and any changes in therein

to be published by Sub-Divisional Officer with

prior sanction of the District Collector only after

ascertaining wishes of the Gram Sabha

(expressed through a resolution passed in Gram

Sabha held for this purpose)

As per Section 6 of the MP Panchayat Raj Act

1993 the Gram Sabha can be held with a quorum

of one-tenth of the total member of Gram Sabha

The MP Revenue Code does not require any

iterative consultation that involves in-depth

exchange of views

The participation of women and other vulnerable

sections is not mandatory

The quorum of the meeting is only ten percent of the

total members of the Gram Sabha The notice for

holding a special Gram Sabha is only 7 days and

there is limited information shared in terms of the

agenda of the meeting Hence a resolution passed

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

to avoid or minimise risks to and adverse impacts on the

Affected Communities and should inform those affected about

how their concerns have been considered

In addition the process should Involve Indigenous Peoplesrsquo representative bodies and

organisations as well as members of the Affected Communities of IPs and

Provide sufficient time for IPs decision-making processes

or five hundred members whichever is less

There is no specific requirement on presence of

women to fulfil quorum requirements

A special meeting of the Gram Sabha is held

within seven days of receiving the requisition

by a Gram Sabha with a bare minimum presence

does not reflect majority decision

The process does not require representative bodies

of IPs to represent their interests

Good Faith Negotiation

FPIC will be established through good faith negotiation between

the Project and the Affected Communities of IPs Good faith

negotiation generally involves (i) Willingness to engage in a process and availability

to meet at reasonable times and frequency (ii) Provision of information necessary for informed

negotiation (iii) Exploration of key issues of importance (iv) Mutually acceptable procedures for the negotiation (v) Willingness to change initial position and modify

offers where possible and (vi) Provision for sufficient time for decision making

The MP Revenue Code require neither iterative

prior consultation nor exchange of views with

administration

The administrative process for allotment of

unoccupied government land does not involve a

negotiation process through which their feedback

and concerns are incorporated or addressed

Consent

In certain circumstances the client is required to obtain the Free

Prior and Informed Consent (FPIC) of affected IPs FPIC does

not necessarily require unanimity and may be achieved even

when individuals or groups within the community explicitly

disagree The measurement of consent is expected to be

included in the lsquomutually accepted processrsquo for FPIC decision

making

Consent

Section 234 (4) required the Gram Sabha to pass

a resolution with support of a majority not less than

two-thirds of the members present and voting As

per Section 6 of the MP Panchayat Raj Act 1993

the Gram Sabha can be held with a quorum of one-

tenth of the total member of Gram Sabha or five

hundred members whichever is less There is no

specific requirement on presence of women to fulfil

quorum requirements

Consent

The FPIC process in IFC PS-1amp7 recognizes that

consent is not necessarily a unanimous decision

yet there has to be a mutually agreed threshold of

consent in an FPIC process that can vary from

project to project The threshold defined in MP

Panchayat Raj Act 1993 is one-tenth of the total

members of Gram Sabha passing a resolution with

support by two third majority present and voting

Thus the consent threshold for a resolution is 66

of the total members of Gram Sabha

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Documentation

The client will document

The mutually accepted process (FPIC Decision Process Framework Document) between the client and Affected Communities of Indigenous Peoples and

Evidence of agreement between the parties as the outcome of the negotiations

Documentation

The documentation is limited to the entries in Gram

Sabha minutes book The entire set of

documentation is kept by Administration and not

shared with Gram Panchayat

Considering this low threshold as per legal

requirements the FPIC process requires a mutually

accepted threshold for decision making

Documentation

The documentation of the process carried out during

the Gram Sabha meetings leading to the resolution

though is written down in the Gram Sabha minutes

book however there is no guideline on what should

be covered Therefore a mutual agreement on

documentation requirement is necessary

As described in GN62ndash65 where government processes involve project-level decision and actions the client should review these processes in relation to the requirements of the Performance Standard and address identified gaps where feasible

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

The FPIC was triggered at the scoping stage on account of impact on grazing land and other natural

resources within the allotted government land on which STs have claims of customary use which is also

recognized under MP Land Revenue Code as Nistar rights The statement of different categories (which

are part of the Nistar rights of village community) of government land to be used for the proposed Solar

Parks from different villages and percentage of ST population in these villages is provided below

31 Affected Villages Government land used11 by ST Population

311 Neemuch Solar Park (Unit 1-3)

The Neemuch Solar Park is comprised of 3 units and the land is acquiredpurchased from 3 villages

The land category (classification in revenue records as per their currentintended use) is provided in

Table 31 below

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected Villages

Village Name

Govt Land Category in Hindi

Govt Land Category in English Sum of Area (Ha)

ST Population in of Total Village Population

Unit -1

Bardavada Chargah Grazing land 2271 55

Charnoi KamdalKK (Kabil Kast)

Grazing land 4013

DathaKamdal Land with stone outcrops and shallow soil

1655

Gair mumkinCharnoi Uncultivable waste land grazing land

492

Kabil Kast Cultivable 2

Kamdal Land with stone outcrops 169

KamdalDathaDahar Grazing land 4641

KamdalDathaKaKa Grazing land 4279

PK 052

NA 2053

Sub-Total (Bardawada) 25774

Kawai Datha Land with stone outcrops and shallow soil

8962 1992

NA 425

Sub-Total (Kawai) 9388

Total Unit 1 351615

Unit -2

Badi Datha 052 2292

Kabil Kast 11568

NA 5835

Sub-Total (Badi) 17455

Kawai NA 17846 1992

Sub-Total (Kawai) 17846

Total Unit 2 35301

Unit -3

Badi Charnoi (grazing) Grazing land 355 2292

Datha 3805

Gairmumkin Charagah

(grazing)

Uncultivable waste land

grazing land

4184

11 The MP Land Revenue Code recognizes the right to use for grazing collection of timber fire-wood earth morums and other

products (see Section 235 of MP Land Revenue Code)

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

KaKa (Kabil Kast) Culturable wasteland 5

Kamdal 11179

NA 13727

Badi total 36945

Total Unit 3 3694557

Grand Total (Unit-1 2 and 3) 107408

Note land category for the units is as per the Allotment Letters NA= Not Available

The screening of the Census 2011 data shows that there is presence of ST population in all three

villages In Badi and Bardawada villages the land categories such as Charnoi Charagah are clearly

recorded as grazing lands The map below shows the location of village settlements and their area

designated as Grazing Land

The ST families in Badi and Kawai live in several small cluster of satellite settlements The Bardawada

had only 22 ST population with 4-5 families Bardawada is part of Dhardi Gram Panchayat and the ST

households live farther from the Solar Park boundary Their households are scattered and dependency

on the allotted government land for Bardawada village could not be established In terms of

concentration of ST population Badi and Kawai are considered as major ST settlements

Thus ~100 ST households in Badi and Kawai have a claim on customary use of ~18938 ha of

designated grazing land

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

312 Agar Solar Park (Unit 4 amp 5)

The Table 32 provides a break-up of the designated land categories of government land as per revenue

records in Agar Solar Park

Table 32 Agar Solar Park- Government Land- Land Use Category

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Agar Solar Park (unit 4)

Bijnakhedi Germumkin Uncultivable waste land 5598 0

Sub-Total (Bijnakhedi) 5598

Dudhpura Agriculture Agriculture 2243 0

Bardi NA 6631

Gothan Livestock rearing land 2

Khadar The floodplains formed by

yonger alluvium

018

Tree Plantation NA 1495

NA NA 5082

Sub Total (Dudhpura) 15669

Karwa Khedi Chragha Grazing land 251 0

K K NA 475

Khachar Grazing land 068

Pahad Hilly terrain 12392

NA 216

Sub Total (Karwa Khedi) 15346

Keasi Dehariya Gochar Grazing land 283 0

Sub Total (Keasi Dehariya) 283

Ladwan Bardi 7963 579

Charnoi Grazing land 947

Gochar Grazing land 2749

Kavil Kast 609

Khachar Grazing land 238

Pahad Hilly terrain 3062

Waterbody Water body 094

NA 475

Sub Total (Ladwan) 16137

Madhopur Germumkin Uncultivable waste land 1558 0

Sub Total (Madhopur) 1558

Pipalia Kumar Bardi 3492 0

Agriculture land Agriculture 506

Sub Total (Pipalia Kumar) 3998

Total Unit 4 611381

Susner Solar Park (Unit 5)

Palda Germumkin Uncultivable waste land 5689 036

NA 6928

Sub Total (Palda) 12617

Naharkheda Germumkin KaKa Uncultivable waste land 4125 0

Germumkin Uncultivable waste land 1868

NA NA 8908

Sub Total (Naharkheda) 14901

Umariya Charnoi Grazing land 3660 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Charokhar Grazing land 416

Chragha Grazing land 9114

Germumkin Uncultivable waste land 147

Kadim NA 011

Shaskiye Government land 218

Sheda NA 01

NA NA 20907

Sub Total (Umariya) 35806

Pipaliya Nankar NA NA 1822805 0

Total Unit 5 8161745

Note land category for the unit 4 is as per the kml file provided by RUMSL on 30012020 as the allotment letters did not carry

the land use details

Ladwan village has 579 of ST population (~12 households) who have claim on customary use of

3934 ha of designated grazing land Palda was found to have only 1 ST family Moreover no Charnoi

Chargah Gochar land is acquired from Palda Hence ST families in Ladwan were selected to be in

focus for FPIC process

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

313 Shajapur Solar Park (Unit 6-8)

The Table 33 provides a break-up of the land categories of government land as per revenue records

in Shajapur Solar Park In Shajapur Solar Park (Unit 6-8) five villages have ST population They are

Jawadi (034 STs) Parsula (1768 STs) Dehripal (018 STs) Fawaka (238 STs) and

Chouma (072 STs) Of these Dehripal Fawaka and Surajpur do not have any Charnoi Chargah

Gochar land impacted

Table 33 Shajapur Solar Park- Government Land- Land Use Category

Village Name Govt Land

Category in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Moman Badodiya-Unit6

Burlay Agriculture Agriculture 813 0

Germumkin Uncultivable waste land 224

Nala Stream Drain 138

Burlay Total 3191

Jawadi Agriculture Agriculture 198 034

(1 Household with

3 persons)

Gochar Grazing land 4189

Idhan Hetu For fuelenergy 209

Kabil Kast 316

Muram Hetu For Murram (fine aggregate) 063

Pahad Hilly terrain 339

Shivir Camping ground 041

NA 2011

Jawadi total 3596

Dhatrawada Agriculture Agriculture 338 0

Charnoi Grazing land 058

Chragha Grazing land 4058

Germumkin Uncultivable waste land 10638

Gothan Livestock rearing land 128

K Kast 557

Kabil Kast 1217

Kadim 074

Khadan Quarry 291

Khalihan Threshinggrain storage etc 167

Murum Hetu

Khadan

For Murram 125

Nala StreamDrain 042

Road Road 117

NA 6

Dhatrawada total 1841

Total (Unit 6) 25197

Momain Badodiya-Unit 7

Parsula Agriculture Agriculture 515 1768

(~41 households) Barda Rockyhilly 847

Barda Nistar

Chragha

Grazing land 947

Charnoi Grazing land 1064

Idhan Hetu

Surakshit

Secured for fuelenergy-

firewood

209

KK 137

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Khchar Grazing land 311

Nala Streamdrain 146

Nistar Chragha Grazing land 393

Parsula Total 12192

Dehripal Agriculture Agriculture 124 018

(1 Household with

5 populaiton)

Birdi GM 295

Brda 8054

Brda Lala 055

Chuna Hetu 105

Germumkin Uncultivable waste land 2015

Kankad Chuna

Hetu

For coarse aggregate and

lime

105

Khad ke Gadde 15

Muram Hetu For Murram (fine aggregate) 042

Watershed

Planning

Watershed planning 027

NA 1916

Dehripal Total 14004

Bijanakhedi Agriculture Agriculture 2199 0

Bardi 4101

Bardi Charnoi Grazing land 1274

Bardi 385

Chamdi Sthan 042

Charagah Grazing land 035

Charnoi Grazing land 018

Chragha Grazing land 1404

Germumkin Uncultivable waste land 858

Idhan Hetu 209

Khad ke gadhe Manure collection 084

Khalihan Hetu Threshinggrain storage etc 143

Mitti Hetu 063

Muram Hetu For Murram 063

Nala Streamdrain 36

Pathar Hetu For Stone 105

Road Road 203

Shivir Bhumi Camping ground 042

NA 288

Bijanakhedi total 11876

Fawaka Agriculture Agriculture 016 238

(4 Households with

28 population)

Brda Hilly terrain 863

Idhan Hetu Secured for fuelenergy-

firewood

25

Kakkad 418

Muram Hetu For Murram (fine aggregate) 179

Fawaka Total 1726

Chouma Agriculture Agriculture 392 072

(3 Households with

19 population)

Brdi Hilly terrain 562

Chamda Sthan For de-skinning 021

Charnoi Grazing land 989

GM 2943

Gothan Livestock rearing land 5

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Muram Pathar

Khadan

Murram (fine aggregate) 041

Nala Streamdrain 015

Chouma total 5463

Burlay Germumkin Uncultivable waste land 1543 0

Nala Streamdrain 019

NA 2604

Burlay Total 4166

Total (unit 7) 49427

Shajhapur (unit 8)

Surajpur Bardi Hill Terrain 898 203

(3 Households with

16 population)

Germumkin Bardi Uncultivable hill terrain 1170

Nala Streamdrain 597

NA 1894

Surajpur total 4559

Lalpur Beed 023 0

Beed Gair Mumkin 053

Brdi 2333

Charagrah Grazing land 18

Charnoi Grazing land 115

Gair Mumkin Brdi 1608

Kadim 115

Nala Streamdrain 055

NA 1684

Lalpur Total 6166

Hanoti NA 16291 0

Total (unit 8) 27024

Note land category for the units is as per the excel sheet received on 18062020 from RUMSL

Hence 41 ST households in Parsula who have a claim of customary use on ~3134 ha of

designated grazing land was selected to be the focus for FPIC Process The map below shows

the location of Parsula and the area designated as Grazing Land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

32 Selection of FPIC Villages

The assessment of the relevance of the four special circumstances that requires free prior informed

consent (FPIC) to be obtained from affected ST population was undertaken On the basis of the detailed

assessment undertaken as part of ESIA RAP along with targeted consultations with the IP

communities three circumstances are assessed to be not relevant to the project context

Relocation of STs was avoided while determining Solar Park boundary for all the three solar

parks and therefore no relocation of STs is anticipated from lands and natural resources subject

to traditional ownership or under customary use

The physical impact on cultural heritage sites with affiliation to STs is avoided in the three Solar

Park lay out and there is no potential significant impact on critical cultural heritage that is

essential to the identity andor cultural ceremonial or spiritual aspects of local STs community

The Solar Park does not propose to use the cultural heritage including knowledge innovations or

practices of STs for commercial purpose

Table 34 provides the list of villages where the FPIC process will focus covering ST households living

within it The assessment concludes that affected ST families have been living in these villages for

generations and have been using the government land (which was assessed to be subject to

traditional ownership or under customary use of the ST communities) allotted for Solar Park Project

for free grazing their cattle collection of fire-wood and collect edible fruits and plants mostly for self-

consumption The diversion of these land for the solar park will result in impacts on lands and natural

resources It was noticed that 7 other project affected villages had less than 5 ST households the

impact on their customary use of land acquired for the project was assessed and included in this table

too

Table 34 Villages to be covered in FPIC Process

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

Neemuch

Solar Park

Badi

(including 2

satellite

settlements)

80 (~450) Bhill Bardawada which is part of Dhardi Gram

Panchayat has only 4 ST families The location

of these ST households and consultations did

not indicate the government land allotted to

Neemuch Solar Park were under customary use

by them Kawai 17 (~100) Bhill

Agar Solar

Park

Ladwan 12 (~50) Bhill Palda village has 1 ST household and no

grazing (designated as Charnoi Chargah

Gochar) land is acquired from Palda

Palda village has 276ha of designated grazing

land and 28735ha of unoccupied government

land which they will continue to use for free

grazing their cattle and collection of fire wood

Hence the customary use of land by ST

household will continue with a negligible impact

Shajapur

Solar Park

Parsula 41 (~250) Bhill

Bhilala

Apart from Parsula 5 other affected villages

have less than five ST households These

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

villages (with the number of ST households)

are Jawadi (1) Dehripal (1) Fawaka (4)

Chouma (3) and Surajpur (3) The remaining

designated grazing land and total government

land for these 5 villages is provided below

Village Remain-

ing Desig-nated Grazing land (ha)

Total govern-ment land after Project allotment (ha)

Designated Grazing Land in percentage total Govern-ment land

Jawadi 2125 2705 786

Dehripal 241 8116 03

Fawaka 5032 5703 882

Chouma 2278 8167 279

Surajpur 1224 2592 472

The consultation with STs at Parsula informed

that unlike them these ST families do not keep

livestock in large number and mostly work as

construction workers Hence the land allotted to

Solar Park was not under customary use by

them for their livelihood

Note The ST families in these 7 villages will have access to the Grievance Mechanism to register their claims to

participate in the FPIC process In such a case their demands will be shared with concerned ST Committee (or

referred to Mediation Committee) and decision to include them in the process will be taken and an appropriate

mechanism for their representation and participation will be adopted

33 Impact on Nomadic Pastoral Communities

The seasonal use of the grazing and government land by nomadic pastoral communities was noticed

in scoping stage However further consultations with local villagers revealed that they do not visit

regularly and rarely camp on the land allotted to Solar Park These nomadic pastoral communities are

from the neighbouring state Rajasthan and are not recognized as STs in Madhya Pradesh

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan and

consultation with any pastoral nomadic tribes was not held as they did not visit these sites when ERM

conducted field visits The general migration pattern of pastoral nomads is expected to have faced

constraints of Covid-19 restrictions If pastoral nomads or their representatives will be identified during

the FPIC process an appropriate decision on their participation will be taken

ERM will consult GoMP to obtain records of grazing permits issued to pastoral nomads of other states

and determine if any of the villages impacted by Solar Parks figure in it More information on their

migration routes and pattern of seasonal use of forest and revenue land for grazing (which would help

assessing their collective attachment to impacted land) will be collected

Due to C-19 restrictions the regular migration patterns by pastoral nomads are affected in 2020 The

next migration season will be in Nov-Dec 2021 In absence of the particular pastoral nomads the

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

GoMP data on pastoral nomad communities who are issued permit will be used and their IPs status

will be screened through secondary ethnographic literature

FPIC is an iterative process If nomadic pastoral communities could not be consulted the rights of

pastoral nomads will be recognized in TDP and a provision for engagement with them to identify

adequate mitigation measures will be kept in TDP

34 Impact on Government and Grazing Land

The total geographical area of these selected FPIC villages grazing land (Charnoi) available after

allotment remaining government land after allotment percentage of the government land remaining is

given in Table 35 below As per provisions of the MP Land Revenue Code a minium of 2 of the

total private land in a revenue village is reserved as Charnoi or grazing land It is observed that

Ladwan and Parsula have more than this recommended minimum

Table 35 Designated grazing land (Charnoi) and Remaining Government Land

Solar Park Unit

Village Name

Geo

gra

ph

ical

Are

a o

f V

illa

ge

(h

a)

To

tal

Pri

vate

La

nd

To

tal

Go

vern

men

t L

an

d P

rio

r to

All

otm

en

t (

of

To

tal

Geo

gra

ph

ic

Are

a)

To

tal

Go

vern

men

t L

an

d R

eq

uir

ed

for

So

lar

Park

(

of

To

tal

Go

vern

men

t L

an

d)

Rem

ain

ing

Go

vern

men

t L

an

d a

fter

All

otm

en

t to

So

lar

Pa

rk

Perc

en

tag

e o

f G

overn

men

t L

an

d o

f

To

tal

Geo

gra

ph

ical

Are

a

( d

ecre

as

e o

r In

cre

as

e)

()

Desig

nate

d G

razin

g L

an

d

avail

ab

le a

fte

r P

roje

ct

all

otm

en

t (h

a)

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g

Lan

d)

of

the R

em

ain

ing

Go

ve

rnm

en

t

La

nd

()

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g)

Lan

d o

f th

e T

ota

l P

rivate

La

nd

Neemuch Solar Park Unit 1 amp2

Kawai 82698 20132 62566 (76)

24572 (39)

37994 (61)

46 (-30)

397 104 2

Neemuch Solar Park Unit 2 amp3

Badi 130055 33599 96456 (74)

51499 (53)

44957 (47)

35 (-39)

646 144 2

Agar Solar Park Unit 4

Ladwan 59076 31913 27163 (46)

16832 (62)

10331 (38)

17 (-29)

6682 6468 21

Shajapur Solar Park Unit 7

Parsula 69061 51439 17622 (26)

1162 (66)

6002 (34)

9 (-17)

1802 3002 4

Note () As per requirement under MP Land Revenue Code a minimum of 2 of the private land area within a

revenue village is to be reserved as Charnoi or grazing land for collective use by villagers

() Total Charnoi or grazing land prior to the allotment of Government land available in secondary sources

(Census 2011) is old as the land allotment took place between 2017 and 2019 Some Government Land

Allotment Letters mentioned the pre-allotment land category classifications (see Table 31 32 and 33) but this

data was not available for all vilalges to calculate the proportionate reduction of Charnoi land

The percentage of government land in some of the villages was high prior to the allotment of land for

Solar Parks For example the government land in Kawai formed 76 and that of Badi 74 of the

total geographical area Allotment of government land for Solar Parks has reduced the proportion of

the government land in these villages but the percentage of reduction varies from village to village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

For Kawai the percentage of government land after allotment has reduced from 76 to 46 (-30)

and for Badi it changed from 74 to 35 (-39) In Ladwan village the percentage of government

land changed from earlier 46 to 17 (-29) Similarly in Parsula the percentage of government

land changed from earlier 26 to 9 (-17)

The revenue department has designated some part of the remaining government land as Charnoi or

grazing land as per current Nistar Patrak The designated grazing land area meets the minimum

requirement of 2 of the total private land of that particular revenue village The designated grazing

land area forms 104 and 144 of the remaining government land for Kawai and Badi respectively

The designated grazing land in Ladwan forms 6682 of the remaining government land and in

Parsula it forms 1002 of the remaining government land

35 Impact on Cultural Sites affiliated to STs

The physical impact on all cultural sites (both for ST and Non-ST communities) was avoided by

excluding them from the Solar Park lay-outs However some of the cultural sites will be in close

proximity or access to some of them would be possible only through the Solar Park boundary An

overview of the cultural sites affiliated to STs for each of the Solar Parks is provided below

Table 36 Impact on Cultural Sites Affiliated to STs

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

Shajapur

Parsula

Gwalon ka

Mandi

Located within Solar

Park boundary

Adequate area (as agreed during FPIC

consultations) around the Gwalon-ka-Mandi to

be left unused in Solar Park lay-out

A road of sufficient width to be provided to

reach Gwalon-ka-Mandi

SPD will carry out improvements of the cultural

site after discussion with STs and other

communities using it

SPD will provide adequate civic amenities

(parking space drinking water lighting public

toilets etc) as per discussion with STs and

other community using it

Agar Solar

Park Ladwan

Gwaal Dev

Shrine

Located at the

margin of Solar Park

boundary

The SPD should leave the shrine and

adequate space around it in its lay out plan

Will ensure that access to the shrine by

community is maintained

The SPD will consult community to improve the

shrine Or build a new shrine for Gowals in the

new grazing area

Neemuch

Solar

ParkBadi and

Kawai

None The shrines and

cremation grounds

used by Bhils in

Kawai and Badi are

None

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

avoided in project

layout plan

No cultural sites or shrines with cultural significance for STs as a community was found during RAP

survey

36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure

The power evacuation infrastructures associated with these 3 Solar Parks are listed below The Pooling

Sub Stations (PSS) are located within the Solar Park boundary There will be 8 transmission line (TL)

sections whose footprint will be outside of the solar park boundary

Table 37 List of Power Evacuation Infrastructure

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

Neemuch

Solar Park

33kV220 kV Pooling Substation Unit-1 258 ha Located within the Solar Park

boundary 33kV220 kV Pooling Substation Unit-1 296 ha

33kV220 kV Pooling Substation Unit-1 887 ha

PGICL ISTS Station Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Neemuch

Solar Park

220 kV SC Line - 1 (From Unit 1 to Unit 2)

Transmission Line (TL) 1

332 km TL footprint is outside of the MP

Solar Park boundary includes

28 Towers (04 ha 144sqm

for each tower base) and RoW

of 13m width of 920ha

220 kV SC Line - 2 (From Unit 2 to PGCIL

ISTS substation)

Transmission Line (TL) 2

157 km

220 kV SC Line - 3 (From Unit 3 to PGCIL

ISTS substation)

Transmission Line (TL) 3

251km

Agar and

Shajapur

Solar

Parks

33kV220 kV PSS 4 in Unit 4 158 ha Located inside Solar Park

boundary 33kV220 kV PSS 5 in Unit 5 539 ha

33kV220 kV PSS 6 in Unit 6 513 ha

33kV220 kV PSS 7 in Unit 7 143 ha

33kV220 kV PSS 8 in Unit 8 196 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

PGCIL ISTS substation 830 ha Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Agar and

Shajapur Solar Parks

220 kV SC Line - 4 (From Agar Solar Park Unit 4 to interconnecting point with TL 7) Transmission Line (TL) 4

121 km TL footprint is outside of the MP

Solar Park boundary includes

372 Towers (536 ha

144sqm for each tower base)

and RoW of 13m width for

11914kms with 14951ha

220 kV SC Line - 5 (From Agar Solar Park Unit 5 to PGCIL ISTS substation) Transmission Line (TL) 5

2932 km

220 kV DC Line - 6 (From Shajapur Solar Park Unit 6 to Shajapur Solar Park Unit 7) Transmission Line (TL) 6

667 km

220 kV SC Line - 7 (From Shajapur Solar Park Unit 7 to PGCIL ISTS substation) Transmission Line (TL) 7

1646 km

220 kV DC Line - 8 (From Shajapur Solar Park Unit 8 to PGCIL ISTS substation) Transmission Line (TL) 8

6548 km

361 Use of Government Land in TLs Associated With Neemuch Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 38 below

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of STs

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

1 Arnya 088 958 007 784

Kheda Moka Ka Dol 223 1807 055 83

Bardawada 009 5651 002 55

Kawai 112 8265 016 20

2

Kawai 104

Badi 102 13004 012 23

3 Badi 285

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

Chaksodijhar12 043 4475 012 0

Grand Total 966 42782 011

The transmission line RoW comes from six revenue villages out of which 5 are Solar Park affected

villages There are 2 additional villages coming under TL RoW ie Arnya (088ha) and Kheda Moka

Ka Dol (223ha)

The population of Arnya in 2011 (as per census) was 969 out of which 784 were ST population

The Kheda Moka Ka Dol is comparatively a smaller village with total population of 348 and 83 of it

belong to STs

The proposed RoW of the transmission line will use 007 and 055 of the unused government land

in Arnya and Kheda Moka Ka Dol respectively The RoW of the Transmission Line does not pass

through any reserved or protected forest land The vegetation cover in the transmission line RoW is

mostly shrubs and grassland There would be no restriction on current use of the RoW for free grazing

of cattle Hence the transmission line will not impact customary use of the RoW land by ST

population in Arnya and Kheda Moka Ka Dol

362 Use of Government Land in TLs Associated With Agar Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 39 below

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST Population

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

4 Ladwan 068 13311 051 6

4 Pachora 089 273 033 0

5 Chkali Parmar 093 1567 059 0

5 Jhikadiya 266 13514 197 0

5 Pipalya kumar 229 13328 172 0

5 Chikali goyal 287 20523 140 0

5 Bhanpura 152 17482 087 0

5 Nipaniya Baijnath 381 29047 131 0

5 Tola Khed 095 3757 253 0

5 Kashi Bardiya 219 5362 408 2

5 Tola Khedi 042 3757 112 0

5 Kankariya 105 13354 079 0

5 Bhimlod 026 22564 012 0

12 Chaksodijhar is part of Badi Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

5 Bapcha agar 266 26778 099 0

5 Karadiya 144 23584 061 0

5 Mangwalia 24 15397 156 0

5 Gaysari 219 5293 414 0

5 Dehrinana 314 29331 107 0

5 Pharaspuri 142 16955 084 0

5 Bingaya Agar 112 150 075 0

5 Ralayti 267 2365 1129 0

5 Piplaya ghata 212 12811 165 0

RoW area passing through Kashi Bardiya village constitute 4 of the total government

The vegetation cover in the transmission line RoW is mostly shrubs and grassland There would be no

restriction on current use of the RoW for free grazing of cattle The RoW of the Transmission Line

does not pass through any reserved or protected forest land and therefore does not involve any

potential use of forest produce Hence the transmission line will not impact customary use of the

RoW land by ST population in Kashi Bardiya

363 Use of Government Land in TLs Associated With Shajapur Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 310 below

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

6 Burlay 494 2876 172 0

6 Bijnakhedi 158 14668 108 0

6 Dehripal 215 27508 078 0

7 Fawaka 237 6083 390 2

7 Dehripal 296 27508 108 0

7 Parsula 219 5891 372 18

7 Megha Khedi 098 3537 277 0

7 Singhwad 071 3118 228 24

7 Palakhi 072 1185 608 0

7 Baigaon 27 2387 1131 11

7 Bagwad 335 14239 235 13

7 Karkadiya 111 8267 134 0

7 Pipalya Kumar 101 13328 076 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

7 Pachora 306 13311 230 0

7 Shivgarh 024 13353 018 0

8 Abhaypur 026 7633 034 0

8 Alampura 337 12006 281 0

8 Arniya 233 9019 258 0

8 Bada Beed Jagatpura 32 49327 065 0

8 Barandwa 646 258 250 1

8 Batawada 022 5854 038 0

8 Bhadoni 096 1672 057 4

8 Bordagujar 217 120 181 0

8 Chachakhedi 155 482 322 0

8 Chandangaon 409 5711 716 0

8 Chikali Parmar 299 1567 191 0

8 Dhakadi 174 467 373 0

8 Dupada 181 3624 050 6

8 Fanya 349 22 1586 0

8 Gujar Khedi 02 0

8 Gurdadiya 188 1279 1470 2

8 Hanoti 004 34035 001 0

8 Harangaon 005 3034 016 0

8 Jadmi 371 3597 1031 0

8 Jhonkar 572 13653 419 0

8 Kadiya 06 13653 044 8

8 Kalmoi 009 3916 023 0

8 Kanasiya 109 40642 027 0

8 Karedi 003 16944 002 0

8 Kareli 197 16944 116 0

8 Katwariya 458 9312 492 33

8 Khajuri Kanad 085 3138 271 3

8 Kharkhadi 071 310 023 0

8 Khutpala 016 2359 068 0

8 Kundla Khurd 23 1507 1526 3

8 Merkhedi 26 26 1000 1

8 Mirapura 068 3767 181 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

8 Murdawan 292 101 289 0

8 Nanukhedi Mana 054 12851 042 0

8 Nanya Khedi Ahir 156 19092 082 0

8 Palasi 028 203 138 21

8 Pipalya Kumar 163 13328 122 0

8 Pipalya Naulay 28 8117 345 25

8 Rojwas 138 10 1380 0

8 Samgi 454 9921 458 2

8 Samgimanda 086 2578 334 0

8 Shankarpur 327 5782 566 0

8 Siroliya 003 10446 003 0

8 Surajpur 249 6912 360 2

8 Suwagaon 092 17558 052 9

The RoW of the transmission lines associated with Shajapur Solar Park passes through 60 villages

and 19 villages have ST population Out of these one village ie Parsula is covered in FPIC process

for Shajapur Solar Park

The RoW of the Transmission Line does not pass through any reserved or protected forest land and

therefore does not involve any potential use of forest produce The vegetation cover in the

transmission line RoW is mostly shrubs and grassland There would be no restriction on current use

of the RoW for free grazing of cattle Hence the transmission line will not impact customary use of the

RoW land by ST population in these 18 villages with ST population

364 Conclusion on FPIC Trigger for Transmission Lines

Based on the details of the presence of STs in Transmission Line corridors and assessment

of current land use and land classifications following inferences can be drawn

1 The TL Tower base and RoW corridor does not have any reserved or protected forest Hence potential customary use of forest produce is not relevant

2 The vegetation within TL RoW is mostly shrubs and grassland which is potentially used by local community for free grazing If any of this land under the ROW has been used for free grazing the people (including the ST families) will have other unused government land available to graze The disruption during construction and stringing will be very temporary and people can continue grazing under the ROW as before The few villages where the impact on unused land was higher than 10 either had no or very small (lt5) of ST population

3 The RAP survey has not identified any cultural site within TLs RoW or Tower Base area 4 There will be no physical displacement of any ST family for TLs

Therefore the circumstances requiring to obtain FPIC is not relevant for transmission lines

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DESK BASED INFORMATION COMPILATION

4 DESK BASED INFORMATION COMPILATION

41 Information Collection and Compilation

ERM has undertaken a desk based review of the information available This step involved collecting

and compilation of relevant information from following sources

Review of Detail Project Report (DPR) prepared by PwC dated October 04 2019

Detailed Project Report for the Project Dec 2019

The Project boundary map provided by RUMSL dated 19 Jun 2020

Collection of digitised maps of village boundaries

Compilation of demographic data using census 2011 data

Review of drone imagery for the project shared by RUMSL to identify EampS sensitivities in the

proposed project boundary

42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks

This section provides the timeline of land allotment process which is compiled from the allotment letters

of the land shared by RUMSL

421 Government Land Allotment for Neemuch Solar Park

Government land is being procured through allotments under the provisions of the Madhya Pradesh

Land Revenue Code 1959 (and its subsequent amendments) Table 41 provides details of the land

allotment for the Neemuch Solar Park

Table 41 Dates of Government Land Allotment for Neemuch Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Village

17-01-2018 7A-20(3)2017-2018 23868 Bardawada Kawai and Badi

30-05-2017 26A-20(3)2016-2017 43951 Kawai and Badi

Total 67819

Source RUMSL

67819 Ha (out of total 96894 Ha) is allocated to RUMSL through two allotment letters in the year 2017

and 2018 respectively out of the 96894 Ha of the required Government Land Both these allotment

letters predates the MP Revenue Code Amendment Act 2018 Allotment of additional 28979ha is under

process

422 Government Land Allotment for Agar Solar Park

Table 42 provides details of the land allotment for the Agar Solar Park which has been undertaken

between Nov 2016 and Jun 2019

Table 42 Dates of Government Land Allotment for Agar Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

28022019 7A-19(3)2017-2018 5633 Bijnakhedi

28022019 6A-19(3)2017-2018 7053 Dudhpura

21062019 31B-1212019-20 1495 Dudhpura

20-06-2019 5A-19(3)2017-18 15925 Karwakhedi

28022019 4A-19(3)2017-2018 283 Kasaidehriya

20062019 3B-1212019-20 19714 Ladwan

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DESK BASED INFORMATION COMPILATION

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

280202019 2A-19(3)2017-18 1683 Madhopur

21012019 1A-19(3)2017-18 3492 Piplya Kumar

04012018 9A-19(3)2017-18 602 Naharkheda

09082018 9A-19(3)2017-18 2669 Naharkheda

30112016 4819(3)2015-16 5562 Palda

02012018 8A-19(3)2017-18 5699 Palda

02012018 11A-19(3)2017-18 16116 Pipliya Nankar

06012018 10A-19(3)2017-18 17663 Umariya

09082018 10A-19(3)2017-18 15583 Umariya

Total 127137

Source RUMSL

127137 Ha is so far allocated to the project over 2016-2019 and 5106 Ha was allocated prior to MP

Revenue Code Amendment Act 2018

423 Government Land Allotment for Shajapur Solar Park

Table 43 provides details of the land allotment for Shajapur Solar Park which took place between May

2017 and Jun 2019

Table 43 Dates of Government Land Allotment for Shajapur Solar Park

Timeline

Allotment Letter

Number

Area

Allotted

Villages

26-05-2017 03A-19(3)2016-2017 14991 Dehripal Parsula Kadula MalyaHedi Burlay Jaawdi

Bhandedi Saagdiya Baandahedi Peepalkheda Dopada

Bijana Kheriyaema Kumhariyakhas Dangicha Jaaman

11-12-2017 26A-19(3)2016-17 618 Dehripal Parsula Favka Jaavdi Burlay Chooma

Bijnakhedi Dhatravada

26-05-2017 02A-19(3)2016-17 320969 Kukdeshwar Baamniyakhedi Bordi Khakri Majhniya

Rehli Rulki Dhanda Pidoniya Goyla Aakya Chauhani

Palsaavad Son Desrapur Khokriya Tonk Hanoti

28-06-2019 03A-19(3)2019-2020 8809 Kukdeshwar Bamniyakhedi Bodi Khakri Majhaniya

Rehli Rulki Tanda Pindoniya Goyla Aakya Chauhani

Palsawaad Son Besrapur Khokriya Tonk Hanoti

Total 117697

Source RUMSL

117697 Ha is allocated to the project over 2017-2019 and 108888 ha was allocated prior to MP

Revenue Code Amendment Act 2018

43 Review of Previous Community Consultations for Allotment of Government Land

The summary of the review of the timeline of the government land allotments in FPIC villages is provided in Table 44

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha Resolution

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Allotment prior to

Nov 2018

Amendment

67819 Ha 5106 Ha 108888 Ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

After Nov 2018

Amendment

28979ha 76077 Ha 8809 Ha

Total government

land in Ha

96894 Ha 127137 Ha 117697 Ha

Was the government

land allotted in FPIC

Villages pre or post

Nov 2018

Amendment in MP

Land Revenue Code

Government land allotted in

Badi and Kawai was prior to

Nov 2018 Amendment in MP

Land Revenue Code

Government land allotted

from Ladwan was on 20th

Jun 2019 which is after

Nov 2018 Amendment in

MP Land Revenue Code

Government land allotted

from Parsula was on 26th

May 2017 and 11th Dec

2017 was prior to Nov

2018 Amendment in MP

Land Revenue Code

Was Gram Sabha

resolution required

for FPIC villages

Yes No Yes

Thus as per legal provision (see section 31) the allocation of government land in BadiKawai from Neemuch Solar Park and Parsula in Shajapur Solar Park required a resolution of their respective Gram Sabha and an NOC by Gram Panchayat ERM did not get access to documentation of community consultation as part of seeking NOC from Gram Panchayats Conversation with Sarpanch of villages with ST population revealed that consultation was restricted to Gram Panchayat members Though they were initially reluctant to sign on the NOC after persuasion of District Collector they finally signed It is significant to note that the demarcation of the allotted land took place only recently (Jun to Aug

2020) and the construction process has not started yet13 The FPIC process in compliance to IFC PS-7 requirement is planned to be carried out prior to the construction works of these Solar Parks

13 The process for purchasing private land through consent process has been started in Neemuch

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

An overview of field visits and community engagement is provided in Section 12 above This section

provides details of the consultation carried out with affected STs in the process of preparation of this

FPIC Approach Paper The process involved following three steps

Step-1 Disclosure of intention of conducting FPIC process with affected STs in villages with

significant ST population

Step-2 Disclosure of final solar park boundary and key environment and social impacts (covered

in ESIA) and Participatory Rural Appraisal exercises with affected STs and meeting potential

representatives

Step-3 Identification of ST Representatives and formation of ST Committees and build mutual

agreement between them and RUMSL on Discussion and Decision Making Framework

The Step-1 was carried out in Dec 2019 and Jan 2020 The Step-2 was carried out in Aug 2020 The

details of the process followed during each of these steps are described in sub-sections below

Note The Step-3 is planned to take place in first week of April 2021 and the Draft Discussion and Decision Making

Framework described in Section 83 will be updated accordingly

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020)

The concerned Gram Panchayats identified with STs Population in previous sections were contacted

to inform them about the overall project and intention to conduct a FPIC process involving affected ST

families along with ESIA process The process included preparing a project profile in Hindi (See

Appendix A-B and photo documentation in Appendix C) and handed this over to the elected

representatives of concerned Gram Panchayats These meetings were attended by local RUMSL

personnel The project overview was explained during the meeting and their queries answered

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 51 below

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Badi 1 Sarpanch of Badi Village

2 Kalam Singh (Traditional Head

of Bhil Community in Mama basti)

3 Government Teacher in Bhil

Community

10-12 men from the village

6-7 women from ST (Bhil)

community

5th of December

2019

Kawai 1 Ghasilal (Ward Member in

Kawai Village)

2 Local communitypeople of

Kawai Village

20-25 persons from Kawai

Village were present

4-5 women

6th of December

2019

512 Disclosure of Intention to Conduct FPIC Agar Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Agar Solar Park

The details of the people contacted during this stage is provided in Table 52

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided-

Number of other community

members present during the

meeting

Date of the

Meeting

Ladwan (two

villages covered-

Ladwan and

Kerwa Khedi)

Mohan Singh (Sarpanch for

both villages)

10 persons in Ladwan and

Kerwa Khedi each

No female members were

present in Kerwa Khedi

In Ladwan seven (7) women

members were present in an

FGD that largely included

women

19th December

2019

Repeat visit on

29th January

2020

513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 53

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park

Name of Gram

Panchayat

Name of Person to whom Project

Information Sheet was Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Parsula Since there was no Sarpanch or

Gram Panchayat member present

during meeting one project

information sheet was provided to the

entire community which was

circulated within everyone present

during the consultation and signature

of 1 person from group (Mr Sujit

Singh) was taken

~15 persons in Parsula

Shajapur were present during

consultation also one separate

consultation was held with

women group having ~10

participants

30th January

2020

One common feedback during the consultations undertaken with the community in general and STs in

particular was they were not aware about the solar park boundary to judge which land will be used by

Solar Park and what will be left out for them The ESIA process was working on avoidance and

minimization measures Therefore they were informed that once the boundaries are fixed by the

design team the details will be shared with them

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises with STs (Aug 2020)

The solar park boundaries were finalized and provided to ERM in the last week of June 2020 by the

design team The draft environment and social impact assessment was completed in the month of

Aug 2020 The field-based activities remained suspended from Mar to Jun 2020 due to strict

restrictions imposed on travel and group activities due to Covid-19 pandemic Therefore the next

round of information disclosure and community consultations took place only in Aug 2020 at the time

of the RAP survey

Meeting Sarpanch and a few available Panchayat members

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village level Introductory amp Project disclosure meeting

PRA exercises with STs and information collection for IPP

- livelihood resource mapping

- mapping of social relations and influence and

- village profile

Identifying prominent persons from STs as potential representatives in FPIC process

Understanding the traditional decision-making system and existence of IPOs through key-

informant interviews

The schedule of field visits carrying out these activities is provided in Table 54 and details of these

activities are provided in subsequent sub-sections

Table 54 Site visit Dates and Site Activities

Solar Prak and FPIC Village

Date Site Activities

Agar Solar Park- Ladwan Village

06082020 Visited Ladwan and contacted Patwari Sarpanch and Panchayat Secretary and Fixed a Project Disclosure Meeting (a common meeting including all communities) for next day

07082020 Village level Project Disclosure Meeting at Ladwan

Participatory social mapping and information collection for IPP

Preliminary discussion with 2 Bhil families

08082020 ERM team met Sarpanch of Parsula to brief him and fix a meeting on 10th Aug

ERM team collected land details and village revenue map from Patwari of Ladwan

Shajapur Solar Park- Parsula Village

10082020 ERM team met Sarpanch and a few Panchayat members at Parsula

Shared Project Disclosure note and fixed a meeting with Bhil households of Parsula on 11th Aug

Mapping of social structure of Parsula village and village profiling

11082020 PRA exercise with Bhil community of Parsula resource mapping at Parsula mapping of social relations and influence

Discussion on impact of the Project on grazing land

Understanding the internal decision-making system amongst Bhil

Identifying prominent persons among Bhil families

12082020 Travelled to Neemuch Site from Agar

Neemuch Solar Park- Badi and Kawai village

13082020 Meeting with Sarpanch Badi and sharing of the Project Disclosure Note with Badi community (including all communities)

Social and resource mapping with Bhils in Badi

Understanding the internal decision-making system among Bhils at Badi

Identifying prominent persons among Bhil families

14082020 PRA at Mama Vasti Badi Resource mapping at Badi and Mama Vasti

Filling of village profile form for Badi and Kawai

Discussion on Impact of the Project on grazing land

Understanding the internal decision-making system at Kawai

Mapping the list of tribal leadership in village

Introductory visit to Kawai and sharing of Project Disclosure Note

15082020 PRA at Kawai with Bhil households

Identification of village leaders for Bhil of Kawai

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village)

5211 Meeting with Sarpanch

ERM team met Sarpanch of Ladwan Gram Panchayat at his residence in Karwakhedi village It was

learnt that Ladwan GP had submitted a letter to District Collector earlier expressing their unwillingness

to give away the government land for Solar Park The key concerns of the villagers included

Whether government has gone ahead on issuing tender for the Solar Park site Especially

without replying to their concerns

Whether the land identified by GP for establishing a Gaushala (shelter for abandon and old cows)

is allotted to the proposed Solar Park

How would the Solar Park address long term un-employment and livelihood issue in the village

ERM informed on its intention to conduct FPIC process covering the ST families in Ladwan village

and some of these questions will be answered during a structured process of discussion

5212 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch

Ladwan consists of two revenue villages Karwakhedi and Ladwan The Gram Panchayat office is at

Ladwan and the current Sarpanch is from Karwakhedi The village is dominated by the Gujjar

Community that is the second largest community in terms of population Scheduled caste is the

largest social group of village comprised of Banchhda Charmkaar Balai and Beldar

A community meeting was held where the Talati (village land revenue officer who keeps the land

records) was present The Talati informed them on the status of land allocation for the Solar Park

ERM showed the map showing the optimised project boundary with khasra numbers of the allotted

land ERM team informed them on the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The community expressed their

key concern about the impact on their livestock which forms an integral part of their livelihood

Community Meeting at Ladwan Explaining potential impacts and benefits

5213 PRA Exercises with STs

ERM held a meeting at a settlement cluster (nai-vasti or new settlement) where STs and SCs lived A

general discussion on their village history and livelihood issues were discussed The participation

level in this discussion was good A cross section of people from various age-groups and gender

participated in this discussion and shared relevant information and expressed their opinion A

separate meeting was held with women too (see Photos below)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

According to the elders of the Bhils their generation is the 9th generation residing in Ladwan village

Prior to the three families (Gujjar Bhil and Charmakaar) establishing this village the village had

Muslim population in medieval times and they deserted the village as some epidemic broke out Three

people from Gujjar Schedule Caste and Bhil community first came from another village and settled in

the village As time passed other families from Banchada-Nat Sondhiya Balai and other started

settling in the village

The discussion also involved their religious and cultural practices and shrines There are three

Chabutarascaffold in the village which are their main place of worship There are two shrines ie

Gowal ka Devta close to the grazing lands and Nagdevta adjacent to the new colony outside the

village

A village corner meeting with men Participation of women in group discussion

The Shrine of Nag Devta at Ladwan Meeting with women at Ladwan

After the general PRA exercise involving a larger group a few active participants were picked up to

have more focused discussion on a few aspects Through participative discussions in these smaller

groups the social hierarchy and livelihood resources used by STs (and SCs living in the village) were

mapped

Creating the map of social hierarchy and influence The map drawn by community showing their

livelihood resources

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Social Groups and Influence Map

Most of the families in Ladwan have cattle that includes cow buffalo and goat Approximately 650 cattle that includes 450 cows and 200 buffalos exists in the village There are about 44 cows kept by Bhil households which is about 4 (on an average) cow per family Bhil households own about 100 goats which is about eight (on an average) goats per family Only one family (Chander Singh) owns two buffaloes Few individuals work as grazier for a cluster of houses and are paid 150 per cattle per month by the owners of cattlersquos The cattle owners hire women and youths for bringing fodder feeding and cleaning of cattle sheds collecting cow dung Payment is done on the monthly basis or the basis of hours of work The common land situated at the Right hand side of the main approach road to Ladwan village from Agar is used by the ST community for grazing their livestock ST families bring fodder firewood and fruits from the same portion This is the only place during rainy season where fodder is available for four months as rest of the area is under crops ST families cannot accesses any other commons which is encroached by the dominant familiescommunity According to the ST community if the village commons is taken by solar park then they do not have any option but to sell their livestock as they cannot afford to buy fodder for the livestock unlike the richer families in the village

Free grazing of a mixed herd of cattle and

buffaloes

A grazier bringing back cattle home at evening

5214 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 55 Names of Potential Representatives in Ladwan Village

Section of Representation Sl No Name of Representative Contact Number

Clan Representative 1 DevSingh-Kanhayialal

2 Mangushanker-Amar Singh

Gujjar

Sondhiya

Other OBC

SC

Bhil

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of Representation Sl No Name of Representative Contact Number

Youth Representatives 3 Babulal-Gangaram

4 Anandilal-Lalsingh

Traditional leader or Mukhia 5 DevSingh-Kanhayialal

522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village)

5221 Meeting with Sarpanch

The ERM team for this field visit was led by the IPs Expert comprised of four members including a

woman to facilitate participation of women The ERM team first met the Sarpanch of Parsula who was

not present in initial meeting held earlier in January 2020 The objective of this meeting with Sarpanch

was to share the project information with him and appraise him of the intention of the ERM team to

hold a meeting and participatory appraisals with ST families

5222 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch The Disclosure note had a map showing the

optimised project boundary with khasra numbers of the acquired land It included the key potential

environment and social impacts and what mitigation measures are proposed in ESIA report prepared

by ERM

5223 Joint Site-visit with Sarpanch and Other Leaders

Sarpanch wanted to visit the proposed project site along with the Patwari to explain him the project

boundary based on the land allotment records available with him ERM team facilitated a site visit by

Sarpanch Naib Sarpanch and Kotwar in presence of Patwari to explain him the proposed project

boundaries He shared his observations and concerns over the allocation for the Solar Park which is

used for grazing domestic livestock by villagers including ST households However he agreed to

facilitate an exclusive meeting with ST families next day

5224 PRA Exercises with STs

The Kotwar of Parsula village belongs to ST community He played a significant role in inviting the ST

families to participate in the meeting as well as shared crucial information on their social and cultural

aspects The meeting with ST families included approximately 40 people both men and women from

various age-groups ERM team showed them the map of Solar Park and explained them locations of

key components The community was divided into two to three groups to hold participatory

assessments

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments

Site visit with Sarpanch and explaining Project boundary

Participatory mapping of livelihood and natural resources within Project boundary

Community meeting with ST from Parsula village at Project site

Identification of a medicinal plant during site walk through

Facilitation of discussions with ST women from Parsula village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gwalon-Ka- Mandi within Solar Park Boundary

Grazing lands used by Bhils Mapping

Rajputs are the dominant caste in the village and a person from the Rajput community is the Patel

(traditional leader) of Parsula village Rajputs control all village resources including sources of drinking

water and the irrigation

There are four religious places (Devsthan) of Bhils in Parsula village At all these places the priest is

from the Bhil community One platform is situated within the land allocated to the Project which is

called Gwalon ka Mandi It is recognised by all the community as the women worship at this place to

have good rains for better crop yield or agriculture Community gatherings are organized at this place

on few occasions in the year

The Bhil households reported to own about 2-3 (maximum 10) cows on an average per family and

about 2-3 goats Some families manage to sell three to five goats in a year ₹3000 to ₹ 8000 per

goat depending on the quality of the goat Families who rear cows manage to sell about 4 to 6 litre of

milk ₹40 per litre to private dairy at Chouma village The Bhil community uses the lsquoBirdirsquo hillock

adjacent to the northern side of the Parsula village for grazing their livestock along with other

communities residing in the village

5225 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 56 Names of Potential Representatives in Parsula Village

Section of

Representation

Sl No Name of Representative Contact Number

ClanHouse Cluster

Representatives

1 Meherbaan Singh 7970187292

2 Goverdhan Sigh 8718098704

3 Rahul 9098266244

4 Maakan 6162432391

5 Dheeraj Singh 8871384373

6 Rambabu 9752340827

7 Ballu 9399263367

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Sl No Name of Representative Contact Number

8 Bheru 7725027924

Youth Representatives 9 Kamal 6267658647

10 Rajesh 9009278550

Woman Representatives 11 Payal NA

Traditional leader or

Mukhia

12 Bhawanlal NA

523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages)

5231 Meeting with Sarpanch

Gram Panchayat Badi has 3 villages namely Badi Kawai and Sucharoki The ERM team met

Sarpanch of Badi on 13th Aug 2020 and explained the intention of holding meetings with ST families to

inform them about the FPIC process He advised that we should brief the community members on the

current status of the project first As most of the ST families work as wage labour he advised the

team to come early in the morning He assured to inform the ST families and ask them to cooperate

5232 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for a sample

Hindi version and Annexure-D for sample English version) to Sarpanch and other people present in

the meeting The Disclosure note had a map showing the optimised project boundary with khasra

numbers of the acquired land It included the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The meeting was held at the

center of the village

The community believes that Badi village is 1150 years old calculated based on the date inscribed on

a stone slab in the oldest house in the village It is a common belief that Bhil community came to the

village along with Rajputs The living memory of the community members goes at least six

generations back Badi has ~300 households and there are ~80 ST households Rajputs are the most

dominant community in the village Brahmins and Gujjars also influence the decisions of the village

Gujjars are the largest social group of the village followed by Bhils There are around 30 Muslim

families and they also have some influence on decision-making of the village Apart from Gujjar there

are three other OBC groups that are Sutar Kumhar and Nath

The STs live in three separate habitation clusters The first is in the main village habitation second is

roughly around 05 kilometres away and is called Khari ka Jhopda The third is located further away

around 25 kilometres Both are not connected through roads and one has to walk to reach them The

third habitation is further away where a group of recent migrants form Jhabua (referred as Mama Bhils

by villagers) live and is referred as Mama Basti These Bhil families came here to work as labourers in

the stone mines almost two decades back

At Kawai a meeting with village elders was held prior to discussion with ST families Rajput Gujjar

and Dhakad are the three dominant castes There are only 17 Bhil households in Kawai village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village disclosure meeting at Badi Meeting village elders at Kawai

5233 Site-visit and Walkthrough

The ERM team walked through the site to visit different clusters of ST settlements in Badi and Kawai

Some of the photographs of the main village and satellite smaller settlements where STs live is

provided below

A typical ST house in Badi main settlement The Platform where STs hold their community

meeting

The Khari ka Jhopda Mama Vasti

5234 PRA Exercises with STs

As ST households were found scattered in several small satellite settlements multiple meetings were

held involving a small group of 7 to 12 participants Every ST settlement or cluster of households

usually has a platform under a tree which is used for community meetings and decision making This

space was used for holding PRA exercises Participants were engaged in conversation on their social

relationship and decision making process The understanding gained from these discussions were

then demonstrated in diagrams They were asked if the diagram portrays the right picture or not

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Livelihood and resource mapping in Badi A smaller cluster level meeting at Badi

The village livelihood resource mapping- Kawai Participatory process of understanding

livelihood resources in Kawai

The social relationship and influence map for

Kawai

The social relationship and influence map for

Badi

Similarly a map of the village and surrounding area was created using the information shared by

participants in these meetings They were asked to show where they carry out their livelihood

activities such as farming and grazing etc They were asked to indicate those areas and identify

natural resources or cultural sites located in those locations

Some of the information important for deciding on the FPIC approach collected from these participatory

exercises are as follows

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gram Panchayat Badi has total 16 wards out of which Badi has 9 wards Out of these 9 Wards 2

are reserved for the STs (Bhil)

There are about 250-300 cows kept by Bhil households which is about 4 (on an average) cow

per family Bhil households own about 450 goats which is about 5-6 (on an average) goats per

family Hence for ST families goat is a more popular livestock than cows

Almost all the houses have used locally available stone in constructing the walls of the houses

Pucca houses have used cement and sand as mortar whereas kuchha houses have used mud

The communities fear the loss of access to these stones will make house construction costly and

people who earn from stone quarrying will be impacted

The traditional leader (Mukhia) of Bhils decide on disputes related to marriage and other social

issues Women do not play an active role in decision-making process

Each household cluster of Bhil households have a number of cultural sites where local deities are

worshiped For example in Khera-ka Majra has four cultural sites Ghadiya Bheruji Bhut Maharaj

Bhut Babaji and Dungri Balaji Similarly there are a few cultural sites for goddesses like Leva ki

Mata and Dahana Mataji are located within the Project boundary In all these shrines the priests

belong to Bhil community

STs (Bhils) worship Devnarayan Khejara Mata and Sawria jee in Nimbaheda in Rajasthan The

religious leaders from these places are held with respect and are accepted as mediators or

decision makers for important matters

5235 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table 57

They will be considered for nomination to the representative committee and contacted for capacity

building on FPIC process

Table 57 Names of Potential Representatives in Badi and Kawai Village

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Clan Tola

Representative

Badi Main 1 Gheesalal-Nathulal 9575486482

2 Basantilal-Mangilal 7354345531

3 Motilal-Hiralal 9109003022

4 Nanalal-Ratanlal

Khaira Ka Jhopda 5 Lalu ndashRamlal

6 Tulsi-Devilal

7 Tawarlal-Vardaji

Kawai 9 Ramlal-Hajarilal

Ratanlal

Bherulal(Teacher)

Bherulal- Bhawani

Shantilal

Fargulal

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Youth

Representatives

Badi 10 Omkaar ndashKailaji 8718057436

11 Shyamlal-Mangali 9302086906

Mama Vasti 12 Dinesh ndashThawar Singh

13 Prakash-Ramesh

Woman

Representatives

Badi 14 Kesarbai-Devilal

15 Kavita-Dhanraj

Mama Vasti 16 Shanti-Ramesh

17 Mamta -Naklesh

Kawai 18 Sunder Bai-Bherulal

(Sudibai-Devilal Shimla bai-

Chandrulal LeelaBai-

Chittarmal Prem bai-Gopilal)

19 Kanyabai-Bhuvaniram

Traditional leader or

Mukhia

Badi 20 Bhawani-Laxmi

21 Amar singh-Ramlal 7354325923

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL

A key element in designing a FPIC Process is a mutually agreed and appropriate lsquoengagement and

consultation process14rsquo The lsquoFirst Draft FPIC Approach Paperrsquo was prepared and shared with RUMSL

for their review and comment A virtual workshop was held with RUMSL team on 27th Aug 2020 In

this workshop PS-7 requirements of ICP and FPIC in general and the specific FPIC process designed

for Solar Parks was presented and discussed After their feedbacks were incorporated the lsquoDraft

FPIC Approach Paperrsquo was shared with IFC-WB for review and comments

The objective of these internal discussions are to build an internal institutional consensus on the

appropriateness of the designed engagement and consultation process to comply with the

requirements under IFC PS-7 The subsequent steps for consultations with affected STs and finalizing

a mutually agreed lsquoDiscussion and Decision Making Frameworkrsquo is discussed in Section 81

14 GN-ampGN22 emphasizes to have a shared view of the FPIC process between Project proponent and affected IPs The Project

proponent and affected IPs to agree on an appropriate engagement and consultation process as early as possible and commensurate with the scale of impact and vulnerability of the communities

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INDEPENDENT FACILITATOR AGENCY

6 INDEPENDENT FACILITATOR AGENCY

61 Need for FPIC Process Facilitation Agency

An independent agencyexpert to facilitate the FPIC process is required for the following reasons

There is a strong likelihood of other dominant communities in the village intervening and trying to

influence the internal discussion and decision making by IP The presence of the FA will help

documenting such attempts of external intervention and the presence of the FA may act as

deterrence and help avoid such attempts to interfereinfluence the process

The IP representatives need an intensive process of orientation and capacity building It will be

more effective if this is conducted using the Malvi dialect instead of Hindi Therefore a good

community facilitator with familiarity on Malvi dialect will be helpful

The women and youth will need capacity building and facilitation of their internal discussions prior

to the community level meetings

The facilitation support to IP community in general and IP representatives in particular will require

proficiency in the local dialect Malvi and knowledge of local livelihoods and alternative options

Involvement of a local agencyexpert who also speaks the local dialect and with a good

understanding of local livelihoods (particularly grazing and livestock keeping) will demonstrate

fairness and transparency in the process

62 Screening of FPIC Process Facilitation Agency

ERM identified Institutions (Universities Government Departments and Research Institutes etc)

NGOs and INGOs located and active in Madhya Pradesh state After a preliminary screening selected

potential individualsorganizations were approached to find out their availability and willingness for the

assignment The criteria used for screening included qualification profile affiliation with the type of

institutionsorganizations nature of worksprojects completed working experience with IPsTribes in

Madhya Pradesh conducting meaningful consultation community mobilization and stakeholder

engagement familiarity with World Bank Group safeguardsrsquo policies and procedures comfort with

written and spoken English and local dialects etc The list of independent experts and organizations

screened for the role of facilitation agency is provided in Table 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

1 University of MP Bhopal

Department of Sociology

Dr Arvind Chauhan

Professoramp Head

7999345226

Two candidates with post-PhD and PhD

qualifications from Department of

Sociology interested in working but having

no experience were not considered

2 Dr BR Ambedkar

University MHOW MP

Professor RD Maurya

Former Dean amp Head

Department of Sociology

Old AB Road Gram

Dongargaon Dr

Ambedkar Nagar Madhya

Pradesh 453441

07324 274 377

The retired Professor amp Dean

recommended a college lecturer

belonging to BhilIP from Govt college

Neemuch may be considered as a

resource person in future as appropriate

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

3 Tribal Research and

Development Institute

Bhopal

Rita Singh

35 Shyamla Hills Rd

Bhopal Madhya Pradesh

0755-25570882551257

This institute of MP government is

involved in administration and research

aspects of tribes in Madhya Pradesh

There are full time staff and the person

required for the assignment is not

available However the Government

functionaries may be the resource persons

in sharing information and performing

advisory roles during implementation as

appropriate

4 Institute of Social

Sciences Ujjain

Dr Tapas Faculty

7342510978

Berasiya Rd Navi Bagh

Bhopal Madhya Pradesh

462038

0755 273 0946

The faculty suggested to contact the

Bhopal based NGO (Samarthan)

5 The Samarthan NGO

Bhopal

Shradha kumar

Bhopal Madhya Pradesh

shrdhasrigmailcom

9826912948

The Program Director reported no work

being undertaken by the NGO in proposed

project area and was reluctant to

undertake the assignment She however

mentioned to help coordinating with the

local NGO if available in Neemuch area

and has not responded so far

6 Xavier Institute of

Development and Action

and Studies Jabalpur

Dr Mehul Chauhan

Former Faculty

9977064882

The former faculty suggested two NGOs

(Concept Society and Gramodyog

Sansthan)

7 The Concept Society

Indore

Ms Hemal Kamat Director

9425350272

The candidate appeared for interview has

preferred to be engaged independently

instead of as a NGO

8 Gramodyog Sansthan

Mandala MP

Mr Hariom Shukla

Manager

7999064147

Even after agreeing no one finally

appeared for personal discussion and

interview

9 Balram Sewa Samaj

Neemuch

Mr Kamla Shankar

Manager

7838960968

The only NGO reported to working on

legal aspects in Neemuch area has not

expressed interest to work as FA

10 UNICEF office Bhopal Nagesh Patidar Project

Officer WASH

97525 98212

The staff of UNICEF suggested the name

of suitable candidates and all of them

have appeared for interview and have

expressed the interest in proposed project

work

11 Debate Trust (Referred

by Action Aid Bhopal

Amitav Singh and Leena

Singh

Debate Trust

Duplex C-22 Alkapuri

Near DRM Office

Habibganj Bhopal-462024

Action Aid India had prepared a brief

manual on FPIC (published in 3 Indian

Languages including Hindi in 2018)

reflecting the Indian context and its related

legal system The manual was intended to

help CSOs for their ready reference and

larger reach out Mr Narendra Sharma

who was based in Actionaidrsquos office at

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 65

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

0755-2985007 0755-

2417656 9425018144

9425004556

debateindiagmailcom

Bhopal played a key role in preparing the

Manual in Hindi version

Mr Narendra Sharma referred the NGO

Debate Trust who had experiences in

working with Panchayats

A screening using preferred criteria was undertaken of the shortlisted agencies and details are

available in Appendix-F None of these agenciesindividuals have worked for a FPIC process earlier

Hence an agency which was available and willing to undertake the activity was taken on a trial basis

to help in conducting PRA exercises and sample household survey required for preparation of IPP

63 Roles and Responsibility for FPIC Process Facilitation Agency

The role and responsibilities of the FPIC FA will be as follows

Table 62 Roles and Responsibilities of FPIC FA

Phase Responsibilities

I Formation of local committees with STs Representatives

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Hindi (Malwi dialect) Translation of TDPIPP and designing Information sharing tools

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs (particularly women and youth groups) and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation of the FPIC Process and Preparation of FPIC Process Report

Documents of outcome of the FPIC Process including FPIC AgreementMOUJoint Statement of PrinciplesAgreed Mitigation Plans etc

64 Terms of Reference for FPIC FA

The terms of reference for FPIC FA covering villages to be covered specific responsibilities

deliverables personnel requirement and organizational profile and experience is provided in

Appendix-G

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The PS-7 recommends to have a lsquoshared view15 of achieving ICP or FPICrsquo mutually agreed ldquoFPIC

Decision Process Framework Documentrdquo which is based on principles of Good Faith Negotiation

(GFN) The Designing a lsquodiscussion and decision making frameworkrsquo to achieve the FPIC as per GN

on PS-7 should considers the socio-political context within which the affected IPs households live as

well as impacts of the Project This section deals with key-elements considered for designing the

FPIC process as per requirements in IFC PS-7 and GN-7

71 Use of Language

The PS-7 emphasizes use of the IPs language in the FPIC process It was found that BhilsBhilala in

Ladwan and Parsula are relatively small community and they have been living with close socio-

cultural ties with other communities Hence they use Bhilli (their traditional language) very little The

proficiency of the current generation in the Bhilli vocabulary is too limited to use this in discussion of

the Project and its impact Hence their preference is the use of local (Malvi) dialect of Hindi which

they speak along with other communities in the village The Bhils in Badi and Kawai speak Malvi

dialect with some influence of Rajasthani language as it is at the border of Madhya Pradesh and

Rajasthan

In general the written material on the project is expected to be in Devnagri script using the vocabulary

consistent with Malvi dialect to the extent possible The FPIC FA will have community facilitator who

is conversant with Malvi and explain the written material using the conversational Malvi dialect

72 Use of Customary Decision Making Process and Traditional Leaders

The Bhils in Ladwan reported that they resolve disputes between families through intervention of the

elderly member of the familyclan (Baijwal and Dalodia) or go to other prominent people in the village

such as the priest in the local temple or the landlord on whose land they work The customary leader

of Bhils who covered a cluster (~10 to 12) of Bhil settlements existed earlier (at least 3 generations

back) and the current generation has not sought their help in dispute resolution in their living

memory

The BhilBhilala of Parsula belong to a number of clans (Dalodia Paretia Renkewal Vasunia etc)

and the elder member of the clan is usually approached to resolve any internal disputes There used

to be a collective council (panchayat) covering 5 to 10 villages but these have been non-functional

over the years They also approach the village Sarpanch and prominent personalities from other

communities in the village to resolve disputes involving land and livestock The matters related to land

are finally referred to the Tehsildar (land revenue officer) for resolution The local administration also

plays a significant role in resolving inter-community disputes

In Badi-Kawai they still have a traditional Mukhia (leader) who wields influence in community

matters Each Bhil village has an elder who is considered the mukhia or leader There are designated

places where elders hold community meetings to discuss conflicts among Bhils and matters related to

their social norms and customary laws governing marriage and inheritance etc If matters are not

resolved at the village level community elders (Biradari Panchayat) then the matter is escalated to a

forum of community elders from 5 or 10 villages with Bhil population The highest level of escalation in

the customary decision making system is to refer the matter to a Biradari Panchayat of community

elders from 25 Bhil villages16 These traditional leaders residing outside of the villages directly

impacted by the Project are accommodated as member of the proposed Mediation Committee

15 Refer GN-7 GN22 which mentions that lsquothis should ideally be done through a framework document or plan and client should

document support for the agreed process from the affected population 16 GN-7GN36(i) acknowledges that there may be circumstances where formal and informal leaders of the Indigenous Peoples

reside outside of the Projectrsquos area of influence

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

In general the affected IPs communities use familyclan elders to resolve minor disputes and involve

prominent people from other communities like the priest Sarpanch or other prominent personalities in

the village for resolving their conflicts The matters related to land is resolved by intervention from

local administration (Tehsildar and District Collector) If the matters are related to their customary laws

on marriage social relationship or inheritance the unresolved matters can be escalated to a council

that comprises of elders from 5 10 or 25 villages The traditional Biradari Panchayat has been losing

its power as the younger community members considers their decisions regressive and approach

Gram Panchayat leaders (Sarpanch) or take help from the Police and Court of law Considering the

preference of new generation to go to non-ST Gram Panchayat leaders and local administration they

are considered for the Mediation Committee

73 Promoting Participation of Women and Youths

Women specifically stated during consultation that they do not participate in decision making in their

traditional community meetings which are convened for resolving disputes Though the women come

to attend the community meetings they hardly ever participate and express their views

The BhilBhilala youths do not have traditional or customary forums at which they express their views

They accept the decisions taken in the family or at the clan-level However there are a few educated

young people in the village who have distinct views about their future

As free expression of the views by youths and women in BhilBhilala community meetings is not a

social norm separate meetings of these groups where they are able to express their views openly is

proposed as part of their internal decision making process The FPIC FA will facilitate these separate

meetings and keep external interventions in these meetings to the minimum The views expressed by

them in these meetings should be tabled in joint meetings of the community for consideration

74 Expectation on Material Information Prior to Discussion

It is understood from the preliminary round of discussions with ST communities that they expect the

following information to be shared with them

Details of the Project (lay-out plan) and the related activities that are going to be implemented

Schedule of starting of the possession of allotted government land and purchase of pattaprivate

land

Details of land khasra numbers proposed to be taken for the project

Amount of paymentcompensation consideration amount of the land and assets (including on the

government land) that will be taken by the project

What economic and other entitlements and benefits will be provided to the families dependent on

the allotted government land

If private land is purchased then they will lose the source of income generation or livelihood (as

they are hired for a year on contract basis daily wages take land on lease for cultivation and

take care of the cattlersquos etc) what will their entitlements (economic package) be

What options will the Government or the Solar Park Company provide as alternative to the

common grazing land as cattle and goat breeds they keep require free open grazing and not stall

feeding

What alternative livelihoods will be offered to those Bhil families who will be landless after losing

the governmentpatta land they currently use (though owned by others)

It was expressed that the Project proponents share many documents but the community wants

confirmation that the content is authentic Hence community expects that signed and verified

documents should be shared as part of the FPIC process which can be referred in case of conflict or

contradiction

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The relevant information is scattered in ESIA RAP and IPPIPDP A concise information disclosure

dossier will be prepared by ERM and used by FA during the FPIC process

75 Need for Capacity Building of IP Representatives

The interaction with potential ST representatives from these FPIC villages shows that convening a

community meeting and steering the internal discussion to reach consensus will be a new experience

for them Most of them are semi-literate and will face challenges in understanding the Project details

on their own such that they can then explain it to other community members Therefore following

activities are required

A capacity building workshop for the potential IP representatives to explain the Project its impact

and mitigation measures in the Draft IPPIPDPTDP in detail Although the RAP-LRP disclosure

will happen at the community level and ST families will attend those meetings the Draft

IPPIPDPTDP will also explain these entitlementsbenefits in simple language

Presence of experienced community meeting facilitators (from FPIC FA) for community meetings

will help these ST representatives to have focused discussions documentation of views

expressed and decisions made in those meetings

The women and youths usually do not participate in taking decisions on community issues

Hence the women and youth representatives need orientation through separate sessions

In addition to formal trainingorientation sessions the IP representatives may be taken on

exposure visits to nearby solar parks for improving their understanding

76 Need for a Mediation Mechanism

The ST Committee will hold meetings with the representatives of the Project (RUMSL) to discuss

relevant points and reach a mutual agreement While such discussions are likely to result in reaching

mutual agreements on a number of agenda items the discussions may hit dead-end on some issues

All such unresolved issues will be documented as a dissent note for their reconsideration in the second

round of meeting

If the discussion between ST Committee and the representatives of the Project on any significant issue

reaches a deadlock the matter will be referred to a mediation mechanism The mediation will be done

by a high level committee which will comprise of 4 members

An IP representative nominated from the larger tribal leadership of the area (from their customary

council of 10 or 25 villages) but not belonging to the Project village

The elected representative of the concerned Gram Panchayat or a person nominated from GP

and acceptable to the ST Committee

A senior officer from the District Tribal Welfare Department

District Collector or an officer nominated by them

This Mediation Committee will be constituted at the beginning of the FPIC process and will be activated

only in the case of a significant deadlock This Mediation Committee will be involved to read the Final

FPIC Agreement (even when no matter is referred to them for mediation) and satisfy themselves that it

reflects mutual agreements reached through a fair and credible process17

17 This is proposed in order to provide an external validation of a free and fair FPIC process prior to signing of the FPIC

Agreement

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

77 Following Principles of Good Faith Negotiation

Good faith negotiation generally involves 6 principles (see Table 71) The proposed FPIC Discussion

and Decision Making Framework (DDMF) adheres to these principles with slight modifications

keeping the public health concerns associated with the Covid-19 pandemic

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

1 Willingness to engage in

a process and availability

to meet at reasonable

times and frequency

Both parties need to agree to avoid large gatherings and un-necessary

physical meetings A mechanism for tele-consultations will be explored to

keep the physical meetings to the minimum

The internal discussion meetings of STs will be in smaller groups (in the

open rather than in closed rooms) to avoid large gatherings

There will be two meetings between RUMSL and ST Committee and

similarly number of proceedings by Mediation Committee will be limited

The meeting schedules will be finalized beforehand and Covid-19 public

health protocols as applicable at that time will be followed

2 Provision of information

necessary for informed

negotiation

The basic information on the Project and its potential environment and

social impacts are already provided in state language (Hindi)

The essential information requirement by ST Committee is identified and

these information will be provided in simple information dissemination

tools The FA will further explain them for their better understanding

3 Exploration of key issues

of importance

The likely key issues of importance are grazing and cultural sites located

within Solar Park boundary A small task-force comprising of

representatives of RUMSL as well as ST Committee will carry out a field

inspection prior to their first meeting The task force will observe Covid-

19 protocols issued by Government

4 Mutual acceptable

procedures for the

negotiation

The lsquoDiscussion and Decision Making Frameworkrsquo signed by both parties

will have a commitment to hold all meetings and activities complying the

Covid-19 protocols and advisory issued by Government

5 Willingness to change

initial position and modify

offers where possible

The first meeting will resolve issues where both parties can reach

agreement easily The positions of both parties on contentious issues will

be recorded during first meeting The FPIC FA will record the written

positions of both parties on these contentious issues and share with

them The FPIC FA and ERM will hold separate meetings with both ST

Committee and RUMSL Team after 15 days to understand any changes

in the stated position The FPIC FA and ERM will take a decision on

holding the second and final meeting on these contentious issues when

both parties agree to modify their offers and a meaningful discussion is

possible

6 Provision for sufficient

time for decision making

The ST Committee will benefit from the capacity building and assistance

through FPIC FA to conclude their internal decision making The first

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

meeting between ST Committee and RUMSL Team will be held after a

sufficient gap As the number of ST families participating in the FPIC

Process is small it is expected that it will not take them long to reach

internal consensus However STs will be encouraged to have more

meetings internally to be able to discuss within themselves

78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and Supportive Environment

In these FPIC villages the Project requires to achieve both ICP for mainstream communities and

FPIC for ST The existing and past relationship between RUMSL and affected communities plays a

significant role in FPIC process It is learnt from the news report as well as from consultations that

some villages (particularly Ladwan) have decided to protest against the Solar Park as loss of grazing

land is not acceptable to them The protesters had organised a demonstration and also submitted

letters to the District Collector regarding their objections Ladwan village has a strong network of

women self-help groups (SHGs) who are interested in a dairy development program Thus reduction

in grazing land is perceived by them to have a detrimental impact on their long term employment

opportunity and income generation These SHGs have members from SC OBC as well as ST

families

In other FPIC villages ie Parsula Badi and Kawai though there is a concern for loss of grazing

land yet opposition to Solar Parks is passive There are some specific interest groups among the

non-ST communities who would seek answers to their specific concerns For example in Parsula

village the non-ST families (both in Parsula as well as neighbouring villages) have informally

purchased the patta land Their main concern is whether and how they get the compensation for

these land parcels which will be paid to patta owners In Badi and Kawai the number of people who

have encroached on the government land is comparatively more Also there are few influential

people who earn from selling stones (the most popular building material in that area) extracted from

the allotted government land Thus a range of RAP-LRP issues are expected to crop up during

community engagement In all these villages the affected ST communities though would consider

the compensation and benefits offered to them yet it would be difficult for them to disregard the

collective decisions made by other communities in their village

Thus considering different interest groups involved existing social relationship influence of STs in

decision making it would be a challenge to hold a single engagement process18 for both STs and

mainstream communities Therefore we recommend a parallel or concurrent engagement process for

ST and mainstream (non-ST) communities The comparison of the ICP process for mainstream (non-

ST) and FPIC process for ST is provided in Table 72

18 GN-7 GN31 recommends a single engagement process complying to the higher standard (GFN and FPIC Agreement) where

a Project requires to achieve ICP for mainstream and FPIC for IP It reads ldquoSince the achievement of ICP and FPIC as separate processes with different groups within a community or between proximate communities may be difficult and in some cases be a cause of division within the community a single engagement process resulting in one agreement is generally recommended In such cases the process and agreement should reference the higher standard (ie GFN and agreement demonstrating FPIC) Whether the agreement entails different benefits for the differently affected groups will depend on the project context the Affected Communities and the nature of project impactsrdquo

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages

Aspect Engagement Process with non-ST

(ICP)

Engagement Process with ST (FPIC)

Management Plan ESMP + RAP-LRP IPPIPDPTDP

Representative

Body

Gram Panchayat (existing body) ST Committee (specifically constituted for

this process)

Provision of

information

necessary for

informed

negotiation

Executive summary of Draft ESMP

RAP-LRP in Hindi

Abridged Draft IPPIPDPTDP in Hindi (use

of Malwi vocabulary as much as possible)

Capacity building by FPIC FA

Help from FPIC FA to understand issues

Willingness to

engage in a

process and

availability to meet

at reasonable times

and frequency

One public meeting for receiving

feedback on Draft ESMP RAP-LRP

One round of internal discussion by STs

assisted by FPIC FA

Two rounds of meetings between RUMSL

and ST Committee

Mediation Committee meetings (if required)

Exploration of key

issues of

importance

Key issues covered in ESIA RAP-LRP

will be discussed

Key issues covered in Draft IPPIPDPTDP

will be discussed

Mutual acceptable

procedures for the

negotiation

Informal agreement A formal lsquoDiscussion and Decision Making

Framework Agreementrsquo is signed by both

parties

Willingness to

change initial

position and modify

offers where

possible

Demonstrated through incorporations of

feedbacks received from public

disclosure and consultation

Structured engagement process

documenting (signed by both parties at the

end of the meeting) points agreeddisagreed

and demonstrating the flexibility in their

respective positions

Provision for

sufficient time for

decision making

The time for public meeting for

receiving feedback will be decided in

consultation with Gram Panchayat

Sufficient time for capacity building by FPIC

FA internal discussions and gap between

first and second meeting between RUMSL

and ST Committee

Outcome The public meeting for receiving

feedback on Draft ESMP RAP-LRP is

held peacefully and satisfactory

explanationresponse to

feedbackqueries is provided

Incorporating response to all key issues

raised in public meeting in Final ESMP

RAP-LRP

The Final IPPIPDPTDP incorporates points

mutually agreed between RUMSL and ST

Committee

The FPIC Process Documentation Report-

(vetted by independent FPIC FA and

Mediation Committee) provides an overview

of the FPIC process

FPIC Agreement signed by RUMSL and ST

Committee

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Note The FPIC Process Documentation Report prepared by FA under ERM guidance will cover the

whole process (including all meetings by ST and Non-STs decisions key issues discussed etc)

The use of impacted land for free grazing is practiced by both ST and Non-ST communities The ESIA

and RAP-LRP also address impacts on grazing and have prepared a framework for Grazing Resource

Management Plan The engagement with non-ST population will highlight the mitigation measures

with regard to grazing issue (particularly Grazing Resource Management Plan) in ESIA and RAP-

LRP The feedback from non-ST population on mitigation of impact on grazing will be subsequently

incorporated into Grazing Resource Management Plan in particular and relevant sections in ESIA and

RAP-LRP The non-ST population will be clarified that TDP will have some additional benefit for STs

and therefore will be consulted separately

Thus the separate ST committees will not be perceived to take any decision that affects collective

interest of all villagers particularly the powerful non-ST communities The Gram Panchayat and

Sarpanch is provided a place in Mediation Committee and will be involved in resolving key-issues

referred to them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

81 Introduction

This lsquoDraft Discussion and Decision Making Framework19rsquo is prepared after field visits and

consultations with affected STs and a workshop with RUMSL (see Section-5 for details) This Draft

DDMF will be shared with ST Committees on behalf of RUMSL and after appropriate modifications

(without diluting the key-elements for compliance to PS-7 requirements) the final version will be

signed by representatives of both parties Section 814 provides subsequent steps in this regard

The three proposed solar parks are located in three different Districts and each one will have an

independent Solar Park Developer (SPD) or Concessionaire The impact of each solar park and the

social context of the affected STs also differ in these three locations Hence three ESIA reports as

well as three IPPIPDPTDP are prepared The Draft IPPIPDPTDP prepared for each Solar Park has

a specific package of benefits for the STs in FPIC villages This will be discussed during the proposed

FPIC process and the outcome of this process will be a written lsquoFPIC Agreementrsquo that adopts the Draft

IPPIPDPTDP and agrees to cooperate in its implementation

82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo

The subsequent steps for discussing this Draft Discussion and Decision Making Framework with STs

in the selected FPIC villages (grouped at each Solar Park level) is discussed in this section

821 Appointment of FPIC Facilitation Agency and Orientation

The requirement of a FPIC Facilitation Agency (FA) and their roles and responsibilities are discussed

in Section-6 above The FA will play a key role in forming the ST Committees (at each Solar Park

level) and informing them on their rights to FPIC their legal rights on natural resources prior to their

acceptance of this lsquoDraft Discussion and Decision Making Frameworkrsquo Hence one of the agencies

screened for this role will be appointed and brought on board

After on-boarding them ERM will carry out their orientation by holding a series of virtual workshops with

them The orientation program will include the following

The ICP and FPIC requirements as per IFC PS-7 and WB OP 410

Key findings of the ESIA-ESMP including Draft RAP-LRP

An overview of consultations in FPIC Villages

The Draft IPPIPDPTDPs

The Draft Discussion and Decision Making Framework

The Capacity Building of ST Committees on FPIC and their customary rights on natural

resources

822 Introducing FPIC FA to RUMSL and FPIC Villages

After the orientation of the FPIC FA the key persons will be introduced to the RUMSL team through a

physical meeting Subsequently a field trip will be planned to introduce the FPIC FA in FPIC villages

The RUMSL and ERM will introduce the FPIC FA to the contact persons from earlier field visits and

inform them about their role

19 The term lsquoengagementrsquo and lsquonegotiationrsquo was avoided to keep the language less confrontational and positive for both parties

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

823 Formation of ST Committees

ERM and FPIC FA will jointly discuss the structure and composition of the ST Committee at each

Solar Park20 with affected ST community As per suggestions from them ST Committees will be

formed and their nominations will be ratified through a group meeting21 The composition of the ST

Committee is described further in Section 8311 below

824 Capacity Building of ST Committees

The FPIC FA will discuss with the ST Committee on the time and venue for holding a capacity building

workshop The capacity building workshop will cover the following

The recognition of FPIC as their rights

Specific provisions of FPIC as per IFC PS-7 and WB OP 410

Applicable India Laws and recognition of their customary rights on natural resources

The Draft Discussion and Decision Making Framework (Draft DDMF)

The participation of RUMSL in this capacity building workshop will be optional and as per mutual

agreement by both parties The FPIC-FA will note down the suggestions of the ST Committee on the

Draft DDMF and share them with RUMSL

83 The Draft Discussion amp Decision Making Framework

The proposed discussion (engagement) and negotiation (decision making) framework will include 11

steps as illustrated in the Figure 81 below

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process

These steps are described in sections below

20 Agar and Shajapur Solar Park have only one FPIC village Hence the ST Committee will be selected from within the same

village Neemuch Solar Park has two FPIC village with several satellite ST habitations The ST Committee for Neemuch Solar Park will be larger to accommodate representation of different ST groups 21 The FPIC village level group meetings will be held keeping the Covid-19 public health guideline ERM will use professional

judgement on the acceptability of the selected committee for most ST households if the ratification of the ST Committee is not possible by a large public meeting

Formation of Committees

Acceptance of Draft Discussion and Decision Making

Framework

Disclosure of Draft IPP to ST Committee

Explaining Draft IPP to ST Committee

Internal Consultations by ST Committee

First RUMS and ST Committee Discussion

Second RUMSL and ST Committee Discussions

Reference to Mediation Committee

(if any)

Informing Community about Draft FPIC

Agreement

Final Community Meeting for Expression

of ConsentDissent

FPIC Agreement Signing

FPIC Process Documentation Report

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

831 Formation of Committees

The FPIC process will involve three committees for each Solar Park One representing the affected

ST community the other presenting the Project proponent (RUMSL) and the third a committee to

mediate between the two if the need be The composition of these committees are explained in sub-

sections below

8311 Formation of ST Committee for each Solar Park

Each Solar Park will have a ST Committee which includes representatives from all FPIC villages of

that Solar Park Each ST Committee will comprise of 7 to 13 members (or any odd number22) who

represent different sections of the ST community The principle for selecting the members of this ST

Committee will be as follows

One representative from each clanhabitation cluster (tola)

The clans which have more population may select 2 representatives

Two representatives from youths (18-25 years)

Two women representatives

One traditional leader (Mukhia) or ST community head from each FPIC village

Gowal (cow-herder) who takes othersrsquo cattle for grazing and earns livelihood from this

The ST Committee will select a chairperson to coordinate and conduct their internal meetings The

representative from the youth and women will hold separate group discussions within their sub-groups

and share their concerns preference and feedback The FPIC FA facilitating these internal meetings

will ensure that these points are tabled at the joint committee meetings The ST Committee will

prepare a list of households and the adult members (gt18 years) who will be part of the FPIC process

8312 Formation of RUMSL Teams

RUMSL will form three site level teams (one for each Solar Park) which will include the District

Renewable Energy Officer (DREO) of the concerned district and a staff member to assist him They

will report to RUMSL Managing Director (MD) The names and designation of the RUMSL Team are

as follows

Level Designation Name Contact Number

Head office MDCEO Deepak Saxena

Social Development

Specialist

TBD

Site Level (Agar) DREO Deepak Bulani +91-9229924836

DREO- Staff TBD

Site Level (Shajapur) DREO- Prakash Salunke +91- 9926440877

DREO- Staff

Site Level (Neemuch) DREO- Sohanlal Bajaj +91-9827222217

DREO- Staff Balaram Rathod +91-9827323612

22 To avoid a deadlock on decisions

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The site level RUMSL Team will attend the meetings with ST Committee discuss the issues raised by

them sign on minutes of meetings and report to MD where prior approval is necessary The MD or

his authorised representative will take part in important meetings including meetings with the

Mediation Committee if required

8313 Formation of Mediation Committee

There will be a Mediation Committee for each Solar Park The Mediation Committee will comprise of

three members which will be chaired by the District Collector

Member Selection Process

STs Representative from the

Area Biradari Panchayat

The ST Committee after internal discussion will nominate a prominent person of their community outside of their village who is accepted as a member of Biradari Panchayat or similar bodies

Member from Gram

Panchayat

The ST Committee will nominate a member (or ex-GP member) who is known for his role in resolving local disputes

District Tribal Welfare

Department

A senior Tribal Welfare officer will be nominated by District Collector or the Head of Department of Tribal Welfare

District Collector (or his

representative)

The District Collector of the district within which the particular solar

If District Collector is not available she should decide on who can act as his representative

The ERM FPIC-FA ST Committee and RUMSL Team jointly visit these MC members and brief them

on their role in FPIC Process The formation of the MC should be completed prior to the first meeting

between ST Committee and RUMSL Team

832 Acceptance of Draft Discussion and Decision Framework

After the capacity building of ST Committees FPIC FAERM will coordinate with both parties to fix a

date and time for a joint meeting to discuss the Draft Discussion and Decision Making Framework and

ratify it after making necessary modifications

The composition of the committees mentioned in Section 831 and the steps mentioned in Figure 81

will be explained to ST Committee during their capacity building process (described in Section 824)

A Hindi (with Malwi words used to the extent possible) version of the lsquoDraft Discussion and Decision

Frameworkrsquo (Section 83) will be provided to ST Committee during the capacity building Thus the

affected IPs will get adequate time to discuss and come prepared for any suggestions from their side

to this meeting The

Both parties will discuss on a code of conduct commit to follow this during their meetings The code of

conduct will be based on following principles of good faith negotiation

(i) both parties will be available to meet at reasonable time and frequency

(ii) both parties to share information23 necessary for informed negotiation

(iii) both parties will be willing to change initial position and modify offers where possible

23 The Project will disclose information as per Information Disclosure Plan discussed in Section 513 of the Draft

IPPIPDPTDP The disclosure will include at minimum (i) project boundary (ii) impacts of the project (iii) entitlements and other benefits The information will be shared in a culturally appropriate manner and in a form and language easily understandable to the ST communities The FPIC FA will help the ST community understand and process this information prior to the joint meetings with RUMSL

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

(iv) both parties will give each other reasonable time24 for decision making

(v) both parties will put their view peacefully and will not resort to violence and threat and

(vi) both parties will not engage in discussion when they are under influence of any intoxicants

Both parties will discuss and agree on the quorum required for their meetings and how proceedings of

their meetings will be documented Some suggestions for discussion in this regard are

(i) The quorum for the meeting to be physical presence (or virtual participation) of at least 75 of

the ST Committee and RUMSL Team The FPIC FA will check the quorum of the meeting prior

to starting the proceedings

(ii) The Documentation Assistant in FPIC FA will have the responsibility to record the audiovidoe

of the meeting proceedings

(iii) The FPIC FA will write down the key decisions taken during the discussion and the MoMs will

be read out prior to taking their signature

(iv) The FPIC FA will ensure that ST Committee and RUMSL Team understand the decisions made

If any party express that they need more time (to discuss internally or take approvals) such

information will be recorded

(v) The FPIC FA will also document any dissent expressed by any individual member while

supporting the collective decision of the group she represent in the MoM

The agreed Discussion and Decision Making Framework will have a target time-frameschedule for

completion of each step in the FPIC process Both parties will put their best efforts to complete the

process within t(his time-frame ERM will keep a track of the progress of FPIC process as per this

time-frame and help both parties to avoid unnecessary delays FA will draft the Agreement on Final

Discussion and Decision Making Framework (in Hindi) in consultation with RUMSL and ST

Committee

The final (after ratification) lsquoDiscussion and Decision-making Frameworkrsquo the FPIC-FA will hand over a

signed copy to both parties (ST Committee and RUMSL Team) A pamphlet or poster on accepted

code of conduct will be prepared and displayed at the meeting venue FPIC-FA will request all

members attending the meeting to follow these rules

833 Disclosure of Draft IPPIPDP to ST Committee

ERM will prepare Draft IPPIPDPTDP (in English) for each Solar Park A Summary Draft IPPIPDPTDP

will be translated to Hindi (with use of Malwi as much as possible) ERM will share following documents

to both parties as soon as they ratify the lsquoDiscussion and Decision Making Frameworkrsquo

The Draft IPPIPDPTDP (in English)

Summary Draft IPPIPDPTDP25 (in Hindi)

A simple 4-6 page brochure describing (illustrations where possible) the benefit package

proposed in Draft IPPIPDPTDP

The ST Committee members will be given one week to go through the documents shared with them

and fix a date to explain the Draft IPPIPDPTDP Report

The RUMSL will be provided soft copies of these documents to upload them in their web-site from

where external stakeholders can access these documents

24 The time provided should be adequate to read verify and consult (internally or any external expert on the subject matter)

The FPIC-FA will consult both parties to decide what is reasonable and acceptable to both 25 The Summary Draft IPPIPDPTDP will be 20-25 page It will follow the structure of the IPPIPDPTDP but provide a non-

technical description of the content for easy understanding by ST Committee

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

834 Explaining Draft IPPIPDPTDP to ST Committee

ERM and the FPIC-FA will organize a workshop for ST Committee of each Solar Park at a suitable

location on an agreed date (at least after 7 days from sharing of the documents with ST Committee

The workshop will explain the impacts of the Solar Park and the range of mitigation measures and

project benefits mentioned therein

The FPIC-FA will orient them on how to hold consultations with different sections within their

community and document their views The ST Committee will be provided adequate copies of the

brochure describing the benefit package project boundary maps (in large flex prints) to help them

explain the Solar Project to their community members and hold internal discussions

ERMFPIC-FA will consult ST Committee and RUMSL Team to fix the date for first meeting between

RUMSL and ST Committee

835 Internal Consultation Process by ST Committee

FPIC-FA will help each ST Committee to prepare a tentative schedule for internal discussions The

women representatives will hold meetings with women and youths representatives will hold meetings

among young people The FPIC-FA will make itself available to facilitate and document these internal

meetings

After a round of internal discussion of each sub-group the ST Committee will have the final meeting

to discuss the comments and concerns raised by different sub-groups of the community The ST

Committee will finalize a list of issuesdemands for further discussion with RUMSL The FPIC-FA

prepare the Agenda for First RUMSL-ST Committee Meeting and share it with RUMSL at least a week

before the meeting

The Agenda of the first RUMSL and ST Committee will be shared with the Mediation Committee to

keep them informed about the initiation of discussion between both parties

836 First RUMSL and ST Committee Meeting

The FPIC-FAERM will confirm the quorum prior to starting the proceedings The points mentioned in

the Agenda circulated earlier will be taken up for discussion The RUMSL Team will respond on these

pointsissues The ST Committee will consider these responses and decide if they are satisfied Once

the discussion is concluded the FPIC-FA will write-down the decision made with respect to the

specific Agenda items If any additional points to be discussed by any party those points will be

discussed at the end of the meeting with mutual agreement The FPIC-FA will document the

proceedings of the meeting as per the Discussion and Decision Making Framework (see section 832

above)

If all issues are resolved through discussion in this meeting then another round of discussion is not

required If there will be unresolved issue they will be included in the Agenda for the second meeting

While preparing the Agenda for the second meeting FPIC-FA will record the positions of both parties

with respect to these un-resolved issues The Agenda for the second meeting will be prepared listing

these unresolved issues with an appendix stating the views of each party on these unresolved

issues

RUMSL Team will brief about the mutual agreements and unresolved issues listed for second meeting

with their MD and seek approval if required The ST Committee will similarly brief their community

members on what is agreed after they return

The FPIC FA and ERM will prepare a Draft FPIC Agreement (in Hindi) reflecting the points of mutual

agreements and dissents if any The Draft FPIC Agreement will be shared with both parties

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

837 Second RUMS and STs Committee

The second and subsequent meetings between RUMS Team and IPs Committee will be held on

points where both parties do not agree and it requires further discussion ERMFPIC-FA will consult

both parties to reconsider their views and think about solutions acceptable to them Once ERMFPIC-

FA see both parties are prepared for the next round of discussion date for the second meeting will be

fixed

In this second round of meeting it is expected that a few more points will be mutually agreed The

Draft FPIC Agreement will be updated mentioning these points on which there are mutual agreement

and points of dissentdisagreements

Although it is expected to resolve all issues in two rounds of discussion there is a possibility of

additional rounds of discussion Both RUMSL and ST Committee will discuss on additional meetings

and decide a mutually agreed time-frame to complete the on-going discussion process

If both parties feel canrsquot be resolved through further discussions they will decide if the issue should be

referred to the Mediation Committee or set aside for discussion at a later date26 ERMFPIC-FA will

check if both parties are committed to accept the decision of the Mediation Committee and take the

final decision in consultation with both parties

838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee (MC)

If all issues are resolved through mutual discussion between the RUMSL Team and ST Committee

the Draft FPIC Agreement will be forwarded to MC of the respective Solar Park The MC will be then

requested to be available to chair over the final community meeting (see 8310) to measure the

consent expressed by affected ST in FPIC villages

The MC of the respective Solar Park will consider any issue which was not resolved by mutual

discussion between ST Committee and RUMSL Team and referred to it with an understanding that its

decision will be acceptable to both parties The FPIC-FAERM will hand over documentation of

previous discussion related to the issue and stated positions of both parties with respect to the matter

under consideration to MC

The MC will convene a meeting where it hears the arguments from both sides After considering views

on the matter from both sides MC will offer a solution for consideration If the MC thinks they need to

consult subject experts they will inform both parties and reconvene the meeting after they have

obtained views from such subject experts

Both parties if required will be given time (not more than a week) to consider the resolution offered by

the MC and come back with their final views

After considering the views of both parties on the solutions offered by it the MC will give its final

decision on the matter The MC will try making its decision on consensus and if it is not possible the

decision will be on majority Both parties will be bound by this final decision pronounced by MC The

final decision by MC will be incorporated into the Draft FPIC Agreement

839 Informing Community on Draft FPIC Agreement by ST Committee

The FPIC-FA will provide the Draft FPIC Agreement to the ST Committee The ST Committee

members will inform community members in smaller the sub-groups on the decisions taken during

FPIC discussion with RUMSL The ST Committee will explain their decisions on each issue and ask

26 Particularly matters which are uncertain or may happen in future These issues can be listed as unresolved issues to be

monitored by an agreed mechanism and discussed later

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

each adult member of the community to attend the final community meeting to voice their views and

acceptreject the Draft FPIC Agreement

8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and Ratification of Final IPP and FPIC Agreement

The ST Committee will take decision to hold the final community meeting to express their

consentdissent and fix a date after consulting RUMSL and MC members It will invite RUMS Team

and Mediation Committee to participate and witness the expression of consentdissent by affected

STs

FPIC-FA will ensure that all households in the community are informed about this meeting at least 7

days in advance FPIC-FA will prepare the list of all adult members with support from ST Committee

The IPs Committee will take the responsibility of the invitation and FPIC FA will monitor and document

the process The quorum for holding the final community meeting of affected ST families will be as

follows

Presence of at least 50 of the affected ST families in FPIC village

Presence of at least 60 of the total adult members of these affected ST families

Presence of at least 33 of the total adult women members

Presence of at least 33 of the total youths (between 18 and 25 years)

The FPIC-FA will coordinate with ST Committee members representing women and youth to ensure

that these quorum requirements are met during the final community meeting

The FPIC-FA will set-up a mechanism for recording the presence of eligible ST adult members and

hand over a copy of the Draft FPIC Agreement as they arrive at the meeting venue The Mediation

Committee will preside over this final community meeting The FPIC-FA will inform MC if quorum

requirements for the meeting is achieved After verifying the quorum required and the people

gathered for the meeting are from the affected ST households from FPIC villages the MC will initiate

the meeting proceeding

A representative from RUMSL Team will read out the agreed points mentioned in the Draft FPIC

Agreement and request for their acceptance A representative from the ST Committee will express

their views on points of mutual consensus as well as any unresolved issue that will be discussed and

resolved at a later stage of the project

The MC will then provide opportunities to ST community members present in the meeting to express

their views ST Committee will facilitate community members to express their opinions and

suggestions

The MC will consult with RUMSL and ST Committee if any additional points of agreement and dissent

to be incorporated in the Draft FPIC Agreement After confirming their final positions request the

community members present in the meeting to express their consentdissent and ratifyreject the Draft

FPIC Agreement

The consentdissent will be expressed by raising hands when the members of the Mediation

Committee puts the proposal of ratification to vote If more than 75 of the community members

attending this meeting votes in favour of the Draft FPIC Agreement it would be regarded as

expression of collective consent

The MC will inform the assembled community members about the outcome of the voting and if Draft

FPIC Agreement is ratified or rejected After the Draft FPIC Agreement is ratified by a collective

expression of consent the ST Committee members and RUMSL Team will sign the Final FPIC

Agreement This Agreement will be counter signed by members of the Mediation Committee as

witnesses

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The IPs community may be allowed to carry out any customary ritual on the day of the completion of

the FPIC process and express their support to the proposed Project This FPIC Agreement will be

taken up for implementation and a monitoring committee will oversee its effective implementation

8311 FPIC Process Documentation Report

The FPIC-FA will prepare a FPIC Process Documentation Report summarizing each stage of the

FPIC process It will hand-over all audio-visual records of the FPIC process The process document

report will cover all stages of the FPIC process documenting the following

Process of identification of STs ST representatives and decision-making authorities

Process of assessment of capacity of ST representatives to undertake good faith negotiations

Summary of any capacity building undertaken

Agreed engagement and negotiation framework (including the process undertaken to agree upon

the framework)

Summary of consultations meetings engagement undertaken as part of the FPIC process and

Opinion of FPIC-FA on the process and outcomes

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to

complete the FPIC process

84 Tentative Time-line

The Phase-I FPIC activities was scheduled to be held in Apr 2021 Due to the outbreak of second

wave of Covid-19 in Apr 2021 the field activities are suspended The decision to initiate these

activities will be taken once Covid-19 second wave gets over The schedule for Phase-II activities to

will be discussed with ST Committees of the three Solar Parks and will be decided accordingly As the

progress of FPIC process requires cooperation from affected ST community and the level of

cooperation varies in these three Solar Parks Hence the schedule for Phase-II FPIC activities will be

updated in discussion with respective ST Committees while finalizing the Discussion and Decision

Framework with them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Section Activity Month-1^ Month-2 Month-3 Month-4 Month-5

821 Appointment of FPIC FA and Orientation

822 Introducing FPIC-FA to RUMSL and FPIC Villages

823 Formation of ST Committees

824 Capacity building of ST Committees

8313 Formation of Mediation Committee

832 Acceptance of Draft DDMF

833 Disclosure of Draft IPPIPDPTDP to ST Committee

834 Explaining Draft IPPIPDPTDP to ST Committee

835 Internal Consultation Process by ST Committee

836 First RUMSL and ST Committee Meeting

837 Second RUMSL and ST Committee Meeting

838 Refer Unresolved Matters to MC

839 Inform Community about Draft FPIC Agreement

8310 Final Community Meeting for expression of ConsentDissent

8311 FPIC Process Document Report

Phase-I Activities

Phase-II Activities

Activities to start and complete

OptionalConditional Activity

^ The commencement of these activities will be determined once second wave of Covid-19 gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW

IN THE STATE OF MADHYA PRADESH INDIA

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

85 Responsibility Matrix

The FPIC process will require a collective effort and coordination between ERM RUMSL ST

Committee Mediation Committee and the FPIC FA The roles and responsibilities of these entities are

described in Section 82 and 83 above ERM will play an active role in coordination and provide

information required for a meaningful discussion The key responsibilities and accountabilities are

summarized below for clarity

Activity ERM FPIC-

FA

ST-

Committee

RUMSL-

F

RUMSL-

HO

Mediation

Committee

IFC-

WB

Formation of ST Committee S P P A

Formation of RUMS Team P A

Formation of Mediation

Committee

P P S P A P

Acceptance of Discussion

and Decision Making

Framework

S P P P A C C

Disclosure of Draft IPP to ST

Committee

P S S A C A

Explaining of Draft IPP to ST

Committee

P S

Internal consultation process

by ST Committee

S P P

First RUMSL and ST

Committee Meeting

S P P P A

Second RUMSL and ST

Committee Meeting

S P P P A

Mediation Committee

Proceedings

P P P S P P

Informing Community on Draft

FPIC Agreement by ST

Committee

S P P A

Final ST community meeting-

expression of consent

dissent

S P P P A A C

FPIC Process Documentation

Report

P P S S S S A

P= Primary Responsibility S= Secondary Responsibility C= Must be Consulted A= Approval

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

PROJECT INFORMATION DOCUMENT SHAJAPUR SOLAR PARK

Background

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) The primary objective of RUMSL

is to develop and facilitate the development of large-scale solar projects in the State of Madhya

Pradesh In line with the governmentrsquos ambition to boost solar power in State RUMSL is developing

Solar Park of capacity of 450 MW at Shajapur Madhya Pradesh

The World Bank had agreed to provide financial support for the Project International Finance

Corporation (IFC) is providing investment advisory services to Government of Madhya Pradesh to

develop the project on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards for the Project

Project Details

The proposed 450 MW Solar Park is located in two Tehsils ndashMoman Badodiya and Shajapur of

Shajapur District Out of 450 MW capacity 325 MW will be developed at Moman Badodiya tehsil

(termed as Unit 1 amp 2) and 125 MW will be developed at Shajapur tehsil (termed as Unit 3) of

Shajapur district Madhya Pradesh Almost 89 of the land area is Government land and remaining is

private land The salient feature of the Project are given below

Solar Park

The Solar Park will be developed as two units spread across these lands and the details of the same

ae captured in the table belowndash

Table A1 Details of Land parcels identified for the project Unit Number Area in ha Capacity Tehsil Villages

Unit 1 72048 220 MW Moman

Bododiya

Proposed to span 6 villages - Bijanakhedi

Burlay Chauma Dehripal Fawaka and

Parsula

Unit 2 105 MW Proposed to span Burlay Dhatrawada and

Jawadi whereas

Unit 3 26964 125 MW Shajapur

Tehsil

Hanoti Surajpur and Shajapur

Total 99012 450 MW

Land

Out of the total land requirement of 99012 hectares 86937 hectare is Government land 11074

hectare is private land and 1001 hectare is government patta land The Government land required for

the Solar Park which accounts for almost 89 of the total land required will be leased by the

government of Madhya Pradesh to SPPDs and the private land will be purchased from the land

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

owners for the development of Solar Park as per the prevailing laws and policies in the State of

Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP

Transmission Line

The transmission infrastructure is planned to evacuate power generated from the units to the STU

grid Each unit will have a 33200 kV internal pooling substation The internal pooling substation will

be connected to the proposed MPPTCL 220400 kV substation at Agar through 220 kV transmission

line For cost optimization the single circuit line from unit 1 will be laid till unit 2 towers and there on a

double line circuit of 220 kV shall be connected till the gird substation The Unit 3 internal pooling

substation shall be evacuated through single circuit 220 kV transmission line till the existing MPPTCL

220400 kV substation at Ujjain

The 33220 kV substation at each unit and 220 kV connectivity to the MPPTCL substation will be

developed by RUMSL MPPTCL will establish 220400 kV proposed grid substation at Agar in

connection with the existing 220400 kV MPPTCL substation at Ujjain Madhya Pradesh MPPTCL will

establish 220400 kV proposed grid substation at Agar along with the associated line till 400220 kV

Ujjain substation The solar project developer in the park shall be responsible for laying the 33 kV

cable and 33 kV ring unit as required at each unit to connect its plant to the 33220 kV internal pooling

substations

Road Infrastructure

The road infrastructure requirements is planned to access the Shajapur Solar Park Ms RUMSL shall

carry out road wideningrepairing of existing roads wherever required The road widening repairing of

existing roads is proposed for a length of 65 km which shall be undertaken by RUMSL The

development of internal roads within each unit shall be in the scope of individual Project Developer

Water Requirement

Water requirements for all purposes shall be met by digging bore-wells within each unit and shall be in

the scope of project developer Also the arrangement of construction water shall be in the scope of

contracting agencies and Solar Power Project developer

Common facilities planned

For 450 MW Shajapur solar park the utility area is proposed adjacent to the Unit 1 and Unit 3 -

33220 kV internal substation The other facilities such as RUMSL office fire-fighting equipment

telecommunication infrastructure medical dispensary etc will be located at the pooling substation

area

Project Implementation

The 450 MW Shajapur Solar Park will be implemented in a period of ~21 months

Operation and Maintenance

It is envisaged that different developers may occupy individual units and will be responsible for OampM

The operations and maintenance of common facilities provided like pooling substation intermediate

substations shall be undertaken by RUMSL

Environment and Social Impact Study and Management Plans

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Assessment (ESIA) of three solar parks including internal

evacuation infrastructure and associated transmission lines ESIA carried out for the project will meet

the requirements of Environment and Social Safeguard Policies and Standards of WB and IFC in

addition to applicable environmental and social regulations and policies in India and the State of

Madhya Pradesh

Based on final land footprint and georeferenced site boundaries of the project the ESIA will include a

Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) ERM will share relevant

information and consult with affected local communities to understand their viewsconcerns The

consultation will cover a wide range of people to take into account perspectives from different social

groups women and men young and old and seek their participation in mitigation of adverse impact

as well as enhancement of project benefits

As the project will impact a number of ST families ERM will assess impacts on them and prepare a

Tribal Development Plan (TDP) which will contain a package of proposed impact mitigation measures

and project benefits ERM will implement a Free Prior Informed Consent (FPIC) process covering

affected Scheduled Tribe population The negotiation process leading to obtain FPIC will be agreed

on with the affected ST communities

Free Prior Informed Consent (FPIC) Process for STs

The FPIC Process will be taken up for Surajpur Parsula and Jawadi villages of Shajapur Site for the impacts on tribal population in given villages on the land under traditional ownership and customary use The process will also involve any nomadic tribes who may have claims of using the project site for grazing their livestock and camping during their annual migration The FPIC process will be divided into two phases as described below

Phase What to Do When to Do

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Before inviting bids for solar parks by concessionaire

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Contacts

Further information and queries related to the project can be obtained from RUMSL site office in

Shajapur and head office at Bhopal The information is also available at website of RUMSL

(httpwwwrumslcom)

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

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wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT FPIC

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

NEEMUCH SOLAR PARK

Badi village Kawai Village

Mama Basti Badi village Bardawada village

AGAR SOLAR PARK

Ladwan village Bijnakhedi village

SHAJAPUR SOLAR PARK

Chauma village Parsula village

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

BACKGROUND

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) RUMSL is facilitating developing

Solar Park of capacity of 450 MW at Shajapur on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards (International Finance Corporation and World Bank) for the Project

Project Details The proposed 450 MW Solar Park is located in Moman Badodiya and South Shajapur tehsils of

Shajapur District collectively referred to as Shajapur Solar Park The Shajapur Solar Park will be

spread across 11 villages in Shajapur amp Moman Badodiya Tehsil of Shajapur District comprising the

villages of Burlay Jawadi and Dhatrawada (for Unit 6) Parsula Dehripal Bijnakhedi Fawaka

Chauma Burlay (for Unit 7) and Surajpur Lalpur and Hanoti (for Unit 8) The land required for 450

MW Solar Park including solar fields roads and transmission and distribution network is 9872

hectares The Shajapur Solar Park plot comprises of three non-contiguous land parcels

The solar park will have three (3) units It is understood that each unit will have a different developer

Unit 6 of 105 MW capacity to be developed on an area of 2461 hectares of Private and

Government land

Unit 7 of 220 MW capacity to be developed on an area of 4859 hectare and

Unit 8 of 125 MW capacity to be developed on an area of 2552 hectare

Land Requirement and Status The Solar Park will largely use GoMP land (approx 88) and the remaining land is either private

land or Patta land The Government land required for the Solar Park will be leased by the government

of Madhya Pradesh and the private land will be purchased from the land owners as per the prevailing

laws and policies in the State of Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th

November 2014 of Government of MP)

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

1 Burlay 237 00 64 00 00 00 301

2 Jawadi 322 00 20 00 00 00 342

3 Dhatrawada 1722 00 97 00 00 00 1819

Sub- Total (unit

6)

2281 00 181 00 00 00 2462

4 Parsula 1162 00 00 52 00 00 1214

5 Dehripal 1111 00 124 00 94 00 1329

6 Bijanakhedi 954 00 226 00 00 00 1180

7 Fawaka 171 00 02 00 00 00 173

8 Chouma 327 00 95 00 00 124 546

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

9 Burlay 417 00 00 00 00 00 417

Sub- Total (Unit

7)

4142 0 447 52 94 124 4859

10 Surajpur 227 07 182 00 00 00 416

11 Lalupura 497 08 00 00 00 00 505

12 Hanoti 1319 125 185 00 00 00 1629

Sub- Total (Unit

8)

2043 140 367 00 00 00 2551

Grand Total 8466 140 995 52 94 124 9872

Source Land Data provided by RUMSL 18th June 2020

Transmission Line Each Solar Park Unit will have 33220 kV substations and the power generated from each unit (Unit 6

7 and 8) will be pooled to the 220 kV switching pooling substation The utility area is proposed near

the internal pooling substation located at the Unit 6 and Unit 8

Road Infrastructure Access to Unit 6 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The existing village road has a width of ~4-5 meter and existing

State highways has a width of ~75 meter The road length of ~25 km will be strengthened and

repaired to suit the need during the construction phase

Access to Unit 7 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The road length of ~2 km will be strengthened and repaired to

suit the need during the development phase

Access to Unit 8 The Unit is connected with village road from Jhonkar to Hanoti at a distance 0f ~6

km from Jhonkar The existing road is a two-lane bituminous concrete road with width ~7-75 meters

and a new bituminous road with width ~75 meters and length ~500 meters is proposed to connect

33220 kV plant substation The road length of ~2 km will be strengthened and repaired to suit the

need during the development phase

Water Requirement The total requirement for water is estimated as 323 kL day Developers shall establish bore-wells per

block with required approvals and directions to meet their requirements The entire water supply

system including provision for bore-wells within individual blocks shall be in the scope of the Project

Developer The water requirement for the green belt is estimated to be 7000 litres per day

Common facilities planned The common facilities such as RUMSL office fire-fighting equipment telecommunication

infrastructure medical dispensary weather monitoring station etc will be located at the pooling

substation area located at the Unit 6 The operations and maintenance of common facilities provided

like pooling substation intermediate substations shall be undertaken by RUMSL Ms RUMSL will

establish two Weather Monitoring Station at internal pooling substation (at each unit)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Project Implementation

The 450 MW Shajapur Solar Park will be constructed a time frame of ~21 months with construction

proposed to started in November 2020

Project Impacts Benefits and Mitigation Measures

RUMSL will identify stakeholders and prepare a schedule for consulting them on a regular basis in

construction phase It will also establish a grievance redress mechanism through which local

community can register their grievances and seek redress to any adverse impacts on them The

project through its ESIA process has identified a range of potential impacts and has planned to

implement appropriate mitigation measures The key impactsbenefits and proposed mitigation

measures are discussed below for your knowledge and suggestions for making them more effective

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D1 Moman Badodiya Unit 6

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D2 Moman Badodiya Unit 7

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D3 South Shajapur Unit 8

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact from Land Acquisition

Type of land impacted How Impacts will be addressed

Private Land (Purchased through MP

Mutual Consent Policy 2014

Adequate compensation at twice the value of land and assets as

per MP Mutual Consent Policy 2014

Benefits of Resettlement Action Plan-Livelihoods restoration Plan

Preference to households (rendered landless or with sub-optimal

holdings) of the families post selling land to the project for

employment opportunitiessmall contracts in the

Constructionoperation phase

Pattta Land (Negotiated purchase

through MP Mutual Consent Policy)

Patta is being treated at par with ownership for the land

procurement process and would have same benefits as of private

land owners

Government Land Used for Grazing

easements cultural heritage sites

water sources fuel wood collection and

collection of other resources

Provision for alternate grazing land for cattle near the project

village or confirmation of adequacy of remaining grazing land

Development of community fodder lots in available unoccupied

government land may be explored and covered in Resettlement

Action Plan

Provision of easements shall be maintained in order to not sever

the access to CPRs for the community

Government Land Informally

occupied Capturedencroached for

agriculture or grazing prohibiting use

by other people

RUMSL shall serve a three months advance notice to the project

affected persons (PAPs) to harvest standing crops andor avoid

growing fresh crops

In case the advance notice is not given RUMSL shall pay

compensation for crops at full replacement cost

ImpactsBenefits in Construction Phase

Impact Mitigation Measures

Temporary occupation of land

for construction phase activities

such as Labour Camps Safety

Setbacks Storage areas

Parking areas Other

construction related temporary

land requirements etc

Adequate lease rents to the land owners

Restoration of land to its original state or better at the time of handing it

back to the owners

Compensation for the loss of livelihoods to the users of the land required

for temporary use as this will temporarily economically displace them

Community Health and Safety

including accident risks for

domestic animals

The Contractor shall prepare Traffic Management Plan Workers Code of

Conduct and Health and Safety Plan and implement it after approval of

RUMSL

Stress on Community resources

- Water and Roads

There will be a worker Code of Conduct defined by RUMSL that prevents

workers and contractors from using the local resources like water forest

The contractor shall be asked to use Tanker water supply during the

summer months which are dry months in which water scarcity issues are

reported by the community

Noise Nuisance and Dust Install enclosures around construction area in order to reduce the extent

of noise and dust

Limit construction related activities to day time

Employment and

entrepreneurship opportunities

during construction

The sourcing of local labour wherever possible will be obligatory for the

Solar Project Developers and sub-contractors

Employment of members of SC-STs and vulnerable households will be

at a minimum of 30 of total workers or person-days of employment

Engagement of local vendors to the extent possible for the goods and

services required for the project during construction phase

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact Mitigation Measures

The RUMSL will establish a mechanism to audit subcontractors and

suppliers with respect to compliance of utilizing local labour and

resources

Impacts in Operation Phase

Impact Mitigation Measures

Community Health and

Safety

Community engagement and sensitization sessions should be re-organised at

the beginning of Operations phase in order to mention about the new

developments in the area and provide an understanding of the precautions to

be taken for safety

Impact on Employment RUMSL shall ensure that the Solar project developers (SPDs) advertise the

roles of Technical staff required during operations phases in the local

newspapers to enable hiring of competent people from nearby areas to the

extent feasible

Preference shall be given (to the extent feasible) to hire competent members

from PAHs for semi-skilled jobs like housekeeping or Security Guards

Impacts on Vulnerable Sections Women and Scheduled Tribes

Impact Mitigation Measures

Impacts on Indigenous

Communities Vulnerable

Groups

To Prepare an Indigenous Peoples PlanTribal Development Plan with special

benefits for Scheduled Tribes

Recognizing their right to Free Prior Informed Consent process and its

implementation

As part of the stakeholder engagement ensure adequate representation and

participation of the Scheduled Tribes

Impact on Women A Gender Action Plan will be prepared for the Project to assess and mitigate

gender specific impacts

Ensure that the employment of women from vulnerable households is

prioritised for the project

Efforts are made to support development of women owned enterprises in the

area through the LRP from where procurement for project related may be

prioritised

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

Page 1

शाजापर सोलर पारक रा पररयोजना वििरण दसतािज़

पषठभवि

नवीन और नवीकरणीय ऊरजा मतरजलय क सहयोग स मधय परदश सरकार मधय परदश म जमीनी गरिड स रडी

सौर ऊजाा पररयोजना का गरिकगरसत कर रही ह रीिा अलटर ा मगा सोलर गरलगरमटड (RUMSL) का एक

सािाजगरनक उपकरम िरा 2015 म सथागरपत हआ ह यह उपकरम सोलर एनरी कारपोरशन आफ इगरडया गरलगरमटड

(SECI) तथा मधयपरदश ऊजाा गरिकास गरनगम गरलगरमटड (MPUVNL) क साथ सयकत उपकरम क रप म सथागरपत

हआ ह शाजापर सोलर पाका की कल कषमता 450 मगा िाट होगी और इस सौर ऊजाा पाका को गरनजी -

सािाजगरनक साझदारी क तहत गरनमााण गरकया जाना परसतजववत ह

रीवज अलटर ज मगज सोलर वलवमटड (RUMSL) दवजरज ईआरएम इवडयज परजइवट वलवमटड (ERM) को अतरााषटर ीय

मानको (अतरााषटर ीय गरितत वनगम एि गरिशवबक) क अनसजर सौर पजका क पयजावरणीय और सजमजवरक परभजव

मलजकन (ESIA) क सजथ सजथ पनगरिासथापन कजया योरनज (RAP) और सवततर रप स समदाय की पिा

सगरित सहमगरत (FPIC) परवियज क वलए अनबगरित गरकया गया ह

पररयोजना री परिख जानरारी

450 मगा िाट का परसतागरित सोलर पाका शाजापर गरजल क मोहन बड़ोगरडया और शाजापर तहसील क अतगात

शाजापर सोलर पाका क नाम स जाना जाएगा यह सौर ऊजाा पाका 11 गाािो क कषतर म बनगा यह 11 गााि इस

परकार ह बल जिादी और ितिादा (इकाई 6) पारसला दहरीपल बीजनखड़ी फिाका िौमा बल (इकाई

7) और सरजपर लालपर तथा हनोती (इकाई 8)

इस 450 मगा िाट सोलर पाका हत कल 9872 हकटर जमीन की आियशकता होगी गरजसम सोलर फीलड

सड़क टर ासगरमशन एि गरितरण नटिका शागरमल होगा पाका तीन अलग इकाईयो म गरिकगरसत होगा ऐसा

अनमान ह गरक परतयक इकाई का गरनमााण अलग-अलग गरनमााताओ दवारा गरकया जाएगा

105 मगा िाट कषमता िाली इकाई 62461 हकटर कषतर पर सरकारी तथा गरनजी जमीन पर गरिकगरसत

होगी

220 मगा िाट कषमता िाली इकाई 74859 हकटर कषतर पर गरिकगरसत होगी तथा

125 मगा िाट कषमता िाली इकाई 82552 हकटर कषतर पर गरिकगरसत होगी

Page 2

जिीन री सथिवि एि अविगरहण

सौर ऊजाा पजका लगभग 88 मधय परदश की सरकारी भवम कज उपयोग करगज और शष भवम यज तो वनरी यज

पटटज भवम रहगी सोलर पजका क वलए आवशयक रजरसव भवम मधय परदश सरकजर दवजरज पटट पर दी रजएगी और

वनरी भवम मधय परदश रजजय म परचवलत कजननो और नीवतयो क अनसजर भवम मजवलको स खरीदी रजएगी

(Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP)

कर

गााि

रा

नाि

सरर

ारी

जि

ीन आ

िवि

ि

(NR

ED

) ह

कटर

सरर

ारी

जि

ीन व

िसि

ि प

आि

विि

नह

हकट

वनज

ी ज

िीन

कटर

पटट

री

जि

ीन

हकट

उदय

ावन

री

हकट

िौस

िी

िाल

ाब ह

कटर

रल

जि

ीन (

सरर

ारी

जि

ीन +

वनज

ी ज

िीन

)

हकट

1 बल 237 00 64 00 00 00 301

2 जािादी 322 00 20 00 00 00 342

3 ितरािदा 1722 00 97 00 00 00 1819

योग (इराई 6 ) 2281 00 181 00 00 00 2462

4 परसला 1162 00 00 52 00 00 1214

5 दहरीपल 1111 00 124 00 94 00 1329

6 बीजनखड़ी 954 00 226 00 00 00 1180

7 फािक 171 00 02 00 00 00 173

8 िौमा 327 00 95 00 00 124 546

9 बल 417 00 00 00 00 00 417

योग (इराई 7) 4142 0 447 52 94 124 4859

10 सरजपर 227 07 182 00 00 00 416

11 लालपर 497 08 00 00 00 00 505

12 हनोती 1319 125 185 00 00 00 1629

योग (इराई 8) 2043 140 367 00 00 00 2551

Page 3

रल 8466 140 995 52 94 124 9872

सदभक रीिा अलटर ा मगा सोलर गरलगरमटड दवारा गरदया गया जमीन का डाटा 18 जन 2020

िासविशन लाइन

परतयक सोलर पाका इकाई क 33220 किी क सब सटशन होग तथा परतयक इकाई (6 7 8) स 220 गरकलो

िाट की ऊजाा सब सटशन एकतर गरकया जाएगा आतररक पगरलग सब सटशन इकाई 6 और 8 क समीम

सथागरपत करना परसतागरित ह

सड़र वनिाकण

इराई 6 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रोवक आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

गााि क रासत की िौड़ाई लगभग 4-5 मीटर तथा राजयमगा की िौड़ाई 75 मीटर ह सौर ऊजाा पाका क

गरनमााण हत 25 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 7 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रो की आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 8 िर पहाि

इकाई 8 िाम झोकर स 6 गरकलोमीटर दर िाम झोकर स िाम गरहनोती को जान िाली सड़क स जड़ी ह यह

रासता डबल लन डामर रासता ह गरजसकी लबाई 7-75 मीटर ह एक नई डामर रोड गरजसकी लबाई 500

मीटर तथा िौड़ाई 75 मीटर ह और जो 33220 किी क सब सटशन को जोड़न क गरलए बनाई जाना

परसतागरित ह सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया

जाएगा

पानी री आिशयरिा

यह अनमान ह की परगरत गरदन लगभग 323 गरकलो लीटर पानी आिशयकता होगी पानी की पगरता क गरलए ठकदार

दवारा परगरत बलॉक बोररग की रजएगी सौर ऊजाा पाका क गरनमााण क दौरान परतयक बलॉक क पानी की सपलाइ

की वयिसथा का परा खाका गरजसम बोररग करना भी शागरमल ह ठकदार अपन परसताि म द ग हररत पटटी क

गरलए परगरत गरदन अदाजन कल 700 लीटर पानी की आियशकता होगी

Page 4

सािानय सवििाओ री उपलबधिा

RUMSL का ऑगरफस अगरि शमन सटशन टली कमयगरनकशन (फोन) गरिगरकतसालय गरडसपनसरी मौसम की

जानकारी सटशन इतयागरद इकाई 6 क समीप पलीग सब सटशन पर सथागरपत हाागी पगरलग सबसटशन तथा

मधयमिती सबसटशन गरक तमाम सगरििाओ का सिालन एि दखरख RUMSL दवारा गरकया जाएगा RUMSL

आतररक पलीग सटशन पर दो मौसम अनशरिण सटशन सथागरपत करगा

पररयोजना रा वकरयानवयन

450 मगा िाट का शाजापर सोलर पाका का गरनमााण निमबर 2020 स शरिात कर अगल 21 महीनो म परा

होना अपगरकषत ह

पररयोजना र परभाि लाभ ििा शिन उपाय

सौर ऊजाा पाका क गरनमााण क दौरान RUMSL गरिगरभनन गरहतसािको की पहिान कर उनस गरनयगरमत ििाा और

सलाह मशिरा करतज रहगज पाका गरनमााण क दौरान िामीणो की गरशकायतो को समझन एि उनह दर करन क

गरलए गरशकायत गरनिारण ततर की वयिसथा RUMSL करगा तागरक गरशकायतो का गरनपटारा शीघर हो सक और

लोगो पर हो रह नकारातमक परभाि को दर कर सक पररयोजना दवारा ESIA की परगरकरया क माधयम स सभागरित

परभािो को गरिनहनहतकर उनक गरनपटार हत उगरित और परभकारी उपाय करगा अपगरकषत परभािलाभ और शमन

क उपाय गरनमन गरलनहखत ह तागरक आपक सझािो क आिार पर उनह और परभािी बनाया जा सक

Page 5

नकशा 1 िोहन बदोवदया इराई 6

Page 6

नकशा 2 िोहन बदोवदया इराई 7

Page 7

नकशा 3 शाजापर इराई 8

Page 8

जिीन अविगरहण रा परभाि

परभाविि जिीन रा पररार परभाि रा वनिारण

वनजी जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत 2014 क तहत

खरीदी गरनजी जमीन)

मधय परदश आपसी सहमगरत भगरम करय नीगरत 2014 क तहत

पयाापत मआिजा जमीन या सपगरत क मलय स दगना

पनिासन कायायोजना ndash आजीगरिका पनजीिन योजना स लाभ

पररयोजना हत अगरििहण क बाद पररिार गरजनक पास बहत ही

कम जमीन बिी ह या भगरमहीन पररिारो को पराथगरमकता

गरनमााण क दौरान गरकरयानवयन क समय उनक गरलए काम क

अिसर छोट काया अनबि काटर कट म पराथगरमकता दना

पटटिाली जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत2014 क तहत

तय कर खरीदी गए जमीन)

जमीन क अगरििहण क दौरान पटटा िारको को गरनजी मागरलक की

तरह समझत हए उनक गरलए गरनिााररत सार फायद दना

सररारी जिीन िरनोई सासकगरतक

िरोहर जल शरोत जलाऊ लकड़ी

सिहण गरनसतार की जमीन

अनयससािनो का सिहण क उपयोग म

आन िाली जमीन

पररयोजना क समीप क गााि म िरनोई क गरलए जमीन की

िकनहिक वयिसथा करिाना या अगरििहण क बाद शर जमीन म

गााि क गरलए पयाापत िरनोई की जमीन सगरनगरित करना

खाली पड़ी सरकारी जमीन पर सामदागरयक िारागाह की खप

गरिकगरसत करन हत पनिासनकाया योजना म सभािना खोजना

समदाय क सामदागरयक ससािनो तक पहाि बनी रह उस सगरनगरित

करन क गरलए भारतीय सख भोग अगरिगरनयम 1882 क पराििानो

का पालन गरकया जाएगा

सररारी जिीन अिि कबजिाली

जमीन खती या िराई क गरलए कबजा

अगरतकरमण गरकया गया हो लोगो दवारा

सािाजगरनक उपयोग बागरित गरकया गया

हो

RUMSL पररयोजना स परभागरित लोगो को तीन महीन का पिा

नोगरटस दगा तागरक ि अपनी लगी हई फसल काट सक या नई

फसल न बोए

यगरद गरकसी कारण िश पिा नोगरटस नही दी गयी तो RUMSL परी

फसल की कीमत मआिज क तौर पर द ग

Page 9

वनिाकण र दौरान परभािफायद

परभाि शिनवनपिार र उपाय

गरनमााण क िरण क दौरान गरिगरभनन गगरतगरिगरियो

क गरलए जस मजदर रहिास (क प) सरकषा

वयिसथा भडारण वयिसथा िाहन पागरकि ग कषतर

तथा गरनमााण सबिी अनय जमीन की असथायी

आिशयकता पड़ना आगरद

जमीन मागरलको को पयाापत लीजगरकराए की वयिसथा करना

जमीन मागरलको को उनकी जमीन लौटन क समय वयिनहसथत

रप स सिार कर परानी अिसथा या उसस भी अचछी करक

लौटाना

जमीन मागरलको को उनक जमीन स असथायी रप स हटान एि

उनकी आजीगरिका क नकसान क एिज म मआिजा दना

सामदागरयक सवासथय एि सरकषा तथा घरल

उपयोगी पशओ की दघाटनाका जोनहखम

ठकदार सभी की सरकषा क गरकए आिागमन परबिन पलान

तयार कर ग मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयिहार क गरनयम) और सवासथय एि सरकषा की योजना

बनाकर RUMSL स अनमोदन क पिात ही गरकरयानवयन कर ग

सामदागरयक ससािनो पर दबाि ndash पानी एि

सड़क

RUMSL दवारा मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयहार क गरनयम) गरनिााररत गरकए जाएग गरजसस

कमािारी तथा ठकदार सथानीय ससािनो जस पानी जगल

आगरद का नयायोगरित उपयोग कर पाएग

गगरमायो क समय पानी की गरकललत को दखत हए ठकदार को

यह गरनदश होग की िह पानी क टकर स पानी गरक पगरता कर

शोर बािा एि िल गरनमााण सथल पर दीिार लगानासथागरपत करना तागरक शोर एि

िल कम फल

गरनमााण काया किल गरदन क समय ही करनागरनमााण काया रात

क समय परगरतबगरित करना

गरनमााण क दौरान रोजगार तथा वयिसाय क

अिसर

यथासभि सोलर पाका गरिकगरसत कतााओ तथा ठकदारो आगरद

क गरलए सथानीय लोगो एिम मजदरो को काया दन की

अगरनिायाता होगी

कल रोजगार गरदिस या कल कमािाररयो म कम स कम 30

परगरतशत मजदरकमािारी अनसगरित जागरत - जनजागरत या िगरित

पररिार स होग

सोलर पररयोजना गरनमााण क समय गरकसी भी मालसामिी या

सिा की जररत यथासभि सथानीय गरिकरताओ क माधयम स

की जाएगी

RUMSL गरनमााण क दौरान एक अककषण ततर की वयिसथा

करगा तागरक ठकदार गरिकरता सिा परदाता सथानीय ससािनो

तथा मजदरो का यथोगरित उपयोग कर सक

Page 10

वकरयानवयन र सिय परभाि

परभाि शिन वनपिार र उपाय

सामदागरयक सवासथय एि

सरकषा

सोलर पाका क गरनमााण की परगरकरया क दौरान गरनमााण स होन िाल नए

बदलाि क सबि म समदाय को सिदनशील बनाना हत बठको का

आयोजन करना और सरकषा क गरलए एहगरतयात बरतन हत समय समय पर

गरििार गरिमशा और ििााए करना

रोजगार पर परभाि RUMSL यह सगरनगरित करगा की पररयोजना क गरनमााण क दौरान

तकनीकी कमािाररयो की भती का गरिजञापन सथानीय अखबारो म छप

तागरक योगय सथानीय लोगो को भती गरकया जा सक

अिा कौशल कषमता िाल काम जस कायाालय की दखरख सरकषा गाडा

आगरद पररयोजना स परभागरित पररिारो को पराथगरमकता क आिार पर

गरदय जाए

िविि िगक पर परभाि िवहलाए एि अनसविि जनजावि र सदभक ि

परभाि शिन वनपिार र उपाय

अनसगरित जनजागरत एि

िगरित िगा पर परभाि

अनसगरित जनजागरत समदाय क लाभ को धयान म रखत हए मलगरनिासी

समदाय क गरलए योजना आगरदिासी गरिकास की योजना बनाई जाएगी

सवततर पिा सगरित सहमगरत क आिार पर FPIC की परगरकरया का

गरकरयानवयिन गरकया जाएगा

गरिगरभनन गरहतसािको को शागरमल करत समय अनसगरित जनजागरत समदाय

का पणा रप स परगरतगरनगरितव और भागीदारी को सगरनगरित गरकया जाएगा

मवहलजओ पर परभाि जडर एकशन पलान का गरनमााण गरकया जाएगा तागरक पररयोजना की िजह

स जडर गरिगरशषट परभािो का आकलन कर उनह गरनपटा या कम करन का

परयास हो सक

पररयोजना म िगरित िगा की मगरहलाओ को रोजगार पराथगरमकता गरमल यह

सगरनगरित गरकया जाएगा

पररयोजना कषतर म मगरहला उदयमी गरिकरता सिा परदाताओ को सहयोग

करन क परयास गरकए जायग गरजसस पररयोजना म काम आन सामिी

समान की खरीदी उनस की जा सक

Page 11

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE FPIC FACILITATOR

Page 12

Screening of Facilitating AgencyIndividual Expert for FPIC

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to

undertake an Environmental and Social Impact Assessment (ESIA) of three solar parks

including internal evacuation infrastructure and associated transmission lines of aggregate

capacity of 1500 MW in the Neemuch Agar and Shajapur Districts of Madhya Pradesh India

(hereinafter referred to as the lsquoProjectrsquo) one of the key tasks as part of this assignment is to

secure Free Prior Informed Consent in keeping with the provisions of IFC PS 7 For this

purpose ERM has undertaken the task of identifying a Facilitation AgencyIndividual (FA) to

assist with the FPIC process This document presents the results of the screening and

shortlisting process for the FPIC FA

Approach and Methodology

The approach and methodology followed for shortlisting of FPIC FAs is presented below

1 Two stage approach was followed for the selection of FPIC Facilitation

AgencyIndividual Initially desk research was carried out to identify Institutions (Universities

Government Departments and Research Institutes etc) NGOs and INGOs located in

Madhya Pradesh state In parallel the ERM team also identified the criterion which will be

used to shortlist the potential Facilitating Agencies The criteria used for screening included

qualification profile affiliation with the type of institutionsorganizations nature of

worksprojects completed working experience with Bhils in MP experience in natural

resource management and rural livelihoods conducting meaningful consultation community

mobilization and stakeholder engagement familiarity with World Bank Group safeguardsrsquo

policies and procedures comfort with written and spoken English and local dialects etc

2 In the second stage the potential candidates from these institutions were individually

approached to further assess their suitability and find out their availability for the assignment

Convenient date and time for the personal discussion and interview with them was sought

Accordingly the ERM team organized interview with the available candidates at Bhopal

3 The team27 of Environmental Resource Management (ERM) New Delhi visited

Bhopal during 6-8 January 2020 in order to undertake face to face meetings with these

organizations and individuals identified

Screening

4 The screening against the preferred criteria was undertaken for the potential

candidates available to work as FA for FPIC None of these agenciesindividuals reported to

have worked for a FPIC process earlier Also the candidates interviewed are not familiar

with the World Bank and IFC safeguards related policies and procedure applicable for IPs in

energy and other infrastructure development sectors They are however interested in

working and learning from the project The candidates also had limited experience in the

field of natural resource management and rural livelihoods Details of the screening of

potential candidates is given below

27 Team comprised of Ramesh Swarankar Freelance Consultant and Akshita Mishra Senior Consultant ERM

Page 13

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Amitav Singh

and Leena

Singh

Debate Lok

Nyas (DEBATE)

Duplex C-22

Alkapuri Near

DRM Office

Habibganj

Bhopal-462024

0755-2985007

0755-2417656

9425018144

9425004556

debateindiag

mailcom

MA Social

Works

The key persons are active for

last 3 decades in Social Work

The Debate Trust was

incorporated in 2002-03 and has

more than 15 years of experience

in working with PRIs in Madhya

Pradesh with an focus in Tribal

(Schedule-V) Areas Mr Amitav

Singh is a member of National

Committee for Monitoring of

MNREGA

Ms Leena Singh has also

experience of working with rural

women for more than 15 years

Have

worked

with Bhils

of

Jhabua

Yes Yes Yes

Mr Amitav

Singh is a

leading trainer

for PRA and

Social Audits

by Panchayat

Raj Ministry

No

But was

part of the

FPIC

training

provided

by

ActionAid

Yes

(requires

support in

Reporting)

Score 18 3 2 3 3 3 2 2

Dr Jose

Payyappilly

Address 142

Nyay Nagar

Sukhliya

Indore

Contact-

7828355557

PhD MA

in Social

Work amp

Sociology

About three decades experience

of working on Health HIVAIDS

CSR Literacy Adult education

minority education related

projects and programs funded by

GoI GoM Clinton Foundation Bill

amp Melinda Gate Foundation

UNAIDCARE World Action

Forum VHAI Christian Aid NGO

such as Samarthan in MP

Chhattisgarh and other states It

Has

worked

with Bhils

as part of

a larger

communi

ty in

Jabhua

No No Yes

Trained in

traditional

communicatio

n systems

folklore

folktale

Familiar with

planning

strategy and

community

Associated

with the

network of

NGOs CSOs

and village

level

functionaries

Worked with

local

governments

and elected

No Yes

Page 14

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Email Id

payyappillyjose1

6gmailcom

jose_soolyaho

ocoin

includes the districts in MP with

IPs population

Dr Jose has worked as team

leader director executive director

and other positions Also worked

as Local Governance and BCC

Advisor to DANIDA for Health

Services Program State Media

Coordinator State Resource

centre Adult Education MP

Program Producer Radio Veritas

Asia Manila Philippines

stakeholder

engagement

panchayat

representative

s

Score 14 2 1 1 3 3 1 3

Parushram

Tiwari

Address- C-443

Sarvdharm

Colony Kolar

Road Bhopal

Contact-

09425065132 amp

8319540266

Email Id

drpram42gma

ilcom

PhD

MPhil MA

( Sociology

More than 20 year experience of

working as consultant at different

positions in Public health

HIVAIDS literacy education

nutrition urban development and

governance projects and

programs in MP including Malwa

area and other states

These projects were funded by

UNICEF UNFPA ADB Clinton

Foundation Women amp Child

Development Rural

Development Urban

Administration amp Development

No No Yes Has

worked as

the State

Project

Manager

for Sanjhi

Sehat

project of

MP State

Rural

Livleihood

Mission

Yes Is good

with

coordination

and

communicatio

n

Yes has

experience in

Planning

management

and execution

capacity

building

training and

Networking

and advocacy

Liaison

support and

team building

No Will need

support in

documentatio

n

Page 15

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

State AIDS Control Society of

GoMP and the NGO partners

Dr Tiwari was the Project Director

and District Program officer under

National Literacy Mission at

District Collector offices at Dhar

and Indore MP respectively

during 1991-1998

Score 13 1 1 2 3 3 1 2

Mr Sandip Naik

Adddress-C-55

Kalani Bagh

Dewas MP

Pin Code

455001 India

Contact- +91-94

2591 9221

Email id

naiksandigmai

lcom

Diploma in

Developm

ent

Facilitation

from TISS

Mumbai

MPhil

MA in

Rural

Developm

ent and

English

Literature

About 20 year experience of

working on health nutrition

education governance and

women empowerment with

governments of MP

Worked with NGOs International

agencies and MP government on

senior positions

Since 2014 working with CRY

and TDH on issues of malnutrition

and preparing booklets

brochures pamphlets on nutrition

adolescents issues and childrenrsquos

health Also written textbooks

teachers learning material and

manuals for state govt for SCERT

etc

Yes No No Yes Yes No Yes

Page 16

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Score 14 2 1 1 3 3 1 3

Dr Rahul Dev

Bahawsar

Address Block

No 14 Flat No

5 Shalimar

Enclave E-3

Arera Colony

Bhopal ndash

Madhya

Pradesh

Contact-

08223015124

Email

rbhawsarrediff

mailcom

rahuldevbhawsa

rgmailcom

PhD amp

MPhil in

Population

Studies

from IIPS

Mumbai

MSC

Statistics

24 years experience in

monitoring evaluation and

implementation of programs in

health and social development

sectors in MP Rajasthan and

Gujarat states

Engaged in nutrition assessment

survey in 18 districts of MP states

including IPs dominated districts

such as Dhar Jhabua with Bhil

population and coordinated with

state health women amp child

development and rural

development departments during

the study period

Involved in conducting health

surveys at national level

Worked as a staff with Health

Management Research Institute

Jaipur and IPE Global Consulting

Firm New Delhi etc These

projects were funded by DFID

UNICEF UNFPA GoI GoMP

etc

Yes has

worked

in

Jhabhua

and Dhar

No Yes Has

worked

with State

Rural

Livelihood

Mission

Somewhat

His strengths

lie more

towards

quantitative

research

Somewhat No Yes

Page 17

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Working as freelance expert and

has a registered consultancy firm

that is inactive

Score 12 2 1 2 2 2 1 2

Ms Aastha

Anuragi

Address 173

Sanjay

Complex

Phase-2

Geetanjaly

Square Bhopal-

462003

Contact-

9425365216

8160123726

Email

aasthaanuragi

gmailcom

MBA Rural

Manageme

nt amp MSC

in Physics

More than 15 year experience of

working particularly imparting

training to different stakeholders

in drinking water and sanitation

Swachh Bharat ODF missions

WASH livelihood menstrual

hygiene etc Master trainer for

total sanitation program

Worked as consultant in MP

Chhattisgarh West Bengal UP

Gujarat Jharkhand Bihar states

These projects were funded by

World Bank Water Aid UNICEF

DFID GoI State governments

and ICIMOD Nepal

No No Yes has

worked as

a project

facilitator

with MP

livelihood

project

Yes Yes No No

Score 12 1 1 2 3 3 1 1

Note The scoring for each criterion was as follows 0- Not applicable 1- Not Meeting the Requirement 2- Partially meeting the requirement 3- Completely fulfilling the requirement

Page 18

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

Page 19

TERMS OF REFERENCE FOR FPIC FACILITATION AGENCY

Background

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake an

Environmental and Social Impact Assessment of three solar parks including internal evacuation

infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch

Agar and Shajapur Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work for the project ERM is required to assess the impacts on the indigenous

marginalized communities within the site and its influence area prepare an Indigenous Peoples Plan

(IPP) apart from other ESIA amp RAP deliverables The project is also required to conduct a FPIC process

covering affected Scheduled Tribe (ST) population

Villages to be covered in FPIC Process

The project area has a few small ST settlements and in few others a small number of ST households

live along with a majority non-ST population Following 5 villages are identified for carrying out FPIC

process

Solar Park Selected ST villages

for FPIC

Number of

Households

Name of ST

Community

Agar Solar Park Ladwan 12 Bhil

Shajapur Solar Park Parsula 41 BhilBhilala

Neemuch Solar Park Badi and Kawai 97 BhilBhilala

Note Additional ST families in neighbourhood villages of the same Solar Park will be made part of this

process to a limited extent

Phases in FPIC Process

The FPIC process will be divided into two phases as described below

Phase What to Do Schedule

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Apr 2021^

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

May-Aug 2021^

^ Activities were suspended in April 2021 due to break out of the second wave of Covid-19 in India These

activities will be re-scheduled once Covid-19 second wave gets over

Deliverables and Responsibilities

Phase Responsibilities Deliverable

I Identification of STs Representatives and formation of committees

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Documentation of capacity building of STs Representatives on FPIC

Mutually agreed FPIC Process and composition of local ST Representative committees

Page 20

Phase Responsibilities Deliverable

Hindi Translation of TDPIPP and designing Information sharing tools

Participatory mapping of all natural resources and cultural sites to be impacted

Participatory assessment of impacts on Tribal population

Identification of Livelihood and Welfare programs to be included in Draft TDP

Inventory of natural resource and cultural sites

Documentation of participatory process of impact assessment

Note on livelihood and welfare programs

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation (Photos Video MoMs for each meetingsevents) of FPIC process

The revised package in Draft TDP and a mutually agreed Draft FPIC Agreement

Personnel Requirement

The FPIC Facilitation Agency will require to mobilize following key personnel for completing these tasks

Designation Desired Qualification and Experience

Coordinator The coordinator to be a post-graduate in social sciencessocial work with at

least 15 years of experience in ruraltribal development Prior involvement in

FPIC related work with prominent civil society organizations or multilateral

development finance organizations will be preferred

Facilitator (Male) The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in facilitation of participatory rural appraisals The

facilitator needs to have sound knowledge of livelihood issues in Malwa

region of Madhya Pradesh and must have worked with Panchayati Raj

Institutions for their capacity building The facilitator should be familiar with

the local dialect (Malwi) spoken in Malwa region

Facilitator

(Female)

The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in working with rural women She should have

knowledge of livelihood and social context of women in Malwa region She

should have prior experience in facilitating participatory rural appraisal

processes involving rural women

Documentation

Assistant

The documentation assistant should be a Graduate in social sciencesmass

communication She should have at least 5 years of experience in ruraltribal

development and have carried out process documentation of development

projects She should have a good command over Hindi and should be

familiar with Malwi dialect

Community

Mobilizer

The community mobilizer should have passed higher secondary and have

experience of working with any NGO for at least 2 years She should have

good communication skills She will provide all logistical support necessary

to ensure participation of maximum number of people She also helps

Documentation Assistant in photo and video documentation of the FPIC

process

Organization Profile

The organization should have at least 10 years of experience in working in rural and tribal

development issues in Madhya Pradesh The organization should have a reputation of successfully

implementing projects related to community mobilization and capacity building They should have

Page 21

prior experience of working with tribes and should be known for their dedication and commitment

towards tribal rights and promoting their development

The business of sustainability

ERM has over 160 offices across the following

countries and territories worldwide

Argentina

Australia

Belgium

Brazil

Canada

Chile

China

Colombia

France

Germany

Ghana

Guyana

Hong Kong

India

Indonesia

Ireland

Italy

Japan

Kazakhstan

Kenya

Malaysia

Mexico

Mozambique

Myanmar

The Netherlands

New Zealand

Norway

Panama

Peru

Poland

Portugal

Puerto Rico

Romania

Russia

Senegal

Singapore

South Africa

South Korea

Spain

Sweden

Switzerland

Taiwan

Tanzania

Thailand

UAE

UK

US

Vietnam

ERM India Private Limited

Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

wwwermcom

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page i

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

CONTENTS

1 INTRODUCTION 1

11 Project Background 1 12 Timeline of Various EampS Studies 3 13 Scope amp key deliverables related to FPIC for MP Solar Project 4 14 Structure of the Report 11 15 Limitations 11

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS 12

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in

2018 12 22 International Social Safeguard Policies Applicable to the Project 16

221 IFC Performance Standards 16 222 World Bank Operation Manual OP 410 16

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard

Policies of IFC and WB 17

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION 22

31 Affected Villages Government land used by ST Population 22

311 Neemuch Solar Park (Unit 1-3) 22 312 Agar Solar Park (Unit 4 amp 5) 26 313 Shajapur Solar Park (Unit 6-8) 30

32 Selection of FPIC Villages 36 33 Impact on Nomadic Pastoral Communities 37 34 Impact on Government and Grazing Land 38 35 Impact on Cultural Sites affiliated to STs 39 36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure 40

361 Use of Government Land in TLs Associated With Neemuch Solar Park 41 362 Use of Government Land in TLs Associated With Agar Solar Park 42 363 Use of Government Land in TLs Associated With Shajapur Solar Park 43 364 Conclusion on FPIC Trigger for Transmission Lines 45

4 DESK BASED INFORMATION COMPILATION 46

41 Information Collection and Compilation 46 42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks 46

421 Government Land Allotment for Neemuch Solar Park 46 422 Government Land Allotment for Agar Solar Park 46 423 Government Land Allotment for Shajapur Solar Park 47

43 Review of Previous Community Consultations for Allotment of Government Land 47

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER 49

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020) 49

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park 49 512 Disclosure of Intention to Conduct FPIC Agar Solar Park 49 513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park 50

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises

with STs (Aug 2020) 50

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village) 52 522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village) 55 523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages) 58

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL 62

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

6 INDEPENDENT FACILITATOR AGENCY 63

61 Need for FPIC Process Facilitation Agency 63 62 Screening of FPIC Process Facilitation Agency 63 63 Roles and Responsibility for FPIC Process Facilitation Agency 65 64 Terms of Reference for FPIC FA 65

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS 66

71 Use of Language 66 72 Use of Customary Decision Making Process and Traditional Leaders 66 73 Promoting Participation of Women and Youths 67 74 Expectation on Material Information Prior to Discussion 67 75 Need for Capacity Building of IP Representatives 68 76 Need for a Mediation Mechanism 68 77 Following Principles of Good Faith Negotiation 69 78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and

Supportive Environment 70

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK 73

81 Introduction 73 82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo 73

821 Appointment of FPIC Facilitation Agency and Orientation 73 822 Introducing FPIC FA to RUMSL and FPIC Villages 73 823 Formation of ST Committees 74 824 Capacity Building of ST Committees 74

83 The Draft Discussion amp Decision Making Framework 74

831 Formation of Committees 75 832 Acceptance of Draft Discussion and Decision Framework 76 833 Disclosure of Draft IPPIPDP to ST Committee 77 834 Explaining Draft IPPIPDPTDP to ST Committee 78 835 Internal Consultation Process by ST Committee 78 836 First RUMSL and ST Committee Meeting 78 837 Second RUMS and STs Committee 79 838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee

(MC) 79 839 Informing Community on Draft FPIC Agreement by ST Committee 79 8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and

Ratification of Final IPP and FPIC Agreement 80 8311 FPIC Process Documentation Report 81

84 Tentative Time-line 81 85 Responsibility Matrix 83

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT

FPIC

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE

FPIC FACILITATOR

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page iii

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Tables

Table 11 Villages to be covered in FPIC Process 1

Table 12 Salient Features of the Project 2

Table 13 The status of ESIA Study Components and Community Engagement 3

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables 5

Table 21 Key Provisions of Land Revenue Code 12

Table 22 Comparison of Provisions of Consent Process in Applicable Indian Regulations vis-agrave-

vis Provisions in IFC PS-7 17

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land

Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

19

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected

Villages 22

Table 32 Agar Solar Park- Government Land- Land Use Category 26

Table 33 Shajapur Solar Park- Government Land- Land Use Category 30

Table 34 Villages to be covered in FPIC Process 36

Table 35 Designated grazing land (Charnoi) and Remaining Government Land 38

Table 36 Impact on Cultural Sites Affiliated to STs 39

Table 37 List of Power Evacuation Infrastructure 40

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of

STs 41

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST

Population 42

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs 43

Table 41 Dates of Government Land Allotment for Neemuch Solar Park 46

Table 42 Dates of Government Land Allotment for Agar Solar Park 46

Table 43 Dates of Government Land Allotment for Shajapur Solar Park 47

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha

Resolution 47

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park 49

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park 50

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park 50

Table 54 Site visit Dates and Site Activities 51

Table 55 Names of Potential Representatives in Ladwan Village 54

Table 56 Names of Potential Representatives in Parsula Village 57

Table 57 Names of Potential Representatives in Badi and Kawai Village 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency 63

Table 62 Roles and Responsibilities of FPIC FA 65

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context 69

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages 71

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page iv

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Figures

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages 24

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages 25

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages 28

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages 29

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages 33

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages 34

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages 35

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments 56

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process 74

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Acronyms and Abbreviations

Name Description

CSO Civil Society Organizations

DDMF Discussion and Decision Making Framework

DPR Detail Project Report

DREO District Renewable Energy Officer

ESIA Environment and Social Impact Assessment

ESS Environment and Social Standards

FA Facilitation Agency

FPIC Free Prior Informed Consent

FPIC-FA FPIC Facilitation Agency

FPICon Free Prior Informed Consultation

GAP Gender Action Plan

GFN Good Faith Negotiation

GN Guidance Note

GoMP Government of Madhya Pradesh

GP Gram Panchayats

HO Head Office

ICP Informed Consultation and Participation

IFC International Finance Corporation

IPDP Indigenous Peoples Development Plan

IPP Indigenous Peoples Plan

Ips Indigenous Peoples

JV Joint Venture

LRP Livelihood Restoration Plan

MC Mediation Committee

MNRE Ministry of New and Renewable Energy

MPLRC Madhya Pradesh Land Revenue Code

MPUVNL Madhya Pradesh Urja Vikas Nigam Limited

MW Mega Watt

NGO Non-Government Organizations

NOC No Objection Certificate

OBC Other Backward Castes

OP Operation Policy

PPP Public Private Partnership

PRA Participatory Rural Appraisal

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Name Description

PS Performance Standard

RAP Resettlement Action Plan

RPO Renewable Purchase Obligation

RUMSL Rewa Ultra Mega Solar Limited

SC Scheduled Caste

SEP Stakeholder Engagement Plan

SHG Self Help Group

SPD Solar Park Developer

SPO Solar Purchase Obligation

ST Scheduled Tribe

TDP Tribal Development Plan

ToR Terms of Reference

WB ESF World Bank Environment and Social Framework

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 1

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

1 INTRODUCTION

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Impact Assessment (ESIA) including Resettlement and

Rehabilitation Action Plan (RAP) of three solar parks including internal evacuation infrastructure and

associated transmission lines of aggregate capacity of 1500 MW in the Neemuch Agar and Shajapur

Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work ERM is required to assess the impacts of the Project on the Indigenous

Peoples (IPs) or Scheduled Tribe (ST) and develop an approach and implement the process of Free

Prior Informed Consent (FPIC) The villages in Table 11 were identified to be covered in the FPIC

process during the scoping stage The intention of conducting FPIC process involving ST families in

these identified villages was communicated to the Sarpanch1 and a project information sheet (in

Hindi) was shared around Dec 2019

Table 11 Villages to be covered in FPIC Process

Solar Park Selected ST

villages for FPIC

Number of

Households

Name of ST

Community

Date on which Gram

Panchayat was informed

about FPIC Process

Agar Solar Park Ladwan 12 Bhilala 19th Dec 2019

Shajapur Solar Park Parsula 41 Bhilala 30th Jan 2020

Neemuch Solar Park Badi and Kawai 61 Bhil and Bhilala 5th and 6th Dec 2019

The Covid-19 pandemic brought restrictions for finalizing the project boundary and preparation of

ESIA Reports between Mar 2020 and Jun 2020 ERM initiated the FPIC related works and submitted

a Memo on selection of FPIC villages dated 29th Jun 2020 which reviewed the government land

allotment and triggers for FPIC

The FPIC Approach Paper (current document) is based on the understanding of the socio-political

context within which the affected STIPs population lives and suggestions received from the

prominent ST representatives with whom a preliminary round of discussions was held The Discussion

and Decision Making Framework (see Section 8) is accepted by RUMSL and was planned to be taken

back to the affected ST community for discussion and acceptance in Apr 2021 (see Section 832)

This has been delayed due to second wave of Covid-19 which started in Apr 2021 and decision on

further visits and consultations will be undertaken based on how situation unfolds in the coming

weeks The FPIC Approach paper will be finalized after the Discussion and Decision Making

Framework is discussed with ST Committees representing affected ST communities and agreed by

them

11 Project Background

The Government of India has identified the solar power sector as one of the critical components for

infrastructure development and overall economic growth The Government of Madhya Pradesh

(GoMP) through Ministry of New and Renewable Energy (MNRE) is developing ground mounted grid

connected solar power projects in Madhya Pradesh International Finance Corporation (IFC) is

providing investment advisory services to RUMSL thereby enabling Government of Madhya Pradesh

(GoMP) to develop the project on Public Private Partnership (PPP) mode and to support GoMP in

1 The rural local self-government bodies in India are known as Gram Panchayat which comprises of several wards Each ward

elects a ward member to represent them The Gram Panchayat thus comprises of multiple elected Ward Members The Chair Person of these elected local body is known as Sarpanch The vice chairperson of the Gram Panchayat is known as Upsarpanch or Naibsarpanch All adult electorate of a Gram Panchayat constitute Gram Sabha or General Assembly of the Gram Panchayat

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 2

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

meeting its energy requirements and in the process meet its Renewable Purchase Obligation (RPO)

and Solar Purchase Obligation (SPO)

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) Its primary objective is to develop

and facilitate development of large scale solar power projects in the state of Madhya Pradesh

RUMSL is planning to develop three solar parks (see details in Table 12) and their associated

internal evacuation infrastructure and transmission lines The World Bank had agreed to provide

financial support for the Project

Table 12 Salient Features of the Project

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Capacity and Configuration

3 Units (Units 1 2 3) adding up to 500 MW

2 Units (Units 4 and 5) adding up to 550 MW across Susner (Unit 4) and Agar (Unit 5)

3 Units adding up to 450 MW across Moman Badodiya (Units 6 and 7) and South Shajapur (Unit 8)

Total Land Area as of 24 June 2020

Unit 1 3515 ha Unit 2 34713 ha Unit 3 36701 ha Total 106573 ha

Unit 4 60809 ha Unit 5- 79918 ha Total 140758 ha

Unit 6- 2462 ha Unit 7 4859 ha Unit 8 2551 Total 9872 ha

Government Land (ha) allotted as of 24 Jun 2020

67819 ha

Allotment of additional 28979ha is under process Thus the total government land area is 962949 ha

127338 ha 931 ha allotted and additional 14ha to be allotted

Date of Government Land allotment

Allotment Date

Area in Ha

17-01-2018 23868

30-05-2017 43951

Total 67819

Allotment Date

Area in Ha

28022019 5633

28022019 7053

21062019 1495

20-06-2019 15925

28022019 283

20062019 19714

280202019 1683

21012019 3492

04012018 602

09082018 2669

30112016 5562

02012018 5699

02012018 16116

06012018 17663

09082018 15583

Total 127137

Allotment Date

Area in ha

26-05-2017 914

26-05-2017 3052

26-05-2017 2011

11-12-2017 11261

11-12-2017 1171

11-12-2017 171

11-12-2017 1386

11-12-2017 4015

11-12-2017 4596

11-12-2017 9545

11-12-2017 1763

26-05-2017 16461

28-06-2019 2675

28-06-2019 6134

Total 931

Private Land 1862 ha 1342 ha 9951 ha

Patta land 7572 ha 0 515 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Proposed Commissioning Date

Tender and bid process tasks completed

- Start of registration downloading of the RFP access to Data Room on 26th Jan 2020

- Facilitation of site visit 26 to 28th Feb 2020

- Issue of Draft Project Agreements on 15th Jun 2020

- First pre-bid meeting was held on 30th Jun 2020

- ESIA Reports was issued on 16th Oct 2020

Tender and bid process schedule ahead

- Second pre-bid meeting on 30th Mar 2021

- Proposal due date for 3 sites between 3rd Jun 2021 and 18th Jun 2021

- Financial proposal opening between 14th Jun and 28th Jun 2021

- Reverse Auction Process 17th Jun and 30th Jun 2021

Purchase of Private land between Apr and Jun 2021

Target date for providing SPD land access June 2021

Indicative construction time of 19 months

Target date for commissioning of Solar Park Nov 2022 It is understood that RUMSL will initiate a process of hand over of balance government land to revenue department no longer required for the project

12 Timeline of Various EampS Studies

The allotment letters of the government land were issued at different points of time between 2017 and

2019 The boundary demarcation (tarmeem2) of these allotted government land for the 3 solar parks

was completed in October 2020 RUMSL is planning to initiate private and patta land procurement to

start in Apr 2021 and all sale agreements are signed by Jun 2021

The timeline of ESIA studies of these 3 Solar Parks is provided in Table 13 below

Table 13 The status of ESIA Study Components and Community Engagement

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

ESIA Field

visits

December 2019 December 2019-

January 2020

January ndash February

2020

September 2020

Report Final ESIA

submitted in

October 2020

Final ESIA

submitted in

October 2020

Final ESIA submitted

in October 2020 Draft ESIAs for

Neemuch TL and

Agar- Shajapur

TL submitted in

November 2020

RAP-

LRP

Field

visits

November-

December 2020

August 2020 August 2020 December 2020

Report Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-WB

Draft RAP-LRP is

reviewed by IFC-

2 Tarmeem ground verification process to confirm land ownership and to demarcate any patta land andor private land that

may have been identified within a government khasra This process is done by Revenue Department from time to time in the normal course of action (with or without any project) As an outcome of this process following can be achieved Revisions in the Patwari maps Khasra books Digital database other revenue records preparation of survey reports etc This process is undertaken by Officials from the Revenue Department usually inclusive of the Tehsildar RI Patwari etc

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

WB and ready for

Public Disclosure in

Mar 2021

WB and ready for

Public Disclosure

in Mar 2021

and ready for Public

Disclosure in Mar

2021

WB and ready for

Public Disclosure in

Mar 2021

IPP Field

Visits

Initiation 5-6th Dec 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and Draft IPP 13-16th Aug 2020

HH Survey 7-14th Sep 2020

Initiation 19th December 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 6-7th Aug 2020

HH Survey Not done

Initiation 30th Jan 2020

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 8-12th Aug 2020

HH Survey 13-14th Aug 2020

No IPP to be prepared for Transmission Line

Report Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure in

Mar 2021

Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure

in Mar 2021

Draft IPP is reviewed

by IFC-WB and

ready for Public

Disclosure in Mar

2021

The ERM ESIA team has held several consultation meetings in project affected villages covering a

cross-section of stakeholders in a sequential manner The broad understanding of the socio-economic

and livelihood practices was carried out in Dec 2019 and Jan 2020 as part of collection of baseline

information The detailed study for RAP-LRP and IPP subsequently took place in Aug 2020 The details

of the consultations held for ESIA RAP-LRP are part of those reports and details of field visits and

consultation activities carried out for preparation of this FPIC Approach Paper and Draft IPP is described

in Section 4 below

13 Scope amp key deliverables related to FPIC for MP Solar Project

ERM as a part of the FPIC requirement for the project is expected to support the elaboration and

implementation of a robust FPIC process for the MP Solar Park project to be developed in 2 Phases

Phase I the overall principles and engagement process and criteria for obtaining FPIC should be

agreed on with the affected Indigenous People (IP) communities potentially before bidding

Phase II the focus of the proposed FPIC process will then be on seeking consent from affected

IP communities for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior

to the main construction phase) In phase II it is likely that the PPP concessionaire will also

play a role and as such the Social Expert will continue to advise RUMSL but also monitor the

activities of the concessionaire

The Table 14 below summarises the key deliverables tasks involved and expectations against each

of these tasks in terms as per the scope The current status progress of these tasks and timeline for

future activities is also proposed It should be noted that these timelines may change in keeping with

evolving health and safety situation in context of COVID-19

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

I OBJECTIVE AS PER RFP The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities before bidding ie the submission of proposal for solar parks by concessionaire

Guidance to RUMSL (ONGOING)

Provide guidance to RUMSL on the most appropriate sequencing of steps vis-agrave-vis the FPIC process as per IFC PS 7 requirements

eg agreement and verification of legitimate IP representatives to represent affected communities in FPIC negotiations

agreement with IPs and their representatives on the FPIC engagement process and next steps including disclosure and consultation of draft updated project impact mitigation benefits package documentation

share of responsibilities between RUMSL and PPP concessionaire etc

This will also include advise on broader stakeholder analysis and engagement strategy

to build support for the FPIC approach and implementation of the project and

to participate in agreed outreach to influential local and international stakeholders andor additional sources of adviceinput

ERM has been providing handholding support to the client in terms of meetings and calls where the requirements of IFC PS 7 are discussed and possible implications of project decisions on the FPIC applicability are discussed

The training for RUMSL team on ICP (SEP) PS-7 and FPIC process on 27th Aug 2020

Sharing of Draft FPIC Approach Paper 1st Sep 2020

Discussion on Draft IPP and Formation of Committees for FPIC Process 16th Mar 2021

Submission of Note on FPIC budget FPIC Process

Responsibilities of PPP concessionaire submitted as part of Draft IPPs (Appendix-F)

A meeting with facilitating agency and their ToR was held in 1st Week of Apr 2021

A Joint field trip with RUMSL FPIC Team will be held after Covid-19 Second Wave is over to

- Verify the IP representatives and formation of ST committees

- To agree with ST committee on Draft Discussion and Decision Making Framework

Draft FPIC approach paper

Desk-based Information Compilation and Assessments

Review national applicable law to identify any gaps with IFC PS7 and ways to bridge them

While developing the FPIC approach leverage as much as possible the requirements of applicable law and the consent process usually applied when IP are affected

The FPIC approach should also ensure that affected IP communities are involved

ERM did not get access to documentation of community consultation as part of seeking

NOC3 from Gram Panchayats

Conversation with Sarpanch of villages with ST population revealed that consultation was

A field trip for a joint meeting between RUMSL and ST communities is proposed to be held after Covid-19 Second Wave is over The field trip will include the following

3 The allotment of unused Government land within any revenue village needed a resolution of concerned local government body (Gram Panchayat) under S 234 (4) till Nov 2018 See more details in

Section 21 below The Solar Parks does not require any EIA studied in India

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Identification of affected IP individuals and communities and representatives as well as project impacts mitigation measures and potential benefits related to them (ongoing process during ESIA)

Initial Meeting with Gram Panchayats (GPs) and Informing them on FPIC

Social MappingSite walk-through

Preparation of Draft FPIC Approach Paper which builds on key elements of IFC PS7 FPIC requirements is prepared in consultation with RUMSL IP representatives and other stakeholders and could be acceptable to each party

Internal Discussion and Consensus on FPIC Approach Paper

Sharing of Draft FPIC Approach with IP and Consensus Building

in the identification of impacts and provide input on the development of mitigation and benefit plans

The FPIC approach should be cognizant that impacts on vulnerable groups within the Affected Communities of IP if any should be adequately addressed during negotiation and in relevant documentation

It should be based on the engagement with local IP community decision-making authoritiesrepresentatives (and taking into account gender and other IFC PS 7 related prerogatives) to discuss the FPIC process with input from support organization

The draft approach paper should reflect a mutually acceptable engagement and negotiation framework for the FPIC process based on the principles of Good Faith Negotiations It should include a clear agreed indication on what constitutes consent in the project context

Ensure through revision and feedback that all other components under this assignment (ifwhen available) are aligned with the defined FPIC approach ndash including the Environmental and Social Impact Assessment (ESIA) Resettlement Action Plan (RAP) Stakeholder Engagement Plan (SEP) Gender Action Plan (GAP) and develop the Indigenous People Development Plan (IPDP)

restricted to Gram Panchayat members Though they initially reluctant to sign on the NOC after persuasion of District Collector they finally signed

PRA exercises which includes participatory mapping of social relationship livelihood and natural resources was held between 6th to 15th Aug 2020

The social mapping during 6-15th Aug collected information on existence of traditional decision making process and gender representation aspect

The proposed FPIC process as part of this FPIC approach paper (Refer Chapter-8) reflect GFN principles

The FPIC approach paper was discussed with RUMSL prior to sharing it with WB-IFC

The ESIA disclosure was done as part of the PRA exercises for IPP in Aug 2020The RAP survey was done in these villages around the same time to address their concerns over loss of privatepatta land

Consultations during RAP and Draft IPP preparation included PRA process where STs participated to identify impacts and expressed their expectation on project benefits

The feedbacks and key issues in ESIA (including GAP SEP) and RAP is synchronised in Draft IPP

- Introduce FPIC Facilitation Agency

- Facilitate formation of ST representative committees

- Inform them their rights in the context of FPIC process

- Consult and build mutual agreement on the lsquoengagement and negotiation frameworkrsquo (as in Chapter-8 of this report) which will include a clear agreed indication on what constitutes consent

- The STs Representatives will be asked about time they require for internal discussion and a tentative date for the first discussion on benefits proposed in IPP will be fixed

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Independent FPIC Facilitator Agency

Assess the need for Independent FPIC Facilitator Agency

Screening of IPOsCSOs for Independent FPIC Facilitator Agency possible facilitator options to determine how they can play a role in the process - who what how

Provide a list of names of key advocacy groupsNGOsCSOs considered SWOT (or similar) analysis of each organization considered identification of preferred organization and

Terms of Referencersquo for the role of the same in the FPIC process and its relevance for the FPIC process in that area and for that specific group

To be discussed in next call FA brings credibility of an independent agency (other than RUMSL and ESIA consultant) Considering the project context their position can be reviewed

The review and assessing the need for a FA is discussed in section 6 of this report The Scope of work for the FA is provided in Appendix-F

Preparation of IPDPIPPTDP

Note ESIA RAP SEP and other management plans should be prepared by this stage Infact the FPIC process report should also draw input from the engagement undertaken as part of the ESIA process

Indigenous People Plan (or

Community Development Plan

Stakeholder Engagement Plan) or

similar management documents

aimed at ensuring ongoing and

adequate engagement with IPs

The collection of baseline

information through PRA

exercises and a sample

household survey was done

in Aug 2019 The IPP draws

inputs from consultations for

ESIA RAP-LRP and

benefits are also

synchronised

Three Draft IPPs one for

each Solar Parks with a

package of benefits for

affected STs is ready and

disclosed in May 2021

These will be shared with

affected STs as part of the

FPIC negotiation process

subsequently for their

considerations and

acceptance

Preparation of Draft FPIC Process Report

FPIC Process Report will include (but not be limited to)

identification of IPs IP representatives and decision-making authorities

assessment of capacity of IPs IP representatives to undertake good faith negotiations

summary of any capacity building undertaken

agreed engagement and negotiation framework (including the process undertaken to agree upon the framework)

This document will be further updated and finalised once the whole process is completed

Note The FPIC process should incorporate key considerations contained in IFC PS 7 and GN 7 eg the need for free prior and informed engagement inclusion of differentiated measures to allow the effective participation of those identified as particularly disadvantaged or vulnerable including analysis of the legitimacy and representativeness of IP leaders and the role responsibilities and participation of

To be initiated once FPIC Process starts

The process of identification of IPs representatives and decision making authorities (ST RUMSL and Mediation Committees) which will take place once Covid-19 second wave is over and will be documented as Draft FPIC Process Report This will be a living document which will be updated after every round of field activities and negotiation meetings

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

detailed summary of consultations meetings engagement undertaken as part of the FPIC process

expert opinion on the process and outcomes

share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to complete the FPIC process

external stakeholders with vested interests in the outcome

Input to the bidding document

For the bidders in terms of FPIC amp IPDP requirements

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc

The Draft IPP for each Solar Park has Annexure-F providing roles and responsibilities and scope of work for the Solar Park Developer (SPD)

All 3 Draft IPPs with Annexure-F are ready for disclosure in May 2021

II OBJECTIVE AS PER RFP Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Preparation of communication Material

Communication material to be based on IPDP ESIA and RAP This should include culturally appropriate document on impacts and mitigation to be used during FPIC engagement and negotiation

All preparation including translation of FPIC-related materials including communication material summaries of relevant EampS documentation local benefits plans etc (printing arrangement to be agreed with RUMSL)

A Project Profile Fact Sheet was shared in Dec 2019

A summary of ESIA was shared in Aug 2020

The communication material based on Draft IPP will be prepared and used during FPIC process The Draft communication material will be shared with IFC-WB for their approval prior to its use in field

A parallel information disclosure process of RAP-LRP would also take place

Culturally Appropriate Information Disclosure Campaign

Share accurate and up to date information on project impacts proposed mitigation measures and proposed benefit streams in a culturally appropriate manner (ie in local language (as appropriate following discussion with IP representatives) in written and oral format)

The information disclosure should especially ensure that following are achieved

provide sufficient time for capacity building and

support to affected communities to understand these matters and their rights

The affected ST population speaks Malwi dialect The FPIC FA will have facilitators who would be familiar with this local dialect used

The FPIC FA will carry out the capacity building activities

The FPIC FA will spend 2 days at each Solar Park to do the capacity building workshops with local ST Representatives who would participate in FPIC discussion with RUMSL

The FPIC FA will do this once Covid-19 second wave gets over

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Consent from the Indigenous communities

Meetings for Negotiation and Decision Making

Participate in and offer expert support to key FPIC-related meetings involving affected IP representatives RUMSL and other relevant authorities etc during the FPIC process

Support RUMSL in the organization of these meetings and in recording their outcome including the collection of comments and concerns of those attending

Measuring Consent and Signing of FPIC Agreement

Note This include also support the RUMSL in designing undertaking and collecting evidence of Good Faith Negotiations (GFN) resulting in Consent which involves (i) willingness to engage in a process and availability to meet at reasonable times and frequency (ii) provision of information necessary for informed negotiation (iii) exploration of key issues of importance (iv) use of mutually acceptable procedures for negotiation (v) willingness to change initial position and modify offers where possible and (vi) provision of sufficient time for decision making

Present updated materials and seek consent from affected IP communities and their leaders

Document the consent process in a mutually agreed written format including an agreed mechanism for monitoring of key commitments in future and grievance redress as well as identifying share of responsibilities between the RUMSL SPDs and other relevant parties

Evidence of representativeness and involvement of Indigenous Peoples representative bodies and organizations (eg councils of elders or village councils)

Evidence of agreement between the parties as the outcome of GFN (eg FPIC agreement MOU a letter of intent and a joint statement of principles agreed mitigation plans collective land agreements etc)

Other documents may include Client records photographs media reports personal letters or third-party accounts etc regarding eventsdemonstrations other activities for the project undertaken by project-affected IP communities with high relative levels of participation by (i) the affected community as a whole or (ii) by sub-groups particularly affected by the project

ERM will work alongside FPIC FA and RUMSL to help the FPIC process taking right direction

Final FPIC Process Document

Throughout the FPIC process (Phase I and Phase II) ERM should help documenting the FPIC process and provide an opinion and direction about the process and outcome vis-agrave-vis IFC PS7

The whole set of activity in Phase II need to be updated as part of the Final FPIC Process Document

The tentative timeline for the FPIC Process was scheduled between Jun 2021 and Sep 2021 The timeline will be revised after the ongoing Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

The Draft FPIC Process Report will be submitted within 2 weeks of completion of FPIC process

Advise RUMSL but also monitor the activities of the concessionaire in phase II

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INTRODUCTION

14 Structure of the Report

This report is organized into following sections

Section 1 Introduction (this section)

Section 2 Applicable law and gaps assessment against IFC PS7 requirements

Section 3 Affected IPs population project impacts and mitigation

Section 4 Desk-based information compilation

Section 5 Engagement leading up to FPIC Approach Paper

Section 6 Independent facilitator agency

Section 7 Key elements in FPIC Process

Section 8 Draft Discussion and Decision Making Framework

15 Limitations

This Report is prepared after multiple field visits and interactions with affected ST community elected

leaders of Gram Panchayat and other key informants The assessments are based on information

received from RUMSL and other secondary information at some places The public health concerns

due to Covid-19 pandemic has prevented large community gatherings and communityrsquos willingness to

allow people from outside to spend much time with them

ERM team communicated with community members over telephone to seek clarifications and know

their views However it was not always possible to keep the discussion focused and definitive as it

could have been in case of a face to face discussion ERM has made efforts to build trust among

affected STs by sharing relevant information and answering their queries with clarity As FPIC process

is an itinerant process this relationship is expected to further evolve in future

The Draft Discussion and Decision Making Framework described in Chapter 83 though has been

accepted by RUMSL and reviewed by IFC and WB it would be discussed with committees formed by

affected STs and their feedbacks will be incorporated The FPIC process described in Chapter-8

therefore would undergo necessary changes

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan could not

be ascertained as nomadic tribes did not visit these sites when ERM conducted field visits The general

migration pattern of pastoral nomads is expected to have faced constraints of Covid-19 restrictions If

pastoral nomads or their representatives will be identified during the FPIC process an appropriate

decision on their participation will be taken

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

This section provides an understanding of the applicable national regulations that pertain to the process

of land procurement and the rights of the Indigenous Peoples and a comparison between the provisions

of the same against the IFC PS 7 requirements

It should be noted that the Environmental and Social Impact Assessment (ESIA) Reports4 and the

Resettlement Action Plans (RAP) provide a detailed understanding of applicable regulations This

section is focused on the government land procurement process and its impacts on the collective rights

of the Indigenous Peoples identified in the project

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in 2018

The allotment of government land for these three solar parks is done under provisions of the MP Land

Revenue Code 1959 The Chapter-XVIII of this Code deals with rights in abadi5 (habitation area) and

un-occupied land and its produce

The Madhya Pradesh Land Revenue Code (MPLRC) was enacted in 1959 and has undergone several

amendments since then It was recently amended in 2018 and 2019 These recent amendments along

with other changes changed the procedure for allotment of unoccupied government land Some of the

land allotment letters were prior to this amendment and others after this amendment (see details in

Section 42) Table 21 below provides a comparison of key provisions in pre and post 2018

amendment

Table 21 Key Provisions of Land Revenue Code

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

Collective (Nistar) Rights on Unoccupied Government Land

Section 114- Land recordsmdash In addition to the map and

Bhoo Adhikar Pustikas there shall be prepared for each

village a khasra or field book and such other land records as

may be prescribed

Section 233- Record of unoccupied landmdash A record of

unoccupied land shall in accordance with rules made in this

behalf be prepared and maintained for every village

showing separatelymdash (a) unoccupied land set apart for

exercise of nistar rights under Section 237

Section 114 (e) (i) (ii) requires

the details of all unoccupied land

be maintained as described in

Section 233 One Such

document is the Nistar Patrak

under Section 234 Section 233 A record of all unoccupied land shall be prepared for every village and urban area in accordance with rules made in this behalf

Preparation of

Nistar Patrak

and change in

entries in

Nistar Patrak

Section 234 (1)- The Sub-Divisional Officer shall in

accordance with the provisions of this Code and the rules

made thereunder prepare a Nistar Patrak for every village

embodying a scheme of management of all unoccupied land

in the village and all matters incidental thereto and more

particularly matters specified in section 235

Section 234- same as 1959 Sub

section (2) (3) (4) have been

removed

4 Three separate ESIA Reports for Solar Parks one for each Solar Park one for the Neemuch Transmission Lines (Units 12

and 3) and another for the Transmission Lines for Agar and Shajapur Solar Parks (for Units 4 to 8) have been prepared 5 According to the MP Land Revenue Code 1959 abadi means the area reserved from time to time in a village for the residence

of the inhabitants thereof or for purposes ancillary thereto and any other cognate variation of this expression such as village site or gaonsthan shall also be construed accordingly No change was made to this definition in the subsequent amendments to the code

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(2) A draft of the Nistar Patrak shall be published in the

village and after ascertaining the wishes of the Gram Sabha

it shall be finalised by Sub-Divisional Officer

(3) A copy of the Nistar Patrak so finalised shall be kept in

the office of the Gram Panchayat

(4) On a resolution passed by the Gram Sabha by a majority

of not less than two-thirds of the members present and

voting the Sub-Divisional Officer with the prior sanction of

the Collector and also after making any such inquiry as he

deems fit inter se change the entries in the Nistar Patrak

(b) Record additional unoccupied land under any entry in the

Nistar patrak for fulfilment of further Nistar rights of villagers

Matters to be provided for in Nistar Patrak

Section 235- The matter which shall be provided for in the

Nistar Patrak shall be as follows namely

(a) terms and conditions on which grazing of cattle in the

village will be permitted

(b) the terms and conditions on which and the extent to

which any resident may obtain-

(i) wood timber fuel or any other forest produce

(ii) mooram6 kankar7 sand earth clay stones or any other

minor mineral

(c) instructions regulating generally the grazing of cattle and

the removal of the articles mentioned in paragraph (b)

(d) any other matter required to be recorded in the Nistar

Patrak by or under this Code

Section 235- same as previous provision of Land Revenue Code

Provision in

Nistar Patrak

for certain

matters

Section 236 - In preparing the Nistar Patrak as provided in

Section 235 the Collector shall as far as possible make

provision for-

(a) free grazing of the cattle used for agriculture

(b) removal free of charge by the residents of the village for

their bona fide domestic consumption of-

(i) forest produce

(ii) minor minerals

(c) the concessions to be granted to the village craftsmen for

the removal of the articles specified in clause (b) for the

purpose of their craft

Section 236 - same as previous

provision of Land Revenue Code

Collector to

set apart land

for exercise of

Nistar rights

Section 237 (1) Subject to the rules made under this Code

the Collector may set apart unoccupied land for the following

purposes namely-

(a) for timber or fuel reserve

(b) for pasture grass bir or fodder reserve

(c) for burial ground and cremation ground

(d) for gaothan

(e) for encamping ground

Section 237 (1) remains same

6 Soil used particularly for road paving 7 In India an impure concretionary carbonate of lime usually occurring in nodules in alluvial deposits and especially in the

older of these formations

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(f) for threshing floor

(g) for bazar

(h) for skinning ground

(i) for manure pits

(j) for public purposes such as schools play grounds parks

road lanes drains and the like and

(k) for any other purposes which may be prescribed for the

exercise of right of Nistar

237 (2) Lands set apart specially for any purpose mentioned

in sub-section (1) shall not otherwise be diverted without the

sanction of the Collector

Section 237 (3) Subject to the rules made under this Code

the Collector after securing the land mentioned in clause (b)

of subsection (1) to minimum two percent of the total

agriculture land of that village may divert such unoccupied

land as mentioned in sub-section (1) into abadi or for

construction of roads state highways national highways

canals tanks hospitals schools colleges Goshalas and

any other public utility projects as may be determined by the

State Government

Provided that the land set apart for the purposes mentioned

in subsection (1) shall not be diverted and allotted to any

person for agriculture purpose

Section 237 (4) When it becomes indispensable to divert the

land set apart for the purposes mentioned in sub-section (1)

for such development and infrastructural projects which are

owned or approved by the State Government but not

covered under sub-section (3) the Collector after satisfying

himself on alternatives available and also on obtaining land

of equivalent area for fulfilling the same nistar rights from the

concerned project may divert the land for such purposes by

passing a reasoned order to this effect Thus in case Nistar

land needs to be diverted for the project the project needs to

make available an equivalent area for the replacement of the

same nistar rights

The section 237 (2) is removed

Section 237 (3) remained same

Section 237 (4) remains same

Rights in Fruit Bearing Trees and other trees in Un-Occupied Government Land

Section 239 (1) Where before coming into force of this

Code any fruit bearing tree was planted by any person in the

unoccupied land of any village and is so recorded then

notwithstanding that such land vests in the State

Government such person and his successor in interest

shall from generation to generation be entitled to possession

and usufruct of such trees without payment of any royalty or

other charge whatsoever therefore

Section 239 (6) the State Government may make rules for

carrying out the purposes of this section

Section 239 (1) same as 1959

Section 239 (6) The unoccupied

land on which any tree planting

permit or tree patta has been

given prior to the commencement

of MP Land Revenue Code

(Amendment) Act 2018 may be

used for any public purpose by

the order of Collector If any

interest of the holder of such tree

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

planting permit or tree patta is

adversely affected due to such

use the holder shall be entitled

for such compensation which

shall be calculated in such

manner as may be prescribedrdquo

Exclusive jurisdiction of revenue authorities

Section 257 - Except as otherwise provided in this Code or

in any other enactment for the time being in force no Civil

Court shall entertain any suit instituted or application made

to obtain a decision or order on any matter which the State

Government the Board or any Revenue Officer is by this

Code empowered to determine decide or dispose of and in

particular and without prejudice to the generality of this

provision no Civil Court shall exercise jurisdiction over any

of the following matters - (w) any claim to modify any entry

in the Nistar Patrak

Section 258 (1) The State Government may make rules

generally for the purpose of carrying into effect the

provisions of this Code

(2) In particulars and without prejudice to the generality of

the foregoing powers such rules may provide for (lviii) the manner in which the wishes of the villagers shall be ascertained under Section 234 (2)

Section 257 - same as 1959

Section 258 (1) and (2) (lviii)

same as 1959 it should be noted that the Section 234 (2) was removed in 2018 Amendment

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers Diverting the un-occupied

government land8 categorised as grazing land that is recorded in Nistar Patrak (there may be other

grazing land available) and such other Nistar rights9 including the right in fruit bearing trees and other

trees in unoccupied government land after the amendment in 2018 does not require any consent

process with concerned village community

Hence it is expected that the government land allotted for the project prior to the 2018 Amendment of

MP Land Revenue Code is expected to have involved a resolution of concerned Gram Sabha As per

Sec-6 of the Madhya Pradesh Panchayat Raj Act 1993 the quorum of every meeting of Gram Sabha

shall not be less than one-tenth of the total number of members of the Gram Sabha or five hundred

members of the Gram Sabha whichever is less The Act does not specify presence of women in

Gram Sabha to be mandatory

Other Indian laws which has provisions for consent process are not applicable to this project and an

overview of them is provided in Box 31 below

8 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands 9 Nistar rights refer to collective rights of a revenue village to use specified government land for the purposes mentioned in

S235 of MP Land Revenue Code This includes right to free grazing cattle collecting minor minerals construction materials burialcremation grounds for religious and cultural events etc

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Box 21 Other Indian Laws with provisions for consent process and their applicability

22 International Social Safeguard Policies Applicable to the Project

221 IFC Performance Standards

The part of PS1 dealing with Management Program envisages an Indigenous Peoples Plan (IPP) as a

thematic plan and should be developed by qualified experts with substantive experience For projects

with adverse impacts to Indigenous Peoples the client is required to engage them in a process of

Informed Consultation and Participation (ICP) and in certain circumstances the client is required to

obtain their Free Prior and Informed Consent (FPIC)

The FPIC from the affected communities of Indigenous Peoples is required when the following special

circumstances (in paragraphs 13ndash17 of Performance Standard 7) are present

Impacts on lands and natural resources subject to traditional ownership or under customary use

Relocation of Indigenous Peoples from lands and natural resources subject to traditional

ownership or under customary use

Significant impacts on critical cultural heritage that is essential to the identity andor cultural

ceremonial or spiritual aspects of IPs lives

Where a project proposes to use the cultural heritage including knowledge innovations or

practices of Indigenous Peoples for commercial purposes

IFC PS7 requires to avoid adverse impacts on Indigenous People and if adverse impacts are

unavoidable the project should prepare an Indigenous Peoples Plan outlining the actions to minimize

andor compensate for adverse impacts in a culturally appropriate manner Some of the key

provisions with respect to IPP are

A free-standing IPP may be prepared or it may be a component of a broader community

development plan

The IPP should detail actions to minimize andor compensate for adverse social and economic

impacts and identify opportunities and actions to enhance positive impacts of the project on the

Indigenous Peoples

Where appropriate the IPP may also include measures to promote conservation and sustainable

management of the natural resources on which the Indigenous Peoples depend

The IPP should include a clear statement of roles and responsibilities funding and resource

inputs a time-bound schedule of activities and a budget

The IPP shall be regular monitored and should be flexible to allow for it to be adapted as needed

if circumstances change

222 World Bank Operation Manual OP 410

The World Bankrsquos Operational Policy on Indigenous Peoples (OP 410) aims at ensuring that the

development process fosters full respect for the dignity human rights and cultures of IPs thereby

In Indian context the constitutionally recognized Scheduled Tribes are usually considered as Indigenous Peoples

while determining their entitlements under international social safeguards systems

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006( FRA) is not

relevant as no forestland was diverted The Provisions of the Panchayat (Extension to the Scheduled Areas) Act

1996 (PESA) acts is not applicable for the project as the project site is not in a schedule V area There are no

specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement

consultation and consent

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

contributing to the Bankrsquos mission of poverty reduction and sustainable development To achieve this

objective Bank-assisted projects which affect IPs provide them a voice in design and implementation

avoid adverse impacts where feasible or minimize and mitigate them and ensure that benefits

intended for them are culturally appropriate

The Bank recognizes that IPs are commonly among the poorest and most vulnerable segments of

society and in many countries they have not fully benefited from the development process It also

recognizes that the identities cultures lands and resources of indigenous peoples are uniquely

intertwined and especially vulnerable to changes caused by development programs Because of this

issues related to indigenous peoples and development are complex and require special measures to

ensure that IPs are not disadvantaged and that they are included in and benefit from these programs

as appropriate

Under the OP 410 the Bank requires the borrower to undertake a social assessment to evaluate

projectrsquos potential positive and adverse effects on the IPs and to examine project alternatives A

project that affects Indigenous Peoples the borrower engages affected IPs in a free prior and

informed consultation (FPICon) process

Note The World Bank adopted Environment and Social Framework (ESF) which comprises of ten Environment

and Social Standards (ESS) The ESS-7 deals with Indigenous PeoplesSub-Saharan African Historically

Underserved Traditional Local Communities which requires FPIC to be obtained in special circumstances where

customary rights on natural resources used by IPs is impacted The WB has financed the renewable projects to

MNRE prior to adoption of the new ESF in Dec 2019 The Shajapur Solar Park is under the old WB safeguards

and therefore the new ESF is not applicable

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard Policies of IFC and WB

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers The diversion of the un-

occupied government land10 categorised as grazing land that is recorded in Nistar Patrak (there may

be other grazing land available) and such other Nistar rights including the right in fruit bearing trees

and other trees in unoccupied government land after the amendment in 2018 does not require any

consent process with concerned village community A comparison of key provisions of PS-7 vis-agrave-vis

legal provisions in Indian context is provided in Table 22

Table 22 Comparison of Provisions of Consent Process in Applicable Indian

Regulations vis-agrave-vis Provisions in IFC PS-7

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Assessment of Impact on Indigenous People

The client will identify through a process of Social and Environmental Assessment all communities of Indigenous Peoples who may be affected by the project within the projects area of influence The client will assess the nature and degree of the expected social cultural (including cultural heritage) and environmental impacts (direct and indirect) on them and avoid adverse impacts whenever feasible

There is no requirements for environment impact assessment (EIA) for Solar Park Projects There are no specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement consultation and consent

10 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands Such usages will be confirmed only through the Tarneem process for each site

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Preparation of IPP

The clients actions will be developed with the informed consultation and participation of affected Indigenous Peoples and contained in a time-bound plan such as an Indigenous People Plan or a broader community development plan with separate components for Indigenous Peoples

There is no legal requirement for an Indigenous Peoplersquos development plan

Consultation and Consent from affected IPs

In projects with adverse impacts on affected communities of Indigenous Peoples the consultation process will ensure their free prior and informed consultation and process of community engagement will be culturally appropriate and commensurate with the risks and potential impacts to the Indigenous Peoples

The acquisition of the private land owned by ST will be done through MP Consent Policy 2014 and the RAP addresses the impact on individual ST land ownersoccupiers The impact on customary rights (such as Nistar rights) over collectively used unoccupied government land is dealt under the provisions of MP Land Revenue Code 1959 There is no consultationconsent process for diversion of grazingNistar lands under MP Land Revenue Code 1959 (As amended up to 2019) The consent process in other Indian laws such as FRA or PESA which has consent process is not relevant to the project

Land Revenue Code had a requirement for Gram Sabha consent to be taken prior to diversion of

Nistar rights as part of the 2018 Amendment the same provision was removed As most of the

government land for Shajapur Solar Park was allotted in 2017 Table 23 below provides a

comparison of provisions of the consent process under MP Land Revenue Code 1959 (prior to Nov

2018 amendment) vis-agrave-vis requirements under IFC PS-7

The key elements of FPIC process as per IFC PS (including Guidance Notes- GN) identified for

comparison includes

1 Requirements of information disclosure (as in PS-129) 2 Informed consultation and participation (as in PS-130-31 and PS-710) 3 Good Faith Negotiation (as in GN-725) and 4 Consent and documentation (as in PS-712)

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Information Disclosure

Relevant project information must be disclosed to Affected

Communities and other stakeholders to enable them to

understand the risks impacts and opportunities of the project

The Project will provide Affected Communities with access to

relevant information on

the purpose nature duration and scale of the project

risks and potential impacts and relevant mitigation measures

the envisaged stakeholder engagement process and

the grievance mechanism

Information disclosed must be relevant transparent objective

meaningful and easily accessible and in a culturally appropriate

local language(s) and format and is understandable to Affected

Communities

Under MP Revenue Code 1959 and MP

Panchayat Raj Act 1993 the information

disclosure to affected communities (including

Schedule Tribes) is limited to the intended

purpose of the allotment of unoccupied

government land

The disclosed information and proceedings are

recorded using the language of the State

The information disclosure to affected communities

prior to the meeting does not disclose all relevant

information particularly potential risks The

information disclosed is not easily accessible to STs

and other vulnerable communities

The process does not involve any grievance

mechanism

Informed consultation and participation

Where a Project has potentially significant adverse impacts on

affected communities an ldquoinformed consultation and

participationrdquo (ICP) process should take place ICP is an

organised and iterative consultation that involves a more in-

depth exchange of views and information leading to the Project

incorporating the views of those affected into project decision-

making on matters that affect them directly

The consultation process should capture both menrsquos and

womenrsquos views and their different concerns and priorities The

process should be documented in particular the measures taken

Section 234 of MP Revenue Code 1959 (Prior to

Nov 2018 Amendment) required the draft Nistar

Patrak of every village and any changes in therein

to be published by Sub-Divisional Officer with

prior sanction of the District Collector only after

ascertaining wishes of the Gram Sabha

(expressed through a resolution passed in Gram

Sabha held for this purpose)

As per Section 6 of the MP Panchayat Raj Act

1993 the Gram Sabha can be held with a quorum

of one-tenth of the total member of Gram Sabha

The MP Revenue Code does not require any

iterative consultation that involves in-depth

exchange of views

The participation of women and other vulnerable

sections is not mandatory

The quorum of the meeting is only ten percent of the

total members of the Gram Sabha The notice for

holding a special Gram Sabha is only 7 days and

there is limited information shared in terms of the

agenda of the meeting Hence a resolution passed

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

to avoid or minimise risks to and adverse impacts on the

Affected Communities and should inform those affected about

how their concerns have been considered

In addition the process should Involve Indigenous Peoplesrsquo representative bodies and

organisations as well as members of the Affected Communities of IPs and

Provide sufficient time for IPs decision-making processes

or five hundred members whichever is less

There is no specific requirement on presence of

women to fulfil quorum requirements

A special meeting of the Gram Sabha is held

within seven days of receiving the requisition

by a Gram Sabha with a bare minimum presence

does not reflect majority decision

The process does not require representative bodies

of IPs to represent their interests

Good Faith Negotiation

FPIC will be established through good faith negotiation between

the Project and the Affected Communities of IPs Good faith

negotiation generally involves (i) Willingness to engage in a process and availability

to meet at reasonable times and frequency (ii) Provision of information necessary for informed

negotiation (iii) Exploration of key issues of importance (iv) Mutually acceptable procedures for the negotiation (v) Willingness to change initial position and modify

offers where possible and (vi) Provision for sufficient time for decision making

The MP Revenue Code require neither iterative

prior consultation nor exchange of views with

administration

The administrative process for allotment of

unoccupied government land does not involve a

negotiation process through which their feedback

and concerns are incorporated or addressed

Consent

In certain circumstances the client is required to obtain the Free

Prior and Informed Consent (FPIC) of affected IPs FPIC does

not necessarily require unanimity and may be achieved even

when individuals or groups within the community explicitly

disagree The measurement of consent is expected to be

included in the lsquomutually accepted processrsquo for FPIC decision

making

Consent

Section 234 (4) required the Gram Sabha to pass

a resolution with support of a majority not less than

two-thirds of the members present and voting As

per Section 6 of the MP Panchayat Raj Act 1993

the Gram Sabha can be held with a quorum of one-

tenth of the total member of Gram Sabha or five

hundred members whichever is less There is no

specific requirement on presence of women to fulfil

quorum requirements

Consent

The FPIC process in IFC PS-1amp7 recognizes that

consent is not necessarily a unanimous decision

yet there has to be a mutually agreed threshold of

consent in an FPIC process that can vary from

project to project The threshold defined in MP

Panchayat Raj Act 1993 is one-tenth of the total

members of Gram Sabha passing a resolution with

support by two third majority present and voting

Thus the consent threshold for a resolution is 66

of the total members of Gram Sabha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Documentation

The client will document

The mutually accepted process (FPIC Decision Process Framework Document) between the client and Affected Communities of Indigenous Peoples and

Evidence of agreement between the parties as the outcome of the negotiations

Documentation

The documentation is limited to the entries in Gram

Sabha minutes book The entire set of

documentation is kept by Administration and not

shared with Gram Panchayat

Considering this low threshold as per legal

requirements the FPIC process requires a mutually

accepted threshold for decision making

Documentation

The documentation of the process carried out during

the Gram Sabha meetings leading to the resolution

though is written down in the Gram Sabha minutes

book however there is no guideline on what should

be covered Therefore a mutual agreement on

documentation requirement is necessary

As described in GN62ndash65 where government processes involve project-level decision and actions the client should review these processes in relation to the requirements of the Performance Standard and address identified gaps where feasible

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

The FPIC was triggered at the scoping stage on account of impact on grazing land and other natural

resources within the allotted government land on which STs have claims of customary use which is also

recognized under MP Land Revenue Code as Nistar rights The statement of different categories (which

are part of the Nistar rights of village community) of government land to be used for the proposed Solar

Parks from different villages and percentage of ST population in these villages is provided below

31 Affected Villages Government land used11 by ST Population

311 Neemuch Solar Park (Unit 1-3)

The Neemuch Solar Park is comprised of 3 units and the land is acquiredpurchased from 3 villages

The land category (classification in revenue records as per their currentintended use) is provided in

Table 31 below

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected Villages

Village Name

Govt Land Category in Hindi

Govt Land Category in English Sum of Area (Ha)

ST Population in of Total Village Population

Unit -1

Bardavada Chargah Grazing land 2271 55

Charnoi KamdalKK (Kabil Kast)

Grazing land 4013

DathaKamdal Land with stone outcrops and shallow soil

1655

Gair mumkinCharnoi Uncultivable waste land grazing land

492

Kabil Kast Cultivable 2

Kamdal Land with stone outcrops 169

KamdalDathaDahar Grazing land 4641

KamdalDathaKaKa Grazing land 4279

PK 052

NA 2053

Sub-Total (Bardawada) 25774

Kawai Datha Land with stone outcrops and shallow soil

8962 1992

NA 425

Sub-Total (Kawai) 9388

Total Unit 1 351615

Unit -2

Badi Datha 052 2292

Kabil Kast 11568

NA 5835

Sub-Total (Badi) 17455

Kawai NA 17846 1992

Sub-Total (Kawai) 17846

Total Unit 2 35301

Unit -3

Badi Charnoi (grazing) Grazing land 355 2292

Datha 3805

Gairmumkin Charagah

(grazing)

Uncultivable waste land

grazing land

4184

11 The MP Land Revenue Code recognizes the right to use for grazing collection of timber fire-wood earth morums and other

products (see Section 235 of MP Land Revenue Code)

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

KaKa (Kabil Kast) Culturable wasteland 5

Kamdal 11179

NA 13727

Badi total 36945

Total Unit 3 3694557

Grand Total (Unit-1 2 and 3) 107408

Note land category for the units is as per the Allotment Letters NA= Not Available

The screening of the Census 2011 data shows that there is presence of ST population in all three

villages In Badi and Bardawada villages the land categories such as Charnoi Charagah are clearly

recorded as grazing lands The map below shows the location of village settlements and their area

designated as Grazing Land

The ST families in Badi and Kawai live in several small cluster of satellite settlements The Bardawada

had only 22 ST population with 4-5 families Bardawada is part of Dhardi Gram Panchayat and the ST

households live farther from the Solar Park boundary Their households are scattered and dependency

on the allotted government land for Bardawada village could not be established In terms of

concentration of ST population Badi and Kawai are considered as major ST settlements

Thus ~100 ST households in Badi and Kawai have a claim on customary use of ~18938 ha of

designated grazing land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

312 Agar Solar Park (Unit 4 amp 5)

The Table 32 provides a break-up of the designated land categories of government land as per revenue

records in Agar Solar Park

Table 32 Agar Solar Park- Government Land- Land Use Category

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Agar Solar Park (unit 4)

Bijnakhedi Germumkin Uncultivable waste land 5598 0

Sub-Total (Bijnakhedi) 5598

Dudhpura Agriculture Agriculture 2243 0

Bardi NA 6631

Gothan Livestock rearing land 2

Khadar The floodplains formed by

yonger alluvium

018

Tree Plantation NA 1495

NA NA 5082

Sub Total (Dudhpura) 15669

Karwa Khedi Chragha Grazing land 251 0

K K NA 475

Khachar Grazing land 068

Pahad Hilly terrain 12392

NA 216

Sub Total (Karwa Khedi) 15346

Keasi Dehariya Gochar Grazing land 283 0

Sub Total (Keasi Dehariya) 283

Ladwan Bardi 7963 579

Charnoi Grazing land 947

Gochar Grazing land 2749

Kavil Kast 609

Khachar Grazing land 238

Pahad Hilly terrain 3062

Waterbody Water body 094

NA 475

Sub Total (Ladwan) 16137

Madhopur Germumkin Uncultivable waste land 1558 0

Sub Total (Madhopur) 1558

Pipalia Kumar Bardi 3492 0

Agriculture land Agriculture 506

Sub Total (Pipalia Kumar) 3998

Total Unit 4 611381

Susner Solar Park (Unit 5)

Palda Germumkin Uncultivable waste land 5689 036

NA 6928

Sub Total (Palda) 12617

Naharkheda Germumkin KaKa Uncultivable waste land 4125 0

Germumkin Uncultivable waste land 1868

NA NA 8908

Sub Total (Naharkheda) 14901

Umariya Charnoi Grazing land 3660 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Charokhar Grazing land 416

Chragha Grazing land 9114

Germumkin Uncultivable waste land 147

Kadim NA 011

Shaskiye Government land 218

Sheda NA 01

NA NA 20907

Sub Total (Umariya) 35806

Pipaliya Nankar NA NA 1822805 0

Total Unit 5 8161745

Note land category for the unit 4 is as per the kml file provided by RUMSL on 30012020 as the allotment letters did not carry

the land use details

Ladwan village has 579 of ST population (~12 households) who have claim on customary use of

3934 ha of designated grazing land Palda was found to have only 1 ST family Moreover no Charnoi

Chargah Gochar land is acquired from Palda Hence ST families in Ladwan were selected to be in

focus for FPIC process

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages

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Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

313 Shajapur Solar Park (Unit 6-8)

The Table 33 provides a break-up of the land categories of government land as per revenue records

in Shajapur Solar Park In Shajapur Solar Park (Unit 6-8) five villages have ST population They are

Jawadi (034 STs) Parsula (1768 STs) Dehripal (018 STs) Fawaka (238 STs) and

Chouma (072 STs) Of these Dehripal Fawaka and Surajpur do not have any Charnoi Chargah

Gochar land impacted

Table 33 Shajapur Solar Park- Government Land- Land Use Category

Village Name Govt Land

Category in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Moman Badodiya-Unit6

Burlay Agriculture Agriculture 813 0

Germumkin Uncultivable waste land 224

Nala Stream Drain 138

Burlay Total 3191

Jawadi Agriculture Agriculture 198 034

(1 Household with

3 persons)

Gochar Grazing land 4189

Idhan Hetu For fuelenergy 209

Kabil Kast 316

Muram Hetu For Murram (fine aggregate) 063

Pahad Hilly terrain 339

Shivir Camping ground 041

NA 2011

Jawadi total 3596

Dhatrawada Agriculture Agriculture 338 0

Charnoi Grazing land 058

Chragha Grazing land 4058

Germumkin Uncultivable waste land 10638

Gothan Livestock rearing land 128

K Kast 557

Kabil Kast 1217

Kadim 074

Khadan Quarry 291

Khalihan Threshinggrain storage etc 167

Murum Hetu

Khadan

For Murram 125

Nala StreamDrain 042

Road Road 117

NA 6

Dhatrawada total 1841

Total (Unit 6) 25197

Momain Badodiya-Unit 7

Parsula Agriculture Agriculture 515 1768

(~41 households) Barda Rockyhilly 847

Barda Nistar

Chragha

Grazing land 947

Charnoi Grazing land 1064

Idhan Hetu

Surakshit

Secured for fuelenergy-

firewood

209

KK 137

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Khchar Grazing land 311

Nala Streamdrain 146

Nistar Chragha Grazing land 393

Parsula Total 12192

Dehripal Agriculture Agriculture 124 018

(1 Household with

5 populaiton)

Birdi GM 295

Brda 8054

Brda Lala 055

Chuna Hetu 105

Germumkin Uncultivable waste land 2015

Kankad Chuna

Hetu

For coarse aggregate and

lime

105

Khad ke Gadde 15

Muram Hetu For Murram (fine aggregate) 042

Watershed

Planning

Watershed planning 027

NA 1916

Dehripal Total 14004

Bijanakhedi Agriculture Agriculture 2199 0

Bardi 4101

Bardi Charnoi Grazing land 1274

Bardi 385

Chamdi Sthan 042

Charagah Grazing land 035

Charnoi Grazing land 018

Chragha Grazing land 1404

Germumkin Uncultivable waste land 858

Idhan Hetu 209

Khad ke gadhe Manure collection 084

Khalihan Hetu Threshinggrain storage etc 143

Mitti Hetu 063

Muram Hetu For Murram 063

Nala Streamdrain 36

Pathar Hetu For Stone 105

Road Road 203

Shivir Bhumi Camping ground 042

NA 288

Bijanakhedi total 11876

Fawaka Agriculture Agriculture 016 238

(4 Households with

28 population)

Brda Hilly terrain 863

Idhan Hetu Secured for fuelenergy-

firewood

25

Kakkad 418

Muram Hetu For Murram (fine aggregate) 179

Fawaka Total 1726

Chouma Agriculture Agriculture 392 072

(3 Households with

19 population)

Brdi Hilly terrain 562

Chamda Sthan For de-skinning 021

Charnoi Grazing land 989

GM 2943

Gothan Livestock rearing land 5

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Muram Pathar

Khadan

Murram (fine aggregate) 041

Nala Streamdrain 015

Chouma total 5463

Burlay Germumkin Uncultivable waste land 1543 0

Nala Streamdrain 019

NA 2604

Burlay Total 4166

Total (unit 7) 49427

Shajhapur (unit 8)

Surajpur Bardi Hill Terrain 898 203

(3 Households with

16 population)

Germumkin Bardi Uncultivable hill terrain 1170

Nala Streamdrain 597

NA 1894

Surajpur total 4559

Lalpur Beed 023 0

Beed Gair Mumkin 053

Brdi 2333

Charagrah Grazing land 18

Charnoi Grazing land 115

Gair Mumkin Brdi 1608

Kadim 115

Nala Streamdrain 055

NA 1684

Lalpur Total 6166

Hanoti NA 16291 0

Total (unit 8) 27024

Note land category for the units is as per the excel sheet received on 18062020 from RUMSL

Hence 41 ST households in Parsula who have a claim of customary use on ~3134 ha of

designated grazing land was selected to be the focus for FPIC Process The map below shows

the location of Parsula and the area designated as Grazing Land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

32 Selection of FPIC Villages

The assessment of the relevance of the four special circumstances that requires free prior informed

consent (FPIC) to be obtained from affected ST population was undertaken On the basis of the detailed

assessment undertaken as part of ESIA RAP along with targeted consultations with the IP

communities three circumstances are assessed to be not relevant to the project context

Relocation of STs was avoided while determining Solar Park boundary for all the three solar

parks and therefore no relocation of STs is anticipated from lands and natural resources subject

to traditional ownership or under customary use

The physical impact on cultural heritage sites with affiliation to STs is avoided in the three Solar

Park lay out and there is no potential significant impact on critical cultural heritage that is

essential to the identity andor cultural ceremonial or spiritual aspects of local STs community

The Solar Park does not propose to use the cultural heritage including knowledge innovations or

practices of STs for commercial purpose

Table 34 provides the list of villages where the FPIC process will focus covering ST households living

within it The assessment concludes that affected ST families have been living in these villages for

generations and have been using the government land (which was assessed to be subject to

traditional ownership or under customary use of the ST communities) allotted for Solar Park Project

for free grazing their cattle collection of fire-wood and collect edible fruits and plants mostly for self-

consumption The diversion of these land for the solar park will result in impacts on lands and natural

resources It was noticed that 7 other project affected villages had less than 5 ST households the

impact on their customary use of land acquired for the project was assessed and included in this table

too

Table 34 Villages to be covered in FPIC Process

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

Neemuch

Solar Park

Badi

(including 2

satellite

settlements)

80 (~450) Bhill Bardawada which is part of Dhardi Gram

Panchayat has only 4 ST families The location

of these ST households and consultations did

not indicate the government land allotted to

Neemuch Solar Park were under customary use

by them Kawai 17 (~100) Bhill

Agar Solar

Park

Ladwan 12 (~50) Bhill Palda village has 1 ST household and no

grazing (designated as Charnoi Chargah

Gochar) land is acquired from Palda

Palda village has 276ha of designated grazing

land and 28735ha of unoccupied government

land which they will continue to use for free

grazing their cattle and collection of fire wood

Hence the customary use of land by ST

household will continue with a negligible impact

Shajapur

Solar Park

Parsula 41 (~250) Bhill

Bhilala

Apart from Parsula 5 other affected villages

have less than five ST households These

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

villages (with the number of ST households)

are Jawadi (1) Dehripal (1) Fawaka (4)

Chouma (3) and Surajpur (3) The remaining

designated grazing land and total government

land for these 5 villages is provided below

Village Remain-

ing Desig-nated Grazing land (ha)

Total govern-ment land after Project allotment (ha)

Designated Grazing Land in percentage total Govern-ment land

Jawadi 2125 2705 786

Dehripal 241 8116 03

Fawaka 5032 5703 882

Chouma 2278 8167 279

Surajpur 1224 2592 472

The consultation with STs at Parsula informed

that unlike them these ST families do not keep

livestock in large number and mostly work as

construction workers Hence the land allotted to

Solar Park was not under customary use by

them for their livelihood

Note The ST families in these 7 villages will have access to the Grievance Mechanism to register their claims to

participate in the FPIC process In such a case their demands will be shared with concerned ST Committee (or

referred to Mediation Committee) and decision to include them in the process will be taken and an appropriate

mechanism for their representation and participation will be adopted

33 Impact on Nomadic Pastoral Communities

The seasonal use of the grazing and government land by nomadic pastoral communities was noticed

in scoping stage However further consultations with local villagers revealed that they do not visit

regularly and rarely camp on the land allotted to Solar Park These nomadic pastoral communities are

from the neighbouring state Rajasthan and are not recognized as STs in Madhya Pradesh

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan and

consultation with any pastoral nomadic tribes was not held as they did not visit these sites when ERM

conducted field visits The general migration pattern of pastoral nomads is expected to have faced

constraints of Covid-19 restrictions If pastoral nomads or their representatives will be identified during

the FPIC process an appropriate decision on their participation will be taken

ERM will consult GoMP to obtain records of grazing permits issued to pastoral nomads of other states

and determine if any of the villages impacted by Solar Parks figure in it More information on their

migration routes and pattern of seasonal use of forest and revenue land for grazing (which would help

assessing their collective attachment to impacted land) will be collected

Due to C-19 restrictions the regular migration patterns by pastoral nomads are affected in 2020 The

next migration season will be in Nov-Dec 2021 In absence of the particular pastoral nomads the

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

GoMP data on pastoral nomad communities who are issued permit will be used and their IPs status

will be screened through secondary ethnographic literature

FPIC is an iterative process If nomadic pastoral communities could not be consulted the rights of

pastoral nomads will be recognized in TDP and a provision for engagement with them to identify

adequate mitigation measures will be kept in TDP

34 Impact on Government and Grazing Land

The total geographical area of these selected FPIC villages grazing land (Charnoi) available after

allotment remaining government land after allotment percentage of the government land remaining is

given in Table 35 below As per provisions of the MP Land Revenue Code a minium of 2 of the

total private land in a revenue village is reserved as Charnoi or grazing land It is observed that

Ladwan and Parsula have more than this recommended minimum

Table 35 Designated grazing land (Charnoi) and Remaining Government Land

Solar Park Unit

Village Name

Geo

gra

ph

ical

Are

a o

f V

illa

ge

(h

a)

To

tal

Pri

vate

La

nd

To

tal

Go

vern

men

t L

an

d P

rio

r to

All

otm

en

t (

of

To

tal

Geo

gra

ph

ic

Are

a)

To

tal

Go

vern

men

t L

an

d R

eq

uir

ed

for

So

lar

Park

(

of

To

tal

Go

vern

men

t L

an

d)

Rem

ain

ing

Go

vern

men

t L

an

d a

fter

All

otm

en

t to

So

lar

Pa

rk

Perc

en

tag

e o

f G

overn

men

t L

an

d o

f

To

tal

Geo

gra

ph

ical

Are

a

( d

ecre

as

e o

r In

cre

as

e)

()

Desig

nate

d G

razin

g L

an

d

avail

ab

le a

fte

r P

roje

ct

all

otm

en

t (h

a)

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g

Lan

d)

of

the R

em

ain

ing

Go

ve

rnm

en

t

La

nd

()

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g)

Lan

d o

f th

e T

ota

l P

rivate

La

nd

Neemuch Solar Park Unit 1 amp2

Kawai 82698 20132 62566 (76)

24572 (39)

37994 (61)

46 (-30)

397 104 2

Neemuch Solar Park Unit 2 amp3

Badi 130055 33599 96456 (74)

51499 (53)

44957 (47)

35 (-39)

646 144 2

Agar Solar Park Unit 4

Ladwan 59076 31913 27163 (46)

16832 (62)

10331 (38)

17 (-29)

6682 6468 21

Shajapur Solar Park Unit 7

Parsula 69061 51439 17622 (26)

1162 (66)

6002 (34)

9 (-17)

1802 3002 4

Note () As per requirement under MP Land Revenue Code a minimum of 2 of the private land area within a

revenue village is to be reserved as Charnoi or grazing land for collective use by villagers

() Total Charnoi or grazing land prior to the allotment of Government land available in secondary sources

(Census 2011) is old as the land allotment took place between 2017 and 2019 Some Government Land

Allotment Letters mentioned the pre-allotment land category classifications (see Table 31 32 and 33) but this

data was not available for all vilalges to calculate the proportionate reduction of Charnoi land

The percentage of government land in some of the villages was high prior to the allotment of land for

Solar Parks For example the government land in Kawai formed 76 and that of Badi 74 of the

total geographical area Allotment of government land for Solar Parks has reduced the proportion of

the government land in these villages but the percentage of reduction varies from village to village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

For Kawai the percentage of government land after allotment has reduced from 76 to 46 (-30)

and for Badi it changed from 74 to 35 (-39) In Ladwan village the percentage of government

land changed from earlier 46 to 17 (-29) Similarly in Parsula the percentage of government

land changed from earlier 26 to 9 (-17)

The revenue department has designated some part of the remaining government land as Charnoi or

grazing land as per current Nistar Patrak The designated grazing land area meets the minimum

requirement of 2 of the total private land of that particular revenue village The designated grazing

land area forms 104 and 144 of the remaining government land for Kawai and Badi respectively

The designated grazing land in Ladwan forms 6682 of the remaining government land and in

Parsula it forms 1002 of the remaining government land

35 Impact on Cultural Sites affiliated to STs

The physical impact on all cultural sites (both for ST and Non-ST communities) was avoided by

excluding them from the Solar Park lay-outs However some of the cultural sites will be in close

proximity or access to some of them would be possible only through the Solar Park boundary An

overview of the cultural sites affiliated to STs for each of the Solar Parks is provided below

Table 36 Impact on Cultural Sites Affiliated to STs

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

Shajapur

Parsula

Gwalon ka

Mandi

Located within Solar

Park boundary

Adequate area (as agreed during FPIC

consultations) around the Gwalon-ka-Mandi to

be left unused in Solar Park lay-out

A road of sufficient width to be provided to

reach Gwalon-ka-Mandi

SPD will carry out improvements of the cultural

site after discussion with STs and other

communities using it

SPD will provide adequate civic amenities

(parking space drinking water lighting public

toilets etc) as per discussion with STs and

other community using it

Agar Solar

Park Ladwan

Gwaal Dev

Shrine

Located at the

margin of Solar Park

boundary

The SPD should leave the shrine and

adequate space around it in its lay out plan

Will ensure that access to the shrine by

community is maintained

The SPD will consult community to improve the

shrine Or build a new shrine for Gowals in the

new grazing area

Neemuch

Solar

ParkBadi and

Kawai

None The shrines and

cremation grounds

used by Bhils in

Kawai and Badi are

None

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

avoided in project

layout plan

No cultural sites or shrines with cultural significance for STs as a community was found during RAP

survey

36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure

The power evacuation infrastructures associated with these 3 Solar Parks are listed below The Pooling

Sub Stations (PSS) are located within the Solar Park boundary There will be 8 transmission line (TL)

sections whose footprint will be outside of the solar park boundary

Table 37 List of Power Evacuation Infrastructure

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

Neemuch

Solar Park

33kV220 kV Pooling Substation Unit-1 258 ha Located within the Solar Park

boundary 33kV220 kV Pooling Substation Unit-1 296 ha

33kV220 kV Pooling Substation Unit-1 887 ha

PGICL ISTS Station Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Neemuch

Solar Park

220 kV SC Line - 1 (From Unit 1 to Unit 2)

Transmission Line (TL) 1

332 km TL footprint is outside of the MP

Solar Park boundary includes

28 Towers (04 ha 144sqm

for each tower base) and RoW

of 13m width of 920ha

220 kV SC Line - 2 (From Unit 2 to PGCIL

ISTS substation)

Transmission Line (TL) 2

157 km

220 kV SC Line - 3 (From Unit 3 to PGCIL

ISTS substation)

Transmission Line (TL) 3

251km

Agar and

Shajapur

Solar

Parks

33kV220 kV PSS 4 in Unit 4 158 ha Located inside Solar Park

boundary 33kV220 kV PSS 5 in Unit 5 539 ha

33kV220 kV PSS 6 in Unit 6 513 ha

33kV220 kV PSS 7 in Unit 7 143 ha

33kV220 kV PSS 8 in Unit 8 196 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

PGCIL ISTS substation 830 ha Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Agar and

Shajapur Solar Parks

220 kV SC Line - 4 (From Agar Solar Park Unit 4 to interconnecting point with TL 7) Transmission Line (TL) 4

121 km TL footprint is outside of the MP

Solar Park boundary includes

372 Towers (536 ha

144sqm for each tower base)

and RoW of 13m width for

11914kms with 14951ha

220 kV SC Line - 5 (From Agar Solar Park Unit 5 to PGCIL ISTS substation) Transmission Line (TL) 5

2932 km

220 kV DC Line - 6 (From Shajapur Solar Park Unit 6 to Shajapur Solar Park Unit 7) Transmission Line (TL) 6

667 km

220 kV SC Line - 7 (From Shajapur Solar Park Unit 7 to PGCIL ISTS substation) Transmission Line (TL) 7

1646 km

220 kV DC Line - 8 (From Shajapur Solar Park Unit 8 to PGCIL ISTS substation) Transmission Line (TL) 8

6548 km

361 Use of Government Land in TLs Associated With Neemuch Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 38 below

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of STs

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

1 Arnya 088 958 007 784

Kheda Moka Ka Dol 223 1807 055 83

Bardawada 009 5651 002 55

Kawai 112 8265 016 20

2

Kawai 104

Badi 102 13004 012 23

3 Badi 285

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

Chaksodijhar12 043 4475 012 0

Grand Total 966 42782 011

The transmission line RoW comes from six revenue villages out of which 5 are Solar Park affected

villages There are 2 additional villages coming under TL RoW ie Arnya (088ha) and Kheda Moka

Ka Dol (223ha)

The population of Arnya in 2011 (as per census) was 969 out of which 784 were ST population

The Kheda Moka Ka Dol is comparatively a smaller village with total population of 348 and 83 of it

belong to STs

The proposed RoW of the transmission line will use 007 and 055 of the unused government land

in Arnya and Kheda Moka Ka Dol respectively The RoW of the Transmission Line does not pass

through any reserved or protected forest land The vegetation cover in the transmission line RoW is

mostly shrubs and grassland There would be no restriction on current use of the RoW for free grazing

of cattle Hence the transmission line will not impact customary use of the RoW land by ST

population in Arnya and Kheda Moka Ka Dol

362 Use of Government Land in TLs Associated With Agar Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 39 below

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST Population

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

4 Ladwan 068 13311 051 6

4 Pachora 089 273 033 0

5 Chkali Parmar 093 1567 059 0

5 Jhikadiya 266 13514 197 0

5 Pipalya kumar 229 13328 172 0

5 Chikali goyal 287 20523 140 0

5 Bhanpura 152 17482 087 0

5 Nipaniya Baijnath 381 29047 131 0

5 Tola Khed 095 3757 253 0

5 Kashi Bardiya 219 5362 408 2

5 Tola Khedi 042 3757 112 0

5 Kankariya 105 13354 079 0

5 Bhimlod 026 22564 012 0

12 Chaksodijhar is part of Badi Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

5 Bapcha agar 266 26778 099 0

5 Karadiya 144 23584 061 0

5 Mangwalia 24 15397 156 0

5 Gaysari 219 5293 414 0

5 Dehrinana 314 29331 107 0

5 Pharaspuri 142 16955 084 0

5 Bingaya Agar 112 150 075 0

5 Ralayti 267 2365 1129 0

5 Piplaya ghata 212 12811 165 0

RoW area passing through Kashi Bardiya village constitute 4 of the total government

The vegetation cover in the transmission line RoW is mostly shrubs and grassland There would be no

restriction on current use of the RoW for free grazing of cattle The RoW of the Transmission Line

does not pass through any reserved or protected forest land and therefore does not involve any

potential use of forest produce Hence the transmission line will not impact customary use of the

RoW land by ST population in Kashi Bardiya

363 Use of Government Land in TLs Associated With Shajapur Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 310 below

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

6 Burlay 494 2876 172 0

6 Bijnakhedi 158 14668 108 0

6 Dehripal 215 27508 078 0

7 Fawaka 237 6083 390 2

7 Dehripal 296 27508 108 0

7 Parsula 219 5891 372 18

7 Megha Khedi 098 3537 277 0

7 Singhwad 071 3118 228 24

7 Palakhi 072 1185 608 0

7 Baigaon 27 2387 1131 11

7 Bagwad 335 14239 235 13

7 Karkadiya 111 8267 134 0

7 Pipalya Kumar 101 13328 076 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

7 Pachora 306 13311 230 0

7 Shivgarh 024 13353 018 0

8 Abhaypur 026 7633 034 0

8 Alampura 337 12006 281 0

8 Arniya 233 9019 258 0

8 Bada Beed Jagatpura 32 49327 065 0

8 Barandwa 646 258 250 1

8 Batawada 022 5854 038 0

8 Bhadoni 096 1672 057 4

8 Bordagujar 217 120 181 0

8 Chachakhedi 155 482 322 0

8 Chandangaon 409 5711 716 0

8 Chikali Parmar 299 1567 191 0

8 Dhakadi 174 467 373 0

8 Dupada 181 3624 050 6

8 Fanya 349 22 1586 0

8 Gujar Khedi 02 0

8 Gurdadiya 188 1279 1470 2

8 Hanoti 004 34035 001 0

8 Harangaon 005 3034 016 0

8 Jadmi 371 3597 1031 0

8 Jhonkar 572 13653 419 0

8 Kadiya 06 13653 044 8

8 Kalmoi 009 3916 023 0

8 Kanasiya 109 40642 027 0

8 Karedi 003 16944 002 0

8 Kareli 197 16944 116 0

8 Katwariya 458 9312 492 33

8 Khajuri Kanad 085 3138 271 3

8 Kharkhadi 071 310 023 0

8 Khutpala 016 2359 068 0

8 Kundla Khurd 23 1507 1526 3

8 Merkhedi 26 26 1000 1

8 Mirapura 068 3767 181 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

8 Murdawan 292 101 289 0

8 Nanukhedi Mana 054 12851 042 0

8 Nanya Khedi Ahir 156 19092 082 0

8 Palasi 028 203 138 21

8 Pipalya Kumar 163 13328 122 0

8 Pipalya Naulay 28 8117 345 25

8 Rojwas 138 10 1380 0

8 Samgi 454 9921 458 2

8 Samgimanda 086 2578 334 0

8 Shankarpur 327 5782 566 0

8 Siroliya 003 10446 003 0

8 Surajpur 249 6912 360 2

8 Suwagaon 092 17558 052 9

The RoW of the transmission lines associated with Shajapur Solar Park passes through 60 villages

and 19 villages have ST population Out of these one village ie Parsula is covered in FPIC process

for Shajapur Solar Park

The RoW of the Transmission Line does not pass through any reserved or protected forest land and

therefore does not involve any potential use of forest produce The vegetation cover in the

transmission line RoW is mostly shrubs and grassland There would be no restriction on current use

of the RoW for free grazing of cattle Hence the transmission line will not impact customary use of the

RoW land by ST population in these 18 villages with ST population

364 Conclusion on FPIC Trigger for Transmission Lines

Based on the details of the presence of STs in Transmission Line corridors and assessment

of current land use and land classifications following inferences can be drawn

1 The TL Tower base and RoW corridor does not have any reserved or protected forest Hence potential customary use of forest produce is not relevant

2 The vegetation within TL RoW is mostly shrubs and grassland which is potentially used by local community for free grazing If any of this land under the ROW has been used for free grazing the people (including the ST families) will have other unused government land available to graze The disruption during construction and stringing will be very temporary and people can continue grazing under the ROW as before The few villages where the impact on unused land was higher than 10 either had no or very small (lt5) of ST population

3 The RAP survey has not identified any cultural site within TLs RoW or Tower Base area 4 There will be no physical displacement of any ST family for TLs

Therefore the circumstances requiring to obtain FPIC is not relevant for transmission lines

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DESK BASED INFORMATION COMPILATION

4 DESK BASED INFORMATION COMPILATION

41 Information Collection and Compilation

ERM has undertaken a desk based review of the information available This step involved collecting

and compilation of relevant information from following sources

Review of Detail Project Report (DPR) prepared by PwC dated October 04 2019

Detailed Project Report for the Project Dec 2019

The Project boundary map provided by RUMSL dated 19 Jun 2020

Collection of digitised maps of village boundaries

Compilation of demographic data using census 2011 data

Review of drone imagery for the project shared by RUMSL to identify EampS sensitivities in the

proposed project boundary

42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks

This section provides the timeline of land allotment process which is compiled from the allotment letters

of the land shared by RUMSL

421 Government Land Allotment for Neemuch Solar Park

Government land is being procured through allotments under the provisions of the Madhya Pradesh

Land Revenue Code 1959 (and its subsequent amendments) Table 41 provides details of the land

allotment for the Neemuch Solar Park

Table 41 Dates of Government Land Allotment for Neemuch Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Village

17-01-2018 7A-20(3)2017-2018 23868 Bardawada Kawai and Badi

30-05-2017 26A-20(3)2016-2017 43951 Kawai and Badi

Total 67819

Source RUMSL

67819 Ha (out of total 96894 Ha) is allocated to RUMSL through two allotment letters in the year 2017

and 2018 respectively out of the 96894 Ha of the required Government Land Both these allotment

letters predates the MP Revenue Code Amendment Act 2018 Allotment of additional 28979ha is under

process

422 Government Land Allotment for Agar Solar Park

Table 42 provides details of the land allotment for the Agar Solar Park which has been undertaken

between Nov 2016 and Jun 2019

Table 42 Dates of Government Land Allotment for Agar Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

28022019 7A-19(3)2017-2018 5633 Bijnakhedi

28022019 6A-19(3)2017-2018 7053 Dudhpura

21062019 31B-1212019-20 1495 Dudhpura

20-06-2019 5A-19(3)2017-18 15925 Karwakhedi

28022019 4A-19(3)2017-2018 283 Kasaidehriya

20062019 3B-1212019-20 19714 Ladwan

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DESK BASED INFORMATION COMPILATION

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

280202019 2A-19(3)2017-18 1683 Madhopur

21012019 1A-19(3)2017-18 3492 Piplya Kumar

04012018 9A-19(3)2017-18 602 Naharkheda

09082018 9A-19(3)2017-18 2669 Naharkheda

30112016 4819(3)2015-16 5562 Palda

02012018 8A-19(3)2017-18 5699 Palda

02012018 11A-19(3)2017-18 16116 Pipliya Nankar

06012018 10A-19(3)2017-18 17663 Umariya

09082018 10A-19(3)2017-18 15583 Umariya

Total 127137

Source RUMSL

127137 Ha is so far allocated to the project over 2016-2019 and 5106 Ha was allocated prior to MP

Revenue Code Amendment Act 2018

423 Government Land Allotment for Shajapur Solar Park

Table 43 provides details of the land allotment for Shajapur Solar Park which took place between May

2017 and Jun 2019

Table 43 Dates of Government Land Allotment for Shajapur Solar Park

Timeline

Allotment Letter

Number

Area

Allotted

Villages

26-05-2017 03A-19(3)2016-2017 14991 Dehripal Parsula Kadula MalyaHedi Burlay Jaawdi

Bhandedi Saagdiya Baandahedi Peepalkheda Dopada

Bijana Kheriyaema Kumhariyakhas Dangicha Jaaman

11-12-2017 26A-19(3)2016-17 618 Dehripal Parsula Favka Jaavdi Burlay Chooma

Bijnakhedi Dhatravada

26-05-2017 02A-19(3)2016-17 320969 Kukdeshwar Baamniyakhedi Bordi Khakri Majhniya

Rehli Rulki Dhanda Pidoniya Goyla Aakya Chauhani

Palsaavad Son Desrapur Khokriya Tonk Hanoti

28-06-2019 03A-19(3)2019-2020 8809 Kukdeshwar Bamniyakhedi Bodi Khakri Majhaniya

Rehli Rulki Tanda Pindoniya Goyla Aakya Chauhani

Palsawaad Son Besrapur Khokriya Tonk Hanoti

Total 117697

Source RUMSL

117697 Ha is allocated to the project over 2017-2019 and 108888 ha was allocated prior to MP

Revenue Code Amendment Act 2018

43 Review of Previous Community Consultations for Allotment of Government Land

The summary of the review of the timeline of the government land allotments in FPIC villages is provided in Table 44

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha Resolution

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Allotment prior to

Nov 2018

Amendment

67819 Ha 5106 Ha 108888 Ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

After Nov 2018

Amendment

28979ha 76077 Ha 8809 Ha

Total government

land in Ha

96894 Ha 127137 Ha 117697 Ha

Was the government

land allotted in FPIC

Villages pre or post

Nov 2018

Amendment in MP

Land Revenue Code

Government land allotted in

Badi and Kawai was prior to

Nov 2018 Amendment in MP

Land Revenue Code

Government land allotted

from Ladwan was on 20th

Jun 2019 which is after

Nov 2018 Amendment in

MP Land Revenue Code

Government land allotted

from Parsula was on 26th

May 2017 and 11th Dec

2017 was prior to Nov

2018 Amendment in MP

Land Revenue Code

Was Gram Sabha

resolution required

for FPIC villages

Yes No Yes

Thus as per legal provision (see section 31) the allocation of government land in BadiKawai from Neemuch Solar Park and Parsula in Shajapur Solar Park required a resolution of their respective Gram Sabha and an NOC by Gram Panchayat ERM did not get access to documentation of community consultation as part of seeking NOC from Gram Panchayats Conversation with Sarpanch of villages with ST population revealed that consultation was restricted to Gram Panchayat members Though they were initially reluctant to sign on the NOC after persuasion of District Collector they finally signed It is significant to note that the demarcation of the allotted land took place only recently (Jun to Aug

2020) and the construction process has not started yet13 The FPIC process in compliance to IFC PS-7 requirement is planned to be carried out prior to the construction works of these Solar Parks

13 The process for purchasing private land through consent process has been started in Neemuch

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

An overview of field visits and community engagement is provided in Section 12 above This section

provides details of the consultation carried out with affected STs in the process of preparation of this

FPIC Approach Paper The process involved following three steps

Step-1 Disclosure of intention of conducting FPIC process with affected STs in villages with

significant ST population

Step-2 Disclosure of final solar park boundary and key environment and social impacts (covered

in ESIA) and Participatory Rural Appraisal exercises with affected STs and meeting potential

representatives

Step-3 Identification of ST Representatives and formation of ST Committees and build mutual

agreement between them and RUMSL on Discussion and Decision Making Framework

The Step-1 was carried out in Dec 2019 and Jan 2020 The Step-2 was carried out in Aug 2020 The

details of the process followed during each of these steps are described in sub-sections below

Note The Step-3 is planned to take place in first week of April 2021 and the Draft Discussion and Decision Making

Framework described in Section 83 will be updated accordingly

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020)

The concerned Gram Panchayats identified with STs Population in previous sections were contacted

to inform them about the overall project and intention to conduct a FPIC process involving affected ST

families along with ESIA process The process included preparing a project profile in Hindi (See

Appendix A-B and photo documentation in Appendix C) and handed this over to the elected

representatives of concerned Gram Panchayats These meetings were attended by local RUMSL

personnel The project overview was explained during the meeting and their queries answered

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 51 below

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Badi 1 Sarpanch of Badi Village

2 Kalam Singh (Traditional Head

of Bhil Community in Mama basti)

3 Government Teacher in Bhil

Community

10-12 men from the village

6-7 women from ST (Bhil)

community

5th of December

2019

Kawai 1 Ghasilal (Ward Member in

Kawai Village)

2 Local communitypeople of

Kawai Village

20-25 persons from Kawai

Village were present

4-5 women

6th of December

2019

512 Disclosure of Intention to Conduct FPIC Agar Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Agar Solar Park

The details of the people contacted during this stage is provided in Table 52

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided-

Number of other community

members present during the

meeting

Date of the

Meeting

Ladwan (two

villages covered-

Ladwan and

Kerwa Khedi)

Mohan Singh (Sarpanch for

both villages)

10 persons in Ladwan and

Kerwa Khedi each

No female members were

present in Kerwa Khedi

In Ladwan seven (7) women

members were present in an

FGD that largely included

women

19th December

2019

Repeat visit on

29th January

2020

513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 53

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park

Name of Gram

Panchayat

Name of Person to whom Project

Information Sheet was Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Parsula Since there was no Sarpanch or

Gram Panchayat member present

during meeting one project

information sheet was provided to the

entire community which was

circulated within everyone present

during the consultation and signature

of 1 person from group (Mr Sujit

Singh) was taken

~15 persons in Parsula

Shajapur were present during

consultation also one separate

consultation was held with

women group having ~10

participants

30th January

2020

One common feedback during the consultations undertaken with the community in general and STs in

particular was they were not aware about the solar park boundary to judge which land will be used by

Solar Park and what will be left out for them The ESIA process was working on avoidance and

minimization measures Therefore they were informed that once the boundaries are fixed by the

design team the details will be shared with them

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises with STs (Aug 2020)

The solar park boundaries were finalized and provided to ERM in the last week of June 2020 by the

design team The draft environment and social impact assessment was completed in the month of

Aug 2020 The field-based activities remained suspended from Mar to Jun 2020 due to strict

restrictions imposed on travel and group activities due to Covid-19 pandemic Therefore the next

round of information disclosure and community consultations took place only in Aug 2020 at the time

of the RAP survey

Meeting Sarpanch and a few available Panchayat members

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village level Introductory amp Project disclosure meeting

PRA exercises with STs and information collection for IPP

- livelihood resource mapping

- mapping of social relations and influence and

- village profile

Identifying prominent persons from STs as potential representatives in FPIC process

Understanding the traditional decision-making system and existence of IPOs through key-

informant interviews

The schedule of field visits carrying out these activities is provided in Table 54 and details of these

activities are provided in subsequent sub-sections

Table 54 Site visit Dates and Site Activities

Solar Prak and FPIC Village

Date Site Activities

Agar Solar Park- Ladwan Village

06082020 Visited Ladwan and contacted Patwari Sarpanch and Panchayat Secretary and Fixed a Project Disclosure Meeting (a common meeting including all communities) for next day

07082020 Village level Project Disclosure Meeting at Ladwan

Participatory social mapping and information collection for IPP

Preliminary discussion with 2 Bhil families

08082020 ERM team met Sarpanch of Parsula to brief him and fix a meeting on 10th Aug

ERM team collected land details and village revenue map from Patwari of Ladwan

Shajapur Solar Park- Parsula Village

10082020 ERM team met Sarpanch and a few Panchayat members at Parsula

Shared Project Disclosure note and fixed a meeting with Bhil households of Parsula on 11th Aug

Mapping of social structure of Parsula village and village profiling

11082020 PRA exercise with Bhil community of Parsula resource mapping at Parsula mapping of social relations and influence

Discussion on impact of the Project on grazing land

Understanding the internal decision-making system amongst Bhil

Identifying prominent persons among Bhil families

12082020 Travelled to Neemuch Site from Agar

Neemuch Solar Park- Badi and Kawai village

13082020 Meeting with Sarpanch Badi and sharing of the Project Disclosure Note with Badi community (including all communities)

Social and resource mapping with Bhils in Badi

Understanding the internal decision-making system among Bhils at Badi

Identifying prominent persons among Bhil families

14082020 PRA at Mama Vasti Badi Resource mapping at Badi and Mama Vasti

Filling of village profile form for Badi and Kawai

Discussion on Impact of the Project on grazing land

Understanding the internal decision-making system at Kawai

Mapping the list of tribal leadership in village

Introductory visit to Kawai and sharing of Project Disclosure Note

15082020 PRA at Kawai with Bhil households

Identification of village leaders for Bhil of Kawai

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village)

5211 Meeting with Sarpanch

ERM team met Sarpanch of Ladwan Gram Panchayat at his residence in Karwakhedi village It was

learnt that Ladwan GP had submitted a letter to District Collector earlier expressing their unwillingness

to give away the government land for Solar Park The key concerns of the villagers included

Whether government has gone ahead on issuing tender for the Solar Park site Especially

without replying to their concerns

Whether the land identified by GP for establishing a Gaushala (shelter for abandon and old cows)

is allotted to the proposed Solar Park

How would the Solar Park address long term un-employment and livelihood issue in the village

ERM informed on its intention to conduct FPIC process covering the ST families in Ladwan village

and some of these questions will be answered during a structured process of discussion

5212 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch

Ladwan consists of two revenue villages Karwakhedi and Ladwan The Gram Panchayat office is at

Ladwan and the current Sarpanch is from Karwakhedi The village is dominated by the Gujjar

Community that is the second largest community in terms of population Scheduled caste is the

largest social group of village comprised of Banchhda Charmkaar Balai and Beldar

A community meeting was held where the Talati (village land revenue officer who keeps the land

records) was present The Talati informed them on the status of land allocation for the Solar Park

ERM showed the map showing the optimised project boundary with khasra numbers of the allotted

land ERM team informed them on the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The community expressed their

key concern about the impact on their livestock which forms an integral part of their livelihood

Community Meeting at Ladwan Explaining potential impacts and benefits

5213 PRA Exercises with STs

ERM held a meeting at a settlement cluster (nai-vasti or new settlement) where STs and SCs lived A

general discussion on their village history and livelihood issues were discussed The participation

level in this discussion was good A cross section of people from various age-groups and gender

participated in this discussion and shared relevant information and expressed their opinion A

separate meeting was held with women too (see Photos below)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

According to the elders of the Bhils their generation is the 9th generation residing in Ladwan village

Prior to the three families (Gujjar Bhil and Charmakaar) establishing this village the village had

Muslim population in medieval times and they deserted the village as some epidemic broke out Three

people from Gujjar Schedule Caste and Bhil community first came from another village and settled in

the village As time passed other families from Banchada-Nat Sondhiya Balai and other started

settling in the village

The discussion also involved their religious and cultural practices and shrines There are three

Chabutarascaffold in the village which are their main place of worship There are two shrines ie

Gowal ka Devta close to the grazing lands and Nagdevta adjacent to the new colony outside the

village

A village corner meeting with men Participation of women in group discussion

The Shrine of Nag Devta at Ladwan Meeting with women at Ladwan

After the general PRA exercise involving a larger group a few active participants were picked up to

have more focused discussion on a few aspects Through participative discussions in these smaller

groups the social hierarchy and livelihood resources used by STs (and SCs living in the village) were

mapped

Creating the map of social hierarchy and influence The map drawn by community showing their

livelihood resources

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Social Groups and Influence Map

Most of the families in Ladwan have cattle that includes cow buffalo and goat Approximately 650 cattle that includes 450 cows and 200 buffalos exists in the village There are about 44 cows kept by Bhil households which is about 4 (on an average) cow per family Bhil households own about 100 goats which is about eight (on an average) goats per family Only one family (Chander Singh) owns two buffaloes Few individuals work as grazier for a cluster of houses and are paid 150 per cattle per month by the owners of cattlersquos The cattle owners hire women and youths for bringing fodder feeding and cleaning of cattle sheds collecting cow dung Payment is done on the monthly basis or the basis of hours of work The common land situated at the Right hand side of the main approach road to Ladwan village from Agar is used by the ST community for grazing their livestock ST families bring fodder firewood and fruits from the same portion This is the only place during rainy season where fodder is available for four months as rest of the area is under crops ST families cannot accesses any other commons which is encroached by the dominant familiescommunity According to the ST community if the village commons is taken by solar park then they do not have any option but to sell their livestock as they cannot afford to buy fodder for the livestock unlike the richer families in the village

Free grazing of a mixed herd of cattle and

buffaloes

A grazier bringing back cattle home at evening

5214 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 55 Names of Potential Representatives in Ladwan Village

Section of Representation Sl No Name of Representative Contact Number

Clan Representative 1 DevSingh-Kanhayialal

2 Mangushanker-Amar Singh

Gujjar

Sondhiya

Other OBC

SC

Bhil

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of Representation Sl No Name of Representative Contact Number

Youth Representatives 3 Babulal-Gangaram

4 Anandilal-Lalsingh

Traditional leader or Mukhia 5 DevSingh-Kanhayialal

522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village)

5221 Meeting with Sarpanch

The ERM team for this field visit was led by the IPs Expert comprised of four members including a

woman to facilitate participation of women The ERM team first met the Sarpanch of Parsula who was

not present in initial meeting held earlier in January 2020 The objective of this meeting with Sarpanch

was to share the project information with him and appraise him of the intention of the ERM team to

hold a meeting and participatory appraisals with ST families

5222 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch The Disclosure note had a map showing the

optimised project boundary with khasra numbers of the acquired land It included the key potential

environment and social impacts and what mitigation measures are proposed in ESIA report prepared

by ERM

5223 Joint Site-visit with Sarpanch and Other Leaders

Sarpanch wanted to visit the proposed project site along with the Patwari to explain him the project

boundary based on the land allotment records available with him ERM team facilitated a site visit by

Sarpanch Naib Sarpanch and Kotwar in presence of Patwari to explain him the proposed project

boundaries He shared his observations and concerns over the allocation for the Solar Park which is

used for grazing domestic livestock by villagers including ST households However he agreed to

facilitate an exclusive meeting with ST families next day

5224 PRA Exercises with STs

The Kotwar of Parsula village belongs to ST community He played a significant role in inviting the ST

families to participate in the meeting as well as shared crucial information on their social and cultural

aspects The meeting with ST families included approximately 40 people both men and women from

various age-groups ERM team showed them the map of Solar Park and explained them locations of

key components The community was divided into two to three groups to hold participatory

assessments

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments

Site visit with Sarpanch and explaining Project boundary

Participatory mapping of livelihood and natural resources within Project boundary

Community meeting with ST from Parsula village at Project site

Identification of a medicinal plant during site walk through

Facilitation of discussions with ST women from Parsula village

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gwalon-Ka- Mandi within Solar Park Boundary

Grazing lands used by Bhils Mapping

Rajputs are the dominant caste in the village and a person from the Rajput community is the Patel

(traditional leader) of Parsula village Rajputs control all village resources including sources of drinking

water and the irrigation

There are four religious places (Devsthan) of Bhils in Parsula village At all these places the priest is

from the Bhil community One platform is situated within the land allocated to the Project which is

called Gwalon ka Mandi It is recognised by all the community as the women worship at this place to

have good rains for better crop yield or agriculture Community gatherings are organized at this place

on few occasions in the year

The Bhil households reported to own about 2-3 (maximum 10) cows on an average per family and

about 2-3 goats Some families manage to sell three to five goats in a year ₹3000 to ₹ 8000 per

goat depending on the quality of the goat Families who rear cows manage to sell about 4 to 6 litre of

milk ₹40 per litre to private dairy at Chouma village The Bhil community uses the lsquoBirdirsquo hillock

adjacent to the northern side of the Parsula village for grazing their livestock along with other

communities residing in the village

5225 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 56 Names of Potential Representatives in Parsula Village

Section of

Representation

Sl No Name of Representative Contact Number

ClanHouse Cluster

Representatives

1 Meherbaan Singh 7970187292

2 Goverdhan Sigh 8718098704

3 Rahul 9098266244

4 Maakan 6162432391

5 Dheeraj Singh 8871384373

6 Rambabu 9752340827

7 Ballu 9399263367

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Sl No Name of Representative Contact Number

8 Bheru 7725027924

Youth Representatives 9 Kamal 6267658647

10 Rajesh 9009278550

Woman Representatives 11 Payal NA

Traditional leader or

Mukhia

12 Bhawanlal NA

523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages)

5231 Meeting with Sarpanch

Gram Panchayat Badi has 3 villages namely Badi Kawai and Sucharoki The ERM team met

Sarpanch of Badi on 13th Aug 2020 and explained the intention of holding meetings with ST families to

inform them about the FPIC process He advised that we should brief the community members on the

current status of the project first As most of the ST families work as wage labour he advised the

team to come early in the morning He assured to inform the ST families and ask them to cooperate

5232 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for a sample

Hindi version and Annexure-D for sample English version) to Sarpanch and other people present in

the meeting The Disclosure note had a map showing the optimised project boundary with khasra

numbers of the acquired land It included the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The meeting was held at the

center of the village

The community believes that Badi village is 1150 years old calculated based on the date inscribed on

a stone slab in the oldest house in the village It is a common belief that Bhil community came to the

village along with Rajputs The living memory of the community members goes at least six

generations back Badi has ~300 households and there are ~80 ST households Rajputs are the most

dominant community in the village Brahmins and Gujjars also influence the decisions of the village

Gujjars are the largest social group of the village followed by Bhils There are around 30 Muslim

families and they also have some influence on decision-making of the village Apart from Gujjar there

are three other OBC groups that are Sutar Kumhar and Nath

The STs live in three separate habitation clusters The first is in the main village habitation second is

roughly around 05 kilometres away and is called Khari ka Jhopda The third is located further away

around 25 kilometres Both are not connected through roads and one has to walk to reach them The

third habitation is further away where a group of recent migrants form Jhabua (referred as Mama Bhils

by villagers) live and is referred as Mama Basti These Bhil families came here to work as labourers in

the stone mines almost two decades back

At Kawai a meeting with village elders was held prior to discussion with ST families Rajput Gujjar

and Dhakad are the three dominant castes There are only 17 Bhil households in Kawai village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village disclosure meeting at Badi Meeting village elders at Kawai

5233 Site-visit and Walkthrough

The ERM team walked through the site to visit different clusters of ST settlements in Badi and Kawai

Some of the photographs of the main village and satellite smaller settlements where STs live is

provided below

A typical ST house in Badi main settlement The Platform where STs hold their community

meeting

The Khari ka Jhopda Mama Vasti

5234 PRA Exercises with STs

As ST households were found scattered in several small satellite settlements multiple meetings were

held involving a small group of 7 to 12 participants Every ST settlement or cluster of households

usually has a platform under a tree which is used for community meetings and decision making This

space was used for holding PRA exercises Participants were engaged in conversation on their social

relationship and decision making process The understanding gained from these discussions were

then demonstrated in diagrams They were asked if the diagram portrays the right picture or not

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Livelihood and resource mapping in Badi A smaller cluster level meeting at Badi

The village livelihood resource mapping- Kawai Participatory process of understanding

livelihood resources in Kawai

The social relationship and influence map for

Kawai

The social relationship and influence map for

Badi

Similarly a map of the village and surrounding area was created using the information shared by

participants in these meetings They were asked to show where they carry out their livelihood

activities such as farming and grazing etc They were asked to indicate those areas and identify

natural resources or cultural sites located in those locations

Some of the information important for deciding on the FPIC approach collected from these participatory

exercises are as follows

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gram Panchayat Badi has total 16 wards out of which Badi has 9 wards Out of these 9 Wards 2

are reserved for the STs (Bhil)

There are about 250-300 cows kept by Bhil households which is about 4 (on an average) cow

per family Bhil households own about 450 goats which is about 5-6 (on an average) goats per

family Hence for ST families goat is a more popular livestock than cows

Almost all the houses have used locally available stone in constructing the walls of the houses

Pucca houses have used cement and sand as mortar whereas kuchha houses have used mud

The communities fear the loss of access to these stones will make house construction costly and

people who earn from stone quarrying will be impacted

The traditional leader (Mukhia) of Bhils decide on disputes related to marriage and other social

issues Women do not play an active role in decision-making process

Each household cluster of Bhil households have a number of cultural sites where local deities are

worshiped For example in Khera-ka Majra has four cultural sites Ghadiya Bheruji Bhut Maharaj

Bhut Babaji and Dungri Balaji Similarly there are a few cultural sites for goddesses like Leva ki

Mata and Dahana Mataji are located within the Project boundary In all these shrines the priests

belong to Bhil community

STs (Bhils) worship Devnarayan Khejara Mata and Sawria jee in Nimbaheda in Rajasthan The

religious leaders from these places are held with respect and are accepted as mediators or

decision makers for important matters

5235 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table 57

They will be considered for nomination to the representative committee and contacted for capacity

building on FPIC process

Table 57 Names of Potential Representatives in Badi and Kawai Village

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Clan Tola

Representative

Badi Main 1 Gheesalal-Nathulal 9575486482

2 Basantilal-Mangilal 7354345531

3 Motilal-Hiralal 9109003022

4 Nanalal-Ratanlal

Khaira Ka Jhopda 5 Lalu ndashRamlal

6 Tulsi-Devilal

7 Tawarlal-Vardaji

Kawai 9 Ramlal-Hajarilal

Ratanlal

Bherulal(Teacher)

Bherulal- Bhawani

Shantilal

Fargulal

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Youth

Representatives

Badi 10 Omkaar ndashKailaji 8718057436

11 Shyamlal-Mangali 9302086906

Mama Vasti 12 Dinesh ndashThawar Singh

13 Prakash-Ramesh

Woman

Representatives

Badi 14 Kesarbai-Devilal

15 Kavita-Dhanraj

Mama Vasti 16 Shanti-Ramesh

17 Mamta -Naklesh

Kawai 18 Sunder Bai-Bherulal

(Sudibai-Devilal Shimla bai-

Chandrulal LeelaBai-

Chittarmal Prem bai-Gopilal)

19 Kanyabai-Bhuvaniram

Traditional leader or

Mukhia

Badi 20 Bhawani-Laxmi

21 Amar singh-Ramlal 7354325923

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL

A key element in designing a FPIC Process is a mutually agreed and appropriate lsquoengagement and

consultation process14rsquo The lsquoFirst Draft FPIC Approach Paperrsquo was prepared and shared with RUMSL

for their review and comment A virtual workshop was held with RUMSL team on 27th Aug 2020 In

this workshop PS-7 requirements of ICP and FPIC in general and the specific FPIC process designed

for Solar Parks was presented and discussed After their feedbacks were incorporated the lsquoDraft

FPIC Approach Paperrsquo was shared with IFC-WB for review and comments

The objective of these internal discussions are to build an internal institutional consensus on the

appropriateness of the designed engagement and consultation process to comply with the

requirements under IFC PS-7 The subsequent steps for consultations with affected STs and finalizing

a mutually agreed lsquoDiscussion and Decision Making Frameworkrsquo is discussed in Section 81

14 GN-ampGN22 emphasizes to have a shared view of the FPIC process between Project proponent and affected IPs The Project

proponent and affected IPs to agree on an appropriate engagement and consultation process as early as possible and commensurate with the scale of impact and vulnerability of the communities

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INDEPENDENT FACILITATOR AGENCY

6 INDEPENDENT FACILITATOR AGENCY

61 Need for FPIC Process Facilitation Agency

An independent agencyexpert to facilitate the FPIC process is required for the following reasons

There is a strong likelihood of other dominant communities in the village intervening and trying to

influence the internal discussion and decision making by IP The presence of the FA will help

documenting such attempts of external intervention and the presence of the FA may act as

deterrence and help avoid such attempts to interfereinfluence the process

The IP representatives need an intensive process of orientation and capacity building It will be

more effective if this is conducted using the Malvi dialect instead of Hindi Therefore a good

community facilitator with familiarity on Malvi dialect will be helpful

The women and youth will need capacity building and facilitation of their internal discussions prior

to the community level meetings

The facilitation support to IP community in general and IP representatives in particular will require

proficiency in the local dialect Malvi and knowledge of local livelihoods and alternative options

Involvement of a local agencyexpert who also speaks the local dialect and with a good

understanding of local livelihoods (particularly grazing and livestock keeping) will demonstrate

fairness and transparency in the process

62 Screening of FPIC Process Facilitation Agency

ERM identified Institutions (Universities Government Departments and Research Institutes etc)

NGOs and INGOs located and active in Madhya Pradesh state After a preliminary screening selected

potential individualsorganizations were approached to find out their availability and willingness for the

assignment The criteria used for screening included qualification profile affiliation with the type of

institutionsorganizations nature of worksprojects completed working experience with IPsTribes in

Madhya Pradesh conducting meaningful consultation community mobilization and stakeholder

engagement familiarity with World Bank Group safeguardsrsquo policies and procedures comfort with

written and spoken English and local dialects etc The list of independent experts and organizations

screened for the role of facilitation agency is provided in Table 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

1 University of MP Bhopal

Department of Sociology

Dr Arvind Chauhan

Professoramp Head

7999345226

Two candidates with post-PhD and PhD

qualifications from Department of

Sociology interested in working but having

no experience were not considered

2 Dr BR Ambedkar

University MHOW MP

Professor RD Maurya

Former Dean amp Head

Department of Sociology

Old AB Road Gram

Dongargaon Dr

Ambedkar Nagar Madhya

Pradesh 453441

07324 274 377

The retired Professor amp Dean

recommended a college lecturer

belonging to BhilIP from Govt college

Neemuch may be considered as a

resource person in future as appropriate

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

3 Tribal Research and

Development Institute

Bhopal

Rita Singh

35 Shyamla Hills Rd

Bhopal Madhya Pradesh

0755-25570882551257

This institute of MP government is

involved in administration and research

aspects of tribes in Madhya Pradesh

There are full time staff and the person

required for the assignment is not

available However the Government

functionaries may be the resource persons

in sharing information and performing

advisory roles during implementation as

appropriate

4 Institute of Social

Sciences Ujjain

Dr Tapas Faculty

7342510978

Berasiya Rd Navi Bagh

Bhopal Madhya Pradesh

462038

0755 273 0946

The faculty suggested to contact the

Bhopal based NGO (Samarthan)

5 The Samarthan NGO

Bhopal

Shradha kumar

Bhopal Madhya Pradesh

shrdhasrigmailcom

9826912948

The Program Director reported no work

being undertaken by the NGO in proposed

project area and was reluctant to

undertake the assignment She however

mentioned to help coordinating with the

local NGO if available in Neemuch area

and has not responded so far

6 Xavier Institute of

Development and Action

and Studies Jabalpur

Dr Mehul Chauhan

Former Faculty

9977064882

The former faculty suggested two NGOs

(Concept Society and Gramodyog

Sansthan)

7 The Concept Society

Indore

Ms Hemal Kamat Director

9425350272

The candidate appeared for interview has

preferred to be engaged independently

instead of as a NGO

8 Gramodyog Sansthan

Mandala MP

Mr Hariom Shukla

Manager

7999064147

Even after agreeing no one finally

appeared for personal discussion and

interview

9 Balram Sewa Samaj

Neemuch

Mr Kamla Shankar

Manager

7838960968

The only NGO reported to working on

legal aspects in Neemuch area has not

expressed interest to work as FA

10 UNICEF office Bhopal Nagesh Patidar Project

Officer WASH

97525 98212

The staff of UNICEF suggested the name

of suitable candidates and all of them

have appeared for interview and have

expressed the interest in proposed project

work

11 Debate Trust (Referred

by Action Aid Bhopal

Amitav Singh and Leena

Singh

Debate Trust

Duplex C-22 Alkapuri

Near DRM Office

Habibganj Bhopal-462024

Action Aid India had prepared a brief

manual on FPIC (published in 3 Indian

Languages including Hindi in 2018)

reflecting the Indian context and its related

legal system The manual was intended to

help CSOs for their ready reference and

larger reach out Mr Narendra Sharma

who was based in Actionaidrsquos office at

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

0755-2985007 0755-

2417656 9425018144

9425004556

debateindiagmailcom

Bhopal played a key role in preparing the

Manual in Hindi version

Mr Narendra Sharma referred the NGO

Debate Trust who had experiences in

working with Panchayats

A screening using preferred criteria was undertaken of the shortlisted agencies and details are

available in Appendix-F None of these agenciesindividuals have worked for a FPIC process earlier

Hence an agency which was available and willing to undertake the activity was taken on a trial basis

to help in conducting PRA exercises and sample household survey required for preparation of IPP

63 Roles and Responsibility for FPIC Process Facilitation Agency

The role and responsibilities of the FPIC FA will be as follows

Table 62 Roles and Responsibilities of FPIC FA

Phase Responsibilities

I Formation of local committees with STs Representatives

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Hindi (Malwi dialect) Translation of TDPIPP and designing Information sharing tools

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs (particularly women and youth groups) and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation of the FPIC Process and Preparation of FPIC Process Report

Documents of outcome of the FPIC Process including FPIC AgreementMOUJoint Statement of PrinciplesAgreed Mitigation Plans etc

64 Terms of Reference for FPIC FA

The terms of reference for FPIC FA covering villages to be covered specific responsibilities

deliverables personnel requirement and organizational profile and experience is provided in

Appendix-G

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The PS-7 recommends to have a lsquoshared view15 of achieving ICP or FPICrsquo mutually agreed ldquoFPIC

Decision Process Framework Documentrdquo which is based on principles of Good Faith Negotiation

(GFN) The Designing a lsquodiscussion and decision making frameworkrsquo to achieve the FPIC as per GN

on PS-7 should considers the socio-political context within which the affected IPs households live as

well as impacts of the Project This section deals with key-elements considered for designing the

FPIC process as per requirements in IFC PS-7 and GN-7

71 Use of Language

The PS-7 emphasizes use of the IPs language in the FPIC process It was found that BhilsBhilala in

Ladwan and Parsula are relatively small community and they have been living with close socio-

cultural ties with other communities Hence they use Bhilli (their traditional language) very little The

proficiency of the current generation in the Bhilli vocabulary is too limited to use this in discussion of

the Project and its impact Hence their preference is the use of local (Malvi) dialect of Hindi which

they speak along with other communities in the village The Bhils in Badi and Kawai speak Malvi

dialect with some influence of Rajasthani language as it is at the border of Madhya Pradesh and

Rajasthan

In general the written material on the project is expected to be in Devnagri script using the vocabulary

consistent with Malvi dialect to the extent possible The FPIC FA will have community facilitator who

is conversant with Malvi and explain the written material using the conversational Malvi dialect

72 Use of Customary Decision Making Process and Traditional Leaders

The Bhils in Ladwan reported that they resolve disputes between families through intervention of the

elderly member of the familyclan (Baijwal and Dalodia) or go to other prominent people in the village

such as the priest in the local temple or the landlord on whose land they work The customary leader

of Bhils who covered a cluster (~10 to 12) of Bhil settlements existed earlier (at least 3 generations

back) and the current generation has not sought their help in dispute resolution in their living

memory

The BhilBhilala of Parsula belong to a number of clans (Dalodia Paretia Renkewal Vasunia etc)

and the elder member of the clan is usually approached to resolve any internal disputes There used

to be a collective council (panchayat) covering 5 to 10 villages but these have been non-functional

over the years They also approach the village Sarpanch and prominent personalities from other

communities in the village to resolve disputes involving land and livestock The matters related to land

are finally referred to the Tehsildar (land revenue officer) for resolution The local administration also

plays a significant role in resolving inter-community disputes

In Badi-Kawai they still have a traditional Mukhia (leader) who wields influence in community

matters Each Bhil village has an elder who is considered the mukhia or leader There are designated

places where elders hold community meetings to discuss conflicts among Bhils and matters related to

their social norms and customary laws governing marriage and inheritance etc If matters are not

resolved at the village level community elders (Biradari Panchayat) then the matter is escalated to a

forum of community elders from 5 or 10 villages with Bhil population The highest level of escalation in

the customary decision making system is to refer the matter to a Biradari Panchayat of community

elders from 25 Bhil villages16 These traditional leaders residing outside of the villages directly

impacted by the Project are accommodated as member of the proposed Mediation Committee

15 Refer GN-7 GN22 which mentions that lsquothis should ideally be done through a framework document or plan and client should

document support for the agreed process from the affected population 16 GN-7GN36(i) acknowledges that there may be circumstances where formal and informal leaders of the Indigenous Peoples

reside outside of the Projectrsquos area of influence

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

In general the affected IPs communities use familyclan elders to resolve minor disputes and involve

prominent people from other communities like the priest Sarpanch or other prominent personalities in

the village for resolving their conflicts The matters related to land is resolved by intervention from

local administration (Tehsildar and District Collector) If the matters are related to their customary laws

on marriage social relationship or inheritance the unresolved matters can be escalated to a council

that comprises of elders from 5 10 or 25 villages The traditional Biradari Panchayat has been losing

its power as the younger community members considers their decisions regressive and approach

Gram Panchayat leaders (Sarpanch) or take help from the Police and Court of law Considering the

preference of new generation to go to non-ST Gram Panchayat leaders and local administration they

are considered for the Mediation Committee

73 Promoting Participation of Women and Youths

Women specifically stated during consultation that they do not participate in decision making in their

traditional community meetings which are convened for resolving disputes Though the women come

to attend the community meetings they hardly ever participate and express their views

The BhilBhilala youths do not have traditional or customary forums at which they express their views

They accept the decisions taken in the family or at the clan-level However there are a few educated

young people in the village who have distinct views about their future

As free expression of the views by youths and women in BhilBhilala community meetings is not a

social norm separate meetings of these groups where they are able to express their views openly is

proposed as part of their internal decision making process The FPIC FA will facilitate these separate

meetings and keep external interventions in these meetings to the minimum The views expressed by

them in these meetings should be tabled in joint meetings of the community for consideration

74 Expectation on Material Information Prior to Discussion

It is understood from the preliminary round of discussions with ST communities that they expect the

following information to be shared with them

Details of the Project (lay-out plan) and the related activities that are going to be implemented

Schedule of starting of the possession of allotted government land and purchase of pattaprivate

land

Details of land khasra numbers proposed to be taken for the project

Amount of paymentcompensation consideration amount of the land and assets (including on the

government land) that will be taken by the project

What economic and other entitlements and benefits will be provided to the families dependent on

the allotted government land

If private land is purchased then they will lose the source of income generation or livelihood (as

they are hired for a year on contract basis daily wages take land on lease for cultivation and

take care of the cattlersquos etc) what will their entitlements (economic package) be

What options will the Government or the Solar Park Company provide as alternative to the

common grazing land as cattle and goat breeds they keep require free open grazing and not stall

feeding

What alternative livelihoods will be offered to those Bhil families who will be landless after losing

the governmentpatta land they currently use (though owned by others)

It was expressed that the Project proponents share many documents but the community wants

confirmation that the content is authentic Hence community expects that signed and verified

documents should be shared as part of the FPIC process which can be referred in case of conflict or

contradiction

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 68

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The relevant information is scattered in ESIA RAP and IPPIPDP A concise information disclosure

dossier will be prepared by ERM and used by FA during the FPIC process

75 Need for Capacity Building of IP Representatives

The interaction with potential ST representatives from these FPIC villages shows that convening a

community meeting and steering the internal discussion to reach consensus will be a new experience

for them Most of them are semi-literate and will face challenges in understanding the Project details

on their own such that they can then explain it to other community members Therefore following

activities are required

A capacity building workshop for the potential IP representatives to explain the Project its impact

and mitigation measures in the Draft IPPIPDPTDP in detail Although the RAP-LRP disclosure

will happen at the community level and ST families will attend those meetings the Draft

IPPIPDPTDP will also explain these entitlementsbenefits in simple language

Presence of experienced community meeting facilitators (from FPIC FA) for community meetings

will help these ST representatives to have focused discussions documentation of views

expressed and decisions made in those meetings

The women and youths usually do not participate in taking decisions on community issues

Hence the women and youth representatives need orientation through separate sessions

In addition to formal trainingorientation sessions the IP representatives may be taken on

exposure visits to nearby solar parks for improving their understanding

76 Need for a Mediation Mechanism

The ST Committee will hold meetings with the representatives of the Project (RUMSL) to discuss

relevant points and reach a mutual agreement While such discussions are likely to result in reaching

mutual agreements on a number of agenda items the discussions may hit dead-end on some issues

All such unresolved issues will be documented as a dissent note for their reconsideration in the second

round of meeting

If the discussion between ST Committee and the representatives of the Project on any significant issue

reaches a deadlock the matter will be referred to a mediation mechanism The mediation will be done

by a high level committee which will comprise of 4 members

An IP representative nominated from the larger tribal leadership of the area (from their customary

council of 10 or 25 villages) but not belonging to the Project village

The elected representative of the concerned Gram Panchayat or a person nominated from GP

and acceptable to the ST Committee

A senior officer from the District Tribal Welfare Department

District Collector or an officer nominated by them

This Mediation Committee will be constituted at the beginning of the FPIC process and will be activated

only in the case of a significant deadlock This Mediation Committee will be involved to read the Final

FPIC Agreement (even when no matter is referred to them for mediation) and satisfy themselves that it

reflects mutual agreements reached through a fair and credible process17

17 This is proposed in order to provide an external validation of a free and fair FPIC process prior to signing of the FPIC

Agreement

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

77 Following Principles of Good Faith Negotiation

Good faith negotiation generally involves 6 principles (see Table 71) The proposed FPIC Discussion

and Decision Making Framework (DDMF) adheres to these principles with slight modifications

keeping the public health concerns associated with the Covid-19 pandemic

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

1 Willingness to engage in

a process and availability

to meet at reasonable

times and frequency

Both parties need to agree to avoid large gatherings and un-necessary

physical meetings A mechanism for tele-consultations will be explored to

keep the physical meetings to the minimum

The internal discussion meetings of STs will be in smaller groups (in the

open rather than in closed rooms) to avoid large gatherings

There will be two meetings between RUMSL and ST Committee and

similarly number of proceedings by Mediation Committee will be limited

The meeting schedules will be finalized beforehand and Covid-19 public

health protocols as applicable at that time will be followed

2 Provision of information

necessary for informed

negotiation

The basic information on the Project and its potential environment and

social impacts are already provided in state language (Hindi)

The essential information requirement by ST Committee is identified and

these information will be provided in simple information dissemination

tools The FA will further explain them for their better understanding

3 Exploration of key issues

of importance

The likely key issues of importance are grazing and cultural sites located

within Solar Park boundary A small task-force comprising of

representatives of RUMSL as well as ST Committee will carry out a field

inspection prior to their first meeting The task force will observe Covid-

19 protocols issued by Government

4 Mutual acceptable

procedures for the

negotiation

The lsquoDiscussion and Decision Making Frameworkrsquo signed by both parties

will have a commitment to hold all meetings and activities complying the

Covid-19 protocols and advisory issued by Government

5 Willingness to change

initial position and modify

offers where possible

The first meeting will resolve issues where both parties can reach

agreement easily The positions of both parties on contentious issues will

be recorded during first meeting The FPIC FA will record the written

positions of both parties on these contentious issues and share with

them The FPIC FA and ERM will hold separate meetings with both ST

Committee and RUMSL Team after 15 days to understand any changes

in the stated position The FPIC FA and ERM will take a decision on

holding the second and final meeting on these contentious issues when

both parties agree to modify their offers and a meaningful discussion is

possible

6 Provision for sufficient

time for decision making

The ST Committee will benefit from the capacity building and assistance

through FPIC FA to conclude their internal decision making The first

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

meeting between ST Committee and RUMSL Team will be held after a

sufficient gap As the number of ST families participating in the FPIC

Process is small it is expected that it will not take them long to reach

internal consensus However STs will be encouraged to have more

meetings internally to be able to discuss within themselves

78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and Supportive Environment

In these FPIC villages the Project requires to achieve both ICP for mainstream communities and

FPIC for ST The existing and past relationship between RUMSL and affected communities plays a

significant role in FPIC process It is learnt from the news report as well as from consultations that

some villages (particularly Ladwan) have decided to protest against the Solar Park as loss of grazing

land is not acceptable to them The protesters had organised a demonstration and also submitted

letters to the District Collector regarding their objections Ladwan village has a strong network of

women self-help groups (SHGs) who are interested in a dairy development program Thus reduction

in grazing land is perceived by them to have a detrimental impact on their long term employment

opportunity and income generation These SHGs have members from SC OBC as well as ST

families

In other FPIC villages ie Parsula Badi and Kawai though there is a concern for loss of grazing

land yet opposition to Solar Parks is passive There are some specific interest groups among the

non-ST communities who would seek answers to their specific concerns For example in Parsula

village the non-ST families (both in Parsula as well as neighbouring villages) have informally

purchased the patta land Their main concern is whether and how they get the compensation for

these land parcels which will be paid to patta owners In Badi and Kawai the number of people who

have encroached on the government land is comparatively more Also there are few influential

people who earn from selling stones (the most popular building material in that area) extracted from

the allotted government land Thus a range of RAP-LRP issues are expected to crop up during

community engagement In all these villages the affected ST communities though would consider

the compensation and benefits offered to them yet it would be difficult for them to disregard the

collective decisions made by other communities in their village

Thus considering different interest groups involved existing social relationship influence of STs in

decision making it would be a challenge to hold a single engagement process18 for both STs and

mainstream communities Therefore we recommend a parallel or concurrent engagement process for

ST and mainstream (non-ST) communities The comparison of the ICP process for mainstream (non-

ST) and FPIC process for ST is provided in Table 72

18 GN-7 GN31 recommends a single engagement process complying to the higher standard (GFN and FPIC Agreement) where

a Project requires to achieve ICP for mainstream and FPIC for IP It reads ldquoSince the achievement of ICP and FPIC as separate processes with different groups within a community or between proximate communities may be difficult and in some cases be a cause of division within the community a single engagement process resulting in one agreement is generally recommended In such cases the process and agreement should reference the higher standard (ie GFN and agreement demonstrating FPIC) Whether the agreement entails different benefits for the differently affected groups will depend on the project context the Affected Communities and the nature of project impactsrdquo

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages

Aspect Engagement Process with non-ST

(ICP)

Engagement Process with ST (FPIC)

Management Plan ESMP + RAP-LRP IPPIPDPTDP

Representative

Body

Gram Panchayat (existing body) ST Committee (specifically constituted for

this process)

Provision of

information

necessary for

informed

negotiation

Executive summary of Draft ESMP

RAP-LRP in Hindi

Abridged Draft IPPIPDPTDP in Hindi (use

of Malwi vocabulary as much as possible)

Capacity building by FPIC FA

Help from FPIC FA to understand issues

Willingness to

engage in a

process and

availability to meet

at reasonable times

and frequency

One public meeting for receiving

feedback on Draft ESMP RAP-LRP

One round of internal discussion by STs

assisted by FPIC FA

Two rounds of meetings between RUMSL

and ST Committee

Mediation Committee meetings (if required)

Exploration of key

issues of

importance

Key issues covered in ESIA RAP-LRP

will be discussed

Key issues covered in Draft IPPIPDPTDP

will be discussed

Mutual acceptable

procedures for the

negotiation

Informal agreement A formal lsquoDiscussion and Decision Making

Framework Agreementrsquo is signed by both

parties

Willingness to

change initial

position and modify

offers where

possible

Demonstrated through incorporations of

feedbacks received from public

disclosure and consultation

Structured engagement process

documenting (signed by both parties at the

end of the meeting) points agreeddisagreed

and demonstrating the flexibility in their

respective positions

Provision for

sufficient time for

decision making

The time for public meeting for

receiving feedback will be decided in

consultation with Gram Panchayat

Sufficient time for capacity building by FPIC

FA internal discussions and gap between

first and second meeting between RUMSL

and ST Committee

Outcome The public meeting for receiving

feedback on Draft ESMP RAP-LRP is

held peacefully and satisfactory

explanationresponse to

feedbackqueries is provided

Incorporating response to all key issues

raised in public meeting in Final ESMP

RAP-LRP

The Final IPPIPDPTDP incorporates points

mutually agreed between RUMSL and ST

Committee

The FPIC Process Documentation Report-

(vetted by independent FPIC FA and

Mediation Committee) provides an overview

of the FPIC process

FPIC Agreement signed by RUMSL and ST

Committee

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Note The FPIC Process Documentation Report prepared by FA under ERM guidance will cover the

whole process (including all meetings by ST and Non-STs decisions key issues discussed etc)

The use of impacted land for free grazing is practiced by both ST and Non-ST communities The ESIA

and RAP-LRP also address impacts on grazing and have prepared a framework for Grazing Resource

Management Plan The engagement with non-ST population will highlight the mitigation measures

with regard to grazing issue (particularly Grazing Resource Management Plan) in ESIA and RAP-

LRP The feedback from non-ST population on mitigation of impact on grazing will be subsequently

incorporated into Grazing Resource Management Plan in particular and relevant sections in ESIA and

RAP-LRP The non-ST population will be clarified that TDP will have some additional benefit for STs

and therefore will be consulted separately

Thus the separate ST committees will not be perceived to take any decision that affects collective

interest of all villagers particularly the powerful non-ST communities The Gram Panchayat and

Sarpanch is provided a place in Mediation Committee and will be involved in resolving key-issues

referred to them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

81 Introduction

This lsquoDraft Discussion and Decision Making Framework19rsquo is prepared after field visits and

consultations with affected STs and a workshop with RUMSL (see Section-5 for details) This Draft

DDMF will be shared with ST Committees on behalf of RUMSL and after appropriate modifications

(without diluting the key-elements for compliance to PS-7 requirements) the final version will be

signed by representatives of both parties Section 814 provides subsequent steps in this regard

The three proposed solar parks are located in three different Districts and each one will have an

independent Solar Park Developer (SPD) or Concessionaire The impact of each solar park and the

social context of the affected STs also differ in these three locations Hence three ESIA reports as

well as three IPPIPDPTDP are prepared The Draft IPPIPDPTDP prepared for each Solar Park has

a specific package of benefits for the STs in FPIC villages This will be discussed during the proposed

FPIC process and the outcome of this process will be a written lsquoFPIC Agreementrsquo that adopts the Draft

IPPIPDPTDP and agrees to cooperate in its implementation

82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo

The subsequent steps for discussing this Draft Discussion and Decision Making Framework with STs

in the selected FPIC villages (grouped at each Solar Park level) is discussed in this section

821 Appointment of FPIC Facilitation Agency and Orientation

The requirement of a FPIC Facilitation Agency (FA) and their roles and responsibilities are discussed

in Section-6 above The FA will play a key role in forming the ST Committees (at each Solar Park

level) and informing them on their rights to FPIC their legal rights on natural resources prior to their

acceptance of this lsquoDraft Discussion and Decision Making Frameworkrsquo Hence one of the agencies

screened for this role will be appointed and brought on board

After on-boarding them ERM will carry out their orientation by holding a series of virtual workshops with

them The orientation program will include the following

The ICP and FPIC requirements as per IFC PS-7 and WB OP 410

Key findings of the ESIA-ESMP including Draft RAP-LRP

An overview of consultations in FPIC Villages

The Draft IPPIPDPTDPs

The Draft Discussion and Decision Making Framework

The Capacity Building of ST Committees on FPIC and their customary rights on natural

resources

822 Introducing FPIC FA to RUMSL and FPIC Villages

After the orientation of the FPIC FA the key persons will be introduced to the RUMSL team through a

physical meeting Subsequently a field trip will be planned to introduce the FPIC FA in FPIC villages

The RUMSL and ERM will introduce the FPIC FA to the contact persons from earlier field visits and

inform them about their role

19 The term lsquoengagementrsquo and lsquonegotiationrsquo was avoided to keep the language less confrontational and positive for both parties

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

823 Formation of ST Committees

ERM and FPIC FA will jointly discuss the structure and composition of the ST Committee at each

Solar Park20 with affected ST community As per suggestions from them ST Committees will be

formed and their nominations will be ratified through a group meeting21 The composition of the ST

Committee is described further in Section 8311 below

824 Capacity Building of ST Committees

The FPIC FA will discuss with the ST Committee on the time and venue for holding a capacity building

workshop The capacity building workshop will cover the following

The recognition of FPIC as their rights

Specific provisions of FPIC as per IFC PS-7 and WB OP 410

Applicable India Laws and recognition of their customary rights on natural resources

The Draft Discussion and Decision Making Framework (Draft DDMF)

The participation of RUMSL in this capacity building workshop will be optional and as per mutual

agreement by both parties The FPIC-FA will note down the suggestions of the ST Committee on the

Draft DDMF and share them with RUMSL

83 The Draft Discussion amp Decision Making Framework

The proposed discussion (engagement) and negotiation (decision making) framework will include 11

steps as illustrated in the Figure 81 below

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process

These steps are described in sections below

20 Agar and Shajapur Solar Park have only one FPIC village Hence the ST Committee will be selected from within the same

village Neemuch Solar Park has two FPIC village with several satellite ST habitations The ST Committee for Neemuch Solar Park will be larger to accommodate representation of different ST groups 21 The FPIC village level group meetings will be held keeping the Covid-19 public health guideline ERM will use professional

judgement on the acceptability of the selected committee for most ST households if the ratification of the ST Committee is not possible by a large public meeting

Formation of Committees

Acceptance of Draft Discussion and Decision Making

Framework

Disclosure of Draft IPP to ST Committee

Explaining Draft IPP to ST Committee

Internal Consultations by ST Committee

First RUMS and ST Committee Discussion

Second RUMSL and ST Committee Discussions

Reference to Mediation Committee

(if any)

Informing Community about Draft FPIC

Agreement

Final Community Meeting for Expression

of ConsentDissent

FPIC Agreement Signing

FPIC Process Documentation Report

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

831 Formation of Committees

The FPIC process will involve three committees for each Solar Park One representing the affected

ST community the other presenting the Project proponent (RUMSL) and the third a committee to

mediate between the two if the need be The composition of these committees are explained in sub-

sections below

8311 Formation of ST Committee for each Solar Park

Each Solar Park will have a ST Committee which includes representatives from all FPIC villages of

that Solar Park Each ST Committee will comprise of 7 to 13 members (or any odd number22) who

represent different sections of the ST community The principle for selecting the members of this ST

Committee will be as follows

One representative from each clanhabitation cluster (tola)

The clans which have more population may select 2 representatives

Two representatives from youths (18-25 years)

Two women representatives

One traditional leader (Mukhia) or ST community head from each FPIC village

Gowal (cow-herder) who takes othersrsquo cattle for grazing and earns livelihood from this

The ST Committee will select a chairperson to coordinate and conduct their internal meetings The

representative from the youth and women will hold separate group discussions within their sub-groups

and share their concerns preference and feedback The FPIC FA facilitating these internal meetings

will ensure that these points are tabled at the joint committee meetings The ST Committee will

prepare a list of households and the adult members (gt18 years) who will be part of the FPIC process

8312 Formation of RUMSL Teams

RUMSL will form three site level teams (one for each Solar Park) which will include the District

Renewable Energy Officer (DREO) of the concerned district and a staff member to assist him They

will report to RUMSL Managing Director (MD) The names and designation of the RUMSL Team are

as follows

Level Designation Name Contact Number

Head office MDCEO Deepak Saxena

Social Development

Specialist

TBD

Site Level (Agar) DREO Deepak Bulani +91-9229924836

DREO- Staff TBD

Site Level (Shajapur) DREO- Prakash Salunke +91- 9926440877

DREO- Staff

Site Level (Neemuch) DREO- Sohanlal Bajaj +91-9827222217

DREO- Staff Balaram Rathod +91-9827323612

22 To avoid a deadlock on decisions

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The site level RUMSL Team will attend the meetings with ST Committee discuss the issues raised by

them sign on minutes of meetings and report to MD where prior approval is necessary The MD or

his authorised representative will take part in important meetings including meetings with the

Mediation Committee if required

8313 Formation of Mediation Committee

There will be a Mediation Committee for each Solar Park The Mediation Committee will comprise of

three members which will be chaired by the District Collector

Member Selection Process

STs Representative from the

Area Biradari Panchayat

The ST Committee after internal discussion will nominate a prominent person of their community outside of their village who is accepted as a member of Biradari Panchayat or similar bodies

Member from Gram

Panchayat

The ST Committee will nominate a member (or ex-GP member) who is known for his role in resolving local disputes

District Tribal Welfare

Department

A senior Tribal Welfare officer will be nominated by District Collector or the Head of Department of Tribal Welfare

District Collector (or his

representative)

The District Collector of the district within which the particular solar

If District Collector is not available she should decide on who can act as his representative

The ERM FPIC-FA ST Committee and RUMSL Team jointly visit these MC members and brief them

on their role in FPIC Process The formation of the MC should be completed prior to the first meeting

between ST Committee and RUMSL Team

832 Acceptance of Draft Discussion and Decision Framework

After the capacity building of ST Committees FPIC FAERM will coordinate with both parties to fix a

date and time for a joint meeting to discuss the Draft Discussion and Decision Making Framework and

ratify it after making necessary modifications

The composition of the committees mentioned in Section 831 and the steps mentioned in Figure 81

will be explained to ST Committee during their capacity building process (described in Section 824)

A Hindi (with Malwi words used to the extent possible) version of the lsquoDraft Discussion and Decision

Frameworkrsquo (Section 83) will be provided to ST Committee during the capacity building Thus the

affected IPs will get adequate time to discuss and come prepared for any suggestions from their side

to this meeting The

Both parties will discuss on a code of conduct commit to follow this during their meetings The code of

conduct will be based on following principles of good faith negotiation

(i) both parties will be available to meet at reasonable time and frequency

(ii) both parties to share information23 necessary for informed negotiation

(iii) both parties will be willing to change initial position and modify offers where possible

23 The Project will disclose information as per Information Disclosure Plan discussed in Section 513 of the Draft

IPPIPDPTDP The disclosure will include at minimum (i) project boundary (ii) impacts of the project (iii) entitlements and other benefits The information will be shared in a culturally appropriate manner and in a form and language easily understandable to the ST communities The FPIC FA will help the ST community understand and process this information prior to the joint meetings with RUMSL

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 77

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

(iv) both parties will give each other reasonable time24 for decision making

(v) both parties will put their view peacefully and will not resort to violence and threat and

(vi) both parties will not engage in discussion when they are under influence of any intoxicants

Both parties will discuss and agree on the quorum required for their meetings and how proceedings of

their meetings will be documented Some suggestions for discussion in this regard are

(i) The quorum for the meeting to be physical presence (or virtual participation) of at least 75 of

the ST Committee and RUMSL Team The FPIC FA will check the quorum of the meeting prior

to starting the proceedings

(ii) The Documentation Assistant in FPIC FA will have the responsibility to record the audiovidoe

of the meeting proceedings

(iii) The FPIC FA will write down the key decisions taken during the discussion and the MoMs will

be read out prior to taking their signature

(iv) The FPIC FA will ensure that ST Committee and RUMSL Team understand the decisions made

If any party express that they need more time (to discuss internally or take approvals) such

information will be recorded

(v) The FPIC FA will also document any dissent expressed by any individual member while

supporting the collective decision of the group she represent in the MoM

The agreed Discussion and Decision Making Framework will have a target time-frameschedule for

completion of each step in the FPIC process Both parties will put their best efforts to complete the

process within t(his time-frame ERM will keep a track of the progress of FPIC process as per this

time-frame and help both parties to avoid unnecessary delays FA will draft the Agreement on Final

Discussion and Decision Making Framework (in Hindi) in consultation with RUMSL and ST

Committee

The final (after ratification) lsquoDiscussion and Decision-making Frameworkrsquo the FPIC-FA will hand over a

signed copy to both parties (ST Committee and RUMSL Team) A pamphlet or poster on accepted

code of conduct will be prepared and displayed at the meeting venue FPIC-FA will request all

members attending the meeting to follow these rules

833 Disclosure of Draft IPPIPDP to ST Committee

ERM will prepare Draft IPPIPDPTDP (in English) for each Solar Park A Summary Draft IPPIPDPTDP

will be translated to Hindi (with use of Malwi as much as possible) ERM will share following documents

to both parties as soon as they ratify the lsquoDiscussion and Decision Making Frameworkrsquo

The Draft IPPIPDPTDP (in English)

Summary Draft IPPIPDPTDP25 (in Hindi)

A simple 4-6 page brochure describing (illustrations where possible) the benefit package

proposed in Draft IPPIPDPTDP

The ST Committee members will be given one week to go through the documents shared with them

and fix a date to explain the Draft IPPIPDPTDP Report

The RUMSL will be provided soft copies of these documents to upload them in their web-site from

where external stakeholders can access these documents

24 The time provided should be adequate to read verify and consult (internally or any external expert on the subject matter)

The FPIC-FA will consult both parties to decide what is reasonable and acceptable to both 25 The Summary Draft IPPIPDPTDP will be 20-25 page It will follow the structure of the IPPIPDPTDP but provide a non-

technical description of the content for easy understanding by ST Committee

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 78

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

834 Explaining Draft IPPIPDPTDP to ST Committee

ERM and the FPIC-FA will organize a workshop for ST Committee of each Solar Park at a suitable

location on an agreed date (at least after 7 days from sharing of the documents with ST Committee

The workshop will explain the impacts of the Solar Park and the range of mitigation measures and

project benefits mentioned therein

The FPIC-FA will orient them on how to hold consultations with different sections within their

community and document their views The ST Committee will be provided adequate copies of the

brochure describing the benefit package project boundary maps (in large flex prints) to help them

explain the Solar Project to their community members and hold internal discussions

ERMFPIC-FA will consult ST Committee and RUMSL Team to fix the date for first meeting between

RUMSL and ST Committee

835 Internal Consultation Process by ST Committee

FPIC-FA will help each ST Committee to prepare a tentative schedule for internal discussions The

women representatives will hold meetings with women and youths representatives will hold meetings

among young people The FPIC-FA will make itself available to facilitate and document these internal

meetings

After a round of internal discussion of each sub-group the ST Committee will have the final meeting

to discuss the comments and concerns raised by different sub-groups of the community The ST

Committee will finalize a list of issuesdemands for further discussion with RUMSL The FPIC-FA

prepare the Agenda for First RUMSL-ST Committee Meeting and share it with RUMSL at least a week

before the meeting

The Agenda of the first RUMSL and ST Committee will be shared with the Mediation Committee to

keep them informed about the initiation of discussion between both parties

836 First RUMSL and ST Committee Meeting

The FPIC-FAERM will confirm the quorum prior to starting the proceedings The points mentioned in

the Agenda circulated earlier will be taken up for discussion The RUMSL Team will respond on these

pointsissues The ST Committee will consider these responses and decide if they are satisfied Once

the discussion is concluded the FPIC-FA will write-down the decision made with respect to the

specific Agenda items If any additional points to be discussed by any party those points will be

discussed at the end of the meeting with mutual agreement The FPIC-FA will document the

proceedings of the meeting as per the Discussion and Decision Making Framework (see section 832

above)

If all issues are resolved through discussion in this meeting then another round of discussion is not

required If there will be unresolved issue they will be included in the Agenda for the second meeting

While preparing the Agenda for the second meeting FPIC-FA will record the positions of both parties

with respect to these un-resolved issues The Agenda for the second meeting will be prepared listing

these unresolved issues with an appendix stating the views of each party on these unresolved

issues

RUMSL Team will brief about the mutual agreements and unresolved issues listed for second meeting

with their MD and seek approval if required The ST Committee will similarly brief their community

members on what is agreed after they return

The FPIC FA and ERM will prepare a Draft FPIC Agreement (in Hindi) reflecting the points of mutual

agreements and dissents if any The Draft FPIC Agreement will be shared with both parties

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 79

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

837 Second RUMS and STs Committee

The second and subsequent meetings between RUMS Team and IPs Committee will be held on

points where both parties do not agree and it requires further discussion ERMFPIC-FA will consult

both parties to reconsider their views and think about solutions acceptable to them Once ERMFPIC-

FA see both parties are prepared for the next round of discussion date for the second meeting will be

fixed

In this second round of meeting it is expected that a few more points will be mutually agreed The

Draft FPIC Agreement will be updated mentioning these points on which there are mutual agreement

and points of dissentdisagreements

Although it is expected to resolve all issues in two rounds of discussion there is a possibility of

additional rounds of discussion Both RUMSL and ST Committee will discuss on additional meetings

and decide a mutually agreed time-frame to complete the on-going discussion process

If both parties feel canrsquot be resolved through further discussions they will decide if the issue should be

referred to the Mediation Committee or set aside for discussion at a later date26 ERMFPIC-FA will

check if both parties are committed to accept the decision of the Mediation Committee and take the

final decision in consultation with both parties

838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee (MC)

If all issues are resolved through mutual discussion between the RUMSL Team and ST Committee

the Draft FPIC Agreement will be forwarded to MC of the respective Solar Park The MC will be then

requested to be available to chair over the final community meeting (see 8310) to measure the

consent expressed by affected ST in FPIC villages

The MC of the respective Solar Park will consider any issue which was not resolved by mutual

discussion between ST Committee and RUMSL Team and referred to it with an understanding that its

decision will be acceptable to both parties The FPIC-FAERM will hand over documentation of

previous discussion related to the issue and stated positions of both parties with respect to the matter

under consideration to MC

The MC will convene a meeting where it hears the arguments from both sides After considering views

on the matter from both sides MC will offer a solution for consideration If the MC thinks they need to

consult subject experts they will inform both parties and reconvene the meeting after they have

obtained views from such subject experts

Both parties if required will be given time (not more than a week) to consider the resolution offered by

the MC and come back with their final views

After considering the views of both parties on the solutions offered by it the MC will give its final

decision on the matter The MC will try making its decision on consensus and if it is not possible the

decision will be on majority Both parties will be bound by this final decision pronounced by MC The

final decision by MC will be incorporated into the Draft FPIC Agreement

839 Informing Community on Draft FPIC Agreement by ST Committee

The FPIC-FA will provide the Draft FPIC Agreement to the ST Committee The ST Committee

members will inform community members in smaller the sub-groups on the decisions taken during

FPIC discussion with RUMSL The ST Committee will explain their decisions on each issue and ask

26 Particularly matters which are uncertain or may happen in future These issues can be listed as unresolved issues to be

monitored by an agreed mechanism and discussed later

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

each adult member of the community to attend the final community meeting to voice their views and

acceptreject the Draft FPIC Agreement

8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and Ratification of Final IPP and FPIC Agreement

The ST Committee will take decision to hold the final community meeting to express their

consentdissent and fix a date after consulting RUMSL and MC members It will invite RUMS Team

and Mediation Committee to participate and witness the expression of consentdissent by affected

STs

FPIC-FA will ensure that all households in the community are informed about this meeting at least 7

days in advance FPIC-FA will prepare the list of all adult members with support from ST Committee

The IPs Committee will take the responsibility of the invitation and FPIC FA will monitor and document

the process The quorum for holding the final community meeting of affected ST families will be as

follows

Presence of at least 50 of the affected ST families in FPIC village

Presence of at least 60 of the total adult members of these affected ST families

Presence of at least 33 of the total adult women members

Presence of at least 33 of the total youths (between 18 and 25 years)

The FPIC-FA will coordinate with ST Committee members representing women and youth to ensure

that these quorum requirements are met during the final community meeting

The FPIC-FA will set-up a mechanism for recording the presence of eligible ST adult members and

hand over a copy of the Draft FPIC Agreement as they arrive at the meeting venue The Mediation

Committee will preside over this final community meeting The FPIC-FA will inform MC if quorum

requirements for the meeting is achieved After verifying the quorum required and the people

gathered for the meeting are from the affected ST households from FPIC villages the MC will initiate

the meeting proceeding

A representative from RUMSL Team will read out the agreed points mentioned in the Draft FPIC

Agreement and request for their acceptance A representative from the ST Committee will express

their views on points of mutual consensus as well as any unresolved issue that will be discussed and

resolved at a later stage of the project

The MC will then provide opportunities to ST community members present in the meeting to express

their views ST Committee will facilitate community members to express their opinions and

suggestions

The MC will consult with RUMSL and ST Committee if any additional points of agreement and dissent

to be incorporated in the Draft FPIC Agreement After confirming their final positions request the

community members present in the meeting to express their consentdissent and ratifyreject the Draft

FPIC Agreement

The consentdissent will be expressed by raising hands when the members of the Mediation

Committee puts the proposal of ratification to vote If more than 75 of the community members

attending this meeting votes in favour of the Draft FPIC Agreement it would be regarded as

expression of collective consent

The MC will inform the assembled community members about the outcome of the voting and if Draft

FPIC Agreement is ratified or rejected After the Draft FPIC Agreement is ratified by a collective

expression of consent the ST Committee members and RUMSL Team will sign the Final FPIC

Agreement This Agreement will be counter signed by members of the Mediation Committee as

witnesses

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The IPs community may be allowed to carry out any customary ritual on the day of the completion of

the FPIC process and express their support to the proposed Project This FPIC Agreement will be

taken up for implementation and a monitoring committee will oversee its effective implementation

8311 FPIC Process Documentation Report

The FPIC-FA will prepare a FPIC Process Documentation Report summarizing each stage of the

FPIC process It will hand-over all audio-visual records of the FPIC process The process document

report will cover all stages of the FPIC process documenting the following

Process of identification of STs ST representatives and decision-making authorities

Process of assessment of capacity of ST representatives to undertake good faith negotiations

Summary of any capacity building undertaken

Agreed engagement and negotiation framework (including the process undertaken to agree upon

the framework)

Summary of consultations meetings engagement undertaken as part of the FPIC process and

Opinion of FPIC-FA on the process and outcomes

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to

complete the FPIC process

84 Tentative Time-line

The Phase-I FPIC activities was scheduled to be held in Apr 2021 Due to the outbreak of second

wave of Covid-19 in Apr 2021 the field activities are suspended The decision to initiate these

activities will be taken once Covid-19 second wave gets over The schedule for Phase-II activities to

will be discussed with ST Committees of the three Solar Parks and will be decided accordingly As the

progress of FPIC process requires cooperation from affected ST community and the level of

cooperation varies in these three Solar Parks Hence the schedule for Phase-II FPIC activities will be

updated in discussion with respective ST Committees while finalizing the Discussion and Decision

Framework with them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Section Activity Month-1^ Month-2 Month-3 Month-4 Month-5

821 Appointment of FPIC FA and Orientation

822 Introducing FPIC-FA to RUMSL and FPIC Villages

823 Formation of ST Committees

824 Capacity building of ST Committees

8313 Formation of Mediation Committee

832 Acceptance of Draft DDMF

833 Disclosure of Draft IPPIPDPTDP to ST Committee

834 Explaining Draft IPPIPDPTDP to ST Committee

835 Internal Consultation Process by ST Committee

836 First RUMSL and ST Committee Meeting

837 Second RUMSL and ST Committee Meeting

838 Refer Unresolved Matters to MC

839 Inform Community about Draft FPIC Agreement

8310 Final Community Meeting for expression of ConsentDissent

8311 FPIC Process Document Report

Phase-I Activities

Phase-II Activities

Activities to start and complete

OptionalConditional Activity

^ The commencement of these activities will be determined once second wave of Covid-19 gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW

IN THE STATE OF MADHYA PRADESH INDIA

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

85 Responsibility Matrix

The FPIC process will require a collective effort and coordination between ERM RUMSL ST

Committee Mediation Committee and the FPIC FA The roles and responsibilities of these entities are

described in Section 82 and 83 above ERM will play an active role in coordination and provide

information required for a meaningful discussion The key responsibilities and accountabilities are

summarized below for clarity

Activity ERM FPIC-

FA

ST-

Committee

RUMSL-

F

RUMSL-

HO

Mediation

Committee

IFC-

WB

Formation of ST Committee S P P A

Formation of RUMS Team P A

Formation of Mediation

Committee

P P S P A P

Acceptance of Discussion

and Decision Making

Framework

S P P P A C C

Disclosure of Draft IPP to ST

Committee

P S S A C A

Explaining of Draft IPP to ST

Committee

P S

Internal consultation process

by ST Committee

S P P

First RUMSL and ST

Committee Meeting

S P P P A

Second RUMSL and ST

Committee Meeting

S P P P A

Mediation Committee

Proceedings

P P P S P P

Informing Community on Draft

FPIC Agreement by ST

Committee

S P P A

Final ST community meeting-

expression of consent

dissent

S P P P A A C

FPIC Process Documentation

Report

P P S S S S A

P= Primary Responsibility S= Secondary Responsibility C= Must be Consulted A= Approval

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

PROJECT INFORMATION DOCUMENT SHAJAPUR SOLAR PARK

Background

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) The primary objective of RUMSL

is to develop and facilitate the development of large-scale solar projects in the State of Madhya

Pradesh In line with the governmentrsquos ambition to boost solar power in State RUMSL is developing

Solar Park of capacity of 450 MW at Shajapur Madhya Pradesh

The World Bank had agreed to provide financial support for the Project International Finance

Corporation (IFC) is providing investment advisory services to Government of Madhya Pradesh to

develop the project on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards for the Project

Project Details

The proposed 450 MW Solar Park is located in two Tehsils ndashMoman Badodiya and Shajapur of

Shajapur District Out of 450 MW capacity 325 MW will be developed at Moman Badodiya tehsil

(termed as Unit 1 amp 2) and 125 MW will be developed at Shajapur tehsil (termed as Unit 3) of

Shajapur district Madhya Pradesh Almost 89 of the land area is Government land and remaining is

private land The salient feature of the Project are given below

Solar Park

The Solar Park will be developed as two units spread across these lands and the details of the same

ae captured in the table belowndash

Table A1 Details of Land parcels identified for the project Unit Number Area in ha Capacity Tehsil Villages

Unit 1 72048 220 MW Moman

Bododiya

Proposed to span 6 villages - Bijanakhedi

Burlay Chauma Dehripal Fawaka and

Parsula

Unit 2 105 MW Proposed to span Burlay Dhatrawada and

Jawadi whereas

Unit 3 26964 125 MW Shajapur

Tehsil

Hanoti Surajpur and Shajapur

Total 99012 450 MW

Land

Out of the total land requirement of 99012 hectares 86937 hectare is Government land 11074

hectare is private land and 1001 hectare is government patta land The Government land required for

the Solar Park which accounts for almost 89 of the total land required will be leased by the

government of Madhya Pradesh to SPPDs and the private land will be purchased from the land

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

owners for the development of Solar Park as per the prevailing laws and policies in the State of

Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP

Transmission Line

The transmission infrastructure is planned to evacuate power generated from the units to the STU

grid Each unit will have a 33200 kV internal pooling substation The internal pooling substation will

be connected to the proposed MPPTCL 220400 kV substation at Agar through 220 kV transmission

line For cost optimization the single circuit line from unit 1 will be laid till unit 2 towers and there on a

double line circuit of 220 kV shall be connected till the gird substation The Unit 3 internal pooling

substation shall be evacuated through single circuit 220 kV transmission line till the existing MPPTCL

220400 kV substation at Ujjain

The 33220 kV substation at each unit and 220 kV connectivity to the MPPTCL substation will be

developed by RUMSL MPPTCL will establish 220400 kV proposed grid substation at Agar in

connection with the existing 220400 kV MPPTCL substation at Ujjain Madhya Pradesh MPPTCL will

establish 220400 kV proposed grid substation at Agar along with the associated line till 400220 kV

Ujjain substation The solar project developer in the park shall be responsible for laying the 33 kV

cable and 33 kV ring unit as required at each unit to connect its plant to the 33220 kV internal pooling

substations

Road Infrastructure

The road infrastructure requirements is planned to access the Shajapur Solar Park Ms RUMSL shall

carry out road wideningrepairing of existing roads wherever required The road widening repairing of

existing roads is proposed for a length of 65 km which shall be undertaken by RUMSL The

development of internal roads within each unit shall be in the scope of individual Project Developer

Water Requirement

Water requirements for all purposes shall be met by digging bore-wells within each unit and shall be in

the scope of project developer Also the arrangement of construction water shall be in the scope of

contracting agencies and Solar Power Project developer

Common facilities planned

For 450 MW Shajapur solar park the utility area is proposed adjacent to the Unit 1 and Unit 3 -

33220 kV internal substation The other facilities such as RUMSL office fire-fighting equipment

telecommunication infrastructure medical dispensary etc will be located at the pooling substation

area

Project Implementation

The 450 MW Shajapur Solar Park will be implemented in a period of ~21 months

Operation and Maintenance

It is envisaged that different developers may occupy individual units and will be responsible for OampM

The operations and maintenance of common facilities provided like pooling substation intermediate

substations shall be undertaken by RUMSL

Environment and Social Impact Study and Management Plans

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Assessment (ESIA) of three solar parks including internal

evacuation infrastructure and associated transmission lines ESIA carried out for the project will meet

the requirements of Environment and Social Safeguard Policies and Standards of WB and IFC in

addition to applicable environmental and social regulations and policies in India and the State of

Madhya Pradesh

Based on final land footprint and georeferenced site boundaries of the project the ESIA will include a

Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) ERM will share relevant

information and consult with affected local communities to understand their viewsconcerns The

consultation will cover a wide range of people to take into account perspectives from different social

groups women and men young and old and seek their participation in mitigation of adverse impact

as well as enhancement of project benefits

As the project will impact a number of ST families ERM will assess impacts on them and prepare a

Tribal Development Plan (TDP) which will contain a package of proposed impact mitigation measures

and project benefits ERM will implement a Free Prior Informed Consent (FPIC) process covering

affected Scheduled Tribe population The negotiation process leading to obtain FPIC will be agreed

on with the affected ST communities

Free Prior Informed Consent (FPIC) Process for STs

The FPIC Process will be taken up for Surajpur Parsula and Jawadi villages of Shajapur Site for the impacts on tribal population in given villages on the land under traditional ownership and customary use The process will also involve any nomadic tribes who may have claims of using the project site for grazing their livestock and camping during their annual migration The FPIC process will be divided into two phases as described below

Phase What to Do When to Do

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Before inviting bids for solar parks by concessionaire

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Contacts

Further information and queries related to the project can be obtained from RUMSL site office in

Shajapur and head office at Bhopal The information is also available at website of RUMSL

(httpwwwrumslcom)

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT FPIC

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

NEEMUCH SOLAR PARK

Badi village Kawai Village

Mama Basti Badi village Bardawada village

AGAR SOLAR PARK

Ladwan village Bijnakhedi village

SHAJAPUR SOLAR PARK

Chauma village Parsula village

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

BACKGROUND

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) RUMSL is facilitating developing

Solar Park of capacity of 450 MW at Shajapur on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards (International Finance Corporation and World Bank) for the Project

Project Details The proposed 450 MW Solar Park is located in Moman Badodiya and South Shajapur tehsils of

Shajapur District collectively referred to as Shajapur Solar Park The Shajapur Solar Park will be

spread across 11 villages in Shajapur amp Moman Badodiya Tehsil of Shajapur District comprising the

villages of Burlay Jawadi and Dhatrawada (for Unit 6) Parsula Dehripal Bijnakhedi Fawaka

Chauma Burlay (for Unit 7) and Surajpur Lalpur and Hanoti (for Unit 8) The land required for 450

MW Solar Park including solar fields roads and transmission and distribution network is 9872

hectares The Shajapur Solar Park plot comprises of three non-contiguous land parcels

The solar park will have three (3) units It is understood that each unit will have a different developer

Unit 6 of 105 MW capacity to be developed on an area of 2461 hectares of Private and

Government land

Unit 7 of 220 MW capacity to be developed on an area of 4859 hectare and

Unit 8 of 125 MW capacity to be developed on an area of 2552 hectare

Land Requirement and Status The Solar Park will largely use GoMP land (approx 88) and the remaining land is either private

land or Patta land The Government land required for the Solar Park will be leased by the government

of Madhya Pradesh and the private land will be purchased from the land owners as per the prevailing

laws and policies in the State of Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th

November 2014 of Government of MP)

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

1 Burlay 237 00 64 00 00 00 301

2 Jawadi 322 00 20 00 00 00 342

3 Dhatrawada 1722 00 97 00 00 00 1819

Sub- Total (unit

6)

2281 00 181 00 00 00 2462

4 Parsula 1162 00 00 52 00 00 1214

5 Dehripal 1111 00 124 00 94 00 1329

6 Bijanakhedi 954 00 226 00 00 00 1180

7 Fawaka 171 00 02 00 00 00 173

8 Chouma 327 00 95 00 00 124 546

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

9 Burlay 417 00 00 00 00 00 417

Sub- Total (Unit

7)

4142 0 447 52 94 124 4859

10 Surajpur 227 07 182 00 00 00 416

11 Lalupura 497 08 00 00 00 00 505

12 Hanoti 1319 125 185 00 00 00 1629

Sub- Total (Unit

8)

2043 140 367 00 00 00 2551

Grand Total 8466 140 995 52 94 124 9872

Source Land Data provided by RUMSL 18th June 2020

Transmission Line Each Solar Park Unit will have 33220 kV substations and the power generated from each unit (Unit 6

7 and 8) will be pooled to the 220 kV switching pooling substation The utility area is proposed near

the internal pooling substation located at the Unit 6 and Unit 8

Road Infrastructure Access to Unit 6 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The existing village road has a width of ~4-5 meter and existing

State highways has a width of ~75 meter The road length of ~25 km will be strengthened and

repaired to suit the need during the construction phase

Access to Unit 7 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The road length of ~2 km will be strengthened and repaired to

suit the need during the development phase

Access to Unit 8 The Unit is connected with village road from Jhonkar to Hanoti at a distance 0f ~6

km from Jhonkar The existing road is a two-lane bituminous concrete road with width ~7-75 meters

and a new bituminous road with width ~75 meters and length ~500 meters is proposed to connect

33220 kV plant substation The road length of ~2 km will be strengthened and repaired to suit the

need during the development phase

Water Requirement The total requirement for water is estimated as 323 kL day Developers shall establish bore-wells per

block with required approvals and directions to meet their requirements The entire water supply

system including provision for bore-wells within individual blocks shall be in the scope of the Project

Developer The water requirement for the green belt is estimated to be 7000 litres per day

Common facilities planned The common facilities such as RUMSL office fire-fighting equipment telecommunication

infrastructure medical dispensary weather monitoring station etc will be located at the pooling

substation area located at the Unit 6 The operations and maintenance of common facilities provided

like pooling substation intermediate substations shall be undertaken by RUMSL Ms RUMSL will

establish two Weather Monitoring Station at internal pooling substation (at each unit)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Project Implementation

The 450 MW Shajapur Solar Park will be constructed a time frame of ~21 months with construction

proposed to started in November 2020

Project Impacts Benefits and Mitigation Measures

RUMSL will identify stakeholders and prepare a schedule for consulting them on a regular basis in

construction phase It will also establish a grievance redress mechanism through which local

community can register their grievances and seek redress to any adverse impacts on them The

project through its ESIA process has identified a range of potential impacts and has planned to

implement appropriate mitigation measures The key impactsbenefits and proposed mitigation

measures are discussed below for your knowledge and suggestions for making them more effective

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D1 Moman Badodiya Unit 6

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D2 Moman Badodiya Unit 7

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D3 South Shajapur Unit 8

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact from Land Acquisition

Type of land impacted How Impacts will be addressed

Private Land (Purchased through MP

Mutual Consent Policy 2014

Adequate compensation at twice the value of land and assets as

per MP Mutual Consent Policy 2014

Benefits of Resettlement Action Plan-Livelihoods restoration Plan

Preference to households (rendered landless or with sub-optimal

holdings) of the families post selling land to the project for

employment opportunitiessmall contracts in the

Constructionoperation phase

Pattta Land (Negotiated purchase

through MP Mutual Consent Policy)

Patta is being treated at par with ownership for the land

procurement process and would have same benefits as of private

land owners

Government Land Used for Grazing

easements cultural heritage sites

water sources fuel wood collection and

collection of other resources

Provision for alternate grazing land for cattle near the project

village or confirmation of adequacy of remaining grazing land

Development of community fodder lots in available unoccupied

government land may be explored and covered in Resettlement

Action Plan

Provision of easements shall be maintained in order to not sever

the access to CPRs for the community

Government Land Informally

occupied Capturedencroached for

agriculture or grazing prohibiting use

by other people

RUMSL shall serve a three months advance notice to the project

affected persons (PAPs) to harvest standing crops andor avoid

growing fresh crops

In case the advance notice is not given RUMSL shall pay

compensation for crops at full replacement cost

ImpactsBenefits in Construction Phase

Impact Mitigation Measures

Temporary occupation of land

for construction phase activities

such as Labour Camps Safety

Setbacks Storage areas

Parking areas Other

construction related temporary

land requirements etc

Adequate lease rents to the land owners

Restoration of land to its original state or better at the time of handing it

back to the owners

Compensation for the loss of livelihoods to the users of the land required

for temporary use as this will temporarily economically displace them

Community Health and Safety

including accident risks for

domestic animals

The Contractor shall prepare Traffic Management Plan Workers Code of

Conduct and Health and Safety Plan and implement it after approval of

RUMSL

Stress on Community resources

- Water and Roads

There will be a worker Code of Conduct defined by RUMSL that prevents

workers and contractors from using the local resources like water forest

The contractor shall be asked to use Tanker water supply during the

summer months which are dry months in which water scarcity issues are

reported by the community

Noise Nuisance and Dust Install enclosures around construction area in order to reduce the extent

of noise and dust

Limit construction related activities to day time

Employment and

entrepreneurship opportunities

during construction

The sourcing of local labour wherever possible will be obligatory for the

Solar Project Developers and sub-contractors

Employment of members of SC-STs and vulnerable households will be

at a minimum of 30 of total workers or person-days of employment

Engagement of local vendors to the extent possible for the goods and

services required for the project during construction phase

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact Mitigation Measures

The RUMSL will establish a mechanism to audit subcontractors and

suppliers with respect to compliance of utilizing local labour and

resources

Impacts in Operation Phase

Impact Mitigation Measures

Community Health and

Safety

Community engagement and sensitization sessions should be re-organised at

the beginning of Operations phase in order to mention about the new

developments in the area and provide an understanding of the precautions to

be taken for safety

Impact on Employment RUMSL shall ensure that the Solar project developers (SPDs) advertise the

roles of Technical staff required during operations phases in the local

newspapers to enable hiring of competent people from nearby areas to the

extent feasible

Preference shall be given (to the extent feasible) to hire competent members

from PAHs for semi-skilled jobs like housekeeping or Security Guards

Impacts on Vulnerable Sections Women and Scheduled Tribes

Impact Mitigation Measures

Impacts on Indigenous

Communities Vulnerable

Groups

To Prepare an Indigenous Peoples PlanTribal Development Plan with special

benefits for Scheduled Tribes

Recognizing their right to Free Prior Informed Consent process and its

implementation

As part of the stakeholder engagement ensure adequate representation and

participation of the Scheduled Tribes

Impact on Women A Gender Action Plan will be prepared for the Project to assess and mitigate

gender specific impacts

Ensure that the employment of women from vulnerable households is

prioritised for the project

Efforts are made to support development of women owned enterprises in the

area through the LRP from where procurement for project related may be

prioritised

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

Page 1

शाजापर सोलर पारक रा पररयोजना वििरण दसतािज़

पषठभवि

नवीन और नवीकरणीय ऊरजा मतरजलय क सहयोग स मधय परदश सरकार मधय परदश म जमीनी गरिड स रडी

सौर ऊजाा पररयोजना का गरिकगरसत कर रही ह रीिा अलटर ा मगा सोलर गरलगरमटड (RUMSL) का एक

सािाजगरनक उपकरम िरा 2015 म सथागरपत हआ ह यह उपकरम सोलर एनरी कारपोरशन आफ इगरडया गरलगरमटड

(SECI) तथा मधयपरदश ऊजाा गरिकास गरनगम गरलगरमटड (MPUVNL) क साथ सयकत उपकरम क रप म सथागरपत

हआ ह शाजापर सोलर पाका की कल कषमता 450 मगा िाट होगी और इस सौर ऊजाा पाका को गरनजी -

सािाजगरनक साझदारी क तहत गरनमााण गरकया जाना परसतजववत ह

रीवज अलटर ज मगज सोलर वलवमटड (RUMSL) दवजरज ईआरएम इवडयज परजइवट वलवमटड (ERM) को अतरााषटर ीय

मानको (अतरााषटर ीय गरितत वनगम एि गरिशवबक) क अनसजर सौर पजका क पयजावरणीय और सजमजवरक परभजव

मलजकन (ESIA) क सजथ सजथ पनगरिासथापन कजया योरनज (RAP) और सवततर रप स समदाय की पिा

सगरित सहमगरत (FPIC) परवियज क वलए अनबगरित गरकया गया ह

पररयोजना री परिख जानरारी

450 मगा िाट का परसतागरित सोलर पाका शाजापर गरजल क मोहन बड़ोगरडया और शाजापर तहसील क अतगात

शाजापर सोलर पाका क नाम स जाना जाएगा यह सौर ऊजाा पाका 11 गाािो क कषतर म बनगा यह 11 गााि इस

परकार ह बल जिादी और ितिादा (इकाई 6) पारसला दहरीपल बीजनखड़ी फिाका िौमा बल (इकाई

7) और सरजपर लालपर तथा हनोती (इकाई 8)

इस 450 मगा िाट सोलर पाका हत कल 9872 हकटर जमीन की आियशकता होगी गरजसम सोलर फीलड

सड़क टर ासगरमशन एि गरितरण नटिका शागरमल होगा पाका तीन अलग इकाईयो म गरिकगरसत होगा ऐसा

अनमान ह गरक परतयक इकाई का गरनमााण अलग-अलग गरनमााताओ दवारा गरकया जाएगा

105 मगा िाट कषमता िाली इकाई 62461 हकटर कषतर पर सरकारी तथा गरनजी जमीन पर गरिकगरसत

होगी

220 मगा िाट कषमता िाली इकाई 74859 हकटर कषतर पर गरिकगरसत होगी तथा

125 मगा िाट कषमता िाली इकाई 82552 हकटर कषतर पर गरिकगरसत होगी

Page 2

जिीन री सथिवि एि अविगरहण

सौर ऊजाा पजका लगभग 88 मधय परदश की सरकारी भवम कज उपयोग करगज और शष भवम यज तो वनरी यज

पटटज भवम रहगी सोलर पजका क वलए आवशयक रजरसव भवम मधय परदश सरकजर दवजरज पटट पर दी रजएगी और

वनरी भवम मधय परदश रजजय म परचवलत कजननो और नीवतयो क अनसजर भवम मजवलको स खरीदी रजएगी

(Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP)

कर

गााि

रा

नाि

सरर

ारी

जि

ीन आ

िवि

ि

(NR

ED

) ह

कटर

सरर

ारी

जि

ीन व

िसि

ि प

आि

विि

नह

हकट

वनज

ी ज

िीन

कटर

पटट

री

जि

ीन

हकट

उदय

ावन

री

हकट

िौस

िी

िाल

ाब ह

कटर

रल

जि

ीन (

सरर

ारी

जि

ीन +

वनज

ी ज

िीन

)

हकट

1 बल 237 00 64 00 00 00 301

2 जािादी 322 00 20 00 00 00 342

3 ितरािदा 1722 00 97 00 00 00 1819

योग (इराई 6 ) 2281 00 181 00 00 00 2462

4 परसला 1162 00 00 52 00 00 1214

5 दहरीपल 1111 00 124 00 94 00 1329

6 बीजनखड़ी 954 00 226 00 00 00 1180

7 फािक 171 00 02 00 00 00 173

8 िौमा 327 00 95 00 00 124 546

9 बल 417 00 00 00 00 00 417

योग (इराई 7) 4142 0 447 52 94 124 4859

10 सरजपर 227 07 182 00 00 00 416

11 लालपर 497 08 00 00 00 00 505

12 हनोती 1319 125 185 00 00 00 1629

योग (इराई 8) 2043 140 367 00 00 00 2551

Page 3

रल 8466 140 995 52 94 124 9872

सदभक रीिा अलटर ा मगा सोलर गरलगरमटड दवारा गरदया गया जमीन का डाटा 18 जन 2020

िासविशन लाइन

परतयक सोलर पाका इकाई क 33220 किी क सब सटशन होग तथा परतयक इकाई (6 7 8) स 220 गरकलो

िाट की ऊजाा सब सटशन एकतर गरकया जाएगा आतररक पगरलग सब सटशन इकाई 6 और 8 क समीम

सथागरपत करना परसतागरित ह

सड़र वनिाकण

इराई 6 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रोवक आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

गााि क रासत की िौड़ाई लगभग 4-5 मीटर तथा राजयमगा की िौड़ाई 75 मीटर ह सौर ऊजाा पाका क

गरनमााण हत 25 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 7 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रो की आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 8 िर पहाि

इकाई 8 िाम झोकर स 6 गरकलोमीटर दर िाम झोकर स िाम गरहनोती को जान िाली सड़क स जड़ी ह यह

रासता डबल लन डामर रासता ह गरजसकी लबाई 7-75 मीटर ह एक नई डामर रोड गरजसकी लबाई 500

मीटर तथा िौड़ाई 75 मीटर ह और जो 33220 किी क सब सटशन को जोड़न क गरलए बनाई जाना

परसतागरित ह सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया

जाएगा

पानी री आिशयरिा

यह अनमान ह की परगरत गरदन लगभग 323 गरकलो लीटर पानी आिशयकता होगी पानी की पगरता क गरलए ठकदार

दवारा परगरत बलॉक बोररग की रजएगी सौर ऊजाा पाका क गरनमााण क दौरान परतयक बलॉक क पानी की सपलाइ

की वयिसथा का परा खाका गरजसम बोररग करना भी शागरमल ह ठकदार अपन परसताि म द ग हररत पटटी क

गरलए परगरत गरदन अदाजन कल 700 लीटर पानी की आियशकता होगी

Page 4

सािानय सवििाओ री उपलबधिा

RUMSL का ऑगरफस अगरि शमन सटशन टली कमयगरनकशन (फोन) गरिगरकतसालय गरडसपनसरी मौसम की

जानकारी सटशन इतयागरद इकाई 6 क समीप पलीग सब सटशन पर सथागरपत हाागी पगरलग सबसटशन तथा

मधयमिती सबसटशन गरक तमाम सगरििाओ का सिालन एि दखरख RUMSL दवारा गरकया जाएगा RUMSL

आतररक पलीग सटशन पर दो मौसम अनशरिण सटशन सथागरपत करगा

पररयोजना रा वकरयानवयन

450 मगा िाट का शाजापर सोलर पाका का गरनमााण निमबर 2020 स शरिात कर अगल 21 महीनो म परा

होना अपगरकषत ह

पररयोजना र परभाि लाभ ििा शिन उपाय

सौर ऊजाा पाका क गरनमााण क दौरान RUMSL गरिगरभनन गरहतसािको की पहिान कर उनस गरनयगरमत ििाा और

सलाह मशिरा करतज रहगज पाका गरनमााण क दौरान िामीणो की गरशकायतो को समझन एि उनह दर करन क

गरलए गरशकायत गरनिारण ततर की वयिसथा RUMSL करगा तागरक गरशकायतो का गरनपटारा शीघर हो सक और

लोगो पर हो रह नकारातमक परभाि को दर कर सक पररयोजना दवारा ESIA की परगरकरया क माधयम स सभागरित

परभािो को गरिनहनहतकर उनक गरनपटार हत उगरित और परभकारी उपाय करगा अपगरकषत परभािलाभ और शमन

क उपाय गरनमन गरलनहखत ह तागरक आपक सझािो क आिार पर उनह और परभािी बनाया जा सक

Page 5

नकशा 1 िोहन बदोवदया इराई 6

Page 6

नकशा 2 िोहन बदोवदया इराई 7

Page 7

नकशा 3 शाजापर इराई 8

Page 8

जिीन अविगरहण रा परभाि

परभाविि जिीन रा पररार परभाि रा वनिारण

वनजी जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत 2014 क तहत

खरीदी गरनजी जमीन)

मधय परदश आपसी सहमगरत भगरम करय नीगरत 2014 क तहत

पयाापत मआिजा जमीन या सपगरत क मलय स दगना

पनिासन कायायोजना ndash आजीगरिका पनजीिन योजना स लाभ

पररयोजना हत अगरििहण क बाद पररिार गरजनक पास बहत ही

कम जमीन बिी ह या भगरमहीन पररिारो को पराथगरमकता

गरनमााण क दौरान गरकरयानवयन क समय उनक गरलए काम क

अिसर छोट काया अनबि काटर कट म पराथगरमकता दना

पटटिाली जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत2014 क तहत

तय कर खरीदी गए जमीन)

जमीन क अगरििहण क दौरान पटटा िारको को गरनजी मागरलक की

तरह समझत हए उनक गरलए गरनिााररत सार फायद दना

सररारी जिीन िरनोई सासकगरतक

िरोहर जल शरोत जलाऊ लकड़ी

सिहण गरनसतार की जमीन

अनयससािनो का सिहण क उपयोग म

आन िाली जमीन

पररयोजना क समीप क गााि म िरनोई क गरलए जमीन की

िकनहिक वयिसथा करिाना या अगरििहण क बाद शर जमीन म

गााि क गरलए पयाापत िरनोई की जमीन सगरनगरित करना

खाली पड़ी सरकारी जमीन पर सामदागरयक िारागाह की खप

गरिकगरसत करन हत पनिासनकाया योजना म सभािना खोजना

समदाय क सामदागरयक ससािनो तक पहाि बनी रह उस सगरनगरित

करन क गरलए भारतीय सख भोग अगरिगरनयम 1882 क पराििानो

का पालन गरकया जाएगा

सररारी जिीन अिि कबजिाली

जमीन खती या िराई क गरलए कबजा

अगरतकरमण गरकया गया हो लोगो दवारा

सािाजगरनक उपयोग बागरित गरकया गया

हो

RUMSL पररयोजना स परभागरित लोगो को तीन महीन का पिा

नोगरटस दगा तागरक ि अपनी लगी हई फसल काट सक या नई

फसल न बोए

यगरद गरकसी कारण िश पिा नोगरटस नही दी गयी तो RUMSL परी

फसल की कीमत मआिज क तौर पर द ग

Page 9

वनिाकण र दौरान परभािफायद

परभाि शिनवनपिार र उपाय

गरनमााण क िरण क दौरान गरिगरभनन गगरतगरिगरियो

क गरलए जस मजदर रहिास (क प) सरकषा

वयिसथा भडारण वयिसथा िाहन पागरकि ग कषतर

तथा गरनमााण सबिी अनय जमीन की असथायी

आिशयकता पड़ना आगरद

जमीन मागरलको को पयाापत लीजगरकराए की वयिसथा करना

जमीन मागरलको को उनकी जमीन लौटन क समय वयिनहसथत

रप स सिार कर परानी अिसथा या उसस भी अचछी करक

लौटाना

जमीन मागरलको को उनक जमीन स असथायी रप स हटान एि

उनकी आजीगरिका क नकसान क एिज म मआिजा दना

सामदागरयक सवासथय एि सरकषा तथा घरल

उपयोगी पशओ की दघाटनाका जोनहखम

ठकदार सभी की सरकषा क गरकए आिागमन परबिन पलान

तयार कर ग मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयिहार क गरनयम) और सवासथय एि सरकषा की योजना

बनाकर RUMSL स अनमोदन क पिात ही गरकरयानवयन कर ग

सामदागरयक ससािनो पर दबाि ndash पानी एि

सड़क

RUMSL दवारा मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयहार क गरनयम) गरनिााररत गरकए जाएग गरजसस

कमािारी तथा ठकदार सथानीय ससािनो जस पानी जगल

आगरद का नयायोगरित उपयोग कर पाएग

गगरमायो क समय पानी की गरकललत को दखत हए ठकदार को

यह गरनदश होग की िह पानी क टकर स पानी गरक पगरता कर

शोर बािा एि िल गरनमााण सथल पर दीिार लगानासथागरपत करना तागरक शोर एि

िल कम फल

गरनमााण काया किल गरदन क समय ही करनागरनमााण काया रात

क समय परगरतबगरित करना

गरनमााण क दौरान रोजगार तथा वयिसाय क

अिसर

यथासभि सोलर पाका गरिकगरसत कतााओ तथा ठकदारो आगरद

क गरलए सथानीय लोगो एिम मजदरो को काया दन की

अगरनिायाता होगी

कल रोजगार गरदिस या कल कमािाररयो म कम स कम 30

परगरतशत मजदरकमािारी अनसगरित जागरत - जनजागरत या िगरित

पररिार स होग

सोलर पररयोजना गरनमााण क समय गरकसी भी मालसामिी या

सिा की जररत यथासभि सथानीय गरिकरताओ क माधयम स

की जाएगी

RUMSL गरनमााण क दौरान एक अककषण ततर की वयिसथा

करगा तागरक ठकदार गरिकरता सिा परदाता सथानीय ससािनो

तथा मजदरो का यथोगरित उपयोग कर सक

Page 10

वकरयानवयन र सिय परभाि

परभाि शिन वनपिार र उपाय

सामदागरयक सवासथय एि

सरकषा

सोलर पाका क गरनमााण की परगरकरया क दौरान गरनमााण स होन िाल नए

बदलाि क सबि म समदाय को सिदनशील बनाना हत बठको का

आयोजन करना और सरकषा क गरलए एहगरतयात बरतन हत समय समय पर

गरििार गरिमशा और ििााए करना

रोजगार पर परभाि RUMSL यह सगरनगरित करगा की पररयोजना क गरनमााण क दौरान

तकनीकी कमािाररयो की भती का गरिजञापन सथानीय अखबारो म छप

तागरक योगय सथानीय लोगो को भती गरकया जा सक

अिा कौशल कषमता िाल काम जस कायाालय की दखरख सरकषा गाडा

आगरद पररयोजना स परभागरित पररिारो को पराथगरमकता क आिार पर

गरदय जाए

िविि िगक पर परभाि िवहलाए एि अनसविि जनजावि र सदभक ि

परभाि शिन वनपिार र उपाय

अनसगरित जनजागरत एि

िगरित िगा पर परभाि

अनसगरित जनजागरत समदाय क लाभ को धयान म रखत हए मलगरनिासी

समदाय क गरलए योजना आगरदिासी गरिकास की योजना बनाई जाएगी

सवततर पिा सगरित सहमगरत क आिार पर FPIC की परगरकरया का

गरकरयानवयिन गरकया जाएगा

गरिगरभनन गरहतसािको को शागरमल करत समय अनसगरित जनजागरत समदाय

का पणा रप स परगरतगरनगरितव और भागीदारी को सगरनगरित गरकया जाएगा

मवहलजओ पर परभाि जडर एकशन पलान का गरनमााण गरकया जाएगा तागरक पररयोजना की िजह

स जडर गरिगरशषट परभािो का आकलन कर उनह गरनपटा या कम करन का

परयास हो सक

पररयोजना म िगरित िगा की मगरहलाओ को रोजगार पराथगरमकता गरमल यह

सगरनगरित गरकया जाएगा

पररयोजना कषतर म मगरहला उदयमी गरिकरता सिा परदाताओ को सहयोग

करन क परयास गरकए जायग गरजसस पररयोजना म काम आन सामिी

समान की खरीदी उनस की जा सक

Page 11

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE FPIC FACILITATOR

Page 12

Screening of Facilitating AgencyIndividual Expert for FPIC

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to

undertake an Environmental and Social Impact Assessment (ESIA) of three solar parks

including internal evacuation infrastructure and associated transmission lines of aggregate

capacity of 1500 MW in the Neemuch Agar and Shajapur Districts of Madhya Pradesh India

(hereinafter referred to as the lsquoProjectrsquo) one of the key tasks as part of this assignment is to

secure Free Prior Informed Consent in keeping with the provisions of IFC PS 7 For this

purpose ERM has undertaken the task of identifying a Facilitation AgencyIndividual (FA) to

assist with the FPIC process This document presents the results of the screening and

shortlisting process for the FPIC FA

Approach and Methodology

The approach and methodology followed for shortlisting of FPIC FAs is presented below

1 Two stage approach was followed for the selection of FPIC Facilitation

AgencyIndividual Initially desk research was carried out to identify Institutions (Universities

Government Departments and Research Institutes etc) NGOs and INGOs located in

Madhya Pradesh state In parallel the ERM team also identified the criterion which will be

used to shortlist the potential Facilitating Agencies The criteria used for screening included

qualification profile affiliation with the type of institutionsorganizations nature of

worksprojects completed working experience with Bhils in MP experience in natural

resource management and rural livelihoods conducting meaningful consultation community

mobilization and stakeholder engagement familiarity with World Bank Group safeguardsrsquo

policies and procedures comfort with written and spoken English and local dialects etc

2 In the second stage the potential candidates from these institutions were individually

approached to further assess their suitability and find out their availability for the assignment

Convenient date and time for the personal discussion and interview with them was sought

Accordingly the ERM team organized interview with the available candidates at Bhopal

3 The team27 of Environmental Resource Management (ERM) New Delhi visited

Bhopal during 6-8 January 2020 in order to undertake face to face meetings with these

organizations and individuals identified

Screening

4 The screening against the preferred criteria was undertaken for the potential

candidates available to work as FA for FPIC None of these agenciesindividuals reported to

have worked for a FPIC process earlier Also the candidates interviewed are not familiar

with the World Bank and IFC safeguards related policies and procedure applicable for IPs in

energy and other infrastructure development sectors They are however interested in

working and learning from the project The candidates also had limited experience in the

field of natural resource management and rural livelihoods Details of the screening of

potential candidates is given below

27 Team comprised of Ramesh Swarankar Freelance Consultant and Akshita Mishra Senior Consultant ERM

Page 13

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Amitav Singh

and Leena

Singh

Debate Lok

Nyas (DEBATE)

Duplex C-22

Alkapuri Near

DRM Office

Habibganj

Bhopal-462024

0755-2985007

0755-2417656

9425018144

9425004556

debateindiag

mailcom

MA Social

Works

The key persons are active for

last 3 decades in Social Work

The Debate Trust was

incorporated in 2002-03 and has

more than 15 years of experience

in working with PRIs in Madhya

Pradesh with an focus in Tribal

(Schedule-V) Areas Mr Amitav

Singh is a member of National

Committee for Monitoring of

MNREGA

Ms Leena Singh has also

experience of working with rural

women for more than 15 years

Have

worked

with Bhils

of

Jhabua

Yes Yes Yes

Mr Amitav

Singh is a

leading trainer

for PRA and

Social Audits

by Panchayat

Raj Ministry

No

But was

part of the

FPIC

training

provided

by

ActionAid

Yes

(requires

support in

Reporting)

Score 18 3 2 3 3 3 2 2

Dr Jose

Payyappilly

Address 142

Nyay Nagar

Sukhliya

Indore

Contact-

7828355557

PhD MA

in Social

Work amp

Sociology

About three decades experience

of working on Health HIVAIDS

CSR Literacy Adult education

minority education related

projects and programs funded by

GoI GoM Clinton Foundation Bill

amp Melinda Gate Foundation

UNAIDCARE World Action

Forum VHAI Christian Aid NGO

such as Samarthan in MP

Chhattisgarh and other states It

Has

worked

with Bhils

as part of

a larger

communi

ty in

Jabhua

No No Yes

Trained in

traditional

communicatio

n systems

folklore

folktale

Familiar with

planning

strategy and

community

Associated

with the

network of

NGOs CSOs

and village

level

functionaries

Worked with

local

governments

and elected

No Yes

Page 14

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Email Id

payyappillyjose1

6gmailcom

jose_soolyaho

ocoin

includes the districts in MP with

IPs population

Dr Jose has worked as team

leader director executive director

and other positions Also worked

as Local Governance and BCC

Advisor to DANIDA for Health

Services Program State Media

Coordinator State Resource

centre Adult Education MP

Program Producer Radio Veritas

Asia Manila Philippines

stakeholder

engagement

panchayat

representative

s

Score 14 2 1 1 3 3 1 3

Parushram

Tiwari

Address- C-443

Sarvdharm

Colony Kolar

Road Bhopal

Contact-

09425065132 amp

8319540266

Email Id

drpram42gma

ilcom

PhD

MPhil MA

( Sociology

More than 20 year experience of

working as consultant at different

positions in Public health

HIVAIDS literacy education

nutrition urban development and

governance projects and

programs in MP including Malwa

area and other states

These projects were funded by

UNICEF UNFPA ADB Clinton

Foundation Women amp Child

Development Rural

Development Urban

Administration amp Development

No No Yes Has

worked as

the State

Project

Manager

for Sanjhi

Sehat

project of

MP State

Rural

Livleihood

Mission

Yes Is good

with

coordination

and

communicatio

n

Yes has

experience in

Planning

management

and execution

capacity

building

training and

Networking

and advocacy

Liaison

support and

team building

No Will need

support in

documentatio

n

Page 15

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

State AIDS Control Society of

GoMP and the NGO partners

Dr Tiwari was the Project Director

and District Program officer under

National Literacy Mission at

District Collector offices at Dhar

and Indore MP respectively

during 1991-1998

Score 13 1 1 2 3 3 1 2

Mr Sandip Naik

Adddress-C-55

Kalani Bagh

Dewas MP

Pin Code

455001 India

Contact- +91-94

2591 9221

Email id

naiksandigmai

lcom

Diploma in

Developm

ent

Facilitation

from TISS

Mumbai

MPhil

MA in

Rural

Developm

ent and

English

Literature

About 20 year experience of

working on health nutrition

education governance and

women empowerment with

governments of MP

Worked with NGOs International

agencies and MP government on

senior positions

Since 2014 working with CRY

and TDH on issues of malnutrition

and preparing booklets

brochures pamphlets on nutrition

adolescents issues and childrenrsquos

health Also written textbooks

teachers learning material and

manuals for state govt for SCERT

etc

Yes No No Yes Yes No Yes

Page 16

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Score 14 2 1 1 3 3 1 3

Dr Rahul Dev

Bahawsar

Address Block

No 14 Flat No

5 Shalimar

Enclave E-3

Arera Colony

Bhopal ndash

Madhya

Pradesh

Contact-

08223015124

Email

rbhawsarrediff

mailcom

rahuldevbhawsa

rgmailcom

PhD amp

MPhil in

Population

Studies

from IIPS

Mumbai

MSC

Statistics

24 years experience in

monitoring evaluation and

implementation of programs in

health and social development

sectors in MP Rajasthan and

Gujarat states

Engaged in nutrition assessment

survey in 18 districts of MP states

including IPs dominated districts

such as Dhar Jhabua with Bhil

population and coordinated with

state health women amp child

development and rural

development departments during

the study period

Involved in conducting health

surveys at national level

Worked as a staff with Health

Management Research Institute

Jaipur and IPE Global Consulting

Firm New Delhi etc These

projects were funded by DFID

UNICEF UNFPA GoI GoMP

etc

Yes has

worked

in

Jhabhua

and Dhar

No Yes Has

worked

with State

Rural

Livelihood

Mission

Somewhat

His strengths

lie more

towards

quantitative

research

Somewhat No Yes

Page 17

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Working as freelance expert and

has a registered consultancy firm

that is inactive

Score 12 2 1 2 2 2 1 2

Ms Aastha

Anuragi

Address 173

Sanjay

Complex

Phase-2

Geetanjaly

Square Bhopal-

462003

Contact-

9425365216

8160123726

Email

aasthaanuragi

gmailcom

MBA Rural

Manageme

nt amp MSC

in Physics

More than 15 year experience of

working particularly imparting

training to different stakeholders

in drinking water and sanitation

Swachh Bharat ODF missions

WASH livelihood menstrual

hygiene etc Master trainer for

total sanitation program

Worked as consultant in MP

Chhattisgarh West Bengal UP

Gujarat Jharkhand Bihar states

These projects were funded by

World Bank Water Aid UNICEF

DFID GoI State governments

and ICIMOD Nepal

No No Yes has

worked as

a project

facilitator

with MP

livelihood

project

Yes Yes No No

Score 12 1 1 2 3 3 1 1

Note The scoring for each criterion was as follows 0- Not applicable 1- Not Meeting the Requirement 2- Partially meeting the requirement 3- Completely fulfilling the requirement

Page 18

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

Page 19

TERMS OF REFERENCE FOR FPIC FACILITATION AGENCY

Background

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake an

Environmental and Social Impact Assessment of three solar parks including internal evacuation

infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch

Agar and Shajapur Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work for the project ERM is required to assess the impacts on the indigenous

marginalized communities within the site and its influence area prepare an Indigenous Peoples Plan

(IPP) apart from other ESIA amp RAP deliverables The project is also required to conduct a FPIC process

covering affected Scheduled Tribe (ST) population

Villages to be covered in FPIC Process

The project area has a few small ST settlements and in few others a small number of ST households

live along with a majority non-ST population Following 5 villages are identified for carrying out FPIC

process

Solar Park Selected ST villages

for FPIC

Number of

Households

Name of ST

Community

Agar Solar Park Ladwan 12 Bhil

Shajapur Solar Park Parsula 41 BhilBhilala

Neemuch Solar Park Badi and Kawai 97 BhilBhilala

Note Additional ST families in neighbourhood villages of the same Solar Park will be made part of this

process to a limited extent

Phases in FPIC Process

The FPIC process will be divided into two phases as described below

Phase What to Do Schedule

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Apr 2021^

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

May-Aug 2021^

^ Activities were suspended in April 2021 due to break out of the second wave of Covid-19 in India These

activities will be re-scheduled once Covid-19 second wave gets over

Deliverables and Responsibilities

Phase Responsibilities Deliverable

I Identification of STs Representatives and formation of committees

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Documentation of capacity building of STs Representatives on FPIC

Mutually agreed FPIC Process and composition of local ST Representative committees

Page 20

Phase Responsibilities Deliverable

Hindi Translation of TDPIPP and designing Information sharing tools

Participatory mapping of all natural resources and cultural sites to be impacted

Participatory assessment of impacts on Tribal population

Identification of Livelihood and Welfare programs to be included in Draft TDP

Inventory of natural resource and cultural sites

Documentation of participatory process of impact assessment

Note on livelihood and welfare programs

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation (Photos Video MoMs for each meetingsevents) of FPIC process

The revised package in Draft TDP and a mutually agreed Draft FPIC Agreement

Personnel Requirement

The FPIC Facilitation Agency will require to mobilize following key personnel for completing these tasks

Designation Desired Qualification and Experience

Coordinator The coordinator to be a post-graduate in social sciencessocial work with at

least 15 years of experience in ruraltribal development Prior involvement in

FPIC related work with prominent civil society organizations or multilateral

development finance organizations will be preferred

Facilitator (Male) The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in facilitation of participatory rural appraisals The

facilitator needs to have sound knowledge of livelihood issues in Malwa

region of Madhya Pradesh and must have worked with Panchayati Raj

Institutions for their capacity building The facilitator should be familiar with

the local dialect (Malwi) spoken in Malwa region

Facilitator

(Female)

The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in working with rural women She should have

knowledge of livelihood and social context of women in Malwa region She

should have prior experience in facilitating participatory rural appraisal

processes involving rural women

Documentation

Assistant

The documentation assistant should be a Graduate in social sciencesmass

communication She should have at least 5 years of experience in ruraltribal

development and have carried out process documentation of development

projects She should have a good command over Hindi and should be

familiar with Malwi dialect

Community

Mobilizer

The community mobilizer should have passed higher secondary and have

experience of working with any NGO for at least 2 years She should have

good communication skills She will provide all logistical support necessary

to ensure participation of maximum number of people She also helps

Documentation Assistant in photo and video documentation of the FPIC

process

Organization Profile

The organization should have at least 10 years of experience in working in rural and tribal

development issues in Madhya Pradesh The organization should have a reputation of successfully

implementing projects related to community mobilization and capacity building They should have

Page 21

prior experience of working with tribes and should be known for their dedication and commitment

towards tribal rights and promoting their development

The business of sustainability

ERM has over 160 offices across the following

countries and territories worldwide

Argentina

Australia

Belgium

Brazil

Canada

Chile

China

Colombia

France

Germany

Ghana

Guyana

Hong Kong

India

Indonesia

Ireland

Italy

Japan

Kazakhstan

Kenya

Malaysia

Mexico

Mozambique

Myanmar

The Netherlands

New Zealand

Norway

Panama

Peru

Poland

Portugal

Puerto Rico

Romania

Russia

Senegal

Singapore

South Africa

South Korea

Spain

Sweden

Switzerland

Taiwan

Tanzania

Thailand

UAE

UK

US

Vietnam

ERM India Private Limited

Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

wwwermcom

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

6 INDEPENDENT FACILITATOR AGENCY 63

61 Need for FPIC Process Facilitation Agency 63 62 Screening of FPIC Process Facilitation Agency 63 63 Roles and Responsibility for FPIC Process Facilitation Agency 65 64 Terms of Reference for FPIC FA 65

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS 66

71 Use of Language 66 72 Use of Customary Decision Making Process and Traditional Leaders 66 73 Promoting Participation of Women and Youths 67 74 Expectation on Material Information Prior to Discussion 67 75 Need for Capacity Building of IP Representatives 68 76 Need for a Mediation Mechanism 68 77 Following Principles of Good Faith Negotiation 69 78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and

Supportive Environment 70

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK 73

81 Introduction 73 82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo 73

821 Appointment of FPIC Facilitation Agency and Orientation 73 822 Introducing FPIC FA to RUMSL and FPIC Villages 73 823 Formation of ST Committees 74 824 Capacity Building of ST Committees 74

83 The Draft Discussion amp Decision Making Framework 74

831 Formation of Committees 75 832 Acceptance of Draft Discussion and Decision Framework 76 833 Disclosure of Draft IPPIPDP to ST Committee 77 834 Explaining Draft IPPIPDPTDP to ST Committee 78 835 Internal Consultation Process by ST Committee 78 836 First RUMSL and ST Committee Meeting 78 837 Second RUMS and STs Committee 79 838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee

(MC) 79 839 Informing Community on Draft FPIC Agreement by ST Committee 79 8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and

Ratification of Final IPP and FPIC Agreement 80 8311 FPIC Process Documentation Report 81

84 Tentative Time-line 81 85 Responsibility Matrix 83

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT

FPIC

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY

ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE

FPIC FACILITATOR

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Tables

Table 11 Villages to be covered in FPIC Process 1

Table 12 Salient Features of the Project 2

Table 13 The status of ESIA Study Components and Community Engagement 3

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables 5

Table 21 Key Provisions of Land Revenue Code 12

Table 22 Comparison of Provisions of Consent Process in Applicable Indian Regulations vis-agrave-

vis Provisions in IFC PS-7 17

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land

Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

19

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected

Villages 22

Table 32 Agar Solar Park- Government Land- Land Use Category 26

Table 33 Shajapur Solar Park- Government Land- Land Use Category 30

Table 34 Villages to be covered in FPIC Process 36

Table 35 Designated grazing land (Charnoi) and Remaining Government Land 38

Table 36 Impact on Cultural Sites Affiliated to STs 39

Table 37 List of Power Evacuation Infrastructure 40

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of

STs 41

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST

Population 42

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs 43

Table 41 Dates of Government Land Allotment for Neemuch Solar Park 46

Table 42 Dates of Government Land Allotment for Agar Solar Park 46

Table 43 Dates of Government Land Allotment for Shajapur Solar Park 47

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha

Resolution 47

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park 49

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park 50

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park 50

Table 54 Site visit Dates and Site Activities 51

Table 55 Names of Potential Representatives in Ladwan Village 54

Table 56 Names of Potential Representatives in Parsula Village 57

Table 57 Names of Potential Representatives in Badi and Kawai Village 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency 63

Table 62 Roles and Responsibilities of FPIC FA 65

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context 69

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages 71

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CONTENTS

List of Figures

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages 24

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages 25

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages 28

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages 29

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages 33

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages 34

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages 35

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments 56

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process 74

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Acronyms and Abbreviations

Name Description

CSO Civil Society Organizations

DDMF Discussion and Decision Making Framework

DPR Detail Project Report

DREO District Renewable Energy Officer

ESIA Environment and Social Impact Assessment

ESS Environment and Social Standards

FA Facilitation Agency

FPIC Free Prior Informed Consent

FPIC-FA FPIC Facilitation Agency

FPICon Free Prior Informed Consultation

GAP Gender Action Plan

GFN Good Faith Negotiation

GN Guidance Note

GoMP Government of Madhya Pradesh

GP Gram Panchayats

HO Head Office

ICP Informed Consultation and Participation

IFC International Finance Corporation

IPDP Indigenous Peoples Development Plan

IPP Indigenous Peoples Plan

Ips Indigenous Peoples

JV Joint Venture

LRP Livelihood Restoration Plan

MC Mediation Committee

MNRE Ministry of New and Renewable Energy

MPLRC Madhya Pradesh Land Revenue Code

MPUVNL Madhya Pradesh Urja Vikas Nigam Limited

MW Mega Watt

NGO Non-Government Organizations

NOC No Objection Certificate

OBC Other Backward Castes

OP Operation Policy

PPP Public Private Partnership

PRA Participatory Rural Appraisal

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Name Description

PS Performance Standard

RAP Resettlement Action Plan

RPO Renewable Purchase Obligation

RUMSL Rewa Ultra Mega Solar Limited

SC Scheduled Caste

SEP Stakeholder Engagement Plan

SHG Self Help Group

SPD Solar Park Developer

SPO Solar Purchase Obligation

ST Scheduled Tribe

TDP Tribal Development Plan

ToR Terms of Reference

WB ESF World Bank Environment and Social Framework

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

1 INTRODUCTION

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Impact Assessment (ESIA) including Resettlement and

Rehabilitation Action Plan (RAP) of three solar parks including internal evacuation infrastructure and

associated transmission lines of aggregate capacity of 1500 MW in the Neemuch Agar and Shajapur

Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work ERM is required to assess the impacts of the Project on the Indigenous

Peoples (IPs) or Scheduled Tribe (ST) and develop an approach and implement the process of Free

Prior Informed Consent (FPIC) The villages in Table 11 were identified to be covered in the FPIC

process during the scoping stage The intention of conducting FPIC process involving ST families in

these identified villages was communicated to the Sarpanch1 and a project information sheet (in

Hindi) was shared around Dec 2019

Table 11 Villages to be covered in FPIC Process

Solar Park Selected ST

villages for FPIC

Number of

Households

Name of ST

Community

Date on which Gram

Panchayat was informed

about FPIC Process

Agar Solar Park Ladwan 12 Bhilala 19th Dec 2019

Shajapur Solar Park Parsula 41 Bhilala 30th Jan 2020

Neemuch Solar Park Badi and Kawai 61 Bhil and Bhilala 5th and 6th Dec 2019

The Covid-19 pandemic brought restrictions for finalizing the project boundary and preparation of

ESIA Reports between Mar 2020 and Jun 2020 ERM initiated the FPIC related works and submitted

a Memo on selection of FPIC villages dated 29th Jun 2020 which reviewed the government land

allotment and triggers for FPIC

The FPIC Approach Paper (current document) is based on the understanding of the socio-political

context within which the affected STIPs population lives and suggestions received from the

prominent ST representatives with whom a preliminary round of discussions was held The Discussion

and Decision Making Framework (see Section 8) is accepted by RUMSL and was planned to be taken

back to the affected ST community for discussion and acceptance in Apr 2021 (see Section 832)

This has been delayed due to second wave of Covid-19 which started in Apr 2021 and decision on

further visits and consultations will be undertaken based on how situation unfolds in the coming

weeks The FPIC Approach paper will be finalized after the Discussion and Decision Making

Framework is discussed with ST Committees representing affected ST communities and agreed by

them

11 Project Background

The Government of India has identified the solar power sector as one of the critical components for

infrastructure development and overall economic growth The Government of Madhya Pradesh

(GoMP) through Ministry of New and Renewable Energy (MNRE) is developing ground mounted grid

connected solar power projects in Madhya Pradesh International Finance Corporation (IFC) is

providing investment advisory services to RUMSL thereby enabling Government of Madhya Pradesh

(GoMP) to develop the project on Public Private Partnership (PPP) mode and to support GoMP in

1 The rural local self-government bodies in India are known as Gram Panchayat which comprises of several wards Each ward

elects a ward member to represent them The Gram Panchayat thus comprises of multiple elected Ward Members The Chair Person of these elected local body is known as Sarpanch The vice chairperson of the Gram Panchayat is known as Upsarpanch or Naibsarpanch All adult electorate of a Gram Panchayat constitute Gram Sabha or General Assembly of the Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

meeting its energy requirements and in the process meet its Renewable Purchase Obligation (RPO)

and Solar Purchase Obligation (SPO)

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) Its primary objective is to develop

and facilitate development of large scale solar power projects in the state of Madhya Pradesh

RUMSL is planning to develop three solar parks (see details in Table 12) and their associated

internal evacuation infrastructure and transmission lines The World Bank had agreed to provide

financial support for the Project

Table 12 Salient Features of the Project

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Capacity and Configuration

3 Units (Units 1 2 3) adding up to 500 MW

2 Units (Units 4 and 5) adding up to 550 MW across Susner (Unit 4) and Agar (Unit 5)

3 Units adding up to 450 MW across Moman Badodiya (Units 6 and 7) and South Shajapur (Unit 8)

Total Land Area as of 24 June 2020

Unit 1 3515 ha Unit 2 34713 ha Unit 3 36701 ha Total 106573 ha

Unit 4 60809 ha Unit 5- 79918 ha Total 140758 ha

Unit 6- 2462 ha Unit 7 4859 ha Unit 8 2551 Total 9872 ha

Government Land (ha) allotted as of 24 Jun 2020

67819 ha

Allotment of additional 28979ha is under process Thus the total government land area is 962949 ha

127338 ha 931 ha allotted and additional 14ha to be allotted

Date of Government Land allotment

Allotment Date

Area in Ha

17-01-2018 23868

30-05-2017 43951

Total 67819

Allotment Date

Area in Ha

28022019 5633

28022019 7053

21062019 1495

20-06-2019 15925

28022019 283

20062019 19714

280202019 1683

21012019 3492

04012018 602

09082018 2669

30112016 5562

02012018 5699

02012018 16116

06012018 17663

09082018 15583

Total 127137

Allotment Date

Area in ha

26-05-2017 914

26-05-2017 3052

26-05-2017 2011

11-12-2017 11261

11-12-2017 1171

11-12-2017 171

11-12-2017 1386

11-12-2017 4015

11-12-2017 4596

11-12-2017 9545

11-12-2017 1763

26-05-2017 16461

28-06-2019 2675

28-06-2019 6134

Total 931

Private Land 1862 ha 1342 ha 9951 ha

Patta land 7572 ha 0 515 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Proposed Commissioning Date

Tender and bid process tasks completed

- Start of registration downloading of the RFP access to Data Room on 26th Jan 2020

- Facilitation of site visit 26 to 28th Feb 2020

- Issue of Draft Project Agreements on 15th Jun 2020

- First pre-bid meeting was held on 30th Jun 2020

- ESIA Reports was issued on 16th Oct 2020

Tender and bid process schedule ahead

- Second pre-bid meeting on 30th Mar 2021

- Proposal due date for 3 sites between 3rd Jun 2021 and 18th Jun 2021

- Financial proposal opening between 14th Jun and 28th Jun 2021

- Reverse Auction Process 17th Jun and 30th Jun 2021

Purchase of Private land between Apr and Jun 2021

Target date for providing SPD land access June 2021

Indicative construction time of 19 months

Target date for commissioning of Solar Park Nov 2022 It is understood that RUMSL will initiate a process of hand over of balance government land to revenue department no longer required for the project

12 Timeline of Various EampS Studies

The allotment letters of the government land were issued at different points of time between 2017 and

2019 The boundary demarcation (tarmeem2) of these allotted government land for the 3 solar parks

was completed in October 2020 RUMSL is planning to initiate private and patta land procurement to

start in Apr 2021 and all sale agreements are signed by Jun 2021

The timeline of ESIA studies of these 3 Solar Parks is provided in Table 13 below

Table 13 The status of ESIA Study Components and Community Engagement

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

ESIA Field

visits

December 2019 December 2019-

January 2020

January ndash February

2020

September 2020

Report Final ESIA

submitted in

October 2020

Final ESIA

submitted in

October 2020

Final ESIA submitted

in October 2020 Draft ESIAs for

Neemuch TL and

Agar- Shajapur

TL submitted in

November 2020

RAP-

LRP

Field

visits

November-

December 2020

August 2020 August 2020 December 2020

Report Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-WB

Draft RAP-LRP is

reviewed by IFC-

2 Tarmeem ground verification process to confirm land ownership and to demarcate any patta land andor private land that

may have been identified within a government khasra This process is done by Revenue Department from time to time in the normal course of action (with or without any project) As an outcome of this process following can be achieved Revisions in the Patwari maps Khasra books Digital database other revenue records preparation of survey reports etc This process is undertaken by Officials from the Revenue Department usually inclusive of the Tehsildar RI Patwari etc

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

WB and ready for

Public Disclosure in

Mar 2021

WB and ready for

Public Disclosure

in Mar 2021

and ready for Public

Disclosure in Mar

2021

WB and ready for

Public Disclosure in

Mar 2021

IPP Field

Visits

Initiation 5-6th Dec 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and Draft IPP 13-16th Aug 2020

HH Survey 7-14th Sep 2020

Initiation 19th December 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 6-7th Aug 2020

HH Survey Not done

Initiation 30th Jan 2020

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 8-12th Aug 2020

HH Survey 13-14th Aug 2020

No IPP to be prepared for Transmission Line

Report Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure in

Mar 2021

Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure

in Mar 2021

Draft IPP is reviewed

by IFC-WB and

ready for Public

Disclosure in Mar

2021

The ERM ESIA team has held several consultation meetings in project affected villages covering a

cross-section of stakeholders in a sequential manner The broad understanding of the socio-economic

and livelihood practices was carried out in Dec 2019 and Jan 2020 as part of collection of baseline

information The detailed study for RAP-LRP and IPP subsequently took place in Aug 2020 The details

of the consultations held for ESIA RAP-LRP are part of those reports and details of field visits and

consultation activities carried out for preparation of this FPIC Approach Paper and Draft IPP is described

in Section 4 below

13 Scope amp key deliverables related to FPIC for MP Solar Project

ERM as a part of the FPIC requirement for the project is expected to support the elaboration and

implementation of a robust FPIC process for the MP Solar Park project to be developed in 2 Phases

Phase I the overall principles and engagement process and criteria for obtaining FPIC should be

agreed on with the affected Indigenous People (IP) communities potentially before bidding

Phase II the focus of the proposed FPIC process will then be on seeking consent from affected

IP communities for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior

to the main construction phase) In phase II it is likely that the PPP concessionaire will also

play a role and as such the Social Expert will continue to advise RUMSL but also monitor the

activities of the concessionaire

The Table 14 below summarises the key deliverables tasks involved and expectations against each

of these tasks in terms as per the scope The current status progress of these tasks and timeline for

future activities is also proposed It should be noted that these timelines may change in keeping with

evolving health and safety situation in context of COVID-19

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

I OBJECTIVE AS PER RFP The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities before bidding ie the submission of proposal for solar parks by concessionaire

Guidance to RUMSL (ONGOING)

Provide guidance to RUMSL on the most appropriate sequencing of steps vis-agrave-vis the FPIC process as per IFC PS 7 requirements

eg agreement and verification of legitimate IP representatives to represent affected communities in FPIC negotiations

agreement with IPs and their representatives on the FPIC engagement process and next steps including disclosure and consultation of draft updated project impact mitigation benefits package documentation

share of responsibilities between RUMSL and PPP concessionaire etc

This will also include advise on broader stakeholder analysis and engagement strategy

to build support for the FPIC approach and implementation of the project and

to participate in agreed outreach to influential local and international stakeholders andor additional sources of adviceinput

ERM has been providing handholding support to the client in terms of meetings and calls where the requirements of IFC PS 7 are discussed and possible implications of project decisions on the FPIC applicability are discussed

The training for RUMSL team on ICP (SEP) PS-7 and FPIC process on 27th Aug 2020

Sharing of Draft FPIC Approach Paper 1st Sep 2020

Discussion on Draft IPP and Formation of Committees for FPIC Process 16th Mar 2021

Submission of Note on FPIC budget FPIC Process

Responsibilities of PPP concessionaire submitted as part of Draft IPPs (Appendix-F)

A meeting with facilitating agency and their ToR was held in 1st Week of Apr 2021

A Joint field trip with RUMSL FPIC Team will be held after Covid-19 Second Wave is over to

- Verify the IP representatives and formation of ST committees

- To agree with ST committee on Draft Discussion and Decision Making Framework

Draft FPIC approach paper

Desk-based Information Compilation and Assessments

Review national applicable law to identify any gaps with IFC PS7 and ways to bridge them

While developing the FPIC approach leverage as much as possible the requirements of applicable law and the consent process usually applied when IP are affected

The FPIC approach should also ensure that affected IP communities are involved

ERM did not get access to documentation of community consultation as part of seeking

NOC3 from Gram Panchayats

Conversation with Sarpanch of villages with ST population revealed that consultation was

A field trip for a joint meeting between RUMSL and ST communities is proposed to be held after Covid-19 Second Wave is over The field trip will include the following

3 The allotment of unused Government land within any revenue village needed a resolution of concerned local government body (Gram Panchayat) under S 234 (4) till Nov 2018 See more details in

Section 21 below The Solar Parks does not require any EIA studied in India

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Identification of affected IP individuals and communities and representatives as well as project impacts mitigation measures and potential benefits related to them (ongoing process during ESIA)

Initial Meeting with Gram Panchayats (GPs) and Informing them on FPIC

Social MappingSite walk-through

Preparation of Draft FPIC Approach Paper which builds on key elements of IFC PS7 FPIC requirements is prepared in consultation with RUMSL IP representatives and other stakeholders and could be acceptable to each party

Internal Discussion and Consensus on FPIC Approach Paper

Sharing of Draft FPIC Approach with IP and Consensus Building

in the identification of impacts and provide input on the development of mitigation and benefit plans

The FPIC approach should be cognizant that impacts on vulnerable groups within the Affected Communities of IP if any should be adequately addressed during negotiation and in relevant documentation

It should be based on the engagement with local IP community decision-making authoritiesrepresentatives (and taking into account gender and other IFC PS 7 related prerogatives) to discuss the FPIC process with input from support organization

The draft approach paper should reflect a mutually acceptable engagement and negotiation framework for the FPIC process based on the principles of Good Faith Negotiations It should include a clear agreed indication on what constitutes consent in the project context

Ensure through revision and feedback that all other components under this assignment (ifwhen available) are aligned with the defined FPIC approach ndash including the Environmental and Social Impact Assessment (ESIA) Resettlement Action Plan (RAP) Stakeholder Engagement Plan (SEP) Gender Action Plan (GAP) and develop the Indigenous People Development Plan (IPDP)

restricted to Gram Panchayat members Though they initially reluctant to sign on the NOC after persuasion of District Collector they finally signed

PRA exercises which includes participatory mapping of social relationship livelihood and natural resources was held between 6th to 15th Aug 2020

The social mapping during 6-15th Aug collected information on existence of traditional decision making process and gender representation aspect

The proposed FPIC process as part of this FPIC approach paper (Refer Chapter-8) reflect GFN principles

The FPIC approach paper was discussed with RUMSL prior to sharing it with WB-IFC

The ESIA disclosure was done as part of the PRA exercises for IPP in Aug 2020The RAP survey was done in these villages around the same time to address their concerns over loss of privatepatta land

Consultations during RAP and Draft IPP preparation included PRA process where STs participated to identify impacts and expressed their expectation on project benefits

The feedbacks and key issues in ESIA (including GAP SEP) and RAP is synchronised in Draft IPP

- Introduce FPIC Facilitation Agency

- Facilitate formation of ST representative committees

- Inform them their rights in the context of FPIC process

- Consult and build mutual agreement on the lsquoengagement and negotiation frameworkrsquo (as in Chapter-8 of this report) which will include a clear agreed indication on what constitutes consent

- The STs Representatives will be asked about time they require for internal discussion and a tentative date for the first discussion on benefits proposed in IPP will be fixed

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Independent FPIC Facilitator Agency

Assess the need for Independent FPIC Facilitator Agency

Screening of IPOsCSOs for Independent FPIC Facilitator Agency possible facilitator options to determine how they can play a role in the process - who what how

Provide a list of names of key advocacy groupsNGOsCSOs considered SWOT (or similar) analysis of each organization considered identification of preferred organization and

Terms of Referencersquo for the role of the same in the FPIC process and its relevance for the FPIC process in that area and for that specific group

To be discussed in next call FA brings credibility of an independent agency (other than RUMSL and ESIA consultant) Considering the project context their position can be reviewed

The review and assessing the need for a FA is discussed in section 6 of this report The Scope of work for the FA is provided in Appendix-F

Preparation of IPDPIPPTDP

Note ESIA RAP SEP and other management plans should be prepared by this stage Infact the FPIC process report should also draw input from the engagement undertaken as part of the ESIA process

Indigenous People Plan (or

Community Development Plan

Stakeholder Engagement Plan) or

similar management documents

aimed at ensuring ongoing and

adequate engagement with IPs

The collection of baseline

information through PRA

exercises and a sample

household survey was done

in Aug 2019 The IPP draws

inputs from consultations for

ESIA RAP-LRP and

benefits are also

synchronised

Three Draft IPPs one for

each Solar Parks with a

package of benefits for

affected STs is ready and

disclosed in May 2021

These will be shared with

affected STs as part of the

FPIC negotiation process

subsequently for their

considerations and

acceptance

Preparation of Draft FPIC Process Report

FPIC Process Report will include (but not be limited to)

identification of IPs IP representatives and decision-making authorities

assessment of capacity of IPs IP representatives to undertake good faith negotiations

summary of any capacity building undertaken

agreed engagement and negotiation framework (including the process undertaken to agree upon the framework)

This document will be further updated and finalised once the whole process is completed

Note The FPIC process should incorporate key considerations contained in IFC PS 7 and GN 7 eg the need for free prior and informed engagement inclusion of differentiated measures to allow the effective participation of those identified as particularly disadvantaged or vulnerable including analysis of the legitimacy and representativeness of IP leaders and the role responsibilities and participation of

To be initiated once FPIC Process starts

The process of identification of IPs representatives and decision making authorities (ST RUMSL and Mediation Committees) which will take place once Covid-19 second wave is over and will be documented as Draft FPIC Process Report This will be a living document which will be updated after every round of field activities and negotiation meetings

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

detailed summary of consultations meetings engagement undertaken as part of the FPIC process

expert opinion on the process and outcomes

share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to complete the FPIC process

external stakeholders with vested interests in the outcome

Input to the bidding document

For the bidders in terms of FPIC amp IPDP requirements

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc

The Draft IPP for each Solar Park has Annexure-F providing roles and responsibilities and scope of work for the Solar Park Developer (SPD)

All 3 Draft IPPs with Annexure-F are ready for disclosure in May 2021

II OBJECTIVE AS PER RFP Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Preparation of communication Material

Communication material to be based on IPDP ESIA and RAP This should include culturally appropriate document on impacts and mitigation to be used during FPIC engagement and negotiation

All preparation including translation of FPIC-related materials including communication material summaries of relevant EampS documentation local benefits plans etc (printing arrangement to be agreed with RUMSL)

A Project Profile Fact Sheet was shared in Dec 2019

A summary of ESIA was shared in Aug 2020

The communication material based on Draft IPP will be prepared and used during FPIC process The Draft communication material will be shared with IFC-WB for their approval prior to its use in field

A parallel information disclosure process of RAP-LRP would also take place

Culturally Appropriate Information Disclosure Campaign

Share accurate and up to date information on project impacts proposed mitigation measures and proposed benefit streams in a culturally appropriate manner (ie in local language (as appropriate following discussion with IP representatives) in written and oral format)

The information disclosure should especially ensure that following are achieved

provide sufficient time for capacity building and

support to affected communities to understand these matters and their rights

The affected ST population speaks Malwi dialect The FPIC FA will have facilitators who would be familiar with this local dialect used

The FPIC FA will carry out the capacity building activities

The FPIC FA will spend 2 days at each Solar Park to do the capacity building workshops with local ST Representatives who would participate in FPIC discussion with RUMSL

The FPIC FA will do this once Covid-19 second wave gets over

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Consent from the Indigenous communities

Meetings for Negotiation and Decision Making

Participate in and offer expert support to key FPIC-related meetings involving affected IP representatives RUMSL and other relevant authorities etc during the FPIC process

Support RUMSL in the organization of these meetings and in recording their outcome including the collection of comments and concerns of those attending

Measuring Consent and Signing of FPIC Agreement

Note This include also support the RUMSL in designing undertaking and collecting evidence of Good Faith Negotiations (GFN) resulting in Consent which involves (i) willingness to engage in a process and availability to meet at reasonable times and frequency (ii) provision of information necessary for informed negotiation (iii) exploration of key issues of importance (iv) use of mutually acceptable procedures for negotiation (v) willingness to change initial position and modify offers where possible and (vi) provision of sufficient time for decision making

Present updated materials and seek consent from affected IP communities and their leaders

Document the consent process in a mutually agreed written format including an agreed mechanism for monitoring of key commitments in future and grievance redress as well as identifying share of responsibilities between the RUMSL SPDs and other relevant parties

Evidence of representativeness and involvement of Indigenous Peoples representative bodies and organizations (eg councils of elders or village councils)

Evidence of agreement between the parties as the outcome of GFN (eg FPIC agreement MOU a letter of intent and a joint statement of principles agreed mitigation plans collective land agreements etc)

Other documents may include Client records photographs media reports personal letters or third-party accounts etc regarding eventsdemonstrations other activities for the project undertaken by project-affected IP communities with high relative levels of participation by (i) the affected community as a whole or (ii) by sub-groups particularly affected by the project

ERM will work alongside FPIC FA and RUMSL to help the FPIC process taking right direction

Final FPIC Process Document

Throughout the FPIC process (Phase I and Phase II) ERM should help documenting the FPIC process and provide an opinion and direction about the process and outcome vis-agrave-vis IFC PS7

The whole set of activity in Phase II need to be updated as part of the Final FPIC Process Document

The tentative timeline for the FPIC Process was scheduled between Jun 2021 and Sep 2021 The timeline will be revised after the ongoing Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

The Draft FPIC Process Report will be submitted within 2 weeks of completion of FPIC process

Advise RUMSL but also monitor the activities of the concessionaire in phase II

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INTRODUCTION

14 Structure of the Report

This report is organized into following sections

Section 1 Introduction (this section)

Section 2 Applicable law and gaps assessment against IFC PS7 requirements

Section 3 Affected IPs population project impacts and mitigation

Section 4 Desk-based information compilation

Section 5 Engagement leading up to FPIC Approach Paper

Section 6 Independent facilitator agency

Section 7 Key elements in FPIC Process

Section 8 Draft Discussion and Decision Making Framework

15 Limitations

This Report is prepared after multiple field visits and interactions with affected ST community elected

leaders of Gram Panchayat and other key informants The assessments are based on information

received from RUMSL and other secondary information at some places The public health concerns

due to Covid-19 pandemic has prevented large community gatherings and communityrsquos willingness to

allow people from outside to spend much time with them

ERM team communicated with community members over telephone to seek clarifications and know

their views However it was not always possible to keep the discussion focused and definitive as it

could have been in case of a face to face discussion ERM has made efforts to build trust among

affected STs by sharing relevant information and answering their queries with clarity As FPIC process

is an itinerant process this relationship is expected to further evolve in future

The Draft Discussion and Decision Making Framework described in Chapter 83 though has been

accepted by RUMSL and reviewed by IFC and WB it would be discussed with committees formed by

affected STs and their feedbacks will be incorporated The FPIC process described in Chapter-8

therefore would undergo necessary changes

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan could not

be ascertained as nomadic tribes did not visit these sites when ERM conducted field visits The general

migration pattern of pastoral nomads is expected to have faced constraints of Covid-19 restrictions If

pastoral nomads or their representatives will be identified during the FPIC process an appropriate

decision on their participation will be taken

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

This section provides an understanding of the applicable national regulations that pertain to the process

of land procurement and the rights of the Indigenous Peoples and a comparison between the provisions

of the same against the IFC PS 7 requirements

It should be noted that the Environmental and Social Impact Assessment (ESIA) Reports4 and the

Resettlement Action Plans (RAP) provide a detailed understanding of applicable regulations This

section is focused on the government land procurement process and its impacts on the collective rights

of the Indigenous Peoples identified in the project

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in 2018

The allotment of government land for these three solar parks is done under provisions of the MP Land

Revenue Code 1959 The Chapter-XVIII of this Code deals with rights in abadi5 (habitation area) and

un-occupied land and its produce

The Madhya Pradesh Land Revenue Code (MPLRC) was enacted in 1959 and has undergone several

amendments since then It was recently amended in 2018 and 2019 These recent amendments along

with other changes changed the procedure for allotment of unoccupied government land Some of the

land allotment letters were prior to this amendment and others after this amendment (see details in

Section 42) Table 21 below provides a comparison of key provisions in pre and post 2018

amendment

Table 21 Key Provisions of Land Revenue Code

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

Collective (Nistar) Rights on Unoccupied Government Land

Section 114- Land recordsmdash In addition to the map and

Bhoo Adhikar Pustikas there shall be prepared for each

village a khasra or field book and such other land records as

may be prescribed

Section 233- Record of unoccupied landmdash A record of

unoccupied land shall in accordance with rules made in this

behalf be prepared and maintained for every village

showing separatelymdash (a) unoccupied land set apart for

exercise of nistar rights under Section 237

Section 114 (e) (i) (ii) requires

the details of all unoccupied land

be maintained as described in

Section 233 One Such

document is the Nistar Patrak

under Section 234 Section 233 A record of all unoccupied land shall be prepared for every village and urban area in accordance with rules made in this behalf

Preparation of

Nistar Patrak

and change in

entries in

Nistar Patrak

Section 234 (1)- The Sub-Divisional Officer shall in

accordance with the provisions of this Code and the rules

made thereunder prepare a Nistar Patrak for every village

embodying a scheme of management of all unoccupied land

in the village and all matters incidental thereto and more

particularly matters specified in section 235

Section 234- same as 1959 Sub

section (2) (3) (4) have been

removed

4 Three separate ESIA Reports for Solar Parks one for each Solar Park one for the Neemuch Transmission Lines (Units 12

and 3) and another for the Transmission Lines for Agar and Shajapur Solar Parks (for Units 4 to 8) have been prepared 5 According to the MP Land Revenue Code 1959 abadi means the area reserved from time to time in a village for the residence

of the inhabitants thereof or for purposes ancillary thereto and any other cognate variation of this expression such as village site or gaonsthan shall also be construed accordingly No change was made to this definition in the subsequent amendments to the code

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(2) A draft of the Nistar Patrak shall be published in the

village and after ascertaining the wishes of the Gram Sabha

it shall be finalised by Sub-Divisional Officer

(3) A copy of the Nistar Patrak so finalised shall be kept in

the office of the Gram Panchayat

(4) On a resolution passed by the Gram Sabha by a majority

of not less than two-thirds of the members present and

voting the Sub-Divisional Officer with the prior sanction of

the Collector and also after making any such inquiry as he

deems fit inter se change the entries in the Nistar Patrak

(b) Record additional unoccupied land under any entry in the

Nistar patrak for fulfilment of further Nistar rights of villagers

Matters to be provided for in Nistar Patrak

Section 235- The matter which shall be provided for in the

Nistar Patrak shall be as follows namely

(a) terms and conditions on which grazing of cattle in the

village will be permitted

(b) the terms and conditions on which and the extent to

which any resident may obtain-

(i) wood timber fuel or any other forest produce

(ii) mooram6 kankar7 sand earth clay stones or any other

minor mineral

(c) instructions regulating generally the grazing of cattle and

the removal of the articles mentioned in paragraph (b)

(d) any other matter required to be recorded in the Nistar

Patrak by or under this Code

Section 235- same as previous provision of Land Revenue Code

Provision in

Nistar Patrak

for certain

matters

Section 236 - In preparing the Nistar Patrak as provided in

Section 235 the Collector shall as far as possible make

provision for-

(a) free grazing of the cattle used for agriculture

(b) removal free of charge by the residents of the village for

their bona fide domestic consumption of-

(i) forest produce

(ii) minor minerals

(c) the concessions to be granted to the village craftsmen for

the removal of the articles specified in clause (b) for the

purpose of their craft

Section 236 - same as previous

provision of Land Revenue Code

Collector to

set apart land

for exercise of

Nistar rights

Section 237 (1) Subject to the rules made under this Code

the Collector may set apart unoccupied land for the following

purposes namely-

(a) for timber or fuel reserve

(b) for pasture grass bir or fodder reserve

(c) for burial ground and cremation ground

(d) for gaothan

(e) for encamping ground

Section 237 (1) remains same

6 Soil used particularly for road paving 7 In India an impure concretionary carbonate of lime usually occurring in nodules in alluvial deposits and especially in the

older of these formations

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(f) for threshing floor

(g) for bazar

(h) for skinning ground

(i) for manure pits

(j) for public purposes such as schools play grounds parks

road lanes drains and the like and

(k) for any other purposes which may be prescribed for the

exercise of right of Nistar

237 (2) Lands set apart specially for any purpose mentioned

in sub-section (1) shall not otherwise be diverted without the

sanction of the Collector

Section 237 (3) Subject to the rules made under this Code

the Collector after securing the land mentioned in clause (b)

of subsection (1) to minimum two percent of the total

agriculture land of that village may divert such unoccupied

land as mentioned in sub-section (1) into abadi or for

construction of roads state highways national highways

canals tanks hospitals schools colleges Goshalas and

any other public utility projects as may be determined by the

State Government

Provided that the land set apart for the purposes mentioned

in subsection (1) shall not be diverted and allotted to any

person for agriculture purpose

Section 237 (4) When it becomes indispensable to divert the

land set apart for the purposes mentioned in sub-section (1)

for such development and infrastructural projects which are

owned or approved by the State Government but not

covered under sub-section (3) the Collector after satisfying

himself on alternatives available and also on obtaining land

of equivalent area for fulfilling the same nistar rights from the

concerned project may divert the land for such purposes by

passing a reasoned order to this effect Thus in case Nistar

land needs to be diverted for the project the project needs to

make available an equivalent area for the replacement of the

same nistar rights

The section 237 (2) is removed

Section 237 (3) remained same

Section 237 (4) remains same

Rights in Fruit Bearing Trees and other trees in Un-Occupied Government Land

Section 239 (1) Where before coming into force of this

Code any fruit bearing tree was planted by any person in the

unoccupied land of any village and is so recorded then

notwithstanding that such land vests in the State

Government such person and his successor in interest

shall from generation to generation be entitled to possession

and usufruct of such trees without payment of any royalty or

other charge whatsoever therefore

Section 239 (6) the State Government may make rules for

carrying out the purposes of this section

Section 239 (1) same as 1959

Section 239 (6) The unoccupied

land on which any tree planting

permit or tree patta has been

given prior to the commencement

of MP Land Revenue Code

(Amendment) Act 2018 may be

used for any public purpose by

the order of Collector If any

interest of the holder of such tree

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

planting permit or tree patta is

adversely affected due to such

use the holder shall be entitled

for such compensation which

shall be calculated in such

manner as may be prescribedrdquo

Exclusive jurisdiction of revenue authorities

Section 257 - Except as otherwise provided in this Code or

in any other enactment for the time being in force no Civil

Court shall entertain any suit instituted or application made

to obtain a decision or order on any matter which the State

Government the Board or any Revenue Officer is by this

Code empowered to determine decide or dispose of and in

particular and without prejudice to the generality of this

provision no Civil Court shall exercise jurisdiction over any

of the following matters - (w) any claim to modify any entry

in the Nistar Patrak

Section 258 (1) The State Government may make rules

generally for the purpose of carrying into effect the

provisions of this Code

(2) In particulars and without prejudice to the generality of

the foregoing powers such rules may provide for (lviii) the manner in which the wishes of the villagers shall be ascertained under Section 234 (2)

Section 257 - same as 1959

Section 258 (1) and (2) (lviii)

same as 1959 it should be noted that the Section 234 (2) was removed in 2018 Amendment

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers Diverting the un-occupied

government land8 categorised as grazing land that is recorded in Nistar Patrak (there may be other

grazing land available) and such other Nistar rights9 including the right in fruit bearing trees and other

trees in unoccupied government land after the amendment in 2018 does not require any consent

process with concerned village community

Hence it is expected that the government land allotted for the project prior to the 2018 Amendment of

MP Land Revenue Code is expected to have involved a resolution of concerned Gram Sabha As per

Sec-6 of the Madhya Pradesh Panchayat Raj Act 1993 the quorum of every meeting of Gram Sabha

shall not be less than one-tenth of the total number of members of the Gram Sabha or five hundred

members of the Gram Sabha whichever is less The Act does not specify presence of women in

Gram Sabha to be mandatory

Other Indian laws which has provisions for consent process are not applicable to this project and an

overview of them is provided in Box 31 below

8 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands 9 Nistar rights refer to collective rights of a revenue village to use specified government land for the purposes mentioned in

S235 of MP Land Revenue Code This includes right to free grazing cattle collecting minor minerals construction materials burialcremation grounds for religious and cultural events etc

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Box 21 Other Indian Laws with provisions for consent process and their applicability

22 International Social Safeguard Policies Applicable to the Project

221 IFC Performance Standards

The part of PS1 dealing with Management Program envisages an Indigenous Peoples Plan (IPP) as a

thematic plan and should be developed by qualified experts with substantive experience For projects

with adverse impacts to Indigenous Peoples the client is required to engage them in a process of

Informed Consultation and Participation (ICP) and in certain circumstances the client is required to

obtain their Free Prior and Informed Consent (FPIC)

The FPIC from the affected communities of Indigenous Peoples is required when the following special

circumstances (in paragraphs 13ndash17 of Performance Standard 7) are present

Impacts on lands and natural resources subject to traditional ownership or under customary use

Relocation of Indigenous Peoples from lands and natural resources subject to traditional

ownership or under customary use

Significant impacts on critical cultural heritage that is essential to the identity andor cultural

ceremonial or spiritual aspects of IPs lives

Where a project proposes to use the cultural heritage including knowledge innovations or

practices of Indigenous Peoples for commercial purposes

IFC PS7 requires to avoid adverse impacts on Indigenous People and if adverse impacts are

unavoidable the project should prepare an Indigenous Peoples Plan outlining the actions to minimize

andor compensate for adverse impacts in a culturally appropriate manner Some of the key

provisions with respect to IPP are

A free-standing IPP may be prepared or it may be a component of a broader community

development plan

The IPP should detail actions to minimize andor compensate for adverse social and economic

impacts and identify opportunities and actions to enhance positive impacts of the project on the

Indigenous Peoples

Where appropriate the IPP may also include measures to promote conservation and sustainable

management of the natural resources on which the Indigenous Peoples depend

The IPP should include a clear statement of roles and responsibilities funding and resource

inputs a time-bound schedule of activities and a budget

The IPP shall be regular monitored and should be flexible to allow for it to be adapted as needed

if circumstances change

222 World Bank Operation Manual OP 410

The World Bankrsquos Operational Policy on Indigenous Peoples (OP 410) aims at ensuring that the

development process fosters full respect for the dignity human rights and cultures of IPs thereby

In Indian context the constitutionally recognized Scheduled Tribes are usually considered as Indigenous Peoples

while determining their entitlements under international social safeguards systems

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006( FRA) is not

relevant as no forestland was diverted The Provisions of the Panchayat (Extension to the Scheduled Areas) Act

1996 (PESA) acts is not applicable for the project as the project site is not in a schedule V area There are no

specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement

consultation and consent

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

contributing to the Bankrsquos mission of poverty reduction and sustainable development To achieve this

objective Bank-assisted projects which affect IPs provide them a voice in design and implementation

avoid adverse impacts where feasible or minimize and mitigate them and ensure that benefits

intended for them are culturally appropriate

The Bank recognizes that IPs are commonly among the poorest and most vulnerable segments of

society and in many countries they have not fully benefited from the development process It also

recognizes that the identities cultures lands and resources of indigenous peoples are uniquely

intertwined and especially vulnerable to changes caused by development programs Because of this

issues related to indigenous peoples and development are complex and require special measures to

ensure that IPs are not disadvantaged and that they are included in and benefit from these programs

as appropriate

Under the OP 410 the Bank requires the borrower to undertake a social assessment to evaluate

projectrsquos potential positive and adverse effects on the IPs and to examine project alternatives A

project that affects Indigenous Peoples the borrower engages affected IPs in a free prior and

informed consultation (FPICon) process

Note The World Bank adopted Environment and Social Framework (ESF) which comprises of ten Environment

and Social Standards (ESS) The ESS-7 deals with Indigenous PeoplesSub-Saharan African Historically

Underserved Traditional Local Communities which requires FPIC to be obtained in special circumstances where

customary rights on natural resources used by IPs is impacted The WB has financed the renewable projects to

MNRE prior to adoption of the new ESF in Dec 2019 The Shajapur Solar Park is under the old WB safeguards

and therefore the new ESF is not applicable

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard Policies of IFC and WB

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers The diversion of the un-

occupied government land10 categorised as grazing land that is recorded in Nistar Patrak (there may

be other grazing land available) and such other Nistar rights including the right in fruit bearing trees

and other trees in unoccupied government land after the amendment in 2018 does not require any

consent process with concerned village community A comparison of key provisions of PS-7 vis-agrave-vis

legal provisions in Indian context is provided in Table 22

Table 22 Comparison of Provisions of Consent Process in Applicable Indian

Regulations vis-agrave-vis Provisions in IFC PS-7

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Assessment of Impact on Indigenous People

The client will identify through a process of Social and Environmental Assessment all communities of Indigenous Peoples who may be affected by the project within the projects area of influence The client will assess the nature and degree of the expected social cultural (including cultural heritage) and environmental impacts (direct and indirect) on them and avoid adverse impacts whenever feasible

There is no requirements for environment impact assessment (EIA) for Solar Park Projects There are no specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement consultation and consent

10 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands Such usages will be confirmed only through the Tarneem process for each site

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Preparation of IPP

The clients actions will be developed with the informed consultation and participation of affected Indigenous Peoples and contained in a time-bound plan such as an Indigenous People Plan or a broader community development plan with separate components for Indigenous Peoples

There is no legal requirement for an Indigenous Peoplersquos development plan

Consultation and Consent from affected IPs

In projects with adverse impacts on affected communities of Indigenous Peoples the consultation process will ensure their free prior and informed consultation and process of community engagement will be culturally appropriate and commensurate with the risks and potential impacts to the Indigenous Peoples

The acquisition of the private land owned by ST will be done through MP Consent Policy 2014 and the RAP addresses the impact on individual ST land ownersoccupiers The impact on customary rights (such as Nistar rights) over collectively used unoccupied government land is dealt under the provisions of MP Land Revenue Code 1959 There is no consultationconsent process for diversion of grazingNistar lands under MP Land Revenue Code 1959 (As amended up to 2019) The consent process in other Indian laws such as FRA or PESA which has consent process is not relevant to the project

Land Revenue Code had a requirement for Gram Sabha consent to be taken prior to diversion of

Nistar rights as part of the 2018 Amendment the same provision was removed As most of the

government land for Shajapur Solar Park was allotted in 2017 Table 23 below provides a

comparison of provisions of the consent process under MP Land Revenue Code 1959 (prior to Nov

2018 amendment) vis-agrave-vis requirements under IFC PS-7

The key elements of FPIC process as per IFC PS (including Guidance Notes- GN) identified for

comparison includes

1 Requirements of information disclosure (as in PS-129) 2 Informed consultation and participation (as in PS-130-31 and PS-710) 3 Good Faith Negotiation (as in GN-725) and 4 Consent and documentation (as in PS-712)

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Information Disclosure

Relevant project information must be disclosed to Affected

Communities and other stakeholders to enable them to

understand the risks impacts and opportunities of the project

The Project will provide Affected Communities with access to

relevant information on

the purpose nature duration and scale of the project

risks and potential impacts and relevant mitigation measures

the envisaged stakeholder engagement process and

the grievance mechanism

Information disclosed must be relevant transparent objective

meaningful and easily accessible and in a culturally appropriate

local language(s) and format and is understandable to Affected

Communities

Under MP Revenue Code 1959 and MP

Panchayat Raj Act 1993 the information

disclosure to affected communities (including

Schedule Tribes) is limited to the intended

purpose of the allotment of unoccupied

government land

The disclosed information and proceedings are

recorded using the language of the State

The information disclosure to affected communities

prior to the meeting does not disclose all relevant

information particularly potential risks The

information disclosed is not easily accessible to STs

and other vulnerable communities

The process does not involve any grievance

mechanism

Informed consultation and participation

Where a Project has potentially significant adverse impacts on

affected communities an ldquoinformed consultation and

participationrdquo (ICP) process should take place ICP is an

organised and iterative consultation that involves a more in-

depth exchange of views and information leading to the Project

incorporating the views of those affected into project decision-

making on matters that affect them directly

The consultation process should capture both menrsquos and

womenrsquos views and their different concerns and priorities The

process should be documented in particular the measures taken

Section 234 of MP Revenue Code 1959 (Prior to

Nov 2018 Amendment) required the draft Nistar

Patrak of every village and any changes in therein

to be published by Sub-Divisional Officer with

prior sanction of the District Collector only after

ascertaining wishes of the Gram Sabha

(expressed through a resolution passed in Gram

Sabha held for this purpose)

As per Section 6 of the MP Panchayat Raj Act

1993 the Gram Sabha can be held with a quorum

of one-tenth of the total member of Gram Sabha

The MP Revenue Code does not require any

iterative consultation that involves in-depth

exchange of views

The participation of women and other vulnerable

sections is not mandatory

The quorum of the meeting is only ten percent of the

total members of the Gram Sabha The notice for

holding a special Gram Sabha is only 7 days and

there is limited information shared in terms of the

agenda of the meeting Hence a resolution passed

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

to avoid or minimise risks to and adverse impacts on the

Affected Communities and should inform those affected about

how their concerns have been considered

In addition the process should Involve Indigenous Peoplesrsquo representative bodies and

organisations as well as members of the Affected Communities of IPs and

Provide sufficient time for IPs decision-making processes

or five hundred members whichever is less

There is no specific requirement on presence of

women to fulfil quorum requirements

A special meeting of the Gram Sabha is held

within seven days of receiving the requisition

by a Gram Sabha with a bare minimum presence

does not reflect majority decision

The process does not require representative bodies

of IPs to represent their interests

Good Faith Negotiation

FPIC will be established through good faith negotiation between

the Project and the Affected Communities of IPs Good faith

negotiation generally involves (i) Willingness to engage in a process and availability

to meet at reasonable times and frequency (ii) Provision of information necessary for informed

negotiation (iii) Exploration of key issues of importance (iv) Mutually acceptable procedures for the negotiation (v) Willingness to change initial position and modify

offers where possible and (vi) Provision for sufficient time for decision making

The MP Revenue Code require neither iterative

prior consultation nor exchange of views with

administration

The administrative process for allotment of

unoccupied government land does not involve a

negotiation process through which their feedback

and concerns are incorporated or addressed

Consent

In certain circumstances the client is required to obtain the Free

Prior and Informed Consent (FPIC) of affected IPs FPIC does

not necessarily require unanimity and may be achieved even

when individuals or groups within the community explicitly

disagree The measurement of consent is expected to be

included in the lsquomutually accepted processrsquo for FPIC decision

making

Consent

Section 234 (4) required the Gram Sabha to pass

a resolution with support of a majority not less than

two-thirds of the members present and voting As

per Section 6 of the MP Panchayat Raj Act 1993

the Gram Sabha can be held with a quorum of one-

tenth of the total member of Gram Sabha or five

hundred members whichever is less There is no

specific requirement on presence of women to fulfil

quorum requirements

Consent

The FPIC process in IFC PS-1amp7 recognizes that

consent is not necessarily a unanimous decision

yet there has to be a mutually agreed threshold of

consent in an FPIC process that can vary from

project to project The threshold defined in MP

Panchayat Raj Act 1993 is one-tenth of the total

members of Gram Sabha passing a resolution with

support by two third majority present and voting

Thus the consent threshold for a resolution is 66

of the total members of Gram Sabha

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Documentation

The client will document

The mutually accepted process (FPIC Decision Process Framework Document) between the client and Affected Communities of Indigenous Peoples and

Evidence of agreement between the parties as the outcome of the negotiations

Documentation

The documentation is limited to the entries in Gram

Sabha minutes book The entire set of

documentation is kept by Administration and not

shared with Gram Panchayat

Considering this low threshold as per legal

requirements the FPIC process requires a mutually

accepted threshold for decision making

Documentation

The documentation of the process carried out during

the Gram Sabha meetings leading to the resolution

though is written down in the Gram Sabha minutes

book however there is no guideline on what should

be covered Therefore a mutual agreement on

documentation requirement is necessary

As described in GN62ndash65 where government processes involve project-level decision and actions the client should review these processes in relation to the requirements of the Performance Standard and address identified gaps where feasible

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

The FPIC was triggered at the scoping stage on account of impact on grazing land and other natural

resources within the allotted government land on which STs have claims of customary use which is also

recognized under MP Land Revenue Code as Nistar rights The statement of different categories (which

are part of the Nistar rights of village community) of government land to be used for the proposed Solar

Parks from different villages and percentage of ST population in these villages is provided below

31 Affected Villages Government land used11 by ST Population

311 Neemuch Solar Park (Unit 1-3)

The Neemuch Solar Park is comprised of 3 units and the land is acquiredpurchased from 3 villages

The land category (classification in revenue records as per their currentintended use) is provided in

Table 31 below

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected Villages

Village Name

Govt Land Category in Hindi

Govt Land Category in English Sum of Area (Ha)

ST Population in of Total Village Population

Unit -1

Bardavada Chargah Grazing land 2271 55

Charnoi KamdalKK (Kabil Kast)

Grazing land 4013

DathaKamdal Land with stone outcrops and shallow soil

1655

Gair mumkinCharnoi Uncultivable waste land grazing land

492

Kabil Kast Cultivable 2

Kamdal Land with stone outcrops 169

KamdalDathaDahar Grazing land 4641

KamdalDathaKaKa Grazing land 4279

PK 052

NA 2053

Sub-Total (Bardawada) 25774

Kawai Datha Land with stone outcrops and shallow soil

8962 1992

NA 425

Sub-Total (Kawai) 9388

Total Unit 1 351615

Unit -2

Badi Datha 052 2292

Kabil Kast 11568

NA 5835

Sub-Total (Badi) 17455

Kawai NA 17846 1992

Sub-Total (Kawai) 17846

Total Unit 2 35301

Unit -3

Badi Charnoi (grazing) Grazing land 355 2292

Datha 3805

Gairmumkin Charagah

(grazing)

Uncultivable waste land

grazing land

4184

11 The MP Land Revenue Code recognizes the right to use for grazing collection of timber fire-wood earth morums and other

products (see Section 235 of MP Land Revenue Code)

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

KaKa (Kabil Kast) Culturable wasteland 5

Kamdal 11179

NA 13727

Badi total 36945

Total Unit 3 3694557

Grand Total (Unit-1 2 and 3) 107408

Note land category for the units is as per the Allotment Letters NA= Not Available

The screening of the Census 2011 data shows that there is presence of ST population in all three

villages In Badi and Bardawada villages the land categories such as Charnoi Charagah are clearly

recorded as grazing lands The map below shows the location of village settlements and their area

designated as Grazing Land

The ST families in Badi and Kawai live in several small cluster of satellite settlements The Bardawada

had only 22 ST population with 4-5 families Bardawada is part of Dhardi Gram Panchayat and the ST

households live farther from the Solar Park boundary Their households are scattered and dependency

on the allotted government land for Bardawada village could not be established In terms of

concentration of ST population Badi and Kawai are considered as major ST settlements

Thus ~100 ST households in Badi and Kawai have a claim on customary use of ~18938 ha of

designated grazing land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

312 Agar Solar Park (Unit 4 amp 5)

The Table 32 provides a break-up of the designated land categories of government land as per revenue

records in Agar Solar Park

Table 32 Agar Solar Park- Government Land- Land Use Category

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Agar Solar Park (unit 4)

Bijnakhedi Germumkin Uncultivable waste land 5598 0

Sub-Total (Bijnakhedi) 5598

Dudhpura Agriculture Agriculture 2243 0

Bardi NA 6631

Gothan Livestock rearing land 2

Khadar The floodplains formed by

yonger alluvium

018

Tree Plantation NA 1495

NA NA 5082

Sub Total (Dudhpura) 15669

Karwa Khedi Chragha Grazing land 251 0

K K NA 475

Khachar Grazing land 068

Pahad Hilly terrain 12392

NA 216

Sub Total (Karwa Khedi) 15346

Keasi Dehariya Gochar Grazing land 283 0

Sub Total (Keasi Dehariya) 283

Ladwan Bardi 7963 579

Charnoi Grazing land 947

Gochar Grazing land 2749

Kavil Kast 609

Khachar Grazing land 238

Pahad Hilly terrain 3062

Waterbody Water body 094

NA 475

Sub Total (Ladwan) 16137

Madhopur Germumkin Uncultivable waste land 1558 0

Sub Total (Madhopur) 1558

Pipalia Kumar Bardi 3492 0

Agriculture land Agriculture 506

Sub Total (Pipalia Kumar) 3998

Total Unit 4 611381

Susner Solar Park (Unit 5)

Palda Germumkin Uncultivable waste land 5689 036

NA 6928

Sub Total (Palda) 12617

Naharkheda Germumkin KaKa Uncultivable waste land 4125 0

Germumkin Uncultivable waste land 1868

NA NA 8908

Sub Total (Naharkheda) 14901

Umariya Charnoi Grazing land 3660 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Charokhar Grazing land 416

Chragha Grazing land 9114

Germumkin Uncultivable waste land 147

Kadim NA 011

Shaskiye Government land 218

Sheda NA 01

NA NA 20907

Sub Total (Umariya) 35806

Pipaliya Nankar NA NA 1822805 0

Total Unit 5 8161745

Note land category for the unit 4 is as per the kml file provided by RUMSL on 30012020 as the allotment letters did not carry

the land use details

Ladwan village has 579 of ST population (~12 households) who have claim on customary use of

3934 ha of designated grazing land Palda was found to have only 1 ST family Moreover no Charnoi

Chargah Gochar land is acquired from Palda Hence ST families in Ladwan were selected to be in

focus for FPIC process

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

313 Shajapur Solar Park (Unit 6-8)

The Table 33 provides a break-up of the land categories of government land as per revenue records

in Shajapur Solar Park In Shajapur Solar Park (Unit 6-8) five villages have ST population They are

Jawadi (034 STs) Parsula (1768 STs) Dehripal (018 STs) Fawaka (238 STs) and

Chouma (072 STs) Of these Dehripal Fawaka and Surajpur do not have any Charnoi Chargah

Gochar land impacted

Table 33 Shajapur Solar Park- Government Land- Land Use Category

Village Name Govt Land

Category in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Moman Badodiya-Unit6

Burlay Agriculture Agriculture 813 0

Germumkin Uncultivable waste land 224

Nala Stream Drain 138

Burlay Total 3191

Jawadi Agriculture Agriculture 198 034

(1 Household with

3 persons)

Gochar Grazing land 4189

Idhan Hetu For fuelenergy 209

Kabil Kast 316

Muram Hetu For Murram (fine aggregate) 063

Pahad Hilly terrain 339

Shivir Camping ground 041

NA 2011

Jawadi total 3596

Dhatrawada Agriculture Agriculture 338 0

Charnoi Grazing land 058

Chragha Grazing land 4058

Germumkin Uncultivable waste land 10638

Gothan Livestock rearing land 128

K Kast 557

Kabil Kast 1217

Kadim 074

Khadan Quarry 291

Khalihan Threshinggrain storage etc 167

Murum Hetu

Khadan

For Murram 125

Nala StreamDrain 042

Road Road 117

NA 6

Dhatrawada total 1841

Total (Unit 6) 25197

Momain Badodiya-Unit 7

Parsula Agriculture Agriculture 515 1768

(~41 households) Barda Rockyhilly 847

Barda Nistar

Chragha

Grazing land 947

Charnoi Grazing land 1064

Idhan Hetu

Surakshit

Secured for fuelenergy-

firewood

209

KK 137

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Khchar Grazing land 311

Nala Streamdrain 146

Nistar Chragha Grazing land 393

Parsula Total 12192

Dehripal Agriculture Agriculture 124 018

(1 Household with

5 populaiton)

Birdi GM 295

Brda 8054

Brda Lala 055

Chuna Hetu 105

Germumkin Uncultivable waste land 2015

Kankad Chuna

Hetu

For coarse aggregate and

lime

105

Khad ke Gadde 15

Muram Hetu For Murram (fine aggregate) 042

Watershed

Planning

Watershed planning 027

NA 1916

Dehripal Total 14004

Bijanakhedi Agriculture Agriculture 2199 0

Bardi 4101

Bardi Charnoi Grazing land 1274

Bardi 385

Chamdi Sthan 042

Charagah Grazing land 035

Charnoi Grazing land 018

Chragha Grazing land 1404

Germumkin Uncultivable waste land 858

Idhan Hetu 209

Khad ke gadhe Manure collection 084

Khalihan Hetu Threshinggrain storage etc 143

Mitti Hetu 063

Muram Hetu For Murram 063

Nala Streamdrain 36

Pathar Hetu For Stone 105

Road Road 203

Shivir Bhumi Camping ground 042

NA 288

Bijanakhedi total 11876

Fawaka Agriculture Agriculture 016 238

(4 Households with

28 population)

Brda Hilly terrain 863

Idhan Hetu Secured for fuelenergy-

firewood

25

Kakkad 418

Muram Hetu For Murram (fine aggregate) 179

Fawaka Total 1726

Chouma Agriculture Agriculture 392 072

(3 Households with

19 population)

Brdi Hilly terrain 562

Chamda Sthan For de-skinning 021

Charnoi Grazing land 989

GM 2943

Gothan Livestock rearing land 5

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Muram Pathar

Khadan

Murram (fine aggregate) 041

Nala Streamdrain 015

Chouma total 5463

Burlay Germumkin Uncultivable waste land 1543 0

Nala Streamdrain 019

NA 2604

Burlay Total 4166

Total (unit 7) 49427

Shajhapur (unit 8)

Surajpur Bardi Hill Terrain 898 203

(3 Households with

16 population)

Germumkin Bardi Uncultivable hill terrain 1170

Nala Streamdrain 597

NA 1894

Surajpur total 4559

Lalpur Beed 023 0

Beed Gair Mumkin 053

Brdi 2333

Charagrah Grazing land 18

Charnoi Grazing land 115

Gair Mumkin Brdi 1608

Kadim 115

Nala Streamdrain 055

NA 1684

Lalpur Total 6166

Hanoti NA 16291 0

Total (unit 8) 27024

Note land category for the units is as per the excel sheet received on 18062020 from RUMSL

Hence 41 ST households in Parsula who have a claim of customary use on ~3134 ha of

designated grazing land was selected to be the focus for FPIC Process The map below shows

the location of Parsula and the area designated as Grazing Land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

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Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

32 Selection of FPIC Villages

The assessment of the relevance of the four special circumstances that requires free prior informed

consent (FPIC) to be obtained from affected ST population was undertaken On the basis of the detailed

assessment undertaken as part of ESIA RAP along with targeted consultations with the IP

communities three circumstances are assessed to be not relevant to the project context

Relocation of STs was avoided while determining Solar Park boundary for all the three solar

parks and therefore no relocation of STs is anticipated from lands and natural resources subject

to traditional ownership or under customary use

The physical impact on cultural heritage sites with affiliation to STs is avoided in the three Solar

Park lay out and there is no potential significant impact on critical cultural heritage that is

essential to the identity andor cultural ceremonial or spiritual aspects of local STs community

The Solar Park does not propose to use the cultural heritage including knowledge innovations or

practices of STs for commercial purpose

Table 34 provides the list of villages where the FPIC process will focus covering ST households living

within it The assessment concludes that affected ST families have been living in these villages for

generations and have been using the government land (which was assessed to be subject to

traditional ownership or under customary use of the ST communities) allotted for Solar Park Project

for free grazing their cattle collection of fire-wood and collect edible fruits and plants mostly for self-

consumption The diversion of these land for the solar park will result in impacts on lands and natural

resources It was noticed that 7 other project affected villages had less than 5 ST households the

impact on their customary use of land acquired for the project was assessed and included in this table

too

Table 34 Villages to be covered in FPIC Process

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

Neemuch

Solar Park

Badi

(including 2

satellite

settlements)

80 (~450) Bhill Bardawada which is part of Dhardi Gram

Panchayat has only 4 ST families The location

of these ST households and consultations did

not indicate the government land allotted to

Neemuch Solar Park were under customary use

by them Kawai 17 (~100) Bhill

Agar Solar

Park

Ladwan 12 (~50) Bhill Palda village has 1 ST household and no

grazing (designated as Charnoi Chargah

Gochar) land is acquired from Palda

Palda village has 276ha of designated grazing

land and 28735ha of unoccupied government

land which they will continue to use for free

grazing their cattle and collection of fire wood

Hence the customary use of land by ST

household will continue with a negligible impact

Shajapur

Solar Park

Parsula 41 (~250) Bhill

Bhilala

Apart from Parsula 5 other affected villages

have less than five ST households These

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

villages (with the number of ST households)

are Jawadi (1) Dehripal (1) Fawaka (4)

Chouma (3) and Surajpur (3) The remaining

designated grazing land and total government

land for these 5 villages is provided below

Village Remain-

ing Desig-nated Grazing land (ha)

Total govern-ment land after Project allotment (ha)

Designated Grazing Land in percentage total Govern-ment land

Jawadi 2125 2705 786

Dehripal 241 8116 03

Fawaka 5032 5703 882

Chouma 2278 8167 279

Surajpur 1224 2592 472

The consultation with STs at Parsula informed

that unlike them these ST families do not keep

livestock in large number and mostly work as

construction workers Hence the land allotted to

Solar Park was not under customary use by

them for their livelihood

Note The ST families in these 7 villages will have access to the Grievance Mechanism to register their claims to

participate in the FPIC process In such a case their demands will be shared with concerned ST Committee (or

referred to Mediation Committee) and decision to include them in the process will be taken and an appropriate

mechanism for their representation and participation will be adopted

33 Impact on Nomadic Pastoral Communities

The seasonal use of the grazing and government land by nomadic pastoral communities was noticed

in scoping stage However further consultations with local villagers revealed that they do not visit

regularly and rarely camp on the land allotted to Solar Park These nomadic pastoral communities are

from the neighbouring state Rajasthan and are not recognized as STs in Madhya Pradesh

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan and

consultation with any pastoral nomadic tribes was not held as they did not visit these sites when ERM

conducted field visits The general migration pattern of pastoral nomads is expected to have faced

constraints of Covid-19 restrictions If pastoral nomads or their representatives will be identified during

the FPIC process an appropriate decision on their participation will be taken

ERM will consult GoMP to obtain records of grazing permits issued to pastoral nomads of other states

and determine if any of the villages impacted by Solar Parks figure in it More information on their

migration routes and pattern of seasonal use of forest and revenue land for grazing (which would help

assessing their collective attachment to impacted land) will be collected

Due to C-19 restrictions the regular migration patterns by pastoral nomads are affected in 2020 The

next migration season will be in Nov-Dec 2021 In absence of the particular pastoral nomads the

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

GoMP data on pastoral nomad communities who are issued permit will be used and their IPs status

will be screened through secondary ethnographic literature

FPIC is an iterative process If nomadic pastoral communities could not be consulted the rights of

pastoral nomads will be recognized in TDP and a provision for engagement with them to identify

adequate mitigation measures will be kept in TDP

34 Impact on Government and Grazing Land

The total geographical area of these selected FPIC villages grazing land (Charnoi) available after

allotment remaining government land after allotment percentage of the government land remaining is

given in Table 35 below As per provisions of the MP Land Revenue Code a minium of 2 of the

total private land in a revenue village is reserved as Charnoi or grazing land It is observed that

Ladwan and Parsula have more than this recommended minimum

Table 35 Designated grazing land (Charnoi) and Remaining Government Land

Solar Park Unit

Village Name

Geo

gra

ph

ical

Are

a o

f V

illa

ge

(h

a)

To

tal

Pri

vate

La

nd

To

tal

Go

vern

men

t L

an

d P

rio

r to

All

otm

en

t (

of

To

tal

Geo

gra

ph

ic

Are

a)

To

tal

Go

vern

men

t L

an

d R

eq

uir

ed

for

So

lar

Park

(

of

To

tal

Go

vern

men

t L

an

d)

Rem

ain

ing

Go

vern

men

t L

an

d a

fter

All

otm

en

t to

So

lar

Pa

rk

Perc

en

tag

e o

f G

overn

men

t L

an

d o

f

To

tal

Geo

gra

ph

ical

Are

a

( d

ecre

as

e o

r In

cre

as

e)

()

Desig

nate

d G

razin

g L

an

d

avail

ab

le a

fte

r P

roje

ct

all

otm

en

t (h

a)

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g

Lan

d)

of

the R

em

ain

ing

Go

ve

rnm

en

t

La

nd

()

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g)

Lan

d o

f th

e T

ota

l P

rivate

La

nd

Neemuch Solar Park Unit 1 amp2

Kawai 82698 20132 62566 (76)

24572 (39)

37994 (61)

46 (-30)

397 104 2

Neemuch Solar Park Unit 2 amp3

Badi 130055 33599 96456 (74)

51499 (53)

44957 (47)

35 (-39)

646 144 2

Agar Solar Park Unit 4

Ladwan 59076 31913 27163 (46)

16832 (62)

10331 (38)

17 (-29)

6682 6468 21

Shajapur Solar Park Unit 7

Parsula 69061 51439 17622 (26)

1162 (66)

6002 (34)

9 (-17)

1802 3002 4

Note () As per requirement under MP Land Revenue Code a minimum of 2 of the private land area within a

revenue village is to be reserved as Charnoi or grazing land for collective use by villagers

() Total Charnoi or grazing land prior to the allotment of Government land available in secondary sources

(Census 2011) is old as the land allotment took place between 2017 and 2019 Some Government Land

Allotment Letters mentioned the pre-allotment land category classifications (see Table 31 32 and 33) but this

data was not available for all vilalges to calculate the proportionate reduction of Charnoi land

The percentage of government land in some of the villages was high prior to the allotment of land for

Solar Parks For example the government land in Kawai formed 76 and that of Badi 74 of the

total geographical area Allotment of government land for Solar Parks has reduced the proportion of

the government land in these villages but the percentage of reduction varies from village to village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

For Kawai the percentage of government land after allotment has reduced from 76 to 46 (-30)

and for Badi it changed from 74 to 35 (-39) In Ladwan village the percentage of government

land changed from earlier 46 to 17 (-29) Similarly in Parsula the percentage of government

land changed from earlier 26 to 9 (-17)

The revenue department has designated some part of the remaining government land as Charnoi or

grazing land as per current Nistar Patrak The designated grazing land area meets the minimum

requirement of 2 of the total private land of that particular revenue village The designated grazing

land area forms 104 and 144 of the remaining government land for Kawai and Badi respectively

The designated grazing land in Ladwan forms 6682 of the remaining government land and in

Parsula it forms 1002 of the remaining government land

35 Impact on Cultural Sites affiliated to STs

The physical impact on all cultural sites (both for ST and Non-ST communities) was avoided by

excluding them from the Solar Park lay-outs However some of the cultural sites will be in close

proximity or access to some of them would be possible only through the Solar Park boundary An

overview of the cultural sites affiliated to STs for each of the Solar Parks is provided below

Table 36 Impact on Cultural Sites Affiliated to STs

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

Shajapur

Parsula

Gwalon ka

Mandi

Located within Solar

Park boundary

Adequate area (as agreed during FPIC

consultations) around the Gwalon-ka-Mandi to

be left unused in Solar Park lay-out

A road of sufficient width to be provided to

reach Gwalon-ka-Mandi

SPD will carry out improvements of the cultural

site after discussion with STs and other

communities using it

SPD will provide adequate civic amenities

(parking space drinking water lighting public

toilets etc) as per discussion with STs and

other community using it

Agar Solar

Park Ladwan

Gwaal Dev

Shrine

Located at the

margin of Solar Park

boundary

The SPD should leave the shrine and

adequate space around it in its lay out plan

Will ensure that access to the shrine by

community is maintained

The SPD will consult community to improve the

shrine Or build a new shrine for Gowals in the

new grazing area

Neemuch

Solar

ParkBadi and

Kawai

None The shrines and

cremation grounds

used by Bhils in

Kawai and Badi are

None

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

avoided in project

layout plan

No cultural sites or shrines with cultural significance for STs as a community was found during RAP

survey

36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure

The power evacuation infrastructures associated with these 3 Solar Parks are listed below The Pooling

Sub Stations (PSS) are located within the Solar Park boundary There will be 8 transmission line (TL)

sections whose footprint will be outside of the solar park boundary

Table 37 List of Power Evacuation Infrastructure

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

Neemuch

Solar Park

33kV220 kV Pooling Substation Unit-1 258 ha Located within the Solar Park

boundary 33kV220 kV Pooling Substation Unit-1 296 ha

33kV220 kV Pooling Substation Unit-1 887 ha

PGICL ISTS Station Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Neemuch

Solar Park

220 kV SC Line - 1 (From Unit 1 to Unit 2)

Transmission Line (TL) 1

332 km TL footprint is outside of the MP

Solar Park boundary includes

28 Towers (04 ha 144sqm

for each tower base) and RoW

of 13m width of 920ha

220 kV SC Line - 2 (From Unit 2 to PGCIL

ISTS substation)

Transmission Line (TL) 2

157 km

220 kV SC Line - 3 (From Unit 3 to PGCIL

ISTS substation)

Transmission Line (TL) 3

251km

Agar and

Shajapur

Solar

Parks

33kV220 kV PSS 4 in Unit 4 158 ha Located inside Solar Park

boundary 33kV220 kV PSS 5 in Unit 5 539 ha

33kV220 kV PSS 6 in Unit 6 513 ha

33kV220 kV PSS 7 in Unit 7 143 ha

33kV220 kV PSS 8 in Unit 8 196 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

PGCIL ISTS substation 830 ha Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Agar and

Shajapur Solar Parks

220 kV SC Line - 4 (From Agar Solar Park Unit 4 to interconnecting point with TL 7) Transmission Line (TL) 4

121 km TL footprint is outside of the MP

Solar Park boundary includes

372 Towers (536 ha

144sqm for each tower base)

and RoW of 13m width for

11914kms with 14951ha

220 kV SC Line - 5 (From Agar Solar Park Unit 5 to PGCIL ISTS substation) Transmission Line (TL) 5

2932 km

220 kV DC Line - 6 (From Shajapur Solar Park Unit 6 to Shajapur Solar Park Unit 7) Transmission Line (TL) 6

667 km

220 kV SC Line - 7 (From Shajapur Solar Park Unit 7 to PGCIL ISTS substation) Transmission Line (TL) 7

1646 km

220 kV DC Line - 8 (From Shajapur Solar Park Unit 8 to PGCIL ISTS substation) Transmission Line (TL) 8

6548 km

361 Use of Government Land in TLs Associated With Neemuch Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 38 below

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of STs

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

1 Arnya 088 958 007 784

Kheda Moka Ka Dol 223 1807 055 83

Bardawada 009 5651 002 55

Kawai 112 8265 016 20

2

Kawai 104

Badi 102 13004 012 23

3 Badi 285

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

Chaksodijhar12 043 4475 012 0

Grand Total 966 42782 011

The transmission line RoW comes from six revenue villages out of which 5 are Solar Park affected

villages There are 2 additional villages coming under TL RoW ie Arnya (088ha) and Kheda Moka

Ka Dol (223ha)

The population of Arnya in 2011 (as per census) was 969 out of which 784 were ST population

The Kheda Moka Ka Dol is comparatively a smaller village with total population of 348 and 83 of it

belong to STs

The proposed RoW of the transmission line will use 007 and 055 of the unused government land

in Arnya and Kheda Moka Ka Dol respectively The RoW of the Transmission Line does not pass

through any reserved or protected forest land The vegetation cover in the transmission line RoW is

mostly shrubs and grassland There would be no restriction on current use of the RoW for free grazing

of cattle Hence the transmission line will not impact customary use of the RoW land by ST

population in Arnya and Kheda Moka Ka Dol

362 Use of Government Land in TLs Associated With Agar Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 39 below

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST Population

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

4 Ladwan 068 13311 051 6

4 Pachora 089 273 033 0

5 Chkali Parmar 093 1567 059 0

5 Jhikadiya 266 13514 197 0

5 Pipalya kumar 229 13328 172 0

5 Chikali goyal 287 20523 140 0

5 Bhanpura 152 17482 087 0

5 Nipaniya Baijnath 381 29047 131 0

5 Tola Khed 095 3757 253 0

5 Kashi Bardiya 219 5362 408 2

5 Tola Khedi 042 3757 112 0

5 Kankariya 105 13354 079 0

5 Bhimlod 026 22564 012 0

12 Chaksodijhar is part of Badi Gram Panchayat

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

5 Bapcha agar 266 26778 099 0

5 Karadiya 144 23584 061 0

5 Mangwalia 24 15397 156 0

5 Gaysari 219 5293 414 0

5 Dehrinana 314 29331 107 0

5 Pharaspuri 142 16955 084 0

5 Bingaya Agar 112 150 075 0

5 Ralayti 267 2365 1129 0

5 Piplaya ghata 212 12811 165 0

RoW area passing through Kashi Bardiya village constitute 4 of the total government

The vegetation cover in the transmission line RoW is mostly shrubs and grassland There would be no

restriction on current use of the RoW for free grazing of cattle The RoW of the Transmission Line

does not pass through any reserved or protected forest land and therefore does not involve any

potential use of forest produce Hence the transmission line will not impact customary use of the

RoW land by ST population in Kashi Bardiya

363 Use of Government Land in TLs Associated With Shajapur Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 310 below

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

6 Burlay 494 2876 172 0

6 Bijnakhedi 158 14668 108 0

6 Dehripal 215 27508 078 0

7 Fawaka 237 6083 390 2

7 Dehripal 296 27508 108 0

7 Parsula 219 5891 372 18

7 Megha Khedi 098 3537 277 0

7 Singhwad 071 3118 228 24

7 Palakhi 072 1185 608 0

7 Baigaon 27 2387 1131 11

7 Bagwad 335 14239 235 13

7 Karkadiya 111 8267 134 0

7 Pipalya Kumar 101 13328 076 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

7 Pachora 306 13311 230 0

7 Shivgarh 024 13353 018 0

8 Abhaypur 026 7633 034 0

8 Alampura 337 12006 281 0

8 Arniya 233 9019 258 0

8 Bada Beed Jagatpura 32 49327 065 0

8 Barandwa 646 258 250 1

8 Batawada 022 5854 038 0

8 Bhadoni 096 1672 057 4

8 Bordagujar 217 120 181 0

8 Chachakhedi 155 482 322 0

8 Chandangaon 409 5711 716 0

8 Chikali Parmar 299 1567 191 0

8 Dhakadi 174 467 373 0

8 Dupada 181 3624 050 6

8 Fanya 349 22 1586 0

8 Gujar Khedi 02 0

8 Gurdadiya 188 1279 1470 2

8 Hanoti 004 34035 001 0

8 Harangaon 005 3034 016 0

8 Jadmi 371 3597 1031 0

8 Jhonkar 572 13653 419 0

8 Kadiya 06 13653 044 8

8 Kalmoi 009 3916 023 0

8 Kanasiya 109 40642 027 0

8 Karedi 003 16944 002 0

8 Kareli 197 16944 116 0

8 Katwariya 458 9312 492 33

8 Khajuri Kanad 085 3138 271 3

8 Kharkhadi 071 310 023 0

8 Khutpala 016 2359 068 0

8 Kundla Khurd 23 1507 1526 3

8 Merkhedi 26 26 1000 1

8 Mirapura 068 3767 181 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

8 Murdawan 292 101 289 0

8 Nanukhedi Mana 054 12851 042 0

8 Nanya Khedi Ahir 156 19092 082 0

8 Palasi 028 203 138 21

8 Pipalya Kumar 163 13328 122 0

8 Pipalya Naulay 28 8117 345 25

8 Rojwas 138 10 1380 0

8 Samgi 454 9921 458 2

8 Samgimanda 086 2578 334 0

8 Shankarpur 327 5782 566 0

8 Siroliya 003 10446 003 0

8 Surajpur 249 6912 360 2

8 Suwagaon 092 17558 052 9

The RoW of the transmission lines associated with Shajapur Solar Park passes through 60 villages

and 19 villages have ST population Out of these one village ie Parsula is covered in FPIC process

for Shajapur Solar Park

The RoW of the Transmission Line does not pass through any reserved or protected forest land and

therefore does not involve any potential use of forest produce The vegetation cover in the

transmission line RoW is mostly shrubs and grassland There would be no restriction on current use

of the RoW for free grazing of cattle Hence the transmission line will not impact customary use of the

RoW land by ST population in these 18 villages with ST population

364 Conclusion on FPIC Trigger for Transmission Lines

Based on the details of the presence of STs in Transmission Line corridors and assessment

of current land use and land classifications following inferences can be drawn

1 The TL Tower base and RoW corridor does not have any reserved or protected forest Hence potential customary use of forest produce is not relevant

2 The vegetation within TL RoW is mostly shrubs and grassland which is potentially used by local community for free grazing If any of this land under the ROW has been used for free grazing the people (including the ST families) will have other unused government land available to graze The disruption during construction and stringing will be very temporary and people can continue grazing under the ROW as before The few villages where the impact on unused land was higher than 10 either had no or very small (lt5) of ST population

3 The RAP survey has not identified any cultural site within TLs RoW or Tower Base area 4 There will be no physical displacement of any ST family for TLs

Therefore the circumstances requiring to obtain FPIC is not relevant for transmission lines

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DESK BASED INFORMATION COMPILATION

4 DESK BASED INFORMATION COMPILATION

41 Information Collection and Compilation

ERM has undertaken a desk based review of the information available This step involved collecting

and compilation of relevant information from following sources

Review of Detail Project Report (DPR) prepared by PwC dated October 04 2019

Detailed Project Report for the Project Dec 2019

The Project boundary map provided by RUMSL dated 19 Jun 2020

Collection of digitised maps of village boundaries

Compilation of demographic data using census 2011 data

Review of drone imagery for the project shared by RUMSL to identify EampS sensitivities in the

proposed project boundary

42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks

This section provides the timeline of land allotment process which is compiled from the allotment letters

of the land shared by RUMSL

421 Government Land Allotment for Neemuch Solar Park

Government land is being procured through allotments under the provisions of the Madhya Pradesh

Land Revenue Code 1959 (and its subsequent amendments) Table 41 provides details of the land

allotment for the Neemuch Solar Park

Table 41 Dates of Government Land Allotment for Neemuch Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Village

17-01-2018 7A-20(3)2017-2018 23868 Bardawada Kawai and Badi

30-05-2017 26A-20(3)2016-2017 43951 Kawai and Badi

Total 67819

Source RUMSL

67819 Ha (out of total 96894 Ha) is allocated to RUMSL through two allotment letters in the year 2017

and 2018 respectively out of the 96894 Ha of the required Government Land Both these allotment

letters predates the MP Revenue Code Amendment Act 2018 Allotment of additional 28979ha is under

process

422 Government Land Allotment for Agar Solar Park

Table 42 provides details of the land allotment for the Agar Solar Park which has been undertaken

between Nov 2016 and Jun 2019

Table 42 Dates of Government Land Allotment for Agar Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

28022019 7A-19(3)2017-2018 5633 Bijnakhedi

28022019 6A-19(3)2017-2018 7053 Dudhpura

21062019 31B-1212019-20 1495 Dudhpura

20-06-2019 5A-19(3)2017-18 15925 Karwakhedi

28022019 4A-19(3)2017-2018 283 Kasaidehriya

20062019 3B-1212019-20 19714 Ladwan

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

280202019 2A-19(3)2017-18 1683 Madhopur

21012019 1A-19(3)2017-18 3492 Piplya Kumar

04012018 9A-19(3)2017-18 602 Naharkheda

09082018 9A-19(3)2017-18 2669 Naharkheda

30112016 4819(3)2015-16 5562 Palda

02012018 8A-19(3)2017-18 5699 Palda

02012018 11A-19(3)2017-18 16116 Pipliya Nankar

06012018 10A-19(3)2017-18 17663 Umariya

09082018 10A-19(3)2017-18 15583 Umariya

Total 127137

Source RUMSL

127137 Ha is so far allocated to the project over 2016-2019 and 5106 Ha was allocated prior to MP

Revenue Code Amendment Act 2018

423 Government Land Allotment for Shajapur Solar Park

Table 43 provides details of the land allotment for Shajapur Solar Park which took place between May

2017 and Jun 2019

Table 43 Dates of Government Land Allotment for Shajapur Solar Park

Timeline

Allotment Letter

Number

Area

Allotted

Villages

26-05-2017 03A-19(3)2016-2017 14991 Dehripal Parsula Kadula MalyaHedi Burlay Jaawdi

Bhandedi Saagdiya Baandahedi Peepalkheda Dopada

Bijana Kheriyaema Kumhariyakhas Dangicha Jaaman

11-12-2017 26A-19(3)2016-17 618 Dehripal Parsula Favka Jaavdi Burlay Chooma

Bijnakhedi Dhatravada

26-05-2017 02A-19(3)2016-17 320969 Kukdeshwar Baamniyakhedi Bordi Khakri Majhniya

Rehli Rulki Dhanda Pidoniya Goyla Aakya Chauhani

Palsaavad Son Desrapur Khokriya Tonk Hanoti

28-06-2019 03A-19(3)2019-2020 8809 Kukdeshwar Bamniyakhedi Bodi Khakri Majhaniya

Rehli Rulki Tanda Pindoniya Goyla Aakya Chauhani

Palsawaad Son Besrapur Khokriya Tonk Hanoti

Total 117697

Source RUMSL

117697 Ha is allocated to the project over 2017-2019 and 108888 ha was allocated prior to MP

Revenue Code Amendment Act 2018

43 Review of Previous Community Consultations for Allotment of Government Land

The summary of the review of the timeline of the government land allotments in FPIC villages is provided in Table 44

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha Resolution

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Allotment prior to

Nov 2018

Amendment

67819 Ha 5106 Ha 108888 Ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

After Nov 2018

Amendment

28979ha 76077 Ha 8809 Ha

Total government

land in Ha

96894 Ha 127137 Ha 117697 Ha

Was the government

land allotted in FPIC

Villages pre or post

Nov 2018

Amendment in MP

Land Revenue Code

Government land allotted in

Badi and Kawai was prior to

Nov 2018 Amendment in MP

Land Revenue Code

Government land allotted

from Ladwan was on 20th

Jun 2019 which is after

Nov 2018 Amendment in

MP Land Revenue Code

Government land allotted

from Parsula was on 26th

May 2017 and 11th Dec

2017 was prior to Nov

2018 Amendment in MP

Land Revenue Code

Was Gram Sabha

resolution required

for FPIC villages

Yes No Yes

Thus as per legal provision (see section 31) the allocation of government land in BadiKawai from Neemuch Solar Park and Parsula in Shajapur Solar Park required a resolution of their respective Gram Sabha and an NOC by Gram Panchayat ERM did not get access to documentation of community consultation as part of seeking NOC from Gram Panchayats Conversation with Sarpanch of villages with ST population revealed that consultation was restricted to Gram Panchayat members Though they were initially reluctant to sign on the NOC after persuasion of District Collector they finally signed It is significant to note that the demarcation of the allotted land took place only recently (Jun to Aug

2020) and the construction process has not started yet13 The FPIC process in compliance to IFC PS-7 requirement is planned to be carried out prior to the construction works of these Solar Parks

13 The process for purchasing private land through consent process has been started in Neemuch

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

An overview of field visits and community engagement is provided in Section 12 above This section

provides details of the consultation carried out with affected STs in the process of preparation of this

FPIC Approach Paper The process involved following three steps

Step-1 Disclosure of intention of conducting FPIC process with affected STs in villages with

significant ST population

Step-2 Disclosure of final solar park boundary and key environment and social impacts (covered

in ESIA) and Participatory Rural Appraisal exercises with affected STs and meeting potential

representatives

Step-3 Identification of ST Representatives and formation of ST Committees and build mutual

agreement between them and RUMSL on Discussion and Decision Making Framework

The Step-1 was carried out in Dec 2019 and Jan 2020 The Step-2 was carried out in Aug 2020 The

details of the process followed during each of these steps are described in sub-sections below

Note The Step-3 is planned to take place in first week of April 2021 and the Draft Discussion and Decision Making

Framework described in Section 83 will be updated accordingly

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020)

The concerned Gram Panchayats identified with STs Population in previous sections were contacted

to inform them about the overall project and intention to conduct a FPIC process involving affected ST

families along with ESIA process The process included preparing a project profile in Hindi (See

Appendix A-B and photo documentation in Appendix C) and handed this over to the elected

representatives of concerned Gram Panchayats These meetings were attended by local RUMSL

personnel The project overview was explained during the meeting and their queries answered

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 51 below

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Badi 1 Sarpanch of Badi Village

2 Kalam Singh (Traditional Head

of Bhil Community in Mama basti)

3 Government Teacher in Bhil

Community

10-12 men from the village

6-7 women from ST (Bhil)

community

5th of December

2019

Kawai 1 Ghasilal (Ward Member in

Kawai Village)

2 Local communitypeople of

Kawai Village

20-25 persons from Kawai

Village were present

4-5 women

6th of December

2019

512 Disclosure of Intention to Conduct FPIC Agar Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Agar Solar Park

The details of the people contacted during this stage is provided in Table 52

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided-

Number of other community

members present during the

meeting

Date of the

Meeting

Ladwan (two

villages covered-

Ladwan and

Kerwa Khedi)

Mohan Singh (Sarpanch for

both villages)

10 persons in Ladwan and

Kerwa Khedi each

No female members were

present in Kerwa Khedi

In Ladwan seven (7) women

members were present in an

FGD that largely included

women

19th December

2019

Repeat visit on

29th January

2020

513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 53

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park

Name of Gram

Panchayat

Name of Person to whom Project

Information Sheet was Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Parsula Since there was no Sarpanch or

Gram Panchayat member present

during meeting one project

information sheet was provided to the

entire community which was

circulated within everyone present

during the consultation and signature

of 1 person from group (Mr Sujit

Singh) was taken

~15 persons in Parsula

Shajapur were present during

consultation also one separate

consultation was held with

women group having ~10

participants

30th January

2020

One common feedback during the consultations undertaken with the community in general and STs in

particular was they were not aware about the solar park boundary to judge which land will be used by

Solar Park and what will be left out for them The ESIA process was working on avoidance and

minimization measures Therefore they were informed that once the boundaries are fixed by the

design team the details will be shared with them

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises with STs (Aug 2020)

The solar park boundaries were finalized and provided to ERM in the last week of June 2020 by the

design team The draft environment and social impact assessment was completed in the month of

Aug 2020 The field-based activities remained suspended from Mar to Jun 2020 due to strict

restrictions imposed on travel and group activities due to Covid-19 pandemic Therefore the next

round of information disclosure and community consultations took place only in Aug 2020 at the time

of the RAP survey

Meeting Sarpanch and a few available Panchayat members

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village level Introductory amp Project disclosure meeting

PRA exercises with STs and information collection for IPP

- livelihood resource mapping

- mapping of social relations and influence and

- village profile

Identifying prominent persons from STs as potential representatives in FPIC process

Understanding the traditional decision-making system and existence of IPOs through key-

informant interviews

The schedule of field visits carrying out these activities is provided in Table 54 and details of these

activities are provided in subsequent sub-sections

Table 54 Site visit Dates and Site Activities

Solar Prak and FPIC Village

Date Site Activities

Agar Solar Park- Ladwan Village

06082020 Visited Ladwan and contacted Patwari Sarpanch and Panchayat Secretary and Fixed a Project Disclosure Meeting (a common meeting including all communities) for next day

07082020 Village level Project Disclosure Meeting at Ladwan

Participatory social mapping and information collection for IPP

Preliminary discussion with 2 Bhil families

08082020 ERM team met Sarpanch of Parsula to brief him and fix a meeting on 10th Aug

ERM team collected land details and village revenue map from Patwari of Ladwan

Shajapur Solar Park- Parsula Village

10082020 ERM team met Sarpanch and a few Panchayat members at Parsula

Shared Project Disclosure note and fixed a meeting with Bhil households of Parsula on 11th Aug

Mapping of social structure of Parsula village and village profiling

11082020 PRA exercise with Bhil community of Parsula resource mapping at Parsula mapping of social relations and influence

Discussion on impact of the Project on grazing land

Understanding the internal decision-making system amongst Bhil

Identifying prominent persons among Bhil families

12082020 Travelled to Neemuch Site from Agar

Neemuch Solar Park- Badi and Kawai village

13082020 Meeting with Sarpanch Badi and sharing of the Project Disclosure Note with Badi community (including all communities)

Social and resource mapping with Bhils in Badi

Understanding the internal decision-making system among Bhils at Badi

Identifying prominent persons among Bhil families

14082020 PRA at Mama Vasti Badi Resource mapping at Badi and Mama Vasti

Filling of village profile form for Badi and Kawai

Discussion on Impact of the Project on grazing land

Understanding the internal decision-making system at Kawai

Mapping the list of tribal leadership in village

Introductory visit to Kawai and sharing of Project Disclosure Note

15082020 PRA at Kawai with Bhil households

Identification of village leaders for Bhil of Kawai

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village)

5211 Meeting with Sarpanch

ERM team met Sarpanch of Ladwan Gram Panchayat at his residence in Karwakhedi village It was

learnt that Ladwan GP had submitted a letter to District Collector earlier expressing their unwillingness

to give away the government land for Solar Park The key concerns of the villagers included

Whether government has gone ahead on issuing tender for the Solar Park site Especially

without replying to their concerns

Whether the land identified by GP for establishing a Gaushala (shelter for abandon and old cows)

is allotted to the proposed Solar Park

How would the Solar Park address long term un-employment and livelihood issue in the village

ERM informed on its intention to conduct FPIC process covering the ST families in Ladwan village

and some of these questions will be answered during a structured process of discussion

5212 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch

Ladwan consists of two revenue villages Karwakhedi and Ladwan The Gram Panchayat office is at

Ladwan and the current Sarpanch is from Karwakhedi The village is dominated by the Gujjar

Community that is the second largest community in terms of population Scheduled caste is the

largest social group of village comprised of Banchhda Charmkaar Balai and Beldar

A community meeting was held where the Talati (village land revenue officer who keeps the land

records) was present The Talati informed them on the status of land allocation for the Solar Park

ERM showed the map showing the optimised project boundary with khasra numbers of the allotted

land ERM team informed them on the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The community expressed their

key concern about the impact on their livestock which forms an integral part of their livelihood

Community Meeting at Ladwan Explaining potential impacts and benefits

5213 PRA Exercises with STs

ERM held a meeting at a settlement cluster (nai-vasti or new settlement) where STs and SCs lived A

general discussion on their village history and livelihood issues were discussed The participation

level in this discussion was good A cross section of people from various age-groups and gender

participated in this discussion and shared relevant information and expressed their opinion A

separate meeting was held with women too (see Photos below)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

According to the elders of the Bhils their generation is the 9th generation residing in Ladwan village

Prior to the three families (Gujjar Bhil and Charmakaar) establishing this village the village had

Muslim population in medieval times and they deserted the village as some epidemic broke out Three

people from Gujjar Schedule Caste and Bhil community first came from another village and settled in

the village As time passed other families from Banchada-Nat Sondhiya Balai and other started

settling in the village

The discussion also involved their religious and cultural practices and shrines There are three

Chabutarascaffold in the village which are their main place of worship There are two shrines ie

Gowal ka Devta close to the grazing lands and Nagdevta adjacent to the new colony outside the

village

A village corner meeting with men Participation of women in group discussion

The Shrine of Nag Devta at Ladwan Meeting with women at Ladwan

After the general PRA exercise involving a larger group a few active participants were picked up to

have more focused discussion on a few aspects Through participative discussions in these smaller

groups the social hierarchy and livelihood resources used by STs (and SCs living in the village) were

mapped

Creating the map of social hierarchy and influence The map drawn by community showing their

livelihood resources

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Social Groups and Influence Map

Most of the families in Ladwan have cattle that includes cow buffalo and goat Approximately 650 cattle that includes 450 cows and 200 buffalos exists in the village There are about 44 cows kept by Bhil households which is about 4 (on an average) cow per family Bhil households own about 100 goats which is about eight (on an average) goats per family Only one family (Chander Singh) owns two buffaloes Few individuals work as grazier for a cluster of houses and are paid 150 per cattle per month by the owners of cattlersquos The cattle owners hire women and youths for bringing fodder feeding and cleaning of cattle sheds collecting cow dung Payment is done on the monthly basis or the basis of hours of work The common land situated at the Right hand side of the main approach road to Ladwan village from Agar is used by the ST community for grazing their livestock ST families bring fodder firewood and fruits from the same portion This is the only place during rainy season where fodder is available for four months as rest of the area is under crops ST families cannot accesses any other commons which is encroached by the dominant familiescommunity According to the ST community if the village commons is taken by solar park then they do not have any option but to sell their livestock as they cannot afford to buy fodder for the livestock unlike the richer families in the village

Free grazing of a mixed herd of cattle and

buffaloes

A grazier bringing back cattle home at evening

5214 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 55 Names of Potential Representatives in Ladwan Village

Section of Representation Sl No Name of Representative Contact Number

Clan Representative 1 DevSingh-Kanhayialal

2 Mangushanker-Amar Singh

Gujjar

Sondhiya

Other OBC

SC

Bhil

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of Representation Sl No Name of Representative Contact Number

Youth Representatives 3 Babulal-Gangaram

4 Anandilal-Lalsingh

Traditional leader or Mukhia 5 DevSingh-Kanhayialal

522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village)

5221 Meeting with Sarpanch

The ERM team for this field visit was led by the IPs Expert comprised of four members including a

woman to facilitate participation of women The ERM team first met the Sarpanch of Parsula who was

not present in initial meeting held earlier in January 2020 The objective of this meeting with Sarpanch

was to share the project information with him and appraise him of the intention of the ERM team to

hold a meeting and participatory appraisals with ST families

5222 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch The Disclosure note had a map showing the

optimised project boundary with khasra numbers of the acquired land It included the key potential

environment and social impacts and what mitigation measures are proposed in ESIA report prepared

by ERM

5223 Joint Site-visit with Sarpanch and Other Leaders

Sarpanch wanted to visit the proposed project site along with the Patwari to explain him the project

boundary based on the land allotment records available with him ERM team facilitated a site visit by

Sarpanch Naib Sarpanch and Kotwar in presence of Patwari to explain him the proposed project

boundaries He shared his observations and concerns over the allocation for the Solar Park which is

used for grazing domestic livestock by villagers including ST households However he agreed to

facilitate an exclusive meeting with ST families next day

5224 PRA Exercises with STs

The Kotwar of Parsula village belongs to ST community He played a significant role in inviting the ST

families to participate in the meeting as well as shared crucial information on their social and cultural

aspects The meeting with ST families included approximately 40 people both men and women from

various age-groups ERM team showed them the map of Solar Park and explained them locations of

key components The community was divided into two to three groups to hold participatory

assessments

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments

Site visit with Sarpanch and explaining Project boundary

Participatory mapping of livelihood and natural resources within Project boundary

Community meeting with ST from Parsula village at Project site

Identification of a medicinal plant during site walk through

Facilitation of discussions with ST women from Parsula village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gwalon-Ka- Mandi within Solar Park Boundary

Grazing lands used by Bhils Mapping

Rajputs are the dominant caste in the village and a person from the Rajput community is the Patel

(traditional leader) of Parsula village Rajputs control all village resources including sources of drinking

water and the irrigation

There are four religious places (Devsthan) of Bhils in Parsula village At all these places the priest is

from the Bhil community One platform is situated within the land allocated to the Project which is

called Gwalon ka Mandi It is recognised by all the community as the women worship at this place to

have good rains for better crop yield or agriculture Community gatherings are organized at this place

on few occasions in the year

The Bhil households reported to own about 2-3 (maximum 10) cows on an average per family and

about 2-3 goats Some families manage to sell three to five goats in a year ₹3000 to ₹ 8000 per

goat depending on the quality of the goat Families who rear cows manage to sell about 4 to 6 litre of

milk ₹40 per litre to private dairy at Chouma village The Bhil community uses the lsquoBirdirsquo hillock

adjacent to the northern side of the Parsula village for grazing their livestock along with other

communities residing in the village

5225 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 56 Names of Potential Representatives in Parsula Village

Section of

Representation

Sl No Name of Representative Contact Number

ClanHouse Cluster

Representatives

1 Meherbaan Singh 7970187292

2 Goverdhan Sigh 8718098704

3 Rahul 9098266244

4 Maakan 6162432391

5 Dheeraj Singh 8871384373

6 Rambabu 9752340827

7 Ballu 9399263367

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Sl No Name of Representative Contact Number

8 Bheru 7725027924

Youth Representatives 9 Kamal 6267658647

10 Rajesh 9009278550

Woman Representatives 11 Payal NA

Traditional leader or

Mukhia

12 Bhawanlal NA

523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages)

5231 Meeting with Sarpanch

Gram Panchayat Badi has 3 villages namely Badi Kawai and Sucharoki The ERM team met

Sarpanch of Badi on 13th Aug 2020 and explained the intention of holding meetings with ST families to

inform them about the FPIC process He advised that we should brief the community members on the

current status of the project first As most of the ST families work as wage labour he advised the

team to come early in the morning He assured to inform the ST families and ask them to cooperate

5232 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for a sample

Hindi version and Annexure-D for sample English version) to Sarpanch and other people present in

the meeting The Disclosure note had a map showing the optimised project boundary with khasra

numbers of the acquired land It included the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The meeting was held at the

center of the village

The community believes that Badi village is 1150 years old calculated based on the date inscribed on

a stone slab in the oldest house in the village It is a common belief that Bhil community came to the

village along with Rajputs The living memory of the community members goes at least six

generations back Badi has ~300 households and there are ~80 ST households Rajputs are the most

dominant community in the village Brahmins and Gujjars also influence the decisions of the village

Gujjars are the largest social group of the village followed by Bhils There are around 30 Muslim

families and they also have some influence on decision-making of the village Apart from Gujjar there

are three other OBC groups that are Sutar Kumhar and Nath

The STs live in three separate habitation clusters The first is in the main village habitation second is

roughly around 05 kilometres away and is called Khari ka Jhopda The third is located further away

around 25 kilometres Both are not connected through roads and one has to walk to reach them The

third habitation is further away where a group of recent migrants form Jhabua (referred as Mama Bhils

by villagers) live and is referred as Mama Basti These Bhil families came here to work as labourers in

the stone mines almost two decades back

At Kawai a meeting with village elders was held prior to discussion with ST families Rajput Gujjar

and Dhakad are the three dominant castes There are only 17 Bhil households in Kawai village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village disclosure meeting at Badi Meeting village elders at Kawai

5233 Site-visit and Walkthrough

The ERM team walked through the site to visit different clusters of ST settlements in Badi and Kawai

Some of the photographs of the main village and satellite smaller settlements where STs live is

provided below

A typical ST house in Badi main settlement The Platform where STs hold their community

meeting

The Khari ka Jhopda Mama Vasti

5234 PRA Exercises with STs

As ST households were found scattered in several small satellite settlements multiple meetings were

held involving a small group of 7 to 12 participants Every ST settlement or cluster of households

usually has a platform under a tree which is used for community meetings and decision making This

space was used for holding PRA exercises Participants were engaged in conversation on their social

relationship and decision making process The understanding gained from these discussions were

then demonstrated in diagrams They were asked if the diagram portrays the right picture or not

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Livelihood and resource mapping in Badi A smaller cluster level meeting at Badi

The village livelihood resource mapping- Kawai Participatory process of understanding

livelihood resources in Kawai

The social relationship and influence map for

Kawai

The social relationship and influence map for

Badi

Similarly a map of the village and surrounding area was created using the information shared by

participants in these meetings They were asked to show where they carry out their livelihood

activities such as farming and grazing etc They were asked to indicate those areas and identify

natural resources or cultural sites located in those locations

Some of the information important for deciding on the FPIC approach collected from these participatory

exercises are as follows

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gram Panchayat Badi has total 16 wards out of which Badi has 9 wards Out of these 9 Wards 2

are reserved for the STs (Bhil)

There are about 250-300 cows kept by Bhil households which is about 4 (on an average) cow

per family Bhil households own about 450 goats which is about 5-6 (on an average) goats per

family Hence for ST families goat is a more popular livestock than cows

Almost all the houses have used locally available stone in constructing the walls of the houses

Pucca houses have used cement and sand as mortar whereas kuchha houses have used mud

The communities fear the loss of access to these stones will make house construction costly and

people who earn from stone quarrying will be impacted

The traditional leader (Mukhia) of Bhils decide on disputes related to marriage and other social

issues Women do not play an active role in decision-making process

Each household cluster of Bhil households have a number of cultural sites where local deities are

worshiped For example in Khera-ka Majra has four cultural sites Ghadiya Bheruji Bhut Maharaj

Bhut Babaji and Dungri Balaji Similarly there are a few cultural sites for goddesses like Leva ki

Mata and Dahana Mataji are located within the Project boundary In all these shrines the priests

belong to Bhil community

STs (Bhils) worship Devnarayan Khejara Mata and Sawria jee in Nimbaheda in Rajasthan The

religious leaders from these places are held with respect and are accepted as mediators or

decision makers for important matters

5235 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table 57

They will be considered for nomination to the representative committee and contacted for capacity

building on FPIC process

Table 57 Names of Potential Representatives in Badi and Kawai Village

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Clan Tola

Representative

Badi Main 1 Gheesalal-Nathulal 9575486482

2 Basantilal-Mangilal 7354345531

3 Motilal-Hiralal 9109003022

4 Nanalal-Ratanlal

Khaira Ka Jhopda 5 Lalu ndashRamlal

6 Tulsi-Devilal

7 Tawarlal-Vardaji

Kawai 9 Ramlal-Hajarilal

Ratanlal

Bherulal(Teacher)

Bherulal- Bhawani

Shantilal

Fargulal

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Youth

Representatives

Badi 10 Omkaar ndashKailaji 8718057436

11 Shyamlal-Mangali 9302086906

Mama Vasti 12 Dinesh ndashThawar Singh

13 Prakash-Ramesh

Woman

Representatives

Badi 14 Kesarbai-Devilal

15 Kavita-Dhanraj

Mama Vasti 16 Shanti-Ramesh

17 Mamta -Naklesh

Kawai 18 Sunder Bai-Bherulal

(Sudibai-Devilal Shimla bai-

Chandrulal LeelaBai-

Chittarmal Prem bai-Gopilal)

19 Kanyabai-Bhuvaniram

Traditional leader or

Mukhia

Badi 20 Bhawani-Laxmi

21 Amar singh-Ramlal 7354325923

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL

A key element in designing a FPIC Process is a mutually agreed and appropriate lsquoengagement and

consultation process14rsquo The lsquoFirst Draft FPIC Approach Paperrsquo was prepared and shared with RUMSL

for their review and comment A virtual workshop was held with RUMSL team on 27th Aug 2020 In

this workshop PS-7 requirements of ICP and FPIC in general and the specific FPIC process designed

for Solar Parks was presented and discussed After their feedbacks were incorporated the lsquoDraft

FPIC Approach Paperrsquo was shared with IFC-WB for review and comments

The objective of these internal discussions are to build an internal institutional consensus on the

appropriateness of the designed engagement and consultation process to comply with the

requirements under IFC PS-7 The subsequent steps for consultations with affected STs and finalizing

a mutually agreed lsquoDiscussion and Decision Making Frameworkrsquo is discussed in Section 81

14 GN-ampGN22 emphasizes to have a shared view of the FPIC process between Project proponent and affected IPs The Project

proponent and affected IPs to agree on an appropriate engagement and consultation process as early as possible and commensurate with the scale of impact and vulnerability of the communities

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INDEPENDENT FACILITATOR AGENCY

6 INDEPENDENT FACILITATOR AGENCY

61 Need for FPIC Process Facilitation Agency

An independent agencyexpert to facilitate the FPIC process is required for the following reasons

There is a strong likelihood of other dominant communities in the village intervening and trying to

influence the internal discussion and decision making by IP The presence of the FA will help

documenting such attempts of external intervention and the presence of the FA may act as

deterrence and help avoid such attempts to interfereinfluence the process

The IP representatives need an intensive process of orientation and capacity building It will be

more effective if this is conducted using the Malvi dialect instead of Hindi Therefore a good

community facilitator with familiarity on Malvi dialect will be helpful

The women and youth will need capacity building and facilitation of their internal discussions prior

to the community level meetings

The facilitation support to IP community in general and IP representatives in particular will require

proficiency in the local dialect Malvi and knowledge of local livelihoods and alternative options

Involvement of a local agencyexpert who also speaks the local dialect and with a good

understanding of local livelihoods (particularly grazing and livestock keeping) will demonstrate

fairness and transparency in the process

62 Screening of FPIC Process Facilitation Agency

ERM identified Institutions (Universities Government Departments and Research Institutes etc)

NGOs and INGOs located and active in Madhya Pradesh state After a preliminary screening selected

potential individualsorganizations were approached to find out their availability and willingness for the

assignment The criteria used for screening included qualification profile affiliation with the type of

institutionsorganizations nature of worksprojects completed working experience with IPsTribes in

Madhya Pradesh conducting meaningful consultation community mobilization and stakeholder

engagement familiarity with World Bank Group safeguardsrsquo policies and procedures comfort with

written and spoken English and local dialects etc The list of independent experts and organizations

screened for the role of facilitation agency is provided in Table 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

1 University of MP Bhopal

Department of Sociology

Dr Arvind Chauhan

Professoramp Head

7999345226

Two candidates with post-PhD and PhD

qualifications from Department of

Sociology interested in working but having

no experience were not considered

2 Dr BR Ambedkar

University MHOW MP

Professor RD Maurya

Former Dean amp Head

Department of Sociology

Old AB Road Gram

Dongargaon Dr

Ambedkar Nagar Madhya

Pradesh 453441

07324 274 377

The retired Professor amp Dean

recommended a college lecturer

belonging to BhilIP from Govt college

Neemuch may be considered as a

resource person in future as appropriate

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

3 Tribal Research and

Development Institute

Bhopal

Rita Singh

35 Shyamla Hills Rd

Bhopal Madhya Pradesh

0755-25570882551257

This institute of MP government is

involved in administration and research

aspects of tribes in Madhya Pradesh

There are full time staff and the person

required for the assignment is not

available However the Government

functionaries may be the resource persons

in sharing information and performing

advisory roles during implementation as

appropriate

4 Institute of Social

Sciences Ujjain

Dr Tapas Faculty

7342510978

Berasiya Rd Navi Bagh

Bhopal Madhya Pradesh

462038

0755 273 0946

The faculty suggested to contact the

Bhopal based NGO (Samarthan)

5 The Samarthan NGO

Bhopal

Shradha kumar

Bhopal Madhya Pradesh

shrdhasrigmailcom

9826912948

The Program Director reported no work

being undertaken by the NGO in proposed

project area and was reluctant to

undertake the assignment She however

mentioned to help coordinating with the

local NGO if available in Neemuch area

and has not responded so far

6 Xavier Institute of

Development and Action

and Studies Jabalpur

Dr Mehul Chauhan

Former Faculty

9977064882

The former faculty suggested two NGOs

(Concept Society and Gramodyog

Sansthan)

7 The Concept Society

Indore

Ms Hemal Kamat Director

9425350272

The candidate appeared for interview has

preferred to be engaged independently

instead of as a NGO

8 Gramodyog Sansthan

Mandala MP

Mr Hariom Shukla

Manager

7999064147

Even after agreeing no one finally

appeared for personal discussion and

interview

9 Balram Sewa Samaj

Neemuch

Mr Kamla Shankar

Manager

7838960968

The only NGO reported to working on

legal aspects in Neemuch area has not

expressed interest to work as FA

10 UNICEF office Bhopal Nagesh Patidar Project

Officer WASH

97525 98212

The staff of UNICEF suggested the name

of suitable candidates and all of them

have appeared for interview and have

expressed the interest in proposed project

work

11 Debate Trust (Referred

by Action Aid Bhopal

Amitav Singh and Leena

Singh

Debate Trust

Duplex C-22 Alkapuri

Near DRM Office

Habibganj Bhopal-462024

Action Aid India had prepared a brief

manual on FPIC (published in 3 Indian

Languages including Hindi in 2018)

reflecting the Indian context and its related

legal system The manual was intended to

help CSOs for their ready reference and

larger reach out Mr Narendra Sharma

who was based in Actionaidrsquos office at

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

0755-2985007 0755-

2417656 9425018144

9425004556

debateindiagmailcom

Bhopal played a key role in preparing the

Manual in Hindi version

Mr Narendra Sharma referred the NGO

Debate Trust who had experiences in

working with Panchayats

A screening using preferred criteria was undertaken of the shortlisted agencies and details are

available in Appendix-F None of these agenciesindividuals have worked for a FPIC process earlier

Hence an agency which was available and willing to undertake the activity was taken on a trial basis

to help in conducting PRA exercises and sample household survey required for preparation of IPP

63 Roles and Responsibility for FPIC Process Facilitation Agency

The role and responsibilities of the FPIC FA will be as follows

Table 62 Roles and Responsibilities of FPIC FA

Phase Responsibilities

I Formation of local committees with STs Representatives

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Hindi (Malwi dialect) Translation of TDPIPP and designing Information sharing tools

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs (particularly women and youth groups) and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation of the FPIC Process and Preparation of FPIC Process Report

Documents of outcome of the FPIC Process including FPIC AgreementMOUJoint Statement of PrinciplesAgreed Mitigation Plans etc

64 Terms of Reference for FPIC FA

The terms of reference for FPIC FA covering villages to be covered specific responsibilities

deliverables personnel requirement and organizational profile and experience is provided in

Appendix-G

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The PS-7 recommends to have a lsquoshared view15 of achieving ICP or FPICrsquo mutually agreed ldquoFPIC

Decision Process Framework Documentrdquo which is based on principles of Good Faith Negotiation

(GFN) The Designing a lsquodiscussion and decision making frameworkrsquo to achieve the FPIC as per GN

on PS-7 should considers the socio-political context within which the affected IPs households live as

well as impacts of the Project This section deals with key-elements considered for designing the

FPIC process as per requirements in IFC PS-7 and GN-7

71 Use of Language

The PS-7 emphasizes use of the IPs language in the FPIC process It was found that BhilsBhilala in

Ladwan and Parsula are relatively small community and they have been living with close socio-

cultural ties with other communities Hence they use Bhilli (their traditional language) very little The

proficiency of the current generation in the Bhilli vocabulary is too limited to use this in discussion of

the Project and its impact Hence their preference is the use of local (Malvi) dialect of Hindi which

they speak along with other communities in the village The Bhils in Badi and Kawai speak Malvi

dialect with some influence of Rajasthani language as it is at the border of Madhya Pradesh and

Rajasthan

In general the written material on the project is expected to be in Devnagri script using the vocabulary

consistent with Malvi dialect to the extent possible The FPIC FA will have community facilitator who

is conversant with Malvi and explain the written material using the conversational Malvi dialect

72 Use of Customary Decision Making Process and Traditional Leaders

The Bhils in Ladwan reported that they resolve disputes between families through intervention of the

elderly member of the familyclan (Baijwal and Dalodia) or go to other prominent people in the village

such as the priest in the local temple or the landlord on whose land they work The customary leader

of Bhils who covered a cluster (~10 to 12) of Bhil settlements existed earlier (at least 3 generations

back) and the current generation has not sought their help in dispute resolution in their living

memory

The BhilBhilala of Parsula belong to a number of clans (Dalodia Paretia Renkewal Vasunia etc)

and the elder member of the clan is usually approached to resolve any internal disputes There used

to be a collective council (panchayat) covering 5 to 10 villages but these have been non-functional

over the years They also approach the village Sarpanch and prominent personalities from other

communities in the village to resolve disputes involving land and livestock The matters related to land

are finally referred to the Tehsildar (land revenue officer) for resolution The local administration also

plays a significant role in resolving inter-community disputes

In Badi-Kawai they still have a traditional Mukhia (leader) who wields influence in community

matters Each Bhil village has an elder who is considered the mukhia or leader There are designated

places where elders hold community meetings to discuss conflicts among Bhils and matters related to

their social norms and customary laws governing marriage and inheritance etc If matters are not

resolved at the village level community elders (Biradari Panchayat) then the matter is escalated to a

forum of community elders from 5 or 10 villages with Bhil population The highest level of escalation in

the customary decision making system is to refer the matter to a Biradari Panchayat of community

elders from 25 Bhil villages16 These traditional leaders residing outside of the villages directly

impacted by the Project are accommodated as member of the proposed Mediation Committee

15 Refer GN-7 GN22 which mentions that lsquothis should ideally be done through a framework document or plan and client should

document support for the agreed process from the affected population 16 GN-7GN36(i) acknowledges that there may be circumstances where formal and informal leaders of the Indigenous Peoples

reside outside of the Projectrsquos area of influence

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

In general the affected IPs communities use familyclan elders to resolve minor disputes and involve

prominent people from other communities like the priest Sarpanch or other prominent personalities in

the village for resolving their conflicts The matters related to land is resolved by intervention from

local administration (Tehsildar and District Collector) If the matters are related to their customary laws

on marriage social relationship or inheritance the unresolved matters can be escalated to a council

that comprises of elders from 5 10 or 25 villages The traditional Biradari Panchayat has been losing

its power as the younger community members considers their decisions regressive and approach

Gram Panchayat leaders (Sarpanch) or take help from the Police and Court of law Considering the

preference of new generation to go to non-ST Gram Panchayat leaders and local administration they

are considered for the Mediation Committee

73 Promoting Participation of Women and Youths

Women specifically stated during consultation that they do not participate in decision making in their

traditional community meetings which are convened for resolving disputes Though the women come

to attend the community meetings they hardly ever participate and express their views

The BhilBhilala youths do not have traditional or customary forums at which they express their views

They accept the decisions taken in the family or at the clan-level However there are a few educated

young people in the village who have distinct views about their future

As free expression of the views by youths and women in BhilBhilala community meetings is not a

social norm separate meetings of these groups where they are able to express their views openly is

proposed as part of their internal decision making process The FPIC FA will facilitate these separate

meetings and keep external interventions in these meetings to the minimum The views expressed by

them in these meetings should be tabled in joint meetings of the community for consideration

74 Expectation on Material Information Prior to Discussion

It is understood from the preliminary round of discussions with ST communities that they expect the

following information to be shared with them

Details of the Project (lay-out plan) and the related activities that are going to be implemented

Schedule of starting of the possession of allotted government land and purchase of pattaprivate

land

Details of land khasra numbers proposed to be taken for the project

Amount of paymentcompensation consideration amount of the land and assets (including on the

government land) that will be taken by the project

What economic and other entitlements and benefits will be provided to the families dependent on

the allotted government land

If private land is purchased then they will lose the source of income generation or livelihood (as

they are hired for a year on contract basis daily wages take land on lease for cultivation and

take care of the cattlersquos etc) what will their entitlements (economic package) be

What options will the Government or the Solar Park Company provide as alternative to the

common grazing land as cattle and goat breeds they keep require free open grazing and not stall

feeding

What alternative livelihoods will be offered to those Bhil families who will be landless after losing

the governmentpatta land they currently use (though owned by others)

It was expressed that the Project proponents share many documents but the community wants

confirmation that the content is authentic Hence community expects that signed and verified

documents should be shared as part of the FPIC process which can be referred in case of conflict or

contradiction

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The relevant information is scattered in ESIA RAP and IPPIPDP A concise information disclosure

dossier will be prepared by ERM and used by FA during the FPIC process

75 Need for Capacity Building of IP Representatives

The interaction with potential ST representatives from these FPIC villages shows that convening a

community meeting and steering the internal discussion to reach consensus will be a new experience

for them Most of them are semi-literate and will face challenges in understanding the Project details

on their own such that they can then explain it to other community members Therefore following

activities are required

A capacity building workshop for the potential IP representatives to explain the Project its impact

and mitigation measures in the Draft IPPIPDPTDP in detail Although the RAP-LRP disclosure

will happen at the community level and ST families will attend those meetings the Draft

IPPIPDPTDP will also explain these entitlementsbenefits in simple language

Presence of experienced community meeting facilitators (from FPIC FA) for community meetings

will help these ST representatives to have focused discussions documentation of views

expressed and decisions made in those meetings

The women and youths usually do not participate in taking decisions on community issues

Hence the women and youth representatives need orientation through separate sessions

In addition to formal trainingorientation sessions the IP representatives may be taken on

exposure visits to nearby solar parks for improving their understanding

76 Need for a Mediation Mechanism

The ST Committee will hold meetings with the representatives of the Project (RUMSL) to discuss

relevant points and reach a mutual agreement While such discussions are likely to result in reaching

mutual agreements on a number of agenda items the discussions may hit dead-end on some issues

All such unresolved issues will be documented as a dissent note for their reconsideration in the second

round of meeting

If the discussion between ST Committee and the representatives of the Project on any significant issue

reaches a deadlock the matter will be referred to a mediation mechanism The mediation will be done

by a high level committee which will comprise of 4 members

An IP representative nominated from the larger tribal leadership of the area (from their customary

council of 10 or 25 villages) but not belonging to the Project village

The elected representative of the concerned Gram Panchayat or a person nominated from GP

and acceptable to the ST Committee

A senior officer from the District Tribal Welfare Department

District Collector or an officer nominated by them

This Mediation Committee will be constituted at the beginning of the FPIC process and will be activated

only in the case of a significant deadlock This Mediation Committee will be involved to read the Final

FPIC Agreement (even when no matter is referred to them for mediation) and satisfy themselves that it

reflects mutual agreements reached through a fair and credible process17

17 This is proposed in order to provide an external validation of a free and fair FPIC process prior to signing of the FPIC

Agreement

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

77 Following Principles of Good Faith Negotiation

Good faith negotiation generally involves 6 principles (see Table 71) The proposed FPIC Discussion

and Decision Making Framework (DDMF) adheres to these principles with slight modifications

keeping the public health concerns associated with the Covid-19 pandemic

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

1 Willingness to engage in

a process and availability

to meet at reasonable

times and frequency

Both parties need to agree to avoid large gatherings and un-necessary

physical meetings A mechanism for tele-consultations will be explored to

keep the physical meetings to the minimum

The internal discussion meetings of STs will be in smaller groups (in the

open rather than in closed rooms) to avoid large gatherings

There will be two meetings between RUMSL and ST Committee and

similarly number of proceedings by Mediation Committee will be limited

The meeting schedules will be finalized beforehand and Covid-19 public

health protocols as applicable at that time will be followed

2 Provision of information

necessary for informed

negotiation

The basic information on the Project and its potential environment and

social impacts are already provided in state language (Hindi)

The essential information requirement by ST Committee is identified and

these information will be provided in simple information dissemination

tools The FA will further explain them for their better understanding

3 Exploration of key issues

of importance

The likely key issues of importance are grazing and cultural sites located

within Solar Park boundary A small task-force comprising of

representatives of RUMSL as well as ST Committee will carry out a field

inspection prior to their first meeting The task force will observe Covid-

19 protocols issued by Government

4 Mutual acceptable

procedures for the

negotiation

The lsquoDiscussion and Decision Making Frameworkrsquo signed by both parties

will have a commitment to hold all meetings and activities complying the

Covid-19 protocols and advisory issued by Government

5 Willingness to change

initial position and modify

offers where possible

The first meeting will resolve issues where both parties can reach

agreement easily The positions of both parties on contentious issues will

be recorded during first meeting The FPIC FA will record the written

positions of both parties on these contentious issues and share with

them The FPIC FA and ERM will hold separate meetings with both ST

Committee and RUMSL Team after 15 days to understand any changes

in the stated position The FPIC FA and ERM will take a decision on

holding the second and final meeting on these contentious issues when

both parties agree to modify their offers and a meaningful discussion is

possible

6 Provision for sufficient

time for decision making

The ST Committee will benefit from the capacity building and assistance

through FPIC FA to conclude their internal decision making The first

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

meeting between ST Committee and RUMSL Team will be held after a

sufficient gap As the number of ST families participating in the FPIC

Process is small it is expected that it will not take them long to reach

internal consensus However STs will be encouraged to have more

meetings internally to be able to discuss within themselves

78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and Supportive Environment

In these FPIC villages the Project requires to achieve both ICP for mainstream communities and

FPIC for ST The existing and past relationship between RUMSL and affected communities plays a

significant role in FPIC process It is learnt from the news report as well as from consultations that

some villages (particularly Ladwan) have decided to protest against the Solar Park as loss of grazing

land is not acceptable to them The protesters had organised a demonstration and also submitted

letters to the District Collector regarding their objections Ladwan village has a strong network of

women self-help groups (SHGs) who are interested in a dairy development program Thus reduction

in grazing land is perceived by them to have a detrimental impact on their long term employment

opportunity and income generation These SHGs have members from SC OBC as well as ST

families

In other FPIC villages ie Parsula Badi and Kawai though there is a concern for loss of grazing

land yet opposition to Solar Parks is passive There are some specific interest groups among the

non-ST communities who would seek answers to their specific concerns For example in Parsula

village the non-ST families (both in Parsula as well as neighbouring villages) have informally

purchased the patta land Their main concern is whether and how they get the compensation for

these land parcels which will be paid to patta owners In Badi and Kawai the number of people who

have encroached on the government land is comparatively more Also there are few influential

people who earn from selling stones (the most popular building material in that area) extracted from

the allotted government land Thus a range of RAP-LRP issues are expected to crop up during

community engagement In all these villages the affected ST communities though would consider

the compensation and benefits offered to them yet it would be difficult for them to disregard the

collective decisions made by other communities in their village

Thus considering different interest groups involved existing social relationship influence of STs in

decision making it would be a challenge to hold a single engagement process18 for both STs and

mainstream communities Therefore we recommend a parallel or concurrent engagement process for

ST and mainstream (non-ST) communities The comparison of the ICP process for mainstream (non-

ST) and FPIC process for ST is provided in Table 72

18 GN-7 GN31 recommends a single engagement process complying to the higher standard (GFN and FPIC Agreement) where

a Project requires to achieve ICP for mainstream and FPIC for IP It reads ldquoSince the achievement of ICP and FPIC as separate processes with different groups within a community or between proximate communities may be difficult and in some cases be a cause of division within the community a single engagement process resulting in one agreement is generally recommended In such cases the process and agreement should reference the higher standard (ie GFN and agreement demonstrating FPIC) Whether the agreement entails different benefits for the differently affected groups will depend on the project context the Affected Communities and the nature of project impactsrdquo

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages

Aspect Engagement Process with non-ST

(ICP)

Engagement Process with ST (FPIC)

Management Plan ESMP + RAP-LRP IPPIPDPTDP

Representative

Body

Gram Panchayat (existing body) ST Committee (specifically constituted for

this process)

Provision of

information

necessary for

informed

negotiation

Executive summary of Draft ESMP

RAP-LRP in Hindi

Abridged Draft IPPIPDPTDP in Hindi (use

of Malwi vocabulary as much as possible)

Capacity building by FPIC FA

Help from FPIC FA to understand issues

Willingness to

engage in a

process and

availability to meet

at reasonable times

and frequency

One public meeting for receiving

feedback on Draft ESMP RAP-LRP

One round of internal discussion by STs

assisted by FPIC FA

Two rounds of meetings between RUMSL

and ST Committee

Mediation Committee meetings (if required)

Exploration of key

issues of

importance

Key issues covered in ESIA RAP-LRP

will be discussed

Key issues covered in Draft IPPIPDPTDP

will be discussed

Mutual acceptable

procedures for the

negotiation

Informal agreement A formal lsquoDiscussion and Decision Making

Framework Agreementrsquo is signed by both

parties

Willingness to

change initial

position and modify

offers where

possible

Demonstrated through incorporations of

feedbacks received from public

disclosure and consultation

Structured engagement process

documenting (signed by both parties at the

end of the meeting) points agreeddisagreed

and demonstrating the flexibility in their

respective positions

Provision for

sufficient time for

decision making

The time for public meeting for

receiving feedback will be decided in

consultation with Gram Panchayat

Sufficient time for capacity building by FPIC

FA internal discussions and gap between

first and second meeting between RUMSL

and ST Committee

Outcome The public meeting for receiving

feedback on Draft ESMP RAP-LRP is

held peacefully and satisfactory

explanationresponse to

feedbackqueries is provided

Incorporating response to all key issues

raised in public meeting in Final ESMP

RAP-LRP

The Final IPPIPDPTDP incorporates points

mutually agreed between RUMSL and ST

Committee

The FPIC Process Documentation Report-

(vetted by independent FPIC FA and

Mediation Committee) provides an overview

of the FPIC process

FPIC Agreement signed by RUMSL and ST

Committee

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Note The FPIC Process Documentation Report prepared by FA under ERM guidance will cover the

whole process (including all meetings by ST and Non-STs decisions key issues discussed etc)

The use of impacted land for free grazing is practiced by both ST and Non-ST communities The ESIA

and RAP-LRP also address impacts on grazing and have prepared a framework for Grazing Resource

Management Plan The engagement with non-ST population will highlight the mitigation measures

with regard to grazing issue (particularly Grazing Resource Management Plan) in ESIA and RAP-

LRP The feedback from non-ST population on mitigation of impact on grazing will be subsequently

incorporated into Grazing Resource Management Plan in particular and relevant sections in ESIA and

RAP-LRP The non-ST population will be clarified that TDP will have some additional benefit for STs

and therefore will be consulted separately

Thus the separate ST committees will not be perceived to take any decision that affects collective

interest of all villagers particularly the powerful non-ST communities The Gram Panchayat and

Sarpanch is provided a place in Mediation Committee and will be involved in resolving key-issues

referred to them

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

81 Introduction

This lsquoDraft Discussion and Decision Making Framework19rsquo is prepared after field visits and

consultations with affected STs and a workshop with RUMSL (see Section-5 for details) This Draft

DDMF will be shared with ST Committees on behalf of RUMSL and after appropriate modifications

(without diluting the key-elements for compliance to PS-7 requirements) the final version will be

signed by representatives of both parties Section 814 provides subsequent steps in this regard

The three proposed solar parks are located in three different Districts and each one will have an

independent Solar Park Developer (SPD) or Concessionaire The impact of each solar park and the

social context of the affected STs also differ in these three locations Hence three ESIA reports as

well as three IPPIPDPTDP are prepared The Draft IPPIPDPTDP prepared for each Solar Park has

a specific package of benefits for the STs in FPIC villages This will be discussed during the proposed

FPIC process and the outcome of this process will be a written lsquoFPIC Agreementrsquo that adopts the Draft

IPPIPDPTDP and agrees to cooperate in its implementation

82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo

The subsequent steps for discussing this Draft Discussion and Decision Making Framework with STs

in the selected FPIC villages (grouped at each Solar Park level) is discussed in this section

821 Appointment of FPIC Facilitation Agency and Orientation

The requirement of a FPIC Facilitation Agency (FA) and their roles and responsibilities are discussed

in Section-6 above The FA will play a key role in forming the ST Committees (at each Solar Park

level) and informing them on their rights to FPIC their legal rights on natural resources prior to their

acceptance of this lsquoDraft Discussion and Decision Making Frameworkrsquo Hence one of the agencies

screened for this role will be appointed and brought on board

After on-boarding them ERM will carry out their orientation by holding a series of virtual workshops with

them The orientation program will include the following

The ICP and FPIC requirements as per IFC PS-7 and WB OP 410

Key findings of the ESIA-ESMP including Draft RAP-LRP

An overview of consultations in FPIC Villages

The Draft IPPIPDPTDPs

The Draft Discussion and Decision Making Framework

The Capacity Building of ST Committees on FPIC and their customary rights on natural

resources

822 Introducing FPIC FA to RUMSL and FPIC Villages

After the orientation of the FPIC FA the key persons will be introduced to the RUMSL team through a

physical meeting Subsequently a field trip will be planned to introduce the FPIC FA in FPIC villages

The RUMSL and ERM will introduce the FPIC FA to the contact persons from earlier field visits and

inform them about their role

19 The term lsquoengagementrsquo and lsquonegotiationrsquo was avoided to keep the language less confrontational and positive for both parties

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

823 Formation of ST Committees

ERM and FPIC FA will jointly discuss the structure and composition of the ST Committee at each

Solar Park20 with affected ST community As per suggestions from them ST Committees will be

formed and their nominations will be ratified through a group meeting21 The composition of the ST

Committee is described further in Section 8311 below

824 Capacity Building of ST Committees

The FPIC FA will discuss with the ST Committee on the time and venue for holding a capacity building

workshop The capacity building workshop will cover the following

The recognition of FPIC as their rights

Specific provisions of FPIC as per IFC PS-7 and WB OP 410

Applicable India Laws and recognition of their customary rights on natural resources

The Draft Discussion and Decision Making Framework (Draft DDMF)

The participation of RUMSL in this capacity building workshop will be optional and as per mutual

agreement by both parties The FPIC-FA will note down the suggestions of the ST Committee on the

Draft DDMF and share them with RUMSL

83 The Draft Discussion amp Decision Making Framework

The proposed discussion (engagement) and negotiation (decision making) framework will include 11

steps as illustrated in the Figure 81 below

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process

These steps are described in sections below

20 Agar and Shajapur Solar Park have only one FPIC village Hence the ST Committee will be selected from within the same

village Neemuch Solar Park has two FPIC village with several satellite ST habitations The ST Committee for Neemuch Solar Park will be larger to accommodate representation of different ST groups 21 The FPIC village level group meetings will be held keeping the Covid-19 public health guideline ERM will use professional

judgement on the acceptability of the selected committee for most ST households if the ratification of the ST Committee is not possible by a large public meeting

Formation of Committees

Acceptance of Draft Discussion and Decision Making

Framework

Disclosure of Draft IPP to ST Committee

Explaining Draft IPP to ST Committee

Internal Consultations by ST Committee

First RUMS and ST Committee Discussion

Second RUMSL and ST Committee Discussions

Reference to Mediation Committee

(if any)

Informing Community about Draft FPIC

Agreement

Final Community Meeting for Expression

of ConsentDissent

FPIC Agreement Signing

FPIC Process Documentation Report

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

831 Formation of Committees

The FPIC process will involve three committees for each Solar Park One representing the affected

ST community the other presenting the Project proponent (RUMSL) and the third a committee to

mediate between the two if the need be The composition of these committees are explained in sub-

sections below

8311 Formation of ST Committee for each Solar Park

Each Solar Park will have a ST Committee which includes representatives from all FPIC villages of

that Solar Park Each ST Committee will comprise of 7 to 13 members (or any odd number22) who

represent different sections of the ST community The principle for selecting the members of this ST

Committee will be as follows

One representative from each clanhabitation cluster (tola)

The clans which have more population may select 2 representatives

Two representatives from youths (18-25 years)

Two women representatives

One traditional leader (Mukhia) or ST community head from each FPIC village

Gowal (cow-herder) who takes othersrsquo cattle for grazing and earns livelihood from this

The ST Committee will select a chairperson to coordinate and conduct their internal meetings The

representative from the youth and women will hold separate group discussions within their sub-groups

and share their concerns preference and feedback The FPIC FA facilitating these internal meetings

will ensure that these points are tabled at the joint committee meetings The ST Committee will

prepare a list of households and the adult members (gt18 years) who will be part of the FPIC process

8312 Formation of RUMSL Teams

RUMSL will form three site level teams (one for each Solar Park) which will include the District

Renewable Energy Officer (DREO) of the concerned district and a staff member to assist him They

will report to RUMSL Managing Director (MD) The names and designation of the RUMSL Team are

as follows

Level Designation Name Contact Number

Head office MDCEO Deepak Saxena

Social Development

Specialist

TBD

Site Level (Agar) DREO Deepak Bulani +91-9229924836

DREO- Staff TBD

Site Level (Shajapur) DREO- Prakash Salunke +91- 9926440877

DREO- Staff

Site Level (Neemuch) DREO- Sohanlal Bajaj +91-9827222217

DREO- Staff Balaram Rathod +91-9827323612

22 To avoid a deadlock on decisions

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The site level RUMSL Team will attend the meetings with ST Committee discuss the issues raised by

them sign on minutes of meetings and report to MD where prior approval is necessary The MD or

his authorised representative will take part in important meetings including meetings with the

Mediation Committee if required

8313 Formation of Mediation Committee

There will be a Mediation Committee for each Solar Park The Mediation Committee will comprise of

three members which will be chaired by the District Collector

Member Selection Process

STs Representative from the

Area Biradari Panchayat

The ST Committee after internal discussion will nominate a prominent person of their community outside of their village who is accepted as a member of Biradari Panchayat or similar bodies

Member from Gram

Panchayat

The ST Committee will nominate a member (or ex-GP member) who is known for his role in resolving local disputes

District Tribal Welfare

Department

A senior Tribal Welfare officer will be nominated by District Collector or the Head of Department of Tribal Welfare

District Collector (or his

representative)

The District Collector of the district within which the particular solar

If District Collector is not available she should decide on who can act as his representative

The ERM FPIC-FA ST Committee and RUMSL Team jointly visit these MC members and brief them

on their role in FPIC Process The formation of the MC should be completed prior to the first meeting

between ST Committee and RUMSL Team

832 Acceptance of Draft Discussion and Decision Framework

After the capacity building of ST Committees FPIC FAERM will coordinate with both parties to fix a

date and time for a joint meeting to discuss the Draft Discussion and Decision Making Framework and

ratify it after making necessary modifications

The composition of the committees mentioned in Section 831 and the steps mentioned in Figure 81

will be explained to ST Committee during their capacity building process (described in Section 824)

A Hindi (with Malwi words used to the extent possible) version of the lsquoDraft Discussion and Decision

Frameworkrsquo (Section 83) will be provided to ST Committee during the capacity building Thus the

affected IPs will get adequate time to discuss and come prepared for any suggestions from their side

to this meeting The

Both parties will discuss on a code of conduct commit to follow this during their meetings The code of

conduct will be based on following principles of good faith negotiation

(i) both parties will be available to meet at reasonable time and frequency

(ii) both parties to share information23 necessary for informed negotiation

(iii) both parties will be willing to change initial position and modify offers where possible

23 The Project will disclose information as per Information Disclosure Plan discussed in Section 513 of the Draft

IPPIPDPTDP The disclosure will include at minimum (i) project boundary (ii) impacts of the project (iii) entitlements and other benefits The information will be shared in a culturally appropriate manner and in a form and language easily understandable to the ST communities The FPIC FA will help the ST community understand and process this information prior to the joint meetings with RUMSL

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

(iv) both parties will give each other reasonable time24 for decision making

(v) both parties will put their view peacefully and will not resort to violence and threat and

(vi) both parties will not engage in discussion when they are under influence of any intoxicants

Both parties will discuss and agree on the quorum required for their meetings and how proceedings of

their meetings will be documented Some suggestions for discussion in this regard are

(i) The quorum for the meeting to be physical presence (or virtual participation) of at least 75 of

the ST Committee and RUMSL Team The FPIC FA will check the quorum of the meeting prior

to starting the proceedings

(ii) The Documentation Assistant in FPIC FA will have the responsibility to record the audiovidoe

of the meeting proceedings

(iii) The FPIC FA will write down the key decisions taken during the discussion and the MoMs will

be read out prior to taking their signature

(iv) The FPIC FA will ensure that ST Committee and RUMSL Team understand the decisions made

If any party express that they need more time (to discuss internally or take approvals) such

information will be recorded

(v) The FPIC FA will also document any dissent expressed by any individual member while

supporting the collective decision of the group she represent in the MoM

The agreed Discussion and Decision Making Framework will have a target time-frameschedule for

completion of each step in the FPIC process Both parties will put their best efforts to complete the

process within t(his time-frame ERM will keep a track of the progress of FPIC process as per this

time-frame and help both parties to avoid unnecessary delays FA will draft the Agreement on Final

Discussion and Decision Making Framework (in Hindi) in consultation with RUMSL and ST

Committee

The final (after ratification) lsquoDiscussion and Decision-making Frameworkrsquo the FPIC-FA will hand over a

signed copy to both parties (ST Committee and RUMSL Team) A pamphlet or poster on accepted

code of conduct will be prepared and displayed at the meeting venue FPIC-FA will request all

members attending the meeting to follow these rules

833 Disclosure of Draft IPPIPDP to ST Committee

ERM will prepare Draft IPPIPDPTDP (in English) for each Solar Park A Summary Draft IPPIPDPTDP

will be translated to Hindi (with use of Malwi as much as possible) ERM will share following documents

to both parties as soon as they ratify the lsquoDiscussion and Decision Making Frameworkrsquo

The Draft IPPIPDPTDP (in English)

Summary Draft IPPIPDPTDP25 (in Hindi)

A simple 4-6 page brochure describing (illustrations where possible) the benefit package

proposed in Draft IPPIPDPTDP

The ST Committee members will be given one week to go through the documents shared with them

and fix a date to explain the Draft IPPIPDPTDP Report

The RUMSL will be provided soft copies of these documents to upload them in their web-site from

where external stakeholders can access these documents

24 The time provided should be adequate to read verify and consult (internally or any external expert on the subject matter)

The FPIC-FA will consult both parties to decide what is reasonable and acceptable to both 25 The Summary Draft IPPIPDPTDP will be 20-25 page It will follow the structure of the IPPIPDPTDP but provide a non-

technical description of the content for easy understanding by ST Committee

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

834 Explaining Draft IPPIPDPTDP to ST Committee

ERM and the FPIC-FA will organize a workshop for ST Committee of each Solar Park at a suitable

location on an agreed date (at least after 7 days from sharing of the documents with ST Committee

The workshop will explain the impacts of the Solar Park and the range of mitigation measures and

project benefits mentioned therein

The FPIC-FA will orient them on how to hold consultations with different sections within their

community and document their views The ST Committee will be provided adequate copies of the

brochure describing the benefit package project boundary maps (in large flex prints) to help them

explain the Solar Project to their community members and hold internal discussions

ERMFPIC-FA will consult ST Committee and RUMSL Team to fix the date for first meeting between

RUMSL and ST Committee

835 Internal Consultation Process by ST Committee

FPIC-FA will help each ST Committee to prepare a tentative schedule for internal discussions The

women representatives will hold meetings with women and youths representatives will hold meetings

among young people The FPIC-FA will make itself available to facilitate and document these internal

meetings

After a round of internal discussion of each sub-group the ST Committee will have the final meeting

to discuss the comments and concerns raised by different sub-groups of the community The ST

Committee will finalize a list of issuesdemands for further discussion with RUMSL The FPIC-FA

prepare the Agenda for First RUMSL-ST Committee Meeting and share it with RUMSL at least a week

before the meeting

The Agenda of the first RUMSL and ST Committee will be shared with the Mediation Committee to

keep them informed about the initiation of discussion between both parties

836 First RUMSL and ST Committee Meeting

The FPIC-FAERM will confirm the quorum prior to starting the proceedings The points mentioned in

the Agenda circulated earlier will be taken up for discussion The RUMSL Team will respond on these

pointsissues The ST Committee will consider these responses and decide if they are satisfied Once

the discussion is concluded the FPIC-FA will write-down the decision made with respect to the

specific Agenda items If any additional points to be discussed by any party those points will be

discussed at the end of the meeting with mutual agreement The FPIC-FA will document the

proceedings of the meeting as per the Discussion and Decision Making Framework (see section 832

above)

If all issues are resolved through discussion in this meeting then another round of discussion is not

required If there will be unresolved issue they will be included in the Agenda for the second meeting

While preparing the Agenda for the second meeting FPIC-FA will record the positions of both parties

with respect to these un-resolved issues The Agenda for the second meeting will be prepared listing

these unresolved issues with an appendix stating the views of each party on these unresolved

issues

RUMSL Team will brief about the mutual agreements and unresolved issues listed for second meeting

with their MD and seek approval if required The ST Committee will similarly brief their community

members on what is agreed after they return

The FPIC FA and ERM will prepare a Draft FPIC Agreement (in Hindi) reflecting the points of mutual

agreements and dissents if any The Draft FPIC Agreement will be shared with both parties

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

837 Second RUMS and STs Committee

The second and subsequent meetings between RUMS Team and IPs Committee will be held on

points where both parties do not agree and it requires further discussion ERMFPIC-FA will consult

both parties to reconsider their views and think about solutions acceptable to them Once ERMFPIC-

FA see both parties are prepared for the next round of discussion date for the second meeting will be

fixed

In this second round of meeting it is expected that a few more points will be mutually agreed The

Draft FPIC Agreement will be updated mentioning these points on which there are mutual agreement

and points of dissentdisagreements

Although it is expected to resolve all issues in two rounds of discussion there is a possibility of

additional rounds of discussion Both RUMSL and ST Committee will discuss on additional meetings

and decide a mutually agreed time-frame to complete the on-going discussion process

If both parties feel canrsquot be resolved through further discussions they will decide if the issue should be

referred to the Mediation Committee or set aside for discussion at a later date26 ERMFPIC-FA will

check if both parties are committed to accept the decision of the Mediation Committee and take the

final decision in consultation with both parties

838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee (MC)

If all issues are resolved through mutual discussion between the RUMSL Team and ST Committee

the Draft FPIC Agreement will be forwarded to MC of the respective Solar Park The MC will be then

requested to be available to chair over the final community meeting (see 8310) to measure the

consent expressed by affected ST in FPIC villages

The MC of the respective Solar Park will consider any issue which was not resolved by mutual

discussion between ST Committee and RUMSL Team and referred to it with an understanding that its

decision will be acceptable to both parties The FPIC-FAERM will hand over documentation of

previous discussion related to the issue and stated positions of both parties with respect to the matter

under consideration to MC

The MC will convene a meeting where it hears the arguments from both sides After considering views

on the matter from both sides MC will offer a solution for consideration If the MC thinks they need to

consult subject experts they will inform both parties and reconvene the meeting after they have

obtained views from such subject experts

Both parties if required will be given time (not more than a week) to consider the resolution offered by

the MC and come back with their final views

After considering the views of both parties on the solutions offered by it the MC will give its final

decision on the matter The MC will try making its decision on consensus and if it is not possible the

decision will be on majority Both parties will be bound by this final decision pronounced by MC The

final decision by MC will be incorporated into the Draft FPIC Agreement

839 Informing Community on Draft FPIC Agreement by ST Committee

The FPIC-FA will provide the Draft FPIC Agreement to the ST Committee The ST Committee

members will inform community members in smaller the sub-groups on the decisions taken during

FPIC discussion with RUMSL The ST Committee will explain their decisions on each issue and ask

26 Particularly matters which are uncertain or may happen in future These issues can be listed as unresolved issues to be

monitored by an agreed mechanism and discussed later

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

each adult member of the community to attend the final community meeting to voice their views and

acceptreject the Draft FPIC Agreement

8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and Ratification of Final IPP and FPIC Agreement

The ST Committee will take decision to hold the final community meeting to express their

consentdissent and fix a date after consulting RUMSL and MC members It will invite RUMS Team

and Mediation Committee to participate and witness the expression of consentdissent by affected

STs

FPIC-FA will ensure that all households in the community are informed about this meeting at least 7

days in advance FPIC-FA will prepare the list of all adult members with support from ST Committee

The IPs Committee will take the responsibility of the invitation and FPIC FA will monitor and document

the process The quorum for holding the final community meeting of affected ST families will be as

follows

Presence of at least 50 of the affected ST families in FPIC village

Presence of at least 60 of the total adult members of these affected ST families

Presence of at least 33 of the total adult women members

Presence of at least 33 of the total youths (between 18 and 25 years)

The FPIC-FA will coordinate with ST Committee members representing women and youth to ensure

that these quorum requirements are met during the final community meeting

The FPIC-FA will set-up a mechanism for recording the presence of eligible ST adult members and

hand over a copy of the Draft FPIC Agreement as they arrive at the meeting venue The Mediation

Committee will preside over this final community meeting The FPIC-FA will inform MC if quorum

requirements for the meeting is achieved After verifying the quorum required and the people

gathered for the meeting are from the affected ST households from FPIC villages the MC will initiate

the meeting proceeding

A representative from RUMSL Team will read out the agreed points mentioned in the Draft FPIC

Agreement and request for their acceptance A representative from the ST Committee will express

their views on points of mutual consensus as well as any unresolved issue that will be discussed and

resolved at a later stage of the project

The MC will then provide opportunities to ST community members present in the meeting to express

their views ST Committee will facilitate community members to express their opinions and

suggestions

The MC will consult with RUMSL and ST Committee if any additional points of agreement and dissent

to be incorporated in the Draft FPIC Agreement After confirming their final positions request the

community members present in the meeting to express their consentdissent and ratifyreject the Draft

FPIC Agreement

The consentdissent will be expressed by raising hands when the members of the Mediation

Committee puts the proposal of ratification to vote If more than 75 of the community members

attending this meeting votes in favour of the Draft FPIC Agreement it would be regarded as

expression of collective consent

The MC will inform the assembled community members about the outcome of the voting and if Draft

FPIC Agreement is ratified or rejected After the Draft FPIC Agreement is ratified by a collective

expression of consent the ST Committee members and RUMSL Team will sign the Final FPIC

Agreement This Agreement will be counter signed by members of the Mediation Committee as

witnesses

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The IPs community may be allowed to carry out any customary ritual on the day of the completion of

the FPIC process and express their support to the proposed Project This FPIC Agreement will be

taken up for implementation and a monitoring committee will oversee its effective implementation

8311 FPIC Process Documentation Report

The FPIC-FA will prepare a FPIC Process Documentation Report summarizing each stage of the

FPIC process It will hand-over all audio-visual records of the FPIC process The process document

report will cover all stages of the FPIC process documenting the following

Process of identification of STs ST representatives and decision-making authorities

Process of assessment of capacity of ST representatives to undertake good faith negotiations

Summary of any capacity building undertaken

Agreed engagement and negotiation framework (including the process undertaken to agree upon

the framework)

Summary of consultations meetings engagement undertaken as part of the FPIC process and

Opinion of FPIC-FA on the process and outcomes

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to

complete the FPIC process

84 Tentative Time-line

The Phase-I FPIC activities was scheduled to be held in Apr 2021 Due to the outbreak of second

wave of Covid-19 in Apr 2021 the field activities are suspended The decision to initiate these

activities will be taken once Covid-19 second wave gets over The schedule for Phase-II activities to

will be discussed with ST Committees of the three Solar Parks and will be decided accordingly As the

progress of FPIC process requires cooperation from affected ST community and the level of

cooperation varies in these three Solar Parks Hence the schedule for Phase-II FPIC activities will be

updated in discussion with respective ST Committees while finalizing the Discussion and Decision

Framework with them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Section Activity Month-1^ Month-2 Month-3 Month-4 Month-5

821 Appointment of FPIC FA and Orientation

822 Introducing FPIC-FA to RUMSL and FPIC Villages

823 Formation of ST Committees

824 Capacity building of ST Committees

8313 Formation of Mediation Committee

832 Acceptance of Draft DDMF

833 Disclosure of Draft IPPIPDPTDP to ST Committee

834 Explaining Draft IPPIPDPTDP to ST Committee

835 Internal Consultation Process by ST Committee

836 First RUMSL and ST Committee Meeting

837 Second RUMSL and ST Committee Meeting

838 Refer Unresolved Matters to MC

839 Inform Community about Draft FPIC Agreement

8310 Final Community Meeting for expression of ConsentDissent

8311 FPIC Process Document Report

Phase-I Activities

Phase-II Activities

Activities to start and complete

OptionalConditional Activity

^ The commencement of these activities will be determined once second wave of Covid-19 gets over

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 83

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW

IN THE STATE OF MADHYA PRADESH INDIA

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

85 Responsibility Matrix

The FPIC process will require a collective effort and coordination between ERM RUMSL ST

Committee Mediation Committee and the FPIC FA The roles and responsibilities of these entities are

described in Section 82 and 83 above ERM will play an active role in coordination and provide

information required for a meaningful discussion The key responsibilities and accountabilities are

summarized below for clarity

Activity ERM FPIC-

FA

ST-

Committee

RUMSL-

F

RUMSL-

HO

Mediation

Committee

IFC-

WB

Formation of ST Committee S P P A

Formation of RUMS Team P A

Formation of Mediation

Committee

P P S P A P

Acceptance of Discussion

and Decision Making

Framework

S P P P A C C

Disclosure of Draft IPP to ST

Committee

P S S A C A

Explaining of Draft IPP to ST

Committee

P S

Internal consultation process

by ST Committee

S P P

First RUMSL and ST

Committee Meeting

S P P P A

Second RUMSL and ST

Committee Meeting

S P P P A

Mediation Committee

Proceedings

P P P S P P

Informing Community on Draft

FPIC Agreement by ST

Committee

S P P A

Final ST community meeting-

expression of consent

dissent

S P P P A A C

FPIC Process Documentation

Report

P P S S S S A

P= Primary Responsibility S= Secondary Responsibility C= Must be Consulted A= Approval

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

PROJECT INFORMATION DOCUMENT SHAJAPUR SOLAR PARK

Background

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) The primary objective of RUMSL

is to develop and facilitate the development of large-scale solar projects in the State of Madhya

Pradesh In line with the governmentrsquos ambition to boost solar power in State RUMSL is developing

Solar Park of capacity of 450 MW at Shajapur Madhya Pradesh

The World Bank had agreed to provide financial support for the Project International Finance

Corporation (IFC) is providing investment advisory services to Government of Madhya Pradesh to

develop the project on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards for the Project

Project Details

The proposed 450 MW Solar Park is located in two Tehsils ndashMoman Badodiya and Shajapur of

Shajapur District Out of 450 MW capacity 325 MW will be developed at Moman Badodiya tehsil

(termed as Unit 1 amp 2) and 125 MW will be developed at Shajapur tehsil (termed as Unit 3) of

Shajapur district Madhya Pradesh Almost 89 of the land area is Government land and remaining is

private land The salient feature of the Project are given below

Solar Park

The Solar Park will be developed as two units spread across these lands and the details of the same

ae captured in the table belowndash

Table A1 Details of Land parcels identified for the project Unit Number Area in ha Capacity Tehsil Villages

Unit 1 72048 220 MW Moman

Bododiya

Proposed to span 6 villages - Bijanakhedi

Burlay Chauma Dehripal Fawaka and

Parsula

Unit 2 105 MW Proposed to span Burlay Dhatrawada and

Jawadi whereas

Unit 3 26964 125 MW Shajapur

Tehsil

Hanoti Surajpur and Shajapur

Total 99012 450 MW

Land

Out of the total land requirement of 99012 hectares 86937 hectare is Government land 11074

hectare is private land and 1001 hectare is government patta land The Government land required for

the Solar Park which accounts for almost 89 of the total land required will be leased by the

government of Madhya Pradesh to SPPDs and the private land will be purchased from the land

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

owners for the development of Solar Park as per the prevailing laws and policies in the State of

Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP

Transmission Line

The transmission infrastructure is planned to evacuate power generated from the units to the STU

grid Each unit will have a 33200 kV internal pooling substation The internal pooling substation will

be connected to the proposed MPPTCL 220400 kV substation at Agar through 220 kV transmission

line For cost optimization the single circuit line from unit 1 will be laid till unit 2 towers and there on a

double line circuit of 220 kV shall be connected till the gird substation The Unit 3 internal pooling

substation shall be evacuated through single circuit 220 kV transmission line till the existing MPPTCL

220400 kV substation at Ujjain

The 33220 kV substation at each unit and 220 kV connectivity to the MPPTCL substation will be

developed by RUMSL MPPTCL will establish 220400 kV proposed grid substation at Agar in

connection with the existing 220400 kV MPPTCL substation at Ujjain Madhya Pradesh MPPTCL will

establish 220400 kV proposed grid substation at Agar along with the associated line till 400220 kV

Ujjain substation The solar project developer in the park shall be responsible for laying the 33 kV

cable and 33 kV ring unit as required at each unit to connect its plant to the 33220 kV internal pooling

substations

Road Infrastructure

The road infrastructure requirements is planned to access the Shajapur Solar Park Ms RUMSL shall

carry out road wideningrepairing of existing roads wherever required The road widening repairing of

existing roads is proposed for a length of 65 km which shall be undertaken by RUMSL The

development of internal roads within each unit shall be in the scope of individual Project Developer

Water Requirement

Water requirements for all purposes shall be met by digging bore-wells within each unit and shall be in

the scope of project developer Also the arrangement of construction water shall be in the scope of

contracting agencies and Solar Power Project developer

Common facilities planned

For 450 MW Shajapur solar park the utility area is proposed adjacent to the Unit 1 and Unit 3 -

33220 kV internal substation The other facilities such as RUMSL office fire-fighting equipment

telecommunication infrastructure medical dispensary etc will be located at the pooling substation

area

Project Implementation

The 450 MW Shajapur Solar Park will be implemented in a period of ~21 months

Operation and Maintenance

It is envisaged that different developers may occupy individual units and will be responsible for OampM

The operations and maintenance of common facilities provided like pooling substation intermediate

substations shall be undertaken by RUMSL

Environment and Social Impact Study and Management Plans

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Assessment (ESIA) of three solar parks including internal

evacuation infrastructure and associated transmission lines ESIA carried out for the project will meet

the requirements of Environment and Social Safeguard Policies and Standards of WB and IFC in

addition to applicable environmental and social regulations and policies in India and the State of

Madhya Pradesh

Based on final land footprint and georeferenced site boundaries of the project the ESIA will include a

Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) ERM will share relevant

information and consult with affected local communities to understand their viewsconcerns The

consultation will cover a wide range of people to take into account perspectives from different social

groups women and men young and old and seek their participation in mitigation of adverse impact

as well as enhancement of project benefits

As the project will impact a number of ST families ERM will assess impacts on them and prepare a

Tribal Development Plan (TDP) which will contain a package of proposed impact mitigation measures

and project benefits ERM will implement a Free Prior Informed Consent (FPIC) process covering

affected Scheduled Tribe population The negotiation process leading to obtain FPIC will be agreed

on with the affected ST communities

Free Prior Informed Consent (FPIC) Process for STs

The FPIC Process will be taken up for Surajpur Parsula and Jawadi villages of Shajapur Site for the impacts on tribal population in given villages on the land under traditional ownership and customary use The process will also involve any nomadic tribes who may have claims of using the project site for grazing their livestock and camping during their annual migration The FPIC process will be divided into two phases as described below

Phase What to Do When to Do

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Before inviting bids for solar parks by concessionaire

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Contacts

Further information and queries related to the project can be obtained from RUMSL site office in

Shajapur and head office at Bhopal The information is also available at website of RUMSL

(httpwwwrumslcom)

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

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wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT FPIC

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

NEEMUCH SOLAR PARK

Badi village Kawai Village

Mama Basti Badi village Bardawada village

AGAR SOLAR PARK

Ladwan village Bijnakhedi village

SHAJAPUR SOLAR PARK

Chauma village Parsula village

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

BACKGROUND

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) RUMSL is facilitating developing

Solar Park of capacity of 450 MW at Shajapur on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards (International Finance Corporation and World Bank) for the Project

Project Details The proposed 450 MW Solar Park is located in Moman Badodiya and South Shajapur tehsils of

Shajapur District collectively referred to as Shajapur Solar Park The Shajapur Solar Park will be

spread across 11 villages in Shajapur amp Moman Badodiya Tehsil of Shajapur District comprising the

villages of Burlay Jawadi and Dhatrawada (for Unit 6) Parsula Dehripal Bijnakhedi Fawaka

Chauma Burlay (for Unit 7) and Surajpur Lalpur and Hanoti (for Unit 8) The land required for 450

MW Solar Park including solar fields roads and transmission and distribution network is 9872

hectares The Shajapur Solar Park plot comprises of three non-contiguous land parcels

The solar park will have three (3) units It is understood that each unit will have a different developer

Unit 6 of 105 MW capacity to be developed on an area of 2461 hectares of Private and

Government land

Unit 7 of 220 MW capacity to be developed on an area of 4859 hectare and

Unit 8 of 125 MW capacity to be developed on an area of 2552 hectare

Land Requirement and Status The Solar Park will largely use GoMP land (approx 88) and the remaining land is either private

land or Patta land The Government land required for the Solar Park will be leased by the government

of Madhya Pradesh and the private land will be purchased from the land owners as per the prevailing

laws and policies in the State of Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th

November 2014 of Government of MP)

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

1 Burlay 237 00 64 00 00 00 301

2 Jawadi 322 00 20 00 00 00 342

3 Dhatrawada 1722 00 97 00 00 00 1819

Sub- Total (unit

6)

2281 00 181 00 00 00 2462

4 Parsula 1162 00 00 52 00 00 1214

5 Dehripal 1111 00 124 00 94 00 1329

6 Bijanakhedi 954 00 226 00 00 00 1180

7 Fawaka 171 00 02 00 00 00 173

8 Chouma 327 00 95 00 00 124 546

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

9 Burlay 417 00 00 00 00 00 417

Sub- Total (Unit

7)

4142 0 447 52 94 124 4859

10 Surajpur 227 07 182 00 00 00 416

11 Lalupura 497 08 00 00 00 00 505

12 Hanoti 1319 125 185 00 00 00 1629

Sub- Total (Unit

8)

2043 140 367 00 00 00 2551

Grand Total 8466 140 995 52 94 124 9872

Source Land Data provided by RUMSL 18th June 2020

Transmission Line Each Solar Park Unit will have 33220 kV substations and the power generated from each unit (Unit 6

7 and 8) will be pooled to the 220 kV switching pooling substation The utility area is proposed near

the internal pooling substation located at the Unit 6 and Unit 8

Road Infrastructure Access to Unit 6 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The existing village road has a width of ~4-5 meter and existing

State highways has a width of ~75 meter The road length of ~25 km will be strengthened and

repaired to suit the need during the construction phase

Access to Unit 7 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The road length of ~2 km will be strengthened and repaired to

suit the need during the development phase

Access to Unit 8 The Unit is connected with village road from Jhonkar to Hanoti at a distance 0f ~6

km from Jhonkar The existing road is a two-lane bituminous concrete road with width ~7-75 meters

and a new bituminous road with width ~75 meters and length ~500 meters is proposed to connect

33220 kV plant substation The road length of ~2 km will be strengthened and repaired to suit the

need during the development phase

Water Requirement The total requirement for water is estimated as 323 kL day Developers shall establish bore-wells per

block with required approvals and directions to meet their requirements The entire water supply

system including provision for bore-wells within individual blocks shall be in the scope of the Project

Developer The water requirement for the green belt is estimated to be 7000 litres per day

Common facilities planned The common facilities such as RUMSL office fire-fighting equipment telecommunication

infrastructure medical dispensary weather monitoring station etc will be located at the pooling

substation area located at the Unit 6 The operations and maintenance of common facilities provided

like pooling substation intermediate substations shall be undertaken by RUMSL Ms RUMSL will

establish two Weather Monitoring Station at internal pooling substation (at each unit)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Project Implementation

The 450 MW Shajapur Solar Park will be constructed a time frame of ~21 months with construction

proposed to started in November 2020

Project Impacts Benefits and Mitigation Measures

RUMSL will identify stakeholders and prepare a schedule for consulting them on a regular basis in

construction phase It will also establish a grievance redress mechanism through which local

community can register their grievances and seek redress to any adverse impacts on them The

project through its ESIA process has identified a range of potential impacts and has planned to

implement appropriate mitigation measures The key impactsbenefits and proposed mitigation

measures are discussed below for your knowledge and suggestions for making them more effective

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D1 Moman Badodiya Unit 6

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D2 Moman Badodiya Unit 7

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D3 South Shajapur Unit 8

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact from Land Acquisition

Type of land impacted How Impacts will be addressed

Private Land (Purchased through MP

Mutual Consent Policy 2014

Adequate compensation at twice the value of land and assets as

per MP Mutual Consent Policy 2014

Benefits of Resettlement Action Plan-Livelihoods restoration Plan

Preference to households (rendered landless or with sub-optimal

holdings) of the families post selling land to the project for

employment opportunitiessmall contracts in the

Constructionoperation phase

Pattta Land (Negotiated purchase

through MP Mutual Consent Policy)

Patta is being treated at par with ownership for the land

procurement process and would have same benefits as of private

land owners

Government Land Used for Grazing

easements cultural heritage sites

water sources fuel wood collection and

collection of other resources

Provision for alternate grazing land for cattle near the project

village or confirmation of adequacy of remaining grazing land

Development of community fodder lots in available unoccupied

government land may be explored and covered in Resettlement

Action Plan

Provision of easements shall be maintained in order to not sever

the access to CPRs for the community

Government Land Informally

occupied Capturedencroached for

agriculture or grazing prohibiting use

by other people

RUMSL shall serve a three months advance notice to the project

affected persons (PAPs) to harvest standing crops andor avoid

growing fresh crops

In case the advance notice is not given RUMSL shall pay

compensation for crops at full replacement cost

ImpactsBenefits in Construction Phase

Impact Mitigation Measures

Temporary occupation of land

for construction phase activities

such as Labour Camps Safety

Setbacks Storage areas

Parking areas Other

construction related temporary

land requirements etc

Adequate lease rents to the land owners

Restoration of land to its original state or better at the time of handing it

back to the owners

Compensation for the loss of livelihoods to the users of the land required

for temporary use as this will temporarily economically displace them

Community Health and Safety

including accident risks for

domestic animals

The Contractor shall prepare Traffic Management Plan Workers Code of

Conduct and Health and Safety Plan and implement it after approval of

RUMSL

Stress on Community resources

- Water and Roads

There will be a worker Code of Conduct defined by RUMSL that prevents

workers and contractors from using the local resources like water forest

The contractor shall be asked to use Tanker water supply during the

summer months which are dry months in which water scarcity issues are

reported by the community

Noise Nuisance and Dust Install enclosures around construction area in order to reduce the extent

of noise and dust

Limit construction related activities to day time

Employment and

entrepreneurship opportunities

during construction

The sourcing of local labour wherever possible will be obligatory for the

Solar Project Developers and sub-contractors

Employment of members of SC-STs and vulnerable households will be

at a minimum of 30 of total workers or person-days of employment

Engagement of local vendors to the extent possible for the goods and

services required for the project during construction phase

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact Mitigation Measures

The RUMSL will establish a mechanism to audit subcontractors and

suppliers with respect to compliance of utilizing local labour and

resources

Impacts in Operation Phase

Impact Mitigation Measures

Community Health and

Safety

Community engagement and sensitization sessions should be re-organised at

the beginning of Operations phase in order to mention about the new

developments in the area and provide an understanding of the precautions to

be taken for safety

Impact on Employment RUMSL shall ensure that the Solar project developers (SPDs) advertise the

roles of Technical staff required during operations phases in the local

newspapers to enable hiring of competent people from nearby areas to the

extent feasible

Preference shall be given (to the extent feasible) to hire competent members

from PAHs for semi-skilled jobs like housekeeping or Security Guards

Impacts on Vulnerable Sections Women and Scheduled Tribes

Impact Mitigation Measures

Impacts on Indigenous

Communities Vulnerable

Groups

To Prepare an Indigenous Peoples PlanTribal Development Plan with special

benefits for Scheduled Tribes

Recognizing their right to Free Prior Informed Consent process and its

implementation

As part of the stakeholder engagement ensure adequate representation and

participation of the Scheduled Tribes

Impact on Women A Gender Action Plan will be prepared for the Project to assess and mitigate

gender specific impacts

Ensure that the employment of women from vulnerable households is

prioritised for the project

Efforts are made to support development of women owned enterprises in the

area through the LRP from where procurement for project related may be

prioritised

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

Page 1

शाजापर सोलर पारक रा पररयोजना वििरण दसतािज़

पषठभवि

नवीन और नवीकरणीय ऊरजा मतरजलय क सहयोग स मधय परदश सरकार मधय परदश म जमीनी गरिड स रडी

सौर ऊजाा पररयोजना का गरिकगरसत कर रही ह रीिा अलटर ा मगा सोलर गरलगरमटड (RUMSL) का एक

सािाजगरनक उपकरम िरा 2015 म सथागरपत हआ ह यह उपकरम सोलर एनरी कारपोरशन आफ इगरडया गरलगरमटड

(SECI) तथा मधयपरदश ऊजाा गरिकास गरनगम गरलगरमटड (MPUVNL) क साथ सयकत उपकरम क रप म सथागरपत

हआ ह शाजापर सोलर पाका की कल कषमता 450 मगा िाट होगी और इस सौर ऊजाा पाका को गरनजी -

सािाजगरनक साझदारी क तहत गरनमााण गरकया जाना परसतजववत ह

रीवज अलटर ज मगज सोलर वलवमटड (RUMSL) दवजरज ईआरएम इवडयज परजइवट वलवमटड (ERM) को अतरााषटर ीय

मानको (अतरााषटर ीय गरितत वनगम एि गरिशवबक) क अनसजर सौर पजका क पयजावरणीय और सजमजवरक परभजव

मलजकन (ESIA) क सजथ सजथ पनगरिासथापन कजया योरनज (RAP) और सवततर रप स समदाय की पिा

सगरित सहमगरत (FPIC) परवियज क वलए अनबगरित गरकया गया ह

पररयोजना री परिख जानरारी

450 मगा िाट का परसतागरित सोलर पाका शाजापर गरजल क मोहन बड़ोगरडया और शाजापर तहसील क अतगात

शाजापर सोलर पाका क नाम स जाना जाएगा यह सौर ऊजाा पाका 11 गाािो क कषतर म बनगा यह 11 गााि इस

परकार ह बल जिादी और ितिादा (इकाई 6) पारसला दहरीपल बीजनखड़ी फिाका िौमा बल (इकाई

7) और सरजपर लालपर तथा हनोती (इकाई 8)

इस 450 मगा िाट सोलर पाका हत कल 9872 हकटर जमीन की आियशकता होगी गरजसम सोलर फीलड

सड़क टर ासगरमशन एि गरितरण नटिका शागरमल होगा पाका तीन अलग इकाईयो म गरिकगरसत होगा ऐसा

अनमान ह गरक परतयक इकाई का गरनमााण अलग-अलग गरनमााताओ दवारा गरकया जाएगा

105 मगा िाट कषमता िाली इकाई 62461 हकटर कषतर पर सरकारी तथा गरनजी जमीन पर गरिकगरसत

होगी

220 मगा िाट कषमता िाली इकाई 74859 हकटर कषतर पर गरिकगरसत होगी तथा

125 मगा िाट कषमता िाली इकाई 82552 हकटर कषतर पर गरिकगरसत होगी

Page 2

जिीन री सथिवि एि अविगरहण

सौर ऊजाा पजका लगभग 88 मधय परदश की सरकारी भवम कज उपयोग करगज और शष भवम यज तो वनरी यज

पटटज भवम रहगी सोलर पजका क वलए आवशयक रजरसव भवम मधय परदश सरकजर दवजरज पटट पर दी रजएगी और

वनरी भवम मधय परदश रजजय म परचवलत कजननो और नीवतयो क अनसजर भवम मजवलको स खरीदी रजएगी

(Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP)

कर

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नाि

सरर

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जि

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िवि

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(NR

ED

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कटर

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हकट

वनज

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हकट

1 बल 237 00 64 00 00 00 301

2 जािादी 322 00 20 00 00 00 342

3 ितरािदा 1722 00 97 00 00 00 1819

योग (इराई 6 ) 2281 00 181 00 00 00 2462

4 परसला 1162 00 00 52 00 00 1214

5 दहरीपल 1111 00 124 00 94 00 1329

6 बीजनखड़ी 954 00 226 00 00 00 1180

7 फािक 171 00 02 00 00 00 173

8 िौमा 327 00 95 00 00 124 546

9 बल 417 00 00 00 00 00 417

योग (इराई 7) 4142 0 447 52 94 124 4859

10 सरजपर 227 07 182 00 00 00 416

11 लालपर 497 08 00 00 00 00 505

12 हनोती 1319 125 185 00 00 00 1629

योग (इराई 8) 2043 140 367 00 00 00 2551

Page 3

रल 8466 140 995 52 94 124 9872

सदभक रीिा अलटर ा मगा सोलर गरलगरमटड दवारा गरदया गया जमीन का डाटा 18 जन 2020

िासविशन लाइन

परतयक सोलर पाका इकाई क 33220 किी क सब सटशन होग तथा परतयक इकाई (6 7 8) स 220 गरकलो

िाट की ऊजाा सब सटशन एकतर गरकया जाएगा आतररक पगरलग सब सटशन इकाई 6 और 8 क समीम

सथागरपत करना परसतागरित ह

सड़र वनिाकण

इराई 6 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रोवक आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

गााि क रासत की िौड़ाई लगभग 4-5 मीटर तथा राजयमगा की िौड़ाई 75 मीटर ह सौर ऊजाा पाका क

गरनमााण हत 25 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 7 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रो की आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 8 िर पहाि

इकाई 8 िाम झोकर स 6 गरकलोमीटर दर िाम झोकर स िाम गरहनोती को जान िाली सड़क स जड़ी ह यह

रासता डबल लन डामर रासता ह गरजसकी लबाई 7-75 मीटर ह एक नई डामर रोड गरजसकी लबाई 500

मीटर तथा िौड़ाई 75 मीटर ह और जो 33220 किी क सब सटशन को जोड़न क गरलए बनाई जाना

परसतागरित ह सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया

जाएगा

पानी री आिशयरिा

यह अनमान ह की परगरत गरदन लगभग 323 गरकलो लीटर पानी आिशयकता होगी पानी की पगरता क गरलए ठकदार

दवारा परगरत बलॉक बोररग की रजएगी सौर ऊजाा पाका क गरनमााण क दौरान परतयक बलॉक क पानी की सपलाइ

की वयिसथा का परा खाका गरजसम बोररग करना भी शागरमल ह ठकदार अपन परसताि म द ग हररत पटटी क

गरलए परगरत गरदन अदाजन कल 700 लीटर पानी की आियशकता होगी

Page 4

सािानय सवििाओ री उपलबधिा

RUMSL का ऑगरफस अगरि शमन सटशन टली कमयगरनकशन (फोन) गरिगरकतसालय गरडसपनसरी मौसम की

जानकारी सटशन इतयागरद इकाई 6 क समीप पलीग सब सटशन पर सथागरपत हाागी पगरलग सबसटशन तथा

मधयमिती सबसटशन गरक तमाम सगरििाओ का सिालन एि दखरख RUMSL दवारा गरकया जाएगा RUMSL

आतररक पलीग सटशन पर दो मौसम अनशरिण सटशन सथागरपत करगा

पररयोजना रा वकरयानवयन

450 मगा िाट का शाजापर सोलर पाका का गरनमााण निमबर 2020 स शरिात कर अगल 21 महीनो म परा

होना अपगरकषत ह

पररयोजना र परभाि लाभ ििा शिन उपाय

सौर ऊजाा पाका क गरनमााण क दौरान RUMSL गरिगरभनन गरहतसािको की पहिान कर उनस गरनयगरमत ििाा और

सलाह मशिरा करतज रहगज पाका गरनमााण क दौरान िामीणो की गरशकायतो को समझन एि उनह दर करन क

गरलए गरशकायत गरनिारण ततर की वयिसथा RUMSL करगा तागरक गरशकायतो का गरनपटारा शीघर हो सक और

लोगो पर हो रह नकारातमक परभाि को दर कर सक पररयोजना दवारा ESIA की परगरकरया क माधयम स सभागरित

परभािो को गरिनहनहतकर उनक गरनपटार हत उगरित और परभकारी उपाय करगा अपगरकषत परभािलाभ और शमन

क उपाय गरनमन गरलनहखत ह तागरक आपक सझािो क आिार पर उनह और परभािी बनाया जा सक

Page 5

नकशा 1 िोहन बदोवदया इराई 6

Page 6

नकशा 2 िोहन बदोवदया इराई 7

Page 7

नकशा 3 शाजापर इराई 8

Page 8

जिीन अविगरहण रा परभाि

परभाविि जिीन रा पररार परभाि रा वनिारण

वनजी जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत 2014 क तहत

खरीदी गरनजी जमीन)

मधय परदश आपसी सहमगरत भगरम करय नीगरत 2014 क तहत

पयाापत मआिजा जमीन या सपगरत क मलय स दगना

पनिासन कायायोजना ndash आजीगरिका पनजीिन योजना स लाभ

पररयोजना हत अगरििहण क बाद पररिार गरजनक पास बहत ही

कम जमीन बिी ह या भगरमहीन पररिारो को पराथगरमकता

गरनमााण क दौरान गरकरयानवयन क समय उनक गरलए काम क

अिसर छोट काया अनबि काटर कट म पराथगरमकता दना

पटटिाली जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत2014 क तहत

तय कर खरीदी गए जमीन)

जमीन क अगरििहण क दौरान पटटा िारको को गरनजी मागरलक की

तरह समझत हए उनक गरलए गरनिााररत सार फायद दना

सररारी जिीन िरनोई सासकगरतक

िरोहर जल शरोत जलाऊ लकड़ी

सिहण गरनसतार की जमीन

अनयससािनो का सिहण क उपयोग म

आन िाली जमीन

पररयोजना क समीप क गााि म िरनोई क गरलए जमीन की

िकनहिक वयिसथा करिाना या अगरििहण क बाद शर जमीन म

गााि क गरलए पयाापत िरनोई की जमीन सगरनगरित करना

खाली पड़ी सरकारी जमीन पर सामदागरयक िारागाह की खप

गरिकगरसत करन हत पनिासनकाया योजना म सभािना खोजना

समदाय क सामदागरयक ससािनो तक पहाि बनी रह उस सगरनगरित

करन क गरलए भारतीय सख भोग अगरिगरनयम 1882 क पराििानो

का पालन गरकया जाएगा

सररारी जिीन अिि कबजिाली

जमीन खती या िराई क गरलए कबजा

अगरतकरमण गरकया गया हो लोगो दवारा

सािाजगरनक उपयोग बागरित गरकया गया

हो

RUMSL पररयोजना स परभागरित लोगो को तीन महीन का पिा

नोगरटस दगा तागरक ि अपनी लगी हई फसल काट सक या नई

फसल न बोए

यगरद गरकसी कारण िश पिा नोगरटस नही दी गयी तो RUMSL परी

फसल की कीमत मआिज क तौर पर द ग

Page 9

वनिाकण र दौरान परभािफायद

परभाि शिनवनपिार र उपाय

गरनमााण क िरण क दौरान गरिगरभनन गगरतगरिगरियो

क गरलए जस मजदर रहिास (क प) सरकषा

वयिसथा भडारण वयिसथा िाहन पागरकि ग कषतर

तथा गरनमााण सबिी अनय जमीन की असथायी

आिशयकता पड़ना आगरद

जमीन मागरलको को पयाापत लीजगरकराए की वयिसथा करना

जमीन मागरलको को उनकी जमीन लौटन क समय वयिनहसथत

रप स सिार कर परानी अिसथा या उसस भी अचछी करक

लौटाना

जमीन मागरलको को उनक जमीन स असथायी रप स हटान एि

उनकी आजीगरिका क नकसान क एिज म मआिजा दना

सामदागरयक सवासथय एि सरकषा तथा घरल

उपयोगी पशओ की दघाटनाका जोनहखम

ठकदार सभी की सरकषा क गरकए आिागमन परबिन पलान

तयार कर ग मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयिहार क गरनयम) और सवासथय एि सरकषा की योजना

बनाकर RUMSL स अनमोदन क पिात ही गरकरयानवयन कर ग

सामदागरयक ससािनो पर दबाि ndash पानी एि

सड़क

RUMSL दवारा मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयहार क गरनयम) गरनिााररत गरकए जाएग गरजसस

कमािारी तथा ठकदार सथानीय ससािनो जस पानी जगल

आगरद का नयायोगरित उपयोग कर पाएग

गगरमायो क समय पानी की गरकललत को दखत हए ठकदार को

यह गरनदश होग की िह पानी क टकर स पानी गरक पगरता कर

शोर बािा एि िल गरनमााण सथल पर दीिार लगानासथागरपत करना तागरक शोर एि

िल कम फल

गरनमााण काया किल गरदन क समय ही करनागरनमााण काया रात

क समय परगरतबगरित करना

गरनमााण क दौरान रोजगार तथा वयिसाय क

अिसर

यथासभि सोलर पाका गरिकगरसत कतााओ तथा ठकदारो आगरद

क गरलए सथानीय लोगो एिम मजदरो को काया दन की

अगरनिायाता होगी

कल रोजगार गरदिस या कल कमािाररयो म कम स कम 30

परगरतशत मजदरकमािारी अनसगरित जागरत - जनजागरत या िगरित

पररिार स होग

सोलर पररयोजना गरनमााण क समय गरकसी भी मालसामिी या

सिा की जररत यथासभि सथानीय गरिकरताओ क माधयम स

की जाएगी

RUMSL गरनमााण क दौरान एक अककषण ततर की वयिसथा

करगा तागरक ठकदार गरिकरता सिा परदाता सथानीय ससािनो

तथा मजदरो का यथोगरित उपयोग कर सक

Page 10

वकरयानवयन र सिय परभाि

परभाि शिन वनपिार र उपाय

सामदागरयक सवासथय एि

सरकषा

सोलर पाका क गरनमााण की परगरकरया क दौरान गरनमााण स होन िाल नए

बदलाि क सबि म समदाय को सिदनशील बनाना हत बठको का

आयोजन करना और सरकषा क गरलए एहगरतयात बरतन हत समय समय पर

गरििार गरिमशा और ििााए करना

रोजगार पर परभाि RUMSL यह सगरनगरित करगा की पररयोजना क गरनमााण क दौरान

तकनीकी कमािाररयो की भती का गरिजञापन सथानीय अखबारो म छप

तागरक योगय सथानीय लोगो को भती गरकया जा सक

अिा कौशल कषमता िाल काम जस कायाालय की दखरख सरकषा गाडा

आगरद पररयोजना स परभागरित पररिारो को पराथगरमकता क आिार पर

गरदय जाए

िविि िगक पर परभाि िवहलाए एि अनसविि जनजावि र सदभक ि

परभाि शिन वनपिार र उपाय

अनसगरित जनजागरत एि

िगरित िगा पर परभाि

अनसगरित जनजागरत समदाय क लाभ को धयान म रखत हए मलगरनिासी

समदाय क गरलए योजना आगरदिासी गरिकास की योजना बनाई जाएगी

सवततर पिा सगरित सहमगरत क आिार पर FPIC की परगरकरया का

गरकरयानवयिन गरकया जाएगा

गरिगरभनन गरहतसािको को शागरमल करत समय अनसगरित जनजागरत समदाय

का पणा रप स परगरतगरनगरितव और भागीदारी को सगरनगरित गरकया जाएगा

मवहलजओ पर परभाि जडर एकशन पलान का गरनमााण गरकया जाएगा तागरक पररयोजना की िजह

स जडर गरिगरशषट परभािो का आकलन कर उनह गरनपटा या कम करन का

परयास हो सक

पररयोजना म िगरित िगा की मगरहलाओ को रोजगार पराथगरमकता गरमल यह

सगरनगरित गरकया जाएगा

पररयोजना कषतर म मगरहला उदयमी गरिकरता सिा परदाताओ को सहयोग

करन क परयास गरकए जायग गरजसस पररयोजना म काम आन सामिी

समान की खरीदी उनस की जा सक

Page 11

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE FPIC FACILITATOR

Page 12

Screening of Facilitating AgencyIndividual Expert for FPIC

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to

undertake an Environmental and Social Impact Assessment (ESIA) of three solar parks

including internal evacuation infrastructure and associated transmission lines of aggregate

capacity of 1500 MW in the Neemuch Agar and Shajapur Districts of Madhya Pradesh India

(hereinafter referred to as the lsquoProjectrsquo) one of the key tasks as part of this assignment is to

secure Free Prior Informed Consent in keeping with the provisions of IFC PS 7 For this

purpose ERM has undertaken the task of identifying a Facilitation AgencyIndividual (FA) to

assist with the FPIC process This document presents the results of the screening and

shortlisting process for the FPIC FA

Approach and Methodology

The approach and methodology followed for shortlisting of FPIC FAs is presented below

1 Two stage approach was followed for the selection of FPIC Facilitation

AgencyIndividual Initially desk research was carried out to identify Institutions (Universities

Government Departments and Research Institutes etc) NGOs and INGOs located in

Madhya Pradesh state In parallel the ERM team also identified the criterion which will be

used to shortlist the potential Facilitating Agencies The criteria used for screening included

qualification profile affiliation with the type of institutionsorganizations nature of

worksprojects completed working experience with Bhils in MP experience in natural

resource management and rural livelihoods conducting meaningful consultation community

mobilization and stakeholder engagement familiarity with World Bank Group safeguardsrsquo

policies and procedures comfort with written and spoken English and local dialects etc

2 In the second stage the potential candidates from these institutions were individually

approached to further assess their suitability and find out their availability for the assignment

Convenient date and time for the personal discussion and interview with them was sought

Accordingly the ERM team organized interview with the available candidates at Bhopal

3 The team27 of Environmental Resource Management (ERM) New Delhi visited

Bhopal during 6-8 January 2020 in order to undertake face to face meetings with these

organizations and individuals identified

Screening

4 The screening against the preferred criteria was undertaken for the potential

candidates available to work as FA for FPIC None of these agenciesindividuals reported to

have worked for a FPIC process earlier Also the candidates interviewed are not familiar

with the World Bank and IFC safeguards related policies and procedure applicable for IPs in

energy and other infrastructure development sectors They are however interested in

working and learning from the project The candidates also had limited experience in the

field of natural resource management and rural livelihoods Details of the screening of

potential candidates is given below

27 Team comprised of Ramesh Swarankar Freelance Consultant and Akshita Mishra Senior Consultant ERM

Page 13

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Amitav Singh

and Leena

Singh

Debate Lok

Nyas (DEBATE)

Duplex C-22

Alkapuri Near

DRM Office

Habibganj

Bhopal-462024

0755-2985007

0755-2417656

9425018144

9425004556

debateindiag

mailcom

MA Social

Works

The key persons are active for

last 3 decades in Social Work

The Debate Trust was

incorporated in 2002-03 and has

more than 15 years of experience

in working with PRIs in Madhya

Pradesh with an focus in Tribal

(Schedule-V) Areas Mr Amitav

Singh is a member of National

Committee for Monitoring of

MNREGA

Ms Leena Singh has also

experience of working with rural

women for more than 15 years

Have

worked

with Bhils

of

Jhabua

Yes Yes Yes

Mr Amitav

Singh is a

leading trainer

for PRA and

Social Audits

by Panchayat

Raj Ministry

No

But was

part of the

FPIC

training

provided

by

ActionAid

Yes

(requires

support in

Reporting)

Score 18 3 2 3 3 3 2 2

Dr Jose

Payyappilly

Address 142

Nyay Nagar

Sukhliya

Indore

Contact-

7828355557

PhD MA

in Social

Work amp

Sociology

About three decades experience

of working on Health HIVAIDS

CSR Literacy Adult education

minority education related

projects and programs funded by

GoI GoM Clinton Foundation Bill

amp Melinda Gate Foundation

UNAIDCARE World Action

Forum VHAI Christian Aid NGO

such as Samarthan in MP

Chhattisgarh and other states It

Has

worked

with Bhils

as part of

a larger

communi

ty in

Jabhua

No No Yes

Trained in

traditional

communicatio

n systems

folklore

folktale

Familiar with

planning

strategy and

community

Associated

with the

network of

NGOs CSOs

and village

level

functionaries

Worked with

local

governments

and elected

No Yes

Page 14

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Email Id

payyappillyjose1

6gmailcom

jose_soolyaho

ocoin

includes the districts in MP with

IPs population

Dr Jose has worked as team

leader director executive director

and other positions Also worked

as Local Governance and BCC

Advisor to DANIDA for Health

Services Program State Media

Coordinator State Resource

centre Adult Education MP

Program Producer Radio Veritas

Asia Manila Philippines

stakeholder

engagement

panchayat

representative

s

Score 14 2 1 1 3 3 1 3

Parushram

Tiwari

Address- C-443

Sarvdharm

Colony Kolar

Road Bhopal

Contact-

09425065132 amp

8319540266

Email Id

drpram42gma

ilcom

PhD

MPhil MA

( Sociology

More than 20 year experience of

working as consultant at different

positions in Public health

HIVAIDS literacy education

nutrition urban development and

governance projects and

programs in MP including Malwa

area and other states

These projects were funded by

UNICEF UNFPA ADB Clinton

Foundation Women amp Child

Development Rural

Development Urban

Administration amp Development

No No Yes Has

worked as

the State

Project

Manager

for Sanjhi

Sehat

project of

MP State

Rural

Livleihood

Mission

Yes Is good

with

coordination

and

communicatio

n

Yes has

experience in

Planning

management

and execution

capacity

building

training and

Networking

and advocacy

Liaison

support and

team building

No Will need

support in

documentatio

n

Page 15

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

State AIDS Control Society of

GoMP and the NGO partners

Dr Tiwari was the Project Director

and District Program officer under

National Literacy Mission at

District Collector offices at Dhar

and Indore MP respectively

during 1991-1998

Score 13 1 1 2 3 3 1 2

Mr Sandip Naik

Adddress-C-55

Kalani Bagh

Dewas MP

Pin Code

455001 India

Contact- +91-94

2591 9221

Email id

naiksandigmai

lcom

Diploma in

Developm

ent

Facilitation

from TISS

Mumbai

MPhil

MA in

Rural

Developm

ent and

English

Literature

About 20 year experience of

working on health nutrition

education governance and

women empowerment with

governments of MP

Worked with NGOs International

agencies and MP government on

senior positions

Since 2014 working with CRY

and TDH on issues of malnutrition

and preparing booklets

brochures pamphlets on nutrition

adolescents issues and childrenrsquos

health Also written textbooks

teachers learning material and

manuals for state govt for SCERT

etc

Yes No No Yes Yes No Yes

Page 16

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Score 14 2 1 1 3 3 1 3

Dr Rahul Dev

Bahawsar

Address Block

No 14 Flat No

5 Shalimar

Enclave E-3

Arera Colony

Bhopal ndash

Madhya

Pradesh

Contact-

08223015124

Email

rbhawsarrediff

mailcom

rahuldevbhawsa

rgmailcom

PhD amp

MPhil in

Population

Studies

from IIPS

Mumbai

MSC

Statistics

24 years experience in

monitoring evaluation and

implementation of programs in

health and social development

sectors in MP Rajasthan and

Gujarat states

Engaged in nutrition assessment

survey in 18 districts of MP states

including IPs dominated districts

such as Dhar Jhabua with Bhil

population and coordinated with

state health women amp child

development and rural

development departments during

the study period

Involved in conducting health

surveys at national level

Worked as a staff with Health

Management Research Institute

Jaipur and IPE Global Consulting

Firm New Delhi etc These

projects were funded by DFID

UNICEF UNFPA GoI GoMP

etc

Yes has

worked

in

Jhabhua

and Dhar

No Yes Has

worked

with State

Rural

Livelihood

Mission

Somewhat

His strengths

lie more

towards

quantitative

research

Somewhat No Yes

Page 17

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Working as freelance expert and

has a registered consultancy firm

that is inactive

Score 12 2 1 2 2 2 1 2

Ms Aastha

Anuragi

Address 173

Sanjay

Complex

Phase-2

Geetanjaly

Square Bhopal-

462003

Contact-

9425365216

8160123726

Email

aasthaanuragi

gmailcom

MBA Rural

Manageme

nt amp MSC

in Physics

More than 15 year experience of

working particularly imparting

training to different stakeholders

in drinking water and sanitation

Swachh Bharat ODF missions

WASH livelihood menstrual

hygiene etc Master trainer for

total sanitation program

Worked as consultant in MP

Chhattisgarh West Bengal UP

Gujarat Jharkhand Bihar states

These projects were funded by

World Bank Water Aid UNICEF

DFID GoI State governments

and ICIMOD Nepal

No No Yes has

worked as

a project

facilitator

with MP

livelihood

project

Yes Yes No No

Score 12 1 1 2 3 3 1 1

Note The scoring for each criterion was as follows 0- Not applicable 1- Not Meeting the Requirement 2- Partially meeting the requirement 3- Completely fulfilling the requirement

Page 18

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

Page 19

TERMS OF REFERENCE FOR FPIC FACILITATION AGENCY

Background

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake an

Environmental and Social Impact Assessment of three solar parks including internal evacuation

infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch

Agar and Shajapur Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work for the project ERM is required to assess the impacts on the indigenous

marginalized communities within the site and its influence area prepare an Indigenous Peoples Plan

(IPP) apart from other ESIA amp RAP deliverables The project is also required to conduct a FPIC process

covering affected Scheduled Tribe (ST) population

Villages to be covered in FPIC Process

The project area has a few small ST settlements and in few others a small number of ST households

live along with a majority non-ST population Following 5 villages are identified for carrying out FPIC

process

Solar Park Selected ST villages

for FPIC

Number of

Households

Name of ST

Community

Agar Solar Park Ladwan 12 Bhil

Shajapur Solar Park Parsula 41 BhilBhilala

Neemuch Solar Park Badi and Kawai 97 BhilBhilala

Note Additional ST families in neighbourhood villages of the same Solar Park will be made part of this

process to a limited extent

Phases in FPIC Process

The FPIC process will be divided into two phases as described below

Phase What to Do Schedule

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Apr 2021^

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

May-Aug 2021^

^ Activities were suspended in April 2021 due to break out of the second wave of Covid-19 in India These

activities will be re-scheduled once Covid-19 second wave gets over

Deliverables and Responsibilities

Phase Responsibilities Deliverable

I Identification of STs Representatives and formation of committees

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Documentation of capacity building of STs Representatives on FPIC

Mutually agreed FPIC Process and composition of local ST Representative committees

Page 20

Phase Responsibilities Deliverable

Hindi Translation of TDPIPP and designing Information sharing tools

Participatory mapping of all natural resources and cultural sites to be impacted

Participatory assessment of impacts on Tribal population

Identification of Livelihood and Welfare programs to be included in Draft TDP

Inventory of natural resource and cultural sites

Documentation of participatory process of impact assessment

Note on livelihood and welfare programs

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation (Photos Video MoMs for each meetingsevents) of FPIC process

The revised package in Draft TDP and a mutually agreed Draft FPIC Agreement

Personnel Requirement

The FPIC Facilitation Agency will require to mobilize following key personnel for completing these tasks

Designation Desired Qualification and Experience

Coordinator The coordinator to be a post-graduate in social sciencessocial work with at

least 15 years of experience in ruraltribal development Prior involvement in

FPIC related work with prominent civil society organizations or multilateral

development finance organizations will be preferred

Facilitator (Male) The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in facilitation of participatory rural appraisals The

facilitator needs to have sound knowledge of livelihood issues in Malwa

region of Madhya Pradesh and must have worked with Panchayati Raj

Institutions for their capacity building The facilitator should be familiar with

the local dialect (Malwi) spoken in Malwa region

Facilitator

(Female)

The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in working with rural women She should have

knowledge of livelihood and social context of women in Malwa region She

should have prior experience in facilitating participatory rural appraisal

processes involving rural women

Documentation

Assistant

The documentation assistant should be a Graduate in social sciencesmass

communication She should have at least 5 years of experience in ruraltribal

development and have carried out process documentation of development

projects She should have a good command over Hindi and should be

familiar with Malwi dialect

Community

Mobilizer

The community mobilizer should have passed higher secondary and have

experience of working with any NGO for at least 2 years She should have

good communication skills She will provide all logistical support necessary

to ensure participation of maximum number of people She also helps

Documentation Assistant in photo and video documentation of the FPIC

process

Organization Profile

The organization should have at least 10 years of experience in working in rural and tribal

development issues in Madhya Pradesh The organization should have a reputation of successfully

implementing projects related to community mobilization and capacity building They should have

Page 21

prior experience of working with tribes and should be known for their dedication and commitment

towards tribal rights and promoting their development

The business of sustainability

ERM has over 160 offices across the following

countries and territories worldwide

Argentina

Australia

Belgium

Brazil

Canada

Chile

China

Colombia

France

Germany

Ghana

Guyana

Hong Kong

India

Indonesia

Ireland

Italy

Japan

Kazakhstan

Kenya

Malaysia

Mexico

Mozambique

Myanmar

The Netherlands

New Zealand

Norway

Panama

Peru

Poland

Portugal

Puerto Rico

Romania

Russia

Senegal

Singapore

South Africa

South Korea

Spain

Sweden

Switzerland

Taiwan

Tanzania

Thailand

UAE

UK

US

Vietnam

ERM India Private Limited

Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

wwwermcom

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page iii

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Tables

Table 11 Villages to be covered in FPIC Process 1

Table 12 Salient Features of the Project 2

Table 13 The status of ESIA Study Components and Community Engagement 3

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables 5

Table 21 Key Provisions of Land Revenue Code 12

Table 22 Comparison of Provisions of Consent Process in Applicable Indian Regulations vis-agrave-

vis Provisions in IFC PS-7 17

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land

Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

19

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected

Villages 22

Table 32 Agar Solar Park- Government Land- Land Use Category 26

Table 33 Shajapur Solar Park- Government Land- Land Use Category 30

Table 34 Villages to be covered in FPIC Process 36

Table 35 Designated grazing land (Charnoi) and Remaining Government Land 38

Table 36 Impact on Cultural Sites Affiliated to STs 39

Table 37 List of Power Evacuation Infrastructure 40

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of

STs 41

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST

Population 42

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs 43

Table 41 Dates of Government Land Allotment for Neemuch Solar Park 46

Table 42 Dates of Government Land Allotment for Agar Solar Park 46

Table 43 Dates of Government Land Allotment for Shajapur Solar Park 47

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha

Resolution 47

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park 49

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park 50

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park 50

Table 54 Site visit Dates and Site Activities 51

Table 55 Names of Potential Representatives in Ladwan Village 54

Table 56 Names of Potential Representatives in Parsula Village 57

Table 57 Names of Potential Representatives in Badi and Kawai Village 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency 63

Table 62 Roles and Responsibilities of FPIC FA 65

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context 69

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages 71

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page iv

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Figures

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages 24

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages 25

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages 28

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages 29

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages 33

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages 34

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages 35

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments 56

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process 74

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Acronyms and Abbreviations

Name Description

CSO Civil Society Organizations

DDMF Discussion and Decision Making Framework

DPR Detail Project Report

DREO District Renewable Energy Officer

ESIA Environment and Social Impact Assessment

ESS Environment and Social Standards

FA Facilitation Agency

FPIC Free Prior Informed Consent

FPIC-FA FPIC Facilitation Agency

FPICon Free Prior Informed Consultation

GAP Gender Action Plan

GFN Good Faith Negotiation

GN Guidance Note

GoMP Government of Madhya Pradesh

GP Gram Panchayats

HO Head Office

ICP Informed Consultation and Participation

IFC International Finance Corporation

IPDP Indigenous Peoples Development Plan

IPP Indigenous Peoples Plan

Ips Indigenous Peoples

JV Joint Venture

LRP Livelihood Restoration Plan

MC Mediation Committee

MNRE Ministry of New and Renewable Energy

MPLRC Madhya Pradesh Land Revenue Code

MPUVNL Madhya Pradesh Urja Vikas Nigam Limited

MW Mega Watt

NGO Non-Government Organizations

NOC No Objection Certificate

OBC Other Backward Castes

OP Operation Policy

PPP Public Private Partnership

PRA Participatory Rural Appraisal

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Name Description

PS Performance Standard

RAP Resettlement Action Plan

RPO Renewable Purchase Obligation

RUMSL Rewa Ultra Mega Solar Limited

SC Scheduled Caste

SEP Stakeholder Engagement Plan

SHG Self Help Group

SPD Solar Park Developer

SPO Solar Purchase Obligation

ST Scheduled Tribe

TDP Tribal Development Plan

ToR Terms of Reference

WB ESF World Bank Environment and Social Framework

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

1 INTRODUCTION

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Impact Assessment (ESIA) including Resettlement and

Rehabilitation Action Plan (RAP) of three solar parks including internal evacuation infrastructure and

associated transmission lines of aggregate capacity of 1500 MW in the Neemuch Agar and Shajapur

Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work ERM is required to assess the impacts of the Project on the Indigenous

Peoples (IPs) or Scheduled Tribe (ST) and develop an approach and implement the process of Free

Prior Informed Consent (FPIC) The villages in Table 11 were identified to be covered in the FPIC

process during the scoping stage The intention of conducting FPIC process involving ST families in

these identified villages was communicated to the Sarpanch1 and a project information sheet (in

Hindi) was shared around Dec 2019

Table 11 Villages to be covered in FPIC Process

Solar Park Selected ST

villages for FPIC

Number of

Households

Name of ST

Community

Date on which Gram

Panchayat was informed

about FPIC Process

Agar Solar Park Ladwan 12 Bhilala 19th Dec 2019

Shajapur Solar Park Parsula 41 Bhilala 30th Jan 2020

Neemuch Solar Park Badi and Kawai 61 Bhil and Bhilala 5th and 6th Dec 2019

The Covid-19 pandemic brought restrictions for finalizing the project boundary and preparation of

ESIA Reports between Mar 2020 and Jun 2020 ERM initiated the FPIC related works and submitted

a Memo on selection of FPIC villages dated 29th Jun 2020 which reviewed the government land

allotment and triggers for FPIC

The FPIC Approach Paper (current document) is based on the understanding of the socio-political

context within which the affected STIPs population lives and suggestions received from the

prominent ST representatives with whom a preliminary round of discussions was held The Discussion

and Decision Making Framework (see Section 8) is accepted by RUMSL and was planned to be taken

back to the affected ST community for discussion and acceptance in Apr 2021 (see Section 832)

This has been delayed due to second wave of Covid-19 which started in Apr 2021 and decision on

further visits and consultations will be undertaken based on how situation unfolds in the coming

weeks The FPIC Approach paper will be finalized after the Discussion and Decision Making

Framework is discussed with ST Committees representing affected ST communities and agreed by

them

11 Project Background

The Government of India has identified the solar power sector as one of the critical components for

infrastructure development and overall economic growth The Government of Madhya Pradesh

(GoMP) through Ministry of New and Renewable Energy (MNRE) is developing ground mounted grid

connected solar power projects in Madhya Pradesh International Finance Corporation (IFC) is

providing investment advisory services to RUMSL thereby enabling Government of Madhya Pradesh

(GoMP) to develop the project on Public Private Partnership (PPP) mode and to support GoMP in

1 The rural local self-government bodies in India are known as Gram Panchayat which comprises of several wards Each ward

elects a ward member to represent them The Gram Panchayat thus comprises of multiple elected Ward Members The Chair Person of these elected local body is known as Sarpanch The vice chairperson of the Gram Panchayat is known as Upsarpanch or Naibsarpanch All adult electorate of a Gram Panchayat constitute Gram Sabha or General Assembly of the Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

meeting its energy requirements and in the process meet its Renewable Purchase Obligation (RPO)

and Solar Purchase Obligation (SPO)

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) Its primary objective is to develop

and facilitate development of large scale solar power projects in the state of Madhya Pradesh

RUMSL is planning to develop three solar parks (see details in Table 12) and their associated

internal evacuation infrastructure and transmission lines The World Bank had agreed to provide

financial support for the Project

Table 12 Salient Features of the Project

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Capacity and Configuration

3 Units (Units 1 2 3) adding up to 500 MW

2 Units (Units 4 and 5) adding up to 550 MW across Susner (Unit 4) and Agar (Unit 5)

3 Units adding up to 450 MW across Moman Badodiya (Units 6 and 7) and South Shajapur (Unit 8)

Total Land Area as of 24 June 2020

Unit 1 3515 ha Unit 2 34713 ha Unit 3 36701 ha Total 106573 ha

Unit 4 60809 ha Unit 5- 79918 ha Total 140758 ha

Unit 6- 2462 ha Unit 7 4859 ha Unit 8 2551 Total 9872 ha

Government Land (ha) allotted as of 24 Jun 2020

67819 ha

Allotment of additional 28979ha is under process Thus the total government land area is 962949 ha

127338 ha 931 ha allotted and additional 14ha to be allotted

Date of Government Land allotment

Allotment Date

Area in Ha

17-01-2018 23868

30-05-2017 43951

Total 67819

Allotment Date

Area in Ha

28022019 5633

28022019 7053

21062019 1495

20-06-2019 15925

28022019 283

20062019 19714

280202019 1683

21012019 3492

04012018 602

09082018 2669

30112016 5562

02012018 5699

02012018 16116

06012018 17663

09082018 15583

Total 127137

Allotment Date

Area in ha

26-05-2017 914

26-05-2017 3052

26-05-2017 2011

11-12-2017 11261

11-12-2017 1171

11-12-2017 171

11-12-2017 1386

11-12-2017 4015

11-12-2017 4596

11-12-2017 9545

11-12-2017 1763

26-05-2017 16461

28-06-2019 2675

28-06-2019 6134

Total 931

Private Land 1862 ha 1342 ha 9951 ha

Patta land 7572 ha 0 515 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Proposed Commissioning Date

Tender and bid process tasks completed

- Start of registration downloading of the RFP access to Data Room on 26th Jan 2020

- Facilitation of site visit 26 to 28th Feb 2020

- Issue of Draft Project Agreements on 15th Jun 2020

- First pre-bid meeting was held on 30th Jun 2020

- ESIA Reports was issued on 16th Oct 2020

Tender and bid process schedule ahead

- Second pre-bid meeting on 30th Mar 2021

- Proposal due date for 3 sites between 3rd Jun 2021 and 18th Jun 2021

- Financial proposal opening between 14th Jun and 28th Jun 2021

- Reverse Auction Process 17th Jun and 30th Jun 2021

Purchase of Private land between Apr and Jun 2021

Target date for providing SPD land access June 2021

Indicative construction time of 19 months

Target date for commissioning of Solar Park Nov 2022 It is understood that RUMSL will initiate a process of hand over of balance government land to revenue department no longer required for the project

12 Timeline of Various EampS Studies

The allotment letters of the government land were issued at different points of time between 2017 and

2019 The boundary demarcation (tarmeem2) of these allotted government land for the 3 solar parks

was completed in October 2020 RUMSL is planning to initiate private and patta land procurement to

start in Apr 2021 and all sale agreements are signed by Jun 2021

The timeline of ESIA studies of these 3 Solar Parks is provided in Table 13 below

Table 13 The status of ESIA Study Components and Community Engagement

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

ESIA Field

visits

December 2019 December 2019-

January 2020

January ndash February

2020

September 2020

Report Final ESIA

submitted in

October 2020

Final ESIA

submitted in

October 2020

Final ESIA submitted

in October 2020 Draft ESIAs for

Neemuch TL and

Agar- Shajapur

TL submitted in

November 2020

RAP-

LRP

Field

visits

November-

December 2020

August 2020 August 2020 December 2020

Report Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-WB

Draft RAP-LRP is

reviewed by IFC-

2 Tarmeem ground verification process to confirm land ownership and to demarcate any patta land andor private land that

may have been identified within a government khasra This process is done by Revenue Department from time to time in the normal course of action (with or without any project) As an outcome of this process following can be achieved Revisions in the Patwari maps Khasra books Digital database other revenue records preparation of survey reports etc This process is undertaken by Officials from the Revenue Department usually inclusive of the Tehsildar RI Patwari etc

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

WB and ready for

Public Disclosure in

Mar 2021

WB and ready for

Public Disclosure

in Mar 2021

and ready for Public

Disclosure in Mar

2021

WB and ready for

Public Disclosure in

Mar 2021

IPP Field

Visits

Initiation 5-6th Dec 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and Draft IPP 13-16th Aug 2020

HH Survey 7-14th Sep 2020

Initiation 19th December 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 6-7th Aug 2020

HH Survey Not done

Initiation 30th Jan 2020

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 8-12th Aug 2020

HH Survey 13-14th Aug 2020

No IPP to be prepared for Transmission Line

Report Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure in

Mar 2021

Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure

in Mar 2021

Draft IPP is reviewed

by IFC-WB and

ready for Public

Disclosure in Mar

2021

The ERM ESIA team has held several consultation meetings in project affected villages covering a

cross-section of stakeholders in a sequential manner The broad understanding of the socio-economic

and livelihood practices was carried out in Dec 2019 and Jan 2020 as part of collection of baseline

information The detailed study for RAP-LRP and IPP subsequently took place in Aug 2020 The details

of the consultations held for ESIA RAP-LRP are part of those reports and details of field visits and

consultation activities carried out for preparation of this FPIC Approach Paper and Draft IPP is described

in Section 4 below

13 Scope amp key deliverables related to FPIC for MP Solar Project

ERM as a part of the FPIC requirement for the project is expected to support the elaboration and

implementation of a robust FPIC process for the MP Solar Park project to be developed in 2 Phases

Phase I the overall principles and engagement process and criteria for obtaining FPIC should be

agreed on with the affected Indigenous People (IP) communities potentially before bidding

Phase II the focus of the proposed FPIC process will then be on seeking consent from affected

IP communities for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior

to the main construction phase) In phase II it is likely that the PPP concessionaire will also

play a role and as such the Social Expert will continue to advise RUMSL but also monitor the

activities of the concessionaire

The Table 14 below summarises the key deliverables tasks involved and expectations against each

of these tasks in terms as per the scope The current status progress of these tasks and timeline for

future activities is also proposed It should be noted that these timelines may change in keeping with

evolving health and safety situation in context of COVID-19

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

I OBJECTIVE AS PER RFP The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities before bidding ie the submission of proposal for solar parks by concessionaire

Guidance to RUMSL (ONGOING)

Provide guidance to RUMSL on the most appropriate sequencing of steps vis-agrave-vis the FPIC process as per IFC PS 7 requirements

eg agreement and verification of legitimate IP representatives to represent affected communities in FPIC negotiations

agreement with IPs and their representatives on the FPIC engagement process and next steps including disclosure and consultation of draft updated project impact mitigation benefits package documentation

share of responsibilities between RUMSL and PPP concessionaire etc

This will also include advise on broader stakeholder analysis and engagement strategy

to build support for the FPIC approach and implementation of the project and

to participate in agreed outreach to influential local and international stakeholders andor additional sources of adviceinput

ERM has been providing handholding support to the client in terms of meetings and calls where the requirements of IFC PS 7 are discussed and possible implications of project decisions on the FPIC applicability are discussed

The training for RUMSL team on ICP (SEP) PS-7 and FPIC process on 27th Aug 2020

Sharing of Draft FPIC Approach Paper 1st Sep 2020

Discussion on Draft IPP and Formation of Committees for FPIC Process 16th Mar 2021

Submission of Note on FPIC budget FPIC Process

Responsibilities of PPP concessionaire submitted as part of Draft IPPs (Appendix-F)

A meeting with facilitating agency and their ToR was held in 1st Week of Apr 2021

A Joint field trip with RUMSL FPIC Team will be held after Covid-19 Second Wave is over to

- Verify the IP representatives and formation of ST committees

- To agree with ST committee on Draft Discussion and Decision Making Framework

Draft FPIC approach paper

Desk-based Information Compilation and Assessments

Review national applicable law to identify any gaps with IFC PS7 and ways to bridge them

While developing the FPIC approach leverage as much as possible the requirements of applicable law and the consent process usually applied when IP are affected

The FPIC approach should also ensure that affected IP communities are involved

ERM did not get access to documentation of community consultation as part of seeking

NOC3 from Gram Panchayats

Conversation with Sarpanch of villages with ST population revealed that consultation was

A field trip for a joint meeting between RUMSL and ST communities is proposed to be held after Covid-19 Second Wave is over The field trip will include the following

3 The allotment of unused Government land within any revenue village needed a resolution of concerned local government body (Gram Panchayat) under S 234 (4) till Nov 2018 See more details in

Section 21 below The Solar Parks does not require any EIA studied in India

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Identification of affected IP individuals and communities and representatives as well as project impacts mitigation measures and potential benefits related to them (ongoing process during ESIA)

Initial Meeting with Gram Panchayats (GPs) and Informing them on FPIC

Social MappingSite walk-through

Preparation of Draft FPIC Approach Paper which builds on key elements of IFC PS7 FPIC requirements is prepared in consultation with RUMSL IP representatives and other stakeholders and could be acceptable to each party

Internal Discussion and Consensus on FPIC Approach Paper

Sharing of Draft FPIC Approach with IP and Consensus Building

in the identification of impacts and provide input on the development of mitigation and benefit plans

The FPIC approach should be cognizant that impacts on vulnerable groups within the Affected Communities of IP if any should be adequately addressed during negotiation and in relevant documentation

It should be based on the engagement with local IP community decision-making authoritiesrepresentatives (and taking into account gender and other IFC PS 7 related prerogatives) to discuss the FPIC process with input from support organization

The draft approach paper should reflect a mutually acceptable engagement and negotiation framework for the FPIC process based on the principles of Good Faith Negotiations It should include a clear agreed indication on what constitutes consent in the project context

Ensure through revision and feedback that all other components under this assignment (ifwhen available) are aligned with the defined FPIC approach ndash including the Environmental and Social Impact Assessment (ESIA) Resettlement Action Plan (RAP) Stakeholder Engagement Plan (SEP) Gender Action Plan (GAP) and develop the Indigenous People Development Plan (IPDP)

restricted to Gram Panchayat members Though they initially reluctant to sign on the NOC after persuasion of District Collector they finally signed

PRA exercises which includes participatory mapping of social relationship livelihood and natural resources was held between 6th to 15th Aug 2020

The social mapping during 6-15th Aug collected information on existence of traditional decision making process and gender representation aspect

The proposed FPIC process as part of this FPIC approach paper (Refer Chapter-8) reflect GFN principles

The FPIC approach paper was discussed with RUMSL prior to sharing it with WB-IFC

The ESIA disclosure was done as part of the PRA exercises for IPP in Aug 2020The RAP survey was done in these villages around the same time to address their concerns over loss of privatepatta land

Consultations during RAP and Draft IPP preparation included PRA process where STs participated to identify impacts and expressed their expectation on project benefits

The feedbacks and key issues in ESIA (including GAP SEP) and RAP is synchronised in Draft IPP

- Introduce FPIC Facilitation Agency

- Facilitate formation of ST representative committees

- Inform them their rights in the context of FPIC process

- Consult and build mutual agreement on the lsquoengagement and negotiation frameworkrsquo (as in Chapter-8 of this report) which will include a clear agreed indication on what constitutes consent

- The STs Representatives will be asked about time they require for internal discussion and a tentative date for the first discussion on benefits proposed in IPP will be fixed

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Independent FPIC Facilitator Agency

Assess the need for Independent FPIC Facilitator Agency

Screening of IPOsCSOs for Independent FPIC Facilitator Agency possible facilitator options to determine how they can play a role in the process - who what how

Provide a list of names of key advocacy groupsNGOsCSOs considered SWOT (or similar) analysis of each organization considered identification of preferred organization and

Terms of Referencersquo for the role of the same in the FPIC process and its relevance for the FPIC process in that area and for that specific group

To be discussed in next call FA brings credibility of an independent agency (other than RUMSL and ESIA consultant) Considering the project context their position can be reviewed

The review and assessing the need for a FA is discussed in section 6 of this report The Scope of work for the FA is provided in Appendix-F

Preparation of IPDPIPPTDP

Note ESIA RAP SEP and other management plans should be prepared by this stage Infact the FPIC process report should also draw input from the engagement undertaken as part of the ESIA process

Indigenous People Plan (or

Community Development Plan

Stakeholder Engagement Plan) or

similar management documents

aimed at ensuring ongoing and

adequate engagement with IPs

The collection of baseline

information through PRA

exercises and a sample

household survey was done

in Aug 2019 The IPP draws

inputs from consultations for

ESIA RAP-LRP and

benefits are also

synchronised

Three Draft IPPs one for

each Solar Parks with a

package of benefits for

affected STs is ready and

disclosed in May 2021

These will be shared with

affected STs as part of the

FPIC negotiation process

subsequently for their

considerations and

acceptance

Preparation of Draft FPIC Process Report

FPIC Process Report will include (but not be limited to)

identification of IPs IP representatives and decision-making authorities

assessment of capacity of IPs IP representatives to undertake good faith negotiations

summary of any capacity building undertaken

agreed engagement and negotiation framework (including the process undertaken to agree upon the framework)

This document will be further updated and finalised once the whole process is completed

Note The FPIC process should incorporate key considerations contained in IFC PS 7 and GN 7 eg the need for free prior and informed engagement inclusion of differentiated measures to allow the effective participation of those identified as particularly disadvantaged or vulnerable including analysis of the legitimacy and representativeness of IP leaders and the role responsibilities and participation of

To be initiated once FPIC Process starts

The process of identification of IPs representatives and decision making authorities (ST RUMSL and Mediation Committees) which will take place once Covid-19 second wave is over and will be documented as Draft FPIC Process Report This will be a living document which will be updated after every round of field activities and negotiation meetings

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

detailed summary of consultations meetings engagement undertaken as part of the FPIC process

expert opinion on the process and outcomes

share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to complete the FPIC process

external stakeholders with vested interests in the outcome

Input to the bidding document

For the bidders in terms of FPIC amp IPDP requirements

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc

The Draft IPP for each Solar Park has Annexure-F providing roles and responsibilities and scope of work for the Solar Park Developer (SPD)

All 3 Draft IPPs with Annexure-F are ready for disclosure in May 2021

II OBJECTIVE AS PER RFP Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Preparation of communication Material

Communication material to be based on IPDP ESIA and RAP This should include culturally appropriate document on impacts and mitigation to be used during FPIC engagement and negotiation

All preparation including translation of FPIC-related materials including communication material summaries of relevant EampS documentation local benefits plans etc (printing arrangement to be agreed with RUMSL)

A Project Profile Fact Sheet was shared in Dec 2019

A summary of ESIA was shared in Aug 2020

The communication material based on Draft IPP will be prepared and used during FPIC process The Draft communication material will be shared with IFC-WB for their approval prior to its use in field

A parallel information disclosure process of RAP-LRP would also take place

Culturally Appropriate Information Disclosure Campaign

Share accurate and up to date information on project impacts proposed mitigation measures and proposed benefit streams in a culturally appropriate manner (ie in local language (as appropriate following discussion with IP representatives) in written and oral format)

The information disclosure should especially ensure that following are achieved

provide sufficient time for capacity building and

support to affected communities to understand these matters and their rights

The affected ST population speaks Malwi dialect The FPIC FA will have facilitators who would be familiar with this local dialect used

The FPIC FA will carry out the capacity building activities

The FPIC FA will spend 2 days at each Solar Park to do the capacity building workshops with local ST Representatives who would participate in FPIC discussion with RUMSL

The FPIC FA will do this once Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Consent from the Indigenous communities

Meetings for Negotiation and Decision Making

Participate in and offer expert support to key FPIC-related meetings involving affected IP representatives RUMSL and other relevant authorities etc during the FPIC process

Support RUMSL in the organization of these meetings and in recording their outcome including the collection of comments and concerns of those attending

Measuring Consent and Signing of FPIC Agreement

Note This include also support the RUMSL in designing undertaking and collecting evidence of Good Faith Negotiations (GFN) resulting in Consent which involves (i) willingness to engage in a process and availability to meet at reasonable times and frequency (ii) provision of information necessary for informed negotiation (iii) exploration of key issues of importance (iv) use of mutually acceptable procedures for negotiation (v) willingness to change initial position and modify offers where possible and (vi) provision of sufficient time for decision making

Present updated materials and seek consent from affected IP communities and their leaders

Document the consent process in a mutually agreed written format including an agreed mechanism for monitoring of key commitments in future and grievance redress as well as identifying share of responsibilities between the RUMSL SPDs and other relevant parties

Evidence of representativeness and involvement of Indigenous Peoples representative bodies and organizations (eg councils of elders or village councils)

Evidence of agreement between the parties as the outcome of GFN (eg FPIC agreement MOU a letter of intent and a joint statement of principles agreed mitigation plans collective land agreements etc)

Other documents may include Client records photographs media reports personal letters or third-party accounts etc regarding eventsdemonstrations other activities for the project undertaken by project-affected IP communities with high relative levels of participation by (i) the affected community as a whole or (ii) by sub-groups particularly affected by the project

ERM will work alongside FPIC FA and RUMSL to help the FPIC process taking right direction

Final FPIC Process Document

Throughout the FPIC process (Phase I and Phase II) ERM should help documenting the FPIC process and provide an opinion and direction about the process and outcome vis-agrave-vis IFC PS7

The whole set of activity in Phase II need to be updated as part of the Final FPIC Process Document

The tentative timeline for the FPIC Process was scheduled between Jun 2021 and Sep 2021 The timeline will be revised after the ongoing Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

The Draft FPIC Process Report will be submitted within 2 weeks of completion of FPIC process

Advise RUMSL but also monitor the activities of the concessionaire in phase II

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

14 Structure of the Report

This report is organized into following sections

Section 1 Introduction (this section)

Section 2 Applicable law and gaps assessment against IFC PS7 requirements

Section 3 Affected IPs population project impacts and mitigation

Section 4 Desk-based information compilation

Section 5 Engagement leading up to FPIC Approach Paper

Section 6 Independent facilitator agency

Section 7 Key elements in FPIC Process

Section 8 Draft Discussion and Decision Making Framework

15 Limitations

This Report is prepared after multiple field visits and interactions with affected ST community elected

leaders of Gram Panchayat and other key informants The assessments are based on information

received from RUMSL and other secondary information at some places The public health concerns

due to Covid-19 pandemic has prevented large community gatherings and communityrsquos willingness to

allow people from outside to spend much time with them

ERM team communicated with community members over telephone to seek clarifications and know

their views However it was not always possible to keep the discussion focused and definitive as it

could have been in case of a face to face discussion ERM has made efforts to build trust among

affected STs by sharing relevant information and answering their queries with clarity As FPIC process

is an itinerant process this relationship is expected to further evolve in future

The Draft Discussion and Decision Making Framework described in Chapter 83 though has been

accepted by RUMSL and reviewed by IFC and WB it would be discussed with committees formed by

affected STs and their feedbacks will be incorporated The FPIC process described in Chapter-8

therefore would undergo necessary changes

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan could not

be ascertained as nomadic tribes did not visit these sites when ERM conducted field visits The general

migration pattern of pastoral nomads is expected to have faced constraints of Covid-19 restrictions If

pastoral nomads or their representatives will be identified during the FPIC process an appropriate

decision on their participation will be taken

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

This section provides an understanding of the applicable national regulations that pertain to the process

of land procurement and the rights of the Indigenous Peoples and a comparison between the provisions

of the same against the IFC PS 7 requirements

It should be noted that the Environmental and Social Impact Assessment (ESIA) Reports4 and the

Resettlement Action Plans (RAP) provide a detailed understanding of applicable regulations This

section is focused on the government land procurement process and its impacts on the collective rights

of the Indigenous Peoples identified in the project

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in 2018

The allotment of government land for these three solar parks is done under provisions of the MP Land

Revenue Code 1959 The Chapter-XVIII of this Code deals with rights in abadi5 (habitation area) and

un-occupied land and its produce

The Madhya Pradesh Land Revenue Code (MPLRC) was enacted in 1959 and has undergone several

amendments since then It was recently amended in 2018 and 2019 These recent amendments along

with other changes changed the procedure for allotment of unoccupied government land Some of the

land allotment letters were prior to this amendment and others after this amendment (see details in

Section 42) Table 21 below provides a comparison of key provisions in pre and post 2018

amendment

Table 21 Key Provisions of Land Revenue Code

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

Collective (Nistar) Rights on Unoccupied Government Land

Section 114- Land recordsmdash In addition to the map and

Bhoo Adhikar Pustikas there shall be prepared for each

village a khasra or field book and such other land records as

may be prescribed

Section 233- Record of unoccupied landmdash A record of

unoccupied land shall in accordance with rules made in this

behalf be prepared and maintained for every village

showing separatelymdash (a) unoccupied land set apart for

exercise of nistar rights under Section 237

Section 114 (e) (i) (ii) requires

the details of all unoccupied land

be maintained as described in

Section 233 One Such

document is the Nistar Patrak

under Section 234 Section 233 A record of all unoccupied land shall be prepared for every village and urban area in accordance with rules made in this behalf

Preparation of

Nistar Patrak

and change in

entries in

Nistar Patrak

Section 234 (1)- The Sub-Divisional Officer shall in

accordance with the provisions of this Code and the rules

made thereunder prepare a Nistar Patrak for every village

embodying a scheme of management of all unoccupied land

in the village and all matters incidental thereto and more

particularly matters specified in section 235

Section 234- same as 1959 Sub

section (2) (3) (4) have been

removed

4 Three separate ESIA Reports for Solar Parks one for each Solar Park one for the Neemuch Transmission Lines (Units 12

and 3) and another for the Transmission Lines for Agar and Shajapur Solar Parks (for Units 4 to 8) have been prepared 5 According to the MP Land Revenue Code 1959 abadi means the area reserved from time to time in a village for the residence

of the inhabitants thereof or for purposes ancillary thereto and any other cognate variation of this expression such as village site or gaonsthan shall also be construed accordingly No change was made to this definition in the subsequent amendments to the code

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(2) A draft of the Nistar Patrak shall be published in the

village and after ascertaining the wishes of the Gram Sabha

it shall be finalised by Sub-Divisional Officer

(3) A copy of the Nistar Patrak so finalised shall be kept in

the office of the Gram Panchayat

(4) On a resolution passed by the Gram Sabha by a majority

of not less than two-thirds of the members present and

voting the Sub-Divisional Officer with the prior sanction of

the Collector and also after making any such inquiry as he

deems fit inter se change the entries in the Nistar Patrak

(b) Record additional unoccupied land under any entry in the

Nistar patrak for fulfilment of further Nistar rights of villagers

Matters to be provided for in Nistar Patrak

Section 235- The matter which shall be provided for in the

Nistar Patrak shall be as follows namely

(a) terms and conditions on which grazing of cattle in the

village will be permitted

(b) the terms and conditions on which and the extent to

which any resident may obtain-

(i) wood timber fuel or any other forest produce

(ii) mooram6 kankar7 sand earth clay stones or any other

minor mineral

(c) instructions regulating generally the grazing of cattle and

the removal of the articles mentioned in paragraph (b)

(d) any other matter required to be recorded in the Nistar

Patrak by or under this Code

Section 235- same as previous provision of Land Revenue Code

Provision in

Nistar Patrak

for certain

matters

Section 236 - In preparing the Nistar Patrak as provided in

Section 235 the Collector shall as far as possible make

provision for-

(a) free grazing of the cattle used for agriculture

(b) removal free of charge by the residents of the village for

their bona fide domestic consumption of-

(i) forest produce

(ii) minor minerals

(c) the concessions to be granted to the village craftsmen for

the removal of the articles specified in clause (b) for the

purpose of their craft

Section 236 - same as previous

provision of Land Revenue Code

Collector to

set apart land

for exercise of

Nistar rights

Section 237 (1) Subject to the rules made under this Code

the Collector may set apart unoccupied land for the following

purposes namely-

(a) for timber or fuel reserve

(b) for pasture grass bir or fodder reserve

(c) for burial ground and cremation ground

(d) for gaothan

(e) for encamping ground

Section 237 (1) remains same

6 Soil used particularly for road paving 7 In India an impure concretionary carbonate of lime usually occurring in nodules in alluvial deposits and especially in the

older of these formations

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(f) for threshing floor

(g) for bazar

(h) for skinning ground

(i) for manure pits

(j) for public purposes such as schools play grounds parks

road lanes drains and the like and

(k) for any other purposes which may be prescribed for the

exercise of right of Nistar

237 (2) Lands set apart specially for any purpose mentioned

in sub-section (1) shall not otherwise be diverted without the

sanction of the Collector

Section 237 (3) Subject to the rules made under this Code

the Collector after securing the land mentioned in clause (b)

of subsection (1) to minimum two percent of the total

agriculture land of that village may divert such unoccupied

land as mentioned in sub-section (1) into abadi or for

construction of roads state highways national highways

canals tanks hospitals schools colleges Goshalas and

any other public utility projects as may be determined by the

State Government

Provided that the land set apart for the purposes mentioned

in subsection (1) shall not be diverted and allotted to any

person for agriculture purpose

Section 237 (4) When it becomes indispensable to divert the

land set apart for the purposes mentioned in sub-section (1)

for such development and infrastructural projects which are

owned or approved by the State Government but not

covered under sub-section (3) the Collector after satisfying

himself on alternatives available and also on obtaining land

of equivalent area for fulfilling the same nistar rights from the

concerned project may divert the land for such purposes by

passing a reasoned order to this effect Thus in case Nistar

land needs to be diverted for the project the project needs to

make available an equivalent area for the replacement of the

same nistar rights

The section 237 (2) is removed

Section 237 (3) remained same

Section 237 (4) remains same

Rights in Fruit Bearing Trees and other trees in Un-Occupied Government Land

Section 239 (1) Where before coming into force of this

Code any fruit bearing tree was planted by any person in the

unoccupied land of any village and is so recorded then

notwithstanding that such land vests in the State

Government such person and his successor in interest

shall from generation to generation be entitled to possession

and usufruct of such trees without payment of any royalty or

other charge whatsoever therefore

Section 239 (6) the State Government may make rules for

carrying out the purposes of this section

Section 239 (1) same as 1959

Section 239 (6) The unoccupied

land on which any tree planting

permit or tree patta has been

given prior to the commencement

of MP Land Revenue Code

(Amendment) Act 2018 may be

used for any public purpose by

the order of Collector If any

interest of the holder of such tree

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

planting permit or tree patta is

adversely affected due to such

use the holder shall be entitled

for such compensation which

shall be calculated in such

manner as may be prescribedrdquo

Exclusive jurisdiction of revenue authorities

Section 257 - Except as otherwise provided in this Code or

in any other enactment for the time being in force no Civil

Court shall entertain any suit instituted or application made

to obtain a decision or order on any matter which the State

Government the Board or any Revenue Officer is by this

Code empowered to determine decide or dispose of and in

particular and without prejudice to the generality of this

provision no Civil Court shall exercise jurisdiction over any

of the following matters - (w) any claim to modify any entry

in the Nistar Patrak

Section 258 (1) The State Government may make rules

generally for the purpose of carrying into effect the

provisions of this Code

(2) In particulars and without prejudice to the generality of

the foregoing powers such rules may provide for (lviii) the manner in which the wishes of the villagers shall be ascertained under Section 234 (2)

Section 257 - same as 1959

Section 258 (1) and (2) (lviii)

same as 1959 it should be noted that the Section 234 (2) was removed in 2018 Amendment

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers Diverting the un-occupied

government land8 categorised as grazing land that is recorded in Nistar Patrak (there may be other

grazing land available) and such other Nistar rights9 including the right in fruit bearing trees and other

trees in unoccupied government land after the amendment in 2018 does not require any consent

process with concerned village community

Hence it is expected that the government land allotted for the project prior to the 2018 Amendment of

MP Land Revenue Code is expected to have involved a resolution of concerned Gram Sabha As per

Sec-6 of the Madhya Pradesh Panchayat Raj Act 1993 the quorum of every meeting of Gram Sabha

shall not be less than one-tenth of the total number of members of the Gram Sabha or five hundred

members of the Gram Sabha whichever is less The Act does not specify presence of women in

Gram Sabha to be mandatory

Other Indian laws which has provisions for consent process are not applicable to this project and an

overview of them is provided in Box 31 below

8 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands 9 Nistar rights refer to collective rights of a revenue village to use specified government land for the purposes mentioned in

S235 of MP Land Revenue Code This includes right to free grazing cattle collecting minor minerals construction materials burialcremation grounds for religious and cultural events etc

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Box 21 Other Indian Laws with provisions for consent process and their applicability

22 International Social Safeguard Policies Applicable to the Project

221 IFC Performance Standards

The part of PS1 dealing with Management Program envisages an Indigenous Peoples Plan (IPP) as a

thematic plan and should be developed by qualified experts with substantive experience For projects

with adverse impacts to Indigenous Peoples the client is required to engage them in a process of

Informed Consultation and Participation (ICP) and in certain circumstances the client is required to

obtain their Free Prior and Informed Consent (FPIC)

The FPIC from the affected communities of Indigenous Peoples is required when the following special

circumstances (in paragraphs 13ndash17 of Performance Standard 7) are present

Impacts on lands and natural resources subject to traditional ownership or under customary use

Relocation of Indigenous Peoples from lands and natural resources subject to traditional

ownership or under customary use

Significant impacts on critical cultural heritage that is essential to the identity andor cultural

ceremonial or spiritual aspects of IPs lives

Where a project proposes to use the cultural heritage including knowledge innovations or

practices of Indigenous Peoples for commercial purposes

IFC PS7 requires to avoid adverse impacts on Indigenous People and if adverse impacts are

unavoidable the project should prepare an Indigenous Peoples Plan outlining the actions to minimize

andor compensate for adverse impacts in a culturally appropriate manner Some of the key

provisions with respect to IPP are

A free-standing IPP may be prepared or it may be a component of a broader community

development plan

The IPP should detail actions to minimize andor compensate for adverse social and economic

impacts and identify opportunities and actions to enhance positive impacts of the project on the

Indigenous Peoples

Where appropriate the IPP may also include measures to promote conservation and sustainable

management of the natural resources on which the Indigenous Peoples depend

The IPP should include a clear statement of roles and responsibilities funding and resource

inputs a time-bound schedule of activities and a budget

The IPP shall be regular monitored and should be flexible to allow for it to be adapted as needed

if circumstances change

222 World Bank Operation Manual OP 410

The World Bankrsquos Operational Policy on Indigenous Peoples (OP 410) aims at ensuring that the

development process fosters full respect for the dignity human rights and cultures of IPs thereby

In Indian context the constitutionally recognized Scheduled Tribes are usually considered as Indigenous Peoples

while determining their entitlements under international social safeguards systems

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006( FRA) is not

relevant as no forestland was diverted The Provisions of the Panchayat (Extension to the Scheduled Areas) Act

1996 (PESA) acts is not applicable for the project as the project site is not in a schedule V area There are no

specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement

consultation and consent

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

contributing to the Bankrsquos mission of poverty reduction and sustainable development To achieve this

objective Bank-assisted projects which affect IPs provide them a voice in design and implementation

avoid adverse impacts where feasible or minimize and mitigate them and ensure that benefits

intended for them are culturally appropriate

The Bank recognizes that IPs are commonly among the poorest and most vulnerable segments of

society and in many countries they have not fully benefited from the development process It also

recognizes that the identities cultures lands and resources of indigenous peoples are uniquely

intertwined and especially vulnerable to changes caused by development programs Because of this

issues related to indigenous peoples and development are complex and require special measures to

ensure that IPs are not disadvantaged and that they are included in and benefit from these programs

as appropriate

Under the OP 410 the Bank requires the borrower to undertake a social assessment to evaluate

projectrsquos potential positive and adverse effects on the IPs and to examine project alternatives A

project that affects Indigenous Peoples the borrower engages affected IPs in a free prior and

informed consultation (FPICon) process

Note The World Bank adopted Environment and Social Framework (ESF) which comprises of ten Environment

and Social Standards (ESS) The ESS-7 deals with Indigenous PeoplesSub-Saharan African Historically

Underserved Traditional Local Communities which requires FPIC to be obtained in special circumstances where

customary rights on natural resources used by IPs is impacted The WB has financed the renewable projects to

MNRE prior to adoption of the new ESF in Dec 2019 The Shajapur Solar Park is under the old WB safeguards

and therefore the new ESF is not applicable

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard Policies of IFC and WB

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers The diversion of the un-

occupied government land10 categorised as grazing land that is recorded in Nistar Patrak (there may

be other grazing land available) and such other Nistar rights including the right in fruit bearing trees

and other trees in unoccupied government land after the amendment in 2018 does not require any

consent process with concerned village community A comparison of key provisions of PS-7 vis-agrave-vis

legal provisions in Indian context is provided in Table 22

Table 22 Comparison of Provisions of Consent Process in Applicable Indian

Regulations vis-agrave-vis Provisions in IFC PS-7

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Assessment of Impact on Indigenous People

The client will identify through a process of Social and Environmental Assessment all communities of Indigenous Peoples who may be affected by the project within the projects area of influence The client will assess the nature and degree of the expected social cultural (including cultural heritage) and environmental impacts (direct and indirect) on them and avoid adverse impacts whenever feasible

There is no requirements for environment impact assessment (EIA) for Solar Park Projects There are no specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement consultation and consent

10 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands Such usages will be confirmed only through the Tarneem process for each site

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Preparation of IPP

The clients actions will be developed with the informed consultation and participation of affected Indigenous Peoples and contained in a time-bound plan such as an Indigenous People Plan or a broader community development plan with separate components for Indigenous Peoples

There is no legal requirement for an Indigenous Peoplersquos development plan

Consultation and Consent from affected IPs

In projects with adverse impacts on affected communities of Indigenous Peoples the consultation process will ensure their free prior and informed consultation and process of community engagement will be culturally appropriate and commensurate with the risks and potential impacts to the Indigenous Peoples

The acquisition of the private land owned by ST will be done through MP Consent Policy 2014 and the RAP addresses the impact on individual ST land ownersoccupiers The impact on customary rights (such as Nistar rights) over collectively used unoccupied government land is dealt under the provisions of MP Land Revenue Code 1959 There is no consultationconsent process for diversion of grazingNistar lands under MP Land Revenue Code 1959 (As amended up to 2019) The consent process in other Indian laws such as FRA or PESA which has consent process is not relevant to the project

Land Revenue Code had a requirement for Gram Sabha consent to be taken prior to diversion of

Nistar rights as part of the 2018 Amendment the same provision was removed As most of the

government land for Shajapur Solar Park was allotted in 2017 Table 23 below provides a

comparison of provisions of the consent process under MP Land Revenue Code 1959 (prior to Nov

2018 amendment) vis-agrave-vis requirements under IFC PS-7

The key elements of FPIC process as per IFC PS (including Guidance Notes- GN) identified for

comparison includes

1 Requirements of information disclosure (as in PS-129) 2 Informed consultation and participation (as in PS-130-31 and PS-710) 3 Good Faith Negotiation (as in GN-725) and 4 Consent and documentation (as in PS-712)

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Information Disclosure

Relevant project information must be disclosed to Affected

Communities and other stakeholders to enable them to

understand the risks impacts and opportunities of the project

The Project will provide Affected Communities with access to

relevant information on

the purpose nature duration and scale of the project

risks and potential impacts and relevant mitigation measures

the envisaged stakeholder engagement process and

the grievance mechanism

Information disclosed must be relevant transparent objective

meaningful and easily accessible and in a culturally appropriate

local language(s) and format and is understandable to Affected

Communities

Under MP Revenue Code 1959 and MP

Panchayat Raj Act 1993 the information

disclosure to affected communities (including

Schedule Tribes) is limited to the intended

purpose of the allotment of unoccupied

government land

The disclosed information and proceedings are

recorded using the language of the State

The information disclosure to affected communities

prior to the meeting does not disclose all relevant

information particularly potential risks The

information disclosed is not easily accessible to STs

and other vulnerable communities

The process does not involve any grievance

mechanism

Informed consultation and participation

Where a Project has potentially significant adverse impacts on

affected communities an ldquoinformed consultation and

participationrdquo (ICP) process should take place ICP is an

organised and iterative consultation that involves a more in-

depth exchange of views and information leading to the Project

incorporating the views of those affected into project decision-

making on matters that affect them directly

The consultation process should capture both menrsquos and

womenrsquos views and their different concerns and priorities The

process should be documented in particular the measures taken

Section 234 of MP Revenue Code 1959 (Prior to

Nov 2018 Amendment) required the draft Nistar

Patrak of every village and any changes in therein

to be published by Sub-Divisional Officer with

prior sanction of the District Collector only after

ascertaining wishes of the Gram Sabha

(expressed through a resolution passed in Gram

Sabha held for this purpose)

As per Section 6 of the MP Panchayat Raj Act

1993 the Gram Sabha can be held with a quorum

of one-tenth of the total member of Gram Sabha

The MP Revenue Code does not require any

iterative consultation that involves in-depth

exchange of views

The participation of women and other vulnerable

sections is not mandatory

The quorum of the meeting is only ten percent of the

total members of the Gram Sabha The notice for

holding a special Gram Sabha is only 7 days and

there is limited information shared in terms of the

agenda of the meeting Hence a resolution passed

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

to avoid or minimise risks to and adverse impacts on the

Affected Communities and should inform those affected about

how their concerns have been considered

In addition the process should Involve Indigenous Peoplesrsquo representative bodies and

organisations as well as members of the Affected Communities of IPs and

Provide sufficient time for IPs decision-making processes

or five hundred members whichever is less

There is no specific requirement on presence of

women to fulfil quorum requirements

A special meeting of the Gram Sabha is held

within seven days of receiving the requisition

by a Gram Sabha with a bare minimum presence

does not reflect majority decision

The process does not require representative bodies

of IPs to represent their interests

Good Faith Negotiation

FPIC will be established through good faith negotiation between

the Project and the Affected Communities of IPs Good faith

negotiation generally involves (i) Willingness to engage in a process and availability

to meet at reasonable times and frequency (ii) Provision of information necessary for informed

negotiation (iii) Exploration of key issues of importance (iv) Mutually acceptable procedures for the negotiation (v) Willingness to change initial position and modify

offers where possible and (vi) Provision for sufficient time for decision making

The MP Revenue Code require neither iterative

prior consultation nor exchange of views with

administration

The administrative process for allotment of

unoccupied government land does not involve a

negotiation process through which their feedback

and concerns are incorporated or addressed

Consent

In certain circumstances the client is required to obtain the Free

Prior and Informed Consent (FPIC) of affected IPs FPIC does

not necessarily require unanimity and may be achieved even

when individuals or groups within the community explicitly

disagree The measurement of consent is expected to be

included in the lsquomutually accepted processrsquo for FPIC decision

making

Consent

Section 234 (4) required the Gram Sabha to pass

a resolution with support of a majority not less than

two-thirds of the members present and voting As

per Section 6 of the MP Panchayat Raj Act 1993

the Gram Sabha can be held with a quorum of one-

tenth of the total member of Gram Sabha or five

hundred members whichever is less There is no

specific requirement on presence of women to fulfil

quorum requirements

Consent

The FPIC process in IFC PS-1amp7 recognizes that

consent is not necessarily a unanimous decision

yet there has to be a mutually agreed threshold of

consent in an FPIC process that can vary from

project to project The threshold defined in MP

Panchayat Raj Act 1993 is one-tenth of the total

members of Gram Sabha passing a resolution with

support by two third majority present and voting

Thus the consent threshold for a resolution is 66

of the total members of Gram Sabha

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Documentation

The client will document

The mutually accepted process (FPIC Decision Process Framework Document) between the client and Affected Communities of Indigenous Peoples and

Evidence of agreement between the parties as the outcome of the negotiations

Documentation

The documentation is limited to the entries in Gram

Sabha minutes book The entire set of

documentation is kept by Administration and not

shared with Gram Panchayat

Considering this low threshold as per legal

requirements the FPIC process requires a mutually

accepted threshold for decision making

Documentation

The documentation of the process carried out during

the Gram Sabha meetings leading to the resolution

though is written down in the Gram Sabha minutes

book however there is no guideline on what should

be covered Therefore a mutual agreement on

documentation requirement is necessary

As described in GN62ndash65 where government processes involve project-level decision and actions the client should review these processes in relation to the requirements of the Performance Standard and address identified gaps where feasible

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

The FPIC was triggered at the scoping stage on account of impact on grazing land and other natural

resources within the allotted government land on which STs have claims of customary use which is also

recognized under MP Land Revenue Code as Nistar rights The statement of different categories (which

are part of the Nistar rights of village community) of government land to be used for the proposed Solar

Parks from different villages and percentage of ST population in these villages is provided below

31 Affected Villages Government land used11 by ST Population

311 Neemuch Solar Park (Unit 1-3)

The Neemuch Solar Park is comprised of 3 units and the land is acquiredpurchased from 3 villages

The land category (classification in revenue records as per their currentintended use) is provided in

Table 31 below

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected Villages

Village Name

Govt Land Category in Hindi

Govt Land Category in English Sum of Area (Ha)

ST Population in of Total Village Population

Unit -1

Bardavada Chargah Grazing land 2271 55

Charnoi KamdalKK (Kabil Kast)

Grazing land 4013

DathaKamdal Land with stone outcrops and shallow soil

1655

Gair mumkinCharnoi Uncultivable waste land grazing land

492

Kabil Kast Cultivable 2

Kamdal Land with stone outcrops 169

KamdalDathaDahar Grazing land 4641

KamdalDathaKaKa Grazing land 4279

PK 052

NA 2053

Sub-Total (Bardawada) 25774

Kawai Datha Land with stone outcrops and shallow soil

8962 1992

NA 425

Sub-Total (Kawai) 9388

Total Unit 1 351615

Unit -2

Badi Datha 052 2292

Kabil Kast 11568

NA 5835

Sub-Total (Badi) 17455

Kawai NA 17846 1992

Sub-Total (Kawai) 17846

Total Unit 2 35301

Unit -3

Badi Charnoi (grazing) Grazing land 355 2292

Datha 3805

Gairmumkin Charagah

(grazing)

Uncultivable waste land

grazing land

4184

11 The MP Land Revenue Code recognizes the right to use for grazing collection of timber fire-wood earth morums and other

products (see Section 235 of MP Land Revenue Code)

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KaKa (Kabil Kast) Culturable wasteland 5

Kamdal 11179

NA 13727

Badi total 36945

Total Unit 3 3694557

Grand Total (Unit-1 2 and 3) 107408

Note land category for the units is as per the Allotment Letters NA= Not Available

The screening of the Census 2011 data shows that there is presence of ST population in all three

villages In Badi and Bardawada villages the land categories such as Charnoi Charagah are clearly

recorded as grazing lands The map below shows the location of village settlements and their area

designated as Grazing Land

The ST families in Badi and Kawai live in several small cluster of satellite settlements The Bardawada

had only 22 ST population with 4-5 families Bardawada is part of Dhardi Gram Panchayat and the ST

households live farther from the Solar Park boundary Their households are scattered and dependency

on the allotted government land for Bardawada village could not be established In terms of

concentration of ST population Badi and Kawai are considered as major ST settlements

Thus ~100 ST households in Badi and Kawai have a claim on customary use of ~18938 ha of

designated grazing land

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Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages

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Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

312 Agar Solar Park (Unit 4 amp 5)

The Table 32 provides a break-up of the designated land categories of government land as per revenue

records in Agar Solar Park

Table 32 Agar Solar Park- Government Land- Land Use Category

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Agar Solar Park (unit 4)

Bijnakhedi Germumkin Uncultivable waste land 5598 0

Sub-Total (Bijnakhedi) 5598

Dudhpura Agriculture Agriculture 2243 0

Bardi NA 6631

Gothan Livestock rearing land 2

Khadar The floodplains formed by

yonger alluvium

018

Tree Plantation NA 1495

NA NA 5082

Sub Total (Dudhpura) 15669

Karwa Khedi Chragha Grazing land 251 0

K K NA 475

Khachar Grazing land 068

Pahad Hilly terrain 12392

NA 216

Sub Total (Karwa Khedi) 15346

Keasi Dehariya Gochar Grazing land 283 0

Sub Total (Keasi Dehariya) 283

Ladwan Bardi 7963 579

Charnoi Grazing land 947

Gochar Grazing land 2749

Kavil Kast 609

Khachar Grazing land 238

Pahad Hilly terrain 3062

Waterbody Water body 094

NA 475

Sub Total (Ladwan) 16137

Madhopur Germumkin Uncultivable waste land 1558 0

Sub Total (Madhopur) 1558

Pipalia Kumar Bardi 3492 0

Agriculture land Agriculture 506

Sub Total (Pipalia Kumar) 3998

Total Unit 4 611381

Susner Solar Park (Unit 5)

Palda Germumkin Uncultivable waste land 5689 036

NA 6928

Sub Total (Palda) 12617

Naharkheda Germumkin KaKa Uncultivable waste land 4125 0

Germumkin Uncultivable waste land 1868

NA NA 8908

Sub Total (Naharkheda) 14901

Umariya Charnoi Grazing land 3660 0

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Charokhar Grazing land 416

Chragha Grazing land 9114

Germumkin Uncultivable waste land 147

Kadim NA 011

Shaskiye Government land 218

Sheda NA 01

NA NA 20907

Sub Total (Umariya) 35806

Pipaliya Nankar NA NA 1822805 0

Total Unit 5 8161745

Note land category for the unit 4 is as per the kml file provided by RUMSL on 30012020 as the allotment letters did not carry

the land use details

Ladwan village has 579 of ST population (~12 households) who have claim on customary use of

3934 ha of designated grazing land Palda was found to have only 1 ST family Moreover no Charnoi

Chargah Gochar land is acquired from Palda Hence ST families in Ladwan were selected to be in

focus for FPIC process

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Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages

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Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

313 Shajapur Solar Park (Unit 6-8)

The Table 33 provides a break-up of the land categories of government land as per revenue records

in Shajapur Solar Park In Shajapur Solar Park (Unit 6-8) five villages have ST population They are

Jawadi (034 STs) Parsula (1768 STs) Dehripal (018 STs) Fawaka (238 STs) and

Chouma (072 STs) Of these Dehripal Fawaka and Surajpur do not have any Charnoi Chargah

Gochar land impacted

Table 33 Shajapur Solar Park- Government Land- Land Use Category

Village Name Govt Land

Category in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Moman Badodiya-Unit6

Burlay Agriculture Agriculture 813 0

Germumkin Uncultivable waste land 224

Nala Stream Drain 138

Burlay Total 3191

Jawadi Agriculture Agriculture 198 034

(1 Household with

3 persons)

Gochar Grazing land 4189

Idhan Hetu For fuelenergy 209

Kabil Kast 316

Muram Hetu For Murram (fine aggregate) 063

Pahad Hilly terrain 339

Shivir Camping ground 041

NA 2011

Jawadi total 3596

Dhatrawada Agriculture Agriculture 338 0

Charnoi Grazing land 058

Chragha Grazing land 4058

Germumkin Uncultivable waste land 10638

Gothan Livestock rearing land 128

K Kast 557

Kabil Kast 1217

Kadim 074

Khadan Quarry 291

Khalihan Threshinggrain storage etc 167

Murum Hetu

Khadan

For Murram 125

Nala StreamDrain 042

Road Road 117

NA 6

Dhatrawada total 1841

Total (Unit 6) 25197

Momain Badodiya-Unit 7

Parsula Agriculture Agriculture 515 1768

(~41 households) Barda Rockyhilly 847

Barda Nistar

Chragha

Grazing land 947

Charnoi Grazing land 1064

Idhan Hetu

Surakshit

Secured for fuelenergy-

firewood

209

KK 137

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Khchar Grazing land 311

Nala Streamdrain 146

Nistar Chragha Grazing land 393

Parsula Total 12192

Dehripal Agriculture Agriculture 124 018

(1 Household with

5 populaiton)

Birdi GM 295

Brda 8054

Brda Lala 055

Chuna Hetu 105

Germumkin Uncultivable waste land 2015

Kankad Chuna

Hetu

For coarse aggregate and

lime

105

Khad ke Gadde 15

Muram Hetu For Murram (fine aggregate) 042

Watershed

Planning

Watershed planning 027

NA 1916

Dehripal Total 14004

Bijanakhedi Agriculture Agriculture 2199 0

Bardi 4101

Bardi Charnoi Grazing land 1274

Bardi 385

Chamdi Sthan 042

Charagah Grazing land 035

Charnoi Grazing land 018

Chragha Grazing land 1404

Germumkin Uncultivable waste land 858

Idhan Hetu 209

Khad ke gadhe Manure collection 084

Khalihan Hetu Threshinggrain storage etc 143

Mitti Hetu 063

Muram Hetu For Murram 063

Nala Streamdrain 36

Pathar Hetu For Stone 105

Road Road 203

Shivir Bhumi Camping ground 042

NA 288

Bijanakhedi total 11876

Fawaka Agriculture Agriculture 016 238

(4 Households with

28 population)

Brda Hilly terrain 863

Idhan Hetu Secured for fuelenergy-

firewood

25

Kakkad 418

Muram Hetu For Murram (fine aggregate) 179

Fawaka Total 1726

Chouma Agriculture Agriculture 392 072

(3 Households with

19 population)

Brdi Hilly terrain 562

Chamda Sthan For de-skinning 021

Charnoi Grazing land 989

GM 2943

Gothan Livestock rearing land 5

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Muram Pathar

Khadan

Murram (fine aggregate) 041

Nala Streamdrain 015

Chouma total 5463

Burlay Germumkin Uncultivable waste land 1543 0

Nala Streamdrain 019

NA 2604

Burlay Total 4166

Total (unit 7) 49427

Shajhapur (unit 8)

Surajpur Bardi Hill Terrain 898 203

(3 Households with

16 population)

Germumkin Bardi Uncultivable hill terrain 1170

Nala Streamdrain 597

NA 1894

Surajpur total 4559

Lalpur Beed 023 0

Beed Gair Mumkin 053

Brdi 2333

Charagrah Grazing land 18

Charnoi Grazing land 115

Gair Mumkin Brdi 1608

Kadim 115

Nala Streamdrain 055

NA 1684

Lalpur Total 6166

Hanoti NA 16291 0

Total (unit 8) 27024

Note land category for the units is as per the excel sheet received on 18062020 from RUMSL

Hence 41 ST households in Parsula who have a claim of customary use on ~3134 ha of

designated grazing land was selected to be the focus for FPIC Process The map below shows

the location of Parsula and the area designated as Grazing Land

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Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages

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Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages

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Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

32 Selection of FPIC Villages

The assessment of the relevance of the four special circumstances that requires free prior informed

consent (FPIC) to be obtained from affected ST population was undertaken On the basis of the detailed

assessment undertaken as part of ESIA RAP along with targeted consultations with the IP

communities three circumstances are assessed to be not relevant to the project context

Relocation of STs was avoided while determining Solar Park boundary for all the three solar

parks and therefore no relocation of STs is anticipated from lands and natural resources subject

to traditional ownership or under customary use

The physical impact on cultural heritage sites with affiliation to STs is avoided in the three Solar

Park lay out and there is no potential significant impact on critical cultural heritage that is

essential to the identity andor cultural ceremonial or spiritual aspects of local STs community

The Solar Park does not propose to use the cultural heritage including knowledge innovations or

practices of STs for commercial purpose

Table 34 provides the list of villages where the FPIC process will focus covering ST households living

within it The assessment concludes that affected ST families have been living in these villages for

generations and have been using the government land (which was assessed to be subject to

traditional ownership or under customary use of the ST communities) allotted for Solar Park Project

for free grazing their cattle collection of fire-wood and collect edible fruits and plants mostly for self-

consumption The diversion of these land for the solar park will result in impacts on lands and natural

resources It was noticed that 7 other project affected villages had less than 5 ST households the

impact on their customary use of land acquired for the project was assessed and included in this table

too

Table 34 Villages to be covered in FPIC Process

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

Neemuch

Solar Park

Badi

(including 2

satellite

settlements)

80 (~450) Bhill Bardawada which is part of Dhardi Gram

Panchayat has only 4 ST families The location

of these ST households and consultations did

not indicate the government land allotted to

Neemuch Solar Park were under customary use

by them Kawai 17 (~100) Bhill

Agar Solar

Park

Ladwan 12 (~50) Bhill Palda village has 1 ST household and no

grazing (designated as Charnoi Chargah

Gochar) land is acquired from Palda

Palda village has 276ha of designated grazing

land and 28735ha of unoccupied government

land which they will continue to use for free

grazing their cattle and collection of fire wood

Hence the customary use of land by ST

household will continue with a negligible impact

Shajapur

Solar Park

Parsula 41 (~250) Bhill

Bhilala

Apart from Parsula 5 other affected villages

have less than five ST households These

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

villages (with the number of ST households)

are Jawadi (1) Dehripal (1) Fawaka (4)

Chouma (3) and Surajpur (3) The remaining

designated grazing land and total government

land for these 5 villages is provided below

Village Remain-

ing Desig-nated Grazing land (ha)

Total govern-ment land after Project allotment (ha)

Designated Grazing Land in percentage total Govern-ment land

Jawadi 2125 2705 786

Dehripal 241 8116 03

Fawaka 5032 5703 882

Chouma 2278 8167 279

Surajpur 1224 2592 472

The consultation with STs at Parsula informed

that unlike them these ST families do not keep

livestock in large number and mostly work as

construction workers Hence the land allotted to

Solar Park was not under customary use by

them for their livelihood

Note The ST families in these 7 villages will have access to the Grievance Mechanism to register their claims to

participate in the FPIC process In such a case their demands will be shared with concerned ST Committee (or

referred to Mediation Committee) and decision to include them in the process will be taken and an appropriate

mechanism for their representation and participation will be adopted

33 Impact on Nomadic Pastoral Communities

The seasonal use of the grazing and government land by nomadic pastoral communities was noticed

in scoping stage However further consultations with local villagers revealed that they do not visit

regularly and rarely camp on the land allotted to Solar Park These nomadic pastoral communities are

from the neighbouring state Rajasthan and are not recognized as STs in Madhya Pradesh

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan and

consultation with any pastoral nomadic tribes was not held as they did not visit these sites when ERM

conducted field visits The general migration pattern of pastoral nomads is expected to have faced

constraints of Covid-19 restrictions If pastoral nomads or their representatives will be identified during

the FPIC process an appropriate decision on their participation will be taken

ERM will consult GoMP to obtain records of grazing permits issued to pastoral nomads of other states

and determine if any of the villages impacted by Solar Parks figure in it More information on their

migration routes and pattern of seasonal use of forest and revenue land for grazing (which would help

assessing their collective attachment to impacted land) will be collected

Due to C-19 restrictions the regular migration patterns by pastoral nomads are affected in 2020 The

next migration season will be in Nov-Dec 2021 In absence of the particular pastoral nomads the

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

GoMP data on pastoral nomad communities who are issued permit will be used and their IPs status

will be screened through secondary ethnographic literature

FPIC is an iterative process If nomadic pastoral communities could not be consulted the rights of

pastoral nomads will be recognized in TDP and a provision for engagement with them to identify

adequate mitigation measures will be kept in TDP

34 Impact on Government and Grazing Land

The total geographical area of these selected FPIC villages grazing land (Charnoi) available after

allotment remaining government land after allotment percentage of the government land remaining is

given in Table 35 below As per provisions of the MP Land Revenue Code a minium of 2 of the

total private land in a revenue village is reserved as Charnoi or grazing land It is observed that

Ladwan and Parsula have more than this recommended minimum

Table 35 Designated grazing land (Charnoi) and Remaining Government Land

Solar Park Unit

Village Name

Geo

gra

ph

ical

Are

a o

f V

illa

ge

(h

a)

To

tal

Pri

vate

La

nd

To

tal

Go

vern

men

t L

an

d P

rio

r to

All

otm

en

t (

of

To

tal

Geo

gra

ph

ic

Are

a)

To

tal

Go

vern

men

t L

an

d R

eq

uir

ed

for

So

lar

Park

(

of

To

tal

Go

vern

men

t L

an

d)

Rem

ain

ing

Go

vern

men

t L

an

d a

fter

All

otm

en

t to

So

lar

Pa

rk

Perc

en

tag

e o

f G

overn

men

t L

an

d o

f

To

tal

Geo

gra

ph

ical

Are

a

( d

ecre

as

e o

r In

cre

as

e)

()

Desig

nate

d G

razin

g L

an

d

avail

ab

le a

fte

r P

roje

ct

all

otm

en

t (h

a)

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g

Lan

d)

of

the R

em

ain

ing

Go

ve

rnm

en

t

La

nd

()

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g)

Lan

d o

f th

e T

ota

l P

rivate

La

nd

Neemuch Solar Park Unit 1 amp2

Kawai 82698 20132 62566 (76)

24572 (39)

37994 (61)

46 (-30)

397 104 2

Neemuch Solar Park Unit 2 amp3

Badi 130055 33599 96456 (74)

51499 (53)

44957 (47)

35 (-39)

646 144 2

Agar Solar Park Unit 4

Ladwan 59076 31913 27163 (46)

16832 (62)

10331 (38)

17 (-29)

6682 6468 21

Shajapur Solar Park Unit 7

Parsula 69061 51439 17622 (26)

1162 (66)

6002 (34)

9 (-17)

1802 3002 4

Note () As per requirement under MP Land Revenue Code a minimum of 2 of the private land area within a

revenue village is to be reserved as Charnoi or grazing land for collective use by villagers

() Total Charnoi or grazing land prior to the allotment of Government land available in secondary sources

(Census 2011) is old as the land allotment took place between 2017 and 2019 Some Government Land

Allotment Letters mentioned the pre-allotment land category classifications (see Table 31 32 and 33) but this

data was not available for all vilalges to calculate the proportionate reduction of Charnoi land

The percentage of government land in some of the villages was high prior to the allotment of land for

Solar Parks For example the government land in Kawai formed 76 and that of Badi 74 of the

total geographical area Allotment of government land for Solar Parks has reduced the proportion of

the government land in these villages but the percentage of reduction varies from village to village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

For Kawai the percentage of government land after allotment has reduced from 76 to 46 (-30)

and for Badi it changed from 74 to 35 (-39) In Ladwan village the percentage of government

land changed from earlier 46 to 17 (-29) Similarly in Parsula the percentage of government

land changed from earlier 26 to 9 (-17)

The revenue department has designated some part of the remaining government land as Charnoi or

grazing land as per current Nistar Patrak The designated grazing land area meets the minimum

requirement of 2 of the total private land of that particular revenue village The designated grazing

land area forms 104 and 144 of the remaining government land for Kawai and Badi respectively

The designated grazing land in Ladwan forms 6682 of the remaining government land and in

Parsula it forms 1002 of the remaining government land

35 Impact on Cultural Sites affiliated to STs

The physical impact on all cultural sites (both for ST and Non-ST communities) was avoided by

excluding them from the Solar Park lay-outs However some of the cultural sites will be in close

proximity or access to some of them would be possible only through the Solar Park boundary An

overview of the cultural sites affiliated to STs for each of the Solar Parks is provided below

Table 36 Impact on Cultural Sites Affiliated to STs

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

Shajapur

Parsula

Gwalon ka

Mandi

Located within Solar

Park boundary

Adequate area (as agreed during FPIC

consultations) around the Gwalon-ka-Mandi to

be left unused in Solar Park lay-out

A road of sufficient width to be provided to

reach Gwalon-ka-Mandi

SPD will carry out improvements of the cultural

site after discussion with STs and other

communities using it

SPD will provide adequate civic amenities

(parking space drinking water lighting public

toilets etc) as per discussion with STs and

other community using it

Agar Solar

Park Ladwan

Gwaal Dev

Shrine

Located at the

margin of Solar Park

boundary

The SPD should leave the shrine and

adequate space around it in its lay out plan

Will ensure that access to the shrine by

community is maintained

The SPD will consult community to improve the

shrine Or build a new shrine for Gowals in the

new grazing area

Neemuch

Solar

ParkBadi and

Kawai

None The shrines and

cremation grounds

used by Bhils in

Kawai and Badi are

None

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

avoided in project

layout plan

No cultural sites or shrines with cultural significance for STs as a community was found during RAP

survey

36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure

The power evacuation infrastructures associated with these 3 Solar Parks are listed below The Pooling

Sub Stations (PSS) are located within the Solar Park boundary There will be 8 transmission line (TL)

sections whose footprint will be outside of the solar park boundary

Table 37 List of Power Evacuation Infrastructure

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

Neemuch

Solar Park

33kV220 kV Pooling Substation Unit-1 258 ha Located within the Solar Park

boundary 33kV220 kV Pooling Substation Unit-1 296 ha

33kV220 kV Pooling Substation Unit-1 887 ha

PGICL ISTS Station Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Neemuch

Solar Park

220 kV SC Line - 1 (From Unit 1 to Unit 2)

Transmission Line (TL) 1

332 km TL footprint is outside of the MP

Solar Park boundary includes

28 Towers (04 ha 144sqm

for each tower base) and RoW

of 13m width of 920ha

220 kV SC Line - 2 (From Unit 2 to PGCIL

ISTS substation)

Transmission Line (TL) 2

157 km

220 kV SC Line - 3 (From Unit 3 to PGCIL

ISTS substation)

Transmission Line (TL) 3

251km

Agar and

Shajapur

Solar

Parks

33kV220 kV PSS 4 in Unit 4 158 ha Located inside Solar Park

boundary 33kV220 kV PSS 5 in Unit 5 539 ha

33kV220 kV PSS 6 in Unit 6 513 ha

33kV220 kV PSS 7 in Unit 7 143 ha

33kV220 kV PSS 8 in Unit 8 196 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

PGCIL ISTS substation 830 ha Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Agar and

Shajapur Solar Parks

220 kV SC Line - 4 (From Agar Solar Park Unit 4 to interconnecting point with TL 7) Transmission Line (TL) 4

121 km TL footprint is outside of the MP

Solar Park boundary includes

372 Towers (536 ha

144sqm for each tower base)

and RoW of 13m width for

11914kms with 14951ha

220 kV SC Line - 5 (From Agar Solar Park Unit 5 to PGCIL ISTS substation) Transmission Line (TL) 5

2932 km

220 kV DC Line - 6 (From Shajapur Solar Park Unit 6 to Shajapur Solar Park Unit 7) Transmission Line (TL) 6

667 km

220 kV SC Line - 7 (From Shajapur Solar Park Unit 7 to PGCIL ISTS substation) Transmission Line (TL) 7

1646 km

220 kV DC Line - 8 (From Shajapur Solar Park Unit 8 to PGCIL ISTS substation) Transmission Line (TL) 8

6548 km

361 Use of Government Land in TLs Associated With Neemuch Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 38 below

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of STs

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

1 Arnya 088 958 007 784

Kheda Moka Ka Dol 223 1807 055 83

Bardawada 009 5651 002 55

Kawai 112 8265 016 20

2

Kawai 104

Badi 102 13004 012 23

3 Badi 285

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

Chaksodijhar12 043 4475 012 0

Grand Total 966 42782 011

The transmission line RoW comes from six revenue villages out of which 5 are Solar Park affected

villages There are 2 additional villages coming under TL RoW ie Arnya (088ha) and Kheda Moka

Ka Dol (223ha)

The population of Arnya in 2011 (as per census) was 969 out of which 784 were ST population

The Kheda Moka Ka Dol is comparatively a smaller village with total population of 348 and 83 of it

belong to STs

The proposed RoW of the transmission line will use 007 and 055 of the unused government land

in Arnya and Kheda Moka Ka Dol respectively The RoW of the Transmission Line does not pass

through any reserved or protected forest land The vegetation cover in the transmission line RoW is

mostly shrubs and grassland There would be no restriction on current use of the RoW for free grazing

of cattle Hence the transmission line will not impact customary use of the RoW land by ST

population in Arnya and Kheda Moka Ka Dol

362 Use of Government Land in TLs Associated With Agar Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 39 below

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST Population

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

4 Ladwan 068 13311 051 6

4 Pachora 089 273 033 0

5 Chkali Parmar 093 1567 059 0

5 Jhikadiya 266 13514 197 0

5 Pipalya kumar 229 13328 172 0

5 Chikali goyal 287 20523 140 0

5 Bhanpura 152 17482 087 0

5 Nipaniya Baijnath 381 29047 131 0

5 Tola Khed 095 3757 253 0

5 Kashi Bardiya 219 5362 408 2

5 Tola Khedi 042 3757 112 0

5 Kankariya 105 13354 079 0

5 Bhimlod 026 22564 012 0

12 Chaksodijhar is part of Badi Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

5 Bapcha agar 266 26778 099 0

5 Karadiya 144 23584 061 0

5 Mangwalia 24 15397 156 0

5 Gaysari 219 5293 414 0

5 Dehrinana 314 29331 107 0

5 Pharaspuri 142 16955 084 0

5 Bingaya Agar 112 150 075 0

5 Ralayti 267 2365 1129 0

5 Piplaya ghata 212 12811 165 0

RoW area passing through Kashi Bardiya village constitute 4 of the total government

The vegetation cover in the transmission line RoW is mostly shrubs and grassland There would be no

restriction on current use of the RoW for free grazing of cattle The RoW of the Transmission Line

does not pass through any reserved or protected forest land and therefore does not involve any

potential use of forest produce Hence the transmission line will not impact customary use of the

RoW land by ST population in Kashi Bardiya

363 Use of Government Land in TLs Associated With Shajapur Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 310 below

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

6 Burlay 494 2876 172 0

6 Bijnakhedi 158 14668 108 0

6 Dehripal 215 27508 078 0

7 Fawaka 237 6083 390 2

7 Dehripal 296 27508 108 0

7 Parsula 219 5891 372 18

7 Megha Khedi 098 3537 277 0

7 Singhwad 071 3118 228 24

7 Palakhi 072 1185 608 0

7 Baigaon 27 2387 1131 11

7 Bagwad 335 14239 235 13

7 Karkadiya 111 8267 134 0

7 Pipalya Kumar 101 13328 076 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

7 Pachora 306 13311 230 0

7 Shivgarh 024 13353 018 0

8 Abhaypur 026 7633 034 0

8 Alampura 337 12006 281 0

8 Arniya 233 9019 258 0

8 Bada Beed Jagatpura 32 49327 065 0

8 Barandwa 646 258 250 1

8 Batawada 022 5854 038 0

8 Bhadoni 096 1672 057 4

8 Bordagujar 217 120 181 0

8 Chachakhedi 155 482 322 0

8 Chandangaon 409 5711 716 0

8 Chikali Parmar 299 1567 191 0

8 Dhakadi 174 467 373 0

8 Dupada 181 3624 050 6

8 Fanya 349 22 1586 0

8 Gujar Khedi 02 0

8 Gurdadiya 188 1279 1470 2

8 Hanoti 004 34035 001 0

8 Harangaon 005 3034 016 0

8 Jadmi 371 3597 1031 0

8 Jhonkar 572 13653 419 0

8 Kadiya 06 13653 044 8

8 Kalmoi 009 3916 023 0

8 Kanasiya 109 40642 027 0

8 Karedi 003 16944 002 0

8 Kareli 197 16944 116 0

8 Katwariya 458 9312 492 33

8 Khajuri Kanad 085 3138 271 3

8 Kharkhadi 071 310 023 0

8 Khutpala 016 2359 068 0

8 Kundla Khurd 23 1507 1526 3

8 Merkhedi 26 26 1000 1

8 Mirapura 068 3767 181 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

8 Murdawan 292 101 289 0

8 Nanukhedi Mana 054 12851 042 0

8 Nanya Khedi Ahir 156 19092 082 0

8 Palasi 028 203 138 21

8 Pipalya Kumar 163 13328 122 0

8 Pipalya Naulay 28 8117 345 25

8 Rojwas 138 10 1380 0

8 Samgi 454 9921 458 2

8 Samgimanda 086 2578 334 0

8 Shankarpur 327 5782 566 0

8 Siroliya 003 10446 003 0

8 Surajpur 249 6912 360 2

8 Suwagaon 092 17558 052 9

The RoW of the transmission lines associated with Shajapur Solar Park passes through 60 villages

and 19 villages have ST population Out of these one village ie Parsula is covered in FPIC process

for Shajapur Solar Park

The RoW of the Transmission Line does not pass through any reserved or protected forest land and

therefore does not involve any potential use of forest produce The vegetation cover in the

transmission line RoW is mostly shrubs and grassland There would be no restriction on current use

of the RoW for free grazing of cattle Hence the transmission line will not impact customary use of the

RoW land by ST population in these 18 villages with ST population

364 Conclusion on FPIC Trigger for Transmission Lines

Based on the details of the presence of STs in Transmission Line corridors and assessment

of current land use and land classifications following inferences can be drawn

1 The TL Tower base and RoW corridor does not have any reserved or protected forest Hence potential customary use of forest produce is not relevant

2 The vegetation within TL RoW is mostly shrubs and grassland which is potentially used by local community for free grazing If any of this land under the ROW has been used for free grazing the people (including the ST families) will have other unused government land available to graze The disruption during construction and stringing will be very temporary and people can continue grazing under the ROW as before The few villages where the impact on unused land was higher than 10 either had no or very small (lt5) of ST population

3 The RAP survey has not identified any cultural site within TLs RoW or Tower Base area 4 There will be no physical displacement of any ST family for TLs

Therefore the circumstances requiring to obtain FPIC is not relevant for transmission lines

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

4 DESK BASED INFORMATION COMPILATION

41 Information Collection and Compilation

ERM has undertaken a desk based review of the information available This step involved collecting

and compilation of relevant information from following sources

Review of Detail Project Report (DPR) prepared by PwC dated October 04 2019

Detailed Project Report for the Project Dec 2019

The Project boundary map provided by RUMSL dated 19 Jun 2020

Collection of digitised maps of village boundaries

Compilation of demographic data using census 2011 data

Review of drone imagery for the project shared by RUMSL to identify EampS sensitivities in the

proposed project boundary

42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks

This section provides the timeline of land allotment process which is compiled from the allotment letters

of the land shared by RUMSL

421 Government Land Allotment for Neemuch Solar Park

Government land is being procured through allotments under the provisions of the Madhya Pradesh

Land Revenue Code 1959 (and its subsequent amendments) Table 41 provides details of the land

allotment for the Neemuch Solar Park

Table 41 Dates of Government Land Allotment for Neemuch Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Village

17-01-2018 7A-20(3)2017-2018 23868 Bardawada Kawai and Badi

30-05-2017 26A-20(3)2016-2017 43951 Kawai and Badi

Total 67819

Source RUMSL

67819 Ha (out of total 96894 Ha) is allocated to RUMSL through two allotment letters in the year 2017

and 2018 respectively out of the 96894 Ha of the required Government Land Both these allotment

letters predates the MP Revenue Code Amendment Act 2018 Allotment of additional 28979ha is under

process

422 Government Land Allotment for Agar Solar Park

Table 42 provides details of the land allotment for the Agar Solar Park which has been undertaken

between Nov 2016 and Jun 2019

Table 42 Dates of Government Land Allotment for Agar Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

28022019 7A-19(3)2017-2018 5633 Bijnakhedi

28022019 6A-19(3)2017-2018 7053 Dudhpura

21062019 31B-1212019-20 1495 Dudhpura

20-06-2019 5A-19(3)2017-18 15925 Karwakhedi

28022019 4A-19(3)2017-2018 283 Kasaidehriya

20062019 3B-1212019-20 19714 Ladwan

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

280202019 2A-19(3)2017-18 1683 Madhopur

21012019 1A-19(3)2017-18 3492 Piplya Kumar

04012018 9A-19(3)2017-18 602 Naharkheda

09082018 9A-19(3)2017-18 2669 Naharkheda

30112016 4819(3)2015-16 5562 Palda

02012018 8A-19(3)2017-18 5699 Palda

02012018 11A-19(3)2017-18 16116 Pipliya Nankar

06012018 10A-19(3)2017-18 17663 Umariya

09082018 10A-19(3)2017-18 15583 Umariya

Total 127137

Source RUMSL

127137 Ha is so far allocated to the project over 2016-2019 and 5106 Ha was allocated prior to MP

Revenue Code Amendment Act 2018

423 Government Land Allotment for Shajapur Solar Park

Table 43 provides details of the land allotment for Shajapur Solar Park which took place between May

2017 and Jun 2019

Table 43 Dates of Government Land Allotment for Shajapur Solar Park

Timeline

Allotment Letter

Number

Area

Allotted

Villages

26-05-2017 03A-19(3)2016-2017 14991 Dehripal Parsula Kadula MalyaHedi Burlay Jaawdi

Bhandedi Saagdiya Baandahedi Peepalkheda Dopada

Bijana Kheriyaema Kumhariyakhas Dangicha Jaaman

11-12-2017 26A-19(3)2016-17 618 Dehripal Parsula Favka Jaavdi Burlay Chooma

Bijnakhedi Dhatravada

26-05-2017 02A-19(3)2016-17 320969 Kukdeshwar Baamniyakhedi Bordi Khakri Majhniya

Rehli Rulki Dhanda Pidoniya Goyla Aakya Chauhani

Palsaavad Son Desrapur Khokriya Tonk Hanoti

28-06-2019 03A-19(3)2019-2020 8809 Kukdeshwar Bamniyakhedi Bodi Khakri Majhaniya

Rehli Rulki Tanda Pindoniya Goyla Aakya Chauhani

Palsawaad Son Besrapur Khokriya Tonk Hanoti

Total 117697

Source RUMSL

117697 Ha is allocated to the project over 2017-2019 and 108888 ha was allocated prior to MP

Revenue Code Amendment Act 2018

43 Review of Previous Community Consultations for Allotment of Government Land

The summary of the review of the timeline of the government land allotments in FPIC villages is provided in Table 44

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha Resolution

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Allotment prior to

Nov 2018

Amendment

67819 Ha 5106 Ha 108888 Ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

After Nov 2018

Amendment

28979ha 76077 Ha 8809 Ha

Total government

land in Ha

96894 Ha 127137 Ha 117697 Ha

Was the government

land allotted in FPIC

Villages pre or post

Nov 2018

Amendment in MP

Land Revenue Code

Government land allotted in

Badi and Kawai was prior to

Nov 2018 Amendment in MP

Land Revenue Code

Government land allotted

from Ladwan was on 20th

Jun 2019 which is after

Nov 2018 Amendment in

MP Land Revenue Code

Government land allotted

from Parsula was on 26th

May 2017 and 11th Dec

2017 was prior to Nov

2018 Amendment in MP

Land Revenue Code

Was Gram Sabha

resolution required

for FPIC villages

Yes No Yes

Thus as per legal provision (see section 31) the allocation of government land in BadiKawai from Neemuch Solar Park and Parsula in Shajapur Solar Park required a resolution of their respective Gram Sabha and an NOC by Gram Panchayat ERM did not get access to documentation of community consultation as part of seeking NOC from Gram Panchayats Conversation with Sarpanch of villages with ST population revealed that consultation was restricted to Gram Panchayat members Though they were initially reluctant to sign on the NOC after persuasion of District Collector they finally signed It is significant to note that the demarcation of the allotted land took place only recently (Jun to Aug

2020) and the construction process has not started yet13 The FPIC process in compliance to IFC PS-7 requirement is planned to be carried out prior to the construction works of these Solar Parks

13 The process for purchasing private land through consent process has been started in Neemuch

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

An overview of field visits and community engagement is provided in Section 12 above This section

provides details of the consultation carried out with affected STs in the process of preparation of this

FPIC Approach Paper The process involved following three steps

Step-1 Disclosure of intention of conducting FPIC process with affected STs in villages with

significant ST population

Step-2 Disclosure of final solar park boundary and key environment and social impacts (covered

in ESIA) and Participatory Rural Appraisal exercises with affected STs and meeting potential

representatives

Step-3 Identification of ST Representatives and formation of ST Committees and build mutual

agreement between them and RUMSL on Discussion and Decision Making Framework

The Step-1 was carried out in Dec 2019 and Jan 2020 The Step-2 was carried out in Aug 2020 The

details of the process followed during each of these steps are described in sub-sections below

Note The Step-3 is planned to take place in first week of April 2021 and the Draft Discussion and Decision Making

Framework described in Section 83 will be updated accordingly

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020)

The concerned Gram Panchayats identified with STs Population in previous sections were contacted

to inform them about the overall project and intention to conduct a FPIC process involving affected ST

families along with ESIA process The process included preparing a project profile in Hindi (See

Appendix A-B and photo documentation in Appendix C) and handed this over to the elected

representatives of concerned Gram Panchayats These meetings were attended by local RUMSL

personnel The project overview was explained during the meeting and their queries answered

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 51 below

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Badi 1 Sarpanch of Badi Village

2 Kalam Singh (Traditional Head

of Bhil Community in Mama basti)

3 Government Teacher in Bhil

Community

10-12 men from the village

6-7 women from ST (Bhil)

community

5th of December

2019

Kawai 1 Ghasilal (Ward Member in

Kawai Village)

2 Local communitypeople of

Kawai Village

20-25 persons from Kawai

Village were present

4-5 women

6th of December

2019

512 Disclosure of Intention to Conduct FPIC Agar Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Agar Solar Park

The details of the people contacted during this stage is provided in Table 52

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided-

Number of other community

members present during the

meeting

Date of the

Meeting

Ladwan (two

villages covered-

Ladwan and

Kerwa Khedi)

Mohan Singh (Sarpanch for

both villages)

10 persons in Ladwan and

Kerwa Khedi each

No female members were

present in Kerwa Khedi

In Ladwan seven (7) women

members were present in an

FGD that largely included

women

19th December

2019

Repeat visit on

29th January

2020

513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 53

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park

Name of Gram

Panchayat

Name of Person to whom Project

Information Sheet was Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Parsula Since there was no Sarpanch or

Gram Panchayat member present

during meeting one project

information sheet was provided to the

entire community which was

circulated within everyone present

during the consultation and signature

of 1 person from group (Mr Sujit

Singh) was taken

~15 persons in Parsula

Shajapur were present during

consultation also one separate

consultation was held with

women group having ~10

participants

30th January

2020

One common feedback during the consultations undertaken with the community in general and STs in

particular was they were not aware about the solar park boundary to judge which land will be used by

Solar Park and what will be left out for them The ESIA process was working on avoidance and

minimization measures Therefore they were informed that once the boundaries are fixed by the

design team the details will be shared with them

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises with STs (Aug 2020)

The solar park boundaries were finalized and provided to ERM in the last week of June 2020 by the

design team The draft environment and social impact assessment was completed in the month of

Aug 2020 The field-based activities remained suspended from Mar to Jun 2020 due to strict

restrictions imposed on travel and group activities due to Covid-19 pandemic Therefore the next

round of information disclosure and community consultations took place only in Aug 2020 at the time

of the RAP survey

Meeting Sarpanch and a few available Panchayat members

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village level Introductory amp Project disclosure meeting

PRA exercises with STs and information collection for IPP

- livelihood resource mapping

- mapping of social relations and influence and

- village profile

Identifying prominent persons from STs as potential representatives in FPIC process

Understanding the traditional decision-making system and existence of IPOs through key-

informant interviews

The schedule of field visits carrying out these activities is provided in Table 54 and details of these

activities are provided in subsequent sub-sections

Table 54 Site visit Dates and Site Activities

Solar Prak and FPIC Village

Date Site Activities

Agar Solar Park- Ladwan Village

06082020 Visited Ladwan and contacted Patwari Sarpanch and Panchayat Secretary and Fixed a Project Disclosure Meeting (a common meeting including all communities) for next day

07082020 Village level Project Disclosure Meeting at Ladwan

Participatory social mapping and information collection for IPP

Preliminary discussion with 2 Bhil families

08082020 ERM team met Sarpanch of Parsula to brief him and fix a meeting on 10th Aug

ERM team collected land details and village revenue map from Patwari of Ladwan

Shajapur Solar Park- Parsula Village

10082020 ERM team met Sarpanch and a few Panchayat members at Parsula

Shared Project Disclosure note and fixed a meeting with Bhil households of Parsula on 11th Aug

Mapping of social structure of Parsula village and village profiling

11082020 PRA exercise with Bhil community of Parsula resource mapping at Parsula mapping of social relations and influence

Discussion on impact of the Project on grazing land

Understanding the internal decision-making system amongst Bhil

Identifying prominent persons among Bhil families

12082020 Travelled to Neemuch Site from Agar

Neemuch Solar Park- Badi and Kawai village

13082020 Meeting with Sarpanch Badi and sharing of the Project Disclosure Note with Badi community (including all communities)

Social and resource mapping with Bhils in Badi

Understanding the internal decision-making system among Bhils at Badi

Identifying prominent persons among Bhil families

14082020 PRA at Mama Vasti Badi Resource mapping at Badi and Mama Vasti

Filling of village profile form for Badi and Kawai

Discussion on Impact of the Project on grazing land

Understanding the internal decision-making system at Kawai

Mapping the list of tribal leadership in village

Introductory visit to Kawai and sharing of Project Disclosure Note

15082020 PRA at Kawai with Bhil households

Identification of village leaders for Bhil of Kawai

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village)

5211 Meeting with Sarpanch

ERM team met Sarpanch of Ladwan Gram Panchayat at his residence in Karwakhedi village It was

learnt that Ladwan GP had submitted a letter to District Collector earlier expressing their unwillingness

to give away the government land for Solar Park The key concerns of the villagers included

Whether government has gone ahead on issuing tender for the Solar Park site Especially

without replying to their concerns

Whether the land identified by GP for establishing a Gaushala (shelter for abandon and old cows)

is allotted to the proposed Solar Park

How would the Solar Park address long term un-employment and livelihood issue in the village

ERM informed on its intention to conduct FPIC process covering the ST families in Ladwan village

and some of these questions will be answered during a structured process of discussion

5212 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch

Ladwan consists of two revenue villages Karwakhedi and Ladwan The Gram Panchayat office is at

Ladwan and the current Sarpanch is from Karwakhedi The village is dominated by the Gujjar

Community that is the second largest community in terms of population Scheduled caste is the

largest social group of village comprised of Banchhda Charmkaar Balai and Beldar

A community meeting was held where the Talati (village land revenue officer who keeps the land

records) was present The Talati informed them on the status of land allocation for the Solar Park

ERM showed the map showing the optimised project boundary with khasra numbers of the allotted

land ERM team informed them on the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The community expressed their

key concern about the impact on their livestock which forms an integral part of their livelihood

Community Meeting at Ladwan Explaining potential impacts and benefits

5213 PRA Exercises with STs

ERM held a meeting at a settlement cluster (nai-vasti or new settlement) where STs and SCs lived A

general discussion on their village history and livelihood issues were discussed The participation

level in this discussion was good A cross section of people from various age-groups and gender

participated in this discussion and shared relevant information and expressed their opinion A

separate meeting was held with women too (see Photos below)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

According to the elders of the Bhils their generation is the 9th generation residing in Ladwan village

Prior to the three families (Gujjar Bhil and Charmakaar) establishing this village the village had

Muslim population in medieval times and they deserted the village as some epidemic broke out Three

people from Gujjar Schedule Caste and Bhil community first came from another village and settled in

the village As time passed other families from Banchada-Nat Sondhiya Balai and other started

settling in the village

The discussion also involved their religious and cultural practices and shrines There are three

Chabutarascaffold in the village which are their main place of worship There are two shrines ie

Gowal ka Devta close to the grazing lands and Nagdevta adjacent to the new colony outside the

village

A village corner meeting with men Participation of women in group discussion

The Shrine of Nag Devta at Ladwan Meeting with women at Ladwan

After the general PRA exercise involving a larger group a few active participants were picked up to

have more focused discussion on a few aspects Through participative discussions in these smaller

groups the social hierarchy and livelihood resources used by STs (and SCs living in the village) were

mapped

Creating the map of social hierarchy and influence The map drawn by community showing their

livelihood resources

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Social Groups and Influence Map

Most of the families in Ladwan have cattle that includes cow buffalo and goat Approximately 650 cattle that includes 450 cows and 200 buffalos exists in the village There are about 44 cows kept by Bhil households which is about 4 (on an average) cow per family Bhil households own about 100 goats which is about eight (on an average) goats per family Only one family (Chander Singh) owns two buffaloes Few individuals work as grazier for a cluster of houses and are paid 150 per cattle per month by the owners of cattlersquos The cattle owners hire women and youths for bringing fodder feeding and cleaning of cattle sheds collecting cow dung Payment is done on the monthly basis or the basis of hours of work The common land situated at the Right hand side of the main approach road to Ladwan village from Agar is used by the ST community for grazing their livestock ST families bring fodder firewood and fruits from the same portion This is the only place during rainy season where fodder is available for four months as rest of the area is under crops ST families cannot accesses any other commons which is encroached by the dominant familiescommunity According to the ST community if the village commons is taken by solar park then they do not have any option but to sell their livestock as they cannot afford to buy fodder for the livestock unlike the richer families in the village

Free grazing of a mixed herd of cattle and

buffaloes

A grazier bringing back cattle home at evening

5214 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 55 Names of Potential Representatives in Ladwan Village

Section of Representation Sl No Name of Representative Contact Number

Clan Representative 1 DevSingh-Kanhayialal

2 Mangushanker-Amar Singh

Gujjar

Sondhiya

Other OBC

SC

Bhil

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of Representation Sl No Name of Representative Contact Number

Youth Representatives 3 Babulal-Gangaram

4 Anandilal-Lalsingh

Traditional leader or Mukhia 5 DevSingh-Kanhayialal

522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village)

5221 Meeting with Sarpanch

The ERM team for this field visit was led by the IPs Expert comprised of four members including a

woman to facilitate participation of women The ERM team first met the Sarpanch of Parsula who was

not present in initial meeting held earlier in January 2020 The objective of this meeting with Sarpanch

was to share the project information with him and appraise him of the intention of the ERM team to

hold a meeting and participatory appraisals with ST families

5222 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch The Disclosure note had a map showing the

optimised project boundary with khasra numbers of the acquired land It included the key potential

environment and social impacts and what mitigation measures are proposed in ESIA report prepared

by ERM

5223 Joint Site-visit with Sarpanch and Other Leaders

Sarpanch wanted to visit the proposed project site along with the Patwari to explain him the project

boundary based on the land allotment records available with him ERM team facilitated a site visit by

Sarpanch Naib Sarpanch and Kotwar in presence of Patwari to explain him the proposed project

boundaries He shared his observations and concerns over the allocation for the Solar Park which is

used for grazing domestic livestock by villagers including ST households However he agreed to

facilitate an exclusive meeting with ST families next day

5224 PRA Exercises with STs

The Kotwar of Parsula village belongs to ST community He played a significant role in inviting the ST

families to participate in the meeting as well as shared crucial information on their social and cultural

aspects The meeting with ST families included approximately 40 people both men and women from

various age-groups ERM team showed them the map of Solar Park and explained them locations of

key components The community was divided into two to three groups to hold participatory

assessments

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments

Site visit with Sarpanch and explaining Project boundary

Participatory mapping of livelihood and natural resources within Project boundary

Community meeting with ST from Parsula village at Project site

Identification of a medicinal plant during site walk through

Facilitation of discussions with ST women from Parsula village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gwalon-Ka- Mandi within Solar Park Boundary

Grazing lands used by Bhils Mapping

Rajputs are the dominant caste in the village and a person from the Rajput community is the Patel

(traditional leader) of Parsula village Rajputs control all village resources including sources of drinking

water and the irrigation

There are four religious places (Devsthan) of Bhils in Parsula village At all these places the priest is

from the Bhil community One platform is situated within the land allocated to the Project which is

called Gwalon ka Mandi It is recognised by all the community as the women worship at this place to

have good rains for better crop yield or agriculture Community gatherings are organized at this place

on few occasions in the year

The Bhil households reported to own about 2-3 (maximum 10) cows on an average per family and

about 2-3 goats Some families manage to sell three to five goats in a year ₹3000 to ₹ 8000 per

goat depending on the quality of the goat Families who rear cows manage to sell about 4 to 6 litre of

milk ₹40 per litre to private dairy at Chouma village The Bhil community uses the lsquoBirdirsquo hillock

adjacent to the northern side of the Parsula village for grazing their livestock along with other

communities residing in the village

5225 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 56 Names of Potential Representatives in Parsula Village

Section of

Representation

Sl No Name of Representative Contact Number

ClanHouse Cluster

Representatives

1 Meherbaan Singh 7970187292

2 Goverdhan Sigh 8718098704

3 Rahul 9098266244

4 Maakan 6162432391

5 Dheeraj Singh 8871384373

6 Rambabu 9752340827

7 Ballu 9399263367

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Sl No Name of Representative Contact Number

8 Bheru 7725027924

Youth Representatives 9 Kamal 6267658647

10 Rajesh 9009278550

Woman Representatives 11 Payal NA

Traditional leader or

Mukhia

12 Bhawanlal NA

523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages)

5231 Meeting with Sarpanch

Gram Panchayat Badi has 3 villages namely Badi Kawai and Sucharoki The ERM team met

Sarpanch of Badi on 13th Aug 2020 and explained the intention of holding meetings with ST families to

inform them about the FPIC process He advised that we should brief the community members on the

current status of the project first As most of the ST families work as wage labour he advised the

team to come early in the morning He assured to inform the ST families and ask them to cooperate

5232 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for a sample

Hindi version and Annexure-D for sample English version) to Sarpanch and other people present in

the meeting The Disclosure note had a map showing the optimised project boundary with khasra

numbers of the acquired land It included the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The meeting was held at the

center of the village

The community believes that Badi village is 1150 years old calculated based on the date inscribed on

a stone slab in the oldest house in the village It is a common belief that Bhil community came to the

village along with Rajputs The living memory of the community members goes at least six

generations back Badi has ~300 households and there are ~80 ST households Rajputs are the most

dominant community in the village Brahmins and Gujjars also influence the decisions of the village

Gujjars are the largest social group of the village followed by Bhils There are around 30 Muslim

families and they also have some influence on decision-making of the village Apart from Gujjar there

are three other OBC groups that are Sutar Kumhar and Nath

The STs live in three separate habitation clusters The first is in the main village habitation second is

roughly around 05 kilometres away and is called Khari ka Jhopda The third is located further away

around 25 kilometres Both are not connected through roads and one has to walk to reach them The

third habitation is further away where a group of recent migrants form Jhabua (referred as Mama Bhils

by villagers) live and is referred as Mama Basti These Bhil families came here to work as labourers in

the stone mines almost two decades back

At Kawai a meeting with village elders was held prior to discussion with ST families Rajput Gujjar

and Dhakad are the three dominant castes There are only 17 Bhil households in Kawai village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village disclosure meeting at Badi Meeting village elders at Kawai

5233 Site-visit and Walkthrough

The ERM team walked through the site to visit different clusters of ST settlements in Badi and Kawai

Some of the photographs of the main village and satellite smaller settlements where STs live is

provided below

A typical ST house in Badi main settlement The Platform where STs hold their community

meeting

The Khari ka Jhopda Mama Vasti

5234 PRA Exercises with STs

As ST households were found scattered in several small satellite settlements multiple meetings were

held involving a small group of 7 to 12 participants Every ST settlement or cluster of households

usually has a platform under a tree which is used for community meetings and decision making This

space was used for holding PRA exercises Participants were engaged in conversation on their social

relationship and decision making process The understanding gained from these discussions were

then demonstrated in diagrams They were asked if the diagram portrays the right picture or not

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Livelihood and resource mapping in Badi A smaller cluster level meeting at Badi

The village livelihood resource mapping- Kawai Participatory process of understanding

livelihood resources in Kawai

The social relationship and influence map for

Kawai

The social relationship and influence map for

Badi

Similarly a map of the village and surrounding area was created using the information shared by

participants in these meetings They were asked to show where they carry out their livelihood

activities such as farming and grazing etc They were asked to indicate those areas and identify

natural resources or cultural sites located in those locations

Some of the information important for deciding on the FPIC approach collected from these participatory

exercises are as follows

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gram Panchayat Badi has total 16 wards out of which Badi has 9 wards Out of these 9 Wards 2

are reserved for the STs (Bhil)

There are about 250-300 cows kept by Bhil households which is about 4 (on an average) cow

per family Bhil households own about 450 goats which is about 5-6 (on an average) goats per

family Hence for ST families goat is a more popular livestock than cows

Almost all the houses have used locally available stone in constructing the walls of the houses

Pucca houses have used cement and sand as mortar whereas kuchha houses have used mud

The communities fear the loss of access to these stones will make house construction costly and

people who earn from stone quarrying will be impacted

The traditional leader (Mukhia) of Bhils decide on disputes related to marriage and other social

issues Women do not play an active role in decision-making process

Each household cluster of Bhil households have a number of cultural sites where local deities are

worshiped For example in Khera-ka Majra has four cultural sites Ghadiya Bheruji Bhut Maharaj

Bhut Babaji and Dungri Balaji Similarly there are a few cultural sites for goddesses like Leva ki

Mata and Dahana Mataji are located within the Project boundary In all these shrines the priests

belong to Bhil community

STs (Bhils) worship Devnarayan Khejara Mata and Sawria jee in Nimbaheda in Rajasthan The

religious leaders from these places are held with respect and are accepted as mediators or

decision makers for important matters

5235 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table 57

They will be considered for nomination to the representative committee and contacted for capacity

building on FPIC process

Table 57 Names of Potential Representatives in Badi and Kawai Village

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Clan Tola

Representative

Badi Main 1 Gheesalal-Nathulal 9575486482

2 Basantilal-Mangilal 7354345531

3 Motilal-Hiralal 9109003022

4 Nanalal-Ratanlal

Khaira Ka Jhopda 5 Lalu ndashRamlal

6 Tulsi-Devilal

7 Tawarlal-Vardaji

Kawai 9 Ramlal-Hajarilal

Ratanlal

Bherulal(Teacher)

Bherulal- Bhawani

Shantilal

Fargulal

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Youth

Representatives

Badi 10 Omkaar ndashKailaji 8718057436

11 Shyamlal-Mangali 9302086906

Mama Vasti 12 Dinesh ndashThawar Singh

13 Prakash-Ramesh

Woman

Representatives

Badi 14 Kesarbai-Devilal

15 Kavita-Dhanraj

Mama Vasti 16 Shanti-Ramesh

17 Mamta -Naklesh

Kawai 18 Sunder Bai-Bherulal

(Sudibai-Devilal Shimla bai-

Chandrulal LeelaBai-

Chittarmal Prem bai-Gopilal)

19 Kanyabai-Bhuvaniram

Traditional leader or

Mukhia

Badi 20 Bhawani-Laxmi

21 Amar singh-Ramlal 7354325923

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL

A key element in designing a FPIC Process is a mutually agreed and appropriate lsquoengagement and

consultation process14rsquo The lsquoFirst Draft FPIC Approach Paperrsquo was prepared and shared with RUMSL

for their review and comment A virtual workshop was held with RUMSL team on 27th Aug 2020 In

this workshop PS-7 requirements of ICP and FPIC in general and the specific FPIC process designed

for Solar Parks was presented and discussed After their feedbacks were incorporated the lsquoDraft

FPIC Approach Paperrsquo was shared with IFC-WB for review and comments

The objective of these internal discussions are to build an internal institutional consensus on the

appropriateness of the designed engagement and consultation process to comply with the

requirements under IFC PS-7 The subsequent steps for consultations with affected STs and finalizing

a mutually agreed lsquoDiscussion and Decision Making Frameworkrsquo is discussed in Section 81

14 GN-ampGN22 emphasizes to have a shared view of the FPIC process between Project proponent and affected IPs The Project

proponent and affected IPs to agree on an appropriate engagement and consultation process as early as possible and commensurate with the scale of impact and vulnerability of the communities

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INDEPENDENT FACILITATOR AGENCY

6 INDEPENDENT FACILITATOR AGENCY

61 Need for FPIC Process Facilitation Agency

An independent agencyexpert to facilitate the FPIC process is required for the following reasons

There is a strong likelihood of other dominant communities in the village intervening and trying to

influence the internal discussion and decision making by IP The presence of the FA will help

documenting such attempts of external intervention and the presence of the FA may act as

deterrence and help avoid such attempts to interfereinfluence the process

The IP representatives need an intensive process of orientation and capacity building It will be

more effective if this is conducted using the Malvi dialect instead of Hindi Therefore a good

community facilitator with familiarity on Malvi dialect will be helpful

The women and youth will need capacity building and facilitation of their internal discussions prior

to the community level meetings

The facilitation support to IP community in general and IP representatives in particular will require

proficiency in the local dialect Malvi and knowledge of local livelihoods and alternative options

Involvement of a local agencyexpert who also speaks the local dialect and with a good

understanding of local livelihoods (particularly grazing and livestock keeping) will demonstrate

fairness and transparency in the process

62 Screening of FPIC Process Facilitation Agency

ERM identified Institutions (Universities Government Departments and Research Institutes etc)

NGOs and INGOs located and active in Madhya Pradesh state After a preliminary screening selected

potential individualsorganizations were approached to find out their availability and willingness for the

assignment The criteria used for screening included qualification profile affiliation with the type of

institutionsorganizations nature of worksprojects completed working experience with IPsTribes in

Madhya Pradesh conducting meaningful consultation community mobilization and stakeholder

engagement familiarity with World Bank Group safeguardsrsquo policies and procedures comfort with

written and spoken English and local dialects etc The list of independent experts and organizations

screened for the role of facilitation agency is provided in Table 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

1 University of MP Bhopal

Department of Sociology

Dr Arvind Chauhan

Professoramp Head

7999345226

Two candidates with post-PhD and PhD

qualifications from Department of

Sociology interested in working but having

no experience were not considered

2 Dr BR Ambedkar

University MHOW MP

Professor RD Maurya

Former Dean amp Head

Department of Sociology

Old AB Road Gram

Dongargaon Dr

Ambedkar Nagar Madhya

Pradesh 453441

07324 274 377

The retired Professor amp Dean

recommended a college lecturer

belonging to BhilIP from Govt college

Neemuch may be considered as a

resource person in future as appropriate

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

3 Tribal Research and

Development Institute

Bhopal

Rita Singh

35 Shyamla Hills Rd

Bhopal Madhya Pradesh

0755-25570882551257

This institute of MP government is

involved in administration and research

aspects of tribes in Madhya Pradesh

There are full time staff and the person

required for the assignment is not

available However the Government

functionaries may be the resource persons

in sharing information and performing

advisory roles during implementation as

appropriate

4 Institute of Social

Sciences Ujjain

Dr Tapas Faculty

7342510978

Berasiya Rd Navi Bagh

Bhopal Madhya Pradesh

462038

0755 273 0946

The faculty suggested to contact the

Bhopal based NGO (Samarthan)

5 The Samarthan NGO

Bhopal

Shradha kumar

Bhopal Madhya Pradesh

shrdhasrigmailcom

9826912948

The Program Director reported no work

being undertaken by the NGO in proposed

project area and was reluctant to

undertake the assignment She however

mentioned to help coordinating with the

local NGO if available in Neemuch area

and has not responded so far

6 Xavier Institute of

Development and Action

and Studies Jabalpur

Dr Mehul Chauhan

Former Faculty

9977064882

The former faculty suggested two NGOs

(Concept Society and Gramodyog

Sansthan)

7 The Concept Society

Indore

Ms Hemal Kamat Director

9425350272

The candidate appeared for interview has

preferred to be engaged independently

instead of as a NGO

8 Gramodyog Sansthan

Mandala MP

Mr Hariom Shukla

Manager

7999064147

Even after agreeing no one finally

appeared for personal discussion and

interview

9 Balram Sewa Samaj

Neemuch

Mr Kamla Shankar

Manager

7838960968

The only NGO reported to working on

legal aspects in Neemuch area has not

expressed interest to work as FA

10 UNICEF office Bhopal Nagesh Patidar Project

Officer WASH

97525 98212

The staff of UNICEF suggested the name

of suitable candidates and all of them

have appeared for interview and have

expressed the interest in proposed project

work

11 Debate Trust (Referred

by Action Aid Bhopal

Amitav Singh and Leena

Singh

Debate Trust

Duplex C-22 Alkapuri

Near DRM Office

Habibganj Bhopal-462024

Action Aid India had prepared a brief

manual on FPIC (published in 3 Indian

Languages including Hindi in 2018)

reflecting the Indian context and its related

legal system The manual was intended to

help CSOs for their ready reference and

larger reach out Mr Narendra Sharma

who was based in Actionaidrsquos office at

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

0755-2985007 0755-

2417656 9425018144

9425004556

debateindiagmailcom

Bhopal played a key role in preparing the

Manual in Hindi version

Mr Narendra Sharma referred the NGO

Debate Trust who had experiences in

working with Panchayats

A screening using preferred criteria was undertaken of the shortlisted agencies and details are

available in Appendix-F None of these agenciesindividuals have worked for a FPIC process earlier

Hence an agency which was available and willing to undertake the activity was taken on a trial basis

to help in conducting PRA exercises and sample household survey required for preparation of IPP

63 Roles and Responsibility for FPIC Process Facilitation Agency

The role and responsibilities of the FPIC FA will be as follows

Table 62 Roles and Responsibilities of FPIC FA

Phase Responsibilities

I Formation of local committees with STs Representatives

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Hindi (Malwi dialect) Translation of TDPIPP and designing Information sharing tools

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs (particularly women and youth groups) and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation of the FPIC Process and Preparation of FPIC Process Report

Documents of outcome of the FPIC Process including FPIC AgreementMOUJoint Statement of PrinciplesAgreed Mitigation Plans etc

64 Terms of Reference for FPIC FA

The terms of reference for FPIC FA covering villages to be covered specific responsibilities

deliverables personnel requirement and organizational profile and experience is provided in

Appendix-G

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The PS-7 recommends to have a lsquoshared view15 of achieving ICP or FPICrsquo mutually agreed ldquoFPIC

Decision Process Framework Documentrdquo which is based on principles of Good Faith Negotiation

(GFN) The Designing a lsquodiscussion and decision making frameworkrsquo to achieve the FPIC as per GN

on PS-7 should considers the socio-political context within which the affected IPs households live as

well as impacts of the Project This section deals with key-elements considered for designing the

FPIC process as per requirements in IFC PS-7 and GN-7

71 Use of Language

The PS-7 emphasizes use of the IPs language in the FPIC process It was found that BhilsBhilala in

Ladwan and Parsula are relatively small community and they have been living with close socio-

cultural ties with other communities Hence they use Bhilli (their traditional language) very little The

proficiency of the current generation in the Bhilli vocabulary is too limited to use this in discussion of

the Project and its impact Hence their preference is the use of local (Malvi) dialect of Hindi which

they speak along with other communities in the village The Bhils in Badi and Kawai speak Malvi

dialect with some influence of Rajasthani language as it is at the border of Madhya Pradesh and

Rajasthan

In general the written material on the project is expected to be in Devnagri script using the vocabulary

consistent with Malvi dialect to the extent possible The FPIC FA will have community facilitator who

is conversant with Malvi and explain the written material using the conversational Malvi dialect

72 Use of Customary Decision Making Process and Traditional Leaders

The Bhils in Ladwan reported that they resolve disputes between families through intervention of the

elderly member of the familyclan (Baijwal and Dalodia) or go to other prominent people in the village

such as the priest in the local temple or the landlord on whose land they work The customary leader

of Bhils who covered a cluster (~10 to 12) of Bhil settlements existed earlier (at least 3 generations

back) and the current generation has not sought their help in dispute resolution in their living

memory

The BhilBhilala of Parsula belong to a number of clans (Dalodia Paretia Renkewal Vasunia etc)

and the elder member of the clan is usually approached to resolve any internal disputes There used

to be a collective council (panchayat) covering 5 to 10 villages but these have been non-functional

over the years They also approach the village Sarpanch and prominent personalities from other

communities in the village to resolve disputes involving land and livestock The matters related to land

are finally referred to the Tehsildar (land revenue officer) for resolution The local administration also

plays a significant role in resolving inter-community disputes

In Badi-Kawai they still have a traditional Mukhia (leader) who wields influence in community

matters Each Bhil village has an elder who is considered the mukhia or leader There are designated

places where elders hold community meetings to discuss conflicts among Bhils and matters related to

their social norms and customary laws governing marriage and inheritance etc If matters are not

resolved at the village level community elders (Biradari Panchayat) then the matter is escalated to a

forum of community elders from 5 or 10 villages with Bhil population The highest level of escalation in

the customary decision making system is to refer the matter to a Biradari Panchayat of community

elders from 25 Bhil villages16 These traditional leaders residing outside of the villages directly

impacted by the Project are accommodated as member of the proposed Mediation Committee

15 Refer GN-7 GN22 which mentions that lsquothis should ideally be done through a framework document or plan and client should

document support for the agreed process from the affected population 16 GN-7GN36(i) acknowledges that there may be circumstances where formal and informal leaders of the Indigenous Peoples

reside outside of the Projectrsquos area of influence

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

In general the affected IPs communities use familyclan elders to resolve minor disputes and involve

prominent people from other communities like the priest Sarpanch or other prominent personalities in

the village for resolving their conflicts The matters related to land is resolved by intervention from

local administration (Tehsildar and District Collector) If the matters are related to their customary laws

on marriage social relationship or inheritance the unresolved matters can be escalated to a council

that comprises of elders from 5 10 or 25 villages The traditional Biradari Panchayat has been losing

its power as the younger community members considers their decisions regressive and approach

Gram Panchayat leaders (Sarpanch) or take help from the Police and Court of law Considering the

preference of new generation to go to non-ST Gram Panchayat leaders and local administration they

are considered for the Mediation Committee

73 Promoting Participation of Women and Youths

Women specifically stated during consultation that they do not participate in decision making in their

traditional community meetings which are convened for resolving disputes Though the women come

to attend the community meetings they hardly ever participate and express their views

The BhilBhilala youths do not have traditional or customary forums at which they express their views

They accept the decisions taken in the family or at the clan-level However there are a few educated

young people in the village who have distinct views about their future

As free expression of the views by youths and women in BhilBhilala community meetings is not a

social norm separate meetings of these groups where they are able to express their views openly is

proposed as part of their internal decision making process The FPIC FA will facilitate these separate

meetings and keep external interventions in these meetings to the minimum The views expressed by

them in these meetings should be tabled in joint meetings of the community for consideration

74 Expectation on Material Information Prior to Discussion

It is understood from the preliminary round of discussions with ST communities that they expect the

following information to be shared with them

Details of the Project (lay-out plan) and the related activities that are going to be implemented

Schedule of starting of the possession of allotted government land and purchase of pattaprivate

land

Details of land khasra numbers proposed to be taken for the project

Amount of paymentcompensation consideration amount of the land and assets (including on the

government land) that will be taken by the project

What economic and other entitlements and benefits will be provided to the families dependent on

the allotted government land

If private land is purchased then they will lose the source of income generation or livelihood (as

they are hired for a year on contract basis daily wages take land on lease for cultivation and

take care of the cattlersquos etc) what will their entitlements (economic package) be

What options will the Government or the Solar Park Company provide as alternative to the

common grazing land as cattle and goat breeds they keep require free open grazing and not stall

feeding

What alternative livelihoods will be offered to those Bhil families who will be landless after losing

the governmentpatta land they currently use (though owned by others)

It was expressed that the Project proponents share many documents but the community wants

confirmation that the content is authentic Hence community expects that signed and verified

documents should be shared as part of the FPIC process which can be referred in case of conflict or

contradiction

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The relevant information is scattered in ESIA RAP and IPPIPDP A concise information disclosure

dossier will be prepared by ERM and used by FA during the FPIC process

75 Need for Capacity Building of IP Representatives

The interaction with potential ST representatives from these FPIC villages shows that convening a

community meeting and steering the internal discussion to reach consensus will be a new experience

for them Most of them are semi-literate and will face challenges in understanding the Project details

on their own such that they can then explain it to other community members Therefore following

activities are required

A capacity building workshop for the potential IP representatives to explain the Project its impact

and mitigation measures in the Draft IPPIPDPTDP in detail Although the RAP-LRP disclosure

will happen at the community level and ST families will attend those meetings the Draft

IPPIPDPTDP will also explain these entitlementsbenefits in simple language

Presence of experienced community meeting facilitators (from FPIC FA) for community meetings

will help these ST representatives to have focused discussions documentation of views

expressed and decisions made in those meetings

The women and youths usually do not participate in taking decisions on community issues

Hence the women and youth representatives need orientation through separate sessions

In addition to formal trainingorientation sessions the IP representatives may be taken on

exposure visits to nearby solar parks for improving their understanding

76 Need for a Mediation Mechanism

The ST Committee will hold meetings with the representatives of the Project (RUMSL) to discuss

relevant points and reach a mutual agreement While such discussions are likely to result in reaching

mutual agreements on a number of agenda items the discussions may hit dead-end on some issues

All such unresolved issues will be documented as a dissent note for their reconsideration in the second

round of meeting

If the discussion between ST Committee and the representatives of the Project on any significant issue

reaches a deadlock the matter will be referred to a mediation mechanism The mediation will be done

by a high level committee which will comprise of 4 members

An IP representative nominated from the larger tribal leadership of the area (from their customary

council of 10 or 25 villages) but not belonging to the Project village

The elected representative of the concerned Gram Panchayat or a person nominated from GP

and acceptable to the ST Committee

A senior officer from the District Tribal Welfare Department

District Collector or an officer nominated by them

This Mediation Committee will be constituted at the beginning of the FPIC process and will be activated

only in the case of a significant deadlock This Mediation Committee will be involved to read the Final

FPIC Agreement (even when no matter is referred to them for mediation) and satisfy themselves that it

reflects mutual agreements reached through a fair and credible process17

17 This is proposed in order to provide an external validation of a free and fair FPIC process prior to signing of the FPIC

Agreement

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

77 Following Principles of Good Faith Negotiation

Good faith negotiation generally involves 6 principles (see Table 71) The proposed FPIC Discussion

and Decision Making Framework (DDMF) adheres to these principles with slight modifications

keeping the public health concerns associated with the Covid-19 pandemic

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

1 Willingness to engage in

a process and availability

to meet at reasonable

times and frequency

Both parties need to agree to avoid large gatherings and un-necessary

physical meetings A mechanism for tele-consultations will be explored to

keep the physical meetings to the minimum

The internal discussion meetings of STs will be in smaller groups (in the

open rather than in closed rooms) to avoid large gatherings

There will be two meetings between RUMSL and ST Committee and

similarly number of proceedings by Mediation Committee will be limited

The meeting schedules will be finalized beforehand and Covid-19 public

health protocols as applicable at that time will be followed

2 Provision of information

necessary for informed

negotiation

The basic information on the Project and its potential environment and

social impacts are already provided in state language (Hindi)

The essential information requirement by ST Committee is identified and

these information will be provided in simple information dissemination

tools The FA will further explain them for their better understanding

3 Exploration of key issues

of importance

The likely key issues of importance are grazing and cultural sites located

within Solar Park boundary A small task-force comprising of

representatives of RUMSL as well as ST Committee will carry out a field

inspection prior to their first meeting The task force will observe Covid-

19 protocols issued by Government

4 Mutual acceptable

procedures for the

negotiation

The lsquoDiscussion and Decision Making Frameworkrsquo signed by both parties

will have a commitment to hold all meetings and activities complying the

Covid-19 protocols and advisory issued by Government

5 Willingness to change

initial position and modify

offers where possible

The first meeting will resolve issues where both parties can reach

agreement easily The positions of both parties on contentious issues will

be recorded during first meeting The FPIC FA will record the written

positions of both parties on these contentious issues and share with

them The FPIC FA and ERM will hold separate meetings with both ST

Committee and RUMSL Team after 15 days to understand any changes

in the stated position The FPIC FA and ERM will take a decision on

holding the second and final meeting on these contentious issues when

both parties agree to modify their offers and a meaningful discussion is

possible

6 Provision for sufficient

time for decision making

The ST Committee will benefit from the capacity building and assistance

through FPIC FA to conclude their internal decision making The first

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

meeting between ST Committee and RUMSL Team will be held after a

sufficient gap As the number of ST families participating in the FPIC

Process is small it is expected that it will not take them long to reach

internal consensus However STs will be encouraged to have more

meetings internally to be able to discuss within themselves

78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and Supportive Environment

In these FPIC villages the Project requires to achieve both ICP for mainstream communities and

FPIC for ST The existing and past relationship between RUMSL and affected communities plays a

significant role in FPIC process It is learnt from the news report as well as from consultations that

some villages (particularly Ladwan) have decided to protest against the Solar Park as loss of grazing

land is not acceptable to them The protesters had organised a demonstration and also submitted

letters to the District Collector regarding their objections Ladwan village has a strong network of

women self-help groups (SHGs) who are interested in a dairy development program Thus reduction

in grazing land is perceived by them to have a detrimental impact on their long term employment

opportunity and income generation These SHGs have members from SC OBC as well as ST

families

In other FPIC villages ie Parsula Badi and Kawai though there is a concern for loss of grazing

land yet opposition to Solar Parks is passive There are some specific interest groups among the

non-ST communities who would seek answers to their specific concerns For example in Parsula

village the non-ST families (both in Parsula as well as neighbouring villages) have informally

purchased the patta land Their main concern is whether and how they get the compensation for

these land parcels which will be paid to patta owners In Badi and Kawai the number of people who

have encroached on the government land is comparatively more Also there are few influential

people who earn from selling stones (the most popular building material in that area) extracted from

the allotted government land Thus a range of RAP-LRP issues are expected to crop up during

community engagement In all these villages the affected ST communities though would consider

the compensation and benefits offered to them yet it would be difficult for them to disregard the

collective decisions made by other communities in their village

Thus considering different interest groups involved existing social relationship influence of STs in

decision making it would be a challenge to hold a single engagement process18 for both STs and

mainstream communities Therefore we recommend a parallel or concurrent engagement process for

ST and mainstream (non-ST) communities The comparison of the ICP process for mainstream (non-

ST) and FPIC process for ST is provided in Table 72

18 GN-7 GN31 recommends a single engagement process complying to the higher standard (GFN and FPIC Agreement) where

a Project requires to achieve ICP for mainstream and FPIC for IP It reads ldquoSince the achievement of ICP and FPIC as separate processes with different groups within a community or between proximate communities may be difficult and in some cases be a cause of division within the community a single engagement process resulting in one agreement is generally recommended In such cases the process and agreement should reference the higher standard (ie GFN and agreement demonstrating FPIC) Whether the agreement entails different benefits for the differently affected groups will depend on the project context the Affected Communities and the nature of project impactsrdquo

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages

Aspect Engagement Process with non-ST

(ICP)

Engagement Process with ST (FPIC)

Management Plan ESMP + RAP-LRP IPPIPDPTDP

Representative

Body

Gram Panchayat (existing body) ST Committee (specifically constituted for

this process)

Provision of

information

necessary for

informed

negotiation

Executive summary of Draft ESMP

RAP-LRP in Hindi

Abridged Draft IPPIPDPTDP in Hindi (use

of Malwi vocabulary as much as possible)

Capacity building by FPIC FA

Help from FPIC FA to understand issues

Willingness to

engage in a

process and

availability to meet

at reasonable times

and frequency

One public meeting for receiving

feedback on Draft ESMP RAP-LRP

One round of internal discussion by STs

assisted by FPIC FA

Two rounds of meetings between RUMSL

and ST Committee

Mediation Committee meetings (if required)

Exploration of key

issues of

importance

Key issues covered in ESIA RAP-LRP

will be discussed

Key issues covered in Draft IPPIPDPTDP

will be discussed

Mutual acceptable

procedures for the

negotiation

Informal agreement A formal lsquoDiscussion and Decision Making

Framework Agreementrsquo is signed by both

parties

Willingness to

change initial

position and modify

offers where

possible

Demonstrated through incorporations of

feedbacks received from public

disclosure and consultation

Structured engagement process

documenting (signed by both parties at the

end of the meeting) points agreeddisagreed

and demonstrating the flexibility in their

respective positions

Provision for

sufficient time for

decision making

The time for public meeting for

receiving feedback will be decided in

consultation with Gram Panchayat

Sufficient time for capacity building by FPIC

FA internal discussions and gap between

first and second meeting between RUMSL

and ST Committee

Outcome The public meeting for receiving

feedback on Draft ESMP RAP-LRP is

held peacefully and satisfactory

explanationresponse to

feedbackqueries is provided

Incorporating response to all key issues

raised in public meeting in Final ESMP

RAP-LRP

The Final IPPIPDPTDP incorporates points

mutually agreed between RUMSL and ST

Committee

The FPIC Process Documentation Report-

(vetted by independent FPIC FA and

Mediation Committee) provides an overview

of the FPIC process

FPIC Agreement signed by RUMSL and ST

Committee

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Note The FPIC Process Documentation Report prepared by FA under ERM guidance will cover the

whole process (including all meetings by ST and Non-STs decisions key issues discussed etc)

The use of impacted land for free grazing is practiced by both ST and Non-ST communities The ESIA

and RAP-LRP also address impacts on grazing and have prepared a framework for Grazing Resource

Management Plan The engagement with non-ST population will highlight the mitigation measures

with regard to grazing issue (particularly Grazing Resource Management Plan) in ESIA and RAP-

LRP The feedback from non-ST population on mitigation of impact on grazing will be subsequently

incorporated into Grazing Resource Management Plan in particular and relevant sections in ESIA and

RAP-LRP The non-ST population will be clarified that TDP will have some additional benefit for STs

and therefore will be consulted separately

Thus the separate ST committees will not be perceived to take any decision that affects collective

interest of all villagers particularly the powerful non-ST communities The Gram Panchayat and

Sarpanch is provided a place in Mediation Committee and will be involved in resolving key-issues

referred to them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

81 Introduction

This lsquoDraft Discussion and Decision Making Framework19rsquo is prepared after field visits and

consultations with affected STs and a workshop with RUMSL (see Section-5 for details) This Draft

DDMF will be shared with ST Committees on behalf of RUMSL and after appropriate modifications

(without diluting the key-elements for compliance to PS-7 requirements) the final version will be

signed by representatives of both parties Section 814 provides subsequent steps in this regard

The three proposed solar parks are located in three different Districts and each one will have an

independent Solar Park Developer (SPD) or Concessionaire The impact of each solar park and the

social context of the affected STs also differ in these three locations Hence three ESIA reports as

well as three IPPIPDPTDP are prepared The Draft IPPIPDPTDP prepared for each Solar Park has

a specific package of benefits for the STs in FPIC villages This will be discussed during the proposed

FPIC process and the outcome of this process will be a written lsquoFPIC Agreementrsquo that adopts the Draft

IPPIPDPTDP and agrees to cooperate in its implementation

82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo

The subsequent steps for discussing this Draft Discussion and Decision Making Framework with STs

in the selected FPIC villages (grouped at each Solar Park level) is discussed in this section

821 Appointment of FPIC Facilitation Agency and Orientation

The requirement of a FPIC Facilitation Agency (FA) and their roles and responsibilities are discussed

in Section-6 above The FA will play a key role in forming the ST Committees (at each Solar Park

level) and informing them on their rights to FPIC their legal rights on natural resources prior to their

acceptance of this lsquoDraft Discussion and Decision Making Frameworkrsquo Hence one of the agencies

screened for this role will be appointed and brought on board

After on-boarding them ERM will carry out their orientation by holding a series of virtual workshops with

them The orientation program will include the following

The ICP and FPIC requirements as per IFC PS-7 and WB OP 410

Key findings of the ESIA-ESMP including Draft RAP-LRP

An overview of consultations in FPIC Villages

The Draft IPPIPDPTDPs

The Draft Discussion and Decision Making Framework

The Capacity Building of ST Committees on FPIC and their customary rights on natural

resources

822 Introducing FPIC FA to RUMSL and FPIC Villages

After the orientation of the FPIC FA the key persons will be introduced to the RUMSL team through a

physical meeting Subsequently a field trip will be planned to introduce the FPIC FA in FPIC villages

The RUMSL and ERM will introduce the FPIC FA to the contact persons from earlier field visits and

inform them about their role

19 The term lsquoengagementrsquo and lsquonegotiationrsquo was avoided to keep the language less confrontational and positive for both parties

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

823 Formation of ST Committees

ERM and FPIC FA will jointly discuss the structure and composition of the ST Committee at each

Solar Park20 with affected ST community As per suggestions from them ST Committees will be

formed and their nominations will be ratified through a group meeting21 The composition of the ST

Committee is described further in Section 8311 below

824 Capacity Building of ST Committees

The FPIC FA will discuss with the ST Committee on the time and venue for holding a capacity building

workshop The capacity building workshop will cover the following

The recognition of FPIC as their rights

Specific provisions of FPIC as per IFC PS-7 and WB OP 410

Applicable India Laws and recognition of their customary rights on natural resources

The Draft Discussion and Decision Making Framework (Draft DDMF)

The participation of RUMSL in this capacity building workshop will be optional and as per mutual

agreement by both parties The FPIC-FA will note down the suggestions of the ST Committee on the

Draft DDMF and share them with RUMSL

83 The Draft Discussion amp Decision Making Framework

The proposed discussion (engagement) and negotiation (decision making) framework will include 11

steps as illustrated in the Figure 81 below

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process

These steps are described in sections below

20 Agar and Shajapur Solar Park have only one FPIC village Hence the ST Committee will be selected from within the same

village Neemuch Solar Park has two FPIC village with several satellite ST habitations The ST Committee for Neemuch Solar Park will be larger to accommodate representation of different ST groups 21 The FPIC village level group meetings will be held keeping the Covid-19 public health guideline ERM will use professional

judgement on the acceptability of the selected committee for most ST households if the ratification of the ST Committee is not possible by a large public meeting

Formation of Committees

Acceptance of Draft Discussion and Decision Making

Framework

Disclosure of Draft IPP to ST Committee

Explaining Draft IPP to ST Committee

Internal Consultations by ST Committee

First RUMS and ST Committee Discussion

Second RUMSL and ST Committee Discussions

Reference to Mediation Committee

(if any)

Informing Community about Draft FPIC

Agreement

Final Community Meeting for Expression

of ConsentDissent

FPIC Agreement Signing

FPIC Process Documentation Report

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

831 Formation of Committees

The FPIC process will involve three committees for each Solar Park One representing the affected

ST community the other presenting the Project proponent (RUMSL) and the third a committee to

mediate between the two if the need be The composition of these committees are explained in sub-

sections below

8311 Formation of ST Committee for each Solar Park

Each Solar Park will have a ST Committee which includes representatives from all FPIC villages of

that Solar Park Each ST Committee will comprise of 7 to 13 members (or any odd number22) who

represent different sections of the ST community The principle for selecting the members of this ST

Committee will be as follows

One representative from each clanhabitation cluster (tola)

The clans which have more population may select 2 representatives

Two representatives from youths (18-25 years)

Two women representatives

One traditional leader (Mukhia) or ST community head from each FPIC village

Gowal (cow-herder) who takes othersrsquo cattle for grazing and earns livelihood from this

The ST Committee will select a chairperson to coordinate and conduct their internal meetings The

representative from the youth and women will hold separate group discussions within their sub-groups

and share their concerns preference and feedback The FPIC FA facilitating these internal meetings

will ensure that these points are tabled at the joint committee meetings The ST Committee will

prepare a list of households and the adult members (gt18 years) who will be part of the FPIC process

8312 Formation of RUMSL Teams

RUMSL will form three site level teams (one for each Solar Park) which will include the District

Renewable Energy Officer (DREO) of the concerned district and a staff member to assist him They

will report to RUMSL Managing Director (MD) The names and designation of the RUMSL Team are

as follows

Level Designation Name Contact Number

Head office MDCEO Deepak Saxena

Social Development

Specialist

TBD

Site Level (Agar) DREO Deepak Bulani +91-9229924836

DREO- Staff TBD

Site Level (Shajapur) DREO- Prakash Salunke +91- 9926440877

DREO- Staff

Site Level (Neemuch) DREO- Sohanlal Bajaj +91-9827222217

DREO- Staff Balaram Rathod +91-9827323612

22 To avoid a deadlock on decisions

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The site level RUMSL Team will attend the meetings with ST Committee discuss the issues raised by

them sign on minutes of meetings and report to MD where prior approval is necessary The MD or

his authorised representative will take part in important meetings including meetings with the

Mediation Committee if required

8313 Formation of Mediation Committee

There will be a Mediation Committee for each Solar Park The Mediation Committee will comprise of

three members which will be chaired by the District Collector

Member Selection Process

STs Representative from the

Area Biradari Panchayat

The ST Committee after internal discussion will nominate a prominent person of their community outside of their village who is accepted as a member of Biradari Panchayat or similar bodies

Member from Gram

Panchayat

The ST Committee will nominate a member (or ex-GP member) who is known for his role in resolving local disputes

District Tribal Welfare

Department

A senior Tribal Welfare officer will be nominated by District Collector or the Head of Department of Tribal Welfare

District Collector (or his

representative)

The District Collector of the district within which the particular solar

If District Collector is not available she should decide on who can act as his representative

The ERM FPIC-FA ST Committee and RUMSL Team jointly visit these MC members and brief them

on their role in FPIC Process The formation of the MC should be completed prior to the first meeting

between ST Committee and RUMSL Team

832 Acceptance of Draft Discussion and Decision Framework

After the capacity building of ST Committees FPIC FAERM will coordinate with both parties to fix a

date and time for a joint meeting to discuss the Draft Discussion and Decision Making Framework and

ratify it after making necessary modifications

The composition of the committees mentioned in Section 831 and the steps mentioned in Figure 81

will be explained to ST Committee during their capacity building process (described in Section 824)

A Hindi (with Malwi words used to the extent possible) version of the lsquoDraft Discussion and Decision

Frameworkrsquo (Section 83) will be provided to ST Committee during the capacity building Thus the

affected IPs will get adequate time to discuss and come prepared for any suggestions from their side

to this meeting The

Both parties will discuss on a code of conduct commit to follow this during their meetings The code of

conduct will be based on following principles of good faith negotiation

(i) both parties will be available to meet at reasonable time and frequency

(ii) both parties to share information23 necessary for informed negotiation

(iii) both parties will be willing to change initial position and modify offers where possible

23 The Project will disclose information as per Information Disclosure Plan discussed in Section 513 of the Draft

IPPIPDPTDP The disclosure will include at minimum (i) project boundary (ii) impacts of the project (iii) entitlements and other benefits The information will be shared in a culturally appropriate manner and in a form and language easily understandable to the ST communities The FPIC FA will help the ST community understand and process this information prior to the joint meetings with RUMSL

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 77

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

(iv) both parties will give each other reasonable time24 for decision making

(v) both parties will put their view peacefully and will not resort to violence and threat and

(vi) both parties will not engage in discussion when they are under influence of any intoxicants

Both parties will discuss and agree on the quorum required for their meetings and how proceedings of

their meetings will be documented Some suggestions for discussion in this regard are

(i) The quorum for the meeting to be physical presence (or virtual participation) of at least 75 of

the ST Committee and RUMSL Team The FPIC FA will check the quorum of the meeting prior

to starting the proceedings

(ii) The Documentation Assistant in FPIC FA will have the responsibility to record the audiovidoe

of the meeting proceedings

(iii) The FPIC FA will write down the key decisions taken during the discussion and the MoMs will

be read out prior to taking their signature

(iv) The FPIC FA will ensure that ST Committee and RUMSL Team understand the decisions made

If any party express that they need more time (to discuss internally or take approvals) such

information will be recorded

(v) The FPIC FA will also document any dissent expressed by any individual member while

supporting the collective decision of the group she represent in the MoM

The agreed Discussion and Decision Making Framework will have a target time-frameschedule for

completion of each step in the FPIC process Both parties will put their best efforts to complete the

process within t(his time-frame ERM will keep a track of the progress of FPIC process as per this

time-frame and help both parties to avoid unnecessary delays FA will draft the Agreement on Final

Discussion and Decision Making Framework (in Hindi) in consultation with RUMSL and ST

Committee

The final (after ratification) lsquoDiscussion and Decision-making Frameworkrsquo the FPIC-FA will hand over a

signed copy to both parties (ST Committee and RUMSL Team) A pamphlet or poster on accepted

code of conduct will be prepared and displayed at the meeting venue FPIC-FA will request all

members attending the meeting to follow these rules

833 Disclosure of Draft IPPIPDP to ST Committee

ERM will prepare Draft IPPIPDPTDP (in English) for each Solar Park A Summary Draft IPPIPDPTDP

will be translated to Hindi (with use of Malwi as much as possible) ERM will share following documents

to both parties as soon as they ratify the lsquoDiscussion and Decision Making Frameworkrsquo

The Draft IPPIPDPTDP (in English)

Summary Draft IPPIPDPTDP25 (in Hindi)

A simple 4-6 page brochure describing (illustrations where possible) the benefit package

proposed in Draft IPPIPDPTDP

The ST Committee members will be given one week to go through the documents shared with them

and fix a date to explain the Draft IPPIPDPTDP Report

The RUMSL will be provided soft copies of these documents to upload them in their web-site from

where external stakeholders can access these documents

24 The time provided should be adequate to read verify and consult (internally or any external expert on the subject matter)

The FPIC-FA will consult both parties to decide what is reasonable and acceptable to both 25 The Summary Draft IPPIPDPTDP will be 20-25 page It will follow the structure of the IPPIPDPTDP but provide a non-

technical description of the content for easy understanding by ST Committee

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

834 Explaining Draft IPPIPDPTDP to ST Committee

ERM and the FPIC-FA will organize a workshop for ST Committee of each Solar Park at a suitable

location on an agreed date (at least after 7 days from sharing of the documents with ST Committee

The workshop will explain the impacts of the Solar Park and the range of mitigation measures and

project benefits mentioned therein

The FPIC-FA will orient them on how to hold consultations with different sections within their

community and document their views The ST Committee will be provided adequate copies of the

brochure describing the benefit package project boundary maps (in large flex prints) to help them

explain the Solar Project to their community members and hold internal discussions

ERMFPIC-FA will consult ST Committee and RUMSL Team to fix the date for first meeting between

RUMSL and ST Committee

835 Internal Consultation Process by ST Committee

FPIC-FA will help each ST Committee to prepare a tentative schedule for internal discussions The

women representatives will hold meetings with women and youths representatives will hold meetings

among young people The FPIC-FA will make itself available to facilitate and document these internal

meetings

After a round of internal discussion of each sub-group the ST Committee will have the final meeting

to discuss the comments and concerns raised by different sub-groups of the community The ST

Committee will finalize a list of issuesdemands for further discussion with RUMSL The FPIC-FA

prepare the Agenda for First RUMSL-ST Committee Meeting and share it with RUMSL at least a week

before the meeting

The Agenda of the first RUMSL and ST Committee will be shared with the Mediation Committee to

keep them informed about the initiation of discussion between both parties

836 First RUMSL and ST Committee Meeting

The FPIC-FAERM will confirm the quorum prior to starting the proceedings The points mentioned in

the Agenda circulated earlier will be taken up for discussion The RUMSL Team will respond on these

pointsissues The ST Committee will consider these responses and decide if they are satisfied Once

the discussion is concluded the FPIC-FA will write-down the decision made with respect to the

specific Agenda items If any additional points to be discussed by any party those points will be

discussed at the end of the meeting with mutual agreement The FPIC-FA will document the

proceedings of the meeting as per the Discussion and Decision Making Framework (see section 832

above)

If all issues are resolved through discussion in this meeting then another round of discussion is not

required If there will be unresolved issue they will be included in the Agenda for the second meeting

While preparing the Agenda for the second meeting FPIC-FA will record the positions of both parties

with respect to these un-resolved issues The Agenda for the second meeting will be prepared listing

these unresolved issues with an appendix stating the views of each party on these unresolved

issues

RUMSL Team will brief about the mutual agreements and unresolved issues listed for second meeting

with their MD and seek approval if required The ST Committee will similarly brief their community

members on what is agreed after they return

The FPIC FA and ERM will prepare a Draft FPIC Agreement (in Hindi) reflecting the points of mutual

agreements and dissents if any The Draft FPIC Agreement will be shared with both parties

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

837 Second RUMS and STs Committee

The second and subsequent meetings between RUMS Team and IPs Committee will be held on

points where both parties do not agree and it requires further discussion ERMFPIC-FA will consult

both parties to reconsider their views and think about solutions acceptable to them Once ERMFPIC-

FA see both parties are prepared for the next round of discussion date for the second meeting will be

fixed

In this second round of meeting it is expected that a few more points will be mutually agreed The

Draft FPIC Agreement will be updated mentioning these points on which there are mutual agreement

and points of dissentdisagreements

Although it is expected to resolve all issues in two rounds of discussion there is a possibility of

additional rounds of discussion Both RUMSL and ST Committee will discuss on additional meetings

and decide a mutually agreed time-frame to complete the on-going discussion process

If both parties feel canrsquot be resolved through further discussions they will decide if the issue should be

referred to the Mediation Committee or set aside for discussion at a later date26 ERMFPIC-FA will

check if both parties are committed to accept the decision of the Mediation Committee and take the

final decision in consultation with both parties

838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee (MC)

If all issues are resolved through mutual discussion between the RUMSL Team and ST Committee

the Draft FPIC Agreement will be forwarded to MC of the respective Solar Park The MC will be then

requested to be available to chair over the final community meeting (see 8310) to measure the

consent expressed by affected ST in FPIC villages

The MC of the respective Solar Park will consider any issue which was not resolved by mutual

discussion between ST Committee and RUMSL Team and referred to it with an understanding that its

decision will be acceptable to both parties The FPIC-FAERM will hand over documentation of

previous discussion related to the issue and stated positions of both parties with respect to the matter

under consideration to MC

The MC will convene a meeting where it hears the arguments from both sides After considering views

on the matter from both sides MC will offer a solution for consideration If the MC thinks they need to

consult subject experts they will inform both parties and reconvene the meeting after they have

obtained views from such subject experts

Both parties if required will be given time (not more than a week) to consider the resolution offered by

the MC and come back with their final views

After considering the views of both parties on the solutions offered by it the MC will give its final

decision on the matter The MC will try making its decision on consensus and if it is not possible the

decision will be on majority Both parties will be bound by this final decision pronounced by MC The

final decision by MC will be incorporated into the Draft FPIC Agreement

839 Informing Community on Draft FPIC Agreement by ST Committee

The FPIC-FA will provide the Draft FPIC Agreement to the ST Committee The ST Committee

members will inform community members in smaller the sub-groups on the decisions taken during

FPIC discussion with RUMSL The ST Committee will explain their decisions on each issue and ask

26 Particularly matters which are uncertain or may happen in future These issues can be listed as unresolved issues to be

monitored by an agreed mechanism and discussed later

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

each adult member of the community to attend the final community meeting to voice their views and

acceptreject the Draft FPIC Agreement

8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and Ratification of Final IPP and FPIC Agreement

The ST Committee will take decision to hold the final community meeting to express their

consentdissent and fix a date after consulting RUMSL and MC members It will invite RUMS Team

and Mediation Committee to participate and witness the expression of consentdissent by affected

STs

FPIC-FA will ensure that all households in the community are informed about this meeting at least 7

days in advance FPIC-FA will prepare the list of all adult members with support from ST Committee

The IPs Committee will take the responsibility of the invitation and FPIC FA will monitor and document

the process The quorum for holding the final community meeting of affected ST families will be as

follows

Presence of at least 50 of the affected ST families in FPIC village

Presence of at least 60 of the total adult members of these affected ST families

Presence of at least 33 of the total adult women members

Presence of at least 33 of the total youths (between 18 and 25 years)

The FPIC-FA will coordinate with ST Committee members representing women and youth to ensure

that these quorum requirements are met during the final community meeting

The FPIC-FA will set-up a mechanism for recording the presence of eligible ST adult members and

hand over a copy of the Draft FPIC Agreement as they arrive at the meeting venue The Mediation

Committee will preside over this final community meeting The FPIC-FA will inform MC if quorum

requirements for the meeting is achieved After verifying the quorum required and the people

gathered for the meeting are from the affected ST households from FPIC villages the MC will initiate

the meeting proceeding

A representative from RUMSL Team will read out the agreed points mentioned in the Draft FPIC

Agreement and request for their acceptance A representative from the ST Committee will express

their views on points of mutual consensus as well as any unresolved issue that will be discussed and

resolved at a later stage of the project

The MC will then provide opportunities to ST community members present in the meeting to express

their views ST Committee will facilitate community members to express their opinions and

suggestions

The MC will consult with RUMSL and ST Committee if any additional points of agreement and dissent

to be incorporated in the Draft FPIC Agreement After confirming their final positions request the

community members present in the meeting to express their consentdissent and ratifyreject the Draft

FPIC Agreement

The consentdissent will be expressed by raising hands when the members of the Mediation

Committee puts the proposal of ratification to vote If more than 75 of the community members

attending this meeting votes in favour of the Draft FPIC Agreement it would be regarded as

expression of collective consent

The MC will inform the assembled community members about the outcome of the voting and if Draft

FPIC Agreement is ratified or rejected After the Draft FPIC Agreement is ratified by a collective

expression of consent the ST Committee members and RUMSL Team will sign the Final FPIC

Agreement This Agreement will be counter signed by members of the Mediation Committee as

witnesses

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The IPs community may be allowed to carry out any customary ritual on the day of the completion of

the FPIC process and express their support to the proposed Project This FPIC Agreement will be

taken up for implementation and a monitoring committee will oversee its effective implementation

8311 FPIC Process Documentation Report

The FPIC-FA will prepare a FPIC Process Documentation Report summarizing each stage of the

FPIC process It will hand-over all audio-visual records of the FPIC process The process document

report will cover all stages of the FPIC process documenting the following

Process of identification of STs ST representatives and decision-making authorities

Process of assessment of capacity of ST representatives to undertake good faith negotiations

Summary of any capacity building undertaken

Agreed engagement and negotiation framework (including the process undertaken to agree upon

the framework)

Summary of consultations meetings engagement undertaken as part of the FPIC process and

Opinion of FPIC-FA on the process and outcomes

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to

complete the FPIC process

84 Tentative Time-line

The Phase-I FPIC activities was scheduled to be held in Apr 2021 Due to the outbreak of second

wave of Covid-19 in Apr 2021 the field activities are suspended The decision to initiate these

activities will be taken once Covid-19 second wave gets over The schedule for Phase-II activities to

will be discussed with ST Committees of the three Solar Parks and will be decided accordingly As the

progress of FPIC process requires cooperation from affected ST community and the level of

cooperation varies in these three Solar Parks Hence the schedule for Phase-II FPIC activities will be

updated in discussion with respective ST Committees while finalizing the Discussion and Decision

Framework with them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Section Activity Month-1^ Month-2 Month-3 Month-4 Month-5

821 Appointment of FPIC FA and Orientation

822 Introducing FPIC-FA to RUMSL and FPIC Villages

823 Formation of ST Committees

824 Capacity building of ST Committees

8313 Formation of Mediation Committee

832 Acceptance of Draft DDMF

833 Disclosure of Draft IPPIPDPTDP to ST Committee

834 Explaining Draft IPPIPDPTDP to ST Committee

835 Internal Consultation Process by ST Committee

836 First RUMSL and ST Committee Meeting

837 Second RUMSL and ST Committee Meeting

838 Refer Unresolved Matters to MC

839 Inform Community about Draft FPIC Agreement

8310 Final Community Meeting for expression of ConsentDissent

8311 FPIC Process Document Report

Phase-I Activities

Phase-II Activities

Activities to start and complete

OptionalConditional Activity

^ The commencement of these activities will be determined once second wave of Covid-19 gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW

IN THE STATE OF MADHYA PRADESH INDIA

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

85 Responsibility Matrix

The FPIC process will require a collective effort and coordination between ERM RUMSL ST

Committee Mediation Committee and the FPIC FA The roles and responsibilities of these entities are

described in Section 82 and 83 above ERM will play an active role in coordination and provide

information required for a meaningful discussion The key responsibilities and accountabilities are

summarized below for clarity

Activity ERM FPIC-

FA

ST-

Committee

RUMSL-

F

RUMSL-

HO

Mediation

Committee

IFC-

WB

Formation of ST Committee S P P A

Formation of RUMS Team P A

Formation of Mediation

Committee

P P S P A P

Acceptance of Discussion

and Decision Making

Framework

S P P P A C C

Disclosure of Draft IPP to ST

Committee

P S S A C A

Explaining of Draft IPP to ST

Committee

P S

Internal consultation process

by ST Committee

S P P

First RUMSL and ST

Committee Meeting

S P P P A

Second RUMSL and ST

Committee Meeting

S P P P A

Mediation Committee

Proceedings

P P P S P P

Informing Community on Draft

FPIC Agreement by ST

Committee

S P P A

Final ST community meeting-

expression of consent

dissent

S P P P A A C

FPIC Process Documentation

Report

P P S S S S A

P= Primary Responsibility S= Secondary Responsibility C= Must be Consulted A= Approval

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

PROJECT INFORMATION DOCUMENT SHAJAPUR SOLAR PARK

Background

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) The primary objective of RUMSL

is to develop and facilitate the development of large-scale solar projects in the State of Madhya

Pradesh In line with the governmentrsquos ambition to boost solar power in State RUMSL is developing

Solar Park of capacity of 450 MW at Shajapur Madhya Pradesh

The World Bank had agreed to provide financial support for the Project International Finance

Corporation (IFC) is providing investment advisory services to Government of Madhya Pradesh to

develop the project on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards for the Project

Project Details

The proposed 450 MW Solar Park is located in two Tehsils ndashMoman Badodiya and Shajapur of

Shajapur District Out of 450 MW capacity 325 MW will be developed at Moman Badodiya tehsil

(termed as Unit 1 amp 2) and 125 MW will be developed at Shajapur tehsil (termed as Unit 3) of

Shajapur district Madhya Pradesh Almost 89 of the land area is Government land and remaining is

private land The salient feature of the Project are given below

Solar Park

The Solar Park will be developed as two units spread across these lands and the details of the same

ae captured in the table belowndash

Table A1 Details of Land parcels identified for the project Unit Number Area in ha Capacity Tehsil Villages

Unit 1 72048 220 MW Moman

Bododiya

Proposed to span 6 villages - Bijanakhedi

Burlay Chauma Dehripal Fawaka and

Parsula

Unit 2 105 MW Proposed to span Burlay Dhatrawada and

Jawadi whereas

Unit 3 26964 125 MW Shajapur

Tehsil

Hanoti Surajpur and Shajapur

Total 99012 450 MW

Land

Out of the total land requirement of 99012 hectares 86937 hectare is Government land 11074

hectare is private land and 1001 hectare is government patta land The Government land required for

the Solar Park which accounts for almost 89 of the total land required will be leased by the

government of Madhya Pradesh to SPPDs and the private land will be purchased from the land

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

owners for the development of Solar Park as per the prevailing laws and policies in the State of

Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP

Transmission Line

The transmission infrastructure is planned to evacuate power generated from the units to the STU

grid Each unit will have a 33200 kV internal pooling substation The internal pooling substation will

be connected to the proposed MPPTCL 220400 kV substation at Agar through 220 kV transmission

line For cost optimization the single circuit line from unit 1 will be laid till unit 2 towers and there on a

double line circuit of 220 kV shall be connected till the gird substation The Unit 3 internal pooling

substation shall be evacuated through single circuit 220 kV transmission line till the existing MPPTCL

220400 kV substation at Ujjain

The 33220 kV substation at each unit and 220 kV connectivity to the MPPTCL substation will be

developed by RUMSL MPPTCL will establish 220400 kV proposed grid substation at Agar in

connection with the existing 220400 kV MPPTCL substation at Ujjain Madhya Pradesh MPPTCL will

establish 220400 kV proposed grid substation at Agar along with the associated line till 400220 kV

Ujjain substation The solar project developer in the park shall be responsible for laying the 33 kV

cable and 33 kV ring unit as required at each unit to connect its plant to the 33220 kV internal pooling

substations

Road Infrastructure

The road infrastructure requirements is planned to access the Shajapur Solar Park Ms RUMSL shall

carry out road wideningrepairing of existing roads wherever required The road widening repairing of

existing roads is proposed for a length of 65 km which shall be undertaken by RUMSL The

development of internal roads within each unit shall be in the scope of individual Project Developer

Water Requirement

Water requirements for all purposes shall be met by digging bore-wells within each unit and shall be in

the scope of project developer Also the arrangement of construction water shall be in the scope of

contracting agencies and Solar Power Project developer

Common facilities planned

For 450 MW Shajapur solar park the utility area is proposed adjacent to the Unit 1 and Unit 3 -

33220 kV internal substation The other facilities such as RUMSL office fire-fighting equipment

telecommunication infrastructure medical dispensary etc will be located at the pooling substation

area

Project Implementation

The 450 MW Shajapur Solar Park will be implemented in a period of ~21 months

Operation and Maintenance

It is envisaged that different developers may occupy individual units and will be responsible for OampM

The operations and maintenance of common facilities provided like pooling substation intermediate

substations shall be undertaken by RUMSL

Environment and Social Impact Study and Management Plans

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Assessment (ESIA) of three solar parks including internal

evacuation infrastructure and associated transmission lines ESIA carried out for the project will meet

the requirements of Environment and Social Safeguard Policies and Standards of WB and IFC in

addition to applicable environmental and social regulations and policies in India and the State of

Madhya Pradesh

Based on final land footprint and georeferenced site boundaries of the project the ESIA will include a

Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) ERM will share relevant

information and consult with affected local communities to understand their viewsconcerns The

consultation will cover a wide range of people to take into account perspectives from different social

groups women and men young and old and seek their participation in mitigation of adverse impact

as well as enhancement of project benefits

As the project will impact a number of ST families ERM will assess impacts on them and prepare a

Tribal Development Plan (TDP) which will contain a package of proposed impact mitigation measures

and project benefits ERM will implement a Free Prior Informed Consent (FPIC) process covering

affected Scheduled Tribe population The negotiation process leading to obtain FPIC will be agreed

on with the affected ST communities

Free Prior Informed Consent (FPIC) Process for STs

The FPIC Process will be taken up for Surajpur Parsula and Jawadi villages of Shajapur Site for the impacts on tribal population in given villages on the land under traditional ownership and customary use The process will also involve any nomadic tribes who may have claims of using the project site for grazing their livestock and camping during their annual migration The FPIC process will be divided into two phases as described below

Phase What to Do When to Do

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Before inviting bids for solar parks by concessionaire

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Contacts

Further information and queries related to the project can be obtained from RUMSL site office in

Shajapur and head office at Bhopal The information is also available at website of RUMSL

(httpwwwrumslcom)

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APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

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APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT FPIC

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

NEEMUCH SOLAR PARK

Badi village Kawai Village

Mama Basti Badi village Bardawada village

AGAR SOLAR PARK

Ladwan village Bijnakhedi village

SHAJAPUR SOLAR PARK

Chauma village Parsula village

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APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

BACKGROUND

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) RUMSL is facilitating developing

Solar Park of capacity of 450 MW at Shajapur on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards (International Finance Corporation and World Bank) for the Project

Project Details The proposed 450 MW Solar Park is located in Moman Badodiya and South Shajapur tehsils of

Shajapur District collectively referred to as Shajapur Solar Park The Shajapur Solar Park will be

spread across 11 villages in Shajapur amp Moman Badodiya Tehsil of Shajapur District comprising the

villages of Burlay Jawadi and Dhatrawada (for Unit 6) Parsula Dehripal Bijnakhedi Fawaka

Chauma Burlay (for Unit 7) and Surajpur Lalpur and Hanoti (for Unit 8) The land required for 450

MW Solar Park including solar fields roads and transmission and distribution network is 9872

hectares The Shajapur Solar Park plot comprises of three non-contiguous land parcels

The solar park will have three (3) units It is understood that each unit will have a different developer

Unit 6 of 105 MW capacity to be developed on an area of 2461 hectares of Private and

Government land

Unit 7 of 220 MW capacity to be developed on an area of 4859 hectare and

Unit 8 of 125 MW capacity to be developed on an area of 2552 hectare

Land Requirement and Status The Solar Park will largely use GoMP land (approx 88) and the remaining land is either private

land or Patta land The Government land required for the Solar Park will be leased by the government

of Madhya Pradesh and the private land will be purchased from the land owners as per the prevailing

laws and policies in the State of Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th

November 2014 of Government of MP)

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

1 Burlay 237 00 64 00 00 00 301

2 Jawadi 322 00 20 00 00 00 342

3 Dhatrawada 1722 00 97 00 00 00 1819

Sub- Total (unit

6)

2281 00 181 00 00 00 2462

4 Parsula 1162 00 00 52 00 00 1214

5 Dehripal 1111 00 124 00 94 00 1329

6 Bijanakhedi 954 00 226 00 00 00 1180

7 Fawaka 171 00 02 00 00 00 173

8 Chouma 327 00 95 00 00 124 546

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

9 Burlay 417 00 00 00 00 00 417

Sub- Total (Unit

7)

4142 0 447 52 94 124 4859

10 Surajpur 227 07 182 00 00 00 416

11 Lalupura 497 08 00 00 00 00 505

12 Hanoti 1319 125 185 00 00 00 1629

Sub- Total (Unit

8)

2043 140 367 00 00 00 2551

Grand Total 8466 140 995 52 94 124 9872

Source Land Data provided by RUMSL 18th June 2020

Transmission Line Each Solar Park Unit will have 33220 kV substations and the power generated from each unit (Unit 6

7 and 8) will be pooled to the 220 kV switching pooling substation The utility area is proposed near

the internal pooling substation located at the Unit 6 and Unit 8

Road Infrastructure Access to Unit 6 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The existing village road has a width of ~4-5 meter and existing

State highways has a width of ~75 meter The road length of ~25 km will be strengthened and

repaired to suit the need during the construction phase

Access to Unit 7 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The road length of ~2 km will be strengthened and repaired to

suit the need during the development phase

Access to Unit 8 The Unit is connected with village road from Jhonkar to Hanoti at a distance 0f ~6

km from Jhonkar The existing road is a two-lane bituminous concrete road with width ~7-75 meters

and a new bituminous road with width ~75 meters and length ~500 meters is proposed to connect

33220 kV plant substation The road length of ~2 km will be strengthened and repaired to suit the

need during the development phase

Water Requirement The total requirement for water is estimated as 323 kL day Developers shall establish bore-wells per

block with required approvals and directions to meet their requirements The entire water supply

system including provision for bore-wells within individual blocks shall be in the scope of the Project

Developer The water requirement for the green belt is estimated to be 7000 litres per day

Common facilities planned The common facilities such as RUMSL office fire-fighting equipment telecommunication

infrastructure medical dispensary weather monitoring station etc will be located at the pooling

substation area located at the Unit 6 The operations and maintenance of common facilities provided

like pooling substation intermediate substations shall be undertaken by RUMSL Ms RUMSL will

establish two Weather Monitoring Station at internal pooling substation (at each unit)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Project Implementation

The 450 MW Shajapur Solar Park will be constructed a time frame of ~21 months with construction

proposed to started in November 2020

Project Impacts Benefits and Mitigation Measures

RUMSL will identify stakeholders and prepare a schedule for consulting them on a regular basis in

construction phase It will also establish a grievance redress mechanism through which local

community can register their grievances and seek redress to any adverse impacts on them The

project through its ESIA process has identified a range of potential impacts and has planned to

implement appropriate mitigation measures The key impactsbenefits and proposed mitigation

measures are discussed below for your knowledge and suggestions for making them more effective

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D1 Moman Badodiya Unit 6

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D2 Moman Badodiya Unit 7

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D3 South Shajapur Unit 8

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact from Land Acquisition

Type of land impacted How Impacts will be addressed

Private Land (Purchased through MP

Mutual Consent Policy 2014

Adequate compensation at twice the value of land and assets as

per MP Mutual Consent Policy 2014

Benefits of Resettlement Action Plan-Livelihoods restoration Plan

Preference to households (rendered landless or with sub-optimal

holdings) of the families post selling land to the project for

employment opportunitiessmall contracts in the

Constructionoperation phase

Pattta Land (Negotiated purchase

through MP Mutual Consent Policy)

Patta is being treated at par with ownership for the land

procurement process and would have same benefits as of private

land owners

Government Land Used for Grazing

easements cultural heritage sites

water sources fuel wood collection and

collection of other resources

Provision for alternate grazing land for cattle near the project

village or confirmation of adequacy of remaining grazing land

Development of community fodder lots in available unoccupied

government land may be explored and covered in Resettlement

Action Plan

Provision of easements shall be maintained in order to not sever

the access to CPRs for the community

Government Land Informally

occupied Capturedencroached for

agriculture or grazing prohibiting use

by other people

RUMSL shall serve a three months advance notice to the project

affected persons (PAPs) to harvest standing crops andor avoid

growing fresh crops

In case the advance notice is not given RUMSL shall pay

compensation for crops at full replacement cost

ImpactsBenefits in Construction Phase

Impact Mitigation Measures

Temporary occupation of land

for construction phase activities

such as Labour Camps Safety

Setbacks Storage areas

Parking areas Other

construction related temporary

land requirements etc

Adequate lease rents to the land owners

Restoration of land to its original state or better at the time of handing it

back to the owners

Compensation for the loss of livelihoods to the users of the land required

for temporary use as this will temporarily economically displace them

Community Health and Safety

including accident risks for

domestic animals

The Contractor shall prepare Traffic Management Plan Workers Code of

Conduct and Health and Safety Plan and implement it after approval of

RUMSL

Stress on Community resources

- Water and Roads

There will be a worker Code of Conduct defined by RUMSL that prevents

workers and contractors from using the local resources like water forest

The contractor shall be asked to use Tanker water supply during the

summer months which are dry months in which water scarcity issues are

reported by the community

Noise Nuisance and Dust Install enclosures around construction area in order to reduce the extent

of noise and dust

Limit construction related activities to day time

Employment and

entrepreneurship opportunities

during construction

The sourcing of local labour wherever possible will be obligatory for the

Solar Project Developers and sub-contractors

Employment of members of SC-STs and vulnerable households will be

at a minimum of 30 of total workers or person-days of employment

Engagement of local vendors to the extent possible for the goods and

services required for the project during construction phase

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact Mitigation Measures

The RUMSL will establish a mechanism to audit subcontractors and

suppliers with respect to compliance of utilizing local labour and

resources

Impacts in Operation Phase

Impact Mitigation Measures

Community Health and

Safety

Community engagement and sensitization sessions should be re-organised at

the beginning of Operations phase in order to mention about the new

developments in the area and provide an understanding of the precautions to

be taken for safety

Impact on Employment RUMSL shall ensure that the Solar project developers (SPDs) advertise the

roles of Technical staff required during operations phases in the local

newspapers to enable hiring of competent people from nearby areas to the

extent feasible

Preference shall be given (to the extent feasible) to hire competent members

from PAHs for semi-skilled jobs like housekeeping or Security Guards

Impacts on Vulnerable Sections Women and Scheduled Tribes

Impact Mitigation Measures

Impacts on Indigenous

Communities Vulnerable

Groups

To Prepare an Indigenous Peoples PlanTribal Development Plan with special

benefits for Scheduled Tribes

Recognizing their right to Free Prior Informed Consent process and its

implementation

As part of the stakeholder engagement ensure adequate representation and

participation of the Scheduled Tribes

Impact on Women A Gender Action Plan will be prepared for the Project to assess and mitigate

gender specific impacts

Ensure that the employment of women from vulnerable households is

prioritised for the project

Efforts are made to support development of women owned enterprises in the

area through the LRP from where procurement for project related may be

prioritised

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APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

Page 1

शाजापर सोलर पारक रा पररयोजना वििरण दसतािज़

पषठभवि

नवीन और नवीकरणीय ऊरजा मतरजलय क सहयोग स मधय परदश सरकार मधय परदश म जमीनी गरिड स रडी

सौर ऊजाा पररयोजना का गरिकगरसत कर रही ह रीिा अलटर ा मगा सोलर गरलगरमटड (RUMSL) का एक

सािाजगरनक उपकरम िरा 2015 म सथागरपत हआ ह यह उपकरम सोलर एनरी कारपोरशन आफ इगरडया गरलगरमटड

(SECI) तथा मधयपरदश ऊजाा गरिकास गरनगम गरलगरमटड (MPUVNL) क साथ सयकत उपकरम क रप म सथागरपत

हआ ह शाजापर सोलर पाका की कल कषमता 450 मगा िाट होगी और इस सौर ऊजाा पाका को गरनजी -

सािाजगरनक साझदारी क तहत गरनमााण गरकया जाना परसतजववत ह

रीवज अलटर ज मगज सोलर वलवमटड (RUMSL) दवजरज ईआरएम इवडयज परजइवट वलवमटड (ERM) को अतरााषटर ीय

मानको (अतरााषटर ीय गरितत वनगम एि गरिशवबक) क अनसजर सौर पजका क पयजावरणीय और सजमजवरक परभजव

मलजकन (ESIA) क सजथ सजथ पनगरिासथापन कजया योरनज (RAP) और सवततर रप स समदाय की पिा

सगरित सहमगरत (FPIC) परवियज क वलए अनबगरित गरकया गया ह

पररयोजना री परिख जानरारी

450 मगा िाट का परसतागरित सोलर पाका शाजापर गरजल क मोहन बड़ोगरडया और शाजापर तहसील क अतगात

शाजापर सोलर पाका क नाम स जाना जाएगा यह सौर ऊजाा पाका 11 गाािो क कषतर म बनगा यह 11 गााि इस

परकार ह बल जिादी और ितिादा (इकाई 6) पारसला दहरीपल बीजनखड़ी फिाका िौमा बल (इकाई

7) और सरजपर लालपर तथा हनोती (इकाई 8)

इस 450 मगा िाट सोलर पाका हत कल 9872 हकटर जमीन की आियशकता होगी गरजसम सोलर फीलड

सड़क टर ासगरमशन एि गरितरण नटिका शागरमल होगा पाका तीन अलग इकाईयो म गरिकगरसत होगा ऐसा

अनमान ह गरक परतयक इकाई का गरनमााण अलग-अलग गरनमााताओ दवारा गरकया जाएगा

105 मगा िाट कषमता िाली इकाई 62461 हकटर कषतर पर सरकारी तथा गरनजी जमीन पर गरिकगरसत

होगी

220 मगा िाट कषमता िाली इकाई 74859 हकटर कषतर पर गरिकगरसत होगी तथा

125 मगा िाट कषमता िाली इकाई 82552 हकटर कषतर पर गरिकगरसत होगी

Page 2

जिीन री सथिवि एि अविगरहण

सौर ऊजाा पजका लगभग 88 मधय परदश की सरकारी भवम कज उपयोग करगज और शष भवम यज तो वनरी यज

पटटज भवम रहगी सोलर पजका क वलए आवशयक रजरसव भवम मधय परदश सरकजर दवजरज पटट पर दी रजएगी और

वनरी भवम मधय परदश रजजय म परचवलत कजननो और नीवतयो क अनसजर भवम मजवलको स खरीदी रजएगी

(Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP)

कर

गााि

रा

नाि

सरर

ारी

जि

ीन आ

िवि

ि

(NR

ED

) ह

कटर

सरर

ारी

जि

ीन व

िसि

ि प

आि

विि

नह

हकट

वनज

ी ज

िीन

कटर

पटट

री

जि

ीन

हकट

उदय

ावन

री

हकट

िौस

िी

िाल

ाब ह

कटर

रल

जि

ीन (

सरर

ारी

जि

ीन +

वनज

ी ज

िीन

)

हकट

1 बल 237 00 64 00 00 00 301

2 जािादी 322 00 20 00 00 00 342

3 ितरािदा 1722 00 97 00 00 00 1819

योग (इराई 6 ) 2281 00 181 00 00 00 2462

4 परसला 1162 00 00 52 00 00 1214

5 दहरीपल 1111 00 124 00 94 00 1329

6 बीजनखड़ी 954 00 226 00 00 00 1180

7 फािक 171 00 02 00 00 00 173

8 िौमा 327 00 95 00 00 124 546

9 बल 417 00 00 00 00 00 417

योग (इराई 7) 4142 0 447 52 94 124 4859

10 सरजपर 227 07 182 00 00 00 416

11 लालपर 497 08 00 00 00 00 505

12 हनोती 1319 125 185 00 00 00 1629

योग (इराई 8) 2043 140 367 00 00 00 2551

Page 3

रल 8466 140 995 52 94 124 9872

सदभक रीिा अलटर ा मगा सोलर गरलगरमटड दवारा गरदया गया जमीन का डाटा 18 जन 2020

िासविशन लाइन

परतयक सोलर पाका इकाई क 33220 किी क सब सटशन होग तथा परतयक इकाई (6 7 8) स 220 गरकलो

िाट की ऊजाा सब सटशन एकतर गरकया जाएगा आतररक पगरलग सब सटशन इकाई 6 और 8 क समीम

सथागरपत करना परसतागरित ह

सड़र वनिाकण

इराई 6 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रोवक आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

गााि क रासत की िौड़ाई लगभग 4-5 मीटर तथा राजयमगा की िौड़ाई 75 मीटर ह सौर ऊजाा पाका क

गरनमााण हत 25 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 7 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रो की आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 8 िर पहाि

इकाई 8 िाम झोकर स 6 गरकलोमीटर दर िाम झोकर स िाम गरहनोती को जान िाली सड़क स जड़ी ह यह

रासता डबल लन डामर रासता ह गरजसकी लबाई 7-75 मीटर ह एक नई डामर रोड गरजसकी लबाई 500

मीटर तथा िौड़ाई 75 मीटर ह और जो 33220 किी क सब सटशन को जोड़न क गरलए बनाई जाना

परसतागरित ह सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया

जाएगा

पानी री आिशयरिा

यह अनमान ह की परगरत गरदन लगभग 323 गरकलो लीटर पानी आिशयकता होगी पानी की पगरता क गरलए ठकदार

दवारा परगरत बलॉक बोररग की रजएगी सौर ऊजाा पाका क गरनमााण क दौरान परतयक बलॉक क पानी की सपलाइ

की वयिसथा का परा खाका गरजसम बोररग करना भी शागरमल ह ठकदार अपन परसताि म द ग हररत पटटी क

गरलए परगरत गरदन अदाजन कल 700 लीटर पानी की आियशकता होगी

Page 4

सािानय सवििाओ री उपलबधिा

RUMSL का ऑगरफस अगरि शमन सटशन टली कमयगरनकशन (फोन) गरिगरकतसालय गरडसपनसरी मौसम की

जानकारी सटशन इतयागरद इकाई 6 क समीप पलीग सब सटशन पर सथागरपत हाागी पगरलग सबसटशन तथा

मधयमिती सबसटशन गरक तमाम सगरििाओ का सिालन एि दखरख RUMSL दवारा गरकया जाएगा RUMSL

आतररक पलीग सटशन पर दो मौसम अनशरिण सटशन सथागरपत करगा

पररयोजना रा वकरयानवयन

450 मगा िाट का शाजापर सोलर पाका का गरनमााण निमबर 2020 स शरिात कर अगल 21 महीनो म परा

होना अपगरकषत ह

पररयोजना र परभाि लाभ ििा शिन उपाय

सौर ऊजाा पाका क गरनमााण क दौरान RUMSL गरिगरभनन गरहतसािको की पहिान कर उनस गरनयगरमत ििाा और

सलाह मशिरा करतज रहगज पाका गरनमााण क दौरान िामीणो की गरशकायतो को समझन एि उनह दर करन क

गरलए गरशकायत गरनिारण ततर की वयिसथा RUMSL करगा तागरक गरशकायतो का गरनपटारा शीघर हो सक और

लोगो पर हो रह नकारातमक परभाि को दर कर सक पररयोजना दवारा ESIA की परगरकरया क माधयम स सभागरित

परभािो को गरिनहनहतकर उनक गरनपटार हत उगरित और परभकारी उपाय करगा अपगरकषत परभािलाभ और शमन

क उपाय गरनमन गरलनहखत ह तागरक आपक सझािो क आिार पर उनह और परभािी बनाया जा सक

Page 5

नकशा 1 िोहन बदोवदया इराई 6

Page 6

नकशा 2 िोहन बदोवदया इराई 7

Page 7

नकशा 3 शाजापर इराई 8

Page 8

जिीन अविगरहण रा परभाि

परभाविि जिीन रा पररार परभाि रा वनिारण

वनजी जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत 2014 क तहत

खरीदी गरनजी जमीन)

मधय परदश आपसी सहमगरत भगरम करय नीगरत 2014 क तहत

पयाापत मआिजा जमीन या सपगरत क मलय स दगना

पनिासन कायायोजना ndash आजीगरिका पनजीिन योजना स लाभ

पररयोजना हत अगरििहण क बाद पररिार गरजनक पास बहत ही

कम जमीन बिी ह या भगरमहीन पररिारो को पराथगरमकता

गरनमााण क दौरान गरकरयानवयन क समय उनक गरलए काम क

अिसर छोट काया अनबि काटर कट म पराथगरमकता दना

पटटिाली जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत2014 क तहत

तय कर खरीदी गए जमीन)

जमीन क अगरििहण क दौरान पटटा िारको को गरनजी मागरलक की

तरह समझत हए उनक गरलए गरनिााररत सार फायद दना

सररारी जिीन िरनोई सासकगरतक

िरोहर जल शरोत जलाऊ लकड़ी

सिहण गरनसतार की जमीन

अनयससािनो का सिहण क उपयोग म

आन िाली जमीन

पररयोजना क समीप क गााि म िरनोई क गरलए जमीन की

िकनहिक वयिसथा करिाना या अगरििहण क बाद शर जमीन म

गााि क गरलए पयाापत िरनोई की जमीन सगरनगरित करना

खाली पड़ी सरकारी जमीन पर सामदागरयक िारागाह की खप

गरिकगरसत करन हत पनिासनकाया योजना म सभािना खोजना

समदाय क सामदागरयक ससािनो तक पहाि बनी रह उस सगरनगरित

करन क गरलए भारतीय सख भोग अगरिगरनयम 1882 क पराििानो

का पालन गरकया जाएगा

सररारी जिीन अिि कबजिाली

जमीन खती या िराई क गरलए कबजा

अगरतकरमण गरकया गया हो लोगो दवारा

सािाजगरनक उपयोग बागरित गरकया गया

हो

RUMSL पररयोजना स परभागरित लोगो को तीन महीन का पिा

नोगरटस दगा तागरक ि अपनी लगी हई फसल काट सक या नई

फसल न बोए

यगरद गरकसी कारण िश पिा नोगरटस नही दी गयी तो RUMSL परी

फसल की कीमत मआिज क तौर पर द ग

Page 9

वनिाकण र दौरान परभािफायद

परभाि शिनवनपिार र उपाय

गरनमााण क िरण क दौरान गरिगरभनन गगरतगरिगरियो

क गरलए जस मजदर रहिास (क प) सरकषा

वयिसथा भडारण वयिसथा िाहन पागरकि ग कषतर

तथा गरनमााण सबिी अनय जमीन की असथायी

आिशयकता पड़ना आगरद

जमीन मागरलको को पयाापत लीजगरकराए की वयिसथा करना

जमीन मागरलको को उनकी जमीन लौटन क समय वयिनहसथत

रप स सिार कर परानी अिसथा या उसस भी अचछी करक

लौटाना

जमीन मागरलको को उनक जमीन स असथायी रप स हटान एि

उनकी आजीगरिका क नकसान क एिज म मआिजा दना

सामदागरयक सवासथय एि सरकषा तथा घरल

उपयोगी पशओ की दघाटनाका जोनहखम

ठकदार सभी की सरकषा क गरकए आिागमन परबिन पलान

तयार कर ग मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयिहार क गरनयम) और सवासथय एि सरकषा की योजना

बनाकर RUMSL स अनमोदन क पिात ही गरकरयानवयन कर ग

सामदागरयक ससािनो पर दबाि ndash पानी एि

सड़क

RUMSL दवारा मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयहार क गरनयम) गरनिााररत गरकए जाएग गरजसस

कमािारी तथा ठकदार सथानीय ससािनो जस पानी जगल

आगरद का नयायोगरित उपयोग कर पाएग

गगरमायो क समय पानी की गरकललत को दखत हए ठकदार को

यह गरनदश होग की िह पानी क टकर स पानी गरक पगरता कर

शोर बािा एि िल गरनमााण सथल पर दीिार लगानासथागरपत करना तागरक शोर एि

िल कम फल

गरनमााण काया किल गरदन क समय ही करनागरनमााण काया रात

क समय परगरतबगरित करना

गरनमााण क दौरान रोजगार तथा वयिसाय क

अिसर

यथासभि सोलर पाका गरिकगरसत कतााओ तथा ठकदारो आगरद

क गरलए सथानीय लोगो एिम मजदरो को काया दन की

अगरनिायाता होगी

कल रोजगार गरदिस या कल कमािाररयो म कम स कम 30

परगरतशत मजदरकमािारी अनसगरित जागरत - जनजागरत या िगरित

पररिार स होग

सोलर पररयोजना गरनमााण क समय गरकसी भी मालसामिी या

सिा की जररत यथासभि सथानीय गरिकरताओ क माधयम स

की जाएगी

RUMSL गरनमााण क दौरान एक अककषण ततर की वयिसथा

करगा तागरक ठकदार गरिकरता सिा परदाता सथानीय ससािनो

तथा मजदरो का यथोगरित उपयोग कर सक

Page 10

वकरयानवयन र सिय परभाि

परभाि शिन वनपिार र उपाय

सामदागरयक सवासथय एि

सरकषा

सोलर पाका क गरनमााण की परगरकरया क दौरान गरनमााण स होन िाल नए

बदलाि क सबि म समदाय को सिदनशील बनाना हत बठको का

आयोजन करना और सरकषा क गरलए एहगरतयात बरतन हत समय समय पर

गरििार गरिमशा और ििााए करना

रोजगार पर परभाि RUMSL यह सगरनगरित करगा की पररयोजना क गरनमााण क दौरान

तकनीकी कमािाररयो की भती का गरिजञापन सथानीय अखबारो म छप

तागरक योगय सथानीय लोगो को भती गरकया जा सक

अिा कौशल कषमता िाल काम जस कायाालय की दखरख सरकषा गाडा

आगरद पररयोजना स परभागरित पररिारो को पराथगरमकता क आिार पर

गरदय जाए

िविि िगक पर परभाि िवहलाए एि अनसविि जनजावि र सदभक ि

परभाि शिन वनपिार र उपाय

अनसगरित जनजागरत एि

िगरित िगा पर परभाि

अनसगरित जनजागरत समदाय क लाभ को धयान म रखत हए मलगरनिासी

समदाय क गरलए योजना आगरदिासी गरिकास की योजना बनाई जाएगी

सवततर पिा सगरित सहमगरत क आिार पर FPIC की परगरकरया का

गरकरयानवयिन गरकया जाएगा

गरिगरभनन गरहतसािको को शागरमल करत समय अनसगरित जनजागरत समदाय

का पणा रप स परगरतगरनगरितव और भागीदारी को सगरनगरित गरकया जाएगा

मवहलजओ पर परभाि जडर एकशन पलान का गरनमााण गरकया जाएगा तागरक पररयोजना की िजह

स जडर गरिगरशषट परभािो का आकलन कर उनह गरनपटा या कम करन का

परयास हो सक

पररयोजना म िगरित िगा की मगरहलाओ को रोजगार पराथगरमकता गरमल यह

सगरनगरित गरकया जाएगा

पररयोजना कषतर म मगरहला उदयमी गरिकरता सिा परदाताओ को सहयोग

करन क परयास गरकए जायग गरजसस पररयोजना म काम आन सामिी

समान की खरीदी उनस की जा सक

Page 11

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE FPIC FACILITATOR

Page 12

Screening of Facilitating AgencyIndividual Expert for FPIC

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to

undertake an Environmental and Social Impact Assessment (ESIA) of three solar parks

including internal evacuation infrastructure and associated transmission lines of aggregate

capacity of 1500 MW in the Neemuch Agar and Shajapur Districts of Madhya Pradesh India

(hereinafter referred to as the lsquoProjectrsquo) one of the key tasks as part of this assignment is to

secure Free Prior Informed Consent in keeping with the provisions of IFC PS 7 For this

purpose ERM has undertaken the task of identifying a Facilitation AgencyIndividual (FA) to

assist with the FPIC process This document presents the results of the screening and

shortlisting process for the FPIC FA

Approach and Methodology

The approach and methodology followed for shortlisting of FPIC FAs is presented below

1 Two stage approach was followed for the selection of FPIC Facilitation

AgencyIndividual Initially desk research was carried out to identify Institutions (Universities

Government Departments and Research Institutes etc) NGOs and INGOs located in

Madhya Pradesh state In parallel the ERM team also identified the criterion which will be

used to shortlist the potential Facilitating Agencies The criteria used for screening included

qualification profile affiliation with the type of institutionsorganizations nature of

worksprojects completed working experience with Bhils in MP experience in natural

resource management and rural livelihoods conducting meaningful consultation community

mobilization and stakeholder engagement familiarity with World Bank Group safeguardsrsquo

policies and procedures comfort with written and spoken English and local dialects etc

2 In the second stage the potential candidates from these institutions were individually

approached to further assess their suitability and find out their availability for the assignment

Convenient date and time for the personal discussion and interview with them was sought

Accordingly the ERM team organized interview with the available candidates at Bhopal

3 The team27 of Environmental Resource Management (ERM) New Delhi visited

Bhopal during 6-8 January 2020 in order to undertake face to face meetings with these

organizations and individuals identified

Screening

4 The screening against the preferred criteria was undertaken for the potential

candidates available to work as FA for FPIC None of these agenciesindividuals reported to

have worked for a FPIC process earlier Also the candidates interviewed are not familiar

with the World Bank and IFC safeguards related policies and procedure applicable for IPs in

energy and other infrastructure development sectors They are however interested in

working and learning from the project The candidates also had limited experience in the

field of natural resource management and rural livelihoods Details of the screening of

potential candidates is given below

27 Team comprised of Ramesh Swarankar Freelance Consultant and Akshita Mishra Senior Consultant ERM

Page 13

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Amitav Singh

and Leena

Singh

Debate Lok

Nyas (DEBATE)

Duplex C-22

Alkapuri Near

DRM Office

Habibganj

Bhopal-462024

0755-2985007

0755-2417656

9425018144

9425004556

debateindiag

mailcom

MA Social

Works

The key persons are active for

last 3 decades in Social Work

The Debate Trust was

incorporated in 2002-03 and has

more than 15 years of experience

in working with PRIs in Madhya

Pradesh with an focus in Tribal

(Schedule-V) Areas Mr Amitav

Singh is a member of National

Committee for Monitoring of

MNREGA

Ms Leena Singh has also

experience of working with rural

women for more than 15 years

Have

worked

with Bhils

of

Jhabua

Yes Yes Yes

Mr Amitav

Singh is a

leading trainer

for PRA and

Social Audits

by Panchayat

Raj Ministry

No

But was

part of the

FPIC

training

provided

by

ActionAid

Yes

(requires

support in

Reporting)

Score 18 3 2 3 3 3 2 2

Dr Jose

Payyappilly

Address 142

Nyay Nagar

Sukhliya

Indore

Contact-

7828355557

PhD MA

in Social

Work amp

Sociology

About three decades experience

of working on Health HIVAIDS

CSR Literacy Adult education

minority education related

projects and programs funded by

GoI GoM Clinton Foundation Bill

amp Melinda Gate Foundation

UNAIDCARE World Action

Forum VHAI Christian Aid NGO

such as Samarthan in MP

Chhattisgarh and other states It

Has

worked

with Bhils

as part of

a larger

communi

ty in

Jabhua

No No Yes

Trained in

traditional

communicatio

n systems

folklore

folktale

Familiar with

planning

strategy and

community

Associated

with the

network of

NGOs CSOs

and village

level

functionaries

Worked with

local

governments

and elected

No Yes

Page 14

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Email Id

payyappillyjose1

6gmailcom

jose_soolyaho

ocoin

includes the districts in MP with

IPs population

Dr Jose has worked as team

leader director executive director

and other positions Also worked

as Local Governance and BCC

Advisor to DANIDA for Health

Services Program State Media

Coordinator State Resource

centre Adult Education MP

Program Producer Radio Veritas

Asia Manila Philippines

stakeholder

engagement

panchayat

representative

s

Score 14 2 1 1 3 3 1 3

Parushram

Tiwari

Address- C-443

Sarvdharm

Colony Kolar

Road Bhopal

Contact-

09425065132 amp

8319540266

Email Id

drpram42gma

ilcom

PhD

MPhil MA

( Sociology

More than 20 year experience of

working as consultant at different

positions in Public health

HIVAIDS literacy education

nutrition urban development and

governance projects and

programs in MP including Malwa

area and other states

These projects were funded by

UNICEF UNFPA ADB Clinton

Foundation Women amp Child

Development Rural

Development Urban

Administration amp Development

No No Yes Has

worked as

the State

Project

Manager

for Sanjhi

Sehat

project of

MP State

Rural

Livleihood

Mission

Yes Is good

with

coordination

and

communicatio

n

Yes has

experience in

Planning

management

and execution

capacity

building

training and

Networking

and advocacy

Liaison

support and

team building

No Will need

support in

documentatio

n

Page 15

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

State AIDS Control Society of

GoMP and the NGO partners

Dr Tiwari was the Project Director

and District Program officer under

National Literacy Mission at

District Collector offices at Dhar

and Indore MP respectively

during 1991-1998

Score 13 1 1 2 3 3 1 2

Mr Sandip Naik

Adddress-C-55

Kalani Bagh

Dewas MP

Pin Code

455001 India

Contact- +91-94

2591 9221

Email id

naiksandigmai

lcom

Diploma in

Developm

ent

Facilitation

from TISS

Mumbai

MPhil

MA in

Rural

Developm

ent and

English

Literature

About 20 year experience of

working on health nutrition

education governance and

women empowerment with

governments of MP

Worked with NGOs International

agencies and MP government on

senior positions

Since 2014 working with CRY

and TDH on issues of malnutrition

and preparing booklets

brochures pamphlets on nutrition

adolescents issues and childrenrsquos

health Also written textbooks

teachers learning material and

manuals for state govt for SCERT

etc

Yes No No Yes Yes No Yes

Page 16

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Score 14 2 1 1 3 3 1 3

Dr Rahul Dev

Bahawsar

Address Block

No 14 Flat No

5 Shalimar

Enclave E-3

Arera Colony

Bhopal ndash

Madhya

Pradesh

Contact-

08223015124

Email

rbhawsarrediff

mailcom

rahuldevbhawsa

rgmailcom

PhD amp

MPhil in

Population

Studies

from IIPS

Mumbai

MSC

Statistics

24 years experience in

monitoring evaluation and

implementation of programs in

health and social development

sectors in MP Rajasthan and

Gujarat states

Engaged in nutrition assessment

survey in 18 districts of MP states

including IPs dominated districts

such as Dhar Jhabua with Bhil

population and coordinated with

state health women amp child

development and rural

development departments during

the study period

Involved in conducting health

surveys at national level

Worked as a staff with Health

Management Research Institute

Jaipur and IPE Global Consulting

Firm New Delhi etc These

projects were funded by DFID

UNICEF UNFPA GoI GoMP

etc

Yes has

worked

in

Jhabhua

and Dhar

No Yes Has

worked

with State

Rural

Livelihood

Mission

Somewhat

His strengths

lie more

towards

quantitative

research

Somewhat No Yes

Page 17

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Working as freelance expert and

has a registered consultancy firm

that is inactive

Score 12 2 1 2 2 2 1 2

Ms Aastha

Anuragi

Address 173

Sanjay

Complex

Phase-2

Geetanjaly

Square Bhopal-

462003

Contact-

9425365216

8160123726

Email

aasthaanuragi

gmailcom

MBA Rural

Manageme

nt amp MSC

in Physics

More than 15 year experience of

working particularly imparting

training to different stakeholders

in drinking water and sanitation

Swachh Bharat ODF missions

WASH livelihood menstrual

hygiene etc Master trainer for

total sanitation program

Worked as consultant in MP

Chhattisgarh West Bengal UP

Gujarat Jharkhand Bihar states

These projects were funded by

World Bank Water Aid UNICEF

DFID GoI State governments

and ICIMOD Nepal

No No Yes has

worked as

a project

facilitator

with MP

livelihood

project

Yes Yes No No

Score 12 1 1 2 3 3 1 1

Note The scoring for each criterion was as follows 0- Not applicable 1- Not Meeting the Requirement 2- Partially meeting the requirement 3- Completely fulfilling the requirement

Page 18

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

Page 19

TERMS OF REFERENCE FOR FPIC FACILITATION AGENCY

Background

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake an

Environmental and Social Impact Assessment of three solar parks including internal evacuation

infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch

Agar and Shajapur Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work for the project ERM is required to assess the impacts on the indigenous

marginalized communities within the site and its influence area prepare an Indigenous Peoples Plan

(IPP) apart from other ESIA amp RAP deliverables The project is also required to conduct a FPIC process

covering affected Scheduled Tribe (ST) population

Villages to be covered in FPIC Process

The project area has a few small ST settlements and in few others a small number of ST households

live along with a majority non-ST population Following 5 villages are identified for carrying out FPIC

process

Solar Park Selected ST villages

for FPIC

Number of

Households

Name of ST

Community

Agar Solar Park Ladwan 12 Bhil

Shajapur Solar Park Parsula 41 BhilBhilala

Neemuch Solar Park Badi and Kawai 97 BhilBhilala

Note Additional ST families in neighbourhood villages of the same Solar Park will be made part of this

process to a limited extent

Phases in FPIC Process

The FPIC process will be divided into two phases as described below

Phase What to Do Schedule

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Apr 2021^

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

May-Aug 2021^

^ Activities were suspended in April 2021 due to break out of the second wave of Covid-19 in India These

activities will be re-scheduled once Covid-19 second wave gets over

Deliverables and Responsibilities

Phase Responsibilities Deliverable

I Identification of STs Representatives and formation of committees

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Documentation of capacity building of STs Representatives on FPIC

Mutually agreed FPIC Process and composition of local ST Representative committees

Page 20

Phase Responsibilities Deliverable

Hindi Translation of TDPIPP and designing Information sharing tools

Participatory mapping of all natural resources and cultural sites to be impacted

Participatory assessment of impacts on Tribal population

Identification of Livelihood and Welfare programs to be included in Draft TDP

Inventory of natural resource and cultural sites

Documentation of participatory process of impact assessment

Note on livelihood and welfare programs

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation (Photos Video MoMs for each meetingsevents) of FPIC process

The revised package in Draft TDP and a mutually agreed Draft FPIC Agreement

Personnel Requirement

The FPIC Facilitation Agency will require to mobilize following key personnel for completing these tasks

Designation Desired Qualification and Experience

Coordinator The coordinator to be a post-graduate in social sciencessocial work with at

least 15 years of experience in ruraltribal development Prior involvement in

FPIC related work with prominent civil society organizations or multilateral

development finance organizations will be preferred

Facilitator (Male) The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in facilitation of participatory rural appraisals The

facilitator needs to have sound knowledge of livelihood issues in Malwa

region of Madhya Pradesh and must have worked with Panchayati Raj

Institutions for their capacity building The facilitator should be familiar with

the local dialect (Malwi) spoken in Malwa region

Facilitator

(Female)

The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in working with rural women She should have

knowledge of livelihood and social context of women in Malwa region She

should have prior experience in facilitating participatory rural appraisal

processes involving rural women

Documentation

Assistant

The documentation assistant should be a Graduate in social sciencesmass

communication She should have at least 5 years of experience in ruraltribal

development and have carried out process documentation of development

projects She should have a good command over Hindi and should be

familiar with Malwi dialect

Community

Mobilizer

The community mobilizer should have passed higher secondary and have

experience of working with any NGO for at least 2 years She should have

good communication skills She will provide all logistical support necessary

to ensure participation of maximum number of people She also helps

Documentation Assistant in photo and video documentation of the FPIC

process

Organization Profile

The organization should have at least 10 years of experience in working in rural and tribal

development issues in Madhya Pradesh The organization should have a reputation of successfully

implementing projects related to community mobilization and capacity building They should have

Page 21

prior experience of working with tribes and should be known for their dedication and commitment

towards tribal rights and promoting their development

The business of sustainability

ERM has over 160 offices across the following

countries and territories worldwide

Argentina

Australia

Belgium

Brazil

Canada

Chile

China

Colombia

France

Germany

Ghana

Guyana

Hong Kong

India

Indonesia

Ireland

Italy

Japan

Kazakhstan

Kenya

Malaysia

Mexico

Mozambique

Myanmar

The Netherlands

New Zealand

Norway

Panama

Peru

Poland

Portugal

Puerto Rico

Romania

Russia

Senegal

Singapore

South Africa

South Korea

Spain

Sweden

Switzerland

Taiwan

Tanzania

Thailand

UAE

UK

US

Vietnam

ERM India Private Limited

Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

wwwermcom

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page iv

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

List of Figures

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages 24

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages 25

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages 28

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages 29

Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages 33

Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages 34

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages 35

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments 56

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process 74

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

CONTENTS

Acronyms and Abbreviations

Name Description

CSO Civil Society Organizations

DDMF Discussion and Decision Making Framework

DPR Detail Project Report

DREO District Renewable Energy Officer

ESIA Environment and Social Impact Assessment

ESS Environment and Social Standards

FA Facilitation Agency

FPIC Free Prior Informed Consent

FPIC-FA FPIC Facilitation Agency

FPICon Free Prior Informed Consultation

GAP Gender Action Plan

GFN Good Faith Negotiation

GN Guidance Note

GoMP Government of Madhya Pradesh

GP Gram Panchayats

HO Head Office

ICP Informed Consultation and Participation

IFC International Finance Corporation

IPDP Indigenous Peoples Development Plan

IPP Indigenous Peoples Plan

Ips Indigenous Peoples

JV Joint Venture

LRP Livelihood Restoration Plan

MC Mediation Committee

MNRE Ministry of New and Renewable Energy

MPLRC Madhya Pradesh Land Revenue Code

MPUVNL Madhya Pradesh Urja Vikas Nigam Limited

MW Mega Watt

NGO Non-Government Organizations

NOC No Objection Certificate

OBC Other Backward Castes

OP Operation Policy

PPP Public Private Partnership

PRA Participatory Rural Appraisal

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CONTENTS

Name Description

PS Performance Standard

RAP Resettlement Action Plan

RPO Renewable Purchase Obligation

RUMSL Rewa Ultra Mega Solar Limited

SC Scheduled Caste

SEP Stakeholder Engagement Plan

SHG Self Help Group

SPD Solar Park Developer

SPO Solar Purchase Obligation

ST Scheduled Tribe

TDP Tribal Development Plan

ToR Terms of Reference

WB ESF World Bank Environment and Social Framework

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

1 INTRODUCTION

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Impact Assessment (ESIA) including Resettlement and

Rehabilitation Action Plan (RAP) of three solar parks including internal evacuation infrastructure and

associated transmission lines of aggregate capacity of 1500 MW in the Neemuch Agar and Shajapur

Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work ERM is required to assess the impacts of the Project on the Indigenous

Peoples (IPs) or Scheduled Tribe (ST) and develop an approach and implement the process of Free

Prior Informed Consent (FPIC) The villages in Table 11 were identified to be covered in the FPIC

process during the scoping stage The intention of conducting FPIC process involving ST families in

these identified villages was communicated to the Sarpanch1 and a project information sheet (in

Hindi) was shared around Dec 2019

Table 11 Villages to be covered in FPIC Process

Solar Park Selected ST

villages for FPIC

Number of

Households

Name of ST

Community

Date on which Gram

Panchayat was informed

about FPIC Process

Agar Solar Park Ladwan 12 Bhilala 19th Dec 2019

Shajapur Solar Park Parsula 41 Bhilala 30th Jan 2020

Neemuch Solar Park Badi and Kawai 61 Bhil and Bhilala 5th and 6th Dec 2019

The Covid-19 pandemic brought restrictions for finalizing the project boundary and preparation of

ESIA Reports between Mar 2020 and Jun 2020 ERM initiated the FPIC related works and submitted

a Memo on selection of FPIC villages dated 29th Jun 2020 which reviewed the government land

allotment and triggers for FPIC

The FPIC Approach Paper (current document) is based on the understanding of the socio-political

context within which the affected STIPs population lives and suggestions received from the

prominent ST representatives with whom a preliminary round of discussions was held The Discussion

and Decision Making Framework (see Section 8) is accepted by RUMSL and was planned to be taken

back to the affected ST community for discussion and acceptance in Apr 2021 (see Section 832)

This has been delayed due to second wave of Covid-19 which started in Apr 2021 and decision on

further visits and consultations will be undertaken based on how situation unfolds in the coming

weeks The FPIC Approach paper will be finalized after the Discussion and Decision Making

Framework is discussed with ST Committees representing affected ST communities and agreed by

them

11 Project Background

The Government of India has identified the solar power sector as one of the critical components for

infrastructure development and overall economic growth The Government of Madhya Pradesh

(GoMP) through Ministry of New and Renewable Energy (MNRE) is developing ground mounted grid

connected solar power projects in Madhya Pradesh International Finance Corporation (IFC) is

providing investment advisory services to RUMSL thereby enabling Government of Madhya Pradesh

(GoMP) to develop the project on Public Private Partnership (PPP) mode and to support GoMP in

1 The rural local self-government bodies in India are known as Gram Panchayat which comprises of several wards Each ward

elects a ward member to represent them The Gram Panchayat thus comprises of multiple elected Ward Members The Chair Person of these elected local body is known as Sarpanch The vice chairperson of the Gram Panchayat is known as Upsarpanch or Naibsarpanch All adult electorate of a Gram Panchayat constitute Gram Sabha or General Assembly of the Gram Panchayat

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 2

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

meeting its energy requirements and in the process meet its Renewable Purchase Obligation (RPO)

and Solar Purchase Obligation (SPO)

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) Its primary objective is to develop

and facilitate development of large scale solar power projects in the state of Madhya Pradesh

RUMSL is planning to develop three solar parks (see details in Table 12) and their associated

internal evacuation infrastructure and transmission lines The World Bank had agreed to provide

financial support for the Project

Table 12 Salient Features of the Project

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Capacity and Configuration

3 Units (Units 1 2 3) adding up to 500 MW

2 Units (Units 4 and 5) adding up to 550 MW across Susner (Unit 4) and Agar (Unit 5)

3 Units adding up to 450 MW across Moman Badodiya (Units 6 and 7) and South Shajapur (Unit 8)

Total Land Area as of 24 June 2020

Unit 1 3515 ha Unit 2 34713 ha Unit 3 36701 ha Total 106573 ha

Unit 4 60809 ha Unit 5- 79918 ha Total 140758 ha

Unit 6- 2462 ha Unit 7 4859 ha Unit 8 2551 Total 9872 ha

Government Land (ha) allotted as of 24 Jun 2020

67819 ha

Allotment of additional 28979ha is under process Thus the total government land area is 962949 ha

127338 ha 931 ha allotted and additional 14ha to be allotted

Date of Government Land allotment

Allotment Date

Area in Ha

17-01-2018 23868

30-05-2017 43951

Total 67819

Allotment Date

Area in Ha

28022019 5633

28022019 7053

21062019 1495

20-06-2019 15925

28022019 283

20062019 19714

280202019 1683

21012019 3492

04012018 602

09082018 2669

30112016 5562

02012018 5699

02012018 16116

06012018 17663

09082018 15583

Total 127137

Allotment Date

Area in ha

26-05-2017 914

26-05-2017 3052

26-05-2017 2011

11-12-2017 11261

11-12-2017 1171

11-12-2017 171

11-12-2017 1386

11-12-2017 4015

11-12-2017 4596

11-12-2017 9545

11-12-2017 1763

26-05-2017 16461

28-06-2019 2675

28-06-2019 6134

Total 931

Private Land 1862 ha 1342 ha 9951 ha

Patta land 7572 ha 0 515 ha

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 3

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Aspect Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Proposed Commissioning Date

Tender and bid process tasks completed

- Start of registration downloading of the RFP access to Data Room on 26th Jan 2020

- Facilitation of site visit 26 to 28th Feb 2020

- Issue of Draft Project Agreements on 15th Jun 2020

- First pre-bid meeting was held on 30th Jun 2020

- ESIA Reports was issued on 16th Oct 2020

Tender and bid process schedule ahead

- Second pre-bid meeting on 30th Mar 2021

- Proposal due date for 3 sites between 3rd Jun 2021 and 18th Jun 2021

- Financial proposal opening between 14th Jun and 28th Jun 2021

- Reverse Auction Process 17th Jun and 30th Jun 2021

Purchase of Private land between Apr and Jun 2021

Target date for providing SPD land access June 2021

Indicative construction time of 19 months

Target date for commissioning of Solar Park Nov 2022 It is understood that RUMSL will initiate a process of hand over of balance government land to revenue department no longer required for the project

12 Timeline of Various EampS Studies

The allotment letters of the government land were issued at different points of time between 2017 and

2019 The boundary demarcation (tarmeem2) of these allotted government land for the 3 solar parks

was completed in October 2020 RUMSL is planning to initiate private and patta land procurement to

start in Apr 2021 and all sale agreements are signed by Jun 2021

The timeline of ESIA studies of these 3 Solar Parks is provided in Table 13 below

Table 13 The status of ESIA Study Components and Community Engagement

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

ESIA Field

visits

December 2019 December 2019-

January 2020

January ndash February

2020

September 2020

Report Final ESIA

submitted in

October 2020

Final ESIA

submitted in

October 2020

Final ESIA submitted

in October 2020 Draft ESIAs for

Neemuch TL and

Agar- Shajapur

TL submitted in

November 2020

RAP-

LRP

Field

visits

November-

December 2020

August 2020 August 2020 December 2020

Report Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-

Draft RAP-LRP is

reviewed by IFC-WB

Draft RAP-LRP is

reviewed by IFC-

2 Tarmeem ground verification process to confirm land ownership and to demarcate any patta land andor private land that

may have been identified within a government khasra This process is done by Revenue Department from time to time in the normal course of action (with or without any project) As an outcome of this process following can be achieved Revisions in the Patwari maps Khasra books Digital database other revenue records preparation of survey reports etc This process is undertaken by Officials from the Revenue Department usually inclusive of the Tehsildar RI Patwari etc

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 4

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Study

Title

Activities Neemuch Solar

Park (NSP)

Agar Solar Park

(ASP)

Shajapur Solar Park

(SSP)

Transmission Line

WB and ready for

Public Disclosure in

Mar 2021

WB and ready for

Public Disclosure

in Mar 2021

and ready for Public

Disclosure in Mar

2021

WB and ready for

Public Disclosure in

Mar 2021

IPP Field

Visits

Initiation 5-6th Dec 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and Draft IPP 13-16th Aug 2020

HH Survey 7-14th Sep 2020

Initiation 19th December 2019

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 6-7th Aug 2020

HH Survey Not done

Initiation 30th Jan 2020

Participatory Rural Appraisal (PRA) for FPIC Approach Paper and IPP 8-12th Aug 2020

HH Survey 13-14th Aug 2020

No IPP to be prepared for Transmission Line

Report Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure in

Mar 2021

Draft IPP is

reviewed by IFC-

WB and ready for

Public Disclosure

in Mar 2021

Draft IPP is reviewed

by IFC-WB and

ready for Public

Disclosure in Mar

2021

The ERM ESIA team has held several consultation meetings in project affected villages covering a

cross-section of stakeholders in a sequential manner The broad understanding of the socio-economic

and livelihood practices was carried out in Dec 2019 and Jan 2020 as part of collection of baseline

information The detailed study for RAP-LRP and IPP subsequently took place in Aug 2020 The details

of the consultations held for ESIA RAP-LRP are part of those reports and details of field visits and

consultation activities carried out for preparation of this FPIC Approach Paper and Draft IPP is described

in Section 4 below

13 Scope amp key deliverables related to FPIC for MP Solar Project

ERM as a part of the FPIC requirement for the project is expected to support the elaboration and

implementation of a robust FPIC process for the MP Solar Park project to be developed in 2 Phases

Phase I the overall principles and engagement process and criteria for obtaining FPIC should be

agreed on with the affected Indigenous People (IP) communities potentially before bidding

Phase II the focus of the proposed FPIC process will then be on seeking consent from affected

IP communities for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior

to the main construction phase) In phase II it is likely that the PPP concessionaire will also

play a role and as such the Social Expert will continue to advise RUMSL but also monitor the

activities of the concessionaire

The Table 14 below summarises the key deliverables tasks involved and expectations against each

of these tasks in terms as per the scope The current status progress of these tasks and timeline for

future activities is also proposed It should be noted that these timelines may change in keeping with

evolving health and safety situation in context of COVID-19

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Table 14 MP SOLAR FPIC Related Scope Key Tasks and Deliverables

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

I OBJECTIVE AS PER RFP The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected Indigenous People (IP) communities before bidding ie the submission of proposal for solar parks by concessionaire

Guidance to RUMSL (ONGOING)

Provide guidance to RUMSL on the most appropriate sequencing of steps vis-agrave-vis the FPIC process as per IFC PS 7 requirements

eg agreement and verification of legitimate IP representatives to represent affected communities in FPIC negotiations

agreement with IPs and their representatives on the FPIC engagement process and next steps including disclosure and consultation of draft updated project impact mitigation benefits package documentation

share of responsibilities between RUMSL and PPP concessionaire etc

This will also include advise on broader stakeholder analysis and engagement strategy

to build support for the FPIC approach and implementation of the project and

to participate in agreed outreach to influential local and international stakeholders andor additional sources of adviceinput

ERM has been providing handholding support to the client in terms of meetings and calls where the requirements of IFC PS 7 are discussed and possible implications of project decisions on the FPIC applicability are discussed

The training for RUMSL team on ICP (SEP) PS-7 and FPIC process on 27th Aug 2020

Sharing of Draft FPIC Approach Paper 1st Sep 2020

Discussion on Draft IPP and Formation of Committees for FPIC Process 16th Mar 2021

Submission of Note on FPIC budget FPIC Process

Responsibilities of PPP concessionaire submitted as part of Draft IPPs (Appendix-F)

A meeting with facilitating agency and their ToR was held in 1st Week of Apr 2021

A Joint field trip with RUMSL FPIC Team will be held after Covid-19 Second Wave is over to

- Verify the IP representatives and formation of ST committees

- To agree with ST committee on Draft Discussion and Decision Making Framework

Draft FPIC approach paper

Desk-based Information Compilation and Assessments

Review national applicable law to identify any gaps with IFC PS7 and ways to bridge them

While developing the FPIC approach leverage as much as possible the requirements of applicable law and the consent process usually applied when IP are affected

The FPIC approach should also ensure that affected IP communities are involved

ERM did not get access to documentation of community consultation as part of seeking

NOC3 from Gram Panchayats

Conversation with Sarpanch of villages with ST population revealed that consultation was

A field trip for a joint meeting between RUMSL and ST communities is proposed to be held after Covid-19 Second Wave is over The field trip will include the following

3 The allotment of unused Government land within any revenue village needed a resolution of concerned local government body (Gram Panchayat) under S 234 (4) till Nov 2018 See more details in

Section 21 below The Solar Parks does not require any EIA studied in India

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Identification of affected IP individuals and communities and representatives as well as project impacts mitigation measures and potential benefits related to them (ongoing process during ESIA)

Initial Meeting with Gram Panchayats (GPs) and Informing them on FPIC

Social MappingSite walk-through

Preparation of Draft FPIC Approach Paper which builds on key elements of IFC PS7 FPIC requirements is prepared in consultation with RUMSL IP representatives and other stakeholders and could be acceptable to each party

Internal Discussion and Consensus on FPIC Approach Paper

Sharing of Draft FPIC Approach with IP and Consensus Building

in the identification of impacts and provide input on the development of mitigation and benefit plans

The FPIC approach should be cognizant that impacts on vulnerable groups within the Affected Communities of IP if any should be adequately addressed during negotiation and in relevant documentation

It should be based on the engagement with local IP community decision-making authoritiesrepresentatives (and taking into account gender and other IFC PS 7 related prerogatives) to discuss the FPIC process with input from support organization

The draft approach paper should reflect a mutually acceptable engagement and negotiation framework for the FPIC process based on the principles of Good Faith Negotiations It should include a clear agreed indication on what constitutes consent in the project context

Ensure through revision and feedback that all other components under this assignment (ifwhen available) are aligned with the defined FPIC approach ndash including the Environmental and Social Impact Assessment (ESIA) Resettlement Action Plan (RAP) Stakeholder Engagement Plan (SEP) Gender Action Plan (GAP) and develop the Indigenous People Development Plan (IPDP)

restricted to Gram Panchayat members Though they initially reluctant to sign on the NOC after persuasion of District Collector they finally signed

PRA exercises which includes participatory mapping of social relationship livelihood and natural resources was held between 6th to 15th Aug 2020

The social mapping during 6-15th Aug collected information on existence of traditional decision making process and gender representation aspect

The proposed FPIC process as part of this FPIC approach paper (Refer Chapter-8) reflect GFN principles

The FPIC approach paper was discussed with RUMSL prior to sharing it with WB-IFC

The ESIA disclosure was done as part of the PRA exercises for IPP in Aug 2020The RAP survey was done in these villages around the same time to address their concerns over loss of privatepatta land

Consultations during RAP and Draft IPP preparation included PRA process where STs participated to identify impacts and expressed their expectation on project benefits

The feedbacks and key issues in ESIA (including GAP SEP) and RAP is synchronised in Draft IPP

- Introduce FPIC Facilitation Agency

- Facilitate formation of ST representative committees

- Inform them their rights in the context of FPIC process

- Consult and build mutual agreement on the lsquoengagement and negotiation frameworkrsquo (as in Chapter-8 of this report) which will include a clear agreed indication on what constitutes consent

- The STs Representatives will be asked about time they require for internal discussion and a tentative date for the first discussion on benefits proposed in IPP will be fixed

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Independent FPIC Facilitator Agency

Assess the need for Independent FPIC Facilitator Agency

Screening of IPOsCSOs for Independent FPIC Facilitator Agency possible facilitator options to determine how they can play a role in the process - who what how

Provide a list of names of key advocacy groupsNGOsCSOs considered SWOT (or similar) analysis of each organization considered identification of preferred organization and

Terms of Referencersquo for the role of the same in the FPIC process and its relevance for the FPIC process in that area and for that specific group

To be discussed in next call FA brings credibility of an independent agency (other than RUMSL and ESIA consultant) Considering the project context their position can be reviewed

The review and assessing the need for a FA is discussed in section 6 of this report The Scope of work for the FA is provided in Appendix-F

Preparation of IPDPIPPTDP

Note ESIA RAP SEP and other management plans should be prepared by this stage Infact the FPIC process report should also draw input from the engagement undertaken as part of the ESIA process

Indigenous People Plan (or

Community Development Plan

Stakeholder Engagement Plan) or

similar management documents

aimed at ensuring ongoing and

adequate engagement with IPs

The collection of baseline

information through PRA

exercises and a sample

household survey was done

in Aug 2019 The IPP draws

inputs from consultations for

ESIA RAP-LRP and

benefits are also

synchronised

Three Draft IPPs one for

each Solar Parks with a

package of benefits for

affected STs is ready and

disclosed in May 2021

These will be shared with

affected STs as part of the

FPIC negotiation process

subsequently for their

considerations and

acceptance

Preparation of Draft FPIC Process Report

FPIC Process Report will include (but not be limited to)

identification of IPs IP representatives and decision-making authorities

assessment of capacity of IPs IP representatives to undertake good faith negotiations

summary of any capacity building undertaken

agreed engagement and negotiation framework (including the process undertaken to agree upon the framework)

This document will be further updated and finalised once the whole process is completed

Note The FPIC process should incorporate key considerations contained in IFC PS 7 and GN 7 eg the need for free prior and informed engagement inclusion of differentiated measures to allow the effective participation of those identified as particularly disadvantaged or vulnerable including analysis of the legitimacy and representativeness of IP leaders and the role responsibilities and participation of

To be initiated once FPIC Process starts

The process of identification of IPs representatives and decision making authorities (ST RUMSL and Mediation Committees) which will take place once Covid-19 second wave is over and will be documented as Draft FPIC Process Report This will be a living document which will be updated after every round of field activities and negotiation meetings

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

detailed summary of consultations meetings engagement undertaken as part of the FPIC process

expert opinion on the process and outcomes

share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to complete the FPIC process

external stakeholders with vested interests in the outcome

Input to the bidding document

For the bidders in terms of FPIC amp IPDP requirements

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc

The Draft IPP for each Solar Park has Annexure-F providing roles and responsibilities and scope of work for the Solar Park Developer (SPD)

All 3 Draft IPPs with Annexure-F are ready for disclosure in May 2021

II OBJECTIVE AS PER RFP Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Preparation of communication Material

Communication material to be based on IPDP ESIA and RAP This should include culturally appropriate document on impacts and mitigation to be used during FPIC engagement and negotiation

All preparation including translation of FPIC-related materials including communication material summaries of relevant EampS documentation local benefits plans etc (printing arrangement to be agreed with RUMSL)

A Project Profile Fact Sheet was shared in Dec 2019

A summary of ESIA was shared in Aug 2020

The communication material based on Draft IPP will be prepared and used during FPIC process The Draft communication material will be shared with IFC-WB for their approval prior to its use in field

A parallel information disclosure process of RAP-LRP would also take place

Culturally Appropriate Information Disclosure Campaign

Share accurate and up to date information on project impacts proposed mitigation measures and proposed benefit streams in a culturally appropriate manner (ie in local language (as appropriate following discussion with IP representatives) in written and oral format)

The information disclosure should especially ensure that following are achieved

provide sufficient time for capacity building and

support to affected communities to understand these matters and their rights

The affected ST population speaks Malwi dialect The FPIC FA will have facilitators who would be familiar with this local dialect used

The FPIC FA will carry out the capacity building activities

The FPIC FA will spend 2 days at each Solar Park to do the capacity building workshops with local ST Representatives who would participate in FPIC discussion with RUMSL

The FPIC FA will do this once Covid-19 second wave gets over

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INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

Consent from the Indigenous communities

Meetings for Negotiation and Decision Making

Participate in and offer expert support to key FPIC-related meetings involving affected IP representatives RUMSL and other relevant authorities etc during the FPIC process

Support RUMSL in the organization of these meetings and in recording their outcome including the collection of comments and concerns of those attending

Measuring Consent and Signing of FPIC Agreement

Note This include also support the RUMSL in designing undertaking and collecting evidence of Good Faith Negotiations (GFN) resulting in Consent which involves (i) willingness to engage in a process and availability to meet at reasonable times and frequency (ii) provision of information necessary for informed negotiation (iii) exploration of key issues of importance (iv) use of mutually acceptable procedures for negotiation (v) willingness to change initial position and modify offers where possible and (vi) provision of sufficient time for decision making

Present updated materials and seek consent from affected IP communities and their leaders

Document the consent process in a mutually agreed written format including an agreed mechanism for monitoring of key commitments in future and grievance redress as well as identifying share of responsibilities between the RUMSL SPDs and other relevant parties

Evidence of representativeness and involvement of Indigenous Peoples representative bodies and organizations (eg councils of elders or village councils)

Evidence of agreement between the parties as the outcome of GFN (eg FPIC agreement MOU a letter of intent and a joint statement of principles agreed mitigation plans collective land agreements etc)

Other documents may include Client records photographs media reports personal letters or third-party accounts etc regarding eventsdemonstrations other activities for the project undertaken by project-affected IP communities with high relative levels of participation by (i) the affected community as a whole or (ii) by sub-groups particularly affected by the project

ERM will work alongside FPIC FA and RUMSL to help the FPIC process taking right direction

Final FPIC Process Document

Throughout the FPIC process (Phase I and Phase II) ERM should help documenting the FPIC process and provide an opinion and direction about the process and outcome vis-agrave-vis IFC PS7

The whole set of activity in Phase II need to be updated as part of the Final FPIC Process Document

The tentative timeline for the FPIC Process was scheduled between Jun 2021 and Sep 2021 The timeline will be revised after the ongoing Covid-19 second wave gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

INTRODUCTION

Phase Key Tasks Assignment Requirements Activities Completed Proposed timeline for Remaining Activities

The Draft FPIC Process Report will be submitted within 2 weeks of completion of FPIC process

Advise RUMSL but also monitor the activities of the concessionaire in phase II

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INTRODUCTION

14 Structure of the Report

This report is organized into following sections

Section 1 Introduction (this section)

Section 2 Applicable law and gaps assessment against IFC PS7 requirements

Section 3 Affected IPs population project impacts and mitigation

Section 4 Desk-based information compilation

Section 5 Engagement leading up to FPIC Approach Paper

Section 6 Independent facilitator agency

Section 7 Key elements in FPIC Process

Section 8 Draft Discussion and Decision Making Framework

15 Limitations

This Report is prepared after multiple field visits and interactions with affected ST community elected

leaders of Gram Panchayat and other key informants The assessments are based on information

received from RUMSL and other secondary information at some places The public health concerns

due to Covid-19 pandemic has prevented large community gatherings and communityrsquos willingness to

allow people from outside to spend much time with them

ERM team communicated with community members over telephone to seek clarifications and know

their views However it was not always possible to keep the discussion focused and definitive as it

could have been in case of a face to face discussion ERM has made efforts to build trust among

affected STs by sharing relevant information and answering their queries with clarity As FPIC process

is an itinerant process this relationship is expected to further evolve in future

The Draft Discussion and Decision Making Framework described in Chapter 83 though has been

accepted by RUMSL and reviewed by IFC and WB it would be discussed with committees formed by

affected STs and their feedbacks will be incorporated The FPIC process described in Chapter-8

therefore would undergo necessary changes

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan could not

be ascertained as nomadic tribes did not visit these sites when ERM conducted field visits The general

migration pattern of pastoral nomads is expected to have faced constraints of Covid-19 restrictions If

pastoral nomads or their representatives will be identified during the FPIC process an appropriate

decision on their participation will be taken

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

2 APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

This section provides an understanding of the applicable national regulations that pertain to the process

of land procurement and the rights of the Indigenous Peoples and a comparison between the provisions

of the same against the IFC PS 7 requirements

It should be noted that the Environmental and Social Impact Assessment (ESIA) Reports4 and the

Resettlement Action Plans (RAP) provide a detailed understanding of applicable regulations This

section is focused on the government land procurement process and its impacts on the collective rights

of the Indigenous Peoples identified in the project

21 Provision of Consent Process in MP Land Revenue Code 1959 prior and post its Amendment in 2018

The allotment of government land for these three solar parks is done under provisions of the MP Land

Revenue Code 1959 The Chapter-XVIII of this Code deals with rights in abadi5 (habitation area) and

un-occupied land and its produce

The Madhya Pradesh Land Revenue Code (MPLRC) was enacted in 1959 and has undergone several

amendments since then It was recently amended in 2018 and 2019 These recent amendments along

with other changes changed the procedure for allotment of unoccupied government land Some of the

land allotment letters were prior to this amendment and others after this amendment (see details in

Section 42) Table 21 below provides a comparison of key provisions in pre and post 2018

amendment

Table 21 Key Provisions of Land Revenue Code

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

Collective (Nistar) Rights on Unoccupied Government Land

Section 114- Land recordsmdash In addition to the map and

Bhoo Adhikar Pustikas there shall be prepared for each

village a khasra or field book and such other land records as

may be prescribed

Section 233- Record of unoccupied landmdash A record of

unoccupied land shall in accordance with rules made in this

behalf be prepared and maintained for every village

showing separatelymdash (a) unoccupied land set apart for

exercise of nistar rights under Section 237

Section 114 (e) (i) (ii) requires

the details of all unoccupied land

be maintained as described in

Section 233 One Such

document is the Nistar Patrak

under Section 234 Section 233 A record of all unoccupied land shall be prepared for every village and urban area in accordance with rules made in this behalf

Preparation of

Nistar Patrak

and change in

entries in

Nistar Patrak

Section 234 (1)- The Sub-Divisional Officer shall in

accordance with the provisions of this Code and the rules

made thereunder prepare a Nistar Patrak for every village

embodying a scheme of management of all unoccupied land

in the village and all matters incidental thereto and more

particularly matters specified in section 235

Section 234- same as 1959 Sub

section (2) (3) (4) have been

removed

4 Three separate ESIA Reports for Solar Parks one for each Solar Park one for the Neemuch Transmission Lines (Units 12

and 3) and another for the Transmission Lines for Agar and Shajapur Solar Parks (for Units 4 to 8) have been prepared 5 According to the MP Land Revenue Code 1959 abadi means the area reserved from time to time in a village for the residence

of the inhabitants thereof or for purposes ancillary thereto and any other cognate variation of this expression such as village site or gaonsthan shall also be construed accordingly No change was made to this definition in the subsequent amendments to the code

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(2) A draft of the Nistar Patrak shall be published in the

village and after ascertaining the wishes of the Gram Sabha

it shall be finalised by Sub-Divisional Officer

(3) A copy of the Nistar Patrak so finalised shall be kept in

the office of the Gram Panchayat

(4) On a resolution passed by the Gram Sabha by a majority

of not less than two-thirds of the members present and

voting the Sub-Divisional Officer with the prior sanction of

the Collector and also after making any such inquiry as he

deems fit inter se change the entries in the Nistar Patrak

(b) Record additional unoccupied land under any entry in the

Nistar patrak for fulfilment of further Nistar rights of villagers

Matters to be provided for in Nistar Patrak

Section 235- The matter which shall be provided for in the

Nistar Patrak shall be as follows namely

(a) terms and conditions on which grazing of cattle in the

village will be permitted

(b) the terms and conditions on which and the extent to

which any resident may obtain-

(i) wood timber fuel or any other forest produce

(ii) mooram6 kankar7 sand earth clay stones or any other

minor mineral

(c) instructions regulating generally the grazing of cattle and

the removal of the articles mentioned in paragraph (b)

(d) any other matter required to be recorded in the Nistar

Patrak by or under this Code

Section 235- same as previous provision of Land Revenue Code

Provision in

Nistar Patrak

for certain

matters

Section 236 - In preparing the Nistar Patrak as provided in

Section 235 the Collector shall as far as possible make

provision for-

(a) free grazing of the cattle used for agriculture

(b) removal free of charge by the residents of the village for

their bona fide domestic consumption of-

(i) forest produce

(ii) minor minerals

(c) the concessions to be granted to the village craftsmen for

the removal of the articles specified in clause (b) for the

purpose of their craft

Section 236 - same as previous

provision of Land Revenue Code

Collector to

set apart land

for exercise of

Nistar rights

Section 237 (1) Subject to the rules made under this Code

the Collector may set apart unoccupied land for the following

purposes namely-

(a) for timber or fuel reserve

(b) for pasture grass bir or fodder reserve

(c) for burial ground and cremation ground

(d) for gaothan

(e) for encamping ground

Section 237 (1) remains same

6 Soil used particularly for road paving 7 In India an impure concretionary carbonate of lime usually occurring in nodules in alluvial deposits and especially in the

older of these formations

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

(f) for threshing floor

(g) for bazar

(h) for skinning ground

(i) for manure pits

(j) for public purposes such as schools play grounds parks

road lanes drains and the like and

(k) for any other purposes which may be prescribed for the

exercise of right of Nistar

237 (2) Lands set apart specially for any purpose mentioned

in sub-section (1) shall not otherwise be diverted without the

sanction of the Collector

Section 237 (3) Subject to the rules made under this Code

the Collector after securing the land mentioned in clause (b)

of subsection (1) to minimum two percent of the total

agriculture land of that village may divert such unoccupied

land as mentioned in sub-section (1) into abadi or for

construction of roads state highways national highways

canals tanks hospitals schools colleges Goshalas and

any other public utility projects as may be determined by the

State Government

Provided that the land set apart for the purposes mentioned

in subsection (1) shall not be diverted and allotted to any

person for agriculture purpose

Section 237 (4) When it becomes indispensable to divert the

land set apart for the purposes mentioned in sub-section (1)

for such development and infrastructural projects which are

owned or approved by the State Government but not

covered under sub-section (3) the Collector after satisfying

himself on alternatives available and also on obtaining land

of equivalent area for fulfilling the same nistar rights from the

concerned project may divert the land for such purposes by

passing a reasoned order to this effect Thus in case Nistar

land needs to be diverted for the project the project needs to

make available an equivalent area for the replacement of the

same nistar rights

The section 237 (2) is removed

Section 237 (3) remained same

Section 237 (4) remains same

Rights in Fruit Bearing Trees and other trees in Un-Occupied Government Land

Section 239 (1) Where before coming into force of this

Code any fruit bearing tree was planted by any person in the

unoccupied land of any village and is so recorded then

notwithstanding that such land vests in the State

Government such person and his successor in interest

shall from generation to generation be entitled to possession

and usufruct of such trees without payment of any royalty or

other charge whatsoever therefore

Section 239 (6) the State Government may make rules for

carrying out the purposes of this section

Section 239 (1) same as 1959

Section 239 (6) The unoccupied

land on which any tree planting

permit or tree patta has been

given prior to the commencement

of MP Land Revenue Code

(Amendment) Act 2018 may be

used for any public purpose by

the order of Collector If any

interest of the holder of such tree

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Category Land Revenue Code 1959 (Prior to 2018 and 2019 Amendments)

Land Revenue Code after 2018 and 2019 Amendment

planting permit or tree patta is

adversely affected due to such

use the holder shall be entitled

for such compensation which

shall be calculated in such

manner as may be prescribedrdquo

Exclusive jurisdiction of revenue authorities

Section 257 - Except as otherwise provided in this Code or

in any other enactment for the time being in force no Civil

Court shall entertain any suit instituted or application made

to obtain a decision or order on any matter which the State

Government the Board or any Revenue Officer is by this

Code empowered to determine decide or dispose of and in

particular and without prejudice to the generality of this

provision no Civil Court shall exercise jurisdiction over any

of the following matters - (w) any claim to modify any entry

in the Nistar Patrak

Section 258 (1) The State Government may make rules

generally for the purpose of carrying into effect the

provisions of this Code

(2) In particulars and without prejudice to the generality of

the foregoing powers such rules may provide for (lviii) the manner in which the wishes of the villagers shall be ascertained under Section 234 (2)

Section 257 - same as 1959

Section 258 (1) and (2) (lviii)

same as 1959 it should be noted that the Section 234 (2) was removed in 2018 Amendment

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers Diverting the un-occupied

government land8 categorised as grazing land that is recorded in Nistar Patrak (there may be other

grazing land available) and such other Nistar rights9 including the right in fruit bearing trees and other

trees in unoccupied government land after the amendment in 2018 does not require any consent

process with concerned village community

Hence it is expected that the government land allotted for the project prior to the 2018 Amendment of

MP Land Revenue Code is expected to have involved a resolution of concerned Gram Sabha As per

Sec-6 of the Madhya Pradesh Panchayat Raj Act 1993 the quorum of every meeting of Gram Sabha

shall not be less than one-tenth of the total number of members of the Gram Sabha or five hundred

members of the Gram Sabha whichever is less The Act does not specify presence of women in

Gram Sabha to be mandatory

Other Indian laws which has provisions for consent process are not applicable to this project and an

overview of them is provided in Box 31 below

8 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands 9 Nistar rights refer to collective rights of a revenue village to use specified government land for the purposes mentioned in

S235 of MP Land Revenue Code This includes right to free grazing cattle collecting minor minerals construction materials burialcremation grounds for religious and cultural events etc

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Box 21 Other Indian Laws with provisions for consent process and their applicability

22 International Social Safeguard Policies Applicable to the Project

221 IFC Performance Standards

The part of PS1 dealing with Management Program envisages an Indigenous Peoples Plan (IPP) as a

thematic plan and should be developed by qualified experts with substantive experience For projects

with adverse impacts to Indigenous Peoples the client is required to engage them in a process of

Informed Consultation and Participation (ICP) and in certain circumstances the client is required to

obtain their Free Prior and Informed Consent (FPIC)

The FPIC from the affected communities of Indigenous Peoples is required when the following special

circumstances (in paragraphs 13ndash17 of Performance Standard 7) are present

Impacts on lands and natural resources subject to traditional ownership or under customary use

Relocation of Indigenous Peoples from lands and natural resources subject to traditional

ownership or under customary use

Significant impacts on critical cultural heritage that is essential to the identity andor cultural

ceremonial or spiritual aspects of IPs lives

Where a project proposes to use the cultural heritage including knowledge innovations or

practices of Indigenous Peoples for commercial purposes

IFC PS7 requires to avoid adverse impacts on Indigenous People and if adverse impacts are

unavoidable the project should prepare an Indigenous Peoples Plan outlining the actions to minimize

andor compensate for adverse impacts in a culturally appropriate manner Some of the key

provisions with respect to IPP are

A free-standing IPP may be prepared or it may be a component of a broader community

development plan

The IPP should detail actions to minimize andor compensate for adverse social and economic

impacts and identify opportunities and actions to enhance positive impacts of the project on the

Indigenous Peoples

Where appropriate the IPP may also include measures to promote conservation and sustainable

management of the natural resources on which the Indigenous Peoples depend

The IPP should include a clear statement of roles and responsibilities funding and resource

inputs a time-bound schedule of activities and a budget

The IPP shall be regular monitored and should be flexible to allow for it to be adapted as needed

if circumstances change

222 World Bank Operation Manual OP 410

The World Bankrsquos Operational Policy on Indigenous Peoples (OP 410) aims at ensuring that the

development process fosters full respect for the dignity human rights and cultures of IPs thereby

In Indian context the constitutionally recognized Scheduled Tribes are usually considered as Indigenous Peoples

while determining their entitlements under international social safeguards systems

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006( FRA) is not

relevant as no forestland was diverted The Provisions of the Panchayat (Extension to the Scheduled Areas) Act

1996 (PESA) acts is not applicable for the project as the project site is not in a schedule V area There are no

specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement

consultation and consent

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

contributing to the Bankrsquos mission of poverty reduction and sustainable development To achieve this

objective Bank-assisted projects which affect IPs provide them a voice in design and implementation

avoid adverse impacts where feasible or minimize and mitigate them and ensure that benefits

intended for them are culturally appropriate

The Bank recognizes that IPs are commonly among the poorest and most vulnerable segments of

society and in many countries they have not fully benefited from the development process It also

recognizes that the identities cultures lands and resources of indigenous peoples are uniquely

intertwined and especially vulnerable to changes caused by development programs Because of this

issues related to indigenous peoples and development are complex and require special measures to

ensure that IPs are not disadvantaged and that they are included in and benefit from these programs

as appropriate

Under the OP 410 the Bank requires the borrower to undertake a social assessment to evaluate

projectrsquos potential positive and adverse effects on the IPs and to examine project alternatives A

project that affects Indigenous Peoples the borrower engages affected IPs in a free prior and

informed consultation (FPICon) process

Note The World Bank adopted Environment and Social Framework (ESF) which comprises of ten Environment

and Social Standards (ESS) The ESS-7 deals with Indigenous PeoplesSub-Saharan African Historically

Underserved Traditional Local Communities which requires FPIC to be obtained in special circumstances where

customary rights on natural resources used by IPs is impacted The WB has financed the renewable projects to

MNRE prior to adoption of the new ESF in Dec 2019 The Shajapur Solar Park is under the old WB safeguards

and therefore the new ESF is not applicable

23 Comparison of Provisions in National Laws vis-agrave-vis requirements under Social Safeguard Policies of IFC and WB

Prior to MP Act No 23 of 2018 which amended MP Land Revenue Code 1959 the s234 (4) required

a resolution of Gram Sabha by a majority of not less than two thirds of the members present and

voting for any change in the entries in Nistar Patrak or record additional unoccupied land under any

entry in the Nistar Patrak for fulfillment of further Nistar rights of villagers The diversion of the un-

occupied government land10 categorised as grazing land that is recorded in Nistar Patrak (there may

be other grazing land available) and such other Nistar rights including the right in fruit bearing trees

and other trees in unoccupied government land after the amendment in 2018 does not require any

consent process with concerned village community A comparison of key provisions of PS-7 vis-agrave-vis

legal provisions in Indian context is provided in Table 22

Table 22 Comparison of Provisions of Consent Process in Applicable Indian

Regulations vis-agrave-vis Provisions in IFC PS-7

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Assessment of Impact on Indigenous People

The client will identify through a process of Social and Environmental Assessment all communities of Indigenous Peoples who may be affected by the project within the projects area of influence The client will assess the nature and degree of the expected social cultural (including cultural heritage) and environmental impacts (direct and indirect) on them and avoid adverse impacts whenever feasible

There is no requirements for environment impact assessment (EIA) for Solar Park Projects There are no specific protections or provisions in place for the Indigenous people in terms of impact assessment engagement consultation and consent

10 It should be noted that the un-occupied government land is a legal phrase used in the MP Revenue Code From the site

observations it is understood that there may be certain undocumented usage and dependence on these lands Such usages will be confirmed only through the Tarneem process for each site

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Headings Summary of IFC PS Requirements Key Gap of Applicable Regulations Against IFC PS

Preparation of IPP

The clients actions will be developed with the informed consultation and participation of affected Indigenous Peoples and contained in a time-bound plan such as an Indigenous People Plan or a broader community development plan with separate components for Indigenous Peoples

There is no legal requirement for an Indigenous Peoplersquos development plan

Consultation and Consent from affected IPs

In projects with adverse impacts on affected communities of Indigenous Peoples the consultation process will ensure their free prior and informed consultation and process of community engagement will be culturally appropriate and commensurate with the risks and potential impacts to the Indigenous Peoples

The acquisition of the private land owned by ST will be done through MP Consent Policy 2014 and the RAP addresses the impact on individual ST land ownersoccupiers The impact on customary rights (such as Nistar rights) over collectively used unoccupied government land is dealt under the provisions of MP Land Revenue Code 1959 There is no consultationconsent process for diversion of grazingNistar lands under MP Land Revenue Code 1959 (As amended up to 2019) The consent process in other Indian laws such as FRA or PESA which has consent process is not relevant to the project

Land Revenue Code had a requirement for Gram Sabha consent to be taken prior to diversion of

Nistar rights as part of the 2018 Amendment the same provision was removed As most of the

government land for Shajapur Solar Park was allotted in 2017 Table 23 below provides a

comparison of provisions of the consent process under MP Land Revenue Code 1959 (prior to Nov

2018 amendment) vis-agrave-vis requirements under IFC PS-7

The key elements of FPIC process as per IFC PS (including Guidance Notes- GN) identified for

comparison includes

1 Requirements of information disclosure (as in PS-129) 2 Informed consultation and participation (as in PS-130-31 and PS-710) 3 Good Faith Negotiation (as in GN-725) and 4 Consent and documentation (as in PS-712)

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Table 23 Comparison of Key Elements of FPIC as per IFC PS-7 and Provisions in MP Land Revenue Code 1959 (Prior to Nov 2018 Amendment) and MP Panchayat Raj Act 1993

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Information Disclosure

Relevant project information must be disclosed to Affected

Communities and other stakeholders to enable them to

understand the risks impacts and opportunities of the project

The Project will provide Affected Communities with access to

relevant information on

the purpose nature duration and scale of the project

risks and potential impacts and relevant mitigation measures

the envisaged stakeholder engagement process and

the grievance mechanism

Information disclosed must be relevant transparent objective

meaningful and easily accessible and in a culturally appropriate

local language(s) and format and is understandable to Affected

Communities

Under MP Revenue Code 1959 and MP

Panchayat Raj Act 1993 the information

disclosure to affected communities (including

Schedule Tribes) is limited to the intended

purpose of the allotment of unoccupied

government land

The disclosed information and proceedings are

recorded using the language of the State

The information disclosure to affected communities

prior to the meeting does not disclose all relevant

information particularly potential risks The

information disclosed is not easily accessible to STs

and other vulnerable communities

The process does not involve any grievance

mechanism

Informed consultation and participation

Where a Project has potentially significant adverse impacts on

affected communities an ldquoinformed consultation and

participationrdquo (ICP) process should take place ICP is an

organised and iterative consultation that involves a more in-

depth exchange of views and information leading to the Project

incorporating the views of those affected into project decision-

making on matters that affect them directly

The consultation process should capture both menrsquos and

womenrsquos views and their different concerns and priorities The

process should be documented in particular the measures taken

Section 234 of MP Revenue Code 1959 (Prior to

Nov 2018 Amendment) required the draft Nistar

Patrak of every village and any changes in therein

to be published by Sub-Divisional Officer with

prior sanction of the District Collector only after

ascertaining wishes of the Gram Sabha

(expressed through a resolution passed in Gram

Sabha held for this purpose)

As per Section 6 of the MP Panchayat Raj Act

1993 the Gram Sabha can be held with a quorum

of one-tenth of the total member of Gram Sabha

The MP Revenue Code does not require any

iterative consultation that involves in-depth

exchange of views

The participation of women and other vulnerable

sections is not mandatory

The quorum of the meeting is only ten percent of the

total members of the Gram Sabha The notice for

holding a special Gram Sabha is only 7 days and

there is limited information shared in terms of the

agenda of the meeting Hence a resolution passed

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

to avoid or minimise risks to and adverse impacts on the

Affected Communities and should inform those affected about

how their concerns have been considered

In addition the process should Involve Indigenous Peoplesrsquo representative bodies and

organisations as well as members of the Affected Communities of IPs and

Provide sufficient time for IPs decision-making processes

or five hundred members whichever is less

There is no specific requirement on presence of

women to fulfil quorum requirements

A special meeting of the Gram Sabha is held

within seven days of receiving the requisition

by a Gram Sabha with a bare minimum presence

does not reflect majority decision

The process does not require representative bodies

of IPs to represent their interests

Good Faith Negotiation

FPIC will be established through good faith negotiation between

the Project and the Affected Communities of IPs Good faith

negotiation generally involves (i) Willingness to engage in a process and availability

to meet at reasonable times and frequency (ii) Provision of information necessary for informed

negotiation (iii) Exploration of key issues of importance (iv) Mutually acceptable procedures for the negotiation (v) Willingness to change initial position and modify

offers where possible and (vi) Provision for sufficient time for decision making

The MP Revenue Code require neither iterative

prior consultation nor exchange of views with

administration

The administrative process for allotment of

unoccupied government land does not involve a

negotiation process through which their feedback

and concerns are incorporated or addressed

Consent

In certain circumstances the client is required to obtain the Free

Prior and Informed Consent (FPIC) of affected IPs FPIC does

not necessarily require unanimity and may be achieved even

when individuals or groups within the community explicitly

disagree The measurement of consent is expected to be

included in the lsquomutually accepted processrsquo for FPIC decision

making

Consent

Section 234 (4) required the Gram Sabha to pass

a resolution with support of a majority not less than

two-thirds of the members present and voting As

per Section 6 of the MP Panchayat Raj Act 1993

the Gram Sabha can be held with a quorum of one-

tenth of the total member of Gram Sabha or five

hundred members whichever is less There is no

specific requirement on presence of women to fulfil

quorum requirements

Consent

The FPIC process in IFC PS-1amp7 recognizes that

consent is not necessarily a unanimous decision

yet there has to be a mutually agreed threshold of

consent in an FPIC process that can vary from

project to project The threshold defined in MP

Panchayat Raj Act 1993 is one-tenth of the total

members of Gram Sabha passing a resolution with

support by two third majority present and voting

Thus the consent threshold for a resolution is 66

of the total members of Gram Sabha

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APPLICABLE LAW AND GAPS ASSESSMENT AGAINST IFC PS7 REQUIREMENTS

Key Element of FPIC as per IFC PS-7 Similar Provision in Indian Laws Gaps in Relevant Indian Laws

Documentation

The client will document

The mutually accepted process (FPIC Decision Process Framework Document) between the client and Affected Communities of Indigenous Peoples and

Evidence of agreement between the parties as the outcome of the negotiations

Documentation

The documentation is limited to the entries in Gram

Sabha minutes book The entire set of

documentation is kept by Administration and not

shared with Gram Panchayat

Considering this low threshold as per legal

requirements the FPIC process requires a mutually

accepted threshold for decision making

Documentation

The documentation of the process carried out during

the Gram Sabha meetings leading to the resolution

though is written down in the Gram Sabha minutes

book however there is no guideline on what should

be covered Therefore a mutual agreement on

documentation requirement is necessary

As described in GN62ndash65 where government processes involve project-level decision and actions the client should review these processes in relation to the requirements of the Performance Standard and address identified gaps where feasible

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

3 AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

The FPIC was triggered at the scoping stage on account of impact on grazing land and other natural

resources within the allotted government land on which STs have claims of customary use which is also

recognized under MP Land Revenue Code as Nistar rights The statement of different categories (which

are part of the Nistar rights of village community) of government land to be used for the proposed Solar

Parks from different villages and percentage of ST population in these villages is provided below

31 Affected Villages Government land used11 by ST Population

311 Neemuch Solar Park (Unit 1-3)

The Neemuch Solar Park is comprised of 3 units and the land is acquiredpurchased from 3 villages

The land category (classification in revenue records as per their currentintended use) is provided in

Table 31 below

Table 31 Neemuch Solar Park- Land Category amp Presence of ST households in Project Affected Villages

Village Name

Govt Land Category in Hindi

Govt Land Category in English Sum of Area (Ha)

ST Population in of Total Village Population

Unit -1

Bardavada Chargah Grazing land 2271 55

Charnoi KamdalKK (Kabil Kast)

Grazing land 4013

DathaKamdal Land with stone outcrops and shallow soil

1655

Gair mumkinCharnoi Uncultivable waste land grazing land

492

Kabil Kast Cultivable 2

Kamdal Land with stone outcrops 169

KamdalDathaDahar Grazing land 4641

KamdalDathaKaKa Grazing land 4279

PK 052

NA 2053

Sub-Total (Bardawada) 25774

Kawai Datha Land with stone outcrops and shallow soil

8962 1992

NA 425

Sub-Total (Kawai) 9388

Total Unit 1 351615

Unit -2

Badi Datha 052 2292

Kabil Kast 11568

NA 5835

Sub-Total (Badi) 17455

Kawai NA 17846 1992

Sub-Total (Kawai) 17846

Total Unit 2 35301

Unit -3

Badi Charnoi (grazing) Grazing land 355 2292

Datha 3805

Gairmumkin Charagah

(grazing)

Uncultivable waste land

grazing land

4184

11 The MP Land Revenue Code recognizes the right to use for grazing collection of timber fire-wood earth morums and other

products (see Section 235 of MP Land Revenue Code)

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AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

KaKa (Kabil Kast) Culturable wasteland 5

Kamdal 11179

NA 13727

Badi total 36945

Total Unit 3 3694557

Grand Total (Unit-1 2 and 3) 107408

Note land category for the units is as per the Allotment Letters NA= Not Available

The screening of the Census 2011 data shows that there is presence of ST population in all three

villages In Badi and Bardawada villages the land categories such as Charnoi Charagah are clearly

recorded as grazing lands The map below shows the location of village settlements and their area

designated as Grazing Land

The ST families in Badi and Kawai live in several small cluster of satellite settlements The Bardawada

had only 22 ST population with 4-5 families Bardawada is part of Dhardi Gram Panchayat and the ST

households live farther from the Solar Park boundary Their households are scattered and dependency

on the allotted government land for Bardawada village could not be established In terms of

concentration of ST population Badi and Kawai are considered as major ST settlements

Thus ~100 ST households in Badi and Kawai have a claim on customary use of ~18938 ha of

designated grazing land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 31 Map of Neemuch Unit 1 Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 32 Neemuch- Unit 2 amp3- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

312 Agar Solar Park (Unit 4 amp 5)

The Table 32 provides a break-up of the designated land categories of government land as per revenue

records in Agar Solar Park

Table 32 Agar Solar Park- Government Land- Land Use Category

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Agar Solar Park (unit 4)

Bijnakhedi Germumkin Uncultivable waste land 5598 0

Sub-Total (Bijnakhedi) 5598

Dudhpura Agriculture Agriculture 2243 0

Bardi NA 6631

Gothan Livestock rearing land 2

Khadar The floodplains formed by

yonger alluvium

018

Tree Plantation NA 1495

NA NA 5082

Sub Total (Dudhpura) 15669

Karwa Khedi Chragha Grazing land 251 0

K K NA 475

Khachar Grazing land 068

Pahad Hilly terrain 12392

NA 216

Sub Total (Karwa Khedi) 15346

Keasi Dehariya Gochar Grazing land 283 0

Sub Total (Keasi Dehariya) 283

Ladwan Bardi 7963 579

Charnoi Grazing land 947

Gochar Grazing land 2749

Kavil Kast 609

Khachar Grazing land 238

Pahad Hilly terrain 3062

Waterbody Water body 094

NA 475

Sub Total (Ladwan) 16137

Madhopur Germumkin Uncultivable waste land 1558 0

Sub Total (Madhopur) 1558

Pipalia Kumar Bardi 3492 0

Agriculture land Agriculture 506

Sub Total (Pipalia Kumar) 3998

Total Unit 4 611381

Susner Solar Park (Unit 5)

Palda Germumkin Uncultivable waste land 5689 036

NA 6928

Sub Total (Palda) 12617

Naharkheda Germumkin KaKa Uncultivable waste land 4125 0

Germumkin Uncultivable waste land 1868

NA NA 8908

Sub Total (Naharkheda) 14901

Umariya Charnoi Grazing land 3660 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Village Name Govt Land Category

in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Charokhar Grazing land 416

Chragha Grazing land 9114

Germumkin Uncultivable waste land 147

Kadim NA 011

Shaskiye Government land 218

Sheda NA 01

NA NA 20907

Sub Total (Umariya) 35806

Pipaliya Nankar NA NA 1822805 0

Total Unit 5 8161745

Note land category for the unit 4 is as per the kml file provided by RUMSL on 30012020 as the allotment letters did not carry

the land use details

Ladwan village has 579 of ST population (~12 households) who have claim on customary use of

3934 ha of designated grazing land Palda was found to have only 1 ST family Moreover no Charnoi

Chargah Gochar land is acquired from Palda Hence ST families in Ladwan were selected to be in

focus for FPIC process

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 33 Agar Unit 4 ndashGrazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 34 Susner Unit 5- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

313 Shajapur Solar Park (Unit 6-8)

The Table 33 provides a break-up of the land categories of government land as per revenue records

in Shajapur Solar Park In Shajapur Solar Park (Unit 6-8) five villages have ST population They are

Jawadi (034 STs) Parsula (1768 STs) Dehripal (018 STs) Fawaka (238 STs) and

Chouma (072 STs) Of these Dehripal Fawaka and Surajpur do not have any Charnoi Chargah

Gochar land impacted

Table 33 Shajapur Solar Park- Government Land- Land Use Category

Village Name Govt Land

Category in Hindi

Govt Land Category in

English

Sum of

Area (Ha)

ST Population

in

Moman Badodiya-Unit6

Burlay Agriculture Agriculture 813 0

Germumkin Uncultivable waste land 224

Nala Stream Drain 138

Burlay Total 3191

Jawadi Agriculture Agriculture 198 034

(1 Household with

3 persons)

Gochar Grazing land 4189

Idhan Hetu For fuelenergy 209

Kabil Kast 316

Muram Hetu For Murram (fine aggregate) 063

Pahad Hilly terrain 339

Shivir Camping ground 041

NA 2011

Jawadi total 3596

Dhatrawada Agriculture Agriculture 338 0

Charnoi Grazing land 058

Chragha Grazing land 4058

Germumkin Uncultivable waste land 10638

Gothan Livestock rearing land 128

K Kast 557

Kabil Kast 1217

Kadim 074

Khadan Quarry 291

Khalihan Threshinggrain storage etc 167

Murum Hetu

Khadan

For Murram 125

Nala StreamDrain 042

Road Road 117

NA 6

Dhatrawada total 1841

Total (Unit 6) 25197

Momain Badodiya-Unit 7

Parsula Agriculture Agriculture 515 1768

(~41 households) Barda Rockyhilly 847

Barda Nistar

Chragha

Grazing land 947

Charnoi Grazing land 1064

Idhan Hetu

Surakshit

Secured for fuelenergy-

firewood

209

KK 137

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Khchar Grazing land 311

Nala Streamdrain 146

Nistar Chragha Grazing land 393

Parsula Total 12192

Dehripal Agriculture Agriculture 124 018

(1 Household with

5 populaiton)

Birdi GM 295

Brda 8054

Brda Lala 055

Chuna Hetu 105

Germumkin Uncultivable waste land 2015

Kankad Chuna

Hetu

For coarse aggregate and

lime

105

Khad ke Gadde 15

Muram Hetu For Murram (fine aggregate) 042

Watershed

Planning

Watershed planning 027

NA 1916

Dehripal Total 14004

Bijanakhedi Agriculture Agriculture 2199 0

Bardi 4101

Bardi Charnoi Grazing land 1274

Bardi 385

Chamdi Sthan 042

Charagah Grazing land 035

Charnoi Grazing land 018

Chragha Grazing land 1404

Germumkin Uncultivable waste land 858

Idhan Hetu 209

Khad ke gadhe Manure collection 084

Khalihan Hetu Threshinggrain storage etc 143

Mitti Hetu 063

Muram Hetu For Murram 063

Nala Streamdrain 36

Pathar Hetu For Stone 105

Road Road 203

Shivir Bhumi Camping ground 042

NA 288

Bijanakhedi total 11876

Fawaka Agriculture Agriculture 016 238

(4 Households with

28 population)

Brda Hilly terrain 863

Idhan Hetu Secured for fuelenergy-

firewood

25

Kakkad 418

Muram Hetu For Murram (fine aggregate) 179

Fawaka Total 1726

Chouma Agriculture Agriculture 392 072

(3 Households with

19 population)

Brdi Hilly terrain 562

Chamda Sthan For de-skinning 021

Charnoi Grazing land 989

GM 2943

Gothan Livestock rearing land 5

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Muram Pathar

Khadan

Murram (fine aggregate) 041

Nala Streamdrain 015

Chouma total 5463

Burlay Germumkin Uncultivable waste land 1543 0

Nala Streamdrain 019

NA 2604

Burlay Total 4166

Total (unit 7) 49427

Shajhapur (unit 8)

Surajpur Bardi Hill Terrain 898 203

(3 Households with

16 population)

Germumkin Bardi Uncultivable hill terrain 1170

Nala Streamdrain 597

NA 1894

Surajpur total 4559

Lalpur Beed 023 0

Beed Gair Mumkin 053

Brdi 2333

Charagrah Grazing land 18

Charnoi Grazing land 115

Gair Mumkin Brdi 1608

Kadim 115

Nala Streamdrain 055

NA 1684

Lalpur Total 6166

Hanoti NA 16291 0

Total (unit 8) 27024

Note land category for the units is as per the excel sheet received on 18062020 from RUMSL

Hence 41 ST households in Parsula who have a claim of customary use on ~3134 ha of

designated grazing land was selected to be the focus for FPIC Process The map below shows

the location of Parsula and the area designated as Grazing Land

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

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Figure 35 Moman Badodiya- Unit 6 - grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

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Figure 36 Moman Badodiya- Unit 7- grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Figure 37 South Shajapur- Unit 8- Grazing Land locations and neighbouring villages

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

32 Selection of FPIC Villages

The assessment of the relevance of the four special circumstances that requires free prior informed

consent (FPIC) to be obtained from affected ST population was undertaken On the basis of the detailed

assessment undertaken as part of ESIA RAP along with targeted consultations with the IP

communities three circumstances are assessed to be not relevant to the project context

Relocation of STs was avoided while determining Solar Park boundary for all the three solar

parks and therefore no relocation of STs is anticipated from lands and natural resources subject

to traditional ownership or under customary use

The physical impact on cultural heritage sites with affiliation to STs is avoided in the three Solar

Park lay out and there is no potential significant impact on critical cultural heritage that is

essential to the identity andor cultural ceremonial or spiritual aspects of local STs community

The Solar Park does not propose to use the cultural heritage including knowledge innovations or

practices of STs for commercial purpose

Table 34 provides the list of villages where the FPIC process will focus covering ST households living

within it The assessment concludes that affected ST families have been living in these villages for

generations and have been using the government land (which was assessed to be subject to

traditional ownership or under customary use of the ST communities) allotted for Solar Park Project

for free grazing their cattle collection of fire-wood and collect edible fruits and plants mostly for self-

consumption The diversion of these land for the solar park will result in impacts on lands and natural

resources It was noticed that 7 other project affected villages had less than 5 ST households the

impact on their customary use of land acquired for the project was assessed and included in this table

too

Table 34 Villages to be covered in FPIC Process

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

Neemuch

Solar Park

Badi

(including 2

satellite

settlements)

80 (~450) Bhill Bardawada which is part of Dhardi Gram

Panchayat has only 4 ST families The location

of these ST households and consultations did

not indicate the government land allotted to

Neemuch Solar Park were under customary use

by them Kawai 17 (~100) Bhill

Agar Solar

Park

Ladwan 12 (~50) Bhill Palda village has 1 ST household and no

grazing (designated as Charnoi Chargah

Gochar) land is acquired from Palda

Palda village has 276ha of designated grazing

land and 28735ha of unoccupied government

land which they will continue to use for free

grazing their cattle and collection of fire wood

Hence the customary use of land by ST

household will continue with a negligible impact

Shajapur

Solar Park

Parsula 41 (~250) Bhill

Bhilala

Apart from Parsula 5 other affected villages

have less than five ST households These

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Selected

ST villages

for FPIC

Number of

Households

(Population)

Name of

ST

Communit

y

Other villages with small number of ST

households

villages (with the number of ST households)

are Jawadi (1) Dehripal (1) Fawaka (4)

Chouma (3) and Surajpur (3) The remaining

designated grazing land and total government

land for these 5 villages is provided below

Village Remain-

ing Desig-nated Grazing land (ha)

Total govern-ment land after Project allotment (ha)

Designated Grazing Land in percentage total Govern-ment land

Jawadi 2125 2705 786

Dehripal 241 8116 03

Fawaka 5032 5703 882

Chouma 2278 8167 279

Surajpur 1224 2592 472

The consultation with STs at Parsula informed

that unlike them these ST families do not keep

livestock in large number and mostly work as

construction workers Hence the land allotted to

Solar Park was not under customary use by

them for their livelihood

Note The ST families in these 7 villages will have access to the Grievance Mechanism to register their claims to

participate in the FPIC process In such a case their demands will be shared with concerned ST Committee (or

referred to Mediation Committee) and decision to include them in the process will be taken and an appropriate

mechanism for their representation and participation will be adopted

33 Impact on Nomadic Pastoral Communities

The seasonal use of the grazing and government land by nomadic pastoral communities was noticed

in scoping stage However further consultations with local villagers revealed that they do not visit

regularly and rarely camp on the land allotted to Solar Park These nomadic pastoral communities are

from the neighbouring state Rajasthan and are not recognized as STs in Madhya Pradesh

The use of project footprint by pastoral nomadic tribes from neighbouring states of Rajasthan and

consultation with any pastoral nomadic tribes was not held as they did not visit these sites when ERM

conducted field visits The general migration pattern of pastoral nomads is expected to have faced

constraints of Covid-19 restrictions If pastoral nomads or their representatives will be identified during

the FPIC process an appropriate decision on their participation will be taken

ERM will consult GoMP to obtain records of grazing permits issued to pastoral nomads of other states

and determine if any of the villages impacted by Solar Parks figure in it More information on their

migration routes and pattern of seasonal use of forest and revenue land for grazing (which would help

assessing their collective attachment to impacted land) will be collected

Due to C-19 restrictions the regular migration patterns by pastoral nomads are affected in 2020 The

next migration season will be in Nov-Dec 2021 In absence of the particular pastoral nomads the

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

GoMP data on pastoral nomad communities who are issued permit will be used and their IPs status

will be screened through secondary ethnographic literature

FPIC is an iterative process If nomadic pastoral communities could not be consulted the rights of

pastoral nomads will be recognized in TDP and a provision for engagement with them to identify

adequate mitigation measures will be kept in TDP

34 Impact on Government and Grazing Land

The total geographical area of these selected FPIC villages grazing land (Charnoi) available after

allotment remaining government land after allotment percentage of the government land remaining is

given in Table 35 below As per provisions of the MP Land Revenue Code a minium of 2 of the

total private land in a revenue village is reserved as Charnoi or grazing land It is observed that

Ladwan and Parsula have more than this recommended minimum

Table 35 Designated grazing land (Charnoi) and Remaining Government Land

Solar Park Unit

Village Name

Geo

gra

ph

ical

Are

a o

f V

illa

ge

(h

a)

To

tal

Pri

vate

La

nd

To

tal

Go

vern

men

t L

an

d P

rio

r to

All

otm

en

t (

of

To

tal

Geo

gra

ph

ic

Are

a)

To

tal

Go

vern

men

t L

an

d R

eq

uir

ed

for

So

lar

Park

(

of

To

tal

Go

vern

men

t L

an

d)

Rem

ain

ing

Go

vern

men

t L

an

d a

fter

All

otm

en

t to

So

lar

Pa

rk

Perc

en

tag

e o

f G

overn

men

t L

an

d o

f

To

tal

Geo

gra

ph

ical

Are

a

( d

ecre

as

e o

r In

cre

as

e)

()

Desig

nate

d G

razin

g L

an

d

avail

ab

le a

fte

r P

roje

ct

all

otm

en

t (h

a)

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g

Lan

d)

of

the R

em

ain

ing

Go

ve

rnm

en

t

La

nd

()

Perc

en

tag

e o

f C

harn

oi

(Gra

zin

g)

Lan

d o

f th

e T

ota

l P

rivate

La

nd

Neemuch Solar Park Unit 1 amp2

Kawai 82698 20132 62566 (76)

24572 (39)

37994 (61)

46 (-30)

397 104 2

Neemuch Solar Park Unit 2 amp3

Badi 130055 33599 96456 (74)

51499 (53)

44957 (47)

35 (-39)

646 144 2

Agar Solar Park Unit 4

Ladwan 59076 31913 27163 (46)

16832 (62)

10331 (38)

17 (-29)

6682 6468 21

Shajapur Solar Park Unit 7

Parsula 69061 51439 17622 (26)

1162 (66)

6002 (34)

9 (-17)

1802 3002 4

Note () As per requirement under MP Land Revenue Code a minimum of 2 of the private land area within a

revenue village is to be reserved as Charnoi or grazing land for collective use by villagers

() Total Charnoi or grazing land prior to the allotment of Government land available in secondary sources

(Census 2011) is old as the land allotment took place between 2017 and 2019 Some Government Land

Allotment Letters mentioned the pre-allotment land category classifications (see Table 31 32 and 33) but this

data was not available for all vilalges to calculate the proportionate reduction of Charnoi land

The percentage of government land in some of the villages was high prior to the allotment of land for

Solar Parks For example the government land in Kawai formed 76 and that of Badi 74 of the

total geographical area Allotment of government land for Solar Parks has reduced the proportion of

the government land in these villages but the percentage of reduction varies from village to village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

For Kawai the percentage of government land after allotment has reduced from 76 to 46 (-30)

and for Badi it changed from 74 to 35 (-39) In Ladwan village the percentage of government

land changed from earlier 46 to 17 (-29) Similarly in Parsula the percentage of government

land changed from earlier 26 to 9 (-17)

The revenue department has designated some part of the remaining government land as Charnoi or

grazing land as per current Nistar Patrak The designated grazing land area meets the minimum

requirement of 2 of the total private land of that particular revenue village The designated grazing

land area forms 104 and 144 of the remaining government land for Kawai and Badi respectively

The designated grazing land in Ladwan forms 6682 of the remaining government land and in

Parsula it forms 1002 of the remaining government land

35 Impact on Cultural Sites affiliated to STs

The physical impact on all cultural sites (both for ST and Non-ST communities) was avoided by

excluding them from the Solar Park lay-outs However some of the cultural sites will be in close

proximity or access to some of them would be possible only through the Solar Park boundary An

overview of the cultural sites affiliated to STs for each of the Solar Parks is provided below

Table 36 Impact on Cultural Sites Affiliated to STs

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

Shajapur

Parsula

Gwalon ka

Mandi

Located within Solar

Park boundary

Adequate area (as agreed during FPIC

consultations) around the Gwalon-ka-Mandi to

be left unused in Solar Park lay-out

A road of sufficient width to be provided to

reach Gwalon-ka-Mandi

SPD will carry out improvements of the cultural

site after discussion with STs and other

communities using it

SPD will provide adequate civic amenities

(parking space drinking water lighting public

toilets etc) as per discussion with STs and

other community using it

Agar Solar

Park Ladwan

Gwaal Dev

Shrine

Located at the

margin of Solar Park

boundary

The SPD should leave the shrine and

adequate space around it in its lay out plan

Will ensure that access to the shrine by

community is maintained

The SPD will consult community to improve the

shrine Or build a new shrine for Gowals in the

new grazing area

Neemuch

Solar

ParkBadi and

Kawai

None The shrines and

cremation grounds

used by Bhils in

Kawai and Badi are

None

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park

Village Name

Name of

Cultural Site

Impact Mitigation in Draft TDP

avoided in project

layout plan

No cultural sites or shrines with cultural significance for STs as a community was found during RAP

survey

36 FPIC Screening for Footprint of Associated Power Evacuation Infrastructure

The power evacuation infrastructures associated with these 3 Solar Parks are listed below The Pooling

Sub Stations (PSS) are located within the Solar Park boundary There will be 8 transmission line (TL)

sections whose footprint will be outside of the solar park boundary

Table 37 List of Power Evacuation Infrastructure

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

Neemuch

Solar Park

33kV220 kV Pooling Substation Unit-1 258 ha Located within the Solar Park

boundary 33kV220 kV Pooling Substation Unit-1 296 ha

33kV220 kV Pooling Substation Unit-1 887 ha

PGICL ISTS Station Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Neemuch

Solar Park

220 kV SC Line - 1 (From Unit 1 to Unit 2)

Transmission Line (TL) 1

332 km TL footprint is outside of the MP

Solar Park boundary includes

28 Towers (04 ha 144sqm

for each tower base) and RoW

of 13m width of 920ha

220 kV SC Line - 2 (From Unit 2 to PGCIL

ISTS substation)

Transmission Line (TL) 2

157 km

220 kV SC Line - 3 (From Unit 3 to PGCIL

ISTS substation)

Transmission Line (TL) 3

251km

Agar and

Shajapur

Solar

Parks

33kV220 kV PSS 4 in Unit 4 158 ha Located inside Solar Park

boundary 33kV220 kV PSS 5 in Unit 5 539 ha

33kV220 kV PSS 6 in Unit 6 513 ha

33kV220 kV PSS 7 in Unit 7 143 ha

33kV220 kV PSS 8 in Unit 8 196 ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

Solar Park Power Evacuation Infrastructure Area (ha)

Length (km)

Remarks on Footprint

PGCIL ISTS substation 830 ha Establishment of ISTS

substation will be done by

PGCIL who will be responsible

for procuremnt of land

designing construction and

OampM of the ISTS substation as

per their internal procedures

and managemnt systems The

bays in the ISTS substation will

be allotted to RUMSL for power

evacuation from Agar and

Shajapur Solar Parks

220 kV SC Line - 4 (From Agar Solar Park Unit 4 to interconnecting point with TL 7) Transmission Line (TL) 4

121 km TL footprint is outside of the MP

Solar Park boundary includes

372 Towers (536 ha

144sqm for each tower base)

and RoW of 13m width for

11914kms with 14951ha

220 kV SC Line - 5 (From Agar Solar Park Unit 5 to PGCIL ISTS substation) Transmission Line (TL) 5

2932 km

220 kV DC Line - 6 (From Shajapur Solar Park Unit 6 to Shajapur Solar Park Unit 7) Transmission Line (TL) 6

667 km

220 kV SC Line - 7 (From Shajapur Solar Park Unit 7 to PGCIL ISTS substation) Transmission Line (TL) 7

1646 km

220 kV DC Line - 8 (From Shajapur Solar Park Unit 8 to PGCIL ISTS substation) Transmission Line (TL) 8

6548 km

361 Use of Government Land in TLs Associated With Neemuch Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 38 below

Table 38 Village wise Area for RoW of Neemuch Solar Park Transmission Line and Presence of STs

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

1 Arnya 088 958 007 784

Kheda Moka Ka Dol 223 1807 055 83

Bardawada 009 5651 002 55

Kawai 112 8265 016 20

2

Kawai 104

Badi 102 13004 012 23

3 Badi 285

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL Name of village Total TL RoW

Area (ha)

Total Unused

Govt Land (in

ha)

of Unused

Govt Land

used for TL

RoW

Presence of

ST

Population

Chaksodijhar12 043 4475 012 0

Grand Total 966 42782 011

The transmission line RoW comes from six revenue villages out of which 5 are Solar Park affected

villages There are 2 additional villages coming under TL RoW ie Arnya (088ha) and Kheda Moka

Ka Dol (223ha)

The population of Arnya in 2011 (as per census) was 969 out of which 784 were ST population

The Kheda Moka Ka Dol is comparatively a smaller village with total population of 348 and 83 of it

belong to STs

The proposed RoW of the transmission line will use 007 and 055 of the unused government land

in Arnya and Kheda Moka Ka Dol respectively The RoW of the Transmission Line does not pass

through any reserved or protected forest land The vegetation cover in the transmission line RoW is

mostly shrubs and grassland There would be no restriction on current use of the RoW for free grazing

of cattle Hence the transmission line will not impact customary use of the RoW land by ST

population in Arnya and Kheda Moka Ka Dol

362 Use of Government Land in TLs Associated With Agar Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 39 below

Table 39 Village Wise Area of RoW of Agar Solar Park Transmission Line and Presence of ST Population

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

4 Ladwan 068 13311 051 6

4 Pachora 089 273 033 0

5 Chkali Parmar 093 1567 059 0

5 Jhikadiya 266 13514 197 0

5 Pipalya kumar 229 13328 172 0

5 Chikali goyal 287 20523 140 0

5 Bhanpura 152 17482 087 0

5 Nipaniya Baijnath 381 29047 131 0

5 Tola Khed 095 3757 253 0

5 Kashi Bardiya 219 5362 408 2

5 Tola Khedi 042 3757 112 0

5 Kankariya 105 13354 079 0

5 Bhimlod 026 22564 012 0

12 Chaksodijhar is part of Badi Gram Panchayat

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

L N Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

5 Bapcha agar 266 26778 099 0

5 Karadiya 144 23584 061 0

5 Mangwalia 24 15397 156 0

5 Gaysari 219 5293 414 0

5 Dehrinana 314 29331 107 0

5 Pharaspuri 142 16955 084 0

5 Bingaya Agar 112 150 075 0

5 Ralayti 267 2365 1129 0

5 Piplaya ghata 212 12811 165 0

RoW area passing through Kashi Bardiya village constitute 4 of the total government

The vegetation cover in the transmission line RoW is mostly shrubs and grassland There would be no

restriction on current use of the RoW for free grazing of cattle The RoW of the Transmission Line

does not pass through any reserved or protected forest land and therefore does not involve any

potential use of forest produce Hence the transmission line will not impact customary use of the

RoW land by ST population in Kashi Bardiya

363 Use of Government Land in TLs Associated With Shajapur Solar Park

The village wise break up of government land area of transmission line RoW what percentage that

comprise of the unused government land in that village vis-agrave-vis presencepercentage of ST

population in that village is provided in Table 310 below

Table 310 Village wise Area of Shajapur Transmission Line RoW and Presence of STs

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

6 Burlay 494 2876 172 0

6 Bijnakhedi 158 14668 108 0

6 Dehripal 215 27508 078 0

7 Fawaka 237 6083 390 2

7 Dehripal 296 27508 108 0

7 Parsula 219 5891 372 18

7 Megha Khedi 098 3537 277 0

7 Singhwad 071 3118 228 24

7 Palakhi 072 1185 608 0

7 Baigaon 27 2387 1131 11

7 Bagwad 335 14239 235 13

7 Karkadiya 111 8267 134 0

7 Pipalya Kumar 101 13328 076 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

7 Pachora 306 13311 230 0

7 Shivgarh 024 13353 018 0

8 Abhaypur 026 7633 034 0

8 Alampura 337 12006 281 0

8 Arniya 233 9019 258 0

8 Bada Beed Jagatpura 32 49327 065 0

8 Barandwa 646 258 250 1

8 Batawada 022 5854 038 0

8 Bhadoni 096 1672 057 4

8 Bordagujar 217 120 181 0

8 Chachakhedi 155 482 322 0

8 Chandangaon 409 5711 716 0

8 Chikali Parmar 299 1567 191 0

8 Dhakadi 174 467 373 0

8 Dupada 181 3624 050 6

8 Fanya 349 22 1586 0

8 Gujar Khedi 02 0

8 Gurdadiya 188 1279 1470 2

8 Hanoti 004 34035 001 0

8 Harangaon 005 3034 016 0

8 Jadmi 371 3597 1031 0

8 Jhonkar 572 13653 419 0

8 Kadiya 06 13653 044 8

8 Kalmoi 009 3916 023 0

8 Kanasiya 109 40642 027 0

8 Karedi 003 16944 002 0

8 Kareli 197 16944 116 0

8 Katwariya 458 9312 492 33

8 Khajuri Kanad 085 3138 271 3

8 Kharkhadi 071 310 023 0

8 Khutpala 016 2359 068 0

8 Kundla Khurd 23 1507 1526 3

8 Merkhedi 26 26 1000 1

8 Mirapura 068 3767 181 0

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

AFFECTED IP POPULATION PROJECT IMPACTS AND MITIGATION

TL No

Village Land Area of RoW (ha)

Total Unused Govt Land (in

Ha)

of Unused Govt Land used for TL

RoW

Presence of ST Population

8 Murdawan 292 101 289 0

8 Nanukhedi Mana 054 12851 042 0

8 Nanya Khedi Ahir 156 19092 082 0

8 Palasi 028 203 138 21

8 Pipalya Kumar 163 13328 122 0

8 Pipalya Naulay 28 8117 345 25

8 Rojwas 138 10 1380 0

8 Samgi 454 9921 458 2

8 Samgimanda 086 2578 334 0

8 Shankarpur 327 5782 566 0

8 Siroliya 003 10446 003 0

8 Surajpur 249 6912 360 2

8 Suwagaon 092 17558 052 9

The RoW of the transmission lines associated with Shajapur Solar Park passes through 60 villages

and 19 villages have ST population Out of these one village ie Parsula is covered in FPIC process

for Shajapur Solar Park

The RoW of the Transmission Line does not pass through any reserved or protected forest land and

therefore does not involve any potential use of forest produce The vegetation cover in the

transmission line RoW is mostly shrubs and grassland There would be no restriction on current use

of the RoW for free grazing of cattle Hence the transmission line will not impact customary use of the

RoW land by ST population in these 18 villages with ST population

364 Conclusion on FPIC Trigger for Transmission Lines

Based on the details of the presence of STs in Transmission Line corridors and assessment

of current land use and land classifications following inferences can be drawn

1 The TL Tower base and RoW corridor does not have any reserved or protected forest Hence potential customary use of forest produce is not relevant

2 The vegetation within TL RoW is mostly shrubs and grassland which is potentially used by local community for free grazing If any of this land under the ROW has been used for free grazing the people (including the ST families) will have other unused government land available to graze The disruption during construction and stringing will be very temporary and people can continue grazing under the ROW as before The few villages where the impact on unused land was higher than 10 either had no or very small (lt5) of ST population

3 The RAP survey has not identified any cultural site within TLs RoW or Tower Base area 4 There will be no physical displacement of any ST family for TLs

Therefore the circumstances requiring to obtain FPIC is not relevant for transmission lines

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

4 DESK BASED INFORMATION COMPILATION

41 Information Collection and Compilation

ERM has undertaken a desk based review of the information available This step involved collecting

and compilation of relevant information from following sources

Review of Detail Project Report (DPR) prepared by PwC dated October 04 2019

Detailed Project Report for the Project Dec 2019

The Project boundary map provided by RUMSL dated 19 Jun 2020

Collection of digitised maps of village boundaries

Compilation of demographic data using census 2011 data

Review of drone imagery for the project shared by RUMSL to identify EampS sensitivities in the

proposed project boundary

42 Review of Land Allotment Timeline of Un-occupied Government Land for Solar Parks

This section provides the timeline of land allotment process which is compiled from the allotment letters

of the land shared by RUMSL

421 Government Land Allotment for Neemuch Solar Park

Government land is being procured through allotments under the provisions of the Madhya Pradesh

Land Revenue Code 1959 (and its subsequent amendments) Table 41 provides details of the land

allotment for the Neemuch Solar Park

Table 41 Dates of Government Land Allotment for Neemuch Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Village

17-01-2018 7A-20(3)2017-2018 23868 Bardawada Kawai and Badi

30-05-2017 26A-20(3)2016-2017 43951 Kawai and Badi

Total 67819

Source RUMSL

67819 Ha (out of total 96894 Ha) is allocated to RUMSL through two allotment letters in the year 2017

and 2018 respectively out of the 96894 Ha of the required Government Land Both these allotment

letters predates the MP Revenue Code Amendment Act 2018 Allotment of additional 28979ha is under

process

422 Government Land Allotment for Agar Solar Park

Table 42 provides details of the land allotment for the Agar Solar Park which has been undertaken

between Nov 2016 and Jun 2019

Table 42 Dates of Government Land Allotment for Agar Solar Park

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

28022019 7A-19(3)2017-2018 5633 Bijnakhedi

28022019 6A-19(3)2017-2018 7053 Dudhpura

21062019 31B-1212019-20 1495 Dudhpura

20-06-2019 5A-19(3)2017-18 15925 Karwakhedi

28022019 4A-19(3)2017-2018 283 Kasaidehriya

20062019 3B-1212019-20 19714 Ladwan

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Allotment Date Allotment Letter Number Area Allotted in Ha Villages

280202019 2A-19(3)2017-18 1683 Madhopur

21012019 1A-19(3)2017-18 3492 Piplya Kumar

04012018 9A-19(3)2017-18 602 Naharkheda

09082018 9A-19(3)2017-18 2669 Naharkheda

30112016 4819(3)2015-16 5562 Palda

02012018 8A-19(3)2017-18 5699 Palda

02012018 11A-19(3)2017-18 16116 Pipliya Nankar

06012018 10A-19(3)2017-18 17663 Umariya

09082018 10A-19(3)2017-18 15583 Umariya

Total 127137

Source RUMSL

127137 Ha is so far allocated to the project over 2016-2019 and 5106 Ha was allocated prior to MP

Revenue Code Amendment Act 2018

423 Government Land Allotment for Shajapur Solar Park

Table 43 provides details of the land allotment for Shajapur Solar Park which took place between May

2017 and Jun 2019

Table 43 Dates of Government Land Allotment for Shajapur Solar Park

Timeline

Allotment Letter

Number

Area

Allotted

Villages

26-05-2017 03A-19(3)2016-2017 14991 Dehripal Parsula Kadula MalyaHedi Burlay Jaawdi

Bhandedi Saagdiya Baandahedi Peepalkheda Dopada

Bijana Kheriyaema Kumhariyakhas Dangicha Jaaman

11-12-2017 26A-19(3)2016-17 618 Dehripal Parsula Favka Jaavdi Burlay Chooma

Bijnakhedi Dhatravada

26-05-2017 02A-19(3)2016-17 320969 Kukdeshwar Baamniyakhedi Bordi Khakri Majhniya

Rehli Rulki Dhanda Pidoniya Goyla Aakya Chauhani

Palsaavad Son Desrapur Khokriya Tonk Hanoti

28-06-2019 03A-19(3)2019-2020 8809 Kukdeshwar Bamniyakhedi Bodi Khakri Majhaniya

Rehli Rulki Tanda Pindoniya Goyla Aakya Chauhani

Palsawaad Son Besrapur Khokriya Tonk Hanoti

Total 117697

Source RUMSL

117697 Ha is allocated to the project over 2017-2019 and 108888 ha was allocated prior to MP

Revenue Code Amendment Act 2018

43 Review of Previous Community Consultations for Allotment of Government Land

The summary of the review of the timeline of the government land allotments in FPIC villages is provided in Table 44

Table 44 Government land allocation in FPIC Villages and Requirements of Gram Sabha Resolution

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

Allotment prior to

Nov 2018

Amendment

67819 Ha 5106 Ha 108888 Ha

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DESK BASED INFORMATION COMPILATION

Timeline Neemuch Solar Park (NSP) Agar Solar Park (ASP) Shajapur Solar Park (SSP)

After Nov 2018

Amendment

28979ha 76077 Ha 8809 Ha

Total government

land in Ha

96894 Ha 127137 Ha 117697 Ha

Was the government

land allotted in FPIC

Villages pre or post

Nov 2018

Amendment in MP

Land Revenue Code

Government land allotted in

Badi and Kawai was prior to

Nov 2018 Amendment in MP

Land Revenue Code

Government land allotted

from Ladwan was on 20th

Jun 2019 which is after

Nov 2018 Amendment in

MP Land Revenue Code

Government land allotted

from Parsula was on 26th

May 2017 and 11th Dec

2017 was prior to Nov

2018 Amendment in MP

Land Revenue Code

Was Gram Sabha

resolution required

for FPIC villages

Yes No Yes

Thus as per legal provision (see section 31) the allocation of government land in BadiKawai from Neemuch Solar Park and Parsula in Shajapur Solar Park required a resolution of their respective Gram Sabha and an NOC by Gram Panchayat ERM did not get access to documentation of community consultation as part of seeking NOC from Gram Panchayats Conversation with Sarpanch of villages with ST population revealed that consultation was restricted to Gram Panchayat members Though they were initially reluctant to sign on the NOC after persuasion of District Collector they finally signed It is significant to note that the demarcation of the allotted land took place only recently (Jun to Aug

2020) and the construction process has not started yet13 The FPIC process in compliance to IFC PS-7 requirement is planned to be carried out prior to the construction works of these Solar Parks

13 The process for purchasing private land through consent process has been started in Neemuch

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

5 ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

An overview of field visits and community engagement is provided in Section 12 above This section

provides details of the consultation carried out with affected STs in the process of preparation of this

FPIC Approach Paper The process involved following three steps

Step-1 Disclosure of intention of conducting FPIC process with affected STs in villages with

significant ST population

Step-2 Disclosure of final solar park boundary and key environment and social impacts (covered

in ESIA) and Participatory Rural Appraisal exercises with affected STs and meeting potential

representatives

Step-3 Identification of ST Representatives and formation of ST Committees and build mutual

agreement between them and RUMSL on Discussion and Decision Making Framework

The Step-1 was carried out in Dec 2019 and Jan 2020 The Step-2 was carried out in Aug 2020 The

details of the process followed during each of these steps are described in sub-sections below

Note The Step-3 is planned to take place in first week of April 2021 and the Draft Discussion and Decision Making

Framework described in Section 83 will be updated accordingly

51 Disclosure of Intention of FPIC Process (Dec 2019 amp Jan 2020)

The concerned Gram Panchayats identified with STs Population in previous sections were contacted

to inform them about the overall project and intention to conduct a FPIC process involving affected ST

families along with ESIA process The process included preparing a project profile in Hindi (See

Appendix A-B and photo documentation in Appendix C) and handed this over to the elected

representatives of concerned Gram Panchayats These meetings were attended by local RUMSL

personnel The project overview was explained during the meeting and their queries answered

511 Disclosure of Intention to Conduct FPIC Neemuch Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 51 below

Table 51 Disclosure of FPIC with Concerned GPs for Neemuch Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Badi 1 Sarpanch of Badi Village

2 Kalam Singh (Traditional Head

of Bhil Community in Mama basti)

3 Government Teacher in Bhil

Community

10-12 men from the village

6-7 women from ST (Bhil)

community

5th of December

2019

Kawai 1 Ghasilal (Ward Member in

Kawai Village)

2 Local communitypeople of

Kawai Village

20-25 persons from Kawai

Village were present

4-5 women

6th of December

2019

512 Disclosure of Intention to Conduct FPIC Agar Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Agar Solar Park

The details of the people contacted during this stage is provided in Table 52

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ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Table 52 Disclosure of Intention to Conduct FPIC for Agar Solar Park

Name of Gram

Panchayat

Name of Person to whom

Project Information Sheet was

Provided-

Number of other community

members present during the

meeting

Date of the

Meeting

Ladwan (two

villages covered-

Ladwan and

Kerwa Khedi)

Mohan Singh (Sarpanch for

both villages)

10 persons in Ladwan and

Kerwa Khedi each

No female members were

present in Kerwa Khedi

In Ladwan seven (7) women

members were present in an

FGD that largely included

women

19th December

2019

Repeat visit on

29th January

2020

513 Disclosure of Intention to Conduct FPIC Shajapur Solar Park

The intention to conduct FPIC was done at an early stage of carrying out the ESIA for Neemuch Solar

Park The details of the people contacted during this stage is provided in Table 53

Table 53 Disclosure of Intention to Conduct FPIC for Shajapur Solar Park

Name of Gram

Panchayat

Name of Person to whom Project

Information Sheet was Provided

Number of other community

members present during the

meeting

Date of the

Meeting

Parsula Since there was no Sarpanch or

Gram Panchayat member present

during meeting one project

information sheet was provided to the

entire community which was

circulated within everyone present

during the consultation and signature

of 1 person from group (Mr Sujit

Singh) was taken

~15 persons in Parsula

Shajapur were present during

consultation also one separate

consultation was held with

women group having ~10

participants

30th January

2020

One common feedback during the consultations undertaken with the community in general and STs in

particular was they were not aware about the solar park boundary to judge which land will be used by

Solar Park and what will be left out for them The ESIA process was working on avoidance and

minimization measures Therefore they were informed that once the boundaries are fixed by the

design team the details will be shared with them

52 Disclosure of Project Boundary and Key Environment and Social Impacts and PRA Exercises with STs (Aug 2020)

The solar park boundaries were finalized and provided to ERM in the last week of June 2020 by the

design team The draft environment and social impact assessment was completed in the month of

Aug 2020 The field-based activities remained suspended from Mar to Jun 2020 due to strict

restrictions imposed on travel and group activities due to Covid-19 pandemic Therefore the next

round of information disclosure and community consultations took place only in Aug 2020 at the time

of the RAP survey

Meeting Sarpanch and a few available Panchayat members

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village level Introductory amp Project disclosure meeting

PRA exercises with STs and information collection for IPP

- livelihood resource mapping

- mapping of social relations and influence and

- village profile

Identifying prominent persons from STs as potential representatives in FPIC process

Understanding the traditional decision-making system and existence of IPOs through key-

informant interviews

The schedule of field visits carrying out these activities is provided in Table 54 and details of these

activities are provided in subsequent sub-sections

Table 54 Site visit Dates and Site Activities

Solar Prak and FPIC Village

Date Site Activities

Agar Solar Park- Ladwan Village

06082020 Visited Ladwan and contacted Patwari Sarpanch and Panchayat Secretary and Fixed a Project Disclosure Meeting (a common meeting including all communities) for next day

07082020 Village level Project Disclosure Meeting at Ladwan

Participatory social mapping and information collection for IPP

Preliminary discussion with 2 Bhil families

08082020 ERM team met Sarpanch of Parsula to brief him and fix a meeting on 10th Aug

ERM team collected land details and village revenue map from Patwari of Ladwan

Shajapur Solar Park- Parsula Village

10082020 ERM team met Sarpanch and a few Panchayat members at Parsula

Shared Project Disclosure note and fixed a meeting with Bhil households of Parsula on 11th Aug

Mapping of social structure of Parsula village and village profiling

11082020 PRA exercise with Bhil community of Parsula resource mapping at Parsula mapping of social relations and influence

Discussion on impact of the Project on grazing land

Understanding the internal decision-making system amongst Bhil

Identifying prominent persons among Bhil families

12082020 Travelled to Neemuch Site from Agar

Neemuch Solar Park- Badi and Kawai village

13082020 Meeting with Sarpanch Badi and sharing of the Project Disclosure Note with Badi community (including all communities)

Social and resource mapping with Bhils in Badi

Understanding the internal decision-making system among Bhils at Badi

Identifying prominent persons among Bhil families

14082020 PRA at Mama Vasti Badi Resource mapping at Badi and Mama Vasti

Filling of village profile form for Badi and Kawai

Discussion on Impact of the Project on grazing land

Understanding the internal decision-making system at Kawai

Mapping the list of tribal leadership in village

Introductory visit to Kawai and sharing of Project Disclosure Note

15082020 PRA at Kawai with Bhil households

Identification of village leaders for Bhil of Kawai

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

521 Disclosure and PRA Exercises in Agar Solar Park (Ladwan Village)

5211 Meeting with Sarpanch

ERM team met Sarpanch of Ladwan Gram Panchayat at his residence in Karwakhedi village It was

learnt that Ladwan GP had submitted a letter to District Collector earlier expressing their unwillingness

to give away the government land for Solar Park The key concerns of the villagers included

Whether government has gone ahead on issuing tender for the Solar Park site Especially

without replying to their concerns

Whether the land identified by GP for establishing a Gaushala (shelter for abandon and old cows)

is allotted to the proposed Solar Park

How would the Solar Park address long term un-employment and livelihood issue in the village

ERM informed on its intention to conduct FPIC process covering the ST families in Ladwan village

and some of these questions will be answered during a structured process of discussion

5212 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch

Ladwan consists of two revenue villages Karwakhedi and Ladwan The Gram Panchayat office is at

Ladwan and the current Sarpanch is from Karwakhedi The village is dominated by the Gujjar

Community that is the second largest community in terms of population Scheduled caste is the

largest social group of village comprised of Banchhda Charmkaar Balai and Beldar

A community meeting was held where the Talati (village land revenue officer who keeps the land

records) was present The Talati informed them on the status of land allocation for the Solar Park

ERM showed the map showing the optimised project boundary with khasra numbers of the allotted

land ERM team informed them on the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The community expressed their

key concern about the impact on their livestock which forms an integral part of their livelihood

Community Meeting at Ladwan Explaining potential impacts and benefits

5213 PRA Exercises with STs

ERM held a meeting at a settlement cluster (nai-vasti or new settlement) where STs and SCs lived A

general discussion on their village history and livelihood issues were discussed The participation

level in this discussion was good A cross section of people from various age-groups and gender

participated in this discussion and shared relevant information and expressed their opinion A

separate meeting was held with women too (see Photos below)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

According to the elders of the Bhils their generation is the 9th generation residing in Ladwan village

Prior to the three families (Gujjar Bhil and Charmakaar) establishing this village the village had

Muslim population in medieval times and they deserted the village as some epidemic broke out Three

people from Gujjar Schedule Caste and Bhil community first came from another village and settled in

the village As time passed other families from Banchada-Nat Sondhiya Balai and other started

settling in the village

The discussion also involved their religious and cultural practices and shrines There are three

Chabutarascaffold in the village which are their main place of worship There are two shrines ie

Gowal ka Devta close to the grazing lands and Nagdevta adjacent to the new colony outside the

village

A village corner meeting with men Participation of women in group discussion

The Shrine of Nag Devta at Ladwan Meeting with women at Ladwan

After the general PRA exercise involving a larger group a few active participants were picked up to

have more focused discussion on a few aspects Through participative discussions in these smaller

groups the social hierarchy and livelihood resources used by STs (and SCs living in the village) were

mapped

Creating the map of social hierarchy and influence The map drawn by community showing their

livelihood resources

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Social Groups and Influence Map

Most of the families in Ladwan have cattle that includes cow buffalo and goat Approximately 650 cattle that includes 450 cows and 200 buffalos exists in the village There are about 44 cows kept by Bhil households which is about 4 (on an average) cow per family Bhil households own about 100 goats which is about eight (on an average) goats per family Only one family (Chander Singh) owns two buffaloes Few individuals work as grazier for a cluster of houses and are paid 150 per cattle per month by the owners of cattlersquos The cattle owners hire women and youths for bringing fodder feeding and cleaning of cattle sheds collecting cow dung Payment is done on the monthly basis or the basis of hours of work The common land situated at the Right hand side of the main approach road to Ladwan village from Agar is used by the ST community for grazing their livestock ST families bring fodder firewood and fruits from the same portion This is the only place during rainy season where fodder is available for four months as rest of the area is under crops ST families cannot accesses any other commons which is encroached by the dominant familiescommunity According to the ST community if the village commons is taken by solar park then they do not have any option but to sell their livestock as they cannot afford to buy fodder for the livestock unlike the richer families in the village

Free grazing of a mixed herd of cattle and

buffaloes

A grazier bringing back cattle home at evening

5214 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 55 Names of Potential Representatives in Ladwan Village

Section of Representation Sl No Name of Representative Contact Number

Clan Representative 1 DevSingh-Kanhayialal

2 Mangushanker-Amar Singh

Gujjar

Sondhiya

Other OBC

SC

Bhil

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of Representation Sl No Name of Representative Contact Number

Youth Representatives 3 Babulal-Gangaram

4 Anandilal-Lalsingh

Traditional leader or Mukhia 5 DevSingh-Kanhayialal

522 Disclosure and PRA Exercises in Shajapur Solar Park (Parsula Village)

5221 Meeting with Sarpanch

The ERM team for this field visit was led by the IPs Expert comprised of four members including a

woman to facilitate participation of women The ERM team first met the Sarpanch of Parsula who was

not present in initial meeting held earlier in January 2020 The objective of this meeting with Sarpanch

was to share the project information with him and appraise him of the intention of the ERM team to

hold a meeting and participatory appraisals with ST families

5222 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for Hindi version

and Annexure-D for English version) to Sarpanch The Disclosure note had a map showing the

optimised project boundary with khasra numbers of the acquired land It included the key potential

environment and social impacts and what mitigation measures are proposed in ESIA report prepared

by ERM

5223 Joint Site-visit with Sarpanch and Other Leaders

Sarpanch wanted to visit the proposed project site along with the Patwari to explain him the project

boundary based on the land allotment records available with him ERM team facilitated a site visit by

Sarpanch Naib Sarpanch and Kotwar in presence of Patwari to explain him the proposed project

boundaries He shared his observations and concerns over the allocation for the Solar Park which is

used for grazing domestic livestock by villagers including ST households However he agreed to

facilitate an exclusive meeting with ST families next day

5224 PRA Exercises with STs

The Kotwar of Parsula village belongs to ST community He played a significant role in inviting the ST

families to participate in the meeting as well as shared crucial information on their social and cultural

aspects The meeting with ST families included approximately 40 people both men and women from

various age-groups ERM team showed them the map of Solar Park and explained them locations of

key components The community was divided into two to three groups to hold participatory

assessments

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Figure 51 Photos of Meeting with STs at Parsula and Participatory Assessments

Site visit with Sarpanch and explaining Project boundary

Participatory mapping of livelihood and natural resources within Project boundary

Community meeting with ST from Parsula village at Project site

Identification of a medicinal plant during site walk through

Facilitation of discussions with ST women from Parsula village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gwalon-Ka- Mandi within Solar Park Boundary

Grazing lands used by Bhils Mapping

Rajputs are the dominant caste in the village and a person from the Rajput community is the Patel

(traditional leader) of Parsula village Rajputs control all village resources including sources of drinking

water and the irrigation

There are four religious places (Devsthan) of Bhils in Parsula village At all these places the priest is

from the Bhil community One platform is situated within the land allocated to the Project which is

called Gwalon ka Mandi It is recognised by all the community as the women worship at this place to

have good rains for better crop yield or agriculture Community gatherings are organized at this place

on few occasions in the year

The Bhil households reported to own about 2-3 (maximum 10) cows on an average per family and

about 2-3 goats Some families manage to sell three to five goats in a year ₹3000 to ₹ 8000 per

goat depending on the quality of the goat Families who rear cows manage to sell about 4 to 6 litre of

milk ₹40 per litre to private dairy at Chouma village The Bhil community uses the lsquoBirdirsquo hillock

adjacent to the northern side of the Parsula village for grazing their livestock along with other

communities residing in the village

5225 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table

56 They will be considered for nomination to the representative committee and contacted for

capacity building on FPIC process

Table 56 Names of Potential Representatives in Parsula Village

Section of

Representation

Sl No Name of Representative Contact Number

ClanHouse Cluster

Representatives

1 Meherbaan Singh 7970187292

2 Goverdhan Sigh 8718098704

3 Rahul 9098266244

4 Maakan 6162432391

5 Dheeraj Singh 8871384373

6 Rambabu 9752340827

7 Ballu 9399263367

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Sl No Name of Representative Contact Number

8 Bheru 7725027924

Youth Representatives 9 Kamal 6267658647

10 Rajesh 9009278550

Woman Representatives 11 Payal NA

Traditional leader or

Mukhia

12 Bhawanlal NA

523 Disclosure and PRA Exercises in Neemuch Solar Park (Badi and Kawai Villages)

5231 Meeting with Sarpanch

Gram Panchayat Badi has 3 villages namely Badi Kawai and Sucharoki The ERM team met

Sarpanch of Badi on 13th Aug 2020 and explained the intention of holding meetings with ST families to

inform them about the FPIC process He advised that we should brief the community members on the

current status of the project first As most of the ST families work as wage labour he advised the

team to come early in the morning He assured to inform the ST families and ask them to cooperate

5232 Disclosure of Project Boundary and Key Impacts

ERM team handed over a Potential Project Impact Disclosure Note (see Annexure-E for a sample

Hindi version and Annexure-D for sample English version) to Sarpanch and other people present in

the meeting The Disclosure note had a map showing the optimised project boundary with khasra

numbers of the acquired land It included the key potential environment and social impacts and what

mitigation measures are proposed in ESIA report prepared by ERM The meeting was held at the

center of the village

The community believes that Badi village is 1150 years old calculated based on the date inscribed on

a stone slab in the oldest house in the village It is a common belief that Bhil community came to the

village along with Rajputs The living memory of the community members goes at least six

generations back Badi has ~300 households and there are ~80 ST households Rajputs are the most

dominant community in the village Brahmins and Gujjars also influence the decisions of the village

Gujjars are the largest social group of the village followed by Bhils There are around 30 Muslim

families and they also have some influence on decision-making of the village Apart from Gujjar there

are three other OBC groups that are Sutar Kumhar and Nath

The STs live in three separate habitation clusters The first is in the main village habitation second is

roughly around 05 kilometres away and is called Khari ka Jhopda The third is located further away

around 25 kilometres Both are not connected through roads and one has to walk to reach them The

third habitation is further away where a group of recent migrants form Jhabua (referred as Mama Bhils

by villagers) live and is referred as Mama Basti These Bhil families came here to work as labourers in

the stone mines almost two decades back

At Kawai a meeting with village elders was held prior to discussion with ST families Rajput Gujjar

and Dhakad are the three dominant castes There are only 17 Bhil households in Kawai village

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Village disclosure meeting at Badi Meeting village elders at Kawai

5233 Site-visit and Walkthrough

The ERM team walked through the site to visit different clusters of ST settlements in Badi and Kawai

Some of the photographs of the main village and satellite smaller settlements where STs live is

provided below

A typical ST house in Badi main settlement The Platform where STs hold their community

meeting

The Khari ka Jhopda Mama Vasti

5234 PRA Exercises with STs

As ST households were found scattered in several small satellite settlements multiple meetings were

held involving a small group of 7 to 12 participants Every ST settlement or cluster of households

usually has a platform under a tree which is used for community meetings and decision making This

space was used for holding PRA exercises Participants were engaged in conversation on their social

relationship and decision making process The understanding gained from these discussions were

then demonstrated in diagrams They were asked if the diagram portrays the right picture or not

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Livelihood and resource mapping in Badi A smaller cluster level meeting at Badi

The village livelihood resource mapping- Kawai Participatory process of understanding

livelihood resources in Kawai

The social relationship and influence map for

Kawai

The social relationship and influence map for

Badi

Similarly a map of the village and surrounding area was created using the information shared by

participants in these meetings They were asked to show where they carry out their livelihood

activities such as farming and grazing etc They were asked to indicate those areas and identify

natural resources or cultural sites located in those locations

Some of the information important for deciding on the FPIC approach collected from these participatory

exercises are as follows

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Gram Panchayat Badi has total 16 wards out of which Badi has 9 wards Out of these 9 Wards 2

are reserved for the STs (Bhil)

There are about 250-300 cows kept by Bhil households which is about 4 (on an average) cow

per family Bhil households own about 450 goats which is about 5-6 (on an average) goats per

family Hence for ST families goat is a more popular livestock than cows

Almost all the houses have used locally available stone in constructing the walls of the houses

Pucca houses have used cement and sand as mortar whereas kuchha houses have used mud

The communities fear the loss of access to these stones will make house construction costly and

people who earn from stone quarrying will be impacted

The traditional leader (Mukhia) of Bhils decide on disputes related to marriage and other social

issues Women do not play an active role in decision-making process

Each household cluster of Bhil households have a number of cultural sites where local deities are

worshiped For example in Khera-ka Majra has four cultural sites Ghadiya Bheruji Bhut Maharaj

Bhut Babaji and Dungri Balaji Similarly there are a few cultural sites for goddesses like Leva ki

Mata and Dahana Mataji are located within the Project boundary In all these shrines the priests

belong to Bhil community

STs (Bhils) worship Devnarayan Khejara Mata and Sawria jee in Nimbaheda in Rajasthan The

religious leaders from these places are held with respect and are accepted as mediators or

decision makers for important matters

5235 Identification of Potential ST Representatives

The active members during group discussion were identified and their names are provided in Table 57

They will be considered for nomination to the representative committee and contacted for capacity

building on FPIC process

Table 57 Names of Potential Representatives in Badi and Kawai Village

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Clan Tola

Representative

Badi Main 1 Gheesalal-Nathulal 9575486482

2 Basantilal-Mangilal 7354345531

3 Motilal-Hiralal 9109003022

4 Nanalal-Ratanlal

Khaira Ka Jhopda 5 Lalu ndashRamlal

6 Tulsi-Devilal

7 Tawarlal-Vardaji

Kawai 9 Ramlal-Hajarilal

Ratanlal

Bherulal(Teacher)

Bherulal- Bhawani

Shantilal

Fargulal

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

ENGAGEMENT LEADING UP TO FPIC APPROACH PAPER

Section of

Representation

Name of Sub-

group

Sl

No

Name of Representative Contact Number

Youth

Representatives

Badi 10 Omkaar ndashKailaji 8718057436

11 Shyamlal-Mangali 9302086906

Mama Vasti 12 Dinesh ndashThawar Singh

13 Prakash-Ramesh

Woman

Representatives

Badi 14 Kesarbai-Devilal

15 Kavita-Dhanraj

Mama Vasti 16 Shanti-Ramesh

17 Mamta -Naklesh

Kawai 18 Sunder Bai-Bherulal

(Sudibai-Devilal Shimla bai-

Chandrulal LeelaBai-

Chittarmal Prem bai-Gopilal)

19 Kanyabai-Bhuvaniram

Traditional leader or

Mukhia

Badi 20 Bhawani-Laxmi

21 Amar singh-Ramlal 7354325923

53 Presentation of lsquoFirst Draft Discussion and Decision Making Frameworkrsquo to RUMSL

A key element in designing a FPIC Process is a mutually agreed and appropriate lsquoengagement and

consultation process14rsquo The lsquoFirst Draft FPIC Approach Paperrsquo was prepared and shared with RUMSL

for their review and comment A virtual workshop was held with RUMSL team on 27th Aug 2020 In

this workshop PS-7 requirements of ICP and FPIC in general and the specific FPIC process designed

for Solar Parks was presented and discussed After their feedbacks were incorporated the lsquoDraft

FPIC Approach Paperrsquo was shared with IFC-WB for review and comments

The objective of these internal discussions are to build an internal institutional consensus on the

appropriateness of the designed engagement and consultation process to comply with the

requirements under IFC PS-7 The subsequent steps for consultations with affected STs and finalizing

a mutually agreed lsquoDiscussion and Decision Making Frameworkrsquo is discussed in Section 81

14 GN-ampGN22 emphasizes to have a shared view of the FPIC process between Project proponent and affected IPs The Project

proponent and affected IPs to agree on an appropriate engagement and consultation process as early as possible and commensurate with the scale of impact and vulnerability of the communities

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INDEPENDENT FACILITATOR AGENCY

6 INDEPENDENT FACILITATOR AGENCY

61 Need for FPIC Process Facilitation Agency

An independent agencyexpert to facilitate the FPIC process is required for the following reasons

There is a strong likelihood of other dominant communities in the village intervening and trying to

influence the internal discussion and decision making by IP The presence of the FA will help

documenting such attempts of external intervention and the presence of the FA may act as

deterrence and help avoid such attempts to interfereinfluence the process

The IP representatives need an intensive process of orientation and capacity building It will be

more effective if this is conducted using the Malvi dialect instead of Hindi Therefore a good

community facilitator with familiarity on Malvi dialect will be helpful

The women and youth will need capacity building and facilitation of their internal discussions prior

to the community level meetings

The facilitation support to IP community in general and IP representatives in particular will require

proficiency in the local dialect Malvi and knowledge of local livelihoods and alternative options

Involvement of a local agencyexpert who also speaks the local dialect and with a good

understanding of local livelihoods (particularly grazing and livestock keeping) will demonstrate

fairness and transparency in the process

62 Screening of FPIC Process Facilitation Agency

ERM identified Institutions (Universities Government Departments and Research Institutes etc)

NGOs and INGOs located and active in Madhya Pradesh state After a preliminary screening selected

potential individualsorganizations were approached to find out their availability and willingness for the

assignment The criteria used for screening included qualification profile affiliation with the type of

institutionsorganizations nature of worksprojects completed working experience with IPsTribes in

Madhya Pradesh conducting meaningful consultation community mobilization and stakeholder

engagement familiarity with World Bank Group safeguardsrsquo policies and procedures comfort with

written and spoken English and local dialects etc The list of independent experts and organizations

screened for the role of facilitation agency is provided in Table 61

Table 61 List of IndividualsAgencies Screened for Facilitation Agency

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

1 University of MP Bhopal

Department of Sociology

Dr Arvind Chauhan

Professoramp Head

7999345226

Two candidates with post-PhD and PhD

qualifications from Department of

Sociology interested in working but having

no experience were not considered

2 Dr BR Ambedkar

University MHOW MP

Professor RD Maurya

Former Dean amp Head

Department of Sociology

Old AB Road Gram

Dongargaon Dr

Ambedkar Nagar Madhya

Pradesh 453441

07324 274 377

The retired Professor amp Dean

recommended a college lecturer

belonging to BhilIP from Govt college

Neemuch may be considered as a

resource person in future as appropriate

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

3 Tribal Research and

Development Institute

Bhopal

Rita Singh

35 Shyamla Hills Rd

Bhopal Madhya Pradesh

0755-25570882551257

This institute of MP government is

involved in administration and research

aspects of tribes in Madhya Pradesh

There are full time staff and the person

required for the assignment is not

available However the Government

functionaries may be the resource persons

in sharing information and performing

advisory roles during implementation as

appropriate

4 Institute of Social

Sciences Ujjain

Dr Tapas Faculty

7342510978

Berasiya Rd Navi Bagh

Bhopal Madhya Pradesh

462038

0755 273 0946

The faculty suggested to contact the

Bhopal based NGO (Samarthan)

5 The Samarthan NGO

Bhopal

Shradha kumar

Bhopal Madhya Pradesh

shrdhasrigmailcom

9826912948

The Program Director reported no work

being undertaken by the NGO in proposed

project area and was reluctant to

undertake the assignment She however

mentioned to help coordinating with the

local NGO if available in Neemuch area

and has not responded so far

6 Xavier Institute of

Development and Action

and Studies Jabalpur

Dr Mehul Chauhan

Former Faculty

9977064882

The former faculty suggested two NGOs

(Concept Society and Gramodyog

Sansthan)

7 The Concept Society

Indore

Ms Hemal Kamat Director

9425350272

The candidate appeared for interview has

preferred to be engaged independently

instead of as a NGO

8 Gramodyog Sansthan

Mandala MP

Mr Hariom Shukla

Manager

7999064147

Even after agreeing no one finally

appeared for personal discussion and

interview

9 Balram Sewa Samaj

Neemuch

Mr Kamla Shankar

Manager

7838960968

The only NGO reported to working on

legal aspects in Neemuch area has not

expressed interest to work as FA

10 UNICEF office Bhopal Nagesh Patidar Project

Officer WASH

97525 98212

The staff of UNICEF suggested the name

of suitable candidates and all of them

have appeared for interview and have

expressed the interest in proposed project

work

11 Debate Trust (Referred

by Action Aid Bhopal

Amitav Singh and Leena

Singh

Debate Trust

Duplex C-22 Alkapuri

Near DRM Office

Habibganj Bhopal-462024

Action Aid India had prepared a brief

manual on FPIC (published in 3 Indian

Languages including Hindi in 2018)

reflecting the Indian context and its related

legal system The manual was intended to

help CSOs for their ready reference and

larger reach out Mr Narendra Sharma

who was based in Actionaidrsquos office at

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INDEPENDENT FACILITATOR AGENCY

SNo Name of Institutions

and Organizations

Contact Person and

Contact Details

Remarks

0755-2985007 0755-

2417656 9425018144

9425004556

debateindiagmailcom

Bhopal played a key role in preparing the

Manual in Hindi version

Mr Narendra Sharma referred the NGO

Debate Trust who had experiences in

working with Panchayats

A screening using preferred criteria was undertaken of the shortlisted agencies and details are

available in Appendix-F None of these agenciesindividuals have worked for a FPIC process earlier

Hence an agency which was available and willing to undertake the activity was taken on a trial basis

to help in conducting PRA exercises and sample household survey required for preparation of IPP

63 Roles and Responsibility for FPIC Process Facilitation Agency

The role and responsibilities of the FPIC FA will be as follows

Table 62 Roles and Responsibilities of FPIC FA

Phase Responsibilities

I Formation of local committees with STs Representatives

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Hindi (Malwi dialect) Translation of TDPIPP and designing Information sharing tools

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs (particularly women and youth groups) and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation of the FPIC Process and Preparation of FPIC Process Report

Documents of outcome of the FPIC Process including FPIC AgreementMOUJoint Statement of PrinciplesAgreed Mitigation Plans etc

64 Terms of Reference for FPIC FA

The terms of reference for FPIC FA covering villages to be covered specific responsibilities

deliverables personnel requirement and organizational profile and experience is provided in

Appendix-G

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

7 KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The PS-7 recommends to have a lsquoshared view15 of achieving ICP or FPICrsquo mutually agreed ldquoFPIC

Decision Process Framework Documentrdquo which is based on principles of Good Faith Negotiation

(GFN) The Designing a lsquodiscussion and decision making frameworkrsquo to achieve the FPIC as per GN

on PS-7 should considers the socio-political context within which the affected IPs households live as

well as impacts of the Project This section deals with key-elements considered for designing the

FPIC process as per requirements in IFC PS-7 and GN-7

71 Use of Language

The PS-7 emphasizes use of the IPs language in the FPIC process It was found that BhilsBhilala in

Ladwan and Parsula are relatively small community and they have been living with close socio-

cultural ties with other communities Hence they use Bhilli (their traditional language) very little The

proficiency of the current generation in the Bhilli vocabulary is too limited to use this in discussion of

the Project and its impact Hence their preference is the use of local (Malvi) dialect of Hindi which

they speak along with other communities in the village The Bhils in Badi and Kawai speak Malvi

dialect with some influence of Rajasthani language as it is at the border of Madhya Pradesh and

Rajasthan

In general the written material on the project is expected to be in Devnagri script using the vocabulary

consistent with Malvi dialect to the extent possible The FPIC FA will have community facilitator who

is conversant with Malvi and explain the written material using the conversational Malvi dialect

72 Use of Customary Decision Making Process and Traditional Leaders

The Bhils in Ladwan reported that they resolve disputes between families through intervention of the

elderly member of the familyclan (Baijwal and Dalodia) or go to other prominent people in the village

such as the priest in the local temple or the landlord on whose land they work The customary leader

of Bhils who covered a cluster (~10 to 12) of Bhil settlements existed earlier (at least 3 generations

back) and the current generation has not sought their help in dispute resolution in their living

memory

The BhilBhilala of Parsula belong to a number of clans (Dalodia Paretia Renkewal Vasunia etc)

and the elder member of the clan is usually approached to resolve any internal disputes There used

to be a collective council (panchayat) covering 5 to 10 villages but these have been non-functional

over the years They also approach the village Sarpanch and prominent personalities from other

communities in the village to resolve disputes involving land and livestock The matters related to land

are finally referred to the Tehsildar (land revenue officer) for resolution The local administration also

plays a significant role in resolving inter-community disputes

In Badi-Kawai they still have a traditional Mukhia (leader) who wields influence in community

matters Each Bhil village has an elder who is considered the mukhia or leader There are designated

places where elders hold community meetings to discuss conflicts among Bhils and matters related to

their social norms and customary laws governing marriage and inheritance etc If matters are not

resolved at the village level community elders (Biradari Panchayat) then the matter is escalated to a

forum of community elders from 5 or 10 villages with Bhil population The highest level of escalation in

the customary decision making system is to refer the matter to a Biradari Panchayat of community

elders from 25 Bhil villages16 These traditional leaders residing outside of the villages directly

impacted by the Project are accommodated as member of the proposed Mediation Committee

15 Refer GN-7 GN22 which mentions that lsquothis should ideally be done through a framework document or plan and client should

document support for the agreed process from the affected population 16 GN-7GN36(i) acknowledges that there may be circumstances where formal and informal leaders of the Indigenous Peoples

reside outside of the Projectrsquos area of influence

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

In general the affected IPs communities use familyclan elders to resolve minor disputes and involve

prominent people from other communities like the priest Sarpanch or other prominent personalities in

the village for resolving their conflicts The matters related to land is resolved by intervention from

local administration (Tehsildar and District Collector) If the matters are related to their customary laws

on marriage social relationship or inheritance the unresolved matters can be escalated to a council

that comprises of elders from 5 10 or 25 villages The traditional Biradari Panchayat has been losing

its power as the younger community members considers their decisions regressive and approach

Gram Panchayat leaders (Sarpanch) or take help from the Police and Court of law Considering the

preference of new generation to go to non-ST Gram Panchayat leaders and local administration they

are considered for the Mediation Committee

73 Promoting Participation of Women and Youths

Women specifically stated during consultation that they do not participate in decision making in their

traditional community meetings which are convened for resolving disputes Though the women come

to attend the community meetings they hardly ever participate and express their views

The BhilBhilala youths do not have traditional or customary forums at which they express their views

They accept the decisions taken in the family or at the clan-level However there are a few educated

young people in the village who have distinct views about their future

As free expression of the views by youths and women in BhilBhilala community meetings is not a

social norm separate meetings of these groups where they are able to express their views openly is

proposed as part of their internal decision making process The FPIC FA will facilitate these separate

meetings and keep external interventions in these meetings to the minimum The views expressed by

them in these meetings should be tabled in joint meetings of the community for consideration

74 Expectation on Material Information Prior to Discussion

It is understood from the preliminary round of discussions with ST communities that they expect the

following information to be shared with them

Details of the Project (lay-out plan) and the related activities that are going to be implemented

Schedule of starting of the possession of allotted government land and purchase of pattaprivate

land

Details of land khasra numbers proposed to be taken for the project

Amount of paymentcompensation consideration amount of the land and assets (including on the

government land) that will be taken by the project

What economic and other entitlements and benefits will be provided to the families dependent on

the allotted government land

If private land is purchased then they will lose the source of income generation or livelihood (as

they are hired for a year on contract basis daily wages take land on lease for cultivation and

take care of the cattlersquos etc) what will their entitlements (economic package) be

What options will the Government or the Solar Park Company provide as alternative to the

common grazing land as cattle and goat breeds they keep require free open grazing and not stall

feeding

What alternative livelihoods will be offered to those Bhil families who will be landless after losing

the governmentpatta land they currently use (though owned by others)

It was expressed that the Project proponents share many documents but the community wants

confirmation that the content is authentic Hence community expects that signed and verified

documents should be shared as part of the FPIC process which can be referred in case of conflict or

contradiction

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

The relevant information is scattered in ESIA RAP and IPPIPDP A concise information disclosure

dossier will be prepared by ERM and used by FA during the FPIC process

75 Need for Capacity Building of IP Representatives

The interaction with potential ST representatives from these FPIC villages shows that convening a

community meeting and steering the internal discussion to reach consensus will be a new experience

for them Most of them are semi-literate and will face challenges in understanding the Project details

on their own such that they can then explain it to other community members Therefore following

activities are required

A capacity building workshop for the potential IP representatives to explain the Project its impact

and mitigation measures in the Draft IPPIPDPTDP in detail Although the RAP-LRP disclosure

will happen at the community level and ST families will attend those meetings the Draft

IPPIPDPTDP will also explain these entitlementsbenefits in simple language

Presence of experienced community meeting facilitators (from FPIC FA) for community meetings

will help these ST representatives to have focused discussions documentation of views

expressed and decisions made in those meetings

The women and youths usually do not participate in taking decisions on community issues

Hence the women and youth representatives need orientation through separate sessions

In addition to formal trainingorientation sessions the IP representatives may be taken on

exposure visits to nearby solar parks for improving their understanding

76 Need for a Mediation Mechanism

The ST Committee will hold meetings with the representatives of the Project (RUMSL) to discuss

relevant points and reach a mutual agreement While such discussions are likely to result in reaching

mutual agreements on a number of agenda items the discussions may hit dead-end on some issues

All such unresolved issues will be documented as a dissent note for their reconsideration in the second

round of meeting

If the discussion between ST Committee and the representatives of the Project on any significant issue

reaches a deadlock the matter will be referred to a mediation mechanism The mediation will be done

by a high level committee which will comprise of 4 members

An IP representative nominated from the larger tribal leadership of the area (from their customary

council of 10 or 25 villages) but not belonging to the Project village

The elected representative of the concerned Gram Panchayat or a person nominated from GP

and acceptable to the ST Committee

A senior officer from the District Tribal Welfare Department

District Collector or an officer nominated by them

This Mediation Committee will be constituted at the beginning of the FPIC process and will be activated

only in the case of a significant deadlock This Mediation Committee will be involved to read the Final

FPIC Agreement (even when no matter is referred to them for mediation) and satisfy themselves that it

reflects mutual agreements reached through a fair and credible process17

17 This is proposed in order to provide an external validation of a free and fair FPIC process prior to signing of the FPIC

Agreement

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

77 Following Principles of Good Faith Negotiation

Good faith negotiation generally involves 6 principles (see Table 71) The proposed FPIC Discussion

and Decision Making Framework (DDMF) adheres to these principles with slight modifications

keeping the public health concerns associated with the Covid-19 pandemic

Table 71 How GFN Principles will be followed in Covid-19 Pandemic Context

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

1 Willingness to engage in

a process and availability

to meet at reasonable

times and frequency

Both parties need to agree to avoid large gatherings and un-necessary

physical meetings A mechanism for tele-consultations will be explored to

keep the physical meetings to the minimum

The internal discussion meetings of STs will be in smaller groups (in the

open rather than in closed rooms) to avoid large gatherings

There will be two meetings between RUMSL and ST Committee and

similarly number of proceedings by Mediation Committee will be limited

The meeting schedules will be finalized beforehand and Covid-19 public

health protocols as applicable at that time will be followed

2 Provision of information

necessary for informed

negotiation

The basic information on the Project and its potential environment and

social impacts are already provided in state language (Hindi)

The essential information requirement by ST Committee is identified and

these information will be provided in simple information dissemination

tools The FA will further explain them for their better understanding

3 Exploration of key issues

of importance

The likely key issues of importance are grazing and cultural sites located

within Solar Park boundary A small task-force comprising of

representatives of RUMSL as well as ST Committee will carry out a field

inspection prior to their first meeting The task force will observe Covid-

19 protocols issued by Government

4 Mutual acceptable

procedures for the

negotiation

The lsquoDiscussion and Decision Making Frameworkrsquo signed by both parties

will have a commitment to hold all meetings and activities complying the

Covid-19 protocols and advisory issued by Government

5 Willingness to change

initial position and modify

offers where possible

The first meeting will resolve issues where both parties can reach

agreement easily The positions of both parties on contentious issues will

be recorded during first meeting The FPIC FA will record the written

positions of both parties on these contentious issues and share with

them The FPIC FA and ERM will hold separate meetings with both ST

Committee and RUMSL Team after 15 days to understand any changes

in the stated position The FPIC FA and ERM will take a decision on

holding the second and final meeting on these contentious issues when

both parties agree to modify their offers and a meaningful discussion is

possible

6 Provision for sufficient

time for decision making

The ST Committee will benefit from the capacity building and assistance

through FPIC FA to conclude their internal decision making The first

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

SNo GFN Principle How will it be followed and Considerations of Covid-19 Public Health

Concerns

meeting between ST Committee and RUMSL Team will be held after a

sufficient gap As the number of ST families participating in the FPIC

Process is small it is expected that it will not take them long to reach

internal consensus However STs will be encouraged to have more

meetings internally to be able to discuss within themselves

78 How to Achieve ICP for Mainstream and FPIC for Affected Indigenous Peoples in a Peaceful and Supportive Environment

In these FPIC villages the Project requires to achieve both ICP for mainstream communities and

FPIC for ST The existing and past relationship between RUMSL and affected communities plays a

significant role in FPIC process It is learnt from the news report as well as from consultations that

some villages (particularly Ladwan) have decided to protest against the Solar Park as loss of grazing

land is not acceptable to them The protesters had organised a demonstration and also submitted

letters to the District Collector regarding their objections Ladwan village has a strong network of

women self-help groups (SHGs) who are interested in a dairy development program Thus reduction

in grazing land is perceived by them to have a detrimental impact on their long term employment

opportunity and income generation These SHGs have members from SC OBC as well as ST

families

In other FPIC villages ie Parsula Badi and Kawai though there is a concern for loss of grazing

land yet opposition to Solar Parks is passive There are some specific interest groups among the

non-ST communities who would seek answers to their specific concerns For example in Parsula

village the non-ST families (both in Parsula as well as neighbouring villages) have informally

purchased the patta land Their main concern is whether and how they get the compensation for

these land parcels which will be paid to patta owners In Badi and Kawai the number of people who

have encroached on the government land is comparatively more Also there are few influential

people who earn from selling stones (the most popular building material in that area) extracted from

the allotted government land Thus a range of RAP-LRP issues are expected to crop up during

community engagement In all these villages the affected ST communities though would consider

the compensation and benefits offered to them yet it would be difficult for them to disregard the

collective decisions made by other communities in their village

Thus considering different interest groups involved existing social relationship influence of STs in

decision making it would be a challenge to hold a single engagement process18 for both STs and

mainstream communities Therefore we recommend a parallel or concurrent engagement process for

ST and mainstream (non-ST) communities The comparison of the ICP process for mainstream (non-

ST) and FPIC process for ST is provided in Table 72

18 GN-7 GN31 recommends a single engagement process complying to the higher standard (GFN and FPIC Agreement) where

a Project requires to achieve ICP for mainstream and FPIC for IP It reads ldquoSince the achievement of ICP and FPIC as separate processes with different groups within a community or between proximate communities may be difficult and in some cases be a cause of division within the community a single engagement process resulting in one agreement is generally recommended In such cases the process and agreement should reference the higher standard (ie GFN and agreement demonstrating FPIC) Whether the agreement entails different benefits for the differently affected groups will depend on the project context the Affected Communities and the nature of project impactsrdquo

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Table 72 Comparison of Concurrent ICP and FPIC Engagement Process in FPIC Villages

Aspect Engagement Process with non-ST

(ICP)

Engagement Process with ST (FPIC)

Management Plan ESMP + RAP-LRP IPPIPDPTDP

Representative

Body

Gram Panchayat (existing body) ST Committee (specifically constituted for

this process)

Provision of

information

necessary for

informed

negotiation

Executive summary of Draft ESMP

RAP-LRP in Hindi

Abridged Draft IPPIPDPTDP in Hindi (use

of Malwi vocabulary as much as possible)

Capacity building by FPIC FA

Help from FPIC FA to understand issues

Willingness to

engage in a

process and

availability to meet

at reasonable times

and frequency

One public meeting for receiving

feedback on Draft ESMP RAP-LRP

One round of internal discussion by STs

assisted by FPIC FA

Two rounds of meetings between RUMSL

and ST Committee

Mediation Committee meetings (if required)

Exploration of key

issues of

importance

Key issues covered in ESIA RAP-LRP

will be discussed

Key issues covered in Draft IPPIPDPTDP

will be discussed

Mutual acceptable

procedures for the

negotiation

Informal agreement A formal lsquoDiscussion and Decision Making

Framework Agreementrsquo is signed by both

parties

Willingness to

change initial

position and modify

offers where

possible

Demonstrated through incorporations of

feedbacks received from public

disclosure and consultation

Structured engagement process

documenting (signed by both parties at the

end of the meeting) points agreeddisagreed

and demonstrating the flexibility in their

respective positions

Provision for

sufficient time for

decision making

The time for public meeting for

receiving feedback will be decided in

consultation with Gram Panchayat

Sufficient time for capacity building by FPIC

FA internal discussions and gap between

first and second meeting between RUMSL

and ST Committee

Outcome The public meeting for receiving

feedback on Draft ESMP RAP-LRP is

held peacefully and satisfactory

explanationresponse to

feedbackqueries is provided

Incorporating response to all key issues

raised in public meeting in Final ESMP

RAP-LRP

The Final IPPIPDPTDP incorporates points

mutually agreed between RUMSL and ST

Committee

The FPIC Process Documentation Report-

(vetted by independent FPIC FA and

Mediation Committee) provides an overview

of the FPIC process

FPIC Agreement signed by RUMSL and ST

Committee

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KEY ELEMENTS CONSIDERED FOR DESIGNING THE FPIC PROCESS

Note The FPIC Process Documentation Report prepared by FA under ERM guidance will cover the

whole process (including all meetings by ST and Non-STs decisions key issues discussed etc)

The use of impacted land for free grazing is practiced by both ST and Non-ST communities The ESIA

and RAP-LRP also address impacts on grazing and have prepared a framework for Grazing Resource

Management Plan The engagement with non-ST population will highlight the mitigation measures

with regard to grazing issue (particularly Grazing Resource Management Plan) in ESIA and RAP-

LRP The feedback from non-ST population on mitigation of impact on grazing will be subsequently

incorporated into Grazing Resource Management Plan in particular and relevant sections in ESIA and

RAP-LRP The non-ST population will be clarified that TDP will have some additional benefit for STs

and therefore will be consulted separately

Thus the separate ST committees will not be perceived to take any decision that affects collective

interest of all villagers particularly the powerful non-ST communities The Gram Panchayat and

Sarpanch is provided a place in Mediation Committee and will be involved in resolving key-issues

referred to them

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

8 DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

81 Introduction

This lsquoDraft Discussion and Decision Making Framework19rsquo is prepared after field visits and

consultations with affected STs and a workshop with RUMSL (see Section-5 for details) This Draft

DDMF will be shared with ST Committees on behalf of RUMSL and after appropriate modifications

(without diluting the key-elements for compliance to PS-7 requirements) the final version will be

signed by representatives of both parties Section 814 provides subsequent steps in this regard

The three proposed solar parks are located in three different Districts and each one will have an

independent Solar Park Developer (SPD) or Concessionaire The impact of each solar park and the

social context of the affected STs also differ in these three locations Hence three ESIA reports as

well as three IPPIPDPTDP are prepared The Draft IPPIPDPTDP prepared for each Solar Park has

a specific package of benefits for the STs in FPIC villages This will be discussed during the proposed

FPIC process and the outcome of this process will be a written lsquoFPIC Agreementrsquo that adopts the Draft

IPPIPDPTDP and agrees to cooperate in its implementation

82 Process for Mutual Agreement on lsquoDiscussion and Decision Making Frameworkrsquo

The subsequent steps for discussing this Draft Discussion and Decision Making Framework with STs

in the selected FPIC villages (grouped at each Solar Park level) is discussed in this section

821 Appointment of FPIC Facilitation Agency and Orientation

The requirement of a FPIC Facilitation Agency (FA) and their roles and responsibilities are discussed

in Section-6 above The FA will play a key role in forming the ST Committees (at each Solar Park

level) and informing them on their rights to FPIC their legal rights on natural resources prior to their

acceptance of this lsquoDraft Discussion and Decision Making Frameworkrsquo Hence one of the agencies

screened for this role will be appointed and brought on board

After on-boarding them ERM will carry out their orientation by holding a series of virtual workshops with

them The orientation program will include the following

The ICP and FPIC requirements as per IFC PS-7 and WB OP 410

Key findings of the ESIA-ESMP including Draft RAP-LRP

An overview of consultations in FPIC Villages

The Draft IPPIPDPTDPs

The Draft Discussion and Decision Making Framework

The Capacity Building of ST Committees on FPIC and their customary rights on natural

resources

822 Introducing FPIC FA to RUMSL and FPIC Villages

After the orientation of the FPIC FA the key persons will be introduced to the RUMSL team through a

physical meeting Subsequently a field trip will be planned to introduce the FPIC FA in FPIC villages

The RUMSL and ERM will introduce the FPIC FA to the contact persons from earlier field visits and

inform them about their role

19 The term lsquoengagementrsquo and lsquonegotiationrsquo was avoided to keep the language less confrontational and positive for both parties

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

823 Formation of ST Committees

ERM and FPIC FA will jointly discuss the structure and composition of the ST Committee at each

Solar Park20 with affected ST community As per suggestions from them ST Committees will be

formed and their nominations will be ratified through a group meeting21 The composition of the ST

Committee is described further in Section 8311 below

824 Capacity Building of ST Committees

The FPIC FA will discuss with the ST Committee on the time and venue for holding a capacity building

workshop The capacity building workshop will cover the following

The recognition of FPIC as their rights

Specific provisions of FPIC as per IFC PS-7 and WB OP 410

Applicable India Laws and recognition of their customary rights on natural resources

The Draft Discussion and Decision Making Framework (Draft DDMF)

The participation of RUMSL in this capacity building workshop will be optional and as per mutual

agreement by both parties The FPIC-FA will note down the suggestions of the ST Committee on the

Draft DDMF and share them with RUMSL

83 The Draft Discussion amp Decision Making Framework

The proposed discussion (engagement) and negotiation (decision making) framework will include 11

steps as illustrated in the Figure 81 below

Figure 81 Key Steps in the Proposed Discussion and Decision Making Process

These steps are described in sections below

20 Agar and Shajapur Solar Park have only one FPIC village Hence the ST Committee will be selected from within the same

village Neemuch Solar Park has two FPIC village with several satellite ST habitations The ST Committee for Neemuch Solar Park will be larger to accommodate representation of different ST groups 21 The FPIC village level group meetings will be held keeping the Covid-19 public health guideline ERM will use professional

judgement on the acceptability of the selected committee for most ST households if the ratification of the ST Committee is not possible by a large public meeting

Formation of Committees

Acceptance of Draft Discussion and Decision Making

Framework

Disclosure of Draft IPP to ST Committee

Explaining Draft IPP to ST Committee

Internal Consultations by ST Committee

First RUMS and ST Committee Discussion

Second RUMSL and ST Committee Discussions

Reference to Mediation Committee

(if any)

Informing Community about Draft FPIC

Agreement

Final Community Meeting for Expression

of ConsentDissent

FPIC Agreement Signing

FPIC Process Documentation Report

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

831 Formation of Committees

The FPIC process will involve three committees for each Solar Park One representing the affected

ST community the other presenting the Project proponent (RUMSL) and the third a committee to

mediate between the two if the need be The composition of these committees are explained in sub-

sections below

8311 Formation of ST Committee for each Solar Park

Each Solar Park will have a ST Committee which includes representatives from all FPIC villages of

that Solar Park Each ST Committee will comprise of 7 to 13 members (or any odd number22) who

represent different sections of the ST community The principle for selecting the members of this ST

Committee will be as follows

One representative from each clanhabitation cluster (tola)

The clans which have more population may select 2 representatives

Two representatives from youths (18-25 years)

Two women representatives

One traditional leader (Mukhia) or ST community head from each FPIC village

Gowal (cow-herder) who takes othersrsquo cattle for grazing and earns livelihood from this

The ST Committee will select a chairperson to coordinate and conduct their internal meetings The

representative from the youth and women will hold separate group discussions within their sub-groups

and share their concerns preference and feedback The FPIC FA facilitating these internal meetings

will ensure that these points are tabled at the joint committee meetings The ST Committee will

prepare a list of households and the adult members (gt18 years) who will be part of the FPIC process

8312 Formation of RUMSL Teams

RUMSL will form three site level teams (one for each Solar Park) which will include the District

Renewable Energy Officer (DREO) of the concerned district and a staff member to assist him They

will report to RUMSL Managing Director (MD) The names and designation of the RUMSL Team are

as follows

Level Designation Name Contact Number

Head office MDCEO Deepak Saxena

Social Development

Specialist

TBD

Site Level (Agar) DREO Deepak Bulani +91-9229924836

DREO- Staff TBD

Site Level (Shajapur) DREO- Prakash Salunke +91- 9926440877

DREO- Staff

Site Level (Neemuch) DREO- Sohanlal Bajaj +91-9827222217

DREO- Staff Balaram Rathod +91-9827323612

22 To avoid a deadlock on decisions

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The site level RUMSL Team will attend the meetings with ST Committee discuss the issues raised by

them sign on minutes of meetings and report to MD where prior approval is necessary The MD or

his authorised representative will take part in important meetings including meetings with the

Mediation Committee if required

8313 Formation of Mediation Committee

There will be a Mediation Committee for each Solar Park The Mediation Committee will comprise of

three members which will be chaired by the District Collector

Member Selection Process

STs Representative from the

Area Biradari Panchayat

The ST Committee after internal discussion will nominate a prominent person of their community outside of their village who is accepted as a member of Biradari Panchayat or similar bodies

Member from Gram

Panchayat

The ST Committee will nominate a member (or ex-GP member) who is known for his role in resolving local disputes

District Tribal Welfare

Department

A senior Tribal Welfare officer will be nominated by District Collector or the Head of Department of Tribal Welfare

District Collector (or his

representative)

The District Collector of the district within which the particular solar

If District Collector is not available she should decide on who can act as his representative

The ERM FPIC-FA ST Committee and RUMSL Team jointly visit these MC members and brief them

on their role in FPIC Process The formation of the MC should be completed prior to the first meeting

between ST Committee and RUMSL Team

832 Acceptance of Draft Discussion and Decision Framework

After the capacity building of ST Committees FPIC FAERM will coordinate with both parties to fix a

date and time for a joint meeting to discuss the Draft Discussion and Decision Making Framework and

ratify it after making necessary modifications

The composition of the committees mentioned in Section 831 and the steps mentioned in Figure 81

will be explained to ST Committee during their capacity building process (described in Section 824)

A Hindi (with Malwi words used to the extent possible) version of the lsquoDraft Discussion and Decision

Frameworkrsquo (Section 83) will be provided to ST Committee during the capacity building Thus the

affected IPs will get adequate time to discuss and come prepared for any suggestions from their side

to this meeting The

Both parties will discuss on a code of conduct commit to follow this during their meetings The code of

conduct will be based on following principles of good faith negotiation

(i) both parties will be available to meet at reasonable time and frequency

(ii) both parties to share information23 necessary for informed negotiation

(iii) both parties will be willing to change initial position and modify offers where possible

23 The Project will disclose information as per Information Disclosure Plan discussed in Section 513 of the Draft

IPPIPDPTDP The disclosure will include at minimum (i) project boundary (ii) impacts of the project (iii) entitlements and other benefits The information will be shared in a culturally appropriate manner and in a form and language easily understandable to the ST communities The FPIC FA will help the ST community understand and process this information prior to the joint meetings with RUMSL

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

(iv) both parties will give each other reasonable time24 for decision making

(v) both parties will put their view peacefully and will not resort to violence and threat and

(vi) both parties will not engage in discussion when they are under influence of any intoxicants

Both parties will discuss and agree on the quorum required for their meetings and how proceedings of

their meetings will be documented Some suggestions for discussion in this regard are

(i) The quorum for the meeting to be physical presence (or virtual participation) of at least 75 of

the ST Committee and RUMSL Team The FPIC FA will check the quorum of the meeting prior

to starting the proceedings

(ii) The Documentation Assistant in FPIC FA will have the responsibility to record the audiovidoe

of the meeting proceedings

(iii) The FPIC FA will write down the key decisions taken during the discussion and the MoMs will

be read out prior to taking their signature

(iv) The FPIC FA will ensure that ST Committee and RUMSL Team understand the decisions made

If any party express that they need more time (to discuss internally or take approvals) such

information will be recorded

(v) The FPIC FA will also document any dissent expressed by any individual member while

supporting the collective decision of the group she represent in the MoM

The agreed Discussion and Decision Making Framework will have a target time-frameschedule for

completion of each step in the FPIC process Both parties will put their best efforts to complete the

process within t(his time-frame ERM will keep a track of the progress of FPIC process as per this

time-frame and help both parties to avoid unnecessary delays FA will draft the Agreement on Final

Discussion and Decision Making Framework (in Hindi) in consultation with RUMSL and ST

Committee

The final (after ratification) lsquoDiscussion and Decision-making Frameworkrsquo the FPIC-FA will hand over a

signed copy to both parties (ST Committee and RUMSL Team) A pamphlet or poster on accepted

code of conduct will be prepared and displayed at the meeting venue FPIC-FA will request all

members attending the meeting to follow these rules

833 Disclosure of Draft IPPIPDP to ST Committee

ERM will prepare Draft IPPIPDPTDP (in English) for each Solar Park A Summary Draft IPPIPDPTDP

will be translated to Hindi (with use of Malwi as much as possible) ERM will share following documents

to both parties as soon as they ratify the lsquoDiscussion and Decision Making Frameworkrsquo

The Draft IPPIPDPTDP (in English)

Summary Draft IPPIPDPTDP25 (in Hindi)

A simple 4-6 page brochure describing (illustrations where possible) the benefit package

proposed in Draft IPPIPDPTDP

The ST Committee members will be given one week to go through the documents shared with them

and fix a date to explain the Draft IPPIPDPTDP Report

The RUMSL will be provided soft copies of these documents to upload them in their web-site from

where external stakeholders can access these documents

24 The time provided should be adequate to read verify and consult (internally or any external expert on the subject matter)

The FPIC-FA will consult both parties to decide what is reasonable and acceptable to both 25 The Summary Draft IPPIPDPTDP will be 20-25 page It will follow the structure of the IPPIPDPTDP but provide a non-

technical description of the content for easy understanding by ST Committee

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

834 Explaining Draft IPPIPDPTDP to ST Committee

ERM and the FPIC-FA will organize a workshop for ST Committee of each Solar Park at a suitable

location on an agreed date (at least after 7 days from sharing of the documents with ST Committee

The workshop will explain the impacts of the Solar Park and the range of mitigation measures and

project benefits mentioned therein

The FPIC-FA will orient them on how to hold consultations with different sections within their

community and document their views The ST Committee will be provided adequate copies of the

brochure describing the benefit package project boundary maps (in large flex prints) to help them

explain the Solar Project to their community members and hold internal discussions

ERMFPIC-FA will consult ST Committee and RUMSL Team to fix the date for first meeting between

RUMSL and ST Committee

835 Internal Consultation Process by ST Committee

FPIC-FA will help each ST Committee to prepare a tentative schedule for internal discussions The

women representatives will hold meetings with women and youths representatives will hold meetings

among young people The FPIC-FA will make itself available to facilitate and document these internal

meetings

After a round of internal discussion of each sub-group the ST Committee will have the final meeting

to discuss the comments and concerns raised by different sub-groups of the community The ST

Committee will finalize a list of issuesdemands for further discussion with RUMSL The FPIC-FA

prepare the Agenda for First RUMSL-ST Committee Meeting and share it with RUMSL at least a week

before the meeting

The Agenda of the first RUMSL and ST Committee will be shared with the Mediation Committee to

keep them informed about the initiation of discussion between both parties

836 First RUMSL and ST Committee Meeting

The FPIC-FAERM will confirm the quorum prior to starting the proceedings The points mentioned in

the Agenda circulated earlier will be taken up for discussion The RUMSL Team will respond on these

pointsissues The ST Committee will consider these responses and decide if they are satisfied Once

the discussion is concluded the FPIC-FA will write-down the decision made with respect to the

specific Agenda items If any additional points to be discussed by any party those points will be

discussed at the end of the meeting with mutual agreement The FPIC-FA will document the

proceedings of the meeting as per the Discussion and Decision Making Framework (see section 832

above)

If all issues are resolved through discussion in this meeting then another round of discussion is not

required If there will be unresolved issue they will be included in the Agenda for the second meeting

While preparing the Agenda for the second meeting FPIC-FA will record the positions of both parties

with respect to these un-resolved issues The Agenda for the second meeting will be prepared listing

these unresolved issues with an appendix stating the views of each party on these unresolved

issues

RUMSL Team will brief about the mutual agreements and unresolved issues listed for second meeting

with their MD and seek approval if required The ST Committee will similarly brief their community

members on what is agreed after they return

The FPIC FA and ERM will prepare a Draft FPIC Agreement (in Hindi) reflecting the points of mutual

agreements and dissents if any The Draft FPIC Agreement will be shared with both parties

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DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

837 Second RUMS and STs Committee

The second and subsequent meetings between RUMS Team and IPs Committee will be held on

points where both parties do not agree and it requires further discussion ERMFPIC-FA will consult

both parties to reconsider their views and think about solutions acceptable to them Once ERMFPIC-

FA see both parties are prepared for the next round of discussion date for the second meeting will be

fixed

In this second round of meeting it is expected that a few more points will be mutually agreed The

Draft FPIC Agreement will be updated mentioning these points on which there are mutual agreement

and points of dissentdisagreements

Although it is expected to resolve all issues in two rounds of discussion there is a possibility of

additional rounds of discussion Both RUMSL and ST Committee will discuss on additional meetings

and decide a mutually agreed time-frame to complete the on-going discussion process

If both parties feel canrsquot be resolved through further discussions they will decide if the issue should be

referred to the Mediation Committee or set aside for discussion at a later date26 ERMFPIC-FA will

check if both parties are committed to accept the decision of the Mediation Committee and take the

final decision in consultation with both parties

838 Refer Unresolved Matters (if any) or Draft FPIC Agreement to Mediation Committee (MC)

If all issues are resolved through mutual discussion between the RUMSL Team and ST Committee

the Draft FPIC Agreement will be forwarded to MC of the respective Solar Park The MC will be then

requested to be available to chair over the final community meeting (see 8310) to measure the

consent expressed by affected ST in FPIC villages

The MC of the respective Solar Park will consider any issue which was not resolved by mutual

discussion between ST Committee and RUMSL Team and referred to it with an understanding that its

decision will be acceptable to both parties The FPIC-FAERM will hand over documentation of

previous discussion related to the issue and stated positions of both parties with respect to the matter

under consideration to MC

The MC will convene a meeting where it hears the arguments from both sides After considering views

on the matter from both sides MC will offer a solution for consideration If the MC thinks they need to

consult subject experts they will inform both parties and reconvene the meeting after they have

obtained views from such subject experts

Both parties if required will be given time (not more than a week) to consider the resolution offered by

the MC and come back with their final views

After considering the views of both parties on the solutions offered by it the MC will give its final

decision on the matter The MC will try making its decision on consensus and if it is not possible the

decision will be on majority Both parties will be bound by this final decision pronounced by MC The

final decision by MC will be incorporated into the Draft FPIC Agreement

839 Informing Community on Draft FPIC Agreement by ST Committee

The FPIC-FA will provide the Draft FPIC Agreement to the ST Committee The ST Committee

members will inform community members in smaller the sub-groups on the decisions taken during

FPIC discussion with RUMSL The ST Committee will explain their decisions on each issue and ask

26 Particularly matters which are uncertain or may happen in future These issues can be listed as unresolved issues to be

monitored by an agreed mechanism and discussed later

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021 Page 80

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

each adult member of the community to attend the final community meeting to voice their views and

acceptreject the Draft FPIC Agreement

8310 Final Community Meeting for Expression of ConsentDissent by IPs Community and Ratification of Final IPP and FPIC Agreement

The ST Committee will take decision to hold the final community meeting to express their

consentdissent and fix a date after consulting RUMSL and MC members It will invite RUMS Team

and Mediation Committee to participate and witness the expression of consentdissent by affected

STs

FPIC-FA will ensure that all households in the community are informed about this meeting at least 7

days in advance FPIC-FA will prepare the list of all adult members with support from ST Committee

The IPs Committee will take the responsibility of the invitation and FPIC FA will monitor and document

the process The quorum for holding the final community meeting of affected ST families will be as

follows

Presence of at least 50 of the affected ST families in FPIC village

Presence of at least 60 of the total adult members of these affected ST families

Presence of at least 33 of the total adult women members

Presence of at least 33 of the total youths (between 18 and 25 years)

The FPIC-FA will coordinate with ST Committee members representing women and youth to ensure

that these quorum requirements are met during the final community meeting

The FPIC-FA will set-up a mechanism for recording the presence of eligible ST adult members and

hand over a copy of the Draft FPIC Agreement as they arrive at the meeting venue The Mediation

Committee will preside over this final community meeting The FPIC-FA will inform MC if quorum

requirements for the meeting is achieved After verifying the quorum required and the people

gathered for the meeting are from the affected ST households from FPIC villages the MC will initiate

the meeting proceeding

A representative from RUMSL Team will read out the agreed points mentioned in the Draft FPIC

Agreement and request for their acceptance A representative from the ST Committee will express

their views on points of mutual consensus as well as any unresolved issue that will be discussed and

resolved at a later stage of the project

The MC will then provide opportunities to ST community members present in the meeting to express

their views ST Committee will facilitate community members to express their opinions and

suggestions

The MC will consult with RUMSL and ST Committee if any additional points of agreement and dissent

to be incorporated in the Draft FPIC Agreement After confirming their final positions request the

community members present in the meeting to express their consentdissent and ratifyreject the Draft

FPIC Agreement

The consentdissent will be expressed by raising hands when the members of the Mediation

Committee puts the proposal of ratification to vote If more than 75 of the community members

attending this meeting votes in favour of the Draft FPIC Agreement it would be regarded as

expression of collective consent

The MC will inform the assembled community members about the outcome of the voting and if Draft

FPIC Agreement is ratified or rejected After the Draft FPIC Agreement is ratified by a collective

expression of consent the ST Committee members and RUMSL Team will sign the Final FPIC

Agreement This Agreement will be counter signed by members of the Mediation Committee as

witnesses

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

The IPs community may be allowed to carry out any customary ritual on the day of the completion of

the FPIC process and express their support to the proposed Project This FPIC Agreement will be

taken up for implementation and a monitoring committee will oversee its effective implementation

8311 FPIC Process Documentation Report

The FPIC-FA will prepare a FPIC Process Documentation Report summarizing each stage of the

FPIC process It will hand-over all audio-visual records of the FPIC process The process document

report will cover all stages of the FPIC process documenting the following

Process of identification of STs ST representatives and decision-making authorities

Process of assessment of capacity of ST representatives to undertake good faith negotiations

Summary of any capacity building undertaken

Agreed engagement and negotiation framework (including the process undertaken to agree upon

the framework)

Summary of consultations meetings engagement undertaken as part of the FPIC process and

Opinion of FPIC-FA on the process and outcomes

Share of responsibilities between RUMSL PPP concessionaire and other relevant parties etc to

complete the FPIC process

84 Tentative Time-line

The Phase-I FPIC activities was scheduled to be held in Apr 2021 Due to the outbreak of second

wave of Covid-19 in Apr 2021 the field activities are suspended The decision to initiate these

activities will be taken once Covid-19 second wave gets over The schedule for Phase-II activities to

will be discussed with ST Committees of the three Solar Parks and will be decided accordingly As the

progress of FPIC process requires cooperation from affected ST community and the level of

cooperation varies in these three Solar Parks Hence the schedule for Phase-II FPIC activities will be

updated in discussion with respective ST Committees while finalizing the Discussion and Decision

Framework with them

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Section Activity Month-1^ Month-2 Month-3 Month-4 Month-5

821 Appointment of FPIC FA and Orientation

822 Introducing FPIC-FA to RUMSL and FPIC Villages

823 Formation of ST Committees

824 Capacity building of ST Committees

8313 Formation of Mediation Committee

832 Acceptance of Draft DDMF

833 Disclosure of Draft IPPIPDPTDP to ST Committee

834 Explaining Draft IPPIPDPTDP to ST Committee

835 Internal Consultation Process by ST Committee

836 First RUMSL and ST Committee Meeting

837 Second RUMSL and ST Committee Meeting

838 Refer Unresolved Matters to MC

839 Inform Community about Draft FPIC Agreement

8310 Final Community Meeting for expression of ConsentDissent

8311 FPIC Process Document Report

Phase-I Activities

Phase-II Activities

Activities to start and complete

OptionalConditional Activity

^ The commencement of these activities will be determined once second wave of Covid-19 gets over

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW

IN THE STATE OF MADHYA PRADESH INDIA

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

85 Responsibility Matrix

The FPIC process will require a collective effort and coordination between ERM RUMSL ST

Committee Mediation Committee and the FPIC FA The roles and responsibilities of these entities are

described in Section 82 and 83 above ERM will play an active role in coordination and provide

information required for a meaningful discussion The key responsibilities and accountabilities are

summarized below for clarity

Activity ERM FPIC-

FA

ST-

Committee

RUMSL-

F

RUMSL-

HO

Mediation

Committee

IFC-

WB

Formation of ST Committee S P P A

Formation of RUMS Team P A

Formation of Mediation

Committee

P P S P A P

Acceptance of Discussion

and Decision Making

Framework

S P P P A C C

Disclosure of Draft IPP to ST

Committee

P S S A C A

Explaining of Draft IPP to ST

Committee

P S

Internal consultation process

by ST Committee

S P P

First RUMSL and ST

Committee Meeting

S P P P A

Second RUMSL and ST

Committee Meeting

S P P P A

Mediation Committee

Proceedings

P P P S P P

Informing Community on Draft

FPIC Agreement by ST

Committee

S P P A

Final ST community meeting-

expression of consent

dissent

S P P P A A C

FPIC Process Documentation

Report

P P S S S S A

P= Primary Responsibility S= Secondary Responsibility C= Must be Consulted A= Approval

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX A SAMPLE PROJECT PROFILE FACT SHEET IN ENGLISH

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

PROJECT INFORMATION DOCUMENT SHAJAPUR SOLAR PARK

Background

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) The primary objective of RUMSL

is to develop and facilitate the development of large-scale solar projects in the State of Madhya

Pradesh In line with the governmentrsquos ambition to boost solar power in State RUMSL is developing

Solar Park of capacity of 450 MW at Shajapur Madhya Pradesh

The World Bank had agreed to provide financial support for the Project International Finance

Corporation (IFC) is providing investment advisory services to Government of Madhya Pradesh to

develop the project on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards for the Project

Project Details

The proposed 450 MW Solar Park is located in two Tehsils ndashMoman Badodiya and Shajapur of

Shajapur District Out of 450 MW capacity 325 MW will be developed at Moman Badodiya tehsil

(termed as Unit 1 amp 2) and 125 MW will be developed at Shajapur tehsil (termed as Unit 3) of

Shajapur district Madhya Pradesh Almost 89 of the land area is Government land and remaining is

private land The salient feature of the Project are given below

Solar Park

The Solar Park will be developed as two units spread across these lands and the details of the same

ae captured in the table belowndash

Table A1 Details of Land parcels identified for the project Unit Number Area in ha Capacity Tehsil Villages

Unit 1 72048 220 MW Moman

Bododiya

Proposed to span 6 villages - Bijanakhedi

Burlay Chauma Dehripal Fawaka and

Parsula

Unit 2 105 MW Proposed to span Burlay Dhatrawada and

Jawadi whereas

Unit 3 26964 125 MW Shajapur

Tehsil

Hanoti Surajpur and Shajapur

Total 99012 450 MW

Land

Out of the total land requirement of 99012 hectares 86937 hectare is Government land 11074

hectare is private land and 1001 hectare is government patta land The Government land required for

the Solar Park which accounts for almost 89 of the total land required will be leased by the

government of Madhya Pradesh to SPPDs and the private land will be purchased from the land

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

owners for the development of Solar Park as per the prevailing laws and policies in the State of

Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP

Transmission Line

The transmission infrastructure is planned to evacuate power generated from the units to the STU

grid Each unit will have a 33200 kV internal pooling substation The internal pooling substation will

be connected to the proposed MPPTCL 220400 kV substation at Agar through 220 kV transmission

line For cost optimization the single circuit line from unit 1 will be laid till unit 2 towers and there on a

double line circuit of 220 kV shall be connected till the gird substation The Unit 3 internal pooling

substation shall be evacuated through single circuit 220 kV transmission line till the existing MPPTCL

220400 kV substation at Ujjain

The 33220 kV substation at each unit and 220 kV connectivity to the MPPTCL substation will be

developed by RUMSL MPPTCL will establish 220400 kV proposed grid substation at Agar in

connection with the existing 220400 kV MPPTCL substation at Ujjain Madhya Pradesh MPPTCL will

establish 220400 kV proposed grid substation at Agar along with the associated line till 400220 kV

Ujjain substation The solar project developer in the park shall be responsible for laying the 33 kV

cable and 33 kV ring unit as required at each unit to connect its plant to the 33220 kV internal pooling

substations

Road Infrastructure

The road infrastructure requirements is planned to access the Shajapur Solar Park Ms RUMSL shall

carry out road wideningrepairing of existing roads wherever required The road widening repairing of

existing roads is proposed for a length of 65 km which shall be undertaken by RUMSL The

development of internal roads within each unit shall be in the scope of individual Project Developer

Water Requirement

Water requirements for all purposes shall be met by digging bore-wells within each unit and shall be in

the scope of project developer Also the arrangement of construction water shall be in the scope of

contracting agencies and Solar Power Project developer

Common facilities planned

For 450 MW Shajapur solar park the utility area is proposed adjacent to the Unit 1 and Unit 3 -

33220 kV internal substation The other facilities such as RUMSL office fire-fighting equipment

telecommunication infrastructure medical dispensary etc will be located at the pooling substation

area

Project Implementation

The 450 MW Shajapur Solar Park will be implemented in a period of ~21 months

Operation and Maintenance

It is envisaged that different developers may occupy individual units and will be responsible for OampM

The operations and maintenance of common facilities provided like pooling substation intermediate

substations shall be undertaken by RUMSL

Environment and Social Impact Study and Management Plans

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited (RUMSL) to

undertake an Environmental and Social Assessment (ESIA) of three solar parks including internal

evacuation infrastructure and associated transmission lines ESIA carried out for the project will meet

the requirements of Environment and Social Safeguard Policies and Standards of WB and IFC in

addition to applicable environmental and social regulations and policies in India and the State of

Madhya Pradesh

Based on final land footprint and georeferenced site boundaries of the project the ESIA will include a

Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) ERM will share relevant

information and consult with affected local communities to understand their viewsconcerns The

consultation will cover a wide range of people to take into account perspectives from different social

groups women and men young and old and seek their participation in mitigation of adverse impact

as well as enhancement of project benefits

As the project will impact a number of ST families ERM will assess impacts on them and prepare a

Tribal Development Plan (TDP) which will contain a package of proposed impact mitigation measures

and project benefits ERM will implement a Free Prior Informed Consent (FPIC) process covering

affected Scheduled Tribe population The negotiation process leading to obtain FPIC will be agreed

on with the affected ST communities

Free Prior Informed Consent (FPIC) Process for STs

The FPIC Process will be taken up for Surajpur Parsula and Jawadi villages of Shajapur Site for the impacts on tribal population in given villages on the land under traditional ownership and customary use The process will also involve any nomadic tribes who may have claims of using the project site for grazing their livestock and camping during their annual migration The FPIC process will be divided into two phases as described below

Phase What to Do When to Do

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Before inviting bids for solar parks by concessionaire

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

Consent will be sought prior to the main phase of MP Solar Park project development (ie prior to the main construction phase)

Contacts

Further information and queries related to the project can be obtained from RUMSL site office in

Shajapur and head office at Bhopal The information is also available at website of RUMSL

(httpwwwrumslcom)

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX B SAMPLE PROJECT PROFILE FACT SHEET IN HINDI

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wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX C PHOTO DOCUMENTATION OF DISCLOSURE OF INTENTION TO CONDUCT FPIC

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

NEEMUCH SOLAR PARK

Badi village Kawai Village

Mama Basti Badi village Bardawada village

AGAR SOLAR PARK

Ladwan village Bijnakhedi village

SHAJAPUR SOLAR PARK

Chauma village Parsula village

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX D SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN ENGLISH

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

BACKGROUND

The Government of Madhya Pradesh (GoMP) through Ministry of New and Renewable Energy

(MNRE) is developing ground mounted grid connected solar power projects in Madhya Pradesh

Rewa Ultra Mega Solar Limited (RUMSL) is a Public Undertaking Company incorporated on 10 July

2015 as a 5050 joint venture (JV) company between Solar Energy Corporation of India Limited

(SECI) and Madhya Pradesh Urja Vikas Nigam Limited (MPUVNL) RUMSL is facilitating developing

Solar Park of capacity of 450 MW at Shajapur on a Public Private Partnership mode

ERM India Private Limited (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake

an Environmental and Social Assessment (ESIA) of Solar Park including preparation of Resettlement

Action Plan (RAP) and conducting Free Prior Informed Consent (FPIC) process as per International

Standards (International Finance Corporation and World Bank) for the Project

Project Details The proposed 450 MW Solar Park is located in Moman Badodiya and South Shajapur tehsils of

Shajapur District collectively referred to as Shajapur Solar Park The Shajapur Solar Park will be

spread across 11 villages in Shajapur amp Moman Badodiya Tehsil of Shajapur District comprising the

villages of Burlay Jawadi and Dhatrawada (for Unit 6) Parsula Dehripal Bijnakhedi Fawaka

Chauma Burlay (for Unit 7) and Surajpur Lalpur and Hanoti (for Unit 8) The land required for 450

MW Solar Park including solar fields roads and transmission and distribution network is 9872

hectares The Shajapur Solar Park plot comprises of three non-contiguous land parcels

The solar park will have three (3) units It is understood that each unit will have a different developer

Unit 6 of 105 MW capacity to be developed on an area of 2461 hectares of Private and

Government land

Unit 7 of 220 MW capacity to be developed on an area of 4859 hectare and

Unit 8 of 125 MW capacity to be developed on an area of 2552 hectare

Land Requirement and Status The Solar Park will largely use GoMP land (approx 88) and the remaining land is either private

land or Patta land The Government land required for the Solar Park will be leased by the government

of Madhya Pradesh and the private land will be purchased from the land owners as per the prevailing

laws and policies in the State of Madhya Pradesh (Consent Land Purchase Policyrsquo dated 14th

November 2014 of Government of MP)

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

1 Burlay 237 00 64 00 00 00 301

2 Jawadi 322 00 20 00 00 00 342

3 Dhatrawada 1722 00 97 00 00 00 1819

Sub- Total (unit

6)

2281 00 181 00 00 00 2462

4 Parsula 1162 00 00 52 00 00 1214

5 Dehripal 1111 00 124 00 94 00 1329

6 Bijanakhedi 954 00 226 00 00 00 1180

7 Fawaka 171 00 02 00 00 00 173

8 Chouma 327 00 95 00 00 124 546

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

SI

No

Village

Name

Govt

land

(NRED

allotted)

Govt

Land

Identified

but not

yet

Allotted

Private

Land

Patta

Land

Horticulture Seasonal

Pond

Total Land

Area (Ha)

(Govt Land

+ Pvt Land)

9 Burlay 417 00 00 00 00 00 417

Sub- Total (Unit

7)

4142 0 447 52 94 124 4859

10 Surajpur 227 07 182 00 00 00 416

11 Lalupura 497 08 00 00 00 00 505

12 Hanoti 1319 125 185 00 00 00 1629

Sub- Total (Unit

8)

2043 140 367 00 00 00 2551

Grand Total 8466 140 995 52 94 124 9872

Source Land Data provided by RUMSL 18th June 2020

Transmission Line Each Solar Park Unit will have 33220 kV substations and the power generated from each unit (Unit 6

7 and 8) will be pooled to the 220 kV switching pooling substation The utility area is proposed near

the internal pooling substation located at the Unit 6 and Unit 8

Road Infrastructure Access to Unit 6 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The existing village road has a width of ~4-5 meter and existing

State highways has a width of ~75 meter The road length of ~25 km will be strengthened and

repaired to suit the need during the construction phase

Access to Unit 7 This Unit can be accessed through single lane bituminous village road connecting

Agar ndash Sarangpur State Highway 41 The road length of ~2 km will be strengthened and repaired to

suit the need during the development phase

Access to Unit 8 The Unit is connected with village road from Jhonkar to Hanoti at a distance 0f ~6

km from Jhonkar The existing road is a two-lane bituminous concrete road with width ~7-75 meters

and a new bituminous road with width ~75 meters and length ~500 meters is proposed to connect

33220 kV plant substation The road length of ~2 km will be strengthened and repaired to suit the

need during the development phase

Water Requirement The total requirement for water is estimated as 323 kL day Developers shall establish bore-wells per

block with required approvals and directions to meet their requirements The entire water supply

system including provision for bore-wells within individual blocks shall be in the scope of the Project

Developer The water requirement for the green belt is estimated to be 7000 litres per day

Common facilities planned The common facilities such as RUMSL office fire-fighting equipment telecommunication

infrastructure medical dispensary weather monitoring station etc will be located at the pooling

substation area located at the Unit 6 The operations and maintenance of common facilities provided

like pooling substation intermediate substations shall be undertaken by RUMSL Ms RUMSL will

establish two Weather Monitoring Station at internal pooling substation (at each unit)

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Project Implementation

The 450 MW Shajapur Solar Park will be constructed a time frame of ~21 months with construction

proposed to started in November 2020

Project Impacts Benefits and Mitigation Measures

RUMSL will identify stakeholders and prepare a schedule for consulting them on a regular basis in

construction phase It will also establish a grievance redress mechanism through which local

community can register their grievances and seek redress to any adverse impacts on them The

project through its ESIA process has identified a range of potential impacts and has planned to

implement appropriate mitigation measures The key impactsbenefits and proposed mitigation

measures are discussed below for your knowledge and suggestions for making them more effective

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D1 Moman Badodiya Unit 6

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D2 Moman Badodiya Unit 7

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Figure D3 South Shajapur Unit 8

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact from Land Acquisition

Type of land impacted How Impacts will be addressed

Private Land (Purchased through MP

Mutual Consent Policy 2014

Adequate compensation at twice the value of land and assets as

per MP Mutual Consent Policy 2014

Benefits of Resettlement Action Plan-Livelihoods restoration Plan

Preference to households (rendered landless or with sub-optimal

holdings) of the families post selling land to the project for

employment opportunitiessmall contracts in the

Constructionoperation phase

Pattta Land (Negotiated purchase

through MP Mutual Consent Policy)

Patta is being treated at par with ownership for the land

procurement process and would have same benefits as of private

land owners

Government Land Used for Grazing

easements cultural heritage sites

water sources fuel wood collection and

collection of other resources

Provision for alternate grazing land for cattle near the project

village or confirmation of adequacy of remaining grazing land

Development of community fodder lots in available unoccupied

government land may be explored and covered in Resettlement

Action Plan

Provision of easements shall be maintained in order to not sever

the access to CPRs for the community

Government Land Informally

occupied Capturedencroached for

agriculture or grazing prohibiting use

by other people

RUMSL shall serve a three months advance notice to the project

affected persons (PAPs) to harvest standing crops andor avoid

growing fresh crops

In case the advance notice is not given RUMSL shall pay

compensation for crops at full replacement cost

ImpactsBenefits in Construction Phase

Impact Mitigation Measures

Temporary occupation of land

for construction phase activities

such as Labour Camps Safety

Setbacks Storage areas

Parking areas Other

construction related temporary

land requirements etc

Adequate lease rents to the land owners

Restoration of land to its original state or better at the time of handing it

back to the owners

Compensation for the loss of livelihoods to the users of the land required

for temporary use as this will temporarily economically displace them

Community Health and Safety

including accident risks for

domestic animals

The Contractor shall prepare Traffic Management Plan Workers Code of

Conduct and Health and Safety Plan and implement it after approval of

RUMSL

Stress on Community resources

- Water and Roads

There will be a worker Code of Conduct defined by RUMSL that prevents

workers and contractors from using the local resources like water forest

The contractor shall be asked to use Tanker water supply during the

summer months which are dry months in which water scarcity issues are

reported by the community

Noise Nuisance and Dust Install enclosures around construction area in order to reduce the extent

of noise and dust

Limit construction related activities to day time

Employment and

entrepreneurship opportunities

during construction

The sourcing of local labour wherever possible will be obligatory for the

Solar Project Developers and sub-contractors

Employment of members of SC-STs and vulnerable households will be

at a minimum of 30 of total workers or person-days of employment

Engagement of local vendors to the extent possible for the goods and

services required for the project during construction phase

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF THREE SOLAR PARKS INCLUDING INTERNAL EVACUATION INFRASTRUCTURE AND ASSOCIATED TRANSMISSION LINES OF AGGREGATE CAPACITY OF 1500 MW IN THE STATE OF MADHYA PRADESH INDIA FPIC Approach Draft Discussion and Decision Making Framework

DRAFT DISCUSSION amp DECISION MAKING FRAMEWORK

Impact Mitigation Measures

The RUMSL will establish a mechanism to audit subcontractors and

suppliers with respect to compliance of utilizing local labour and

resources

Impacts in Operation Phase

Impact Mitigation Measures

Community Health and

Safety

Community engagement and sensitization sessions should be re-organised at

the beginning of Operations phase in order to mention about the new

developments in the area and provide an understanding of the precautions to

be taken for safety

Impact on Employment RUMSL shall ensure that the Solar project developers (SPDs) advertise the

roles of Technical staff required during operations phases in the local

newspapers to enable hiring of competent people from nearby areas to the

extent feasible

Preference shall be given (to the extent feasible) to hire competent members

from PAHs for semi-skilled jobs like housekeeping or Security Guards

Impacts on Vulnerable Sections Women and Scheduled Tribes

Impact Mitigation Measures

Impacts on Indigenous

Communities Vulnerable

Groups

To Prepare an Indigenous Peoples PlanTribal Development Plan with special

benefits for Scheduled Tribes

Recognizing their right to Free Prior Informed Consent process and its

implementation

As part of the stakeholder engagement ensure adequate representation and

participation of the Scheduled Tribes

Impact on Women A Gender Action Plan will be prepared for the Project to assess and mitigate

gender specific impacts

Ensure that the employment of women from vulnerable households is

prioritised for the project

Efforts are made to support development of women owned enterprises in the

area through the LRP from where procurement for project related may be

prioritised

wwwermcom Version 04 Project No 0528741 Client Rewa Ultra Mega Solar Limited 5 May 2021

APPENDIX E SAMPLE OF DISCLOSURE OF PROJECT BOUNDARY AND KEY ENVIRONMENT AND SOCIAL IMPACTS IN HINDI

Page 1

शाजापर सोलर पारक रा पररयोजना वििरण दसतािज़

पषठभवि

नवीन और नवीकरणीय ऊरजा मतरजलय क सहयोग स मधय परदश सरकार मधय परदश म जमीनी गरिड स रडी

सौर ऊजाा पररयोजना का गरिकगरसत कर रही ह रीिा अलटर ा मगा सोलर गरलगरमटड (RUMSL) का एक

सािाजगरनक उपकरम िरा 2015 म सथागरपत हआ ह यह उपकरम सोलर एनरी कारपोरशन आफ इगरडया गरलगरमटड

(SECI) तथा मधयपरदश ऊजाा गरिकास गरनगम गरलगरमटड (MPUVNL) क साथ सयकत उपकरम क रप म सथागरपत

हआ ह शाजापर सोलर पाका की कल कषमता 450 मगा िाट होगी और इस सौर ऊजाा पाका को गरनजी -

सािाजगरनक साझदारी क तहत गरनमााण गरकया जाना परसतजववत ह

रीवज अलटर ज मगज सोलर वलवमटड (RUMSL) दवजरज ईआरएम इवडयज परजइवट वलवमटड (ERM) को अतरााषटर ीय

मानको (अतरााषटर ीय गरितत वनगम एि गरिशवबक) क अनसजर सौर पजका क पयजावरणीय और सजमजवरक परभजव

मलजकन (ESIA) क सजथ सजथ पनगरिासथापन कजया योरनज (RAP) और सवततर रप स समदाय की पिा

सगरित सहमगरत (FPIC) परवियज क वलए अनबगरित गरकया गया ह

पररयोजना री परिख जानरारी

450 मगा िाट का परसतागरित सोलर पाका शाजापर गरजल क मोहन बड़ोगरडया और शाजापर तहसील क अतगात

शाजापर सोलर पाका क नाम स जाना जाएगा यह सौर ऊजाा पाका 11 गाािो क कषतर म बनगा यह 11 गााि इस

परकार ह बल जिादी और ितिादा (इकाई 6) पारसला दहरीपल बीजनखड़ी फिाका िौमा बल (इकाई

7) और सरजपर लालपर तथा हनोती (इकाई 8)

इस 450 मगा िाट सोलर पाका हत कल 9872 हकटर जमीन की आियशकता होगी गरजसम सोलर फीलड

सड़क टर ासगरमशन एि गरितरण नटिका शागरमल होगा पाका तीन अलग इकाईयो म गरिकगरसत होगा ऐसा

अनमान ह गरक परतयक इकाई का गरनमााण अलग-अलग गरनमााताओ दवारा गरकया जाएगा

105 मगा िाट कषमता िाली इकाई 62461 हकटर कषतर पर सरकारी तथा गरनजी जमीन पर गरिकगरसत

होगी

220 मगा िाट कषमता िाली इकाई 74859 हकटर कषतर पर गरिकगरसत होगी तथा

125 मगा िाट कषमता िाली इकाई 82552 हकटर कषतर पर गरिकगरसत होगी

Page 2

जिीन री सथिवि एि अविगरहण

सौर ऊजाा पजका लगभग 88 मधय परदश की सरकारी भवम कज उपयोग करगज और शष भवम यज तो वनरी यज

पटटज भवम रहगी सोलर पजका क वलए आवशयक रजरसव भवम मधय परदश सरकजर दवजरज पटट पर दी रजएगी और

वनरी भवम मधय परदश रजजय म परचवलत कजननो और नीवतयो क अनसजर भवम मजवलको स खरीदी रजएगी

(Consent Land Purchase Policyrsquo dated 14th November 2014 of Government of MP)

कर

गााि

रा

नाि

सरर

ारी

जि

ीन आ

िवि

ि

(NR

ED

) ह

कटर

सरर

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जि

ीन व

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आि

विि

नह

हकट

वनज

ी ज

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कटर

पटट

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हकट

1 बल 237 00 64 00 00 00 301

2 जािादी 322 00 20 00 00 00 342

3 ितरािदा 1722 00 97 00 00 00 1819

योग (इराई 6 ) 2281 00 181 00 00 00 2462

4 परसला 1162 00 00 52 00 00 1214

5 दहरीपल 1111 00 124 00 94 00 1329

6 बीजनखड़ी 954 00 226 00 00 00 1180

7 फािक 171 00 02 00 00 00 173

8 िौमा 327 00 95 00 00 124 546

9 बल 417 00 00 00 00 00 417

योग (इराई 7) 4142 0 447 52 94 124 4859

10 सरजपर 227 07 182 00 00 00 416

11 लालपर 497 08 00 00 00 00 505

12 हनोती 1319 125 185 00 00 00 1629

योग (इराई 8) 2043 140 367 00 00 00 2551

Page 3

रल 8466 140 995 52 94 124 9872

सदभक रीिा अलटर ा मगा सोलर गरलगरमटड दवारा गरदया गया जमीन का डाटा 18 जन 2020

िासविशन लाइन

परतयक सोलर पाका इकाई क 33220 किी क सब सटशन होग तथा परतयक इकाई (6 7 8) स 220 गरकलो

िाट की ऊजाा सब सटशन एकतर गरकया जाएगा आतररक पगरलग सब सटशन इकाई 6 और 8 क समीम

सथागरपत करना परसतागरित ह

सड़र वनिाकण

इराई 6 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रोवक आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

गााि क रासत की िौड़ाई लगभग 4-5 मीटर तथा राजयमगा की िौड़ाई 75 मीटर ह सौर ऊजाा पाका क

गरनमााण हत 25 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 7 िर पहाि

इस इकाई तक गााि क रासत स पहि सकत ह रो की आग आगरज-शाजापर राजय मागा - 41 स रडतज ह

सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया जाएगा

इराई 8 िर पहाि

इकाई 8 िाम झोकर स 6 गरकलोमीटर दर िाम झोकर स िाम गरहनोती को जान िाली सड़क स जड़ी ह यह

रासता डबल लन डामर रासता ह गरजसकी लबाई 7-75 मीटर ह एक नई डामर रोड गरजसकी लबाई 500

मीटर तथा िौड़ाई 75 मीटर ह और जो 33220 किी क सब सटशन को जोड़न क गरलए बनाई जाना

परसतागरित ह सौर ऊजाा पाका क गरनमााण क समय 2 गरकलो मीटर की लबी सड़क को सिारा एि बनाया

जाएगा

पानी री आिशयरिा

यह अनमान ह की परगरत गरदन लगभग 323 गरकलो लीटर पानी आिशयकता होगी पानी की पगरता क गरलए ठकदार

दवारा परगरत बलॉक बोररग की रजएगी सौर ऊजाा पाका क गरनमााण क दौरान परतयक बलॉक क पानी की सपलाइ

की वयिसथा का परा खाका गरजसम बोररग करना भी शागरमल ह ठकदार अपन परसताि म द ग हररत पटटी क

गरलए परगरत गरदन अदाजन कल 700 लीटर पानी की आियशकता होगी

Page 4

सािानय सवििाओ री उपलबधिा

RUMSL का ऑगरफस अगरि शमन सटशन टली कमयगरनकशन (फोन) गरिगरकतसालय गरडसपनसरी मौसम की

जानकारी सटशन इतयागरद इकाई 6 क समीप पलीग सब सटशन पर सथागरपत हाागी पगरलग सबसटशन तथा

मधयमिती सबसटशन गरक तमाम सगरििाओ का सिालन एि दखरख RUMSL दवारा गरकया जाएगा RUMSL

आतररक पलीग सटशन पर दो मौसम अनशरिण सटशन सथागरपत करगा

पररयोजना रा वकरयानवयन

450 मगा िाट का शाजापर सोलर पाका का गरनमााण निमबर 2020 स शरिात कर अगल 21 महीनो म परा

होना अपगरकषत ह

पररयोजना र परभाि लाभ ििा शिन उपाय

सौर ऊजाा पाका क गरनमााण क दौरान RUMSL गरिगरभनन गरहतसािको की पहिान कर उनस गरनयगरमत ििाा और

सलाह मशिरा करतज रहगज पाका गरनमााण क दौरान िामीणो की गरशकायतो को समझन एि उनह दर करन क

गरलए गरशकायत गरनिारण ततर की वयिसथा RUMSL करगा तागरक गरशकायतो का गरनपटारा शीघर हो सक और

लोगो पर हो रह नकारातमक परभाि को दर कर सक पररयोजना दवारा ESIA की परगरकरया क माधयम स सभागरित

परभािो को गरिनहनहतकर उनक गरनपटार हत उगरित और परभकारी उपाय करगा अपगरकषत परभािलाभ और शमन

क उपाय गरनमन गरलनहखत ह तागरक आपक सझािो क आिार पर उनह और परभािी बनाया जा सक

Page 5

नकशा 1 िोहन बदोवदया इराई 6

Page 6

नकशा 2 िोहन बदोवदया इराई 7

Page 7

नकशा 3 शाजापर इराई 8

Page 8

जिीन अविगरहण रा परभाि

परभाविि जिीन रा पररार परभाि रा वनिारण

वनजी जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत 2014 क तहत

खरीदी गरनजी जमीन)

मधय परदश आपसी सहमगरत भगरम करय नीगरत 2014 क तहत

पयाापत मआिजा जमीन या सपगरत क मलय स दगना

पनिासन कायायोजना ndash आजीगरिका पनजीिन योजना स लाभ

पररयोजना हत अगरििहण क बाद पररिार गरजनक पास बहत ही

कम जमीन बिी ह या भगरमहीन पररिारो को पराथगरमकता

गरनमााण क दौरान गरकरयानवयन क समय उनक गरलए काम क

अिसर छोट काया अनबि काटर कट म पराथगरमकता दना

पटटिाली जिीन (मधय परदश आपसी

सहमगरत भगरम करय नीगरत2014 क तहत

तय कर खरीदी गए जमीन)

जमीन क अगरििहण क दौरान पटटा िारको को गरनजी मागरलक की

तरह समझत हए उनक गरलए गरनिााररत सार फायद दना

सररारी जिीन िरनोई सासकगरतक

िरोहर जल शरोत जलाऊ लकड़ी

सिहण गरनसतार की जमीन

अनयससािनो का सिहण क उपयोग म

आन िाली जमीन

पररयोजना क समीप क गााि म िरनोई क गरलए जमीन की

िकनहिक वयिसथा करिाना या अगरििहण क बाद शर जमीन म

गााि क गरलए पयाापत िरनोई की जमीन सगरनगरित करना

खाली पड़ी सरकारी जमीन पर सामदागरयक िारागाह की खप

गरिकगरसत करन हत पनिासनकाया योजना म सभािना खोजना

समदाय क सामदागरयक ससािनो तक पहाि बनी रह उस सगरनगरित

करन क गरलए भारतीय सख भोग अगरिगरनयम 1882 क पराििानो

का पालन गरकया जाएगा

सररारी जिीन अिि कबजिाली

जमीन खती या िराई क गरलए कबजा

अगरतकरमण गरकया गया हो लोगो दवारा

सािाजगरनक उपयोग बागरित गरकया गया

हो

RUMSL पररयोजना स परभागरित लोगो को तीन महीन का पिा

नोगरटस दगा तागरक ि अपनी लगी हई फसल काट सक या नई

फसल न बोए

यगरद गरकसी कारण िश पिा नोगरटस नही दी गयी तो RUMSL परी

फसल की कीमत मआिज क तौर पर द ग

Page 9

वनिाकण र दौरान परभािफायद

परभाि शिनवनपिार र उपाय

गरनमााण क िरण क दौरान गरिगरभनन गगरतगरिगरियो

क गरलए जस मजदर रहिास (क प) सरकषा

वयिसथा भडारण वयिसथा िाहन पागरकि ग कषतर

तथा गरनमााण सबिी अनय जमीन की असथायी

आिशयकता पड़ना आगरद

जमीन मागरलको को पयाापत लीजगरकराए की वयिसथा करना

जमीन मागरलको को उनकी जमीन लौटन क समय वयिनहसथत

रप स सिार कर परानी अिसथा या उसस भी अचछी करक

लौटाना

जमीन मागरलको को उनक जमीन स असथायी रप स हटान एि

उनकी आजीगरिका क नकसान क एिज म मआिजा दना

सामदागरयक सवासथय एि सरकषा तथा घरल

उपयोगी पशओ की दघाटनाका जोनहखम

ठकदार सभी की सरकषा क गरकए आिागमन परबिन पलान

तयार कर ग मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयिहार क गरनयम) और सवासथय एि सरकषा की योजना

बनाकर RUMSL स अनमोदन क पिात ही गरकरयानवयन कर ग

सामदागरयक ससािनो पर दबाि ndash पानी एि

सड़क

RUMSL दवारा मजदर एि कमािाररयो हत कोड ऑफ कडकट

(आिार वयहार क गरनयम) गरनिााररत गरकए जाएग गरजसस

कमािारी तथा ठकदार सथानीय ससािनो जस पानी जगल

आगरद का नयायोगरित उपयोग कर पाएग

गगरमायो क समय पानी की गरकललत को दखत हए ठकदार को

यह गरनदश होग की िह पानी क टकर स पानी गरक पगरता कर

शोर बािा एि िल गरनमााण सथल पर दीिार लगानासथागरपत करना तागरक शोर एि

िल कम फल

गरनमााण काया किल गरदन क समय ही करनागरनमााण काया रात

क समय परगरतबगरित करना

गरनमााण क दौरान रोजगार तथा वयिसाय क

अिसर

यथासभि सोलर पाका गरिकगरसत कतााओ तथा ठकदारो आगरद

क गरलए सथानीय लोगो एिम मजदरो को काया दन की

अगरनिायाता होगी

कल रोजगार गरदिस या कल कमािाररयो म कम स कम 30

परगरतशत मजदरकमािारी अनसगरित जागरत - जनजागरत या िगरित

पररिार स होग

सोलर पररयोजना गरनमााण क समय गरकसी भी मालसामिी या

सिा की जररत यथासभि सथानीय गरिकरताओ क माधयम स

की जाएगी

RUMSL गरनमााण क दौरान एक अककषण ततर की वयिसथा

करगा तागरक ठकदार गरिकरता सिा परदाता सथानीय ससािनो

तथा मजदरो का यथोगरित उपयोग कर सक

Page 10

वकरयानवयन र सिय परभाि

परभाि शिन वनपिार र उपाय

सामदागरयक सवासथय एि

सरकषा

सोलर पाका क गरनमााण की परगरकरया क दौरान गरनमााण स होन िाल नए

बदलाि क सबि म समदाय को सिदनशील बनाना हत बठको का

आयोजन करना और सरकषा क गरलए एहगरतयात बरतन हत समय समय पर

गरििार गरिमशा और ििााए करना

रोजगार पर परभाि RUMSL यह सगरनगरित करगा की पररयोजना क गरनमााण क दौरान

तकनीकी कमािाररयो की भती का गरिजञापन सथानीय अखबारो म छप

तागरक योगय सथानीय लोगो को भती गरकया जा सक

अिा कौशल कषमता िाल काम जस कायाालय की दखरख सरकषा गाडा

आगरद पररयोजना स परभागरित पररिारो को पराथगरमकता क आिार पर

गरदय जाए

िविि िगक पर परभाि िवहलाए एि अनसविि जनजावि र सदभक ि

परभाि शिन वनपिार र उपाय

अनसगरित जनजागरत एि

िगरित िगा पर परभाि

अनसगरित जनजागरत समदाय क लाभ को धयान म रखत हए मलगरनिासी

समदाय क गरलए योजना आगरदिासी गरिकास की योजना बनाई जाएगी

सवततर पिा सगरित सहमगरत क आिार पर FPIC की परगरकरया का

गरकरयानवयिन गरकया जाएगा

गरिगरभनन गरहतसािको को शागरमल करत समय अनसगरित जनजागरत समदाय

का पणा रप स परगरतगरनगरितव और भागीदारी को सगरनगरित गरकया जाएगा

मवहलजओ पर परभाि जडर एकशन पलान का गरनमााण गरकया जाएगा तागरक पररयोजना की िजह

स जडर गरिगरशषट परभािो का आकलन कर उनह गरनपटा या कम करन का

परयास हो सक

पररयोजना म िगरित िगा की मगरहलाओ को रोजगार पराथगरमकता गरमल यह

सगरनगरित गरकया जाएगा

पररयोजना कषतर म मगरहला उदयमी गरिकरता सिा परदाताओ को सहयोग

करन क परयास गरकए जायग गरजसस पररयोजना म काम आन सामिी

समान की खरीदी उनस की जा सक

Page 11

APPENDIX F SCREENING OF EXPERTS AND ORGANIZATIONS CONSIDERED FOR THE FPIC FACILITATOR

Page 12

Screening of Facilitating AgencyIndividual Expert for FPIC

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to

undertake an Environmental and Social Impact Assessment (ESIA) of three solar parks

including internal evacuation infrastructure and associated transmission lines of aggregate

capacity of 1500 MW in the Neemuch Agar and Shajapur Districts of Madhya Pradesh India

(hereinafter referred to as the lsquoProjectrsquo) one of the key tasks as part of this assignment is to

secure Free Prior Informed Consent in keeping with the provisions of IFC PS 7 For this

purpose ERM has undertaken the task of identifying a Facilitation AgencyIndividual (FA) to

assist with the FPIC process This document presents the results of the screening and

shortlisting process for the FPIC FA

Approach and Methodology

The approach and methodology followed for shortlisting of FPIC FAs is presented below

1 Two stage approach was followed for the selection of FPIC Facilitation

AgencyIndividual Initially desk research was carried out to identify Institutions (Universities

Government Departments and Research Institutes etc) NGOs and INGOs located in

Madhya Pradesh state In parallel the ERM team also identified the criterion which will be

used to shortlist the potential Facilitating Agencies The criteria used for screening included

qualification profile affiliation with the type of institutionsorganizations nature of

worksprojects completed working experience with Bhils in MP experience in natural

resource management and rural livelihoods conducting meaningful consultation community

mobilization and stakeholder engagement familiarity with World Bank Group safeguardsrsquo

policies and procedures comfort with written and spoken English and local dialects etc

2 In the second stage the potential candidates from these institutions were individually

approached to further assess their suitability and find out their availability for the assignment

Convenient date and time for the personal discussion and interview with them was sought

Accordingly the ERM team organized interview with the available candidates at Bhopal

3 The team27 of Environmental Resource Management (ERM) New Delhi visited

Bhopal during 6-8 January 2020 in order to undertake face to face meetings with these

organizations and individuals identified

Screening

4 The screening against the preferred criteria was undertaken for the potential

candidates available to work as FA for FPIC None of these agenciesindividuals reported to

have worked for a FPIC process earlier Also the candidates interviewed are not familiar

with the World Bank and IFC safeguards related policies and procedure applicable for IPs in

energy and other infrastructure development sectors They are however interested in

working and learning from the project The candidates also had limited experience in the

field of natural resource management and rural livelihoods Details of the screening of

potential candidates is given below

27 Team comprised of Ramesh Swarankar Freelance Consultant and Akshita Mishra Senior Consultant ERM

Page 13

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Amitav Singh

and Leena

Singh

Debate Lok

Nyas (DEBATE)

Duplex C-22

Alkapuri Near

DRM Office

Habibganj

Bhopal-462024

0755-2985007

0755-2417656

9425018144

9425004556

debateindiag

mailcom

MA Social

Works

The key persons are active for

last 3 decades in Social Work

The Debate Trust was

incorporated in 2002-03 and has

more than 15 years of experience

in working with PRIs in Madhya

Pradesh with an focus in Tribal

(Schedule-V) Areas Mr Amitav

Singh is a member of National

Committee for Monitoring of

MNREGA

Ms Leena Singh has also

experience of working with rural

women for more than 15 years

Have

worked

with Bhils

of

Jhabua

Yes Yes Yes

Mr Amitav

Singh is a

leading trainer

for PRA and

Social Audits

by Panchayat

Raj Ministry

No

But was

part of the

FPIC

training

provided

by

ActionAid

Yes

(requires

support in

Reporting)

Score 18 3 2 3 3 3 2 2

Dr Jose

Payyappilly

Address 142

Nyay Nagar

Sukhliya

Indore

Contact-

7828355557

PhD MA

in Social

Work amp

Sociology

About three decades experience

of working on Health HIVAIDS

CSR Literacy Adult education

minority education related

projects and programs funded by

GoI GoM Clinton Foundation Bill

amp Melinda Gate Foundation

UNAIDCARE World Action

Forum VHAI Christian Aid NGO

such as Samarthan in MP

Chhattisgarh and other states It

Has

worked

with Bhils

as part of

a larger

communi

ty in

Jabhua

No No Yes

Trained in

traditional

communicatio

n systems

folklore

folktale

Familiar with

planning

strategy and

community

Associated

with the

network of

NGOs CSOs

and village

level

functionaries

Worked with

local

governments

and elected

No Yes

Page 14

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Email Id

payyappillyjose1

6gmailcom

jose_soolyaho

ocoin

includes the districts in MP with

IPs population

Dr Jose has worked as team

leader director executive director

and other positions Also worked

as Local Governance and BCC

Advisor to DANIDA for Health

Services Program State Media

Coordinator State Resource

centre Adult Education MP

Program Producer Radio Veritas

Asia Manila Philippines

stakeholder

engagement

panchayat

representative

s

Score 14 2 1 1 3 3 1 3

Parushram

Tiwari

Address- C-443

Sarvdharm

Colony Kolar

Road Bhopal

Contact-

09425065132 amp

8319540266

Email Id

drpram42gma

ilcom

PhD

MPhil MA

( Sociology

More than 20 year experience of

working as consultant at different

positions in Public health

HIVAIDS literacy education

nutrition urban development and

governance projects and

programs in MP including Malwa

area and other states

These projects were funded by

UNICEF UNFPA ADB Clinton

Foundation Women amp Child

Development Rural

Development Urban

Administration amp Development

No No Yes Has

worked as

the State

Project

Manager

for Sanjhi

Sehat

project of

MP State

Rural

Livleihood

Mission

Yes Is good

with

coordination

and

communicatio

n

Yes has

experience in

Planning

management

and execution

capacity

building

training and

Networking

and advocacy

Liaison

support and

team building

No Will need

support in

documentatio

n

Page 15

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

State AIDS Control Society of

GoMP and the NGO partners

Dr Tiwari was the Project Director

and District Program officer under

National Literacy Mission at

District Collector offices at Dhar

and Indore MP respectively

during 1991-1998

Score 13 1 1 2 3 3 1 2

Mr Sandip Naik

Adddress-C-55

Kalani Bagh

Dewas MP

Pin Code

455001 India

Contact- +91-94

2591 9221

Email id

naiksandigmai

lcom

Diploma in

Developm

ent

Facilitation

from TISS

Mumbai

MPhil

MA in

Rural

Developm

ent and

English

Literature

About 20 year experience of

working on health nutrition

education governance and

women empowerment with

governments of MP

Worked with NGOs International

agencies and MP government on

senior positions

Since 2014 working with CRY

and TDH on issues of malnutrition

and preparing booklets

brochures pamphlets on nutrition

adolescents issues and childrenrsquos

health Also written textbooks

teachers learning material and

manuals for state govt for SCERT

etc

Yes No No Yes Yes No Yes

Page 16

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Score 14 2 1 1 3 3 1 3

Dr Rahul Dev

Bahawsar

Address Block

No 14 Flat No

5 Shalimar

Enclave E-3

Arera Colony

Bhopal ndash

Madhya

Pradesh

Contact-

08223015124

Email

rbhawsarrediff

mailcom

rahuldevbhawsa

rgmailcom

PhD amp

MPhil in

Population

Studies

from IIPS

Mumbai

MSC

Statistics

24 years experience in

monitoring evaluation and

implementation of programs in

health and social development

sectors in MP Rajasthan and

Gujarat states

Engaged in nutrition assessment

survey in 18 districts of MP states

including IPs dominated districts

such as Dhar Jhabua with Bhil

population and coordinated with

state health women amp child

development and rural

development departments during

the study period

Involved in conducting health

surveys at national level

Worked as a staff with Health

Management Research Institute

Jaipur and IPE Global Consulting

Firm New Delhi etc These

projects were funded by DFID

UNICEF UNFPA GoI GoMP

etc

Yes has

worked

in

Jhabhua

and Dhar

No Yes Has

worked

with State

Rural

Livelihood

Mission

Somewhat

His strengths

lie more

towards

quantitative

research

Somewhat No Yes

Page 17

Name and

Contact

Information

Educationa

l

Qualificatio

ns

Work Experience Experien

ce of

Working

with Bhils

in MP

Experie

nce in

Natural

resource

Manage

ment

Experienc

e in Rural

Livelihood

s

Experience in

Conducting

meaningful

consultation

Experience in

Community

Moblization

Familiarity

with WBG

Safeguard

s

Comfort with

Written and

Spoken

English

Working as freelance expert and

has a registered consultancy firm

that is inactive

Score 12 2 1 2 2 2 1 2

Ms Aastha

Anuragi

Address 173

Sanjay

Complex

Phase-2

Geetanjaly

Square Bhopal-

462003

Contact-

9425365216

8160123726

Email

aasthaanuragi

gmailcom

MBA Rural

Manageme

nt amp MSC

in Physics

More than 15 year experience of

working particularly imparting

training to different stakeholders

in drinking water and sanitation

Swachh Bharat ODF missions

WASH livelihood menstrual

hygiene etc Master trainer for

total sanitation program

Worked as consultant in MP

Chhattisgarh West Bengal UP

Gujarat Jharkhand Bihar states

These projects were funded by

World Bank Water Aid UNICEF

DFID GoI State governments

and ICIMOD Nepal

No No Yes has

worked as

a project

facilitator

with MP

livelihood

project

Yes Yes No No

Score 12 1 1 2 3 3 1 1

Note The scoring for each criterion was as follows 0- Not applicable 1- Not Meeting the Requirement 2- Partially meeting the requirement 3- Completely fulfilling the requirement

Page 18

APPENDIX G TERMS OF REFERENCE FOR THE FPIC FACILITATOR AGENCY

Page 19

TERMS OF REFERENCE FOR FPIC FACILITATION AGENCY

Background

ERM India Pvt Ltd (ERM) has been engaged by Rewa Ultra Mega Solar Limited to undertake an

Environmental and Social Impact Assessment of three solar parks including internal evacuation

infrastructure and associated transmission lines of aggregate capacity of 1500 MW in the Neemuch

Agar and Shajapur Districts of Madhya Pradesh India (hereafter referred to as the lsquoProjectrsquo)

As part of the scope of work for the project ERM is required to assess the impacts on the indigenous

marginalized communities within the site and its influence area prepare an Indigenous Peoples Plan

(IPP) apart from other ESIA amp RAP deliverables The project is also required to conduct a FPIC process

covering affected Scheduled Tribe (ST) population

Villages to be covered in FPIC Process

The project area has a few small ST settlements and in few others a small number of ST households

live along with a majority non-ST population Following 5 villages are identified for carrying out FPIC

process

Solar Park Selected ST villages

for FPIC

Number of

Households

Name of ST

Community

Agar Solar Park Ladwan 12 Bhil

Shajapur Solar Park Parsula 41 BhilBhilala

Neemuch Solar Park Badi and Kawai 97 BhilBhilala

Note Additional ST families in neighbourhood villages of the same Solar Park will be made part of this

process to a limited extent

Phases in FPIC Process

The FPIC process will be divided into two phases as described below

Phase What to Do Schedule

I The overall principles and engagement process and criteria for obtaining FPIC should be agreed on with the affected ST communities

Apr 2021^

II Consent from affected IP communities should be sought for a draft package of proposed impact mitigation measures and benefits

May-Aug 2021^

^ Activities were suspended in April 2021 due to break out of the second wave of Covid-19 in India These

activities will be re-scheduled once Covid-19 second wave gets over

Deliverables and Responsibilities

Phase Responsibilities Deliverable

I Identification of STs Representatives and formation of committees

Capacity building of Representatives of STs on FPIC Process and their rights

Reaching mutual agreement with community on FPIC Process

Documentation of capacity building of STs Representatives on FPIC

Mutually agreed FPIC Process and composition of local ST Representative committees

Page 20

Phase Responsibilities Deliverable

Hindi Translation of TDPIPP and designing Information sharing tools

Participatory mapping of all natural resources and cultural sites to be impacted

Participatory assessment of impacts on Tribal population

Identification of Livelihood and Welfare programs to be included in Draft TDP

Inventory of natural resource and cultural sites

Documentation of participatory process of impact assessment

Note on livelihood and welfare programs

II Information Dissemination- Draft TDP

Facilitation of FPIC related internal meetings of STs and discussion on the package in Draft TDP

Facilitation of DiscussionNegotiation between RUMSL and ST Representatives Committee

Documentation (Photos Video MoMs for each meetingsevents) of FPIC process

The revised package in Draft TDP and a mutually agreed Draft FPIC Agreement

Personnel Requirement

The FPIC Facilitation Agency will require to mobilize following key personnel for completing these tasks

Designation Desired Qualification and Experience

Coordinator The coordinator to be a post-graduate in social sciencessocial work with at

least 15 years of experience in ruraltribal development Prior involvement in

FPIC related work with prominent civil society organizations or multilateral

development finance organizations will be preferred

Facilitator (Male) The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in facilitation of participatory rural appraisals The

facilitator needs to have sound knowledge of livelihood issues in Malwa

region of Madhya Pradesh and must have worked with Panchayati Raj

Institutions for their capacity building The facilitator should be familiar with

the local dialect (Malwi) spoken in Malwa region

Facilitator

(Female)

The Facilitator to be a graduate in social sciencessocial work with at least 15

years of experience in working with rural women She should have

knowledge of livelihood and social context of women in Malwa region She

should have prior experience in facilitating participatory rural appraisal

processes involving rural women

Documentation

Assistant

The documentation assistant should be a Graduate in social sciencesmass

communication She should have at least 5 years of experience in ruraltribal

development and have carried out process documentation of development

projects She should have a good command over Hindi and should be

familiar with Malwi dialect

Community

Mobilizer

The community mobilizer should have passed higher secondary and have

experience of working with any NGO for at least 2 years She should have

good communication skills She will provide all logistical support necessary

to ensure participation of maximum number of people She also helps

Documentation Assistant in photo and video documentation of the FPIC

process

Organization Profile

The organization should have at least 10 years of experience in working in rural and tribal

development issues in Madhya Pradesh The organization should have a reputation of successfully

implementing projects related to community mobilization and capacity building They should have

Page 21

prior experience of working with tribes and should be known for their dedication and commitment

towards tribal rights and promoting their development

The business of sustainability

ERM has over 160 offices across the following

countries and territories worldwide

Argentina

Australia

Belgium

Brazil

Canada

Chile

China

Colombia

France

Germany

Ghana

Guyana

Hong Kong

India

Indonesia

Ireland

Italy

Japan

Kazakhstan

Kenya

Malaysia

Mexico

Mozambique

Myanmar

The Netherlands

New Zealand

Norway

Panama

Peru

Poland

Portugal

Puerto Rico

Romania

Russia

Senegal

Singapore

South Africa

South Korea

Spain

Sweden

Switzerland

Taiwan

Tanzania

Thailand

UAE

UK

US

Vietnam

ERM India Private Limited

Building 10B

3rd Floor DLF Cyber City

Gurgaon NCR ndash 122002

wwwermcom