PH Trail Project Stakeholder Engagement Plan Increased Economic Opportunities and Improved Livelihood for Fragile Communities along the Palestinian Heritage Trail in the West Bank Project No.: (P170706) Stakeholder Engagement Plan (SEP) June 12021 PH Trail Project Stakeholder Engagement Plan Table of Contents Abbreviations and Acronyms..........................................................................................4 1. Introduction ..........................................................................................................5 1.1. Project Overview ....................................................................................................5 1.2.1. Project Location............................................................................................6 1.2.2. Project Description .......................................................................................6 1.2.4.Potential social and environmental risks and impacts of the project ....................9 1.3. Purpose and objectives of SEP ............................................................................ 10 1.3.1. World Bank Environmental and Social Standard 10 ......................................... 10 1.4.2. Palestinian Environmental Assessment Policy ................................................ 11 1.Brief Summary of Previous Stakeholder Engagement Activities ..................................... 12 2.Stakeholder identification and analysis ....................................................................... 12 2.1. Project-affected Parties (PAPs) ........................................................................... 12 2.1.1.Local communities residing in the project areas .............................................. 12 3.2. Other interested parties (OIPs) ........................................................................... 12 3.3. Vulnerable individuals or groups ......................................................................... 13 4. Stakeholder Engagement Program ............................................................................ 14 4.1. Planned stakeholder engagement activities ......................................................... 14 4.2. Engagement methods to be used ........................................................................ 19 4.3. Proposed strategy to incorporate the view of vulnerable groups ............................ 21 4.4. Proposed strategy for information disclosure ....................................................... 21 4.5. Timelines ......................................................................................................... 22 4.6 Review of Comments ......................................................................................... 22 5. Resources and Responsibilities for implementing stakeholder engagement activities...... 22 5.1. Implementation Resources ................................................................................ 22 5.2. Estimated Budget.............................................................................................. 22 6. Grievance Mechanism ............................................................................................. 23 6.1. Grievance Process ............................................................................................. 23 6.1.1. Receipt of Grievances .................................................................................. 23 6.1.2. Procedures for filing the complaints .............................................................. 24 6.1.3. Registering complaints ................................................................................ 24 6.1.4. Referral and Examination of complaints ........................................................ 24 6.1.5. Notifying the complainant and Closing the complaint ..................................... 25 6.1.6. Additional Dispute Resolution Scheme .......................................................... 25 2 PH Trail Project Stakeholder Engagement Plan 6.2. Feedback/grievance monitoring and recording ..................................................... 26 6.3 The grievance mechanism and process for complaints related to GBV, Sexual Harassment and Sexual Abuse .................................................................................. 26 6.4. World Bank Grievance Redress System ................................................................ 27 6.5. Grievance mechanism for workers ...................................................................... 27 6.6. PH Trail Contact Information .............................................................................. 28 7. Monitoring and Reporting ........................................................................................ 28 7.1. Monitoring Reports ........................................................................................... 28 7.1.1. During the Implementation .......................................................................... 28 7.1.2. During Operation ........................................................................................ 29 7.2. Involvement of stakeholders in monitoring activities ............................................ 30 7.3. Reporting back to stakeholder groups ................................................................. 30 Annex I: Technical Note on Public Consultations and Stakeholder Engagement in WB- supported operations when there are constraints on conducting public meetings Annex II: Minutes of Meeting of Public Consultation Meetings 3 PH Trail Project Stakeholder Engagement Plan Abbreviations and Acronyms JSDF Japan Social Development Fund PH Trail Palestinian Heritage Trail HLITOA Holy-Land Incoming Tour Operators Association WHO World Health Organization CBO Community Based Organization EQA Environment Quality Authority ESMP Environmental and Social Management Plan ESO Environmental and Social Officer GRM Grievance Redress Mechanism GRS Grievance Redress Service PMU Project Management Unit SEP Stakeholder Engagement Plan LGU Local Government Unit M&E Monitoring and Evaluation POM Project Operation Manual ESMF Environment and Social Management Framework LMP Labor Management Procedures SEA/SH Sexual Exploitation Abuse/Sexual Harassment GRM Grievance Redress Mechanism ESCP Environmental and Social Commitment Plan ESHS Environmental, Social, Health and Safety USD United States Dollar MOTA Ministry of Tourism and Antiquities MOE Ministry of Education MOL Ministry of Labor NEPTO Network for Experiential Palestinian Tourism Organizations PEAP The Palestinian Environmental Assessment Policy ESF Environmental and Social Framework NGO Non-Governmental organization ESS Environmental and Social Standards IEE Initial Environment and Evaluation EQA Environment Quality Authority PAPs Project Affected Parties OIPs Other Interested Parties 4 PH Trail Project Stakeholder Engagement Plan 1. Introduction 1.1. Project Overview The proposed JSDF-funded project will bring to full maturity the transformation of the Palestinian Heritage Trail into a backbone for socioeconomic development for fragile communities across the West Bank. By basically investing in rural communities along the Path, the project will support the natural evolution of walking trails in the West Bank and maximize the economic impact of experiential tourism as a development tool in these marginalized communities. Also, since tourism activities stopped during COVID-19 crisis in the West Bank, vulnerable groups within the tourism sector are among the hardest hit. 1 The project will leverage the existing community-based tourism network to support vulnerable communities, including households, micro and small businesses, and daily-wage workers, reconnecting to the domestic market first and then to the international one as appropriate. Indeed, the proposed project aligns with the WBG COVID-19 Crisis Response Approach Paper, where it falls under Pillar II of Protecting the Poor and the Vulnerable and Pillar III of Ensuring Sustainable Business Growth and Job Creation. The Project team is collaborating with the World Bank task team working on the COVID-19 project in West Bank and Gaza to explore possible synergies during the preparation stage. The JSDF operation is also needed to explore how to reach, and the extent to which it is possible to reach full sustainability of the investments. Three major points will be analyzed and finalized with the proposed project: institutional sustainability, sustainability of the Path, and sustainability of the community services and businesses along the Path. In conclusion, while the first project financed the lay out of the Path, the JSDF project will enrich and expand the experiences along the Path through investments in community development. 26. Also, the proposed project is innovative in several ways. Among the most relevant are that the project will: (i) reach rural communities usually excluded from mainstream tourism activities in the West Bank. Some of the beneficiary communities will be targeted for the first time by public programs; (ii) help the rural communities increase their resilience and reconnection to economic activities; (iii) build new capacities among the beneficiary communities and individuals. The activities and the “life� of the Path will allow to have the beneficiaries trained for the first time on new topics that in the respect of the existing social and cultural norms will allow them to participate in the tourism industry. As an example, the project will provide women and youth2 for the first time in their lives with concrete economic opportunities in tourism. Women will be trained as entrepreneurs leveraging on their role in the family and communities, and as a result they should be able to start and manage their own economic activities, while youth will be trained and given economic opportunities leveraging on their creativity and their role in society; and (iv) create new types of experiential tourism businesses along the Path and improve their income opportunities, increasing the connectivity among all the involved actors. Furthermore, the value added of the World Bank and of the JSDF is relevant beyond the financing. The added value arises from the Bank’s technical inputs based on international experiences, and the convening power of some among the best international experts, and the international community. The Government of Japan is also very active in the West Bank with 1 UNWTO, an inclusive response for vulnerable groups (link) 2 Considered as those of age between 15 and 29. 5 PH Trail Project Stakeholder Engagement Plan relevant investments and interventions, among which the most relevant ones are “the Corridor for Peace and Prosperity Initiative� and the project for the renewal, protection and increase of value of Hisham’s Palace as a center for local development. These projects aim to peace building through promoting economic and social self-reliance, investing in the following three major pillars: 1) stability and betterment of people’s livelihood, 2) reinforcement of governmental administrative capacity, and 3) promotion of sustainable economic growth. All these projects are highly regarded and well-known in the international and local community. 1. The proposed project is consistent with the WBG’s Assistance Strategy for the West Bank and Gaza (FY22-25), which supports interventions from the starting line of strengthening economic and social resilience towards the finish line of a well-connected Palestine. In particular, the proposed project is consistent with the following objectives of the Assistance Strategy: (i) Objective 1.3 – Achieve better Human Development Outcomes that among the others, aims to enhance the capacity of the workforce with particular focus on youth and women for better job opportunities; and (ii) Objective 2.2 – Connect the Palestinian Economy to Regional and Global Economy that aims to foster a “well-connected Palestine� through interventions, among the others, in knowledge-sharing and expanded business and market linkages given that in the current state, the fragmentation of the Palestinian territories and of the economy has led to weakened sectoral linkages and limited integration to value chains. Finally, the Strategy states that building on the focus of the FY18- 21 Country Assistance Strategy, the World Bank Group will continue to support improved firm capabilities and competitiveness. 1.2.1. Project Location Along the trail in the West Bank mostly rural corridor, there are about 603 rural, marginalized communities, some of which living below the poverty line. About 50 of these communities were targeted by the previous project and could benefit from the creation of the trail and from the project’s activities 1.2.2. Project Description The Palestinian Heritage Trail, formerly known as the Abraham Path/Masar Ibrahim, is the longest trail in the West Bank, and along the trail’s mostly rural corridor, there are about 604 rural, marginalized communities, some of which living below the poverty line. Most of these very poor and marginalized communities are not targeted by other programs given their locations, the lack of connectivity among them, the lack of information about current places of residences5 of Palestinian citizens, and the FCV context. About 56 of these communities were previously targeted by the project that recently closed with specific activities, and benefitted from the creation of the trail, the investments in the Path soft- infrastructures, and the establishment of PH Trail as a supporting institution for the Path. The JSDF funded project will expand the interventions at community-level building capacity and provide livelihood and economic opportunities to communities including local women’s associations, youth groups, local councils, relevant CBOs and CSOs, and to individuals, such as 3PH Trail is currently re-assessing the final number of fragile communities existing along the Path. 4PH Trail is currently re-assessing the final number of fragile communities existing along the Path. 5 Sarah Keener “Citizen Engagement and Public Service Delivery in the Context of Fragility�, the World Bank. 6 PH Trail Project Stakeholder Engagement Plan homestay hosts, guides, transport providers, and local business owners that want to start or strengthen their entrepreneurial activities along the PH Trail. Finally, the new, JSDF project will also have a strong sustainability focus and will allow to define the final Bank’s exit strategy. In particular, the project will explore how to reach, and the extent to which it is possible to reach full sustainability of the investments, and to bring to full maturity the businesses that have been generated along the Path. Figure 1: Vulnerable communities along the Palestinian Heritage Trail The project will use the financing from the JSDF to promote local community development through the implementation of the following two components: Component I: Community Driven Development; This first component will include three sub-components. The first activity will finance community- subprojects, including trainings and some goods that will help the communities to strengthen their touristic offer, to grow their businesses and to cater to local and international tourists/walkers. Specifically, through a community- 7 PH Trail Project Stakeholder Engagement Plan driven development approach, funding will be dedicated to creating and improving the tourism experiences that communities offer, such as making experiences of olive oil, herbal soap, wine, handcrafts, traditional food, and organic farming, through training and the financing of ad hoc equipment. These experiences would offer tourists the opportunity to see how these items are traditionally made and buy products towards the end of their visit. The project will also support community activities to further support “within community� activities, such as creating inter - community walks, through way-marking and signage, training individuals and communities and promotional campaigns among communities; planting trees and gardening of some areas; improving first aid stops; training the communities on cleaning and respecting the environment, on hygiene and on foreign languages; training youth to become community guides; preparing promotional materials such as maps and booklets; and organizing familiarization trips for tour operators. No new construction will be made, and no removal of trees will take place. Also, a cluster approach, through which the communities will be grouped, will be adopted in the implementation of the activities to strengthen the linkages among communities and their working together. Component II: Project Management and Administration, Monitoring and Evaluation, and Knowledge Dissemination. This component includes the following 3 sub-components: (i) Project Management and Administration; (ii) Monitoring and Evaluation; and (iii) Knowledge Dissemination. (i) Sub-component 1, Project Management and Administration: PHT will be the implementing agency of the project and this sub-component will cover the costs of a project manager, some consultancies, and the project audits. (ii) Sub-component 2, Monitoring and Evaluation: the first activity to be implemented under this second sub-component will be the tracking of project’s results and the achievement of the Project Development Objective (PDO) indicators. This component will finance a Monitoring and Evaluation (M&E) system, and the strengthening of the Palestinian Heritage Trail (PHT) monitoring and evaluation framework. (iii) Sub-component 3, Knowledge Dissemination: this last sub-component will finance two dissemination events. One in the field to share project results, lessons learned and project gains, with major stakeholders, representatives of the Japanese government, donors, representatives of the private sector, etc. and the second in Washington DC. 1.2.3. Beneficiaries The project aims to benefit about 3,000 Palestinian individuals present in about 50 fragile communities along the Palestinian Heritage Trail across all the West Bank. There will be a special focus on women and youth, and it is estimated that at least 40% of the beneficiaries will be women and 25% youth. The project will provide livelihood and economic opportunities to about 50 communities including local women’s associations, youth groups, local councils, relevant CBOs and CSOs, firms, and to individuals, such as homestay hosts, guides, transport providers, and local business owners that want to start or strengthen their entrepreneurial activities along the Trail. The benefits are expected to be in terms of income and creation of hours of work for about 3,000 Palestinian individuals belonging to these communities. 8 PH Trail Project Stakeholder Engagement Plan Secondary beneficiaries would include the walkers and visitors, newly hired workers, apprentices, and other communities and firms that purchase the improved products or get the improved services. The benefits are expected to be high in terms of income for the beneficiary communities and creation of hours of work. Other benefits that need to be quantified are the socio-economic inclusion of communities and groups at risk, investments that the project will generate directly and indirectly, and contribution to the sustainment of the businesses and the livelihoods of the communities during the COVID-19 crisis. 1.2.4. Potential social and environmental risks and impacts of the project The expected environmental impacts of the project will be overall positive. The environmental risk for this operation is rated as moderate given that the environmental risks mentioned above are low in scale, predictable and could be managed by available means and limited to the footprint of the project facilities. The project will finance under component 1 community- sub-projects, mainly projects of a soft nature to promote the touristic activities along the PH Trail. However, the project will fund the upgrading activities (rehabilitation/renovation/refurbishment), purchase and installation of equipment for example for wine production, cooking traditional food, olive oil making, herbal soap, which might be associated to potential adverse environmental impacts and risks. This might include OHS risk including exposure to electrical hazards from the use of tools, lifting of heavy equipment and falling and falling objects and handling and disposal of generated waste. Also, the project will finance activities like cleaning of walks and plantation of trees, organic farming, and OHS measures are necessary. In addition, the increasing touristic activities could lead to uncontrolled practices by visitors, especially if unorganized visitors go directly to the Trail, for example for barbecues which would lead to damage such as fire and littering. Other environmental risks include noise, dust and handling and disposal of chemicals which is used in herbal soap making. The low capacity of PHT will be mitigated by recruiting the project M&E officer to supervise the implementation of the requirements of different ESSs, with support from a part-time social and environmental consultant, hired as needed, and the project manager. The social risk for this operation is rated as moderate. The potential social risks relate to: elite capture and lack of transparency in allocation of grants; exclusion of sub-groups within vulnerable categories (e.g. women headed households; youth out of school and unemployed; population from households with disabled members or members with chronic disease, etc.) due to lack of information (in accessible formats) about how to access and avail of project benefits and meaningful engagement with these categories; labor and working conditions for the project’s direct and contracted workers; incidence of GBV and SEA/SH for women and youth due to increased tourist activities in the project area; and community health and safety concerns associated with transmission of diseases such as Covid-19. The project will not involve any land taking and hence there is no risk related to involuntary resettlement. Small civil works will be on existing land owned by beneficiaries and there will be no expansion of existing or building of new facilities. Private individuals/firms seeking co-financing to establish new enterprises will need to demonstrate adherence to willing-buyer willing-seller criteria to meet any land needs to qualify. The ESMF and POM will include an exclusion list of activities requiring any involuntary resettlement or land acquisition. The PH Trail has prepared an Environmental and Social Management Framework (ESMF) and a Labor Management Procedures (LMP) that include measures to address the environmental and social risks of the project and the key labor risks related to workers’ occupational health and safety, child labor and poor working conditions. The LMP contains terms and conditions of employment, measures for nondiscrimination and equality of opportunity, workers’ organizations, no child or forced labor engaged in the project, no SEA/SH amongst workers and other personnel, adequate OHS measures and that a labor GM is established, sensitive to complaints linked with SEA/SH. 9 PH Trail Project Stakeholder Engagement Plan The Project’s SEP will ensure that project benefits, such as access to grants, and job opportunities, can be accessed and optimized for the most vulnerable and youth, including those from poor communities and women through consultation and different methods of engagement activities. Also, the specific criteria for the selection, financing and implementation mechanism of the activities under component 1 will be identified in the project operational manual, however, for the grant matching scheme the project will explore the formation of inclusive community-based committees and engage community members in a participatory needs’ assessment and in the clustering approach that will be implemented. The project’s ESCP will include all the requisite E&S actions and commitments between PH Trail and the World Bank to ensure that environmental and social risks and impacts are addressed and managed in keeping with the Bank’s ESF. The project M&E officer, a part-time social and environmental consultant and the project manager will be responsible for ESMF implementation and management of E&S issues. 1.3. Purpose and objectives of SEP The purpose of the present Stakeholder Engagement Plan is to explain how Stakeholder Engagement will be practised throughout the course of the project life cycle and which methods will be used as part of the process; as well as to outline the responsibilities of PH Trail and contractors in the implementation of Stakeholder Engagement activities. 1.3.1. World Bank Environmental and Social Standard 10 The Environmental and Social Framework (ESF) that was launched on October 1, 2018 forms a new set of environment and social policies to enable the World Bank and Borrower better manage environmental and social risks of projects and to improve development outcomes. An essential part of this framework is the ten Environmental and Social Standards (ESSs), which establish the standards that the PH Trail and the project should meet through the project life cycle. Out of these standards, ESS10, “Stakeholder Engagement and Information Disclosure�, recognizes “the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice�. Specifically, the requirements set out by ESS10 are the following: • Borrowers will engage with stakeholders throughout the project life cycle, commencing such engagement as early as possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on project design. The nature, scope and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts. • The Recipient will provide stakeholders with timely, relevant, understandable, and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination, and intimidation. • The process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. • The Recipient will maintain and disclose as part of the environmental and social assessment, a documented record of stakeholder engagement, including a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not. A Stakeholder Engagement Plan proportionate to the nature and scale of the project and its potential risks and impacts needs to be developed by the Recipient. It must be disclosed, as 10 PH Trail Project Stakeholder Engagement Plan early as possible, and before project appraisal, and the Recipient needs to seek the views of stakeholders on the SEP, including on the identification of stakeholders and the proposals for future engagement. If significant changes are made to the SEP, the Borrower must disclose the updated SEP. According to ESS10, the Recipient should also propose and implement a grievance mechanism to receive and facilitate the resolution of concerns and grievances of project-affected parties related to the environmental and social performance of the project in a timely manner. The grievance mechanism shall ensure that PAPs have the access to a viable system to air grievances, raise concerns, provide feedback and to seek resolution with no intimidation or coerciveness. The grievance system is also important for PHT to ensure they are accountable to complaints and that these complaints are handled transparently and efficiently. 1.4.2. Palestinian Environmental Assessment Policy The Palestinian legislation requires public consultation only for projects that require Environmental Assessment. The Palestinian Environmental Assessment Policy (PEAP) was approved by decree No: 27� 23/4/2000. One of the main principles underlying this policy is that stakeholder consultation is an essential component of it. Article 8 of this policy on Stakeholder Consultation states the following: 1. Proponents are required to consult stakeholders during the scoping and conduct of Environmental Impact Assessments. 2. Stakeholder consultation may be required during Initial Environment and Evaluation (IEE) as determined by the Environment Quality Authority (EQA). 3. The EQA is empowered to conduct its own stakeholder consultation to verify the information provided or extend the proponent’s consultations. 4. Initial Environmental Evaluation and Environmental Impact Assessment Reports shall be made available by proponents for stakeholder review and comment as specified by the EQA. 5. The EQA shall coordinate EA consultations with consultations by other authorities pursuant to other regulations and laws. According to the policy, stakeholder consultation is optional when undertaking an IEE. In consultation with the proponent and the EA Committee as required, the EQA determines whether stakeholder consultation is required and, if so, what the minimum requirements should be. It may be required during scoping and terms-of-reference preparation, and during the conduct of the IEE. However, stakeholder consultation is mandatory when undertaking an EIA. In consultation with the proponent and the EA Committee, the EQA determines what the minimum requirements for stakeholder consultation should be. It may be required during scoping and terms-of-reference preparation, and during the conduct of the EIA. At minimum, the proponent must meet with the principal stakeholders to inform them about the proposed project and to solicit their views about it. Projects that are more problematic should involve consultations that are more extensive. The methods and results of these consultations must be documented in the EIA Report. 11 PH Trail Project Stakeholder Engagement Plan 1. Brief Summary of Previous Stakeholder Engagement Activities For the design of the project components and for the identification of its activities, PHT team conducted several rounds of consultations with potential beneficiaries and stakeholders. PHT team met with about 40 communities, private companies, village councils, CSOs, entrepreneurs, mayors, public officers, homestays, guides, and others. Annex II provides the record of the consultations which took place in February 2019 and in November 2020. In addition, World Bank team members participated in PHT consultations with key stakeholders and members of communities in Fall of 2018 and in Fall of 2020. Throughout all the consultations, PHT team assessed the current economic activities, status and needs of the communities, including of women and youth. The PHT has also conducted a virtual public consultation meeting on November 23rd, 2020. About 17 participants representing homestay hosts, tour guides, community organizations and local authorities attended the meeting. During the meeting, project’s activities were presented to participants in addition to the GM. Feedback from participants was also registered and questions answered. A briefing about the project was presented and suggestions from the local communities collected. A summary of the meeting is provided in Annex II. 2. Stakeholder identification and analysis 2.1. Project-affected Parties (PAPs) Within the scope of this project, there are two main categories for the project-affected parties, namely the local communities residing in the project areas, and the local businesses: 2.1.1 Local communities residing in the project areas The project will provide livelihood and economic opportunities to about 50 communities including local women’s associations, youth groups, local councils, relevant CBOs and CSOs, firms, and to individuals, such as homestay hosts, guides, transport providers, and local business owners that want to start or strengthen their entrepreneurial activities along the Trail. The benefits are expected to be in terms of income and creation of hours of work for about 3,000 Palestinian individuals belonging to these communities. 2.1.2 Already existing businesses at an individual, firm-level, with focus on female and young entrepreneurs Through the project, the local Palestinian firms will access new equipment and goods, gain know-how from experts in the sector, and improve quality and scale of outputs, among other benefits, such as to connect with other firms in their value chains. The project will also explore how to reach, and the extent to which it is possible to reach full sustainability of the investments, and to bring to full maturity the businesses that have been generated along the Trail. 3.2. Other interested parties (OIPs) Table 3-1 below summarizes the key categories of OIPs and the respective justification for their interest in the project. The table includes civil society organizations, private sector, government bodies. Table 3-1: Other interested parties 12 PH Trail Project Stakeholder Engagement Plan Category Institution Interest Ministries and MOTA Staff of the Ministry of Tourism and Antiquities Government (MOTA). MOTA lead the advisory council of the agencies project and MOTA staff were part of outreach and training activities. Non- Network of -This network represents a group of governmental Palestinian independent non-profit organizations, each and civil society Experiential tourism working to share the best of West Bank and organizations organizations Gaza with travelers from around the world. (NEPTO) -The union of The Palestinian Heritage Trail (PH Trail), that includes the three NGOs that worked on the walking trail from its inception: the Rozana Association, the Siraj Center, and the Palestine Wildlife Society. The Private Holy-land Incoming Palestinian private sector tour operators Sector Tour Operators represented by the Holy-land Incoming Tour Association Operators Association (HILTOA). The (HILTOA) association supported the integration of PH Trail with private tour operators in West Bank and Gaza to support the sustainability of services. Academic Bethlehem Bethlehem University’s Institute for institutions University Community Partnership was involved in the training and educational aspects of the Path in West Bank and Gaza. The university prepared the content of a wilderness guide curriculum in cooperation with a professional French tourism organization. Press and media TV and radio, social Inform residents in the project area and the media platforms wider public about the Project such as Bethlehem implementation and planned activities in 2000 FM and Maan addition for marketing the PH Trail locally and TV internationally. 3.3. Vulnerable individuals or groups The project will target disadvantaged and vulnerable individuals and groups such as women, disabled people and youth and their families. In order to ensure disadvantaged or vulnerable needs are taken into consideration, and that they are reached, the implementing entity will adopt several mechanisms such as, publishing all information about the project in Arabic and reaching out to these groups. 13 PH Trail Project Stakeholder Engagement Plan The main vulnerable groups identified for this project are summarized in Table 3-2. . Table 3-2: Vulnerable groups Vulnerable Group Description and Relationship to the Project Women and Female-headed The project targets around 50 homestays and 27 women centers households and across the 60 communities along the trail and most of these women centers run homestays and women centers are run by women. The role of by women women through the services provided in the – communities are very crucial for the success of the project implementation. The project will support women through capacity building and business creation. It is estimated that at least 40% of the beneficiaries will be women and 25% youth. People with The project targets people with disabilities through developing disabilities special segments across the trail to be used by disabled people. The project will also target the disabled people by encouraging them for starting small businesses throughout the targeted communities. Poor and The project will reach out to rural communities usually excluded marginalized from mainstream tourism activities in the West Bank e.g. Bedouin communities communities. Most of these are very poor and marginalized communities and are not targeted by other programs given their locations, the lack of connectivity among them, the lack of information about current places of residences6 of Palestinian citizens, and the FCV context. Some of the beneficiary communities will be targeted for the first time by public programs and individuals will be trained for the first time on new topics that in the respect of the existing social and cultural norms will allow them to participate in the tourism industry. Youth The project will provide some youth7, for the first time in their lives, with concrete economic opportunities in tourism. Youth (both females and males) will be trained as entrepreneurs leveraging on their roles in the family and communities and encourage them to create their business. It is estimated that at least 40% of the beneficiaries will be women and 25% youth. 4. Stakeholder Engagement Program 4.1. Planned stakeholder engagement activities Stakeholder engagement activities need to provide specific stakeholder groups with relevant information and opportunities to voice their views on topics that matter to them. The table 4- 6Sarah Keener “Citizen Engagement and Public Service Delivery in the Context of Fragility�, the World Bank. 7 Considered as those of age between 15 and 29. 14 PH Trail Project Stakeholder Engagement Plan 1 below presents the stakeholder engagement activities envisaged under the project. The activity types and their frequency are adapted to the three main project stages (project design and preparation; construction and operation and maintenance phase). A more detailed explanation of the stakeholder engagement methods used is included in section 4.2. 15 PH Trail Project Stakeholder Engagement Plan Table 4-1: Planned stakeholder engagement activities per project phase Project stage Target stakeholders Topic(s) of Method(s) used Location/frequency Responsibilities engagement Local communities in rural areas Project scope and - Online meetings and - - PH Trail represented by local councils, local rationale. opening event- women’s associations, and relevant Establishing distribute Brochures Annual public events – 3 events community-based associations such as Tourism about the project committees objective and activities Meeting representativesof youth groups or representatives of - local tourism committee local tourism committee - Grievance mechanism three times a year and if - Survey on selected & representative sample. needed Consultations Individual stakeholders directly Project scope and - Individual online As needed - PH Trail engaged or employed on the PH Trail, rationale meetings such as homestay hosts, guides, and - Joint local business owners public/community meetings with PAPs Steering committees (Ministries and Project scope and - Individual online As needed PH Trail Government agencies and local rationale, meetings Project E&S - Joint authorities formulate three steering principles; public/community committees for North, Middle and South of the West Bank Quarterly updates 16 PH Trail Project Stakeholder Engagement Plan Project stage Target stakeholders Topic(s) of Method(s) used Location/frequency Responsibilities engagement Local communities in rural areas Project health and - Public meetings, - Meetings in all affected - PH Trail Implementation represented by local councils, local safety impacts and - Mass/Social Media communities women’s associations, and relevant mitigation Communication – TV, -Communication through community-based associations such measures radio, Facebook mass/social media (as needed); Employment - Disclosure of written - Information desks with as youth groups. Individual opportunities information - Brochures, brochures/posters in affected stakeholders directly engaged or posters, flyers, website employed on the PH Trail, such as Environmental municipalities (continuous) Information desks - In homestay hosts, guides, - and local concerns Municipalities business owners Grievance - Grievance mechanism mechanism representatives of local tourism process. committee and grantees – direct beneficiaries Steering committees (Ministries and Project scope and - Individual meetings As needed - Ph Trail Government agencies rationale - Joint Project E&S public/community steering committees) principles meetings Employment opportunities Environmental concerns Grants process and training Promotional activities 17 PH Trail Project Stakeholder Engagement Plan Project stage Target stakeholders Topic(s) of Method(s) used Location/frequency Responsibilities engagement Local communities in rural areas Satisfaction with Mid-term and final - Meetings in all affected PH Trail represented by local councils, local engagement evaluation and impact communities one per year) women’s associations, and relevant activities and GRM evaluation and sample -Communication through community-based associations such Grievance household survey mass/social media (as needed) Evaluation mechanism - post survey for a - Information desks with as youth groups, Individual process selected representative brochures/posters in affected stakeholders directly engaged or sample in the area. employed on the PH Trail such as homestay hosts, guides, transport providers, and local business owners Steering committees (Ministries and Mid-term and final Meeting and semi- 3 times PH Trail Government agencies impact evaluations structure interviews steering committees) 18 PH Trail Project Stakeholder Engagement Plan 4.2. Engagement methods to be used The project intends to utilize various methods of engagement that will be used as part of its continuous interaction with the stakeholders. The format of every consultation activity should meet general requirements on accessibility, i.e. should be held online or at venues that are easily reachable and do not require long commute, entrance fee or preliminary access authorization. The activity should also meet cultural appropriateness (i.e. with due respect to the local customs and norms), and inclusiveness, i.e. engaging all segments of the local society, including disabled persons, the elderly, and other vulnerable individuals . Those engagement methods shall include small size meetings at the targeted municipalities and announcements through towns social media and networks, public announcement in local governments offices/ local authorities and social media such as Facebook pages, mosques, also announcement with brochures in public areas, and through NGOs. The mosque is usually considered an efficient tool of information at small localities; it can be used to inform the community and to encourage active participation of the different stakeholders. If a large audience is expected to attend a public meeting, necessary arrangements will be made to ensure audibility and visibility of the presentation involved. This includes provision of a projector, places allocated for the wheelchair users, etc. In order to control the risks of virus transmission, the implementing agency will be advised, when conducting stakeholder consultation meetings, to take into account the national restrictions regarding public gatherings during Covid-19 pandemic and the World Bank note on “Public Consultations and Stakeholder Engagement in WB-supported operations when there are constraints on conducting public meetings� included in Annex II. Taking records of the meeting is essential both for the purposes of transparency and accuracy of capturing public comments. At least two ways of recording may be used, including : • taking written minutes of the meeting • photography. A summary description of the engagement methods and techniques that will be applied by PH Trail is provided in Table 4-2. The summary presents a variety of approaches to facilitate the processes of information provision, information feedback as well as participation and consultation. Table 4-2: Engagement Methods and Tools Method / Tool Description and Contents Target Groups Use Correspondence -To distribute Introduction of the project Government officials, (Phone, Emails, information to and information about NGOs, CBOs, and official letters) Government time and venue of universities and Media officials, NGOs, and meetings CBOs -To invite stakeholders to meetings and follow-up. 19 PH Trail Project Stakeholder Engagement Plan Method / Tool Description and Contents Target Groups Use Individual - To discuss specific Project’s specific activities Municipalities, National meetings project activities and plans, design solutions government ministries, and related issues if and impact NGOs, Universities, and needed mitigation/management service providers measures that require in- depth discussion with stakeholders. Public meetings - Project launch - Important highlights of -Local residents, Bedouin meetings and Project, announcements leaders, farmers, community public of planned activities, municipalities and meetings measures for risk governmental agencies throughout the mitigation, overall and local service project life cycle. progress, and major providers. -To present project achievements. information affected parties and larger communities -To allow participants to provide their views and opinions -To build relationship with the communities -To register feedback on discussions and questions. post survey A survey will be citizen’s experience and - Local communities and carried out once feedback about the comparison communities during the project’s project beneficiary lifecycle: towards the end of the project operation. Mass/social A social media Key project updates Local population, and media expert will be other stakeholders engaged on the Information on project communication activities; health and project in order to post information on safety Impacts; Project the dedicated E&S principles; project and PH Trail Facebook page, Ph Trail website, and to communicate with the local population via social media campaigns or tools throughout the project’s lifecycle. 20 PH Trail Project Stakeholder Engagement Plan Method / Tool Description and Contents Target Groups Use Communication -Written - Key project updates and PAPs, public and other materials information will be reports on the project’s stakeholders disclosed to the environmental and social public via a variety performance. of communication - GM guidebook/manual materials including brochures, flyers, - Leaflets to include GM posters, etc. tools - Website to be updated regularly. - /PPT or video interactive content with the beneficiaries to be used during public meetings and on social media platforms. Tours and site - At appropriate Information on project Media, NGOs and CBOs visits points during the activities; health and implementation safety Impacts; Project phase, site visits or E&S principles; and demonstration grievance mechanism tours will be process organized for selected stakeholders Including media, tour operators 4.3. Proposed strategy to incorporate the view of vulnerable groups The project will take special measures to ensure that disadvantaged and vulnerable groups have equal opportunity to access information, provide feedback, or submit grievances. Focus group meetings dedicated specifically to vulnerable groups will be convened whenever relevant. 4.4. Proposed strategy for information disclosure The current PH Trail website (http//: www.paltrail.org) is being used to disclose project documents, including the SEP both in English and in Arabic. PH Trail will create a webpage for the Project on its existing website. All future project related environmental and social monitoring reports, listed in the above sections will be disclosed on this webpage. Project updates will also be posted on the homepage of PH Trail website. An easy-to-understand guide to the terminology used in the environmental and social reports or documents will also be provided on the website. All information brochures/fliers will be posted on the website. Details about the project Grievance Redress Mechanism will be posted on the website. An electronic grievance submission form will also be made available on PH Trail’s website. PH Trail will update and maintain the website regularly (at least once a quarterly basis). Further, PH Trail will use its Facebook page. Project documents will also be disclosed on the World Bank website. 21 PH Trail Project Stakeholder Engagement Plan 4.5. Timelines Information on timelines for project phases and key decisions is provided in Table 4-3. Table 4-3: Project phases timeline Bank Start of Phase Activity Apprai implement out sal ation July 5th September 2025 Component 1: Community Driven Development 2021 2021 Component 2: Project Management and Administration, July 5th September Monitoring and Evaluation, and Knowledge 2025 2021 2021 Dissemination 4.6 Review of Comments As explained in more details above, communication and feedback from stakeholders will be taken into consideration at each stage of this project. The PH Trail plans to have several public meetings with the target population pre-implementation and post implementation to receive reviews and comments. 5. Resources and Responsibilities for implementing stakeholder engagement activities 5.1. Implementation Resources PH Trail will mobilize human and material resources to implement the SEP and manage the Grievance Mechanism (GM). SEP activities will be led by the Project Management Unit (PMU), and some activities with the Communication Department for the implementation of certain relevant activities. The project’s Monitoring & Evaluation/Environmental & Social (M&E/ ES) officer, with support from the part-time social and environmental consultant and the project manager, will be responsible for implementing the stakeholder engagement activities in coordination with different stakeholders, and conducting environmental and social monitoring and reporting. The material resources that PH Trail will mobilize are – (i) a specific area on the PH Trail website; (ii) a Facebook page of Ph Trail; and (iii) printed documents (manuals, brochures, posters, etc.) that will be used, based on the SEP requirements. 5.2. Estimated Budget A tentative budget for implementing the stakeholder engagement plan over four years is attached in Table 5-2. The stakeholder engagement activities featured in the budget cover a variety of environmental and social issues, which may be part of other project documents, so it is possible that they have also been budgeted in other plans. However, the table summarizes all the stakeholder engagement activities in one place for better coordination and monitoring. PH Trail will review this plan every six months to determine if any changes to stakeholder classification or engagement are required. If so, the plan will be updated, and a new revision distributed. The budget will be revised accordingly. Table 5-2: Estimated budget for four years 22 PH Trail Project Stakeholder Engagement Plan Quan Unit Cost Times/4 Total Cost Activities tity (USD) years (USD) Stakeholder Engagement Activities Staff salaries (M&E/ ES officer) Included in the ESMF (Approximately 30% of their time will be dedicated for the implementation of the SEP) Project Launch meetings (three for the 3 1009 4 3,027 different west bank localities Community meetings and stakeholders’ 33 300 4 9,900 consultations Communications materials (posters, 4 1,500 4 6,000 pamphlets… including design) Short video 1 5,000 1 5,000 Project tours for media 4 2,000 4 8,000 Contingency (10%) 6,073 Sub-total - Stakeholder Engagement 38,000 Grievance redress activities Communications materials (GM manual 2000 including design) Internal GM training for PH Trail (Quantity: 10 200 1 2,000 training hours) Contingency (10%) 400 Sub-total – GM 4,400 Total 42,400 6. Grievance Mechanism A grievance mechanism (GM) will be in place for this project to ensure that PAPs have the access to a viable system to air grievances and to seek resolution with no intimidation or coerciveness. The grievance system is also important for PH Trail to ensure they are accountable to complaints and that these complaints are handled transparently and efficiently. PAPs and other potential complainants should be fully informed of the GM, its functions, procedures, timelines and contact persons' information both verbally and through booklets and information brochures during consultations meetings and other stakeholder engagement activities. 6.1. Grievance Process The complaint, in order to be filed, should be related to the project components and/or to its implementation and management. The Monitoring, and Evaluation/ Environmental & Social Officer (M&E/ES Officer) will be assigned to follow up complaints related to the project. The grievance resolution process involves the following main steps: 6.1.1. Receipt of Grievances Anyone from the affected communities or anyone believing they are affected by the Project can submit a grievance: 23 PH Trail Project Stakeholder Engagement Plan • By completing a written grievance registration form that will be available - (i) at the PH Trail office in Beit Sahour. Grievance registration forms will be provided. The Project’s Monitoring & Evaluation/ Environmental & Social Officer (M&E/ ES officer) will review the received grievances and record them in a Grievance Register. • Submitting the complaint electronically via e-mail: complains@phtrail.org via the electronic grievance form: https://paltrail.org/complains. • Telephone and mobile numbers of the GM at PH Trail (+97022775045) and the M&E / ES Officer (to be available once hired); • Sending a written grievance to the fax number: +97022775045. Where possible it is desirable that complaints are submitted in writing by the complainant. Should the complainant not wish to comply with this request and submit the complaint verbally, then the complainant information and the details of the complaint should be entered into a GM log or register that will be maintained by the M&/ ES Officer. 6.1.2. Procedures for filing the complaints The complainant fills in the designated form in writing and signs it, or fills it electronically including all personal information and details of the complaint. The complainant encloses all copies of documents that may support the complaint. The GM staff at the PMU will ensure that the form is filled in accurately. The complainant receives a receipt or a confirmation email of acknowledgment with a reference number to track the complaint. If the complainant choses to file his/her complaint verbally, the M&E/ ES Office must register the complainant information and details of the complaint into the system. The complainant will receive a reference number to track his/her complaint. 6.1.3. Registering complaints The M&E/ES Officer will enter the complaint into the GM log. The complaints register records the following information: • Complaint Reference Number • Date of receipt of complaint • Name of complainant • Confirmation that a complaint is acknowledged • Brief description of Complaint • Details of internal and external communication • Action taken: (Including remedies / determinations / result) • Date of finalization of complaint Original documentation must be kept on file. 6.1.4. Referral and Examination of complaints The M&E/ES officer will inform the complainant that an investigation is underway within three (03) business days. The complainant shall be informed of the estimated duration for resolving the complaint, which is no later than ten (10) business days from the date of receipt of the complaint. Where the complaint is unlikely to be resolved within the estimated duration, the 24 PH Trail Project Stakeholder Engagement Plan M&E/ES officer must promptly contact the complainant to request additional time and explain the delay. In any event, the complaint must be resolved no later than two (02) weeks from the date of receipt of the complaint. If the complaint is not resolved, the M&E/ES officer will refer the complaint to the Director of the PMU to take the appropriate measures. The M&E officer will then follow the steps below: • Verify the validity of the information and documents enclosed. • Ask the complainant to provide further information if necessary. • Refer the complaint to the relevant department. • The M&E/ES Officer charges in the relevant department shall conduct field visits for verification, if necessary, and prepare recommendation to the PMU director of actions to be taken and of any corrective measures to avoid possible reoccurrence. • The M&E/ES Officer shall register the decision and actions taken in the GM log. 6.1.5. Notifying the complainant and closing the complaint Notifying the complainant The M&E/ ES Officer shall notify the complainant of the decision/solution/action immediately either in writing, or by calling or sending the complainant a text message. When providing a response to the complainant, the M&E/ ES Officer must include the following information: • A summary of issues raised in the initial complaint • Reason for the decision. Closing the complaint A complaint is closed in the following cases: • Where the decision/solution of complaint is accepted by the complainant, the M&E/ ES Officer shall close the complaint and sign outcome and date in the Complaint Register. • A Complaint that is not related to the project or any of its components. • A Complaint that is being heard by the judiciary. • A malicious complaint. 6.1.6. Additional Dispute Resolution Scheme Where the complainant is not satisfied with the outcome of his/her complaint, the following procedures shall be considered: Internal Dispute Resolution Scheme The M&E Officer shall advise the complainants that if they are not satisfied with the outcome of their complaint, they may readdress the issues with the director of PMU in Beit Sahour and request a further review or consideration. Where the complainants are not satisfied with the resolution provided by the director of PMU, the M&/ ES Officer shall advise the complainants to readdress the issue to the President of PH Trail. External Dispute Resolution Scheme 25 PH Trail Project Stakeholder Engagement Plan In case the complainants are not satisfied with the internal procedures for handling complaints, the outcomes of the complaints or for any unhandled complaints, the SO shall provide information on a complainant’s right to refer their complaint to the Ministry of Tourism and Antiquities, Complaints Unit at the Prime Minister Cabinet, or to the judicial system. 6.2. Feedback/grievance monitoring and recording The SO work regarding complaints resolution is regulated by the Council of Ministers Decision No. (8) of 2016 and by the Procedure Manual No. (20/17) of 2017. Both documents are made public and published in Arabic on the ministries’ websites. A detailed GM manual that includes guidelines on filing and handling complaints at the project’s level will be finalized with the support of the World Bank consultant. PH Trail will keep log for grievances and how complaints were resolved within a stipulated time frame and then produce monthly reports for senior management. Grievances/feedback reports include data on numbers of grievances/feedback received, compliance with business standards, issues raised in grievances/feedback, trends in grievances/feedback over time, the causes of grievances/feedback, whether remedial action was warranted, and what redress was provided. 6.3 Gender Based Violence Grievances The project’s M&E/ES OFFICER, in collaboration with the General Director will be responsible for handling complaints related to children, and women who may be exposed to violence, sexual exploitation and abuse and sexual harassment (SEA/SH). Telephone information line, email address and procedures will be communicated to beneficiaries during consultation and induction sessions. If GBV and SEA/SH-related incident occurs, it will be reported through the GM, as appropriate and keeping the complainant information confidential. Specifically, the GM will only record the following information related to the complaint: • The nature of the complaint (what the complainant says in her/his own words without direct questioning); • If, to the best of their knowledge, the perpetrator was associated with the project; and, • If possible, the age and gender of the complainant. The M&E OFFICER will be trained on detection of cases of gender- based violence and handling of inquiries, complaints and grievances related to GBV. The following sexual harassment and sexual exploitation and abuse grievance procedures, in line with the PHT internal regulations and Code of Conduct, will be followed: i. refer the victim to the Gender Specialist at PH Trail to provide support. In the case the survivor decides to seek justice the following procedures will be followed, after obtaining the survivors’ permission: 26 PH Trail Project Stakeholder Engagement Plan 1- The M&E/ES OFFICER will be assigned to receive and handle SEA/SH complaints. Telephone information line, email address and procedures will be communicated to beneficiaries during consultation and induction sessions. The telephone number can also be used by employees/workers to discuss questions or concerns about the harassment without having to express an identity. 2- Follow clear procedure for addressing the SEA/SH that will include the following steps: ii. private interview with the complainant and articulate the allegations in writing. iii. investigate the claim. Investigation can be done by a special committee for the prevention of sexual harassment. The committee should be gender balanced and could include a member of senior management and trained sexual harassment staff member. Investigation will be conducted in total confidentiality to prevent any humiliation of the complainant. iv. a finding is made as whether the complaint is substantiated v. a written report documenting the investigation process, evidence, findings, and recommended outcome(s) is submitted to the Higher management. vi. the higher management will implement the recommended outcome(s) or decide on an alternative course of action. vii. determine the forms of disciplinary action and sanction. Disciplinary and sanction should be included in the organization regulations and/or the labor agreement. 6.4. World Bank Grievance Redress System Communities and individuals who believe that they are adversely affected by a project supported by the World Bank may also complaint directly to the Bank through the Bank’s Grievance Redress Service (GRS) (http://projects-beta.worldbank.org/en/projects- operations/products-and-services/grievance-redress-service). A complaint can be submitted to the Bank GRS through the following channels: • By email: grievances@worldbank.org • By fax: +1.202.614.7313 • By mail: The World Bank, Grievance Redress Service, MSN MC10-1018, 1818 H Street Northwest, Washington, DC 20433, USA. 6.5. Grievance mechanism for workers The labor management procedures prepared for this project describes the details related to the complaints system that will be prepared by the project contract or to handle workers' grievances. PH Trailwill require contractors to develop and implement a grievance mechanism for their workforce including sub-contractors, prior to the start of any civil works or installation of equipment. PH Trail will also develop and implement a GM for its workers. The workers grievance mechanism will be described in staff induction trainings, which will be provided to all project workers. The workers grievance mechanism will include: • a procedure to receive grievances such as comment/complaint form, suggestion boxes, email, a telephone hotline; 27 PH Trail Project Stakeholder Engagement Plan • stipulated timeframes to respond to grievances; • a register to record and track the timely resolution of grievances; • an assigned staff to receive, record and track resolution of grievances. Information about the existence of the grievance mechanism will be readily available to all project workers (direct and contracted) through notice boards, the presence of “suggestion/complaint boxes�, and other means as needed. The SO will monitor the contractors’ recording and resolution of grievances, and report these to PH Trail in the monthly progress reports. 6.6. PH Trail Contact Information The point of contact regarding grievance management and the local stakeholder engagement activities is the General Director of the PMU at PH Trail: Description Contact details Agency: PH Trail To: Mr. George Rishmawi General Director, PH Trail E-mail: george@phtrail.org Website: http://paltrailorg Telephone: 0599180872 7. Monitoring and Reporting 7.1. Monitoring Reports 7.1.1. During the Implementation Monitoring reports documenting the social performance of the Project during the implementation will be prepared by the M&E OFFICER for submission to PH Trail and to the World Bank. These reports will include a section regarding stakeholder engagement and grievance management. Table7-1 proposes a comprehensive set of indicators related to SEP performance at this stage. Quarterly and Annual Reports by PH Trail During the Project implementation phase, the M&E Officer will prepare quarterly reports on social performance for PH Trail management; these reports will include an update on implementation of the stakeholder engagement plan and include indicators in Table 7-1. Monthly reports will be used to develop quarterly, and annual reports that will be reviewed by senior PH Trail managers. Six Monthly E&S Compliance Reports to the World Bank Six-monthly reports will be prepared and submitted to the World Bank during the implementation period. A section on stakeholder engagement will be included in these reports, which will include an update on implementation of the stakeholder engagement plan and include indicators in Table 7-1. 28 PH Trail Project Stakeholder Engagement Plan Table 7-1: SEP indicators to be documented in progress reports Engagement with PAPs Number and location of meetings with PAPs Number of men and women that attended each of the meetings above Number, location, attendance, and documentation of the meetings held with the municipalities and communities or other stakeholders Minutes of meetings will be annexed to the report. Summarizing the views and comments of attendees. Engagement with other stakeholders Number and nature of engagement activities with other stakeholders, disaggregated by category of stakeholder (Governmental departments, Academia, NGOs) Issues raised by NGOs and other stakeholders, actions agreed with them and status of those actions Minutes of meetings will be annexed to the six-monthly report Any updates of the SEP Grievance Redress Mechanism Number of grievances received, at PH Trail office, and on the website, disaggregated by complainant’s gender and means of receipt (telephone, email, discussion) Number of grievances received from affected people, external stakeholders Number of grievances that have been (i) filed, (ii) resolved, (iii) closed, and (iv) number of responses that satisfied the complainants, during the reporting period disaggregated by category of grievance, gender, age and location of complainant. Average time of complaint’s resolution process, disaggregated by gender and age of complainants and categories of complaints. Trends in time and comparison of number, categories, and location of complaints with previous reporting periods. Workers Grievances a procedure to receive grievances such as comment/complaint form, suggestion boxes, email, a telephone hotline stipulated timeframes to respond to grievances a register to record and track the timely resolution of grievances An anonymous feature that receives anonymous complaints and ensures privacy 7.1.2. During Operation Annual Reports by PH Trail At the end of each year of operation, the ESO will prepare an annual summary report on social performance for PH Trail management, which will include an update on implementation of the stakeholder engagement plan and include indicators in Table 7-1 above. 29 PH Trail Project Stakeholder Engagement Plan Six Monthly E&S Compliance Reports to the World Bank During the project lifetime, six-monthly and annual social compliance reports will be prepared and submitted to the World Bank. A section on stakeholder engagement will be included in these social compliance reports. In addition, PH Trail will prepare Incident Notifications for the World Bank, if and when required. 7.2. Involvement of stakeholders in monitoring activities The Project provides several opportunities to stakeholders, especially Project Affected Parties to monitor certain aspects of Project performance and provide feedback. GRM will allow PAPs to submit grievances and other types of feedback. Furthermore, frequent and regular community meetings and interactions with PH Trail staff, especially the M&E Officer, will allow PAPs and other local stakeholders to be heard and engaged. The client will also engage with direct stakeholders for household/beneficiary surveys. One survey will be conducted, at least, during the implementation and one survey during the evaluation stage to ensure achieving the Project’s objectives. 7.3. Reporting back to stakeholder groups Reporting to PAPs and other stakeholder groups will be ensured, primarily through public meetings in project-affected municipalities. Minutes of meetings will be shared during subsequent public meetings. Feedback received through the GRM will be responded to in writing and verbally, to the extent possible. SMSs and phone calls will be used to respond to stakeholders whose telephone numbers are available. Key Project updates will be posted on PH Trail’s website. Social media (primarily through the Ph Trail Facebook page) will also be used to report back to different stakeholders. Annexes Annex I: Technical Note: Public Consultations and Stakeholder Engagement in WB- supported operations when there are constraints on conducting public meetings 30 PH Trail Project Stakeholder Engagement Plan With the outbreak and spread of COVID-19, people have been advised, or may be mandated by national or local law, to exercise social distancing, and specifically to avoid public gatherings to prevent and reduce the risk of the virus transmission. Countries have taken various restrictive measures, some imposing strict restrictions on public gatherings, meetings and people’s movement, and others advising against public group events. At the same time, the general public has become increasingly aware and concerned about the risks of transmission, particularly through social interactions at large gatherings. These restrictions have implications for World Bank-supported operations. In particular, they will affect Bank requirements for public consultation and stakeholder engagement in projects, both under implementation and preparation. WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk communication package for healthcare facilities; (iv) Getting your workplace ready for COVID-19; and (v) a guide to preventing and addressing social stigma associated with COVID-19. All these documents are available on the WHO website through the following link: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance. This Note offers suggestions to World Bank task teams for advising counterpart agencies on managing public consultation and stakeholder engagement in their projects, with the recognition that the situation is developing rapidly and careful regard needs to be given to national requirements and any updated guidance issued by WHO. It is important that the alternative ways of managing consultation and stakeholder engagement discussed with clients are in accordance with the local applicable laws and policies, especially those related to media and communication. The suggestions set out below are subject to confirmation that they are in accordance with existing laws and regulations applying to the project. Investment projects under implementation. All projects under implementation are likely to have public consultation and stakeholder engagement activities planned and committed as part of project design. These activities may be described in different project documents and will involve a variety of stakeholders. Commonly planned avenues of such engagement are public hearings, community meetings, focus group discussions, field surveys and individual interviews. With growing concern about the risk of virus spread, there is an urgent need to adjust the approach and methodology for continuing stakeholder consultation and engagement. Taking into account the importance of confirming compliance with national law requirements, below are some suggestions for task teams’ consideration while advising their clients: Task teams will need to review their project, jointly with the PMUs, and should: Identify and review planned activities under the project requiring stakeholder engagement and public consultations. 31 PH Trail Project Stakeholder Engagement Plan • Assess the level of proposed direct engagement with stakeholders, including location and size of proposed gatherings, frequency of engagement, categories of stakeholders (international, national, local) etc. • Assess the level of risks of the virus transmission for these engagements, and how restrictions that are in effect in the country / project area would affect these engagements. • Identify project activities for which consultation/engagement is critical and cannot be postponed without having significant impact on project timelines • Assess the level of ICT penetration among key stakeholder groups, to identify the type of communication channels that can be effectively used in the project context. Based on the above, task teams should discuss and agree with PMUs the specific channels of communication that should be used while conducting stakeholder consultation and engagement activities. The following are some considerations while selecting channels of communication, in light of the current COVID-19 situation: • Avoid public gatherings (taking into account national restrictions), including public hearings, workshops, and community meetings. • If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings If not permitted, make all reasonable efforts to conduct meetings through available online channels, including webex, zoom and skype. • Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chatgroups appropriate for the purpose, based on the type and category of stakeholders. • Employ traditional channels of communications (TV, newspaper, radio, dedicated phone- lines, and mail) when stakeholders to do not have access to online channels or do not use them frequently. Traditional channels can also be highly effective in conveying relevant information to stakeholders and allow them to provide their feedback and suggestions. • Where direct engagement with project affected people or beneficiaries is necessary, identify channels for direct communication with each affected household via a context specific combination of email messages, mail, online platforms, dedicated phone lines with knowledgeable operators; • Each of the proposed channels of engagement should clearly specify how feedback and suggestions can be provided by stakeholders. • An appropriate approach to conducting stakeholder engagement can be developed in most contexts and situations. However, in situations where none of the above means of communication are considered adequate for required consultations with stakeholders, the team should discuss with the PMU whether the project activity can be rescheduled to a later time, when meaningful stakeholder engagement is possible. Where it is not possible to postpone the activity, the task team should consult with the OESRC to obtain advice and guidance. 32 PH Trail Project Stakeholder Engagement Plan Investment projects under preparation. Where projects are under preparation and stakeholder engagement is about to commence or is ongoing, such as in the project E&S planning process, stakeholder consultation and engagement activities should not be deferred, but rather designed to be fit for purpose to ensure effective and meaningful consultations to meet project and stakeholder needs. Some suggestions for advising clients on stakeholder engagement in such situations are given below. These suggestions are subject to the coronavirus situation in the country, and restrictions put in place by governments. The task team and the PMU should: • Review the country COVID-19 spread situation in the project area, and the restrictions put in place by the government to contain virus spread. • Review the draft Stakeholder Engagement Plan (SEP, if it exists) or other agreed stakeholder engagement arrangements, particularly the approach, methods and forms of engagement proposed, and assess the associated potential risks of virus transmission in conducting various engagement activities. • Be sure that all task team and PIU members articulate and express their understandings on social behavior and good hygiene practices, and that any stakeholder engagement events be preceded with the procedure of articulating such hygienic practices. • Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings, and minimize direct interaction between project agencies and beneficiaries / affected people. • If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings. If not permitted, make all reasonable efforts to conduct meetings through available online channels, including webex, zoom and skype meetings. • Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chatgroups appropriate for the purpose, based on the type and category of stakeholders. • Employ traditional channels of communications (TV, newspaper, radio, dedicated phone- lines, public announcements and mail) when stakeholders do not have access to online channels or do not use them frequently. Such channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions. • Employ online communication tools to design virtual workshops in situations where large meetings and workshops are essential, given the preparatory stage of the project. Webex, Skype, and in low ICT capacity situations, audio meetings, can be effective tools to design virtual workshops. The format of such workshops could include the following steps: o Virtual registration of participants: Participants can register online through a dedicated platform. o Distribution of workshop materials to participants, including agenda, project documents, presentations, questionnaires and discussion topics: These can be distributed online to participants. 33 PH Trail Project Stakeholder Engagement Plan o Review of distributed information materials: Participants are given a scheduled duration for this, prior to scheduling a discussion on the information provided. o Discussion, feedback collection and sharing: ✓ Participants can be organized and assigned to different topic groups, teams or virtual “tables� provided they agree to this. ✓ Group, team, and table discussions can be organized through available social media means, such as webex, skype or zoom, or through written feedback in the form of an electronic questionnaire or feedback forms that can be emailed back. o Conclusion and summary: The chair of the workshop will summarize the virtual workshop discussion, formulate conclusions, and share electronically with all participants. • In situations where online interaction is challenging, information can be disseminated through digital platform (where available) like Facebook, Twitter, WhatsApp groups, Project weblinks/ websites, and traditional means of communications (TV, newspaper, radio, phone calls and mails with clear description of mechanisms for providing feedback via mail and / or dedicated telephone lines. All channels of communication need to clearly specify how stakeholders can provide their feedback and suggestions. • Engagement with direct stakeholders for household surveys: There may be planning activities that require direct stakeholder engagement, particularly in the field. One example is resettlement planning where surveys need to be conducted to ascertain socioeconomic status of affected people, take inventory of their affected assets, and facilitate discussions related to relocation and livelihood planning (if related). Such survey activities require active participation of local stakeholders, particularly the potentially adversely affected communities. However, there may be situations involving indigenous communities, or other communities that may not have access to the digital platforms or means of communication, teams should develop specially tailored stakeholder engagement approaches that will be appropriate in the specific setting. The teams should reach out to the regional PMs for ENB and Social Development or to the ESSA for the respective region, in case they need additional support to develop such tailored approaches. • In situations where it is determined that meaningful consultations that are critical to the conduct of a specific project activity cannot be conducted in spite of all reasonable efforts on the part of the client supported by the Bank, the task team should discuss with the client whether the proposed project activities can be postponed by a few weeks in view of the virus spread risks. This would depend on the COVID-19 situation in the country, and the government policy requirements to contain the virus spread. Where it is not possible to postpone the activity (such as in the case of ongoing resettlement) or where the postponement is likely to be for more than a few weeks, the task team should consult with the OESRC to obtain advice and guidance. Annex II Minutes of Meeting of Public Consultation Meetings Date: 23/11/2020 34 PH Trail Project Stakeholder Engagement Plan Place: Virtual through Teams software Attendees: Ayat Dardaroun French speaking Trekking Guide/ Dura Abed Dababsa Trails Developer and Trekking Guide/ Hebron Ahlam Al Khatib Homestay and women center representative/ Qbeibe Ayat Mardawi Homestay owner/ Arraba Jameel Hamadeen Community coordinator, Trekking Guide and accommodation owner/ Sea Level Bedouin Community Kamal Jabareen Guesthouse Manager/ Dhaheriya Municipality Khaled Abu Hashim Council member/ Surra Village Council Lara Samara Engineer/ Battir Municipality Mesadah Muaddi Homestay owner/ Kufr Malek Muhammad Masalma Community Coordinator/ Beit Awwa Nadine Burbar Local Development Department/ Ramallah Municipality Nidal Rishmawi Trekking Guide/ Bethlehem Rabee Yasin Head of Tourism Committee/ Jenin Governorate Shorouk Manassra French speaking Trekking Guide/ Bani Naim Wiam Erikat Public Relation/ Jericho Municipality Zaid Azhari Trekking Guide and Trails Developer/PHT team Rasheed Daoud Community coordinator- Beit Duqqo PHT team: George Rishmawi General Director Samah Qumsieh Awad Executive Director Ghaida Rahil Program Manager Charlie Zeidan Field Project Officer The objective of the meeting: 1. Present the objectives and activities of the proposed WB project. 2. Share with the participants the concept of the Tourism Clusters through with the WB project activities will be implemented. 3. Receive feedback, comments , ideas of the participants. (Partners) General introduction: George welcomed the participants and informed them of the objectives of the meeting. He shared on his screen a presentation (attached) that introduced the project, its’ objectives and related activities. Ghaida highlighted the importance of creating the Tourism Clusters which should lead to better governance and ownership for the communities along the trail so as to collaborate together towards community-based tourism development. In addition, she 35 PH Trail Project Stakeholder Engagement Plan explained the types of grants included in the project: community grants, individual and firms grants (service providers) and asked the participants to share their needs which this project can address under the two types of grants . Open discussion: Then floor was opened for the participants comments/ feedback and ideas which were as follows: • Muhammad Masalma/ Beit Awwa- Community and cluster coordinator: ✓ The booking system application as an activity of the project is an excellent idea and tool to promote the trail within their communities and service providers. ✓ Community involvement in the planning and implementation, and the community needs assessment are the right way to restructure the trail. ✓ The only way to maintain the success is that the communities along the trail believe and adapt the idea of the trail. ✓ Public awareness of the trail should be regularly through implementing a promotional program where each week interview some key persons from each community to talk and promote for their historical and cultural stories and sites. ✓ Local authorities should be encouraged to invest in the trail, because the visitors on the trail will increase the local economic development. • Ayat Mardawi/ Arraba- Al Mardawi Homestay Owner: ✓ Through the project should be a part to support the homestays and guesthouses with maintenance. ✓ To focus on targeting the Palestinians live in the 48 borders to come and visit the trail and its communities. And create a promotional materials and channels for them. • Rabee Yasin/ Jenin Governorate- Head of Tourism Committee ✓ The trail should include all the cultural elements. He proposed to develop an agricultural guesthouse (Manateer). In addition to highlight all the Palestinian cultural and heritage products on the trail. ✓ Enhance the diversity of accommodation and experiences along the trail. ✓ To unite the Palestinian stories along the trail. • Abed Dababsa/ Hebron- Trails Developer and Trekking Guide: ✓ He confirmed the importance of creating the Tourism Clusters. ✓ To focus on the diversity of the tourism services, and to avoid the duplication of services within the same area. ✓ To focus on the cultural events and festivals in the different areas along the trail as a tool to attracts the visitors. ✓ To target the students of Hebron University coming from the 48 borders. • Ahlam Khatib/ Qbeibe- Homestay and women center representative: ✓ Tourism Clusters is a great idea to develop the community-based tourism. 36 PH Trail Project Stakeholder Engagement Plan ✓ There is a church in Qbeba where could be an attraction point to the visitors. And it could create some homestays around it. ✓ Guesthouses are needed to target university students at Qbeba. • Rashid Daoud- Community Coordinator Beit Duqqo ✓ He suggested to have a partnership agreement between PHT and MOE in implementing a program targeting the schools` students to increase their ownership to the trail and their lands. ✓ To add on the scholastic curriculum at schools some materials or/and a section related to the trails and community-based tourism. • Nidal Rishmawi/ Bethlehem- Trekking Guide: ✓ Recommended to develop promotional materials such as brochures in English for each community includes the main sites and stories to be distributed to the visitors. • Mesadah Muaddi/ Kufr Malek- Homestay owner: ✓ She suggested to create a tourism cluster includes Kufur Malek, Aqraba and Duma where they can implement some activities to preserve the heritage culture and generate income such as: hay processes training course. ✓ Organize a weekly trekking trips on PHT trail for youth centers, schools and universities’ students. • Khaled Abu Hashim/ Surra- Council member: ✓ The focus of the grants should be directed to the youth and women. ✓ Create committees of youth for the media and promotion on the community level. ✓ Empower the culture of hiking trail for the local communities. • Kamal Jabareen/Guesthouse Manager/ Dhaheriya Municipality ✓ Should be more attention for the quality development of the guest houses. ✓ To open channels with the Palestinian associations and stakeholders within the 48 borders. ✓ To develop short promotional videos targeting the guesthouses along the trail. ✓ At Dhaheriya city on the trail there is a big public park where could be used as gathering point for the visitors, and for the events. ✓ Each trekking tour guide should be skilled and trained well, and has enough information to present to the visitors. • Shorouk Manassra French speaking Trekking Guide/ Bani Naim ✓ PHT should increase the level of promotion and marketing for the trail locally, through conducting several lectures and seminars especially in the Palestinian universities. ✓ Organize hiking activities on the old and new segments of the trail targeting the local people to enhance their natural, historical and cultural knowledge. In addition, to empower the connection for the local people to their homeland. ✓ As a trekking guide presenting the PHT, we need to improve our skills and information through organizing several capacity buildings programs and field trainings on reading mapping and GPS as an example. ✓ Organize trainings with international trekking guides to exchange knowledge and skills. 37 PH Trail Project Stakeholder Engagement Plan Conclusion: George valued the great ideas and input provided, he mentioned that many of the ideas and suggestion is already being implemented through current projects or is planned/might be implemented in the upcoming project. One thing is that several ideas of what was mentioned are a perfect fit to be applied for though the WB project grants as well as grants for trainings. Ghaida mentioned that this meeting will not be the last one, this kind of meetings will be continued in order to be sure that partners will participate in all project stages, starting from the design, preparation, implementation, and evaluation to be sure that the project is addressing the communities/ partners needs to improve the community- based tourism in Palestine. The Presentation: Project Name Increased Economic Opportunities and Improved Livelihood for Fragile Communities along the Palestinian Heritage Trail in the West Bank and Gaza Project Objective The development objective of the project is to increase economic opportunities and improve livelihood for about 3,000 Palestinian individuals and firms, present in fragile communities along the Palestinian Heritage Trail, across all the West Bank, with a special focus on women and youth Mechanism for Implementing Project Activities Thursday, February 14th, 2019 All project activities will be implemented through the results of needsJericho DMO assessment meeting studies by tourism clusters. Cluster of “Kufr Malik, Moghair, Diuk, Auja, Jericho, Aqbet Jabr� PH trail team: Amira and Ghaida 38 the development of the local The project will enhance community through the implementation of the following two components: PH Trail Project Stakeholder Engagement Plan Attendees: 1. Sahar Othman Represent of Jericho Municipality 2. Ali Abu Kharbeesh Owner of homestay- Bedouin tent 3. Ameen Abu Alia Mayor of Mogheir Local council 4. Lubna Masaeed Head women of Auja WC 5. Nizar Halaqa Head women of Jericho WC 6. Messada Muadi Head women of Kufr Malik WC- and homestays owner 7. Shireen Beirat Member of Kufr Malik WC 8. Intesar Al Akhras Member of Aqbet Jabr WC The aim of the meeting: 1. To Present the new WB project 2. Share with them the clusters (DMOs) concept. 3. Share with them the clusters’ common needs. 4. Brain storm what kind of community driven grants they need. Major Outputs: • The participants showed an acceptance to work together in one cluster • The participants agreed on the common needs highlighted by PH trail • The participants started to think what kind of community activities / projects they can do to attract more visitors to their cluster ( Magheir to Jericho) and they came out with some ideas as follows : Jericho: 1. To include the traditional market to the city tour (located next to Jummeizeh tree) the infrastructure for this market is available and there is lightening in the place. 2. Cooperate with Abu Akram. A Bedouin tent/ new homestay near wad – alqelt 39 PH Trail Project Stakeholder Engagement Plan Moghaier: 1. Trees planting from the beginning of the segment to the end. (olive trees or oak trees,) 2. Garden park or a rest place with toilets / 2 acres are available owned by the local council. 3. Build an apartment for the women centre of Mogheir on an existing building. 4. Guide book and promotional materials- includes information about services in every community. Auja: 1. Cleaning of Ein Samia/ hygiene issue 2. To create alternative route which is safer during winter from Mogheir along the street of Ras 60 (a panorama view from Bisan to Dead sea) 3. Camping area / small tents in the desert. 4. To establish a new City tour to pass through (Haider well, Old houses, Bee Boxes) Kufr Malik: 1. To include the local community in participating in walks with internationals. 2. English and French language courses. 3. Camomile planting garden belongs to Kafr Malik women centre, and a drier machine for drying the camomile. 4. To create a booklet that contains maps with the original/old names of each area such as land, grottos and hills 5. Youth programs, and dabka. 6. Tours in the city of Kafr Malik. Aqbet Jabr: 1. To create a continuous bazar. 2. To create a touristic tent next to the mud house in order to make activities with tourists and for food serving. 40 PH Trail Project Stakeholder Engagement Plan Date: 20/2/2019 Burqin DMO meeting Cluster of “Rummana , Ti’innik ,Al ‘Araqa , Kafr Qud )� PH trail team: Amira and Ghaida Attendees: 1. Khaled Yahya Member of, Al ‘Araqa local council 2. Authman Arqawi Mayor of Al ‘Araqa local council 3. Yousf Arqawi Deputy of Mayor of Al ‘Araqa local council 4. Rami Naef Member of, Al ‘Araqa local council 5. Maha Khalf Owner of homestay/ Burqin 6. Nadia Ateq Member of Burqin municipality 7. Nada Al-Sayegh Owner of homestay/ Burqin 8. Nahd Sobeh Member of Burqin municipality 9. Ayman shalyesh Member of Burqin municipality 10.Abdallah Jarar Member of Kafr Qud local council 11.Shamkh Mahmoud Mayor of Kafr Qud local council 12.Mohammad Sobhi Mayor of Burqin municipality Major Outputs: • The participants showed an acceptance to work together in one cluster • The participants agreed on the common needs highlighted by PH Trail • The participants start to think what kind of community activities / projects they can do to attract more visitors to their cluster ( Rummana – Burqin ) and they came out of some ideas as follow: 1. Public park in Al ‘Araqa village 2. Highlight the historical places in clusters villages 41 PH Trail Project Stakeholder Engagement Plan 3. Central point in the segment – to monitor the hikers and safety 4. Intercommunity walks for schools 5. Hire an employee to work on the promotion of the segment and promote the community-based tourism in the cluster 6. Fam trips to the tour operators 7. Central point to sale the women products of these villages 8. Informational center. 9. Training for some youth to be as a local guide 10. Promotional festivals 11.Cultural Museum in one of the old building 12.Rest areas near wells and springs - Kafr Qud village 42 PH Trail Project Stakeholder Engagement Plan Date: 26 /2/2019 Ad-Dhahiriya DMO meeting Cluster of “Raboud ,Anab – Alkabeer, Al – Surra, Al ‘Alaqa at- Tahta , Al – Burj , Beit mersim “ PH Trail team: Ghaida and Steve (the volunteer) Name Representative 1. Sarhan Al Amre Al Burj Local Council 2. Yosra Ali Khalil Al’bar Adh-Dhahiriya 3. Eman Khalil Mahmoud Abo Al Shar’ Adh-Dhahiriya 4. Amal S’fra Adh-Dhahiriya 5. Najah Sammra Adh-Dhahiriya Ladies society 6. Yasmeen Jaber Adh-Dhahiriya Ladies society 7. Hiyam Loreyan Adh-Dhahiriya Ladies society 8. Majdoleen Tawareh Adh-Dhahiriya Ladies society 9. Sameera Al Kaseesa Adh-Dhahiriya Ladies society 10. Ebtehal Ekteet Raboud Women Center 11. Bayan Yaser Ekteet Raboud Women Center 12. Mariam Mahmad Harbeyat Raboud Cooperative Society 13. Ameena Ibrahim Abo Zene Raboud Women Center 14. Ibtisam Abd Al Hameed Raboud Women Center 15. Ahmad Kaseesa Adh-Dhahiriya municipality 16. Sameer Ahmad Shaker Al - Burj Village Council 17. Kalha Abd Al Hameed Adh-Dhahiriya Ladies club 18. Lina Abd Al Karm Rzkah Adh-Dhahiriya Ladies club 43 PH Trail Project Stakeholder Engagement Plan Major Outputs: • The participants showed an acceptance to work together in one cluster • The participants agreed on the common needs highlighted by PH trail • The participants start to think what kind of community activities / projects they can do to attract more visitors to their cluster (Alsra –Beit Merism) and they came out of some ideas as follow: • Need an expert to support them in identifying their needs • Public park in Beit Mersim • Rest areas along the Masar • Greening the old city of Raboud (plant a trees) • Rehabilitate one of the old houses of Raboud and do it as a rest area • Rehabilitate the castle of Aburj and do it also as a rest area • Donkey of horses’ tours • The clean-up activities in Raboud • Tourist train 44 PH Trail Project Stakeholder Engagement Plan 45 PH Trail Project Stakeholder Engagement Plan 46