Rural Electrification Project Stakeholder Engagement Plan Sebzor Hydropower Plant Associated 110kV transmission lines and substations MAY 2019 i Contents 1. Introduction ...................................................................................................................................... 4 1.1 Background ............................................................................................................................. 4 1.2 Objectives of Stakeholder Engagement Plan ......................................................................... 6 2. Project Summary .............................................................................................................................. 6 2.1 Sebzor hydropower plant ....................................................................................................... 6 2.2 18-kilometer 110kV transmission line from Sebzor to Khorog ............................................ 10 2.3 63-kilometer 110kV transmission line from Khorog to Qozideh .......................................... 12 3. Summary of Potential E&S Impacts ................................................................................................ 14 4. Regulatory Context ......................................................................................................................... 17 4.1 Tajikistan requirements for stakeholder engagement ......................................................... 17 4.2 World Bank requirements for stakeholder engagement ..................................................... 17 5. Summary of Stakeholder Engagement and Identification ............................................................. 19 5.1 Engagement with local stakeholders.................................................................................... 19 5.1.1 Scoping consultations during Sebzor HPP Feasibility Study .................................... 19 5.1.2 Local scoping consultations for the ‘international’ ESIAs for Sebzor HPP and Sebzor- Khorog transmission line ......................................................................................... 20 5.1.3 Local stakeholder consultations for the 63-kilometer Khorog-to-Qozideh transmission line...................................................................................................... 21 5.2 Consultations with institutional stakeholders ...................................................................... 22 6. Stakeholder Identification and Analysis ......................................................................................... 24 6.1 Project-affected persons ...................................................................................................... 24 6.1.1 People affected by land acquisition ........................................................................ 24 6.1.1. Other people residing in the project areas ............................................................. 25 6.1.2. Village representatives (Jamoats) ........................................................................... 25 6.2. Other interested parties ....................................................................................................... 25 6.2.1. Other interested parties - external.......................................................................... 25 6.2.2. Other interested parties – Internal ......................................................................... 25 6.3. Disadvantaged / Vulnerable individuals or groups .............................................................. 26 6.4. Summary of stakeholder interest in and influence over the project ................................... 27 7. Stakeholder Engagement Program ................................................................................................ 27 7.1 Engagement methods and tools........................................................................................... 27 7.1.1 Public/community meetings ................................................................................... 28 7.1.2 Mass/social media communication ......................................................................... 28 7.2 Planned stakeholder engagement activities ........................................................................ 37 7.2.1 Communication materials ....................................................................................... 37 7.1.1. Information Desks ................................................................................................... 37 7.1.2. Grievance redress mechanism ................................................................................ 37 7.1.3. Project tours ............................................................................................................ 42 7.1.4. Citizen/PAP perception survey ................................................................................ 42 7.1.5. Trainings and workshops ......................................................................................... 42 7.1.6. Vulnerable groups ................................................................................................... 42 Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations ii Contents (continued) 7.2. Disclosure of information and public consultations ............................................................. 42 7.3 Stakeholder Engagement during Project Implementation................................................... 47 7.4 Pamir Energy Point of Contact ............................................................................................. 47 8. Grievance Redress Mechanism ...................................................................................................... 48 8.1 Grievance resolution process ............................................................................................... 49 8.2 Grievance processing............................................................................................................ 52 8.3 Grievance Logs...................................................................................................................... 53 8.4 Monitoring and reporting on grievances.............................................................................. 54 8.5 Pamir Energy Point of Contact ............................................................................................. 54 8.6 World Bank Grievance Redress System ................................................................................ 54 Annex 1: Example Grievance Form ...................................................................................................... 56 Annex 2. Minutes of Consultation Meeting on Sebzor HPP and Sebzor-Khorog Transmission Line in Sebzor (Roshtqala District, GBAO).................................................................................................. 58 Annex 3. Minutes of Consultation Meeting on Khorog-Qozideh 110kV Transmission line in Andarob and Qozideh Villages (Ishkashim District, GBAO) ........................................................................... 63 Tables Table 1: Environmental and social documentation for TREP and associated projects.......................... 5 Table 2. Villages between Sebzor and Khorog ...................................................................................... 13 Table 3: Villages between Khorog & Qozideh crossed by the corridor ............................................... 13 Table 4: Scoping meetings with stakeholders in Rushan district in early 2019 ................................... 20 Table 5: Consultations in potentially affected villages between Khorog and Qozideh ....................... 21 Table 6: Scoping meetings with stakeholders in Dushanbe ................................................................ 22 Table 7: Scoping meetings with stakeholders in Khorog ..................................................................... 23 Table 8: Other interested parties - external ........................................................................................ 26 Table 9: Level of interest and influence over the project ................................................................... 27 Table 10: Generic Methods, Tools and Techniques for Stakeholder Engagement .............................. 29 Table 11: Planned stakeholder engagement activities by project phase ........................................... 38 Table 12. Public consultations on Sebzor HPP and associated transmission lines ............................... 43 Figures Figure 1: Location of Gorno-Badakhshan Autonomous Oblast and Khatlon Province .......................... 4 Figure 2: Location of proposed Sebzor HPP and associated 18 km and 63 km 110kV overhead .......... 8 Figure 3: Location of proposed Sebzor HPP and associated 18km transmission line from ................... 9 Figure 4. Corridor of 18km 110kV transmission line from Sebzor HPP to Khorog............................... 11 Figure 5. Examples of towers ............................................................................................................... 12 Figure 6: Villages crossed by the 63km transmission line.................................................................... 13 Figure 7. Early consultation meetings in 2016 ..................................................................................... 19 Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations iii Figures (continued) Figure 8. Meetings with local stakeholders in early 2019 ................................................................... 20 Figure 9. Consultations along 63km transmission line ........................................................................ 22 Figure 10. Disclosure consultation meeting in Sebzor .......................................................................... 45 Figure 11. Disclosure consultation meeting in Andarob ....................................................................... 46 Figure 12. Consultation meeting in Qozideh ........................................................................................ 46 Figure 13: Feedback and GRM Process ................................................................................................ 49 Figure 14: Typical grievance resolution process .................................................................................. 50 Acronyms and Abbreviations Acronym Description CLO Community Liaison Officer E&S Environmental & Social EMF Electromagnetic Field ESF Environmental and Social Framework ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan ESS Environmental and Social Standard of the 2018 World Bank ESF GBAO Gorno-Badakhshan Autonomous Region (VMKB in Tajik) GRC Grievance Resolution Committee (1 and 2) GRM Grievance Redress Mechanism HSE Health, and Safety, Social, and Environment kV Kilovolt masl Meters above sea level NGO Non-Governmental Organization PAP Project-Affected Person (or Project-Affected Party) RAP Resettlement Action Plan RPF Resettlement Policy Framework SEP Stakeholder Engagement Plan WB World Bank Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 4 1. Introduction 1.1 Background The World Bank is considering providing support to the Tajikistan Rural Electrification Project (TREP), whose purpose is to provide electricity access to selected settlements in Khatlon and Gorno- Badakhshan Autonomous Oblast (GBAO) regions of Tajikistan (Figure 1) and to improve the reliability of electricity supply in GBAO. The total value of the project is US$ 70.0 million, with US$ 20.0 million to be financed by the World Bank. TREP is part of the Risk Mitigation Regime (RMR) that is included in the upcoming World Bank Country Partner Framework for the Republic of Tajikistan for fiscal years 2019-2023. Figure 1: Location of Gorno-Badakhshan Autonomous Oblast and Khatlon Province The TREP is being prepared under the World Bank’s new Environment and Social Framework (ESF), which came into effect on October 1, 2018, replacing the Bank’s Environmental and Social Safeguard Policies. Under the ESF, projects such as TREP must comply with ten Environmental and Social Standards (ESS) in investment project lending financed by the Bank. TREP includes several components: • Construction and operation of a run-of-river 10.5-megawatt (MW) Sebzor hydropower plant (Sebzor HPP) on the Shokhdara River and an associated 6.6/35kiloVolt (kV) substation. • Construction and operation of a 63km 110kV transmission line between Khorog substation and a new 35/110kV substation near Qozideh. • Off-grid solutions for electrification of 105 villages located in GBAO and Khatlon, comprising provision of electricity services to target settlements through construction of small hydro (SHPP), solar and wind individual projects, and “last mile grid connections” Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 5 which will involve constructing short distances of low-voltage distribution lines to connect currently unelectrified settlements in GBAO and to the national grid. In addition to these projects that are part of the TREP, an associated 18km 110kV transmission line will carry power generated by the new Sebzor HPP to a new 110/35kV substation in Khorog. This component is being financed by the Swiss State Secretariat for Economic Affairs (SECO) and is included in the present Stakeholder Engagement Plan. The World Bank is also providing financing for environmental and social assessments and other planning documentation needed for these projects to meet the requirements of the World Bank’s ESF and other requirements related to environmental and social performance. The various assessments will include: • Environmental and social impact assessments. The Sebzor hydropower project, the associated 18km transmission line from Sebzor to Khorog, and the 63km transmission line from Khorog to Qozideh will each be assessed in an Environmental and Social Impact Assessment (ESIA). Final feasibility studies are in preparation, and the environmental and social impacts of the projects have previously been subject to a desktop environmental and social evaluation and a full feasibility study. The off-grid solutions projects will have preliminary assessments in Environmental and Social Management Frameworks (ESMFs) that will establish criteria for future evaluations of individual electrification projects. • Stakeholder Engagement Plans. Each project component will have a tailored program to engage affected people and other stakeholders, with this one Plan for Sebzor HPP and the associated 110kV 18km transmission line from Sebzor to Khorog and 63km Khorog- Qozideh transmission line, one Plan for the off-grid project in Khatlon, and a third Plan for the off-grid project in GBAO. • Resettlement Policy Frameworks. Each project component will require the temporary and permanent use of land that is currently allocated to other people and so will result in physical and/or economic displacement of some households. Each will require one or more separate Resettlement Action Plans in the future, but the principles and objectives of the program will be the same for all subprojects. For that reason, a single RPF has been prepared to cover all subprojects. This report presents the Stakeholder Engagement Plan (SEP) for the Sebzor HPP and the two associated 110kV transmission lines, one 18km from Sebzor to Khorog and another for 63km from Khorog to Qozideh (“the Project” or “the projects”). Documents required for each component are identified in Table 1: Environmental and social documentation for TREP and associated projects. Table 1: Environmental and social documentation for TREP and associated projects 18km Sebzor- 63km Khorog- Sebzor HPP & GBAO off-grid Khatlon last- to-Khorog to-Qozideh t- substation solutions mile solutions 110kV t-line line ESIA ✓ ✓ ✓ ESMF ✓ ✓ SEP ✓ ✓ ✓ Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 6 RPF ✓ ESIA: Environmental & Social Impact Assessment ESMF: Environmental and Social Management Framework SEP: Stakeholder Engagement Plan RPF: Resettlement Policy Framework ✓ indicates separate E&S document to be prepared to meet ESF and other applicable requirements ✓ identifies present document Pamir Energy will be responsible for all the project components except the Khatlon last-mile solutions. Pamir Energy was formed in 2002 by the Aga Khan Fund for Economic Development (AKFED) in partnership with the Government of Tajikistan and the International Finance Corporation. Under a public-private partnership agreement with the Government of Tajikistan, the company has assumed the operational management of all power generation, transmission and distribution facilities of the Gorno-Badakhshan Autonomous Oblast (GBAO) of Tajikistan. The Khatlon electrification projects will be implemented by Barqi Tojik, the state-owned company responsible for power generation and transmission in other provinces of Tajikistan. 1.2 Objectives of Stakeholder Engagement Plan The overall objective of this Stakeholder Engagement Plan (SEP) is to define a program for stakeholder engagement, including public information disclosure and consultation, throughout the construction and operation of the Project. The SEP highlights the way Pamir Energy will communicate with people and stakeholder groups who may be affected by or interested. The SEP includes a mechanism by which people can raise concerns, provide feedback, or make complaints about Pamir Energy, the contractors, and the Project itself or its components. While the projects will result in only a few instances of physical resettlement, and relatively limited permanent land acquisition, the involvement of the local population is essential to the success of the projects in order to ensure smooth collaboration between project staff and local communities and to minimize and mitigate environmental and social risks related to the projects. 2. Project Summary The proposed Project, comprising Sebzor HPP, the 18km 110kV Sebzor-to-Khorog power transmission line, and a 63km Khorog-to-Qozideh transmission line, is located in the southwestern part of GBAO, as shown on Figure 2: Location of proposed Sebzor HPP and associated 18 km and 63 km 110kV overhead. 2.1 Sebzor hydropower plant The Sebzor HPP is located on the right bank of the Shokhdara river about 20 kilometers southeast of Khorog). The powerhouse will be connected to a Pamir Energy substation in Khorog via the 18- kilometer 110 kV overhead transmission line that will run from the HPP to a new substation in Khorog (see Figure 3). Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 7 The proposed Sebzor HPP will have the following major components: • A small dam (also known as a weir) 70 meters across and five meters high, with three meters above the riverbed, near Barjingal village. • Small reservoir with maximum depth of three meters that extends about 700 meters upstream and covers an area of about five hectares • Water intake at the weir • Desilting/desanding chamber about 65 meters long and 16 meters wide • Penstock with two pipes, each one 1.2 meters in diameter, running for about 2.8 kilometres from the intake to the powerhouse. The penstock will run immediately beside the road for part of its length and through a tunnel for another part. • Powerhouse with three 3.5MW turbines and generators near Sebzor village • Tailrace will carry water from the powerhouse under the road and back to the river • Work camp and storage area will be located approximately halfway between Barjingal and Sebzor villages. This area will be used for construction workers accommodation and storage of construction materials and construction equipment. It will cover an area of 4- 5 hectares and include a number of workshops, warehouses, fabrication areas, sanitary facilities, worker accommodations, and associated facilities (sanitary, recreation, kitchen, etc.). The Sebzor HPP also comprises reconstruction and expansion of about three kilometers of paved road between Barjingal and Sebzor villages. The road is planned to be expanded from a width of 4-5 meters to 6.5-7 meters, with a new asphalt surface. In addition, the project includes construction of a new bridge across the Shokhdara river at the village of Sebzor. The bridge will be five meters wide and capable of serving cars and light trucks. Each of these projects will be completed by contractors and will employ up to 100 workers during a one-year construction period. Other key aspects of this subproject include the following: • Environmental flows. An “environmental” flow of at least 10 percent of the annual average, or 3m3/s, will be left in the river at all times. At maximum capacity, 10.5m 3/sec will be diverted through the penstock to the powerhouse. All river flows higher than 13.5 m3/sec will , which occurs over 50 percent of the time, will flow over the weir. When flows are lower than 13.5m3/s, the plant will generate less electricity, down to a flow of 4.75 m3/sec, when 3 m3/sec will pass over the weir as environmental flow and the remaining 1.75m3/sec will be diverted to the powerhouse. • Flooding. The Shokhdara River is subject to extreme floods in summer, and even to a Glacial Lake Outburst Flow should there be a breach in the earthen “dam” that holds back a glacial lake in the headwaters. In addition, a dike will be constructed on both riverbanks immediately upstream of the dam to ensure that annual floods do not reach the nearest houses. The weir is being designed to withstand a 1000-year flood (450 m3/sec), and will be 0.45 meters higher than the water level during this flood. Lowest flows are in winter, Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 8 Figure 2: Location of proposed Sebzor HPP and associated 18 km and 63 km 110kV overhead transmission lines, GBAO, Tajikistan Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 9 Figure 3: Location of proposed Sebzor HPP and associated 18km transmission line from Sebzor to Khorog project when discharge in the river ranges from 6 to 15 m3/sec. Highest flows are in summer, with the average peak of over 110m3/s. The average annual flow rate is about 24-30m3/s. • Earthquake/seismic activity. The dam is in an area considered to be at high risk of seismic activity (earthquake), up to about 6-7 on the Richter scale. Additional studies are needed to determine final design parameters to ensure the dam can withstand likely seismic activity. Given the low weir/dam and the relatively small reservoir, even complete failure Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 10 of the dam would have relatively minor downstream consequences, especially when compared to the annual flooding that occurs in summer. • Fish pass. The dam will be designed so that fish can move upstream and downstream via a fish passage. The fish passage will be about 2.5 meters wide and 44 meters long, and is being designed with a flow rate of 1.25m3/s, or about 40 percent of the environmental flow. The fish pass is being designed to accommodate False Osman (Schizopygopsis stoliczkai Steindachner) and Marinka (Schizothorax sp. (intermedius?)), which are the two fish species that migrate upstream and downstream and are caught by local fishers. The length of the construction period is anticipated to be between two and four years, depending on the length of the construction season, which typically extends from April through November but will depend on weather. An international consultant (SWECO) is currently in the process of finalizing the design for HPP, following which Pamir Energy will select construction contractors via open tender. There will be at least two main construction contractors, one for electromechanical works at the powerhouse and substation and one for civil works for the dam, penstock, and powerhouse. The civil works contractor will employ about 400 workers for the hydropower project and he electromechanical contractor about 20 workers, with many or most of those employed by the civil works contractor will come from local communities. Construction activities will involve earthworks, land clearance and leveling, drilling and possibly limited blasting, concrete works, welding works, transportation/storage of various pieces of equipment, and others. Construction will be supervised by a Supervision Consultant (also known as the Owner’s Engineer or Supervising Engineer) to be selected by Pamir Energy. In addition, contractors hired to construct the new bridge will employ about 20 workers and the contractor hired to reconstruct the road will employ about 30 workers. Many or most of these workers will be from local communities as well. The hydropower project could affect the people of five villages: Dashtak, Barjingal (location of weir), Chagev, Midensharv, and Sebzor (location of powerhouse). The total population of these villages is 1517. 2.2 18-kilometer 110kV transmission line from Sebzor to Khorog The proposed 18km transmission line will run from the new substation at Sebzor HPP to a planned 35kV/110kV substation in Khorog Figure 4, which will be located on the right bank of the Gunt river near the confluence of the Shohdara River and the Gunt River. This component of the Project includes construction of a 35kV/110kV substation in Khorog. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 11 Figure 4. Corridor of 18km 110kV transmission line from Sebzor HPP to Khorog There will be a total of 73 steel lattice towers of three types, with examples shown on Figure 5: • Four-legged steel lattice “angle” towers will be anchored in concrete foundations, with the base about 7.5 meters square (thus, corner foundations about 7.5 meters apart and a total “footprint” of 56.25 square meters) and adjustable heights ranging from 15 to 25 meters. • Smaller four-legged steel lattice “suspension” towers for straight sections will also be anchored in concrete foundations and will be slightly smaller than the angle towers. These will occupy an area of about 5 meters square (or 25 square meters) and be about the same height as the angle towers. • In areas where terrain does not allow four foundations for legs, three steel towers (poles) will each be anchored in concrete foundations and will be about 20 meters high. Each foundation will be 1.5 meters square and up to 5 meters apart, thus occupying an area of up to about 30 square meters). Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 12 Figure 5. Examples of towers: angle tower at left, three suspension poles on uneven terrain at top right, example of foundation at bottom right One or two local (i.e., from Tajikistan) contractors will be appointed to complete the construction. It is anticipated around 40 workers will be employed in construction, many or most of them from local communities. Construction activities, which are anticipated to last for two years (that is, two seven- month construction seasons, or as permitted by weather) will include earthworks, concrete works to install foundations for tower legs and poles, transportation/storage of various pieces of towers and insulators, and tower assembly (erecting) works. Other than drills and hand tools, little or no mechanized equipment will be used, as steel parts of the towers will be carried by hand from trucks to locations and assembled in place. When towers are in place, conductors (wires) will be placed on the towers and energized. A total of 29 villages with a total population of 9943 are located between the Sebzor HPP dam/weir and the Khorog substation and thus their populations may potentially be affected. Villages are identified in Table 2. 2.3 63-kilometer 110kV transmission line from Khorog to Qozideh The main purpose of the new 110km power transmission line from Khorog to Qozideh is to improve the reliability of electricity supply to Ishkashim District. In the future, it is foreseen the new line will provide electricity supply to neighboring regions of Afghanistan, but that is not part of the present project. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 13 Table 2. Villages between Sebzor and Khorog The new 110kV line will run through rough and rocky mountain terrain along the Tajik and Andarv Kurtsboghen Shikush Afghan state border parallel to and near the Barmev Lahshik Shod Panj River (also spelled “Pyanj” or “Pyandzh” in Bartavdem Langar Shosh (Tusyon) English). The line will begin at the new 35kV/110kV substation in the city of Khorog, Bodomi bolo Namadroj Shuvjev pass through Roshtqala district, and end in a Chagev Nuj Siyob new 110/35kV substation near the village of Qozideh in Ishkashim district (Figure 2 above Devloh Ridjak Sumjev and Error! Reference source not found.). The Khabost Rijist Tavdem line will pass through or near 13 villages Khichikh Rizef Zhirpor between Khorog and Qozideh. These villages have a total population of 5,633 persons (798 Khidorjev Sazd Zigur households). The villages are identified in Table Kulev Sebzor 3. The project is currently in advanced planning. Due to Table 3: Villages between Khorog deterioration of the existing 35kV line, the first 10-kilometer & Qozideh crossed by the corridor section of the line has already been constructed (a total of Viruthjak Andarob 37 towers), and another five towers in avalanche areas have Gozhak Dasht also been constructed, all financed by other donors. The World Bank financing will be used for construction of towers Pish Kuhi - La'l on the remaining 53km and the stringing of conductors Nishusp Sist (wires) on the towers that have already been constructed. Shichozg Vozg Barchidev Shanbedeh Khaskhorug Figure 6: Villages crossed by the 63km transmission line Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 14 There will be about 250 towers, of which 42 have already been constructed, as described above. The exact number of each type will be determined during final design, as will their locations. The towers will be the same three types as described for the Sebzor-to-Khorog transmission line and illustrated in Figure 5. The construction period will last for two or three years, depending on the length of the construction season, which normally extends from April through November. Towers will be provided by an international vendor, although it is likely they will ultimately be purchased and imported from China. One or two contractors, likely to be from Tajikistan, will be appointed to complete the construction. It is anticipated around 120 workers will be employed in construction, many or most of them from local communities. Construction activities for the transmission line will involve earthworks, including drilling and possibly limited blasting, concrete works to install foundations for tower legs and poles, transportation/storage of various pieces of towers and insulators, and tower assembly (erecting) works. When towers are in place, conductors (wires) will be placed on the towers and energized. For the substation, about 150 workers will be employed in earthworks, concrete works, and installation of electrical equipment. As noted, the transmission line corridor will run parallel to the Panj River. A two-lane road (designated as road RB 06(12R45)) also runs parallel to the river, and the existing 35kV line runs in part between the river and the road and in part inland of the road, sometimes several hundred meters higher than the road. One option considered by Pamir Energy is simply to place the new steel towers in the same locations as the existing wooden poles. However, the existing line passes near or through villages and would likely require some resettlement of households. Therefore, it is Pamir Energy’s intent that the new towers be placed so the corridor does not pass near any occupied houses or other buildings, and so that it avoids orchards and trees as much as possible. In addition, as noted for the 18km line between Sebzor and Khorog, Pamir Energy will require the contractor to use little or no mechanized equipment other than vehicles, rock drills, and hand tools. All materials, including concrete, water, steel parts of the towers, and other materials, will be carried by hand from trucks to the tower locations and the towers will be assembled in place. At present, the 42 new towers carry 35kV conductors (wires). When towers are in place, 110kV conductors (wires) will be placed on the towers and energized. 3. Summary of Potential E&S Impacts Potential environmental and social risks (E&S) and impacts as a result of the Project’s planning, construction and implementation have been examined and addressed in stand-alone Environmental and Social Impact Assessments (ESIAs) for each of the three projects. Key environmental and social considerations that were examined in both reports include: Environmental considerations: • Air quality could be affected by dust from movement of vehicles and equipment on unpaved roads and from earthworks and open piles of spoil, and vehicles and equipment powered by combustion engines would emit pollutants. Impacts would be temporary and with proper controls would be very minor and localized. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 15 • Water quality in the Shokhdara and Panj Rivers could be affected due to erosion from tower sites and from spills of fuel or other hazardous materials. Contractors will be required to prevent erosion and spills, so there should be limited or no impacts. There is a potential risk of negatively affecting fish migration in the Shokhdara River as a result of hydropower plant construction. This risk will be significantly reduced by embedding into the plant’s design a fish passage that will allow fish moving upstream for spawning. • Landscapes and views will be affected temporarily due to construction and maintenance activities and permanently by the presence of the hydropower plant civil structures, penstocks, substations and transmission towers and conductors. • Soil erosion could occur from run-off of rainfall and snowmelt if land clearing and construction activities are not managed properly. Contractors will be required to save topsoil and to prevent erosion. • Geomorphologic hazards. Portions of the two transmission line corridors lie within high- risk zones for avalanches, debris flow, rockfalls, and the entire Project is in a high-risk zone for earthquakes. Designs will take these risks into account so as to minimize the risk of damage to the line in future, and construction will take steps so as not to cause earth movement. The siting of Sebzor HPP and 18ine km transmission accounted for such risks, and the alternatives analysis provided the safest locations for the hydropower plant structures, work camp, storage yard and towers of the 18km line. On the 63km line, towers have been constructed In the areas of highest risk, and other towers in high-risk areas will have diversion structures placed slightly uphill to divert avalanches and mudflows. In addition, the dam and associated infrastructure is being designed to withstand an earthquake of the highest magnitude expected to occur within a 50-year period (9 on the Medvedev–Sponheuer–Karnik [MSK] scale and 7 on the Richter scale). • Plants and animals could be affected by disturbance during construction and by permanent use of their territories. Given the nature of the terrain, the small areas that will be affected, and the limited biodiversity, this will not be a significant issue. • Water quantity in three kilometers of the Shokhdara River between the dam and powerhouse could be adversely affected as a result of diversion of up to 10.5 cubic meters per second (m2/s). At minimum “environmental flow” of at least 3m3/s will pass over the dam at all times, even when flows are very low in winter. There is no irrigation or other known uses of water in this river reach, so there will be impact on local people. Worker health & Safety considerations: • Construction workers will be exposed to elevated risks that is inherent in construction works. These include the risks of working at height, on steep slopes, working around trucks and machinery, working with electricity, trips and falls, working with hazardous materials (paints and fuels), and traffic accidents. Contractors will be required to develop and implement occupational health and safety plans and to train all workers. Social and economic considerations: • Electromagnetic fields could cause health effects if workers or persons living in close proximity to the operating transmission lines were exposed to high levels for long periods Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 16 of time. However, levels will be very low, workers will only be exposed for short periods, and no one will live near the line, so there will be no health effects. • Physical or economic displacement could occur if houses or valuable property are located within a 45-meter protection zone under the line (20 meters from each conductor and 5 meters between conductors). It is Pamir Energy’s intent to locate the substations and towers so no houses or other buildings are in the protection zone, and so the corridor will avoid agricultural and other valuable land as much as possible. Sebzor HPP selected the alternative configuration that required the least resettlement of households. If towers are located on agricultural land, those who currently use the land will be compensated for the land taken. As noted above, only small areas will need to be taken for towers. As for land under the line between the towers, agriculture and grazing will not be affected, except that tall equipment cannot be used and no buildings will be allowed in the protection zone. If that requires a change in land use, Pamir Energy will provide compensation. In addition, tall trees (those over 4 meters high) will need to be cut back to maintain at least a 6-meter clearance from the wires. Those who own or use trees will be compensated in such cases. Small amounts of land will be used for footpaths for workers to travel between the road and tower locations and possibly for equipment storage. Pamir Energy will compensate those whose land is used in this way. Also, if property or crops are damaged during construction or maintenance operations, or animals are injured or killed, their owners will be compensated at replacement value. Compensation requirements are set forth in a Resettlement Policy Framework that has been developed by Pamir Energy and in one or more future Resettlement Action Plans that will be developed by Pamir Energy and approved by the World Bank and the Government of Tajikistan. • An influx of workers from outside the region could disturb local communities with disruptive behavior, use of local resources such as hospitals and schools, and introduction of disease. There will be relatively few outside workers, probably less than half of all workers, and all workers will be subject to a strict Code of Conduct, so there should be very little or no impact. • Traffic accidents and inconvenience could be caused by increased project traffic on the two-lane roads between Barjingal to Sebzor, Sebzor to Khorog, and from Khorog to Qozideh. The contractor will be required to develop and implement traffic management plans to minimize impacts and to repair any damage to the road that construction may cause. • Local employment and income will be increased for up to three years due to seasonal employment of several hundred workers from local communities. • Power supply of GBAO will be improved by constructing Sebzor hydropower plant and the new 18km transmission line. The 63km power transmission line project will improve reliability of the electricity supply to Ishkashim district by replacement of the existing 35km line, and ultimately Afghanistan villages will benefit from electrification. The increased power supply and increased reliability will contribute to future development of the region. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 17 4. Regulatory Context 4.1 Tajikistan requirements for stakeholder engagement Public participation in decisionmaking, which follows from the legislation of the Republic of Tajikistan and obligations under international agreements, is a new phenomenon in Tajikistan that requires the necessary legal regulation. The tradition of closed or limited information about decisions that affect the state of the environment have left a definite imprint on the attitude of society to environmental issues. More than twenty years ago, public participation in the decision-making process was difficult even to imagine. Now, there are a number of environmental and other requirements and acts that to some extent regulate public participation in the EIA process in Tajikistan. These acts include: • The Environmental Protection Law establishes the right of citizens to live in a favorable environment and to be protected from negative environmental impacts (Article 12). Citizens also have the right to environmental information (Article 13) as well as to participate in developing, adopting, and implementing decisions related to environmental impacts (Article 13). The latter is assured by public discussion of drafts of environmentally important decisions and public ecological reviews. Public representative bodies have an obligation to take into consideration citizens’ comments and suggestions. • The Law on Environmental Expertise (art. 7) also provides the rights to citizens to conduct a Public Environmental Expertise (that is, a public environmental review). This law also empowers local authorities to facilitate public hearings, questionnaires, and referendums regarding planned activities that are subject to ecological expertise. On 17 July 2001, Tajikistan acceded to the 1998 Aarhus Convention, the provisions of which have priority over domestic law that stipulates the rights for Public Environmental Expertise. The element of public participation in the EIA procedure is described in detail in the Procedure (Order) for Conducting an EIA of 2018. Public participation procedures are envisaged for all categories of projects, although in practice they are mainly applied to major projects. The Procedure (Order) for Conducting the EIA of 2014 changed the focus and timing of public discussions, as the previous version (2006) provided for the participation of the public at an early stage of the process (i.e., after submitting a draft declaration of intent to the competent environmental authority) and it was indicated that comments and suggestions from the public be taken into account in drafting the technical task for carrying out the EIA. In fact, this ensured the participation of the public at the stage of defining the range of EIA tasks (scoping). The Procedure for Conducting the EIA of 2018 assumes public discussions only after the preparation of the EIA report by the project developer. 4.2 World Bank requirements for stakeholder engagement The World Bank’s Environmental and Social Framework (ESF) came into effect on October 1, 2018. The Framework includes Environmental and Social Standard (ESS) 10, “Stakeholder Engagement and Information Disclosure”, which recognizes “the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice”. ESS10 emphasizes that effective stakeholder engagement can significantly improve the Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 18 environmental and social sustainability of projects, enhance project acceptance, and make a significant contribution to successful project design and implementation. As defined by the 2018 ESF and ESS10, stakeholder engagement is an inclusive process conducted throughout the project life cycle. Where properly designed and implemented, it supports the development of strong, constructive and responsive relationships that are important for successful management of a project’s environmental and social risks. It emphasizes the importance of initiating stakeholder engagement at an early stage of the project development process, as a part of the assessment, management and monitoring of environmental and social impacts. Key requirements of ESS10 include: • “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. • “Borrowers will engage in meaningful consultations with all stakeholders. Borrowers 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 Borrower 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.” Borrowers are required to develop a Stakeholder Engagement Plan (SEP) proportionate to the nature and scale of the project and its potential risks and impacts (paragraph 13). Stakeholders have to be identified and the SEP has to be disclosed for public review and comment as early as possible, before the project is appraised by the World Bank. ESS10 also requires the development and implementation of a grievance redress mechanism that allows project-affected parties and others to raise concerns and provide feedback related to the environmental and social performance of the project and to have those concerns addressed in a timely manner. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 19 5. Summary of Stakeholder Engagement and Identification 5.1 Engagement with local stakeholders 5.1.1 Scoping consultations during Sebzor HPP Feasibility Study In 2016, as part of the Feasibility Study of the Sebzor HPP project, Pamir Energy engaged stakeholders in scoping consultations. The consultation and meetings took place in the following towns and villages and with the following key people (see Figure 7): • Roshtqala (Mr. Yusof Soltonnoyobov, administrative head of the Roshtqala District.) • Barjingal (Mr. Kshkorbekov Kshkorbek (KK) is member of the community council) • Sebzor (The village headman, Sultonnazar Shodoroev) Figure 7. Early consultation meetings in 2016 Project information was disclosed to all persons interviewed and the interviewees were asked to express their attitude about the project, as well as to highlight specific social, economic and environmental problems and considerations in the district and communities around. Overall, interviewed persons expressed support for the proposed project due to high potential social and economic value of the project implementation. Interviewed persons indicated a significance of this project for the regional economy and local communities. Everyone noted that unemployment is a very big issue across the district and the region overall. The Sebzor village head express a hope that local residents will get a chance for work opportunities with Pamir Energy during the project construction phase. In late 2016, Pamir Energy’s consultant, SWECO, produced a Stakeholder Engagement Plan (SEP) that was adopted and implemented by Pamir Energy as the project moved forward. As part of implementation of the SEP, during May-October 2016, Pamir Energy held meetings attended by a total of 135 stakeholders in four communities located in Roshtkala district and within the project area of influence (or potentially affected area). The communities included Barjingal, Dashtak, Mirsaid and Mirshakar. Pamir Energy disclosed project information to the public, including the duration of proposed project activities as well as potential E&S impacts that could result from project construction and operation. The local communities were also provided with information on the possible relocation of households that are located within the area of the proposed Sebzor HPP. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 20 Overall, the local residents once again confirmed their support for the construction of the hydroelectric power station on and near their territory and the heads of households that were located very close to the proposed project agreed that their households could be relocated should that be necessary. A working group (committee) was established among local residents in order to provide support and be in frequent communication with Pamir Energy regarding the relocation and compensation aspects. Some photographs from the 2016 consultations are shown below: Later, upon the completion of these early consultations, Pamir Energy produced a Resettlement Action Plan (RAP), which was then further disclosed and consulted with stakeholders and the affected public. This RAP was never implemented, but served as the basis for the present Resettlement Policy Framework. 5.1.2 Local scoping consultations for the ‘international’ ESIAs for Sebzor HPP and Sebzor-Khorog transmission line In early 2019, prior to and during the preparation of this SEP, Pamir Energy conducted interviews with community members in Khorog and at three villages in Rushan district. The main topic of the community meetings was been to share information, communicate with the local population and identify their needs and interests. Table 4 below provides a list of selected stakeholders who were contacted and interviewed in Rushan district and Figure 8 shows informal consultations in two local communities. Table 4: Scoping meetings with stakeholders in Rushan district in early 2019 Full name Location Affiliation and position Surobov Shams Rushan district Head of Askar Zamirov’s community Muzofirbekov Iqbolkhon Qozideh, Rushan district Head of the Community Saidbekov Sh Gh.Shohbozov’s community, Rushan Head of Gh.Shohbozov’s community district Oshurov Amonbek Rushan district Teacher, School # 26 Ramatulloev Mavlodod Rushan District Works at AKAH Figure 8. Meetings with local stakeholders in early 2019 Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 21 All community members who were interviewed expressed positive opinions about the proposed Sebzor HPP and transmission line construction project. All respondents support the Rural Electrification Project due to its high social and economic value to local communities. Everyone interviewed had knowledge of Pamir Energy and its activities. Nearly everyone noted that the most significant social and economic problems in the region are high unemployment rates and low income. A number of stakeholders interviewed specified that the best communication method with village residents and community members would be through Pamir Energy electricity inspectors, who they see on a regular basis (once a week or so) when inspectors visit households to read electricity consumption meters. Every interviewee expressed interest in participating in further meetings, consultations, and public hearings for the proposed project. 5.1.3 Local stakeholder consultations for the 63-kilometer Khorog-to-Qozideh transmission line Prior and during the preparation of this SEP and the “international” ESIA for the 63km transmission line, Pamir Energy conducted interviews with community members in Khorog and in three villages between Khorog and Qozideh (out of the 13 potentially project-affected communities). The primary purpose of the community meetings was to share information, communicate with the local population, and identify their needs and interests. Table 5 identifies project stakeholders who were consulted in early 2019 and Figure 9 shows one of the groups met. Table 5: Consultations in potentially affected villages between Khorog and Qozideh Full name Location Date of Birth Affiliation Ismoilova Oistamokh (f) Vogz village, Qozideh Jamoat, 12/03/1943 Head of community. Ishkashim district Pensioner Muzofirbov Mavlonzar (m) 01/01/1952 Teacher at school. Pensioner Miravazahonov Shahboh (m) Shandebeh village, Ishkashim 15/05/1947 Engineer. Pensioner Muborakshoeva Bibisulton (f) district 29/11/1949 Dressmaker. Pensioner Ismoilbekov Maram (m) Qozideh village, Ishkashim district 11/09/1947 Worker Asadulaev Rachab (m) Qozideh village, Ishkashim district 08.08.1944 Teacher Abduraimov Abduraim (m) Village Sist, Qozideh, Ishkashim 27.09.1950 Pensioner district Davlatov Okimbek (m) Village Sist, Qozideh, Ishkashim 25.12.1951 Security guard. district Odinaeva Asparmo (f) Nishusp village 19.03.1955 Pensioner Manasurova Olabegim (m) Nishusp village 16.08.1941 Pensioner. Former farmer Inronbekov Sjodmon (m) Pish village 17/03/1950 Construction worker Mirzoeva Soadat Pish village 24/08/1953 Accountant All people who were consulted expressed positive opinions about the proposed transmission line and about the larger World Bank Rural Electrification Project. As with Sebzor HPP and the 18km transmission line, everyone interviewed had knowledge of Pamir Energy and its activities. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 22 Concerns were similar as well: high unemployment and low incomes. They also agreed that the best method of communication would be through Pamir Energy electricity inspectors. Everyone also expressed interest in participating in further meetings and consultations. 5.2 Consultations with institutional stakeholders During the period of February 18 – March 10, 2019, Pamir Energy organized and carried out a series of scoping meetings and consultations with institutional stakeholders1. The consultation process involved identification of key project stakeholders in Dushanbe and GBAO, meetings with state and local authorities in Dushanbe and Khorog (Houkumat, Jamoat), meetings with regional NGOs and academic research institutes and universities in Dushanbe and Khorog (e.g., University of Central Asia and Pamir Biological Institute in Khorog). The main objectives of scoping consultations included: Figure 9. Consultations along 63km transmission line • To identify and verify interests of project stakeholders and to establish working dialogues between Pamir Energy and the stakeholders • To disclose information about the project • To understand stakeholders’ expectations about the project and their respective levels of interest in continued communication and participation in future Pamir Energy activities associated with the proposed project. • To receive feedback, comments, and concerns from stakeholders about the project and on prospective regional electricity supply schemes in general • To obtain feedback on major environmental, social and economic problems in Roshtkala and Ishkashim districts and overall across GBAO. Table 6 and Table 7 identify key project stakeholders who were consulted in February and March 2019. Table 6: Scoping meetings with stakeholders in Dushanbe Date Name of Unit Position Full name 21 February Renewable Energy Center Director Kabutov Kurbondjon 21 February Physics and Mathematics Institute Deputy Head of Boturov Kodir of the Academy of Sciences of the Department Republic of Tajikistan 21 February BARS Consulting Founder Alikhon Latifi 1 Consultations and discussions dealt with the World Bank’s full Tajikistan Rural Electrification Project, which includes the Sebzor hydropower plant, both transmission lines, all substations, and the off-grid and last-mile connections in GBAO and Khatlon. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 23 Date Name of Unit Position Full name 23 Fevruary Tajik Technical University, Senior lecturer Bahdavlatov department «Communication Asratbek networks and switching systems» 24 February NGO «Civil society and Director Alidodov T. environment» 25 February NGO Peshsaf Director Ruslan Shukurov 25 February Office of Youth Ecological Center Director Yuri Skochilov 25 February Tajik Technical University Senior lecturer Ganiev Zokirjon 25 February Ministry of Health and social Head of the Department Kandakov Ahliddin protection of Management and Food Safety, State Sanitary- Epidemiological Service Management and the Ministry of Health and Social Protection 25 February Committee on environment Head of international Salimov Muzaffar protection under the Government affairs sector of Tajikistan 26 February Ministry of Energy and water Head of Investment Manuchehr resources Department Safarzoda 26 February Barqi Tojik Chief Engineer Rahmatov Bakhtiyor 26 February Ministry of Energy and Water Head of Department for Tilloev Vays Resources Analysis and Monitoring of the Electric Power Industry Directorate, Ministry of Energy and Industry of Tajikistan Table 7: Scoping meetings with stakeholders in Khorog Date Name of Unit Position Name 25 February Government The Governor Yodgor Fayzov Committee of Head of committee Mulkamon Nazaraliev Environmental protection Inspection Department of Head of department Aynulloev Shirin Environment Protection Control 26 February University of Central Asia – Professor Royce Slydly Environmental Department Research fellow Shodigul Mamadyorbekova Forest Protection Department Engineer Kambarov Hokim Forestry officer Kosumbekov Khushvaqt Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 24 Date Name of Unit Position Name Association of Entrepreneurs Chairman\Director Boymamad Alibakhshov and Mountain Farmers «Milal- Inter»/Aarhus Center 27 February CAMP ‘Tabiat’, Forest Field coordinator Haqrizo Nurmamadov Protection Department Specialist Abdulmajidov Abdulaziz 28 February Pamir Biological Institute Former Director Dovutsho Navruzshoev Ornithologist A.G. Abdulnazarov 6. Stakeholder Identification and Analysis 6.1 Project-affected persons 6.1.1 People affected by land acquisition Perhaps the key category of people who may be affected by the project would be those who may lose land they current use or other assets, including houses, buildings, trees, or other valuable property. In addition, some people may lose access to common resources due to the project’s use of the land. The hydropower project will require a total of about five hectares, including about 2.1 hectares for the weir and associated structures (intake, desilting chamber, etc.), 0.6 hectares for the penstock, 0.5 hectares for the road expansion/rehabilitation, 0.3 hectares for the powerhouse area, 0.9 hectares for the Pamir Energy crushing plant, and 0.5 hectares for the camp/storage area. In addition, the substation will require about 0.6 hectares. A total of seven households will need to be relocated, as they currently live on land that is needed for the dam, penstock, and powerhouse. In addition, the project will directly affect 0.7 hectares of orchards and 0,4 hectares of other trees that may require cutting (depending on tree height and conductor clearance). Pamir Energy has been allocated 32 hectares, and excess land will be returned for reallocation to its original users. It is expected that seven households are on land required for the Sebzor HPP and so will be required to move to other land. As specified in the Resettlement Policy Framework, these households will be provided equivalent land and Pamir Energy will either build equivalent houses or compensate the households, with the aim of having at least the same standard of living as before. Less than seven hectares will be needed for permanent use by the 18km Sebzor-to-Khorog transmission line, including about 0.4 hectares for permanent use (73 towers x 56.25m 2 per tower) and six hectares for the substation in Khorog. In addition, very small amounts of land will be used temporarily by workers who travel by foot from the road to the tower locations and the contractor will need small areas (up to about 0.5 hectares in total) for storage and temporary use during construction. The 63km transmission line between Khorog and Qozideh will require less than two hectares of land for permanent use, including up to about 1.4 hectares for the transmission line towers (250 towers x 56.5m2 per tower) and less than 0.4 hectares for the substation in Qozideh (60 meters x 60 meters). There will be similar restrictions on 292.95 hectares (63km x 46.5m) along the corridor. Again, paths to towers will be used by workers and small areas will be needed by the contractors for storage and preparation. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 25 Tajikistan norms allow no buildings within 20 meters of an energized 110kV line, so a corridor 45 meters wide is designated as a protection zone – 20 meters from the conductor on each side and five meters between the conductors. No one will be allowed to remain in a house within the safety zone. As noted, there will be restrictions on the corridor, but they are expected to have little effect in practice. The restrictions will affect a total of 83.7 hectares along the 18km corridor and 292.95 hectares along the 63km corridor. These restrictions will prevent future buildings from being built and tall equipment from being used in the corridor. In practice, agriculture and grazing can continue within the corridor with no interruption. When towers are on agricultural or other productive land, Pamir Energy will compensate the people who are currently using the small plots of land that will be taken for towers. If trees grown for timber, firewood, or fruit/nuts need to be cut to avoid interference with the energized conductors, their owners will be compensated sufficiently to pay for replacement trees and for lost production. All land acquisition and compensation will meet the requirements of Tajikistan law and the World Bank. The resettlement and compensation program is described in detail in the Resettlement Policy Framework. People owning or using land in the corridor will thus be a high-priority stakeholder group who will require active and regular engagement as well as being provided accurate information, in particular about compensation and livelihood restoration schemes and employment opportunities. 6.1.1. Other people residing in the project areas A second key category of PAPs will be people who live along the transmission line route who may be disturbed by project traffic, noise, dust, or other construction impacts, and who may also benefit from employment opportunities. As noted in the respective ESIAs, contractors will be required to control dust, noise, and nuisances and also to require workers to adhere to a Code of Conduct to avoid disruption of communities. 6.1.2. Village representatives (Jamoats) A third category of important PAPs will be representatives of Jamoats. Head of Jamoats typically have established day-to-day communication lines with all neighboring villages and smaller communities so it will be important that they have information about the project, including employment status and upcoming activities. 6.2. Other interested parties 6.2.1. Other interested parties - external Table 8 summarizes the key categories of other interested parties and their potential interest in the project. 6.2.2. Other interested parties – Internal Internal interested parties with stakes in the project include the management and staff of Pamir Energy, their future contractors and subcontractors, service providers, local vendors, and suppliers. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 26 Table 8: Other interested parties - external Other interested parties Interest in the project Ministries and Government agencies Overall: To ensure project compliance with Tajik legislation (State level) (e.g. energy policies, environmental performance) during ‒ Committee on environment construction and operation protection under the Government of ‒ Responsible for protected areas and proposed protected Tajikistan areas that are or may be created in the vicinity of the project ‒ Ministry of Energy and water ‒ Promote Tajik energy security and development resources ‒ Possible involvement in some project-related mitigation measures Local (region and district scale) ‒ Protect the rights of inhabitants in the project area government departments and villages ‒ Represent local communities and PAPs (Jamoats) ‒ Receive and address any feedback and grievances from them ‒ Responsible for land allotments and compensation under Tajik law Nongovernmental organizations (local, Monitor project performance in areas of their respective regional, national, international) concerns Consult with Pamir Energy and governments as needed Business and workers’ organizations Interest in procurement and supply chain, potential environmental and social impacts as well as community health and safety Other project developers reliant on or in May require operation of the project to enable the export of the vicinity of the project (e.g. associated power facilities) and their financiers (e.g. ADB, Can help Identify interactions and cumulative impacts with EBRD, KfW, IFC) other proposed developments Press and media Inform people and authorities in the project area and the wider public about project implementation and planned activities General public, tourists, jobseekers Interest in the general socioeconomic impacts of the project, both adverse and beneficial Academic institutions (universities, think ‒ Potential concerns regarding environmental and social tanks, schools) impacts ‒ Potential educational/outreach opportunities to increase awareness and acceptance of the project 6.3. Disadvantaged / Vulnerable individuals or groups Disadvantaged or vulnerable individuals or groups are those who may potentially be disproportionally affected by the project and/or less able to benefit from opportunities offered by the project due to specific difficulties to access and/or understand information about the project. For purposes of this project, the following people and households are considered vulnerable: • Households headed by women, including those whose husbands or partners are working abroad and do not make significant contributions to the household’s income or welfare • Elderly households (headed by pensioners or elderly people) • Households with disabled persons Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 27 • Households in extreme poverty. There is no threshold for poverty in Tajikistan, so this will be determined on a case-by-case basis during studies conducted as part of the Resettlement program. As described in the Resettlement Policy Framework, vulnerable people and households will be eligible for special allowances and compensation. 6.4. Summary of stakeholder interest in and influence over the project Table 9 summarizes the level of interest in and potential influence over the project of the various stakeholder categories identified above. Categories having “high level of interest” and “high ability to influence/impact the project” will require regular and frequent engagement, typically face-to-face and written, and at least several times per year. Categories with medium interest or medium influence will require regular engagement (e.g., twice a year), typically through written information. Other will require infrequent engagement (e.g., once a year), typically through indirect written information (e.g. mass media) Table 9: Level of interest and influence over the project Level of interest in Ability or likelihood to influence or impact the project project High Medium Low High ‒ State Ministries, ‒ Regional government Committees and (Khoukumat in Government Agencies Khorog) ‒ Project-affected ‒ Regional Government persons (Committees) ‒ Jamoats and villages ‒ Other people residing in project areas Medium ‒ NGOs Businesses and workers’ ‒ Academic institutions ‒ Press and media organizations ‒ General public, tourists, jobseekers Low Other project developers and donors 7. Stakeholder Engagement Program 7.1 Engagement methods and tools Various methods of engagement will be used as part of the projects’ interactions with stakeholders in order to ensure that different stakeholder groups are successfully reached and are involved in the process of consultation, decision-making and the development of impact management solutions. International standards increasingly emphasize the importance of a consultation being “free, prior and informed”, which implies an accessible and unconstrained process that is accompanied by the timely provision of relevant and understandable information. In order to fulfil this requirement, a range of consultation methods are applied that specifically focus on this approach. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 28 Information that is communicated in advance of public consultations primarily includes an announcement thereof in the public media – local, regional and national, as well as the distribution of invitations and full details of the forthcoming meeting well in advance, including the agenda. It is crucial that this information is widely available, readily accessible, clearly outlined, and reaches all areas and segments of the target community. Descriptions of the generic engagement methods and techniques that may be engaged and applied by Pamir Energy is provided in Table 10 below. The summary presents a variety of approaches to facilitate the processes of information provision, information feedback as well as participation and consultation. 7.1.1 Public/community meetings Prior to other activities, at the time of disclosure of the Environmental and Social Impact Assessments (ESIAs), Resettlement Policy Framework, and this SEP, Pamir Energy will organize public meetings in Khorog and in each of the Jamoats. With the support of Jamoat leaders, another meeting will be held in each village and Khorog at the beginning of construction activities that will affect the village, and then quarterly during construction seasons (approximately twice per year). Meetings will be open house events where Pamir Energy (and/or contractors) will present information and people will be invited to make comments and express any concerns. If there is sufficient interest, separate meetings will be held for women, at which women will also be the primary representatives of Pamir Energy. Following the disclosure meeting, comments will be considered in the development of final ESIA, ESMF, RPF, and SEP. After the other meetings, Pamir Energy will follow up with Jamoat leaders and with stakeholders who expressed concerns about any environmental or social aspect of the projects. 7.1.2 Mass/social media communication Pamir Energy will appoint a community liaison officer (CLO) during each construction season (about six or seven months per year) in order to remain in close communication with PAPs, village leaders, and with Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 29 Table 10: Generic Methods, Tools and Techniques for Stakeholder Engagement Method / Tool Description and Use Contents Dissemination Method Target Groups Information Provision Distribution of Used to convey - - Printed materials - Distribution as part of - Households in Area of printed public information on the present illustrated and consultation meetings, Influence of each materials: projects and regular narrative information public hearings, subproject leaflets, updates on progress to on activities, facilities, discussions and - Residents of Roshtqala, brochures, fact local, regional and national technologies and design meetings with Ishkashim, Shugnon sheets stakeholders solutions, as well as stakeholders, as well as districts, as well as wider impact mitigation household visits in stakeholders in Tajikistan measures remote areas - External stakeholders - Contents to be concise - Placement at the offices and adapted to a of local administrations layperson reader and NGOs, libraries and - Graphics and pictures other public venues widely used to describe technical aspects - Information may be presented in Russian and/or Tajik for local and national stakeholders, and in English for international stakeholders - Material would reference GRM Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 30 Method / Tool Description and Use Contents Dissemination Method Target Groups Distribution of A newsletter or an update - - Important highlights of - Circulation of - Households in Project printed public circular sent out to Project achievements, newsletter/update Area of Influence materials: stakeholders on a regular announcements of sheet with a specified - Public venues in Project newsletters/ basis to maintain planned activities, frequency in Areas of Area of Influence – local updates awareness of the Project changes, and overall Influence, as well as to administrations, libraries development progress any other stakeholders - Material would that expressed their reference GRM interest in receiving these periodicals - Possible means of distribution: post, emailing, electronic subscription, delivery in person Printed Inserts, announcements, - - Notification of Placement of paid Residents in project area advertisements press releases, short forthcoming major information in local, in the media articles or feature stories events or regional and national in the printed media – commencement of printed media, including newspapers and specific Project activities those intended for general magazines - General description of reader and specialised the Project and its audience benefits to the community Radio or Short radio programmes, - - Description of the Collaboration with media Residents in project area television video materials or Project, Project producers that operate in entries documentary broadcast on development updates, the region and can reach TV solutions for impact local audiences mitigation - Advance announcement of the forthcoming public events or commencement of specific Project activities Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 31 Method / Tool Description and Use Contents Dissemination Method Target Groups Visual Visually convey Project - - Description of the Presentations are widely Same as other presentations presentations information to affected Project and related used as part of the public communities and other solutions/impact hearings and other interested audiences management measures consultation events with - Updates on Project various stakeholders development Notice boards Displays of printed Advance announcements Printed announcements Directly affected information on notice of the forthcoming public and notifications are communities in the project boards in public places events, commencement of placed in visible and easily area specific Project activities, accessible places or changes to the frequented by the local scheduled process public, including libraries, village cultural centres, post offices, shop, local administrations Information Feedback Information Placement of Project- Various Project-related Deposition of materials in Directly affected repositories related information and materials: ESIAs, SEP, RPF publicly available places communities in the project accompanied printed materials in (offices of local NGOs, area by a feedback dedicated/designated local administrations, mechanism locations that also provide libraries) for the duration visitors and readers with of a disclosure period or an opportunity to leave permanently Audience are their comments in a also given free access to a feedback register register of comments and suggestions Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 32 Method / Tool Description and Use Contents Dissemination Method Target Groups Dedicated - Setting up a dedicated As raised by callers - Telephone numbers are - Local communities within telephone line telephone line that can specified on printed the Project Area of (hotline) be used by the public to materials distributed to Influence request information, Project stakeholders - Any other stakeholders make enquiries, or and are mentioned and interested parties provide feedback on the during public meetings Project - Project’s designated - Initially, telephone staff should be assigned numbers of Project’s to answer and respond Community Liaison to the calls, and to Officer(s) can be shared direct callers to with the public specialist experts or to offer a call-back if a question requires detailed consideration Internet/Digital - Launch of Project - - Information about - A link to the Project - Affected communities, Media website with Pamir Energy web-site should be Project stakeholders and information and - ESIA/SEP, RPF specified on printed other interested parties updates on the overall - Project updates materials distributed to that have access to the Project, impact stakeholders internet resources assessment and impact - Other on-line based management process, platforms can also be procurement, used, such as web- employment conferencing, webinar opportunities, as well as presentations, web- on Project’s based meetings, engagement activities Internet surveys/polls with the public etc Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 33 Method / Tool Description and Use Contents Dissemination Method Target Groups - Web-site should have a - Limitation: Not all built-in feature that parties/stakeholders allows viewers to leave have access to the comments or ask internet, especially in questions about the the remote areas and in Project communities - Website should be - available in two - languages – Russian for the local and national audience, and in English for international stakeholders Surveys, The use of public opinion - - Description of the - Soliciting participation - Directly affected Interviews and surveys, interviews and proposed Project and in surveys/interviews households in the Project Questionnaires questionnaires to obtain related with specific Area of Influence stakeholder views and to solutions/impact stakeholder groups or - Other communities within complement the statutory management measures community-wide the Project Area of process of public hearings - Questions targeting - Administering Influence stakeholder perception questionnaires as part of the Project, impacts of the household visits and benefits, concerns and suggestions Feedback & - Can be used to Any questions, queries or - Box placed in safe public - Directly affected suggestion box encourage residents in concerns, especially for place that is readily households in the Project the affected stakeholders that may accessible for the Area of Influence communities to leave have a difficulty expressing community - Other communities within written feedback and their views and issues the Project Area of comments about the during public meetings Influence Project Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 34 Method / Tool Description and Use Contents Dissemination Method Target Groups - Contents should be - Information about the checked by designated availability of the Project staff on a suggestion box should regular basis to ensure be communicated as timely collection of part of Project’s regular input and interaction with local response/action stakeholders Consultation & Participation Public hearings - Meetings in public Detailed information on - Wide and prior - Directly affected places for project the activity and/or facility announcement of the communities in the representatives, in question, with focus on public hearing and the Project Area of Influence affected public, impacts and mitigations, relevant details, - Other communities within authorities, and other including a presentation including notifications in the Project Area of stakeholders for and an interactive mass media Influence presentation of Questions & Answers - Targeted invitations - Residents in the Project information on project session with attendees sent out to identified Area of Influence and discussion stakeholders - Other identified - Subject to statutory - Public disclosure of stakeholders expert review Project materials and - May be organized by associated impact authorities or Pamir assessment Energy documentation in advance Household Household-level visits can - - Description of the - Visits should be Directly affected people visits be conducted to Project and related conducted by supplement the statutory solutions/impact designated staff with process of public hearings, management measures specified periodicity particularly to solicit feedback from affected people and vulnerable persons who may be Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 35 Method / Tool Description and Use Contents Dissemination Method Target Groups unable to attend the - Any questions, queries formal hearings or concerns, especially for stakeholders that may have a difficulty expressing their views and issues during formal community-wide meetings Focus Group Used to facilitate Project’s specific activities - Announcements of the To be determined Discussions and discussion on Project’s and plans, design solutions forthcoming meetings Could include groups such as Round Table specific issues that merit and impact circulated to resettled households, those Workshops collective examination mitigation/management participants in advance who lose land, prospective with various groups of measures that require - Targeted invitations employees, vulnerable stakeholders detailed discussion with sent out groups (elderly, women, etc.) affected stakeholders Information Project’s designated venue - - Project-related Information about the Directly affected centers and for depositing Project- materials, including information center/field communities and any other field offices related information that updates of project office with open hours for stakeholders and interested also offers open hours to status the public, together with parties the community and other - Any issues that are of contact details, is provided members of the public, interest or concern to on the Project’s printed with Project staff available the local communities materials distributed to to respond to queries or and other stakeholders stakeholders, as well as provide clarifications during public meetings and household visits Site Tours - Visits to project sites Demonstration of specific - Targeted invitations - Local communities and facilities organised examples of Project’s distributed to selected - Elected officials for local communities, design solutions and audience offering an - Media groups authorities, and the approaches to managing opportunity to - NGOs and other initiative media to demonstrate impacts participate in a visit to groups Project solutions the Project Site Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 36 Method / Tool Description and Use Contents Dissemination Method Target Groups - Visitors are - Limitation: possible accompanied by the safety restrictions on Project’s staff and the site access during specialists to cover active construction various aspects and to works address questions arising from the public during the tour - Could be in conjunction with meeting Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 37 7.2 Planned stakeholder engagement activities Stakeholder engagement activities will need to provide specific stakeholder groups with relevant information and opportunities to voice their views on topics that matter to them. Table 11 shows the stakeholder engagement activities Pamir Energy currently plans to undertake for the project. The activity types and their frequency are adapted to the three main project stages: project preparation (including design, procurement of contractors and supplies), construction, and operation and maintenance. Methods to be used to engage stakeholders are described in section 7.1. 7.2.1 Communication materials Written information will be disclosed to the public in a number of ways. Initially, the draft ESIAs, RPF, and SEP will be disclosed in English and Russian. In addition, Pamir Energy will prepare brochures on a number of topics, including the project as a whole, on the land acquisition and compensation process, and on the grievance mechanism. These brochures will be available at meetings and will also be posted on bulletin boards in Jamoat offices and on information boards. Pamir Energy will also update its website regularly (at least on a quarterly basis) with key project updates and reports on the project’s environmental and social performance. The website will also provide information about the grievance mechanism. 7.1.1. Information Desks When construction is about to be undertaken in any of the Jamoats, and while construction is ongoing there, an information desk will be set up to provide local residents and affected people with information on stakeholder engagement activities, construction updates, contact details of the Pamir Energy Community Liaison Officer, and grievance management. Pamir Energy will set up these information centers, which may be staffed during certain periods, possibly by contractors. They will be set up in village centers or other easily accessible places where people can receive and share information about the project. The brochures mentioned above will be available at these information desks. 7.1.2. Grievance redress mechanism In compliance with the World Bank’s ESS10, a project-specific mechanism is being set up to handle complaints and issues, and this will be in addition to the normal Jamoat-and village-level processes that are available to citizens. Dedicated communication materials (specifically, a GRM brochure or pamphlet) will be developed to help local residents become familiar with the grievance redress channels and procedures. Locked suggestion/complaint boxes will be posted in each village and at contractor offices and camps, and Pamir Energy will maintain a grievance register in order to capture and track grievances from submission to resolution and communication with complainants. Pamir Energy’s website will include clear information on how feedback, questions, comments, concerns and grievances can be submitted by any stakeholder. It will also provide information on the way grievances will be handled, both in terms of process and deadlines. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 38 Table 11: Planned stakeholder engagement activities by project phase Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities Project Affected Parties: ‒ ESIA, ESMF, RPF, SEP, RAP ‒ Public meetings, separate meetings ‒ In Jamoats for disclosure of ‒ Pamir Energy STAGE 1: PROJECT PREPARATION (PROJECT DESIGN, SCOPING, RESETTLEMENT ‒ People potentially affected disclosure for women and vulnerable ESIA, ESMF, RPF, SEP HSE team by land acquisition ‒ Land acquisition process ‒ Face-to-face meetings ‒ In Jamoats at beginning of ‒ CLO ‒ People residing in project ‒ Assistance in gathering ‒ Mass/social media communication construction that would ‒ Specialists area official documents for (as needed) affect the area responsible for ‒ Vulnerable households authorized land uses ‒ Disclosure of written information: ‒ Survey of PAPs in affected land acquisition ‒ Compensation rates and brochures, posters, flyers, website villages ‒ RAP consultant PLANNING, ESMF/RPF/SEP DISCLOSURE) methodology Information boards or desks - In ‒ Communication through ‒ Project scope and Jamoats mass/social media rationale ‒ Grievance mechanism ‒ Throughout RAP ‒ Project E&S principles development as needed ‒ Resettlement and livelihood restoration options ‒ Grievance mechanism process Other Interested Parties ‒ ESIA, ESMF, RPF, SEP, RAP ‒ Face-to-face meetings ‒ Throughout RAP ‒ Pamir Energy (External) disclosure ‒ Joint public/community meetings development as needed E&S Team & ‒ Khukumat (Khorog) ‒ Land acquisition process with PAPs ‒ Project launch meetings in management ‒ Jamoats ‒ Identification of land plots Jamoats ‒ CLO ‒ Representatives in villages and uses ‒ Quarterly meetings in ‒ Specialists ‒ Resettlement and affected villages and responsible for livelihood restoration Jamoats land acquisition options (if needed) ‒ Disclosure meetings in ‒ RAP consultant ‒ Project scope, rationale Jamoats and Khorog and E&S principles ‒ Grievance mechanism process Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 39 Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities Other Interested Parties ‒ ESIA, ESMF, RPF, SEP, RAP ‒ Public meetings, ‒ Project launch meetings in ‒ Pamir Energy (External) disclosure trainings/workshops (separate Jamoats HSE team ‒ Press and media ‒ Grievance mechanism meetings specifically for women and ‒ Meetings in affected ‒ CLO ‒ NGOs ‒ Project scope, rationale vulnerable as needed) villages and Jamoats as ‒ Businesses and business and E&S principles ‒ Mass/social media communication needed organizations ‒ Disclosure of written information: ‒ Communication through ‒ Workers' organizations Brochures, posters, flyers, website mass/social media (as ‒ Academic institutions ‒ Information boards or desks in needed) ‒ National Government Jamoats ‒ Information desks with Ministries ‒ Grievance mechanism brochures/posters in ‒ Local Government ‒ Notice board for employment affected villages Departments recruitment (continuous) ‒ General public, tourists, jobseekers Other Interested Parties ‒ Project information scope ‒ Face-to-face meetings ‒ Disclosure meetings ‒ Pamir Energy (External) and rationale and E&S ‒ Invitations to public/community HSE team ‒ Other Government principles meetings ‒ CLO Departments from which ‒ Coordination activities permissions/clearances are ‒ Land acquisition process required ‒ Grievance mechanism ‒ Other project developers, process donors ‒ ESIA, ESMF/RPF/SEP disclosure Other Interested Parties ‒ Project information - ‒ Face-to-face meetings As needed ‒ Pamir Energy (Internal) scope and rationale and ‒ Trainings/workshops HSE team ‒ Other Pamir Energy staff E&S principles ‒ Invitations to public/community ‒ CLO ‒ Supervision Consultants ‒ Training ESIA/ESMF/ESMP meetings ‒ Contractor, sub- requirements and other contractors, service sub-management plans providers, suppliers, and ‒ Grievance mechanism their workers process ‒ E&S requirements Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 40 Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities Project Affected Parties: ‒ Grievance mechanism ‒ Public meetings, open houses, ‒ Quarterly meetings in ‒ Pamir Energy ‒ People potentially affected ‒ Health and safety impacts trainings/workshops, affected villages during HSE team by land acquisition (EMF, community H&S, ‒ Separate meetings as needed for construction season ‒ CLO ‒ People residing in project community concerns) women and vulnerable ‒ Communication through ‒ Supervision and area ‒ Employment opportunities ‒ Individual outreach to PAPs as mass/social media as RAP consultants ‒ Vulnerable households ‒ Project status needed needed ‒ Contractor/sub- ‒ Disclosure of written information: ‒ Notice boards updated contractors brochures, posters, flyers, website weekly ‒ NGOs/trainers STAGE 2: Construction and mobilization activities Information boards or desks - In ‒ Brochures in local offices Jamoats ‒ Notice board(s) ‒ Grievance mechanism Other Interested Parties ‒ Project scope, rationale ‒ Face-to-face meetings ‒ As needed (monthly during ‒ Pamir Energy (External) and E&S principles ‒ Joint public/community meetings construction season) HSE team ‒ Governmental committees ‒ Grievance mechanism with PAPs ‒ CLO for land use and ‒ Project status ‒ Supervision and compensation RAP consultants ‒ Jamoats and ‒ Contractor/sub- representatives in villages contractors Other Interested Parties ‒ Project information - ‒ Same as for PAPs ‒ Same as for PAPs ‒ Pamir Energy (External) scope and rationale and HSE team ‒ Press and media E&S principles ‒ CLO ‒ NGOs ‒ Project status ‒ Businesses and business ‒ Health and safety impacts organizations ‒ Employment opportunities ‒ Workers' organizations ‒ Environmental concerns ‒ Academic institutions ‒ Grievance mechanism ‒ National Government process Ministries ‒ Local Government Departments ‒ General public, tourists, jobseekers Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 41 Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities Other Interested Parties ‒ Project information: scope ‒ Face-to-face meetings Daily, as needed ‒ Pamir Energy (Internal) and rationale and E&S ‒ Trainings/workshops HSE team ‒ Other PEC Staff principles ‒ Invitations to public/community ‒ Supervisors ‒ Supervision Consultants ‒ Training on meetings ‒ Contractor, sub- ESIA/ESMF/ESMP contractors, service requirements and other providers, suppliers and sub-management plans their workers ‒ Worker grievance mechanism Project Affected Parties ‒ Satisfaction with ‒ Outreach to individual PAPs Meetings in affected Jamoats Pamir Energy HSE ‒ People residing in project engagement activities and ‒ Pamir Energy website and villages (as team STAGE 3: Operation and maintenance area GRM needed/requested) ‒ Vulnerable households ‒ Grievance mechanism process ‒ Electromagnetic fields ‒ Damage claim process Other Interested Parties ‒ Grievance mechanism ‒ Grievance mechanism As needed Pamir Energy HSE (External) process ‒ Pamir Energy website team & ‒ Press and media ‒ Issues of concern ‒ Face-to-face meetings management ‒ NGOs ‒ Businesses and business organizations ‒ Workers' organizations ‒ Academic institutions ‒ Local Government Departments (Khuokumat, Jamoats) ‒ General public, tourists Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 42 The initial effort to resolve grievances to the complainant’s satisfaction will be undertaken by Pamir Energy. If that is not successful in resolving grievances, they will be referred to a committee at the Jamoat level. The mechanism is described in detail in Chapter 8 below, which includes a form that can be used to submit grievances. Grievances may be submitted anonymously, but in that case it cannot be known if the complainant is satisfied with the resolution. 7.1.3. Project tours At appropriate points during the construction phase, if there is sufficient interest, Pamir Energy may organize site visits or demonstration tours for selected stakeholders from media organizations or local governments. 7.1.4. Citizen/PAP perception survey A perception survey examining citizen’s experience and feedback about the project will be carried out twice during the project’s lifecycle: once near the end of the first construction season and once during the second season. Results of these surveys will be reviewed carefully to identify refinements or changes in project methods and procedures that may be needed to reduce impacts or improve efficiency. 7.1.5. Trainings and workshops Finally, trainings on a variety of social and environmental issues will be provided to Pamir Energy and contractor staff and possibly to interested government or nongovernment service providers. Issues covered could include such topics as the worker code of conduct and the worker grievance mechanism. Pamir Energy may also provide training to residents on various topics, including efficient use of electricity, electrical safety, and other relevant topics. 7.1.6. Vulnerable groups Pamir Energy will take special measures to ensure that disadvantaged and vulnerable groups have equal opportunity to access information, provide feedback, or submit grievances. The deployment of the Community Liaison Officer will help to ensure proactive outreach to all population groups, and they will make a special effort to engage with those identified as vulnerable or disadvantaged. If necessary, Pamir Energy will provide transport to public meetings for vulnerable people, and will also deliver brochures and informational material to such households. 7.2. Disclosure of information and public consultations Consultations with affected people and stakeholder engagement will be carried out throughout project implementation. The Pamir Energy website (http://www.pamirenergy.com/en/presscenter/public.php) will be used to disclose project documents, including those on environmental and social performance. In addition, meetings and other key events will be announced in the regional/state newspaper (“Asia Plus”) Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 43 and the local newspaper “Badakhshon” and described in Pamir Energy “newspapers” that customers receive. This began with disclosure of draft documents in April 2019. Disclosures included: • A draft of this combined Draft Stakeholder Engagement Plan for the Sebzor HPP, 18-kilometer 110-kV Sebzor-Khorog transmission line, and 63-kilomter Khorog-Qozideh transmission line • Draft Resettlement Policy Framework for the Tajikistan Rural Electrification Project. • Draft ESIAs for the Sebzor HPP, Sebzor-Khorog transmission line, and Khorog-Qozideh transmission line.. Besides the draft disclosure documents (which are now followed by final documents), a project brochure with details of the planned project consultations was posted. An easy-to-understand guide to the terminology used in the environmental and social reports or documents will also be posted on the website. In addition, the site will provide details about the Grievance Redress Mechanism and contact details of the Community Liaison Officer. Pamir Energy will update and maintain the website regularly, at least quarterly. Paper copies of all ESIA documentation have been placed in Jamoats and advertisements placed on the notice boards in the villages. Electronic copies are available at the website above. Addresses where the ESIA documents may be reviewed include the following: • Pamir Energy Company, 75 Gulmamadova Street, 736000 Khorog, GBAO, Tajikistan • Administration (Khoukumat) of GBAO in Khorog, address: city Khorog, Lenin street 47, Tajikistan • Administration (Khoukumat) of Roshtqala district in Roshtqala, at address: Khorog, Committee for Environmental Protection (CEP), Lenin street, 46, Tajikistan Following disclosure of the ESIA and other documents, Pamir Energy announced and held three consultation meetings: Table 12. Public consultations on Sebzor HPP and associated transmission lines Meeting Number of Subproject Meeting location date (2019) attendees Sebzor HPP & 18-km 26 April Sebzor (Roshtqala District) 46 t-line Andarob Village (Ishkashim Khorog-Qozideh 29 April Village) 48 transmission line 30 April Qozideh (Ishkashim District) Consultation meeting in Sebzor on Sebzor HPP and 18km transmission line At the meeting (Error! Reference source not found.), Pamir Energy asked people to sign in and handed out brochures that described the project and announced the meeting. The chairman of Roshtqala District, Mr. Safarov Davlat, opened the meeting by welcoming the representatives of Pamir Energy and saying Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 44 how pleased he and the community were that the company had launched the rural electrification project. A total of 46 people from four villages attended the meeting and were actively engaged in the discussion.. Pamir Energy described the projects and the analyses that had been completed, and explained that there would be international financing, and as a result the project would have to meet international standards as well as those required by Tajikistan. Pamir Energy also noted that the line will be designed so that no one will need to relocate and arable land will be avoided unless it cannot be avoided. Attendees were then invited to make comments and ask questions. Most discussion was related to employment, with questions about how and staff will be selected and the very strong desire to work on the project. It was explained that contractors would announce job openings and select workers based on qualifications and technical knowledge. It was emphasized that that many or most people hired by the contractors, and by Pamir Energy, would come from local villages. Another concern was about what would happen to houses and gardens that are demolished. Pamir Energy responded by referring to the requirements of the Resettlement Policy Framework and noted that a detailed Resettlement Action Plan would be developed in the future, before construction begins. In general, there was unanimous support for the project, with comments and questions about what the communities could do to assist project implementation and questions about how soon the project would begin. More detailed minutes and the list of participants are in Annex 2. Consultation meetings in Andorob and Qozideh on 63km Sebzor and transmission lines At the meetings (Figure 12 and Figure 12, Pamir Energy asked people to sign in and handed out brochures that described the project and announced the meeting. A total of 48 people from four villages attended the meetings and, as in Sebzor, attendees actively participated in the discussion.. Pamir Energy described the project and the analyses that had been completed, and explained that there would be international financing, and as a result the project would have to meet international standards as well as those required by Tajikistan. Attendees were then invited to make comments and ask questions. The discussion began with Mr.Khasanov Mehrobsho, the Leader of the Jamaat, expressing his gratitude to the representative of Pamir Energy for the meeting with the local community and mentioned that the community is glad that PE started implementing the project and expressed his as well as community’s willingness to assist in the timely implementation of the project. Questions included the implementation period of the project, with Pamir Energy responding that it would be about 2.5 years. There were many questions about employment, and Pamier Energy noted that many or most of the workers will be from local communities, both hired by contractors during construction and by Pamir Energy during operation, with selections based on qualifications and technical knowledge. .. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 45 Figure 10. Disclosure consultation meeting in Sebzor Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 46 Figure 12. Consultation meeting in Qozideh . Figure 11. Disclosure consultation meeting in Andarob Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 47 7.3 Stakeholder Engagement during Project Implementation Engagement will continue through the life of the project. The SEP provides details of the program that will be used to present information to stakeholders and to receive information and opinions from stakeholders. In summary, there will be: • Public / community meetings • Mass/social media communication • Distribution of information materials • Grievance redress mechanism • Project tours for media, civil society, and local representatives • Information desks at each municipality • Citizen perceptions surveys • Trainings and workshops to raise awareness on key topics of interest such as EMF, impacts on land and compensations, code of conduct for project staff, grievance redress mechanism, or other topics of interest to citizens. 7.4 Pamir Energy Point of Contact The point of contact for stakeholder engagement mechanism is Pamir Energy’s Senior Environmental and Social Officer, identified below. During the construction period, there will be other Community Liaison Officers to assist. : Description Contact details Name Asligul Mamadatoeva Address: 75 Gulmamadova Street 736000 Khorog, GBAO, Tajikistan E-mail: mavluda.mamadatoeva@pamirenergy.com Telephone: +992 35 222 23 10 Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 48 8. Grievance Redress Mechanism Project-affected-people and any other stakeholder may submit comments or complaints at any time by using the project’s Grievance Redress Mechanism (GRM). The overall objectives of the GRM are to: • Provide a transparent process for timely identification and resolution of issues affecting the project and people, including issues related to the resettlement and compensation program. • Strengthen accountability to beneficiaries, including project affected people. The GRM will be accessible to all external project stakeholders, including affected people, community members, civil society, media, and other interested parties. External stakeholders can use the GRM to submit complaints, feedback, queries, suggestions, or even compliments related to the overall management and implementation of the project, including the resettlement and compensation program. The GRM is intended to address issues and complaints in an efficient, timely, and cost-effective manner. A separate mechanism will be available to Pamir Energy and contractor employees, who are internal stakeholders. Pamir Energy will be responsible for managing the stakeholder GRM, but many or most grievances are likely to result from actions of the construction contractors and so will need to be resolved by the contractors themselves, with Pamir Energy oversight. Typical grievances for transmission line projects could include issues related to: • Land acquisition and compensation • Construction damages to property, crops, or animals • Traffic • Environmental impacts such as erosion • Nuisances such as dust or noise • Worker misbehavior. The GRM will be in place and operational well before Pamir Energy begins construction activities and will function until the completion of all construction activities and beyond, till the contractor’s defect liability period ends. Initial compensation, for land and property needed for the project, will be completed before construction begins. People who reside near the line and others who may be affected will be informed, in meetings and with brochures, of the GRM’s purpose, functions, procedures, timelines and contact persons. Additional measures will be taken to inform those who are determined to be eligible for compensation. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 49 The project GRM will include three successive tiers of extra-judicial grievance review and resolution: • The first tier will be the Pamir Energy E&S team, including the Community Liaison Officer. They will deal quickly with issues that can be quickly resolved, and would always involve direct communication with the person(s) who submitted the grievance. • The second tier will be a Grievance Resolution Committee (GRC1) that includes representatives of Pamir Energy and of the complainant’s village and Jamoat. The GRC1 will deal with issues that could not be resolved in the first tier. • The third tier will be a Grievance Redress Commission (GRC2) that included one or more senior Pamir Energy managers and one or more Jamoat and/or village leaders. GRC2 will resolve issues that could not be resolved by GRC1. Grievances would be handled as described in the following subsection. 8.1 Grievance resolution process Information about the GRM will be publicized as part of the initial disclosure consultations in the participating Jamoats and villages. Brochures will be distributed during consultations and public meetings, and posters will be displayed in public places such as in government offices, project offices, village notice boards, community centers, etc. Information about the GRM will also be posted online on the Pamir Energy website (http://www.pamirenergy.com/en/presscenter/public.php) The overall process for the GRM will be comprised of six steps, as shown on Figure 13 and described below. This builds on the way grievances are typically managed, which is illustrated in Figure 14. Figure 13: Feedback and GRM Process Source: Agarwal, Sanjay and David Post. 2009. Feedback Matters: Designing Effective Grievance Redress Mechanisms for Bank- Financed Projects – Part I. SDV. World Bank. • Step 1: Uptake. Project stakeholders will be able to provide feedback and report complaints through several channels: in person at offices (village/mahalla, jamoat, project, and Pamir Energy offices) and at project sites, and by mail, telephone, and email. • Step 2: Sorting and processing. Complaints and feedback will be compiled by the Community Liaison Officer and recorded in a register. Submissions related to the resettlement and compensation program will be referred to the HSE Department for processing and resolution. The Department will assign one individual to be responsible for dealing with each complaint, Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 50 including following through within Pamir Energy and with the complainant to arrive at a resolution, with the goal to resolve complaints within 15 days of receipt. • Step 3: Acknowledgement and followup. Within seven (7) days of the date a complaint is submitted, the responsible person will communicate with the complainant and provide information on the likely course of action and the anticipated timeframe for resolution of the complaint. If complaints are not resolved within 15 days, the responsible person will provide an update about the status of the complaint/question to the complainant and again provide an estimate of how long it will take to resolve the issue. In addition, the HSE Department will Figure 14: Typical grievance resolution process Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 51 report to the General Director every two weeks on grievances that have remained unresolved for 30 days or more. • Step 4: Verification, investigation and action. This step involves gathering information about the grievance to determine the facts surrounding the issue and verifying the complaint’s validity, and then developing a proposed resolution, which could include changes of decisions concerning eligibility for compensation, additional compensation or assistance, changes in the program itself, other actions, or no actions. Depending on the nature of the complaint, the process can include site visits, document reviews, a meeting with the complainant (if known and willing to engage), and meetings with others (both those associated with the project and outside) who may have knowledge or can otherwise help resolve the issue. It is expected that many or most grievances would be resolved at this stage. All activities taken during this and the other steps will be fully documented, and any resolution logged in the register. • Step 5: Monitoring and evaluation. Monitoring refers to the process of tracking grievances and assessing the progress that has been toward resolution. The HSE Department will be responsible for consolidating, monitoring, and reporting on complaints, enquiries and other feedback that have been received, resolved, or pending. This will be accomplished by maintaining the grievance register and records of all steps taken to resolve grievances or otherwise respond to feedback and questions. • Step 6: Providing Feedback. This step involves informing those to submit complaints, feedback, and questions about how issues were resolved, or providing answers to questions. Whenever possible, complainants should be informed of the proposed resolution in person. If the complainant is not satisfied with the resolution, he or she will be informed of further options, which would include pursuing remedies through the World Bank, as described below, or through avenues afforded by the Tajikistan legal system. On a monthly basis, the HSE Department will report to the General Director on grievances resolved since the previous report and on grievances that remain unresolved, with an explanation as to steps to be taken to resolve grievances that have not been resolved within 30 days. Data on grievances and/or original grievance logs will be made available to World Bank missions on request, and summaries of grievances and resolutions will be included in periodic reports to the World Bank. Pamir Energy will be responsible for carrying grievances through all six steps. Step 4 (Verify, Investigate, and Act) could involve interviews of the aggrieved party, workers, or other stakeholders; review of records; consultation with authorities; and/or other fact-finding activities. If the grievance cannot be resolved to the satisfaction of all parties, it will be referred to GRC1, who would retrace Step 4 as needed. The steps following the initial investigation and proposed solution would proceed as follows: • Determination of proposed resolution or referral to second tier: - If resolution is proposed: referral to E&S manager for review and approval (including refinements). Once approved, responsible person would communicate resolution to complainant and refer to corporate management for implementation. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 52 - If referred to second tier, GRC1 would consider facts determined by initial review and conduct such other fact-finding as needed, including interviews of complainant and others if necessary. • GRC1 recommends resolution or refers to GRC2: - If resolution is proposed: referral to Pamir Energy for implementation, including communication to complainant. - If referred to third tier, GRC2 to meet and discuss facts as determined by initial tiers and make determination of proposed resolution. • GRC2-recommended resolution: referred to Pamir Energy for communication to complainant and implementation of recommended actions (if any) • Complainant would be asked to acknowledge acceptance (or rejection) of the resolution. • Pamir Energy would then implement actions that are part of the resolution (if any). If a person who submits a grievance is not satisfied with the resolution at the first or second tiers, he or she may request it be elevated to the next tier. If they are not satisfied with the ultimate resolution, they may pursue legal remedies in court or pursue other avenues as described above. Throughout the entire process, Pamir Energy will maintain detailed records of all deliberations, investigations, findings, and actions, and will maintain a summary log that tracks the overall process. 8.2 Grievance processing Anyone who believes they are eligible for compensation can submit a grievance: • By completing a written grievance form that will be available (a) in the Jamoat and in the villages crossed by the line, (b) at Pamir Energy’s offices in Khorog and on their website, and (c) from CLOs or other members of the HSE Department. An example of a grievance registration form is provided in Annex 1. • By contacting the Pamir Energy Community Liaison Officer or other member of the Pamir Energy HSE Department team, either by telephone or in person. In addition, grievances may be communicated to contractor supervisors or to Pamir Energy electrical inspectors, who will be briefed on receiving and reporting complaints. Grievances received verbally will be recorded by the Community Liaison Officer on a grievance registration form and logged into the Grievance Register. A copy of the logged grievance will be given to the complainant, giving them the opportunity to alert Pamir Energy if the grievance has not been noted down correctly. Pamir Energy will explain to local communities the possibilities and ways to raise a grievance during consultation meetings organized in each village when this draft SEP and other draft documents are disclosed and then at quarterly meetings thereafter. The GRM procedures will be disclosed through the project’s website and will also be described in a brochure or pamphlet made available in Jamoat administration buildings. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 53 The Pamir Energy Community Liaison Officer team will be responsible for logging and tracking grievances. As noted above, one person will be assigned responsibility for investigating and recommending resolution to each grievance, or to recommend referral to GRC1. Information to be recorded in the grievance log will include name and contact details of the complainant and a summary of the grievance and how and when it was submitted, acknowledged, responded to and closed out. All grievances will be acknowledged within 7 days and resolved as quickly as possible. If there has been no resolution within 30 days, the person assigned responsibility for the grievance will contact the complainant to explain the reason for the delay. On at least a monthly basis, a summary of grievances and resolutions will be provided to the Pamir Energy General Director. A generic flow chart for registering and processing grievances is shown in Figure 9 above. The status, number, and trends of grievances will be discussed between the project team and Pamir Energy senior management during meetings held at least monthly and more frequently as needed. A grievance will be considered “resolved” or “closed” when a resolution satisfactory to both parties has been reached, and after any required corrective measures have been successfully implemented. When a proposed solution is agreed by the complainant, the time needed to implement it will depend on the nature of the solution. Once the solution is being implemented or is implemented to the satisfaction of the complainant, the complaint will be closed out and acknowledged in writing by both the complainant and Pamir Energy. In certain situations, it may not be possible to reach a satisfactory resolution. This could occur if a complaint cannot be substantiated or is proved to be speculative or fraudulent. In such situations, Pamir Energy’s efforts to investigate the grievance and to arrive at a conclusion will be well documented and the complainant advised of the situation. It is also possible that a complainant will not be satisfied with the proposed resolution. In such cases, if Pamir Energy cannot do more, the complainant will be asked to acknowledge refusal of the proposed resolution in writing. Pamir Energy will then decide whether to implement the resolution without the agreement of the complainant and the complainant will decide whether to pursue legal remedies. 8.3 Grievance Logs As noted previously, the HSE Department will maintain a grievance log. This log will include at least the following information: • Individual reference number • Name of the person submitting the complaint, question, or other feedback, address and/or contact information (unless the complaint has been submitted anonymously) • Details of the complaint, feedback, or question/her location and details of his / her complaint. • Date of the complaint. • Name of person assigned to deal with the complaint (acknowledge to the complainant, investigate, propose resolutions, etc.) Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 54 • Details of proposed resolution, including person(s) who will be responsible for authorizing and implementing any corrective actions that are part of the proposed resolution • Date when proposed resolution was communicated to the complainant (unless anonymous) • Date when the complainant acknowledged, in writing if possible, being informed of the proposed resolution • Details of whether the complainant was satisfied with the resolution, and whether the complaint can be closed out • If necessary, details of GRC1 and GRC2 referrals, activities, and decisions • Date when the resolution is implemented (if any). 8.4 Monitoring and reporting on grievances Details of monitoring and reporting are described above. Day-to-day implementation of the GRM and reporting to the World Bank will be the responsibility of the HSE Department. To ensure management oversight of grievance handling, the Internal Audit Unit will be responsible for monitoring the overall process, including verification that agreed resolutions are actually implemented. 8.5 Pamir Energy Point of Contact The point of contact regarding the stakeholder engagement program: Description Contact details Name Asligul Mamadatoeva Address: 75 Gulmamadova Street 736000 Khorog, GBAO, Tajikistan E-mail: mavluda.mamadatoeva@pamirenergy.com Telephone: +992 35 222 23 10 Information on the project and future stakeholder engagement programs will available on the pro ject’s website and will be posted on information boards in the villages crossed by the line. Information can also be obtained from Pamir Energy in Khorog. Six-monthly E&S reports that document the implementation of the Stakeholder Engagement Plan (SEP) will be disclosed on the project website and made available in the Jamoats or at the village heads houses. 8.6 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 complaints 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- Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations 55 service). A complaint may be submitted in English, Russian, Tajik, or Shugne, although additional processing time will be needed for complaints that are not in English. 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 • Through the World Bank Tajikistan Country Office in Dushanbe: 48 Ayni Street, Business Center "Sozidanie", 3rd floor, Dushanbe, Tajikistan; Tel: +992 48 701-5810. The complaint must clearly state the adverse impact(s) allegedly caused or likely to be caused by the Bank- supported project. This should be supported by available documentation and correspondence to the extent possible.. The complainant may also indicate the desired outcome of the complaint. Finally, the complaint should identify the complainant(s) or assigned representative/s, and provide contact details. Complaints submitted via the GRS are promptly reviewed to allow quick attention to project-related concerns. In addition, project-affected communities and individuals may submit complaints to the World Bank’s independent Inspection Panel, which will then determine whether harm occurred, or could occur, as a result of the World Bank’s non-compliance with its policies and procedures. Complaints may be submitted to the Inspection Panel at any time after concerns have been brought directly to the World Bank’s attention, and after Bank Management has been given an opportunity to respond. Information on how to submit complaints to the World Bank Inspection Panel may be found at www.inspectionpanel.org. Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations Annex 1: Example Grievance Form Stakeholder Engagement Plan Sebzor Hydropower Plant 110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations Pamir Energy Grievance Form Grievance reference number (to be completed by Pamir Energy): Contact details Name (s): (may be submitted Address: anonymously) Telephone: Email: How would you prefer to be By mail/post: By phone: By email contacted (check one) ☐ ☐ ☐ Preferred language ☐ Tajik ☐ Russian ☐ English Provide details of your grievance. Please describe the problem, who it happened to, when and where it happened, how many times, etc. Describe in as much detail as possible. What is your suggested resolution for the grievance, if you have one? Is there something you would like Pamir Energy or another party/person to do to solve the problem? How have you submitted this Website email By hand form to the project? ☐ ☐ ☐ In person By telephone Other (specify) ☐ ☐ ☐ Who filled out this form (If not Name and contact details: the person named above)? Signature Name of Pamir Energy person assigned responsibility Resolved or referred to GRC1? ☐ Resolved ☐ Referred If referred, date: Resolved referred to GRC2? ☐ Resolved ☐ Referred If referred, date: Completion Final resolution (briefly describe) Short description Accepted? Acknowledgement (Y/N) signature 1st proposed solution 2nd proposed solution 3rd proposed solution Annex 2. Minutes of Consultation Meeting on Sebzor HPP and Sebzor-Khorog Transmission Line in Sebzor (Roshtqala District, GBAO) MINUTES OF MEETING PROJECT NAME Tajikistan Rural Electrification Project: Sebzory Hydropower Plant and Sebzor-Khorog 18-kilometer 110kV transmission line VENUE DATE OF MEETING Sebzor village of Roshqala district, Viloyati Mukhtori 26/04/2019 Kuhistoni Dadakhshon (VMKB) PRESENT A. Saidmamadov– Engineer, Pamir Energy A . Mamadatoeva – Senior Environmental officer, Pamir Energy G. Mamadambarova - Call Center Operator, Pamir Energy N. Shoskandarov- GIS specialist, Pamir Energy R. Khushqadamov - PR Specialist, Pamir Energy R. Ustoboeva - Report Officer, Pamir Energy The community members [the list of participants is attached] 1. Summary For the consultative meeting (on TREP Sebzor component, particularly E&S documentation) all village residents were invited and about 46 community members gathered and participated in the meeting. They received information and details about the planned project implementation as well as related environmental and social impacts that were identified in recent assessments. Sebzor villagers very much welcome the project’s implementation. They expressed no objection or concern related to the project and its impacts as they are generally very hopeful that it will contribute to positive developments for their villages. Primarily, employment opportunities and compensation (in-kind) for potential loss of land were the main point of community interest an discussion. 2. Welcome and Introduction An introductory speech was made by the chairman of Roshqala, Mr. Safarov Davlat, who welcomed the representatives of Pamir Energy Company (PE) and expressed his opinion and the opinion of the local community about how pleased they are that the company had launched rural electrification project in VMKB. Mr. Asad Saidmamadov, a representative of PE, presented the Tajikistan Rural Electrification Project that was developed as part of the Government of Tajikistan and PE initiative construction of the Sebzor HPP rural population in VMKB and Khatlon regions in cooperation with the World Bank (WB). He mentioned that although within 16 years of operation, the company has significantly increased energy availability for 218,000 people (96% of the population) in Eastern Tajikistan, there are still 12,286 people, residing in 61 villages of VMKB, without electricity Moreover Pamir Energy plans to build the Sebzor hydropower plant (HPP) with a capacity of 11 MW on the Shokhdara River near the town of Khorog in the Viloyati Mukhtori Kuhistoni Badakhshon (VMKB) in Tajikistan. It is planned that the project will be funded by the World Bank and other donors. Pamir Energy has completed an Environmental Social Impact Assessment (ESIA) for the construction project of the Sebzor HPP and transmission line to Khorog and is currently conducting the necessary public consultations and meetings with stakeholders and the public. This process and further project information was presented on Power Point by Ms. Asligul Mamadatoeva, the Senior Environmental Officer of Pamir Energy The participants were informed that the Sebzor HPP will generate more than 70 gigawatt-hours of electricity per year which is enough to provide more than 600,000 people with electricity in VMKB and Afghanistan. The planned 18 km transmission line (PTL) will connect the Sebzor Hydroelectric Power Plant with a substation in Khorog and the second, planned 63 km 110 kv transmission line connects the power system of Tajikistan with the southern part of VMKB. In the future, the construction of an additional 110kV transmission line for the transmission of electricity to non-electrified areas in the north of Afghanistan is being considered. As the project involves foreign investors and donors, along with the requirements of the legislation of the Republic of Tajikistan, for project certification (evaluation) there are separate requirements, such as the Environmental and Social Standards (ESS 1-10) of the World Bank. For projects such as HPPs and high-voltage transmission lines, a detailed ESIA is required. Community members received explanation that the ESIAs assess the main environmental and social risks associated with the project and suggests the necessary actions and measures to avoid or minimize significant adverse changes to the environment, health and safety, as well as to socio-economic conditions. Moreover the ESIAs have requirements for conducting appropriate public consultations and disclosing all information about the project and the results of the ESIAs, which is the reason for this meeting. Pamir Energy has completed ESIAs for the project and is currently conducting the necessary public consultations and meetings with stakeholders to disclose information and receive feedback from stakeholders and the public. The environmental and social assessment helps to determine the potential environmental and social effects of the project and as Ms. Asligul Mamadatoeva noted also identifies if additional research/assessment will be needed and conducted on individual project components or aspects. Other relevant and required documents and summary of impacts are listed in the brochures that has been distributed earlier. For instance, as a common practice, while implementing such projects, a plan for resettlement and compensation is developed. An example of the socio- economic aspects would be not only electrification, but also employment opportunities for the local population. Meeting participants were informed that also more detailed information on the project as well as the developed documents on environmental and social aspects of the projects are available on the PE website, the brochures and newspapers (developed by PE) that are distributed, as well as on the regional newspaper – “Badakhshon” and messages sent to consumers via phones. The link to the website is provided in the PE newspapers that were distributed during the meeting. The dates for consultative meetings with the local communities for each targeted village under the project are indicated in the newspaper. That is the reason why we are here today – emphasized Ms. Mamadatoeva, to present the project’s objectives and activities as well as to know the communities’ opinions as stakeholders and to answer their queries. 3. Questions, Answers and Comments Mr. Rakhmonshoeva Davlatbegim expressed her gratitude to Ms. Mamadatoeva for the meeting with the local community and mentioned that as electricity is the basic need for human beings, and even though some of the houses will be demolished, the community is glad that PE started implementing the project in their village and expressed her as well as the community’s willingness to assist in the timely implementation of the project. She further queried the implementation period of the project. Ms. Mamadatoeva responded that the project is subject to the allocation of donor funding ,all three projects, including the Sebzor HPP,18 km of power lines from Sebzor to Khorog and 63km of power lines from Khorog to the village of Kozideh are Planned to be completed in 2-3 years term (2022-2023) The community also quarried about the staff – those who will be working during the operational stage at the HPP? Ms. Mamadatoeva replied that the PE staff as well as local residents, who will be selected based on the required qualifications i.e. with relevant technical knowledge and education. The people were also interested in employment opportunities and queried how the selection process will be held and what are the key requirements? Ms. Mamadatoeva responded that prior to the construction; the contractor will announce the necessary vacancies and those interested can apply. The contractor will then shortlist the candidates and hire/select those who fit the best according to their qualification. One of the participants, Chakaboev Farhod, was interested what will happen to their house and gardens which will be demolished? Ms. Mamadatoeva responded that Pamir Energy will pay compensation to people effected by resettlement and economic displacement. Requirements for compensation are set out in the resettlement policy framework, which was developed by Pamir Energy. In the near future this will be complemented by a detailed and specific resettlement action plan, which will be developed by the company and approved by the World Bank and the Government of Tajikistan. This information will be shared and the process closely and regularly communicated with the stakeholders. 4. Closing Remarks At the end of the meeting it was ensured that all brochures and regional and PE’s newspapers were distributed to all the participants by Gulnor Mamadambarova the representative of Pamir Energy. The pictures of the meeting and the list of participants are attached. Signatures of PE representatives: /s/ A. Mamadatoeva /s/ A .Saidmamadov /s/ G. Mamadambarova /s/ N.Shoskandarov /s/ R.Khushqadamov /s/ R.Ustoboeva Participants - Sebzor meeting, 26.4.2019 Full Name Position Location (village\,jamoat) Safarov Davlat Deputy of District Chairman Parzudj village, M.Mirshakar Rakhmonshoeva Village chairman Chagev village, M.Mirshakar Davlatbegim Pulodbekov Uvaydo Village Chairman Parzudj village, M.Mirshakar Abdullokhonov Abdullokhon Driver Parzudj village, M.Mirshakar Odinabekov Sukhrob Unemployed Parzudj village, M.Mirshakar Pulodbekov Akobir Unemployed Parzudj village, ,M,Mirshakar Odilshoev Rashid Unemployed Parzudj village, M.Mirshakar Amadbekov Mirgarib Pensioner Parzudj village,M.Mirshakar Noyobshoev Sham Unemployed Parzudj village,M.Mirshakar Mavlonazarov Imumnazar Unemployed Parzudj village,M.Mirshakar Bodurov Qiyom Unemployed Parzudj village, M.Mirshakar Safarmamadov Shosodiq Unemployed Parzudj village, M.Mirshakar Abdollov Niyatbek Unemployed Parzudj village, M.Mirshakar Abdulamidov Davlatbek Unemployed Parzudj village, M.Mirshakar Shodiev Amrikhon Unemployed Parzudj village, M.Mirshakar Oshurbekova Zarrina Unemployed Chagev village, M.Mirshakar Sangmamadov Dodmamad Unemployed Chagev village, M.Mirshakar Niyatshoev Ram Unemployed Chagev village, M.Mirshakar Rakhmonov Daler Unemployed Chagev village, M.Mirshakar Qishqorbekov Qishqorbek Unemployed Chagev village, M.Mirshakar Davlatali Nazaraliev Unemployed Chagev village, M.Mirshakar Azizov Tulfor Unemployed Parzudj village, M.Mirshakar Ismoilov Khamza Unemployed Parzudj village, M.Mirshakar Ismoilov Maqsudsho Unemployed Parzudj village, M.Mirshakar Azizkhonova Nodira Unemployed Parzudj village, M.Mirshakar Zarifbekov Gulayoz Unemployed Parzudj villagte, M.Mirshakar Shirinbekov Immat Unemployed Sebzor village, Tusyon Jamoat Navruzov Gulayoz Unemployed Sebzor village, Tusyon Jamoat Ibrohimov Qurbonsho Unemployed Sebzor village, Tusyon Jamoat Abdulamidov Gulrukh Unemployed Sebzor village, Tusyon Jamoat Nazaraliev Qambarali Unemployed Parzudj village, M.Mirshakar Mabatshoev Mavjigul Unemployed Parzudj village, M.Mirshakar Mavlonazarova Zilamo Unemployed Parzudj village, M.Mirshakar Saidshamsova Sarfiyamo Unemployed Parzudj village M.Mirshakar Chaqaboev Farhod Unemployed Parzudj village M.Mirshakar Bekdavlatova Surayo School Director Sebzor village, Tusyon Jamoat Devonaeva Nazribegim Unemployed Chagev village, M.Mirshakar Zavqibekov Zokir Unemployed Chagev village M.Mirshakar Dovutov Eraj Unemployed Chagev village, M.Mirshakar Bakhtshoeva Jamila Unemployed Chagev village, M.Mirshakar Ismoilov Olimsho Unemployed Chagev village, M.Mirshakar Rakhmatov Rakhmat Unemployed Parzudj village, M.Mirshakar Tilloeva Nasrigul Unemployed Chagev village, M.Mirshakar Ambarob Dildor Unemployed Chagev village, M.Mirshakar Ibrophimov Mehrubonsho Pensioner Dashtak village, Mirsaid Mirshakar Annex 3. Minutes of Consultation Meeting on Khorog-Qozideh 110kV Transmission line in Andarob and Qozideh Villages (Ishkashim District, GBAO) MINUTES OF MEETING PROJECT NAME Tajikistan Rural Electrification Project VENUE DATE OF MEETING Andarob and Qozideh villages of Ishkashim district, Viloyati 29&30/04/2019 Mukhtori Kuhistoni Dadakhshon (VMKB) PRESENT A.Mamadatoeva – Senior Environmental Officer, Pamir Energy Mirzo Gulomaseynov – Head of the Territorial Energy Complex (TEC) of Pamir Energy G. Mamadambarova – Call Center Operator, Pamir Energy D.Bakhtibekov – BDU Engineer Pamir Energy N. Shoskandarov – GIS specialist Pamir Energy R.Khushqadamov- PR Specialist, Pamir Energy R.Ustoboeva- Report Officer of Pamir Energy The community members [the list of participants is attached] 1. Summary For the consultative meeting (on TREP construction and operation of a 63-kilometer (km) 110kV transmission line between Khorog substation and a new substation near Qozideh, particularly E&S documentation) all village residents were invited and about 48 community members gathered and participated in the meeting. The first day meeting was held in Andarob village and members from four villages (Sist, Kuhi- La’l, Khaskhorug and Andarob) have participated. The second day meeting was held in Qozideh village and participants form remaining 4 villages (Shanbedeh, Vozg, Barshor, Qozideh) have participated. They received information and details about the planned project implementation as well as related environmental and social impacts that were identified in recent assessments. Andarob and Qozideh villagers very much welcome the project’s implementation. They expressed no objection or concern related to the project and its impacts as they are generally very hopeful that it will contribute to positive developments for their village. Primarily, employment opportunities and compensation (in-kind) for potential loss of land were the main point of community interest an discussion. 2. Welcome and Introduction An introductory speech was made by the chairman of Qozideh Jamoat, Mr Sayfov Amonullo, who welcomed the representatives of Pamir Energy Company (PE) and expressed his opinion and the opinion of the local community about how pleased they are that the company had launched rural electrification project in VMKB and how they are going to benefit from it. Mr. Mirzo Gulomaseynov, the Head of TE, a representative of PE, presented the Tajikistan Rural Electrification Project that was developed as part of the Government of Tajikistan and PE initiative on electrification of the transmission line population in VMKB and Khatlon regions in cooperation with the World Bank (WB). He mentioned that although within 16 years of operation, the company has significantly increased energy availability for 218,000 people (96% of the population) in Eastern Tajikistan, there are still 12,286 people, residing in 61 villages of VMKB, without electricity. Therefore, the given project aims at electrification of these people through the construction of hydropower plants, through the construction of transmission lines. The project will be financed by the WB. Along with the requirements of the legislation of the Republic of Tajikistan, as a precondition for financing, the WB also requires several activities including the environmental and social assessment, according to Mr. Mirzo. As to the environmental and social impacts of the project components; the Sebzor hydropower plant and the associated 18 km transmission line as well as the 63km transmission line will be assessed in an Environmental and Social Impact Assessment (ESIA), which was presented to participants by Pamir Energy’s Senior Environmental Officer Ms. Mamadatoeva. The purpose of this Environmental and Social Impact Assessment (ESIA) is to provide an environmental and social assessment of the project in order to identify potential environmental and social risks throughout construction and operation. It was further explained that the ESIA will guide Pamir Energy in determining what additional surveys or studies are needed and in determining the requirements that need to be placed in contracts for final design and construction of the transmission line and substation so that environmental and social impacts are managed and mitigated in accordance with World Bank ESF requirements and Tajikistan law. Community member were informed that the environmental and social assessment helps to determine the potential environmental and social effects of the project and as Ms. Asligul Mamadatoeva noted also identifies if additional research/assessment will be needed and conducted on individual project components or aspects, which are listed in the brochures which will be distributed at the end of the presentation. For instance, as a common practice, while implementing such projects, a plan for resettlement and compensation is developed. An example of the socio-economic aspect would be not only electrification of the targeted areas, but also employment opportunities for the local population. Ms.Mamadatoeva also highlighted that Pamir Energy will design the transmission and distribution lines in a way that it will not result in any displacement. However, when towers are built on agricultural or other productive lands, it will take measures that people who are currently using the small plots of land are compensated for taking off their lands for towers. In-kind compensation is the preferred means of compensation that Pamir Energy generally aims to use in its projects, according to Ms Mamadatoeva. According to the representative of Pamir Energy Mr. D.Bakhtibekov. In 2013, with the support of foreign donor ‘Norway’ project Ishkashim 1 invested in the 110kV transmission infrastructure with local company Badakhshan TADES from Khorog to Gojak. So far, in the area of Andarob, due to a variety of hazards in winter this building has suffered much damage. Since then the year changed the transmission line with the machining facilities. In this building the number of local residents reached 40 years in high quality in the past six months. In the current year, the World Bank decided to export electricity to an amount of 8,429617 US dollars from Andarob to Hosseinii. The 110 kV power line is created from 63km, with a capacity of 110/35 kV. This construction is mainly focused on the Afghan population. The construction consists of mechanical bases that will last for 2,5 years, and during the construction work, there will be need for a lot of staff from 120 to 150 people. Detailed information on the project as well as the developed documents on environmental and social aspects of the projects are available on the PE website, the brochures and newspapers (developed by PE) that are distributed by Gulnor Mamadambarova, as well as on the regional newspaper – “Badakhshon” and messages sent to consumers via phones. The link to the website is provided in the PE newspapers that were distributed during the meeting. The dates for consultative meetings with the local communities for each targeted village under the project are indicated in the newspaper. That is why we are here today – emphasized Mr D.Bakhtibekov, to present the project’s objectives and activities as well as to know the communities’ opinions as stakeholders and to answer their queries. 3. Questions and Answers Mr.Khasanov Mehrobsho, the Leader of the Jamaat expressed his gratitude to the representative of Pamir Energy company for the meeting with the local community and mentioned that as electricity is the basic need for human beings, the community is glad that PE started implementing the project and expressed his as well as community’s willingness to assist in the timely implementation of the project. He further queried the implementation period of the project. Mr Bakhtibekov responded that the project implementation period. The construction consists of mechanical bases that last for 2,5 years, and during the construction work, we need a lot of staff from 120 to 150 people as he mention above The community also queried the staff –who will be working during the operational stage at the HPP? Ms. Mamadatoeva replied that the PE staff as well as local residents, who will be selected based on the required qualifications i.e. with relevant technical knowledge and education 4. Closing Remarks At the end of the meeting, brochures and regional and PE’s newspapers were distributed to all the participants. The pictures of the meeting and the list of participants with their signatures are attached. Signatures of PE representatives: /s/ A Mamadatoeva /s/ G.Mamadambarova /s/ N.Shoskandarov /s/ R.Khushqadamov /s/ R.Ustoboeva Participants in Consultation Meetings in Andarob and Qozideh Full Name Position Location Shodmamadov Ikrombek Unemployed Qozideh village. Mazamov Musamir Policeman Qozideh village Zamirov Islombek Landstore Andarob village Khudoyorov Olimjon Teacher Andarob village Sobirov Khudonazar Teacher Andarob village Mastibekov Mamadrahim Teacher Khaskhorog Surobov Sharob Teacher Khaskhorog Zanjirbekov Khanjar Unemployed Khaskhorog Odilbekov Intizor Unemployed Dasht village Anoyatbekov Khanjarbek Unemployed Anderob village Muzofirbekov Qudratbek Unemployed Anderob village Palavonbekov Noyob Pensioner Dasht village Utalbekov Azam Unemployed Dasht village Rajabov Usmon Unemployed Dasht village Sarvarov Shokir Unemployed Sizd village Ibrohimov Rashid Unemployed Sizd village Shirinbekov Anvar Unemployed Kuhi lal village Ismoilbekov Bakhtali Unemployed Andarob village Poyandaev Aydimamad School Director Kuhi lal village Jumakhonov Qahramon Unemployed Andarob village Khudoyorov Bahrom Teacher Andarob village Shirinbekova Jonamo Unemployed Qozideh village Rakhmondodova Inobat Unemployed Andarob village Davlatmamadova Lutfiya Unemployed Qozideh village Odinaev Umed Unemployed Kuhi Lal village Safarov Abdul Unemployed Kuhi Lal village Qurbonbekov Khanjar Unemployed Qozideh village Odilbekov Oshurbek Unemployed Dasht village Masaylov Salmon Unemployed Dasht village Safoev Khushqadam Unemployed Andarob village Odilbekov Khudoyor Unemployed Dasht village Shirinbekov Bakhtali Teacher Dasht village Nazarov Amirkhon Unemployed Kuhi Lal village Poyandaev Sojidkhon Unemployed Kuhi Lal village Aslamov Zokir Unemployed Andarob village Shosafobekov Sharaf Unemployed Andarob village Shodmonov Iftikhor Unemployed Andarob vilalge Chorshanbiev Payshanbe Teacher Andarob village Shosafobekov Alimamad Unemployed Andarob village Odinaev Davlatyor Unemployed Andarob village Mastibekov Roziq Unemployed Khaskhorog village Ismatulloev Mamed Unemployed Qozideh village Palavonbekova Ashrafmo Unemployed Andarob village Abdurahimov Jurabek Teacher Qozideh village