M-KAT Green SOLAR POWER PLANT

M-KAT Green SOLAR POWER PLANT

 

STAKEHOLDER ENGAGEMENT PLAN

 

Revision 0

 

 

July 2018

Content

1.. INTRODUCTION. 1

2.. Legal Framework. 1

3.. Summary of the Project Stakeholders Engagement and Information Disclosure to Date 2

4.. STAKEHOLDER IDENTIFICATION AND ANALYSIS. 2

4.1 Stakeholders and Information Needs. 2

4.2 Local Authorities and Regulators. 2

4.3 The Project Workers. 3

4.4 Suppliers of Goods and Services. 3

4.5 Local Population. 4

4.6 Local Media. 4

4.7 Non-Governmental Organizations. 4

5.. Vulnerable groups. 4

6.. Stakeholder engagement and Information Disclosure Mechanism.. 5

7.. RESOURCES AND RESPONSIBILITIES. 5

8.. MONITORING AND REPORTING.. 6

9.. GRIEVANCE REDRESS MECHANISM.. 6

ABBREVIATIONS

CLO    Community Liaison Officer

CSRP  Corporate Social Responsibility Program

EBRD European Bank for Reconstruction and Development

EIA      Environmental Impact Assessment

LLP     Limited Liability Partnership

LRP     Livelihood Restoration Plan

NGO    Non-Governmental Organization

OVOS  Environmental Impact Assessment based on Russian standards 

PR       Performance Requirement of the EBRD Environmental and Social Policy 2008

SEP     Stakeholder Engagement Plan

SPP     Solar Power Plant

     

INTRODUCTION

This Stakeholder Engagement Plan (SEP) describes M-KAT Green LLP’s (the Company)  approach to interacting with stakeholders, including the general public, and the disclosure of relevant information with respect to Company’s current operations and the 100MWac solar photovoltaic power plant M-KAT (SPP) construction plans (the Project).

The SEP includes a strategy to provide timely, meaningful and appropriate information to stakeholders and ensure the opportunity for such stakeholders to express their views and comments. The SEP provides a mechanism for the consideration and response to comments and potential grievances raised by stakeholders. Engagement with stakeholders is an ongoing process, which applies to the entire period of the project implementation and operation.

The Project aims to provide sustainable and environmental and socially friendly source of renewable electrical energy for the region to reduce energy deficit and allow further economic development and creation of new jobs. Few jobs will be created for the local unskilled labour, but presence of the SPP may lead to knowledge transfer and encouragement of the targeted education among the local school graduates. Indirect benefits are expected to be minimal or none.

Legal Framework

The activities specified in this plan conform to Kazakhstan legislation including ratified by Kazakhstan international conventions and the EBRD Performance Requirement 10 for information disclosure and stakeholder engagement. The project will be designed to meet best international practice. Table 1 summarizes the Kazakhstan and EBRD requirements.

Table 1 Stakeholder consultation requirements summary

EBRD PR10 requirements

Kazakhstan Requirements

Identify people or communities that are or could be affected by the project, as well as other interested parties. Ensure that such stakeholders are appropriately engaged on environmental and social issues that could potentially affect them through a process of information disclosure and meaningful consultation. Maintain a constructive relationship with stakeholders on an ongoing basis through meaningful engagement during project implementation. Begin consultations early in the environmental and social appraisal process. Throughout the life of the project provide ongoing information to identified stakeholders, commensurate to the nature of the project and its associated environmental and social impacts, and the level of public interest. Stakeholder engagement will be free of manipulation, interference, coercion, and intimidation, and conducted on the basis of understandable and accessible information, in a culturally appropriate format; If required by the EBRD, Stakeholders should be able to provide comments and recommendations on the draft Stakeholder Engagement Plan; Disclose a non-technical summary in the Kazakh and Russian languages and in accessible and culturally appropriate manner, Tailor stakeholder engagement to the needs of any disadvantaged or vulnerable groups; Publish regular reports to external stakeholders on the Company environmental and social performance; Establish a grievance mechanism, inform the affected communities and ensure that the mechanism addresses concerns promptly and transparently, in a culturally appropriate manner, and is readily accessible to all stakeholders.

Stakeholder identification is not required. Relevant regulatory bodies to be identified Public notice to be published in two local newspapers in Kazakh and Russian languages 20 days before the meeting that ends the consultation. Local council shall be consulted on the time and place of a public meeting and invited to it. Stakeholders shall be engaged and project information disclosed 20 days before the EIA is submitted to the State Environmental Expertise for approval. Grievance mechanism shall comply with the Law on Grievances Handling procedures № 221-III 12.01.2007

The Project Workers

The project workers and the contractors will be informed on the employment conditions, on changes to the work requirements and likely duration of their involvement. The grievance handling mechanism will also be explained.

Table 2 Project stakeholders and information disclosure methods

Stakeholder	What to disclose	How and Where	When
Alga rural area council	NTS, SEP, bulletins employment plans, CSRP discussion results	Telephone, email, formal letters hand delivery if required and meetings at the council office	As soon as possible
District and regional regulatory bodies	EIA, vacancies, formal reports	Formal submissions  through Shu Public Servicing Center, Job Center and Social Protection Office	As required by legislation
Project workers	Employment conditions, grievance mechanism with changes	Information board at SPP onsite office	Before construction starts then continuously
Suppliers of goods and services	Early warning on required services and significant changes in demand. EHS project requirements	Project related website and email after subscribing on the website	As soon as possible
Job seekers	Vacancies and list of professions that would be required at the plant during operation	Project information board at Alga shop,, notes to local newspapers, points of contact, formal reports to  Shu job center and Social Protection Office, website
Alga and Sauytbe residents	NTS, SEP, bulletins, vacancies, Corporate Social Resp. Program	Project information board at Alga shop, whatsap group on request	Before construction starts bulletins once a month
Vulnerable groups	NTS, SEP, bulletins Specific impact and work schedule, LRP	Visits, telephone, email bulletins, text messaging of any changes
Local media	1.NTS, SEP, 2. detailed project information on request	1. Website, 2. emails to points of contact, press-releases	At start of construction and on commissioning
Local and international NGOs	NTS, SEP, project schedule, extracts from annual report	Website notes and mailing if registered	As per EBRD disclosure requirements

Local Population

The local population is represented by the rural area Public Governance Council and organised by the rural area councillor. The Alga and Sauytbe residents are expected to be interested in the project related jobs and qualification improvement opportunities in the nearest future and in a longer perspective. The CLO will disclose the list of professions that will be required by the project at each phase, regular information on the work progress and the grievance mechanism.

The project information location will be disclosed through the local mass media. The media will also be fed with the project updates regularly and will be expected to disclose it. A local shop at the central crossing of Alga village was suggested to be the most appropriate place for sighting the project information.

Local Media

The CLO will identify a point of contact in the popular regional newspaper Shu Dolina and provide him with initial project information, impacts, benefits and opportunities, explain grievance mechanism and give detailed project information on request. The paper is expected to disclose the project information to a wider audience in an accessible and culturally acceptable form.

MONITORING AND REPORTING

The Company will analyse received grievances and given answers at the end of each month.  The CLO will report annually on environmental and social performance, implementation of commitments in the environmental and social action plan, and the implementation of the grievance mechanism. The report will be posted on the project related website and in the locations stated in Table 2.

GRIEVANCE REDRESS MECHANISM

If someone has a complaint or grievance, this will be dealt through grievance and application register or a grievance mechanism that will be managed by the CLO. The objective is to resolve problems in a timely manner. The mechanism will be displayed at the locations shown in Table 2.

The stakeholders can submit their grievance in a box on the information boards, call or write a letter or an email to the CLO who will enter it in the grievance database (Table 3). The database is for controlling the grievance handling process. This mechanism does not limit the public’s rights to use the conventional routes to place grievances and the available legal system.

Depending on the grievance form, the CLO will reply accordingly, as shown in the flowchart below, ensuring that the grieved party knows their rights, the date when the reply is due and that the grievance will not be closed until the party is satisfied with the answer or choose to follow further complaint procedures given below.

Table 3 Grievance database fields. ID example stands for the first questions on September 29^th.

Grievance ID	Name / address	Question /Grievance	Answer method	Given answer	Status	Is response satisfying
2018.09.29.01			Text to mobile		reply date, closed etc.	yes, no

Further complaint procedures:          

1. Write a formal complaint to the Alga rural area council, request the reply date;

2. Write a formal complaint to the Shu town Prosecution Office;

3. Appeal to the Aarhus Convention Implementation Committee by calling to 8 (7172) 799 644 or sending an email to aarhus@inbox.ru

 

GRIEVANCE FORM

Reference No: