Environmental and Social Impact Assessment Volume 6 Stakeholder Engagement Plan

GEORGIA ELECTRICITY TRANSMISSION NETWORK DEVELOPMENT PROJECTS

Prepared for: GSE

SLR Ref:901.12.1 Version No: #1 July 2019 Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

BASIS OF REPORT

This document has been prepared by SLR Consulting Limited with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with GSE (the Client) as part or all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.

Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

CONTENTS

ACRONYMS

PREAMBLE

INTRODUCTION AND PROJECT OVERVIEW...... 1 1.1 Introduction ...... 1 1.2 Purpose and objectives of the SEP ...... 1 1.3 Project Overview ...... 2 1.4 Structure of the SEP ...... 4

REGULATIONS AND REQUIREMENTS ...... 5 2.1 Georgian Requirements ...... 5 2.2 International Requirements ...... 6

PROJECT STAKEHOLDERS ...... 8 3.1 Stakeholder identification and analysis ...... 8 3.2 Vulnerable groups and gender issues among affected people ...... 15 3.3 Categories of key stakeholders to engage with through the Project ...... 15 3.4 Stakeholder Register ...... 18

RESPONSIBILITIES AND RESOURCES ...... 19 4.1 Responsibilities ...... 19 4.2 Resources ...... 20

STAKEHOLDER ENGAGEMENT ACTIVITIES UNDERTAKEN ...... 22 5.1 Introduction ...... 22 5.2 ESIA Scoping Meetings ...... 22 5.3 ESIA Scoping Report ...... 28 5.4 ESIA Baseline engagement ...... 29

STAKEHOLDER ENGAGEMENT PROGRAMME ...... 31 6.1 Stakeholder engagement approach ...... 31 6.2 ESIA Disclosure & Consultation Phase ...... 33 6.3 Resettlement Action Plan consultation ...... 34 6.4 Engagement Activities during Construction Phase ...... 35 6.5 Engagement Activities during Operational Phase ...... 37

Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

GRIEVANCE MECHANISM ...... 39 7.1 Introduction ...... 39 7.2 Grievance process ...... 39 7.3 Grievance Records and Documentation ...... 42 7.4 Closure of Grievances ...... 42 7.5 Workers Grievance Mechanism ...... 44 7.6 GSE Contact Information ...... 44

MONITORING AND REPORTING ...... 46 8.1 Monitoring ...... 46 8.2 Reporting during Construction ...... 47 8.3 Reporting during Operation ...... 48

DOCUMENT REFERENCES

TABLES Table 1.1 Outline of Project Components ...... 3 Table 2.1 International Lenders’ E&S Safeguard Policies on Stakeholder Engagement ...... 6 Table 3.1 List of stakeholders and their interest in the Project ...... 10 Table 3.2 Key Stakeholders ...... 15

FIGURES Figure 1 Project Components Figure 2 Project Development Flowchart Figure 3 Grievance Management Process

APPENDICES Appendix 01: Progress regarding the local EIA process and local disclosure Appendix 02: Issues raised during Scoping meetings with Municipalities Appendix 03: Minutes of meeting from Scoping Meeting with Government Departments Appendix 04: Complaints and Grievance Submission Form

Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

Acronyms Acronym Description

APA Agency of Protected Area CLO Community Liaison Officer CSR Corporate Social Responsibility EBRD European Bank for Reconstruction and Development EIA Environmental Impact Assessment EPC Engineering-Procurement-Construction EPP Emergency Preparedness and Response Plan E&S Environmental & Social ESIA Environmental & Social Impact Assessment ESMS Environmental & Social Management System EU European Union GEL Georgian Lari GSE Georgian State Electrosystem HPP Hydropower Project HS Health & Safety IFC International Finance Cooperation MEPA Ministry of Environment Protection and Agriculture Georgia NACHP National Agency for Cultural Heritage Preservation of Georgia NGO Non-Governmental Organization NTS Non-Technical Summary OECD Organisation for Economic Co-operation and Development PAP Project Affected People PS IFC Performance Standards SEP Stakeholder Engagement Plan

Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

Preamble This document is the Stakeholder Engagement Plan (SEP) of the Georgian Electricity Transmission Network Development projects (Project). It forms Volume 6 of the Environmental and Social Impact Assessment (ESIA) Report. The Project being developed by the Georgian State Electrosystem (GSE) comprises the construction of new and in some cases rehabilitation of existing transmission lines and substations. In summary, the Project is formed into 5 geographical component areas (Project Components), Components A, B, C1, C2 and D. Each new or rehabilitated line and substation is given a Project name which is used throughout the documents. The following table provides an overview of the Project Components and the Project names: Component Line description Project name

A - Tskaltubo to Akhaltsikhe and on to Turkey border at Vale: Samtskhe- - 500kV Tskaltubo to Akhaltsikhe Substation Sairme line Javakheti - 400kV Akhaltsikhe to Turkey border (and on to Tortum in Turkey) Tao line & Imereti - Extension to the existing Akhaltsikhe Substation Akhaltsikhe extension B - Guria Ozurgeti to Zoti HPP and connection from Ozurgeti to the Paliastomi line: - 110kV Ozurgeti to Zoti HPP powerhouse Guria line - 220kV Ozurgeti to Paliastomi loop in connection Paliastomi loop - 110/220kV Ozurgeti Substation Ozurgeti Substation C1 - Nenskra to Mestia: Svaneti - 110/220/500kV Nenskra Substation Nenskra Substation - 110kV Nenskra substation to Mestia HPPs Mestia line -500kV Kavkasioni loop in loop out to Nenskra Substation Kavkasioni loop C2 – Racha Lajanuri connections to Kheledula HPP, Oni HPP and Tskaltubo: Lechkhumi - 110/500kV Lajanuri Substation Lajanuri Substation & Imereti - 220kV Lajanuri to Oni HPP Oni HPP line - 220kV Lajanuri to Kheledula HPP Kheledula HPP line - 500kV Lajanuri to Tskaltubo Lechkhumi line - 220kV Lajanuri HPP to Lajanuri Substation Lajanuri HPP line - 220kV Rehabilitation of the existing 220kV Derchi line from Lajanuri to New Derchi line Tskaltubo, with new connections into Namakhvani Cascade HPP- D - Kakheti Reinforcement of the transmission infrastructure in Kakheti: - 110/220kV line from Gurjaani to Telavi Gurjaani line - 110kV line from Telavi to Akhmeta, constructed on 220kV towers Akhmeta line - 110kV loop to Tsinandali Tsinandali line - 110kV loop to Mukuzani Mukuzani line - Rehabilitation and extension of 110kV Akhmeta Substation Akhmeta Substation - Rehabilitation and extension of 110/220kV Telavi Substation Telavi Substation - Rehabilitation of 110kV Tsinandali Substation Tsinandali Substation - Rehabilitation of 110kV Mukuzani Substation Mukuzani Substation

Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

Component Line description Project name

- Rehabilitation and upgrade of 110/220kV Gurjaani substation Gurjaani Substation

An ESIA has been undertaken of the Project in accordance with international guidelines, including EBRD and KfW policies, European Union directives and Georgian legislation. The ESIA has considered and influenced the design and routing of the Project to avoid the most significant environmental impacts. Where impacts are predicted the ESIA identifies measures that can be adopted to avoid or reduce the impacts. In some cases compensation is proposed. The measures put forward by the ESIA are used to form the Environmental and Social Management Plan (ESMP) found in Volume 8 of the ESIA. This is the document that will be used by GSE, to ensure that the Contractors building the Project do so in a way that meets the outcomes of the ESIA process, by implementing the environmental and social measures being proposed. The ESIA Report is formed of a number of volumes and documents, as follows: • Volume 1 – Non Technical Summary; • Volume 2 –Project Definition – including Project introduction, need and alternatives and project description; • Volume 3 – Biodiversity: o Document 3.1 Biodiversity Project-wide assessment o Document 3.2 Biodiversity Project Component Specific assessment o Document 3.3 Biodiversity figures o Document 3.4 Biodiversity appendices • Volume 4 – Social – including assessments on people, communities, the economy, cultural heritage and Electromagnetic Fields (EMF): o Document 4.1 Social Project-wide assessment o Document 4.2 Social Project Component Specific assessment • Volume 5 – Physical Environment– including assessments on landscape and visual, noise, air quality: o Document 5.1 Physical Environment Project-wide assessment; o Document 5.2 Physical Environment Project Component Specific assessment; • Volume 6 – Stakeholder Engagement Plan (SEP) (this report); • Volume 7 – Land Acquisition, Resettlement and Compensation Framework (LARCF); • Volume 8 – Environmental and Social Management Plan (ESMP): o Document 8.1 Project-wide ESMP; o Document 8.2 Transmission lines ESMP; o Document 8.3 Substations ESMP.

Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

Introduction and Project Overview

1.1 Introduction This report presents the Stakeholder Engagement Plan (SEP) which has been prepared as part of the Environmental and Social Impact Assessment (ESIA) studies for the Georgia Electricity Transmission Network Development Projects (the Project) being implemented by the Georgian State Electrosystem JSC (GSE). This SEP has been developed, and will be implemented by GSE. Stakeholder engagement is a key element of the ESIA process defined by the requirements of the Lenders, in this case EBRD and KFW and regulations written into Georgian legislation. This SEP is prepared in compliance with the Lenders’ Policies regarding stakeholder engagement and Georgian legislation (for details refer to Section 2.0 Regulations and Requirements of this SEP). In order to comply with both local Georgian requirements and those of the Lenders, two environmental reports will be prepared: • An Environmental Impact Assessment (EIA) Report, in accordance with Georgian regulations; and • An ESIA Report, in accordance with the Lenders’ requirements. This SEP is primarily focused on the requirements of the Lenders and the ESIA Report; however, the stakeholder engagement associated with the EIA Report is also referenced. The purpose of stakeholder engagement is to enable stakeholders to engage with the decision making process, express their views and influence mitigation and technical solutions. This document will be updated to reflect the consultation process undertaken as the Project progresses, with the final version being available with other ESIA documents at disclosure.

1.2 Purpose and objectives of the SEP The purpose of this version of the SEP is to describe the stakeholder engagement activities completed to-date and to outline the management and planning responsibilities of activities during the remaining development, construction and operational phases of the Project. It also sets out the proposed information disclosure process, and details of future meetings and consultations with Project Affected People (PAP) and interested stakeholders. This issue of the SEP, which is being prepared ahead of the public disclosure of the draft ESIA Report, describes how informed participation with the stakeholders has been carried out during the preparation of the draft ESIA Report and outlines how responses received during public disclosure will be recorded and considered. The document also outlines how the consultation process will continue and the responsibilities for its execution and delivery. New stakeholders identified through the Project development and construction phases will be added and considered within the SEP. The SEP will continue to evolve as the Project progresses through construction and operation. The SEP reporting the engagement process and its outcomes will be publicly disclosed as part of the final submission of the ESIA documents. Stakeholder engagement provides the basis for PAP to participate in the Project through awareness and sharing their feedback. It enables the incorporation of all relevant views of PAP and other stakeholders into decision-making and Project implementation. The aim of the stakeholder engagement is to build a trusting relationship with the local communities and other interested stakeholders based on a transparent and timely supply of information and open dialogue.

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The SEP includes a grievance mechanism so that stakeholders and the public can raise any concerns, provide feedback and comments about the Project, company’s operations and are informed how those complaints/comments will be handled.

1.3 Project Overview

1.3.1 Project developer The Project is being developed by Georgian State Electrosystem JSC (GSE) (Project Company). The Project’s main funders are the European Bank for Reconstruction and Development (EBRD) and the KfW Development Bank (KfW).

1.3.2 Type of project and project location The Project is part of a wider programme being implemented under a 10 year programme by GSE to strengthen the power transmission grid in Georgia to improve cross border trade opportunities, to meet increased power demands and to connect existing and planned power projects, principally the growth of hydropower (HPP). The Project comprises the development, rehabilitation and replacement of transmission lines, construction and/or extension of substations and development of associated infrastructure (e.g. access roads, construction camps) and comprises five main components: • Component A - Tskaltubo to Akhaltsikhe and on to Turkey border at Vale; • Component B - Ozurgeti to Zoti HPP and connection from Ozurgeti to the Paliastomi line; • Component C1 –Nenskra to Mestia; • Component C2 - Lajanuri connections to Kheledula HPP, Oni HPP and Tskaltubo; and • Component D - Reinforcement of the transmission infrastructure in Kakheti. All Project Components are planned to be commissioned during the course of 2021. The transmission corridors of these components will cross 6 regions: • Samtskhe-Javakheti (Component A) • Imereti (Component A and C2); • Guria (Component B); • Samegrelo-Zemo Svaneti (Component C1); • Racha-Lechkhumi-Kvemo Svaneti (Component C2); and • Kakheti (Component D). Full details of the Project are outlined in Volume 1 Introduction. A summary of the Project is given in Table 1.1. Figure 1 shows the project components and the municipalities crossed by the Project.

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TABLE 1.1 OUTLINE OF PROJECT COMPONENTS Component Line description Project name A Tskaltubo to Akhaltsikhe and on to Turkey border at Vale, comprising: - 500kV Tskaltubo to Akhaltsikhe Substation Sairme line - 400kV Akhaltsikhe to Turkey border (and on to Tortum in Turkey) Tao line - Extension to the existing Akhaltsikhe Substation Akhaltsikhe Substation extension B Ozurgeti to Zoti HPP and connection from Ozurgeti to the Paliastomi line, comprising: Guria line - 110kV Ozurgeti to Zoti HPP powerhouse Paliastomi loop - 220kV Ozurgeti to Paliastomi loop in connection Ozurgeti Substation - 110/220kV Ozurgeti Substation C1 Nenskra to Mestia, comprising: - 110/220/500kV Nenskra Substation Nenskra Substation - 110kV Nenskra Substation to Mestia HPPs Mestia line -500kV Kavkasioni loop in loop out to Nenskra Substation Kavkasioni loop C2 Lajanuri connections to Kheledula HPP, Oni HPP and Tskaltubo, comprising: - 110/500kV Lajanuri Substation Lajanuri Substation - 220kV Lajanuri to Oni HPP Oni HPP line - 220kV (operated at 110kV) Lajanuri to Kheledula HPP Kheledula HPP line - 500kV Lajanuri to Tskaltubo Lechkhumi line - 220kV Rehabilitation of the existing 220kV Derchi line from Lajanuri to New Derchi line Tskaltubo, with new connections into Namakhvani Cascade HPP

- 220kV Lajanuri Substation to Lajanuri HPP Lajanuri HPP line D Reinforcement of the transmission infrastructure in Kakheti, comprising: - 110/220kV line from Gurjaani to Telavi, constructed on 220kV towers Gurjaani line - 110kV line from Telavi to Akhmeta, constructed on 220kV towers Akhmeta line - 110kV loop to Tsinandali Tsinandali loop - 110kV loop to Mukuzani Mukuzani loop - Rehabilitation and extension of 110kV Akhmeta Substation Akhmeta Substation - Rehabilitation and extension of 110/220kV Telavi Substation Telavi Substation - Rehabilitation of 110kV Tsinandali Substation Tsinandali Substation - Rehabilitation of 110kV Mukuzani Substation Mukuzani Substation - Rehabilitation and upgrade of 110/220kV Gurjaani Substation Gurjaani Substation

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1.4 Structure of the SEP The SEP is structured as follows: • Section 1.0, Introduction - presents the purpose and objectives of the SEP, and an overview of the Project; • Section 2.0, Regulations and Requirements - describes the legal and Lenders’ requirements for the disclosure process; • Section 3.0, Project Stakeholders - identifies the Project’s stakeholders and any specific groups who might be considered vulnerable; • Section 4.0, Responsibilities and Resources - details the resources, management functions and responsibilities for the stakeholder’s engagement activities; • Section 5.0 Stakeholder Engagement Activities Undertaken – provides an overview of the activities undertaken prior to the disclosure of the ESIA Report package, including stakeholder meetings, and consultation on the scope of the ESIA studies. • Section 6.0, Stakeholder Engagement Programme - presents the program for stakeholder’s engagement activities during scoping, EIA/ESIA disclosure and construction and operation; • Section 7.0, Grievance Mechanism - explains the Project’s grievance mechanism; and • Section 8.0, Monitoring and Reporting during construction - describes the monitoring and reporting procedures for the SEP implementation.

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Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

Regulations and Requirements

2.1 Georgian Requirements

2.1.1 Constitution of Georgia The Constitution of Georgia was adopted in 1995 and while the constitution does not directly address environmental matters, it does lay down the legal framework that guarantees environmental protection and public access to information with regard to environmental conditions. Article 37, Part 3 states that “any person has the right to live in a healthy environment, use the natural and cultural environment. Any person is obliged to take care of the natural and cultural environment.” Article 37, Part 5 states that “an individual has the right to obtain full, unbiased and timely information regarding his working and living environment.” Article 41, Part 1 states that “a citizen of Georgia is entitled to access information on such citizen as well as official documents available in State Institutions provided it does not contain confidential information of state, professional or commercial importance, in accordance with the applicable legal rules.”

2.1.2 Public Consultation in the EIA Process In April 2000, Georgia ratified the Aarhus convention. This UNECE (United Nations Economic Commission for Europe) convention facilitates and regulates information availability, public involvement in decision making and access to justice for the field of environmental protection. It implements the principle of the need for involvement of all interested parties in order to enable environmentally responsible development. The Georgian legislation requires public consultation only for those projects which require Environmental Impact Assessment. These requirements were recently updated and are set out in the Code of Environmental Assessment (2017). This provides detailed requirements and procedures for conducting public consultations and established timeframes for information disclosure and discussion. The responsibility for the public disclosure now rests with the Ministry of Environment Protection and Agriculture (MEPA), such that the following is required: • The Scoping Report – a preliminary document prepared by the developer, which sets out the type of information to be gathered and examined during EIA, is made available by the Ministry on its official website as well as on the notice board of the relevant local authorities and/or representative bodies and upon request, provides hard or soft copies. The public has a right to provide its opinions and comments regarding the Scoping Report to the Ministry within fifteen days of publication. In addition, the Ministry is required to organize a public hearing no earlier than 10th working day and no later than 15th working day after the publication of scoping application. This is chaired and protocoled by the representative of the Ministry and is held in the closest appropriate administrative building to the site of the project or within its vicinity. Any person has a right to participate in it. Progress on this process is provided in Appendix 1. • The EIA Report - the Ministry must place the submitted application and attached documents on its official website as well as on the notice board of the relevant local authorities and/or representative bodies and upon request, provide paper copies. The public has a right to submit their opinions and comments to the Ministry regarding the EIA Report, proposed development and conditions of the Environmental Decision, within forty days after the publication of the application. In addition, the Ministry is required to organize a public hearing no earlier than 25th working day and no later than 30th working day after the publication of the application. This is chaired and protocoled by the representative of the Ministry and is held in the closest appropriate administrative building to the site

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of the project or within its vicinity. Any person has a right to participate in it. The status of the EIA reports are outlined in Appendix 1. • Environmental Decision - the public must be informed about the decision and be able to access it. Any representative of the public has the right to appeal the decision if it is considered that the public authority in the decision-making process violated the requirements of the legislation.

2.2 International Requirements EBRD and KfW, as the Lenders, generally follow similar policy and procedures under their umbrella environmental or social policies. Table 2.1 shows the environmental and social performance/ safeguards/ requirements for stakeholder engagement for the two Lenders.

TABLE 2.1 INTERNATIONAL LENDERS’ E&S SAFEGUARD POLICIES ON STAKEHOLDER ENGAGEMENT

E&S Safeguards Standards for Stakeholder Engagement (2014) EBRD Environmental and Social Policy. Performance Requirement 10 “Information Disclosure and Stakeholder Engagement (2016) KfW Development Bank, Sustainability Section 4.6 of the Sustainability Guideline: Stakeholder Guideline Engagement and Complaints Management in FC Measures

International requirements regarding stakeholder engagement are more stringent than national ones. In addition to national requirements, the Project must: • Identify all stakeholders having an interest in or potentially affected by the Project; • Plan the engagement activities with stakeholders; • Define, disclose and implement a Grievance Management Procedure; • Undertake meaningful consultation; • Provide on-going reporting to relevant stakeholders; and • All the above must be culturally appropriate and take in to account gender issues as well as vulnerable groups. This SEP has been prepared to be in compliance with these requirements. The information that must be disseminated by a developer comprises: • The purpose, nature, scale and duration of the project activities; • Risks to, and potential impacts on, stakeholders and proposed mitigation plans; • The envisaged stakeholder engagement process and opportunities and ways in which the public can participate; • The time and venue of any envisaged public consultation meetings, and the process by which meetings are notified, summarised and reported; and • The process by which any grievances will be managed. With respect to scoping of the ESIA, for the purposes of the Lenders’ requirements, GSE has undertaken scoping meetings and published a Scoping Report (see Section 5.2) to establish the scope of the ESIA Report. It will then be GSE’s responsibility to present the draft ESIA Report to the public and undertake public hearing(s) for this at the time of disclosure for the project. This scoping phase and public disclosure consultation has been

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Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019 undertaken separately to the scoping consultation on the local EIA process for the Project which is run by the MEPA. GSE is preparing separate EIA reports for the different components of the Project. MEPA will publicize each of the Georgian EIA Reports and hold a public hearing at the Scoping stage for each component. After completion of the final EIA report another public hearing will be organised by MEPA, during which more details are presented about the Project. The developer must also establish a grievance process for the Project for receiving and dealing with any concerns and complaints of members of the affected public and employees. The procedure should be reasonable for and culturally appropriate to the development. Cases and processing results must be documented and form part of the reporting procedure. The proposed Grievance Mechanism for this Project is set out in Section 7.0, Grievance Mechanism of this Stakeholder Engagement Plan.

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Project stakeholders

3.1 Stakeholder identification and analysis Stakeholders are persons or groups: (i) who are directly or indirectly affected by a project; and/or (ii) who may have interests in a project or the ability to influence its outcome, either positively or negatively. The Project components cross the following regions: • Component A – Guria, Samtskhe-Javakheti and Imereti; • Component B – Guria, Adjara Autonomous Republic; • Component C1 – Samegrelo-Zemo Svaneti • Component C2 – Imereti and Racha-Lechkhumi-Lower Svaneti; • Component D – Kakheti. The Project will cross the following municipalities: • Component A –Tskaltubo; Vani; Adigeni; Akhaltsikhe, Chokhatauri,; • Component B - Ozurgeti; Chokhatauri, Kobuleti; • Component C1 - Mestia; • Component C2 - Tskaltubo; Lentekhi; Tsageri; Oni Tkibuli, Ambrolauri,;; and • Component D - Gurjaani; Telavi; Akhmeta. The Project will cross the following communities: • Component A – Chokhatauri district highlands, Kutaisi city (Banoja), Gumbra, Opshkviti, Dzulukhi, Zeindari, Amaghleba, Patriketi, Mukhiani, Kvitiri, Maghlaki, Saprasia, Zeda Vani, Gora, Akhaltsikhe district highlands, Vale, Sviri, Tsqruti, Skhvilisi, Varkhani, Agara, Klde, Persa, Pkhero, Adigeni district highlands, Arali, Eliatsminda and Benara; • Component B – Chokhatauri district highlands, Kakuti, Leghva, Ozurgeti district highlands, Naruja, Likhauri, Shemokmedi, Nabeghlav, and Makvaneti; • Component C1 – Lakhamula, Latali, Chuberi, Nakra, Etseri, Pari, Lenjeri, Becho and Mestia; • Component C2 – Dghnorisa, Rioni, Tskaltubo Community, Opurchkheti, Jvarisa, Mekvena, Ghvirishi, Khopuri, Khvanchkara, Lailashi, Bari, Usakhelo, Parakheti, Tvishi, Tsesi, Chqvishi, Alpana, Khodikari, Lentekhi, Sori, Rtskhmeluri, Orbeli, Chrebalo, Kveda Tsageri, Sadmeli; and Gumbra; • Component D – Vachnadziani, Shashiani, Kisiskhevi, Gurjaani city, Vazisubani, , Akhasheni, Chumlaqi, Gurjaani district highlands, Zemo Alvani, Telavis district highlands, Mukuzani, Kalauri, Kistauri, Ozhio, Telavi, Shalauri, Vardisubani, Zemo Khodasheni, Kvemo Khodasheni, Tsinandali, Akhmeta, Iqalto, Zemo Khodasheni, Ruispiri and Akura. In addition the Project will cross the self-governing cities of Kutaisi city (Component A) and Telavi city (Component D). Figure 1 maps the municipalities and communities crossed by the Project. These communities along the route that may be directly affected have been studied in detail, as set out in Volume 4 Social of the ESIA Report.

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Potential environmental and social impacts have been used to identify stakeholders. It is considered that the likely principal environmental and social impacts would be: • Generation of temporary employment opportunities and, thereby, the provision of an income source for workers and their families contributing to their wellbeing and enhancing their quality of life; • Displacement of people and economic activities (e.g., agricultural land) due to substation and tower footprint or conductor line right of way and safety restrictions; • Forestry and vegetation removal affecting biodiversity; • Construction effects (e.g. noise or temporary displacement of fauna) on biodiversity; • Construction effects from vehicles and machinery causing dust, noise, waste generation and traffic disturbance impacting people and communities; • Impacts on landscapes and people’s views; • Land degradation including sedimentation, pollution and damage due to geohazards; and • Impacts to birds either along important migration routes or breeding areas during construction and once constructed. Table 3.1 presents the main categories of stakeholders identified and outlines their potential interest in the Project. These categories are not exclusive. One individual can belong to several categories. For example, one affected person, or PAP, can also be employed by a sub-contractor of the Project and be a member of a non- governmental organisation (NGO) with an interest in the Project. Where consultation is via community representatives, GSE will make all reasonable efforts to verify that such persons do, in fact, represent the views of affected communities and that they are facilitating the communication process by communicating the information to their constituents and conveying their comments to GSE or the authorities, as appropriate. This list of stakeholders is likely to expand/change in composition as the Project moves through the development phases and through construction and operation. When deciding the frequency and the appropriate engagement technique used to consult a particular stakeholder group, three criteria must be considered: • The extent of impact of the Project on the stakeholder group; • The extent of interest and influence of the stakeholder group on the project; and • The culturally acceptable engagement and information dissemination methods.

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Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019

TABLE 3.1 LIST OF STAKEHOLDERS, THEIR INTEREST IN THE PROJECT AND ENGAGEMENT METHODS TO BE USED

Stakeholder group Interest in the Project

Scoping Meetings Meetings Scoping (undertaken) meetings Public meetings Private workshops and Media Mass Communication of Disclosure information written Liaison Community 1 – Project affected people (PAP) People affected by land acquisition: ◼ ◼ ◼ ◼ ◼ People losing assets and/or private land Loss of sources of income and/or means of due to Project’s land requirements; livelihoods. Entitled to compensation and People losing access to common livelihood restoration if significantly affected resources affected by project footprint. People residing in the Project areas (i.e. Potentially affected by disturbances caused by the ◼ ◼ ◼ ◼ ◼ along the transmission line route, the Project’s heavy vehicles traffic. access tracks and in vicinity of the proposed substations) Vulnerable households amongst the two Potentially disproportionally affected, potentially ◼ ◼ ◼ ◼ ◼ categories above less able to benefit from opportunities offered by the Project, and potentially specific difficulties to access and/or understand information about the Project and its environmental and social impacts and mitigation strategies People in the local communities wishing to Members of the local work force will be interested ◼ ◼ ◼ gain employment. in seeking out opportunities for work such as work associated with tree removal or general construction works

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Stakeholder group Interest in the Project

Scoping Meetings Meetings Scoping (undertaken) meetings Public meetings Private workshops and Media Mass Communication of Disclosure information written Liaison Community 2 - Internal stakeholders Employees of GSE Benefit from employment opportunities. ◼ ◼ ◼ Potential Health and Safety risks. Application of Labour rights. Contractors: e.g. Contractor, Benefit from employment opportunities. ◼ ◼ ◼ subcontractors, service providers, Potential Health and Safety risks. Application of suppliers (including security guards) and Labour rights. workers organisations 3 - External stakeholders National Government Departments:

Ministry of Economy and Sustainable Control the compliance with Georgian energy Development (formerly Ministry of policies during construction and operation and Economy), Ministry of Finance, Ministry promote economic development. of Regional Development and Infrastructure ◼ ◼ ◼ ◼ Ministry of Environmental Protection Make available and engage with the public on the and Agriculture Local Georgian EIA Scoping Report, EIA Report and Environmental Decision. Ensure that the environmental performance of the Project complies with Georgian legislation Agency for Protected Areas Responsible for the protected areas and proposed

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Stakeholder group Interest in the Project

Scoping Meetings Meetings Scoping (undertaken) meetings Public meetings Private workshops and Media Mass Communication of Disclosure information written Liaison Community protected areas that are or will be created in the vicinity of the Project. Ministry of Culture and Sport & Agency Need to be engaged about sites of potential for National Heritage Preservation archaeological interest that could be affected by the project, and about monuments of national interest in the vicinity of the Project. National Agency of Public Registry Will register land plots required by the Project

National Forestry Agency Will work with GSE in state owned forests to organise the removal of timber, distribution to local communities. Also will work with GSE for the planting of trees to compensate for tree removal during the Project. Local Government Departments (e.g. Protect the rights of the inhabitants in the project ◼ ◼ ◼ ◼ roads authorities, national agency for state area property, regional governments) Municipalities (Tskaltubo; Vani; Adigeni; Deputies elected by local population representing ◼ ◼ ◼ ◼ ◼ Akhaltsikhe, Ozurgeti; Chokhatauri; them. Receive and channel the grievances from the Kobuleti, Lentekhi; Tsageri; Oni; communities. Ambrolauri; Tkibuli; Mestia; Gurjaani; Telavi; and Akhmeta) Self-governing cities (Kutaisi city and Telavi

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Stakeholder group Interest in the Project

Scoping Meetings Meetings Scoping (undertaken) meetings Public meetings Private workshops and Media Mass Communication of Disclosure information written Liaison Community city) Gamgebeli (Mayor) representatives of the The representatives will receive and channel ◼ ◼ ◼ ◼ ◼ ◼ Municipalities in the Communities (Temi) information from/to the PAP, including grievances (see Section 3.1) Local religious authorities Need to be consulted and engaged for potential ◼ ◼ ◼ ◼ ◼ graves and cemeteries affected, as well as religious structures or places potentially affected or to which access could be impeded Civil Society Organisations (CSOs) and Ensure that environmental and social performance ◼ ◼ ◼ ◼ Non-Governmental Organisations (NGOs) of the Project is protecting the environment and on a national, regional and local level (e.g. affected people CENN, Sabuka, Ecovision, Green Alternative, BirdLife International, WWF Caucasus, Greens movement of Georgia, Friends of the Earth Georgia, Bankwatch, and also community based NGOs such as village development associations and co- operatives). Businesses and business organisations, Procurement and supply chain ◼ ◼ ◼ including Georgian Chamber of Commerce Potential environmental and social impact and Industry, Georgia Association of receptors e.g. wine growers Manufacturers, Georgia Food Industry Association, Wine Growers Associations

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Stakeholder group Interest in the Project

Scoping Meetings Meetings Scoping (undertaken) meetings Public meetings Private workshops and Media Mass Communication of Disclosure information written Liaison Community Institutions (e.g. universities, think tanks, Potential concerns regarding environmental and ◼ ◼ ◼ schools) social impacts Potential educational/outreach opportunities and to increase awareness and acceptance Press and Media Informing residents in the project area and the ◼ ◼ public about the Project implementation and planned activities. General public, tourists, jobseekers Potential general socio-economic impacts both ◼ ◼ adverse and beneficial Other Project developers reliant on or in May require operation of the Project to enable the ◼ ◼ ◼ the vicinity of the Project including export of power. Potential cumulative inputs. associated facilities and the Lenders for these projects (such as ADB, IFC). ◼ = Engagement method to be used

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3.2 Vulnerable groups and gender issues among affected people The vulnerable groups that may be differentially or disproportionately affected by the Project because of their disadvantaged or vulnerable status have been identified during the initial social baseline surveys undertaken in 2018. Vulnerable groups are those defined as: People who by virtue of gender, ethnicity, age, physical or mental disability, economic disadvantage, or social status may be more adversely affected by project than others and who may be limited in their ability to claim or take advantage of assistance and related development benefits. Following completion of the baseline socio-economic studies, it has been determined that there are no specific gender issues and that no stakeholder group are likely to be excluded from the consultation process. However, it may be possible in remote areas that some vulnerable groups, such as elderly, disabled and/or illiterate people could experience difficulty accessing info centres or meetings. To avoid these difficulties, GSE Community Liaison Officers will organise meetings in every community/village crossed by the transmission line to explain the Project to these vulnerable groups. Households that are currently considered likely to be vulnerable comprise those: • Registered as poor with the local social services; • Internally Displaced People; • With women-headed households; • With elder-headed households (≥ pension age) without any other household member bringing in income; and • Households headed by disabled people.

3.3 Categories of key stakeholders to engage with through the Project Engagement with a number of the above stakeholders shall be prioritised, in relation to the Project construction schedule and the existing social context and local acceptability of the Project, as presented in Table 3.2.

TABLE 3.2 KEY STAKEHOLDERS

Categories of stakeholders Issues & Concerns 1 Municipalities and local communities Represent the local communities and will receive and (Temi) channel any grievances from them. 2 People affected by land acquisition Consultation on compensations, mitigation measures and livelihood restoration program, engaging with vulnerable groups 3 People residing in the Project areas Constructions impacts, employment opportunities, engaging with vulnerable groups 4 National Governmental Departments Involvement in some of the mitigation measures of the Environmental and Social Management Plan (ESMP), as well as in the permitting processes 5 NGOs Compliance with international E&S standards & integration of the views of these NGOs into GSE environmental and

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Categories of stakeholders Issues & Concerns social management strategy 6 Other Project Developers Identification of interactions and cumulative impacts with other proposed developments 7 Wine growers’ associations Potential impacts of land take on vineyards Engagement activities with these categories of stakeholders are described below and in Section 5.0 - Stakeholder Engagement Programme.

3.3.1 Engagement with Municipalities and Local Communities (Temi) Engagement with the municipalities started with the Scoping Meetings, the purpose of which was to introduce the Project and to discuss the scope of the ESIA. These bodies will be consulted throughout the Project the frequency of which will depend on the issues being raised and sensitivity of the local environment. Consultation with the local communities started during the baseline survey phase and will be a key part of the public disclosure phase for the ESIA Report. The findings of consultation to date with municipalities is outlined in Section 5.2.1.

3.3.2 Engagement with People Affected by Land Acquisition People affected by the land take requirements of the Project will be engaged to negotiate compensation packages in a timely and culturally appropriate manner, following definition of the Project. The engagement activities with people affected by the Project’s land requirements will be guided by the Land Acquisition, Resettlement and Compensation Framework (LARCF) (Volume 7 of the ESIA). The activities required with those affected by land acquisition will involve negotiations with people affected at substation sites, the transmission line route and construction access and compound facilities. The following activities will be undertaken: • Identification of People Affected by land acquisition, initial introduction to the project and likely land take requirements; • Discussion of options to restore areas affected by temporary structures and options to enable access as far as is practicable during construction; • Discussion of compensation options for loss of assets and land that will be permanently or temporarily lost; and • Discussion of resettlement options for physically displaced people and assistance packages, including livelihood restoration. These activities will start in late 2018 following the development of the LARCF (Volume 7). This will provide the framework for negotiations with people affected by the project.

3.3.3 Engagement with people residing in the Project areas In addition to the land acquisition, resettlement and compensation process described above, those living in the area of the Project and which may be indirectly affected by its construction and operation, through for example noise, traffic and visual impacts, will be consulted through a range of public consultation methods, including public exhibitions, the project website and through the distribution of a leaflet via a leaflet drop, and through the mail. The leaflet will also be made available in a number of public buildings within the local municipalities.

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It is intended that these members of the public will be consulted directly in the first instance through the ESIA disclosure phase. Ahead of full public disclosure, some details of the projects have been made available through the publication of the ESIA Scoping Report, in some cases the local EIA Scoping Study public hearings, social baseline visits and interviews and information provided to the municipalities and local community leaders.

3.3.4 Engagement with National Government Departments The implementation of the Environmental and Social Management Plan (ESMP) of the Project (Volume 8) will require that GSE engages with several Government departments. The MEPA, the Agency for Protected Areas, National Agency of Forestry and other relevant stakeholders have been engaged through the Scoping Meetings and through one to one meetings to discuss the ESIA and a range of other issues such as tree clearance in the right of way. A Memorandum of Understanding listing the obligations of each party would be drafted. The MEPA will also be engaged with regards to their responsibilities to make available and engage with the public on the Scoping Report, EIA Report and Environmental Decision (MEPA). The Ministry of Economy and Sustainable Development will be engaged by GSE during 2018 to discuss the coordination between the various HPP initiatives and the provisions of the Project. The findings of consultation to date with government departments and agencies is outlined in Section 5.2.1

3.3.5 Engagement with NGOs The Project has identified interested NGOs and is engaging with them as required through the Project. Where relevant, NGOs have been consulted with regards to the scope of the studies and with respect to available baseline information. The Project will continue to engage with NGOs as the Project continues through Disclosure and beyond. In particular, BirdLife International and Sakubo will be engaged as there is a requirement for ongoing bird monitoring. Other NGOs will also be encouraged to contribute where there is ongoing disclosure of Project details through the construction process (see Section 6.5.4). The findings of the consultation undertaken to date with NGOs is outlined in Section 5.2.3.

3.3.6 Engagement with other Project Developers GSE will engage and co-ordinate with the developers of the power generation projects that will: • Require the commissioning of the Project to export the power generated by their development. Required timeframes and technological interactions will require careful design; and • Potentially have a cumulative impact with the Project that will require cumulative assessment and potentially require additional mitigation. These developers will be engaged by GSE during the detailed design to discuss the co-ordination between the various HPP initiatives and the provision of the Project. GSE’s engineering and environmental teams will also liaise with these developers on an ongoing basis, generally through correspondence and one to one meetings.

3.3.7 Engagement with Wine Growers’ Associations GSE will engage with wine growers’ associations where wine producing areas are crossed by the Project.

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3.4 Stakeholder Register GSE has developed and will maintain a stakeholder register per Project Component, which records all stakeholders, contact details, dates of engagement with comments. It will also documents any follow up requirements.

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Responsibilities and Resources

4.1 Responsibilities GSE has overall responsibility for leading and planning the stakeholder engagement process and the Grievance Resolution Mechanism (see Section 7.0, Grievance Mechanism). Stakeholders in the process also have some responsibilities and these together with the responsibilities of GSE are set out in Table 4.1.

TABLE 4.1 RESOURCES AND RESPONSIBILITIES

Resources Responsibilities GSE • Planning and implementation of the SEP; • Lead of stakeholder engagement activities; • Management and resolution of grievances; • Supervision of contractors; • Supervision/monitoring of Implementation Consultants; • Monitoring of environmental and social performance;

Implementation • Supervision/monitoring of Contractor; Consultants • Management of engagement activities during the construction phase;

Contractor • Inform GSE of any issues related to their engagement with stakeholders; • Transmit and resolve complaints caused by the construction activities in close collaboration with and as directed by GSE/Implementation Consultant and by participating in the local Grievance Resolution Committee (see Section 6.0 Grievance Mechanism); • Disclose a summary of the Traffic Management Plan; • Disclose a summary of the Recruitment Management Plan; • Disclose a summary of the Accommodation Plan; and • Inform local communities of any environmental monitoring e.g. noise, vibration, water quality monitoring; and • Announce important construction activities (such as road closures and available alternatives);

National Government • Monitor Project compliance with Georgian legislation; Departments • Participate in the implementation of some activities of the Environmental Ministry of Economy and and Social Management Plan; Sustainable Development, • Participate in the implementation of the Land Acquisition process; Ministry of Environmental Protection and • Make available and engage with the public on the Scoping Report, EIA Agriculture, Report and Environmental Decision (MEPA). Agency for Protected

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Resources Responsibilities Areas • Support distribution of timber to local communities Ministry Culture and • Support for compensation tree planting schemes Sport, and National Agency of Public Registry Municipalities and local • Transfer all complaints to the Project team; communities • Participate to the local Grievance Resolution Committee (see Section 7.0 Grievance Mechanism); • Make available the disclosed ESIA documents;

Project affected people • Invited to engage and ask questions about the Project at Project Meetings and through discussions with Community Liaison Officers where it is of interest or of relevance to them; • Lodge their grievances using the Grievance Resolution Mechanism defined in the SEP (Section 7.0 Grievance Mechanism); • Help the Project to define mitigation measures;

Other Project developers • Engage with GSE regarding project design; • Share ESIA information and documentation with GSE to enable the assessment of cumulative impacts

4.2 Resources GSE will mobilize human and material resources to implement the SEP and manage the Grievance Resolution Mechanism. A trained community liaison team appointed by GSE will take responsibility for and lead all aspects of the stakeholder engagement. The proposed staffing complement is anticipated to comprise: • A Community Liaison Officer in each Municipality crossed by the Project; • One Communication specialist and facilitator (employed during the main ESIA consultation phase); • A number of LARC Liaison Officers to meet the requirements of the Project; and • Two Environmental and Social Managers will be responsible for the environmental and social impact assessment and performance of the Project. Specific named personnel will be established for these roles as the project progresses. The material resources mobilized by GSE will be: • A Project specific area of the GSE website; • An electronic grievance database and an electronic stakeholder database; • Other material resources such as printed documents that will be used, based on the needs of the SEP. An annual budget will be provisioned in the Environmental and Social Management Plan to implement the stakeholder engagement activities.

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4.2.1 Website GSE has established part of the existing GSE website to present the Project and its social and environmental performance. This website is being used to disclose environmental information in Georgian and in English, following the principles highlighted in the United Nations Economic Commission for Europe Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (UNECE Aarhus Convention). Environmental and social performance of the Project is disclosed on this website. The results of the environmental monitoring processes during construction will be published. Half-yearly environmental and social reports will be available on the website. The availability of updated information will be advertised on the homepage of the website. An easy-to-understand guide to the terminology used in the environmental and social reports or documents available will be provided on the website. The website will also explain the Grievance Resolution Mechanism of the Project, provide an electronic complaint form, and contact details of the Community Liaison Officer. GSE will update the website regularly (at least once a quarterly basis) with environmental and social data and news on construction schedule and operation activities. This website will be available in readiness for the disclosure period starting in June 2019. The Project website address is http://www.gse.com.ge/projects/international-projects/Energy-Network-Improvement-Programme- ENIP.

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Stakeholder engagement activities undertaken

5.1 Introduction A number of engagement activities have been undertaken prior to the disclosure of the ESIA Report package. This engagement comprises the following activities which are described in more detail in the following sections: • ESIA Scoping Meetings with municipalities, government departments, government agencies and NGOs; • ESIA Scoping Report which was provided for comment to municipalities, government departments, government agencies, NGOs and which was made available on the GSE website in both English and Georgian; • Georgian EIA Scoping Reports and scoping meetings held by the Ministry of Environmental Protection and Agriculture with municipalities and local communities; and • Baseline ESIA engagement with NGOs and local communities.

5.2 ESIA Scoping Meetings During the ESIA scoping the focus was primarily on gathering environmental information and opinions from stakeholders regarding the scope of the necessary studies. Activities included engagement with stakeholder representatives (municipality and community (Temi) leaders and relevant government departments) and key information organisations (e.g. NGOs) using one-on-one meetings or by correspondence, workshops and smaller meetings. Within the overarching ESIA engagement objectives, the specific objective of engagement during this baseline phase was to: • Introduce the Project and ESIA process to these stakeholders; • Present the procedure to be followed with regards to the environmental and social assessment process; • Discuss environmental and social scoping, i.e. identify the main environmental and social aspects that could potentially be affected by the Project and the methodologies needed to assess these; • To understand any issues raised by stakeholders, which may have to be addressed or incorporated in to the Project design, mitigation measures, particularly where stakeholders have a potential role to play in these measures; • Further identify stakeholders related to the Project; and • Identify and gain access to relevant data for the baseline.

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5.2.1 Meetings with municipalities A series of Scoping Meetings have been held with representatives of the municipalities in areas affected by the project as outlined in Table 5.1.

TABLE 5.1 MUNICIPALITY SCOPING MEETING LOCATIONS AND DATES

Project component Date Location/Municipality A 18 April 2018 Vani 18 April 2018 Tskaltubo 23 April 2018] Akhaltsikhe 23 April 2018 Adigeni 23 April 2018 Chokhatauri 18 April 2018 Kutaisi city B 23 April 2018 Chokhatauri (as per Component A) 23 April 2018 Ozurgeti C1 26 June 2018 Mestia C2 18 April 2018 Kutaisi (as per Component A) 18 April 2018 Tskaltubo (as per Component A) 19 April 2018 Tsageri 19 April 2018 Lentekhi 19 April 2018 Tkibuli 20 April 2018 Oni 20 April 2018 Ambrolauri D 26 April 2018] Telavi 26 April 2018 Gurjaani 27 April 2018 Akhmeta

Those invited to attend the meetings comprised relevant representatives of municipalities through which the components pass. The issues raised during these meetings are outlined in Appendix 2 with a summary of the main issues summarised as follows: • Requests for more details on the transmission line routes and locations of the towers; • Concerns about impacts from EMF and ensuring safe distance from housing; • Interest in the land compensation process, in particular timing of the Project and process for registering unregistered land. Payment agreements should be made before any works; • Query about changes to electricity tariffs and whether there would be local distribution improvements; • Benefits to the community – opportunities for jobs;

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• Query on the link between the projects and HPPs, especially in Svaneti; • Requests for GSE to consider underground cables in places close to settlements; • Requests for the municipality be kept informed and told the route in advance so they can discuss with landowners; • Ongoing issues in Adigeni municipality associated with the Akhaltsikhe to Batumi line, due to access tracks blocking pasture lands. Such things should be avoided; • Request for the project in Akhmeta municipality be used to improve connections in Tusheti to improve tourism opportunities; and • Request for existing towers in Akhmeta be removed from built up areas and diverted away from settlements.

5.2.2 Meetings with Government departments and agencies Table 5.2 summarises the meetings held to date with government departments and agencies during the ESIA process.

TABLE 5.2 MEETINGS HELD WITH GOVERNMENT DEPARTMENTS AND AGENCIES Date Government Department/Agency

2 March 2018 Joint scoping meeting of government departments held at GSE office, Tbilisi

27 March 2018 Meeting with Deputy Head of Ministry of Environmental Protection and Agriculture (MEPA)

27 March 2018 Meeting with Biodiversity Department of MEPA

21 September 2018 Meeting with Deputy Head of National Forestry Agency

28 February 2019 Meeting with Deputy Head of National Forestry Agency

1 April 2019 Meeting with Biodiversity Department of MEPA

2 April 2019 Meeting with Forestry Department of MEPA

Joint Government Departments Scoping Meeting, 2 March 2018 The National Government Departments (i.e. the Ministry of Economy and Sustainable Development, MEPA, the Agency for Protected Areas and Ministry Culture and Sports and National Agency of Public Registry) were also consulted at the scoping stage, through a joint meeting held on 2 March 2018 that covered all components of the Project. During the Scoping Meetings, GSE provided the following information: • Outline proposals for the relevant component being discussed. The outline proposals provided details of connection points, alternative corridors and the selected corridor; • Outline of the ESIA process, the Lenders and Georgian requirements, summary of timescales involved and the roles and responsibilities of those attending the meetings; • Summary of the potential environmental and social effects associated with the project; and • Summary of baseline surveys undertaken or planned to be undertaken and their methodology.

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The meetings were led by GSE but with the support of their ESIA advisors in attendance to help field any technical questions. Appendix 3 provides a description of the issues raised with a response to how they have been addressed by the Project. The following summarised the key issues that were raised during the meeting: • Need to present evidence that alternatives have been adequately considered; • Avoidance of protected areas where possible must be achieved; • Landscape and visual impact in and near to protected sites which are important for promoting ecotourism as well as for biodiversity; • Bird surveys should be undertaken and appropriate mitigation considered; • Use of helicopters should be considered for difficult to access areas; • Emerald Sites present challenges and projects within these would not be approved unless the need and alternatives assessment demonstrated no other option; • Alignment with findings of the Energy Sector Strategic Environmental Assessment is needed; • Importance of obtaining official road and protected sites information; • EMF concerns on health of people and fauna; • Concerns about the need for resettlement; • New Forestry Code coming into force in 2022 – further consultation with the Forestry Agency needed; • Natural monuments database is currently being reviewed and updated – further consultation needed; and • Potential use of underground cables rather than overhead lines should be considered in sensitive areas. Responses to the meeting and minutes of meeting were received from the Agency of Protected Areas, the National Agency of Public Registry and the National Roads Department: • The National Agency of Public Registry are undertaking land registry work in Salkhino which they understand could be crossed by Component A and therefore wish to discuss the ownership/land use restrictions with GSE at a time when details of the routing are known; • The Agency of Protected Areas requested that priority be given to transmission line routes that have minimal impact on the environment and that the minutes of the meeting note that "The power transmission lines should not damage local ecosystems, as well as unique landscapes that are important biodiversity and ecotourism in the protected area for development;" and • National Roads Department – further consultation is required regarding the detailed of the proposed Project where crossings of road are required. Permission is required from the National Roads Department for any road closures. Meetings with MEPA A meeting was held with the Deputy Minister on 27 March 2018. Key outcomes comprised: • Wherever the Project has the potential to impact an Emerald Site, an Appropriate Assessment of this impact will be required. There is no lower threshold relating to the level of impact for when an Appropriate Assessment is needed.

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• MEPA is keen to work with GSE and their environmental team and is pleased that GSE was being open with the ministry. • The challenge in routing between proximity to settlements and natural habitats was discussed. MEPA understood and agreed there is a need to find a balance between impacting biodiversity and communities. • Development in Emerald Sites is not prohibited where it can be demonstrated that the available alternatives would present health risks to communities. • The Deputy Minister recommended that GSE consult with Biodiversity and Forestry Department of MEPA who have responsibility for the Emerald Site network. A second meeting was, therefore, held with the Biodiversity and Forestry Department (27 March 2018) where the routing of lines in proximity to Emerald site was discussed. MEPA reiterated that any development in an Emerald Site must demonstrate that there are no other viable alternatives and clear evidence must be presented showing that alternatives are not viable. The viability of alternatives should not be based upon cost constraints. Details of alternatives studied by the Project are given in Project Definition, Volume 2 of the ESIA. Two further meetings were held in April 2019 to follow up on the outcomes of the Biodiversity Assessment (Volume 3). The first was held to discuss the boundary of the Gomobri Emerald site in Component D. MEPA confirmed the site status is currently a ‘proposed’ Emerald site and that many more surveys were underway to confirm the boundaries and species present in the site. The current boundary of the site was discussed due to an apparent error in the mapping and we discussed the possibility of the boundary having moved during the GIS mapping process. MEPA confirmed there did appear to be some errors in the boundary and that many of the areas where the transmission lines crossed cultivated areas probably weren’t in the Emerald site even though the boundary does show it. MEPA confirmed the boundary is being considered as part of the adoption of the site from ‘proposed’ to ‘candidate,’ but this was still planned to take some months from now (April 2019) to complete. The second meeting held in April 2019 was with the Forestry section of MEPA. This meeting focused on compensation planting due to loss of trees in state owned forests. MEPA confirmed that there is no guidance on compensation planting and that the funds paid for by developers when removing trees represents compensation. This monetary compensation is used for planting schemes across Georgia. No details of planting schemes were provided by MEPA. Meeting with National Forestry Agency of Georgia A number of meetings have been held with the National Forestry Agency of Georgia to discuss issues including: • Tree clearance in the transmission line right of way; • Removal of timber from the right of way; • Planting of trees to compensate for tree removal; and • Provision of cut timber to local communities. A meeting was held with the Deputy Head and Head of Forest Inventory and Regeneration Department of the National Forestry Agency on 21 September 2018. GSE tabled a draft Tree and Vegetation Clearance Specification which outlined a proposed specification to minimise vegetation and tree removal in the transmission line Right of Way corridor based upon Georgian regulations (Decree 3661), good international ______1 Decree 366: On Regulation for Protection of Linear Structures of Power Networks and Determination Zones of Protection

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5.2.3 Meetings with Non-Governmental Organisations Table 5.3 summarises the meetings held to date with NGOs during the ESIA process. A summary from each meeting and key issues raised during the ESIA Scoping phases is presented in the following sections.

TABLE 5.3 MEETINGS HELD WITH NGOS Date NGO

20 September 2018 EcoVision held at GSE office, Tbilisi

21 September 2018 Sabuko held at GSE office, Tbilisi

1 April 2019 Sabuko held at GSE office, Tbilisi

2 April 2019 Nacres held at the offices of Nacres, Tbilisi

2 April 2019 WWF held at the offices of WWF, Tbilisi

Sakubo A meeting was held with the Director of Sabuko (Society for Nature Conservation and local partner of Birdlife International) on 21 September 2018 in order to introduce the Project, explain the ESIA process and as way of follow up to earlier consultation with them and BirdLife International on the scope of bird surveys (September

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2017 and April 2018, see Section 5.5.1). The route selection process was discussed with respect to the avoidance of constraints and the need to balance social impacts and those on biodiversity. The boundaries to the Important Bird Areas (IBAs) were discussed, as was the ESIA Scoping Report for the Project. Sabuko indicated that their main interest is in the key IBA species and ensuring that the impact on these species is fully assessed. GSE confirmed that the studies being undertaken would do this and the bird data and assessment reports would be provided to Sabuko as part of the disclosure process for their comment. A further meeting was held in April 2019, which focused on the bird studies in the Adjara-Imereti IBA and also the Gombori Emerald site. Since the earlier consultation, Sabuko had undertaken black grouse surveys and would provide the results when available for GSE. The concepts of further monitoring of the Project once installed and the content of the Appropriate Assessment was discussed with Sabuko. At the time of the meeting, Sabuko had not reviewed the draft Appropriate Assessment which had been provided to them. Sabuko would review the Appropriate Assessment and provide any comments at a later date. EcoVision A preliminary meeting was held with Ecovision on 20 September 2018 in order to introduce the Project and explain the ESIA process. Ecovision is a Georgian NGO focused on sustainable development and preservation of biodiversity, historical and cultural heritage in Georgia. The ESIA Scoping Report for the Project was provided and GSE requested that Ecovision provides its feedback on the Project. The importance of the ESMP (Volume 8) was also raised by GSE and how this will be used to control the contractor activities. EcoVision stressed that it would be important to develop a clear communication strategy to the communities, in order to: explain the process; to note that work was being done in accordance with lenders standards; and how these strict standards and controls would be implemented. Ecovision will provide GSE with some thoughts on the communication strategy needed. NACRES NACRES Centre for biodiversity conservation and research were consulted in April 2019 following the outcomes of the Biodiversity Assessment (Volume 3). The boundary of the Gombori Emerald site was discussed, and they agreed that some changes to be boundary were needed. NACRES confirmed that the boundary of the Emerald site was a proposed site and little data was available for the site. NACRES also indicated that by December 2019, the boundary of the site and data forms for the site would be updated and then sent to the Bern Convention in order to attain ‘candidate’ status. The meeting also discussed the ways in which NACRES could support GSE with providing on-going monitoring of some of the key biodiversity areas that the Project passes through. The purpose of this is to provide alternative conservation actions as a result of the project. Further discussions between GSE and NACRES are needed. WWF WWF deals mostly with National Parks and does not deal with Emerald sites. They are also working on the Key Biodiversity Areas (KBAs) and were currently working to provide updated species lists for these sites which do cover some of the Project components. These species lists would be provided but have not been received at the time of producing the ESIA reports.

5.3 ESIA Scoping Report An ESIA Scoping Report (dated August 2018) has been prepared in English and Georgian and has been circulated for comment to key consultees during August/September 2018. Consultees have included the municipalities through which the components pass; relevant government agencies (including MEPA, Agency for Protected Areas; Forestry Agency, Ministry of Economy and Sustainable Development, Ministry of Culture and

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Sports and National Agency of Public Registry) and also a number of NGOs (EcoVision, Sabuko, Caucasus Environmental Network (CENN) and Green Alternative). The ESIA Scoping Report has also been posted on the GSE website in both English and Georgian2 The key issues raised in the responses from the consultees comprise: • Municipalities: o Tskaltubo Municipality – who had no comments to make; o Tkibuli Municipality – who had no comments to make; • Government Departments and Agencies: o Agency of Protected Areas – highlighted the need to avoid the boundaries of the existing and planned protected areas with respect to transmission lines and the associated construction infrastructure, including building materials and wastes, to inter alia avoid impacting upon views and ecotourism development; consider Natural Monuments; assess impacts on protected areas and species and propose mitigation where impacts are anticipated; and include a risk assessment with respect to the transmission lines including consideration of fire and other natural disasters; o Georgian National Tourism Administration – who had no comments to make; o National Forestry Agency – who requested shapefiles of the routes but shapefiles have not been shared at this stage of the Project; • NGOs: o BirdLife International – general agreement with the approaches being adopted for surveys reflected in their earlier consultation (see Section 5.5.1 of this report), though the 10 days survey per season recommended by BirdLife International should be regarded as the minimum period for surveys.

5.4 ESIA Baseline engagement In addition to information gathered from the Scoping Meetings, a comprehensive set of baseline data has been obtained for the ESIA. This information was gained by surveys in the field and by requesting from relevant stakeholders. As required, consultation will take the form of correspondence and meetings with National and Local Government Agencies, the municipalities and NGOs.

5.4.1 Consultation with BirdLife International As the selected corridor for Component A passes through the Adjara Imereti Ridge IBA, BirdLife International was consulted in September 2017 and again in April 2018 regarding the scope of ornithological surveys. BirdLife International confirmed the key species of concern and some key issues to consider, which were: • Caspian snowcock (breeding species). This is the only breeding site for this species in Georgia and has been poorly surveyed. The birds tend to breed on rocky slopes. The creation of new roads to these areas could increase the pressure on hunting. The impact assessment should include the location of towers/conductors as this species may be at risk of collision;

______2 http://www.gse.com.ge/projects/international-projects/Energy-Network-Improvement-Programme-ENIP

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• Caucasian Grouse (endemic and breeding species). This species lives in the higher parts of the mountain range where rhododendron is present. The impact assessment should include the location of towers/conductors as this species may be at risk of collision; and • Imperial eagle (non-breeding, migration only). This species breeds in eastern Georgia but will fly through this area on migration. It may fly at lower levels and powerlines could form a collision risk. This species used to also breed near to Gori. Birdlife International confirmed that the IBA area is important as a migration corridor and that bird surveys should concentrate on the high ridges as this is often where most of the raptor activity appears. Surveys should also be undertaken in both Autumn and Spring during the following periods: • Autumn surveys – last two weeks of September, first week of October; and • Spring surveys – mid to late April. It was agreed that surveys would take place during these periods and for a minimum 10 days each period, using one European ornithologist and one Georgian ornithologist. Due to heavy snow on the main ridge, Spring surveys were delayed till mid-May. Birdlife International was consulted again. Whilst this was going to be too late for the eagles and the migration of other species peak in April, it would a good time to monitor activity of Caucasus Grouse and Caspian Snowcock and for the main migration of Honey Buzzard. Further consultation with Birdlife International took place in July 2017 regarding changes to IBA boundaries for the Adjara-Imereti Ridge IBA.

5.4.2 Meetings with local communities as part of socio-economic baseline surveys Qualitative semi-structured interviews were conducted with local residents selected by an iterative snow-ball sampling technique. In total, 60 interviews were conducted with local residents. The list of formal semi- structured interviews conducted is presented in Appendix A of Volume 4 Social. Informal discussions were also conducted whenever possible. These two types of interviews aimed to collect information about local informal land tenure practices (if any), land uses and their seasonality, social organisation and means of livelihoods, women’s position, vulnerable groups and cultural heritages of local value. These interviews did not aim to achieve statistical representativeness, but rather to identify the diversity of socioeconomic situations along the routes of the components.

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Stakeholder engagement programme

6.1 Stakeholder engagement approach The objectives of external communications are to provide continuous engagement with targeted audiences to provide information about the activities, performance, development and investment plans and their implementation. Stakeholder engagement is critical for supporting the Project’s risk management process, specifically the early identification and avoidance/management of potential impacts (negative and positive) and cost effective project design. Stakeholder engagement is an on-going process and there are six main parts relevant to the Project and this SEP: • ESIA Scoping Phase (completed and summarised in Section 5); • Draft ESIA Disclosure & Consultation Phase (this current phase); • Georgian EIA disclosure and public meetings; • Resettlement Action Plan consultation; and • Contractor and GSE Engagement ahead of and during the Construction Phase; and • Operational phase engagement. The following sections describe the activities to be undertaken for the engagement activities outlined in the above list which remain to be completed. A flow chart showing the three phases of the Project (development, construction and operation) and the consultation proposed with the municipalities and local communities is shown in Figure 2. This should be read in conjunction with Sections 6.2 to Section 6.6 of this Stakeholder Engagement Plan.

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6.2 ESIA Disclosure & Consultation Phase

6.2.1 Overview of the Disclosure process This current second phase of the engagement process focuses on disclosing and consulting on the draft results of the ESIA process. The specific objectives for the draft ESIA phase of engagement are to: • Provide stakeholders with the draft impact assessment and associated management/mitigation measures (disclosure); and, • Gather stakeholder input on the draft impact assessment and associated management/mitigation measures (consultation). This phase of meaningful consultation with the inhabitants of the areas of the component areas is taking place over a 120 day disclosure period starting June 2019 prior to the finalization of the ESIA Package Report in the first quarter of 2019. During this engagement phase, disclosure and consultation activities have been designed along the following general principles: • Consultation events and opportunities will be widely and proactively publicised, especially among project affected parties, at least 2-3 weeks prior to any meeting; • The non-technical summary will be accessible prior to any event to ensure that people are informed of the assessment content and conclusions in advance of the meeting; • The location and timing of any meeting will be designed to maximise accessibility to project affected stakeholders; • Information presented will be clear and non-technical, and will be presented in Georgian and English; • Facilitation will be provided to ensure that stakeholders are able to raise their concerns; and • Issues raised will be answered at the meeting or actively followed up.

6.2.2 Disclosure Documents The ESIA Report disclosure package will comprise the following documents that have been prepared in accordance with the guidelines set out in the EBRD Environmental and Social Policy (2014): • Volume 1 – Non-Technical Summary; • Volume 2 – Project Definition; • Volume 3 – Biodiversity; • Volume 4 – Social; • Volume 5 – Physical Environment; • Volume 6 – Stakeholder Engagement Plan (this document); • Volume 7 – Land Acquisition Resettlement and Compensation Framework (LARCF); • Volume 8 – Environmental and Social Management Plan (ESMP); and • Environmental and Social Action Plan (ESAP).

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6.2.3 Consultation on the ESIA Disclosure Documents The disclosure documents have been made widely available to the community and other stakeholders described in this SEP. Feedback forms accompany all the disclosure documentation to enable the registering of comments and concerns on the Project. The disclosure ESIA Report is being made available (i) online through the Project website [http://www.gse.com.ge/home] accessible in both English and Georgian, and (ii) physically in key relevant community locations, comprising: • At the main public building of each municipality; and • At an easily accessible public building at the Regional centre • Non-technical Summary Reports are available for local communities and will be distributed by the GSE Community Liaison Officers’ on demand in both electronic and hard copy. Copies will be made available, where practicable, at the village leaders’ offices and at public gathering places (if present). Inhabitants of the affected areas will be notified of the availability of these documents by advertisements. In addition, at least one formal meeting will be organised in each municipality, with invitations sent to the heads of villages, at the start of the meaningful consultation3 to explain the process and the content of the documents. Some meetings will also be organized in communities affected by the project and remote from the Municipal centres. The date and the purpose of this meeting will be announced by the Community Liaison Officer at least one week in advance. In addition, GSE Community Liaison Officers will organise meetings in every community/village crossed by the transmission line to explain the Project to vulnerable groups, such as the elderly, disabled and/or illiterate people who may experience difficulty accessing info centres or meetings. After the meaningful consultation, a formal meeting may be organised in certain component areas if required, to explain the comments received and the way GSE has taken them into account. The minutes of this meeting will be published on the Project’s webpages. The Community Liaison Officer will document the informal comments received in person regarding the ESIA documents. The ESIA Report will then be finalised based on the comments received from the stakeholders and submitted to the Lenders. GSE will inform those who have participated in the public consultation process in a timely manner of the final decision on the Project, associated environmental and social mitigation measures and any benefits of the project for the local communities, along with reasons and considerations on which the decision is based, and the grievance or complaint mechanism or process available.

6.3 Resettlement Action Plan consultation As set out in Section 9 of the LARCF (Volume 7), once all land take areas have been defined, a Resettlement Action Plan (RAP) will be prepared for each Project Component. This will be based on the final LARCF which will be disclosed as part of the ESIA package and any comments at this stage will be considered accordingly in the finalisation of the LARCF and onwards into the RAPs. For each transmission line section and substation works, a cut-off date with respect to occupation or use of land will be decided which will also mark the date when an asset inventory will start in each affected section of the proposed transmission lines. The cut-off date will be communicated officially to each Head of Municipality, who will then request the Municipal Land

______3 Meaningful consultation is that which engages with relevant stakeholders in a culturally appropriate manner, in proportion to the potential impacts associated with the project and level of concern, bearing in mind the spirit and principles of the UNECE Convention on Access to Information, Public Participation in Decision Making and Access to Justice in Environmental Matters. EBRD PR10 §19 states that “meaningful consultation is a process that provides stakeholders with opportunities to express their views on project risks, impacts and mitigation measures, and allows the Project to consider and respond to them.”

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Acquisition and Resettlement Office (MLARO) and Community level working groups to announce it locally in the affected areas at least two weeks prior to the start of the survey. Two weeks prior the start of the cut-off date and census and asset inventory, the RAP Consultant will organise public meetings in each affected village to announce and explain the process and make appointments for the start of the census and asset inventory. An information leaflet or Guide to Land Acquisition and Compensation (GLAC) will be prepared and distributed during the public meetings and made available at the Municipal and Community (Village) town halls. It will, as a minimum, state clearly the cut-off date, the eligibility principles, describe the Grievance Resolution Mechanism and include the contact details of the RAP Consultant. For each Project Component, meaningful consultation regarding the RAP will be undertaken with the PAPs and communities. Local authorities will also be engaged and will be involved in the consultation process. The RAP Consultant preparing and implementing the RAPs will identify specific constraints inhibiting consultation with vulnerable groups and will define appropriate engagement methods with them. They will also identify a gender sensitive approach to be implemented throughout their consultation process with the PAPs and communities. The processes and mechanisms ensuring the active involvement of PAPs and other stakeholders will be detailed in the RAPs. These will also include the minutes of the consultation meetings, with the list of participants, and the synthesis of the views and concerns of the PAPs, disaggregated by gender. Table 10.2 of the LARCF (Volume 7) presents the various consultation activities that will be implemented during each RAP preparation and implementation. These activities will be phased to accommodate the land take schedule along the different section of each transmission line and substation.

6.4 Engagement Activities during Construction Phase Following the completion of both the ESIA Report and EIA Report and receipt of the environmental decision and construction permit, consultation will be on-going through the construction phase of the Project and will mainly be managed by the main construction contractor. The following sections describe this process.

6.4.1 Launch events A Project launching event will be organised with Government (ministerial level) and relevant stakeholders to mark the official start of the activities funded by KfW and EBRD. Launching events for each of the Project Components will also be organised at the local level, with the main objective being to create awareness about each Project Component and the construction programme. During the construction programme, inauguration events will be organised as each component is completed. A closing event will also be held to mark the official completion of the Project.

6.4.2 Website GSE will update the website regularly (at least once a month) with key environmental and social data; news on construction activities (see Section 6.5.4); details of the Grievance Resolution Mechanism, including a downloadable grievance registration form; and contact details of the Community Liaison Officer. Project information materials, such as Project videos/presentations, the Project Information Leaflet, and Project factsheets will also be made available via the website. GSE will also post information on the company’s Facebook and LinkedIn pages.

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6.4.3 Implementation of workers grievances mechanisms In compliance with the Lenders’ requirement, a specific grievance mechanism for the workers employed by the Project, including contractors, will be defined and implemented, as set out in Section 7.0 Grievance Mechanism.

6.4.4 Disclosure of documents during construction A number of documents will be disclosed to the local communities during detailed design and construction phase of the Project. These documents are listed in the following sections. Reporting requirements of the Project will also result in a number of documents being disclosed and these are summarised in Section 8.2 of this SEP. Project Information Leaflet GSE will publish and circulate a Project Information Leaflet to the local communities which will provide details of the Project and details of any other key information being made available such as times and dates of public meetings, reports being disclosed, the grievance mechanism, contact details for the Project team. Factsheets will also be prepared to cover such aspects as EMF. Recruitment Management Plan The Contractor will disclose its recruitment procedures in the Project component areas by producing a Recruitment Management Plan. This Plan will be provided to the relevant municipality office for each Project Component and it will be advertised via local community noticeboards. Further details on local recruitment can be found in Section 5.4.2 of the ESMP (Document 8.1, Volume 8) Accommodation Plans The Contractor will prepare and disclose summaries of its Accommodation Plans for each Project Component area. The plans will be provided to the relevant municipality office for each Project Component and will be advertised via local community noticeboards. Further details on the proposed Accommodation Plans can be found in Section 5.4.3 of the ESMP (Document 8.1, Volume 8) Traffic Management Plan The Contractor will disclose summaries of its Traffic Management Plan in the three main Project component areas, with the help of the Community Liaison Officer. The Community Liaison Officer will organise ongoing campaigns in the component areas to raise awareness of traffic-related risk during the construction period. Environmental monitoring The Contractor will disclose details of any environmental monitoring such as noise and vibration monitoring which would need to take place within local communities. Interested parties may be invited to participate as appropriate.

6.4.5 Regular meetings with PAPs After the ESIA Disclosure and Consultation Phase and during construction, formal quarterly meetings will be organised by GSE in each of the component areas to explain and discuss the Project activities, and the status and performance of environmental and social management plan activities. These meetings will also be attended by the Contractor and minutes of each meeting will be published on the Project website and be made available in a Town hall local to each meeting. Where appropriate, information will be presented in the form of e.g. presentations, Expo panels, posters and banners could be used to present information in an easy to understand format.

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Informal meetings with PAPs will be organised on an ad-hoc basis by the Community Liaison Officer. Door to door visits by uniformed staff (communication officers) will be undertaken in affected villages within 1km of construction activities prior to starting on site in each area. Vulnerable group focus groups will be held to ensure that these groups’ concerns and issues are taken in account throughout the life of the Project. These meetings will be documented as part of the monitoring and reporting of the engagement activities (see Section 8.0 Monitoring and Reporting).

6.4.6 Meetings with Municipalities, Gamgebeli and other Stakeholders GSE will hold formal regular meetings in each of the Project Component areas with representatives of the municipalities, the Gamgebeli and local and international NGOs (eg, BirdLife International). Meetings will also be held on a national basis with the Government ministries and national NGOs as appropriate.

6.4.7 Site visits At appropriate points during the construction phase, site visits or demonstration tours will be organised for selected stakeholders.

6.4.8 Information Boards Information Boards will be placed at strategic locations in each Project Component area to provide information on: future engagement programmes; the timing and location of nearby construction activities; and contact details of the GSE Community Liaison Officer. Similarly, posters will be posted at village entrances and schools (at the entrances).

6.4.9 Media Articles and case studies will be published in relevant publications in Georgia and also Lenders’ publications/websites about the Programme highlighting the progress and benefits of the Project. Press releases will be published on achievement of Project milestones. On-site seminars and media tours will be held separately for leading National Media representatives and separately for leading Local Media representatives. GSE will also participate in local talk shows.

6.4.10 Schools, Universities and Colleges Open lectures will be held at selected public schools located in the vicinity of the Project Components to provide information on the Project and on the energy sector in Georgia. Open lectures will also be held at Kutaisi and Zugdidi Universities and Colleges. GSE will work with local NGOs to develop integrated lessons among physics and other subject teachers, so that they can conduct and deliver effective and interactive classes related to the Project in science, technology, engineering and mathematics. GSE will support local school and university teachers and students in leading environmental activities in their villages.

6.5 Engagement Activities during Operational Phase

6.5.1 Website GSE will update the website regularly (at least once a quarterly basis) with environmental and social data and news on operation activities.

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6.5.2 Quarterly Meetings with PAPs During the first year of operation, formal quarterly meetings will be organised by GSE in each of the component areas to explain and discuss the ongoing Project activities, and to discuss any ongoing issues with the communities. The minutes of each meeting will be published on the Project website and be made available in a Town hall local to each meeting. Following the first year, these meetings will be on an annual basis. In addition informal, ad hoc meetings will be held with the PAP by the Community Liaison Officer. These will include vulnerable group focus groups.

6.5.3 Newsletter A six-monthly newsletter will be prepared and distributed to the local communities during the first three years of operation and then on an annual basis.

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Grievance Mechanism

7.1 Introduction The Grievance Resolution Mechanism (GRM) addresses grievances that arise as a result of the Project, either the result of actions by GSE or the Contractor employed by GSE, from affected communities and external stakeholders. A separate mechanism is developed to address worker grievances. GSE is responsible for managing the GRM, but many of the grievances regarding the Project will likely relate to the actions of the Contractor and likewise will need to be resolved by the Contractor. GSE, with the support of the Implementation Consultant, will administer the GRM process deciding whether they or the Contractor is responsible and determining the best course of action to resolve the grievance. The Implementation Consultant will support GSE to monitor the grievance resolution process being undertaken by the contractor. Typical grievances for transmission line projects include those related to: • Land acquisition and physical displacement; • Construction damages; • Environmental impact; and • Indirect social impacts. GSE will implement an amicable GRM, with the objective of helping third parties to avoid resorting to the judicial system as far as possible. Complainants can resort to the Court at any time. The step-by-step process does not deter them from doing so. All grievances will be documented and each grievance resolution process and communication will be systematically tracked.

7.2 Grievance process The two-stage grievance resolution process involves the following main steps: • Receipt of grievances; • Screening for standing; • Grievance Resolution Committee (first stage); • GSE resolution at central level (second stage); • Closure of grievances; and • Grievance records and documentation. These steps are described hereafter.

7.2.1 Receipt of Grievances Anyone from the affected communities or anyone believing they are affected by the Project can raise a grievance: • By completing a written grievance registration form that will be available (i) in the Town halls of the local municipalities and in the affected villages (i.e those within proximity of construction activities), (ii) at the entrance of each construction site, (iii) on the Project’s website and (iv) at the Project’s headquarters in Tbilisi. An example of a grievance registration form is provided in Appendix 04. The Project’s Community Liaison Officer of each Municipality will review the received grievances and record them in a Grievance Register.

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• By contacting the GSE Community Liaison Officer, GSE Environmental and Social Manager, or the environmental co-ordinator and community relationships managers of the Contractor, either by phone, or in person. Grievances received verbally will be written down by the Community Liaison Officer on the grievance registration form and logged into the Grievance Register. A copy of the logged grievance will be forwarded to the complainant, giving them the opportunity to alert GSE if the grievance has not been noted down correctly. The Community Liaison Officers or GSE Environmental and Social Manager will explain the possibilities and ways to raise a grievance to local communities during meetings organised in each affected area at the time of disclosure. The GRM procedures will be disclosed through the Project’s website and will also be advertised on billboards/posters in each community and at the entrance of the information desks in the Town halls of each Municipality. In order to ensure that all grievances are captured, the GSE Environmental and Social Manager will contact the Municipality authorities and the Ministry of Economy and Sustainable Development, the MEPA, the National Agency of Public Registry to explain how the grievances they may receive concerning the project should be channelled through the Project’s GRM. Information on the way to log a grievance locally, at GSE office in Tbilisi or through the project’s website will be explained to these authorities and the GSE Environmental and Social Manager will call them regularly to ensure no grievances are missed. All grievances will be registered, reported and tracked by GSE in the Grievance Register by the Community Liaison Officer who is responsible for receiving, logging, referring and following up on grievances. Once a grievance is logged, the related event(s) that caused the grievance will be tracked to prevent similar grievances.

7.2.2 Screening for ‘Standing’ Once a grievance is received, the GSE Environmental and Social Manager will determine whether the complaint has ‘standing,’ i.e., warrants further consideration as an acceptable grievance. The status number and trends of grievances will be discussed between GSE, the Contractor, the RAP Consultant and the Implementation Consultant during weekly E&S meetings during the construction phase. The resolution of grievances of all types will follow the same steps, but the stakeholders involved will depend on the nature of the grievance. All grievances will be handled through the system described hereafter, involving respectively the Environmental and Social Manager (GSE), the Community Liaison Officer , the Contractor's grievance resolution representative, and the Implementation Consultant as representatives of the Project. Complaints related to resettlement (land take and its consequences) will also involve the RAP consultant in the resolution of grievances related to land acquisition and resettlement. If the matter has standing, grievance information will be recorded in a grievance log by GSE’s Community Liaison Officer. The following information will be recorded: (¡) Name and contact details, (ii) Details 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 responded to no later than 30 days. Once a grievance is logged, the related event(s) that caused the grievance will be tracked to ensure proper close-out of the grievance and prevent similar grievances occurring in the future. If the grievance is deemed as ineligible, the GSE Community Liaison Officer will record the reason and document that the complainant has been informed of this decision and the basis for this is explained. Ineligible cases will generally be those that GSE are confident have not occurred as a result of the actions of GSE or its Contractors/sub-contractors. If the complainant is not satisfied with this outcome, they can pursue further action by submitting their case to GSE’s Grievance Redress Commission or the appropriate court of law (Rayon Court). GSE will determine whether the resolution of the grievance is the responsibility of the Contractor (or their subcontractors), GSE, the RAP Consultant or the Implementation Consultant. If the grievance is the responsibility

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7.2.3 Grievance Resolution Committee (Stage 1) Stage 1, of the GRM involves an informal (oral) review of the complaint (whether written or oral). A local Grievance Resolution Committee (GRC) will be established in each Municipality, with an office in the municipal building. Once a standing grievance has been logged, the corresponding local GRC will be engaged to define a solution to solve the grievance. At this stage the grievance is reviewed in an informal (oral) way and the Grievance Redress Committee members make and sign the minutes on the matter. If at Stage 1 the PAP’s complaint is not resolved, the PAP will be informed about grievance resolution procedures of Stage 2. A PAP has the right to use the procedures of Stage 2 without applying to Stage 1 procedures. The timeframe for resolving a stage 1 grievance is 7 days. The GRC shall convene as per necessity (but at least once a month) and shall include eight members. Special provisions will be made for any complaints of a confidential nature. The GRC will be an eight-member committee comprising of the following: • GSE representative (Committee coordinator); • Regional/municipal representative (from “Gamgeoba”); • Village attorney (“Rtsmunebuli”)(Committee member); • Representative of the PAP (Committee member); • Female representative of the Project Affected Household (AH) (Committee member); • Representative of local NGO taking into account the grievance character (Committee member); • Local specialist of social and environmental safeguards from the Implementation Consultant (Committee member); and • Local specialist of social and environmental safeguards from the Contractor or RAP Consultant . Their presence will be needed depending upon grievance’s nature (Committee member). The GSE CLO at the Municipality level will act as secretary of the GRC (creation, coordination, and documentation). Members of the GRC will be invited in accordance with the types of complaints to be addressed. The meeting will start without the complainants by reviewing all PAP complaints received since the last GRC meeting, and to propose a solution to all grievances within the past one or two weeks. Then, the GRC will welcome the complainants whose grievance had been reviewed during the previous meeting to discuss the proposed resolution. For each grievance, the GRC will determine whether additional investigations are warranted. If so, additional information will be collected before the next GRC meeting and will also be provided to the PAP before the meeting. The GRC will then inform the PAP about the date, time and place of its review meeting, and invite the PAP accordingly. The GRC will receive the complainant and discuss with them a solution to their grievance. The committee shall draw up and sign the minutes of their discussion on the matter. If the grievance is satisfactorily resolved, the PAP will also sign the minutes in acknowledgement of the agreement. In cases where the project has agreed to put in place additional measures, these will be specified, with a timetable for delivery, in the minutes of the meeting. If the grievance remains unresolved, the Stage 2 escalation process will be explained to the PAP. The grievance redress procedure of Stage 1 is an informal tool of dispute resolution allowing PAPs and the Project implementation team to resolve the disagreement without any formal procedures, procrastination or impediments. International experience in different projects shows that such informal grievance redress

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Georgian State Electrosystem (GSE) Environmental and Social Impact Assessment SLR Ref No:901.12.1 Volume 6 Stakeholder Engagement Plan July 2019 mechanisms help to solve most of the complaints without formal procedures (i.e. without using the procedures specified in the Administrative Code or litigation). If the PAP is not satisfied, the grievance redress mechanism assists him/her in lodging an official grievance in accordance with the procedures of Stage 2, whereby the plaintiff will be informed of his/her rights and obligations, the rules and procedures of making a grievance, required format of the grievance, terms of grievance submission, etc.).

7.2.4 GSE Resolution at Central Level (Stage 2) If any aggrieved PAP is unsatisfied with the GRC decision, the unsolved grievances will be sent to GSE in written form. The GRC should assist him/her in lodging an official complaint and send it to the appropriate departments (legal, technical, contracts etc.) for redress. The appropriate department within GSE shall then review the complaint in compliance with the Administrative Code of Georgia. The timeframe for referral is 10 days. The plaintiff shall be informed of the decision in writing within a maximum of 30 days. The plaintiff shall be informed in writing of GSE decision. If GSE decision fails to satisfy the aggrieved affected persons, they can pursue further action by submitting their case to the appropriate court of law (Rayon Court).

7.3 Grievance Records and Documentation GSE will nominate a GRM Focal Point to manage the grievance database to keep a record of all grievances received. The database will contain the name of the individual or organization lodging a grievance; the date and nature of the grievance; any follow-up actions taken; the solutions and corrective actions implemented by the Contractor or other relevant party; the final result; and how and when this decision was communicated to the complainant. The Contractor and Implementation Consultant will provide information on grievance management in their monthly reports. Grievance monitoring and reporting will also be included in GSE’s six-monthly and annual public reports.

7.4 Closure of Grievances A grievance will be considered “resolved” or “closed” when a resolution satisfactory to both parties has been reached, and after corrective measures has been successfully implemented. When a proposed solution is agreed between the Project and the complainant, the time needed to implement it will depend on the nature of the solution. However, the actions to implement this solution will be undertaken within one month of the grievance being logged and will be tracked until completion. Once the solution is being implemented or is implemented to the satisfaction of the complainant, a complaint close out form will be signed by both parties (GSE Environmental and Social Manager or representative and the complainant), stating that the complainant considers that the grievance is closed. The grievance will then be archived in the Project Grievance database. In certain situations, however, the Project may “close” a grievance even if the complainant is not satisfied with the outcome. This could be the case, for example, if the complainant is unable to substantiate a grievance, or it is obviously speculative or fraudulent. In such situations, the Project’s efforts to investigate the grievance and to arrive at a conclusion will be well documented and the complainant advised of the situation. GSE will not dismiss grievances based on a cursory review and close them unless the complainant has been notified and had the opportunity to provide supplementary information or evidence.

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Figure 3 – Grievance Resolution Mechanism

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7.5 Workers Grievance Mechanism GSE’s HR Department will develop and implement a grievance mechanism for GSE employees to address workplace concerns. The establishment of this grievance mechanism is part of the proposed corporate GSE restructuring. This grievance mechanism for direct workers, i.e. GSE employees, will be established by Project effectiveness. The Contractor will set up a workers grievance mechanism for the construction period. Workers representatives will be elected and a Workers Safety Committee will be established. The workers can raise a grievance by referring to their elected representative or by completing a form and posting it in the complaint boxes that will be located at key construction sites (offices and canteens). No worker shall be disadvantaged or penalised in any way due to their submission of a grievance. In addition, members of the Workers Safety Committee shall not be disadvantaged or penalised in any way due to their role and the time spent fulfilling the duties of this role. All workers grievances will be registered and tracked by the Contractor HR manager in a workers grievance database. Workers grievances will then be raised and answered at each Workers Safety Committee meeting. The Contractor HSE site manager will then transmit the grievance resolution to the workers and document their resolution and the workers acceptance. This workers’ grievance mechanism will be monitored by GSE on a weekly basis, detailed information on the number, nature and resolution of the workers’ grievances are included in the Monthly E&S reports of the Contractor. The GSE E&S Team will integrate the workers grievance register into the main grievance management system of the Project. Should there already be collective agreements on-site which include grievance mechanisms, these should be followed in preference to the GSE mechanism described here. The Implementation Consultant will monitor the Contractors’ recording and resolution of grievances, and report these to GSE in their monthly progress reports. The process will be monitored by the GRM Focal Point, a GSE representative who will be responsible for the project GRM. The workers grievance mechanism will be described in staff induction trainings, which will be provided to all project workers. The mechanism will be based on the following principles: • The process will be transparent and allow workers to express their concerns and file grievances; • There will be no discrimination against those who express grievances and any grievances will be treated confidentially; • Anonymous grievances will be treated equally as other grievances, whose origin is known; and • Management will treat grievances seriously and take timely and appropriate action in response. Information about the existence of the grievance mechanism will be readily available to all project workers (direct and contracted) through notice boards, the presence of “suggestion/complaint boxes”, and other means as needed.

7.6 GSE Contact Information The point of contact regarding the management of grievances by the Project and the local stakeholder engagement activities is GSE Environmental and Social Manager:

Description Contact details Company: Georgian State Electrosystem (GSE) To: GSE Environmental and Social Manager Address: 2 Baratashvili Street, Tbilisi 0105, Georgia

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Description Contact details E-mail: [email protected]

Website: www.gse.com.ge Telephone: Tel: +995 32 2 510 837 (ext. 461)

Information on the Project and future engagement programmes will available on the Project’s website, and will be posted on information boards in key villages in the Project area. Information can also be obtained from the Community Liaison Officers. Six-monthly E&S reports that document the implementation of the SEP will be disclosed on the Project website and made available in the local town halls. In addition, for information on engagement with national and international stakeholders, and for information on the environmental and social performance of the Project, NGOs, CSOs and media are invited to contact GSE Head of Communications in Tbilisi:

Description Contact details Company: Georgian State Electrosystem (GSE) To: GSE Head of Communications Address: 2 Baratashvili street, Tbilisi 0105, Georgia E-mail: [email protected]

Website: www.gse.com.ge Telephone: Tel: +995 32 2 510 837 (ext. 461)

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Monitoring and reporting

8.1 Monitoring GSE will maintain a database and activity file detailing all public consultation, stakeholder engagement activities, and information disclosure. All grievances collected throughout the Project will also be systematically integrated in a Grievance Register. Monitoring Reports documenting the environmental and social performance of the Project during construction will be prepared for submission to GSE management and to the Lenders and will include a section regarding stakeholder engagement and grievances management. Table 8 proposes a set of indicators relating to the SEP performance at this stage.

TABLE 8.1 SEP INDICATORS TO BE DOCUMENTED IN THE E&S PERFORMANCE REPORTS

Engagement with PAPs Number and location of formal meetings with PAPs Number and location of informal meetings with PAPs Number and location of community awareness raising or training meetings Number of men and women that attended each of the meetings above Number, location, attendance and documentation of the meetings held with the municipalities and communities or other stakeholders For each meeting, number and nature of comments received, actions agreed during these meetings, status of those actions, and how the comments were included in the Project ESMP. Minutes of meetings of formal meetings and summary note of informal meetings will be annexed to the report. They will summarize the view of attendees, and distinguish between comments raised by men and women. Engagement with other stakeholders Number and nature of engagement activities with other stakeholders, disaggregated by category of stakeholder (Governmental departments, municipalities, NGOs) Issues raised by NGOs and other stakeholders, actions agreed with them and status of those actions Minutes of meetings will be annexed to the six-monthly report Number and nature of Project documents publicly disclosed Number and nature of updates of the Project website Number and categories of comments received on the website Grievances Resolution Mechanism Number of grievances received, in total and at the local level, at Tbilisi headquarters, on the website, disaggregated by complainant’s gender and means of receipt (telephone, email, discussion) Number of grievances received from affected people, external stakeholders Number of grievances which have been (i) opened, (ii) opened for more than 30 days, (iii) those which have been resolved, (iv) closed, and (v) number of responses that satisfied the complainants, during the reporting period disaggregated by category of grievance, gender, age and location of complainant.

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Average time of complaint’s resolution process, disaggregated by gender of complainants and categories of complaints Number of local GRC meetings, and outputs of these meetings (minutes of meetings signed by the attendees, including the complainants to be annexed to the report) Trends in time and comparison of number, categories, and location of complaints with previous reporting periods Workers Grievances Number of grievances raised by workers, disaggregated by gender of workers and worksite Number of workers grievances (i) opened, (ii) open during more than 30 days, (iii) resolved, (iv) closed, and (v) number of responses that satisfied the workers, during the reporting period disaggregated by category of grievance, gender, age of workers and worksite. Profile of those who lodge a grievance (gender, age, worksite), by category of grievances. Average time of complaint’s resolution process, disaggregated by gender of complainants and categories of complaints Trend in time and comparison of number, categories, and location of complaints with previous reporting periods

8.2 Reporting during Construction The reporting on Environmental and Social activities conducted by GSE and the Implementation Consultant during the construction phase will be undertaken in accordance with the requirements of the ESMP (Volume 8).

8.2.1 Quarterly and Annual Reports by GSE During the Project development and construction phase, the Community Manager will prepare brief monthly reports on E&S performance for GSE’s Project Director which will include stakeholder engagement activities, as follows and in accordance with the indicators in Table 8.1: • Public outreach activities (formal and informal meetings with stakeholders, newsletters); • Entries to the grievance register; • Newly identified stakeholders (where relevant); and • Plans for the next month and longer term plans. Monthly reports will be used to develop quarterly and annual reports reviewed by senior managers at GSE. The quarterly and annual reports will be disclosed on the Project website and made available in the Town halls within the municipalities through which the Project passes.

8.2.2 Six Monthly E&S Compliance Reports to the Lenders Six-monthly E&S compliance reports will be prepared and submitted to the Lenders during the construction period. These will set out how the Project has met EBRD’s Policy Requirements and KfW’s Sustainability Guidelines. A section on stakeholder engagement will be included in these E&S reports with respect to the indicators given in Table 8.1.

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8.3 Reporting during Operation

8.3.1 Annual Reports by GSE During each year of operation, the Community Liaison Manager will prepare an annual summary report on E&S performance for GSE’s Project Director which will summarise: • Public outreach activities; • Entries to the grievance register; • Newly identified stakeholders (where relevant); and • Future plans. The annual reports will be disclosed on the Project website and made available in the Town halls within the municipalities through which the Project passes.

8.3.2 E&S Compliance Reports to the Lenders During the first year of operation, six-monthly and an annual E&S compliance reports will be prepared and submitted to the Lenders. Annual E&S compliance reports will then prepared and submitted to the Lenders during the rest of the operation period. A section on stakeholder engagement will be included in these E&S compliance reports. In addition, GSE will prepare Project Incident Notifications for Lenders: if and when required. .

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APPENDIX 01

Progress regarding the local EIA process and local disclosure

GSE has started the EIA process to meet the requirements of the Georgian EIA process. The following Scoping Reports have been produced, submitted to MEPA and have had public hearings organised by MEPA: • Component A – Tskaltubo to Akhaltsikhe and Akhaltsikhe to Turkey Border. Meetings held in Gvishtibi, Maglaki, Qvitiri, Mukhiani, Patriketi, Persa, Sviri, Eliatsminda, Vale, Tskhuti, Klde, Varkhani, Prekho, Arali, and Benara between 15 October 2018 and 26 October 2018 • Component C1 – Nenskra Substation and Mestia line. Meetings held in Letseri, Nakra, Becho on 17 and 18 September 2018 • Component C2 – Lajanuri Substation. Meeting held in Tsageri on 16 April 2018. • Component C2 Tskaltubo-Namakhvani-Tvishi-Lajanuri and Tskaltubo-Lajanuri. Meetings held on 21 and 22 January 2019 in the following locations: o Tskaltubo Municipality- in the villages of Rioni and Gvishtibi. o Tkibuli Municipality- in the village of Jvarisa. o Tsageri Municipality- in the villages of Tvishi, Usakhelo and Alpana. • Component C2 - Oni-Lajanuri. Meetings held on 23 and 24 January 2019, in the following locations: o Ambrolauri Municipality -in the villages of Sadmeli, Tsesi, Khidiskari and Khvanchkara; o Oni Municipality-in the villages of Bari and Parekheti. • Component D - Akhmeta-Telavi-Tsinandali-Mukuzani-Gurjaani-Meetings held on 23, 24 and 25 January 2019 in the following locations: o Gurjaani Municipality- in the villages of Gurjaani, Mukuzani and Kalauri; o Telavi Municipality- in the villages of Tsinandali, Shalauri, Ikalto and the city of Telavi; o Akhmeta Municipality- in the village of Zemo Khodasheni and city of Akhmeta.

APPENDIX 02

Issues raised during Scoping meetings with Municipalities

Table 2 Key Issues Raised by Municipalities at Scoping Meetings Meeting Issues Raised Response

Component A

Akhaltsikhe Municipality, 23 • Requested further information on: Information on the transmission routes is April 2018, 23 the transmission route; impacts of provided in Chapter 4 of Volume 2 of the attendees EMF on human health; and ESIA Report. compensation for loss of land and Information on EMF and human health assets. issues is addressed in the Social Assessment • There are ongoing issues in Zikilia (Volume 4 of the ESIA) area with the construction of the Batumi Akhaltsikhe transmission. A LACRF (Volume 7 of the ESIA) has been The construction of access roads has produced which sets out the framework for blocked the access to some pasture land compensation lands. Cattle are not able to cross The issues occurring at Zikilia have been the roads, due to the steep sides of considered in Social assessment (Volume 4 the road. of the ESIA). Ambrolauri Municipality, 20 Information on the transmission routes is April 2018, 6 • Requested further information on: provided in Chapter 4 of Volume 2 of the attendees the transmission route and the start ESIA Report. of construction

Vani Municipality, 18 April 2018, 19 • No questions were asked by the attendees participants. Tskaltubo Municipality, • No questions were asked by the Components A participants. & C2, 18 April 2018, 22 attendees Chokhatauri Information on the transmission routes is Municipality, 23 • Requested further information on: provided in Chapter 4 of Volume 2 of the April 2018, 6 the transmission route; ESIA Report. attendees compensation for loss of land and Information on the project justification is (Components A assets; and project justification. provided in Chapter 2 of Volume 2 of the and B) ESIA Report. A LACRF (Volume 7 of the ESIA) has been produced which sets out the framework for land compensation

Meeting Issues Raised Response

Kutaisi Information on the transmission routes is Municipality, 18 • Requested further information on: provided in Chapter 4 of Volume 2 of the April 2018, 9 the transmission route and if it ESIA Report. attendees would cross forest areas; and A LACRF (Volume 7 of the ESIA) has been (Components A compensation for loss of land. produced which sets out the framework for and C2) land compensation

Component B

Chokhatauri Information on the transmission routes is Municipality, 23 provided in Chapter 4 of Volume 2 of the April 2018, 6 ESIA Report. attendees Information on the project justification is • Requested further information on: provided in Chapter 2 of Volume 2 of the the transmission route; ESIA Report. compensation for loss of land and A LACRF (Volume 7 of the ESIA) has been assets; and project justification. produced which sets out the framework for land compensation

Ozurgeti Information on the transmission routes is Municipality, 23 provided in Chapter 4 of Volume 2 of the April 2018, 21 ESIA Report. attendees Information on the project justification is • Requested further information on: provided in Chapter 2 of Volume 2 of the the transmission route; number of ESIA Report. people that would be affected by the Information on EMF and human health project; minimum distance between issues is addressed in the Social Assessment the transmission and population (Volume 4 of the ESIA) housing; risks and monitoring of EMF; replacement of existing A LACRF (Volume 7 of the ESIA) has been transmission within the Ozurgeti produced which sets out the framework for municipality; benefits for the land compensation municipality; date for start of The details of the landowner of the construction; land owner of the proposed substation are a private matter proposed substation; any upgrades and cannot be disclosed. to the local power supply network; and compensation for loss of land The removal of the existing transmission line and assets. within the Ozurgeti municipality is outside the scope of the project and there will be no other upgrades to the local power supply network as part of this project.

Meeting Issues Raised Response

Component C Mestia A LACRF (Volume 7 of the ESIA) has been Municipality, 26 • Requested further information on produced which sets out the framework for June 2018, 12 the impacts on land and buildings land compensation attendees and compensation for unregistered GSE encouraged people to register any land? unregistered land, using the free registration • It seems that decisions are taken in programme. A mechanism is being put in Tbilisi far away from the municipality place to compensate people for loss of and people concerned by the property which is not registered in project. accordance with lenders requirements. • Could existing problems with transmission line maintenance be GSE encouraged the municipalities to input fixed at the same time that the new into the Project via the Scoping Meetings power line will be built? and through the Project contacts provided. These local distribution lines are operated by other companies and GSE do not have the ability/rights to maintain these. Adigeni Information on the transmission routes is Municipality, 23 • Requested further information on: provided in Chapter 4 of Volume 2 of the April 2018, 5 the transmission route; and ESIA Report. attendees compensation for loss of land and A LACRF (Volume 7 of the ESIA) has been assets. produced which sets out the framework for land compensation

Lentekhi Municipality, 19 • Requested further information on: Details are how these Project Components April 2018,18 the relation between that project relate to HPP projects is provided in Chapter attendees and the development of HPPs in the 4 of Volume 2. In the context of the area; any upgrades to local supply Lentekhi municipality the proposed line from lines; minimum distance required Lajanuri to Kheledula will connect to the between an existing transmission proposed Kheledula HPP project. and a new one; need for the project; dangers of transmission across Upgrades to local supply lines are not the roads; and benefits to the local responsibility of GSE and are not part of the community project. • The transmission that supplies the Implementation of the Project will not result village is dangerous for local in a significant change in the tariff. population. The line is tied to trees and there is no maintenance of remaining towers. Blackouts are also very frequent. • Possibility for free electricity Oni Information on the transmission routes is Municipality. 20 • Requested further information on: provided in Chapter 4 of Volume 2 of the April 2018, 13 compensation for loss of land and ESIA Report. assets; the transmission route;

Meeting Issues Raised Response attendees benefits for the local population; and A LACRF (Volume 7 of the ESIA) has been use of local people during produced which sets out the framework for construction phase. land compensation The Contractor is required to produce a Local Recruitment Plan which will set out local employment opportunities. This requirement is set out in Section 5.4.2 of the ESMP (Volume 8). Tkibuli Information on the transmission routes is Municipality, 19 provided in Chapter 4 of Volume 2 of the April 2018, 14 ESIA Report. attendees GSE is seeking to minimise the amount of tree cutting and a specification for tree • Requested further information on: cutting has be set out in the ESMP (Section the transmission route. 5.3.2 of Document 8.2a, Volume 8). This sets • Population are worried about tree out how trees will be removed and also the cutting within the corridor. requirements of the National Forestry Agency which will administer the sale of saleable timber including the provision of some timber to the local municipality. Adigeni Information on the transmission routes is Municipality, 23 • Requested further information on: provided in Chapter 4 of Volume 2 of the April 2018, 5 the transmission route; and ESIA Report. attendees compensation for loss of land and A LACRF (Volume 7 of the ESIA) has been assets. produced which sets out the framework for land compensation

Tsageri Information on the transmission routes is Municipality, 19 provided in Chapter 4 of Volume 2 of the April 2018, 18 ESIA Report. attendees A LACRF (Volume 7 of the ESIA) has been produced which sets out the framework for land compensation • Requested further information on: the transmission route, including is The purpose of the Project is partly to the project an upgrade for the connect new HPP projects but overall to existing transmissions; and improve reliability of the Georgian compensation for loss of land and transmission network. However, whilst this assets. improves the ability to move power around Georgia more efficiently and with less power cuts, the Project is not changing any local distribution networks which are the responsibility of local distribution companies and not GSE.

Meeting Issues Raised Response

Component D

Gurjaani Information on the project justification is municipality. • Requested information on: need for provided in Chapter 2 of Volume 2 of the the project; compensation ESIA Report. 26 April 2018 procedures; EMF safety distances; Information on EMF and human health 11 attendees wind and solar projects; reduction in issues is addressed in the Social Assessment blackouts; (Volume 4 of the ESIA) • Possibility of changes to electricity tariffs A LACRF (Volume 7 of the ESIA) has been produced which sets out the framework for land compensation There are no wind or solar projects either related to this project or known by the Project Implementation of the Project will not result in significant changes to the tariff. Telavi Use of existing towers is not possible as the municipality • Requested information on: potential voltage of the lines is being increased and for use of existing towers; detailed they will require new slightly bigger towers. 26 April 2018 tower locations; use of underground Tower locations is not yet available as this 11 attendees cables; heights of trees permitted in will only be finalised during the detailed the RoW; design phase which will be undertaken by • The land registration process for the contractor unregistered land is complicated and lengthy. The community needs to Underground cables may be used in vicinity know which people this affects as of proposed Radisson Blu hotel people do not want to do this if they A LACRF (Volume 7 of the ESIA) has been are not affected. produced which sets out the framework for • Could the Tusheti region be brought land compensation. Details of compensation into the project in order to benefit are set out in this document and their economy eg by tourism? compensation will be agreed prior to any • Can the existing towers in the city be works. removed? • Agreements regarding compensation The Tusheti region is outside the scope of should be signed before the works this project. begin not afterwards and locations GSE can confirm that where possible it has of compounds agreed in advance. tried to avoid settled areas and in so doing it will remove of existing towers which are not to be used. Akhmeta municipality. • Requested information on: loss of A LACRF (Volume 7 of the ESIA) has been electricity supply during construction 27 April 2018 produced which sets out the framework for works; timing of works with respect land compensation. 9 attendees to need to register land; the compensation process and its GSE plans to change the route of the existing line which is through the centre of Akhmeta.

Meeting Issues Raised Response

calculation; possibility of complaints. GSE will also remove all existing towers from • Can the mayor and municipality be town where this is possible and when agreed kept informed of progress? by landowners. • Can the existing towers in the city be Public meetings are being held as part of the removed, as existing line goes over ESIA public disclosure and also the Georgian houses, multi-storey buildings, a EIA process which will be run by MEPA. school/kindergarten and the central Consultation feedback will be taken on market? board in the final detailed design of the • Will there be meetings with the Project to avoid and reduce impacts as much community? And can the results of as practically possible. consultation influence the route? • Some villages have had bad experiences with compensation.

APPENDIX 03

Minutes of Scoping Meeting with government agencies

Minutes of meeting with Government agencies, 2 March 2018, GSE Office, Tbilisi Ministry of Economy and Sustainable Development; Agency of Protected Areas; Georgian National Tourism Administration; National Agency of Public Registry; Roads Department; National Forest Agency. GSE SLR Consulting ATTENDEES Gamma Consulting ENVI Consulting WEG Consulting Gergilli

MINUTES SLR Consulting TAKEN BY

ITEM DISCUSSION ACTION The meeting was opened by Zezva Khvedelidze, International Projects 1 Environmental Co-ordinator for GSE. An introduction to the project was presented by Giorgi Guldedava, Program Manager for GSE. Mark Brown, Technical Director of SLR 2 Consulting presented details of the project components and introduced some of the environmental and social issues the project would likely encounter. Questions asked (see underlined text) and responses to questions and discussion points are outlined as follows:

Will GSE avoid protected areas? It was confirmed that GSE was seeking 3 to route lines to avoid protected area where technically possible.

How many alternatives are going to be discussed in the EIA? There should be at least 3 that are considered.

The process has identified as many viable alternatives as possible for Alternatives each route. All viable alternative routes are being considered in an and routing alternatives assessment process, with the number of viable alternatives studies 4 varying from component to component. The ESIA team at SLR ongoing Consulting is working closely with the GSE technical team, to challenge and develop possible alternatives. As well as the consideration of alternative route corridors, alternative routing options for sections of the routes will be considered as more detailed studies are progressed. The routes for all components are still being investigated. The Agency of Protected Areas asked that the latest protected areas information should be used to assist the routing of overhead lines. The

rehabilitation of existing lines within protected areas should be acceptable but for new lines, GSE need to consider the protected area information. The power transmission lines should not damage local ecosystems, as

well as the unique landscapes that are important for both biodiversity and ecotourism. GSE confirmed that the protected areas are being considered in the ongoing studies. GSE noted that this was the reason for the meeting – GSE plan to involve all stakeholders and listen to the information provided. GSE with technical consultants are looking at 5 several alternatives in order to select the most appropriate. The Agency of Protected Areas also noted that if crossing a protected area is unavoidable, then GSE should consider all possible ways for proper rehabilitation, including measures to minimise the visual effect. Visual effects were considered to be directly connected to tourism from which GSE to the local population can be reliant upon for earning income. consider visual impacts adjacent to protected areas SLR Consulting noted that the lines of the routes shown on the 6 presentation are indicative broad corridors only and the routes are still being studied. How are birds considered as they are unpredictable? SLR Consulting outlined that bird surveys were being undertaken in Spring 2018 and that

surveys had been carried out last autumn. Georgian and UK surveyors were being used to identify how significant the populations are, how high 7 they fly and how sensitive they would be to overhead lines. Where Bird studies impacts are potentially significant, a study will be undertaken to see if ongoing effects can be mitigated including the use of bird deflectors on conductor and earth wire lines. Will there be new roads for construction or will GSE use helicopters? GSE outlined that GSE is most likely to use access tracks and is currently 8 searching for access routes. However, it may be necessary to use helicopters in difficult to reach locations. The use of helicopters would only be considered in locations where there is no access by vehicles. What is the result of the geological investigations? GSE outlined that no detailed geological studies have been undertaken as yet. There are 9 some places which cannot be accessed right now due to due to weather condition.

10 It was highlighted that a route through the middle of the Samegrelo Technical Emerald site in Component C (Jvari to Nenskra) was unlikely to get studies

support from the Ministry of Environmental Protection and Agriculture ongoing (MEPA). The attendees, including local environmental consultants,

recommended that GSE should consult directly with the Minister for MEPA. GSE is trying to identify a route that goes along the valley but it is very steep sided. In addition, existing overhead lines (e.g. 500kV

overhead line from Russia) mean that it is likely to be difficult to construct a new line along the Enguri valley in order to avoid the Emerald Site. The Emerald Site shares a boundary with the road and reservoir. In this area the Emerald Site, has been affected by human intervention (e.g. main road to Mestia, areas of logging). The other side of the reservoir which avoids the Emerald Site comprises natural habitat and a route here may be more harmful to biodiversity than a line through the Emerald site. GSE continues to investigate if a route through the valley which minimises impacts on biodiversity can be found. It may not be possible to follow the valley bottom with the only technically feasible route located higher up the valley sides, within the Emerald Site. It was acknowledge by GSE and SLR Consulting that crossing the Emerald Site would require significant environmental surveys and detailed assessment work. GSE indicated that helicopters could be used in case of not accessible areas, within to minimise the associated environmental impacts if the Emerald Site route was selected. GSE will consult the Biodiversity Department and MEPA to discuss this issue further. Consult further with MEPA GSE to Component D - Kakheti region. GSE requested confirmation from the request Biodiversity Department that the shape file held for the Emerald Site in Emerald Site this area is correct. The Agency of Protected Areas recommended that boundaries GSE put this in writing and formally request the files. from MEPA 11 GSE would like to keep to the existing right of way, however, the towers will require replacement, and there is a need to divert the route due to a GSE to number of houses having been built underneath the overhead line. There consult with are also a great number of vineyards in the area. GSE will consult with Wine the wine producers. producing industry Concern was raised by the Agency of Protected Areas that Component E (Kazbegi Region) appears to go through an area being promoted for conservation which is being supported by funding from KfW, who is also the lender for this GSE project. GSE confirmed that this component is required to enable cross border 12 transfer of electricity and is not to connect the Dariali HPP. Studies had not yet started but it was likely that the route would keep to the valley bottom which was likely to be less sensitive than more elevated areas. The alternatives studies which would be carried out would be used to find the least worst impact route.

It was noted that several organisations are involved in conservation projects within the Emerald Sites. All agencies involved with protected GSE to areas and projects to enhance these, work with donors to obtain the consider ongoing finances to do so. Each organisation (such as WWF) undertakes their own studies and surveys to assess the impacts of the conservation conservation projects that they are funding. A concern was raised by the Agency of projects in Protected Areas that should the GSE projects require any changes to the ESIA studies conservation projects then these would be very difficult to implement as

the funding agencies will only be able to fund the detail of the project that was previously agreed. GSE therefore need to work closely with the ministries so that there is no conflict with these enhancement projects. The Roads Department recommended that GSE should give official notice GSE to to the ministers and ask for official road plan information. GSE cannot consult with close roads without approval. GSE confirmed that they will not have the Roads information as to which require closure until the detailed design stage. department GSE want to share their plans and be flexible. The Georgian Government (Ministry of Energy) is currently undertaking a strategic environmental assessment of the Energy sector. GSE should consult with the Ministry of Energy and review the SEA to ensure that the GSE to 14 projects comply with any relevant findings. consult SEA SLR Consulting acknowledged this and confirmed that the project would refer to the SEA once it was available. GSE to The Roads Department asked about impacts of EMF on human health provide 15 and also on fauna and the potential for fragmentation of habitat caused by further EMF. GSE will provide this information at a later stage. information on EMF A question was asked regarding the need for resettlement – SLR Consulting noted that the project is at the early stages at the moment, but some limited resettlement cannot be avoided. Resettlement is a factor 16 that is considered during the consideration of alternatives. GSE aim to select routes with minimal resettlement taking into account other constraints. A Land Acquisition, Resettlement and Compensation framework will be prepared. GSE to It was flagged to the meeting that there is a new forestry code – this will consider new bring in new restrictions with respect to various activities. The code will 17 Forest Code be fully enforced by 2022 but strategic documents will be phased in in ESIA before this. GSE confirmed that they will take note of this. studies The categorisation of Emerald site was clarified by ENVI Consulting. There are 3 categories of Emerald Sites: 1) those already adopted; 2) GSE to candidate Emerald Site which are to be treated as designated; and 3) consult proposed Emerald Sites which do not have any protection at the current MEPA 18 time. An Appropriate Assessment is not a requirement for the proposed further on Emerald Sites, only those that are candidate or adopted. However, the Emerald acceptance process is dynamic so the proposed sites could become sites designated or candidate Emerald Site by the end of the year. Proposed and candidate Emerald Sites should therefore be considered by GSE. GSE to The Agency of Protected Areas recommended that GSE meet with the consult 19 National Forestry Agency (policy department), to discuss projects within National the biosphere reserves. Forestry Agency GSE to consult on The Agency of Protected Areas outlined that there are currently 44 natural natural 20 monuments however these are being currently reviewed/updated by the monuments Agency of Protected Areas. GSE need to consider these. with Agency of Protected Areas

Gamma Consulting asked if the use of underground cable is a possible alternative to overhead lines. GSE noted that in some cases (smaller 21 areas) this could be possible if a number of environmental and social impacts are minimized. GSE and SLR Consulting closed the meeting by outlining that this was the start of the consultation process and that further opportunities for input Minutes to would be available. The minutes of the meeting would be provided to all be circulated attendees and government agencies in attendance would be asked to confirm the minutes and provide any additional feedback.

APPENDIX 04

Complaints and Grievance Submission Form Complaints and Grievance Submission Form

Achara # Name, Last name

Contact Information  Mail: Please indicate the postal address: ______Please indicate the ______preferable means of ______communication (Mail, Telephone, E-mail)  Telephone: ______

 E-mail:______

The language desirable  Georgian for the communication  English  Russian

Describe the grievance/claim: What is the complaint about? What is the claim?

Date of Negotiation: Resolution of Negotiation:

What is the basis of your claim?

Signature: ______Date: ______

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