720MW Karot Hydropower Project Pakistan
Environmental and Social Impact Assessment
Volume VII – Stakeholder Engagement Plan
July 2015
Karot Power Company (Pvt) Ltd
720MW Karot Hydropower Project Pakistan
3015133 PWR EVT 1 B C:\Users\row32675\Documents\Projects\Pakistan Karot Hydro 350133BB01 \Work PIMS 305133 Karot ESIA 12 May 2015 Environmental and Social Impact Assessment Karot Hydropower Project StakeholderVolume VII Engagement - Stakeholder Plan Engagement Plan July 2015
Karot Power Company (Pvt) Ltd
Karot Power Company (Pvt) Ltd Pakistan Office House No. 05 Street 72, F-8/3 Islamabad Pakistan
Mott MacDonald, Victory House, Trafalgar Place, Brighton BN1 4FY, United Kingdom T +44 (0)1273 365 000 F +44(0) 1273 365 100 W www.mottmac.com
Karot Hydropower Project Stakeholder Engagement Plan
Issue and revision record
Revision Date Originator Checker Approver Description A 5 February 2015 H Mills M Lupton M Rowan Draft for client comment M Rowan
B 12 May 2015 M Rowan A Schoene M Maxwell Updated map
C 30 June 2015 M Lupton I Scott I Scott Final for issue
D 31 July 2015 M Lupton I Scott M Maxwell Updated Final for Issue
Information Class: Standard
This document is issued for the party which commissioned it We accept no responsibility for the consequences of this and for specific purposes connected with the above-captioned document being relied upon by any other party, or being used project only. It should not be relied upon by any other party or for any other purpose, or containing any error or omission used for any other purpose. which is due to an error or omission in data supplied to us by other parties.
This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.
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Contents
Chapter Title Page
Glossary of Terms i
1 Introduction 1
2 Project Location and Description 2
3 National and International Regulatory Requirements 11
4 Summary of Previous Stakeholder Engagement 15
5 Stakeholder Identification and Analysis 26
6 Stakeholder Engagement Activities 31
7 Implementation Timescales and Responsibilities 36
8 Project Grievance Mechanism 38
9 Documentation, Monitoring and Reporting 42
Appendices 43 Appendix A. Grievance Form ______44
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Glossary of Terms
Term Definitions in line with International Finance Corporation (IFC) Good Practice Handbook on Stakeholder Engagement (2007) and Performance Standards Consultation Consultation is a two-way process of dialogue between the project company and its stakeholders. Stakeholder consultation is about initiating and sustaining constructive external relationships over time. Grievance Procedure provided by a project to receive and facilitate resolution of affected communities’ Mechanism concerns and grievances about the project’s environmental and social performance. Environmental and A forward-looking instrument that is able to proactively advise decision-makers on what might Social Impact happen if a proposed action is implemented. Impacts are changes that are judged to have Assessment (ESIA) environmental, political, economic or social significance to society. Impacts may be positive or negative and may affect the environment, communities, human health and well-being, desired sustainability objectives, or a combination of these. Information Disclosure means making information accessible to interested and affected parties (stakeholders). Disclosure Communicating such information in a manner that is understandable to stakeholders is an important first (and ongoing) step in the process of stakeholder engagement. Information should be disclosed in advance of all other engagement activities, from consultation and informed participation to negotiation and resolution of grievances. This will make engagement more constructive. Informed Informed participation is a more intensive and active form of consultation. Typically, participation Participation involves a more in-depth exchange of views and information, leading to joint analysis and decision-making. This increased level of involvement tends to generate a shared sense of ownership in a process and its outcomes. Resettlement Action A RAP is developed to manage physical displacement and economic displacement effects of a Plan (RAP) project. It should take account of national law and the requirements of the IFC on involuntary resettlement. Resettlement- Any household involuntarily physically or economically displaced by Project- related changes in affected household land use and ownership or access to natural resources. Physical displacement refers to relocation (RAH) or loss of shelter and economic displacement refers to loss of assets or access to assets that leads to loss of income sources or other means of livelihood. Stakeholders Stakeholders are persons or groups who are directly or indirectly affected by a project, as well as those who may have interests in a project and/or the ability to influence its outcome, either positively or negatively. Stakeholders may include locally affected communities or individuals and their formal and informal representatives, national or local government authorities, politicians, religious leaders, civil society organizations and groups with special interests, the academic community, or other businesses.
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1 Introduction
1.1 Stakeholder Engagement Plan Overview
Karot Power Company (Private) Limited (KPCL) is developing a 720MW Hydropower Project (HPP) (henceforth referred to as the ‘Project’) on the Jhelum River. The proposed Project is in the planning phase and an international standard Environmental and Social Impact Assessment (ESIA) is under preparation.
This document is the Project’s Stakeholder Engagement Plan (SEP). The purpose of the SEP is to manage stakeholder engagement activities for the lifetime of the Project. It has been prepared in line with the laws of Pakistan and the requirements of the International Finance Corporation (IFC) which is providing finance for the Project.
The Project has been identified as being a Category A project which means that it could result in potentially significant and diverse adverse future environmental and/or social impacts. Stakeholder engagement has been planned in line with IFC requirements for Category A projects specifically.
This SEP orients information disclosure, consultation and engagement processes so that stakeholders can best contribute to the Project. The SEP proposes how to engage with stakeholders in ways that enhance the understanding of the Project and its anticipated impacts amongst interested and affected parties. The SEP aims to provide adequate and timely information to affected communities and other stakeholders, and to give these groups sufficient opportunity to voice their opinions and concerns.
The structure of this SEP is: ° Chapter 2: Project location and description ° Chapter 3: Summary of Pakistani legal requirements and international requirements for consultation and disclosure ° Chapter 4: Summary of previous stakeholder engagement ° Chapter 5: Stakeholder identification and analysis ° Chapter 6: Stakeholder engagement activities ° Chapter 7: Implementation timescales and responsibilities ° Chapter 8: Project grievance mechanism ° Chapter 9: Documentation, monitoring and reporting
More details about the Project are provided in the following section.
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2 Project Location and Description
2.1 Overview
The Karot HPP has been under consideration for development since the 1980s. The Project has undergone various design changes and after extensive fieldwork and desk studies, an updated feasibility study was prepared in 2014. The Project is now in the final planning stages prior to construction. The sections below describe the location of the Project and give a summary of its main components.
2.2 Project Location
The Project is proposed to be built on the Jhelum River in Pakistan. The Jhelum River forms the boundary between the province of Punjab in the west and Pakistan-administered Kashmir in the east. The dam will be located near the village of Karot in the Kahuta Tehsil (Pakistan administrative unit) of the Rawalpindi District, approximately 55km south-east of Islamabad. The dam site is accessible via the Rawalpindi-Kotli Road from Beor, and approximately 950m upstream of the Karot Bridge. The bridge is part of the Rawalpindi-Kotli Road and connects Karot village on the right river bank with the Hollar village on the left river bank (when looking downstream).
The reservoir created by the dam will extend approximately 27km upstream and have a volume of 152million cubic metres (Mm 3) at full supply level (FSL) of 461metres above sea level (masl). The powerhouse will be located approximately 650m downstream of the dam and 300m upstream of the Karot Bridge. The proposed Project is located in mountainous terrain and a deep gorge. Figure 2.1 presents the proposed Project location.
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Figure 2.1: Project location
Source: Mott MacDonald based on map included in PES Revised ESIA 2015
The ESIA refers to the: • Project Affected Area (PAA): the area where land is acquired for construction of any component of the Project (or inundation in the case of the reservoir) and where construction and ground works are undertaken. • Project Area of Influence (AoI): the PAA plus the surrounding vicinity where the Project can affect receptors even if there is no direct Project activity taking place, both upstream and downstream of the PAA.
Within the PAA, 74 households in Karot and Hollar will be affected by physical displacement. Table 2.1 identifies 14 villages in the AoI around the dam Project site and the reservoir, where land owners live who own land at the Jhelum River bank edge that will be inundated and hence who will be affected by land acquisition.
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Table 2.1: Villages within the AoI with inhabitants affected by land acquisition due to reservoir inundation River Bank Side (when Villages District Project Area looking downstream) Gorah Rojan Rawalpindi Dam site and reservoir Right Beor Rawalpindi Reservoir Right Oterna Rawalpindi Reservoir Right Soha Rawalpindi Reservoir Right Narr Rawalpindi Reservoir Right Bindla Rawalpindi Reservoir Right Thoon Rawalpindi Reservoir Right Prindla Rawalpindi Reservoir Right Tehriyar Kotli Dam site and reservoir Left Ain Pana Sudhnati Reservoir Left Siah Pura Sudhnoti Reservoir Left Khan Abad Sudhnoti Reservoir Left Pattan Sher Khan Sudhnoti Reservoir Left Azad Pattan Sudhnati Reservoir Left
Source: Laraib Group, May 2014, 2015 correspondence; Mott MacDonald Pakistan
The AoI includes sections of the Rawalpindi district in Punjab province and the Kotli and Sudhnati districts in Pakistan-administered Kashmir.
2.3 Project Components and Layout
The Project comprises a 95.5m high dam, intake, headrace tunnels, surface powerhouse, spillway, a 27km reservoir along the Jhelum River, power transmission equipment, new bridges and roads and a number of associated safety and control features.
Figure 2.2 and Figure 2.3 present a visualisation of the proposed Project and layout of the dam site. The key Project components which are presented in Figure 2.2 and Figure 2.3 are described in Table 2.2.
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Figure 2.2: Visualised Project layout
Source: KPCL (labels added by Mott MacDonald)
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Figure 2.3: Project layout (dam site and lower reach of the reservoir behind the dam)
Source: KPCL (labels and contours of the original riverbed added by Mott MacDonald)
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Table 2.2: Main Project components Component Description Project detail
Dam A typical dam is a wall of solid, impermeable The selected dam type is a rock fill dam with an material built across a river to retain water to asphalt concrete core. The dam will be 95.5m high satisfy a water demand. from its foundations and have a crest length of 460m. Reservoir Building a dam across a river results in the The reservoir will stretch along the Jhelum River creation of a body of water behind the dam. gorge upstream of the dam and reach a length of The size and shape of the reservoir are approximately 27km. The reservoir will be between dictated by the surrounding topography and 320m and 500m wide in the lower reach and height of the dam. narrower when the water level is lower. Currently, the Jhelum River is 30m to 60m wide during the dry season (October to February). The surface area of the reservoir will not be significantly greater than the existing river bed footprint given the steep topography; however the depth of the reservoir will be increased in comparison to the depth of the existing river depth. Intake Water is drawn from a reservoir using an intake The intake structure will be located on the right structure. bank of the Jhelum River between the spillway and the dam. The intake will be installed on the left of the water diversion channel leading to the spillway. The intake will have a total capacity of 1248.4m 3/s and will be positioned at 431.5masl, which is approximately 50m higher than the current river bed at the dam site (approximately 380masl).. Headrace tunnels Water from the intake is channelled into the The Project will have four headrace tunnels that will headrace tunnels. Each headrace tunnel be installed in parallel and transport the water from delivers and accelerates the water into the the intake to the powerhouse. turbines in the powerhouse. Powerhouse The powerhouse will contain the turbines, The powerhouse will be located on the right river generators and other equipment needed for the bank in an above ground structure approximately production of electrical power. 650m downstream of the dam and 300m upstream of the existing Karot Bridge. Four Francis turbines with a capacity of 182MW are proposed to be installed in the powerhouse. Tailrace The tailrace is an outlet of the powerhouse that As the powerhouse is located on the river bank returns the water back to the river once it has downstream of the dam and therefore has a very been through the turbines. short tailrace. Spillway Hydropower schemes incorporate a spillway The Project will have an overflow spillway with six system which allows large flows of water to gates. The spillway structure will be built separately safely bypass the dam in the event of a flood or from the dam on the right river bank and cut across during closure/maintenance of the the natural river bend at Karot. Flood flows will powerhouse. therefore pass through the spillway upstream of the intake and be released downstream of the powerhouse (approximately 700m).
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Component Description Project detail Sediment Sluicing Sluicing gates are gates in a dam near the river The spillway will contain two sluicing gates for Gates bed that are operated to flush the silt and sediment flushing. sediments accumulating in the reservoir over time due to the dam blocking the natural water flow in the river. Diversion Tunnels Diversion tunnels are used to divert the river Three diversion tunnels are planned to be built to flows during construction of the dam or other divert the river flows during construction of the dam. Project elements. Following completion of construction, the diversion tunnels will be blocked for reuse during any dam maintenance works which require the diversion of the river flows. The diversion tunnels will commence between the intake and the dam and end downstream of the dam but upstream of the powerhouse. Coffer Dam Coffer dams are used during construction to The Project will use cofferdams for the construction isolate the foundation area of the dam or other of the dam, diversion tunnels, spillway and structures of a HPP plant, eg powerhouse, powerhouse. from the river flow to enable these areas being Regarding the dam, the cofferdam upstream of the excavated to a suitable foundation depth and dam will remain and be incorporated into the dam the HPP component being installed. structure. The downstream cofferdam will be Cofferdams may be installed temporarily removed following completion of construction. (during construction only) or permanently, ie they are left in situ and are treated to strengthen the dam as needed and ensure its impermeability. Switchyard and Power will need to be exported from the It is planned to install a 500kV switchyard on the Overhead Line powerhouse to the national grid. To export the right river bank, either an air-insulated switchgear electricity, it will have to be stepped up (AIS) adjacent to the powerhouse and connected (increased in voltage) using a transformer at a via underground cables to the powerhouse or a Project substation to connect into the national gas-insulated switchgear (GIS) on top of the transmission system. powerhouse in an auxiliary powerhouse. A 500kV overhead line will be built from the switchyard to export power to the national grid. The length and route of this transmission line are currently not known (refer to the ESIA document for further details). Environmental In run-of-river projects with some diurnal (daily) During reservoir filling, the environmental flow will Flow Release storage, due to the dam and project operation be released through a pipe with a diameter of 1m in the natural river flows downstream are modified one of the diversion tunnels. and in some cases interrupted completely. A During peaking periods during the operational HPP typically releases a minimum amount of phase, it is assumed that the environmental flow will water into the downstream river to ensure that be released at or near the powerhouse location. freshwater and estuarine ecosystems and the human livelihoods and wellbeing that depend on these ecosystems are maintained.
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Component Description Project detail
Fish Passage Depending on the fish species present in a No fish pass is incorporated as part of the Project river, a fish passage may be installed in a HPP design. Fish pass options for this height of dam and in order to allow for the migration of fish across terrain are limited to fish lifts and considered to be the HPP. of limited efficacy and value in this situation in comparison to catch and release, ie catching fish downstream or upstream of the dam and releasing it on the other side of the dam. Details of the ecological impact assessment undertaken as part of this ESIA and comments on the installation of a fish pass are presented in Chapter 10 – Biodiversity of the ESIA Main Report (Volume II). Access roads These are considered to be Project related Road and bridge construction or replacements will facilities. The roads will support delivery of be required in the dam area and in the reservoir equipment and personnel to site, upgrades to area. Internal service roads between the dam, the powerhouse, the water intake and other features existing access roads and creation of new will also be constructed as a part of the Project. permanent access roads and bridges and Access roads where works will be undertaken as possibly some temporary access roads will be known at the time of design freeze (30 June 2015) needed. are part of the Project PAA of the ESIA. Road works along access routes are not included in the PAA but will be addressed by the EPC contractor.
2.3.1 Transmission Line
A 500kV transmission line will be developed to transport power from the HPP to the national grid. The location of the transmission line will be identified by the National Transmission and Despatch Company (NTDC). NTDC will undertake an ESIA separately from the Karot HPP ESIA for the transmission line.
2.3.2 Land Acquisition and Resettlement Impacts
Approximately 2,500 acres will be acquired to for the realisation of Project activities. The land acquisition will cause physical displacement (relocation) of an estimated 74 households (584 persons) in two villages, Karot and Hollar. Another approximately 112 households (823 persons) will lose land only as a result of the construction of the reservoir. Also affected are 78 commercial enterprises, two schools, four mosques, a police check post, a forest check post, two concrete bridges, two suspension bridges, a surface water hydrological gauging station and some 11kV electricity poles. Several thousand fruit, fuel wood and timber trees are also expected to be affected.
Figure 2.4 provides an overview of the resettlement impacts of the reservoir.
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Figure 2.4: Land acquisition for the reservoir
Source: KPCL
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3 National and International Regulatory Requirements
3.1 Overview
This section outlines the key legislation of Pakistan applicable to the Project’s stakeholder engagement process as well as the requirements of the IFC regarding information disclosure, consultation and grievance redress that this Project will meet.
3.2 National Requirements
In Pakistan the main act covering environmental legislation is the Pakistan Environmental Protection Act of 1997 (PEPA or ‘the Act’). The Act establishes the general conditions, prohibitions and enforcement for the promotion of sustainable development. It also outlines the requirements for public consultation that should accompany the ESIA process. There are a number of additional pieces of legislation and guidance documents detailing the requirements for public consultation and information disclosure in Pakistan. These documents include: ° Guidelines for the Preparation and Review of Environmental Reports (1997) ° Policy and Procedures for the Filing, Review and Approval of Environmental Assessments ° Pakistan Environmental Protection Agency Review of Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA) Regulations (2000) ° Guidelines for Public Consultation (1997) ° Land Acquisition Act (1894) (it which requires notifications)
The discussion of national legislation and guidance below is divided into two sections: requirements and principles.
3.2.1 Requirements
The Guidelines for the Preparation and Review of Environmental Reports (1997) state that in order for the ESIA to be credible, fair and transparent, full public involvement should be a part of the process. This should include: making all environmental reports available to the public; publishing lists of decisions – including the requirement for an ESIA and the final outcome of environmental approval; and public availability of any recommendations for mitigation and impact management plans. Information should be arranged so that it is readily accessible and easily understood by all parties. It should clearly state issues in a non-technical way.
According to section 5.3 of the Guidelines for the Preparation and Review of Environmental Reports (1997), good ways to disseminate the information contained within the ESIA include local language video, radio and television, presentations, newsletters and information sheets, displays (supported by members of the study team), gatherings such as local community groups, and small meetings and workshops.
There should be two main phases of consultation during the ESIA: during scoping; and during the preparation, filing and review of the ESIA.
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The Policy and Procedures for the Filing, Review and Approval of Environmental Assessments (1997) requires the project proponents to: ° Prepare the ESIA in consultation with appropriate Federal and/or Provincial Agencies, the local affected communities and relevant Non-Governmental Organisations (NGOs). Proponents must also take account of the comments and views of consulted persons and groups. ° Prior to formally filing the ESIA with the Responsible Authority the project proponent must notify the general public of the proposed project and the availability of the ESIA through a paid advertisement in two national newspapers in general circulation in the affected area, at least one of which must be a non-English newspaper. Publication must be made fifteen days prior to the time the ESIA is filed and the ESIA application must contain copies of the notification. The notification must contain: the location of the Project; the type of project; the name and address of the proponent; a statement that the EIS is on file with the proponent and will be made available to the public for reproduction as and when requested; and the name and the address of the Responsible Authority where the ESIA will be filed (for which the public must be provided access to the Headquarters of the Responsible Authority and at other designated locations). The newspaper notice shall fix a date, time and place for public hearing of any comments on the project or its ESIA. The date for the public hearing shall not be earlier than 30 days from the date of publication of the notice. ° Once an ESIA has been filed, the Responsible Authority must arrange for both the relevant government agencies and the public to provide comments on the ESIA during the 90 day review period. The Responsible Authority must arrange a public hearing of any comments on the project (which must not be earlier than 30 days from the date of publication of the Public Notice).The stakeholders’ opinions and comments must be collected and collated by the Responsible Authority during the review process.
The environmental monitoring results throughout the project should be available to Federal and Provincial Departments and Agencies and to the public and comments should be taken on board by the project team.
3.2.2 Principles
The main document containing principles for public involvement in projects is the ‘Guidelines for Public Consultation’ of 1997. This document states it is important to carry out meaningful consultation in which project proponents clearly explain their proposals to affected communities listen actively to the responses given and make appropriate changes to the proposal to avoid or mitigate negative impacts.
The main objectives of the public consultation meeting given by Pak-EPA (1997) are as follows: ° Informing the stakeholders about what is proposed ° Providing an opportunity for those otherwise unrepresented to present their views and values, therefore allowing more sensitive consideration of mitigation measures and trade-offs ° Providing those involved with planning the proposal with an opportunity to ensure that the benefits of the proposal are maximised and that no major impacts have been overlooked ° Providing an opportunity for the public to influence project design in a positive manner ° Obtaining local and traditional knowledge (corrective and creative), before decision making ° Increasing public confidence in the proponent, reviewers and decision-makers
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° Providing better transparency and accountability in decision making ° Reducing conflict through the early identification of contentious issues, and working through these to find acceptable solutions ° Creating a sense of ownership of the proposal in the minds of the stakeholders ° Developing proposals which are truly sustainable
Conflict resolution approaches must be consistent with local practices. Consideration should also be given to traditional authority structures and decision-making processes wherever possible. The participation of vulnerable groups is also advocated in the guidance. Poor and vulnerable groups often include women, children, those marginalised on the basis of their race or ethnicity as well as those disadvantaged by disabilities or by natural or man-made disasters. Some approaches for facilitating the participation of vulnerable groups include: ° Use of visual methods, carried out in the local setting ° Use of local materials ° Calling on local knowledge as inputs into project design
In addition to this, consideration of issues such as seasonality, which affects workloads as well as transport if roads are flooded, will assist in facilitating the participation of poor and rural communities. Facilitating women’s involvement in consultation activities is also desirable according the Pakistani guidance as women’s roles, workloads and sometimes community or national customs can prevent them from participating. Suggested ways to encourage the participation of women include the careful choice of time and place for meetings that take account of women’s schedules and the availability of safe transport. In order for meetings to be organised in accordance with local vulnerable people’s practices and workloads, preliminary information gathering should be undertaken to investigate gender roles, needs, activities, access to resources, existing institutions and constraints over their participation.
3.3 International Requirements
The IFC, established in 1956, is the private sector arm of the World Bank Group. Public consultation, disclosure and stakeholder engagement are key requirements of IFC’s Policy on Social and Environmental Sustainability embodied within the Performance Standards (PS) of 2012.
The eight IFC PSs are applicable to private sector projects in emerging markets. Each PS has specific consultation requirements and these are embedded in the general requirements specified in PS 1: Assessment and Management of Environmental and Social Risks and Impacts. These requirements specifically refer to the need for and means of achieving community engagement, disclosure of relevant project information, appropriate consultation processes and grievance mechanisms throughout the project lifecycle. The main requirements for stakeholder engagement in projects are: ° Start as early as possible in the project cycle ° Continue throughout the life of the project ° Be free of external manipulation, interference, coercion, or intimidation ° Where applicable enable meaningful community participation
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° Be conducted on the basis of timely, relevant, understandable, and accessible information in a culturally appropriate format
IFC’s Access to Information Policy states that for a Category A project, like this one, a summary of review findings and recommendations must be disclosed and include as a minimum the following information: ° Reference to the PSs and any applicable grievance mechanisms, including the compliance advisor/ombudsman ° The rational for IFC’s categorisation of the project ° A description of the main social and environmental risks and impacts of the project ° Key measures identified to mitigate those risks and impacts, specifying any supplemental measures and actions that will need to be implemented to undertake the project in a manner consistent with the PSs ° Electronic copies or web-links to any relevant environmental and social impact assessment (ESIA) prepared by the developer ° Any additional documents such as Action Plans, SEPs, Resettlement Action Plans (RAPs)
Project reports with information should be disclosed on IFC’s website.
IFC PS7 requires that if any indigenous people are adversely impacted as a result of the Project, then the Project must obtain Free Prior Informed Consent (FPIC).
FPIC requires that the Project Company builds on and expands on the engagement process as stated above. It will include good faith negotiations with the Project Company and the indigenous peoples. These negotiations will be documented and evidence will be provided of the outcome of negotiations. FPIC does not necessarily require the negotiations to be unanimously approved.
FPIC will involve indigenous peoples’ representative bodies and organisations, as well as members of affected communities and indigenous peoples and will provide sufficient time for indigenous peoples decision making processes.
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4 Summary of Previous Stakeholder Engagement
4.1 Overview
This section presents consultations that have been carried out thus far for the Project. It covers the feasibility (2009) and detailed design (2014-2015) periods.
4.2 Stakeholder Engagement carried out during the Feasibility Study (2009)
During the Project feasibility stage completed in 2009, an environmental impact assessment (EIA) was also carried out. Scoping sessions were held with 39 Project-affected persons in three different locations in the Project area; refer to Table 4.1 for details. An assessment of the views of affected persons was made regarding their perceptions, apprehensions and reactions about the construction of the Project. ).
Table 4.1: Summary of the Consultations undertaken during Feasibility Study (2009) No. of No. Date Objectives Person/agency Consulted Participants Group Discussions at Scoping Sessions for Project Information Disclosure 1 18 June 2009 Project disclosure to Community of Karot Village 17 Affectees 2 19 June 2009 Project disclosure to Community of Gorah Village 14 Affectees 3 19 June 2009 Project disclosure to Community of Tandal Village 8 Affectees Total participants: 39
Most of the people expressed their fears that that they might be not properly compensated for their assets. The main demands and expectations of affected persons at that time were: reasonable compensation for losses of their assets, such as land, houses, and shops; and prompt and transparent payment of cash compensation so that they could resettle at the places of their own choice.
4.3 Stakeholder Engagement carried out during Detailed Design Studies (2014)
A series of consultation activities were carried out in June and July 2014 as part of the ESIA undertaken by Pakistan Engineering Services (Pvt) Ltd (PES). These activities consisted of scoping consultations and consultations during the ESIA. Focus group discussions as well as one-to-one meetings with institutions were held. A KPCL leaflet was distributed at meetings.
4.3.1 Meetings with Village Stakeholders
Meetings were held with villagers in Karot, Gora, Samsu, Soan, Brohi, Hollar, Muslimabad and Ain Pana Villages. At the time of the meeting it was considered that these were the villages that would be impacted by land acquisition in the PAA. It is now understood that this list is not correct (refer to list of affected villages in Table 2.1). In total, 91 people attended meetings in the seven villages, as shown in Table 4.2 below.
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Table 4.2: Name of Villages and Number of Participants Consulted Village/Settlement Date No. of Participants Karot (Right Bank) 29-06-2014 40 Gorah (Right Bank) 30-06-2014 5 Sansu (Right Bank) 29-06-2014 2 Soan (Right Bank) 29-06-2014 3 Barohi (Right Bank) 29-06-2014 8 Hollar (Left Bank) 29-06-2014 22 Ain Pana (Left Bank) 28-06-2014 10 Total number of participants 91
Source: Pakistan Engineering Services (Pvt) Ltd
During the village meetings participants were presented with drawings and introductory information about the Project and its likely impacts in Urdu.
Figure 4.1: Consultation with Ain Pana Village Figure 4.2: Scoping Session with affectees of Hollar Community Village
Source: Pakistan Engineering Services (Pvt) Ltd Source: Pakistan Engineering Services (Pvt) Ltd
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Figure 4.3: Consultation with a shopkeeper in Ghora Figure 4.4: Consultation in Karot Village Village
Source: Pakistan Engineering Services (Pvt) Ltd Source: Pakistan Engineering Services (Pvt) Ltd
There was general support for the Project amongst affected villagers however some people had concerns regarding the price to be paid for land to be acquired. Table 4.3 outlines the key concerns raised by communities during the ESIA and the responses provided.
Table 4.3: Main results of 2014 ESIA consultations Community Main Concerns Information Disclosed and Response to Comments Compensation should be paid before start of ESIA consultants introduced themselves and briefed the community the construction of project. about the project. Lack of Health facilities in the village. Key points were: Job opportunities for project area people • Karot Hydropower project is to be built at Karot Village. according to their qualification. • The proposed Dam site is accessed by Rawalpindi /Islamabad Road. There is a scarcity of land, so rates to be based • The proposed dam and powerhouse are located on the Right bank of on double than market rates. Jhelum River at Karot Village. People preferred to be resettled at new site • The project will produce 720MW Electricity; reservoir length is 27km, provided by the project. up to upstream of Azad Pattan Bridge. Steps should be undertaken for establishment • of health and education facilities in the project Land will be acquired up to 461-480m due to creation of Reservoir. area. • Agreed upon compensation will be provided according to the National Relocation sites of displaced persons should be and International guidelines for your lost houses, trees and land. prepared complete with basic social • They were assured that their issues and suggestion will be taken in to infrastructures before shifting the displaced consideration in the report of RAP. persons to a particular relocation site in case of • Described that land rate will be decided after the negotiated by AC inadequate compensation rate. and Community. Free electricity should be provided to the affectees of the Project area.
Source: Pakistan Engineering Services (Pvt) Ltd
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4.3.2 Meetings with Governmental and Non-Governmental Stakeholders
Meetings with government departments, line agencies and NGOs were held during 2014 to discuss the Project and its potential impacts on the local communities and environment. In these meetings, stakeholders were informed about the salient features of the Project, its location and activities. The main concerns, suggestions and recommendations for the implementation of the Project were: ° The Project proponent should fulfil the regulatory requirements of conducting an EIA ° Possible damage to flora and fauna should be addressed ° Construction related issues such as disposal of excavated material, soil erosion and hazards for local communities and workers should be appropriately addressed during the construction activities ° The EPC contractor will need to ensure free mobility of women and children, especially people of Karot and Hollar villages; access will need to be considered carefully ° Safe transportation of construction material ° Provision of occupational health and safety measures ° Employment of local residents during construction and operation of the Project
During 2014, meetings were held with the Deputy Commissioner Office Kotli; Communication & Works Department, Rawalpindi; Assistant Commissioner Office, Kahuta; Commissioner’s Office, Rawalpindi: Private Power and Infrastructure Board (PPIB), Islamabad; National Transmission and Dispatch Company (NTDC); and Ministry of Water & Power, Islamabad. Meeting summaries were provided in the initial stakeholder report prepared to accompany the national ESIA. Results of discussions were reflected in the national ESIA report.
4.4 Charters of Demands
Towards the end of the ESIA process, during meetings held in Karot and Hollar villages on 14 November 2014, Charters of Demands were presented to the Project on behalf of the affected people. The main points of the Charters are shown in Table 4.4 and Table 4.5. During the meetings, KPCL responded, stating that rational demands would be listened to and negotiations would be undertaken.
Table 4.4: Charter of Demands of Karot resettlement-affected persons, November 2014 Number Charter of Demand 1 We are not against the dam; we are ready to give a part of our land which is only being affected by the Project. 2 At this stage, at the start of the Project, we have not enough money to rebuild our houses in new settlements. 3 We are ready to give required land for Project. But the price of land should be determined with negotiation of the affectees. It should not be fixed by one sided. 4 We do not have enough resources to look after our family and the Project should not create further problems for us. 5 As for as security is concerned, security guards can be deployed and fencing can be built. 6 As for as Project workers’ accommodation is concerned, it can be established elsewhere and workers can be brought through transport, such as with Beor campus. 7 The affectees regarding to their business loss at Karot Village should be compensated properly, so that they can have suitable alternative business opportunity.
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Number Charter of Demand 8 We, the people of Karot Village want justice and compensation for our land which should be equal to the land of AJK, so that we have better housing status and we can better look after our children. 9 In other words, we take rights and will go to Court for our rights.
Source: PES Stakeholder Engagement Report
Table 4.5: Charter of Demands of Hollar resettlement-affected persons, November 2014 Number Charter of Demand 1 We are not against the Dam; we are ready to give a part of our land which is only being affected by the project. 2 Land compensation should be as per market price. 3 50% of jobs in the Project construction activities should be given to left bank affectees. 4 Fair compensation should be paid for lost assets. 5 Free plots should be given to affectees. 6 We demand land for houses but want to be reconstruct our houses by ourselves.
Source: PES Stakeholder Engagement Report
Resettlement-affected people in Karot village also called a meeting with their Minister of the National Assembly (MNA) of Pakistan at the Beor camp office on 6 January 2015 to discuss their apprehensions regarding the compensation and resettlement. Participants were: ° Federal Minister for Petroleum/MNA ° General Secretary of the Pakistan Muslim League-Nawaz (PMLN) District Rawalpindi ° President of PMLN Tehsil Kahuta ° Three Committee member of resettlement-affected persons of Karot Village ° Two resettlement-affected persons of Karot village
At this meeting, a separate Charter of Demands specifically on resettlement issues was presented by the village committee members to the Minister.
Table 4.6: Charter of Demands presented by Karot Resettlement Committee to Minister, January 2015 No. Demand Response from Minister 1 The affectees of Karot village are emphasising that There was a suggestion from Federal Minister that the the land price should be equal to the prices in AJK. company provides the affectees with the equivalent land for the whole village anywhere in the nearby area or 2 The affectees are also demanding that they should be 1 anywhere else. The affectees replied that first they given 300 - 500 Kanals in Karot village in a location would like to see the land and if it suits them they will not required by the company so that they can build accept it. their houses in that area. The affectees were also requested by Federal Minister 3 The President of PMLN Tehsil Kahuta also suggested to cooperate with Building Department for the physical that the average price for the whole of Karot village survey and assessment of their houses to finalise the (all types of land) should be determined as on lump survey works. However the affectees refused and sum basis.
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No. Demand Response from Minister 4 The affectees demanded land for houses but for the mentioned that first they want to know the final price for houses to be reconstructed by them. their land and once it is agreed then they will allow survey works.
Overtime the Karot village community members have refined what they want. In March 2015, the latest Charter of Demands was issued; refer to Table 4.7.
Table 4.7: Charter of Demands of Karot resettlement-affected persons Number Charter of Demand 1 Only the specific area related to the project should be acquired, not the whole area. 2 The whole area of Karot village should be measured and specified. 3 The Whole area should be taken on monthly rent till the project completion. 4 After the completion of the project, the price of the used area should be fixed including: commercial area, cultivating land, residential area, unpopulated land 5 The extra area that is not included in the project should be given back to the people so that they may reside there. 6 We don’t want to leave the ancestral area at any cost. 7 The people of the village should be provided residence during the period of the completion of the project. The residential rent must be paid by the construction company on behalf of the inhabitants 8 If we are to be displaced from the area forever we must be given enough compensation so that we may reside at any place easily. 9 The compensation must be given equal to the rate of Azad Jammu & Kashmir. 10 Apart from compensation we must be given a piece of land with all facilities that we enjoy here. 11 The people who have some business here must be compensated according to their monthly income so that they may start their business elsewhere. 12 We are the citizens of Pakistan and our basic rights must be preferred. 13 The compensation must be given according the land value of Kahuta or Nara city. 14 Every family should be given plots beside the residential home so that the people may not face the problem populating and adjusting their children in future. 15 The people of the areas should be taken in confidence before starting the project work. 16 During testing boring and tunnelling tests we had been told that electricity would be generated from these tunnels, but now they the whole village has been acquired forcefully, which is an open injustice to us. 17 We have not been given any notice not to carry on any construction work for the last four years; many people have been building the residential home in the area. If the concerned authority had informed us before time, we would not have carried out additional constructions. We should not be forced. All the families coming under the project should be given the residential home in the same area. 18 If the project is constructed the people of the native area must be preferred in job Quota. 19 Our forefathers are buried in this area and we must not be restricted to visit their graves. 20 Lastly we request the concerned authorities that unless the people of the area are taken into confidence the project work may not be started.
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4.5 EPA Public Hearings in April 2015
After the submission of the national ESIA in February 2015, the EPA in Pakistan-administered Kashmir and the EPA in Punjab each organised a public hearing in Hollar and Karot respectively, within days of each other. The EPAs advertised the EPA hearings in both local and national newspapers.
The consultations were primarily intended to discuss the findings of the ESIA but much of the presentation and discussion focused on land and resettlement issues. Local administration and line ministries like forestry were represented as well as the public. Just over 30 participants registered their attendance in Karot and over 135 were at the Hollar meeting. Issues presented at the hearings related to: ° Land valuation and resettlement compensation ° Need for health and education infrastructure in the area ° Hydropower being environmental-friendly ° Prevention of biodiversity damage ° Provision of free electricity ° Employment opportunities for local people ° Need for more consultation on land ° Meeting the EIA regulatory requirements ° Protection of community through proper and safe construction measures ° Need to ensure free mobility of women and children ° Provision of occupation health and safety equipment.
Figure 4.5: Consultation at Karot village Figure 4.6: Consultation at Hollar village
Source: Sustainable Solutions Source: Sustainable Solutions
4.6 Women’s Perspective
A meeting was held on 10 April 2015 between IFC and representatives of women from Karot village. The women raised fears over the Project activities. The following photographs are from the women’s consultation.
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Figure 4.7: Women’s consultation Figure 4.8: Women’s consultation
Source: Sustainable Solutions Source: Sustainable Solutions
4.7 Meetings to Agree Land Compensation
Kohsar Trading Company, a subsidiary of Laraib Group (Laraib Group), a Pakistani consultancy firm was hired in early 2015 in order to negotiate the land prices for the RAH in Punjab province. Consultations started in March 2015 and are ongoing. Laraib Group has been given permission by the National Electric Power Regulatory Authority (NEPRA) to negotiate land prices individually with land owners. The company Sustainable Solutions has been documenting the consultations between Laraib Group and relevant local government entities and will be documenting the negotiations. Table 4.8 provides an overview of the consultations and negotiations that have been completed so far.
Table 4.8: Meetings held to agree land compensation No. Concern raised Date Reason for meeting 1 Local villagers, revenue staff, 14/07/2015 Discussing and resolving the list of concerns from KPCL representative Karot village. Changes to a draft agreement. 2 Assistant Commissioner 13/07/2015 Discussing and resolving the list of concerns from Kahuta, revenue staff, KPCL Karot village. Changes to a draft agreement. representative, Committee members and majority villagers 3 Assistant Commissioner 10/07/2015 Discussing and resolving the list of concerns from Kahuta, Committee members Karot village. Changes to a draft agreement. and villagers 4 Assistant Commissioner 08/07/2015 Discussing and resolving the list of concerns from Kahuta, Revenue staff, KPCL Karot village. Preparation of a draft agreement. representative, Committee members and few villagers 5 Assistant Commissioner 07/07/2015 Discussing and resolving the list of concerns from Kahuta, four Committee Karot village. Changes to draft agreement. member
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No. Concern raised Date Reason for meeting 6 District Administration 04/07/2015 Meeting with Karot villagers independently of Laraib (including Commissioner , Group and Sustainable Solutions. Discussion on new District Coordination Officer, list of concerns from Karot village. Assistant District Commissionner, Assistant Commissioner Kahuta) and seven member committee 7 KPCL and affected persons 16/05/2015 The draft agreement was agreed and shared with committee other stakeholders like KPCL and PAPs for feed back 8 NEPRA 13/04/2015 To discuss approval for private negotiations 9 Mr. Shahid Khaqan Abbasi 27/03/2015: Preparation of a draft agreement for the negotiated and affected persons resettlement / compensation. 10 Assistant Commissioner Various dates February – To develop understanding about the project and Kahuta March 2015 compensation mechanism 11 Assistant LAC Rawalpindi Various dates February – To develop understanding about the project and March 2015 compensation mechanism 12 Commissioner Rawalpindi Various dates February – To reach an agreement on a mechanism for topping March 2015 up of the difference in rates of the land and non-land assets between AJK and Punjab 13 Senior Member Board of 10 March 2015 To reach on a mechanism for topping up of the Revenue Punjab difference in rates of the land and non-land assets between AJK and Punjab 14 Meeting with NEPRA 20 March 2015 To agree on the mechanism of private negotiations as suggested by the Board of Revenue 15 Meeting with PAPs and 26 March 2015 To share the mechanism of private negotiations with Member of National PAPs and their political representatives. Assembly from the area
Source: Sustainable Solutions
Negotiation meetings were held in June 2015 facilitated by the Minister for Petroleum and the Elders’ Committee set up to represent the residents of Karot village. The meetings did not conclude in agreement and thus Laraib Group will organise further meetings with the locals to reach an agreement in July 2015.
4.8 ESIA and RAP Public Consultations in July 2015
Public consultation meetings on the draft international ESIA and RAP were organised at Azad Pattan and Soha on 25 and 26 July respectively. Table 4.9 contains a summary of the issues raised by stakeholders during the public consultation meetings. Detailed minutes of meetings are provided in Appendix C of Volume III - Technical Appendices.
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Table 4.9: Main results of July 2015 ESIA and RAP consultations Community Main Concerns Information Disclosed and Response to Comments There is a requirement for the Project to provide KPCL and the ESIA and RAP consultants introduced themselves some form of community investment, Some issues and briefed the community about the project. raised included: Responses to communities concerns were: • Clean and safe drinking water facilities • A community investment/social uplift programme will be run as • Electricity should be provided free part of the Project • Health care facilities for women. • The dam is not a storage dam, so water will be continuously • A girl’s school flowing and water level will not rise to the extent that it will cause land slides Landslides were of concern and a request that • buffer zone should be larger because the high PAPs will have priority employment on the Project. level of water which will make the land vulnerable • The ESIA includes impacts on biodiversity and the ESMP includes to landslides. measures to deal with loss of forests. Requests that local people are hired for skilled and • PAPs were provided with contact details for the Project and told unskilled positions on the Project that they could use the contact details if they had any concerns Deforestation will occur which will cause about the Project environmental impacts. • Negotiations are in place so that all affected households will The resettlement compensation packages must be receive similar resettlement compensation same for everyone
Source: Sustainable Solutions
Some of the pictures from the public consultation are presented in Figure 4.9 to Figure 4.12 Error! Reference source not found. .
Figure 4.9: Consultation in Soha Village Figure 4.10: Consultation in Soha Village
Source: Sustainable Solutions July 2015 Source: Sustainable Solutions July 2015
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Figure 4.11: Public consultation Azad Pattan Figure 4.12: Public consultation Azad Pattan
Source: Sustainable Solutions July 2015 Source: Sustainable Solutions July 2015
Women were also consulted in Azad Pattan on 25 July 2015. Women’s concerns were focused on community investment programmes and employment. Figure 4.13 and Figure 4.14 provide photographs of the women’s consultations in Azad Pattan.
Figure 4.13: Women’s consultation Azad Pattan Figure 4.14: Women’s consultation Azad Pattan
Source: Sustainable Solutions July 2015 Source: Sustainable Solutions July 2015
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5 Stakeholder Identification and Analysis
5.1 Overview
Stakeholders are persons or groups who are directly or indirectly affected by a project, as well as those who may have interests in a project and/or the ability to influence its outcome, either positively or negatively. Stakeholders for the Project include locally affected communities and their formal and informal representatives, national or local government authorities, civil society organisations and groups with special interests, the academic community, or businesses.
5.2 Categorising Stakeholders
Just as the degree of stakeholder interest may vary throughout the Project lifecycle, the most appropriate communication and consultation methods will vary among stakeholders. By identifying appropriate consultation methods in advance, this Project aims to give all stakeholders equal opportunity to participate and influence the ESIA process.
An analysis of Project stakeholders, interests, and suggested communication and consultation method is summarised in Table 5.1Error! Reference source not found. below.
Table 5.1: Stakeholder Identification and Analysis Stakeholders Communication and Stakeholder Group Identified Relevance to Project Consultation Methods Local community groups and organisations People affected by Residents of: Interested in how much land will be needed for Meetings with resettlement land acquisition and Karot the Project, what effect it will have on them, affected people. resettlement what price they will receive for lost land and Hollar Visits to homes and land other assets, compensation procedures, plots to undertake surveys Another 14 timescales, entitlements. and negotiate settlements. communities with land owners who Provision of RAP in Urdu will be affected Resettlement specific by economic grievance mechanism. displacement(ref er to the villages listed in Table 2.1) Project affected Villages identified Interested in how the Project will affect them Meetings in Urdu with communities above during its lifetime, in particular in regard to community members and employment opportunities and changes to flow representatives in an regime. ongoing manner. Community Villages identified Interested in how the Project will affect their EPA Public hearings at representatives above people during its lifetime. Karot and Hollar in Urdu including elders and accessible to all. village leaders
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Stakeholders Communication and Stakeholder Group Identified Relevance to Project Consultation Methods Vulnerable groups Poor, women, There is the potential for vulnerable groups to Public consultations at disabled, elderly be excluded from communications and additional appropriate and sick people. management measures. locations Measures to enable their inclusion in the Provision of Project Project will be identified and implemented. information, including a brochure and video, in Urdu. Ongoing engagement via KPCL and EPC Community Liaison Officers. Project grievance mechanism. Members of the Potential for construction nuisance with Meetings to determine Gujjar indigenous regards to traffic movement and noise s may FPIC. group impact their seasonal migration through the Meetings with group Project area leaders. Information about the construction plans, especially in relation to the bridges, and provision of access from the right to left bank provided. Project employees and jobseekers Employees and Preferential Interested in employment opportunities As for project affected prospective treatment will be throughout lifecycle of the Project, health and communities. employees given to safety issues and in labour standards Engagement with Project (direct/indirect) displaced people (including workers’ accommodation staff members responsible and “local” standards). for human resources, people, defined workers’ liaison and as from the three recruitment. districts Worker grievance mechanism. Representatives of Interested in labour standards and workers’ Engagement with Project workers’ unions rights. staff members responsible for human resources, workers’ liaison and recruitment. Worker grievance mechanism. Governmental Authorities Punjab Will provide approval of Project and Face-to-face meetings. Environmental environmental permitting. Project contact provided for Protection Agency direct feedback. (EPA) and EPA of Pakistan- Notification of availability of administered ESIA documentation in Kashmir English and NTS in Urdu/Punjabi.
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Stakeholders Communication and Stakeholder Group Identified Relevance to Project Consultation Methods Revenue Project will collaborate with them to carry out Face-to-face meetings. Departments of acquisition of private land or built-up property Project contact provided for Punjab and Pakistan- for public purposes. direct feedback. administered Can provide useful insights to assist in impact Kashmir Notification of availability of and mitigation identification. ESIA documentation in Should be informed about Project progress. English and NTS in Urdu/Punjabi. Departments of Can assist with evaluation of affected trees Face-to-face meetings. Agriculture, and crops for compensation purposes. Project contact provided for Horticulture, and A ‘No-Objection Certificate’ (NOC) from the direct feedback. Forestry and Wildlife respective Forest Departments and Local Notification of availability of Administration is required. ESIA documentation in Can provide useful insights to assist in impact English and NTS in and mitigation identification. Urdu/Punjabi. Should be informed about Project progress. Planning and Can provide useful insights to assist in impact Face-to-face meetings. Development and mitigation identification. Project contact provided for Department, Should be informed about Project progress. direct feedback. Fisheries Department, Social Notification of availability of and Welfare ESIA documentation in Department, Energy English and NTS in Department Urdu/Punjabi. Departments Collaboration will be needed for relocation of Face-to-face meetings. responsible for public public facilities for the Project. Project contact provided for facilities such as direct feedback. electricity and telephone poles, Notification of availability of public water supply ESIA documentation in schemes, public English and NTS in buildings, Urdu/Punjabi. transportation Local Government The Project will need to liaise with local Face-to-face meetings. officials in the Tehsils authorities for the establishment of Project contact provided for and in the three construction camps, quarries, spoil sites, use direct feedback. affected districts: of water resources, safe disposal of Rawalpindi, Kotli and wastewater and waste. Notification of availability of Sudhnuti ESIA documentation in English and NTS in Urdu. Emergency Service Fire, health, Need to be informed about the Project’s Notification of availability of Providers police and progress and possible threats/safety hazards ESIA documentation in security services. as they may play a crucial role in providing English and NTS in emergency services when required. Urdu/Punjabi. Access to website for project documentation. Non-government organisations
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Stakeholders Communication and Stakeholder Group Identified Relevance to Project Consultation Methods Non-governmental Transparency NGOs with interests in human rights, Notification of availability of organisations Pakistan environmental conservation or large ESIA documentation in (NGOs) and Civil infrastructure projects. English and NTS in Society Interested in impacts of Project and research Urdu/Punjabi. Organisations opportunities. Access to website for Potentially stringent observers and project documentation. commentators. Public consultation event. Depending on mission and understanding of the Project area, could act as a partner in implementing or monitoring. Others Higher education Interested in impacts of Project and research Access to website for institutions opportunities. project documentation. Will provide candidates for employment in the Public consultation event. operational phase. Potentially stringent observers and commentators. Media Newspapers Interest in the Project’s impacts and status. Public consultation event. Radio Access to website for Television project documentation. Business partners Business partners will have an interest in the Public consultation event. and other local development of the Project, in particular Access to website for suppliers and economically. project documentation. businesses
5.3 Vulnerable Groups
The Project team recognises that vulnerable, marginalised and disadvantaged groups are likely to experience impacts differently from mainstream society. For instance, they may be less able to cope with change such as influx of workers into the area than a typical community household. As such, the ESIA reflects the differential impacts of the Project on these groups where evident. Consultation activities will be used to gather information and opinions on how different groups are affected. Consultation and information disclosure activities will take into consideration logistical and cultural factors such as language, physical access, literacy levels, and time availability of these groups.
Taking into account cultural traditions, separate meetings have been held throughout the preparation process with women to encourage their involvement in the Project. During the undertaking of surveys, the ESIA teams have included gender specialists to interview women and hold focus groups with them. During public consultations, separate meetings for women are advised.
5.4 Indigenous Groups
Indigenous peoples are particularly vulnerable if their lands and resources are transformed, encroached upon, or significantly degraded. The Gujjar nomads who seasonally reside for short periods of time close to
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Hollar can be identified as indigenous peoples because they have distinct characteristics and are vulnerable, namely: ° They self-identify as a particular group and tend to marry within the group ° They have traditional routes that they seasonally follow and have been doing so for generations ° They recognise themselves and are recognised by others as a distinct social group within Pakistan by mainstream society ° They have their own language although they can converse in more mainstream languages
Gujjars are considered highly sensitive social receptors because they are collectively attached to an existing route and live in a subsistence lifestyle with more vulnerability to impoverishment risks than mainstream society. However, adverse impacts on the Gujjars can mainly be avoided by the Project. For the following reasons: ° Gujjars pass through and sometimes stay in Hollar for a few days during seasonal migrations, using the Azad Pattan and Karot-Hollar bridges. Gujjars will not be affected by severance (a physical barrier) for getting from the right bank to the left. They will be able to follow their traditional routes. ° Gujjars have some flexibility with regards to resting spots and it is not expected that the land acquisition on the left bank by the Project will make any substantial reduction in their choice of resting place or transform lands to which they have a collective attachment. ° Gujjars may encounter some minor construction nuisance in the form of increased traffic and construction noise during their seasonal treks. This nuisance would be temporary in nature and with considerate contractor appreciation can also be managed to avoid adverse impacts.
Construction nuisance is considered negligible in magnitude because it will be temporary (for only a few days during construction), affect a very tiny number of Gujjars and their animals, and have very little effect on their well-being. The Community Liaison Officers (CLOs) will need to make special efforts to liaise with the Gujjar community members who seasonally pass through Hollar and to obtain FPIC. Additionally information about the construction plans, especially in relation to the bridges, and provision of access from the right to left bank will need to be provided. The potential for construction nuisance with regards to traffic movement and noise should also be discussed and where appropriate additional mitigation measures identified.
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6 Stakeholder Engagement Activities
6.1 Overview
This section describes the main activities that will be undertaken throughout the ESIA process and on an on-going basis throughout the life of the Project. The stakeholder engagement activities serve two key purposes: ° Disclosing appropriate information about the Project and the ESIA process. Disclosure of relevant Project information helps stakeholders understand the risks, impacts and opportunities of the Project. Consultation activities are more informed and constructive if stakeholders have accurate and timely information about the Project and its impacts. ° Providing relevant stakeholders with the opportunity to voice their opinions, preferences and grievances. This enables participation and involvement in the planning and design process.
The various engagement and disclosure activities to be undertaken for the Project are based on principles related to informed consultation and participation as detailed within IFC PS1.
6.2 Informed Consultation and Participation
6.2.1 Overarching Approach
All stakeholders, including NGOs and members of affected communities, have the right to participate in the ESIA process from the scoping phase onwards. The level of involvement will range from receipt of information and key documents to face-to-face meetings and other methods of feeding back comments and concerns. Local communication channels and public mass media will be used to enable accessibility of information to the greatest number of people. Different forms of media such as phone calls and meetings will be used to communicate information to those with literacy problems.
Members of KPCL’s Social and Environmental Department will be responsible for coordinating the implementation of the activities outlined in Table 5.1. The Social and Environmental Department will attend public hearings and consultations and will receive and note the concerns of affected communities on issues that affect them directly and will incorporate their views into its decision-making process. They will be assisted during the design phase by two companies; Mott MacDonald Pakistan, who will assist with logistics and planning the meetings and Sustainable Solutions who will minute the meetings. Once appointed the Community Liaison Officers (refer to Section 6.2.3) will take over the role of coordinating and implementing the activities. Due to the time period over which consultation has been carried out for the Project there may be a sense of impatience amongst affected persons. Further, any new consultation to be carried out prior to construction starting may create confusion and possibly consultation fatigue, which can mean that stakeholders are less willing to participate in consultation activities. When conducting stakeholder engagement, Project parties will consider these issues and explain to participants that the process is ongoing and that comments they have already submitted have been listened to and are valued.
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6.2.2 Consultation and Participation Process
In recognition of the potentially significant changes to people in the Project Area of Influence’s lives, the consultation process will: ° Capture both men and women’s views in separate engagement activities if necessary ° Reflect men’s and women’s different concerns and priorities about impacts, mitigation mechanisms, and benefits ° Inform affected communities how their views and concerns have been incorporated into the Project’s plans and how adverse risks and impacts will be avoided
6.2.3 Community Liaison Officer
When activities commence at site, KPCL and the EPC contractor will identify three Community Liaison Officers (CLOs) who will work under the Social and Environment Department of KPCL. They will be responsible for community liaison and arranging communications with affected communities and ultimately will be responsible for the implementation of this SEP. The CLOs will be based out of a Project office in Punjab, in AJK, Beor or Islamabad. The CLOs, if male, may be supported by female colleagues who will handle the CLO responsibilities for liaison with women from affected communities. The CLOs should be constant throughout the Project and will be largely responsible for implementation of the SEP, particularly receiving and channelling comments and concerns during the ESIA phase and management of the grievance mechanism during the construction and operational phases. The CLOs will also attend and record stakeholder engagement activities and maintain lines of communication with the village leaders and community members directly (also refer to Section 9).
6.2.4 Use of Electronic Media
The Project website www.karotpower.com will be used to advertise the availability of ESIA documentation, to provide links to the documents, and to publish relevant news of interest to the public about the Project. It will also have a feedback page so that stakeholders can contact KPCL with views or concerns about the Project.
Many websites in Pakistan are in English because of the challenges of printing and the assumption that most computer users are literate in English, a national language. However, KPCL understands the need to communicate to local and national stakeholders in Urdu, the more common vernacular. The environment and social webpage will have links to Project information in both English and Urdu.
6.3 Consultations during the 2015 ESIA
The ESIA undertaken in 2015 will build on the national ESIA produced by PES and meet the requirements of IFC, a Project lender. The ESIA will identify the likely environmental and social risks and effects associated with the Project. As part of the ESIA, the following activities relevant to public disclosure and meaningful consultation are planned to meet international requirements: ° ESIA Scoping Disclosure and Consultation:
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– Scoping meetings were conducted by PES in 2014 Ltd – This SEP will be published on the Project website (www.karotpower.com ) ° Draft ESIA Disclosure and Consultation: EPA held hearings on the national ESIA in April 2015 in Karot and Hollar – The ESIA will be prepared giving due consideration to the views and concerns of affected communities – Announcements will be made using culturally appropriate means including banners, local posters, local newspapers, the Project website and village leaders informing their constituents. The ESIA NTS will be available for review. Public consultation meetings will aim to provide two weeks’ notice with location and timing details. Letters will also be sent to notify selected stakeholders – In the announcements, comments will be invited and details will be given as to where comments should be submitted if in advance of the public consultation event – The NTS in Urdu and full ESIA in English will be distributed in the local area to coincide with the IFC disclosure period. They will be distributed to selected stakeholders as detailed in Error! Reference source not found. . – A minimum of two public consultation events2 will be conducted in suitable locations so that governmental and non-governmental stakeholders can attend as well as affected communities. The location and exact dates are yet to be decided (consultations have already been held in Soha and Azad Pattan). KPCL will present non-technical information, as appropriate, about the risks, impacts and mitigations and hear comments and concerns. A feedback form will be provided to allow for anonymous comments to be submitted. – Comments received by KPCL will be forwarded to the ESIA consultants for consideration by technical specialists and inclusion in the final ESIA. – Feedback collection will stay open for one month after announcement of disclosure. Responses will be provided to each interested party presenting questions as soon as is reasonably possible depending on the complexity of the issue and source of information needed to provide the answer.
The draft and final ESIA reports will also be disclosed on the Project website. It is hoped that the EPAs’’ comments will be provided prior to July to allow their incorporation into the final ESIA.
Due consideration was given to the necessity for additional public consultation to the EPA hearings undertaken in April 2015. The EPA hearings focussed on Karot and Hollar and the meetings were focused on land and resettlement issues as was the Project presentation. It is considered worthwhile and appropriate to demonstrate “meaningful” consultation to undertake public consultations at other sites around the reservoir to get feedback more focused on the ESIA results.
A one-page document summarising the differences between the national EIA and the ESIA will be prepared and disclosed to stakeholders.
2 Currently (June 2015) it is recommended that the draft ESIA be disclosed at Pattan Sher Khan at the top of the reservoir, Barohi with transportation organisation for community members from Azad Pattan to attend, Soha, and Beor. 33 350133/PWR/ENS/1/D Stakeholder Engagement Plan 31/07/2015
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6.4 Land Negotiations and Resettlement Consultation
Because of the sensitive aspect of land negotiations, KPCL has hired Laraib Group to represent their company to support the Government lead resettlement activities and undertake negotiations with some private landowners. Laraib Group is working with the households and people directly affected by resettlement impacts along with community representatives. For instance Karot residents have identified a group of seven elders for representing their interests and this village committee is considered a legitimate representative for the land consultations and negotiations. Laraib Group’s current involvement is contracted until land agreements in both the dam and reservoir area are complete.
The separate meetings with people affected by resettlement have the purpose of explaining the Project land requirements, discussing the options for compensation values, explaining the entitlements that will be available, how entitlements will be distributed, livelihood restoration measures, the cut-off date for eligibility and other issues. As appropriate, the meetings on land negotiations and resettlement are undertaken with affected households (individual heads of households) or groups of heads of households. The minister, Commissioners, and local Land Collectors have been closely involved in the negotiations.
In areas where Section 4 to 11 notifications have been completed, there is a local company called Sustainable Solutions which will meet with the affected households to confirm the survey measurements made by government and to confirm no coercion was involved in the land agreement process. These meetings with affected households will be attended by a female sociologist to enable open discussions with women within households and to make provision for their needs in resettlement planning. It is anticipated that these verification meetings will begin in late June after the final awards for Hollar village affected households are announced.
All meetings related to land acquisition and resettlement will be planned, documented and reported on within the RAP.
6.5 Consultation during the Construction and Operational Phases
Stakeholder consultation is a continuous process throughout the life of the Project. Consultation and community engagement will continue throughout the construction and operation phases. The Project website, newspapers and radio will continue to be used to provide public domain information as it becomes available, such as information on management of construction impacts, monitoring reports and annual sustainability reports.
The primary stakeholders, particularly local communities and local governments, will be closely consulted in the development of the relevant actions plans such as Traffic Management Plan and the Emergency Preparedness and Response Plan.
The Project will disseminate all relevant project information to key stakeholders for its implementation. This information relates to project implementation progress, policy approaches and action plans (as mentioned above), grievance mechanism, information related to construction jobs and recruitment. The dissemination
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will be through the distribution of pamphlets and brochures, announcements in mosques, particularly at Friday prayers, and community meetings.
Throughout construction and when there are milestones on the Project such as changes in key activities, the CLO will organise meetings with affected persons so they are informed of the construction schedule as well as likely impacts and mitigation activities to minimise negative effects. These will occur at least once annually.
During construction, the EPC contractor will need to carry out environmental and social monitoring activities. This information will be summarised and reported to KPCL and the company will make annual reports on project performance available during the construction and operational phases. The EPC contractor will also log and report on community grievances, categorising grievances according to risk level and identifying that some grievances will be comments.
The SEP will be reviewed by KPCL at least annually during construction and operation, in order to assess whether: ° The type of consultation and disclosure activities are appropriate for the different stakeholders ° The frequency of consultation activities is sufficient ° Grievances are being adequately dealt with ° The stakeholder list remains appropriate ° Whether engagement should cease or be intensified
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7 Implementation Timescales and Responsibilities
Consultation and disclosure needs to occur at appropriate times to allow stakeholders to be informed and contribute to the management of environmental and social issues throughout the life of the Project. Table 7.1 assigns timescales and responsibilities to the activities identified in the previous section. This is a live document and will be updated as the Project progresses with further details on specific timings, locations and media for certain activities.
Table 7.1: Stakeholder engagement implementation timescales and responsibilities Activity Timing/detail Responsibility 1) ESIA Phase Engagement Announcement and At least two weeks prior to meetings. KPCL Social and implementation of public Adverts to be placed on banners, in local newspapers, on radio and Environmental consultation on the draft on KPCL’s website identifying dates and locations of the public Department ESIA consultation meetings and how to submit comments. Announcements in affected communities in mosques, particularly at Friday prayers, and community meetings. Letters of invitation to key stakeholders. Separate meetings to be held with women to encourage their involvement. Disclosure of Draft and Disclosure of Draft and Final ESIA in English and the Non-Technical KPCL Social and final ESIA Summary in Urdu on Project website, distribution of paper copies to Environmental village leaders, email to key stakeholders as identified in Error! Department Reference source not found. with provision of paper copies where requested. A minimum of two meetings to be held. Locations, dates and times to be confirmed. Expected early July 2015. KPCL and its consultants to present information about the Project and the findings of the ESIA as well as proposed mitigation measures. Announcement of final Adverts to be placed for one week in two newspapers and KPCL Social and decision on Project, announcements/further information on KPI’s website stating that the Environmental expected start date and Project has received finance, the agreed mitigation measures and Department disclosure of final ESIA when construction is expected to commence. Announcements in affected communities in mosques, particularly at Friday prayers, and community meetings. Final ESIA to be disclosed on Project website. Media communications As requested or when press releases deemed relevant. KPCL to identify which manager has media response duties Consultation for To be detailed in RAP KPCL Social and resettlement and Environmental disclosure of NTS of Department, land RAP negotiator, RAP consultants Obtain FPIC from FPIC to be obtained prior to commencement of construction. KPCL Social and indigenous group Meetings to be held with community leaders as part of the FPIC Environmental consultation process. Department, RAP consultants
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Activity Timing/detail Responsibility 2) Construction Phase Engagement Consultation and Meetings with the nearest fire, ambulance, military and police services EPC contractor disclosure on contents of to discuss the EPRP and ensure they are aware of its contents. Emergency Communication channels between the Project and the service Preparedness and providers clearly established. Annual drills organised by the EPC Response Plan (EPRP) contractor. and other key plans Meetings with any communities potentially affected by emergencies to affecting communities ensure that effective plans are in place. Announcements of meeting plans in affected communities in mosques, particularly at Friday prayers, and community meetings. Consultation on key aspects of public health and safety plan, traffic management plan, etc. As appropriate, disclosure of key elements of the EPRP and other plans in leaflet and meeting format. Ongoing community Communications with village leaders and community members. CLOs liaison and grievance Weekly grievance reporting to EPC contractor Project Manager (PM). EPC contractor logging, resolution and reporting Community consultation Information provided to communities on risk, impacts and mitigations CLOs events prior to the start and end of construction, and when other key changes in project activities take place, including material changes to the project description. At least annually. Verbal communication in Urdu. Disclosure of information Information about the construction plans, especially in relation to the CLOs to indigenous peoples bridges, and provision of access from the right to left bank provided to Gujjars. This should be at key project phases and at least two weeks prior to the Gujjars’ seasonal migration. Regular updates of Updates when activities change and milestones are reached, CLOs website Provision of public domain information as it becomes available, such as information on management of impacts, monitoring reports and annual reports. Updating SEP At least annually KPCL in discussion with CLOs Annual Reporting Project specific annual report summarising project performance, CLO KPCL activities including grievances, impact mitigation and management. 3) Operations and Decommissioning Phase Engagement Grievance logging, Six-monthly grievance reporting to KPCL PM. Operational CLO resolution and reporting and KPCL PM Decommissioning With staff prior to retrenchment proceedings. Operational CLO consultation event With communities prior to ceasing operations (or any rehabilitation and KPCL PM works). Updating SEP Annually. Operational CLO and KPCL PM Annual Reporting Information about the Project during its operational phase will be Operational CLO included in KPCL’s annual sustainability reporting. and KPCL PM
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8 Project Grievance Mechanism
8.1 Overview
A grievance can be defined as an actual or perceived problem that might give grounds for complaint. As a general policy, KPCL will work proactively towards preventing grievances through the implementation of impact mitigation measures (as identified by the ESIA) and community liaison.
Anyone will be able to submit a grievance to the Project if they believe a practice is having a detrimental impact on the community, the environment, or on their quality of life. They may also submit comments and suggestions. The sections below consider confidentiality and anonymity and the project’s grievance resolution process.
8.2 Confidentiality and Anonymity
The Project will aim to protect a person’s confidentiality when requested and will guarantee anonymity in annual reporting. Individuals will be asked permission to disclose their identity. Investigations will be undertaken in a manner that is respectful of the aggrieved party and the principle of confidentiality. The aggrieved party will need to recognise that there may be situations when disclosure of identity is required and the Project will identify these situations to see whether the aggrieved party wishes to continue with the investigation and resolution activities.
8.3 Grievance Reporting and Resolution
Grievances will be logged in a formal logging system for which the CLOs will be responsible. People may register grievances using the form in Appendix A or by contacting the CLOs or reporting to their village representative. Contact details for the CLO will be included in appropriate project communication materials such as the non-technical summaries.
The CLOs will classify grievances according to Table 8.1. Where investigations are required, project staff and outside authorities as appropriate, will assist with the process. The CLOs will collaborate with the EPC contractor and KPCL management to identify an appropriate investigation team with the correct skills to review the issue raised. The investigation will also aim to identify whether the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment and training to address and prevent reoccurrence will be part of the investigation activities.
Table 8.1: Grievance Classification Criteria Risk Level (to health, Classification safety or environment) Response Comment (not None or low CLO to identify whether the comment can be answered or the request a grievance) can be accommodated. If it can, an action plan to implement will be developed. Low None or low CLO will conduct investigation, document findings and provide a response. Medium Possible risk and likely a CLO and an appropriate investigation team will conduct investigation. The one off event Site Manager or Occupational Health and Safety Manager may decide to
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Risk Level (to health, Classification safety or environment) Response stop work during the investigation to allow the corrective preventive actions to be determined. The CLO will provide a response. High Probable risk and could CLO will get the contractor to organise a Major Investigation Team for reoccur prompt investigation and resolution. Work may be stopped in the affected area. The CLO will provide a response.
The CLOs will explain in writing or orally in person (especially where literacy is an issue) to the complainant the review process, the results, and any changes to activities that will be undertaken to address the grievance and how the issue is being managed to meet appropriate environmental and social management systems. In some cases it will be appropriate for the CLOs to follow up at a later date to see if the person or organisation is satisfied with the resolution or remedial actions.
The CLOs will summarise grievances weekly during construction and bi-annually during operation removing identification information to protect the confidentiality of the complainant and guaranteeing anonymity. The procedure will be at no cost and without retribution to project affected persons and stakeholders. The procedure for processing grievances is depicted in Figure 8.1.
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Figure 8.1: Grievance process
During the planning phase of the Project, the current point of contact for grievances on Project performance is KPCL’s environment team: M. Naeem Akhtar Senior Advisor Telephone: 0300 492 5769 Email: [email protected]
For land issues, Laraib Group is the main point of contact.
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With construction beginning, the EPC contractor and KPCL will need to nominate the CLOs who will be points of contact for grievances and comments. Grievances and comments should be sent to the Project, where possible by using the form provided in Appendix A.
The following information will be updates once the CLOs have been appointed:
Community Name served Address Telephone Email Website
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9 Documentation, Monitoring and Reporting
This SEP identifies various activities that require documentation, monitoring and reporting, including the following: ° Updating the SEP ° CLO activities: – A list of disclosure activities such as where, when and for how long key documents have been disclosed with photographic evidence and clippings of adverts placed in newspapers and other media – Gender specific minutes of consultation meetings 3 with dates, location, a gender-specific list of participants and photos – All original written consultation correspondence including comments and feedback left at meetings will be retained as evidence of the process and outcomes Keeping records of press attention, such as newspaper and web articles ° Grievance logging and tracking: each grievance will be logged by the CLO, given an identification number and followed through by recording details and timing for their resolution and closing out ° Annual reporting: a Project specific annual report summarising project performance, CLO activities including grievances and updates to the SEP will be produced during construction. Information about the Project during its operational phase will be included in KPCL’s annual sustainability reporting
As part of the ESIA, an ESMP will detail specific monitoring and reporting requirements for environmental and social Project performance. Some of the indicators and benchmarks for assessing the implementation process and outcomes of the SEP are: ° Number of consultation meetings, focus group discussions, announcements, press releases ° Number and lists of participants at meetings ° Issues discussed at meetings ° Actions taken on key issues raised at meetings ° Number complaints and queries raised per recording period ° Types of complaints and queries ° Type of action taken to correct issues and prevent recurrence ° Time taken in addressing complaints
3 This means referencing within the minutes whether comments or concerns were raised by males or females. 42 350133/PWR/ENS/1/D Stakeholder Engagement Plan 31/07/2015
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Appendices
Appendix A. Grievance Form ______44
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Appendix A. Grievance Form
Full Name Contact Information By Post: Please provide mailing address
Please identify how you wish to be contacted (mail, telephone, e-mail) By telephone:
By e-mail:
Preferred language of communication? Urdu / Punjabi Other (please specify)………..………………………………….
Description of incident or grievance (What happened? Where did it happen? Who did it happen to? What is the result of the problem?):
Date of incident/grievance One time incident/grievance (date ______)
Happened more than once (how many times? _____)
On-going (currently experiencing problem)
What would you like to see to resolve this problem?
Internal Use Only Grievance received by: Date: Reference number:
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