SANGACHAL TERMINAL EXTENSION & OFFSHORE WORKS … February... · 2018-08-01 · SANGACHAL TERMINAL...

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SANGACHAL TERMINAL EXTENSION & OFFSHORE WORKS SOCIAL AND RESETTLEMENT ACTION PLAN MONITORING PANEL REVIEW FEBRUARY 2004 Robert Barclay

Transcript of SANGACHAL TERMINAL EXTENSION & OFFSHORE WORKS … February... · 2018-08-01 · SANGACHAL TERMINAL...

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SANGACHAL TERMINAL EXTENSION &

OFFSHORE WORKS

SOCIAL AND RESETTLEMENT ACTION PLAN

MONITORING PANEL REVIEW

FEBRUARY 2004

Robert Barclay

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CONTENTS

1. INTRODUCTION .............................................................................. 4

1.1 REQUIREMENT FOR SRAP REVIEWS ...........................................................4

1.2 PROJECT DESCRIPTION .................................................................................4

1.3 PROJECT SPONSORS ......................................................................................6

1.4 SRAP REVIEW OBJECTIVES.........................................................................7

1.5 SCOPE OF THE FEBRUARY 2004 REVIEW .....................................................8

2. PROGRESS WITH RESETTLEMENT .......................................... 9

2.1 GENERAL .......................................................................................................9

2.2 SMALL ROADSIDE ENTERPRISE ....................................................................9

2.3 PASTORALIST FAMILY.................................................................................10

2.4 COMMERCIAL FISHING INTERESTS ............................................................12

2.5 INFORMAL FISHERMEN ...............................................................................12

2.6 MENR STATE FISHERIES ...........................................................................12

3. LIVELIHOOD RESTORATION ................................................... 13

3.1 LIVELIHOOD RESTORATION........................................................................13

3.2 PROJECT AFFECTED VULNERABLE GROUPS (UNDER THE RAP)...............13

4. SOCIAL AND RAP IMPLEMENTATION................................... 14

4.1 ORGANIZATION AND RESOURCES ...............................................................14

4.2 DOCUMENTATION AND REPORTING............................................................14

4.3 GRIEVANCE PROCESSING............................................................................14

4.4 MONITORING ...............................................................................................15

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5. CONTRACTOR CONTROL PLAN PERFORMANCE ............. 15

5.1 COMMUNITY PERCEPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS..15

5.2 RECRUITMENT, EMPLOYMENT AND TRAINING..........................................18

5.3 TRANSPORT MANAGEMENT ........................................................................18

5.4 CONSTRUCTION CAMP MANAGEMENT.......................................................19

5.5 PROCUREMENT AND SUPPLY CHAIN MANAGEMENT .................................19

5.6 COMMUNITY LIAISON .................................................................................20

6. COMMUNITY INVESTMENT PROGRAM................................ 20

6.1 GENERAL .....................................................................................................20

6.2 SEWERAGE UPGRADE PROJECT..................................................................20

6.3 GLOVE-MAKING CBO ................................................................................22

6.4 VULNERABLE GROUPS AND CIP .................................................................22

6.5 ATA YARDS.................................................................................................23

7. PUBLIC CONSULTATION AND DISCLOSURE....................... 24

8. CONCLUSION ................................................................................. 25

8.1 RESETTLEMENT...........................................................................................25

8.2 CONSTRUCTION ...........................................................................................25

8.3 CIP...............................................................................................................25

9. SUMMARY OF RECOMMENDATIONS .................................... 26

9.1 TRACKING OF RECOMMENDATIONS FROM THE AUGUST 2003 REVIEW ...26

9.2 RECOMMENDATIONS OF THE FEBRUARY 2004 REVIEW ............................28

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1. INTRODUCTION

1.1 Requirement for SRAP Reviews

The second Social and Resettlement Action Plan (SRAP) monitoring review of the Azeri Chirag and Deep Water Gunashli (ACG) Phase 1 Project and the Shah Deniz (SD) Stage 1 Gas Export Project was conducted in February 2004.

Six-monthly SRAP reviews are a requirement of the ACG Phase 1 and SD Stage 1 Gas Export Project Resettlement Action Plan (hereinafter referred to as ‘the RAP’) and the ACG Phase 1 Environmental and Social Action Plan (ESAP). The scope of the SRAP review is defined in the “Terms of Reference for Social and Resettlement Action Plan (SRAP) Monitoring Implementation” (See Appendix A of the August 2003 SRAP report).

SRAP monitoring reviews will be undertaken at six monthly intervals and will continue for 24 months following completion of physical relocation of affected people, or until such time as the SRAP Panel determines affected people’s living standards and income levels have been fully restored, whichever occurs earliest. At this time, a Completion Audit will be undertaken. The purpose of the Completion Audit will be to verify that ACG Phase 1 and SD Stage 1 have complied with the resettlement undertakings defined by the RAP.

The next SRAP monitoring review will take place in August 2004.

1.2 Project Description

The RAP addresses resettlement impacts arising from two projects, namely:

• Azeri, Chirag and Deep Water Gunashli (ACG) Phase 1 Project

• Shah Deniz Stage 1 Gas Export Project

Onshore hydrocarbon reception and processing facilities for both ACG and Shah Deniz will be incorporated in an extension to the existing Sangachal Terminal. The locations of the ACG Contract Area, the Shah Deniz Contract Area and the Sangachal Terminal are shown in Figure 1-1.

The projects involve four principal components:

• Fixed offshore platforms for drilling and production operations within the ACG Contract Area.

• Fixed offshore platform for drilling and production operations within the Shah Deniz Contract Area.

• Sub-sea pipelines for the transportation of oil and gas from the offshore platforms in the respective fields to the Sangachal Terminal

• Extension of the existing Sangachal Terminal to increase its processing and storage capacity to accommodate the increased production of oil and gas from the ACG field, and new production from the Shah Deniz field.

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Figure 1-1 Location of Project Components

Principal resettlement impacts have, or will, result from the following:

• The need to relocate fish acclimatization pens operated by MENR to avoid their being destroyed by pipeline construction activities (completed late in 2001).

• The need to relocate a café and garage from within an onshore gas pipeline corridor that connects the sub-sea pipelines to the Sangachal Terminal.

• The loss of part of an area used informally as winter pasture by a grazier family as a result of land acquisition and construction activities for extension of the Sangachal Terminal.

• The need to remove unclaimed illegal fishing nets (if any remain) and a fish trap from within the 500-metre wide sub-sea pipeline construction corridor.

The project affects 41 people living permanently or seasonally in Garadagh District of Baku City, and an unknown number of illegal fishermen (estimated at about 10 individuals). Resettlement impacts of the project are summarised in Table 1-1. The project affects formal (with legal title or licenses to use resources), informal and illegal land and resource users.

The February 2004 review also encompassed a briefing on the community investment program for the community living in the vicinity of the Amec-Tekfen-Azfen Consortium (ATA) yard which is fabricating the Compression and Water Injection Platform for the ACG project. The yard is situated in the Bibi-Heybat oil fields on the south western outskirts of the Baku urban area.

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Table 1-1 Summary of Resettlement Impacts

Affected Group No. of Affected People

Status Nature of Resettlement Impacts

MENR Fish Breeding Facility

No impact on workers Licensed State facility

Short duration disruption of fish acclimatization operations.

Small enterprise Owner and 10 employees

Formal landowner; no planning or building permits for structures

Loss of buildings, structures and land improvements. Need to relocate the café-garage to a replacement site. Possible short duration enterprise downtime during physical relocation.

Pastoralist family (part of a state cattle breeding enterprise)

An extended family group of 30 members

No formal title or use rights over the subject land

Permanent loss of access to part of land used for winter grazing for 30-40 years. Family preference to relocate winter grazing activities to a replacement grazing area. Relocation of a winter settlement. Possible transitional income loss from sale of dairy produce until new customers are found near the replacement site.

Informal fish trappers 10 fishermen (based on nets observed/ recovered by owners ahead of construction)

Prohibited activity

Loss of any fishing nets not moved from the pipeline construction corridor at time of construction start

Total Project Affected Population

41 (known)

Source: ACG Phase 1 Shah Deniz Stage 1 RAP

1.3 Project Sponsors

Project Sponsors for ACG Phase 1 and Shah Deniz Stage 1 are as follows:

• The Project Sponsors for ACG Phase 1 are the ACG PSA parties and SOCAR. The PSA parties’ parent companies are BP, Unocal, Lukoil, Statoil, Exxon Mobil, TPAO, Devon, Itochu and Delta Hess

• The Project Sponsors for the Shah Deniz Stage 1 Gas Export Project are the Shah Deniz PSA parties including SOCAR. The Shah Deniz PSA parties’ parent companies are BP, Statoil, Total Fina Elf, TPAO, LukAgip, and NICO

For the purposes of the RAP, these two groups will be referred to collectively as the “Project Sponsors”. The ACG PSA partners operate as the Azerbaijan International Operating Company (AIOC). The Shah Deniz PSA partners have yet to establish an operating entity but have been granted the rights to develop and manage hydrocarbon reserves in the Shah Deniz field.

BP has been appointed as “operator” for both ACG Phase 1 and SD Stage 1.

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1.4 SRAP Review Objectives

Objectives of the six-monthly SRAP reviews are as follows:

• To assess overall compliance with the RAP

• To verify that measures to restore or enhance project affected peoples’ quality of life and livelihood are being implemented and to gauge their effectiveness

• To assess the extent to which the quality of life and livelihoods of affected people have been restored

The review will also assess overall compliance with other mitigation measures to address social impacts contained in the ESAP and its component Contractor Control Plans insofar as these require actual visits and interaction with community members to verify whether the commitment has been implemented or complied with. The types of commitments that will be verified by the SRAP review include the following:

• Pollution prevention - dust and noise management in communities.

• Community safety - awareness raising programmes in communities on communicable diseases; community awareness of project traffic routes and traffic safety briefings

• Infrastructure and services - reinstatement of damaged infrastructure and compensation process; project use of water not affecting communities; and roads used by the project are maintained in reasonable condition.

• Community liaison - community awareness of project activities; complaints procedures; camp rules; recruitment process; project traffic speed limits; pre-warning of noisy activities and other planned disruptions; procurement process and regular community meetings and access to community liaison officers (CLOs).

• Grievance management – follow up of grievances reported; accessibility of CLOs; community awareness of complaints procedures and complaints close out.

Under its TOR, the SRAP Panel is also required to review (i) the Community Investment Programs (CIP) and monitoring reports as a basis for assessing the overall contribution of these “value-added” programs towards sustainable social development of terminal affected communities; and, (ii) review the PCDP and reports on on-going consultation, and other ESAP monitoring reports with respect to consultation, as a basis for providing an external overview of the effectiveness of overall community liaison and identifying any critical issues that need to be addressed.

Activities to be undertaken during SRAP reviews are listed in the TOR in Appendix A of the August 2003 SRAP report.

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1.5 Scope of the February 2004 Review

The scope of SRAP review with respect to ACG Phase 1 and SD Stage 1 documentation is summarized in the following table. The differing scopes for ACG Phase 1 and SD Stage 1 are in response to the different lender arrangements for the two projects.

Table 1-2 Reference Documents for SRAP Review for the Two Projects

ACG Phase 1 SD Stage 1 RAP Contractor Control Plans Phase 1 Management Plans ESAP

RAP

The SRAP review was conducted on the 18th and 21st February 2004 by Mr. Robert Barclay. Mr. Ted Pollett, Senior Social Development Specialist with the International Finance Corporation (IFC), accompanied the SRAP Panel as an observer as part of IFC’s own monitoring activities. Activities undertaken during the review included:

• Review of systems and record keeping with BP’s Sangachal Terminal Environmental and Social Department, and Community Liaison Coordinator

• Interviews with resettler representatives including the head of the extended pastoralist family whose winter pastures have been affected by the terminal project, and one of the owners of the café-garage enterprise which is to be relocated

• Attendance at a regular project ‘Human Development Forum’ which was attended by representatives from the NGOs involved in delivering Community Investment Programs (CIPs) and BP’s Sangachal Terminal Environmental and Social Department

• Interviews with village executive committee and municipal heads, aksakal representatives and women’s group representatives in Umid and Sangachal – the two settlements adjacent to the terminal site

• Discussions with a cross-section of Umid and Sangachal villagers encountered in streets and public spaces within Umid and Sangachal

• Meeting with women members of the glove-making community based organization in Umid

• Interview with refugees and internally displaced people living in train carriages on a rail siding in Sangachal

• Inspection of various completed community investment projects in Sangachal

• Briefing and review of the community investment and community liaison program being established for the Bibi-Heybat area in the vicinity of the Amec-Tekfen-Azfen Consortium (ATA) yard which is fabricating the Compression and Water Injection Platform for the ACG project

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• Meeting with Baku Enterprise Centre to obtain an update on progress with local procurement activities

The review involved interactions with a broad cross section of affected people, local communities and stakeholders. A list of interviews and discussions is included in Appendix A of this report.

2. PROGRESS WITH RESETTLEMENT

2.1 General

The progress with resettlement and livelihood restoration activities for each of the project-affected groups listed in Table 1.1 as reported by the project sponsors is summarized in the following sections.

2.2 Small Roadside Enterprise

Since the last review, the Valuation Commission and the owners of the small roadside enterprise have reached an agreement on compensation arrangements for the relocation of the enterprise. The agreement is based on the principles of ‘land for land’ and ‘buildings for buildings’. The “Resolution of the Commission under the Head of Garadagh District Executive Authority for the evaluation and removal of the small enterprise structures from the Pipeline Safety Zone” (November 2003) stipulated the following measures:

• Request for land allotment to be submitted to Baku Executive Power for allocation of an equivalent plot of land

• Replacement structures to be built at the new location

• Facilities at the new location to be developed according to the existing Technical Passport issued to the small enterprise

The enterprise owner received legal assistance from the NGO, Centre for Legal and Economic Education (CLEE) prior to and during the finalization of agreements. Costs for this assistance were borne by the project (in accordance with recommendation c. of the August 2003 SRAP report). BP also assisted the small enterprise owner to obtain a business license.

A formal request for allocation of replacement land to Baku Executive Power has been lodged and a suitable replacement site has been agreed with the owner. The replacement plot is about 1 kilometre to the north of the existing facility and has equivalent frontage to the Baku-Alyat Highway. It is also close to the existing settlement of Umid, which may provide an additional source of custom for the enterprise. At the time of the SRAP review, approval of allocation of the land by Baku City was reported to be imminent.

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BP has engaged a project manager to be responsible for obtaining necessary approvals as well as coordinating design and construction of the replacement buildings. The café-garage owner will be closely consulted throughout this process.

Due to the protracted period of negotiations with the small enterprise, Sangachal Terminal Expansion Project (STEP) construction activities have advanced to the stage where pipeline sleeves are being installed under the Baku-Alyat highway immediately adjacent to the existing enterprise buildings. It was considered that the construction activities may present some safety risk to the enterprise workers and their customers, so an agreement was reached between BP, Tekfen Azfen (the main contractor) and the enterprise owner for the contractor to rent the enterprise site and facilities for the period of the construction works. The agreed rental sum exceeds the revenue and income expenditures reported by the enterprise owner during the RAP baseline survey. Two employees from the enterprise were also engaged as cleaners with the project.

The agreement and additional project support provided to the small enterprise owner fully comply with the provisions and entitlements described in the RAP. Future SRAP reviews will monitor completion and delivery of land and buildings.

2.3 Pastoralist Family

2.3.1 Background

The original livelihood restoration strategy for the extended pastoralist family documented in the RAP involved providing them with alternative winter pasture and camp facilities on land in Gobustan. This would enable the family to stop using their winter camp and pastures in the vicinity of Sangachal Terminal.

Agreements were put in place in 2002 with the Absheron District Executive Authority and a state cattle breeding enterprise authorizing the pastoralist family’s use of the replacement pasture at Gobustan. Although the agreed schedule originally had the pastoralist family moving to their replacement winter pasture in March 2003, the family head subsequently requested that they be able to continue to graze at Sangachal for the balance of the 2003 winter period, with the move to the new site to occur in October 2003 (the following winter). The reason for this request was that the pastoralists still had areas of good pasture they could use at Sangachal and that they considered the additional time would be beneficial for developing the condition of their replacement pasture at Gobustan.

The August 2003 SRAP review reported that due to an administrative oversight, the Gobustan winter pasture land that had been formally allocated for use by the project affected pastoralist family had been occupied by a third party, who had also obtained formal approval to use the land. In spite of intervention by the Ministry of Agriculture, the project has been unable to resolve this situation. The project has also heard that intimidatory tactics had been employed to discourage the pastoralist family from further pursuing their occupation of the land. A compromise proposal, that involved the pastoralist family and third party each utilising 400 hectares of the 800 hectare replacement site, was also not accepted.

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It is clear that attempts to enforce the pastoralists’ right to use the Gobustan land would bring the family into conflict with other influential, vested interests, with potential adverse consequences for the family’s physical welfare and employment security. The SRAP review supports BP’s assessment that the Gobustan option presented in the RAP is no longer viable. During discussions, the pastoralist family head also strongly requested that the family be allowed to remain at their Sangachal settlement, at least in the short term.

2.3.2 Current Status

The pastoralist family has presently resumed use of the winter camp and pastures adjacent to the Sangachal site. The project is providing regular truckloads of water to the pastoralist settlement for stock use. Timber has also been provided to enable the pastoralists to repair their dwellings and livestock shelters. One of the pastoralist menfolk is employed by the project, and has been for more than 12 months. According to the family head, the family has lost some of the grazing area that has been cleared as part of construction activities. The family does, however, have access to adequate replacement pasture to the west of their settlement. This land is also used informally.

The pastoralist family men remain employees of the state cattle breeding enterprise and manage enterprise livestock as well as their own. The family has lease agreements with the state enterprise covering summer pastures in Guba District. The family does not presently have any agreement with their employer covering winter pastures.

BP is continuing to support the pastoralist family in its present location, but realises this is likely not a long term option. BP is mindful of its obligations under the RAP and OD 4.30 to establish secure tenure for the pastoralists over replacement winter grazing area.

2.3.3 Preferences of the Pastoralist Family

During the SRAP review, a meeting was held with the pastoralist family head. Key points arising from the interview were as follows:

• The pastoralist family expressed a strong preference to continue using their winter settlement and pastures adjacent to the Sangachal terminal, at least in the short term

• The family would like the project to assist them (and their employer) in securing replacement winter pasture

• The family head estimated they need about 400-500 hectares of pasture equivalent to what they have at Sangachal, with water, to support their current numbers of livestock

2.3.4 Next Steps

In the short term, as requested by the pastoralist family, BP will support the family to continue their use of the Sangachal winter settlement. In the meantime, in

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cooperation with the pastoralist’s state enterprise employers, BP will seek to locate equivalent alternative winter pasture that can be formally secured for use by the pastoralist family in order to meet project RAP and OD 4.30 obligations. The SRAP review will continue to monitor and report on progress of this matter. BP will endeavor to establish a revised program for securing replacement pasture ahead of the next review.

The SRAP review recommended that some time be allowed to elapse (3-6 months) before recommencing any negotiations with the pastoralists and their employer to allow recent tensions to dissipate.

Recommendation:

a. BP to prepare a 2-3 page briefing note to the Lenders Group to explain the circumstances of the pastoralist family, the reasons for the deviation from the RAP, and the alternatives that are presently under consideration.

b. BP to cooperate with the state livestock enterprise employer of the pastoralists to locate suitable replacement pasture and to facilitate putting in place agreements to secure the pastoralist’s ongoing use.

c. BP to consult closely with the pastoralist family throughout the replacement site selection process.

2.4 Commercial Fishing Interests

BP has previously confirmed that all necessary navigation advisories were issued to the appropriate responsible authorities and other interested parties including the Caspian Fish Company prior to the commencement of laying of the offshore pipeline. BP has had no recent contact with the Caspian Fish Company. No complaints have been received about nearshore or offshore pipe-laying works.

2.5 Informal Fishermen

During the last review, BP advised that 10 gill nets in the pipeline construction exclusion zone had been removed by their owners prior to the offshore pipeline lay commencing. No subsequent complaints have been received by the project.

2.6 MENR State Fisheries

The project sponsors paid the agreed lump sum cash compensation to the Treasury Department of the Ministry of Environment and Natural Resources to cover costs associated with relocating fish pens of an MENR fish breeding facility (see RAP Section 6.3.3). MENR has indicated that the ongoing welfare of the employees of the facility and utilization of the compensation are its responsibility and that it does not need further assistance from the project. BP has made no further contact with MENR regarding this matter.

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3. LIVELIHOOD RESTORATION

3.1 Livelihood Restoration

The project has the potential to affect livelihood of two groups:

• The roadside small enterprise

• The pastoralist family

Arrangements for livelihood restoration for downtime experienced by the roadside small enterprise as a result of the installation of crossing sleeves under the Baku-Alyat Highway are described in Section 2.2.

The pastoralist family has not as yet experienced any direct livelihood losses as a result of the project. The family is maintaining the same sized flocks of livestock as were recorded during the RAP baseline surveys. The family may have experienced some inconvenience through a need to move stock further (less than 1 kilometre) to reach viable pasture. The project has provided the project with offsetting assistance including trucking in water (a cost that prior to the project was borne by the family), providing paid employment to one of the pastoralist family members, and through provision of materials for repairs to houses and livestock shelters.

The pastoralist family head indicated the family was satisfied with the level of support it was receiving from the project.

BP is also continuing with feasibility investigations for fish farming. The objective is to explore the potential of aquaculture as an employment opportunity for informal fishermen to reduce their reliance on prohibited activities.

3.2 Project Affected Vulnerable Groups (under the RAP)

As noted in the RAP, each of the principal project affected groups is vulnerable to varying degrees as they are reliant or partially reliant on informal relationships to give them access to land or resources, or they are engaged in activities that are prohibited or unlawful.

While the initial attempt to find the pastoralist family replacement land has been thwarted, the project has continued to provide appropriate and ongoing support to the family while an alternative arrangement is sought. The pastoralist family head was satisfied with current levels of assistance from the project.

The agreement arrived at for the roadside small enterprise demonstrates BP and SOCAR’s persistence and cooperation with the local government to formalize the enterprise’s building and business licenses, and to achieve compensation in accordance with World Bank OD 4.30 standards.

Project affected parties were observed to have a good rapport with the Project Community Liaison Coordinator, and were comfortable to approach him when they experienced problems or difficulties. Records show that the Community Liaison

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Coordinator has maintained regular contact with each of the groups covered by the RAP.

Overall, STEP is assessed as maintaining adequate support to vulnerable groups covered by the RAP.

4. SOCIAL AND RAP IMPLEMENTATION

4.1 Organization and Resources

The February 2004 review confirmed that BP’s social and resettlement management systems are well established with adequate staffing levels and resources. Contractor Control Plans and related commitments have been integrated into regular social monitoring and reporting systems, and into the overall project management framework.

4.2 Documentation and Reporting

Project documentation and record keeping is being efficiently undertaken. Since the last review, internal RAP monitoring reports have been produced on a quarterly basis (fulfils August 2003 recommendation r.). Up-to-date records of stakeholder meetings, consultation activities and correspondence relating to land acquisition and resettlement activities were available for perusal by the SRAP reviewer.

4.3 Grievance Processing

Grievances were being recorded by file notes. All grievances were reported to be made verbally to the Community Liaison Officer either in person or by phone. Community drop boxes, whilst installed at the Information Centres, have not been used by the community. A weakness in the recording of grievances was that ‘corrective actions’ and ‘outcomes’ were not being fully recorded. Some strengthening measures are recommended below.

Recommendation:

d. All grievances to include a clear record of the ‘corrective action’ taken in response to the complaint, and the ‘outcome’ of the corrective action.

e. A summary log of grievances (Excel spreadsheet) to be kept by BP to summarize:

- Date of grievance - Name and contact details of complainant - Nature of complaint - Agreed corrective action - Person responsible for implementing the corrective - Outcome - Date of close-out

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4.4 Monitoring

Regular monitoring of project affected populations and adjacent villages is being undertaken by the Community Liaison Officer. Quarterly internal RAP monitoring reports are being produced in accordance with RAP and ESAP requirements.

5. CONTRACTOR CONTROL PLAN PERFORMANCE

5.1 Community Perception of Environmental and Social Impacts

During village consultations, villagers and key informants were asked about their perceptions of social and environmental impacts arising from the Sangachal terminal expansion. A relatively small number of impacts were mentioned.

Beneficial impacts raised by villagers included:

• Improved employment opportunities • Improved social conditions

Adverse impacts mentioned by villagers included:

• Nuisance from dust • Health impacts popularly associated with flaring

Both beneficial and adverse impacts were attributed to the influx of outside population to the villages and region that has occurred in the last 4-5 years.

The project employment performance is discussed in Section 5.2.

Village discussions about improved social conditions revolved around job opportunities and the benefits of increased household incomes, as well as the various community development initiatives in education and community micro-projects instigated by BP and its NGO partners in the two villages.

Nuisance from dust was mentioned by residents of both Sangachal and Umid, although wind direction is primarily from the North (therefore Umid is upwind of STEP). Villagers noted that the dust problems were reduced during the winter. BP noted that the project was occurring in an arid environment where particulate levels tend to be high in windy conditions, irrespective of construction activities. Since the August 2003 review, however, BP had reviewed its dust management strategies. Current measures include the following:

• Continuous wetting down of exposed soil areas (ongoing) • Ceasing work during windy conditions • Undertaking regular ambient air monitoring

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BP pointed out that exposed soil areas are progressively being stabilized through re-vegetation and other means, so the project anticipates that dust from the project site will be progressively reduced over coming months.

5.1.1 Gas Flare

In both Umid and Sangachal, a range of illnesses were popularly attributed by villagers to gas flaring at Sangachal Terminal. This attribution was often qualified by comments to the effect that “…we cannot be certain that these effects are caused by the flare, but we suspect…” The kinds of symptoms commonly mentioned included eye irritation, headaches, dizziness, stomach aches, high blood pressure and others. Some consulted people felt the effects were related to the wind direction. Others felt the effects were experienced irrespective of which way the wind was blowing. Several people mentioned that they often experienced headaches at 2 AM and 3 AM in the morning1.

While environmental matters are beyond the scope of the SRAP review, it appears relatively unlikely that flaring could be causing many, if indeed any, of the symptoms being experienced by adjacent villages. BP reports that monitoring results on flare emissions fall within standards required by Azerbaijan law and AIOC Air Quality Standards (developed from WHO/EU/UK standards). While clearly visible from both villages, the flare is sited at a considerable distance from both Umid and Sangachal settlements. In spite of a prevailing wind from the north, there does not seem to be any discernible difference in the pattern of symptoms reported in Umid (north of the flare) compared to Sangachal (to the south). The SRAP panelist also observed many other environmental factors that could potentially be adversely affecting community health. These included overflowing sewage systems with attendant risk of gastro-intestinal diseases, water ponding contributing to risk from malaria, use of relatively ‘dirty’ local gas for domestic cooking and heating, windborne dust potentially saturated with hydrocarbons from disused oil fields to the north as well as emissions from up-wind industrial areas.

In light of villager perceptions, and as a good practice measure, it is recommended that STEP commission a suitably qualified expert to design and implement a health baseline study of the two adjacent communities.

The SRAP review concludes that while information on flare emissions monitoring may allay concerns amongst a few people, a more convincing measure for the two neighboring settlements would be for BP to publicize a clear commitment on the timing for a cessation of gas flaring (except in emergencies) at the Sangachal Terminal. According to AIOC, it is probable that flaring will no longer be necessary, except in emergencies, from about 18 months time.

1 BP’s STEP Environmental and Social Manager observed that these symptoms experienced early in the morning might be consistent with insufficient ventilation while using gas or other combustion heating in dwellings. Locally supplied domestic gas is also known to be relatively ‘dirty’.

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Recommendation:

f. BP to publicize a clear commitment on the timing for a cessation of gas flaring (except in emergencies) at the Sangachal Terminal.

g. As a reputational risk management measure, BP to engage a suitably qualified expert to design and implement a health baseline study of the two adjacent communities.

5.1.2 Population Increase

Increased population through in-migration has occurred throughout Garadagh District, not just in Umid and Sangachal. The population influx is attributed to the increased economic activity occurring in the district. Developments such as the Sangachal Terminal, Azertrans Terminal (Azpetrol), activity in the SPS yards and Sahil cement works have created employment and attracted outsiders to the region.

The Executive Committee Head of Sangachal estimated that the village population had grown by about 20-25 percent since 2000. He attributed this growth to regional economic activity, and not just the Sangachal Terminal expansion. Relatives from other regions moved in with family members in the village to try and take advantage of local job opportunities. A key impact of this had been the pressure on the village secondary school which had grown from 800 to over 1000 pupils since 2000.

In Sangachal, there were some complaints that the influx of outsiders had meant less jobs for local people, but there was also recognition that the increased population had lead to more demand for goods at the local markets. A local women’s group was calling for the village markets to be expanded.

Umid had also experienced some population growth. Some residents have built new, larger houses that have enabled extended family members to settle in the village and seek jobs. House construction and extensions have often been carried out by local terminal construction employees, so there has been a flow-on benefit to the villagers.

The increase in population reflects the success of the national government’s policies directed towards promoting economic development. Increased employment and greater economic activity will also increase government revenues, which, with good governance, can be used to improve and increase the capacity of local services and infrastructure. As noted in Section 6.1, for reasons of avoiding dependence on the project and to promote sustainability, it is important that the project does not assume the functions of government. Through its CIP program and partner, World Vision, the project is contributing to the development of the capacity of local government. The SRAP review assesses this as an appropriate project response to regional economic development and pressures from increased population.

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5.2 Recruitment, Employment and Training

The project maintains weekly records of total numbers of registered people, number of people interviewed, number of people trained, and skilled and unskilled employment numbers. Records disaggregate statistics for Umid, Sangachal and Sahil. At the time of the February 2004 SRAP review, the total workforce was 3,162 of which 75 percent were Azeri. This exceeds the performance targets set for local recruitment and employment. 53 percent of the total workforce was from Garadagh District. A total of 691 workers from Umid, Sangachal and Sahil were employed by the project, compared to 497 at the time of the last review (August 2003).

Employment opportunities were cited by villagers as the major beneficial impact of the project on their communities. Most consulted people were aware of the project’s recruitment procedures and that the project’s information centres were the avenue for them to register for employment. There were no complaints about the recruitment process being unfair. Unemployment levels in Sangachal and Umid remain high and many villagers continue to actively canvas the project for work. Project staff must continue to patiently reiterate messages about limited employment opportunities and avoid interpreting ongoing demands as a criticism of the project.

Manpower forward planning schedules indicate that the Sangachal Terminal construction workforce will be downsized by about 1,500 workers in the period leading up to the next SRAP review (August 2004). This reflects the reduced workforce requirement following the completion of ACG Phase 1. Redundancies will be implemented in accordance within terms of worker agreements and requirements under Azeri labour laws.

The emphasis of programs to date has been on maximizing opportunities for construction phase employment. There is now a need to shift the focus to looking at local employment opportunities during the operations phase. It is recommended that the STEP Construction team liaise with the Operations team as early as possible to (i) identify all positions that can reasonably be filled by local workers; (ii) to identify training or skills development that might be supported by construction phase CIP initiatives to assist local workers to get operations jobs; and, (iii) set targets for construction phase local employment. Even a relatively small number of permanent jobs could contribute significantly to the economies of Sangachal, Umid and other nearby villages.

Recommendation:

h. BP Construction Phase Team to coordinate with the Ops team to start planning for operations phase local employment opportunities as early as practicable.

5.3 Transport Management

Consulted villagers indicated that BP and its contractors had advised the villages about possible traffic impacts prior to construction commencing. Villagers were satisfied with the information that they had received and noted that traffic impacts

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were generally confined to the Baku-Alyat Highway and did not really impinge on village roads.

BP has produced a road safety booklet and the traffic police have used it to run safety programs in local schools. The project has also provided safety barriers, signage and traffic management for the Baku-Alyat Highway upgrading. The highway carries over 100,000 vehicles per day.

5.4 Construction Camp Management

Consulted villagers from both Umid and Sangachal confirmed that there had been no problems arising from the presence of the construction camp or outside workforce. From the perspective of villagers, camp management and implementation of worker ‘codes of conduct’ have been effective.

5.5 Procurement and Supply Chain Management

The SRAP review was briefed by the Baku Enterprise Centre, a BP sponsored organization, on initiatives that have been taken to promote in-county sourcing for the STEP project. The Enterprise Centre has supported a wide range of measures including creating a register of interested local businesses and suppliers; running training in prequalification and bidding procedures, quality assurance, HSE standards, and business ethics. The Enterprise Centre has also supported translation of some of the commonly used oil industry international standards to enable local suppliers, typically geared to Soviet standards, to comply. The Enterprise Centre is in the process of assembling data on project in-country spend which will be made publicly available.

STEP performance at national and regional levels is reportedly strong. Opportunities for local level (village) involvement have been more limited. The project has sourced aggregates from local suppliers, but there are few other village enterprises that have the capacity to supply project needs.

As part of the transition to the operations phase, the Operations and Construction teams should coordinate to identify any linkages where construction phase CIP could support small enterprise formation and capacity building that could assist village enterprises to be formed and to bid on operations phase procurement opportunities. Such opportunities might include landscape maintenance, general maintenance, security, provisioning and food supply, catering, vehicle servicing, fuel supply, uniform manufacture, laundry services, cleaning services, printing and sign writing and the like.

Recommendation:

i. STEP to regularly publicize project in-country spend data to demonstrate the extent of local procurement.

j. STEP to examine potential linkages for the Construction phase CIP program to support SME development targeting operations phase outsourcing and procurement opportunities.

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5.6 Community Liaison

The STEP Community Liaison Officer was widely recognized by villagers as a contact point and avenue for making complaints. There was generally good awareness by villagers of the Project Information Centres and knowledge that these were the focus for project recruitment. Regular meetings are conducted with village level and district administrations. Community liaison activities were assessed as being diligently and effectively handled.

6. COMMUNITY INVESTMENT PROGRAM

6.1 General

The STEP Community Investment Program (CIP) consists of a mix of ongoing programs, micro-projects and ad hoc assistance targeting Sangachal and Umid in particular, but also Umbaki and Sahil. Programs are diverse and cover income generation, education, health, infrastructure restoration, cultural activities and recycling. Programs are implemented either directly by the project through its Human Development Forum, or through partner NGOs such as World Vision. World Vision’s program incorporated participatory procedures for mobilizing communities, establishing and training ‘initiative groups’, prioritizing projects and organizing implementation. . There is an appropriate emphasis on developing villages’ capacity to identify projects, prepare proposal and budgets and mobilize resources. Micro-projects selected by each of the villages were appropriate in terms of scale and technical sophistication relative to village resources and budgets.

Consulted villagers were generally appreciative of the types of assistance they were receiving, although there was considerable frustration and dissatisfaction with the delays in implementing the sewerage project (see Section 6.2).

The SRAP review noted some signs of dependency on STEP project assistance, with some quite strident demands being made that BP address particular village problems or issues that were rightfully in the domain of the local government. Over the remaining period of STEP construction phase community assistance, it is important that there is increased focus on assisting municipal officers and community bodies to develop greater self-reliance in terms of decision-making, prioritizing needs, sourcing funding and implementing projects. Some of the municipality development training programs being developed as part of the ATA project might also be usefully extended to Sangachal and Umid.

Following are some SRAP observations specific to two CIP initiatives - the sewerage project and the glove making CBO.

6.2 Sewerage Upgrade Project

The Umid and Sangachal communities’ highest want is the trunk sewerage project. Some frustration was evident amongst consulted villagers about the delays in getting

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the project started. Many expressed scepticism about whether the sewerage project is in fact going to be delivered (see recommendations k. and k.)

STEP is providing funding for the sewerage project. Baku Municipality Sewerage Department has been given responsibility for project managing the design, tendering, implementation and future operations. Tender documentation was being completed at the time of the February 2004 SRAP review, with a contract expected to be awarded mid-2005. Contractors will install the trunk system. Individual households will be responsible for connecting their houses to the trunk lines. The SRAP review endorses the approach of giving ownership and operations responsibility to the local government. The SRAP review recommends, however, that the capacity of vulnerable households to install their house connections needs to be closely monitored, and if problems arise, village administrations and the project may need to provide additional assistance to ensure these households are able to fully benefit from the project (see recommendation (l. iii).

There was good understanding amongst villagers in both Umid and Sangachal that they will be responsible for installing their house connections, and that once operating, they will be required to pay a small annual levy. Villagers explained that at present they sometimes have to pay for a truck to pump out ditches and drains in the villages which costs US$5-8.00 / family, much more than the proposed sewerage levy.

Villagers have an expectation that the project will supply materials for house connections, with several families indicating they could not afford to buy these with their own resources. Works are already underway to identify the volume of house connection works. Once the major works contract has been awarded and the extent of available funds is known, the project needs to develop and publicize a strategy for addressing supply of connections materials.

A joint approach with the municipalities providing aggregates and backfill materials and STEP or Baku Municipality supplying pipes and fittings is recommended.

In implementing the works, particular attention needs to paid to making good areas of poor drainage and ditches within villages where sewage currently ponds. Health benefits of the project will not be realised and malaria problems will continue if areas of ponding are not made good. BP advises this work has been provided for in the sewerage project tender documents.

The need to consider off-setting benefits for community groups that may miss out on sewerage connection is noted in Section 6.4.

In response to community demands, World Vision has incorporated hygiene and sanitation promotion into health education programs targeting women in Sangachal and Umid, and Umid students.

Recommendation:

k. So far as consistent with the strategy of procuring the sewerage system through Baku Municipality, expedite the tendering process to achieve the earliest possible

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start and as soon as practical, publicize to the beneficiary communities a commitment to a firm construction start date.

l. Develop strategies (preferably through matching inputs from local government or other sources) for (i) providing connections/ related materials; (ii) supply of labour and materials for filling/ re-grading to ameliorate poor drainage areas; and, if required, (iii) assisting vulnerable people to install house connections.

6.3 Glove-Making CBO

The SRAP Panel met with women members of a Community Based Organization (CBO) that has been formed as an income earning initiative to produce and sell leather work gloves to STEP. STEP has sponsored the project through providing NGO technical assistance, provision of sewing machines and purchase of the gloves that are to be produced. The CBO format was chosen as a vehicle to facilitate broadest participation and to simplify tax requirements. It has, however, resulted in the venture being heavily dependent on ongoing inputs from STEP. With a view to achieving long term sustainability and reducing future dependence on the project, it is recommended that the CBO should be operated on the basis of a simple business plan. This requirement notwithstanding, it is important that glove production and income generation start soon in order that CBO members do not become disillusioned by the long gestation period for the venture. This should clearly define the extent of inputs to be provided by STEP. For future sustainability, it is also desirable that the entrepreneurial and business skills of participants be strengthened so that the glove-making venture can, if successful, be evolved into a standalone enterprise.

This an important demonstration project for local communities and it is important that is succeeds.

Recommendation:

m. Provide assistance to the women participants in the glove-making CBO to help them to develop a simple ‘business plan’ to cover such matters as a market assessment, estimate of overheads and a budget, pricing of gloves, procedures for distributing revenues, accounting, record keeping, and taxation. There is potential for the use of the Sahil Business Development Centre in Sahil which is being implemented as part of the Shah Deniz CIP.

6.4 Vulnerable Groups and CIP

With the high incidence of poverty, and a large proportion of refugees and IDPs, many households in the adjacent villages of Sangachal and Umid are to varying degrees vulnerable. The particular issue in adjacent communities is the need to ensure that there is equitable access to benefits delivered by the project (such as through CIP programs) to all, including to vulnerable people.

The SRAP review noted two instances where some vulnerable groups might be disadvantaged in terms of benefiting from the STEP sponsored sewerage rehabilitation project (see Section 6.2). These cases were as follows:

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• Refugees/IDPs living in railway carriages in Sangachal: this group is presently reliant on a temporary communal ablution block (pit latrines, showers) and periodically pays for a truck to remove effluent. The carriage dwellers will not benefit from the sewerage CIP. It is recommended that consideration should be given to designing a small project that provides some equivalent benefits for this group.

• Elderly, physically impaired households – under current proposals, villagers will be responsible for connecting their individual houses to the trunk sewerage system which will be constructed with support from the project. A system of support needs to be agreed to ensure that houses with elderly, physically impaired, or other disadvantaged households are able to complete connections.

Consultations with villagers in Sangachal and Umid revealed many cases where the project and villages have intervened to ensure that vulnerable households have equal or preferential opportunities to benefit from project employment, training and educational programs.

Recommendation:

n. BP to initiate a process to consult with railway carriage-based IDPs and identify types of assistance to benefit this community in lieu of the sewerage rehabilitation project.

o. BP to ensure that measures are agreed with villages benefiting from the sewerage rehabilitation project to assist vulnerable households with installation of house connections.

6.5 ATA Yards

As noted in Section 1.5, the Compression and Water Injection Platform (C&WP) for ACG is being fabricated in the ATA yards situated within the Bibi-Heybat oil fields. While this is essentially a third party operation, BP has a project management presence on the site and has decided to implement a social investment program. A Public Relations Coordinator has been appointed.

With an initial budget of $250,000, the C&WP social investment program will target community and municipal government development for communities in the Bibi Heybat area. Bibi Heybat has a population of about 1,840. The social investment program, which was tendered to national and international NGOs, was awarded to International Rescue Committee. International Rescue Committee has designed a well conceived, multi-sectoral program that supports activities in health, infrastructure, education, youth development, economic development and community mobilization. The program also includes training and capacity building for the municipal government officers.

Twenty-eight families presently live in buildings within the Bibi-Heybat oil field, where oil extraction is still actively occurring. Given the highly polluted condition of the Bibi-Heybat field, and the risks that this presents to its inhabitants’ health and safety, it is strongly recommended that as part of its community assistance, the project look at avenues to facilitate the relocation of these twenty-eight families to a safer

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environment. These families are not living within areas which are directly affected by ATA operations.

It is recommended that BP explore potential partnerships with SOCAR (owners of the Bibi-Heybat site), the World Bank (through its Environmental Fund) and the Ministry of Refugees and IDPs to examine options to relocate these 28 households to alternative dwellings. BP should also review whether there is a need for measures to control any influx of new settlers to the Bibi-Heybat oil fields site such as might be attracted by commercial opportunities in and around the ATA yard. It is undesirable that there be any increase in the numbers of people living within the oil fields.

Recommendation:

p. BP to provide opportunities for the ATA Yard Public Relations Coordinator to regularly engage and interact with other ACG, SD and BTC social teams.

q. BP to explore potential for partnerships with SOCAR, the World Bank/Environmental Fund and Ministry of Refugees and IDPs to facilitate the relocation of the 28 households living within the Bibi-Heybat oil fields.

r. BP to review the need to implement measures to control any influx of new settlers within the Bibi-Heybat oil fields site.

7. PUBLIC CONSULTATION AND DISCLOSURE

Discussions with the STEP Environmental and Social Team show that there is a well established framework of regular meetings with local community representatives and local and district level government administrations. STEP maintains three Project Information Centres in Sangachal, Umid and Sahil that are manned during business hours. The Public Consultation and Disclosure Plan has not recently been updated. It is recommended that STEP prepare a stakeholder consultation matrix (2-3 pages) to update consultation and information dissemination activities. STEP should also monitor the BP Business Unit NGO engagement program to ensure that this effectively meets STEP NGO consultation needs.

Recommendation:

s. BP to prepare an updated stakeholder consultation matrix to cover:

- Key stakeholders to be kept briefed and consulted - Types of information that need to be exchanged - Techniques that will be used for disseminating information and gathering

feedback - Frequency of consultations

t. STEP Environmental and Social Department to monitor efficacy of BP Business Unit NGO engagement program for addressing STEP requirements.

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8. CONCLUSION

8.1 Resettlement

Good progress has been made since the last review in reaching an agreement on the relocation of the small roadside enterprise. The enterprise owners are satisfied with the agreement, and compensation arrangements fully accord with the RAP and OD4.30.

An impasse has been reached on negotiations to secure the project affected pastoralist family replacement winter pastures at Gobustan. While STEP is adequately assisting the pastoralist family to remain with their livestock at their original winter camp adjacent to Sangachal terminal, this is a short term measure. With the pastoralist family’s employer, BP must seek to find an alternative winter pasture acceptable to the family, and establish some security of tenure for its ongoing use. BP has clearly stated that it is mindful of its RAP responsibilities and is committed to finding alternative pastures. The pastoralist family head is being regularly consulted and kept fully informed of developments. The head confirmed his family’s preference to remain in their original camp, at least in the short term, and indicated that his family’s needs are being adequately met.

RAP internal monitoring and reporting is being undertaken efficiently. There is regular ongoing consultation and liaison with the principal project affected groups.

8.2 Construction

Social-related Construction Control Plans were found to have been effectively implemented with efficient reporting, feedback mechanisms and record keeping. Some measures to strengthen recording of grievances and grievance outcomes have been recommended.

To allay some adjoining community concerns, and to fill a gap in health baseline information, the following actions have been recommended:

- BP to publicize a firm commitment to adjacent communities on the timing for cessation of flaring (except in emergencies)

- BP to instigate baseline health surveys in Sangachal and Umid

As STEP construction workforce numbers start to decline, BP needs to start planning to maximize operations phase employment opportunities for Sangachal and Umid workers. Lead times to identify potential employment and outsourcing opportunities and to deliver necessary training and capacity building can be significant. Cooperation between the Construction and Operations Teams are recommended to identify opportunities, and design and deliver any related training.

8.3 CIP

The STEP CIP program is performing well and delivering a wide range of benefits to adjoining communities. There is, however, quite considerable widespread frustration at the slow delivery of the sewerage project. A clear commitment to a construction

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start date for the sewerage project and an early-as-possible construction commencement are recommended to help allay local frustrations. Some recommendations have been made to address some aspects of the sewerage project not covered by the current tender package.

There were some signs of dependency on project assistance apparent in Sangachal and Umid. Increased focus on measures to promote greater municipal and community self-reliance are recommended as part of the final years of construction phase community assistance.

The ATA Yard social investment program to be delivered by the NGO, International Rescue Committee, is a well conceived, multi-sectoral program that supports activities in health, infrastructure, education, youth development, economic development and community mobilization.

9. SUMMARY OF RECOMMENDATIONS

9.1 Tracking of Recommendations from the August 2003 Review

The following table lists recommendations made by the SRAP Panel as a result of the first review in August 2003, together with their status as of February 2004.

Table 9-1 Tracking of Recommendations from the Previous Review

Date Recommendation Status February 2004

August 2003 a. BP to provide all compensation support to the small enterprise as documented in the RAP, in the event this is not provided through the Valuation Commission.

Done

August 2003 b. BP to explore all reasonable means to allow the small enterprise to continue to operate in its present premises, or otherwise make arrangements for continuance of the proprietor’s & employees’ wages & income.

Done

August 2003 c. Prior to the enterprise owner signing any legal agreements, BP should extend to him the offer of legal assistance, such as that being provided to BTC pipeline affected people, using the NGO, Centre for Legal & Economic Education.

Done

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Date Recommendation Status February 2004

August 2003 d. BP to explore additional mechanisms to strengthen the pastoralist land tenure & prevent recurrences of third party occupation of their replacement pasture.

To do

(critical)

August 2003 e. BP to keep the pastoralist family fully advised of progress with preparation of the Gobustan land, so that the family can plan their return trip from their summer pastures.

Done

August 2003 f. In the event the pastoralists need to use their old Sangachal winter settlement, BP to (i) supply water & supplementary fodder (if required); &, (ii) coordinate with BTC Co. to ensure that pipeline construction will not negatively impact upon the pastoralist’s winter operations at Sangachal.

Done

August 2003 g. Internal Monitoring reports to be prepared for 31 October 2003 & 31 January 2004 ahead of the next Expert Panel review & quarterly thereafter.

Done

August 2003 h. February 2003 External Review to include a more focussed assessment of people’s perceptions of project social impacts in Sangachal, Umid & Sahil.

Done

August 2003 i. BP to review site dust management strategies & publicize outcomes in adjacent communities.

Done

August 2003 j. BP to consider implementing a hygiene & sanitation promotion & water demand management strategy as part of its sewerage system rehabilitation project.

Planned

August 2003 k. Expert Panel to allow two to three days for community & stakeholder consultations regarding CIP effectiveness for future reviews.

Done

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9.2 Recommendations of the February 2004 Review

Key recommendations for the Sangachal Terminal Extension Project arising from the February 2004 SRAP review are tabulated below. Recommendations are prioritized as follows:

High Actions that are critical to ensure compliance with commitments contained in the RAP, ESAP or World Bank OD 4.30

Medium Actions desirable to comply with social or resettlement good practice or to address actual or potential areas of social risk

Low Important actions that are less time critical

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Table 9-2 Recommendations of the 2004 SRAP Review

Issue Project Principles Performance Recommendation By Prioritya. BP to prepare a 2-3 page briefing

note to the Lenders Group to explain the circumstances of the pastoralist family, the reasons for the deviation from the RAP, and the alternatives that are presently under consideration.

BP High

b. BP to cooperate with the state livestock enterprise employer of the pastoralists to locate suitable replacement pasture and to facilitate putting in place agreements to secure the pastoralist’s ongoing use.

BP High

Replacement winter pasture for the pastoralist family

Pastoralist family to be assisted to find replacement winter pasture in accordance with the RAP

The replacement winter pasture at Gobustan, as documented in the RAP, has been occupied by third parties. BP is supporting the pastoralist family at their original winter pasture near Sangachal Terminal. After a ‘cooling off’ period, BP will re-commence negotiations to find alternative pasture.

c. BP to consult closely with the pastoralist family throughout the replacement site selection process.

BP High

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Issue Project Principles Performance Recommendation By Priorityd. All grievances to include a clear

record of the ‘corrective action’ taken in response to the complaint, and the ‘outcome’ of the corrective action.

BP HighGrievance outcome recording

Grievance corrective actions and outcomes to be recorded as part of ‘close out’

‘Corrective actions’ and ‘outcomes’ are not always being recorded systematically

e. A summary log of grievances (Excel spreadsheet) to be kept by BP to summarize: - Date of grievance - Name and contact details of

complainant - Nature of complaint - Agreed corrective action - Person responsible for

implementing the corrective - Outcome - Date of close-out

BP High

f. BP to publicize a clear commitment on the timing for a cessation of gas flaring (except in emergencies) at the Sangachal Terminal.

BP MediumLocal concerns about gas flaring and need for a health baseline for local communities

Maintain emissions within agreed standards

In spite of the flare being fully compliant with agreed emission standards, many surrounding villagers are concerned that Sangachal Terminal gas flaring might be affecting their health. STEP has not conducted a detailed health baseline study of adjacent communities.

g. As a reputational risk management measure, BP to engage a suitably qualified expert to design and implement a health baseline study of the two adjacent communities.

BP Medium

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Issue Project Principles Performance Recommendation By PriorityTransition to operations phase – local employment

To maximize opportunities for local employment

BP is presently recruiting and mobilizing its Operation Team for the terminal. Now is an appropriate time to start planning for local employment as part of operations phase activities.

h. BP Construction Phase Team to coordinate with the Ops team to start planning for operations phase local employment opportunities as early as practicable.

BP Medium

i. STEP to regularly publicize project in-country spend data to demonstrate the extent of local procurement.

BP HighLocal procurement

To maximize opportunities for local businesses and enterprises to participate in project procurement

BP’s Enterprise Centre has been proactive with measures to facilitate local businesses (national and regional) to bid on project procurement opportunities. To date, no data on in-country spend is available to demonstrate the extent of local procurement. Potential for the CIP program to support local SME development to enable district and village level enterprises to bid for operations phase procurement needs to be examined.

j. STEP to examine potential linkages for the Construction phase CIP program to support SME development targeting operations phase outsourcing and procurement opportunities.

BP Medium

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Issue Project Principles Performance Recommendation By Priorityk. So far as consistent with the

strategy of procuring the sewerage system through Baku Municipality, expedite the tendering process to achieve the earliest possible start and as soon as practical, publicize to the beneficiary communities a commitment to a firm construction start date.

BP MediumCommunity Investment Program

To provide a trunk sewerage system for Umid and Sangachal as part of STEP CIP initiatives.

The performance of CIP projects as perceived by the host communities was assessed during the SRAP review. Communities were generally appreciative of STEP CIP initiatives. Some strengthening measures for the sewerage upgrade project and glove-making CBO are recommended. Attention to ensuring vulnerable groups receive equivalent benefits sharing opportunities to other community members is highlighted.

l. Develop strategies (preferably through matching inputs from local government or other sources) for (i) providing connections/ related materials; (ii) supply of labour and materials for filling/ re-grading to ameliorate poor drainage areas; and, if required, (iii) assisting vulnerable people to install house connections.

BP Medium

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Issue Project Principles Performance Recommendation By Prioritym. Provide assistance to the women

participants in the glove-making CBO to help them to develop a simple ‘business plan’ to cover such matters as a market assessment, estimate of overheads and a budget, pricing of gloves, procedures for distributing revenues, accounting, record keeping, and taxation. There is potential for the use of the Sahil Business Development Centre in Sahil which is being implemented as part of the Shah Deniz CIP.

BP Medium

n. BP to initiate a process to consult with railway carriage-based IDPs and identify types of assistance to benefit this community in lieu of the sewerage rehabilitation project.

BP High

Community Investment Program cont.

o. BP to ensure that measures are agreed with villages benefiting from the sewerage rehabilitation project to assist vulnerable households with installation of house connections.

BP High

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Issue Project Principles Performance Recommendation By Priorityp. BP to provide opportunities for

the ATA Yard Public Relations Coordinator to regularly engage and interact with other ACG, SD and BTC social teams.

BP Medium

q. BP to explore potential for partnerships with SOCAR, the World Bank/Environmental Fund and Ministry of Refugees and IDPs to facilitate the relocation of the 28 households living within the Bibi-Heybat oil fields.

BP Medium

ATA Yard community liaison and social investment program

To undertake a social investment program for the community adjacent to the ATA yard.

While essentially a third party operation, BP has decided to implement a social investment program (SIP) for the community adjacent to the ATA yards. A well-conceived SIP program has been commenced by International Rescue Committee. The SRAP review has suggested that consideration be given to possible avenues to relocate 28 families living within the Bibi-Heybat oil field. r. BP to review the need to

implement measures to control any influx of new settlers within the Bibi-Heybat oil fields site.

BP Medium

s. BP to prepare an updated stakeholder consultation matrix to cover: - Key stakeholders to be kept

briefed and consulted - Types of information that need

to be exchanged - Techniques that will be used

for disseminating information and gathering feedback

- Frequency of consultations

BP HighPublic Consultation and Disclosure

To maintain effective communications with stakeholders to proactively disseminate relevant information to local communities.

Local community and stakeholder consultation is being efficiently and effectively undertaken. Engagement with NGOs is to be managed through the BP Business Unit as part of an umbrella arrangement encompassing STEP and the BTC Pipeline Project.

t. STEP Environmental and Social Department to monitor efficacy of BP Business Unit NGO engagement program for addressing STEP requirements.

BP High