Stakeholder Engagement Plandocuments.worldbank.org/curated/en/817421569768404590/...line, and a 63km...
Transcript of Stakeholder Engagement Plandocuments.worldbank.org/curated/en/817421569768404590/...line, and a 63km...
MAY 2019
Stakeholder Engagement Plan
Sebzor Hydropower Plant
Associated 110kV transmission lines
and substations
Rural Electrification Project
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Contents
1. Introduction ...................................................................................................................................... 4
1.1 Background ............................................................................................................................. 4
1.2 Objectives of Stakeholder Engagement Plan ......................................................................... 6
2. Project Summary .............................................................................................................................. 6
2.1 Sebzor hydropower plant ....................................................................................................... 6
2.2 18-kilometer 110kV transmission line from Sebzor to Khorog ............................................ 10
2.3 63-kilometer 110kV transmission line from Khorog to Qozideh .......................................... 12
3. Summary of Potential E&S Impacts ................................................................................................ 14
4. Regulatory Context ......................................................................................................................... 17
4.1 Tajikistan requirements for stakeholder engagement ......................................................... 17
4.2 World Bank requirements for stakeholder engagement ..................................................... 17
5. Summary of Stakeholder Engagement and Identification ............................................................. 19
5.1 Engagement with local stakeholders .................................................................................... 19
5.1.1 Scoping consultations during Sebzor HPP Feasibility Study .................................... 19
5.1.2 Local scoping consultations for the ‘international’ ESIAs for Sebzor HPP and Sebzor-
Khorog transmission line ......................................................................................... 20
5.1.3 Local stakeholder consultations for the 63-kilometer Khorog-to-Qozideh
transmission line...................................................................................................... 21
5.2 Consultations with institutional stakeholders ...................................................................... 22
6. Stakeholder Identification and Analysis ......................................................................................... 24
6.1 Project-affected persons ...................................................................................................... 24
6.1.1 People affected by land acquisition ........................................................................ 24
6.1.1. Other people residing in the project areas ............................................................. 25
6.1.2. Village representatives (Jamoats) ........................................................................... 25
6.2. Other interested parties ....................................................................................................... 25
6.2.1. Other interested parties - external.......................................................................... 25
6.2.2. Other interested parties – Internal ......................................................................... 25
6.3. Disadvantaged / Vulnerable individuals or groups .............................................................. 26
6.4. Summary of stakeholder interest in and influence over the project ................................... 27
7. Stakeholder Engagement Program ................................................................................................ 27
7.1 Engagement methods and tools ........................................................................................... 27
7.1.1 Public/community meetings ................................................................................... 28
7.1.2 Mass/social media communication ......................................................................... 28
7.2 Planned stakeholder engagement activities ........................................................................ 37
7.2.1 Communication materials ....................................................................................... 37
7.1.1. Information Desks ................................................................................................... 37
7.1.2. Grievance redress mechanism ................................................................................ 37
7.1.3. Project tours ............................................................................................................ 42
7.1.4. Citizen/PAP perception survey ................................................................................ 42
7.1.5. Trainings and workshops ......................................................................................... 42
7.1.6. Vulnerable groups ................................................................................................... 42
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Contents (continued)
7.2. Disclosure of information and public consultations ............................................................. 42
7.3 Stakeholder Engagement during Project Implementation ................................................... 47
7.4 Pamir Energy Point of Contact ............................................................................................. 47
8. Grievance Redress Mechanism ...................................................................................................... 48
8.1 Grievance resolution process ............................................................................................... 49
8.2 Grievance processing ............................................................................................................ 52
8.3 Grievance Logs ...................................................................................................................... 53
8.4 Monitoring and reporting on grievances.............................................................................. 54
8.5 Pamir Energy Point of Contact ............................................................................................. 54
8.6 World Bank Grievance Redress System ................................................................................ 54
Annex 1: Example Grievance Form ...................................................................................................... 56
Annex 2. Minutes of Consultation Meeting on Sebzor HPP and Sebzor-Khorog Transmission Line in
Sebzor (Roshtqala District, GBAO).................................................................................................. 58
Annex 3. Minutes of Consultation Meeting on Khorog-Qozideh 110kV Transmission line in Andarob
and Qozideh Villages (Ishkashim District, GBAO) ........................................................................... 63
Tables
Table 1: Environmental and social documentation for TREP and associated projects .......................... 5
Table 2. Villages between Sebzor and Khorog ...................................................................................... 13
Table 3: Villages between Khorog & Qozideh crossed by the corridor ............................................... 13
Table 4: Scoping meetings with stakeholders in Rushan district in early 2019 ................................... 20
Table 5: Consultations in potentially affected villages between Khorog and Qozideh ....................... 21
Table 6: Scoping meetings with stakeholders in Dushanbe ................................................................ 22
Table 7: Scoping meetings with stakeholders in Khorog ..................................................................... 23
Table 8: Other interested parties - external ........................................................................................ 26
Table 9: Level of interest and influence over the project ................................................................... 27
Table 10: Generic Methods, Tools and Techniques for Stakeholder Engagement .............................. 29
Table 11: Planned stakeholder engagement activities by project phase ........................................... 38
Table 12. Public consultations on Sebzor HPP and associated transmission lines ............................... 43
Figures
Figure 1: Location of Gorno-Badakhshan Autonomous Oblast and Khatlon Province .......................... 4
Figure 2: Location of proposed Sebzor HPP and associated 18 km and 63 km 110kV overhead .......... 8
Figure 3: Location of proposed Sebzor HPP and associated 18km transmission line from ................... 9
Figure 4. Corridor of 18km 110kV transmission line from Sebzor HPP to Khorog............................... 11
Figure 5. Examples of towers ............................................................................................................... 12
Figure 6: Villages crossed by the 63km transmission line .................................................................... 13
Figure 7. Early consultation meetings in 2016 ..................................................................................... 19
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Figures (continued)
Figure 8. Meetings with local stakeholders in early 2019 ................................................................... 20
Figure 9. Consultations along 63km transmission line ........................................................................ 22
Figure 10. Disclosure consultation meeting in Sebzor .......................................................................... 45
Figure 11. Disclosure consultation meeting in Andarob ....................................................................... 46
Figure 12. Consultation meeting in Qozideh ........................................................................................ 46
Figure 13: Feedback and GRM Process ................................................................................................ 49
Figure 14: Typical grievance resolution process .................................................................................. 50
Acronyms and Abbreviations
Acronym Description
CLO Community Liaison Officer
E&S Environmental & Social
EMF Electromagnetic Field
ESF Environmental and Social Framework
ESIA Environmental and Social Impact Assessment
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESS Environmental and Social Standard of the 2018 World Bank ESF
GBAO Gorno-Badakhshan Autonomous Region (VMKB in Tajik)
GRC Grievance Resolution Committee (1 and 2)
GRM Grievance Redress Mechanism
HSE Health, and Safety, Social, and Environment
kV Kilovolt
masl Meters above sea level
NGO Non-Governmental Organization
PAP Project-Affected Person (or Project-Affected Party)
RAP Resettlement Action Plan
RPF Resettlement Policy Framework
SEP Stakeholder Engagement Plan
WB World Bank
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
1. Introduction
1.1 Background
The World Bank is considering providing support to the Tajikistan Rural Electrification Project (TREP),
whose purpose is to provide electricity access to selected settlements in Khatlon and Gorno-
Badakhshan Autonomous Oblast (GBAO) regions of Tajikistan (Figure 1) and to improve the reliability
of electricity supply in GBAO. The total value of the project is US$ 70.0 million, with US$ 20.0 million
to be financed by the World Bank. TREP is part of the Risk Mitigation Regime (RMR) that is included in
the upcoming World Bank Country Partner Framework for the Republic of Tajikistan for fiscal years
2019-2023.
The TREP is being prepared under the World Bank’s new Environment and Social Framework (ESF),
which came into effect on October 1, 2018, replacing the Bank’s Environmental and Social Safeguard
Policies. Under the ESF, projects such as TREP must comply with ten Environmental and Social
Standards (ESS) in investment project lending financed by the Bank.
TREP includes several components:
• Construction and operation of a run-of-river 10.5-megawatt (MW) Sebzor hydropower
plant (Sebzor HPP) on the Shokhdara River and an associated 6.6/35kiloVolt (kV)
substation.
• Construction and operation of a 63km 110kV transmission line between Khorog
substation and a new 35/110kV substation near Qozideh.
• Off-grid solutions for electrification of 105 villages located in GBAO and Khatlon,
comprising provision of electricity services to target settlements through construction of
small hydro (SHPP), solar and wind individual projects, and “last mile grid connections”
Figure 1: Location of Gorno-Badakhshan Autonomous Oblast and Khatlon Province
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
which will involve constructing short distances of low-voltage distribution lines to connect
currently unelectrified settlements in GBAO and to the national grid.
In addition to these projects that are part of the TREP, an associated 18km 110kV transmission line
will carry power generated by the new Sebzor HPP to a new 110/35kV substation in Khorog. This
component is being financed by the Swiss State Secretariat for Economic Affairs (SECO) and is included
in the present Stakeholder Engagement Plan.
The World Bank is also providing financing for environmental and social assessments and other
planning documentation needed for these projects to meet the requirements of the World Bank’s ESF
and other requirements related to environmental and social performance. The various assessments
will include:
• Environmental and social impact assessments. The Sebzor hydropower project, the
associated 18km transmission line from Sebzor to Khorog, and the 63km transmission line
from Khorog to Qozideh will each be assessed in an Environmental and Social Impact
Assessment (ESIA). Final feasibility studies are in preparation, and the environmental and
social impacts of the projects have previously been subject to a desktop environmental
and social evaluation and a full feasibility study. The off-grid solutions projects will have
preliminary assessments in Environmental and Social Management Frameworks (ESMFs)
that will establish criteria for future evaluations of individual electrification projects.
• Stakeholder Engagement Plans. Each project component will have a tailored program to
engage affected people and other stakeholders, with this one Plan for Sebzor HPP and the
associated 110kV 18km transmission line from Sebzor to Khorog and 63km Khorog-
Qozideh transmission line, one Plan for the off-grid project in Khatlon, and a third Plan for
the off-grid project in GBAO.
• Resettlement Policy Frameworks. Each project component will require the temporary and
permanent use of land that is currently allocated to other people and so will result in
physical and/or economic displacement of some households. Each will require one or
more separate Resettlement Action Plans in the future, but the principles and objectives
of the program will be the same for all subprojects. For that reason, a single RPF has been
prepared to cover all subprojects.
This report presents the Stakeholder Engagement Plan (SEP) for the Sebzor HPP and the two
associated 110kV transmission lines, one 18km from Sebzor to Khorog and another for 63km from
Khorog to Qozideh (“the Project” or “the projects”). Documents required for each component are
identified in Table 1: Environmental and social documentation for TREP and associated projects.
Table 1: Environmental and social documentation for TREP and associated projects
Sebzor HPP &
substation
18km Sebzor-to-Khorog
110kV t-line
63km Khorog-to-Qozideh t-
line
GBAO off-grid solutions
Khatlon last-mile solutions
ESIA ✓ ✓ ✓
ESMF
✓ ✓
SEP ✓ ✓ ✓
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Pamir Energy will be responsible for all the project components except the Khatlon last-mile solutions.
Pamir Energy was formed in 2002 by the Aga Khan Fund for Economic Development (AKFED) in
partnership with the Government of Tajikistan and the International Finance Corporation. Under a
public-private partnership agreement with the Government of Tajikistan, the company has assumed
the operational management of all power generation, transmission and distribution facilities of the
Gorno-Badakhshan Autonomous Oblast (GBAO) of Tajikistan. The Khatlon electrification projects will
be implemented by Barqi Tojik, the state-owned company responsible for power generation and
transmission in other provinces of Tajikistan.
1.2 Objectives of Stakeholder Engagement Plan
The overall objective of this Stakeholder Engagement Plan (SEP) is to define a program for stakeholder
engagement, including public information disclosure and consultation, throughout the construction
and operation of the Project. The SEP highlights the way Pamir Energy will communicate with people
and stakeholder groups who may be affected by or interested. The SEP includes a mechanism by which
people can raise concerns, provide feedback, or make complaints about Pamir Energy, the contractors,
and the Project itself or its components.
While the projects will result in only a few instances of physical resettlement, and relatively limited
permanent land acquisition, the involvement of the local population is essential to the success of the
projects in order to ensure smooth collaboration between project staff and local communities and to
minimize and mitigate environmental and social risks related to the projects.
2. Project Summary
The proposed Project, comprising Sebzor HPP, the 18km 110kV Sebzor-to-Khorog power transmission
line, and a 63km Khorog-to-Qozideh transmission line, is located in the southwestern part of GBAO,
as shown on Figure 2: Location of proposed Sebzor HPP and associated 18 km and 63 km 110kV
overhead.
2.1 Sebzor hydropower plant
The Sebzor HPP is located on the right bank of the Shokhdara river about 20 kilometers southeast of
Khorog). The powerhouse will be connected to a Pamir Energy substation in Khorog via the 18-
kilometer 110 kV overhead transmission line that will run from the HPP to a new substation in Khorog
(see Figure 3).
RPF ✓
ESIA: Environmental & Social Impact Assessment ESMF: Environmental and Social Management Framework SEP: Stakeholder Engagement Plan RPF: Resettlement Policy Framework
✓ indicates separate E&S document to be prepared to meet ESF and other applicable requirements
✓ identifies present document
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
The proposed Sebzor HPP will have the following major components:
• A small dam (also known as a weir) 70 meters across and five meters high, with three
meters above the riverbed, near Barjingal village.
• Small reservoir with maximum depth of three meters that extends about 700 meters
upstream and covers an area of about five hectares
• Water intake at the weir
• Desilting/desanding chamber about 65 meters long and 16 meters wide
• Penstock with two pipes, each one 1.2 meters in diameter, running for about 2.8
kilometres from the intake to the powerhouse. The penstock will run immediately beside
the road for part of its length and through a tunnel for another part.
• Powerhouse with three 3.5MW turbines and generators near Sebzor village
• Tailrace will carry water from the powerhouse under the road and back to the river
• Work camp and storage area will be located approximately halfway between Barjingal and
Sebzor villages. This area will be used for construction workers accommodation and
storage of construction materials and construction equipment. It will cover an area of 4-
5 hectares and include a number of workshops, warehouses, fabrication areas, sanitary
facilities, worker accommodations, and associated facilities (sanitary, recreation, kitchen,
etc.).
The Sebzor HPP also comprises reconstruction and expansion of about three kilometers of paved road
between Barjingal and Sebzor villages. The road is planned to be expanded from a width of 4-5 meters
to 6.5-7 meters, with a new asphalt surface. In addition, the project includes construction of a new
bridge across the Shokhdara river at the village of Sebzor. The bridge will be five meters wide and
capable of serving cars and light trucks. Each of these projects will be completed by contractors and
will employ up to 100 workers during a one-year construction period.
Other key aspects of this subproject include the following:
• Environmental flows. An “environmental” flow of at least 10 percent of the annual
average, or 3m3/s, will be left in the river at all times. At maximum capacity, 10.5m3/sec
will be diverted through the penstock to the powerhouse. All river flows higher than 13.5
m3/sec will , which occurs over 50 percent of the time, will flow over the weir. When flows
are lower than 13.5m3/s, the plant will generate less electricity, down to a flow of 4.75
m3/sec, when 3 m3/sec will pass over the weir as environmental flow and the remaining
1.75m3/sec will be diverted to the powerhouse.
• Flooding. The Shokhdara River is subject to extreme floods in summer, and even to a
Glacial Lake Outburst Flow should there be a breach in the earthen “dam” that holds back
a glacial lake in the headwaters. In addition, a dike will be constructed on both riverbanks
immediately upstream of the dam to ensure that annual floods do not reach the nearest
houses. The weir is being designed to withstand a 1000-year flood (450 m3/sec), and will
be 0.45 meters higher than the water level during this flood. Lowest flows are in winter,
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Figure 2: Location of proposed Sebzor HPP and associated 18 km and 63 km 110kV overhead transmission lines, GBAO, Tajikistan
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Figure 3: Location of proposed Sebzor HPP and associated 18km transmission line from Sebzor to Khorog project
when discharge in the river ranges from 6 to 15 m3/sec. Highest flows are in summer, with the
average peak of over 110m3/s. The average annual flow rate is about 24-30m3/s.
• Earthquake/seismic activity. The dam is in an area considered to be at high risk of seismic
activity (earthquake), up to about 6-7 on the Richter scale. Additional studies are needed
to determine final design parameters to ensure the dam can withstand likely seismic
activity. Given the low weir/dam and the relatively small reservoir, even complete failure
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
of the dam would have relatively minor downstream consequences, especially when
compared to the annual flooding that occurs in summer.
• Fish pass. The dam will be designed so that fish can move upstream and downstream via
a fish passage. The fish passage will be about 2.5 meters wide and 44 meters long, and is
being designed with a flow rate of 1.25m3/s, or about 40 percent of the environmental
flow. The fish pass is being designed to accommodate False Osman (Schizopygopsis
stoliczkai Steindachner) and Marinka (Schizothorax sp. (intermedius?)), which are the two
fish species that migrate upstream and downstream and are caught by local fishers.
The length of the construction period is anticipated to be between two and four years, depending
on the length of the construction season, which typically extends from April through November
but will depend on weather. An international consultant (SWECO) is currently in the process of
finalizing the design for HPP, following which Pamir Energy will select construction contractors via
open tender. There will be at least two main construction contractors, one for electromechanical
works at the powerhouse and substation and one for civil works for the dam, penstock, and
powerhouse. The civil works contractor will employ about 400 workers for the hydropower
project and he electromechanical contractor about 20 workers, with many or most of those
employed by the civil works contractor will come from local communities. Construction activities
will involve earthworks, land clearance and leveling, drilling and possibly limited blasting, concrete
works, welding works, transportation/storage of various pieces of equipment, and others.
Construction will be supervised by a Supervision Consultant (also known as the Owner’s Engineer
or Supervising Engineer) to be selected by Pamir Energy. In addition, contractors hired to construct
the new bridge will employ about 20 workers and the contractor hired to reconstruct the road will
employ about 30 workers. Many or most of these workers will be from local communities as well.
The hydropower project could affect the people of five villages: Dashtak, Barjingal (location of weir),
Chagev, Midensharv, and Sebzor (location of powerhouse). The total population of these villages is
1517.
2.2 18-kilometer 110kV transmission line from Sebzor to Khorog
The proposed 18km transmission line will run from the new substation at Sebzor HPP to a planned
35kV/110kV substation in Khorog Figure 4, which will be located on the right bank of the Gunt river
near the confluence of the Shohdara River and the Gunt River. This component of the Project includes
construction of a 35kV/110kV substation in Khorog.
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
There will be a total of 73 steel lattice towers of three types, with examples shown on Figure 5:
• Four-legged steel lattice “angle” towers will be anchored in concrete foundations, with
the base about 7.5 meters square (thus, corner foundations about 7.5 meters apart and a
total “footprint” of 56.25 square meters) and adjustable heights ranging from 15 to 25
meters.
• Smaller four-legged steel lattice “suspension” towers for straight sections will also be
anchored in concrete foundations and will be slightly smaller than the angle towers. These
will occupy an area of about 5 meters square (or 25 square meters) and be about the same
height as the angle towers.
• In areas where terrain does not allow four foundations for legs, three steel towers (poles)
will each be anchored in concrete foundations and will be about 20 meters high. Each
foundation will be 1.5 meters square and up to 5 meters apart, thus occupying an area of
up to about 30 square meters).
Figure 4. Corridor of 18km 110kV transmission line from Sebzor HPP to Khorog
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
One or two local (i.e., from Tajikistan) contractors will be appointed to complete the construction. It
is anticipated around 40 workers will be employed in construction, many or most of them from local
communities. Construction activities, which are anticipated to last for two years (that is, two seven-
month construction seasons, or as permitted by weather) will include earthworks, concrete works to
install foundations for tower legs and poles, transportation/storage of various pieces of towers and
insulators, and tower assembly (erecting) works. Other than drills and hand tools, little or no
mechanized equipment will be used, as steel parts of the towers will be carried by hand from trucks
to locations and assembled in place. When towers are in place, conductors (wires) will be placed on
the towers and energized.
A total of 29 villages with a total population of 9943 are located between the Sebzor HPP dam/weir
and the Khorog substation and thus their populations may potentially be affected. Villages are
identified in Table 2.
2.3 63-kilometer 110kV transmission line from Khorog to Qozideh
The main purpose of the new 110km power transmission line from Khorog to Qozideh is to improve
the reliability of electricity supply to Ishkashim District. In the future, it is foreseen the new line will
provide electricity supply to neighboring regions of Afghanistan, but that is not part of the present
project.
Figure 5. Examples of towers: angle tower at left, three suspension poles on uneven terrain at top right, example of foundation at bottom right
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
The new 110kV line will run through rough and
rocky mountain terrain along the Tajik and
Afghan state border parallel to and near the
Panj River (also spelled “Pyanj” or “Pyandzh” in
English). The line will begin at the new
35kV/110kV substation in the city of Khorog,
pass through Roshtqala district, and end in a
new 110/35kV substation near the village of
Qozideh in Ishkashim district (Figure 2 above
and Error! Reference source not found.). The
line will pass through or near 13 villages
between Khorog and Qozideh. These villages
have a total population of 5,633 persons (798
households). The villages are identified in Table
3.
The project is currently in advanced planning. Due to
deterioration of the existing 35kV line, the first 10-kilometer
section of the line has already been constructed (a total of
37 towers), and another five towers in avalanche areas have
also been constructed, all financed by other donors. The
World Bank financing will be used for construction of towers
on the remaining 53km and the stringing of conductors
(wires) on the towers that have already been constructed.
Table 2. Villages between Sebzor and Khorog
Andarv Kurtsboghen Shikush
Barmev Lahshik Shod
Bartavdem Langar Shosh (Tusyon)
Bodomi bolo Namadroj Shuvjev
Chagev Nuj Siyob
Devloh Ridjak Sumjev
Khabost Rijist Tavdem
Khichikh Rizef Zhirpor
Khidorjev Sazd Zigur
Kulev Sebzor
Table 3: Villages between Khorog & Qozideh crossed by the corridor
Viruthjak Andarob
Gozhak Dasht
Pish Kuhi - La'l
Nishusp Sist
Shichozg Vozg
Barchidev Shanbedeh
Khaskhorug
Figure 6: Villages crossed by the 63km transmission line
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
There will be about 250 towers, of which 42 have already been constructed, as described above. The
exact number of each type will be determined during final design, as will their locations. The towers
will be the same three types as described for the Sebzor-to-Khorog transmission line and illustrated in
Figure 5.
The construction period will last for two or three years, depending on the length of the construction
season, which normally extends from April through November. Towers will be provided by an
international vendor, although it is likely they will ultimately be purchased and imported from China.
One or two contractors, likely to be from Tajikistan, will be appointed to complete the construction.
It is anticipated around 120 workers will be employed in construction, many or most of them from
local communities. Construction activities for the transmission line will involve earthworks, including
drilling and possibly limited blasting, concrete works to install foundations for tower legs and poles,
transportation/storage of various pieces of towers and insulators, and tower assembly (erecting)
works. When towers are in place, conductors (wires) will be placed on the towers and energized. For
the substation, about 150 workers will be employed in earthworks, concrete works, and installation
of electrical equipment.
As noted, the transmission line corridor will run parallel to the Panj River. A two-lane road (designated
as road RB 06(12R45)) also runs parallel to the river, and the existing 35kV line runs in part between
the river and the road and in part inland of the road, sometimes several hundred meters higher than
the road. One option considered by Pamir Energy is simply to place the new steel towers in the same
locations as the existing wooden poles. However, the existing line passes near or through villages and
would likely require some resettlement of households. Therefore, it is Pamir Energy’s intent that the
new towers be placed so the corridor does not pass near any occupied houses or other buildings, and
so that it avoids orchards and trees as much as possible.
In addition, as noted for the 18km line between Sebzor and Khorog, Pamir Energy will require the
contractor to use little or no mechanized equipment other than vehicles, rock drills, and hand tools.
All materials, including concrete, water, steel parts of the towers, and other materials, will be carried
by hand from trucks to the tower locations and the towers will be assembled in place. At present, the
42 new towers carry 35kV conductors (wires). When towers are in place, 110kV conductors (wires)
will be placed on the towers and energized.
3. Summary of Potential E&S Impacts
Potential environmental and social risks (E&S) and impacts as a result of the Project’s planning,
construction and implementation have been examined and addressed in stand-alone Environmental
and Social Impact Assessments (ESIAs) for each of the three projects. Key environmental and social
considerations that were examined in both reports include:
Environmental considerations:
• Air quality could be affected by dust from movement of vehicles and equipment on
unpaved roads and from earthworks and open piles of spoil, and vehicles and equipment
powered by combustion engines would emit pollutants. Impacts would be temporary and
with proper controls would be very minor and localized.
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
• Water quality in the Shokhdara and Panj Rivers could be affected due to erosion from
tower sites and from spills of fuel or other hazardous materials. Contractors will be
required to prevent erosion and spills, so there should be limited or no impacts. There is
a potential risk of negatively affecting fish migration in the Shokhdara River as a result of
hydropower plant construction. This risk will be significantly reduced by embedding into
the plant’s design a fish passage that will allow fish moving upstream for spawning.
• Landscapes and views will be affected temporarily due to construction and maintenance
activities and permanently by the presence of the hydropower plant civil structures,
penstocks, substations and transmission towers and conductors.
• Soil erosion could occur from run-off of rainfall and snowmelt if land clearing and
construction activities are not managed properly. Contractors will be required to save
topsoil and to prevent erosion.
• Geomorphologic hazards. Portions of the two transmission line corridors lie within high-
risk zones for avalanches, debris flow, rockfalls, and the entire Project is in a high-risk zone
for earthquakes. Designs will take these risks into account so as to minimize the risk of
damage to the line in future, and construction will take steps so as not to cause earth
movement. The siting of Sebzor HPP and 18ine km transmission accounted for such risks,
and the alternatives analysis provided the safest locations for the hydropower plant
structures, work camp, storage yard and towers of the 18km line. On the 63km line,
towers have been constructed In the areas of highest risk, and other towers in high-risk
areas will have diversion structures placed slightly uphill to divert avalanches and
mudflows. In addition, the dam and associated infrastructure is being designed to
withstand an earthquake of the highest magnitude expected to occur within a 50-year
period (9 on the Medvedev–Sponheuer–Karnik [MSK] scale and 7 on the Richter scale).
• Plants and animals could be affected by disturbance during construction and by
permanent use of their territories. Given the nature of the terrain, the small areas that
will be affected, and the limited biodiversity, this will not be a significant issue.
• Water quantity in three kilometers of the Shokhdara River between the dam and
powerhouse could be adversely affected as a result of diversion of up to 10.5 cubic meters
per second (m2/s). At minimum “environmental flow” of at least 3m3/s will pass over the
dam at all times, even when flows are very low in winter. There is no irrigation or other
known uses of water in this river reach, so there will be impact on local people.
Worker health & Safety considerations:
• Construction workers will be exposed to elevated risks that is inherent in construction
works. These include the risks of working at height, on steep slopes, working around
trucks and machinery, working with electricity, trips and falls, working with hazardous
materials (paints and fuels), and traffic accidents. Contractors will be required to develop
and implement occupational health and safety plans and to train all workers.
Social and economic considerations:
• Electromagnetic fields could cause health effects if workers or persons living in close
proximity to the operating transmission lines were exposed to high levels for long periods
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
of time. However, levels will be very low, workers will only be exposed for short periods,
and no one will live near the line, so there will be no health effects.
• Physical or economic displacement could occur if houses or valuable property are located
within a 45-meter protection zone under the line (20 meters from each conductor and 5
meters between conductors). It is Pamir Energy’s intent to locate the substations and
towers so no houses or other buildings are in the protection zone, and so the corridor will
avoid agricultural and other valuable land as much as possible. Sebzor HPP selected the
alternative configuration that required the least resettlement of households.
If towers are located on agricultural land, those who currently use the land will be
compensated for the land taken. As noted above, only small areas will need to be taken
for towers. As for land under the line between the towers, agriculture and grazing will not
be affected, except that tall equipment cannot be used and no buildings will be allowed
in the protection zone. If that requires a change in land use, Pamir Energy will provide
compensation. In addition, tall trees (those over 4 meters high) will need to be cut back
to maintain at least a 6-meter clearance from the wires. Those who own or use trees will
be compensated in such cases.
Small amounts of land will be used for footpaths for workers to travel between the road
and tower locations and possibly for equipment storage. Pamir Energy will compensate
those whose land is used in this way. Also, if property or crops are damaged during
construction or maintenance operations, or animals are injured or killed, their owners will
be compensated at replacement value.
Compensation requirements are set forth in a Resettlement Policy Framework that has
been developed by Pamir Energy and in one or more future Resettlement Action Plans
that will be developed by Pamir Energy and approved by the World Bank and the
Government of Tajikistan.
• An influx of workers from outside the region could disturb local communities with
disruptive behavior, use of local resources such as hospitals and schools, and introduction
of disease. There will be relatively few outside workers, probably less than half of all
workers, and all workers will be subject to a strict Code of Conduct, so there should be
very little or no impact.
• Traffic accidents and inconvenience could be caused by increased project traffic on the
two-lane roads between Barjingal to Sebzor, Sebzor to Khorog, and from Khorog to
Qozideh. The contractor will be required to develop and implement traffic management
plans to minimize impacts and to repair any damage to the road that construction may
cause.
• Local employment and income will be increased for up to three years due to seasonal
employment of several hundred workers from local communities.
• Power supply of GBAO will be improved by constructing Sebzor hydropower plant and the
new 18km transmission line. The 63km power transmission line project will improve
reliability of the electricity supply to Ishkashim district by replacement of the existing
35km line, and ultimately Afghanistan villages will benefit from electrification. The
increased power supply and increased reliability will contribute to future development of
the region.
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
4. Regulatory Context
4.1 Tajikistan requirements for stakeholder engagement
Public participation in decisionmaking, which follows from the legislation of the Republic of Tajikistan
and obligations under international agreements, is a new phenomenon in Tajikistan that requires the
necessary legal regulation. The tradition of closed or limited information about decisions that affect
the state of the environment have left a definite imprint on the attitude of society to environmental
issues. More than twenty years ago, public participation in the decision-making process was difficult
even to imagine. Now, there are a number of environmental and other requirements and acts that to
some extent regulate public participation in the EIA process in Tajikistan. These acts include:
• The Environmental Protection Law establishes the right of citizens to live in a favorable
environment and to be protected from negative environmental impacts (Article 12).
Citizens also have the right to environmental information (Article 13) as well as to
participate in developing, adopting, and implementing decisions related to environmental
impacts (Article 13). The latter is assured by public discussion of drafts of environmentally
important decisions and public ecological reviews. Public representative bodies have an
obligation to take into consideration citizens’ comments and suggestions.
• The Law on Environmental Expertise (art. 7) also provides the rights to citizens to conduct
a Public Environmental Expertise (that is, a public environmental review). This law also
empowers local authorities to facilitate public hearings, questionnaires, and referendums
regarding planned activities that are subject to ecological expertise. On 17 July 2001,
Tajikistan acceded to the 1998 Aarhus Convention, the provisions of which have priority
over domestic law that stipulates the rights for Public Environmental Expertise. The
element of public participation in the EIA procedure is described in detail in the Procedure
(Order) for Conducting an EIA of 2018. Public participation procedures are envisaged for
all categories of projects, although in practice they are mainly applied to major projects.
The Procedure (Order) for Conducting the EIA of 2014 changed the focus and timing of
public discussions, as the previous version (2006) provided for the participation of the
public at an early stage of the process (i.e., after submitting a draft declaration of intent
to the competent environmental authority) and it was indicated that comments and
suggestions from the public be taken into account in drafting the technical task for
carrying out the EIA. In fact, this ensured the participation of the public at the stage of
defining the range of EIA tasks (scoping). The Procedure for Conducting the EIA of 2018
assumes public discussions only after the preparation of the EIA report by the project
developer.
4.2 World Bank requirements for stakeholder engagement
The World Bank’s Environmental and Social Framework (ESF) came into effect on October 1, 2018.
The Framework includes Environmental and Social Standard (ESS) 10, “Stakeholder Engagement and
Information Disclosure”, which recognizes “the importance of open and transparent engagement
between the Borrower and project stakeholders as an essential element of good international
practice”. ESS10 emphasizes that effective stakeholder engagement can significantly improve the
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
environmental and social sustainability of projects, enhance project acceptance, and make a
significant contribution to successful project design and implementation.
As defined by the 2018 ESF and ESS10, stakeholder engagement is an inclusive process conducted
throughout the project life cycle. Where properly designed and implemented, it supports the
development of strong, constructive and responsive relationships that are important for successful
management of a project’s environmental and social risks. It emphasizes the importance of initiating
stakeholder engagement at an early stage of the project development process, as a part of the
assessment, management and monitoring of environmental and social impacts. Key requirements of
ESS10 include:
• “Borrowers will engage with stakeholders throughout the project life cycle, commencing
such engagement as early as possible in the project development process and in a
timeframe that enables meaningful consultations with stakeholders on project design.
The nature, scope and frequency of stakeholder engagement will be proportionate to the
nature and scale of the project and its potential risks and impacts.
• “Borrowers will engage in meaningful consultations with all stakeholders. Borrowers will
provide stakeholders with timely, relevant, understandable and accessible information,
and consult with them in a culturally appropriate manner, which is free of manipulation,
interference, coercion, discrimination and intimidation.
• “The process of stakeholder engagement will involve the following, as set out in further
detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the
engagement with stakeholders will take place; (iii) disclosure of information; (iv)
consultation with stakeholders; (v) addressing and responding to grievances; and (vi)
reporting to stakeholders.
• “The Borrower will maintain and disclose as part of the environmental and social
assessment, a documented record of stakeholder engagement, including a description of
the stakeholders consulted, a summary of the feedback received and a brief explanation
of how the feedback was taken into account, or the reasons why it was not.”
Borrowers are required to develop a Stakeholder Engagement Plan (SEP) proportionate to the nature
and scale of the project and its potential risks and impacts (paragraph 13). Stakeholders have to be
identified and the SEP has to be disclosed for public review and comment as early as possible, before
the project is appraised by the World Bank. ESS10 also requires the development and implementation
of a grievance redress mechanism that allows project-affected parties and others to raise concerns
and provide feedback related to the environmental and social performance of the project and to have
those concerns addressed in a timely manner.
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
5. Summary of Stakeholder Engagement and Identification
5.1 Engagement with local stakeholders
5.1.1 Scoping consultations during Sebzor HPP Feasibility Study
In 2016, as part of the Feasibility Study of the Sebzor HPP project, Pamir Energy engaged stakeholders
in scoping consultations. The consultation and meetings took place in the following towns and villages
and with the following key people (see Figure 7):
• Roshtqala (Mr. Yusof Soltonnoyobov, administrative head of the Roshtqala District.)
• Barjingal (Mr. Kshkorbekov Kshkorbek (KK) is member of the community council)
• Sebzor (The village headman, Sultonnazar Shodoroev)
Project information was disclosed to all persons interviewed and the interviewees were asked to
express their attitude about the project, as well as to highlight specific social, economic and
environmental problems and considerations in the district and communities around. Overall,
interviewed persons expressed support for the proposed project due to high potential social and
economic value of the project implementation. Interviewed persons indicated a significance of this
project for the regional economy and local communities. Everyone noted that unemployment is a very
big issue across the district and the region overall. The Sebzor village head express a hope that local
residents will get a chance for work opportunities with Pamir Energy during the project construction
phase.
In late 2016, Pamir Energy’s consultant, SWECO, produced a Stakeholder Engagement Plan (SEP) that
was adopted and implemented by Pamir Energy as the project moved forward. As part of
implementation of the SEP, during May-October 2016, Pamir Energy held meetings attended by a total
of 135 stakeholders in four communities located in Roshtkala district and within the project area of
influence (or potentially affected area). The communities included Barjingal, Dashtak, Mirsaid and
Mirshakar. Pamir Energy disclosed project information to the public, including the duration of
proposed project activities as well as potential E&S impacts that could result from project construction
and operation. The local communities were also provided with information on the possible relocation
of households that are located within the area of the proposed Sebzor HPP.
Figure 7. Early consultation meetings in 2016
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Overall, the local residents once again confirmed their support for the construction of the
hydroelectric power station on and near their territory and the heads of households that were located
very close to the proposed project agreed that their households could be relocated should that be
necessary. A working group (committee) was established among local residents in order to provide
support and be in frequent communication with Pamir Energy regarding the relocation and
compensation aspects. Some photographs from the 2016 consultations are shown below:
Later, upon the completion of these early consultations, Pamir Energy produced a Resettlement
Action Plan (RAP), which was then further disclosed and consulted with stakeholders and the affected
public. This RAP was never implemented, but served as the basis for the present Resettlement Policy
Framework.
5.1.2 Local scoping consultations for the ‘international’ ESIAs for Sebzor HPP and Sebzor-Khorog
transmission line
In early 2019, prior to and during the preparation of this SEP, Pamir Energy conducted interviews with
community members in Khorog and at three villages in Rushan district. The main topic of the
community meetings was been to share information, communicate with the local population and
identify their needs and interests. Table 4 below provides a list of selected stakeholders who were
contacted and interviewed in Rushan district and Figure 8 shows informal consultations in two local
communities.
Table 4: Scoping meetings with stakeholders in Rushan district in early 2019
Full name Location Affiliation and position
Surobov Shams Rushan district Head of Askar Zamirov’s community
Muzofirbekov Iqbolkhon Qozideh, Rushan district Head of the Community
Saidbekov Sh Gh.Shohbozov’s community, Rushan
district
Head of Gh.Shohbozov’s community
Oshurov Amonbek Rushan district Teacher, School # 26
Ramatulloev Mavlodod Rushan District Works at AKAH
Figure 8. Meetings with local stakeholders in early 2019
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
All community members who were interviewed expressed positive opinions about the proposed
Sebzor HPP and transmission line construction project. All respondents support the Rural
Electrification Project due to its high social and economic value to local communities. Everyone
interviewed had knowledge of Pamir Energy and its activities. Nearly everyone noted that the most
significant social and economic problems in the region are high unemployment rates and low income.
A number of stakeholders interviewed specified that the best communication method with village
residents and community members would be through Pamir Energy electricity inspectors, who they
see on a regular basis (once a week or so) when inspectors visit households to read electricity
consumption meters. Every interviewee expressed interest in participating in further meetings,
consultations, and public hearings for the proposed project.
5.1.3 Local stakeholder consultations for the 63-kilometer Khorog-to-Qozideh transmission line
Prior and during the preparation of this SEP and the “international” ESIA for the 63km transmission
line, Pamir Energy conducted interviews with community members in Khorog and in three villages
between Khorog and Qozideh (out of the 13 potentially project-affected communities). The primary
purpose of the community meetings was to share information, communicate with the local
population, and identify their needs and interests. Table 5 identifies project stakeholders who were
consulted in early 2019 and Figure 9 shows one of the groups met.
Table 5: Consultations in potentially affected villages between Khorog and Qozideh
All people who were consulted expressed positive opinions about the proposed transmission line
and about the larger World Bank Rural Electrification Project. As with Sebzor HPP and the 18km
transmission line, everyone interviewed had knowledge of Pamir Energy and its activities.
Full name Location Date of Birth Affiliation
Ismoilova Oistamokh (f) Vogz village, Qozideh Jamoat, Ishkashim district
12/03/1943 Head of community. Pensioner
Muzofirbov Mavlonzar (m) 01/01/1952 Teacher at school. Pensioner
Miravazahonov Shahboh (m) Shandebeh village, Ishkashim district
15/05/1947 Engineer. Pensioner
Muborakshoeva Bibisulton (f) 29/11/1949 Dressmaker. Pensioner
Ismoilbekov Maram (m) Qozideh village, Ishkashim district 11/09/1947 Worker
Asadulaev Rachab (m) Qozideh village, Ishkashim district 08.08.1944 Teacher
Abduraimov Abduraim (m) Village Sist, Qozideh, Ishkashim district
27.09.1950 Pensioner
Davlatov Okimbek (m) Village Sist, Qozideh, Ishkashim district
25.12.1951 Security guard.
Odinaeva Asparmo (f) Nishusp village 19.03.1955 Pensioner
Manasurova Olabegim (m) Nishusp village 16.08.1941 Pensioner. Former farmer
Inronbekov Sjodmon (m) Pish village 17/03/1950 Construction worker
Mirzoeva Soadat Pish village 24/08/1953 Accountant
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Concerns were similar as well: high unemployment and
low incomes. They also agreed that the best method of
communication would be through Pamir Energy
electricity inspectors. Everyone also expressed interest
in participating in further meetings and consultations.
5.2 Consultations with institutional stakeholders
During the period of February 18 – March 10, 2019,
Pamir Energy organized and carried out a series of
scoping meetings and consultations with institutional
stakeholders1. The consultation process involved
identification of key project stakeholders in Dushanbe
and GBAO, meetings with state and local authorities in
Dushanbe and Khorog (Houkumat, Jamoat), meetings
with regional NGOs and academic research institutes
and universities in Dushanbe and Khorog (e.g.,
University of Central Asia and Pamir Biological Institute
in Khorog). The main objectives of scoping consultations
included:
• To identify and verify interests of project
stakeholders and to establish working dialogues between Pamir Energy and the
stakeholders
• To disclose information about the project
• To understand stakeholders’ expectations about the project and their respective levels of
interest in continued communication and participation in future Pamir Energy activities
associated with the proposed project.
• To receive feedback, comments, and concerns from stakeholders about the project and
on prospective regional electricity supply schemes in general
• To obtain feedback on major environmental, social and economic problems in Roshtkala
and Ishkashim districts and overall across GBAO.
Table 6 and Table 7 identify key project stakeholders who were consulted in February and March 2019.
Table 6: Scoping meetings with stakeholders in Dushanbe
Date Name of Unit Position Full name
21 February Renewable Energy Center Director Kabutov Kurbondjon
21 February Physics and Mathematics Institute of the Academy of Sciences of the Republic of Tajikistan
Deputy Head of Department
Boturov Kodir
21 February BARS Consulting Founder Alikhon Latifi
1 Consultations and discussions dealt with the World Bank’s full Tajikistan Rural Electrification Project, which includes the Sebzor hydropower plant, both transmission lines, all substations, and the off-grid and last-mile connections in GBAO and Khatlon.
Figure 9. Consultations along 63km transmission line
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Date Name of Unit Position Full name
23 Fevruary Tajik Technical University, department «Communication networks and switching systems»
Senior lecturer Bahdavlatov Asratbek
24 February NGO «Civil society and environment»
Director Alidodov T.
25 February NGO Peshsaf Director Ruslan Shukurov
25 February Office of Youth Ecological Center Director Yuri Skochilov
25 February Tajik Technical University Senior lecturer Ganiev Zokirjon
25 February Ministry of Health and social protection
Head of the Department of Management and Food Safety, State Sanitary-Epidemiological Service Management and the Ministry of Health and Social Protection
Kandakov Ahliddin
25 February Committee on environment protection under the Government of Tajikistan
Head of international affairs sector
Salimov Muzaffar
26 February Ministry of Energy and water resources
Head of Investment Department
Manuchehr Safarzoda
26 February Barqi Tojik Chief Engineer Rahmatov Bakhtiyor
26 February Ministry of Energy and Water Resources
Head of Department for Analysis and Monitoring of the Electric Power Industry Directorate, Ministry of Energy and Industry of Tajikistan
Tilloev Vays
Table 7: Scoping meetings with stakeholders in Khorog
Date Name of Unit Position Name
25 February Government The Governor
Yodgor Fayzov
Committee of Environmental protection
Head of committee Mulkamon Nazaraliev
Inspection Department of Environment Protection Control
Head of department
Aynulloev Shirin
26 February University of Central Asia – Environmental Department
Professor Research fellow
Royce Slydly Shodigul Mamadyorbekova
Forest Protection Department Engineer Kambarov Hokim
Forestry officer Kosumbekov Khushvaqt
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Date Name of Unit Position Name
Association of Entrepreneurs and Mountain Farmers «Milal-Inter»/Aarhus Center
Chairman\Director Boymamad Alibakhshov
27 February CAMP ‘Tabiat’, Forest Protection Department
Field coordinator Haqrizo Nurmamadov
Specialist Abdulmajidov Abdulaziz
28 February Pamir Biological Institute Former Director Dovutsho Navruzshoev
Ornithologist A.G. Abdulnazarov
6. Stakeholder Identification and Analysis
6.1 Project-affected persons
6.1.1 People affected by land acquisition
Perhaps the key category of people who may be affected by the project would be those who may lose
land they current use or other assets, including houses, buildings, trees, or other valuable property. In
addition, some people may lose access to common resources due to the project’s use of the land.
The hydropower project will require a total of about five hectares, including about 2.1 hectares for
the weir and associated structures (intake, desilting chamber, etc.), 0.6 hectares for the penstock, 0.5
hectares for the road expansion/rehabilitation, 0.3 hectares for the powerhouse area, 0.9 hectares for
the Pamir Energy crushing plant, and 0.5 hectares for the camp/storage area. In addition, the
substation will require about 0.6 hectares. A total of seven households will need to be relocated, as
they currently live on land that is needed for the dam, penstock, and powerhouse. In addition, the
project will directly affect 0.7 hectares of orchards and 0,4 hectares of other trees that may require
cutting (depending on tree height and conductor clearance). Pamir Energy has been allocated 32
hectares, and excess land will be returned for reallocation to its original users. It is expected that seven
households are on land required for the Sebzor HPP and so will be required to move to other land. As
specified in the Resettlement Policy Framework, these households will be provided equivalent land
and Pamir Energy will either build equivalent houses or compensate the households, with the aim of
having at least the same standard of living as before.
Less than seven hectares will be needed for permanent use by the 18km Sebzor-to-Khorog
transmission line, including about 0.4 hectares for permanent use (73 towers x 56.25m2 per tower)
and six hectares for the substation in Khorog. In addition, very small amounts of land will be used
temporarily by workers who travel by foot from the road to the tower locations and the contractor
will need small areas (up to about 0.5 hectares in total) for storage and temporary use during
construction.
The 63km transmission line between Khorog and Qozideh will require less than two hectares of land
for permanent use, including up to about 1.4 hectares for the transmission line towers (250 towers x
56.5m2 per tower) and less than 0.4 hectares for the substation in Qozideh (60 meters x 60 meters).
There will be similar restrictions on 292.95 hectares (63km x 46.5m) along the corridor. Again, paths
to towers will be used by workers and small areas will be needed by the contractors for storage and
preparation.
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Tajikistan norms allow no buildings within 20 meters of an energized 110kV line, so a corridor 45
meters wide is designated as a protection zone – 20 meters from the conductor on each side and five
meters between the conductors. No one will be allowed to remain in a house within the safety zone.
As noted, there will be restrictions on the corridor, but they are expected to have little effect in
practice. The restrictions will affect a total of 83.7 hectares along the 18km corridor and 292.95
hectares along the 63km corridor. These restrictions will prevent future buildings from being built and
tall equipment from being used in the corridor. In practice, agriculture and grazing can continue within
the corridor with no interruption.
When towers are on agricultural or other productive land, Pamir Energy will compensate the people
who are currently using the small plots of land that will be taken for towers. If trees grown for timber,
firewood, or fruit/nuts need to be cut to avoid interference with the energized conductors, their
owners will be compensated sufficiently to pay for replacement trees and for lost production. All land
acquisition and compensation will meet the requirements of Tajikistan law and the World Bank. The
resettlement and compensation program is described in detail in the Resettlement Policy Framework.
People owning or using land in the corridor will thus be a high-priority stakeholder group who will
require active and regular engagement as well as being provided accurate information, in particular
about compensation and livelihood restoration schemes and employment opportunities.
6.1.1. Other people residing in the project areas
A second key category of PAPs will be people who live along the transmission line route who may be
disturbed by project traffic, noise, dust, or other construction impacts, and who may also benefit from
employment opportunities. As noted in the respective ESIAs, contractors will be required to control
dust, noise, and nuisances and also to require workers to adhere to a Code of Conduct to avoid
disruption of communities.
6.1.2. Village representatives (Jamoats)
A third category of important PAPs will be representatives of Jamoats. Head of Jamoats typically have
established day-to-day communication lines with all neighboring villages and smaller communities so
it will be important that they have information about the project, including employment status and
upcoming activities.
6.2. Other interested parties
6.2.1. Other interested parties - external
Table 8 summarizes the key categories of other interested parties and their potential interest in the
project.
6.2.2. Other interested parties – Internal
Internal interested parties with stakes in the project include the management and staff of Pamir
Energy, their future contractors and subcontractors, service providers, local vendors, and suppliers.
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
Table 8: Other interested parties - external
Other interested parties Interest in the project
Ministries and Government agencies (State level) ‒ Committee on environment
protection under the Government of Tajikistan
‒ Ministry of Energy and water resources
Overall: To ensure project compliance with Tajik legislation (e.g. energy policies, environmental performance) during construction and operation ‒ Responsible for protected areas and proposed protected
areas that are or may be created in the vicinity of the project ‒ Promote Tajik energy security and development ‒ Possible involvement in some project-related mitigation
measures
Local (region and district scale) government departments and villages (Jamoats)
‒ Protect the rights of inhabitants in the project area ‒ Represent local communities and PAPs ‒ Receive and address any feedback and grievances from them ‒ Responsible for land allotments and compensation under
Tajik law
Nongovernmental organizations (local, regional, national, international)
Monitor project performance in areas of their respective concerns Consult with Pamir Energy and governments as needed
Business and workers’ organizations Interest in procurement and supply chain, potential environmental and social impacts as well as community health and safety
Other project developers reliant on or in the vicinity of the project (e.g. associated facilities) and their financiers (e.g. ADB, EBRD, KfW, IFC)
May require operation of the project to enable the export of power Can help Identify interactions and cumulative impacts with other proposed developments
Press and media Inform people and authorities in the project area and the wider public about project implementation and planned activities
General public, tourists, jobseekers Interest in the general socioeconomic impacts of the project, both adverse and beneficial
Academic institutions (universities, think tanks, schools)
‒ Potential concerns regarding environmental and social impacts
‒ Potential educational/outreach opportunities to increase awareness and acceptance of the project
6.3. Disadvantaged / Vulnerable individuals or groups
Disadvantaged or vulnerable individuals or groups are those who may potentially be disproportionally
affected by the project and/or less able to benefit from opportunities offered by the project due to
specific difficulties to access and/or understand information about the project. For purposes of this
project, the following people and households are considered vulnerable:
• Households headed by women, including those whose husbands or partners are working
abroad and do not make significant contributions to the household’s income or welfare
• Elderly households (headed by pensioners or elderly people)
• Households with disabled persons
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Stakeholder Engagement Plan Sebzor Hydropower Plant
110kV transmission lines from Sebzor HPP to Khorog and from Khorog to Qozideh Associated substations
• Households in extreme poverty. There is no threshold for poverty in Tajikistan, so this will
be determined on a case-by-case basis during studies conducted as part of the
Resettlement program.
As described in the Resettlement Policy Framework, vulnerable people and households will be eligible
for special allowances and compensation.
6.4. Summary of stakeholder interest in and influence over the project
Table 9 summarizes the level of interest in and potential influence over the project of the various
stakeholder categories identified above. Categories having “high level of interest” and “high ability to
influence/impact the project” will require regular and frequent engagement, typically face-to-face and
written, and at least several times per year. Categories with medium interest or medium influence will
require regular engagement (e.g., twice a year), typically through written information. Other will
require infrequent engagement (e.g., once a year), typically through indirect written information (e.g.
mass media)
Table 9: Level of interest and influence over the project
Level of interest in project
Ability or likelihood to influence or impact the project
High Medium Low
High ‒ State Ministries, Committees and Government Agencies
‒ Project-affected persons
‒ Regional government (Khoukumat in Khorog)
‒ Regional Government (Committees)
‒ Jamoats and villages ‒ Other people residing
in project areas
Medium ‒ NGOs ‒ Press and media
Businesses and workers’ organizations
‒ Academic institutions ‒ General public,
tourists, jobseekers
Low Other project developers and donors
7. Stakeholder Engagement Program
7.1 Engagement methods and tools
Various methods of engagement will be used as part of the projects’ interactions with stakeholders in
order to ensure that different stakeholder groups are successfully reached and are involved in the
process of consultation, decision-making and the development of impact management solutions.
International standards increasingly emphasize the importance of a consultation being “free, prior and
informed”, which implies an accessible and unconstrained process that is accompanied by the timely
provision of relevant and understandable information. In order to fulfil this requirement, a range of
consultation methods are applied that specifically focus on this approach.
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Information that is communicated in advance of public consultations primarily includes an
announcement thereof in the public media – local, regional and national, as well as the distribution of
invitations and full details of the forthcoming meeting well in advance, including the agenda. It is
crucial that this information is widely available, readily accessible, clearly outlined, and reaches all
areas and segments of the target community.
Descriptions of the generic engagement methods and techniques that may be engaged and applied
by Pamir Energy is provided in Table 10 below. The summary presents a variety of approaches to
facilitate the processes of information provision, information feedback as well as participation and
consultation.
7.1.1 Public/community meetings
Prior to other activities, at the time of disclosure of the Environmental and Social Impact Assessments
(ESIAs), Resettlement Policy Framework, and this SEP, Pamir Energy will organize public meetings in
Khorog and in each of the Jamoats. With the support of Jamoat leaders, another meeting will be held
in each village and Khorog at the beginning of construction activities that will affect the village, and
then quarterly during construction seasons (approximately twice per year). Meetings will be open
house events where Pamir Energy (and/or contractors) will present information and people will be
invited to make comments and express any concerns. If there is sufficient interest, separate meetings
will be held for women, at which women will also be the primary representatives of Pamir Energy.
Following the disclosure meeting, comments will be considered in the development of final ESIA,
ESMF, RPF, and SEP. After the other meetings, Pamir Energy will follow up with Jamoat leaders and
with stakeholders who expressed concerns about any environmental or social aspect of the projects.
7.1.2 Mass/social media communication
Pamir Energy will appoint a community liaison officer (CLO) during each construction season (about
six or seven months per year) in order to remain in close communication with PAPs, village leaders,
and with
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Table 10: Generic Methods, Tools and Techniques for Stakeholder Engagement
Method / Tool Description and Use Contents Dissemination Method Target Groups
Information Provision
Distribution of printed public materials: leaflets, brochures, fact sheets
Used to convey information on the projects and regular updates on progress to local, regional and national stakeholders
- - Printed materials present illustrated and narrative information on activities, facilities, technologies and design solutions, as well as impact mitigation measures
- Contents to be concise and adapted to a layperson reader
- Graphics and pictures widely used to describe technical aspects
- Information may be presented in Russian and/or Tajik for local and national stakeholders, and in English for international stakeholders
- Material would reference GRM
- Distribution as part of consultation meetings, public hearings, discussions and meetings with stakeholders, as well as household visits in remote areas
- Placement at the offices of local administrations and NGOs, libraries and other public venues
- Households in Area of Influence of each subproject
- Residents of Roshtqala, Ishkashim, Shugnon districts, as well as wider stakeholders in Tajikistan
- External stakeholders
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Method / Tool Description and Use Contents Dissemination Method Target Groups
Distribution of printed public materials: newsletters/ updates
A newsletter or an update circular sent out to Project stakeholders on a regular basis to maintain awareness of the Project development
- - Important highlights of achievements, announcements of planned activities, changes, and overall progress
- Material would reference GRM
- Circulation of newsletter/update sheet with a specified frequency in Areas of Influence, as well as to any other stakeholders that expressed their interest in receiving these periodicals
- Possible means of distribution: post, emailing, electronic subscription, delivery in person
- Households in Project Area of Influence
- Public venues in Project Area of Influence – local administrations, libraries
Printed advertisements in the media
Inserts, announcements, press releases, short articles or feature stories in the printed media – newspapers and magazines
- - Notification of forthcoming major events or commencement of specific Project activities
- General description of the Project and its benefits to the community
Placement of paid information in local, regional and national printed media, including those intended for general reader and specialised audience
Residents in project area
Radio or television entries
Short radio programmes, video materials or documentary broadcast on TV
- - Description of the Project, Project development updates, solutions for impact mitigation
- Advance announcement of the forthcoming public events or commencement of specific Project activities
Collaboration with media producers that operate in the region and can reach local audiences
Residents in project area
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Method / Tool Description and Use Contents Dissemination Method Target Groups
Visual presentations
Visually convey Project information to affected communities and other interested audiences
- - Description of the Project and related solutions/impact management measures
- Updates on Project development
Presentations are widely used as part of the public hearings and other consultation events with various stakeholders
Same as other presentations
Notice boards Displays of printed information on notice boards in public places
Advance announcements of the forthcoming public events, commencement of specific Project activities, or changes to the scheduled process
Printed announcements and notifications are placed in visible and easily accessible places frequented by the local public, including libraries, village cultural centres, post offices, shop, local administrations
Directly affected communities in the project area
Information Feedback
Information repositories accompanied by a feedback mechanism
Placement of Project-related information and printed materials in dedicated/designated locations that also provide visitors and readers with an opportunity to leave their comments in a feedback register
Various Project-related materials: ESIAs, SEP, RPF
Deposition of materials in publicly available places (offices of local NGOs, local administrations, libraries) for the duration of a disclosure period or permanently Audience are also given free access to a register of comments and suggestions
Directly affected communities in the project area
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Method / Tool Description and Use Contents Dissemination Method Target Groups
Dedicated telephone line (hotline)
- Setting up a dedicated telephone line that can be used by the public to request information, make enquiries, or provide feedback on the Project
- Initially, telephone numbers of Project’s Community Liaison Officer(s) can be shared with the public
As raised by callers - Telephone numbers are specified on printed materials distributed to Project stakeholders and are mentioned during public meetings
- Project’s designated staff should be assigned to answer and respond to the calls, and to direct callers to specialist experts or to offer a call-back if a question requires detailed consideration
- Local communities within the Project Area of Influence
- Any other stakeholders and interested parties
Internet/Digital Media
- Launch of Project website with information and updates on the overall Project, impact assessment and impact management process, procurement, employment opportunities, as well as on Project’s engagement activities with the public
- - Information about Pamir Energy
- ESIA/SEP, RPF - Project updates
- A link to the Project web-site should be specified on printed materials distributed to stakeholders
- Other on-line based platforms can also be used, such as web-conferencing, webinar presentations, web-based meetings, Internet surveys/polls etc
- Affected communities, Project stakeholders and other interested parties that have access to the internet resources
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Method / Tool Description and Use Contents Dissemination Method Target Groups
- Web-site should have a built-in feature that allows viewers to leave comments or ask questions about the Project
- Website should be available in two languages – Russian for the local and national audience, and in English for international stakeholders
- Limitation: Not all parties/stakeholders have access to the internet, especially in the remote areas and in communities
- -
Surveys, Interviews and Questionnaires
The use of public opinion surveys, interviews and questionnaires to obtain stakeholder views and to complement the statutory process of public hearings
- - Description of the proposed Project and related solutions/impact management measures
- Questions targeting stakeholder perception of the Project, impacts and benefits, concerns and suggestions
- Soliciting participation in surveys/interviews with specific stakeholder groups or community-wide
- Administering questionnaires as part of the household visits
- Directly affected households in the Project Area of Influence
- Other communities within the Project Area of Influence
Feedback & suggestion box
- Can be used to encourage residents in the affected communities to leave written feedback and comments about the Project
Any questions, queries or concerns, especially for stakeholders that may have a difficulty expressing their views and issues during public meetings
- Box placed in safe public place that is readily accessible for the community
- Directly affected households in the Project Area of Influence
- Other communities within the Project Area of Influence
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Method / Tool Description and Use Contents Dissemination Method Target Groups
- Contents should be checked by designated Project staff on a regular basis to ensure timely collection of input and response/action
- Information about the availability of the suggestion box should be communicated as part of Project’s regular interaction with local stakeholders
Consultation & Participation
Public hearings - Meetings in public places for project representatives, affected public, authorities, and other stakeholders for presentation of information on project and discussion
- Subject to statutory expert review
- May be organized by authorities or Pamir Energy
Detailed information on the activity and/or facility in question, with focus on impacts and mitigations, including a presentation and an interactive Questions & Answers session with attendees
- Wide and prior announcement of the public hearing and the relevant details, including notifications in mass media
- Targeted invitations sent out to identified stakeholders
- Public disclosure of Project materials and associated impact assessment documentation in advance
- Directly affected communities in the Project Area of Influence
- Other communities within the Project Area of Influence
- Residents in the Project Area of Influence
- Other identified stakeholders
Household visits
Household-level visits can be conducted to supplement the statutory process of public hearings, particularly to solicit feedback from affected people and vulnerable persons who may be
- - Description of the Project and related solutions/impact management measures
- Visits should be conducted by designated staff with specified periodicity
Directly affected people
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Method / Tool Description and Use Contents Dissemination Method Target Groups
unable to attend the formal hearings
- Any questions, queries or concerns, especially for stakeholders that may have a difficulty expressing their views and issues during formal community-wide meetings
Focus Group Discussions and Round Table Workshops
Used to facilitate discussion on Project’s specific issues that merit collective examination with various groups of stakeholders
Project’s specific activities and plans, design solutions and impact mitigation/management measures that require detailed discussion with affected stakeholders
- Announcements of the forthcoming meetings circulated to participants in advance
- Targeted invitations sent out
To be determined Could include groups such as resettled households, those who lose land, prospective employees, vulnerable groups (elderly, women, etc.)
Information centers and field offices
Project’s designated venue for depositing Project-related information that also offers open hours to the community and other members of the public, with Project staff available to respond to queries or provide clarifications
- - Project-related materials, including updates of project status
- Any issues that are of interest or concern to the local communities and other stakeholders
Information about the information center/field office with open hours for the public, together with contact details, is provided on the Project’s printed materials distributed to stakeholders, as well as during public meetings and household visits
Directly affected communities and any other stakeholders and interested parties
Site Tours - Visits to project sites and facilities organised for local communities, authorities, and the media to demonstrate Project solutions
Demonstration of specific examples of Project’s design solutions and approaches to managing impacts
- Targeted invitations distributed to selected audience offering an opportunity to participate in a visit to the Project Site
- Local communities - Elected officials - Media groups - NGOs and other initiative
groups
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Method / Tool Description and Use Contents Dissemination Method Target Groups
- Visitors are accompanied by the Project’s staff and specialists to cover various aspects and to address questions arising from the public during the tour
- Could be in conjunction with meeting
- Limitation: possible safety restrictions on the site access during active construction works
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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7.2 Planned stakeholder engagement activities
Stakeholder engagement activities will need to provide specific stakeholder groups with relevant
information and opportunities to voice their views on topics that matter to them. Table 11 shows the
stakeholder engagement activities Pamir Energy currently plans to undertake for the project. The activity
types and their frequency are adapted to the three main project stages: project preparation (including
design, procurement of contractors and supplies), construction, and operation and maintenance.
Methods to be used to engage stakeholders are described in section 7.1.
7.2.1 Communication materials
Written information will be disclosed to the public in a number of ways. Initially, the draft ESIAs, RPF, and
SEP will be disclosed in English and Russian. In addition, Pamir Energy will prepare brochures on a number
of topics, including the project as a whole, on the land acquisition and compensation process, and on the
grievance mechanism. These brochures will be available at meetings and will also be posted on bulletin
boards in Jamoat offices and on information boards. Pamir Energy will also update its website regularly
(at least on a quarterly basis) with key project updates and reports on the project’s environmental and
social performance. The website will also provide information about the grievance mechanism.
7.1.1. Information Desks
When construction is about to be undertaken in any of the Jamoats, and while construction is ongoing
there, an information desk will be set up to provide local residents and affected people with information
on stakeholder engagement activities, construction updates, contact details of the Pamir Energy
Community Liaison Officer, and grievance management. Pamir Energy will set up these information
centers, which may be staffed during certain periods, possibly by contractors. They will be set up in village
centers or other easily accessible places where people can receive and share information about the
project. The brochures mentioned above will be available at these information desks.
7.1.2. Grievance redress mechanism
In compliance with the World Bank’s ESS10, a project-specific mechanism is being set up to handle
complaints and issues, and this will be in addition to the normal Jamoat-and village-level processes that
are available to citizens. Dedicated communication materials (specifically, a GRM brochure or pamphlet)
will be developed to help local residents become familiar with the grievance redress channels and
procedures. Locked suggestion/complaint boxes will be posted in each village and at contractor offices
and camps, and Pamir Energy will maintain a grievance register in order to capture and track grievances
from submission to resolution and communication with complainants. Pamir Energy’s website will include
clear information on how feedback, questions, comments, concerns and grievances can be submitted by
any stakeholder. It will also provide information on the way grievances will be handled, both in terms of
process and deadlines.
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Table 11: Planned stakeholder engagement activities by project phase
Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities
STA
GE
1:
PR
OJE
CT
PR
EPA
RA
TIO
N (P
RO
JEC
T D
ESIG
N, S
CO
PIN
G, R
ESET
TLEM
ENT
PLA
NN
ING
, ES
MF/
RP
F/SE
P D
ISC
LOSU
RE)
Project Affected Parties:
‒ People potentially affected by land acquisition
‒ People residing in project area
‒ Vulnerable households
‒ ESIA, ESMF, RPF, SEP, RAP disclosure
‒ Land acquisition process ‒ Assistance in gathering
official documents for authorized land uses
‒ Compensation rates and methodology
‒ Project scope and rationale
‒ Project E&S principles ‒ Resettlement and
livelihood restoration options
‒ Grievance mechanism process
‒ Public meetings, separate meetings for women and vulnerable
‒ Face-to-face meetings ‒ Mass/social media communication
(as needed) ‒ Disclosure of written information:
brochures, posters, flyers, website Information boards or desks - In Jamoats
‒ Grievance mechanism
‒ In Jamoats for disclosure of ESIA, ESMF, RPF, SEP
‒ In Jamoats at beginning of construction that would affect the area
‒ Survey of PAPs in affected villages
‒ Communication through mass/social media
‒ Throughout RAP development as needed
‒ Pamir Energy HSE team
‒ CLO ‒ Specialists
responsible for land acquisition
‒ RAP consultant
Other Interested Parties (External)
‒ Khukumat (Khorog) ‒ Jamoats ‒ Representatives in villages
‒ ESIA, ESMF, RPF, SEP, RAP disclosure
‒ Land acquisition process ‒ Identification of land plots
and uses ‒ Resettlement and
livelihood restoration options (if needed)
‒ Project scope, rationale and E&S principles
‒ Grievance mechanism process
‒ Face-to-face meetings ‒ Joint public/community meetings
with PAPs
‒ Throughout RAP development as needed
‒ Project launch meetings in Jamoats
‒ Quarterly meetings in affected villages and Jamoats
‒ Disclosure meetings in Jamoats and Khorog
‒ Pamir Energy E&S Team & management
‒ CLO ‒ Specialists
responsible for land acquisition
‒ RAP consultant
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities
Other Interested Parties (External)
‒ Press and media ‒ NGOs ‒ Businesses and business
organizations ‒ Workers' organizations ‒ Academic institutions ‒ National Government
Ministries ‒ Local Government
Departments ‒ General public, tourists,
jobseekers
‒ ESIA, ESMF, RPF, SEP, RAP disclosure
‒ Grievance mechanism ‒ Project scope, rationale
and E&S principles
‒ Public meetings, trainings/workshops (separate meetings specifically for women and vulnerable as needed)
‒ Mass/social media communication ‒ Disclosure of written information:
Brochures, posters, flyers, website ‒ Information boards or desks in
Jamoats ‒ Grievance mechanism ‒ Notice board for employment
recruitment
‒ Project launch meetings in Jamoats
‒ Meetings in affected villages and Jamoats as needed
‒ Communication through mass/social media (as needed)
‒ Information desks with brochures/posters in affected villages (continuous)
‒ Pamir Energy HSE team
‒ CLO
Other Interested Parties (External)
‒ Other Government Departments from which permissions/clearances are required
‒ Other project developers, donors
‒ Project information scope and rationale and E&S principles
‒ Coordination activities ‒ Land acquisition process ‒ Grievance mechanism
process ‒ ESIA, ESMF/RPF/SEP
disclosure
‒ Face-to-face meetings ‒ Invitations to public/community
meetings
‒ Disclosure meetings ‒ Pamir Energy HSE team
‒ CLO
Other Interested Parties (Internal) ‒ Other Pamir Energy staff ‒ Supervision Consultants ‒ Contractor, sub-
contractors, service providers, suppliers, and their workers
‒ Project information - scope and rationale and E&S principles
‒ Training ESIA/ESMF/ESMP requirements and other sub-management plans
‒ Grievance mechanism process
‒ E&S requirements
‒ Face-to-face meetings ‒ Trainings/workshops ‒ Invitations to public/community
meetings
As needed ‒ Pamir Energy HSE team
‒ CLO
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities
STA
GE
2: C
on
stru
ctio
n a
nd
mo
bili
zati
on
act
ivit
ies
Project Affected Parties: ‒ People potentially affected
by land acquisition ‒ People residing in project
area ‒ Vulnerable households
‒ Grievance mechanism ‒ Health and safety impacts
(EMF, community H&S, community concerns)
‒ Employment opportunities ‒ Project status
‒ Public meetings, open houses, trainings/workshops,
‒ Separate meetings as needed for women and vulnerable
‒ Individual outreach to PAPs as needed
‒ Disclosure of written information: brochures, posters, flyers, website Information boards or desks - In Jamoats
‒ Notice board(s) ‒ Grievance mechanism
‒ Quarterly meetings in affected villages during construction season
‒ Communication through mass/social media as needed
‒ Notice boards updated weekly
‒ Brochures in local offices
‒ Pamir Energy HSE team
‒ CLO ‒ Supervision and
RAP consultants ‒ Contractor/sub-
contractors ‒ NGOs/trainers
Other Interested Parties (External)
‒ Governmental committees for land use and compensation
‒ Jamoats and representatives in villages
‒ Project scope, rationale and E&S principles
‒ Grievance mechanism ‒ Project status
‒ Face-to-face meetings ‒ Joint public/community meetings
with PAPs
‒ As needed (monthly during construction season)
‒ Pamir Energy HSE team
‒ CLO ‒ Supervision and
RAP consultants ‒ Contractor/sub-
contractors
Other Interested Parties (External)
‒ Press and media ‒ NGOs ‒ Businesses and business
organizations ‒ Workers' organizations ‒ Academic institutions ‒ National Government
Ministries ‒ Local Government
Departments ‒ General public, tourists,
jobseekers
‒ Project information - scope and rationale and E&S principles
‒ Project status ‒ Health and safety impacts ‒ Employment opportunities ‒ Environmental concerns ‒ Grievance mechanism
process
‒ Same as for PAPs ‒ Same as for PAPs ‒ Pamir Energy HSE team
‒ CLO
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities
Other Interested Parties (Internal)
‒ Other PEC Staff ‒ Supervision Consultants ‒ Contractor, sub-
contractors, service providers, suppliers and their workers
‒ Project information: scope and rationale and E&S principles
‒ Training on ESIA/ESMF/ESMP requirements and other sub-management plans
‒ Worker grievance mechanism
‒ Face-to-face meetings ‒ Trainings/workshops ‒ Invitations to public/community
meetings
Daily, as needed ‒ Pamir Energy HSE team
‒ Supervisors
STA
GE
3:
Op
era
tio
n a
nd
ma
inte
na
nce
Project Affected Parties ‒ People residing in project
area ‒ Vulnerable households
‒ Satisfaction with engagement activities and GRM
‒ Grievance mechanism process
‒ Electromagnetic fields ‒ Damage claim process
‒ Outreach to individual PAPs ‒ Pamir Energy website
Meetings in affected Jamoats and villages (as needed/requested)
Pamir Energy HSE team
Other Interested Parties (External)
‒ Press and media ‒ NGOs ‒ Businesses and business
organizations ‒ Workers' organizations ‒ Academic institutions ‒ Local Government
Departments (Khuokumat, Jamoats)
‒ General public, tourists
‒ Grievance mechanism process
‒ Issues of concern
‒ Grievance mechanism ‒ Pamir Energy website ‒ Face-to-face meetings
As needed Pamir Energy HSE team & management
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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The initial effort to resolve grievances to the complainant’s satisfaction will be undertaken by Pamir
Energy. If that is not successful in resolving grievances, they will be referred to a committee at the Jamoat
level.
The mechanism is described in detail in Chapter 8 below, which includes a form that can be used to submit
grievances. Grievances may be submitted anonymously, but in that case it cannot be known if the
complainant is satisfied with the resolution.
7.1.3. Project tours
At appropriate points during the construction phase, if there is sufficient interest, Pamir Energy may
organize site visits or demonstration tours for selected stakeholders from media organizations or local
governments.
7.1.4. Citizen/PAP perception survey
A perception survey examining citizen’s experience and feedback about the project will be carried out
twice during the project’s lifecycle: once near the end of the first construction season and once during the
second season. Results of these surveys will be reviewed carefully to identify refinements or changes in
project methods and procedures that may be needed to reduce impacts or improve efficiency.
7.1.5. Trainings and workshops
Finally, trainings on a variety of social and environmental issues will be provided to Pamir Energy and
contractor staff and possibly to interested government or nongovernment service providers. Issues
covered could include such topics as the worker code of conduct and the worker grievance mechanism.
Pamir Energy may also provide training to residents on various topics, including efficient use of electricity,
electrical safety, and other relevant topics.
7.1.6. Vulnerable groups
Pamir Energy will take special measures to ensure that disadvantaged and vulnerable groups have equal
opportunity to access information, provide feedback, or submit grievances. The deployment of the
Community Liaison Officer will help to ensure proactive outreach to all population groups, and they will
make a special effort to engage with those identified as vulnerable or disadvantaged. If necessary, Pamir
Energy will provide transport to public meetings for vulnerable people, and will also deliver brochures and
informational material to such households.
7.2. Disclosure of information and public consultations
Consultations with affected people and stakeholder engagement will be carried out throughout project implementation. The Pamir Energy website (http://www.pamirenergy.com/en/presscenter/public.php) will be used to disclose project documents, including those on environmental and social performance. In addition, meetings and other key events will be announced in the regional/state newspaper (“Asia Plus”)
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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and the local newspaper “Badakhshon” and described in Pamir Energy “newspapers” that customers receive. This began with disclosure of draft documents in April 2019. Disclosures included:
• A draft of this combined Draft Stakeholder Engagement Plan for the Sebzor HPP, 18-kilometer
110-kV Sebzor-Khorog transmission line, and 63-kilomter Khorog-Qozideh transmission line
• Draft Resettlement Policy Framework for the Tajikistan Rural Electrification Project.
• Draft ESIAs for the Sebzor HPP, Sebzor-Khorog transmission line, and Khorog-Qozideh
transmission line..
Besides the draft disclosure documents (which are now followed by final documents), a project brochure
with details of the planned project consultations was posted. An easy-to-understand guide to the
terminology used in the environmental and social reports or documents will also be posted on the
website. In addition, the site will provide details about the Grievance Redress Mechanism and contact
details of the Community Liaison Officer. Pamir Energy will update and maintain the website regularly, at
least quarterly.
Paper copies of all ESIA documentation have been placed in Jamoats and advertisements placed on the
notice boards in the villages. Electronic copies are available at the website above. Addresses where the
ESIA documents may be reviewed include the following:
• Pamir Energy Company, 75 Gulmamadova Street, 736000 Khorog, GBAO, Tajikistan
• Administration (Khoukumat) of GBAO in Khorog, address: city Khorog, Lenin street 47,
Tajikistan
• Administration (Khoukumat) of Roshtqala district in Roshtqala, at address: Khorog,
Committee for Environmental Protection (CEP), Lenin street, 46, Tajikistan
Following disclosure of the ESIA and other documents, Pamir Energy announced and held three
consultation meetings:
Table 12. Public consultations on Sebzor HPP and associated transmission lines
Subproject Meeting
date (2019) Meeting location
Number of attendees
Sebzor HPP & 18-km t-line
26 April Sebzor (Roshtqala District) 46
Khorog-Qozideh transmission line
29 April Andarob Village (Ishkashim Village) 48
30 April Qozideh (Ishkashim District)
Consultation meeting in Sebzor on Sebzor HPP and 18km transmission line
At the meeting (Error! Reference source not found.), Pamir Energy asked people to sign in and handed
out brochures that described the project and announced the meeting. The chairman of Roshtqala District,
Mr. Safarov Davlat, opened the meeting by welcoming the representatives of Pamir Energy and saying
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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how pleased he and the community were that the company had launched the rural electrification project.
A total of 46 people from four villages attended the meeting and were actively engaged in the discussion..
Pamir Energy described the projects and the analyses that had been completed, and explained that there
would be international financing, and as a result the project would have to meet international standards
as well as those required by Tajikistan. Pamir Energy also noted that the line will be designed so that no
one will need to relocate and arable land will be avoided unless it cannot be avoided. Attendees were
then invited to make comments and ask questions.
Most discussion was related to employment, with questions about how and staff will be selected and the
very strong desire to work on the project. It was explained that contractors would announce job openings
and select workers based on qualifications and technical knowledge. It was emphasized that that many or
most people hired by the contractors, and by Pamir Energy, would come from local villages. Another
concern was about what would happen to houses and gardens that are demolished. Pamir Energy
responded by referring to the requirements of the Resettlement Policy Framework and noted that a
detailed Resettlement Action Plan would be developed in the future, before construction begins. In
general, there was unanimous support for the project, with comments and questions about what the
communities could do to assist project implementation and questions about how soon the project would
begin. More detailed minutes and the list of participants are in Annex 2.
Consultation meetings in Andorob and Qozideh on 63km Sebzor and transmission lines
At the meetings (Figure 12 and Figure 12, Pamir Energy asked people to sign in and handed out brochures
that described the project and announced the meeting. A total of 48 people from four villages attended
the meetings and, as in Sebzor, attendees actively participated in the discussion..
Pamir Energy described the project and the analyses that had been completed, and explained that there
would be international financing, and as a result the project would have to meet international standards
as well as those required by Tajikistan. Attendees were then invited to make comments and ask questions.
The discussion began with Mr.Khasanov Mehrobsho, the Leader of the Jamaat, expressing his gratitude
to the representative of Pamir Energy for the meeting with the local community and mentioned that the
community is glad that PE started implementing the project and expressed his as well as community’s
willingness to assist in the timely implementation of the project.
Questions included the implementation period of the project, with Pamir Energy responding that it would
be about 2.5 years. There were many questions about employment, and Pamier Energy noted that many
or most of the workers will be from local communities, both hired by contractors during construction and
by Pamir Energy during operation, with selections based on qualifications and technical knowledge. ..
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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Figure 10. Disclosure consultation meeting in Sebzor
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Stakeholder Engagement Plan Sebzor Hydropower Plant
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. Figure 12. Consultation meeting in Qozideh
Figure 11. Disclosure consultation meeting in Andarob
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7.3 Stakeholder Engagement during Project Implementation
Engagement will continue through the life of the project. The SEP provides details of the program that will
be used to present information to stakeholders and to receive information and opinions from
stakeholders. In summary, there will be:
• Public / community meetings
• Mass/social media communication
• Distribution of information materials
• Grievance redress mechanism
• Project tours for media, civil society, and local representatives
• Information desks at each municipality
• Citizen perceptions surveys
• Trainings and workshops to raise awareness on key topics of interest such as EMF, impacts on
land and compensations, code of conduct for project staff, grievance redress mechanism, or
other topics of interest to citizens.
7.4 Pamir Energy Point of Contact
The point of contact for stakeholder engagement mechanism is Pamir Energy’s Senior Environmental and
Social Officer, identified below. During the construction period, there will be other Community Liaison
Officers to assist. :
Description Contact details
Name Asligul Mamadatoeva
Address: 75 Gulmamadova Street
736000 Khorog, GBAO, Tajikistan
E-mail: [email protected]
Telephone: +992 35 222 23 10
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8. Grievance Redress Mechanism
Project-affected-people and any other stakeholder may submit comments or complaints at any time by
using the project’s Grievance Redress Mechanism (GRM). The overall objectives of the GRM are to:
• Provide a transparent process for timely identification and resolution of issues affecting the
project and people, including issues related to the resettlement and compensation program.
• Strengthen accountability to beneficiaries, including project affected people.
The GRM will be accessible to all external project stakeholders, including affected people, community
members, civil society, media, and other interested parties. External stakeholders can use the GRM to
submit complaints, feedback, queries, suggestions, or even compliments related to the overall
management and implementation of the project, including the resettlement and compensation program.
The GRM is intended to address issues and complaints in an efficient, timely, and cost-effective manner.
A separate mechanism will be available to Pamir Energy and contractor employees, who are internal
stakeholders.
Pamir Energy will be responsible for managing the stakeholder GRM, but many or most grievances are
likely to result from actions of the construction contractors and so will need to be resolved by the
contractors themselves, with Pamir Energy oversight. Typical grievances for transmission line projects
could include issues related to:
• Land acquisition and compensation
• Construction damages to property, crops, or animals
• Traffic
• Environmental impacts such as erosion
• Nuisances such as dust or noise
• Worker misbehavior.
The GRM will be in place and operational well before Pamir Energy begins construction activities and will
function until the completion of all construction activities and beyond, till the contractor’s defect liability
period ends. Initial compensation, for land and property needed for the project, will be completed before
construction begins. People who reside near the line and others who may be affected will be informed,
in meetings and with brochures, of the GRM’s purpose, functions, procedures, timelines and contact
persons. Additional measures will be taken to inform those who are determined to be eligible for
compensation.
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The project GRM will include three successive tiers of extra-judicial grievance review and resolution:
• The first tier will be the Pamir Energy E&S team, including the Community Liaison Officer.
They will deal quickly with issues that can be quickly resolved, and would always involve direct
communication with the person(s) who submitted the grievance.
• The second tier will be a Grievance Resolution Committee (GRC1) that includes
representatives of Pamir Energy and of the complainant’s village and Jamoat. The GRC1 will
deal with issues that could not be resolved in the first tier.
• The third tier will be a Grievance Redress Commission (GRC2) that included one or more
senior Pamir Energy managers and one or more Jamoat and/or village leaders. GRC2 will
resolve issues that could not be resolved by GRC1.
Grievances would be handled as described in the following subsection.
8.1 Grievance resolution process
Information about the GRM will be publicized as part of the initial disclosure consultations in the
participating Jamoats and villages. Brochures will be distributed during consultations and public meetings,
and posters will be displayed in public places such as in government offices, project offices, village notice
boards, community centers, etc. Information about the GRM will also be posted online on the Pamir
Energy website (http://www.pamirenergy.com/en/presscenter/public.php)
The overall process for the GRM will be comprised of six steps, as shown on Figure 13 and described
below. This builds on the way grievances are typically managed, which is illustrated in Figure 14.
• Step 1: Uptake. Project stakeholders will be able to provide feedback and report complaints
through several channels: in person at offices (village/mahalla, jamoat, project, and Pamir
Energy offices) and at project sites, and by mail, telephone, and email.
• Step 2: Sorting and processing. Complaints and feedback will be compiled by the Community
Liaison Officer and recorded in a register. Submissions related to the resettlement and
compensation program will be referred to the HSE Department for processing and resolution.
The Department will assign one individual to be responsible for dealing with each complaint,
Source: Agarwal, Sanjay and David Post. 2009. Feedback Matters:
Designing Effective Grievance Redress Mechanisms for Bank-
Financed Projects – Part I. SDV. World Bank.
Figure 13: Feedback and GRM Process
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including following through within Pamir Energy and with the complainant to arrive at a
resolution, with the goal to resolve complaints within 15 days of receipt.
• Step 3: Acknowledgement and followup. Within seven (7) days of the date a complaint is
submitted, the responsible person will communicate with the complainant and provide
information on the likely course of action and the anticipated timeframe for resolution of the
complaint. If complaints are not resolved within 15 days, the responsible person will provide
an update about the status of the complaint/question to the complainant and again provide
an estimate of how long it will take to resolve the issue. In addition, the HSE Department will
Figure 14: Typical grievance resolution process
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report to the General Director every two weeks on grievances that have remained unresolved
for 30 days or more.
• Step 4: Verification, investigation and action. This step involves gathering information about
the grievance to determine the facts surrounding the issue and verifying the complaint’s
validity, and then developing a proposed resolution, which could include changes of decisions
concerning eligibility for compensation, additional compensation or assistance, changes in the
program itself, other actions, or no actions. Depending on the nature of the complaint, the
process can include site visits, document reviews, a meeting with the complainant (if known
and willing to engage), and meetings with others (both those associated with the project and
outside) who may have knowledge or can otherwise help resolve the issue. It is expected that
many or most grievances would be resolved at this stage. All activities taken during this and
the other steps will be fully documented, and any resolution logged in the register.
• Step 5: Monitoring and evaluation. Monitoring refers to the process of tracking grievances
and assessing the progress that has been toward resolution. The HSE Department will be
responsible for consolidating, monitoring, and reporting on complaints, enquiries and other
feedback that have been received, resolved, or pending. This will be accomplished by
maintaining the grievance register and records of all steps taken to resolve grievances or
otherwise respond to feedback and questions.
• Step 6: Providing Feedback. This step involves informing those to submit complaints,
feedback, and questions about how issues were resolved, or providing answers to questions.
Whenever possible, complainants should be informed of the proposed resolution in person.
If the complainant is not satisfied with the resolution, he or she will be informed of further
options, which would include pursuing remedies through the World Bank, as described below,
or through avenues afforded by the Tajikistan legal system. On a monthly basis, the HSE
Department will report to the General Director on grievances resolved since the previous
report and on grievances that remain unresolved, with an explanation as to steps to be taken
to resolve grievances that have not been resolved within 30 days. Data on grievances and/or
original grievance logs will be made available to World Bank missions on request, and
summaries of grievances and resolutions will be included in periodic reports to the World
Bank.
Pamir Energy will be responsible for carrying grievances through all six steps. Step 4 (Verify, Investigate,
and Act) could involve interviews of the aggrieved party, workers, or other stakeholders; review of
records; consultation with authorities; and/or other fact-finding activities. If the grievance cannot be
resolved to the satisfaction of all parties, it will be referred to GRC1, who would retrace Step 4 as needed.
The steps following the initial investigation and proposed solution would proceed as follows:
• Determination of proposed resolution or referral to second tier:
- If resolution is proposed: referral to E&S manager for review and approval (including
refinements). Once approved, responsible person would communicate resolution to
complainant and refer to corporate management for implementation.
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- If referred to second tier, GRC1 would consider facts determined by initial review and
conduct such other fact-finding as needed, including interviews of complainant and
others if necessary.
• GRC1 recommends resolution or refers to GRC2:
- If resolution is proposed: referral to Pamir Energy for implementation, including
communication to complainant.
- If referred to third tier, GRC2 to meet and discuss facts as determined by initial tiers and
make determination of proposed resolution.
• GRC2-recommended resolution: referred to Pamir Energy for communication to complainant
and implementation of recommended actions (if any)
• Complainant would be asked to acknowledge acceptance (or rejection) of the resolution.
• Pamir Energy would then implement actions that are part of the resolution (if any).
If a person who submits a grievance is not satisfied with the resolution at the first or second tiers, he or
she may request it be elevated to the next tier. If they are not satisfied with the ultimate resolution, they
may pursue legal remedies in court or pursue other avenues as described above. Throughout the entire
process, Pamir Energy will maintain detailed records of all deliberations, investigations, findings, and
actions, and will maintain a summary log that tracks the overall process.
8.2 Grievance processing
Anyone who believes they are eligible for compensation can submit a grievance:
• By completing a written grievance form that will be available (a) in the Jamoat and in the
villages crossed by the line, (b) at Pamir Energy’s offices in Khorog and on their website, and
(c) from CLOs or other members of the HSE Department. An example of a grievance
registration form is provided in Annex 1.
• By contacting the Pamir Energy Community Liaison Officer or other member of the Pamir
Energy HSE Department team, either by telephone or in person. In addition, grievances may
be communicated to contractor supervisors or to Pamir Energy electrical inspectors, who will
be briefed on receiving and reporting complaints. Grievances received verbally will be
recorded by the Community Liaison Officer on a grievance registration form and logged into
the Grievance Register. A copy of the logged grievance will be given to the complainant, giving
them the opportunity to alert Pamir Energy if the grievance has not been noted down
correctly.
Pamir Energy will explain to local communities the possibilities and ways to raise a grievance during
consultation meetings organized in each village when this draft SEP and other draft documents are
disclosed and then at quarterly meetings thereafter. The GRM procedures will be disclosed through the
project’s website and will also be described in a brochure or pamphlet made available in Jamoat
administration buildings.
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The Pamir Energy Community Liaison Officer team will be responsible for logging and tracking grievances.
As noted above, one person will be assigned responsibility for investigating and recommending resolution
to each grievance, or to recommend referral to GRC1.
Information to be recorded in the grievance log will include name and contact details of the complainant
and a summary of the grievance and how and when it was submitted, acknowledged, responded to and
closed out. All grievances will be acknowledged within 7 days and resolved as quickly as possible. If there
has been no resolution within 30 days, the person assigned responsibility for the grievance will contact
the complainant to explain the reason for the delay. On at least a monthly basis, a summary of grievances
and resolutions will be provided to the Pamir Energy General Director. A generic flow chart for registering
and processing grievances is shown in Figure 9 above. The status, number, and trends of grievances will
be discussed between the project team and Pamir Energy senior management during meetings held at
least monthly and more frequently as needed.
A grievance will be considered “resolved” or “closed” when a resolution satisfactory to both parties has
been reached, and after any required corrective measures have been successfully implemented. When a
proposed solution is agreed by the complainant, the time needed to implement it will depend on the
nature of the solution. Once the solution is being implemented or is implemented to the satisfaction of
the complainant, the complaint will be closed out and acknowledged in writing by both the complainant
and Pamir Energy.
In certain situations, it may not be possible to reach a satisfactory resolution. This could occur if a
complaint cannot be substantiated or is proved to be speculative or fraudulent. In such situations, Pamir
Energy’s efforts to investigate the grievance and to arrive at a conclusion will be well documented and the
complainant advised of the situation. It is also possible that a complainant will not be satisfied with the
proposed resolution. In such cases, if Pamir Energy cannot do more, the complainant will be asked to
acknowledge refusal of the proposed resolution in writing. Pamir Energy will then decide whether to
implement the resolution without the agreement of the complainant and the complainant will decide
whether to pursue legal remedies.
8.3 Grievance Logs
As noted previously, the HSE Department will maintain a grievance log. This log will include at least the
following information:
• Individual reference number
• Name of the person submitting the complaint, question, or other feedback, address and/or
contact information (unless the complaint has been submitted anonymously)
• Details of the complaint, feedback, or question/her location and details of his / her complaint.
• Date of the complaint.
• Name of person assigned to deal with the complaint (acknowledge to the complainant,
investigate, propose resolutions, etc.)
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• Details of proposed resolution, including person(s) who will be responsible for authorizing
and implementing any corrective actions that are part of the proposed resolution
• Date when proposed resolution was communicated to the complainant (unless anonymous)
• Date when the complainant acknowledged, in writing if possible, being informed of the
proposed resolution
• Details of whether the complainant was satisfied with the resolution, and whether the
complaint can be closed out
• If necessary, details of GRC1 and GRC2 referrals, activities, and decisions
• Date when the resolution is implemented (if any).
8.4 Monitoring and reporting on grievances
Details of monitoring and reporting are described above. Day-to-day implementation of the GRM and
reporting to the World Bank will be the responsibility of the HSE Department. To ensure management
oversight of grievance handling, the Internal Audit Unit will be responsible for monitoring the overall
process, including verification that agreed resolutions are actually implemented.
8.5 Pamir Energy Point of Contact
The point of contact regarding the stakeholder engagement program:
Description Contact details
Name Asligul Mamadatoeva
Address: 75 Gulmamadova Street
736000 Khorog, GBAO, Tajikistan
E-mail: [email protected]
Telephone: +992 35 222 23 10
Information on the project and future stakeholder engagement programs will available on the project’s
website and will be posted on information boards in the villages crossed by the line. Information can also
be obtained from Pamir Energy in Khorog.
Six-monthly E&S reports that document the implementation of the Stakeholder Engagement Plan (SEP)
will be disclosed on the project website and made available in the Jamoats or at the village heads houses.
8.6 World Bank Grievance Redress System
Communities and individuals who believe that they are adversely affected by a project supported by the
World Bank may also complaints directly to the Bank through the Bank’s Grievance Redress Service (GRS)
(http://projects-beta.worldbank.org/en/projects-operations/products-and-services/grievance-redress-
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service). A complaint may be submitted in English, Russian, Tajik, or Shugne, although additional
processing time will be needed for complaints that are not in English.
A complaint can be submitted to the Bank GRS through the following channels:
• By email: [email protected]
• By fax: +1.202.614.7313
• By mail: The World Bank, Grievance Redress Service, MSN MC10-1018, 1818 H Street
Northwest, Washington, DC 20433, USA
• Through the World Bank Tajikistan Country Office in Dushanbe: 48 Ayni Street, Business
Center "Sozidanie", 3rd floor, Dushanbe, Tajikistan; Tel: +992 48 701-5810.
The complaint must clearly state the adverse impact(s) allegedly caused or likely to be caused by the Bank-
supported project. This should be supported by available documentation and correspondence to the
extent possible.. The complainant may also indicate the desired outcome of the complaint. Finally, the
complaint should identify the complainant(s) or assigned representative/s, and provide contact details.
Complaints submitted via the GRS are promptly reviewed to allow quick attention to project-related
concerns.
In addition, project-affected communities and individuals may submit complaints to the World Bank’s
independent Inspection Panel, which will then determine whether harm occurred, or could occur, as a
result of the World Bank’s non-compliance with its policies and procedures. Complaints may be submitted
to the Inspection Panel at any time after concerns have been brought directly to the World Bank’s
attention, and after Bank Management has been given an opportunity to respond. Information on how to
submit complaints to the World Bank Inspection Panel may be found at www.inspectionpanel.org.
Stakeholder Engagement Plan Sebzor Hydropower Plant
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Annex 1: Example Grievance Form
Pamir Energy Grievance Form
Grievance reference number (to be completed by Pamir Energy):
Contact details (may be submitted anonymously)
Name (s):
Address:
Telephone:
Email:
How would you prefer to be contacted (check one)
By mail/post:
☐
By phone:
☐
By email
☐
Preferred language ☐ Tajik ☐ Russian ☐ English
Provide details of your grievance. Please describe the problem, who it happened to, when and where it happened, how many times, etc. Describe in as much detail as possible.
What is your suggested resolution for the grievance, if you have one? Is there something you would like Pamir Energy or another party/person to do to solve the problem?
How have you submitted this form to the project?
Website
☐
☐
By hand
☐
In person
☐
By telephone
☐
Other (specify)
☐
Who filled out this form (If not the person named above)?
Name and contact details:
Signature
Name of Pamir Energy person assigned responsibility
Resolved or referred to GRC1? ☐ Resolved ☐ Referred If referred, date:
Resolved referred to GRC2? ☐ Resolved ☐ Referred If referred, date:
Completion
Final resolution (briefly describe)
Short description Accepted? (Y/N)
Acknowledgement signature
1st proposed solution
2nd proposed solution
3rd proposed solution
Annex 2. Minutes of Consultation Meeting on Sebzor HPP and Sebzor-Khorog Transmission Line in Sebzor (Roshtqala District, GBAO)
MINUTES OF MEETING
PROJECT NAME
Tajikistan Rural Electrification Project: Sebzory Hydropower Plant and Sebzor-Khorog
18-kilometer 110kV transmission line
VENUE
Sebzor village of Roshqala district, Viloyati Mukhtori
Kuhistoni Dadakhshon (VMKB)
DATE OF MEETING
26/04/2019
PRESENT
A. Saidmamadov– Engineer, Pamir Energy
A . Mamadatoeva – Senior Environmental officer, Pamir
Energy
G. Mamadambarova - Call Center Operator, Pamir Energy
N. Shoskandarov- GIS specialist, Pamir Energy
R. Khushqadamov - PR Specialist, Pamir Energy
R. Ustoboeva - Report Officer, Pamir Energy
The community members [the list of participants is attached]
1. Summary
For the consultative meeting (on TREP Sebzor component, particularly E&S documentation) all
village residents were invited and about 46 community members gathered and participated in
the meeting. They received information and details about the planned project implementation as
well as related environmental and social impacts that were identified in recent assessments.
Sebzor villagers very much welcome the project’s implementation. They expressed no objection
or concern related to the project and its impacts as they are generally very hopeful that it will
contribute to positive developments for their villages. Primarily, employment opportunities and
compensation (in-kind) for potential loss of land were the main point of community interest an
discussion.
2. Welcome and Introduction
An introductory speech was made by the chairman of Roshqala, Mr. Safarov Davlat, who
welcomed the representatives of Pamir Energy Company (PE) and expressed his opinion and the
opinion of the local community about how pleased they are that the company had launched rural
electrification project in VMKB.
Mr. Asad Saidmamadov, a representative of PE, presented the Tajikistan Rural Electrification
Project that was developed as part of the Government of Tajikistan and PE initiative construction
of the Sebzor HPP rural population in VMKB and Khatlon regions in cooperation with the World
Bank (WB). He mentioned that although within 16 years of operation, the company has
significantly increased energy availability for 218,000 people (96% of the population) in Eastern
Tajikistan, there are still 12,286 people, residing in 61 villages of VMKB, without electricity
Moreover Pamir Energy plans to build the Sebzor hydropower plant (HPP) with a capacity of 11
MW on the Shokhdara River near the town of Khorog in the Viloyati Mukhtori Kuhistoni
Badakhshon (VMKB) in Tajikistan. It is planned that the project will be funded by the World
Bank and other donors.
Pamir Energy has completed an Environmental Social Impact Assessment (ESIA) for the
construction project of the Sebzor HPP and transmission line to Khorog and is currently
conducting the necessary public consultations and meetings with stakeholders and the public.
This process and further project information was presented on Power Point by Ms. Asligul
Mamadatoeva, the Senior Environmental Officer of Pamir Energy
The participants were informed that the Sebzor HPP will generate more than 70 gigawatt-hours
of electricity per year which is enough to provide more than 600,000 people with electricity in
VMKB and Afghanistan. The planned 18 km transmission line (PTL) will connect the Sebzor
Hydroelectric Power Plant with a substation in Khorog and the second, planned 63 km 110 kv
transmission line connects the power system of Tajikistan with the southern part of VMKB. In
the future, the construction of an additional 110kV transmission line for the transmission of
electricity to non-electrified areas in the north of Afghanistan is being considered. As the project
involves foreign investors and donors, along with the requirements of the legislation of the
Republic of Tajikistan, for project certification (evaluation) there are separate requirements, such
as the Environmental and Social Standards (ESS 1-10) of the World Bank. For projects such as
HPPs and high-voltage transmission lines, a detailed ESIA is required.
Community members received explanation that the ESIAs assess the main environmental and
social risks associated with the project and suggests the necessary actions and measures to avoid
or minimize significant adverse changes to the environment, health and safety, as well as to
socio-economic conditions.
Moreover the ESIAs have requirements for conducting appropriate public consultations and
disclosing all information about the project and the results of the ESIAs, which is the reason for
this meeting. Pamir Energy has completed ESIAs for the project and is currently conducting the
necessary public consultations and meetings with stakeholders to disclose information and
receive feedback from stakeholders and the public.
The environmental and social assessment helps to determine the potential environmental and
social effects of the project and as Ms. Asligul Mamadatoeva noted also identifies if additional
research/assessment will be needed and conducted on individual project components or aspects.
Other relevant and required documents and summary of impacts are listed in the brochures that
has been distributed earlier. For instance, as a common practice, while implementing such
projects, a plan for resettlement and compensation is developed. An example of the socio-
economic aspects would be not only electrification, but also employment opportunities for the
local population.
Meeting participants were informed that also more detailed information on the project as well as
the developed documents on environmental and social aspects of the projects are available on
the PE website, the brochures and newspapers (developed by PE) that are distributed, as well as
on the regional newspaper – “Badakhshon” and messages sent to consumers via phones.
The link to the website is provided in the PE newspapers that were distributed during the
meeting. The dates for consultative meetings with the local communities for each targeted village
under the project are indicated in the newspaper. That is the reason why we are here today –
emphasized Ms. Mamadatoeva, to present the project’s objectives and activities as well as to
know the communities’ opinions as stakeholders and to answer their queries.
3. Questions, Answers and Comments
Mr. Rakhmonshoeva Davlatbegim expressed her gratitude to Ms. Mamadatoeva for the meeting
with the local community and mentioned that as electricity is the basic need for human beings,
and even though some of the houses will be demolished, the community is glad that PE started
implementing the project in their village and expressed her as well as the community’s
willingness to assist in the timely implementation of the project. She further queried the
implementation period of the project.
Ms. Mamadatoeva responded that the project is subject to the allocation of donor funding ,all
three projects, including the Sebzor HPP,18 km of power lines from Sebzor to Khorog and 63km
of power lines from Khorog to the village of Kozideh are Planned to be completed in 2-3 years
term (2022-2023)
The community also quarried about the staff – those who will be working during the operational
stage at the HPP?
Ms. Mamadatoeva replied that the PE staff as well as local residents, who will be selected based
on the required qualifications i.e. with relevant technical knowledge and education.
The people were also interested in employment opportunities and queried how the selection
process will be held and what are the key requirements?
Ms. Mamadatoeva responded that prior to the construction; the contractor will announce the
necessary vacancies and those interested can apply. The contractor will then shortlist the
candidates and hire/select those who fit the best according to their qualification.
One of the participants, Chakaboev Farhod, was interested what will happen to their house and
gardens which will be demolished?
Ms. Mamadatoeva responded that Pamir Energy will pay compensation to people effected by
resettlement and economic displacement. Requirements for compensation are set out in the
resettlement policy framework, which was developed by Pamir Energy. In the near future this
will be complemented by a detailed and specific resettlement action plan, which will be
developed by the company and approved by the World Bank and the Government of Tajikistan.
This information will be shared and the process closely and regularly communicated with the
stakeholders.
4. Closing Remarks
At the end of the meeting it was ensured that all brochures and regional and PE’s newspapers
were distributed to all the participants by Gulnor Mamadambarova the representative of Pamir
Energy. The pictures of the meeting and the list of participants are attached.
Signatures of PE representatives:
/s/ A. Mamadatoeva
/s/ A .Saidmamadov
/s/ G. Mamadambarova
/s/ N.Shoskandarov
/s/ R.Khushqadamov
/s/ R.Ustoboeva
Participants - Sebzor meeting, 26.4.2019
Full Name Position Location (village\,jamoat)
Safarov Davlat Deputy of District Chairman Parzudj village, M.Mirshakar
Rakhmonshoeva Davlatbegim
Village chairman Chagev village, M.Mirshakar
Pulodbekov Uvaydo Village Chairman Parzudj village, M.Mirshakar
Abdullokhonov Abdullokhon Driver Parzudj village, M.Mirshakar
Odinabekov Sukhrob Unemployed Parzudj village, M.Mirshakar
Pulodbekov Akobir Unemployed Parzudj village, ,M,Mirshakar
Odilshoev Rashid Unemployed Parzudj village, M.Mirshakar
Amadbekov Mirgarib Pensioner Parzudj village,M.Mirshakar
Noyobshoev Sham Unemployed Parzudj village,M.Mirshakar
Mavlonazarov Imumnazar Unemployed Parzudj village,M.Mirshakar
Bodurov Qiyom Unemployed Parzudj village, M.Mirshakar
Safarmamadov Shosodiq Unemployed Parzudj village, M.Mirshakar
Abdollov Niyatbek Unemployed Parzudj village, M.Mirshakar
Abdulamidov Davlatbek Unemployed Parzudj village, M.Mirshakar
Shodiev Amrikhon Unemployed Parzudj village, M.Mirshakar
Oshurbekova Zarrina Unemployed Chagev village, M.Mirshakar
Sangmamadov Dodmamad Unemployed Chagev village, M.Mirshakar
Niyatshoev Ram Unemployed Chagev village, M.Mirshakar
Rakhmonov Daler Unemployed Chagev village, M.Mirshakar
Qishqorbekov Qishqorbek Unemployed Chagev village, M.Mirshakar
Davlatali Nazaraliev Unemployed Chagev village, M.Mirshakar
Azizov Tulfor Unemployed Parzudj village, M.Mirshakar
Ismoilov Khamza Unemployed Parzudj village, M.Mirshakar
Ismoilov Maqsudsho Unemployed Parzudj village, M.Mirshakar
Azizkhonova Nodira Unemployed Parzudj village, M.Mirshakar
Zarifbekov Gulayoz Unemployed Parzudj villagte, M.Mirshakar
Shirinbekov Immat Unemployed Sebzor village, Tusyon Jamoat
Navruzov Gulayoz Unemployed Sebzor village, Tusyon Jamoat
Ibrohimov Qurbonsho Unemployed Sebzor village, Tusyon Jamoat
Abdulamidov Gulrukh Unemployed Sebzor village, Tusyon Jamoat
Nazaraliev Qambarali Unemployed Parzudj village, M.Mirshakar
Mabatshoev Mavjigul Unemployed Parzudj village, M.Mirshakar
Mavlonazarova Zilamo Unemployed Parzudj village, M.Mirshakar
Saidshamsova Sarfiyamo Unemployed Parzudj village M.Mirshakar
Chaqaboev Farhod Unemployed Parzudj village M.Mirshakar
Bekdavlatova Surayo School Director Sebzor village, Tusyon Jamoat
Devonaeva Nazribegim Unemployed Chagev village, M.Mirshakar
Zavqibekov Zokir Unemployed Chagev village M.Mirshakar
Dovutov Eraj Unemployed Chagev village, M.Mirshakar
Bakhtshoeva Jamila Unemployed Chagev village, M.Mirshakar
Ismoilov Olimsho Unemployed Chagev village, M.Mirshakar
Rakhmatov Rakhmat Unemployed Parzudj village, M.Mirshakar
Tilloeva Nasrigul Unemployed Chagev village, M.Mirshakar
Ambarob Dildor Unemployed Chagev village, M.Mirshakar
Ibrophimov Mehrubonsho Pensioner Dashtak village, Mirsaid Mirshakar
Annex 3. Minutes of Consultation Meeting on Khorog-Qozideh 110kV Transmission line in Andarob and Qozideh Villages (Ishkashim District, GBAO)
MINUTES OF MEETING
PROJECT NAME
Tajikistan Rural Electrification Project
VENUE
Andarob and Qozideh villages of Ishkashim district, Viloyati
Mukhtori Kuhistoni Dadakhshon (VMKB)
DATE OF MEETING
29&30/04/2019
PRESENT
A.Mamadatoeva – Senior Environmental Officer, Pamir Energy
Mirzo Gulomaseynov – Head of the Territorial Energy Complex
(TEC) of Pamir Energy
G. Mamadambarova – Call Center Operator, Pamir Energy
D.Bakhtibekov – BDU Engineer Pamir Energy
N. Shoskandarov – GIS specialist Pamir Energy
R.Khushqadamov- PR Specialist, Pamir Energy
R.Ustoboeva- Report Officer of Pamir Energy
The community members [the list of participants is attached]
1. Summary
For the consultative meeting (on TREP construction and operation of a 63-kilometer (km) 110kV
transmission line between Khorog substation and a new substation near Qozideh, particularly E&S
documentation) all village residents were invited and about 48 community members gathered and
participated in the meeting. The first day meeting was held in Andarob village and members from four
villages (Sist, Kuhi- La’l, Khaskhorug and Andarob) have participated. The second day meeting was held
in Qozideh village and participants form remaining 4 villages (Shanbedeh, Vozg, Barshor, Qozideh) have
participated. They received information and details about the planned project implementation as well as
related environmental and social impacts that were identified in recent assessments. Andarob and
Qozideh villagers very much welcome the project’s implementation. They expressed no objection or
concern related to the project and its impacts as they are generally very hopeful that it will contribute to
positive developments for their village. Primarily, employment opportunities and compensation (in-kind)
for potential loss of land were the main point of community interest an discussion.
2. Welcome and Introduction
An introductory speech was made by the chairman of Qozideh Jamoat, Mr Sayfov Amonullo, who
welcomed the representatives of Pamir Energy Company (PE) and expressed his opinion and the opinion
of the local community about how pleased they are that the company had launched rural electrification
project in VMKB and how they are going to benefit from it.
Mr. Mirzo Gulomaseynov, the Head of TE, a representative of PE, presented the Tajikistan Rural
Electrification Project that was developed as part of the Government of Tajikistan and PE initiative on
electrification of the transmission line population in VMKB and Khatlon regions in cooperation with the
World Bank (WB). He mentioned that although within 16 years of operation, the company has
significantly increased energy availability for 218,000 people (96% of the population) in Eastern
Tajikistan, there are still 12,286 people, residing in 61 villages of VMKB, without electricity. Therefore,
the given project aims at electrification of these people through the construction of hydropower plants,
through the construction of transmission lines. The project will be financed by the WB. Along with the
requirements of the legislation of the Republic of Tajikistan, as a precondition for financing, the WB also
requires several activities including the environmental and social assessment, according to Mr. Mirzo.
As to the environmental and social impacts of the project components; the Sebzor hydropower plant and
the associated 18 km transmission line as well as the 63km transmission line will be assessed in an
Environmental and Social Impact Assessment (ESIA), which was presented to participants by Pamir
Energy’s Senior Environmental Officer Ms. Mamadatoeva. The purpose of this Environmental and Social
Impact Assessment (ESIA) is to provide an environmental and social assessment of the project in order
to identify potential environmental and social risks throughout construction and operation. It was further
explained that the ESIA will guide Pamir Energy in determining what additional surveys or studies are
needed and in determining the requirements that need to be placed in contracts for final design and
construction of the transmission line and substation so that environmental and social impacts are managed
and mitigated in accordance with World Bank ESF requirements and Tajikistan law.
Community member were informed that the environmental and social assessment helps to determine the
potential environmental and social effects of the project and as Ms. Asligul Mamadatoeva noted also
identifies if additional research/assessment will be needed and conducted on individual project
components or aspects, which are listed in the brochures which will be distributed at the end of the
presentation. For instance, as a common practice, while implementing such projects, a plan for
resettlement and compensation is developed. An example of the socio-economic aspect would be not
only electrification of the targeted areas, but also employment opportunities for the local population.
Ms.Mamadatoeva also highlighted that Pamir Energy will design the transmission and distribution lines
in a way that it will not result in any displacement. However, when towers are built on agricultural or
other productive lands, it will take measures that people who are currently using the small plots of land
are compensated for taking off their lands for towers. In-kind compensation is the preferred means of
compensation that Pamir Energy generally aims to use in its projects, according to Ms Mamadatoeva.
According to the representative of Pamir Energy Mr. D.Bakhtibekov. In 2013, with the support
of foreign donor ‘Norway’ project Ishkashim 1 invested in the 110kV transmission infrastructure
with local company Badakhshan TADES from Khorog to Gojak. So far, in the area of Andarob,
due to a variety of hazards in winter this building has suffered much damage. Since then the year
changed the transmission line with the machining facilities. In this building the number of local
residents reached 40 years in high quality in the past six months.
In the current year, the World Bank decided to export electricity to an amount of 8,429617 US
dollars from Andarob to Hosseinii. The 110 kV power line is created from 63km, with a capacity
of 110/35 kV. This construction is mainly focused on the Afghan population. The construction
consists of mechanical bases that will last for 2,5 years, and during the construction work, there
will be need for a lot of staff from 120 to 150 people.
Detailed information on the project as well as the developed documents on environmental and
social aspects of the projects are available on the PE website, the brochures and newspapers
(developed by PE) that are distributed by Gulnor Mamadambarova, as well as on the regional
newspaper – “Badakhshon” and messages sent to consumers via phones.
The link to the website is provided in the PE newspapers that were distributed during the meeting. The
dates for consultative meetings with the local communities for each targeted village under the project are
indicated in the newspaper. That is why we are here today – emphasized Mr D.Bakhtibekov, to present
the project’s objectives and activities as well as to know the communities’ opinions as stakeholders and
to answer their queries.
3. Questions and Answers
Mr.Khasanov Mehrobsho, the Leader of the Jamaat expressed his gratitude to the representative of Pamir
Energy company for the meeting with the local community and mentioned that as electricity is the basic
need for human beings, the community is glad that PE started implementing the project and expressed
his as well as community’s willingness to assist in the timely implementation of the project. He further
queried the implementation period of the project.
Mr Bakhtibekov responded that the project implementation period. The construction consists of
mechanical bases that last for 2,5 years, and during the construction work, we need a lot of staff
from 120 to 150 people as he mention above
The community also queried the staff –who will be working during the operational stage at the HPP?
Ms. Mamadatoeva replied that the PE staff as well as local residents, who will be selected based on the
required qualifications i.e. with relevant technical knowledge and education
4. Closing Remarks
At the end of the meeting, brochures and regional and PE’s newspapers were distributed to all the
participants. The pictures of the meeting and the list of participants with their signatures are attached.
Signatures of PE representatives:
/s/ A Mamadatoeva
/s/ G.Mamadambarova
/s/ N.Shoskandarov
/s/ R.Khushqadamov
/s/ R.Ustoboeva
Participants in Consultation Meetings in Andarob and Qozideh
Full Name Position Location
Shodmamadov Ikrombek Unemployed Qozideh village.
Mazamov Musamir Policeman Qozideh village
Zamirov Islombek Landstore Andarob village
Khudoyorov Olimjon Teacher Andarob village
Sobirov Khudonazar Teacher Andarob village
Mastibekov Mamadrahim Teacher Khaskhorog
Surobov Sharob Teacher Khaskhorog
Zanjirbekov Khanjar Unemployed Khaskhorog
Odilbekov Intizor Unemployed Dasht village
Anoyatbekov Khanjarbek Unemployed Anderob village
Muzofirbekov Qudratbek Unemployed Anderob village
Palavonbekov Noyob Pensioner Dasht village
Utalbekov Azam Unemployed Dasht village
Rajabov Usmon Unemployed Dasht village
Sarvarov Shokir Unemployed Sizd village
Ibrohimov Rashid Unemployed Sizd village
Shirinbekov Anvar Unemployed Kuhi lal village
Ismoilbekov Bakhtali Unemployed Andarob village
Poyandaev Aydimamad School Director Kuhi lal village
Jumakhonov Qahramon Unemployed Andarob village
Khudoyorov Bahrom Teacher Andarob village
Shirinbekova Jonamo Unemployed Qozideh village
Rakhmondodova Inobat Unemployed Andarob village
Davlatmamadova Lutfiya Unemployed Qozideh village
Odinaev Umed Unemployed Kuhi Lal village
Safarov Abdul Unemployed Kuhi Lal village
Qurbonbekov Khanjar Unemployed Qozideh village
Odilbekov Oshurbek Unemployed Dasht village
Masaylov Salmon Unemployed Dasht village
Safoev Khushqadam Unemployed Andarob village
Odilbekov Khudoyor Unemployed Dasht village
Shirinbekov Bakhtali Teacher Dasht village
Nazarov Amirkhon Unemployed Kuhi Lal village
Poyandaev Sojidkhon Unemployed Kuhi Lal village
Aslamov Zokir Unemployed Andarob village
Shosafobekov Sharaf Unemployed Andarob village
Shodmonov Iftikhor Unemployed Andarob vilalge
Chorshanbiev Payshanbe Teacher Andarob village
Shosafobekov Alimamad Unemployed Andarob village
Odinaev Davlatyor Unemployed Andarob village
Mastibekov Roziq Unemployed Khaskhorog village
Ismatulloev Mamed Unemployed Qozideh village
Palavonbekova Ashrafmo Unemployed Andarob village
Abdurahimov Jurabek Teacher Qozideh village