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LNG Terminal Project Świnoujście, Poland Stakeholder Engagement Plan February 2013 NOTE This Stakeholder Engagement Plan has been prepared for the purposes of providing the

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Page 1: 1 INTRODUCTION - Polskie LNG€¦  · Web view-Szczecin gas pipeline. Information about the construction of the Świnoujście - Szczecin gas pipeline was presented by GAZ-SYSTEM

LNG Terminal ProjectŚwinoujście, Poland

Stakeholder Engagement Plan

February 2013

NOTE

This Stakeholder Engagement Plan has been prepared for the purposes of providing the public with information on the project for the construction of a liquefied natural gas (LNG) terminal in Świnoujście.

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Spis treści1 INTRODUCTION 31.1 SCOPE, PURPOSE AND OBJECTIVE OF THIS STAKEHOLDER ENGAGEMENT

PLAN 31.2 BRIEF DESCRIPTION OF THE PROJECT 32 REGULATIONS AND REQUIREMENTS FOR CONSULTATION

AND DISCLOSURE RELATING TO THE LNG TERMINAL PROJECT 7

2.1 POLISH REQUIREMENTS 72.1.1 Statutory and Public Consultation

72.1.2 Polish-German Transboundary Consultation Framework

92.2 BEST INTERNATIONAL PRACTICES IN PUBLIC

CONSULTATIONS 93 STAKEHOLDER IDENTIFICATION AND COMMUNICATION

METHODS 103.1 PREVIOUS STAKEHOLDER CONSULTATION ACTIVITIES AND

PUBLIC DISCLOSURE 113.2 OVERVIEW 113.3 STATUTORY CONSULTATIONS AND PUBLIC DISCLOSURE

ACCOMPLISHED 123.3.1 Stakeholder Consultations during previous spatial planning and land

development procedures addressing the LNG Terminal site. 123.3.2 Stakeholder Consultation during previous EIA Proceedings for the Project’s

Components 123.3.3 Public consultation in the course of introducing the gas pipeline into the local

Site Development Plan 133.4 VOLUNTARY CONSULTATIONS AND PUBLIC DISCLOSURE

ACCOMPLISHED 143.5 TRANSBOUNDARY CONSULTATIONS ON THE PROJECT TO DATE 174 ADDITIONAL PUBLIC DISCLOSURE 18 Public Disclosure Sites 19TABLE A-1. DISCLOSURE PACKAGE AVAILABILITY SITES (IN THE

PERIOD OF 60 DAYS IN 2010/2011) 194.1 ADDITIONAL INFORMATION AND EDUCATIONAL ACTIVITY 20Table A- 2 Communication strategy 21Table A-3 Communication strategy for the Świnoujście–Szczecin gas transmission

pipeline (without the LNG Terminal connecting pipeline section) 234.2 PUBLIC DISCLOSURE AND FEEDBACK MECHANISM FOR THE

GERMAN SIDE 234.3 INFORMATION CAMPAIGN SCHEDULE 234.4 GRIEVANCE MECHANISM 23

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5 RESOURCES AND RESPONSIBILITIES FOR SEP IMPLEMENTATION 24

6 ANNEXES 256.1 A: LIST OF STAKEHOLDERS 256.2 B: INQUIRY / COMPLAINT FORM TEMPLATE 25

1 INTRODUCTION

1.1 SCOPE, PURPOSE AND OBJECTIVE OF THIS STAKEHOLDER ENGAGEMENT PLAN

This document determines and defines the Stakeholder Engagement Plan (SEP) under the on-going construction project of the Liquefied Natural Gas (LNG) Receiving Terminal in Świnoujście (Project).

The present SEP provides characteristics of Project information activities performed by four entities, namely: Polskie LNG S.A. (PLNG), the Maritime Office Szczecin (UMS), the Szczecin and Świnoujście Seaports Authority, Świnoujście (ZMPSiS) and Operator Gazociągów Przesyłowych GAZ-SYSTEM S.A. (GAZ-SYSTEM) (together collectively referred to as the “Project Sponsors”).

The Stakeholder Engagement Plan has been drawn up in accordance with requirements of the European Bank for Reconstruction and Development (EBRD) concerning the project implementation efficiency as well as EBRD’s information policy together with standards set forth by International Finance Corporation.

The Stakeholder Engagement Plan covers:

Review of statutory requirements regarding conduct of public consultations and disclosure of information, in particular regarding public consultations carried out as part of the process of securing permits,

Identification of stakeholders in the area impacted by the Project, Data on earlier consultations and disclosure of information about the

Project, Description of the proposed manner of handling claims and grievances, Plan of future public disclosure activities during successive phases of the

Project, Identification of sites where the relevant Project documentation will be

accessible.

1.2 BRIEF DESCRIPTION OF THE PROJECT

The Project consists of four main Project Components:

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Polskie LNG S.A. is a special purpose vehicle founded in 2007 to construct and operate the LNG Terminal in Świnoujście, i.e. the liquefied natural gas receiving and regasification plant.

GAZ-SYSTEM S.A. – coordination of the entire LNG Terminal Project; co-funding and future operation of the connecting and transmission pipelines.

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The entire Project is an integral part of the Polish Energy Policy to 20301 and constitutes a subject of the Act of 24 April 2009 on investment in the liquefied natural gas regasification terminal in Świnoujście (so-called special purpose Act) 2.

The LNG terminal in Świnoujście will be the first such plant in Poland and in the entire CEE region. Currently in Europe there are 21 LNG regasification terminals in operation (of which the largest number in Spain). There are 7 LNG terminal under construction and 35 planned installations. Altogether there are 84 LNG terminals in operation - of which the most numerous in Japan.

The implementation time schedules of the various Project components are aligned in order to receive the first LNG cargo and commence Terminal’s operation in 2014.

The LNG Terminal is situated on a 48-hectare plot on Wolin Island on the right (i.e. east) bank of the Świna River, the area that has been intended for port’s expansion. The entire project will be performed with the highest consideration for natural environment. In order to preserve the nearby historical forts and bunkers as well as gray dunes, the terminal is built in the distance of 750 meters from the coastline and about 1 km from the health resort zone "C". This location is beneficial also in terms of the "wind rose", and according to calculations of pollutants’ dispersal in the atmosphere, all relevant air quality standards determined by law will be met.

Under the Project’s framework, a new breakwater will be constructed in the Baltic Sea to the east of the existing breakwater at the mouth of Świna River, extending from the coast (beach) to the north and north-west reaching a total length of about 3 kilometres. A new port will be formed by dredging and providing space for a turning basin and approach fairway for the LNG transport ships. The Breakwater, together with the new Jetty (see below), will form a new external port 1 Reference: http://www.mg.gov.pl/English/Programmes/Polands+Energy+Policy+until+2030.htm2 Act on Re-gasification LNG Terminal in Świnoujście dated April 24, 2009 (Journal of Laws no. 84, item 700)

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Maritime Office - construction and maintenance of the breakwater and maritime port infrastructure including the new breakwater, wind dam, turning basin and approach fairway along with vessel navigation safety supervision.

Szczecin and Świnoujście Seaports Authority – construction of port’s infrastructure including the berthing station, as well as the infrastructure to set up the installation for gas transmission from the berthing station to onshore LNG terminal.

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facility for the LNG ships. The project titled “Breakwater for the external port in Świnoujście” will be implemented by the Maritime Office in Szczecin.

The new Jetty, located within the new Breakwater area, will allow proper mooring and safe and stable berthing of the LNG ships during unloading. It will be outfitted with all necessary handling facilities, such as navigation and mooring equipment, etc. The construction of the Jetty is carried out by Szczecin and Świnoujście Seaports Authority and the facility will be operated by Polskie LNG S.A. under a special agreement.

In order to feed the natural gas - re-gasified in the LNG terminal - into the Polish national gas transmission pipeline grid, Gaz-System will build approx. 6-kilometre-long high pressure connector gas pipeline (of nominal diameter of 800 mm). In the vicinity of Łunowo this pipeline will be connected to the newly built approx. 74 kilometre long Świnoujście-Szczecin high pressure gas pipeline of 800 mm nominal diameter connecting the LNG terminal with a new grid station in Brudno village near Goleniów. Approximately 95% of the length of the new gas transmission pipeline will run in parallel with the existing gas transmission pipeline. The route runs from the LNG terminal, eastwards across the Wolin Island to the city of Wolin and, having crossed the Dziwna river near the city of Wolin, turns south towards Stepnica and arrives in Goleniów. The route of the gas

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Model of the LNG Terminal in Świnoujscie

1. Breakwater2. External port3. Unloading berth4. Pipeline bridge5. LNG Terminal

Source: Szczecin and Świnoujście Seaports Authority

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transmission pipeline will run through the following municipalities: Świnoujście, Międzyzdroje, Wolin, Stepnica, and Goleniów.

The rough location of the Project Components and the administrative units affected are shown in Figures 1 and 2 below.

Figures 1 and 2. Overview of Administrative Units and settlements in the Project Area

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2 REGULATIONS AND REQUIREMENTS FOR CONSULTATION AND DISCLOSURE RELATING TO THE LNG TERMINAL PROJECT

2.1 POLISH REQUIREMENTS

2.1.1 Statutory and Public Consultation

Consultations required by Polish lawIn a project of this scale, many national authorities are involved in the process of planning and issuing relevant permits. During the course of an Environmental Impact Assessment (EIA) in Poland, the authority competent for issuing the decision about environmental conditioning in the subject case was usually the Regional Directorate for Environment Protection in Szczecin, who:

Reviews the Project’s Environmental Impact Analysis, receives the opinion from the National Sanitary Inspectorate (Państwowy Wojewódzki Inspektor Sanitarny – PWIS) about environmental conditioning

Conducts public consultationFurthermore, a substantial number of permits / decisions regarding the construction and operating the LNG terminal and the new external harbour facilities including the LNG unloading berth shall be obtained by PLNG and the other Project Sponsors.In these administrative proceedings the following authorities are primarily involved: West Pomeranian Voivode Office in Szczecin West Pomeranian Marshal Office in Szczecin Regional Water Management Authority in Szczecin Regional Director of State Forest in Szczecin Voivodship Heritage Conservator Office in Szczecin, Maritime Office in Szczecin Wolin National Park Fire Brigades’ Headquarters for Western Pomerania Voivodship Land Drainage and Water Facilities Authority in Szczecin Office of Regional Geologist Road Administration (depending on road category at county / municipal level) Port Master’s Office in Świnoujście Goleniów and Międzyzdroje Forest Inspectorates (subsidiaries of the Regional

Directorate for State Forests in Szczecin) Regional Inspectorate for Environmental Protection in Szczecin Regional Labour Inspectorate in Szczecin Technical Inspections Office in Szczecin Customs Office – Branch in Świnoujście

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Decision on environmental conditions of Project’s approval of investment sets the environmental conditions that must be considered by project executors.

Public Disclosure and Consultation Requirements in Poland

Poland is a signatory to the Aarhus Convention3 ensuring basic public access to environmental information and public participation in decision-making process regarding the environment-related issues. The fundamental Polish legislative acts concerning public disclosure of information on projects’ environmental impact include:

1. Constitution of the Republic of Poland dated 2 April, 1997 (Journal of Laws of 1997, No. 78, item 483), which stipulates the right of citizens to obtain information about activities of public authority agencies; in particular Article 74. stating explicitly that “everyone has the right to information about the condition and protection of environment”.

2. Environment Protection Act of 27 April 2001 (Journal of Laws of the Republic of Poland, 2008, No. 25, item 150, amended).

3. Act on Access to Information on the Environment and Its Protection, public participation in protection of the environment and on Environmental Impact Assessments of 3 October 2008; Journal of Laws of the Republic of Poland, 2008, No. 199, item 1227.), and The Code of Administrative Proceedings, consolidated text in Journal of Laws of the Republic of Poland 2000, No. 98, item 1071, amended.

Under the legal provisions currently applicable in Poland, procedures relating to environmental impact assessment involve mandatory public consultations. Consultations are open to any interested party, non-government organization and other entities. The EIA Report is displayed by the relevant authority for public inspection for a period of 21 days.

The leading authority is responsible for publication of relevant notices and for their posting on the office’s official website. The notice shall contain information that the EIA Report is displayed to the public.

Public consultations addressing the Project were carried out by individual Project Sponsors in compliance with Polish regulatory requirements regarding environment protection and in concordance with spatial planning procedures.

The Sponsors of particular Project components, on their own initiative, publicized additional information on implementation of the Project. These actions are described in detail in Chapter 4.

2.1.2 Polish-German Transboundary Consultation Framework

Poland is a signatory on the UNECE Convention on EIA in a transboundary context, known as the “Espoo Convention”4. In addition, Poland and Germany have signed a bilateral Agreement on the Implementation of the Espoo 3 Aarhus Convention: Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters of 1998. http://www.unece.org/env/pp/ 4 'Espoo (EIA) Convention' Espoo 1991 http://www.unece.org/env/eia/eia.htm

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Convention (Agreement of 11 April 2006, signed in Neuhardenberg, Brandenburg)5. This agreement determines in detail the procedures of the Espoo Convention, and provides standards for notification of the other country in case of Project’s potential transboundary impact.

The Environmental Impact Assessment Reports commissioned by Project Sponsors demonstrate that the Project will not have any significant transboundary impact.

Nevertheless, there are local agreements in force between the German neighbouring federal state of Mecklenburg-Vorpommern and the region of West-Pomerania (województwo zachodniopomorskie) in Poland, endorsing good neighbourhood, economic and cultural cooperation and development, as well as cooperation in the field of nature and environmental protection6.

As part of the consultations, several meetings with German representatives were held, addressing environmental issues relating to the Project and safety of Project’s operation and functioning after its completion. The Project Sponsors have adopted appropriate measures involving the relevant state authorities (General Directorate for Environmental Protection and Regional Directorate for Environmental Protection in Szczecin), as described in sub-chapter 4.4.

2.2 BEST INTERNATIONAL PRACTICES IN PUBLIC CONSULTATIONS

Best international practices in public consultations were described in: Equator Principles – mainly principle 5 and 6; IFC – International Finance Corporation’s standard No. 1) pertaining to public

and environmental assessment and management systems (referred to in the Equator Principles);

EBRD’s performance requirement No. 10 (PR 10: Public disclosure and Stakeholder Engagement) and;

EBRD’s guidelines on Stakeholder Engagement PlanThese guidelines acknowledge the public right to access information on the Project and related emissions to the atmosphere, to proper consultations taking into account the size and comprehensive nature of the Project, and to receive up-to-date information on the project throughout its progress.

On the whole, these guidelines set out the following requirements: identification of stakeholders to be included in the information and

consultation campaign, public presentation of relevant information on the Project by Project Owner,

5Agreement on the Implementation of the Espoo Convention of 25 February 1991 (Espoo Convention), http://www.bmu.de/english/europe_and_environment/downloads/doc/39920.php 6http://www.regierungmv.de/cms2/Regierungsportal_prod/Regierungsportal/de/stk/Themen/Ostseekooperation_und_regionale_Partnerschaften/Polen/Zusammenarbeit_mit_Westpommern/index.jsp

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procedure or specific policy to allow the public to submit comments or claim grievances (Grievance Mechanism).

In addition to the stakeholder consultation requirement, documentation resulting from the environmental and social impact assessment process will be made available to the public.

Additional activities include:

preparation and publication of the Stakeholder Engagement Plan (SEP) pertaining to public disclosure and stakeholder consultations, including consultations with the public; presentation of the Non-Technical Summary on the Project Owner’s website and in the areas potentially affected by the project,

preparation and presentation of information on any matters not included in the EIA, necessary for the fulfilment of the lenders’ requirements – this will be developed in a form of a supplement to the EIA Report / Procedure;

preparation of the Environmental and Social Action Plan (ESAP) describing social and environmental actions aimed at managing, mitigating and monitoring any consequences identified during the preparation of EIA Reports for particular components of the Project, and presenting all these factors in tabular form containing the commitments concerning environmental and social issues, health-related and security aspects, as well as employment-related and other.

3 STAKEHOLDER IDENTIFICATION AND COMMUNICATION METHODS

The following Chapter provides a preliminary identification of the parties/stakeholders involved in the Project. This includes local public, governmental agencies, organizations, public administration of different levels, local self-government bodies, other statutory stakeholders and various non-governmental organizations (NGOs).

The key stakeholder groups include:

1. Local communities – residents of areas where various Project components are located.

2. Owners and users of land on which the Project is located. 3. NGOs and local community groups, including local fishermen. 4. Local state and self-government administration authorities.5. Government administration offices. 6. International stakeholders 7. Public service organisations. Mass media

Annex A provides a detailed list of all stakeholders identified so far, including their contact data.

By this SEP document, Project Sponsors assure that all relevant administrative bodies were appropriately notified about the procedure and are in possession of

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the SEP document, as well as they understand the mechanism of disclosing information and handling grievances (described in Section 5.4).

Fig. 3 The view of the LNG Terminal.

3.1 PREVIOUS STAKEHOLDER CONSULTATION ACTIVITIES AND PUBLIC DISCLOSURE

3.2 OVERVIEW

Statutory public disclosure, institutional stakeholders and public consultations have taken place at various stages and different levels during Project planning and permits’ acquisition. They pertained to: Land development planning procedure for the LNG terminal site in Świnoujście

municipality (of 2004, amended in 2007) Land development planning procedure for the connection pipeline and the

transmission pipeline (since 2009 onwards ) Separate EIA procedures for four Project components (the LNG Terminal, the

new breakwater, the jetty and the connection and transmission pipelines – conducted in 2009 and 2010).

The Project Sponsors also took part in public meetings beyond the statutory required process and provided additional information on the Project to all interested parties. With regard to trans boundary issues, new contacts were established and information exchanged with German authorities, however no formal Espoo proceedings for the Project have been launched, because the EIA did not indicate any transboundary impact, also in the cumulative perspective.

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Details on these previous consultation and disclosure activities are provided below. Additional activities planned with respect to disclosure of Project-related information are described in Section 4.

3.3 STATUTORY CONSULTATIONS AND PUBLIC DISCLOSURE ACCOMPLISHED

3.3.1 Stakeholder Consultations during previous spatial planning and land development procedures addressing the LNG Terminal site.

In 2007, in order to meet the requirements set out in the Spatial Planning and Land Use Act, the Municipal Council in Świnoujście organized a public hearing concerning amendment procedures for the Site Development Plan for the LNG Terminal Site. The public meeting took place on 30 August 2007. According to the records, only several members of the public from Warszow district and the Municipal Council participated. Key questions discussed concerned the access to the beach and Ku Morzu Street, destruction of habitats, transfer of land ownership, expected number of LNG tankers and relocation of the power line.

3.3.2 Stakeholder Consultation during previous EIA Proceedings for the Project’s Components

During the four separate EIA proceedings for the Project Components: LNG Terminal - land and marine part, Breakwater - land and marine part, Jetty and gas pipeline - consultations were conducted in concordance with relevant regulatory provisions.

Statutory Stakeholder ConsultationThe competent authorities for the EIA procedure and issuing the Decision on environmental conditions of approval of investment (referred to as “environmental decision”) for particular Project components include: The Mayor of Świnoujście Municipality for the EIA report related to the land part of the LNG Terminal and the Breakwater and the Regional Directorate for Environmental Protection in Szczecin (RDOS) for the marine parts of the LNG Terminal, the new Breakwater, the Jetty and the Pipeline.

The competent authorities involved the institutional stakeholders indicated in the aforementioned Act in decision making process. The Regional Directorate for Environmental Protection inquired about the opinion of the National Regional Sanitary Inspector in Szczecin (PWIS) on mandatory character of EIA procedure (for the part of the Project – excluding the pipeline) and at the stage of consultation with statutory bodies (opinion on environmental decision). In the cases where the Decisions on environmental conditions of approval were issued by the Municipality of Świnoujście, the Regional Directorate for Environmental Protection was consulted during the stage of ascribing the obligation of performing the EIA and requested settlement of the environmental conditions prior to issuing the decision. No further statutory stakeholders/authorities were involved during the statutory EIA procedures.

Other statutory stakeholders such as the Forest Inspectorate or Regional Water Management Authority were involved in further procedures and decisions, carried

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out prior to or pursuant to the EIA procedures (spatial planning procedures, special permissions/derogations, construction permit) as required under respective regulations.

Public Consultations and Public disclosure As required by law, the EIA reports constituted a basis for public consultations (submitting comments and conclusions) through the period of 21 days. The draft EIA Reports were disclosed for 21 days in hard copy at the respective competent authority’s offices (Regional Directorate for Environmental Protection / Świnoujście Municipality) for public inspection allowing submission of comments in line with the applicable regulations. The possibility to inspect the EIA Reports was announced on notice boards of the permitting authority (Municipality of Świnoujście / Regional Directorate for Environmental Protection), as well as the official websites of the said authorities. Regarding the EIAs for the breakwater and jetty, additional announcements were posted at Szczecin Maritime Office and Szczecin and Świnoujscie Seaport Authorities’ offices. Respective announcements about the gas pipeline EIA were also posted on the notice boards of the district (powiat) and municipality (gmina) administration offices where the connection pipeline was located.

Pursuant to the Polish Act on Environment Impact Assessment, there is no general requirement that a public EIA consultation is carried out, but it is at the discretion of the Competent Authority to decide if necessary. Due to insignificant number of comments received from the public, public EIA consultation was carried out for none of the Project components. Only one NGO - West-Pomeranian Society for Practical Ecology (Zachodniopomorskie Towarzystwo Ekologii Praktycznej - ZTEP) filed comments to the EIA on the marine part of LNG Terminal7 during the designated 21-day period.

3.3.3 Public consultation in the course of introducing the gas pipeline into the local Site Development Plans

Since 2008, the amendment procedure regarding the Local Site Development Plan has been conducted for five municipalities along the designed gas pipeline route. The amendments to the Local Site Development Plan must be preceded by amendments to the Study of Conditions and Directions of Spatial Development (Studium Uwarunkowań i Kierunków Zagospodarowania Przestrzennego) for the affected municipalities. Study of Conditions and Directions of Spatial Development and Local Site Development Plan require strategic Environmental Impact Assessment and public consultations to be conducted.  In compliance with Polish law, public consultations have been conducted along the entire pipeline route.

In Świnoujście municipality, where the connecting pipeline is located, the Study of Conditions and Directions of Spatial Development amendment procedure has been completed and Local Site Development Plan is awaiting enactment by the Municipality Council. The Local Site Development Plan documents together with an environmental impact assessment forecast were presented to the public for 21 days. During that period, the municipality arranged a public debate on the issues presented in the draft Local Site Development Plan as part of the statutory 7 The comments concerned i.a. alternatives and exit studies

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procedure. The accessibility of documents and the meetings planned were announced in the local media and on notice boards. In the other four municipalities along the transmission pipeline, the Local Site Development Plan amendment procedure has not been completed. A public information programme and public consultation is planned. The reports from the consultations conducted so far do not include any negative comments or protests from the public.

3.4 VOLUNTARY CONSULTATIONS AND PUBLIC DISCLOSURE ACCOMPLISHED

In addition to the mandatory public consultation and public disclosure described above, the sponsors of particular Project components engaged into voluntary public meetings and consultations regarding the LNG Terminal and new harbour with jetty8. The general objective of these activities, which took place in Świnoujście between September 2007 and March 2010, was to inform the public about the project details and to provide the opportunity to ask questions and comment on the Project. From September 2007 to April 2009, in ‘Information Points’ located in Warszów and Świnoujście open meetings were held on a monthly basis. Those meetings were attended by Project representatives who answered questions from local residents. The following public meetings with Świnoujście residents were held: The first meeting with residents was held in the Municipal Culture Hall in

Świnoujście in January 2007.

9 October 2009: Meeting with local residents held at Warszow Culture Hall, organised by Warszów District Authority, with participation of the Mayor of Świnoujście Municipality, representatives of local Police, Firemen, local media and about 120 citizens. Polskie LNG representatives were invited to present the overall Project and respond to queries.

15 January 2010: Meeting with local residents held at Warszow Culture Hall, organised by local civic group Association for Development of the Right Bank of the Swina River (Stowarzyszenie na Rzecz Rozwoju Prawobrzeża Świnoujścia), with participation of the President of Świnoujście, representatives of the City Council and about 200 residents. The representatives of Polskie LNG, the Maritime Office in Szczecin and Szczecin and Świnoujście Seaports Authority were invited to present the Project and respond to queries.

10 March 2010: A Seminar organized by the City Council of Świnoujście on Polskie LNG’ initiative, held at Świnoujście Culture Hall with participation of the Mayor of Świnoujście, the President of Świnoujście City Council, members of the City Council and about 80 citizens. The Project was represented by Polskie LNG. The seminar was also attended by the representatives of the Maritime Office in Szczecin, the Szczecin and Świnoujście Seaports Authority and a number of experts in environment and industrial safety. The session was covered by local media. 9

8 For the gas pipeline no additional meetings beyond the statutory consultations for the site development plan amendment were arranged.

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All the above meetings were announced locally by invitation postings displayed on notice boards.

The Meeting on 10 March 2010 lasted about 6 hours and approx. 100 questions were discussed. Key issues addressed by local residents included inter alia LNG plant safety, construction jobs and business opportunities and workforce lodging, public health and safety concerns in Warszów due the large number of workers, inconvenience due to construction, future use of the beaches and Project’s impact on local fishery. Also in March 2010 Polskie LNG produced a Pamphlet describing the key aspects of the Project. Furthermore, Polskie LNG and Szczecin and Świnoujście Seaports Authority provided a list of frequently asked questions (FAQs).

In addition, on 20 February 2009 in the West Pomerania Region Office a session of the Public Consultative Council for construction of the LNG Terminal in Świnoujście was held. During the session, the Project’s progress was demonstrated, along with environmental protection regulations in force and the status of administrative procedures relevant for the Project.

The meeting, chaired by West Pomerania voivode - Mr. Marcin Zydorowicz, was attended by representatives of Polskie LNG, the Maritime Office in Szczecin, the Szczecin and Świnoujście Seaports Authority, city of Świnoujście and Regional Directorate for Environment Protection in Szczecin.

Since the completion of „due diligence” procedure of 2010 for the LNG Terminal in Świnoujście construction project, the Project Sponsors intended to provide transparent information on its findings and to conduct a dialog with stakeholders. Therefore a disclosure and information campaign has been launched to provide stakeholders with the Information Package (see more on page 18) which was an end-product of the procedure, followed by the second round of open meetings with Świnoujście citizens and other Project stakeholders.

The representatives of four investors i.e. Polskie LNG S.A., Szczecin Maritime Office, Szczecin and Świnoujscie Seaports Authority and Gas Transmission Operator GAZ-SYSTEM S.A. were available for public during duty hours in the Municipal Culture Hall in Świnoujście, 2nd branch office in Warszów district; 18, Sosnowa St. on the following dates:

• 25 November 2010 (Thursday) - 12:00 - 14:00

• 9 December 2010 (Thursday) - 12:00 - 14:00

• 4 January 2011 (Tuesday) - 16:00 - 18:00

• 18 January 2011 (Tuesday) - 16:00 - 18:00

Nearly 70 local enterpreneurs took part in the meeting with representatives of the LNG Terminal investors, held on 17 February 2011 in Świnoujście. The event was organized by the President of Świnoujscie and the Association for the Development of Szczecin and West Pomerania "Business Club Szczecin." The 9 Coverage available at TV Świnoujście. http://www.tvswinoujscie.pl/20100310759/gazowe-seminarium.html

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motto of the meeting was "Construction of the LNG Terminal as an opportunity for development of regional and local entrepreneurship" and its purpose was to discuss the schedule of works and progress of the largest project in the region. The representatives of all four investors involved in the construction of the LNG Terminal, i.e. Polskie LNG S.A., Szczecin and Świnoujście Seaports Authority S.A., the Maritime Office in Szczecin and Gaz-System SA met with local entrepreneurs both from Świnoujście and the region, primarily to present business opportunities resulting from the construction of the LNG Terminal and the external port in Świnoujście. The Project Contractors provided information on the demand for various services / supplies, both during the construction stage and after terminal’s start-up. The meeting was covered by local media.

Besides the continued handling of media inquiries, a number of meetings with representatives of local editors took place in order to better satisfy information needs on the Project. One of those meetings in a form of a press breakfast with local media representatives arranged by Polskie LNG S.A. on 2 August 2012 in Szczecin addressed the relevant aspects of the Project.

Information Meetings related to the Świnoujście-Szczecin gas pipeline

Information about the construction of the Świnoujście - Szczecin gas pipeline was presented by GAZ-SYSTEM at an information meeting held on 5 June 2008 in Szczecin, with participation of local self-government officials, and representatives of local government offices. The purpose of the meeting was to present the project of gas transmission pipeline construction in West Pomerania and to provide information regarding the consideration given to the local community’s needs and environmental care during implementation of the Project. More than 30 persons attended the meeting. The participants received information materials and a leaflet about GAZ-SYSTEM’s investment (containing information on Świnoujście - Szczecin pipeline). Additionally, a meeting with local journalists was organized on the same day. Information on investments implemented by GAZ-SYSTEM was also published in local press.

In January 2011, various information materials (leaflets, posters) addressing the construction of Świnoujście - Szczecin gas pipeline and a Gas Compressor station in Goleniów were distributed in the municipality offices of five districts: Świnoujście, Międzyzdroje, Goleniów, Wolin and Stepnica. Additionally, in March and December 2011 an information leaflet along with a cover letter on the construction of Swinoujscie-Szczecin gas pipeline and the Gas Compressor station in Goleniów was distributed to property owners living along the pipeline route, and residents of five municipalities: Swinoujscie, Miedzyzdroje, Goleniów, Wolin and Stepnica.

In addition, on 31 March 2011, an annual information leaflet was inserted in the West Pomerania edition of Gazeta Wyborcza daily, (17 680 copies).

Furthermore, on 11 November 2011 and on 11 November 2012 information leaflets were distributed to participants of 23rd and 24th Goleniów Independence Mile marathon and Goleniów local residents.

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In December 2011 another wave of information materials’ distribution to the local administration offices of five towns situated on the route of Swinoujscie-Szczecin gas pipeline. In March and April 2012, GAZ-SYSTEM organized a series of information meetings with municipal authorities - mayors of towns and villages located on the route of the pipeline and with private owners of the said land about the construction of the pipeline. The meetings were held in Stepnica (13 March 2012 and 21 March 2012), Goleniów (14 March 2012), Międzyzdroje (3 April 2012) and Wolin (3 April 2012). During those meetings, GAZ-SYSTEM representatives together with the West Pomerania Regional Office staff presented background information on the construction of the pipeline in areas concerned and provided basic information about procedures of compensation for owners of land affected by the construction of the pipeline.

In May 2012, GAZ-SYSTEM prepared additional information materials concerning the construction of the gas pipeline (leaflets about commencement of Świnoujście-Szczecin gas pipeline construction and about the procedure of awarding compensation on account of the construction of the pipeline).

The leaflets have been distributed to property owners along the pipeline route, and delivered directly to authorities of the following municipalities: Świnoujście, Stepnica, Goleniów, Wolin and Międzyzdroje.

3.5 TRANSBOUNDARY CONSULTATIONS ON THE PROJECT TO DATE

Representatives of the West-Pomerania Voivodship held a number of meetings with representatives of German administration to inform them about the LNG Terminal Project. The Environment Impact Analysis for all Project components did not include a formal transboundary consultation under the ESPOO Convention10 with German authorities or German public, since no transboundary impact was indentified in the EIAs. However, Polskie LNG and GAZ-SYSTEM, on behalf of the LNG Terminal Project Sponsors and Project Coordinator, were involved in an ongoing consultation process with the regional authorities in Germany (the National Environmental Agency in Stralsund, “StAUN”). Further consultations will involve the disclosure of key documents to German authorities, including Risk Assessment and the Emergency Situations and Oil Spill Response Plans. Moreover, in August 2010, the LNG Project Sponsors hosted a visit of StAUN representatives on the site of the planned Project. At this meeting an action plan was agreed together with the mechanism of providing information and handling inquiries from German representatives.

In response, the German authority sent an official opinion stating that there are no grounds to consider any significant adverse environmental impact on the German territory exerted by the largest possible industrial break-down during transport, unloading or loading the liquefied natural gas in Świnoujście.

10 Convention on Environmental Impact Assessment in a Transboundary Context - http://www.unece.org/env/eia/

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Photo: LNG tanks

4 ADDITIONAL PUBLIC DISCLOSURE

As described in Section 3.4 above, the Project Sponsors have implemented additional information activity above and beyond the actions required under relevant regulations. In compliance with international best practice, the Project Sponsors intend to further engage in additional supplementary activities as described in the following sections.

Following the completion of „due diligence” procedure in November 2010, Project Sponsors published the Information Package on company website www.polskielng.pl/terminal-a-srodowisoko and displayed in a hardcopy in various locations specified in Table 5-2 to provide information on the Project to all persons concerned. Project Sponsors established a mechanism for handling questions and comments (described in detail in section 4.4.)

Disclosure Package

The Project Information Package disclosed by the Sponsors includes the following documents:

1. Non-Technical Summary (NTS) – Polish, English and German language versions

2. Stakeholder Engagement Plan (SEP) including details of the Grievance mechanism for the Project – Polish, English and German language versions

3. Environmental & Social Action Plan (ESAP) – Polish and English language versions

4. Social Review - Polish and English language versions

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5. Draft Biodiversity Action Plan (BAP) - Polish and English language versions

6. EIA for the LNG Terminal – Polish and English language versions

7. EIA for the Breakwater – Polish and English language versions

8. EIA for the Jetty – Polish and English language versions

9. EIA for the Pipeline – Polish and English language versions

10. EIA for dredging at the Breakwater – Polish and English language versions

11. EIA for dredging at the Jetty – Polish and English language versions

12. “Memorandum“ (assessment of accumulated impact on environment exerted by the Terminal, the Breakwater and the Jetty) – Polish and English language versions

Project Sponsors published the information (on websites and in the local press) on the availability of the Disclosure Package pursuant to the provisions for disclosing information described in Annex A hereto. Within 60 days of the Disclosure Package publication, stakeholders had an opportunity to ask questions and raise comments on the Disclosure Package content via the Inquiry / complaint form (Annex B) which could be submitted via the e-mail, post or into drop boxes located at the Disclosure sites (Table A.1) .

Public Disclosure Sites

The Disclosure Package was made available as a hard copy in Świnoujście and Warszów. The documents were accessible in a hard copy in the locations specified in Table A-1 below.

Table A-1. Disclosure Package Availability Sites (in the period of 60 days in 2010/2011) City / street / place Opening hours Contact personŚwinoujścieMunicipal Culture Hall in Świnoujścieul. Wojska Polskiego 1/1phone (fax) (091) 321-59-49

ŚwinoujścieMunicipal Culture Hall branch no. 2 in Warszówul. Sosnowa 1872-602 Świnoujście

Mon-Fri: 12:00pm-8:00pmSat: 12:00pm-4:00pmSun: closed

Mon-Fri: 12:00pm-8:00pmSat: 12:00pm-4:00pmSun: closed

Mr Andrzej GrzechowskiActing Director of the Municipal Culture HallPhone 091- 327-87-55

Ms Bożena RogowskaManager of the Municipal Culture Hall branchPhone: 091 321 52 02

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AhlbeckTown HallGemeinde Ostseebad HeringsdorfKurparkstraße4

Seebad 17419 Ahlbeck

Disclosure Package is available at http://en.polskielng.pl/en/terminal-a-srodowisko/ and also at http://en.gaz-system.pl/terminal-lng/raporty-eboir/

It is the intention of Project Sponsors to transparently inform about the LNG Terminal Project and to conduct dialogue with Project stakeholders. Consistently with this approach, the objective of making the Disclosure Package accessible is to:

Provide information to local communities about the schedule and scope of planned works, along with presentation of methods of acquiring information and feedback on the works performed;

Publicize Sponsors’ commitment to best practice implementation in the domains of environment protection and in work safety of personnel and subcontractors;

Publicize the procedure of lodging questions, complaints, requests and grievances for their fair consideration and response to the stakeholders.

4.1 ADDITIONAL INFORMATION AND EDUCATIONAL ACTIVITY

THE EUROPEAN LNG TRAINING CENTRE In March 2011, the European LNG Training Centre was established as a joint initiative of Polskie LNG and two recognized Polish Universities - Maritime University of Szczecin and AGH University of Science and

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Technology in Cracow. This is the first Centre of this kind in our part of the continent. It is also the best equipped lab in Europe designed for learning about maintenance and operation of LNG terminals and one of the most modern in the world. It offers 4 top-of-the-range simulators.The Centre is authorized to issue all necessary certificates for LNG terminals’ operations personnel. The qualifications acquired during the studies at the Centre open the doors to the graduates’ future international career in this industry.

Sponsors of individual Project components continuously maintain working relationships with representatives of mass media, and information updates on Project implementation are published in dedicated LNG terminal websites of particular sponsors.

Furthermore, the Project Sponsors (Polskie LNG, Szczecin and Świnoujście Seaports Authority, Szczecin Maritime Office, and GAZ-SYSTEM) provide information on Project history and progress, either on their websites in the form of press releases or at press conferences.

In addition to the activities listed above, various leaflets and information folders as well as visualizations and presentations of the Project and LNG technology were developed.

Disclosure of information about the Project will allow all stakeholders to learn and comprehend all risks and environmental impact of the Project, as well as to acquire information on all advantages and benefits of the Project implementation.

In order to ensure transparency and accessibility of information about progress of the LNG Terminal Project the Project Sponsors shall be involved in communication activities during all phases, covering preparatory works, construction and operation, as described in Table A-2 below.

Table A- 2 Communication strategy

STAKEHOLDERS COMMUNICATION STRATEGY DURATION

Local community – residents of municipalities in which Project elements are located

Access to Disclosure Package available at http://en.polskielng.pl/en/terminal-a-srodowisko/

Press releases on company website.

Information and articles dedicated to environment and safety aspects of the Project in local and regional media,

Terminal newsletter distributed to Świnoujście citizens.

Leaflets and folders containing information on the Project.

CLO’s mailbox: [email protected]

Support for local initiatives for the development of Świnoujście and its citizens.

During entire Project lifecycle

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Organization of educational and information campaigns addressing the LNG Terminal and technology.

Owners and users of land on which the Project is located.

Access to Disclosure Package available at http://en.polskielng.pl/en/terminal-a-srodowisko/

Press releases on company website.

Information and articles dedicated to environment and safety aspects of the Project in local and regional media,

Terminal newsletter distributed to Świnoujście citizens.

Leaflets and folders containing information on the Project.

CLO’s mailbox: [email protected]

Support for local initiatives for the development of Świnoujście and its citizens.

Organization of educational and information campaigns addressing the LNG Terminal and technology.

During entire Project lifecycle

NGO and local community groups, including fishermen.

Access to Disclosure Package available at http://en.polskielng.pl/en/terminal-a-srodowisko/

Press releases on company website.

Information and articles dedicated to environment and safety aspects of the Project in local and regional media,

Terminal newsletter distributed to Świnoujście citizens.

Leaflets and folders containing information on the Project.

CLO’s mailbox: [email protected]

Support for local initiatives for the development of Świnoujście and its citizens.

Organization of educational and information campaigns addressing the LNG Terminal and technology.

Meeting with local fishermen under Social Dialogue project.

During entire Project lifecycle

Local national and self-government authorities

Access to Disclosure Package available at http://en.polskielng.pl/en/terminal-a-srodowisko/

Consultation meetings – information, exchange of documents and correspondence concerning the Project

During entire Project lifecycle

National administration Official correspondence Consultation meetings –

During entire

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offices information, exchange of documents and correspondence concerning the Project

Project lifecycle

International stakeholders

Access to Disclosure Package available at http://en.polskielng.pl/en/terminal-a-srodowisko/ in English language version

Leaflets and folders containing information on the Project in English language version

Project Sponsors’ websites in English language version .

CLO’s mailbox: [email protected]

During entire Project lifecycle

Public service organizations

Correspondence and direct meetings

Access to Disclosure Package available at http://en.polskielng.pl/en/terminal-a-srodowisko/

During entire Project lifecycle

Mass media On-going cooperaiton with local and nation-wide media.

Press releases and cooperation in preparation of publications on the Project.

Organization of meetings, press conferences and press breakfasts.

CLO’s mailbox: [email protected]

During entire Project lifecycle

Contractors and subcontractors

Correspondence and direct meetings

During entire Project lifecycle

Staff and Personnel Pursuant to Sponsors’ internal communication rules and procedures

During entire Project lifecycle

In addition to the activities presented in Table A-2, the following information activities are planned with regard to the Świnoujście–Szczecin high-pressure pipeline section:

Table A-3 Communication strategy for the Świnoujście–Szczecin gas transmission pipeline (without the LNG Terminal connecting pipeline section)

Planned activities DeadlinesProduction of a documentary film about the Świnoujście-Szczecin gas pipeline to be publicized on the company website

March – May 2013

Grand opening of the Świnoujście-Szczecin gas pipeline

September/October 2013

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4.2 PUBLIC DISCLOSURE AND FEEDBACK MECHANISM FOR THE GERMAN SIDE

Public Disclosure and Feedback MechanismAs described in Section 3.5 above, no formal transboundary proceedings for the LNG Project were required by RDOŚ, the competent authority for the local EIAs. However, in compliance with best international practice, the LNG Project Sponsors disclosed non-technical summary containing the NTS and the SEP documents in German language version on the Project website11 and a hardcopy was available in the publicly accessible location in Ahlbeck12 (Heringsdorf Municipality) across the border from Świnoujście: Gemeinde Ostseebad Heringsdorf, Kurparkstraße 4, Seebad Ahlbeck 17419.

4.3 INFORMATION CAMPAIGN SCHEDULE

The Disclosure Package was made available on 16 November 2010 and comments and questions were accepted for the subsequent 60 days. When the public review period was closed, comments submitted by means of inquiry / complaint form described in item 4.4 were accepted by the Community Liaison Officer (CLO).

The CLO is responsible for maintaining an up-to-date schedule of stakeholder engagement activities planned for the Project.

4.4 GRIEVANCE MECHANISM

The Project Sponsors implemented a mechanism for handling inquiries and grievances in order to ensure responses to all issues and grievances, in particular those relating to stakeholders and municipalities where the Project is being developed. With respect to the Project in question, the said procedure will additionally involve:

Project information available at a separate webpage: http://en.polskielng.pl/nc/terminal-a-srodowisko/ along with a link to the inquiry / complaint form.

General Project information brochure containing the description, phases of implementation and the grievance lodging mechanism.

Community Liaison Officer’s contact data indicated in all information materials and webpages to provide easy access to relevant information on the Project.

Project Sponsors have designated a Community Liaison Officer (CLO) responsible for advising local communities on Project progress and issues of public interest.

The CLO is the key person delegated for maintaining relations with local community and coordinating the said issues on behalf of all Project sponsors involved, i.e. PLNG/GAZ-SYSTEM, Szczecin and Świnoujście Seaports Authority, and Maritime Office Szczecin.

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The CLO will also be responsible for advising the stakeholders and Contractors about the grievance mechanism.

Grievance MechanismThe CLO shall keep a register of all comments, complaints and suggestions received. Furthermore the CLO shall run a record of grievance mechanism, coordinate the responses to inquiries and monitor the performance. Grievances shall be responded to within 10 working days following the receipt. All inquiries relating to the Project are recorded and analysed.

An inquiry / complaint form template is enclosed in Annex B. This form, or any other written format, can be used by the stakeholders for submitting questions, comments, suggestions or grievances.

5 RESOURCES AND RESPONSIBILITIES FOR SEP IMPLEMENTATION

The Stakeholder Engagement and the Grievance Mechanism for the Project are managed by the Community Liaison Officer (CLO). The contact details of CLO are:

COMMUNITY LIAISON OFFICERAleksandra [email protected] +48 22 590 84 17mobile + 48 668 339 537_____________________________http://www.polskielng.pl/

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6 ANNEXES

6.1 A: LIST OF STAKEHOLDERS

6.2 B: INQUIRY / COMPLAINT FORM TEMPLATE