stakeholder engagement plan€¦ · 2019-10-30 · stakeholder engagement plan originally...
TRANSCRIPT
STAKEHOLDER ENGAGEMENT
PLAN
AL RAJEF WIND FARM PROJECT
October 30, 2019
ARWF-O&M-Stakeholder Engagement Plan-Rev00 2
RESPONSIBILITIES
DATE NAME FUNCTION
Elaboration 30 Oct 2019 Patricia Gimenez Senior Environmental & Social Specialist
Validation 12 Nov 2019 Daniel Lancha Head of Delivery & Operations
Approval 12 Nov 2019 Daniel Lancha Head of Delivery & Operations
REVISION HISTORY
VERSION DATE AUTHOR COMMENTS
00 30 Oct 2019 Patricia Gimenez First issue
ARWF-O&M-Stakeholder Engagement Plan-Rev00 3
ACRONYMS
ARWF Al Rajef Wind Farm
Asl above sea level
COD Commercial Operational Date
COP Communication on Progress
CLO Community Liasion Office
EBRD European Bank for Reconstruction and Development
EIA Environmental Impact Assessment
E&S Environment and Social
ESIA Environmental and Social Impact Assessment
GWRE Green Watts Renewable Energy
IFC International Finance Corporation
MOE Ministry of Environment
O&M Operations & Maintenance
QHSSE Quality, Health, Safety, Social and Environmental
SEP Stakeholder Engagement Plan
UNGC United Nations Global Compact
WTG Wind Turbine Generator
ARWF-O&M-Stakeholder Engagement Plan-Rev00 4
INDEX
1 INTRODUCTION.................................................................................................................................. 7
1.1 Project Description ........................................................................................................................ 7
1.2 Background to the SEP ................................................................................................................ 9
1.3 Purpose of this Plan ...................................................................................................................... 9
2 REGULATORY FRAMEWORK ......................................................................................................... 10
2.1 Jordanian Requirements ............................................................................................................. 10
2.2 International Requirements ......................................................................................................... 10
3 PREVIOUS STAKEHOLDER ENGAGEMENT .................................................................................. 11
3.1 Stakeholder Identification and Analysis ...................................................................................... 11
3.2 Stakeholder Engagement Planning ............................................................................................ 11
3.3 Disclosure of Information, Consultation and Participation .......................................................... 12
3.3.1 Development Stage ............................................................................................................ 12
3.3.2 Construction Stage ............................................................................................................. 13
4 PROJECT STAKEHOLDERS ............................................................................................................ 16
5 Stakeholder Engagement Program.................................................................................................... 18
5.1 Disclosure of Information ............................................................................................................ 18
5.2 Good Practice Considerations .................................................................................................... 21
6 GRIEVANCE MECHANISM ............................................................................................................... 22
6.1 Grievance Mechanism Process .................................................................................................. 22
6.1.1 STEP 1 Receiving a Grievance .......................................................................................... 23
6.1.2 STEP 2 Record the Grievance ........................................................................................... 23
6.1.3 STEP 3 Screen the Grievance ............................................................................................ 24
6.1.4 STEP 4 Acknowledge the Grievance.................................................................................. 24
6.1.5 STEP 5 Investigate the Grievance...................................................................................... 24
6.1.6 STEP 6 Acting on the Grievance ........................................................................................ 25
6.1.7 STEP 7 Close Out & Follow up ........................................................................................... 25
6.2 Good Practice Considerations .................................................................................................... 25
7 RESOURCES & RESPONSIBILITIES ............................................................................................... 27
7.1 Community Liaison Office ........................................................................................................... 27
7.2 Development Coordinator & Social Specialist ............................................................................ 28
7.3 Grievance Recipients .................................................................................................................. 28
7.4 Corporate QHSE Team .............................................................................................................. 29
7.5 O&M Team .................................................................................................................................. 29
7.6 Senior and Executive Management ............................................................................................ 29
ARWF-O&M-Stakeholder Engagement Plan-Rev00 5
7.7 Identified Stakeholders ............................................................................................................... 30
7.7.1 Members of the Identified Local Communities ................................................................... 30
7.7.2 Interest based Stakeholders ............................................................................................... 30
7.7.3 Participatory Stakeholders .................................................................................................. 30
7.7.4 Internal Stakeholders .......................................................................................................... 30
8 MONITORING AND REPORTING ..................................................................................................... 31
8.1 Monitoring and Auditing .............................................................................................................. 31
8.2 Reporting .................................................................................................................................... 31
ANNEX 1 – PROJECT GRIEVANCE FORM .............................................................................................. 33
ANNEX 2 – PROJECT GRIEVANCE LOG ................................................................................................. 36
ANNEX 3 – PROJECT GRIEVANCE CLOSEOUT FORM ......................................................................... 38
ANNEX 4 – CLO ENGAGEMENT ACTIVITIES LOG ................................................................................. 41
ARWF-O&M-Stakeholder Engagement Plan-Rev00 6
INDEX OF TABLES
Table 1 Main Technical Project Characteristics ........................................................................................... 8
Table 2 Prior Identified Stakeholder Groups .............................................................................................. 11
Table 3 Prior Identified Stakeholder Groups and Communication Methods .............................................. 12
Table 4 Disclosure of Information, Consultation and Participation during Development Stage ................. 13
Table 5 Identified Stakeholder Groups ....................................................................................................... 17
Table 6 Disclosure of Information ............................................................................................................... 20
Table 7 Good Practice Considerations for Stakeholder Engagement ........................................................ 21
Table 8 Community Liaison Office Details .................................................................................................. 23
Table 9 Grievance Level of Severity ........................................................................................................... 24
Table 10 Good Practice Considerations for Grievance Management ........................................................ 26
Table 11 Good Practice Considerations for Participatory Monitoring......................................................... 31
INDEX OF FIGURES
Figure 1 Project Location .............................................................................................................................. 7
Figure 2 Project Layout ................................................................................................................................. 8
Figure 3 Identified Stakeholder Groups ...................................................................................................... 16
Figure 4 Grievance Mechanism Process .................................................................................................... 22
ARWF-O&M-Stakeholder Engagement Plan-Rev00 7
1 INTRODUCTION
This document presents the ‘Stakeholder Engagement Plan’ (ARWF-O&M-SEP) for the Operation &
Maintenance (O&M) phase of the Al Rajef 86.1MW Wind Farm (the ‘Project’), building up on the
Stakeholder Engagement Plan originally developed by ECO Consult during the Environmental and Social
Impact Assessment (ESIA) stage1.
1.1 Project Description
The Project is located near the village of Al Rajef in the Ma'an Governorate, approximately 220km south
of Amman and 100 km north of Aqaba, in the Hashemite Kingdom of Jordan. The Project is located within
a hilly, sandy and rocky area expanding over 850 hectares of leased lands on the tip of Southern Mountains
or Sharah highlands with an approximate elevation of 1,550 to 1,700m above sea level (asl).
FIGURE 1 PROJECT LOCATION
The Project consists of 41 Wind Turbine Generators (WTGs) with associated underground cables to the
substation and with a network of over 28km of access roads. The nearest settlements are: (i) Al Rajef and
Dlaghah & Rassees both of which are located on the western border of the Project site, (ii) Taybeh which
is located around 3km to the north of the Project site and (iii) Fardakh and Sadaqah located to the eastern
borders of the Project site at 2.5km and 1.5km respectively. Herding activities from locals and Bedouins
continue to take place across the Project lands during the O&M phase.
The following figure depicts the location of all 41 WTGs, the boundaries of the Project’s leased lands, the
access road and the overhead line as well as the nearest villages.
1 Al-Rajef Wind Power Project – Draft SEP in English, Rev 0, 4 May 2016
Project
Location
ARWF-O&M-Stakeholder Engagement Plan-Rev00 8
FIGURE 2 PROJECT LAYOUT
The main technical characteristics of the Project are presented in the following table:
Main Technical Characteristics
Turbines make & wind class 41 x G114 2.1MW, Siemens Gamesa III A
Estimated Energy Output 271 GWh per year
Turbine generator type Doubly fed induction, 4 poles
Tower height 80 m
Length of the blade 56 m
Turbine output voltage 33 KV (Gen is 690 V)
Electrical Interconnection 132kV
Substation Step-up Transformer 2 x 33/132kV 80MVA
EPC Contract Turnkey
EPC & OM Contractor Siemens Gamesa & Elecnor
TABLE 1 MAIN TECHNICAL PROJECT CHARACTERISTICS
The Project achieved Commercial Operational Date (COD) on the 30th October 2018. The Project is
estimated to avoid over 160,000 tons of CO2 emissions per year and save over 380,000 m3 of water per
year that would have otherwise been materialised through conventional sources of power generation. The
Dhlaghah &
Rassees
Fardhakh
Sadaqah
Al Rajef
Taybeh
ARWF-O&M-Stakeholder Engagement Plan-Rev00 9
estimated energy output is estimate to account for energy demand of over 53,000 average Jordanian
households per year. In fact, the installed capacity represents almost 15 per cent of the contribution towards
the National Wind Energy target of 600MW of generation capacity by 2020 as per Master Strategy of
Energy Sector in Jordan (2007-2020), enabling the national power sector diversification away from its
current near full dependence on thermal generation fuelled by imported oil and gas.
The Project has been developed by Jordan Green Watts Renewable Energy (GWRE) LLC (the Project
Company’) which is 100 per cent owned by Alcazar Energy. Project financing was provided by: European
Bank for Reconstruction and Development (EBRD), PROPARCO and DEG. The Power Purchase
Agreement (PPA) with the Ministry of Energy and Mineral Resources (MEMR) is valid for 20 years and the
National Electrical Power Company (NEPCO) is the off taker of the power produced.
The Project is classified Category A as per the EBRD Environmental and Social Policy (2014) and as such
it was subject to a comprehensive ESIA developed in line with EBRD Performance Requirements (2014)
as well as the International Finance Corporation (IFC) Performance Standards on Environmental and
Social (E&S) Sustainability (2012), and Jordanian legislative requirements. Key impacts and risks
considered included biodiversity, culture heritage, land acquisition and use, and workers and community
health, safety and security, and the ESIA concluded that environmental and social impacts are site specific
and can be mitigated. In addition, an Environmental and Social Action Plan (ESAP) was developed to
monitor that the Project is constructed and operated in line with the applicable legal framework. As an
example and given the proximity of the Wind Farm to the Rift Valley flyway, an Avifauna Monitoring and
Shutdown on-demand Protocol is currently being implemented to identify individuals of ‘Priority Bird’
populations and/or flocks of non-Priority Migratory Soaring Birds (MSB) species at risk of collision and
enable the temporary shutdown of specific WTGs.
1.2 Background to the SEP
The Stakeholder Engagement Plan during the ESIA stage was developed by an independent specialised
consultant, ECO Consult, in line with EBRD Performance Requirements. The Stakeholder Engagement
Plan formed part of the ESIA disclosure package which was developed in both Arabic and English
languages and disclosed to the public in May 2016 prior to the construction of the Project. No comments
were received during the 60-day disclosure period. The ESIA disclosure package can be found in the
following link:
https://www.ebrd.com/work-with-us/projects/esia/al-rajef-wind-farm.html
1.3 Purpose of this Plan
This ‘Stakeholder Engagement Plan’ presents a high-level summary of the stakeholder engagement
activates conducted during the development and construction stages of the Project as well as:
- Outlines the systematic approach that has been and will continue to be followed to maintain a
constructive, strong and responsive relationship and for effective engagement with the Project
stakeholders during the O&M phase, in particular with the ‘identified local communities’;
- Presents the process and means for disclosing meaningful and relevant environmental and social
information to the different Project stakeholders; and
- Describes the grievance mechanism, including the means for raising a Project-related grievance
for identified communities and other stakeholders as well as the evaluation and management
process.
The ‘Stakeholder Engagement Plan’ is intended to follow best practice2 and to be periodically reviewed
and updated as considered applicable based on the Project’s environmental and social performance.
2 IFC publication “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets”, 2007
ARWF-O&M-Stakeholder Engagement Plan-Rev00 10
2 REGULATORY FRAMEWORK
2.1 Jordanian Requirements
The requirements of national law with respect to stakeholder engagement for public information and
consultation are related to those under the ‘Environmental Impact Assessment (EIA) Regulation No. 37 of
2005’ by the Ministry of Environment (MOE), which in general identifies the overall process, requirements
and content for EIA studies in Jordan. The EIA Regulation requires:
- That a scoping session with potentially affected stakeholders is held at the onset of comprehensive
EIA studies in order to inform them about the Project and allow them to participate in the EIA
process; and
- That the outcomes of the EIA are announced to the public and stakeholders in a manner that the
MORE deems appropriate as per the type and scale of the Project.
There is no further national legislation requirements for stakeholder engagement during subsequent
phases of projects such as construction, commissioning or operation.
2.2 International Requirements
The EBRD Environmental and Social Policy (2014), applicable to the Project since it is EBRD-funded
project:
- Outlines how EBRD will assess and monitor the environmental and social risks and impacts of its
projects;
- Sets minimum requirements for managing environmental and social impacts and risks caused by
EBRD financed projects throughout the lifetime of the projects; and
- Defines the respective roles and responsibilities of both EBRD and its clients in designing,
implementing and operating projects in accordance with this Policy.
The requirements for stakeholder engagement in line with best international practice are described in
“EBRD Performance Requirement 10: Information Disclosure and Stakeholder Engagement” as follows:
- Stakeholder engagement will involve the following elements: stakeholder identification and
analysis, stakeholder engagement planning, disclosure of information, consultation, and
participation, grievance mechanism and ongoing reporting to relevant stakeholders;
- Clients will conduct stakeholder engagement on the basis of providing local communities that are
directly affected by the project and other relevant stakeholders with access to timely, relevant,
understandable and accessible information, in a culturally appropriate manner, and free of
manipulation, interference, coercion and intimidation;
- The nature and frequency of stakeholder engagement will be proportionate to the nature and scale
of the project and its potential adverse impacts on the affected communities, the sensitivity of the
environment and the level of public interest. In order to tailor the engagement to the specifics of
the client and the project, it is essential that clients identify stakeholders as outlined below. The
requirements of national law with respect to public information and consultation, including those
laws implementing host country obligations under international law, must always be met; and
- The client will define clear roles, responsibilities, and authority as well as designate specific
personnel to be responsible for the implementation and monitoring of stakeholder engagement
activities.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 11
3 PREVIOUS STAKEHOLDER ENGAGEMENT
3.1 Stakeholder Identification and Analysis
Stakeholder groups were identified in line with the EIA Regulation No.37 of 2005 as outlined in Section 5.1
of the “Al-Rajef Wind Power Project – Draft SEP in English, Rev 0, 4 May 2016” developed by ECO Consult
and summarised as follows:
Classification Stakeholder Groups
Stakeholders who may be directly
or indirectly affected by the Project
Villages in the vicinity of the Project (i.e. Al Rajef, Taybeh, Dlaghah & Rassees, Fardakh,
Sadaqah), also identified as ‘Affected Local Communities’ in the ESIA
Women groups
Nomadic groups
Stakeholders who may participate
in the implementation of the
Project
Investor and Project Lenders
National Electricity Power Company (NEPCO)
Local contractors and its employees
Vehicles, machinery and equipment suppliers
Stakeholders who may have a
possibility to influence and make
decisions on the implementation of
the Project
Central Government and International Agencies: MoENV, Ministry of Public Works and
Housing (MPWH), Traffic Department, Ministry of Tourism and Antiquities, United Nations
Educational, Scientific and Cultural Organisation (UNESCO), etc
Local Governmental Entities: Petra Development and Tourism and Region Authority
(PDTRA), Petra and Wadi Mousa Water Directorate, Department of Antiquities Ma’an, etc
Non-Governmental Organisations (NGOs): BirdLife International, Royal Society for
Conservation of Nature (RSCN)
Stakeholders who are not affected
by the Project but may be
interested in the implementation of
the Project
National Governmental Entities: Ministry of Labor, Ministry of Municipal Affairs, Ministry of
Energy and Mineral Resources (MEMR), Ministry of Health, Ministry of Water and
Irrigation, Royal Jordanian Air Force, etc
NGOs: Jordan Engineers Association, EDAMA, Jordan Environment Society, National
Environment and Wildlife Society (NEWS), The Jordan Society for Sustainable
Development, Renewable Energy and Environment Investment Society
TABLE 2 PRIOR IDENTIFIED STAKEHOLDER GROUPS
3.2 Stakeholder Engagement Planning
Communication methods and tools were identified for engagement with the above identified stakeholder
groups as outlined in Section 5.3 of the “Al-Rajef Wind Power Project – Draft SEP in English, Rev 0, 4 May
2016” developed by ECO Consult. The level of engagement planned varied between different stakeholder
groups and intended to provide information on variety of project related topics including but not limited to:
construction activities, implementation of environmental and social management measures, grievance
mechanism, employment and procurement opportunities, project timelines, social investment initiatives,
etc. The proposed communication methods and tools are presented below for each stakeholder group:
Classification Stakeholder Groups Communication Methods and Tools
Stakeholders who may
be directly or indirectly
affected by the Project
Villages in the vicinity of the Project (i.e. Al Rajef, Taybeh,
Dlaghah & Rassees, Fardakh, Sadaqah)
Group meetings
Bulletin boards and Project leaflets
Disclosure of documents
Developer’s website
Women groups Group meetings
Bulletin boards and Project leaflets
ARWF-O&M-Stakeholder Engagement Plan-Rev00 12
Classification Stakeholder Groups Communication Methods and Tools
Disclosure of documents
Developer’s website
Nomadic groups Group meetings
Bulletin boards and Project leaflets
Stakeholders who may
participate in the
implementation of the
Project
Investor and Project Lenders Official meetings
Official correspondence
NEPCO Official meetings
Official correspondence
Local contractors and its employees
Internal meetings
Developer’s website
Project leaflets
Vehicles, machinery and equipment suppliers Internal meetings
Developer’s website
Stakeholders who may
have a possibility to
influence and make
decisions on the
implementation of the
Project
Central Government and International Agencies: MoENV,
MPWH, Traffic Department, Ministry of Tourism and
Antiquities, UNESCO
Internal meetings
Official correspondence
Local Governmental Entities: PDTRA, Petra and Wadi
Mousa Water Directorate, Department of Antiquities Ma’an,
Internal meetings
Official correspondence
NGOs: BirdLife International, RSCN Internal meetings
Official correspondence
Stakeholders who are
not affected by the
Project but may be
interested in the
implementation of the
Project
National Governmental Entities: Ministry of Labor, Ministry
of Municipal Affairs, MEMR, Ministry of Health, Ministry of
Water and Irrigation, Royal Jordanian Air Force, etc
Internal meetings
Official correspondence
NGOs: Jordan Engineers Association, EDAMA, Jordan
Environment Society, NEWS, The Jordan Society for
Sustainable Development, Renewable Energy and
Environment Investment Society
Internal meetings
Official correspondence
TABLE 3 PRIOR IDENTIFIED STAKEHOLDER GROUPS AND COMMUNICATION METHODS
3.3 Disclosure of Information, Consultation and Participation
3.3.1 Development Stage
As per the Jordanian legislation requirements and international best practice, stakeholder engagement
activities were initiated at an early stage in the Project and formed an integral part of the assessment of
environmental and social risks for the Project as part of the ESIA process.
Stakeholder engagement with landowners in the project area started as early as 2011 with the purpose of
introducing the potential projects as well as evaluating the potential for land leasing across the project site.
These meetings were informal and hence not documented.
A summary of the main stakeholder engagement activities conducted prior to construction commencing
are provided in the following table:
Engagement
Activity Date Purpose and Details of Stakeholder Engagement Activity
Scoping
Session
3rd September
2013
Scoping session was held in line with EIA Regulation No.37 of 2005, introducing the
Project, methodology of the ESIA and anticipated E&S impacts. Stakeholders were
identified by the ESIA team and the MOE including national governmental entities, local
governmental entities, NGOs and local community representatives. The main topics
ARWF-O&M-Stakeholder Engagement Plan-Rev00 13
Engagement
Activity Date Purpose and Details of Stakeholder Engagement Activity
raised by stakeholders related to landscape and visual, avifauna, infrastructure and
utilities, occupational health and safety, community health and safety and socio-
economic development. Outcomes presented in detail in the ESIA.
Onsite
Consultation
with Local
Communities
June 2013
Consultations with local community members who undertake agriculture and grazing
activities within the Project site with the purpose of understanding the activities being
undertaken onsite and introducing the Project and its potential associated impacts on
their activities (i.e. land use, shadow flicker, noise). Outcomes presented in detail in the
ESIA.
Onsite
Consultation
with Nomads
August 2015
Consultations with nomads who practice herding activities within the Project area with
the purpose of understanding the activities being undertaken onsite, the socioeconomic
conditions of the nomadic groups and introducing the Project and its potential
associated impacts on their activities (i.e. land use, shadow flicker, noise).
Consultations were gender specific. Outcomes presented in detail in the ESIA.
Specialist
Consultation
April 2012 to
November 2015
Various stakeholder consultations took place during the ESIA process with a number of
governmental entities including MoENV, Ministry of Agriculture, Ministry of Municipal
Affairs, Department of Antiquities, Civil Aviation Regulatory Commission (CARC),
PDTRA, RJAF, with regards to land use, archaeology and cultural heritage, geology
and hydrogeology, infrastructure and utilities, socio-economic. Outcomes presented in
detail in the ESIA.
Disclosure
Session to
Local
Communities
30th March 2016
Disclosure session for local community representatives from nearest villages (i.e. Al
Rajef, Taybeh, Dlaghah & Rassees, Fardakh, Sdaqah) to present the outcomes and
conclusions of the ESIA study and in particular the management and monitoring
measures identified. The main topics presented related to landuse, avifauna,
community health and safety and socio-economic development. Outcomes presented in
detail in the ESIA.
TABLE 4 DISCLOSURE OF INFORMATION, CONSULTATION AND PARTICIPATION DURING DEVELOPMENT STAGE
3.3.2 Construction Stage
During the construction stage, there were two main mechanisms for stakeholder engagement developed
and implemented being the establishment of the community grievance mechanism managed by the
Community Liasion Desk (CLD) and the establishment of the Local Community Committee (LCC) who
managed the process for local employment and procurement for the Project.
3.3.2.1 Community Grievance Mechanism and Community Liaison Desk
The Community Liasion Desk was established in November 2016 and comprised of the following members:
- Salem Ali Faraj Al-Rawajfeh, Project Liaison Officer;
- Ibrahim Hwaishel Al-Rawajfeh, Public Relations Officer;
- Yaser Ibrahim Hwaishel Al-Rawajfeh, Public Relations Officer Assistant;
- Isra Mohammad Nsoor, Community Liaison Officer;
- Foud Qasem Mohammad Khalifeh, Community Liaison Officer; and
- Loay Mohammad Ahmad Alkalaifeh, Community Liaison Officer.
The Community Liasion Desk was responsible for a variety of tasks, for which they received specific training
by ECO Consult, including:
- Disclosure of documentation such as the Project layout, ESIA, Non-Technical Summary (NYTS)
of the ESIA, Stakeholder Engagement Plan, land use maps, Project timeline, etc;
- Record keeping of meetings, consultation events and/or focus groups including dates, venues,
attendees, objectives, outcomes and any significant issues raised within an electronic and hard
copy filing system for all external relations activities;
ARWF-O&M-Stakeholder Engagement Plan-Rev00 14
- Implementation of the Project’s community grievance mechanism informing the local communities
about the grievance process in the course of its community engagement activities and reporting
regularly to the public on its implementation. The mechanism was managed through direct and
ongoing engagement with the Project team and the local communities. A grievance box was placed
at the CLD office located in Al Rajef village were grievance forms were also available, in the case
that any complainant would prefer to raise a complaint anonymously.
A Grievance Log was maintained for the Project during the construction phase as part of the Quality,
Health, Safety, Social and Environmental (QHSSE) Statistics recorded combining both grievances
received from members of the local communities as well as workers from the Contractor and
subcontractors’ teams. The grievances received either in writing or verbally were recorded in the log,
reviewed and evaluated, resolution proposed, responsibilities assigned, and actions addressed timely and
accordingly.
As a matter of summary, 36 grievances were recorded since the beginning of the construction phase until
the commencement of operations, 31 of which from members of the local communities. Twenty-four (24)
of the grievances from members of the local communities related to construction works allegedly damaging
crops in adjacent plots, trespassing by the Project subcontractors on non-Project leased land, disposal of
soil excess materials and waste on non-Project leased land and temporary closure of secondary roads.
Seven (7) grievances from members of the local communities related to concerns or complaints regarding
the process of local employment and procurement of vehicles, machinery, equipment and services. All
grievances were reviewed, evaluated, addressed and closed (even though not always to the satisfaction
of the complainant), with the exception of one grievance which was escalated to a court case and therefore
remain open.
3.3.2.2 Local Employment and Procurement and Local Community Committee
The Local Community Committee was established in June 2017 and comprised of the following members:
- Mohammad Ahmad Khalifeh, Local Community Committee member, natural fromTaybeh;
- Abdullah Khaleel Khulifat, Local Community Committee member, natural from Taybeh;
- Husieen Hmood Rawajfeh, Local Community Committee member, natural from Al Rajef; and
- Khlaid Khlaf Rawajfeh, Local Community Committee member, natural from Al Rajef.
The Local Community Committee was established with the goal of enabling an impartial mechanism for
the fair, equitable and transparent allocation of local employment and construction work packages during
the construction phase of the Project. The Local Community Committee was responsible for facilitating the
process and maximising the outcome of local employment and procurement including:
- Greeting the members of the ‘affected local communities’ at the CLD office and explaining the
process for local employment and procurement established for the Project;
- Prompting the individuals to filling in the application form either for employment or procurement of
goods and services, duly registering the completed application forms and maintaining records
accordingly;
- Providing a unified platform for documenting and creating a database with the available resources
in terms of skills and experience as well available vehicles, equipment and machinery within the
‘affected local communities’;
- Receiving requests from the EPC Contractor with regards to needed positions and associated role
and requirements and providing suitable candidates’ CVs and contact details;
- Receiving requests from the EPC Contractor with regards to procurement needs for goods,
vehicles, machinery, equipment and services and providing suitable local suppliers;
- Maintaining and open dialogue and regular communication with the EPC Contractor
representatives with regards to application trends and any potential particular concerns raised by
the community members.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 15
Social statistics were maintained for the Project during the construction phase as part of the QHSSE
Statistics recorded listing all workers from the Contractor and subcontractors’ teams including nationality
and whether original from the ‘local communities’. As a matter of summary, 261 workers out of a total of
543 recorded were Jordanian since the beginning of the construction phase until the commencement of
operations, 156 of which were natural from the local communities. This represents a local content of over
28 per cent.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 16
4 PROJECT STAKEHOLDERS
According to IFC Performance Standard 1 on ‘Assessment and Management of Environmental and Social
Risks and Impacts’, stakeholders are defined as “persons, groups or communities external to the core
operations of a project who may be affected by the project or have interest in it. This may include
individuals, businesses, communities, local government authorities, local nongovernmental and other
institutions, and other interested or affected parties”.
The following diagram depicts the identified stakeholder groups for the O&M phase of the Project:
FIGURE 3 IDENTIFIED STAKEHOLDER GROUPS
The following table presents a more detailed description of the identified stakeholder groups for the O&M
phase of the Project:
For the purposes of the Stakeholder Engagement Plan, ‘Stakeholders’ are defined as individuals, groups
or communities who may have an interest in the Project or who may affect or be affected by the Project’s
activities and who have the ability to influence the Project’s financial, environmental and social
performance
ARWF-O&M-Stakeholder Engagement Plan-Rev00 17
Classification 3 Stakeholder Groups
Identified Local Communities
Stakeholders who may be directly
or indirectly, positively or
negatively, affected by the
operation of the Project
Villages in the vicinity of the Project (i.e. Al Rajef, Taybeh, Dlaghah & Rassees, Fardakh,
Sadaqah)
Legitimate stakeholder representatives i.e. elected officials, non-elected community
leaders, leaders of informal or traditional community institutions, and elders within the
identified local communities
Community Based Organisations (CBO) (i.e. Al Rajef Association, Dlaghah Charity
Association, Fardakh Charity Association for Social Development, Sadaqah Charity
Association for Social Development)
Nomadic groups, referring to nomadic tribes in the south of Jordan who travel in different
areas with no fixed residence and whose livelihood is generally goat, sheep or camel
herding
Local emergency response governmental bodies (i.e. Civil Defence, Police Department,
Healthcare Department)
Interest Based Stakeholders
Broader stakeholders who may
have ‘interests’ and/or the
possibility to influence the
implementation of the Project
during O&M phase
National Governmental Entities: MoENV, Ministry of Labor, Ministry of Municipal Affairs,
Ministry of Education, Ministry of Tourism and Antiquities
Local Governmental Entities:, Directorate of Education, Directorate of Social Development
Organisations and Associations at National level: BirdLife International, RSCN, Jordan
Engineers Association, Jordan Renewable Energy and Energy Efficiency Fund (JREEEF)
NGOs: EDAMA, Jordan Environment Society, National Environment and Wildlife Society
(NEWS), The Jordan Society for Sustainable Development, Renewable Energy and
Environment Investment Society
Media: Newspapers, local and national TV stations, social media
Internal & Participatory
Stakeholders
Stakeholders who participate in
the implementation of the Project
during O&M phase
O&M Contractor (Elecnor & Siemens Gamesa Renewable Energy) and its subcontractors
(i.e. Petrotec, Quick Intervention and other specialised contractors) – ‘Internal
Stakeholders’
Project Lenders: EBRD, PROPARCO and DEG
Shareholders for Alcazar Energy: IFC, IFC Asset Management Company, Dash ventures,
Mubadala Infrastructure Partners
NEPCO as the off taker of the power produced
MEMR as the PPA signatory
TABLE 5 IDENTIFIED STAKEHOLDER GROUPS
‘Internal Stakeholders’, including individuals and organisations who participate in the actual operations of
the Project, have been considered as stakeholders even though at the core of the Project’s operations,
since their engagement and consultation is key for the effective management of environmental and social
risks. The methods of engagement with the internal stakeholders will differ from those used for external
stakeholders.
3 Classification as per IFC Guidance Note 1 Assessment and Management of Environmental and Social Risks and Impacts, GN95
ARWF-O&M-Stakeholder Engagement Plan-Rev00 18
5 STAKEHOLDER ENGAGEMENT PROGRAM
Stakeholder engagement is critical to maintaining a constructive and responsive relationship not only with
the ‘identified local communities’ but also with wider stakeholder groups and to ensuring the continuation
of the ‘environmental & social license to operate’ for the Project.
Stakeholder engagement forms an integral part of Alcazar Energy’s QHSSE Management System
(QHSSEMS) as well as the Project-specific QHSSEMS. The stakeholder engagement program presented
herein has been developed specifically for the O&M phase of the Project and is intended to be
commensurate with the potential environmental and social risks and opportunities arising from the
operation of the Project as well as with the sensitivity of the environment and the level of public interest.
5.1 Disclosure of Information
The Project Company will continue to provide the Identified Local Communities throughout the O&M phase
with access to relevant information on:
- The purpose, nature, scale and timelines of the Project;
- Potential environmental & social risks and impacts on such communities and the relevant
mitigation measures being implemented to manage those; and
- The stakeholder engagement process including the grievance mechanism.
In addition, the Project Company will communicate any material changes to the Project which may result
in additional adverse impacts and any particular issues or topics that may have been identified through the
grievance mechanism as a concern to those Identified Local Communities as a means to further engage
and involve those Communities in the environmental and social performance of the Project.
The Project Company will also regularly disclose information on the management of environmental and
social impacts, the implementation of the Project-specific QHSSEMS and the compliance against the ESAP
and legal framework as well as the opportunities for performance improvement and lessons learned
through an annual Corporate Sustainability Report.
The following table presents further information that is to be disclosed to the Identified Local Communities
and the broader Stakeholder groups together with timelines and frequency of communication as well as
responsibilities within the Project and company structure.
Information disclosure involves delivering information about the Project, its risks, impacts and
opportunities to the Identified Local Communities and ensuring access to such information by other
identified Stakeholder groups in a manner that is accurate, timely and understandable, which in return will
facilitate future engagement and the resolution of potential grievances
ARWF-O&M-Stakeholder Engagement Plan-Rev00
Stakeholder Group Document Subject to Disclosure Method of Disclosure Timing and Frequency Responsibility
Identified Local
Communities - Al Rajef,
Taybeh, Dlaghah &
Rassees, Fardakh, Sadaqah
including Local Community
representatives and CBOs
✓ ESIA, Non-technical Summary (NTS) of the ESIA,
ESAP and Updated Stakeholder Engagement Plan
✓ Avifauna Monitoring and Shutdown on Demand
Protocol
✓ Social Development and Investment Program
✓ Grievance Mechanism related documentation:
Grievance mechanism simplified procedure in Arabic,
Grievance box and grievance forms and Updated
Grievance Log
✓ Project brochure and/or poster
✓ Hard copy of all documents available at the
CLO office in Al Rajef village
✓ Grievance mechanism simplified procedure
in Arabic available at the CLO office
✓ Grievance box and grievance forms (in
English and Arabic) available outside the
CLO office to be used in case of anonymity
✓ Updated Grievance Log available at the CLO
office
✓ Project brochure and/or poster available at
the CLO office and at the CBOs in Al Rajef,
Dlaghah, Fardakh, Sadaqah and Petra
Association for Social Development
✓ ESIA, NTS, Updated SEP and Project
brochure and/or poster available on Alcazar
Energy’s website
Continually available with the
most updated version of all
documents – Frequency of
checks semi-annually for all
documents and monthly for
grievance related
documentation
Continually available
CLO / Development
Coordinator & Social
Specialist
Corporate QHSE Team
Nomadic Groups, Local
Herders and users of the
grounds of the ARWF
Topics to be covered during information disclosure:
✓ Avifauna: Inform them not to leave animal fodder or
cattle carcasses and keep good housekeeping (not
littering), and to inform the CLO if any bird carcasses
are found across ARWF
✓ Blade & Ice Throw: Inform them of the risk of blade &
ice throw and to stay away from the WTGs as far as
possible in order to minimise the associated
community health & safety risks
✓ Noise: Inform them that the noise generated by the
WTGs when in operation is normal and increases with
wind speed and to stay away from the WTGs as far as
possible to minimise nuisance
✓ In addition they will be informed about the Project and
Grievance related documentation available within the
CLO office
Engagement with nomads, local herders and
users of the grounds of the ARWF for
information disclosure through consultation
(conversation on the ground)
Weekly, in particular during
picks in herding season and
at the beginning of the winter
season accordingly
CLO / Development
Coordinator & Social
Specialist
ARWF-O&M-Stakeholder Engagement Plan-Rev00 20
Stakeholder Group Document Subject to Disclosure Method of Disclosure Timing and Frequency Responsibility
Local emergency response
governmental bodies (i.e.
Civil Defence, Police
Department, Healthcare
Department)
Emergency Preparedness and Response Plan (EPRP)
including different potential emergency scenarios and the
level of emergency including coordination for Emergency
drills
✓ Consultation and meetings
✓ Correspondence and official letters
Once EPRP is approved and
afterwards only if there are
significant changes to the
EPRP
O&M Contractor – HSE
Manager and HSE
Assistant
National Governmental
Entities: MoENV
Semi-annual Synopsis of Avian and Bat Monitoring &
Impact Mitigation Measure Report as well as the
Operational Raw Data of avifauna monitoring
Electronic and hard-copy submission Semi-annually: in April
covering the previous autumn
and winter, in October
covering the previous spring
and summer
Development
Coordinator & Social
Specialist / QHSE Team
Project Lenders: EBRD,
PROPARCO and DEG
Project Progress Report including a review of
Environmental & Social matters arising in relation to the
Project including QHSE performance and details of any
accidents, emergencies or other material events
Annual Monitoring Report on Environmental & Social
Performance including Impact Indicators (as per EBRD
Proforma)
Electronic submission
Electronic submission
Quarterly from ‘Technical
Completion’ to ‘Financial
Completion’
Semi-annually after ‘Final
Completion’
Annually (120 days from each
31st December)
Corporate O&M Team
and QHSE Team
QHSE Team
Shareholders: IFC, IFC
Asset Management
Company, Dash ventures,
Mubadala Infrastructure
Partners
Project Progress Report including a review of
Environmental & Social matters arising in relation to the
Project including QHSE performance and details of any
accidents, emergencies or other material events
Electronic submission Monthly from Commercial
Operational Date (COD)
Corporate O&M Team
and QHSE Team
All Internal and External
Stakeholders
Corporate Sustainability Reporting including
communication on E&S performance for the ARWF
Publicly available through Corporate website
Hard copy available in English at the CLO office
Released at the end of Q1
annually – First report to be
released end of Q1 2020,
after that to be continuously
available online
Corporate QHSE Team
Development
Coordinator & Social
Specialist
TABLE 6 DISCLOSURE OF INFORMATION
ARWF-O&M-Stakeholder Engagement Plan-Rev00 21
5.2 Good Practice Considerations
As previously noted, the Project aims to follow international best practice in the management of the
Project’s environmental & social risks. In line with the recommended considerations in the IFC publication
on “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging
Markets”, the following management measures and actions have been, are or will be implemented by the
Project Company accordingly:
Good Practice Pointers4 Implemented or Committed Action by the Project Company
Managing the Transition from
Construction to Operations
A significant decrease in the workforce required towards the end of construction phase for
the Project was experienced (including that of the security team, where all employees were
from Identified Local Communities). This translated into a decrease in the number of
grievances registered as well as a reduction in the scope of work of the LCC.
Continuity is being ensured by retaining the same Project Liaison Officer and Community
Liaison Officers who have established strong relationships with stakeholders, and gradually
decreasing the size of the LCC over the first 18 months of operation.
Periodically Review and Update
Stakeholder Information and
Assessment of Stakeholder
Perceptions
The stakeholder identification and associated information will be regularly reviewed, and
updates as needed over time, especially if there are significant changes in the external
environment that may mean a new stakeholder group should be included or others
prioritised. Assessment of stakeholder perceptions are not currently planned; these may be
reconsidered should a trend on grievances express the need for it.
Integration of ongoing
stakeholder commitments into
O&M QHSEMS
Commitments for environmental and social mitigation and performance monitoring and
improvement have been considered within the Project-specific QHSSEMS for the O&M
phase to ensure the continuity of management of environmental and social risks and
impacts.
Communication of the
Emergency Response and
Preparedness Plan (EPRP)
Based on the identification of emergency scenarios as per the Project-specific EPRP for the
O&M phase, the emergency scenarios are mostly related to potential occupational health
and safety incidents (and first aid response). As such, the O&M Contractor is expected to
communicate the Project-specific EPRP with local emergency response governmental
bodies (i.e. Civil Defence, Police Department, Healthcare Department).
The emergency scenarios identified that may involve or have an impact on the larger
‘identified local communities’ are limited to Level 3 of Emergency (e.g. floods, major
structural failure, severe wind storms, severe extremes in temperature) and blade and ice
throw risk which is covered through engagement with local herders and ongoing awareness.
TABLE 7 GOOD PRACTICE CONSIDERATIONS FOR STAKEHOLDER ENGAGEMENT
4 As per IFC publication on “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets”, May 2007, Part 2, Operations.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 22
6 GRIEVANCE MECHANISM
The Grievance Mechanism presented herein describes the Project Community Grievance Procedure which
is also in line with the Corporate Grievance Mechanism Procedure (Ref: AE-QHSE-PRO-024). The Worker
Grievance Mechanism is described as part of the Project-specific QHSSE MS developed and implemented
by the Contractor (Ref: ARWF‐OM‐28082019-SOC-Worker&CommunityGrievance Mechanism-4.4-03).
The Grievance Mechanism has been in place since the establishment of the Community Liasion Office in
November 2016 at the development stage of the Project and has been an integral part of the Project’s
QHSSE Management System. The Grievance Mechanism is and continues to be a critical aspect of the
stakeholder engagement process for the Project. The Grievance Mechanism:
- provides the appropriate platform for receiving, documenting and addressing complaints promptly
and communications from external stakeholders and allowing for anonymous complaints;
- uses an understandable and transparent consultative process that is culturally appropriate, at no
cost and not impeding access to other judicial and administrative mechanisms available in Jordan
for resolution of disputes;
- is fully documented for transparency as well as to prevent the recurrence of stakeholder concerns;
- is readily accessible to the Identified Local Communities through the Community Liasion Office
and communicated through displayed posters at the Community Based Organizations (CBO); and
- is ultimately intended to capture and respond to stakeholders concerns.
6.1 Grievance Mechanism Process
The following figure presents the different steps of the grievance management:
FIGURE 4 GRIEVANCE MECHANISM PROCESS
For the purposes of the Stakeholder Engagement Plan, the Grievance Mechanism is intended to provide
well functioning procedure for receiving and addressing concerns about the Project’s environmental &
social performance from stakeholders, in particular from members of the Identified Local Communities,
whenever they may arise and facilitating resolution throughout the operational phase of the Project
ARWF-O&M-Stakeholder Engagement Plan-Rev00 23
The Grievance Mechanism is mostly implemented by the Community Liaison Office mainly through the
Project Liaison Officer (commonly referred to as CLO), who is under the responsibility of the Development
Manager, and in coordination with the Development Coordinator & Social Specialist and the Corporate
QHSE Team.
6.1.1 STEP 1 Receiving a Grievance
There are different ways in which a grievance from a stakeholder may be received such as verbal (e.g.
face to face or over the phone) or written (e.g. by letter or by email) and this may be received by different
members of the Project Company.
Grievances from members of the Identified Local Communities may most likely be received by the
Community Liaison Office. The Community Liasion Office has a dedicated telephone number, an email
and physical address where a complaints or grievance box together with forms in Arabic are available. The
contact details of the CLO and the location of the Community Liaison Office are as follows:
Project Liaison Officer Mr. Salem Al Rawajfeh
Mobile +962 775 606020
Email [email protected]
Office Location Near to Al-Rajif Secondary Boy's School, Al Rajef Village, Petra District, Ma’an Governorate
Coordinates: Latitude 30.191380 N, Longitude 35.443128 E
TABLE 8 COMMUNITY LIAISON OFFICE DETAILS
Whichever the way a grievance is received, it is the responsibility of the recipient to prompt the complainant
to complete a Project Grievance Form (see AE-QHSE-DOC-033 in Annex 1) or to complete the form on
his/her behalf should the complainant be illiterate.
Upon receiving a grievance by a complainant, the ‘direct employees’5 shall briefly explain the process and
different remaining steps to be followed as per the procedure including an ‘early’ indication on what the
appropriate actions may or may not entail in order to manage expectations of the complainant. The ‘direct
employees’ shall also ensure confidentiality of the complainant should he/she prefer to remain anonymous.
Once the form is completed, it shall be shared with the QHSE team.
Additionally, it could also occur that a member of the local community raise a concern within the Project
facilities (e.g. at the control building, substation, across the project site or outside the Project site) to
‘contracted workers’, in which case and in line with the Worker Grievance Procedure, the ‘contracted
workers’6 shall direct the individual to raise the concern through the Community Grievance Mechanism and
at the CLO office in Al Rajef. Any escalation that could lead to a situation of a Security Incident would then
be managed through the Security Management Plan or Emergency Response Plan.
6.1.2 STEP 2 Record the Grievance
All formal grievances shall be communicated to the QHSE team and recorded in the Project Grievance Log
Register (see ARWF-O&M-SOC-Grievance Log in Annex 2) and the completed Grievance Forms shall be
saved in the Project’s shared file system for record keeping purposes. In the case that the complainant
requested to remain anonymous, this should be respected accordingly within the Grievance Log.
5 ‘Direct employees’ are those engaged by the Project Company for their services (such as those of the CLO) or by Alcazar Energy. 6 ‘Contracted workers’ are those engaged through third parties, such as the Contractor or its subcontractors, to perform work related to core business processes for the operation and maintenance of the Project
ARWF-O&M-Stakeholder Engagement Plan-Rev00 24
6.1.3 STEP 3 Screen the Grievance
Grievances shall be screened and evaluated depending on the nature and the level of magnitude of the
complaint and/or the associated consequence, sensitivity of the complainants/s and the combined severity
of the complaint. Determining the level of severity of a grievance is critical in order to determine who the
grievance owner should be and how the grievance should be approached. See below table categorising
the different levels:
Severity Description Likely Grievance Owner
Level 1 The magnitude of the complaint is limited and possibly within the Project
operations and activities and the complainant/s does not belong to a
vulnerable group. The complaint may be managed at a local level through
the CLO and/or the Site Team
Community Liaison Office
and/or Development
Coordinator & Social
Specialist
Level 2 The magnitude of the complaint may go beyond the Project area of
influence and operations. The complainant/s is a respected member or
representative of the Identified Local Communities. The grievance has the
potential to be escalated beyond the Project (e.g. to the Project Lenders)
and may pose environmental & social risks if improperly managed. The
complaint may be managed at a Corporate level and coordinated by the
QHSE Team.
Corporate QHSE Team
Level 3 The magnitude of the complaint may go above and beyond the Project area
of influence and operations, may be repeated (not the first occurrence)
and/or may be irreversible. The complainant/s is a respected member or
representative of the Identified Local Communities, governmental
representative or lobbying group. The grievance has the potential to be
escalated beyond the reach of the Company (e.g. to media and social
media) posing a reputational risk to Alcazar Energy in addition to the
inherent environmental & social risks.
Senior or Executive
Management
TABLE 9 GRIEVANCE LEVEL OF SEVERITY
6.1.4 STEP 4 Acknowledge the Grievance
A grievance shall be acknowledged by the recipient and/or assigned grievance owner, within two working
days of a grievance being formally received. The communication shall be made either verbally or in written
form, depending on the preferred method of communication by outlined by the complainant in the
Grievance Form. The date of acknowledgement shall be noted in the Grievance Log accordingly.
The acknowledgement of a grievance should include a high-level summary of the understanding of the
grievance, the first steps that will be taken by the Project Company in order to address the grievance and
an estimated timeframe. The acknowledgment also provides an opportunity for the grievance owner to
request for any clarifications or additional information in relation to the grievance in question.
6.1.5 STEP 5 Investigate the Grievance
The grievance owner shall be responsible for leading and coordinating the investigation of the grievance.
The investigation may entail consulting ‘direct employees’, ‘contracted workers’ or external stakeholders
as appropriate and determined on case-by-case basis. Records of meetings, discussions, activities and
documented evidence during the investigation shall be recorded. The information gathered during the
investigation shall be analysed to assist in identifying the root cause of the grievance and evaluating
whether the grievance is substantiated and actionable in line with Project legal framework. It is also the
responsibility of the grievance owner to ensure that the identity of the complainant remains anonymous if
applicable and that those involved in the investigation are knowledgeable of that.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 25
6.1.6 STEP 6 Acting on the Grievance
Following the investigation, the grievance owner in coordination with the QHSE Team and O&M Team
shall determine how the grievance is to be addressed with the proposed steps to be followed including well
defined responsibilities and reasonable timelines on case by case basis. The proposed steps should take
into consideration the nature of the grievance and sensitivity of the complainant, so that confidentiality and
anonymity is respected as appropriate. The complainant shall be informed on the proposed actions and
engaged in the process to the extent believed appropriate on case by case basis.
The QHSE Team shall be responsible for assigning actions, monitoring implementation of actions
undertaken and making sure deadlines are adhered to. The implementable actions to be followed including
responsibilities and timelines shall be rigorously recorded within the Grievance Log by the QHSE Team.
6.1.7 STEP 7 Close Out & Follow up
Once all the proposed actions have been effectively implemented, the grievance owner considers the
grievance has been addressed and the QHSE Team has verified its implementation, the grievance owner
shall formally advise the complainant via their preferred method of contact of the implementation of such
actions, the rationale behind it in line with the Project legal framework and request feedback about the level
of satisfaction on the outcome and process followed. These shall de documented by the grievance owner
and recorded within the Grievance Log by the Corporate QHSE Team.
The grievance owner shall also fill in and signed off the Project Grievance Closeout Form (see AE-QHSE-
DOC-033 in Annex 3) and prompt the complainant to review it and sign it. It is worth noting that a
complainant may or may not be satisfied with the outcome and process followed to address the grievance
based on for instance his/her expectations, personal interests or understanding of the issue. Even in those
cases, a grievance may be considered ‘Closed’. This shall be documented within the Project Grievance
Log and the Project Grievance Closeout Form.
6.2 Good Practice Considerations
As previously noted, the Project aims to follow international best practice in the management of the
Project’s environmental & social risks. In line with the recommended considerations in the IFC publication
on “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging
Markets”, the following measures and actions in relation to grievance management have been, are or will
be implemented by the Project Company:
Good Practice Pointers Implemented or Committed Action by the Project Company
Transparent and fair
grievance management
process readily
understandable, accessible
and culturally appropriate
for the local population
The Grievance Mechanism continues to be implemented throughout the Project O&M phase
through the Community Liaison Office and the accessibility to the grievance box. The Grievance
Mechanism Procedure will be simplified into a format and language (i.e. Arabic) readily
understandable to the Identified Local Communities and be available in hard copy at the
Community Liaison Office. The Grievance Mechanism Procedure will also be communicated
orally to individuals with lower levels of literacy through the Community Liaison Office
Scaling the grievance
mechanism to the Project
needs
Given the scale of the Project and the nature of operation and maintenance activities, the
Grievance Mechanism continues to be implemented throughout the Project O&M phase through
the Community Liaison Office. As previously noted, continuity is being ensured by retaining the
same Project Liaison Officer and Community Liaison Officers who have established strong
relationships with stakeholders, and gradually decreasing the size of the LCC over the first 18
months of operation. In addition, the Grievance Mechanism as part of this Stakeholder
Engagement Plan as well as the simplified version in Arabic will be advertised in the Corporate
website under Project related Environmental & Social information.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 26
Good Practice Pointers Implemented or Committed Action by the Project Company
Keeping documented
records of grievances
received and reporting
back
The Project Grievance Log is maintained up-to-date and the associated information is recorded
under the Project document control system. The E&S performance of the Project including how
the Project Company has been responding to the grievances received will be communicated
through the Corporate Sustainability Report on annual basis.
TABLE 10 GOOD PRACTICE CONSIDERATIONS FOR GRIEVANCE MANAGEMENT
ARWF-O&M-Stakeholder Engagement Plan-Rev00 27
7 RESOURCES & RESPONSIBILITIES
This section is intended to define clear roles, responsibilities and authority for the designated individuals,
groups or teams responsible for the implementation and monitoring of stakeholder engagement activities
in addition to the expected high-level responsibilities of the identified stakeholders.
7.1 Community Liaison Office
The Community Liasion Office during the O&M phase is composed of Salem Ali Faraj Al-Rawajfeh (Project
Liaison Officer), Yaser Ibrahim Hwaishel Al-Rawajfeh (Public Relations Officer Assistant) and Loay
Mohammad Ahmad Alkalaifeh (Community Liaison Officer). The responsibilities of the Community Liasion
Office are as follows:
- Acting as the focal point of contact for day-to-day engagement and consultation with members of
the Identified Local Communities;
- Continuing to build and maintain a constructive and dynamic relationship with the Identified Local
Communities, including Local Community representatives, CBOs and local governmental entities,
for the long-term, fostering an environment of community involvement and ownership, and
providing a sense of control over Project-related information being communicated to them;
- Monitoring community attitudes and trends towards the Project and communicating those to the
Development Coordinator & Social Specialist;
- Maintaining a proactive and engaging relation with the Development Coordinator & Social
Specialist keeping him duly and timely informed of any particular issues or concerns identified,
grievances raised, opportunities for engagement and any additional related subjects;
- Supporting as required in the implementation ‘on-the-ground’ of the Social Development &
Investment Program;
- Making the Project related documentation is available within the CLO office as well as CBOs as
described in Section 5;
- Providing support to tailor the content of the Project brochure and/or poster to ensure that the
content and format fits the information needs of the Identified Local Communities;
- Coordinating with the Development Coordinator & Social Specialist Maintaining for any suggested
or planned stakeholder engagement sessions, including support meetings, focus groups or
briefings or community gatherings in relation to the Project;
- Conducting engagement with nomads, local herders and users of the grounds of the Project for
information disclosure through consultation and informing them of the appropriate avifauna
management measures, the risk of blade & ice throw and the noise generation by the WTGs.
Keeping documented evidence of such engagement, maintaining records within the provided log
(see Annex 4) and periodically sharing those with the Development Coordinator & Social
Specialist;
- Effectively implementing the Grievance Mechanism described in Section 6 by:
o Receiving and recording all verbal or written complaints and communicating those with the
Development Coordinator & Social Specialist;
o Leading and coordinating the investigation of ‘Level 1’ grievances as well as the
implementation of actions within the associated timelines;
o Keeping physical record of completed Grievance Forms and Grievance Close-out Forms
and sharing those timely with the Development Coordinator & Social Specialist; and
o Monitoring of the Community Grievance Box and availability of Grievance Forms on daily
basis.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 28
7.2 Development Coordinator & Social Specialist
- Provide guidance, direction and supervision to the Community Liaison Office on all matters related
to stakeholder engagement and the implementation of the grievance mechanism; but not limited
consultation and disclosure events, community meetings, evaluating, reporting and resolving
community grievances and providing feedback to the communities on issues.
- Acting as a point of liaison between the Community Liaison Office and the QHSE Team;
- Continue building and maintaining a constructive and dynamic relationship between the Identified
Local Communities and the Interest-based Stakeholders (in particular the Directorate of Education
and the Directorate of Solidarity) and Alcazar Energy communicating our strong commitment to
socio-economic development, environmental protection, respect for labour & human rights and
strong governance;
- Supporting the Development Manager in the liaison with the national Participatory Stakeholders
(i.e. NEPCO and MEMR) being a focal point of contact;
- Monitoring community attitudes and trends towards the Project, identifying changes in satisfaction
levels and the underlying causes, identifying any particular E&S risks and opportunities, and
communicating those, and any particular issues or concerns and grievances raised, to the QHSE
Team so any suitable changes in the stakeholder engagement approach can be timely
implemented if necessary;
- Ensuring that Project related documentation is available within the CLO office as well as CBOs as
described in Section 5;
- Providing support to develop the content of the Project brochure and/or poster to ensure that the
content and format fits the information needs of the Identified Local Communities and is in line with
the provisions of this Stakeholder Engagement Plan;
- Maintaining records of stakeholder engagement activities, including consultation with nomads,
local herders and Project-grounds users, support meetings, focus groups or briefings or community
gatherings in relation to the Project as well meetings or formal communications with Interest-based
Stakeholders and national Participatory Stakeholders. Ensuring that the Stakeholder Engagement
Log is updated on monthly basis with inputs from the team at country level and shared with the
QHSE Team;
- Managing and coordinating the implementation of the different initiatives and projects under the
Social Development & Investment Program;
- Coordinating the submission of the Semi-annual Synopsis of Avian and Bat Monitoring & Impact
Mitigation Measure Report as well as the Operational Raw Data of avifauna monitoring to the
MoEnv in timely manner; and
- Effectively supporting the CLO in the implementation of the Grievance Mechanism described in
Section 6 and ensuring documentation is timely shared and effectively communicated to the QHSE
Team, including the Grievance Log for ‘Level 1’ grievances.
7.3 Grievance Recipients
- Prompting the complainant to complete a Project Grievance Form or to complete the form on
his/her behalf should the complainant be illiterate;
- Briefly explaining the process and steps to be followed as per the procedure, ensuring the
confidentiality of the complainant in the process if wished so;
- Acknowledging grievances within two working days of a grievance being formally received on the
written or verbal mode that the complainant preferred (if any); and
- Determining proposed steps to address the grievance including well defined responsibilities and
reasonable timelines on case by case basis in liaison with the O&M Team and QHSE Team and
advising the complainant of the implementation of such actions, requesting feedback on
satisfaction on the outcome and process followed; and
- Completing, recording and share the Grievance Closeout Form as appropriate internally.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 29
7.4 Corporate QHSE Team
- Responsible for managing and overseeing the effective implementation of this Stakeholder
Engagement Plan and the Grievance Mechanism described herein including its periodical
monitoring and evaluation of performance;
- Ensuring that Project related documentation ESIA, NTS, Updated SEP and Project brochure
and/or poster are continuously available on the Corporate website;
- Ensuring the implementation of the Avifauna Monitoring & Observer-led Shutdown Protocol and
Carcass Search Protocol, approving the Semi-annual Synopsis of Avian and Bat Monitoring &
Impact Mitigation Measure Report and ensuring the timely submission together with the
Operational Raw Data of avifauna monitoring to the MoEnv;
- Providing necessary input on the Stakeholder Engagement Log on monthly basis;
- Providing necessary input on the Project Progress Report to be submitted to the Participatory
Stakeholders (i.e. Project Lenders and Company Shareholders) including a review of
Environmental & Social matters arising in relation to the Project including QHSE performance and
details of any accidents, emergencies or other material events;
- Developing the Corporate Sustainability Report including communication on environmental and
social performance for the Project, amongst other Company projects, and ensuring it is made
publicly available through the Corporate website;
- Effectively implementing the Grievance Mechanism described in Section 6 by:
o Leading and coordinating the investigation of ‘Level 2’ grievances as well as the
implementation of actions within the associated timelines and overseeing the same for
‘Level 1’ grievances;
o Keeping electronic record of completed Grievance Forms and Grievance Close-out Forms
and maintaining the Grievance Log updated;
o Assigning actions, monitoring implementation of actions undertaken and making sure
deadlines established are adhered to; and
o Ensuring that ‘direct employees’ and ‘contracted workers’ are aware and knowledgeable
of their responsibilities under the Grievance Mechanism through e.g. refresher training
sessions.
7.5 O&M Team
- Directly supporting the QHSE Team on the effective implementation of this Stakeholder
Engagement Plan and the Grievance Mechanism described herein;
- Providing necessary input on the Stakeholder Engagement Log on monthly basis; and
- Duly and timely submission of the Project Progress Report, including a review of Environmental &
Social matters arising in relation to the Project including QHSE performance and details of any
accidents, emergencies or other material events, to the Participatory Stakeholders (i.e. Project
Lenders and Company Shareholders).
7.6 Senior and Executive Management
Ultimately responsible for overseeing the effective implementation of this Stakeholder Engagement Plan,
and the Grievance Mechanism described herein:
- Ensuring adequate resources are made available accordingly and that all parties are aware and
knowledgeable of their responsibilities under the Stakeholder Engagement Plan and the Grievance
Mechanism; and
- Monitoring of its performance through ongoing stakeholder analysis and assessment of
stakeholder concerns from a risk-perspective, which could affect not only the environmental &
social performance of the Project but also the Company’s reputation and business performance.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 30
7.7 Identified Stakeholders
7.7.1 Members of the Identified Local Communities
Responsible for following the established procedure and mechanisms for the submission of any concern,
issue or complaint in relation to the operation of the Project.
7.7.2 Interest-based Stakeholders
- Following formal communication channels for any engagement with Alcazar Energy in relation to
the operation of the Project; and
- Following the established procedure and mechanisms for the submission of any concern, issue or
complaint in relation to the operation of the Project.
7.7.3 Participatory Stakeholders
Responsible for following formal communication channels for any engagement with Alcazar Energy in
relation to the operation of the Project.
7.7.4 Internal Stakeholders
The O&M Contractor, and its subcontractors, are responsible for:
- Following the established procedures and mechanisms in relation to this Stakeholder Engagement
Plan, as applicable, as well as for the successful implementation of the Worker Grievance
Mechanism as part of the Project-specific QHSSE; and
- Communicating and sharing the Emergency Preparedness and Response Plan (EPRP), once
approved, with the local emergency response governmental bodies (i.e. Civil Defence, Police
Department, Healthcare Department).
ARWF-O&M-Stakeholder Engagement Plan-Rev00 31
8 MONITORING AND REPORTING
8.1 Monitoring and Auditing
The implementation of this Stakeholder Engagement Plan shall be monitored through the periodical review
of the Stakeholder Engagement Log to be updated and submitted by the Development Coordinator and
Social Specialist to the QHSE Team on monthly basis, to assess whether the engagement activities within
this Plan are being successfully and timely undertaken.
The implementation of this Plan shall also be monitored through the continuous review of the Grievance
Log within the QHSE Statistics. The performance of its implementation and the timely resolution of
grievances shall be evaluated on monthly basis as part of the review of the Project’s QHSSE key
performance indicators (KPIs).
In addition, the Project also recognises the importance of applying ‘participatory monitoring’ techniques to
increase both the accountability of the Project and the credibility of the environmental and social monitoring
results:
Good Practice on
Participatory Monitoring Implemented Actions by the Project Company
Participation of Identified
Local Communities in
monitoring environmental
impacts and management
measures
During the Spring period from March 2019 to May 2019, a training program was implemented
entailing the fair and transparent selection and training of five (5) local community members as
junior avifauna observers and carcass searchers. The junior avifauna observers successfully
completed the training, after which they have been employed by EcoConsult, the
environmental consultant engaged for the implementation of the avifauna operational
monitoring, observer-led shutdown and carcass search activities.
Participation of Identified
Local Communities in
monitoring community
attitudes and social trends
towards the Project
The Community Liasion Office is composed of members from the Identified Local Communities
,with the Project Liaison Officer one of the five (5) leaders of the Al Rajef Association, and a
respectable representative and advocate of the interests and concerns of the community
TABLE 11 GOOD PRACTICE CONSIDERATIONS FOR PARTICIPATORY MONITORING
The implementation of this Stakeholder Engagement Plan shall be audited through quarterly inspections
conducted by the QHSE Team to recognize as far as possible any non-conformance, gaps or
recommendations for improvement. The review of documentation shall include for instance an on-the-
ground assessment to determine whether the Project-related and Grievance Mechanism related
documentation being available at the designated locations.
8.2 Reporting
The reports that shall be made available to the Identified Local Communities as are as previously noted
- ESIA, NTS, ESAP and Updated Stakeholder Engagement Plan;
- Avifauna Monitoring and Shutdown on Demand Protocol and the Semi-annual Synopsis of Avian
and Bat Monitoring & Impact Mitigation Measure Report;
- Social Development and Investment Program,
- Grievance Mechanism related documentation: Grievance mechanism simplified procedure in
Arabic, Grievance box and grievance forms and Updated Grievance Log; and
- The Project brochure and/or poster.
ARWF-O&M-Stakeholder Engagement Plan-Rev00 32
The Project brochure and/or poster, which is currently under development, shall be a key document
presenting the most relevant facts of interest to the local communities on the above documents in the
adequate shape, format and language.
The different reports to be disclosed and share with interest-based Stakeholders and Participatory
Stakeholders are listed in Section 5.1.
In addition, Alcazar Energy plans to publicly release its first Corporate Sustainability Report in Q2 2020.
This report is intended to be complementary to, but not a substitute for the documentation for disclosure of
information targeted to the different stakeholder groups in Section 5.1.
The release of the first Corporate Sustainability Report has been timed with the reporting timeframe of the
Project Annual Monitoring Report on Environmental & Social Performance including Impact Indicators to
be submitted to the Project Lenders. The Corporate Sustainability Report will also represent the our first
‘Communication on Progress’ (COP) fulfilling our commitment as Participants to the United Nations Global
Compact (UNGC) since March 2019. The COP is an annual disclosure to stakeholders on progress made
in implementing the Ten Principles of the UNGC with respect to human rights, labour, environment and
anti-corruption describing the practical actions taken and the performance measurements against them
Sustainability reporting provides an opportunity to communicate information to a wide range of
stakeholders about the environmental, social, economic, and governance performance of the Project and
the wider Company operations, also offering a platform to report back on the process of stakeholder
engagement and grievance management
ARWF-O&M-Stakeholder Engagement Plan-Rev00 33
ANNEX 1 – PROJECT GRIEVANCE FORM
Al Rajef Wind Farm 34
GRIEVANCE REGISTRATION FORM
GENERAL
Project
Case #
Complainant full Name
Contact Information
Please mark how you wish to be contacted (mail, telephone, e-mail).
By Post: (Please provide mailing address)
_________________________________________________________________________________________________________________________________________________________________________________________
By Telephone: _______________________________________________
By E-mail: ___________________________________________________
IDENTIFICATION OF THE CONCERN / INCIDENT / GRIEVANCE
Description of Concern / Incident / Grievance
What is your grievance?
What happened?
Where did it happen?
Who did it happen to?
What is the result of the problem?
Date of Concern / Incident / Grievance
One-time incident/grievance (date _______________)
Happened more than once (how many times? _____)
On-going (currently experiencing problem)
RESOLUTION PROPOSAL
What would you like to see happen to resolve the problem?
Date: _______________________________
Please return this form to:
• Mr. Qusai Al-Abbassi | [email protected] | Tel: +962 6 461 4005
• QHSE Team | [email protected] | Tel: +971 4 558 7805
محطة الراجف لتوليد الطاقة من الرياح
ي تسجيل الشكاونموذج
معلومات عامة
المشروع
رقم الحالة
اسم المشتكي بالكامل
معلومات الاتصال
المناسبة للاتصاليرجى اختيار الوسيلة بك )بريد، هاتف، بريد الإلكتروني(.
يرجى وضع عنوان البريد الخاص بك( :عن طريق البريد( ______________________________________________________________________________________________________________________________________________________________________________________________________
:عن طريق الهاتف ____________________________________________________________________________________________________________________________________
:عن طريق البريد الإلكتروني ____________________________________________________________________________________________________________________________________
بيان المشكلة / الحادث / الشكوى
وصف المشكلة / الحادث / الشكوى ما هي الشكوى؟ ما الذي حدث؟
أين حدث؟ مع من حدث؟
ما هي نتيجة المشكلة؟
(______________________حادث / شكوى لمرة واحدة )التاريخ تاريخ المشكلة / الحادث / الشكوى ( __________حدثت أكثر من مرة )كم عدد المرات؟
مستمر )مشكلة يتم اختبارها بشكل مستمر(
مقترح الحل
ماذا برأيك الحل الممكن لهذه المشكلة؟
__________________________________التاريخ:
يرجى إرجاع هذا النموذج إلى:
8915 506 79 962+| هاتف: [email protected] | السيد. قصي العباسي
7805 558 4 971+| هاتف: [email protected] الصحة، والسلامة، والبيئة | وقسم الجودة،
ARWF-O&M-Stakeholder Engagement Plan-Rev00 36
ANNEX 2 – PROJECT GRIEVANCE LOG
ARWF-O&M-Stakeholder Engagement Plan-Rev00 38
ANNEX 3 – PROJECT GRIEVANCE CLOSEOUT FORM
Al Rajef Wind Farm
GRIEVANCE CLOSE OUT FORM
GENERAL
Project
Case #
Complainant full Name
Type of issue
(mark with X). Complaint Suggestion Concern
ACTION FOR RESOLUTIONS
Resolutive action and timeframe
ACTION
TARGET DATE
Justification for the action
CONCLUSIONS (This section is completed upon completion of all agreed actions)
Action Implementation Date
Complainant Satisfied with Process
Yes No
Comments
Complainant Satisfied with Outcome
Yes No
Comments
Complainant Signature on Complaint Close Out ____________________________ Date _________________
Grievance Owner Signature on Complaint Close Out
____________________________ Date _________________
الرياحمحطة الراجف لتوليد الطاقة من
ي الشكاو إغلاقنموذج
معلومات عامة
المشروع
رقم الحالة
اسم المشتكي بالكامل
نوع القضية (. X)ضع اشارة
شكوى
اقتراح
مخاوف اجراءات الحل
الحل الحل الاجرائي والاطار الزمني
الوقت المستهدف
تفسير الحل
عند الانتهاء من جميع الإجراءات المتفق عليها(مكتمل لاستنتاجات )هذا القسم ا
تاريخ تنفيذ الإجراء
عن العملية ض مقدم الشكوى را نعم
لا
تعليقات
النتيجة مقدم الشكوى راض عن
نعم
لا
تعليقات
توقيع مقدم الشكوى على إغلاق
الشكوى
_______________________________________ التاريخ: __________________________
إغلاق توقيع صاحب الشكوى على
الشكوى
_______________________________________ التاريخ: __________________________
ARWF-O&M-Stakeholder Engagement Plan-Rev00 41
ANNEX 4 – CLO ENGAGEMENT ACTIVITIES LOG
ARWF-O&M-Stakeholder Engagement Plan-Rev00 42
ARWF-O&M-Stakeholder Engagement Plan-Rev00 43