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CONSTRUCTION AND OPERATION OF FOUR SMALL HYDRO-POWER PLANTS IN THE REPUBLIC OF MACEDONIA Stakeholder Engagement Plan December 2010 Notice This Stakeholder Engagement Plan was developed with help of Empiria EMS DOOEL Skopje for PCC SE as part of public disclosure and consultations of the SMALL HYDRO-POWER PLANTS PROJECT IN MACEDONIA ЕМПИРИА - ЕМС

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Page 1: Stakeholder Engagement Plan - pcc-hydro-mk. · PDF fileStakeholder Engagement Plan ... Empiria EMS DOOEL Skopje for PCC SE as part of public disclosure and consultations of the SMALL

CONSTRUCTION AND OPERATION OF FOUR SMALL HYDRO-POWER PLANTS IN

THE REPUBLIC OF MACEDONIA

Stakeholder Engagement Plan

December 2010

Notice This Stakeholder Engagement Plan was developed with help of Empiria EMS DOOEL Skopje for PCC SE as part of public disclosure and consultations of the SMALL HYDRO-POWER PLANTS PROJECT IN MACEDONIA

ЕМПИРИА - ЕМС

Page 2: Stakeholder Engagement Plan - pcc-hydro-mk. · PDF fileStakeholder Engagement Plan ... Empiria EMS DOOEL Skopje for PCC SE as part of public disclosure and consultations of the SMALL

Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 2

Contents

Introduction ............................................................................................................................... 3 1 Locations of Small Hydro Power Plans ............................................................................ 4 2 Requirements for Stakeholders Engagement ................................................................. 10

2.1 Macedonian Requirements ..................................................................................... 10 2.1.1 The Public Participation Provisions of Macedonian Legislation ...................... 10 2.1.2 Properties Acquisition / Resettlement Issues ................................................. 10

2.2 EBRD Requirements .............................................................................................. 11 3 Review of the Stakeholders Engagement ...................................................................... 13 4 Identification of Stakeholders and Communication Methods .......................................... 14

4.1 Stakeholder Identification ....................................................................................... 14 4.2 Stakeholders Characteristics .................................................................................. 15 4.3 Communication Tools ............................................................................................. 18

5 Information Disclosure .................................................................................................... 20 6 Grievance Mechanism .................................................................................................... 21 7 Developer Contact Information ....................................................................................... 21 Annex ..................................................................................................................................... 22

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Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 3

Introduction This document describes and defines the Stakeholder Engagement Plan (SEP) of the project: “CONSTRUCTION AND OPERATION OF FOUR SMALL HYDRO-POWER PLANTS IN THE REPUBLIC OF MACEDONIA” (further referred to as “the Project”). On behalf of the Government of the Republic of Macedonia, the Macedonian Ministry of Economy has issued several public calls for granting water concession for production of electricity from small hydro power plants (SHPPs) under the model DBOT (Design, Build, Operate and Transfer). The program of the Government envisages construction of about 400 SHPPs with single electricity power up to 5 MW or with total power of about 250 MW. The expected annual production of electricity is about 1,200 GWh. PCC SE has been granted with concessions for 4 sites for construction and operation of SHPPs. Their capacity ranges from 0.6 MW to 1.4 MW. The total installed capacity would be 3.8 MW. The Concession Agreements with the Macedonian Government have been signed on the 30th of March, 2010. PCC HYDRO DOOEL Skopje (further referred to as “the Developer”) is a wholly owned subsidiary of PCC SE which is a holding of a privately owned German industrial group with three business divisions: chemicals, energy and logistics and is one of the world leading renewable energy companies, dedicated to generating electricity using sustainable and environmentally friendly resources. The Developer is currently carrying out a planning stage of the initiative which includes development of SHHPs and associated infrastructure at the following localities:

1. SHPP Galicnik 3 (power ≈ 1.1 MW)

2. SHPP Patiska Reka (power ≈ 0.6 MW)

3. SHPP Gradecka (power ≈ 0.7 MW)

4. SHPP Brajcino 2 (power ≈ 1,4 MW) The present Stakeholder Engagement Plan has been developed in compliance with EBRD’s Performance Requirements, EBRD’s Public Information Policy and best international practice in order to enhance public information and stakeholder1 engagement procedures, and includes the following:

Local legal framework of consultation activities and project disclosure requirements particularly in respect of those public consultation activities that are directly required under the national permitting process.

Identification of potential stakeholders in the Project area of influence.

Description of how any concerns or grievances will be handled.

1 “Stakeholder” is a person, group or organization that is affected or can be affected by the

environmental and/or social consequences of a proposed project/activity; this includes individuals/groups/organisations that express interest in the project/activity and in the participation to round tables and discussion meetings, and/or are able to influence the project’s implementation and/or operations.

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Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 4

Planned approach for further consultation during preparation, construction and operations phases of the Project, including details on appropriate formats for effective and culturally meaningful interaction with the various stakeholders.

Disclosure plan, including the identification of any locations where relevant project documentation will be available locally and elsewhere as well as languages to be used.

The SEP will be reviewed and updated on a regular basis. If activities change or new activities relating to stakeholder engagement commence, the SEP will be brought up to date. The SEP will also be reviewed periodically during project implementation and updated as necessary.

1 Locations of Small Hydro Power Plans Site information of the four planned SHPPs is given in the following table.

No Site name Location Facilities / Infrastructure

1 Galicnik 3 (~ 1,1 MW)

Distance from village Jance to the intake is 1.5 km, and from powerhouse 600 m. This SHPP including the village of Jance and surrounding area are on the territory of the National Park Mavrovo. Intake structures

(including sand trap and fish ladder)

Headrace channel

Water chamber

Penstock

Power-house

Access roads, and

Grid connection

2 Patiska Reka (~ 0,6 MW)

Distance from village Patiska Reka to the intake 1 is 1.4 km, to intake 2 is 1.1 km, to the powerhouse is 400 m. Distance from Skopje to intakes 1 and 2 is 34 km and to the powerhouse is 33 km.

3 Gradecka (~ 0,7 MW)

Distance from town Vinica to the intake is 7.3 km, to the powerhouse is 5 km. From village Gradec distance from intake is 2.3 km and to the powerhouse is 200 m.

4 Brajcino 2 (~ 1,4 MW)

Distance from town Resen to the intake 1 is 35 km, as well as to intake 2 and the powerhouse. Distance from village Brajcino to the intake 1 is 3.3 km, to the intake 2 is 2.6 km and to the powerhouse is 1.4 km. The location is near the border with Greece and on the territory of the National Park Pelister.

A map of the location of each of the SHPPs as well as maps of the planned infrastructure is given below.

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Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 5

Figure – Locations of the SHPPs

Bitola

Resen

Prespa Lake

Ohrid Lake

Dojran Lake

SHPP Brajcino 2 (1386 kW)

SHPP Galicnik 3 (1150 kW)

Mavrovo Lake

Skopje

SHPP Patiska Reka (610 kW)

Kocani

SHPP Gradecka (720 kW) Vinica

StipVeles

Prilep

Kumanovo

Tetovo

Gostivar

Strumica

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Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 6

Figure – Location of the facilities and infrastructure of SHPP Galicnik 3

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Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 7

Figure – Location of the facilities and infrastructure of SHPP Patiska Reka

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Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 8

Figure – Location of the facilities and infrastructure of SHPP Gradecka

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Small Hydro-Power Plants in Macedonia

Stakeholder Engagement Plan 9

Figure – Location of the facilities and infrastructure of SHPP Brajcino 2

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2 Requirements for Stakeholders Engagement

2.1 Macedonian Requirements

2.1.1 The Public Participation Provisions of Macedonian Legislation Public participation in spatial planning and environmental protection processes in Macedonia are regulated by:

• Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (Aarhus Convention), (Official Gazette of RM no. 40/99)

• Law on Spatial and Urban Planning (Official Gazette of RM no. 51/05, 37/07 and 24/08)

• Law on the Environment (Official Gazette of RM no. 53/05, 81/05, 24/07 and 159/08) and associated secondary regulation

Environmental Impact Assessment (EIA) of certain projects is required to be carried out in Macedonia in accordance with Articles 76-94 of the Macedonian Law on the Environment (LoE). This law and the associated secondary legislation set out the requirements for undertaking environmental assessment (EA) of potential environmental impacts of public and private projects which are likely to have a significant impact on the environment before development consent / construction permit is granted in the form of approval for project implementation. The Macedonian legislation concerning the environmental impact assessment defines the rules and detailed procedures for including the public in the decision-making process. The practical public involvement is performed through: a) disclosing of the information to the public, b) public participation where public can actively be involved in public discussions and submitting its written opinion within the different EIA phases of the procedure and c) through the mechanism of access to justice, when public could influence the decision making with submitting appeals to the Court or Second Instance Commission of the Government. The Developer has initiated the EA procedure by submission of Notifications for the intention for project implementation for each of four SHHP sites to the Macedonian environmental competent authority - the Ministry of Environment and Physical Planning (MEPP). Following a screening exercise, the MEPP has officially informed the Developer that an EIA procedure for all four proposed SHPPs is not required. Instead, PCC HYDRO has been obliged to prepare a Study for Environment Protection for each of the SHPP in compliance with the article 24 of the LoE and associated by-laws. The administrative procedure for approval of the Studies does not include formal requirement for public consultation process nor public hearing(s) events.

2.1.2 Properties Acquisition / Resettlement Issues In a case when a certain facility of a SHPP needs to be constructed on private owned land, PCC HYDRO will conduct an appropriate process for conclusion of an Agreement for land purchase and/or timely limited Agreement for use of land, with every concerned party. If such

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agreement, after reasonable efforts, could not be concluded, PCC HYDRO has right to ask for an expropriation procedure for necessary land for project implementation. This acquisition shall be conducted in accordance to the Macedonian Law on Expropriation (Official Gazette of RM no. 33/95, 20/98, 40/99, 31/03, 46/05 and 10/08). It is expected that the eventual acquisition of properties will not be connected with any compulsory operations, no involuntary physical or economical displacement will take place, nobody will be deprived of livelihood, and nobody will incur economical losses. Due to the above, no Resettlement Action Plan (RAP) will be required. Any eventual permanent loss of land, forest and other property, and possible damage during the construction phase, or during operation and maintenance of the infrastructure will be subject to compensation under positive Macedonian regulations.

2.2 EBRD Requirements The EBRD is committed to promote environmentally sound projects and sustainable development within the full range of its activities, applying sound banking principles to all its operations. Consequently, the Bank formulated its environmental policy and requirements aimed at achieving the following two main objectives:

• Ensuring that potential environmental consequences of each Bank-financed investment project are identified and evaluated at a very early stage in the project planning/decision making process, i.e. integrate environmental considerations into the project cycle, including project preparation, approval and implementation.

• Developing/applying techniques designed to improve environmental aspects of all Bank-financed projects by identifying environmental opportunities and incorporating environmental improvements/benefits into these projects.

The present project is governed by the EBRD Environmental Policy and the applicable Performance Requirements (PR) adopted in 2008. Specific stakeholder engagement requirements are set out in the following documents:

• EBRD Environmental and Social Policy (2008)

• EBRD Public Information Policy (2008)

• PR 10 Information Disclosure and Stakeholder Engagement (2008). Other relevant documents applicable to the EBRD-funded projects include:

• UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (Aarhus Convention)

• The EU Directive 85/337/EEC, amended by the Directive 97/11/ЕС, on the Assessment of the Effects of Certain Public and Private Projects on the Environment.

EBRD considers public consultation and stakeholder engagement as an on-going process, to be started at the earliest stage of the environmental assessment process, and to be continued throughout the entire life of the EBRD-financed project. An essential element in the stakeholder engagement process, in order to ensure meaningful and effective consultation process, is the careful identification of all involved stakeholders and the examination of their concerns, expectations and preferences. Special attention should be paid to the identification of vulnerable stakeholders whose life and well-being is

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directly dependant by the Developer’s activities. The consultation and dialogue with these stakeholder groups need to be planned and managed with special care. Furthermore, the EBRD requires that the project developer establish and maintain an effective grievance mechanism, ensuring that any stakeholder complaints and concerns are received, handled and resolved effectively, in a prompt and timely manner. Maintaining close interaction with the local community and promoting its development should be an essential element of corporate policies and activities of all companies borrowing through the EBRD. Even if there is no explicit requirement for social investment activities, they are encouraged and appreciated.

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3 Review of the Stakeholders Engagement PCC HYDRO shall allow public information / participation and consultations during the implementation of all project stages. During the initial project stage, PCC HYDRO organized and conducted several consultation meetings with competent authorities and the residents of the settlements in vicinity of each of the localities of the SHPPs. The aim of these meetings was to deliver the information related to SHPP construction and operation to local community as well as to explore local communities’ response and eventual concerns in regard to the proposed developments. In context of the activities for information and involvement of relevant stakeholders in the process of environmental and social impact assessment, following meetings were organized: (i) meetings with representatives of administrations of each of the municipalities on which territory the SHPPs are planned and (ii) meetings with representatives of each of the concerned local communities. In addition, a scoping (kick-off) leaflet on Macedonian language as an information tool for each of the SHPPs has been prepared. It includes:

o A summary Project description. o A summary description of the ESIA process. o A summary description of the stakeholder engagement process and of the

grievance mechanism. Early information and involvement of various stakeholders was realized via organization of an ESIA scoping workshop. The scoping workshop was held on 30th June 2010 as one-day event. It included presentations of the Project and the ESIA scope, as well as introduction of the draft version of this SEP. As a part of the implementation of the ESIA process, the Developer organized final one-day ESIA workshop on 6th December 2010. The aim of this event was to present and discuss the information and findings related to environmental and social assessment of the SHPPs construction and operation to various stakeholders. The following documents for each of the four planned SHPP have been disseminated to the participants on the final ESIA workshop:

• Non-Technical Summary (NTS), and • Environmental and Social Action Plan (ESAP).

This version of the SEP was also presented on the workshop.

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4 Identification of Stakeholders and Communication Methods

4.1 Stakeholder Identification There are several groups of people and social groups who are interested in the Project on different levels. These may be described as following:

people and social groups who will be directly or indirectly influenced by the Project

people and social groups who participate in implementation of the Project

people and social groups who have a possibility to influence and make decisions on implementation of the Project.

The following table represents the identified stakeholders in accordance to above classification.

Table – Stakeholder identification

Stakeholders that will be directly or indirectly influenced by the Project

Stakeholders who participate in implementation of the Project

Stakeholders with possibility to influence and make decisions on implementation of the Project

• Residents of villages and communities where SHPPs and associate infrastructure will be located

• Residents of the municipalities where SHPPs and associate infrastructure will be located

• Land owners of infrastructure sites / overhead line towers

• Residents along transport routes / access roads

• NGOs – nature associations on local and national level

• The Developer • Employees of the Developer

(internal stakeholders) • Construction companies • Equipments suppliers • Transport companies • Energy recipient (energy

transmission and distribution networks)

• Government Administration • Local self governments (LSG)

administration • Local Councils • Local Inspectorates

(communal affairs, environment, transport, etc)

• Ministry of Environment and Physical Planning

• Ministry of Transport and Communications

• Ministry of Economy • Ministry of Agriculture,

Forestry and Water Economy • Ministry of Health • Management bodies of the

National Parks (where relevant)

• Emergency services

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4.2 Stakeholders Characteristics Table – Stakeholder identification - directly or indirectly influenced by the Project

SHPP Galicnik 3 (power ≈ 1.1 MW) Stakeholders Population *) Communication

Method Residents of (i) villages / communities (ii) municipality where SHPP and associated infrastructure will be located

Village Jance 146newsletter, public / consultation meeting(s)

LSG Mavrovo-Rostuse 8.618

Land owners of infrastructure sites in person Residents along transport routes / access roads in person

NGOs – nature associations on local and national level e-mail, newsletter,

website SHPP Patiska Reka (power ≈ 0.6 MW)

Stakeholders Population *) Communication Method

Residents of (i) villages / communities (ii) municipality where SHPP and associated infrastructure will be located

Village Patiska Reka 579 newsletter, public /

consultation meeting(s) LSG Sopishte 5.656

Land owners of infrastructure sites in person Residents along transport routes / access roads in person

NGOs – nature associations on local and national level e-mail, newsletter,

website SHPP Gradecka (power ≈ 0.7 MW)

Stakeholders Population *) Communication Method

Residents of (i) villages / communities (ii) municipality where SHPP and associated infrastructure will be located

Village Gradec 1.0245newsletter, public / consultation meeting(s) LSG Vinica 19.938

Land owners of infrastructure sites in person Residents along transport routes / access roads in person

NGOs – nature associations on local and national level e-mail, newsletter,

website SHPP Brajcino 2 (power ≈ 1,4 MW)

Stakeholders Population *) Communication Method

Residents of (i) villages / communities (ii) municipality where SHPP and associated infrastructure will be located

Villages Brajcino 134newsletter, public / consultation meeting(s) LSG Resen 16.825

Land owners of infrastructure sites in person Residents along transport routes / access roads in person

NGOs – nature associations on local and national level e-mail, newsletter,

website *) Census of Population, Households and Dwellings in Republic of Macedonia, 2002

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Table – Stakeholder identification - participate in implementation of the Project

Stakeholder Communication Method

The Developer In accordance with the rules and procedures of internal communication of the Developer

Employees of the Developer In accordance with the rules and procedures of internal communication of the Developer

Construction companies In accordance with the rules given in agreement between the Developer and the construction company

Equipments suppliers In accordance with the rules given in agreement between the Developer and the equipments suppliers

Transport companies In accordance with the rules given in agreement between the Developer and the transport companies

Energy recipient

MEPSO (Macedonian energy transmission and system operator)

In accordance with the rules given in agreement between the Developer and MEPSO

EVN Macedonia (electro energy distribution company)

In accordance with the rules given in agreement between the Developer and EVN Macedonia

Table – Stakeholder identification – influence and decision makers

Stakeholder Communication Method

Ministries

Ministry of Environment & Physical Planning Bul. "Goce Delcev", MRTV building (10,11,12 floor), Skopje Phone:+389 3 251-400 Fax:+389 3 220-165 Internet: www.moepp.gov.mk e-mail: [email protected]

• Official letters / correspondence

• Submission of documentation

On-going-process, in accordance to administrative procedures

Ministry of Economy Jurij Gagarin no.15, Skopje Phone: + 389 2 3093-408 Fax: + 389 2 3084-472 Internet: www.economy.gov.mk e-mail: [email protected]

• Official letters / correspondence

• Submission of documentation

On-going-process, in accordance to administrative procedures

Ministry of Agriculture, Forestry and Water Economy Jurij Gagarin no.15, Skopje Phone: + 389 02 3134- 477 Fax: + 389 02 3134- 477 Internet: www.mzsv.gov.mk

• Official letters / correspondence

• Submission of documentation

On-going-process, in accordance to administrative procedures

Ministry of Transport and Communications Crvena Skopska Opstina no.4, Skopje Phone: + 389 2 3145-497 Fax: + 389 2 3126-228 Internet: www.mtc.gov.mk

• Official letters / correspondence

• Submission of documentation

On-going-process, in accordance to administrative procedures

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Table – Stakeholder identification – influence and decision makers (continued)

Administration of Local Self Governments (LSGs)

Municipality of Mavrovo – Rostuse 1254, Mavrovo i Rostuse Phone: + 389 42 478-815 Fax: + 389 42 478-814 Internet: / e-mail: mavrovо[email protected]

• Consultative meetings

• Correspondence relating to projects

• Exchange of information

• Submission of documentation

On-going-process, in accordance to administrative procedures

Municipality of Sopishte Str. 2 no.2, 1054 Sopishte Phone: + 389 2 2785-100 Fax: + 389 2 2785-109 Internet: www.opstinasopiste.gov.mk e-mail: opstina [email protected] Municipality of Vinica Bel Kamen bb, 2310 Vinica Phone: + 389 33 361-945 Fax: + 389 33 363-294 Internet: www.opstinavinica.gov.mk e-mail: [email protected] Municipality of Resen Marsal Tito square 20, 7310 Resen Phone: + 389 47 454-450 Fax: + 389 47 452-200 Internet: www.resen.gov.mk e-mail: [email protected]

National Parks / Protected Areas relevant for: • SHPP

Galicnik 3 • SHPP

Brajcino 2 • SHPP

Patiska Reka

National Park Mavrovo Mavrovo village Phones: + 389 42 489-019 &

+ 389 42 489-505 Internet: www.npmavrovo.org.mk • Consultative

meetings • Correspondence

relating to projects • Exchange of

information

On-going-process

National Park Pelister 29th November 14, 7000 Bitola Phone: + 389 47 233-464 Internet: www.nppelister.org.mk e-mail: [email protected] PE for Managing and Protection of the Multipurpose Area - Yassenwww.jasen.com.mk e-mail: [email protected]

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Table – Stakeholder identification – NGOs interested in the project

Name Contact Details Communication Method

Association of Ecologists of Macedonia (DEM) (an NGO umbrella)

Vasil Gjorgov 39, Skopje Phone: + 389 2 3290-118 Fax: + 389 2 3220-518 Internet: www.dem.org.mk e-mail: [email protected]

• direct meeting(s) • e-mail • web site

On request

Macedonian Green Center (MGC) (group of 6 NGO active in the field of energy sector)

Ognjan Prica 1-4/23,Skopje Phone/Fax: +389 2 6132 432 Phone: +389 78 205 217 Internet: www.zeleni.org.mk e-mail: [email protected]

Macedonian Ecological Society (MES)

K.Josifovski Pitu 28/3-7, Skopje Fax: + 389 2 2402-774 www.mes.org.mk e-mail: [email protected]

Local NGO: • Association for

Sustainable Development - Brajcino

• (other NGOs - to be identified)

• Village Brajcino • (to be identified)

4.3 Communication Tools In general terms, the Developer employs the following methods for communication with the public:

• Information via mass-media and internet-based sources

• Meetings with the public (roundtable meetings with public representatives)

• Awareness-raising booklets and leaflets

• Annual report (including information about targets achieved in environmental protection, health and safety, and community development)

• Support for various community development projects. With a view at promoting and enhancing dialogue with stakeholders in order to ensure full compliance with the relevant EBRD requirements, PCC HYDRO will evaluate the use of additional communication/interaction methods. General information comprising the most important information related to the various stages of the development of the SHPPs (planning, construction and operations) will be available:

• on information board in offices of the LSGs • at local village administrators • on the Developer’s website 2 • in local newspapers.

Detailed information including relevant documents like Non-Technical Summary (NTS), Stakeholder Engagement Plan (SEP), Environmental & Social Action Plan (ESAP), as well

2 PCC HYDRO shall establish a web site in due course

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Environmental and Social Impact Assessment (ESIA) reports including environmental and building decisions / permits will be available in hard copies, upon previous request:

• in offices of relevant line ministries • in offices of the concerned LSGs • in the Developer’s office in Skopje.

Electronic versions of the above documents, i.e. the NTS, the SEP and the ESAP will be available on the developer’s website. The contact information of the village administrators is given in the below table. Table – Village administrators

SHPP LSG (municipality) Village(s) being under impact by the SHPP

Village administrator (contact details)

Galicnik 3 Mavrovo-Rostuse Jance Mr. Tefik Tefikovski, Fax: + 389 42 478 814

Patiska Reka Sopishte Patiska Reka Mr. Dzabir Redzepovski Fax: + 389 2 2785-109

Gradecka Vinica Gradec Mr. Branko Gorgiev Fax: + 389 33 363-294

Brajcino 2 Resen Brajcino & Ljubojno Mr. Vasko Kostovski, Brajcino Fax: + 389 47 452-200

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5 Information Disclosure Disclosure of relevant project information helps stakeholders to understand the project environmental and social risks, impacts and opportunities. The Developer intends to implement the Project as an example of good practice in development of hydro power infrastructure, with the aim to involve stakeholders and to keep good communication practices during the lifetime of the project. According to this approach, the target of the information disclosure / communication will be:

• To provide to local communities a schedule and information on activities that will be arranged, together with the mechanisms for their feedback.

• To improve the knowledge of what a project for small hydro power plant involves, in all stages of the project life cycle.

• To make public the commitment of the company to ensure the best practices in terms of environment protection and health and safety for workers and contractors.

• To make available to the public a grievance procedure, in order to collect the negative feedback and to act in correcting the causes that may lead to a negative opinion about developed small hydro power plants.

In order to ensure transparency and availability of information regarding SHPP development in planning, construction and operation stages, the Developer will conduct the following actions:

• One page information leaflet (in Macedonian language version) – will be prepared and distributed in the areas of the SHPP locations mainly in LSG offices. The leaflet will include the most important information about SHPP project as well as indicate the Developer’s web site and telephone information lines for communication.

• Website information – the Developer will disclose the projects information on the separate pad on its website. Information will be available in Macedonian and English and, in case of any relevant project changes, the Developer will publicly disclose them as well as their impacts.

The following documentation should be made available to the public on the website and in hard copies, upon previous request:

i. Project’s Non-Technical Summary (NTS).

ii. Stakeholder Engagement Plan (SEP), including Grievance Mechanism.

iii. Environmental and Social Action Plan (ESAP). Additionally, those stakeholders that are directly involved in the activities of construction will be granted access to following information:

iv. Construction Plan and relevant construction documents

v. Overhead Power Line Construction Plan and relevant documents

vi. Transport Plan

vii. Environmental & Social Impact Assessment (ESIA) reports of particular SHPP

viii. Environmental decision and building permit

ix. The Developer’s Environmental and Social Policy and Health and Safety Policy including Developer’s contractor requirements.

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6 Grievance Mechanism The Developer shall implement a Grievance Mechanism to ensure that it is responsive to any concerns, complaints particularly from affected stakeholders and communities. Special care will be focused on training of PCC HYDRO staff involved in the grievance mechanism management regarding functioning of grievance mechanism, particularly the stakeholder’s opinion and communication mechanism. Grievance process outline and Grievance Form are accordingly given in the Annex. The following indicative timeframe will be used:

• Written acknowledgement of receipt of the grievance: within 5 days of receiving the grievance

• Proposed resolution: within 30 days of receiving the grievance. In addition the active Grievance Procedure should be enlarged by following actions:

• Link to obtain the grievance form will be published on the Developer’s website.

• The information on the avenues to lodge a grievance will be placed on the information boards and websites of local authorities.

• The Developer will allocate responsibility of dealing with community grievances. A workers’ grievance mechanism will be established for the employees of construction companies as a part of general system or separately. Contractors of construction works will be informed by the Developer about necessity of implementation grievance mechanism for their employees in line with the requirements of the EBRD. The planned public grievance form is presented in the Annex. Such form in Macedonian will be posted on the Developer’s website together with the description of the grievance response mechanism and provided to the relevant authorities in the municipalities.

7 Developer Contact Information

Company: PCC HYDRO

Postal address: Kozle 1-B, 1000 Skopje, Macedonia

Phone: + 389 2 3085-088

Fax: + 389 2 3085-088

E-mail address: [email protected]

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Stakeholder Engagement Plan 22

Annex Figure - Flowchart for processing of grievances

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Figure – Public Grievance Form for SHPP Galicnik 3 and SHPP Brajcino 2 Public Grievance Form

Signature: _____________________________

Date: _____________________________

Please return this form to: Mr. Kristian Gligorovski Kozle 1-B, 1000 Skopje, Macedonia Phone: + 389 2 3085-088 Fax: + 389 2 3085-088 e-mail: [email protected]

Macedonian

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Figure – Public Grievance Form for SHPP Patiska Reka and SHPP Gradecka Reka

Public Grievance Form

Signature: _____________________________

Date: _____________________________

Please return this form to: Mr. Saso Gligorov Kozle 1-B, 1000 Skopje, Macedonia Phone: + 389 2 3085-088 Fax: + 389 2 3085-088 e-mail: [email protected]

Macedonian