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Southern Chattogram and Kaliakoir Transmission

Infrastructure Development Project

Stakeholder Engagement Plan (SEP)

Prepared by
Power Grid Company of Bangladesh Limited (PGCB)

May 2023
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Table of Contents
1. Introduction ....................................................................................................................................... 1
2. Objectives .......................................................................................................................................... 1
3. Project Description and Location ...................................................................................................... 2
4. Potential Impacts and Risks ............................................................................................................... 3
5. Previous Stakeholder Engagement Activities .................................................................................... 4
6. Stakeholder identification and analysis............................................................................................. 9
7. Stakeholder Engagement Program ................................................................................................. 12
8. Description of Engagement Methods.............................................................................................. 14
8.1 Engagement methods and tools in light of COVID-19 outbreak .................................................... 15
8.2 Advance Public Notification ........................................................................................................... 16
8.3 Communication with project affected people and vulnerable communities ................................ 16
8.4 Planned stakeholder engagement activities .................................................................................. 24
9. Grievance Redress Mechanisms ...................................................................................................... 30
10. Monitoring and Reporting .......................................................................................................... 32
10.1 Closing the Feedback Loop: Reporting back to stakeholder groups ............................................ 33
10.2 Points of contact .......................................................................................................................... 34
10.3 Roles and Responsibilities ............................................................................................................ 35
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Stakeholder Engagement Plan

1. Introduction
Power Grid Company of Bangladesh Limited (PGCB) under Ministry of Energy, Power and Mineral
Resources (MoEPMR) has taken up a project for construction of substations and transmission lines
named “Southern Chattogram and Kaliakoir Transmission Infrastructure Development Project” for
reliable power supply funded by the Government of Bangladesh (GoB) and Asian Infrastructure
Investment Bank (AIIB). Stakeholder consultations are important processes through which a two-way
dialogue is created between the PGCB and the stakeholders. Stakeholders are persons or groups who
are directly or indirectly affected by a Project, as well as those who may have interests in a Project and/or
the ability to influence its outcome, either positively or negatively. They can comprise individuals,
communities, social groups, organizations, etc. It is often observed that the poor and the marginalized
are often ignored either due to the fact that they are unaware or do not have a forum to voice their
opinion. Where properly designed and implemented, it supports the development of strong,
constructive and responsive relationships that are important for successful management of a project’s
environmental and social risks. AIIB’s Environmental and Social Framework (ESF) 2016 (Amended 2019)
also emphasizes that transparency and meaningful consultation is essential for the design and
implementation of a Project and works closely with its Clients to achieve this objective. Stakeholder
engagement is an inclusive process conducted throughout the project life cycle. By identifying and
consulting all stakeholders, especially the poor and the vulnerable, it is essential to ensure that the
Project meets the need of all sections of the people. This SEP has been developed as per findings of
Stakeholder Engagement during preparation of Resettlement Plan (RP), Environmental and Social
Impact Assessment (ESIA), Labor Management Plan (LMP) and Gender Based Violence (GBV) prevention
plan.

2. Objectives
The overall objective of this Stakeholder Engagement Plan (SEP) is to define a program for stakeholder
engagement, including public information disclosure and consultation, throughout the construction of
sub-stations (SS) and Transmission Lines (TL), other project activities, and operation of the proposed
projects. The SEP outlines the ways in which the project will engage national stakeholders, labors, and
contractors, and provide them with a mechanism through which people can raise concerns, provide
feedback, or make positive and negative complaints about the project(s) themselves.

The involvement of the local population and interested stakeholders is essential to the success of the
project in order to ensure smooth collaboration between project staff and local communities and to
minimize and mitigate environmental and social risks related to the proposed project. Stakeholder
engagement is an inclusive process conducted throughout the project life cycle. Where properly
designed and implemented, it supports the development of strong, constructive and responsive
relationships that are important for successful management of environmental and social risks identified
in a project. Communicating early, often, and clearly with stakeholders helps manage expectations and
avoid risks, potential conflict, and project delays.1 In addition, the plan assists in managing stakeholder
expectations, which will have a bearing throughout the lifespan of the project. Hence, this SEP provides
a plan to interact effectively with stakeholders to support project interests. The key objectives are:

1
Pollet., T (2014), A Strategic Approach to Early Stakeholder Engagement
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✓ Providing meaningful information in a format and language that is readily understandable and
tailored to the needs of the target stakeholder group(s) including all affected households and
interested groups including women in the community;
✓ Providing information in advance of consultation activities and decision-making;
✓ Disseminating information in ways and locations that make it easy for stakeholders to access it;
✓ Respect for local traditions, languages, timeframes and decision-making processes;
✓ Two-way dialogue that gives both sides the opportunity to exchange views and information, to
listen, and to have their issues heard and addressed;
✓ Inclusiveness in representation of views, including women, vulnerable and/or minority groups
✓ Processes free of intimidation or coercion;
✓ Clear mechanisms for responding to people’s concerns, suggestions, and grievances;
✓ Incorporating feedback into Project or program design and reporting back to stakeholders.

This SEP:
✓ Involves interactions between and among identified groups of people and provides stakeholders
with an opportunity to raise their concerns and share their opinions and ensures that this
information is taken into consideration when making decisions pertaining to the project.
✓ Begins early during the project planning process to gather initial views on the project proposal
and design.
✓ Encourages stakeholder’s feedback, especially as a way of informing the project design and
engagement by stakeholders in the identification and mitigation of environmental and social
risks and impacts.
✓ Ensures prior disclosure and dissemination of relevant, transparent, objective, meaningful and
easily accessible information in a timeframe that enables meaningful consultation with
stakeholders in a culturally appropriate format, in relevant local languages and is
understandable to stakeholders.
✓ Considers and responds to feedback.
✓ Supports active and inclusive engagement with project affected parties, project beneficiary
group, and interested parties.
✓ Ensures that implementation of the SEP will be documented and disclosed prior to Project
appraisal.
✓ Suggest formation of Grievance Redressed Committees at different levels so that people can
raise their concern without any fear.

In addition, this SEP will endeavor to disclose information that will allow stakeholders to understand the
risks and impacts of the project as well as potential opportunities. And, it will provide stakeholders with
access to information, as early as possible before the AIIB proceeds to project appraisal, and in a
timeframe that enables meaningful consultations with stakeholders on project design.

3. Project Description and Location

To distribute uninterrupted and quality power in Chattogram, Cox’s Bazar, and Gazipur area new sub-
stations and associate transmission lines (TLs) are going to be constructed in that area. Major
components of the Project are-

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Table 1: Project Interventions and Locations

Name of Land Size SS Required Bays Associated Length (Km)
Substations (acre) Type Transmission Lines
230/132/33kV SS: 20 GIS 230kV: LB=8; TB=2; Anwara-Cox’s Bazar (N) 230kV
Anwara BCB=1 double circuit line (Initially
2x250/350 MVA Charged at 132kV)
(230/132kV) 132kV: LB=2; TB=4
2x80/120 MVA
(132/33kV) 105
(Future 400 kV 33kV: TB=2
Provision)
132/33kV GIS 10 GIS 132kV: LB=8; Anwara-Cox’s Bazar (N) 230kV
Substation: CBB=2; TB=3; double circuit line (Initially
Cox’s Bazar Spare=1; BCB=1 Charged at 132kV)
3x80/120 MVA 33kV: TB=3 LILO of Dohazari-Cox’s Bazar 1.09
(Future 230 kV 132kV four circuit transmission
Provision) line
132/33kV GIS 5 GIS 132kV: LB=2; TB=2; Cox’s Bazar to Teknaf 73.10
Substation: Teknaf BCB=1 132 kV double circuit transmission
2x80/120 MVA 33kV: TB=2 line
230/33kV GIS 5 GIS 230kV: LB=2; TB=2; Existing Kaliakair SS to BHTC 4.88
Substation: BCB=1 230kV double circuit transmission
BHTC line (230kV Bay Extension at
2x125/140 MVA 33kV: TB=2 Kaliakair: 2 Nos.)
4 Nos. 40 Total (Transmission Line) 184.07

4. Potential Impacts and Risks

Four proposed sub-stations require total 40 acres of land. Out of 40, 35 acres are private land which
require land acquisition, and the remaining 5 acres is owned by Bangladesh Hi-tech Park Authority
(BHTPA). BHTPA following the policy of World Bank has carried out a SIA and an abbreviate RP
respectively for BHTC. According to the report, they paid applicable compensation to the affected people
after receiving the land from T&T Board. For construction of substations a total of 233 households (644
persons) will be affected. Besides, 17 sharecroppers and 69 wage earners will also lose their income due
to acquisition of land.

A total of about 763 towers will have to construct for laying the transmission lines, of which 223 are
angel towers and 540 are suspension towers. Out of 763 towers, 420 will be constructed on agricultural
land and 343 on the non-agricultural land, resulting crops of agricultural land may be damaged. For each
angel and suspension tower, 225 sqm (15m X 15m) and 100 sqm (10m X 10m) have been considered for
230 kV and 132kV transmission lines respectively. Hence, a total of 18.07 acres of agricultural land will
be affected.

As per Census, a total of 248 HHs will be affected for the construction of substations and associated
transmission lines. Among them 233 HHs will lose their agricultural land and 15 HHs due to construction
of transmission lines as they are under the RoW. The overhead transmission lines will include agricultural
land, settlement areas, rivers, etc. Any physical displacement and economic losses due to construction
of TLs, will be compensated according to entitlement proposed with the RP of this project.

Affected households (land owners, lessees, sharecroppers) mainly cultivate rice and vegetables on that
land. Thus, will lose their work/employment, and wages/income, which will reduce earning scope of
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affected people and will have an impact on their income and livelihoods. In fact, the lands earmarked
for substations are fertile land cultivated by farmers in several seasons of the year and planned to
construct ‘future houses’ by land-filling as they are located closer to the main roads. Because of the
rerouting, the line will pass through Government owned/ fallow land and therefore number of
sharecroppers or affected people remain almost unchanged, but if any issue arises during the
implementation period, the issues will be resolved by the PD Office/ Consultant/ Contractor accordingly
based on the Check survey reports as per the GoB and AIIB guidelines and the Stakeholder Engagement
Plan will be duly updated.

Regarding the Displaced Rohingya People, the nearest distance is boundary of Camp 01E is about 225-
meter, Camp 07 about 330-meter, Camp 08E about 227-meter away from proposed transmission line.
Cox’s Bazar to Teknaf Highway is located between the Camps and proposed transmission line. It was
found that about 6.10km of transmission line (AP 47 to AP 59) will pass with the periphery of Kutupalong
Rohingya Camps. So, construction of transmission line may not have any negative impact on Rohingya
Camps. It is expected that there will be no direct negative impacts on the displace Rohingya People (DRP)
due to construction of TL. However, to avoid any unexpected impacts during construction on the DRP
and construction workers, project has prepared a Labor Management Plan (LMP) and ESIA.

There is a risk of engaging Rohingya refugees as labor by the contractor. Moreover, among the refugees,
about 50% are child and they tend to engage themselves with the construction related activities of the
project. Project construction labors and Rohingya female may be at risk of gender-based violence (GVB),
since there about 50% are Rohingya women and girls. Risk of fire by the construction activities of the
project may affect camps. Noise due to civil work during construction phase can affect the community.
However, a labor management plan (LMP) is being prepared by the project and LMP guides that
following existing guidelines and practices, Rohingya people may not be engaged in construction work.

Due to the potential pollution, impacts on natural habitat, health and safety issues associated with
construction activities, livelihood impacts on the neighborhood, impacts on gender and labor influx as
the result of the construction of SS and TLs, the Project is assigned a Category A as it is likely to have
significant adverse environmental and social impacts that are irreversible, cumulative, diverse or
unprecedented.

5. Previous Stakeholder Engagement Activities

In order to assess stakeholder needs, expectations, perceptions, and choices, and to ensure their rights
and voices, a two-fold consultation processes was carried out during the survey. Thus, Consultations
were conducted firstly with both the primary and secondary stakeholders. Later, affected persons of
different occupations were consulted through FGDs. Three consultations were carried out at three
different locations of the project areas. Public Consultation Meeting 1 (PCM-1) was carried out at Parki
Bazar, Anwara, PCM-2 was carried out at Bangla Bazar, Cox’s Bazar Sadar and PCM-3 was carried out at
Sutrapur, Kaliakair. The total number of participants in three SCMs was 63.

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Table 2: Schedule and number of participants of SMCs

Sub-stations Meeting place Mauza Upazila/District Date Time No. of
Area participants
Anwara Sub- Parki Bazar Dudkumar Anwara, 27/07/2020 05:00 29
station adjacent to the Chattogram pm
proposed
substation of
Anwara
Cox’s Bazar Bangla Bazar Khurulia Cox’s Bazar 23/08/2020 02:30 14
Sub-station adjacent to the Sadar, Cox’s pm
proposed Bazar
substation of Cox’s
Bazar
Bangabandhu Sutrapur, Kaliakair Sutrapur Kaliakair 21/07/2020 12:00 20
high-tech pm
Park
Total 63

The specific issues and concerns within the primary stakeholders were obtained from the FGDs. Six (6)
FGDs were conducted at different locations of the project areas with different occupational groups
including businessman, farmer, teacher, day labor, transport labor, service holder, mason and
shopkeeper. All the FGDs were conducted near the substations area. A total of 52 participants from
different groups were attended in six (6) FGDs.
Table 3: Meeting schedule and number of participants of FGDs
Sub-stations Meeting place Mauza Upazila/District Date Time No. of
Area participants
Anwara Sub- Gobadia, Dudkumra Anwara, 08/09/2020 11:00 7
station Barashat Chattogram am
Cox’s Bazar Sub- Purbo Khurulia Cox’s Bazar Sadar, 10/07/2020 10:00 7
station Muktarpur Cox’s Bazar am
Cox’s Bazar Sub- Banglabazar Banglabazar Cox’s Bazar Sadar, 23/08/2020 02:45 12
station Cox’s Bazar pm
Teknaf Sub- Ali Khali, Hnila South Hnila Teknaf, Cox’s Bazar 17/08/2020 05:00 7
Station pm
Bangabandhu Sutrapur, Sutrapur Kaliakair, Gazipur 21/09/2020 11:00 12
Hi-Tech Kaliakair am
City
Bangabandhu Bagchapai, Chapai Kaliakair, Gazipur 21/09/2020 2:40 7
Hi-Tech Kaliakair am
City
Total 52

The details and/or summary of consultations for different areas held with issues raised or discussed and
suggestions provided by the respective primary stakeholders are presented in 4.

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Table 4: Details of Consultations Held for the Project

Major Issues Issues and concerns raised Response from the project
Awareness • Most of the participants are not • Project will bring many positive benefits
about the aware of the proposed substations. to the local communities. The project will
proposed Only local government improve and stabilize the power supply.
project representatives are aware because Moreover, if the electricity supply
the former consulting firm informed increases, it will create more livelihood
them regarding the substation. The opportunities and employment for
participants asked why this people.
substation is required. In Anwara, • Compensation will be paid as per
Teknaf and Cox’s Bazar, the Acquisition and Requisition of Immovable
participants opined that agricultural Property Act-2017 and policy of AIIB’s ESS
land will be affected due to 2
construction of substations and some
of the farmers will lose their total
agricultural land. They also asked
about the compensation package.
Benefits of • The participants expected that • The economic and social development
the Project transmission lines will contribute to will be increased. New industries will be
improved village and household constructed due to availability of power
power supply, reduce load shedding, supply. Local people will get job in that
stable supply of electricity to irrigate industries and economically benefitted.
crop cultivations, uninterrupted Due to construction of substation new
power supply at night for children’s investment in different sectors will be
studies, development of industries increased as available power supply is
and commercial centers and mandatory for establishing any
employment for our unemployed development entities;
people in civil works; • Incessant electricity supply with full
• Ensure incessant electricity supply voltage in the project area will be
with full voltage in the project area; ensured;
• Setting up new industrial area along • Installation of substation will invite allied
with small and medium industry using infrastructure e.g. road, industry; which
the generated power; would impact indirectly on the land price.
• Construction of road, industry; The price of land will rise likely due to
• Employment opportunities will be enhanced economic activity;
increased to some extent. • PGCB will negotiate with the construction
• Permanent employment for educated contractors to place their priority in local
youth at substations specifically labor in recruiting labor teams for civil
affected households as per their skill. works.
Lack of working opportunity can
create frustration among the affected
people. This may lead them to
committing crimes and may make the
society unstable.
Loss of land, • Some landowners are not entirely • Compensation for all losses caused to the
livelihoods dependent on the land that will be APs will be paid at replacement cost
and incomes acquired, and they live elsewhere irrespective of the title of the AP as per
and either in Chattogram, Dhaka or the provisions in the ARIPA, 2017 and in
compensation abroad. Their lands are cultivated by compliance with AIIB’s ESS 2 policy; If
tenants or sharecroppers. These there is a gap between statutory
landowners are willing to sell their compensation and the replacement cost,

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Major Issues Issues and concerns raised Response from the project
land so that they can get rid of the the gap will be bridged by PGCB based on
tenants and sharecroppers. Others assessments and recommendations of
are exclusively dependent on the land the Property Assessment and Valuation
that will be acquired for substations, Committees (PAVC) to be appointed by
and they will lose a stable source of PGCB;
food for their families, livelihoods and • Compensation for crop losses will be paid
income. Landowners losing their land for a period of one year and taking into
for substations should be paid a consideration the loss of incomes and
higher compensation over and above investments of the farmers. Farmers will
the mouza rate to enable them to also be allowed to cultivate underneath
purchase alternate agricultural land; the transmission tower base areas;
• Transmission towers will restrict the • Compensation will be paid for the trees
land use. Tractors and machinery to be removed. Also, tree owners will be
cannot be used. Productivity of the allowed to retain the timber from the
land will decrease. Civil works will trees;
cause crop losses and restrict • Compensation will be paid at
farmers’ access to their cultivated replacement cost enabling people to
areas for several seasons; purchase alternate land. The project will
• Removal of fruit-bearing and timber assist the APs to find alternative land
trees will reduce incomes; either for outright purchase or leasing.
• Project should consider allocating Leaseholders and sharecroppers will be
alternate land of similar quality to compensated for their crop and income
people who lose their land and losses. Furthermore, they will be assisted
specifically to the leaseholders and to find alternate land;
sharecroppers who are exclusively • Project has tried to avoid/minimize
dependent on acquired land for their resettlement impacts and particularly the
livelihoods and incomes. Affected residential areas, and none of lands
people (land owners, lessees, earmarked for substations are within the
sharecroppers) mainly cultivate rice residential areas. The location is
and vegetables in the affected land proposed by a team of professionals
and thus, will lose their considering the engineering and
work/employment, and technical requirements. However,
wages/income which will reduce community concerns over the land will be
earning scope of affected people and further reviewed by PGCB;
will have an impact on their income • The landowners who live abroad can
and livelihoods; appoint a power of attorney on their
• The lands earmarked for substations behalf. Or else the compensation money
are fertile land cultivated by farmers will remain in DC’s account and the
in several seasons of the year and eligible parties can claim the money
planned to construct ‘future houses’ whenever they are available by showing
by land-filling as they are located evidence in support of their claims and
closer to the main roads. Land ownership.
acquisitions will adversely affect the
activities and expectations of the
landowners. Project should consider
selecting alternative land;
• What is the procedure for landowners
who live abroad to claim their
compensation

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Major Issues Issues and concerns raised Response from the project
Avoidance • Transmission lines should avoid • Route plan of transmission lines has been
and traversing public places like schools, developed avoiding traversing public
safeguards mosques, graveyards, madarasa, places like schools, mosques, graveyards,
markets etc. as well as residential madarasa, markets etc. as well as
dwellings of the people; residential dwellings of the people.
• Transmission lines and towers can Installation of transmission towers will
cause possible electrocution, avoid residential areas and other public
accidents, fires and damages to trees spaces. If unavoidable, project will
and crops particularly during natural provide compensation at replacement
disasters like heavy rains, lightening, cost and other rehabilitation and
storms and winds; restoration assistance. PGCB ensures that
• Route plan should be developed transmission lines do not cause
avoiding elephant movement path as population displacements. People can
there are 19 elephants in that area live in the same places if distance
and they use path near Ramu between the roof of their structures and
Cantonment; the transmission conductors are
• The authority should develop route maintained at 7-8 meters;
plan considering Rohingya Camp • PGCB will ensure that all required safety
areas; measures are followed by contractors
during substation construction and PGCB
officers during its operations;
• Route plan has been developed avoiding
elephant movement path near Ramu
Cantonment;
• Route plan has been developed
considering Rohingya Camp area and
minimum 225 meters away from the
Rohingya Camp areas.
Risks and • Sound and air pollution will increase • Necessary safety measures such as
hazards during construction of the substation; erecting bamboo sheds over the built
• Risk of accidental occurrence might structures and fencing off the
be increased beside the substation construction sites will be adopted by the
area; contractors during conductor stringing.
• Risks associated with cultivation of Civil works will be scheduled to avoid
land under this high-power line, cultivation seasons, and peak periods for
particularly during the rainy season; other livelihood activities;
• Transportation of construction • Contractors will be obliged to avoid
material can cause traffic congestion, traffic congestion and follow health and
dust and noise emissions; safety guidelines to control dust
• Landfilling for substations can disturb emissions and noise generation. PGCB
the drainage systems and would officers will monitor the performance of
adversely affect the rest of the lands, the contractors and compliance with
water logging, floods, etc. safeguards requirements;
• Construction work of the • The final engineering designs will study
transmission lines should not damage the drainage systems and necessary
utility services and our water sources measures would be incorporated to avoid
and pumps; environmental hazards;
• Civil works of the project will lead to • No utility services or water sources will
influx of migrant labor teams; their be affected. If affected, project will
possible misconduct and engagement restore them at its own cost within a
in sexual harassment of women; drug reasonable time frame;

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Major Issues Issues and concerns raised Response from the project
peddling and abuse, human • PGCB and the contractors will endeavor
trafficking, etc. to minimize labor influx and place priority
• Compensation payments should not in local labor. Awareness raising
be delayed. Middlemen interfering programs will be conducted for labor
with compensation process and teams. It will be a mandatory
seeking bribes should be avoided. It requirement for the contractors to
should be a trouble-free process for enforce a code of conduct for the labor
APs. teams. PGCB will establish a grievance
redress mechanism (GRM) to facilitate
any affected/aggrieved parties to report
their grievances/complaints and seek
resolution within a reasonable time
frame;
• PGCB together with DC will ensure that
compensation is paid on due time and
before taking possession of land.
Compensation will be paid directly to the
landowner/ claimant through a cheque.

6. Stakeholder identification and analysis

In order to ensure effective engagement and open, frequent and honest dialogue with local
communities and other key stakeholders, a stakeholder engagement plan is designed throughout the
life of the Project. This plan is to be developed and implemented in order to identify stakeholder and
their issues of concern, establishes the methods for consultation, and provides a specific action plan for
stakeholder engagement throughout the life of the Project.
Table 5: Stakeholder Assessment
Key Stakeholders
Project Proponent : Power Grid Company of Bangladesh (PGCB)
Related organizations/ Local : DOE, DOF, DAE, RHD, BR, BWDB, Department of Fisheries, Ward
government Commissioner/UP member (male and female)
Local people : Businessmen, Service holder, Farmers, Day Labor, Teacher,
Transport Worker, Homemaker, Shopkeeper, etc.
Non-Governmental Organizations : Nishorgo, CODEC, IUCN
Engagement Methods
ESIA phase : − Organizing consultation meetings by inviting key
stakeholders above at draft scoping report and draft ESIA
report
Pre-construction/ Construction : − Regular communication with local community through
phase/ Regular operation Phase personal contact;
− Meeting with the representative of village on the quarterly
basis;
− Participatory meeting with villagers;
− Interpersonal Interview with villagers.
Information Disclosure
ESIA phase: : − Disclosures of draft ESIA report once cleared by line ministry
Pre-construction/ Construction and AIIB.
phase/ Regular operation Phase
− Grievance mechanism process and complaints register

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All phase : − Receiving complaints and opinions from the public on regular
basis through the engagement method;
− Meeting with the representative of villagers;
− Participatory meeting with villagers.

All the stakeholders have been primarily categorized into two categories that have been identified as:

 Primary Stakeholders: include people, groups, institutions that either have a direct influence on
the project or are directly impacted (positively or adversely) by the project and its activities i.e.
the grass-root stakeholders, such as project affected persons and general public including
women and people with physical disabilities residing in the project area (for the proposed
project: people living in the project area particularly the RoW) and the Rohigya community has
been considered as primary stakeholders for this project though they may not be affected by
the project directly;
 Secondary stakeholders: are those that have a bearing on the project and its activities by the
virtue of their being closely linked or associated with the primary stakeholders and due to the
influence, they have on the primary stakeholder groups.
 Apart from categorization, the stakeholders have also been classified in accordance with the
level of influence they have over the project as well as their priority to the project proponent in
terms of importance.
The stakeholders have been classified in accordance with the level of influence they have over the
Project as well as their priority to the Project proponent in terms of importance. The influence and
priority have both been primarily rates as:

 High Influence/Priority: This implies a high degree of influence of the stakeholder on the Project
in terms of participation and decision making or high priority for Project proponent to engage
that stakeholder.
 Medium Influence/Priority: This implies a moderate level of influence and participation of the
stakeholder in the Project as well as a priority level for Project proponent to engage the
stakeholder who are neither highly critical nor are insignificant in terms of influence.
 Low Influence/Priority: This implies a low degree of influence of the stakeholder on the Project
in terms of participation and decision making or low priority for Project proponent to engage
that stakeholder.
Based on the above attributes, the following table delineates the stakeholders identified for the Project
and their analysis.
Table 6: Stakeholder Mapping for the Project
Stakeholders Category of Brief profile Influence Basis of Influence Rating
stakeholder status
Management
Local Community Primary Primarily includes Medium • No major restrictions around
adjacent community the Project site
to the substations • Project bring development
and TL to the area
• Increase in employment
opportunities and
preference in job during
construction phase

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Stakeholders Category of Brief profile Influence Basis of Influence Rating

stakeholder status
• Improvement in electrical
supply and infrastructure in
the area
• Minimize impact
Directly Project Primary Those who will be High • May be displaced due to
affected people affected directly due land acquisition and
to construction of SS construction of SS
and TLs • Vulnerable HHs, Wage
labors and sharecroppers
will be economically
affected
Unidentified HHs Primary These hh were not High • If these HHs are not
traceable at the time identified or do not agree to
of project provide land for
survey/census construction of SS, this may
cause delay in project
implementation or may
cause alternative location
may require to consider
Power Grid Secondary PGCB is the Project Highest • Primary Project proponent
Company of proponent own a • Responsible for construction
Bangladesh (PGCB) controlling stake of and operation of this Project
100% in the Project • Primary financial
beneficiaries
• Responsible for all the
Project related risks and
impact liabilities
Community
Regulatory/Administrative Authorities & Agencies
Department of Secondary The Department of High Responsible for environmental
Environment (DOE) Environment is the clearance, management and
primary government monitoring including necessary
regulatory authority compliance throughout the
for Environmental Project lifecycle
protection in
Bangladesh.
Department of Secondary The Department of High Responsible for forest protection,
Forest (DOF) Forest is the primary conservation and management
government and provide permit for cutting
regulatory authority trees for width clearing of TL
for protection of during construction phase
forest in Bangladesh.
Ministry of Railway Secondary Ministry of Railway High Responsible for the construction
is the primary of new railway and maintenance
government of existing. Provides permit while
regulatory authority use the right-of-way and/or
for construction and crossing (overhead and
maintenance of underground) power and gas
railways in transmission and distribution
Bangladesh lines, etc.

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Stakeholders Category of Brief profile Influence Basis of Influence Rating

stakeholder status
Roads and Highways Secondary Roads and Highways High Responsible for the construction
Department (RHD) Department is the of new roads and highways, and
primary government maintenance of existing. Provides
regulatory authority permit while use the right-of-way
for the construction and/or crossing (overhead and
and repair of roads underground) power and gas
and highways in transmission and distribution
Bangladesh lines, etc.
Other Regulatory & Primary High • Agencies required for
Permitting obtaining permits and
Authorities licenses for operation of the
Project
• Primary involvement during
operation phases
Political Administration
Upazila (sub–District Secondary Elected Medium • Key linkage between the
Level) Political representatives of community and the PGCB
Administration people at sub-
district level for a
fixed tenure
Union/Ward leaders Secondary Elected Medium • Plays important role in
& local representatives at providing public opinion and
representative Union/Ward level sentiment on the Project
i.e., village level for a • Empowered to provide
fixed tenure consent and authorization
for establishment of Project
on behalf of the community

7. Stakeholder Engagement Program

Stakeholder engagement becomes a successful exercise when proper and participatory communicative
methods are used. This ensures that the stakeholders are kept engaged and well informed of the Project
development at every stage. A combination of communicative methods is usually used to engage with
the stakeholders. To determine which option is best suited to the various stakeholders, a benefit analysis
of each option can be carried out. The communicative methods are:

• General Information consisting of the Project’s various activities, the operation stage and impacts
that might arise shall be made available:
− on information board of Chattogram, Cox’s Bazar and Gazipur district, Anwara, Teknaf, Cox’s
Bazar Sadar and Kaliakair upazila, Barasat, Jhilwanja, Hnila and Sreefaltali union Offices of
the project areas
− on information board of PGCB
− on PGCB’s website
− in local newspaper
• Detailed information including documents like ESIA report; Environment, Health & Safety and Social
Policy, Environment Management Plan, RP, LMP including environmental decisions shall be in hard
copies and disseminated to:
− district, upazila, union/ward council Offices of the project areas

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− Project Site Offices

− Electronic version of these documents will be made available at PGCB’s website.
• In addition to this, a host of tools and techniques can be adopted to engage with the stakeholders
in a transparent and accountable manner. Below a list of the tools and techniques which can be
adopted are mentioned:

➢ Public Meeting: Public meeting should be arranged to disclose information on a large scale
involving the stakeholders of a particular village/union regarding project sites. A schedule of the
meeting can be circulated well in advance and discussions can involve feedback session from
the stakeholders. The meeting can be conducted in the premise of the adjacent school of the
Project for proximity and familiarity purposes. Once the meeting concludes, minutes of the same
should be kept as a record with the site office and a copy given to the ward member of the
respective area. Schedules of future meetings should be discussed and finalized so that the
stakeholders can gauge the seriousness of the Project proponent in continuing the engagement
process.

➢ Focus Group Discussion (FGDs): FGDs are important when gauging with a particular group of
stakeholders on issues related to the Project activities. FGDs should be conducted to understand
the needs, perceptions, concerns of the group. The discussion will give space for the participants
to voice their concerns and suggestions. The moderator of the FGD should be impartial in his/
her view and should encourage everyone present to participate in the discussion. Records of the
FGDs should be maintained and updated regularly.

➢ Participatory Workshops: Participatory workshops are meetings which enable local people to
analyze, share and enhance their knowledge to plan, manage and evaluate development
Projects and program. Visual aids–such as mapping, videos, illustrations, timelines, card sorting
and ranking, Venn diagrams, seasonal calendar diagramming and body maps can be used in
participatory workshops to engage participants and capture knowledge. Participatory Workshop
is an effective means of getting participants to reflect on issues and their own personal
experiences. These workshops also pay particular attention to group dynamics and breaking
down distinctions between ‘uppers’ – those with power, standing, influence, etc. within a
community – and ‘lowers’ – those with less power, influence and standing within a community.
To initiate such a workshop, an expert familiar with participatory tools and conducting such
workshops shall be engaged.

➢ Participatory Rural Appraisal (PRA) Techniques: PRA techniques are usually adopted to
emphasize local knowledge by enabling local people to make their own appraisal, analysis and
plan. PRA uses group animation and exercises to facilitate information sharing, analysis and
action among stakeholders. This process can be useful when the Project proponent initiates any
developmental activities in the area and uses the local knowledge to plan and strategize so that
they feel responsible for delivery of the objectives.

The consultation with the stakeholders will be conducted by PGCB, RP implementing NGO/firm and all
relevant project officials in collaboration with the Environment, Project Director/Site In charge at the
site level. Any grievances from the community relating to any issues that might arise from the Project
activities will be managed by the PGCB or its consultant, and/or RP implementing NGO/firm based at
the Site Office.

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The stakeholders will be informed in advance of the planned Project activities. The development of the
facilities will be based on the ESIA procedures and mitigation issues once an ESIA study has been
completed. Information on the summary of the ESIA draft will be disclosed to the public in the Bangla
for easier accessibility.

Consultations with the direct internal stakeholders will be provided separately from this document. At
a minimum, communication will involve meetings, information boards announcements and an Intranet
system to apprise the direct employees of PGCB regarding the procedures of emergency response
system, incident/accident reporting, grievance redressal mechanism, HR Policies and Procedures,
welfare measures etc. In addition, communication of general employment conditions, company’s code
of conduct for work site, EHS concerns, use of Personal Protective Equipment’s (PPEs), information and
awareness about the requirements of Bangladesh labour laws and minimum wages, working hours,
grievance redressal, retrenchment process etc. should be conducted with workers engaged with
contractors.

Project related information will be posted on the informational boards at the site office as well as at the
Corporate Level. Information on the Project milestones will be published in advance on the company’s
website to be available for the public and non-governmental organization to comprehend the attitude
of the external stakeholders. In addition, PGCB will publish information on the Project in the local
newspapers.

In turn, if any issues are raised by the stakeholders, the Project proponent management comprising of
the Grievance Committee at the Site Level will respond accordingly in the shortest possible time. Details
of which have been provided in the Grievance Redressal Mechanism Plan developed for PGCB.

The responsibility for the SEP implementation will be held by the Social Specialist based at the Head
Office of PGCB in Dhaka. He will be supported by the Director (HR & Administration - Corporate Level),
EHS Manager (from contractor site) and the Community Liaison Officer (both at the Site Level) of the
Company.

8. Description of Engagement Methods

Various methods of engagement will be used as part of the project’s interaction with the stakeholders,
to ensure that different stakeholder groups are successfully reached and are involved in the process of
consultation, decision-making and the development of impact management solutions.

Information that is communicated in advance of public consultations primarily includes an

announcement thereof in the public media – local, regional and national, as well as the distribution of
invitations and full details of the forthcoming meeting well in advance, including the agenda. In case of
international stakeholders’ engagement, advance invitation will be sent or be connected through social
media such as Skype, Viber, and WhatsApp etc. Due to Covid-19, tools and methods will be different-
using digital technology, phone calls, or traditional methods of communication (details given in Chapter
2) It is crucial that this information is widely available, readily accessible, clearly outlined, and reaches
all areas and segments of the target community. Following parameters will be used to achieve a
successful stakeholder’s engagement program:

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8.1 Engagement methods and tools in light of COVID-19 outbreak

With the outbreak and spread of COVID-19, people have been mandated by national or local law to
exercise social distancing, and specifically to avoid public gatherings to prevent and reduce the risk of
the virus transmission. Various restrictive measures have been adopted including some imposing strict
restrictions on public gatherings, meetings and people’s movement, and others advising against public
group events. At the same time, the general public has become increasingly aware and concerned about
the risks of transmission, particularly through social interactions at large gatherings.

WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and
Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk
Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk
communication package for healthcare facilities; (iv) Getting your workplace ready for COVID-19; and
(v) a guide to preventing and addressing social stigma associated with COVID-19. All these documents
are available on the WHO website through the following link:
https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance.

Given the COVID-19 pandemic situation, managing public consultation and stakeholder engagement in
the Project needs to adhere to national requirements and any updated guidance issued by WHO and the
World Bank. The alternative ways of managing consultations and stakeholder engagement will be in
accordance with the local applicable laws and policies, especially those related to media and
communication. The suggestions set out below are subject to confirmation that they are in accordance
with existing laws and regulations applying to the project.

With growing concern about the risk of virus spread, there was an urgent need to adjust the approach
and methodology for continuing stakeholder consultation and engagement. Considering the importance
of complying with national law requirements, below are some suggestions for stakeholder consultation
amidst COVID-19 outbreak:
• Identify and review planned activities under the project requiring stakeholder engagement and
public consultations.
• Assess the level of proposed direct engagement with stakeholders, including location and size
of proposed gatherings, frequency of engagement, and categories of stakeholders.
• Assess the level of risks of the virus transmission for these engagements, and how restrictions
that are in effect in the country / project area would affect these engagements.
• Identify project activities for which consultation/engagement is critical and cannot be
postponed without having significant impact on project timelines.
• Assess the level of ICT penetration among key stakeholder groups, to identify the type of
communication channels that can be effectively used in the project context.

Based on the above, specific channels of communication that will be used while conducting further
stakeholder consultation and engagement activities need additional considerations. The following are
some considerations while selecting channels of communication, in light of the current COVID-19
situation:
• Avoid public gatherings (taking into account national restrictions), including public hearings,
workshops and community meetings;
• If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus
group meetings; If not permitted, make all reasonable efforts to conduct meetings through
online channels, including WebEx, Zoom and Skype;

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• Be sure that everyone involved in stakeholder planning articulate and express their
understandings on social behavior and good hygiene practices, and that any stakeholder
engagement events be preceded with the procedure of articulating such hygienic practices.
• Diversify means of communication and rely more on social media and online channels. Where
possible and appropriate, create dedicated online platforms and chat groups appropriate for
the purpose, based on the type and category of stakeholders;
• Where direct engagement with project affected people or beneficiaries is necessary, identify
channels for direct communication with each affected household via a context specific
combination of email messages, mail, online platforms, dedicated phone lines with
knowledgeable operators;
• Each of the proposed channels of engagement should clearly specify how feedback and
suggestions can be provided by stakeholders;
• However, in situations where none of the above means of communication are considered
adequate for required consultations with stakeholders, PGCB should discuss whether the
project activity can be rescheduled to a later time. Where it is not possible to postpone the
activity or where the postponement is likely to be for more than a few weeks, IA should consult
AIIB Teams to obtain advice and guidance.

8.2 Advance Public Notification

Advance public notification of an upcoming consultation meeting will be given and it will be available
via publicly accessible locations and channels. The primary means of notification may include mass
media and the dissemination of posters/ advertisements in public places. The project keeps proof of the
publication (e.g., a copy of the newspaper announcement) for the accountability and reporting
purposes. Existing notice boards in the communities may be particularly useful for distributing the
announcements, such as boards adjacent to the widely visited public premises like local government
office (ward commissioner office/union Parishad), village markets, post offices, transport links, and
offices of the local NGOs. When the notifications are placed on public boards in open air, it should be
remembered that the posters are exposed to weather, may be removed by bypasses or covered by other
advertisements. The project’s staff will therefore maintain regular checks in order to ensure that the
notifications provided on the public boards remain in place and legible. In case of international
stakeholders, notice will be given through email, phone calls, through websites etc.

8.3 Communication with project affected people and vulnerable communities

Another critical aspect of the meeting preparation process is selecting the methods of communication
that reach the potential audience with lower levels of literacy or those who are not well-versed in the
technical aspects of the project. Oral communication is an option that enables the information to be
readily conveyed to such persons. This includes involving the selected community representatives/
village leaders/ local NGOs and initiative groups to relay up-to-date information on the project and
consultation meetings to other members of the community, particularly to those in remote areas of the
vicinity of the project sites of PGCB for a larger part of the year. Moreover, due to the construction of
SS and TLs, local communities, and local business might be affected as well. Advertising the project and
the associated meetings could be made via announcements or television and making direct calls and
through dedicated websites, social media and local FM Radio (mobile phone communication with
internet facility is widely available in Bangladesh) could be adopted for reaching out to the remote
audiences. The announcement of a public meeting or a hearing is made sufficiently in advance, thereby

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enabling participants to make necessary arrangements, and provides all relevant details, including date,
time, location/venue and contact persons. The following, when adopted give dividend:

• Making available a register for comments and suggestions by any member of the affected
community and general public to provide their written feedback on the contents of the
presented materials. As a rule, the register is made available for the entire duration of the
requisite disclosure period. Where necessary, a project representative or an appointed
consultant should be made available to receive and record any verbal feedback in case some
stakeholders experience a difficulty with providing comments in the written form.
• Drafting and communicating an agenda for the consultation meeting provides a clear and
itemized outline of the meeting’s structure, sequence, chairpersons, a range of issues that will
be discussed and a format of the discussion. This gives the prospective participants an
opportunity to prepare their questions and comments in advance. It is essential to allocate a
sufficient amount of time for a concluding Q&A session at the end of any public meeting or a
hearing to record comments and suggestions for subsequent incorporation into the project
design. The recorded comments and how they have been addressed by the project become an
appropriate material for inclusion in the project’s regular reporting to the stakeholders.
• Knowledge and advice of the community representatives and local NGOs are invaluable to
ensure that these aspects are fully observed. If deemed necessary, separate meetings and focus
group discussions will be held, as described above.

An attendance list is made available at the commencement of the consultation/hearing in order to

record all participants who are present at the meeting and their affiliation. Wherever possible,
attendees’ signatures should be obtained as a proof of their participation. Details of the attendees who
were not initially on the list (e.g., those participating in place of somebody else, or general public) should
be included in addition to those who have registered for the meeting in advance.

In most cases and as a general practice, the introductory initial part of the meeting or a hearing will be
delivered in a format that is readily understandable to the audience of laypersons and should be free of
excessive technical jargon. If necessary, preference should be given, whenever possible, to the oral and
visual methods of communication (including presentations, pictorials, illustrations, graphics and
animation) accompanied by hand-out materials imparting the relevant information in understandable
terms rather than as text laden with technical intricacies. Where technical specifics of the project’s
particular activities or solutions are required to be delivered in a greater detail, it will be ensured that
the information conveyed remains comprehensible to all members of the audience and that the
description of complex technicalities is adapted to their level of understanding, thereby enabling
productive feedback and effective discussion.

If a large audience is expected to attend a public meeting or a hearing, necessary arrangements will be
made to ensure audibility and visibility of the presentation and any demonstrations involved. This
includes provision of a microphone, proper illumination, projector, places allocated for the wheelchair
users and covid management procedures etc.

Taking records of the meeting is essential both for the purposes of transparency and the accuracy of
capturing public comments. At least three ways of recording may be used, including: Taking of written
minutes of the meeting by a specially assigned person or a secretary; Audio recording (e.g., by means of
voice recorders); and Photographing.

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Questions provided in the evaluation form on the consultation may cover the following aspects:
✓ Participant’s name and affiliation (these items are not mandatory if the participant prefers to
keep the form confidential)
✓ How did they learn about the Project and the consultation meeting?
✓ Are they generally in favor of the Project?
✓ What are their main concerns or expectations/hopes associated with the Project or the
particular activity discussed at the meeting?
✓ Do they think the Project will bring some advantages to their community as a whole?
✓ Is there anything in the Project and its design solutions that they would like to change or
improve?
✓ Do they think that the consultation meeting has been useful in understanding the specific
activities of the Project, as well as associated impacts and mitigation measures? What aspects
of the meeting they particularly appreciated or would recommend for improvement?

Bearing in mind that some of the participants might find completion of the evaluation form challenging
due to the literacy constraints or concerns about their confidentiality, the distribution of the feedback
forms should always be explained that filling the form is optional. Some persons may be willing to
express their feedback verbally and in this case a member of Project staff will be allocated to take notes.

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Table 7: Methods, Tools and Techniques for Stakeholder Engagement

Method / Tool Description and Use Contents Dissemination Method Target Groups
Information Provision
Distribution of Used to convey information on Printed materials present Distribution as part of consultation Households in Project
printed public the Project and regular updates illustrative and written meetings, public hearings, Area of Influence.
materials: leaflets, on its progress to local, regional information on Project discussions and meetings with Residents in the project
brochures, fact and national stakeholders. activities, facilities, stakeholders, as well as household area and adjacent
sheets technologies and design visits in remote areas. communities
solutions, as well as impact Placement at the offices of local
mitigation measures. administrations and NGOs, libraries
Presented contents are concise and other public venues.
and adapted to a layperson
reader. Graphics and pictorials Once the project will be approved by
are widely used to describe the Bank and line ministry,
technical aspects. documents will be disclosed
Information may be presented
both in Bangla for local and
national stakeholders, and in
English for international
audience.
Distribution of A newsletter or an updated Important highlights of Project Circulation of the newsletter or Households in Project
printed public circular sent out to Project achievements, announcements update sheet with a specified Area of Influence.
materials: stakeholders on a regular basis of planned activities, changes, frequency in the Project Area of Public venues in Project
newsletters/ to maintain awareness of the and overall progress. Influence, as well as to any other Area of Influence – local
updates Project development. stakeholders that expressed their administrations,
interest in receiving these periodicals. communities.
Means of distribution – post,
emailing, electronic subscription,
delivery in person.
Visual Visually convey Project Description of the Project and Presentations are widely used as part Affected communities in
presentations information to affected related solutions/impact of the public hearings and other in the project area,
communities and other management measures. consultation events with various participants of the
interested audiences. Updates on Project stakeholders. public hearings,
development. consultations, rounds
PGCB will make use of this tool during tables, focus group
all public consultations, FGDs and discussions and other
other meetings where large group of

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Method / Tool Description and Use Contents Dissemination Method Target Groups
people will be gathered either to forums attended by
ventilate their concerns or to be Project stakeholders.
informed of progress of work of new
component/sub component.
Notice boards Displays of printed information Advance announcements of Printed announcements and Directly affected
on notice boards in public the forthcoming public events, notifications are placed in visible and communities in the
places. commencement of specific easily accessible places frequented by project area
Project activities, or changes to the local public, including libraries,
the scheduled process. village cultural centers, post offices,
shop, local administrations.

These would be regularly updated as

the simplest and most cost-effective
means to educate all about the
progress of the project, changes in
the plan or what is in the offing.
Notice Boards could also be used as a
tool for circulation of jobs for the
local population
Websites All the project activities, All contents mentioned above Through websites For all types of
documentation, notices, project will be displayed in the project stakeholders
Use of Dedicated updates will be published in the websites. Websites would be updated on
Website by PGCB project websites. regular basis. All circulation that are
including communicated through other means
dedicated social must be included in the website.
media platform
like Twitter,
Facebook,
WhatsApp, etc.
Information Feedback
Information Placement of Project-related Various Project-related Deposition of materials in publicly Directly affected
repositories information and printed materials, ESIA/SEP/RP/LMP available places (offices of local communities in the
accompanied by a materials in and other safeguard NGOs, local administrations, libraries) project area and all
feedback dedicated/designated locations documentation, environmental for the duration of a disclosure period interested stakeholders
mechanism that also provide visitors and and social action plans. or permanently. Audience is also
readers with an opportunity to given free access to a register for
comments and suggestions.

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Method / Tool Description and Use Contents Dissemination Method Target Groups
leave their comments in a As and when new material is
feedback register. available, it should be kept in the
repository
Surveys, The use of public opinion Description of the proposed Soliciting participation in Directly affected
Interviews and surveys, interviews and Project and related surveys/interviews with specific households in the
Questionnaires questionnaires to obtain solutions/impact management stakeholder groups or community Project Area of
stakeholder views and to measures. wide. Influence.
complement the statutory Questions targeting Administering questionnaires as part Other communities
process of public hearings. stakeholder perception of the of the household visits. within the Project Area
Project, associated impacts and of Influence.
benefits, concerns and To be conducted on need basis
suggestions.
Feedback & A suggestion box can be used to Any questions, queries or Appropriate location for a suggestion Directly affected
Suggestion Box encourage residents in the concerns, especially for box should be selected in a safe public households in the
affected communities to leave stakeholders that may have a place to make it readily accessible for Project Area of
written feedback and comments difficulty expressing their the community. Influence.
about the Project. views and issues during public Information about the availability of Other communities
Contents of the suggestion box meetings. the suggestion box should be within the Project Area
should be checked by communicated as part of Project’s of Influence.
designated Project staff on a regular interaction with local
regular basis to ensure timely stakeholders.
collection of input and
response/action, as necessary. Should always be available at the
project site throughout the lifecycle
of the project.
Feedbacks/Suggestions must be
addressed regularly and actions to be
circulated using appropriate means.
Consultation & Participation
Public hearings Project representatives, the Detailed information on the Wide and prior announcement of the Directly affected
affected public, authorities, activity and/or facility in public hearing and the relevant communities in the
regulatory bodies and other question, including a details, including notifications in Project Area of
stakeholders for detailed presentation and an local, regional and national mass Influence.
discussion on a specific activity interactive Questions & media. Other communities
or facility that is planned by the Answers session with the Targeted invitations are sent out to within the Project Area
Project and which is subject to audience. stakeholders. of Influence.
the statutory expert review.

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Method / Tool Description and Use Contents Dissemination Method Target Groups
Public disclosure of Project materials Residents of in the
and associated impact assessment Project Area of
documentation in advance of the Influence
hearing. Viewers/readers of the
materials are also given free access to
a register of comments and
suggestions that is made available
during the disclosure period.
Public hearing must be arranged as
and when required. Leaving aside the
construction related work, rest of the
project work is primarily academic
and may not be useful for public
hearing but useful for the relevant
stakeholders. Public hearing must
the relevant and address specific
components and subcomponents
Focus Group Used to facilitate discussion on Project’s specific activities and Announcements of the forthcoming Directly affected
discussion (FGD) Project’s specific issues that plans, design solutions and meetings are widely circulated to households in the
merit collective examination impact participants in advance. Project Area of
with various groups of mitigation/management Targeted invitations are sent out to Influence, youth,
stakeholders. measures that require detailed stakeholders. elderly, women, and
discussion with affected To be arranged as and when relevant other vulnerable
stakeholders. groups.
Dissemination of the outcome of the
FGD to be uploaded in the relevant
website and its reflection would also
be made conspicuous in the curricula,
Invitation for FGD to be and other linked platforms.
uploaded in the relevant
website
Information Project’s designated venue for Project-related materials. Information about the info center or Directly affected
centers and field depositing Project-related Any issues that are of interest a field office with open hours for the communities in the
offices information that also offers or concern to the local public, together with contact details, Project Area of
open hours to the community communities and other is provided on the Project’s printed Influence and any other
and other members of the stakeholders. materials distributed to stakeholders and
public, with Project staff interested parties.

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Method / Tool Description and Use Contents Dissemination Method Target Groups
available to respond to queries stakeholders, as well as during public
or provide clarifications. meetings and household visits.
Site Tours Visits to Project Site and Demonstration of specific Targeted invitations distributed to Local communities
facilities organized for local examples of Project’s design selected audience offering an within the Project Area
communities, authorities and solutions and approaches to opportunity to participate in a visit to of Influence.
the media to demonstrate managing impacts. the Project Site. Elected officials.
Project solutions. Limitation: possible safety Media groups.
Visitors are accompanied by the restrictions on the site access during NGOs and other
Project’s staff and specialists to active construction works. initiative groups.
cover various aspects and to
address questions arising from To be conducted periodically to
the public during the tour. monitor the progress of the project or
certain specific component/
subcomponent

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8.4 Planned stakeholder engagement activities

Stakeholder engagement activities will need to provide stakeholder groups with relevant information and opportunities to voice their views on
issues that matter to them. Table 8 presents the stakeholder engagement activities PIU and PMU will undertake for their project(s). The activity
types and their frequency are adapted to the three main project stages: project preparation (including design, procurement of contractors and
supplies), construction, and operation and maintenance.
Table 8: Stakeholder Engagement Activities
Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities
Project Affected People: ESIA, LMP, Gender and GBV Public meetings, separate During preparation and PGCB staff
People potentially prevention plan, SEP, RP meetings for women and detailed design stage- responsible for
Stage 1: Project preparation (Project design, Scoping, Resettlement
Planning, ESIA, LMP, GVP Plan and SEP preparation and Disclosure)

affected by land disclosures; vulnerable that would affect the land acquisition
acquisition, when Land acquisition process; area. or its consultant
triggered Assistance in gathering Face-to-face meetings
People residing in project official documents for Continuous
area authorized land use; Mass/social media communication through
Vulnerable households Compensation rates and communication (as mass/social media and
methodology; needed) routine interactions
Compensation packages; throughout RP
Project scope and Disclosure of written development as
rationale; information: brochures, needed.
Project E&S principles; posters, flyers, website
Resettlement and
livelihood restoration Information boards or
options; desks
Grievance mechanism
process; Grievance mechanism

Local news paper

The following modes to be

adopted specifically for the
vulnerable groups:

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• Robust engagement
with local community-
based organizations.
• The project would
arrange separate
consultation sessions
for different target
groups
• Resources allocation
towards local
administration
representatives and
councilors.
• Provision of
transportation or
transportation cost
particularly for the
disabled, marginalized
and the elderly ones
including women
• Engagement of local
NGO’s and CBO’s who
work with vulnerable
people at the
community level to
help disseminate
information and
organize consultations
• Separate consultation
with men and women
to be arranged
• Manageable and
gendered FGD to be
arranged so that

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Stakeholder Engagement Plan

Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities

women can speak
freely
• The project must have
adequate means to
reach the disabled ones
in the community. If
need be, teams must
visit the disabled ones
in their habitat
• Information may be
printed in Braille to
allow the blind ones to
have access to the
project details
Other Interested Parties ESIA, RP, LMP, SEP Public meetings, Throughout PGCB
(Internal) disclosures RP/ESIA/LMP/SEP and responsible for
Press and media Grievance mechanism Mass/social media GBV prevention plan land acquisition
NGOs Project scope, rationale communication development as or its consultant
Businesses and business and E&S principles needed;
organizations Disclosure of written
Workers' organizations information: Brochures, Project launch meetings
Academic institutions posters, flyers, website at local PGCB office and
National Government PGCB head quarter;
Ministries Information boards
Different Government Quarterly meetings in
Departments Grievance mechanism affected villages and
General public, Rohingya affected communities
communities, jobseekers Notice board for
employment recruitment Disclosure meetings in
local, national level

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Stakeholder Engagement Plan

Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities

Other Interested Parties Legal compliance issues Face-to-face meetings Disclosure meetings PGCB and PIU
(External) Reports as required
Other Government Project information scope Invitations to
Departments from which and rationale and E&S public/community
permissions/clearances principles meetings
are required;
Other project developers, Coordination activities Submission of required
donors reports
Land acquisition process

Grievance mechanism
process

Disclosures of E&S
documents
Project Affected People Grievance mechanism Public meetings, open Quarterly meetings PGCB, PIU, ESU,
houses, during construction or its consultants
STAGE 2: Construction and mobilization activities

People potentially Health and safety impacts trainings/workshops; seasons contractors,

affected by land (ESMP, community H&S, Separate meetings as
acquisition community concerns) needed for women and Communication RP implementing
vulnerable; through mass/social NGO
People residing in project Employment opportunities Individual outreach to PAPs media as needed
area Project status as needed;
Disclosure of written Notice boards updated
Vulnerable households information: brochures, weekly
posters, flyers, website
Information boards in PGCB Routine interactions
Notice board(s) at Brochures in local
construction sites, offices
Grievance mechanism and
as guided with ESF
documents mainly RP and
ESIA.

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Stakeholder Engagement Plan

Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities

Rohingya Camp authority Project activities, duration, Face to face meetings, As and when required. PGCB, PIU, ESU
and communities OHS measures, fire safety meeting at site 1st meeting before the or its consultant,
measures, etc. management, RRRC and construction starts contractors,
IOL office
Vulnerable communities Vulnerable group has to be Face to face, consultation, Before the construction PGCB, PIU, ESU
and project affected identified considering the FGD etc. starts and during the or its
people households which are (i) construction period consultants,
living below the official contractors,
poverty line; (ii) women
headed households living RP implementing
below the official poverty NGO
line; and (iii) headed by
elderly persons or disabled
persons.

Announcement of
vacancies (skilled/unskilled)
at proposed site;

Announcement of contract
work for small scale work
associated with the
proposed Project;
Other Interested Parties Project scope, rationale and Face-to-face meetings As needed (monthly PGCB, PIU, ESU or
(External) E&S principles during construction its consultant,
Joint public/community season) contractors
Governmental Grievance mechanism meetings with PAPs
committees for land use
and compensation Project status
representatives in villages
Bank compensation
requirements

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Stakeholder Engagement Plan

Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities

Other Interested Parties Project information - scope Public meetings, open Same as for PAPs Same as above
(External) and rationale and E&S houses,
Press and media principles trainings/workshops
NGOs Project status Disclosure of written
Businesses and business Health and safety impacts information: brochures,
organizations Employment opportunities posters, flyers, website,
Workers' organizations Environmental concerns Information boards Notice
Academic institutions Grievance mechanism board(s) at construction
National Government process sites
Ministries Grievance mechanism
Various Government
Departments
General public, tourists,
jobseekers
Other Interested Parties Grievance mechanism Grievance mechanism As and when required PGCB Staff, PIU,
(External) process PGCB website ESU or its
Press and media Issues of concern Face-to-face meetings consultant
NGOs Status and compliance Submission of reports as
Businesses and business reports required
organizations
Workers' organizations
Academic institutions
Local Government
Departments
General public, tourists

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9. Grievance Redress Mechanisms

The Project Proponent would establish a procedure to deal with and resolve any queries as well as
address complaints and grievances about any irregularities. In this regard, a policy and/or guideline
will be prepared and adopted for assessing and mitigating potential social and environmental
impacts through grievance redress mechanism (GRM). The GRM will deal with complaints and
grievances related to both social/resettlement and environmental issues of the Project. Grievance
Redress Committees (GRC) will be formed to receive and resolve complaints as well as grievances
from aggrieved persons from the local stakeholders including the Project-affected persons. Based
on consensus, the procedure will help resolving issues/conflicts amicably and quickly, saving the
aggrieved persons from having to resort to expensive, time-consuming legal actions. The GRCs will
be established through a gazette notification from the Ministry of Power, Energy and Mineral
Resources (MoPEMR); therefore, the GRC will be a legally constituted body.

The Grievance Redress Committee (GRC) will be established locally at Project sites and centrally at
the Project level to receive and settle grievances from the affected persons and other local
stakeholders. Most of the grievances will be resolved at the local-level GRC (LGRC), but those cases
that cannot be resolved at the local level will be forwarded to central level. The local level GRC will
be constituted with the following persons:
1. Executive Engineer, PGCB: Convener
2. Representative of INGO (Non-voting): Member-Secretary
3. Chairman of Union Perished (UP) concerned: Member
4. Female member of ward of the UP concerned: Member
5. Retired teacher from the union concerned: Member
6. Representative of PAPs: Member

The RP implementing NGO will keep a close liaison with the affected people and discuss any type of
issues, observation, complaints at focus group discussion (FGD) meetings on a weekly or fortnightly
basis. Most of the issues will hopefully be settled in the focus group meeting but some issues
requiring formal hearing and resolution will be brought to the Grievance Redress Committee (GRC)
for resolution in form of a formal complaint. All complaints will have to be received at the local
(Union) level GRC (LGRC) and resolved within a certain period (maximum four weeks from the date
of lodging the complaints) as per circular of the MoPEMR (gazette notification). If the resolution
attempt at the local level fails, the LGRC will refer the complaint with the minutes of the hearings to
the PGRC.

To ensure impartiality and transparency, hearings on complaints will remain open to the public. The
GRCs will record the details of the complaints and their resolution in a register, including intake
details, resolution process and the closing procedures. PGCB will maintain the following three
Grievance Registers:
Intake Register: (1) Case number, (2) Date of receipt, (3) Name of complainant, (4) Gender, (5) Father
or husband, (6) Complete address, (7) Main objection (loss of land/property or entitlements), (8)
Complainants’ story and expectation with evidence, and (8) Previous records of similar grievances.
Resolution Register: (1) Serial no., (2) Case no., (3) Name of complainant, (4) Complainant’s story
and expectation, (5) Date of hearing, (6) Date of field investigation (if any), (7) Results of hearing and
field investigation, (8) Decision of GRC, (9) Progress (pending, solved), and (10) Agreements or
commitments.
Closing Register: (1) Serial no., (2) Case no., (3) Name of complainant, (4) Decisions and response to
complainants, (5) Mode and medium of communication, (6) Date of closing, (7) Confirmation of
complainants’ satisfaction, and (8) Management actions to avoid recurrence.

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Grievance resolution will be a continuous process in project level activities and implementation of
those. The PIC will keep records of all resolved and unresolved complaints and grievances (one file
for each case record) and make them available for review as and when asked for by Bank and any
other interested persons/entities. The PIU also prepares periodic reports on the grievance resolution
process and publish these on the PGCB website.

The PGCB intends to strengthen the GRM through information and communication technology to
ensure that all complaints including those of sexual exploitation and abuse are immediately reported
to the PGCB. The complaints registered in this system will be managed by a dedicated administrator
that will liaise immediately any GBV and SEA complaints with the contractors, consultant and
PGCB/PIU/ESU for immediate measures. If the GRM receives a case on sexual exploitation and abuse
related to the project, it will be recorded with due consideration to the confidentiality and privacy
of the complainant, and with the consent of the complainant will be referred to the relevant
assistance, if needed, for referral to any other service providers. The first cut of mapping of GBV
service providers focused exclusively on services that respond to gender-based violence in
Bangladesh. The mapping includes nation-wide a total of 135 service providers, within which around
50 SPs are based in the Chattogram division. The ESU/PGCB or its consultant will keep the
information confidential to protect privacy of GBV and SEA complainants. In cases, where the
perpetrator(s) is linked to project activities then the contractor will take appropriate actions as per
the Code of Conduct signed by the particular person and under the effective law in Bangladesh. PGCB
will report activities and outcomes of GBV and SEA surveillance and management to the AIIB on a
regular basis. For further details, please GBV prevention plan.

To ensure that grievance redress decisions are made in formal hearings and in a transparent manner,
the Convener will apply the following guidelines:
i. A standard application format will be used for receiving grievances which will be available
at the office of NGO /Consulting firm. This application format would be concurred by the PD.
ii. Reject a grievance redress application with any recommendations written on it by a GRC
member or others such as politicians and other influential persons.
iii. Remove a recommendation by any person that may separately accompany the grievance
redress application.
iv. Disqualify a GRC member who has made a recommendation on the application separately
before the formal hearing.
v. Where a GRC member is removed, appoint another person in consultation with the Project
Director.
vi. The Convener will also ensure strict adherence to the impact mitigation policies and
guidelines adopted in this RAP and the mitigation standards, such as compensation rates
established through market price surveys.

The following steps will be followed for the successful implementation of GRM.

• Step 1: Project stakeholders will be able to provide feedback and report/record

complaints through several channels: in person at offices and at project sites, and by
mail, telephone, and email.
• Step 2: Complaints and feedback will be compiled by the secretary in each level and
recorded in a register. He or she will place the grievances to the committee and the
complained person with the goal to resolve complaints within 15 days of receipt.
• Step 3: Within seven (7) days of the date a complaint is submitted; the responsible
person will communicate with the complainant and provide information on the likely
course of action and the anticipated timeframe for resolution of the complaint. If
complaints are not resolved within 15 days, the responsible person will provide an

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update about the status of the complaint/question to the complainant and again
provide an estimate of how long it will take to resolve the issue.
• Step 4: This step involves gathering information about the grievance to determine the
facts surrounding the issue and verifying the complaint’s validity, and then developing a
proposed resolution. Depending on the nature of the complaint, the process can include
site visits, document reviews, a meeting with the complainant (if known and willing to
engage), and meetings with others (both those associated with the project and outside)
who may have knowledge or can otherwise help resolve the issue. It is expected that
many or most grievances would be resolved at this stage. All activities taken during this
and the other steps will be fully documented, and any resolution logged in the register.
• Step 5: This step involves informing those to submit complaints, feedback, and questions
about how issues were resolved, or providing answers to questions. Whenever possible,
complainants should be informed of the proposed resolution in person. If the
complainant is not satisfied with the resolution, he or she will be informed of further
options, which would include pursuing remedies through the World Bank, as described
below. Data on grievances and/or original grievance logs will be made available to AIIB
missions on request, and summaries of grievances and resolutions will be included in
periodic reports to the AIIB.

10.Monitoring and Reporting

Monitoring of Project activities is necessary to cater to the stakeholder’s concerns by ensuring
transparency in guaranteeing the PGCB’s commitment in implementing the mitigation measures
that addresses the environmental and social impacts arising from the Project.
Through this information flow, the local stakeholders feel the sense of responsibility for the
environment and welfare in relation to the Project and feel empowered to act on issues that might
affect their lives.

PGCB should undertake a commitment in undertaking internal audits every quarter. All related
information shall be readily maintained at the site office and produced at the time of the audits.
Audit reports shall be accordingly created after every quarterly audit and submitted to the Social
Officer. All records of these reports shall be maintained at the site office as well as the Corporate
Office. In addition, an external auditor shall be engaged every six monthly to assess the activities of
the Project and its mitigation measures. The auditor shall accordingly submit a report to the
company for review and this should be forwarded to the lender financing the Project as well.

The monitoring report will include clear and specific indicators both as regard the engagement with
stakeholders and also the project’s grievance redress management. PGCB or its consultant will work
on a reporting matrix in this regard.
Table 09: Monitoring report Matrix
Key elements Timeframe Methods Responsibilities
Stakeholders’ access to Periodic (during project Interviews, PIU and ESU
project information and preparation and observations, together with Social
consultations maintained throughout survey and Environmental
project implementation) monitor
Project beneficiaries’ Periodic (during project Interviews, PIU/ESU and/or its
awareness of project implementation) observations, consultant
activities, their survey
entitlements and
responsibilities

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Key elements Timeframe Methods Responsibilities

Acceptability and Periodic (during project Interviews, Same as above
appropriateness of implementation) observations,
consultation and survey, score-card
engagement approaches as relevant
Community facilitators’ Periodic (during project Interviews, Same as Above
engagement with target implementation) observations,
beneficiaries survey, score-card
as relevant
Accessibility and Periodic (during project Spot checks, ES Monitor
readability of public implementation) interviews, desk-
information review
dissemination materials
Tones in social media Periodic (during project Social media PGCB/PIU
and broader public implementation) monitoring,
perceptions (including interviews,
NGOs/CSOs) observations
Rate of grievances and Periodic (during project Desk review, PGCB and/or its
complaints (reported implementation) interviews, survey consultant
and unreported)

10.1 Closing the Feedback Loop: Reporting back to stakeholder groups

The project team will ensure regular/periodic reporting back and information sharing with the PAPs
and as well as the stakeholders’ groups. This ‘reporting back’ measures vis-à-vis the PAPs should be
always carried through face-to-face meeting or direct interactions, for the other stakeholders’ group,
although this may be adjusted considering the COVID-19 situation. Other pertinent media, such as
website, social media, press briefing, may also be used.

Monthly summaries and internal reports on public grievances, enquiries and related incidents,
together with the status of implementation of associated corrective/preventative actions will be
collated by responsible staff and referred to the senior management of the project(s). The monthly
summaries will provide a mechanism for assessing both the number and the nature of complaints
and requests for information, along with the Project’s ability to address those in a timely and
effective manner.

The Project through the social monitor will arrange necessary training associated with the
implementation of this SEP that will be provided to the members of staff who, due to their
professional duties, may be involved in interactions with the external public, as well as to the senior
management. Specialized training will also be provided to the staff appointed to deal with
community stakeholder grievances as per the Public Grievance Procedure. Project contractors will
also receive necessary instructions for the Grievance Procedure and in relation to the main principles
of community relations.

Information on public engagement activities undertaken by the Project during the year may be
conveyed to the stakeholders in two possible ways:

1. Publication of a standalone annual report on project’s interaction with the stakeholders.

2. A number of Key Performance Indicators (KPIs) will also be monitored by the project on a
regular basis, including the following parameters:

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✓ Number of public hearings, consultation meetings and other public

discussions/forums conducted within a reporting period (e.g., monthly, quarterly, or
annually);
✓ Frequency of public engagement activities;
✓ Geographical coverage of public engagement activities – number of locations and
settlements covered by the consultation process, including the settlements in remote
areas within the Project Area of Influence (PAI);
✓ Number of public grievances received within a reporting period (e.g., monthly,
quarterly, or annually) and number of those resolved within the prescribed timeline;
✓ Type of public grievances received;
✓ Number of press materials published/broadcasted in the local, regional, and national
media;
✓ Amount of Project’s charitable investments in the local communities in the Project
Area of Influence.
The outcomes/feedback from these ‘reporting back’ measures will be compiled and
shared/disclosed with the stakeholders’ and general public through the use of proper media, such
as PGCB websites, social media accounts, communication materials, etc.

10.2 Points of contact

Information on the project and future stakeholder engagement programs will be available on the
project’s website and will be posted on information boards in the project site, local government
offices, local markets and point of assembly etc. Information can also be obtained from PGCB offices
and from their websites. There should be a dedicated point of contact for recording project related
complaints (including GBV related complaints) and passing those to the GRC for necessary action at
their end. GRM should be user friendly and easily approachable, particularly by the disabled,
marginalized and the vulnerable groups including the elderly.
The point of contact regarding the stakeholder engagement program at PGCB should provide the
following information:

Description Contact details

Name and position
Address:
E-mail:
Telephone:

Toll Free Number:

- For PGCB

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10.3 Roles and Responsibilities

The specific role/responsibilities as regard the project’s stakeholders’ management is provided
below:
Table 10: Role and Responsibilities for SEP Implementation
Actor/Stakeholder/ Responsibilities
responsible person
ESU/PIU-PGCB and/or its - Overall planning and implementation of the SEP;
consultant - Lead activities on stakeholders’ engagement
- Management and resolution of grievances;
- Guide/coordinate/supervise the contractors for activities
related to the SEP
- Monitoring and reporting on SEP to PGCB and AIIB
- Take lead in carrying out the beneficiary satisfaction survey
- Supervision/monitoring of Contractor on SEP and GRM
Site Contractor(s) / sub- - Report/inform PGCB on issues related to the implementation
contractors of the SEP / engagement with the stakeholders.
- Resolve and convey management/resolution of grievance
cases to the project GRM team, in particular labor related
grievance cases.
- Prepare, disclose and implement the contractor’s code of
conduct, CESMP, etc.
- Collaborate/inform the local communities and other local
level stakeholders on the E&S monitoring
- Provide SEP and other E&S documents implementation with
monthly/quarterly/half yearly progress report.

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