stakeholder engagement plan - alcazar energy

STAKEHOLDER ENGAGEMENT

PLAN

SHOBAK WIND FARM PROJECT

March 03, 2020

SHOB-O&M-Stakeholder Engagement Plan-Rev03 2

RESPONSIBILITIES

DATE NAME FUNCTION

Elaboration 20 Apr 2020 Patricia Gimenez Quality, H&S, Environmental & Social Manager

Validation 20 Apr 2020 Sharon Santos QHSE Coordinator

Approval Daniel Lancha Head of Delivery & Operations

REVISION HISTORY

VERSION DATE AUTHOR COMMENTS

00 03 Mar 2020 Patricia Gimenez First issue

01 20 Apr 2020 Patricia Gimenez Updated with Noise Management Plan

02 25 Nov 2020 Qusai Al-Abbassi Updated with community grievance boxes

03 10 Feb 2021 Patricia Gimenez Updated with CLO office details


ACRONYMS

Asl above sea level

ATMP Active Turbine Management Plan

CARC Civil Aviation Regulatory Commission

CIP Community Integration Plan

COD Commercial Operational Date

COP Communication on Progress

CLO Community Liasion Office

EBRD European Bank for Reconstruction and Development

EIA Environmental Impact Assessment

E&S Environment and Social

ESIA Environmental and Social Impact Assessment

ESAP Environment and Social Action Plan

GIIP Good International Industry Practice

IDB Islamic Development Bank

IFC International Finance Corporation

JEA Jordan Engineers Association

JREEEF Jordan Renewable Energy And Energy Efficiency Fund

KPI Key Performance Indicators

MOENV Ministry of Environment

NEPCO National Electrical Power Company

O&M Operations & Maintenance

PPA Power Purchase Agreement

QHSSE Quality, Health, Safety, Social and Environmental

SEP Stakeholder Engagement Plan

SHOB Shobak Wind Farm

UNGC United Nations Global Compact

WTG Wind Turbine Generator


INDEX

1 INTRODUCTION.................................................................................................................................. 7

1.1 Project Description ........................................................................................................................ 7

1.2 Background to the SEP ................................................................................................................ 9

1.3 Purpose of this Plan ...................................................................................................................... 9

2 REGULATORY FRAMEWORK ......................................................................................................... 10

2.1 Jordanian Requirements ............................................................................................................. 10

2.2 International Requirements ......................................................................................................... 10

2.3 Company Policy .......................................................................................................................... 11

3 PREVIOUS STAKEHOLDER ENGAGEMENT .................................................................................. 12

3.1 Stakeholder Identification and Analysis ...................................................................................... 12

3.2 Stakeholder Engagement Planning ............................................................................................ 12

3.3 Disclosure of Information, Consultation and Participation .......................................................... 14

3.3.1 Development Stage ............................................................................................................ 14

3.3.2 Construction Stage ............................................................................................................. 14

4 PROJECT STAKEHOLDERS ............................................................................................................ 17

5 Stakeholder Engagement Program.................................................................................................... 19

5.1 Disclosure of Information ............................................................................................................ 19

5.2 Good Practice Considerations .................................................................................................... 23

6 GRIEVANCE MECHANISM ............................................................................................................... 24

6.1 Grievance Mechanism Process .................................................................................................. 24

6.1.1 STEP 1 Receiving a Grievance .......................................................................................... 25

6.1.2 STEP 2 Record the Grievance ........................................................................................... 25

6.1.3 STEP 3 Screen the Grievance ............................................................................................ 26

6.1.4 STEP 4 Acknowledge the Grievance.................................................................................. 26

6.1.5 STEP 5 Investigate the Grievance...................................................................................... 26

6.1.6 STEP 6 Acting on the Grievance ........................................................................................ 27

6.1.7 STEP 7 Close Out & Follow up ........................................................................................... 27

6.2 Considerations on Noise Management ...................................................................................... 27

6.3 Good Practice Considerations .................................................................................................... 28

7 RESOURCES & RESPONSIBILITIES ............................................................................................... 30

7.1 Community Liaison Office ........................................................................................................... 30

7.2 Development Coordinator & Social Specialist ............................................................................ 30

7.3 Grievance Recipients .................................................................................................................. 31

7.4 Corporate QHSE Team .............................................................................................................. 32


7.5 O&M Team .................................................................................................................................. 32

7.6 Senior and Executive Management ............................................................................................ 32

7.7 Identified Stakeholders ............................................................................................................... 33

7.7.1 Members of the Identified Local Communities ................................................................... 33

7.7.2 Interest-based Stakeholders ............................................................................................... 33

7.7.3 Participatory Stakeholders .................................................................................................. 33

7.7.4 Internal Stakeholders .......................................................................................................... 33

8 MONITORING AND REPORTING ..................................................................................................... 34

8.1 Monitoring and Auditing .............................................................................................................. 34

8.2 Reporting .................................................................................................................................... 34

ANNEX 1 – PROJECT GRIEVANCE FORM .............................................................................................. 36

ANNEX 2 – PROJECT GRIEVANCE LOG ................................................................................................. 39

ANNEX 3 – PROJECT GRIEVANCE CLOSEOUT FORM ......................................................................... 41

ANNEX 4 – CLO ENGAGEMENT ACTIVITIES LOG ................................................................................. 44


INDEX OF TABLES

Table 1 Main Technical Project Characteristics ........................................................................................... 8

Table 2 Prior Identified Stakeholder Groups .............................................................................................. 12

Table 3 Prior Identified Stakeholder Groups and Communication Methods .............................................. 14

Table 4 Disclosure of Information, Consultation and Participation during Development Stage ................. 14

Table 5 Identified Stakeholder Groups ....................................................................................................... 18

Table 6 Disclosure of Information ............................................................................................................... 22

Table 7 Good Practice Considerations for Stakeholder Engagement ........................................................ 23

Table 8 Community Liaison Office Details .................................................................................................. 25

Table 9 Grievance Level of Severity ........................................................................................................... 26

Table 10 Good Practice Considerations for Grievance Management ........................................................ 29

Table 11 Good Practice Considerations for Participatory Monitoring......................................................... 34

INDEX OF FIGURES

Figure 1 Project Location .............................................................................................................................. 7

Figure 2 Project Layout ................................................................................................................................. 8

Figure 3 Identified Stakeholder Groups ...................................................................................................... 17

Figure 4 Grievance Mechanism Process .................................................................................................... 24


1 INTRODUCTION

This document presents the ‘Stakeholder Engagement Plan’ (SHOB-O&M-SEP) for the Operation &

Maintenance (O&M) phase of the Shobak 44.85MW Wind Farm (the ‘Project’), building up on the

Stakeholder Engagement Plan originally developed by ECO Consult during the Environmental and Social

Impact Assessment (ESIA) stage1.

1.1 Project Description

The Project is located approximately 160km south of the capital city of Amman within the district of Shobak,

in Ma’an governorate in the Hashemite Kingdom of Jordan. The Project is located within a hilly, sandy and

rocky area expanding over 1,450 hectares of leased governmentally owned lands within the Al-Sherah

Heights with an approximate elevation of 1,200m above sea level (asl).

FIGURE 1 PROJECT LOCATION

The Project consists of 13 Wind Turbine Generators (WTGs) with associated underground cables to the

substation and with a network of 12km of cable trenches and 10.5km of internal roads. The nearest

settlements are: (i) Mdhaibie’ (also known as Al-Faisaliyeh) located approximately 1km to south), Zaitooneh

located approximately 1km to the south-west, Zobeiriyeh located around 1.3km to the west and Mothallath

Al-Shobak located around 1km to the west. Herding activities from locals and Bedouins continue to take

place across the Project lands during the construction phase and expected to continue during the O&M

phase.

1 Final SEP_Shobak Wind Farm Project_13Sep2017_REV3

Project

Location


The following figure depicts the location of all 13 WTGs, the boundaries of the Project’s leased lands, the

access road and the archaeological sites as well as the nearest villages.

FIGURE 2 PROJECT LAYOUT

The main technical characteristics of the Project are presented in the following table:

Main Technical Characteristics

Turbines make & wind class 13 x VESTAS V136 3.45MW

Estimated Energy Output 153 GWh per year

Tower height 112 m

Length of the blade 68 m

Electrical Interconnection 132kV

Substation Step-up Transformer 2 x 33/132kV 45/54MVA

EPC Contract Turnkey

EPC & OM Contractor Vestas

TABLE 1 MAIN TECHNICAL PROJECT CHARACTERISTICS

The Project is expected to achieve Commercial Operational Date (COD) by end of March 2020. The Project

is estimated to avoid over 92,000 tons of CO2 emissions per year and save over 214,000 m3 of water per

year that would have otherwise been materialised through conventional sources of power generation. The

estimated energy output is estimated to account for the energy demand of over 30,000 average Jordanian

households per year. In fact, the installed capacity represents almost 10 per cent of the National Wind

Energy target of 600MW of generation capacity by 2020 as per Master Strategy of Energy Sector in Jordan

(2007-2020), contributing towards energy diversification in Jordan, improving energy security and reducing

the dependence on fossil fuels.

The Project has been developed by Shobak Wind Energy PSC (the Project Company’) which is 90 per

cent owned by Alcazar Energy and 10 per cent owned by Hecate Energy LLC. Project financing was

provided by: European Bank for Reconstruction and Development (EBRD), Islamic Development Bank


(ISDB) and Europe Arab Bank. The Power Purchase Agreement (PPA) with the National Electrical Power

Company (NEPCO) is valid for 20 years with NEPCO being the off taker of the power produced.

The Project is classified Category A as per the EBRD Environmental and Social Policy (2014) and as such

it was subject to a comprehensive ESIA developed in line with EBRD Performance Requirements (2014)

as well as the International Finance Corporation (IFC) Performance Standards on Environmental and

Social (E&S) Sustainability (2012), and Jordanian legislative requirements. Key impacts and risks

considered included biodiversity, culture heritage, land acquisition and use, and workers and community

health, safety and security, and the ESIA concluded that environmental and social impacts are site specific

and can be mitigated. In addition, an Environmental and Social Action Plan (ESAP) was developed to

monitor that the Project is constructed and operated in line with the applicable legal framework. As an

example and given the proximity of the Wind Farm to the Rift Valley flyway and the Dana Biosphere

Reserve, an Active Turbine Management Plan (ATMP) is currently being implemented to conduct the

inflight monitoring of birds within and in the proximity of the Project, to identify individuals of ‘Priority Bird’

populations and/or flocks of non-Priority Migratory Soaring Birds (MSB) species at risk of collision and

enable the temporary shutdown of specific WTGs, and to conduct the search of carcasses within an specific

distance from the WTGs.

1.2 Background to the SEP

The Stakeholder Engagement Plan during the ESIA stage was developed by an independent specialised

consultant, ECO Consult, in line with EBRD Performance Requirements. The Stakeholder Engagement

Plan formed part of the ESIA disclosure package which was developed in both Arabic and English

languages and disclosed to the public in November 2017 prior to the construction of the Project. No

comments were received during the 60-day disclosure period. The ESIA disclosure package can be found

in the following link:

https://www.ebrd.com/work-with-us/projects/esia/shobak-wind-farm.html

1.3 Purpose of this Plan

This ‘Stakeholder Engagement Plan’ presents a high-level summary of the stakeholder engagement

activates conducted during the development and construction stages of the Project as well as:

- Outlines the systematic approach that has been and will continue to be followed to maintain a

constructive, strong and responsive relationship and for effective engagement with the Project

stakeholders during the O&M phase, in particular with the ‘identified local communities’;

- Presents the process and means for disclosing meaningful and relevant environmental and social

information to the different Project stakeholders; and

- Describes the grievance mechanism, including the means for raising a Project-related grievance

for identified communities and other stakeholders as well as the evaluation and management

process.

The ‘Stakeholder Engagement Plan’ is intended to follow best practice2 and to be periodically reviewed

and updated as considered applicable based on the Project’s environmental and social performance.

2 IFC publication “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets”, 2007

https://www.ebrd.com/work-with-us/projects/esia/shobak-wind-farm.html


2 REGULATORY FRAMEWORK

2.1 Jordanian Requirements

The requirements of national law with respect to stakeholder engagement for public information and

consultation are related to those under the ‘Environmental Impact Assessment (EIA) Regulation No. 37 of

2005’ by the Ministry of Environment (MoENV), which in general identifies the overall process,

requirements and content for EIA studies in Jordan. The EIA Regulation requires:

- That a scoping session with potentially affected stakeholders is held at the onset of comprehensive

EIA studies in order to inform them about the Project and allow them to participate in the EIA

process; and

- That the outcomes of the EIA are announced to the public and stakeholders in a manner that the

MORE deems appropriate as per the type and scale of the Project.

There are no further national legislation requirements for stakeholder engagement during subsequent

phases of projects such as construction, commissioning or operation.

2.2 International Requirements

The EBRD Environmental and Social Policy (2014), applicable to the Project since it is EBRD-funded

project:

- Outlines how EBRD will assess and monitor the environmental and social risks and impacts of its

projects;

- Sets minimum requirements for managing environmental and social impacts and risks caused by

EBRD financed projects throughout the lifetime of the projects; and

- Defines the respective roles and responsibilities of both EBRD and its clients in designing,

implementing and operating projects in accordance with this Policy.

The requirements for stakeholder engagement in line with best international practice are described in

“EBRD Performance Requirement 10: Information Disclosure and Stakeholder Engagement” as follows:

- Stakeholder engagement will involve the following elements: stakeholder identification and

analysis, stakeholder engagement planning, disclosure of information, consultation, and

participation, grievance mechanism and ongoing reporting to relevant stakeholders;

- Clients will conduct stakeholder engagement on the basis of providing local communities that are

directly affected by the project and other relevant stakeholders with access to timely, relevant,

understandable and accessible information, in a culturally appropriate manner, and free of

manipulation, interference, coercion and intimidation;

- The nature and frequency of stakeholder engagement will be proportionate to the nature and scale

of the project and its potential adverse impacts on the affected communities, the sensitivity of the

environment and the level of public interest. In order to tailor the engagement to the specifics of

the client and the project, it is essential that clients identify stakeholders as outlined below. The

requirements of national law with respect to public information and consultation, including those

laws implementing host country obligations under international law, must always be met; and

- The client will define clear roles, responsibilities, and authority as well as designate specific

personnel to be responsible for the implementation and monitoring of stakeholder engagement

activities.


On the other hand, “IFC Performance Standard 1 on Assessment and Management of Environmental and

Social Risks and Impacts” sets out the following requirements of stakeholder engagement during project

preparation:

- Stakeholder Engagement is an on-going process that may involve the following elements:

stakeholder analysis & planning, disclosure & dissemination of information, consultation &

participation, grievance mechanism, and on-going reporting to Affected Communities;

- A Stakeholder Engagement Plan (SEP) will be developed and implemented that is scaled to the

project risks and impacts and development stage, and be tailored to the characteristics and

interests of the Affected Communities;

- Affected Communities will be provided with access to relevant information on: (i) the purpose,

nature, and scale of the project; (ii) the duration of proposed project activities; (iii) any risks to and

potential impacts on such communities and relevant mitigation measures; (iv) the envisaged

stakeholder engagement process; and (v) the grievance mechanism;

- When Affected Communities are subject to identified risks and adverse impacts from a project, a

process of consultation will be undertaken in a manner that provides the Affected Communities

with opportunities to express their views on project risks, impacts and mitigation measures, and

allows the client to consider and respond to them;

- The extent and degree of engagement should be commensurate with the project’s risks and

adverse impacts and concerns raised by Affected Communities;

- The consultation process will be tailored to language preferences of Affected Communities, their

decision-making process, and the needs of disadvantaged or vulnerable groups; and

- Where there are Affected Communities, a grievance mechanism will be established to receive and

facilitate resolution of Affected Communities’ concerns and grievances about the client’s

environmental and social performance.

2.3 Company Policy

Alcazar Energy considers stakeholder engagement as a core constituent of its operations as emphasized

within its recently approved “Social Policy” where it states:

- To maintain a constructive and responsive relationship not only with the local communities where

we operate and with wider stakeholder groups based on stakeholder engagement and access to

relevant information; and

- To endeavour to strengthen our corporate governance system as well as our engagement with

diverse stakeholders that form the basis of the overall sustainability of our operations.


3 PREVIOUS STAKEHOLDER ENGAGEMENT

3.1 Stakeholder Identification and Analysis

Stakeholder groups were identified in line with the EIA Regulation No.37 of 2005 as outlined in Section 5

of the “Final SEP_Shobak Wind Farm Project_13Sep2017_REV3” developed by ECO Consult and

summarised as follows:

Classification Stakeholder Groups

Stakeholders who may be directly

or indirectly affected by the Project

Villages in the vicinity of the Project (i.e. Project (i.e. Al-Faisaliyeh, Zaitooneh, Zobeiriyeh,

Mothallath Al-Shobak), also identified as ‘Affected Local Communities’ in the ESIA

Women groups, youth and unemployed

Community Based Organisations

Local academic institutions

Local enterprises and businesses

Nomadic groups

Stakeholders who may participate

in the implementation of the

Project

Investor and Project Lenders

Local contractors and its employees (contracted workers and third-party workers)

Stakeholders who may have a

possibility to influence and make

decisions on the implementation of

the Project or may have an interest

in the Project

Central Government and International Agencies: MoENV, Ministry of Agriculture, Ministry

of Labour, Ministry of Municipal Affairs, Ministry of Energy and Mineral Resources

(MEMR), Ministry of Health, Ministry of finance, Ministry of Industry and Trade, Ministry of

Water and Irrigation, Ministry of Public Works and Housing (MPWH), Traffic Department,

Ministry of Tourism and Antiquities, Department of Antiquities, Civil Aviation Regulatory

Commission (CARC), The General Directorate of Jordan Civil Defence, Royal Jordanian

Air Force, Jordan Engineers Association, etc

Local Governmental Entities: Shobak District Office, New Shobak Municipality, Ma’an

Water Directorate, Ma’an Public Works and Directorate, Department of Antiquities Ma’an

Non-Governmental Organisations (NGOs): Jordan Environment Society, National

Environment and Wildlife Society (NEWS), The Jordan Society for Sustainable

Development, EDAMA, Renewable Energy and Environment Investment Society, Jordan

River Foundation, Jordanian Hashemite Fund for Human Development, BirdLife

International, Royal Society for Conservation of Nature (RSCN)

TABLE 2 PRIOR IDENTIFIED STAKEHOLDER GROUPS

3.2 Stakeholder Engagement Planning

Communication methods and tools were identified for engagement with the above identified stakeholder

groups as outlined in Section 6 of the “Final SEP_Shobak Wind Farm Project_13Sep2017_REV3”

developed by ECO Consult. The level of engagement planned varied between different stakeholder groups

and intended to provide information on variety of project related topics including but not limited to:

construction activities, implementation of environmental and social management measures, grievance

mechanism, employment and procurement opportunities, project timelines, social investment initiatives,

etc. The proposed communication methods and tools are presented below for each stakeholder group:

Classification Objectives Communication Methods and Tools

Stakeholders who may

be directly or indirectly

affected by the Project

Disclose information and

outcomes of the ESIA to the

local communities

Local community disclosure session held with the local community

to inform them on the main outputs and outcomes of the ESIA

study, in coordination with the Shobak District Office and Shobak

Municipality, including local community representatives such as

elected member of municipal council, elder representatives of



tribal groups, community based organizations, women groups,

youth and unemployed, local enterprises and businesses, and

local governmental institutions

Disclose information and

outcomes of the Community

Integration Plan (CIP)

Local community awareness session held with the local

community to inform them on the main outputs and outcomes of

the CIP, in coordination with the Shobak District Office and

Shobak Municipality, including local community representatives

and nomadic groups

Disclose information on Project

Awareness session for disclosure on land use agricultural baseline

mapping emphasizing that grazing and/or agriculture activities may

take place outside of construction and operation areas

Inform local communities on any significant changes on Project

and its activities, community risk, impacts and mitigations upon

occurrence

Notify local communities on all

job opportunities for the

Project for construction and

operation

Advertisements at local newspapers and key local community

platforms to include Developer local office, Shobak District Office,

Shobak Municipality, women CBO’s, youth CBO’, etc

Disclosure of Stakeholder

Engagement Plan (SEP)

including grievance

mechanism

On the company website, hardcopy in Arabic at Developer Local

Officer, Shobak District Office and Shobak Municipalityand

summary in Arabic posted at key local community platforms to

include Developer Local Office, Shobak District Office, Shobak

Municipality, women CBO’s, youth CBO’s, etc. before construction

Updates on the Project E&S

performance including

grievance mechanism

implementation, CIP, etc.

Leaflet in Arabic with updates on project and its environmental and

social issues semi-annually during construction and annually

during operation, to be distributed to nomadic groups

Annual environmental report to be disclosed on company website

Hardcopy of Project Update Report in Arabic to be available at

Developer Local Office

Propagation maps of noise

and shadow flicker from the

turbines

Informative sessions onsite to explain to nomads to build up their

tents in less affected areas


participate in the

implementation of the

Project - Investor and

Project Lenders



grievance mechanism

implementation, CIP, etc

Individual/Internal Meetings (if required)

Submission of annual environmental report as per lender

requirements and template


have a possibility to

influence and make

decisions on the


Project – Central

Government

Governmental inspections and

audits

Individual / Internal Meetings (if required)

Correspondence and official letters (if required)



grievance mechanism


Email notifications and Hardcopy of Project Update Report in

Arabic to be available at Developer Local Office

Permit applications from

MoENV, CARC, Royal

Jordanian Air Force


Correspondence and official letters



influence and make

decisions on the




grievance mechanism


Leaflet in Arabic with updates on project and its environmental and

social issues semi-annually during construction and annually

during operation

Awareness session on CIP in coordination with Shobak

Municipality



Project – Local

Government

Coordination for solid waste,

wastewater and supply of

water, traffic and transport plan

and any archaeological finds


Correspondence and official letters



influence and make

decisions on the


Project – NGOs and

other Organisations



grievance mechanism


Email notification

Project updates report to be disclosed at Developer Local Office

Disclosure of ESIA package Email notification

ESIA, NTS and SEP to be disclosed on company website

TABLE 3 PRIOR IDENTIFIED STAKEHOLDER GROUPS AND COMMUNICATION METHODS

3.3 Disclosure of Information, Consultation and Participation

3.3.1 Development Stage

As per the Jordanian legislation requirements and international best practice, stakeholder engagement

activities were initiated at an early stage in the Project and formed an integral part of the assessment of

environmental and social risks for the Project as part of the ESIA process.

A summary of the main stakeholder engagement activities conducted prior to construction commencing

are provided in the following table:

Engagement

Activity Date Purpose and Details of Stakeholder Engagement Activity

Scoping

Session

10th January

2017

Scoping session was held in line with EIA Regulation No.37 of 2005, introducing the

Project, methodology of the ESIA and anticipated E&S impacts. Stakeholders were

identified by the ESIA team and MoENV and invited through formal letters issued by the

MoENV including national governmental entities, local governmental entities, NGOs,

academic and research institutions and local community representatives. The main topics

raised by stakeholders related to land use, avifauna, noise and occupational health and

safety, community health and safety and socio-economic development. Outcomes

presented in detail in the ESIA.

Local

Community

Consultation

Session

10th May 2017

Consultation with local community representatives coordinated and headed by the Local

Governor of Shobak District and with the purpose of understanding the activities being

undertaken onsite and introducing the Project and its potential associated impacts on their

activities (i.e. land use, socio-economic development). Stakeholders invited include:

members of the Municipal Council including females, local governmental institutions, elder

representatives of tribal groups, CBOs, local enterprises and businesses and vulnerable

groups.Outcomes presented in detail in the ESIA.

Specialist

Consultation

August 2016 to

August 2017

Specialized consultations and engagements with various stakeholder groups to include

national and local governmental entities, NGOs, land users and nomads. Outcomes

presented in detail in the ESIA.

TABLE 4 DISCLOSURE OF INFORMATION, CONSULTATION AND PARTICIPATION DURING DEVELOPMENT STAGE

3.3.2 Construction Stage

During the construction stage, there were two main mechanisms for stakeholder engagement developed

and implemented being the establishment of the community grievance mechanism managed by the

Community Liasion Desk (CLD) and the establishment of the Local Community Committee (LCC) who

managed the process for local employment and procurement for the Project.


3.3.2.1 Community Grievance Mechanism and Community Liaison Desk

The Community Liaison Desk (CLD) was established in December 2017 and comprised of the Project

Liaison Officer (Ret. Col. Mr. Khalil Odeh Al Hawartheh) and the Public Relations Officer (Hamzeh Abd Al

Rahman Ali Al Shqeerat). The Contractor (i.e. Vestas) and main subcontractor (I.e. Prenecon) also have a

Community Liaison Officer from thelocal communities respectively, assigned to the Project and based

onsite.

The CLD is responsible for a variety of tasks including the implementation of the Project’s community

grievance mechanism informing the local communities about the grievance process in the course of its

community engagement activities. The mechanism is managed through direct and ongoing engagement

with the Project team and the local communities. A grievance box is located at the Project site offices within

the security cabin of the Subcontractor’s campsite were grievance forms were also available, in the case

that any complainant would prefer to raise a complaint anonymously.

A Grievance Log is maintained for the Project as part of the Quality, Health, Safety, Social and

Environmental (QHSSE) Statistics recorded combining both grievances received from members of the local

communities as well as workers from the Contractor and subcontractors’ teams. The grievances received

either in writing or verbally were recorded in the log, reviewed and evaluated, resolution proposed,

responsibilities assigned, and actions addressed timely and accordingly.

As a matter of summary, 26 grievances have been recorded since the beginning of the construction.

Sixteen (16) grievances from members of the local communities, seven (7) of them related to the process

of local employment and selection process, four (4) of them related to concerns or complaints regarding

community investment programs, initiatives and deadlines and five (5) of them related to construction

works, land infringement and property damage. All grievances were reviewed, evaluated, addressed with

the support of CLD and closed (even though not always to the satisfaction of the complainant).

3.3.2.2 Local Employment and Procurement and Local Community Committee

The Local Community Committee (LCC) was established in July 2018 by the main Contractor and

comprised of one (1) representative from Shobak, one (1) representative from Al Faisaliah Village (Bedwin

tribe of Shobak) and one (1) representative from Al Jafer District.

The Local Community Committee was established with the goal of enabling an impartial mechanism for

the fair, equitable and transparent allocation of local employment and construction work packages during

the construction phase of the Project. The Local Community Committee was responsible for facilitating the

process and maximising the outcome of local employment and procurement including:

- Greeting the members of the ‘affected local communities’ at the CLD office and explaining the

process for local employment and procurement established for the Project;

- Prompting the individuals to filling in the application form either for employment or procurement of

goods and services, duly registering the completed application forms and maintaining records

accordingly;

- Providing a unified platform for documenting and creating a database with the available resources

in terms of skills and experience as well available vehicles, equipment and machinery within the

‘affected local communities’;

- Receiving requests from the EPC Contractor with regards to needed positions and associated role

and requirements and providing suitable candidates’ CVs and contact details;

- Receiving requests from the EPC Contractor with regards to procurement needs for goods,

vehicles, machinery, equipment and services and providing suitable local suppliers;

- Maintaining and open dialogue and regular communication with the EPC Contractor

representatives with regards to application trends and any potential particular concerns raised by

the community members.


Social statistics are maintained for the Project during the construction phase as part of the QHSSE

Statistics recorded listing all workers from the Contractor and subcontractors’ teams including nationality

and whether original from the ‘local communities’. As a matter of summary, 233 workers out of a total of

314 recorded are Jordanian since the beginning of the construction phase to date, 103 of which were

natural from the local communities. This represents a local content of over 32 per cent.


4 PROJECT STAKEHOLDERS

According to IFC Performance Standard 1 on ‘Assessment and Management of Environmental and Social

Risks and Impacts’, stakeholders are defined as “persons, groups or communities external to the core

operations of a project who may be affected by the project or have interest in it. This may include

individuals, businesses, communities, local government authorities, local nongovernmental and other

institutions, and other interested or affected parties”.

The following diagram depicts the identified stakeholder groups for the O&M phase of the Project:

FIGURE 3 IDENTIFIED STAKEHOLDER GROUPS

The following table presents a more detailed description of the identified stakeholder groups for the O&M

phase of the Project:

For the purposes of the Stakeholder Engagement Plan, ‘Stakeholders’ are defined as individuals, groups

or communities who may have an interest in the Project or who may affect or be affected by the Project’s

activities and who have the ability to influence the Project’s financial, environmental and social

performance


Classification 3 Stakeholder Groups

Identified Local Communities

Stakeholders who may be directly

or indirectly, positively or

negatively, affected by the

operation of the Project

Villages in the vicinity of the Project (i.e. Al-Faisaliyeh, Zaitooneh, Zobeiriyeh, Mothallath

Al-Shobak) and to a certain extent and additionally the 12 villages in the District of Shobak

Legitimate stakeholder representatives i.e. elected officials, non-elected community

leaders, leaders of informal or traditional community institutions, and elders within the

identified local communities

Community Based Organisations (CBO) or Associations for Social Development (i.e. Tuba,

Baq'a, B'r Aldabaghat, Al juhaer, Al'entma, Madabee, Al Zaetoneh, Al Mansoura, Al

mqar'ea, Al-zubareah, Al-shobak, Al ekha, Haoala, Al Abdalia and Coalition of

Associations in Shobak)

Nomadic groups, referring to nomadic tribes in the south of Jordan who travel in different

areas with no fixed residence and whose livelihood is generally goat, sheep or camel

herding

Local emergency response governmental bodies (i.e. Civil Defence, Police Department,

Healthcare Department)

Interest Based Stakeholders

Broader stakeholders who may

have ‘interests’ and/or the

possibility to influence the

implementation of the Project

during O&M phase

National Governmental Entities: MoENV, Ministry of Labor, Ministry of Municipal Affairs,

Ministry of Education, Ministry of Tourism and Antiquities

Local Governmental Entities: Directorate of Education, Directorate of Social Development

Organisations and Associations at National level: BirdLife International, RSCN, Jordan

Engineers Association, Jordan Renewable Energy and Energy Efficiency Fund (JREEEF)

NGOs: EDAMA, Jordan Environment Society, National Environment and Wildlife Society

(NEWS), The Jordan Society for Sustainable Development, Renewable Energy and

Environment Investment Society

Media: Newspapers, local and national TV stations, social media

Internal & Participatory

Stakeholders

Stakeholders who participate in

the implementation of the Project

during O&M phase

EPC and O&M Contractor (Vestas) and its subcontractors (i.e. Prenecon, Securitas and

other specialised contractors) – ‘Internal Stakeholders’

Local emergency response governmental bodies (i.e. Civil Defence, Police Department,

Healthcare Department, Military)

Project Lenders: EBRD, ISDB and Europe Arab Bank

Shareholders for Alcazar Energy: IFC, IFC Asset Management Company, Dash ventures,

Mubadala Infrastructure Partners

NEPCO as the off taker of the power produced and PPA signatory

MEMR as the Regulator

TABLE 5 IDENTIFIED STAKEHOLDER GROUPS

‘Internal Stakeholders’, including individuals and organisations who participate in the actual operations of

the Project, have been considered as stakeholders even though at the core of the Project’s operations,

since their engagement and consultation is key for the effective management of environmental and social

risks. The methods of engagement with the internal stakeholders will differ from those used for external

stakeholders.

3 Classification as per IFC Guidance Note 1 Assessment and Management of Environmental and Social Risks and Impacts, GN95


5 STAKEHOLDER ENGAGEMENT PROGRAM

Stakeholder engagement is critical to maintaining a constructive and responsive relationship not only with

the ‘identified local communities’ but also with wider stakeholder groups and to ensuring the continuation

of the ‘environmental & social license to operate’ for the Project.

Stakeholder engagement forms an integral part of Alcazar Energy’s QHSSE Management System

(QHSSEMS) as well as the Project-specific QHSSEMS. The stakeholder engagement program presented

herein has been developed specifically for the O&M phase of the Project and is intended to be

commensurate with the potential environmental and social risks and opportunities arising from the

operation of the Project as well as with the sensitivity of the environment and the level of public interest.

5.1 Disclosure of Information

The Project Company will continue to provide the Identified Local Communities throughout the O&M phase

with access to relevant information on:

- The purpose, nature, scale and timelines of the Project;

- Potential environmental & social risks and impacts on such communities and the relevant

mitigation measures being implemented to manage those; and

- The stakeholder engagement process including the grievance mechanism.

In addition, the Project Company will communicate any material changes to the Project which may result

in additional adverse impacts and any particular issues or topics that may have been identified through the

grievance mechanism as a concern to those Identified Local Communities as a means to further engage

and involve those Communities in the environmental and social performance of the Project.

The Project Company will also regularly disclose information on the management of environmental and

social impacts, the implementation of the Project-specific QHSSEMS and the compliance against the ESAP

and legal framework as well as the opportunities for performance improvement and lessons learned

through an annual Corporate Sustainability Report.

The following table presents further information that is to be disclosed to the Identified Local Communities

and the broader Stakeholder groups together with timelines and frequency of communication as well as

responsibilities within the Project and company structure.

Information disclosure involves delivering information about the Project, its risks, impacts and

opportunities to the Identified Local Communities and ensuring access to such information by other

identified Stakeholder groups in a manner that is accurate, timely and understandable, which in return will

facilitate future engagement and the resolution of potential grievances

SHOB-O&M-Stakeholder Engagement Plan-Rev02

Stakeholder Group Document Subject to Disclosure Method of Disclosure Timing and Frequency Responsibility

Identified Local

Communities - Al-

Faisaliyeh, Zaitooneh,

Zobeiriyeh, Mothallath Al-

Shobak including Local

Community representatives

and CBOs

✓ ESIA, Non-technical Summary (NTS) of the ESIA,

ESAP and Updated Stakeholder Engagement Plan

✓ Active Turbine Management Plan (ATMP)

✓ Social Development and Investment Plan

✓ Grievance Mechanism related documentation:

Grievance mechanism simplified procedure in Arabic,

Grievance boxes and grievance forms and Updated

Grievance Log

✓ Project brochure and/or poster

✓ Hard copy of all documents available at the

CLO office in the Shobak village as well as

in the Control Building at he Project site

✓ Grievance mechanism simplified procedure

in Arabic available at the CLO office

✓ Grievance box and grievance forms (in

English and Arabic) available outside the

CLO office to be used in case of anonymity

✓ Grievance box and grievance forms located

at the security caravan at the entrance of

the Substation

✓ Updated Grievance Log available at the

CLO office

✓ Project brochure and/or poster available at

the CLO office and at the CBOs in Al-

Faisaliyeh, Zaitooneh, Zobeiriyeh,

Mothallath Al-Shobak

✓ ESIA, NTS, Updated SEP and Project

brochure and/or poster available on Alcazar

Energy’s website

Continually available with the

most updated version of all

documents – Frequency of

checks semi-annually for all

documents and monthly for

grievance related

documentation

Continually available

CLO / Development

Coordinator & Social

Specialist

Corporate QHSE Team

Nomadic Groups, Local

Herders and users of the

grounds of the SHOB

Topics to be covered during information disclosure:

✓ Avifauna: Inform them not to leave animal fodder or

cattle carcasses and keep good housekeeping (not

littering), and to inform the CLO if any bird carcasses

are found across SHOB

✓ Blade & Ice Throw: Inform them of the risk of blade &

ice throw and to stay away from the WTGs as far as

possible in order to minimise the associated

community health & safety risks

✓ Noise: Inform them that the noise generated by the

WTGs when in operation is normal and increases with

wind speed and to stay away from the WTGs as far as

possible to minimise nuisance

Engagement with nomads, local herders and

users of the grounds of the SHOB for

information disclosure through consultation

(conversation on the ground)

Weekly, in particular during

peaks in herding season and

at the beginning of the winter

season accordingly

CLO / Development


Specialist



✓ In addition they will be informed about the Project and

Grievance related documentation available within the

CLO office

Local emergency response

governmental bodies (i.e.

Civil Defence, Police

Department, Healthcare

Department)

Emergency Preparedness and Response Plan (EPRP)

including different potential emergency scenarios and the

level of emergency including coordination for Emergency

drills

✓ Consultation and meetings

✓ Correspondence and official letters

Once EPRP is approved and

afterwards only if there are

significant changes to the

EPRP

O&M Contractor – HSE

Manager

National Governmental

Entities: MoENV

Semi-annual Synopsis of Avian and Bat Monitoring &

Impact Mitigation Measure Report as well as the

Operational Raw Data on avifauna monitoring

Electronic and hard-copy submission Semi-annually: in April

covering the previous autumn

and winter, in October

covering the previous spring

and summer

Development


Specialist / QHSE Team

Project Lenders: EBRD,

ISDB and Europe Arab

Bank

Project Progress Report including a review of

Environmental & Social matters arising in relation to the

Project including QHSE performance and details of any

accidents, emergencies or other material events

Annual Monitoring Report on Environmental & Social

Performance including Impact Indicators (as per EBRD

Proforma)

Electronic submission

Electronic submission

Quarterly from ‘Technical

Completion’ to ‘Financial

Completion’

Semi-annually after ‘Final

Completion’

Annually (60 days from each

30th November) after

‘Technical Completion’

Annually (60 days from each

31st December) after the 2nd

anniversary of ‘Technical

Completion’

Corporate O&M Team

and QHSE Team

Lenders’ E&S Adviser

QHSE Team



Shareholders: IFC, IFC

Asset Management

Company, Dash ventures,

Mubadala Infrastructure

Partners

Project Progress Report including a review of

Environmental & Social matters arising in relation to the

Project including QHSE performance and details of any

accidents, emergencies or other material events, in the

form of the Operational Dashboard

Electronic submission Monthly from Commercial

Operational Date (COD)

Corporate O&M Team

and QHSE Team

All Internal and External

Stakeholders

Corporate Sustainability Reporting including

communication on E&S performance for SHOB

Publicly available through Corporate website

Hard copy available in English at the CLO

office

Released at the end of Q1

annually – First report to be

released in Q2 2020, after that

to be continuously available

online

Corporate QHSE Team

Development


Specialist

TABLE 6 DISCLOSURE OF INFORMATION


5.2 Good Practice Considerations

As previously noted, the Project aims to follow international best practice in the management of the

Project’s environmental & social risks. In line with the recommended considerations in the IFC publication

on “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging

Markets”, the following management measures and actions have been, are or will be implemented by the

Project Company accordingly:

Good Practice Pointers4 Implemented or Committed Action by the Project Company

Managing the Transition from

Construction to Operations

A significant decrease in the workforce required towards the end of construction phase for

the Project has been experienced (including that local subcontractors’ workers and the

security team, where all employees were from Identified Local Communities). This

translated into a reduction in the scope of work of the LCC.

Continuity is being ensured by retaining the same Project Liaison Officer and CLD team who

have established strong relationships with stakeholders.

Periodically Review and Update

Stakeholder Information and

Assessment of Stakeholder

Perceptions

The stakeholder identification and associated information will be regularly reviewed, and

updates as needed over time, especially if there are significant changes in the external

environment that may mean a new stakeholder group should be included or others

prioritised. The monitoring and assessment of stakeholder perceptions in particular in

relation to the contribution of social development and investment initiatives shall be

undertaken and the methodology for measuring the returns is currently being evaluated.

Integration of ongoing

stakeholder commitments into

O&M QHSEMS

Commitments for environmental and social mitigation and performance monitoring and

improvement have been considered within the Project-specific QHSSEMS for the O&M

phase to ensure the continuity of management of environmental and social risks and

impacts.

Communication of the

Emergency Response and

Preparedness Plan (EPRP)

Based on the identification of emergency scenarios as per the Project-specific EPRP for the

O&M phase, the emergency scenarios are mostly related to potential occupational health

and safety incidents (and first aid response). As such, the O&M Contractor is expected to

communicate the Project-specific EPRP with local emergency response governmental

bodies (i.e. Civil Defence, Police Department, Healthcare Department).

The emergency scenarios identified that may involve or have an impact on the larger

‘identified local communities’ are limited to Level 3 of Emergency (e.g. floods, major

structural failure, severe wind storms, severe extremes in temperature) and blade and ice

throw risk which is covered through engagement with local herders and ongoing awareness.

TABLE 7 GOOD PRACTICE CONSIDERATIONS FOR STAKEHOLDER ENGAGEMENT

4 As per IFC publication on “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets”, May 2007, Part 2, Operations.


6 GRIEVANCE MECHANISM

The Grievance Mechanism presented herein describes the Project Community Grievance Procedure which

is also in line with the Corporate Grievance Mechanism Procedure (Ref: AE-QHSE-PRO-024). The Worker

Grievance Mechanism is described as part of the Project-specific QHSSE MS developed and implemented

by the Contractor (Ref: [HOLD]).

The Grievance Mechanism has been in place since the establishment of the Community Liasion Office in

November 2017 at the development stage of the Project and has been an integral part of the Project’s

QHSSE Management System. The Grievance Mechanism is and continues to be a critical aspect of the

stakeholder engagement process for the Project. The Grievance Mechanism:

- provides the appropriate platform for receiving, documenting and addressing complaints promptly

and communications from external stakeholders and allowing for anonymous complaints;

- uses an understandable and transparent consultative process that is culturally appropriate, at no

cost and not impeding access to other judicial and administrative mechanisms available in Jordan

for resolution of disputes;

- is fully documented for transparency as well as to prevent the recurrence of stakeholder concerns;

- is readily accessible to the Identified Local Communities through the Community Liasion Office

and communicated through displayed posters at the Community Based Organizations (CBO); and

- is ultimately intended to capture and respond to stakeholders’ concerns.

6.1 Grievance Mechanism Process

The following figure presents the different steps of the grievance management:

FIGURE 4 GRIEVANCE MECHANISM PROCESS

For the purposes of the Stakeholder Engagement Plan, the Grievance Mechanism is intended to provide

a well functioning procedure for receiving and addressing concerns about the Project’s environmental &

social performance from stakeholders, in particular from members of the Identified Local Communities,

whenever they may arise and facilitating resolution throughout the operational phase of the Project


The Grievance Mechanism is mostly implemented by the Community Liaison Office mainly through the

Project Liaison Officer (commonly referred to as CLO), who is under the responsibility of the Development

Manager, and in coordination with the Development Coordinator & Social Specialist and the Corporate

QHSE Team.

6.1.1 STEP 1 Receiving a Grievance

There are different ways in which a grievance from a stakeholder may be received such as verbal (e.g.

face to face or over the phone) or written (e.g. by letter or by email) and this may be received by different

members of the Project Company.

Grievances from members of the Identified Local Communities may most likely be received by the

Community Liaison Office. The Community Liaison Office has a dedicated telephone number, an email

and physical address where a complaints or grievance box together with forms in Arabic are available. The

contact details of the CLO and the location of the Community Liaison Office are as follows:

Project Liaison Officer Ret. Col. Mr. Khalil Odeh Al Hawartheh

Mobile +962772151728

Email [email protected]

Office Location Near to Shobak Mutasarrifah Building, Al Shobak District, Muthalath Village, Ma’an

Governorate

Coordinates: Latitude 30.518053 N, Longitude 35.535038 E

TABLE 8 COMMUNITY LIAISON OFFICE DETAILS

Whichever the way a grievance is received, it is the responsibility of the recipient to prompt the complainant

to complete a Project Grievance Form (see AE-QHSE-DOC-033 in Annex 1) or to complete the form on

his/her behalf should the complainant be illiterate.

Upon receiving a grievance by a complainant, the ‘direct employees’5 shall briefly explain the process and

different remaining steps to be followed as per the procedure including an ‘early’ indication on what the

appropriate actions may or may not entail in order to manage expectations of the complainant. The ‘direct

employees’ shall also ensure confidentiality of the complainant should he/she prefer to remain anonymous.

Once the form is completed, it shall be shared with the QHSE team.

Additionally, it could also occur that a member of the local community raise a concern within the Project

facilities (e.g. at the control building, substation, across the project site or outside the Project site) to

‘contracted workers’, in which case and in line with the Worker Grievance Procedure, the ‘contracted

workers’6 shall direct the individual to raise the concern through the Community Grievance Mechanism and

at the CLO. Any escalation that could lead to a situation of a Security Incident would then be managed

through the Security Management Plan or Emergency Response Plan.

6.1.2 STEP 2 Record the Grievance

All formal grievances shall be communicated to the QHSE team and recorded in the Project Grievance Log

Register (see SHOB-O&M-SOC-Grievance Log in Annex 2) and the completed Grievance Forms shall be

saved in the Project’s shared file system for record keeping purposes. In the case that the complainant

requested to remain anonymous, this should be respected accordingly within the Grievance Log.

5 ‘Direct employees’ are those engaged by the Project Company for their services (such as those of the CLO) or by Alcazar Energy. 6 ‘Contracted workers’ are those engaged through third parties, such as the Contractor or its subcontractors, to perform work related to core business processes for the operation and maintenance of the Project

mailto:[email protected]


6.1.3 STEP 3 Screen the Grievance

Grievances shall be screened and evaluated depending on the nature and the level of magnitude of the

complaint and/or the associated consequence, sensitivity of the complainants/s and the combined severity

of the complaint. Determining the level of severity of a grievance is critical in order to determine who the

grievance owner should be and how the grievance should be approached. See below table categorising

the different levels:

Severity Description Likely Grievance Owner

Level 1 The magnitude of the complaint is limited and possibly within the Project

operations and activities and the complainant/s does not belong to a

vulnerable group. The complaint may be managed at a local level through

the CLO and/or the Site Team

Community Liaison Office

and/or Development


Specialist

Level 2 The magnitude of the complaint may go beyond the Project area of

influence and operations. The complainant/s is a respected member or

representative of the Identified Local Communities. The grievance has the

potential to be escalated beyond the Project (e.g. to the Project Lenders)

and may pose environmental & social risks if improperly managed. The

complaint may be managed at a Corporate level and coordinated by the

QHSE Team.

Corporate QHSE Team

Level 3 The magnitude of the complaint may go above and beyond the Project area

of influence and operations, may be repeated (not the first occurrence)

and/or may be irreversible. The complainant/s is a respected member or

representative of the Identified Local Communities, governmental

representative or lobbying group. The grievance has the potential to be

escalated beyond the reach of the Company (e.g. to media and social

media) posing a reputational risk to Alcazar Energy in addition to the

inherent environmental & social risks.

Senior or Executive

Management

TABLE 9 GRIEVANCE LEVEL OF SEVERITY

6.1.4 STEP 4 Acknowledge the Grievance

A grievance shall be acknowledged by the recipient and/or assigned grievance owner, within two working

days of a grievance being formally received. The communication shall be made either verbally or in written

form, depending on the preferred method of communication by outlined by the complainant in the

Grievance Form. The date of acknowledgement shall be noted in the Grievance Log accordingly.

The acknowledgement of a grievance should include a high-level summary of the understanding of the

grievance, the first steps that will be taken by the Project Company in order to address the grievance and

an estimated timeframe. The acknowledgment also provides an opportunity for the grievance owner to

request for any clarifications or additional information in relation to the grievance in question.

6.1.5 STEP 5 Investigate the Grievance

The grievance owner shall be responsible for leading and coordinating the investigation of the grievance.

The investigation may entail consulting ‘direct employees’, ‘contracted workers’ or external stakeholders

as appropriate and determined on case-by-case basis. Records of meetings, discussions, activities and

documented evidence during the investigation shall be recorded. The information gathered during the

investigation shall be analysed to assist in identifying the root cause of the grievance and evaluating

whether the grievance is substantiated and actionable in line with Project legal framework. It is also the


responsibility of the grievance owner to ensure that the identity of the complainant remains anonymous if

applicable and that those involved in the investigation are knowledgeable of that.

6.1.6 STEP 6 Acting on the Grievance

Following the investigation, the grievance owner in coordination with the QHSE Team and O&M Team

shall determine how the grievance is to be addressed with the proposed steps to be followed including well

defined responsibilities and reasonable timelines on case by case basis. The proposed steps should take

into consideration the nature of the grievance and sensitivity of the complainant, so that confidentiality and

anonymity is respected as appropriate. The complainant shall be informed on the proposed actions and

engaged in the process to the extent believed appropriate on case by case basis.

The QHSE Team shall be responsible for assigning actions, monitoring implementation of actions

undertaken and making sure deadlines are adhered to. The implementable actions to be followed including

responsibilities and timelines shall be rigorously recorded within the Grievance Log by the QHSE Team.

6.1.7 STEP 7 Close Out & Follow up

Once all the proposed actions have been effectively implemented, the grievance owner considers the

grievance has been addressed and the QHSE Team has verified its implementation, the grievance owner

shall formally advise the complainant via their preferred method of contact of the implementation of such

actions, the rationale behind it in line with the Project legal framework and request feedback about the level

of satisfaction on the outcome and process followed. These shall de documented by the grievance owner

and recorded within the Grievance Log by the Corporate QHSE Team.

The grievance owner shall also fill in and signed off the Project Grievance Closeout Form (see AE-QHSE-

DOC-033 in Annex 3) and prompt the complainant to review it and sign it. It is worth noting that a

complainant may or may not be satisfied with the outcome and process followed to address the grievance

based on for instance his/her expectations, personal interests or understanding of the issue. Even in those

cases, a grievance may be considered ‘Closed’. This shall be documented within the Project Grievance

Log and the Project Grievance Closeout Form.

6.2 Considerations on Noise Management

As a requirement established in the ESIA, an ‘Operational Noise Verification Assessment was conducted

once all the turbines became operational (and prior to Commercial Operational Date) according to the

impact significance criteria guided by the Jordanian regulations for noise and the IFC EHS Guidelines

(2007). The noise verification assessment was completed in April 2020 by an independent environmental

and noise specialist consultant (ECO Consult and WKC) in line with best international practice. The noise

verification assessment concluded that:

“The operational noise levels show that the LA90 noise levels are 7.7 dB(A) and 5 dB(A) below the

Jordanian noise limits for daytime and night-time respectively. Considering the distance between the

nearest NSR and the nearest wind turbines, such outcomes are expected and hence, it is concluded that

noise levels from the operation of the wind turbines should not increase the background noise level at the

location where the monitoring was undertaken, which is recognized as the most sensitive receptor, and

therefore should not cause any nuisance impact at nearby villages.”


Based on the above, the study did not identify a requirement for environmental curtailment of the

operational turbines. The operational noise management measures shall therefore be supported by the

implementation of the Community Grievance Mechanism, as described herein:

- Any potential nuisance complaints in relation to the operation of the turbines received from

members of the local communities (even though based on the findings of the Noise Verification

Assessment) by any member of the Project team (employees, O&M Contractor, subcontractors)

shall be communicated to the CLO and the QHSE Team and registered through the Community

Grievance Mechanism;

- A preliminary evaluation of the grievance shall be conducted and as deemed appropriate, a site

visit shall be undertaken by the CLO along with other members of the O&M team to assess the

location of the potential noise sensitive receptor and whether such nuisance or disturbance

potentially originate from the operation of any specific wind turbines.

- In the case that for example, the complainant is not deemed a noise sensitive receptor or that the

nuisance is identified and not caused by the operation of any specific turbines, such grounds and

evaluation findings shall be explained to the complainant;

- Should the site visit and preliminary evaluation reveal that there could potentially be actual

nuisance and disturbance from the operation of any specific turbines on the potential sensitive

receptor, further assessments shall be evaluated in line with best practice on a case by case basis.

Assessments shall be carried out as appropriate in order to identify the potential mitigation

measures which could for instance include improvement of dwelling’s envelope condition and

insulation; and

- The complainant shall be kept duly informed and engaged during this process, which shall also be

fully documented with records saved as per the Project shared file system. The Grievance log shall

be kept updated.

6.3 Good Practice Considerations

As previously noted, the Project aims to follow international best practice in the management of the

Project’s environmental & social risks. In line with the recommended considerations in the IFC publication

on “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging

Markets”, the following measures and actions in relation to grievance management have been, are or will

be implemented by the Project Company:

Good Practice Pointers Implemented or Committed Action by the Project Company

Transparent and fair

grievance management

process readily

understandable, accessible

and culturally appropriate

for the local population

The Grievance Mechanism continues to be implemented throughout the Project O&M phase

through the Community Liaison Office and the accessibility to the grievance box. The Grievance

Mechanism Procedure will be simplified into a format and language (i.e. Arabic) readily

understandable to the Identified Local Communities and be available in hard copy at the

Community Liaison Office. The Grievance Mechanism Procedure will also be communicated

orally to individuals with lower levels of literacy through the Community Liaison Office

Scaling the grievance

mechanism to the Project

needs

Given the scale of the Project and the nature of operation and maintenance activities, the

Grievance Mechanism continues to be implemented throughout the Project O&M phase through

the Community Liaison Office. As previously noted, continuity is being ensured by retaining the

same Project Liaison Officer and CLD team who have established strong relationships with

stakeholders. In addition, the Grievance Mechanism as part of this Stakeholder Engagement

Plan as well as the simplified version in Arabic will be advertised in the Corporate website under

Project related Environmental & Social information.


Good Practice Pointers Implemented or Committed Action by the Project Company

Keeping documented

records of grievances

received and reporting

back

The Project Grievance Log is maintained up-to-date and the associated information is recorded

under the Project document control system. The E&S performance of the Project including how

the Project Company has been responding to the grievances received will be communicated

through the Corporate Sustainability Report on annual basis.

TABLE 10 GOOD PRACTICE CONSIDERATIONS FOR GRIEVANCE MANAGEMENT


7 RESOURCES & RESPONSIBILITIES

This section is intended to define clear roles, responsibilities and authority for the designated individuals,

groups or teams responsible for the implementation and monitoring of stakeholder engagement activities

in addition to the expected high-level responsibilities of the identified stakeholders.

7.1 Community Liaison Office

The Community Liasion Office during the O&M phase is composed of Project Liaison Officer (Ret. Col. Mr.

Khalil Odeh Al Hawartheh) and the Public Relations Officer (Hamzeh Abd Al Rahman Ali Al Shqeerat). The

responsibilities of the Community Liasion Office are as follows:

- Acting as the focal point of contact for day-to-day engagement and consultation with members of

the Identified Local Communities;

- Continuing to build and maintain a constructive and dynamic relationship with the Identified Local

Communities, including Local Community representatives, CBOs and local governmental entities,

for the long-term, fostering an environment of community involvement and ownership, and

providing a sense of control over Project-related information being communicated to them;

- Monitoring community attitudes and trends towards the Project and communicating those to the

Development Coordinator & Social Specialist;

- Maintaining a proactive and engaging relation with the Development Coordinator & Social

Specialist keeping him duly and timely informed of any particular issues or concerns identified,

grievances raised, opportunities for engagement and any additional related subjects;

- Supporting as required in the implementation ‘on-the-ground’ of the Social Development &

Investment Program;

- Making the Project related documentation is available within the CLO office as well as CBOs as

described in Section 5;

- Providing support to tailor the content of the Project brochure and/or poster to ensure that the

content and format fits the information needs of the Identified Local Communities;

- Coordinating with the Development Coordinator & Social Specialist Maintaining for any suggested

or planned stakeholder engagement sessions, including support meetings, focus groups or

briefings or community gatherings in relation to the Project;

- Conducting engagement with nomads, local herders and users of the grounds of the Project for

information disclosure through consultation and informing them of the appropriate avifauna

management measures, the risk of blade & ice throw and the noise generation by the WTGs.

Keeping documented evidence of such engagement, maintaining records within the provided log

(see Annex 4) and periodically sharing those with the Development Coordinator & Social

Specialist;

- Effectively implementing the Grievance Mechanism described in Section 6 by:

o Receiving and recording all verbal or written complaints and communicating those with the

Development Coordinator & Social Specialist;

o Leading and coordinating the investigation of ‘Level 1’ grievances as well as the

implementation of actions within the associated timelines;

o Keeping physical record of completed Grievance Forms and Grievance Closeout Forms

and sharing those timely with the Development Coordinator & Social Specialist; and

o Monitoring of the Community Grievance Box and availability of Grievance Forms on daily

basis.

7.2 Development Coordinator & Social Specialist

- Provide guidance, direction and supervision to the Community Liaison Office on all matters related

to stakeholder engagement and the implementation of the grievance mechanism; but not limited


consultation and disclosure events, community meetings, evaluating, reporting and resolving

community grievances and providing feedback to the communities on issues.

- Acting as a point of liaison between the Community Liaison Office and the QHSE Team;

- Continue building and maintaining a constructive and dynamic relationship between the Identified

Local Communities and the Interest-based Stakeholders (in particular the Directorate of Education

and the Directorate of Solidarity) and Alcazar Energy communicating our strong commitment to

socio-economic development, environmental protection, respect for labour & human rights and

strong governance;

- Supporting the Development Manager in the liaison with the national Participatory Stakeholders

(i.e. NEPCO and MEMR) being a focal point of contact;

- Monitoring community attitudes and trends towards the Project, identifying changes in satisfaction

levels and the underlying causes, identifying any particular E&S risks and opportunities, and

communicating those, and any particular issues or concerns and grievances raised, to the QHSE

Team so any suitable changes in the stakeholder engagement approach can be timely

implemented if necessary;

- Ensuring that Project related documentation is available within the CLO office as well as CBOs as

described in Section 5;

- Providing support to develop the content of the Project brochure and/or poster to ensure that the

content and format fits the information needs of the Identified Local Communities and is in line with

the provisions of this Stakeholder Engagement Plan;

- Maintaining records of stakeholder engagement activities, including consultation with nomads,

local herders and Project-grounds users, support meetings, focus groups or briefings or community

gatherings in relation to the Project as well meetings or formal communications with Interest-based

Stakeholders and national Participatory Stakeholders. Ensuring that the Stakeholder Engagement

Log is updated on monthly basis with inputs from the team at country level and shared with the

QHSE Team;

- Managing and coordinating the implementation of the different initiatives and projects under the

Social Development & Investment Program;

- Coordinating the submission of the Semi-annual Synopsis of Avian and Bat Monitoring & Impact

Mitigation Measure Report as well as the Operational Raw Data of avifauna monitoring to the

MoEnv in timely manner; and

- Effectively supporting the CLO in the implementation of the Grievance Mechanism described in

Section 6 and ensuring documentation is timely shared and effectively communicated to the QHSE

Team, including the Grievance Log for ‘Level 1’ grievances.

7.3 Grievance Recipients

- Prompting the complainant to complete a Project Grievance Form or to complete the form on

his/her behalf should the complainant be illiterate;

- Briefly explaining the process and steps to be followed as per the procedure, ensuring the

confidentiality of the complainant in the process if wished so;

- Acknowledging grievances within two working days of a grievance being formally received on the

written or verbal mode that the complainant preferred (if any); and

- Determining proposed steps to address the grievance including well defined responsibilities and

reasonable timelines on case by case basis in liaison with the O&M Team and QHSE Team and

advising the complainant of the implementation of such actions, requesting feedback on

satisfaction on the outcome and process followed; and

- Completing, recording and share the Grievance Closeout Form as appropriate internally.


7.4 Corporate QHSE Team

- Responsible for managing and overseeing the effective implementation of this Stakeholder

Engagement Plan and the Grievance Mechanism described herein including its periodical

monitoring and evaluation of performance;

- Ensuring that Project related documentation ESIA, NTS, Updated SEP and Project brochure

and/or poster are continuously available on the Corporate website;

- Ensuring the implementation of the Avifauna Monitoring & Observer-led Shutdown Protocol and

Carcass Search Protocol, approving the Semi-annual Synopsis of Avian and Bat Monitoring &

Impact Mitigation Measure Report and ensuring the timely submission together with the

Operational Raw Data of avifauna monitoring to the MoEnv;

- Providing necessary input on the Stakeholder Engagement Log on monthly basis;

- Providing necessary input on the Project Progress Report to be submitted to the Participatory

Stakeholders (i.e. Project Lenders and Company Shareholders) including a review of

Environmental & Social matters arising in relation to the Project including QHSE performance and

details of any accidents, emergencies or other material events;

- Developing the Corporate Sustainability Report including communication on environmental and

social performance for the Project, amongst other Company projects, and ensuring it is made

publicly available through the Corporate website;

- Effectively implementing the Grievance Mechanism described in Section 6 by:

o Leading and coordinating the investigation of ‘Level 2’ grievances as well as the

implementation of actions within the associated timelines and overseeing the same for

‘Level 1’ grievances;

o Keeping electronic record of completed Grievance Forms and Grievance Close-out Forms

and maintaining the Grievance Log updated;

o Assigning actions, monitoring implementation of actions undertaken and making sure

deadlines established are adhered to; and

o Ensuring that ‘direct employees’ and ‘contracted workers’ are aware and knowledgeable

of their responsibilities under the Grievance Mechanism through e.g. refresher training

sessions.

7.5 O&M Team

- Directly supporting the QHSE Team on the effective implementation of this Stakeholder

Engagement Plan and the Grievance Mechanism described herein;

- Providing necessary input on the Stakeholder Engagement Log on monthly basis; and

- Duly and timely submission of the Project Progress Report, including a review of Environmental &

Social matters arising in relation to the Project including QHSE performance and details of any

accidents, emergencies or other material events, to the Participatory Stakeholders (i.e. Project

Lenders and Company Shareholders).

7.6 Senior and Executive Management

Ultimately responsible for overseeing the effective implementation of this Stakeholder Engagement Plan,

and the Grievance Mechanism described herein:

- Ensuring adequate resources are made available accordingly and that all parties are aware and

knowledgeable of their responsibilities under the Stakeholder Engagement Plan and the Grievance

Mechanism; and

- Monitoring of its performance through ongoing stakeholder analysis and assessment of

stakeholder concerns from a risk-perspective, which could affect not only the environmental &

social performance of the Project but also the Company’s reputation and business performance.


7.7 Identified Stakeholders

7.7.1 Members of the Identified Local Communities

Responsible for following the established procedure and mechanisms for the submission of any concern,

issue or complaint in relation to the operation of the Project.

7.7.2 Interest-based Stakeholders

- Following formal communication channels for any engagement with Alcazar Energy in relation to

the operation of the Project; and

- Following the established procedure and mechanisms for the submission of any concern, issue or

complaint in relation to the operation of the Project.

7.7.3 Participatory Stakeholders

Responsible for following formal communication channels for any engagement with Alcazar Energy in

relation to the operation of the Project.

7.7.4 Internal Stakeholders

The O&M Contractor, and its subcontractors, are responsible for:

- Following the established procedures and mechanisms in relation to this Stakeholder Engagement

Plan, as applicable, as well as for the successful implementation of the Worker Grievance

Mechanism as part of the Project-specific QHSSE; and

- Communicating and sharing the Emergency Preparedness and Response Plan (EPRP), once

approved, with the local emergency response governmental bodies (i.e. Civil Defence, Police

Department, Healthcare Department).


8 MONITORING AND REPORTING

8.1 Monitoring and Auditing

The implementation of this Stakeholder Engagement Plan shall be monitored through the periodical review

of the Stakeholder Engagement Log to be updated and submitted by the Development Coordinator and

Social Specialist to the QHSE Team on monthly basis, to assess whether the engagement activities within

this Plan are being successfully and timely undertaken.

The implementation of this Plan shall also be monitored through the continuous review of the Grievance

Log within the QHSE Statistics. The performance of its implementation and the timely resolution of

grievances shall be evaluated on monthly basis as part of the review of the Project’s QHSSE key

performance indicators (KPIs).

In addition, the Project also recognises the importance of applying ‘participatory monitoring’ techniques to

increase both the accountability of the Project and the credibility of the environmental and social monitoring

results:

Good Practice on

Participatory Monitoring Implemented Actions by the Project Company

Participation of Identified

Local Communities in

monitoring environmental

impacts and management

measures

During the Autumn period from Sep 2019 to Nov 2019, a training program was implemented

entailing the fair and transparent selection and training of six (6) local community members as

junior avifauna observers and carcass searchers with the aim of building local capacity. The

junior avifauna observers also have a direct communication line and trust relation with the

Project Liasion Officer and the Project team, which they can exercise in order to share the

views gathered from other members of the Identified Local Communities

Participation of Identified

Local Communities in

monitoring community

attitudes and social trends

towards the Project

The Community Liasion Office is composed of members from the Identified Local

Communities, with the Project Liaison Officer being a respectable representative and advocate

of the interests and concerns of the community. Through its different engagements, the Project

Liaison Officer monitors the opinions and reactions of the local communities towards the

Project and reports those to the Project team

TABLE 11 GOOD PRACTICE CONSIDERATIONS FOR PARTICIPATORY MONITORING

The implementation of this Stakeholder Engagement Plan shall be audited through quarterly inspections

conducted by the QHSE Team to recognize as far as possible any non-conformance, gaps or

recommendations for improvement. The review of documentation shall include for instance an on-the-

ground assessment to determine whether the Project-related and Grievance Mechanism related

documentation being available at the designated locations.

8.2 Reporting

The reports that shall be made available to the Identified Local Communities as are as previously noted:

- ESIA, NTS, ESAP and Updated Stakeholder Engagement Plan;

- Avifauna Monitoring and Shutdown on Demand Protocol and the Semi-annual Synopsis of Avian

and Bat Monitoring & Impact Mitigation Measure Report;

- Social Development and Investment Program,

- Grievance Mechanism related documentation: Grievance mechanism simplified procedure in

Arabic, Grievance box and grievance forms and Updated Grievance Log; and

- The Project brochure and/or poster.


The Project brochure and/or poster, which is currently under development, shall be a key document

presenting the most relevant facts of interest to the local communities on the above documents in the

adequate shape, format and language.

The different reports to be disclosed and share with interest-based Stakeholders and Participatory

Stakeholders are listed in Section 5.1.

In addition, Alcazar Energy plans to publicly release its first Corporate Sustainability Report in Q2 2020.

This report is intended to be complementary to, but not a substitute for the documentation for disclosure of

information targeted to the different stakeholder groups in Section 5.1.

The release of the first Corporate Sustainability Report has been timed with the reporting timeframe of the

Project Annual Monitoring Report on Environmental & Social Performance including Impact Indicators to

be submitted to the Project Lenders. The Corporate Sustainability Report will also represent the our first

‘Communication on Progress’ (COP) fulfilling our commitment as Participants to the United Nations Global

Compact (UNGC) since March 2019. The COP is an annual disclosure to stakeholders on progress made

in implementing the Ten Principles of the UNGC with respect to human rights, labour, environment and

anti-corruption describing the practical actions taken and the performance measurements against them

Sustainability reporting provides an opportunity to communicate information to a wide range of

stakeholders about the environmental, social, economic, and governance performance of the Project and

the wider Company operations, also offering a platform to report back on the process of stakeholder

engagement and grievance management


ANNEX 1 – PROJECT GRIEVANCE FORM

GRIEVANCE REGISTRATION FORM

GENERAL

Project

Case #

Complainant full Name

Contact Information

Please mark how you wish to be contacted (mail, telephone, e-mail).

By Post: (Please provide mailing address)

_________________________________________________________________________________________________________________________________________________________________________________________

By Telephone: _______________________________________________

By E-mail: ___________________________________________________

IDENTIFICATION OF THE CONCERN / INCIDENT / GRIEVANCE

Description of Concern / Incident / Grievance

What is your grievance?

What happened?

Where did it happen?

Who did it happen to?

What is the result of the problem?

Date of Concern / Incident / Grievance

One-time incident/grievance (date _______________)

Happened more than once (how many times? _____)

On-going (currently experiencing problem)

RESOLUTION PROPOSAL

What would you like to see happen to resolve the problem?

Date: _______________________________

Please return this form to:

• Mr. Qusai Al-Abbassi | [email protected] | Tel: +962 79 506 8915

• QHSE Team | [email protected] | Tel: +971 4 558 7805



ي تسجيل الشكاونموذج

معلومات عامة

المشروع

رقم الحالة

اسم المشتكي بالكامل

معلومات الاتصال

يرجى اختيار الوسيلة المناسبة للاتصال بك )بريد، هاتف، بريد الإلكتروني(.

يرجى وضع عنوان البريد الخاص بك( :عن طريق البريد( ______________________________________________________________________________________________________________________________________________________________________________________________________

:عن طريق الهاتف ____________________________________________________________________________________________________________________________________

:عن طريق البريد الإلكتروني ____________________________________________________________________________________________________________________________________

بيان المشكلة / الحادث / الشكوى

وصف المشكلة / الحادث / الشكوى ما هي الشكوى؟ ما الذي حدث؟

أين حدث؟ مع من حدث؟

ما هي نتيجة المشكلة؟

(______________________حادث / شكوى لمرة واحدة )التاريخ تاريخ المشكلة / الحادث / الشكوى ( __________حدثت أكثر من مرة )كم عدد المرات؟

مستمر )مشكلة يتم اختبارها بشكل مستمر(

مقترح الحل

ماذا برأيك الحل الممكن لهذه المشكلة؟

__________________________________التاريخ:

يرجى إرجاع هذا النموذج إلى:

8915 506 79 962+| هاتف: [email protected] | السيد. قصي العباسي

7805 558 4 971+| هاتف: [email protected] الصحة، والسلامة، والبيئة | وقسم الجودة،


ANNEX 2 – PROJECT GRIEVANCE LOG

PROJECT: Shobak Wind Farm DATE: 03/Mar/2020 PREPARED BY: Patricia Gimenez

ARWF-O&M-Stakeholder Engagement Plan-Rev03 41

ANNEX 3 – PROJECT GRIEVANCE CLOSEOUT FORM

GRIEVANCE CLOSE OUT FORM

GENERAL

Project

Case #

Complainant full Name

Type of issue

(mark with X). Complaint Suggestion Concern

ACTION FOR RESOLUTIONS

Resolutive action and timeframe

ACTION

TARGET DATE

Justification for the action

CONCLUSIONS (This section is completed upon completion of all agreed actions)

Action Implementation Date

Complainant Satisfied with Process

Yes No

Comments

Complainant Satisfied with Outcome

Yes No

Comments

Complainant Signature on Complaint Close Out ____________________________ Date _________________

Grievance Owner Signature on Complaint Close Out

____________________________ Date _________________

ي الشكاو إغلاقنموذج

معلومات عامة

المشروع

الحالة رقم

اسم المشتكي بالكامل

نوع القضية (. X)ضع اشارة

شكوى

اقتراح

مخاوف اجراءات الحل

الحل الحل الاجرائي والاطار الزمني

الوقت المستهدف

تفسير الحل

عند الانتهاء من جميع الإجراءات المتفق عليها(مكتمل لاستنتاجات )هذا القسم ا

تاريخ تنفيذ الإجراء

عن العملية ض مقدم الشكوى را نعم

لا

تعليقات

مقدم الشكوى راض عن النتيجة

نعم

لا

تعليقات

توقيع مقدم الشكوى على إغلاق

الشكوى

__________________________ _______________________________________ التاريخ:

إغلاق توقيع صاحب الشكوى على

الشكوى

_______________________________________ التاريخ: __________________________

ARWF-O&M-Stakeholder Engagement Plan-Rev03 44

ANNEX 4 – CLO ENGAGEMENT ACTIVITIES LOG

stakeholder engagement plan - alcazar energy

Documents