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Funded by the EU Delegation to South Africa
BOSA TRANSACTION ADVISORY SERVICES
STAKEHOLDER ENGAGEMENT PLAN – JUNE 2017
DOCUMENT CONTROL
Document prepared by
Aurecon South Africa (Pty) Ltd
Reg No 1977/003711/07
Aurecon Centre Lynnwood Bridge Office Park 4 Daventry Street Lynnwood Manor 0081
T F E W
+27 44 8055428 +27 83 3086750 diane.erasmus@aurecongroup.com aurecongroup.com
A person using Aurecon documents or data accepts the risk of: a) Using the documents or data in electronic form without requesting and checking them for accuracy against the original hard
copy version.
b) Using the documents or data for any purpose not agreed to in writing by Aurecon.
Document control
Report title Stakeholder Engagement Plan – BOSA Transaction Advisory Services
Document ID 112581REP001 Project number 112581
File path \\ZAGRJPFS01\Adm_Old$\Data\PROJECT\ENVIRO\PROJECTS\112581 ~ BOSA ESIA\7. Deliver Service\SEP\112581REP001 BOSA Stakeholder Engagement Plan v0.docx
Client SAPP CC Client contact Mr. Alison Chikova
Rev Date Revision details/status Author Reviewer Verifier (if required)
Approver
0 8 December 2016 First Draft Submission Various Nigel Waters Deon Vrey
1 1 June 2107 Second Draft Submission A Visagie; D Erasmus
Nigel Waters Deon Very
Current revision A6
Approval
Author signature Approver signature
Name Diane Erasmus Name Deon Vrey
Title Associate Title Technical Director
CONTENTS
DOCUMENT CONTROL
CONTENTS
1 Introduction 1
1.1 Project Background 1
1.2 The aims and objectives of Stakeholder Engagement 1
1.3 Stakeholders 3
1.4 Scope of work 4
1.5 Legal framework 5
2 Stakeholder Engagement in the ESIA 5
2.1 Timelines 5
2.2 Step 1: Stakeholder identification 7
2.3 Step 2: Notification 9
2.3.1 Background Information Document (BID) and Pamphlets 9 2.3.2 Advertisements and Site Notices 9 2.3.3 Invitation to comment 10 2.3.4 Language 11
2.4 Step 4: Comment periods and meetings 11
2.4.1 Comment periods 11 2.4.2 Meetings 11 2.4.3 Comments and Responses Report 12 2.4.4 Review Project Documentation 13
2.5 Step 6: Milestone notifications 13
2.6 Review ESIA and ESMP 14
3 Grievance Mechanism 14
3.1 During the construction phase 15
3.2 During the operational phase 15
3.3 Roles and Responsibilities 16
4 Conclusion 16
5 Bibliography 17
Figures
Figure 1 | Guiding principles for effective stakeholder engagement 2
Figure 2 | Alignment of final approved routes, from new Watershed site location northwest of
Mafeking 3
Figure 3 | Summary of SEP timeframe 6
Tables
Table 1 | List of relevant legal regulations at national and international scales 5
Table 2 | Provisional list of the progress or milestones 13
BOSA Stakeholder Engagement Plan CONTENTS Page | i
Acronyms
Acronyms Description
AoI Area of Influence
BID Background Information Document
BPC Botswana Power Corporation
EIA Environmental Impact Assessment
ESIA Environmental and Social Impact Assessment
ESMS Environmental and Social Management System
IFC International Finance Corporation
NGO’s Non-governmental Organisations
SAHRA South African Heritage Resources Agency
SAPP Southern African Power Pool
SEP Stakeholder Engagement Plan
BOSA Stakeholder Engagement Plan Page | 1
1 Introduction
1.1 Project Background
The Southern African Power Pool (SAPP) is proposing to construct approximately 210 km of 400 kV
transmission lines from the existing Isang substation near Gaborone in Botswana to the proposed
Watershed B substation in South Africa, as shown in Figure 1, with 146 km in South Africa and 64 km
in Botswana. The 400 kV line will comprise two transmission lines, placed up to 60 m apart from each
other. The beneficiaries will be Eskom in South Africa and the Botswana Power Corporation in Botswana
(BPC).
In terms of the environmental legislation in both South Africa and Botswana, the project falls within the
mandatory list of projects requiring that an Environmental Impact Assessment (EIA) is undertaken, which
require authorisation from the competent environmental authority prior to commencement. The
environmental assessment includes a substantial social component and is therefore termed an
Environmental and Social Impact Assessment (ESIA).
To appropriately incorporate social considerations fully, Aurecon has prepared a Stakeholder
Engagement Plan (SEP) as per the requirements of the International Finance Corporation (IFC) and the
World Bank. This SEP provides the platform for the Utilities (Eskom and BPC) to consult with the
potentially affected stakeholders and communities to identify and address any issues or concerns of the
stakeholders and community that may arise because of the project. It further provides a mechanism to
allow for ongoing stakeholder engagement and grievance management through the project lifecycle, in
line with international best practice. This SEP therefore provides a framework for the engagement
process but should, where required, be seen as a dynamic document to be updated continuously
throughout the life cycle of the project in order to adapt to conditions on the site or meet the needs of
the stakeholders and communities as these changes become evident.
On submission of the full Scoping and ESIA Reports to the environmental authorities in both South
Africa and Botswana, a more formalised comment period will be given to the relevant stakeholders and
authorities to provide written comments on the contents of the reports. However, in terms of the IFC
requirements, it is important to start with stakeholder engagement from the initial phases of the project
planning to fully incorporate the stakeholders’ concerns, issues and questions to inform project design
and planning and ensure access local knowledge. Stakeholder engagement must be continued
throughout the project lifecycle to ensure the project’s success. Stakeholder engagement after the ESIA
will be undertaken by the project proponent.
1.2 The aims and objectives of Stakeholder Engagement
Stakeholder engagement has been described by the IFC as a broad, inclusive and continuous process
of communication between an organisation and those potentially impacted by the activities of the
organisation. It can include a wide range of activities which is relevant to the entire life of a project.
It is recognised that there are significant reputational risks for an organisation that result from poor
stakeholder relations. Corporate social responsibility, transparency and reporting are increasing in
importance and good stakeholder relations are a prerequisite for good risk management (IFC, 2007).
The aim of stakeholder engagement differs at different stages of the project lifecycle. At the ESIA stage,
the aim is to provide an opportunity for stakeholders to be informed of projects occurring in their area
and that may affect them directly or indirectly and to provide an accessible and meaningful opportunity
for people to ask questions, raise concerns or grievances; and to ensure that these are used to guide
new development, and ongoing operations, in a responsible manner that compliments the local
socioeconomic environment and enhances the benefit of a given project.
BOSA Stakeholder Engagement Plan Page | 2
The objective at early stages of project development is as follows:
• To implement projects that contribute to upliftment and cohesion within the local social
environment;
• To implement projects that have the support, trust and respect of communities in which they
operate (social license to operate);
• To implement projects that meet the needs of the many, not the few;
• To implement projects that are adapted to fit a market niche;
• To implement projects that build the communities in which they operate; projects that avoid the
marginalisation of vulnerable groups;
• To implement projects that respect and protect local culture and customs;
• To implement projects that manage negative impacts to natural and social capital and do not
undermine human health and wellbeing.
In pursuit of these objectives the project will also contribute to business environment that lowers
business risk and promotes economic resilience. The IFC Performance Standard 1 states the objectives
as:
• To ensure that grievances from Affected Communities and external communications from
other stakeholders are responded to and managed appropriately; and
• To promote and provide means for adequate engagement with Affected Communities
throughout the project cycle on issues that could potentially affect them and to ensure that
relevant environmental and social information is disclosed and disseminated.
Companies seeking to undertake effective stakeholder engagement should consider the following
guiding principles as shown in Figure 2 (Source: (IFC, 2010, p. 39)).
Figure 1 | Guiding principles for effective stakeholder engagement
BOSA Stakeholder Engagement Plan Page | 3
1.3 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. Stakeholders may include locally affected communities or individuals and their formal and
informal representatives, national or local government authorities, politicians, religious leaders, civil
society organisations and groups with special interests, the academic community, or other businesses
(IFC, 2007). The landowners and communities affected by this project will be along the alignment shown
in Figure 2 below.
Figure 2 | Alignment of final approved routes, from new Watershed site location northwest of Mafeking
BOSA Stakeholder Engagement Plan Page | 4
1.4 Scope of work
A Stakeholder Engagement Plan must be compiled for the duration of the project life cycle. It is the
responsibility of each Utility to have such a plan in place. The scope of work for this part of the SEP is
for the ESIA phase. Stakeholder engagement requirements for the construction phase must be compiled
by the project proponent implemented and by the Contractor and the Utility is responsible for
Stakeholder Engagement during the operational phase.
The public consultation process required for the project forms part of the ESIA process. Furthermore, to
meet the IFC’s international requirements, intensive stakeholder engagement is a prerequisite.
The IFC Performance Standard 1 applies to all Category A projects1 that have potentially significant
environmental and social risks and impacts. The requirements section of each Performance Standard
applies to all activities financed under the project, unless otherwise noted in the specific limitations
described in each paragraph. Clients are encouraged to apply the Environmental and Social
Management System (ESMS) developed under Performance Standard 1 to all their project activities,
regardless of financing source. A number of cross-cutting topics such as climate change, gender, human
rights, water and indigenous peoples, are addressed across multiple Performance Standards (IFC,
2012).
The IFC Performance Standard 1 also establishes the importance of: (i) integrated assessment to
identify the social and environmental impacts, risks, and opportunities of projects; (ii) effective
community engagement through disclosure of project-related information and consultation with local
communities on matters that directly affect them; and (iii) the management of social and environmental
performance throughout the life of the project. According to the IFC Performance Standard 1 Guidance
Notes, a SEP should address the following:
• Describe regulatory, lender, company, and/or other requirements for consultation and
disclosure;
• Identify and prioritise key stakeholder groups, focusing on Affected Communities;
• Provide a strategy and timetable for sharing information and consulting with each of these
groups;
• Describe resources and responsibilities for implementing stakeholder engagement activities;
and
• Describe how stakeholder engagement activities will be incorporated into a company’s
management system.
IFC Performance Standard 1 also stipulates that stakeholder consultation should include elements of
capacity building to ensure the process is considered “free, prior and informed”. This will be done by:
• Providing accessible and adequate information without creating undue fears (related to potential
negative impacts) or expectations (regarding jobs);
• Including visual illustrations and verbal explanations for illiterate stakeholders; and
• Using local languages and small groups to ensure stakeholders do not feel intimidated.
• Consultation will provide vulnerable groups equal opportunities to participate by:
• Giving special effort to identify disadvantaged or vulnerable groups; and
• Providing transportation and or subsidies for vulnerable poor, if required, to ensure their
participation does not come at the expense of their livelihoods.
1 Category A projects are expected to have a significant adverse social and/or environmental impacts that are diverse, irreversible or unprecedented. Category B projects are those expected to have limited adverse impacts as above.
BOSA Stakeholder Engagement Plan Page | 5
1.5 Legal framework
The ESIA will be undertaken in line with South African and Botswana environmental law, alongside other
international standards and regulations, as reflected above. The legal framework thus includes but is
not limited to the following legal documents identified in Table 1.
Table 1 | List of relevant legal regulations at national and international scales
Act Country of relevance
The Constitution of the Republic of South Africa (Act no 108
of 1996) South Africa
Botswana Constitution (1966) Botswana
National Environmental Management Act (Act no 107 of
1998) South Africa
Environmental Impact Assessment Regulations (2014) South Africa
Environmental Assessment Act 2011 Botswana
Environmental Assessment Regulations, 2012 Botswana
International Finance Corporation. (2010). Guide to Human
Rights Impact Assessment and Management. South Africa and Botswana
The Equator Principles South Africa and Botswana
2 Stakeholder Engagement in the ESIA
The following section provides a step by step process of stakeholder engagement activities to be
implemented in lead up to the commencement of construction. Please note that for the successful and
effective implementation of the SEP, this document must be treated as dynamic and as such is expected
be updated throughout the process of the project as additional information informs the project and new
relationships are formed.
2.1 Timelines
A draft timeline for the ESIA stakeholder engagement activities is included in Figure 3 on the following
page. It provides a summary version of the proposed Gantt chart for the ESIA process, showing the
steps contained in this SEP, which is elaborated on in sequential order under subheadings to follow.
BOSA Stakeholder Engagement Plan Page | 6
BOSA line ESIA Oct-16
Nov-16
Dec-16
Jan-17
Feb-17
Mar-17
Apr-17
May-17
Jun-17
Jul-17
Aug-17
Sep-17
Oct-17
Nov-17
Dec-17
Jan-18
Feb-18
Mar- 18
Apr-18
Pre-application phase
Scoping Phase
SE / PPP Round 1 (Notification)
SE / PPP Round 2 (Scoping)
Final Scoping Report (FSR) & CRR
Specialist Studies
Specialist studies
EIA Phase
SE / PPP Round 3 (EIA)
Final EIA Report
Notify I&APs of decision
Appeal period
RAP
Figure 3 | Summary of SEP timeframe
BOSA Stakeholder Engagement Plan Page | 7
2.2 Step 1: Stakeholder identification
The objective is to identify and register the key stakeholders that will be directly affected by the project or
entities that have a jurisdictional mandate governing any aspect into which the project may exert influence.
During this phase, the Environmental Authority shall be consulted and asked which other parties should be
included on the stakeholder registry. The key stakeholders, referred to as Interested and Affected Parties
(I&APs), are to be captured in a stakeholder registry/ database.
The contact information for the following primary stakeholders is sourced as follows:
SOUTH AFRICA AND BOTSWANA COMMUNITY2:
Properties on which the transmission line will be located are primary stakeholders
Neighbouring / adjacent landowners of affected landowners on either side are also considered
primary stakeholders
Relevant Non-governmental Organisations (NGO’s)Schools, religious centres, hospitals or other
social infrastructure within the project
IN SOUTH AFRICA
South African Heritage Resources Agency (SAHRA)
North West Provincial Heritage Resources Authority
Local, district and provincial municipalities
Mahikeng Local Municipality
Ramotshere Moiloa Local Municipality
Ngaka Modiri Molema District Municipality
Provincial departments of agriculture, environment and rural development
Department of Rural, Environment and Agricultural Development
Department of Energy
Department of Water and Sanitation - Regional Office
Department of Water and Sanitation - National Office
Department of Agriculture, Forestry and Fisheries - National Office
Department of Agriculture, Forestry and Fisheries - Regional Office
Department of Rural Development and Land Reform
Department of Mineral Resources - Regional Office
State Owned Companies (Transnet)
South African Heritage Resources Agency
Telkom
Transnet SOC Ltd
South African National Roads Agency (SANRAL)
Eskom
IN BOTSWANA
Departments in Botswana
Department of Waste Management & Pollution Control (DWMPC)
Water Utilities Corporation
Department of Lands
2 A better understanding of the social hierarchical structure of the affected communities will be needed to identify the correct communication channels for these stakeholders. For example, it may be required that chiefs are identified within a community and expect to be the first port of call. From there the chiefs may assist in organising meetings with other affected members of the community.
BOSA Stakeholder Engagement Plan Page | 8
Department of Public Health
Department of Tourism
Department of National Museum and Monuments
Department of Wildlife
Department of Forestry
Department of Crop Production
Department of Veterinary Services
Department of Animal Production
Botswana Tourism Organisation
KGATLENG DISTRICT COUNCIL
Kgatleng District Council Fire Department
Kgatleng District Council Environmental Health
Kgatleng District Council Roads Division
Kgatleng Land Board
Tribal Administrations/ Authorities
Dikgosi, Headmen and Village Development Committees (VDCs)
Members of Parliament and District Commissioners
Tribal Administrations, Land Boards and sub-Land Board
Elected representatives-MPs
Kgatleng Constituency (MP)
Non-Authority Stakeholders
Businesses around/along site
Residents close to/along site
Bird Life Botswana
Kalahari Conservation Society
Deed searches were used to identify property owners and their contact details. Property owners were then
contacted via telephone to verify postal and email addresses. In terms of an electronic database, I&AP
details are captured and updated as and when information is distributed to or received from I&APs. This
ongoing and up-to-date record of communication is an important requirement of the authorities for public
involvement.
The database is also used to code what are termed “key stakeholders”. These include the authorities, land
owners, I&APs who act as sectoral representatives, and individuals who have previously expressed
sentiments (positive or negative) regarding the area and environmental processes.
A linear project such as this may have impacts on people outside of the immediately affected stakeholders,
known as secondary stakeholders. Secondary stakeholders can be identified by means of newspaper
advertisements, radio notices and word of mouth.
Background information documents, pamphlets and site notices were distributed to the following community
halls, libraries, post office:
South Africa:
• Bewley,
• Lehurutshe: Community Library,
• Serake/ Driefontein: Swartfontein Post office or shopping complex,
• Supingstad: Shop / spaza
Botswana:
• Dikwididing
• Mochudi
BOSA Stakeholder Engagement Plan Page | 9
2.3 Step 2: Notification
Notification about the project will be undertaken at four stages in the project, as follows:
2.3.1 Background Information Document (BID) and Pamphlets
A short detailed Background Information Document (BID) was compiled in a non-technical format (Appendix
1). In the initial phases of the project, this document was distributed to interested members of the public
and communities. Early engagement of the government departments was initiated. Meetings were held with
the Department of Environment Affairs in South Africa and Botswana
The BID documents included maps and diagrams to assist those with lower literacy levels. The BID
included:
• A description of the project;
• A very brief description the projects regulatory requirements or framework, the lender and the
Project Proponent(s);
• A description of how stakeholders may become involved or submit comments regarding the
project and by when they should do so;
• An explanation of stakeholder engagement sessions to take place; and
• Project contact details.
2.3.2 Advertisements and Site Notices
Newspaper advertisements will be placed in the relevant newspapers in Botswana and South Africa to
inform the public of the project and the availability of project information as indicated below:
• The above-mentioned advertisements invite members of the public to become involved with the
stakeholder engagement process and provide information on the following:
Post decision making
Notification of decision reeached by DEA in SA and Botswana
ESIA
Advertisements in newspapers
Draft Reports in public venues & on website
Executive Summaries & translated pamphlets
Meetings held along route
I&APs notified of Final Report
Scoping
Advertisements in newspapers
Draft Reports in public venues & on website
Executive Summaries & translated pamphlets
Meetings held along route
Initial notification
Background Information Document (BID)Pamphlets in Tswana, Setswana &
AfrikaansNotices along route
BOSA Stakeholder Engagement Plan Page | 10
• Where they can obtain more information about the project;
• How to register as a stakeholder;
• How and when they can submit written comments;
• The date and location of any public open day meeting;
• The opportunity for any interested party to raise issues of concern on the day of the meeting.
The following will be undertaken in terms of advertising during Scoping and the ESIA phase:
• South Africa
o To be placed at the start of the public comment period
o One relevant local newspaper: Mafikeng Mail or Capro Media
o One provincial or national newspaper: Beeld
• Botswana
o To be placed weekly for three weeks, the first advertisement 21 days before the public meeting
date
o National newspaper: The Daily News (government owned newspaper that comes out daily and
is given freely to all communities around the country).
The EIA Act 2011 section 7 7 in Botswana states the following: An applicant shall...(a) publicise once the
intended activity, its effects and benefits in the mass media using the official languages for a period of not
less than 21 days; and (b) after the expiration of the period of 21 days, ensure that the practitioner holds
meetings with the affected people or communities to explain the nature of the activity and its effects.
Site notices were erected at conspicuous locations along the alignment corridor (based on visibility and
accessibility) and at locations such as municipalities, post offices and libraries. This will be done again at
Scoping and in the ESIA phase. The posters provide the same information as contained in the newsprint
and radio advertisements as well as a layout map of the project.
2.3.3 Invitation to comment
All stakeholders with postal addresses and email addresses were notified of the project. Where we had
postal details, registered mail was sent. Currently we do not have a lot of email addresses. As a last resort,
site visits may be necessary to get all relevant contact detail.
Any persons responding to the advertisements and expressing an interest in becoming a stakeholder for
the project have been captured on a stakeholder register as a secondary stakeholder. This will continue for
the duration of the project. Care is taken to capture names and contact details of all secondary stakeholders
accurately.
It is expected the main form of communication used to engage secondary stakeholders will be in the form
text messages over mobile telephones. Bulk text messages will be used to inform the stakeholders about
meetings and emails will be sent as another communication method. Communication about the project in
Botswana will also occur via the Kgotla (Tribal) Community meetings, which routinely take place in every
significant settlement.
To ensure that the project is communicated as widely as possible, notification should be distributed by
secondary measures in addition to direct communication with identified stakeholders. It is likely that the
largest spread will be transferred by word-of-mouth. However other measures of media can also be used,
as appropriate.
Radio advertisements on a relevant local radio station can be aired to creating awareness about a meeting
and advertise that there is a project happening and how more information can be obtained. However, it has
been identified that radio messages in Botswana will not reached the affected communities and as such
BOSA Stakeholder Engagement Plan Page | 11
arrangements will be made with tribal authorities to drive around communities to broadcast the project and
proposed meetings in the relevant settlements in both Botswana and South Africa.
The reports will be loaded on the Aurecon PPP website and this will be put on all the notification with correct
website address as well as a telephone number and fax number.
2.3.4 Language
Some of the stakeholders in more rural areas are less illiterate than those in urban areas and documents
will therefore be written in a style (i.e. a low Gunning fog index3) that is accessible to a range of literacy
levels. Full written reports will be provided in English. Summary documentation is translated into Afrikaans
and Tswana in South Africa and Setswana in Botswana. An Afrikaans and local language translator will be
available at all meetings so that information can be provided in the language of choice of stakeholders (a
key success factor during previous processes in the area). Presentations during open houses will be mainly
in English. However, stakeholders will be welcome to use the language of their choice during discussion
sessions and will be responded to in that language, with summary translations into other languages where
required.
Acknowledging that some of the interested parties may be illiterate, during the site visit the team members
shall have alternative mediums to illustrate the proposed development. These may include, pictures,
models, posters and diagrams and explain what impacts could be expected.
In the submission of the Scoping and ESIA reports, a longer non-technical summary will be provided with
detail about the project and will include maps and details of the potential impacts and proposed mitigation
measures.
2.4 Step 4: Comment periods and meetings
2.4.1 Comment periods
Following the compilation and submission of the Draft Scoping and ESIA reports to the relevant
environmental authorities, a formalised comment period will commence. Notification of availability of reports
for review will be done using the same methods identified above. Stakeholders will be given the opportunity
to express concerns and ask questions about the proposed project.
All comments, concerns and questions related to the project are recorded in a Comments and Response
Report (CRR) and responses given. Where responses might need to be further researched or
supplemented with further information, responses will be given as soon as this is available.
2.4.2 Meetings
Public meetings are organised through the relevant stakeholders. The format of the meeting will be tailored
to the needs of the stakeholders attending the meeting. Meetings may take the format of a formal meeting
via invitation, an open house meeting at a certain time, or an open day providing stakeholders to attend at
any time during an afternoon around their schedules.
3 See http://www.readabilityformulas.com/gunning-fog-readability-formula.php
BOSA Stakeholder Engagement Plan Page | 12
The following information and materials will be made available at the meeting:
The following representatives will form part of the project team at public meetings:
Stakeholders will also be further engaged during the socio-economic impact assessment. Where a
response to any comments or queries is not readily available or deals with a complex or potentially sensitive
or significant issues and demands a more considered approach to consultations, further meetings with the
affected stakeholders group may be arranged by Aurecon. The aim of these meetings would be to reach
an understanding with the affected stakeholder groups and reach consensus on a way forward.
Aurecon will notify the all parties, including the DBSA and SAPP, of any instances arising from the ESIA
where follow-up consultation may be required as part of a more strategic approach.
Some issues may also require ongoing, iterative engagement extending into the operational phase. In this
situation, Eskom / BPC must communicate through the forum in which representatives from the relevant
stakeholder groups, government and project role players meet at regular intervals (i.e. every three or four
months) to discuss progress or emerging matters associated with a particular issue.
2.4.3 Comments and Responses Report
Written comments sent via email, post or fax will be collected and analysed and categorised. Key comments
and issues captured during the public meetings will also be categorised. Aurecon will then prepare
BID handouts and /or a non-technical summary
•Scoping Report
•ESIA Report
•Environmental and Social Management Plan (ESMP)
Responses to frequently asked questions
•Number and types of jobs during the construction and operational phases
• Local employment policy
•How and when to apply
•Will access to propert be compromised
•Time frame for the project
• Labour and recruitment policy / process likely to be used during the construction and operational phases
• Information about grievance mechanism
Visual illustrations of project
•Maps
•Pictures / diagrams / illustrations of project components
Comment forms •To capture comments and queries requiring further investigation
A representative from EISA team
A technical specialist
Representative from Eskom in SA
or BPC in Botswana
Public Participation team members to assist
with translation and answering locally specific questions and with capture of
comments
BOSA Stakeholder Engagement Plan Page | 13
responses to the comments and develop a Comments and Responses Report (CRR). Where necessary
an explanation will be provided of how comments will be used to revise the ESIA and Environmental and
Social Management Programme (ESMP) or other policies and procedures.
All registered stakeholders will be notified of the availability of the CRR and where they may obtain a copy
or view the report. The CRR shall be made available via the following means:
• A hard copy at predetermined venues such as the libraries in local towns; and
• A digital copy on Aurecon’s Public Participation page on the internet site.
The draft EIR will be updated by including comments obtained from the proponent and will then be sent to
the authorities and other I&APs for external review. The comments received from the authorities and other
I&APs will be analysed and incorporated into a final EIR document.
The Final EIR and Specialist Study Reports will be distributed, once amended, to the authorities. The Final
Issues and Response report will be distributed to land owners and key stakeholders.
2.4.4 Review Project Documentation
Based on the CRR, a review of the Draft Scoping Report and the Draft ESIA and ESMP must be undertaken
to reflect any new issues and how these issues are to be managed, monitored and reported on. Where and
if required, stakeholder reporting mechanisms should be established in the ESIA and ESMP to inform key
stakeholder groups of progress and performance in relation to particular issues of concern through the
construction phase.
The ESIA must also refer to the Grievance mechanism described under Section 3 and ensure that the
Contractor makes the necessary provisions for the management of grievances.
2.5 Step 6: Milestone notifications
All registered stakeholders will be kept informed of project progress and key milestones using email, post
and bulk sms during the stakeholder engagement process and up until facility commissioning. Table 2 is a
provisional list of the progress or milestones that should be released but may be modified to suit project
needs.
Table 2 | Provisional list of the progress or milestones
No. Timing Message
Part of the ESIA
1 21 Days before the Public
meetings (requirement in
Botswana)
BOSA transmission line – Public meeting to be held on [insert dates
and venue]. Documentation can be downloaded from [insert web
address] or viewed at [insert location]. Please make sure you attend
meeting4.
2 Day before public
documents released for
public review (requirement
in SA)
BOSA transmission line - Public comment period on [insert
document name] open for the following period [insert dates]. Report
can be downloaded from [insert web address] or viewed at [insert
location]. Please make sure you review and comment.
3 Day before open day
meeting
BOSA transmission line - Public open day tomorrow 14h00 to
19h00.
4 Advertisements will also be placed in newspaper at timing required by national legislation to provide notification of public meetings, availability of documentation and the of the decision made by the relevant authorities, as per country specific requirements
BOSA Stakeholder Engagement Plan Page | 14
4 Day before the closing of
the comment period
BOSA transmission line - Public comment period ends tomorrow,
please make sure you have submitted your comments.
5 Day before the release of
the CRR
BOSA transmission line - Comments and responses report to be
released tomorrow. Report can be downloaded from [insert web
address] or viewed at [insert location].
6 Following DEA decision
(both in South Africa in and
Botswana)
BOSA transmission line – Notification of decision by DEA. Copy can
be downloaded from [insert web address] or requested from [insert
contact details].
Following the ESIA process
7 Construction contract
awarded
BOSA transmission line - Building contract has been awarded to
[insert contractor name]. This is for information only, please do not
respond.
8 Recruitment process (This
needs to be discussed with
Contractor and modified to
needs)
BOSA transmission line - Construction phase job recruitment starts
tomorrow, [number] positions are available. Apply in person at
[location]. This is for information only, please do not respond.
9 Day before Contractor
mobilisation
BOSA transmission line - Construction starts tomorrow. This is for
information only, please do not respond.
10 Operational phase
recruitment (if required)
BOSA transmission line - Operational phase job recruitment starts
tomorrow. [nature and number of the job opportunities, i.e. (?)
cleaners, (?) security, (?) maintenance, etc.] Apply in person at
[location]. This is for information only, please do not respond.
10 Week before official
opening
BOSA transmission line - Official opening on [date]. This is for
information only, please do not respond.
2.6 Review ESIA and ESMP Based on the CRR, a review of the ESIA and ESMP must be undertaken to reflect any new issues and how
these issues are to be managed, monitored and reported on. Where and if required, stakeholder reporting
mechanisms should be established in the ESIA and ESMP to inform key stakeholder groups of progress
and performance in relation to particular issues of concern through the construction phase.
The ESIA must also refer to the Grievance mechanism described under Section 3 and ensure that the
Contractor makes the necessary provisions for the management of grievances.
3 Grievance Mechanism
The IFC Performance Standard 1 and Equator Principle No 6 (The Equator Principles Association, 2013)
state that where there are Affected Communities, the developer shall establish a Grievance Mechanism
(GM) to receive and facilitate the resolution of concerns and grievances relating to the project’s
environmental and social performance. The GM should be scaled to the potential risks and adverse impacts
of the project and have Affected Communities as its primary user. It should seek to resolve concerns
promptly, using an understandable and transparent consultative process that is culturally appropriate and
readily accessible, and at no cost and without retribution to the party that originated the issue or concern.
The GM should not impede access to judicial or administrative remedies. The developer shall inform the
Affected Communities about the mechanism during the stakeholder engagement process.
BOSA Stakeholder Engagement Plan Page | 15
The objective of a GM is to receive and facilitate resolution of the concerns and grievances about the
project’s environmental and social performance. The usefulness of a GM is dependent on how swiftly issues
can be resolved. Therefore, stakeholders must be informed of the existence of the GM at the early stages
and the procedures for lodging, discussing and resolving project related complaints. A GM must be adapted
to local social and cultural norms and must be readily accessible to all segments of the affected
communities.
3.1 During the construction phase While Aurecon will only be involved in the stakeholder engagement for the ESIA phase, this SEP covers
the life cycle of the project and this stakeholder engagement requirements for the constriction phase must
be implemented by the project proponent and the Contractor.
The Contractor shall erect a project signboard where they are working and maintain it throughout the
construction period. The sign shall contain the relevant emergency telephone numbers and email address
where specific site project staff can be reached and where grievances may be lodged. A telephone number
and email address for the developer should also appear on the signboard where grievances may be lodged.
The Contractor shall be required the keep and maintain a grievance register at the site offices. Any persons
wanting to lodge a grievance shall be provided the opportunity to do so in the register and where necessary
assisted in capturing the grievance in writing. Contractor shall appoint an Environmental Liaison Officer
(ELO) who will be the contact person for grievances from the public.
Where grievances are received telephonically, the ELO shall record these in the register. Care must be
taken to ensure that the name and contact details, and preferred means of contact, be captured whenever
a grievance is lodged. The Contractor/ELO shall report all new grievances to the developer immediately
and at least within 24 hours of the grievance. On receiving a grievance, the Contractor shall immediately
investigate and take photographs (where relevant) of any scene or situation or relevant evidence that
resulted in the grievance.
Grievances may be lodged by telephone or by e-mail or letter. The date, time, person(s) involved and the
nature of the grievance or complaint will be logged and assigned to the appropriate client team member for
investigation. The findings of the investigation are to be captured. The grievance investigations will be
reviewed at monthly Contractors meetings and will remain active until it has been resolved and official
response provided to the aggrieved. The official response should provide the aggrieved with a summary of
the investigation findings and what measures or corrective actions will be implemented to resolve the
matter. The Environmental Control Officer (ECO) must record how the ELO has dealt with grievances from
the public in the Monthly Environmental Audits.
Where required, the ESIA and ESMP should be amended to include any new management measure
emerging from such an investigation.
3.2 During the operational phase While Aurecon will only be involved in the stakeholder engagement for the ESIA phase, this SEP covers
the life cycle of the project and this stakeholder engagement requirements for the constriction phase must
be implemented by the project proponent and the Contractor.
The developer shall erect noticeboards at conspicuous locations around the servitude (typically at road
crossings) or in public places in settlement areas along the route, providing the contact details (telephone
and email) where grievances may be lodged. A grievance form shall be compiled and kept at all local office
branches. Should a member of the public have a grievance, the staff should direct them to one of the
grievance form location and telephone the manager on duty. Any new grievances forms shall be reported
to management the same working day.
The grievance mechanism shall form part of the operational staff’s induction training. All staff must know
where the grievance forms are kept and trained to assist the public in filing a grievance. Where management
BOSA Stakeholder Engagement Plan Page | 16
intervention or presence is required at the scene of an incident, staff should be able to contact the relevant
manager (at any time of day or night). Where an incident has occurred, the manager shall photograph any
scene, evidence, damage etc. related to the grievance for later use in the investigation.
On receiving a grievance, management shall appoint an investigator to undertake an investigation of the
grievance, and if necessary confer with the complainant to confirm the nature of the grievance and the
parties involved. Where there may be criminal liability, management shall cordon off the incident area
(scene) and consult with the police to determine if a criminal case should be investigated.
A record shall be kept of all grievances, the findings of any investigations, photographic evidence, any
responses provided to the aggrieved, and measures taken to correct the issue and prevent a reoccurrence.
These records should be reflected on during the management system review process and where necessary
used to amend the management system aspects register, policies and procedures to address these risks
in future. The process is used to demonstrate the continual improvement concept underpinning most
management systems.
Eskom and/or BPC must submit an annual self-assessment to DEA, which will include records of all
grievances received in that year with a description of how they were managed.
3.3 Roles and Responsibilities The implementation of the SEP is the responsibility of Aurecon for the period of the ESIA (and does
therefore not include the construction or operational phases) and further than that it must be implemented
by Eskom or BPC, depending on which country the length of line is located in.
Aurecon will designate a person for the implementation of the SEP during the ESIA and the responsible
person’s name and contact information will be provided after this person has been identified and assigned.
The utilities must submit self-assessments annually to the DEA which will include records of all grievances
received in that year and how they were dealt with.
4 Conclusion
Stakeholder engagement is an ongoing and iterative process and should continue throughout the project
lifecycle. It aims to ensure that a business venture remains in touch with the community it serves and their
needs and issues. It also ensures that potential impacts continue to be identified and managed in a
responsible fashion, thus lowering overall business risk and improving resilience.
To ensure this continues throughout the lifecycle of the development, it is important that the process be
recorded appropriately and monitored. All meetings should have signed registers and all issues raised
should be recorded in either the CRR or GM. Feedback should also be given to those that continue to have
interest in the project.
BOSA Stakeholder Engagement Plan Page | 17
5 Bibliography
IFC. (2007, May). Stakeholder Engagement: A Good Practice Handbook for Companies Doing
Business in Emerging Markets. Retrieved 07 01, 2015, from www.ifc.org/enviro:
http://www.ifc.org/wps/wcm/connect/938f1a0048855805beacfe6a6515bb18/IFC_Stakeholder
Engagement.pdf?MOD=AJPERES
IFC. (2010). Guide to Human Rights Impact Assessment and Management. Retrieved 07 22, 2015,
from www.ifc.org/hriam:
http://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/Guid
e+to+Human+Rights+Impact+Assessment+and+Management/
IFC. (2012, January 1). Performance Standards on Environmental and Social Sustainability.
Retrieved 06 07, 2015, from www.ifc.org:
http://www.ifc.org/wps/wcm/connect/115482804a0255db96fbffd1a5d13d27/PS_English_201
2_Full-Document.pdf?MOD=AJPERES
The Equator Principles Association. (2013, June). The Equator Principles. Retrieved from Equator
Principles: http://www.equator-principles.com/resources/equator_principles_III.pdf
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