Masdar Infinity Power Holding 200MW Wind Power Project in Gulf of Suez
Masdar Infinity Power Holding 200MW Wind Power Project in Gulf of Suez
JULY 2023
FINAL
TABLE OF CONTENTS
LIST OF TABLES
Table 1: Summary of Turbine Specifications................................................................................................. 6
Table 2: Identified Groups of Stakeholders ................................................................................................ 15
Table 3: Preliminary Stakeholder Analysis and Priority Contact List for the Project .................................... 19
Table 4: Summary of Consultations Undertaken during ESIA Process ......................................................... 21
Table 5: Stakeholder Engagement Strategy and Plan in Relation to the Project .......................................... 26
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1. INTRODUCTION
The Government of Egypt (GoE) issued the Renewable Energy Law to support the creation of a favorable
economic environment for a significant increase in renewable energy investment in the country. In accordance
with the Law, the Egyptian Electricity Transmission Company (EETC) invites private investors to submit their
offers for solar and wind development projects, for specific capacities and the award will be made to that bidder
with the lowest price. In addition, the GoE (through the New and Renewable Energy Authority (NREA)) provides
the land for the investors.
In accordance with the above, Infinity Power Holding (IPH) was selected for the development of a 200-Megawatt
(MW) Wind Power facility in Ras Ghareb District of the Red Sea Governorate (hereafter referred to as ‘the
Project’).
This document constitutes a Stakeholder Engagement Plan (SEP) to be implemented by the Developer
throughout the planning, construction, and operation phase for the Project. The SEP outlines a systematic
approach to stakeholder engagement that will help the Developer build and maintain over time a constructive
relationship with their stakeholders, particularly the locally affected communities. The SEP is a live document
which will be updated throughout the Project construction, operation, and implementation.
The Project welcomes suggestions for improvement of this SEP. Suggestions can be submitted via the contact
information for the Developer at the end of this document (Chapter ‘5’).
▪ Chapter 2 – Project Description: provides a summary of the Project location, main Project components,
Project schedule and job opportunities for the construction and operation phase. Finally, the Chapter also
provided an overview of E&S risks and opportunities.
▪ Chapter 3 – Regulatory Context: highlights the main requirements that are relevant for stakeholder
engagement to the Project to include Egyptian regulations and international best practice requirements.
▪ Chapter 4 – Identification of Stakeholders: identifies all relevant stakeholders for the construction and
operation phase of the Project at all geographic levels to include national, regional, and local levels as well
as communities within the area of influence of the Project.
▪ Chapter 5 – Summary of Past Stakeholder Engagement Activities: provides a summary of past stakeholder
engagement activities undertaken for the Project during the planning and design phase of the Project.
▪ Chapter 6 – Stakeholder Engagement Strategy and Plan: identifies an engagement strategy for each
stakeholder group to include objective for engagement, communication methods and tools, timeframe, and
responsibilities. Chapter also provides contact details of the Developer for communication with all relevant
stakeholders of the Project.
▪ Chapter 7 – Grievance Mechanism: identifies a mechanism for managing and handling any concerns or
complaints related to the Project during the construction and operation phase. This includes a mechanism
for stakeholder and communities and another for workers.
▪ Chapter 8 – Monitoring and Reporting: identifies the key monitoring and reporting requirements that are
applicable for the implementation of the plan.
▪ Chapter 9 – Roles and Responsibilities: identifies the roles and responsibilities for the Developer and other
involved entities in implementation of the plan.
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1.1 Project Location
The Project site is located within the Red Sea Governorate, approximately 250km southeast of the capital city
of Cairo (Figure 1). More specifically, the Project site is located within the Ras Ghareb City (or District) and
therefore administratively is under the Ras Ghareb City Council.
The closest community settlement to the Project site is Ras Ghareb town (located 18km to the east) – refer to
Figure 2 below. The Project has a total area of 37.5km2 area that has been allocated to the Developer by NREA
for the development of this Project. In addition, within the area there are key Bedouin groups that settle
permanently in areas such as Ras Ghareb and Wadi Dara and other groups that are nomadic and many settle
within the mountain ranges to the west of the Project area as seen in Figure 3 below.
In addition, it is important to note that the Project area is part of a 300km2 Strategic Area that was initially
owned by the Government of Egypt (GoE) and has been allocated to NREA for the purpose of wind farm
development projects with a total capacity of 1,500MW. NREA in turn allocates the land to private developers
under land use usufruct agreements. Refer to below for the location of the Strategic Area location in relation to
the Project site.
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Figure 3: Project Site as Part of the 300km2 Area Allocated for Wind Farm Developments
Wind turbine technology relies on harvesting the kinetic energy in wind (i.e., movement of wind) and turning it
into mechanical energy which in turn is used for electricity generation. The key components of the Project
include the following:
▪ Wind Turbines: a typical wind turbine is presented in Figure 4 below. The specifications of the wind turbine
are provided in the table below.
Table 1: Summary of Turbine Specifications
Parameter Goldwind Envision
Model GWH182 7.2MW EN182 7.8MW
Rated Capacity 7200kW 7800kW
Hub Height 110m 110m
Rotor diameter 182m 182m
Maximum tip Speed 89m/s 89m/s
Number of WTGS 28 26
▪ Supporting infrastructure and utility elements for the Project which will include:
- Substation that converts the output from the turbines to a voltage that is appropriate for connection
with National Grid
- Onsite building infrastructure that will include an administrative building (offices) and a warehouse for
storage of equipment and machinery
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- Road network for ease of access of various project components throughout the site
▪ Associated facilities which will mainly include an Overhead Transmission Line (OHTL) that will connect from
the substation onsite to the National Grid.
Figure 4: (a) Typical Structural Components of a Wind Turbine, (b) Typical Components of a Wind Farm (Source: EHS
Guidelines for Wind Energy, IFC)
The Project will result in crucial positive environmental and economic impacts on the strategic and national level
given the current challenges the energy sector in Egypt is facing. Such positive impacts underpin rationale for
the Project. These include the following:
▪ The Project allows for more sustainable development and shows the commitment of the Government of
Egypt to realizing its Energy Strategy and meeting the set targets for renewable energy sources.
▪ The Project will contribute to increasing energy security through reliance on an indigenous, inexhaustible,
and mostly import-independent energy resource. The Project is expected to provide around 800-Gigawatt
Hour (GWh) of electricity per year, which is enough to power more than 300,000 households in Egypt.
▪ Generating electricity through wind power is relatively pollution-free during operation. Compared with the
conventional way of producing electricity in Egypt, the clean energy produced is expected to reduce
consumption of fossil fuels for electricity generation and will thus help in reducing greenhouse gas emissions
as well as air pollutant emissions. The Project will likely displace more than 400,000 metric tons of CO2
annually.
▪ Planning and Construction Phase: that will include: (i) preparation of the detailed design, (ii) transportation
of components to the site, (iii) site preparation activities (land clearing, excavations, etc.), and (iv)
installation of components.
▪ Operations Phase: that will include the normal daily operation of the wind farm and the undertaking of
maintenance activities as required.
▪ Decommissioning Phase (to be determined): that will include the dismantling of the various Project
components at the end of the lifetime.
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1.4 Overview of Potential E&S Risks and Opportunities
The table below provides an overview of the potential E&S risks and opportunities that are expected throughout
the key project phases.
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Potential Risks and Opportunities during the Construction Phase
Attribute /
Likely Impact – Planning and Construction Phase
Issue
Landscape Visual and landscape impacts due to presence of elements typical of a construction site such as equipment and machinery.
and Visual
Land Use Project could conflict the formal assigned land sues set by the various governmental entities.
Geology, Potential for flood risks on the Project area.
Hydrology,
and Risk of soil and groundwater contamination during the various construction activities from improper housekeeping activities, spillage of hazardous material, random discharge of
hydrogeology waste and wastewater.
Biodiversity Improper management of construction activities could disturb/damage habitats and fauna within the Project site.
Archaeology Improper management of construction activities could disturb/damage archaeological remains which could be buried in the ground (if any).
Air Quality Construction activities will likely result in an increased level of dust, particulate matter, and pollutant emissions
and Noise
Possible noise emissions to the environment from the construction activities which will likely include the use of machinery and equipment
Infrastructure Road Networks – if transportation activities of the various project components to the site are not properly managed beforehand, they could entail risk of damage to the existing
and Utilities roads and could be of public safety concerns to other users on the road. In addition, if planning activities are not well managed it could damage/disturb existing onsite road
networks.
Water Resources – water requirements of the Project could entail constraints on the existing resources and users.
Waste Utilities – it is important to ensure that existing utilities would be able to handle the amount of waste, wastewater and hazardous generated from the Project during the
construction phase.
Aviation, Telecommunication, and TV & Radio Links – Improper planning and site selection of the Project could impact aircraft safety and/or could potentially interfere with
certain electromagnetic transmissions associated with air transport, telecommunications, and radio/television systems in the area.
Occupational There will be some generic risks to workers health and safety from working on construction sites, as it increases the risk of injury or death due to accidents.
Health and
Safety
Public Health Public access of unauthorized personnel to the various Project components (turbines, substation) could result in various public safety hazards.
and Safety
Worker influx could result in certain community health, safety, and security impacts, including competition over basic social services (water, housing, health care facilities, waste
collection and disposal, etc.), risk of diseases, inappropriate conduct by workers towards locals, an increase in social vices1, etc.
Inappropriate conduct of security personnel towards local communities could result in resentment, distrust and escalation of events
1 Social vices are deviant behaviors such as illicit sex, drug addiction, immoral behavior, and criminal tendencies.
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Road Networks – The main junction that leads to Ras Gharib (which is located just outside of the city) also leads to the Project site and this junction in specific is expected to have
an increased level of traffic. If transportation activities of the various project components to the site are not properly managed beforehand, they could entail risk of public health
and safety concerns to other users on the road (e.g. exceeding speed limits, in adherence to driving rules, etc.).
Socio- The Project is expected at a minimum to provide job opportunities for local communities as well as procurement opportunities for local businesses. This, to some extent, could
economic contribute to enhancing the living environment for its inhabitants, elevate their standards of living, and bring social and economic prosperity to local communities. Around 250 job
Development opportunities are expected at peak during the construction phase. This will mainly include skilled job opportunities (engineers, technicians, consultants, surveyors, etc.) and
unskilled job opportunities (mainly laborers but will also include a few security personnel).
Landscape and Visual Visual impacts concern the turbines themselves (e.g., color, height, and number of turbines) relating to their interaction with the character of the surrounding landscape.
Geology, Hydrology Risk of soil and groundwater contamination during the various operational activities from improper housekeeping activities, spillage of hazardous material, random
and Hydrogeology discharge of waste and wastewater.
Avifauna (Birds) Wind turbines are associated with impacts on birds from risks of strikes and collision on both migratory and resident soaring birds. Such impacts depend on several
factors but could affect the population levels of certain species especially those with international/national critical conservation status.
Bats The potential impacts from the Project during operation are mainly related to risk of bat strikes and collisions with rotors of the operating wind turbines.
Infrastructure and Water Resources – water requirements of the Project could entail constraints on the existing resources and users.
Utilities
Waste Utilities – it is important to ensure that existing utilities would be able to handle the amount of waste, wastewater and hazardous generated from the Project
during the construction phase.
Occupational Health There will be some risks to workers health and safety during the operation and maintenance activities of the Project.
and Safety
Public Health and Operating wind turbines will produce noise from mechanical and aerodynamic effects. This could be a source of disturbance and nuisance to the receptors and could
Safety create a disturbing indoor environment.
Operating wind turbines will produce shadow flicker which could be a source of disturbance and nuisance to the receptors and could create a disturbing indoor
environment.
Public access of unauthorized personnel to the various Project components (turbines, substation) could result in various public safety hazards.
Inappropriate conduct of security personnel towards local communities could result in resentment, distrust and escalation of events
Blade or tower glint can impact sensitive receptors as the reflection of sunlight off the rotor blade may be angled toward nearby receptors.
Failure in rotor blade can result in the ‘throwing’ of the blade. Although overall risk of such events is extremely low, it could affect the public safety of nearby receptors.
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Socio-economic The Project is expected at a minimum to provide job opportunities for local communities as well as procurement opportunities for local businesses. This, to some extent,
Development could contribute to enhancing the living environment for its inhabitants, elevate their standards of living, and bring social and economic prosperity to local communities.
Around 25 job opportunities are expected during the operation phase for a duration of 20 years. This will include skilled job opportunities (such as engineers, technicians,
administrative employees, etc.) and unskilled job opportunities (such as security personnel, drivers, etc.).
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2. REGULATORY CONTEXT
2.1 Egyptian Legislation Requirements
Stakeholder consultation and engagement under the Egyptian requirements, is primarily linked to the
Environmental and Social Impact Assessment (ESIA) study as stipulated in the “Law of Environment No. 4 of
1994 and its amendments in Law No. 9 of 2009”. According to the last updated executive regulation and the
ministerial decree No. 26 of 2016, the ESIA system classifies the projects into four categories based on different
levels of ESIA requirements according to severity of possible impacts and location of the establishment and its
proximity to residential settlements.
In specific, wind farm development projects in general are categorized as “Category C’’ (projects which require
a comprehensive ESIA study) and which require consultations under two (2) phases as part of the ESIA study: (i)
environmental and social scoping phase which requires targeted consultations; and (ii) disclosure phase which
requires a public disclosure session for ESIA outcomes.
The scoping should include targeted stakeholder consultations with key stakeholders as relevant to the Project,
while the public disclosure consultation must include the following entities:
▪ Representatives of the Governorate and local units where the project is located
The EEAA guidelines methodology identifies the following articles covering the guidelines on conducting the
public consultation as part of the ESIA study are as follows:
The Developer will be seeking financing for the Project from International Financial Institutions (IFIs). Therefore,
the Developer wishes to design and manage the Project in accordance with good international industry practice
and standards. This SEP meets international best practice requirements to include the relevant E&S
requirements of IFIs.
The IFC Policy on Environmental and Social Sustainability, including the IFC Performance Standards (PS) have
become the de facto international environmental and social performance benchmark for project financing. The
IFC Policy on E&S Sustainability, the IFC Performance Standards, along with the IFC Access to Information Policy
constitute the overall IFC Sustainability Framework, where “IFC Performance Standard 1 on Assessment and
Management of Environmental and Social Risks and Impacts” (IFC, 2012) sets out the following
recommendations for stakeholder engagement:
▪ Stakeholder Engagement is an on-going process that may involve, in varying degrees, the following
elements: stakeholder analysis & planning, disclosure & dissemination of information, consultation &
participation, grievance mechanism, and on-going reporting to Affected Communities.
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▪ Project stakeholders are those persons or groups who:
o are directly and/or indirectly affected by the project (or the company’s operations)
o have “interests” in the project or parent company that determine them as stakeholders
o have the potential to influence project outcomes or company operations
▪ A Stakeholder Engagement Plan (SEP) that is scaled to the project risks and impacts and is developed and
tailored to the characteristics and interests of the Affected Communities and will be implemented
accordingly.
▪ 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. ‘Effective’ or ‘meaningful consultation' is further explained in Para 30 of PS1.
▪ 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.
▪ For projects with potentially significant adverse impacts, the client will conduct an Informed Consultation
and Participation (ICP) process that will result in the Affected Communities’ informed participation.
▪ 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.
Additionally, IFC provides ample guidance on the whole process in its good practice handbook on stakeholder
engagement (2007).
European Bank for Reconstruction and Development (EBRD) Performance Requirements (PR)
The SEP will also follow the requirements of the EBRD in relation to the stakeholder engagement process and
activities. EBRD “PR10: Information Disclosure and Stakeholder Engagement” sets out the following
requirements of stakeholder engagement during project preparation:
▪ A Stakeholder Engagement Plan (SEP) must be developed and implemented for projects that are likely to
have adverse environmental or social impacts and issues, tailored to consider the main characteristics and
interests of the affected parties and other interested parties.
▪ The first step in successful stakeholder engagement is for the client to identify the various individuals or
groups who (i) are affected or likely to be affected (directly or indirectly) by the project (“affected parties”),
or (ii) may have an interest in the project (“other interested parties”). Resources for public information and
consultation should focus on affected parties, in the first instance.
▪ As part of the stakeholder identification process, the client will identify individuals and groups that may be
differentially or disproportionately affected by the project because of their disadvantaged or vulnerable
status. The client will also identify how stakeholders may be affected and the extent of the potential (actual
or perceived) impacts. Where impacts are perceived, additional communication may be required to provide
information and reassurance of the assessed level of impacts. An adequate level of detail must be included
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in the stakeholder identification and analysis to enable the Bank to determine the level of communication
that is appropriate for the project under consideration. Employees are always considered stakeholders.2
▪ The Client will inform the EBRD how communication with the identified stakeholders will be handled
throughout project preparation and implementation, including the type of grievance procedure envisaged.
2Good international practice among IFIs dictates that the entire workforce on a project - particularly during the construction phase, for
example all workers employed by the EPC contractor and it subcontractors - is considered a key stakeholder group.
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3. IDENTIFICATION OF STAKEHOLDERS
This chapter includes the identification of stakeholders that are relevant to the Project and provides a
stakeholder mapping as well.
In order to design an engagement process with stakeholders, several stakeholder groups that may be interested
and/or affected by the development and implementation of this Project have been identified. There are various
social groups that have an interest in the Project on different levels. These may be described as:
1. People and groups who will be directly or indirectly affected by the project (such as local communities).
2. People and groups who may participate in the implementation of the project (such as investors and lenders).
3. People and groups who are not affected by the project development per se may but have a possibility to
influence and make decisions on implementation of the Project (such as Ministries or regulatory agencies).
The main categories of stakeholders identified so far are listed in the table below. This document is a living
document and will need to be updated and modified during Project development and as a result of its
implementation with the various identified stakeholders throughout as identified below.
Vulnerable Groups
The stakeholder list also includes vulnerable groups and is defined as groups that are expected to be
disproportionally affected by project impacts due to their race, color, sex, language, religion, political opinion,
national or social origin, gender, ethnicity, culture, physical or mental disability, and other. Vulnerable groups
are context-specific and depend on a range of issues which must be understood such as project location, socio-
economic, historical, and demographic context, as well as the nature of the development and type of impacts
anticipated.
▪ Women groups of the local community. Cultural norms in Egypt and within the local communities, in
specific, could limit their participation in decision-making in general as well as their employment
opportunities as opposed to their male counterparts. Even though such cultural norms are considered
applicable within local communities, however Bedouin women in particular are considered much more
vulnerable than mainstream women in Upper Egypt.
▪ Disabled Groups: are considered vulnerable groups mainly due to physical disability which could limit their
access to information on the Project and could limit their participation in decision-making in general as well
as their employment opportunities as opposed to able-bodied groups.
▪ Elderly Groups: are considered vulnerable groups mainly due to age limitations which could limit their
access to information on the Project and could limit their participation in decision-making in general.
Given the nature and location of the Project there are no additional groups considered as vulnerable that would
require special consideration throughout the consultation process.
Table 2: Identified Groups of Stakeholders
Level of Stakeholder interest in/involvement to the Project
1. Stakeholders who may be directly or indirectly affected by the Project
Residents of the nearby villages of the Project to include Ras Gharib Town which are administratively under Red Sea
Governorate and Ras Ghareb City (or District). For the above, this includes the following groups within the local
communities in specific:
▪ Community Members: local community members have a vested interest in the project due to mainly potential
for job opportunities. In addition, local community members could be impacted by other potential negative
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impacts (e.g., worker influx, noise & shadow flicker, etc.). Such impacts are discussed and identified within the
ESIA.
▪ Community Leaders: They are socially active members and known figureheads for local community members,
who may or may not hold government positions. Community leaders involved in the project are the heads of
affected communities
▪ Business Community (local subcontractors): such groups have a vested interest in the project due to mainly
potential for procurement opportunities such as subcontracting works (e.g., civil works, provision of food and
amenities, etc.)
Women groups within local communities, such groups have a vested interest in the project due to mainly potential
for job opportunities. In addition, such groups could be impacted by other potential negative impacts (e.g., worker
influx, Gender Based Violence and Harassment (GBVH), etc.) Such impacts are discussed and identified within the
ESIA
Bedouin Groups: the key Bedouin group known in the area are the Tabbna, Hamadin and Khoshman. Tabbna and
Hamadin settle permanently in key cities such as Ras Ghareb, Zaafarana. The Khoshman are nomadic groups that
settle within the mountain ranges located west of the area in general. All these Bedouin groups apply a type of
customary ownership within the Project area lands which is known as ‘Urfi Contracts’ and ‘Ghafra System’. Such
tribes would be helpful in providing security and protection and could also have a vested interest in employment
and procurement opportunities (such as security guards, provision of raw materials, provision of food supplies and
water to the workers, etc.).
2. Stakeholders who may Participate in Implementation of the Project
Investor/Lender: entities that will provide financing for the Project development. In particular, they have interest in
ensuring that the Project is developed and implemented in accordance with their E&S requirements and standards
and will monitor the compliance of the Project against such requirements.
Workers: This includes all Project workforce to include but not limited to workers from Developer team, workers from
EPC Contractor, Project Operator, and any involved subcontractor(s).
3. Stakeholders who may have a possibility to influence and make decisions on implementation of the
project and/or may have an interest in the Project
Central Government
The Egyptian Environmental Affairs Agency (EEAA): state body regulating environmental management. For this
Project, this will include review and approval of ESIA, issuance of environmental permit, monitoring implementation
of Environmental and Social Management Plan (ESMP) and compliance with other conditions, as applicable.
Egyptian Electricity Transmission Company (EETC): off-taker and entity that signed the Power Purchase Agreement
(PPA) with Developer. They will also be responsible for designing, building, and operating the associated
interconnection facilities (i.e., Overhead Transmission Line).
New & Renewable Energy Authority (NREA): national focal point for expanding efforts to develop renewable energy
technologies to Egypt in coordination with other concerned national institutions. In addition, NREA also the entity
responsible for allocation of the land for the development of the Project.
Ministry of Labor: official governmental entity responsible for setting labor policies and legislations as well as
ensuring protection of labor rights and working conditions. Has a vested interest in ensuring that labor rights and
proper working condition are maintained for the Project in accordance with Egyptian laws and regulations.
Ministry of Civil Aviation: Official governmental entity responsible for civil aviation management in Egypt and
responsible for issuing permits for projects with specific height requirements.
Armed Forces Operations Authority: Official governmental entity responsible for military aviation management in
Egypt and responsible for issuing permits for projects with specific height requirements.
Ministry of Tourism and Archeology The ministry is the entity responsible for the preservation and protection of the
heritage and ancient history of Egypt, under which operates all inspector offices in the governorates.
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Ministry of Interior: The Ministry is responsible for national and local security, as well as approving emergency
response and firefighting plans for establishments/projects.
General Petroleum Company: a national State-owned company engaged in exploration, production, and
development of hydrocarbons, is responsible for the management of oil and gas exploration and production
activities on behalf of the State. It is one of the subsidiary companies affiliated to the Ministry of Petroleum. It has
the right of concession for petroleum exploration in some parts of the Project area and adjacent areas and represents
the main investment activity in the Project area.
National Telecom Regulatory Authority: Responsible for overall regulation and administration of the
telecommunication sector in Egypt including interface with telecommunication companies and their infrastructure
elements such as broadcasting towers. Given that project could impact such infrastructure elements, approvals are
required.
Telecommunication Operators: Could own and operate telecommunication infrastructure within the area. This
includes mainly Orange, Etisalat, and Vodafone. Given that project could impact such infrastructure elements,
approvals are required.
Radio and Television Union: Responsible for overall regulation and administration of the radio and television sector
in Egypt including infrastructure elements. Given that project could impact such infrastructure elements, approvals
are required.
Red Sea Governorate: Governorate’s main role is supporting the Project in all aspects as required to include providing
required permissions. They key departments of the Governorate that are related to the Project include the following:
- Environmental Administration that is responsible for monitoring compliance to environmental requirements
along with EEAA.
- Labor Office that is responsible for overall management of the labor force in Red Sea Governorate, monitoring
recruitment by development projects within the Governorate, monitor labor grievances and other.
- Roads Directorate: responsible for services and development of external roads in the governorate and issuing
permits for any construction work on the external roads.
- Public Health Directorate: provide the health services and facilities to the local districts and ensure overall local
community health and safety.
Ras Gharib Local City Council: main role is supporting the Project in all aspects as required to include providing
required permissions. In addition, the Council is also responsible for supervision and follow-up for monitoring
compliance to environmental requirements along with EEAA and Red Sea Governorate, and has overall responsibility
for solid waste management and disposal within their area of influence.
Directorate of Social Solidarity Ras Gharib: official governmental entity that acts as the overall management,
organization and registration of local community associations, foundations, and NGOs. They could have a vested
interest in obtaining updates on employment and procurement opportunities provided by the Developer as well as
any social responsibility programs.
Red Sea Water and Wastewater Company: official entity that is responsible for water and wastewater management
within the Governorate. In addition, it will be the entity that will be responsible for providing the Project’s
requirements of water as well as disposal of wastewater.
Red Sea Governorate Antiquities Inspector Offices: Official governmental entity representing the Ministry of
Antiquities within the Red Sea Governorate. They will be responsible for protection and management of archaeology
and cultural heritage resources in the area as well as implementation of chance find procedures by development
projects.
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NGOS are Organizations with direct interest in the Project, and which may have useful data or insight into local issues
of relevance to the Project. These organizations can also influence the views of others regarding the Project, both
nationally and international and in general NGOs are responsible for sharing information with the community. The
key NGOs active within the area are summarized below.
NGOs/ CBOs Scope
Association for the Conservation of the Environment in Red Sea (HEPCA) Environmental protection
Nature Conservation Egypt (NCE): this is considered one of the most important and key NGOs in Egypt that is involved
in biodiversity protection and conservation. NCE is also the Egyptian partner of the Bird Life International. They have
a vested interest in the impacts of the Project on biodiversity in general and avifauna in particular and they key
mitigation and monitoring programs that will be implemented.
Education providers (in particular technical / vocational training institutes): Provides knowledge and skills required
for various occupations, including renewables and solar power in specific that is delivered through formal, non-
formal and informal learning processes. The education curriculum in undergraduate, postgraduate, or Technical and
Vocational Education and Training (TVET) could be reviewed and revised to match the market and workforce
requirements.
Media (Newspaper, Television, Internet): They could disclose potential information and updates about the Project.
Regional Center for Renewable Energy and Energy Efficiency (RCREEE): responsible for managing certain aspects of
the overall development process on behalf of the Developer. This includes in specific the overall management of the
ESIA process with the Consultant. In addition, during the operation phase, RCREEE will be responsible in particular
for the implementation of the Active Turbine Management Plan (ATMP).
Further to the above, a preliminary stakeholder analysis is undertaken below to clarify stakeholders’ interest in
the Project and their ability to influence the Project’s development. Accordingly, a priority contact list is
identified.
High rating for priority contact list indicates importance of continuous and regular consultation and
engagement. On the other hand, medium rating for priority contact list does not reduce the importance of the
entity as a stakeholder but indicates that their engagement is required at specific stages or milestones of the
Project (i.e., when the involvement of these entities is triggered for a specific purpose such as obtaining a
specific service).
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Table 3: Preliminary Stakeholder Analysis and Priority Contact List for the Project
# Stakeholder Group Priority
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4. SUMMARY OF PAST STAKEHOLDER ENGAGEMENT ACTIVITIES
The table below provides a summary of all stakeholders that were previously consulted and engaged throughout
the Project – mainly as part of the ESIA that is currently being undertaken for the Project. The table provides a
summary of the stakeholder groups that were engaged and the main objective and outcome.
▪ Identify and determine additional requirements or key issues of concern to be taken into account for the
ESIA study
Throughout the consultations a handout was prepared and distributed to such stakeholder groups with key
information to include but not limited to rationale for project, project location and setting, key components,
and activities of the Project and other as applicable. The handout is provided in Annex 5.
The table below presents summary for the outcomes of the stakeholder consultations undertaken, while the
figure that follows presents sample photos.
Once the Draft ESIA is completed, a public consultation session will be held in Ras Gharib City, Red Sea
Governorate. The overall objective of the session is to present the outcomes and conclusions of the ESIA studies
to allow interested stakeholders (including local communities) to comment on the scope of work undertaken.
As required by EEAA, the session will be an ‘open’ session for any entity/person to attend that will be announced
through appropriate platforms (including newspaper advertisement) at least 2 weeks in advance of the session
as well as public announcements on social media platforms that are frequently used by local people of Ras
Ghareb residents and Bedouin groups. In addition, specific invitations will be issued to list of invitees that will
be identified jointly in coordination between EEAA, RCREEE and the ESIA consultant and will include: (i) EEAA
headquarter and regional branch; (ii) New and Renewable Energy Authority (NREA); (iii) Egyptian Electricity
Transmission Company EETC; (iv) local governmental entities in Red Sea Governorate and Ras Gharib; (v) NGOs;
(vi) local community representatives; and other.
Annex 6 provides a list of Frequency Asked Questions (FAQ) which will be kept up to date.
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Table 4: Summary of Consultations Undertaken during ESIA Process
No. Entity Objective Outcomes
1 EEAA Introduction of project and ▪ Expressed their support to renewable energy projects
12 May 2021 location, discuss overall ▪ Adherence to all environmental standards during construction and operation
methodology for ESIA, key ▪ Stressed on the importance of undertaking environmental baseline studies for the site to include in particular a bird
anticipated impacts, and migration studies by a specialist given the importance of the area
determine any key issues of ▪ Importance of adhering to community consultation sessions with representation of the local community and project
concern and/or additional stakeholders, in accordance with the EEAA guidelines for ESIA studies.
requirements to be taken into ▪ The impacts of the surrounding environment on the Project should be studied which includes in particular impacts
account as part of the study. resulting from natural factors such as floods.
▪ Impacts resulting from development activities in the area as well as assessing current and previous use of the land of
the Project site and its surrounding. It was noted that there is a dumpsite near the Project site belonging to the Ras
Gharib city council that will be removed to another alternative area that is currently being selected.
2 EETC ▪ Expressed their support to the Project
11 May 2021 ▪ ESIA study should include the Overhead Transmission Line (OHTL) of the Project.
▪ Indicated the importance of continuous consultation by the Developer with EETC during the various stages of the
Project until the completion of ESIA study and up to the operational stage.
3 NREA ▪ Stressed the importance of studying the OHTL
27 Abril 2021 ▪ ESIA should consider the applicable environmental standards when constructing OHTL, as well as the Project site to
include in particular impacts on bird migrating in the area.
▪ There should be communication with local communities through stakeholder engagement activities, which provide
information about the project to know their expectations and concerns about wind energy projects.
4 Ministry of ▪ Explained that the Egyptian government is currently moving towards produce clean energy projects, in a way that
Electricity and does not affect the environment or natural resources.
Energy ▪ Stressed on importance of ESIA study including consideration of the potential risks to bird migration.
11 May 2021 ▪ Discussed on importance of consulting with stakeholders after preparing the ESIA draft for discussion.
5 Ministry of Same as above but with focus ▪ Stated the importance of holding a meeting with officials in the National Telecom Regulatory Authority (NTRA), as the
Communication on telecommunication and national authority competent to regulate and administer the telecommunications sector.
23 May 2021 radio/TV infrastructure and ▪ An official letter was sent to conduct a meeting with officials in NTRA. The Consultant is still awaiting a date to be set
broadcasting towers in the for the meeting with NTRA.
area and potential impacts ▪ In addition, the Consultant has conducted meetings with officials of the telecom companies Vodafone, Etisalat, and
from Project on such facilities. Orange.
▪ Officials in the telecommunications companies explained that the presence of communication towers in the region
means that there are other towers at a distance of not less than 5 km. Such towers are connected through microwave
connections. Connections need to be empty from any obstacles along with a width of at least 30m to maintain the
effectiveness of the network and the continuity of the connection.
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▪ The ESIA Consultant is currently following up with NTRA to identify the official procedures to be followed to obtain
approval from these entities and/or identify key requirements to be taken into account.
6 Ras Gahreb ▪ The radio and television towers connection that are close to the Project site extend from Zafarana to Ras Ghareb to
Radio and TV Hurghada, in addition to other towers in the direction of Sheikh Fadl Road. The distance between each tower is about
Unit 60 km, depending on the terrain of the area
17 MAY 2021 ▪ The existing radio and television towers are used for receiving and transmitting the microwave signal, and for radio
waves FM, In addition to TV In addition to TV waves, VHF waves,
▪ They explained that to determine the impacts on radio and television towers; the Radio and Television Union in Cairo
should be contacted. A memorandum was prepared to arrange for a meeting with the entity, but no response has
been provided to date.
7 Ministry of Same as 1 above but with ▪ Explained that there are no archaeological discoveries sites close to the Project site. However, a field survey for the
Tourism and focus on archeology and Project site should be conducted to ensure that there are no archaeological sites.
Archeology cultural heritage methodology ▪ The archaeological sites closest to the Project site can be identified through the database of the Geographic
23 MAY 2021 and impacts for the ESIA and Information Systems Department at the Ministry of Tourism and Antiquities, as well as through the archaeology
any issues of concern related departments closest to the project site (the closest antiquities directorate to the project site is in Safaga City).
to that.
8 Key national and Same as 1 above but with ▪ Explained that positioning the turbines could have a negative effect on birds and therefore there needs to be a balance
local E&S NGOs focus on biodiversity, birds between risks and benefits and minimize any adverse environmental impacts. This must be taken into account in the
18 May 2021 and bats methodology and design phase of the Project.
impacts for the ESIA and any ▪ Discussed the existence of a dumpsite near the Project site and which is considered an attraction area for birds. This
issues of concern related to should be taken into account in choosing an alternative site for the dumpsite. Coordination should be made with the
that. Nature Protection Sector in the Red Sea Governorate to follow up on choosing a suitable site for the dumpsite that
takes into account the potential risks to birds in the area.
9
▪ Stressed on the importance of having corridors for migratory birds between the turbines as part of the design of the
Project.
▪ Stated that wind farms projects are in general environmentally friendly. The establishment of the Project does not
conflict with protecting the environment in Red Sea Governorate, as it is definitely better than establishing coal-fired
power plant.
▪ Pointed out that investment projects in the area should communicate with local communities to support the local
development projects in Ras Gharib city (through CSR activities) and should also give priority to youth from the local
community for job opportunities.
10 Ras Ghareb Local Same as 1 above but with ▪ Officials welcomed the Project and explained that wind energy projects are the best investment in Ras Ghareb
Council focus on land use, ▪ City Council officials confirmed that the dumpsite is located near the Project site and will be relocated to another
17 May 2021 infrastructure and utilities and alternative site that is currently being studied.
socio-economic methodology ▪ Officials at the Urban Planning Department confirmed that the Project area does not include any future urban planning,
and impacts and any issues of and was not part of any previous urban planning. The area is mainly allocated within exploratory sites belonging to the
concern related to that. General Petroleum Company.
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▪ Clarified that the dumpsite near the Project site is the only dump area in Ras Ghareb. It is leased to a contractor whom
employs 6 workers to sort and collect garbage; they are the contractor's workers, not the city council workers.
11 Red Sea ▪ Officials made it clear that the project area does not fall within the scope of residential projects or any residential or
Governorate industrial activities, as it is intended for energy projects only, in addition to the areas allocated for the exploration of
19 May 2021 the General Petroleum Corporation.
▪ The importance of the ESIA studying migratory birds and identifying proper mitigation and monitoring requirements.
▪ The issue of relocating the dumpsite to another alternative site was discussed where he mentioned that engineering
studies are currently being conducted to choose a suitable site for the new landfill.
12 Red Sea Water Same as above but with focus ▪ Explained that the current Project site does not conflict with any existing facilities (water / sanitation).
and Wastewater on water supply and ▪ Explained that Ras Ghareb Water Company is able to provide the Project's needs for water and sanitation services, but
Company wastewater management for through contractors; because the company does not have trucks to transport water or sanitary waste.
19 May 2021 the Project area. and any
issues of concern related to
that.
13 Petroleum Same as above but with focus ▪ Indicated that there are exploratory wells in the Project land and nearby sites. Exploration wells are currently closed,
Facilities and on land use issues and their in order to access more information about the number of exploration wells, and the possibility of re-exploring them
companies in the key activities undertaken again; It will require coordination through the head office in Cairo.
area within the area. ▪ The consultant sent an official letter to Chairman of the Board of the General Petroleum Company to arrange for an
18 May 2021 interview with no response to date.
14 Ras Ghareb Same as above but with focus The Consultant conducted Focus Group Discussion (FGD) and meetings with representatives of the local community in Ras
citizens on land use and socio- Ghareb. Key local community representatives will be identified through the Ras Ghareb City Administration and key local
16 May 2021 economic methodology and NGOs in Ras Ghareb. Community members explained that Ras Ghareb is a small city that lacks many services, in addition
impacts. Key local community to limited job opportunities. They hoped that investment projects as this one would help provide job opportunities for all
representatives will be including in particular youth which would have a direct impact on the local community. No specific concerns were raised
identified through the Ras by the local community members on the Project development. On the contrary, they made it clear that the Project site is
Ghareb City Administration a great distance from the city center, and they do not foresee any direct negative impact on the local community, whether
and key local NGOs in Ras in the construction or operation stage. Other issues raised include
Ghareb. ▪ They do not feel a direct economic benefit from investment projects in the field of wind energy to date as they believe
Developers in general do not depend on the city of Ras Gharib for supplies and contracting work despite the availability
of construction contractors and supplies.
▪ They stated that the City Council has lists of officially registered companies, local contractors and supply companies
▪ They suggested that job opportunities can be announced through the city council as well and indicated that the city's
labor office also has the available workforce according to different specializations.
15 Bedouins Same as above but with focus Meetings were held with heads of tribal leaders of Bedouin families. The results indicated the following:
residing near the on land use and socio- ▪ There are no stable Bedouin communities in or near the Project site. The only settled villages in the desert for Bedouin
project area economic methodology and families are in Zaafarana and Wadi Dara Which is at least 50 km away from the Project site,
16 May 2021 impacts. Consultations will be
Page | 23
undertaken with head of tribal ▪ The Project site or the surrounding areas does not have any key land use activities for them such as grazing or farming
leader. activities. However, the area in general is subject to their Ghafra System that is divided between two families, the
Tabbna and the Hamadin families.
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5. FUTURE STAKEHOLDER ENGAGEMENT STRATEGY, PLAN, AND RESPONSIBILITIES
The table below identifies the stakeholder engagement strategy and plan to include stakeholders relevant to
the Project (Table 5), the objectives of the consultation with each group, the communication methods and tools,
time frame and responsible entity for undertaking such consultations.
A Project Stakeholder Register3 will be updated monthly for the Project which serves as a log for all consultation
and engagement undertaken for the Project. This shall be reviewed and updated regularly by the assigned
Community Liaison Officer (CLO) s. A template is provided in Annex 4 – Project Stakeholder Register Form which
will be used wither in Microsoft Word or Excel format.
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Stakeholder Objectives Communication Methods and Tools Timeframe Responsibility
1. Individual targeted meetings with tribal leaders of such
Bedouin Groups Disclosure of Stakeholder Annually during Developer
groups to explain SEP and grievance mechanism
Engagement Plan (SEP) including construction and
(CLO)
grievance mechanism. operation
1. Prepare and distribute leaflet in Arabic with updates on
Updates on the Project including Quarterly during Developer
Project including environmental and social issues. This
environmental and social issues and construction
could include updates on the Project development, number (CLO)
CSR activities undertaken
of employment opportunities allocated for local
communities, the bidding process for Project components,
Annually during
construction plans, updates on CSR programs implemented,
operation
etc.
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Stakeholder Objectives Communication Methods and Tools Timeframe Responsibility
3. As per training plan to be developed
Provide general/specialized training Upon employment /
requirements as applicable to include continuous
but not limited to induction, Toolbox
Talks (TBT), occupational health and
safety, waste management, etc.
Stakeholders who may have a possibility to influence and make decisions on implementation of the Project and/or may have an interest in the Project
Central Government
1. EEAA 1. Individual/Internal Meetings (if required)
Some governmental stakeholders Upon occurrence Developer team
2. EETC
might require to undertake certain as applicable
3. NREA
inspections or auditing exercises 2. Correspondence and official letters (if required)
4. Ministry of Interior Upon occurrence Developer team
and/or might require certain
5. Ministry of Labor as applicable
updates/information on the
6. Ministry of Health
implementation of the Project.
1. Email notification. Annual environmental and social report
Updates on the Project including Annually – 1st quarter Developer
to be disclosed on company website.
environmental and social issues (e.g. of each year
(CLO)
environmental performance,
grievance mechanism
implementation, CSR programs
implemented, etc.)
1. Individual/Internal Meetings (if required)
Ministry of Transportation / Roads Submission of traffic and transport Once before Developer team
2. Correspondence and Official Letters
and Bridges Directorate, Red Sea management plan in relation to construction as applicable /
Governorate turbine transportation EPC Contractor
1. Individual/Internal Meetings (if required)
Ministry of Civil Aviation Submit application to obtain their Once during planning Developer
2. Correspondence and Official Letters
approval for Project development phase
NREA
RCREEE
Page | 28
Stakeholder Objectives Communication Methods and Tools Timeframe Responsibility
1. Individual/Internal Meetings (if required)
Armed Forces Operations Submit application to obtain their Once during planning Developer
2. Correspondence and Official Letters
Authority approval for Project development phase
NREA
RCREEE
Page | 29
Stakeholder Objectives Communication Methods and Tools Timeframe Responsibility
1. Individual/Internal Meetings (if required)
- Identify requirements for Continuously Developer
4. Correspondence and Official Letters
coordination of work throughout throughout
NREA
the construction and operation construction and
phase operation as
applicable
Local Government
1. Individual/Internal Meetings (if required)
Ras Ghareb Local Unit Coordination for the collection of Once before EPC Contractor/
solid waste from the site to the construction Project Operator
municipal approved landfill
Once before
2. Correspondence and Official Letters operation
1. Individual/Internal Meetings (if required)
Coordination for list of private Once before EPC Contractor/
contractors approved for collection of construction Project Operator
hazardous waste from the site to the
Swaqa Hazardous Waste Treatment
Facility. Once before
2. Correspondence and Official Letters
operation
1. Individual/Internal Meetings (if required)
Ras Ghareb Water Company Coordination for list of private Once before EPC Contractor/
contractors approved for collection of construction Project Operator
wastewater from Project site.
Once before
2. Correspondence and Official Letters
operation
1. Individual/Internal Meetings (if required)
Coordination to secure the water Once before EPC Contractor/
requirements of the Project (if construction Project Operator
required)
Once before
2. Correspondence and Official Letters
operation
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Stakeholder Objectives Communication Methods and Tools Timeframe Responsibility
Ministry of Antiquities – Red Sea Notify to check if they will provide any 1. Individual/Internal Meetings (if required)
Once before EPC Contractor
Antiquities Inspection Office observers to oversee excavation 2. Correspondence and Official Letters
construction
process
As per list provided earlier 1. Email notification. Annual environmental and social report
Updates on the Project including Annually – 1st quarter Developer
to be disclosed on company website.
environmental and social issues (e.g. of each year
(CLO)
environmental performance,
grievance mechanism
implementation, CSR programs
implemented, etc.)
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ESIA and Supporting Documents Information Disclosure
It is of utmost importance to ensure that stakeholders are kept well informed about the Project throughout its
life cycle, thus information will be accessible to the public, key stakeholders, and local communities through
dissemination of related documents.
The disclosure package will include the following key documents that are available publicly in the Arabic and
English languages.
▪ Environmental and Social Impact Assessment (ESIA) for the IPH Wind Farm that will also include the
associated Overhead Transmission Line (OHTL)
▪ Developer’s Website. The documentation above will remain on the website for the life of the project.
▪ Hard copies are available at Red Sea Governorate and Ras Ghareb Local Governmental Unit
▪ Soft copies can also be made available to stakeholders via email to ([email protected]). In addition, any
inquiries or comments with the Developer can be directed to this email address as well.
Finally, it is important to note that all stakeholders can raise concerns or comments via the grievance mechanism
provided in “Chapter 6” below.
4
The most recent, updated version.
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6. GRIEVANCE MECHANISM
6.1 Stakeholder Grievance Mechanism
IPH understands that management of grievances is a vital component of stakeholder engagement and an
important aspect of risk management for a project. Grievances can be an indication of growing stakeholder
concerns (real and perceived) and can escalate if not identified and resolved. Identifying and responding to
grievances supports the development of positive relationships between projects, communities, and other
stakeholders. Monitoring of grievances will signal any recurrent issues, or escalating conflicts and disputes.
IPH will implement a Grievance Mechanism to ensure that it is responsive to any concerns and complaints
particularly from affected stakeholders and communities. IPH will accept all comments and complaints
associated with the Project and individuals who submit their comments or grievances have the right to request
that their name be kept confidential. At all times, complainants are also able to seek legal remedies in
accordance with the laws and regulations of Egypt.
IPH will monitor the way in which grievances are being handled and ensure they are properly addressed within
deadlines specified within the mechanism presented below. IPH will also report regularly to the public on the
grievance mechanism implementation, protecting the privacy of individuals.
The figure below presents a process diagram for the stakeholder grievance procedure which is further explained
throughout the section below.
Page | 33
Figure 5: Stakeholder Grievance Process Diagram
1. A Grievance Disclosure Sheet will be disclosed at key locations. The Grievance Disclosure Sheet will inform
the local communities on how and where to lodge a grievance in accordance with step 2 below.
2. Stakeholders willing to lodge a grievance should be able to use the following avenues:
Page | 34
a. Grievance Sheets (Annex 1) with grievance boxes will be made available at the following locations:
CLO
Address: 57 Nile Corniche St., El Maadi 11431, Cairo, Egypt (please check the project’s webpage on our
website for updated details)
Telephone: +3 12 0522 2555 (please check the project’s webpage on our website for updated details)
E-mail: [email protected] (please check the project’s webpage on our website for updated details)
3. All grievances (whether submitted through a grievance form, e-mail, telephone, etc.) will be recorded on a
grievance log sheet by the CLO (Annex 2).
4. It is possible that for some grievances, women might feel uncomfortable discussing a grievance with a
person of the opposite sex, therefore the grievance mechanism also includes a female CLO that will be
available.
5. This mechanism is applicable for any project related stakeholder group to raise a grievance. This includes
but not limited to national / regional governmental entities, local communities, Non-Governmental
Organizations (NGOs), media, research, and academic institutions, and other. This mechanism addresses
grievances related to the following:
- Any grievance related to project activities to include but not limited to: (i) damage to public / private assets;
(ii) degradation / deterioration of local infrastructure (e.g. roads); (iii) disturbance from noise, dust, traffic
accidents, pollution, excessive speed of project’s vehicles; (iv) degradation of the environment and
disturbance of wildlife; (v) disturbance to land uses, (vi) other similar issues.
- Any grievance against involved person/entity in the project to include but not limited to the Developer, EPC
Contractor, subcontractors, and suppliers. This could include but not limited to: (i) negative behavior of
construction workforce towards local communities; (ii) misconduct of security service providers; (iii)
inappropriate behavior of workers in terms of managing employment and procurement opportunities, (iv)
other similar issues.
However, the following grievances will not be addressed in the case they are submitted. In this case, the
applicant will be informed that the grievance will not be addressed along with a justification. This includes
the following in particular:
- Grievances against an entity / person / worker that is/was not involved in the project in any way directly or
indirectly
Page | 35
- A complaint that is currently being reviewed by the judiciary system and/or for which a final and definitive
court ruling has been issued
6. Grievance procedure starts with formal acknowledgment in accordance with the preferred method of
communication specified by the complainant within 7 working days of submission. If the grievance is not
well understood or if additional information is required, clarification will be sought from the complainant
during this step.
7. In coordination with the relevant personnel, the CLO will analyze the root cause of the grievance, investigate
if the grievance is correct or not, and identify the required actions to be implemented to deal with the issue
and identify the timeline for their completion (if applicable). For other more complex grievances, third
parties could be involved in the investigation as applicable. Specific examples on this includes the following:
- Grievances that entail safety concerns such as personal threats. Such grievances might require the
involvement of local Police
- Grievances that entail damage to property which have been verified might require an assessment of the
damaged asset with the support of an external specialist in agreement with the complainant.
8. The CLO will prepare a grievance resolution form (see Annex 3) which includes the nature of the grievance,
date of its submission, actions implemented to resolve the grievance and date of implementation, or
proposed actions to be implemented to resolve the grievance along with the timeline for their completion.
Grievance resolution form will be submitted within (30) days of receiving the grievance.
9. The grievance resolution form, including necessary budget to resolve the grievance, must be approved and
signed‐off by the Project Manager.
10. The outcomes of the grievance resolution form will be communicated to the complainant by the CLO in
accordance with the preferred method of communication specified.
11. In case the grievance resolution form identifies proposed actions to be implemented, the CLO will monitor
and follow up to ensure that such actions have been implemented in accordance with the timeline proposed
within the grievance resolution form. The CLO will contact the complainant once such actions are completed
in accordance with the preferred method of communication specified.
12. The CLO will ensure that the grievance forms, grievance log sheet, and grievance resolution form are always
updated and maintained onsite.
13. The grievance mechanism will be implemented promptly and at no cost and without retribution to the party
that originated the issue or concern.
14. The use of grievance mechanism shall not impede access to judiciary means.
15. The grievance mechanism allows submission of anonymous complaints by community members.
16. In the case the complainant does not accept the proposed resolution the following steps will be undertaken:
- The CLO will raise the issue to the Project Manager for discussion and adoption of new resolutions for the
grievance.
- In the case the complainant does not accept the new resolution, the Project Manager will raise the issue to
the E&S Department at headquarters for discussion and adoption of new resolutions for the grievance.
17. In the case the complainant does not accept the new resolution proposes, the compliant will be asked to
access judiciary means to resolve his/her grievance.
Stakeholder Grievance Mechanism for Gender Based Violence, Sexual Harassment and Sexual Exploitation
and Abuse
Page | 36
The requirements set below are considered applicable for handling grievances related to the following and in
accordance with the requirements set within the “Good Practice Note Addressing Gender Based Violence in
Investment Project Financing involving Major Civil Works” (2018, World Bank).
▪ Violence Against Women and Girls (VAWG): defined violence against women and girls as any act of gender-
based violence that results in, or is likely to result in, physical, sexual, or mental harm or suffering to women,
including threats of such acts, coercion, or arbitrary deprivation of liberty, whether occurring in public or in
private life
▪ Gender-based Violence (GBV) is an umbrella term for any harmful act that is perpetrated against a person’s
will and that is based on socially ascribed (i.e. gender) differences between males and females. It includes
acts that inflict physical, sexual, or mental harm or suffering, threats of such acts, coercion, and other
deprivations of liberty. These acts can occur in public or in private. Women and girls are disproportionately
affected by GBV across the globe.
▪ Sexual Exploitation and Abuse (SEA): any actual or attempted abuse of a position of vulnerability, differential
power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially, or politically
from the sexual exploitation of another. Sexual abuse is further defined as “the actual or threatened physical
intrusion of a sexual nature, whether by force or under unequal or coercive conditions.” Women, girls, boys,
and men can experience SEA. In the context of World Bank supported projects, project beneficiaries or
members of project-affected communities may experience SEA.
For the above complaints, there are risks of stigmatization, rejection, and reprisals against survivors. This creates
and reinforces a culture of silence so survivors may be reticent to approach the project directly. Therefore, the
following steps should be considered for any grievances related to the above.
▪ Both the male and female CLO will receive appropriate training from an authorized GBV Service Provider
(National Council for Women) on how to collect GBV cases confidentially and empathetically (with no
judgement). It is essential to respond appropriately to a survivor’s complaint by respecting the survivor’s
choices. This means that the survivor’s rights, needs, and wishes are prioritized in every decision related to
the incident. The survivor who has the courage to come forward must always be treated with dignity and
respect. Every effort should be made to protect the safety and wellbeing of the survivor and any action
should always be taken with the survivor’s informed consent. These steps serve to minimize the potential
for re-traumatization and further violence against the survivor.
▪ Confidentiality is essential throughout the process. Otherwise, the survivor risks retaliation and a loss of
security.
▪ No identifiable information on the survivor should be stored including in particular the grievance log
register. In addition, if a grievance is submitted through a grievance form it will be kept confidential.
▪ Should the grievance be received by the CLO through a grievance form, telephone, email or other, the CLO
should not ask for, or record, information on more than three aspects related to the incident and which
include the following:
- Nature of the complaint (what the complainant says in her/his own words without direct questioning)
- If, to the best of their knowledge, the perpetrator was associated with the project; and,
▪ The CLO should assist the survivor by referring them to the GBV Services Provider for support immediately
after receiving a complaint directly from a survivor. It is up to the survivor, and only the survivor, whether
to take up the referral. The list of services providers is included below:
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▪ The GBV Services Provider provides the necessary support to the survivor until it is no longer needed.
Survivors may need access to police, justice, health, psychosocial, safe shelter and livelihood services to
begin healing from their experience of violence. This will be arranged by the GBV Services Provider on their
behalf in accordance with the survivor’s wishes.
▪ The CLO will immediately notify the Project Manager (if the consent of the survivor is obtained). The survivor
must give consent to data sharing and know what data will be shared, with whom and for what purposes.
▪ The CLO, Project Manager and GBV Services Provider will meet immediately to agree on a plan for resolution
as well as the appropriate remedy for the perpetrator in accordance with the below. Note: The survivor
must give the service provider representative consent to participate in the resolution mechanism on her/his
behalf.
- Reviews the case and collectively agree upon the appropriate actions to be taken and sanctions, if any.
- Assigns the appropriate ‘Focal Point’ to implement the actions—with the assistance of the GBV Services
Provider.
- Upon resolution, the Focal Point and GBV Services Provider advise that it has been resolved, who in turn
advise the CLO.
- The CLO notes the resolution and closes the cases and submits a close-out report to the Project Manager
whom in turn reviews and approves the report.
▪ All entities involved above in case resolution, need to understand their legal obligations when it comes to
reporting cases to the police. Reporting should be done in accordance with the law, especially in cases that
require mandatory reporting of certain types of incidents, such as sexual abuse of a minor. When there is
no legal obligation to report the case according to the local law, survivors hold the decision of whether to
report cases for resolution and other service providers and reporting of a case to anyone can only be made
with the consent of the survivor.
▪ If a case is first received by the GBV Services Provider, a report should be sent to the CLO to ensure it is
recorded in the system. If any follow up is required by the CLO, it will be provided immediately with the
consent of the survivor as applicable.
▪ If the survivor does not wish to place an official complaint through the grievance mechanism, the complaint
is considered closed.
▪ If the alleged perpetrator is an employee of the Developer, EPC Contractor, or subcontractor, to protect the
safety of the survivor, and the workplace in general, the worker, in consultation with the survivor—and with
the support of the GBV Services Provider—should assess the risk of ongoing abuse to the survivor.
Reasonable adjustments should be made to the alleged perpetrator’s work schedule and work
environment—preferably by moving the perpetrator rather than the survivor—as deemed necessary.
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7. MONITORING AND REPORTING
The following monitoring requirements will be undertaken by the CLO with regards to the implementation of
the SEP:
▪ Weekly inspections will be undertaken at stakeholder grievance boxes and worker grievance boxes to
collect any grievance forms.
▪ Twice per month inspections will be undertaken to ensure: (i) SEP is disclosed in hard copy at the Red Sea
Governorate and Ras Gharib Local Administration; (ii) summary advertisements of grievance mechanism
are available at local community platforms.
▪ Quarterly inspections will be undertaken to: (i) ensure project update leaflets are available at local
community platforms; (ii) stakeholder grievance boxes and forms are available at designated locations;
(iii) worker grievance boxes and forms are available at designated locations.
▪ Monitoring requirements are to be updated once available for implementation of the local employment
and procurement procedure as well as the social responsibility program. This could include for example
submission of employment and procurement databases, proof of announcement advertisements, etc.
- Discussion with sample of workers to ensure they are familiar with the process.
- Collection and review of grievance forms, grievance closeout forms and grievance log sheet.
The following reporting requirements will be prepared by the CLO with regards to the implementation of the
SEP:
▪ On a monthly basis the stakeholder register form will be submitted as provided in Annex 4.
▪ On a monthly basis the stakeholder grievance form will be submitted as provided in Annex 2.
▪ On a monthly basis the worker grievance form will be submitted as provided in Annex 8.
▪ The SEP will be updated and resubmitted on a semiannual basis during the construction phase and on an
annual basis during the operation phase.
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3 Number of vulnerable groups engaged All communication to be reported in stakeholder register
(including women groups)
4 Number of requests for information via All communication to be reported in stakeholder register
websites, CLOs and local information
centers
This chapter identifies the roles and responsibilities related to implementation of the SEP.
▪ Oversee the overall implementation of this Stakeholder Engagement Plan, including frequent interfacing
with CLOs.
▪ Overall responsibility for implementing the requirements of the stakeholder engagement plan as
identified under ‘Chapter 5 5’
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▪ Overall responsibility for implementing the requirements of the stakeholder grievance mechanism to
include distribution of grievance disclosure sheets, collection of grievance forms, updating grievance log
sheet, filling grievance resolution forms and grievance close-out forms.
▪ Overall responsibility for implementing the worker grievance mechanism for their staff. This includes
distribution of grievance disclosure sheets, collection of grievance forms, updating grievance log sheets,
filling resolution form and grievance close-out forms.
▪ Coordinate with the EPC Contractor’s team / oversee the implementation of the EPC Contractor and its
subcontractors of all requirements related to SEP and worker grievance mechanism.
▪ Implementing the requirements of the stakeholder engagement plan as applicable and as identified under
‘5.’ As noted in Table 5,the EPC Contractor CLO will have no role in consultation and engagement activities
with local communities or Bedouin groups. EPC Contractor CLO engagement activities are limited to those
requirements for the project that are mainly with governmental entities such as securing water
requirements from the Water Company, assigning authorized waste collectors from City Council, etc.
Note: The EPC Contractor and its subcontractors(s) will have no role in the implementation of the stakeholder
grievance mechanism. Any complaints received directly or indirectly by any EPC or subcontractor staff shall be
redirected to the IPH CLOs.
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9. ANNEXES
9.1 Annex 1 – Grievance Disclosure Sheet
Reference No.
Full Name:
(Anonymous submission is
allowed)
Signature: Date:
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9.2 Annex 2 – Grievance Log Sheet
Ref How Was Date of Name and Description of Grievance Actions Taken to Resolve the Date of Has grievance
grievance Submission of Contact Grievance Communication been resolved
No.
submitted Grievance Information of Solution (Y/N) if not
explain why
9.3 Annex 3 – Grievance Resolution Form
Reference No:
Description of Concern,
Incident or Grievance:
Date of Grievance
Section 1
Summary of Actions
Undertaken to Resolve
Grievance
Date of Implementation
Section 2
Summary of Proposed
Actions to be
Implemented to Resolve
Grievance
Timeline for
Implementation
CLO:
Signature:
Date:
9.4 Annex 4 – Project Stakeholder Register Form
Stakeholder Importance and Priority Contact Expectations Communication Timeframe Responsibility
# Name, position, Role Level of Interest Ability to Influence Priority Methods and Tools
group, etc. Low Medium High Low Medium High Low Medium High
9.5 Annex 5 – Project Handout
9.6 Annex 6: Frequently Asked Questions (FAQ)
Based on agreement with the Government of Egypt (GoE), the project will be connecting to the National Grid
that supplies electricity for all end-users. Project will not be providing electricity specifically for a local
community area but rather all end-users across Egypt.
2. What are the job opportunities that the Project will provide?
Project will require the following workforce throughout the construction and operation phase:
▪ Around 250 job opportunities at peak during the construction phase for a duration of approximately 24
months. This will mainly include around skilled job opportunities (to include engineers, technicians,
consultants, surveyors, etc.) and unskilled job opportunities (mainly laborers but will also include a number
of security personnel).
▪ Around 24 job opportunities during the operation phase for a duration of 20 years. This will include skilled
job opportunities (such as engineers, technicians, administrative employees, etc.) and unskilled job
opportunities (such as security personnel, drivers, etc.).
3. How will job opportunities be managed? And how can one apply?
A Local Recruitment Procedure will be prepared and announced at a later stage. The procedure will identify the
number of job opportunities targeted for local communities to include skilled and unskilled workers. Such job
opportunities shall also take into account employment of local communities in the area around the Project to
include fresh graduate engineers, technicians, laborers, etc.
In addition, the procedure will include details on how job opportunities will be announced as well as a selection
process that is fair and transparent and provides equal opportunities for all including females.
The Procedure should be developed in coordination with local authorities such as the Local Labor Office and will
investigate the potential for implementation through a joint collaboration between the Developer/EPC
Contractor and the other wind farm developers in the area.
4. How will procurement opportunities be managed? and how can one apply?
A Local Procurement Procedure will be prepared and announced at a later stage. The procedure will identify
procurement opportunities targeted for local communities to include for example local subcontractors, local
supplies and services, cleaning services, etc.
In addition, the procedure will include details on how procurement opportunities will be announced as well as
a selection process that is fair and transparent and provides equal opportunities for all.
The Procedure should be developed in coordination with local authorities such as the Local Labor Office and will
investigate the potential for implementation through a joint collaboration between the Developer/EPC
Contractor and the other wind farm developers in the area.
5. Will the project implement a Social Responsibility Program? How can one benefit from this?
A social responsibility program will be considered by the Developer which will aim to benefit the local
communities to the greatest extent possible. A structured approach to this will be developed which will identify
priority development projects which could benefit local communities (e.g. based on a needs assessment if
available).
Based on that the social responsibility program can prioritize projects for local communities based on available
budget, vision, timeline for implementation and other factors.
CLO
Address: 57 Nile Corniche St., El Maadi 11431, Cairo, Egypt (please check the project’s webpage on our
website for updated details)
Telephone: +3 12 0522 2555 (please check the project’s webpage on our website for updated details)
E-mail: [email protected] (please check the project’s webpage on our website for updated details)