Non-Technical Summary

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Non-Technical Summary
Kurty-Buribaytal Road Section 2214-2295 km, Part of the
Reconstruction of the ‘Center-South’ Corridor Linking Astana to
Almaty
April 2015
Table of Contents
1.
1.1.
1.2.
1.3.
2.
2.1.
2.2.
2.3.
2.4.
3.
3.1.
3.2
Project Description ............................................................................................... 3
Overview of the Project ................................................................................................................................ 3
Road Setting ...................................................................................................................................................... 3
The Proposed Investment ........................................................................................................................... 4
Background ........................................................................................................... 5
Rational for the Project ................................................................................................................................. 5
Legal Aspects and Compliance ................................................................................................................ 6
Environmental and Social Situation and Considerations ............................................................ 6
Assessment of the Project .......................................................................................................................... 6
Process .................................................................................................................. 7
Project Design and Regulatory Compliance ...................................................................................... 7
Public Consultations and Disclosure and Dealing with Objections ........................................ 7
4. Summary of Environmental Benefits, Potential Adverse Impacts, Mitigation
and Management Measures ........................................................................................ 8
5. Summary of Social Benefits Potential Adverse Impacts, Mitigation and
Management Measures.............................................................................................. 10
6.
6.1
6.2
6.3
Communications ................................................................................................. 12
Stakeholder Engagement Plan .............................................................................................................. 12
Grievance Mechanism ............................................................................................................................... 12
Contacts ............................................................................................................................................................ 13
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1. Project Description
1.1.
Overview of the Project
The European Bank for Reconstruction and Development (EBRD) is considering providing
finance for the reconstruction of a section of the 228 km “Kurty Buribaytal” or the “Centre South” corridor linking Astana to Almaty. The Committee for Roads within the Ministry of
Investment and Development is the government ministry that is seeking the EBRD finance
for a section of the road that is 81 km (the “Project”).
The proposed investments include the reconstruction and widening of the existing road, the
reconstruction of bridges and upgrading of intersections as well as financing of supervising
engineers, implementation assistance to the Project Implementation Unit (PIU) and
institutional components.
The 81 km section (Section 2) that EBRD is potentially financing starts at a point
approximately 200km from Almaty to 281km. The road sections are:
■
Section 1: km 2152-2214 (62km)
■
Section 2: km 2214-2295 (81km)
■
Section 3: km 2295-2335 (40km)
■
Section 4: km 2335-2380 (45km)
The overall 228 km length of the road connects Kurty village with Buribaytal village. As well
as the EBRD, the other road sections will potentially be financed by other International
Financial Institutions.
It is planned that the time scale of the start of construction for all sections is early 2016. The
estimated construction period of each section is 33 months.
This document is a Non-Technical Summary (NTS) that provides a summary of the Project
in non-technical language covering the background and project description, the
Environmental and Social Impact Assessment (ESIA) process, the environmental and social
benefits/impacts, mitigation and management measures and the contact details for
communications with a summary of the Stakeholder Engagement Plan (SEP) that includes a
grievance mechanism.
1.2.
Road Setting
The proposed EBRD funded road Section 2 is located in Zhambyl district of Almaty Oblast,
between the villages of Kanshengel and Aksuyek. It is part of the transit “Centre-South”
corridor of “Astana-Karaganda-Balkhash-Kapshagay-Almaty. The entire road section is
aligned in south-eastern direction. Currently, the road has two lanes.
The 19,300km2 Zhambyl district has 61 settlements inhabited by some 136,800 people of
more than 30 nationalities. ksuyek, located 6.5km north-west of the road end was
abandoned by 10,000 people and empty houses have been dismantled for reuse as building
material. The population now consists of 1,231 residents of the elderly who once worked at
the mine. Kanshengel village consists of 11 farm houses. Over time its population has
gradually fallen to 144 residents.
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However, there are no populated settlements directly along the road section, only a few
isolated properties within the distance of vision of a few kilometres from the road. These
isolated farms and other residential structures use dirt roads to connect to the main road.
There are no businesses, petrol stations or other formal or informal economic activities in the
vicinity of the road. There are a few areas where drivers can stop though there are no
resting facilities (no bathrooms, shops etc.).
There are a number of road accidents memorials located in the immediate vicinity of the
road. The Archaeological Department has undertaken a study to identify all sites and objects
that are of cultural significance in the vicinity of the road which identified one tomb and five
early Iron Age kurgan burial grounds of particular archaeologically historical and cultural
interest.
The road runs on flat terrain in the desert-steppe zone of poor pasture land, which is used
for non-intensive herding on both sides of the road. Due to the absence of a large number of
traffic and the road guards, herders drive their cattle not through underpasses or under
bridges, but right through the road wherever convenient. There are several wells at a certain
distance from the road.
The road alignment crosses three river beds Tesik, Shengeldy and Kurmansay. The road
also passes through the territory of Zhusandaly Preserve which is inhabited by a number of
mammals that include goitered gazelle, wolfs, jackals, foxes, corsac foxes, hares and
various birds.
1.3.
The Proposed Investment
Due to its age and traffic loading, the surface condition has deteriorated to a poor quality.
The 228 km section is the last part of the Astana-Almaty highway which is to be rebuilt as
part of the road programme to reconstruct the entire road to meet the Kazakh Category 1b
Road Standard.
The proposed work will include the widening of the road from a two lane to four-lane
highway with a new bituminous concrete pavement, the construction of several new bridges
and reconstruction of existing bridges and upgrading of intersections.
The construction of 3 new bridges will be conducted within the water protection belts of the
three rivers next to the existing bridges. Additionally 5 more bridges will be built. It is also
planned that 32 pipe and 37 box culverts will be installed at the place of existing structures
to allow water to flow under the road.
Other components of the design include 4 rest areas and 2 bus stops and there will be 17
cattle underpasses. There will also be 8 new off-ramps (five of them are two-sided - northsouth) that will be added to 5 existing off-ramps to ensure access from the field roads that
are used by the local population.
As the road is designed to be elevated above the existing road up to 3m, 8 borrow pits /
quarries are to be developed along the road for earth and partial sand-gravel mixture. During
construction, there will be other temporary structures that will include 18 construction pads, a
contractor’s camp and a concrete batching / asphalt plant.
After project completion, Ministry of Investment and Development will be in charge of the
operation and maintenance of the project road.
Figure 1 below shows the Kurty-Buribaytal road.
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Figure 1 Kurty-Buribaytal Road
ADB financed
section, 81km
EBRD loan
savings, 16km
Buribaital
New EBRD
section, 56km
WB loan
savings, 75km
Kurty
Note that sections provided in the map above are the initial sections that were proposed to
be funded. EBRD has now been requested to provide a loan for the construction of the road
“Kurty-Buribaytal” with length of 81 km (Section 2: km 2214-2295).
2. Background
2.1.
Rational for the Project
The road represents the last unreconstructed section of the larger transport corridor
connecting the city of Astana and Almaty which was reconstructed in 2003. Currently the
road has two lanes that will be increased to four lanes. The road’s asphalt pavement is past
its effective working life and its condition is deteriorating at a fast rate, due to a combination
of traffic loading and the age of the pavement. Reconstruction of the road is now urgently
required to improve the ride quality of the road, minimise road user costs and provide a
pavement that can be maintained in a cost effective manner. In addition widening of the road
will reduce the number of traffic accidents due to narrow width of the road which forces
drivers to cross into the oncoming traffic lane to overtake vehicles.
The road will serve local and national transport needs as well as the agricultural sector,
which is key sector in Kazakhstan, which will be a major beneficiary. Labour movement will
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also be enhanced with communities near to the road such as Kanshegel, Ashysu and
Aydarly benefitting from easier transport links. The road will also be part of a route between
China and Western Europe via Western China, through Kazakhstan to Russia. This will be
economically beneficial from a trade and tourism perspective. There will be the international
transportation of goods produced in countries that include Tajikistan, the Kyrgyz Republic
and Uzbekistan.
2.2.
Legal Aspects and Compliance
Under the Kazakhstan regulatory regime, a feasibility study and detailed design has been
completed, accepted and approved by the State Expertise. The final design is now being
determined.
A national Environmental Impact Assessment (EIA) has previously been developed in
accordance with the rules, regulations and standards of the Republic of Kazakhstan for
design and construction of roads. The current ESIA has been developed in order to also
meet the EBRD Environmental and Social Policy requirements.
An independent gap analysis review of the ESIA and other key documentation has been
undertaken against EBRD’s Performance Requirements, EU standards and best practice.
The gaps identified have been used to develop an Environmental and Social Action Plan
(ESAP) for implementation and a disclosure pack comprising this NTS and a Stakeholder
Engagement Plan (SEP) in English, Kazakh and Russian.
The SEP provides a framework for consultation activities and project disclosure information
including the identification of potential stakeholders, methods used for consultation activities
and the records to be kept.
2.3.
Environmental and Social Situation and Considerations
Potential environmental and social (including community and occupational health and safety)
impacts have been identified and mitigation measures have been developed that are
presented in an Environmental Management and Monitoring Plan (EMMP) within the ESIA.
The gap analysis review has also identified implementable ESAP actions. The Committee
for Roads are committed to ensure that the EMMP and ESAP are implemented. A summary
of the key impacts and mitigation are provided in the next Section.
2.4.
Assessment of the Project
The project has been in the planning for a number of years. The ESIA has considered an
alternative (“without project" and "with the project") concluding that the selected alignment of
widening of the present carriageway to 4 lanes with a dividing strip, offers the best
environmental approach to solving the problems with the present alignment and encouraging
greater economic and social links between town and cities. The ESAP has an action to
provide further details of the assessment of impacts of alternatives. The key environment
and social impacts associated with the project with mitigation measures developed during
the construction and operational phases are:
Climate and Air Quality
Noise and Vibration
Water Supply
Surface Water
Groundwater
Wastewater Management
Geology and Land
Ecosystems and Flora and Fauna
Geohazards / Seismic
Waste Management
Cultural Resources
Visual Landscape
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Occupational Health and Safety
including labour standards
Community Health and Safety
including Road Safety
Land Acquisition
Other Socio-Economic Impacts
3. Process
3.1.
Project Design and Regulatory Compliance
The national EIA was developed in accordance with the rules, regulations and standards of
the Republic of Kazakhstan for the design and construction of roads. State Environmental
Expertise Positive Conclusion on the pre-EIA was obtained 22nd December 2014, with the
following prior approvals:
■
The Sanitary Epidemiological Service – 2nd December 2014,
■
The Balkhash-Alakol Basin Water Inspectorate approval – 28th November 2014,
■
The Department of Consumer Rights Protection of the Ministry of National Economics –
2nd December 2014
The final draft EIA was completed in November 2014 and finished on 12th January 2015
which fully meets national requirements. The current draft ESIA has been prepared
specifically for the EBRD in order to meet the EBRD Environmental and Social Policy
requirements. Identified gaps have been as addressed with ESAP actions that are
recommended for implementation in order to meet EBRD’s Performance Requirements, EU
standards and best practice.
A feasibility study and the road design is now finalised and is in the process of being
reviewed by the authorities. Key stages in the future will be the issue of invitations to tender
for road construction companies and also appointment of project management and project
supervision roles.
Operational and environmental permits have reportedly only been obtained for borrow pits /
quarries for earthworks and soil gravel mix. Permits of other temporary and permanent land
use – construction pads, spoil dumps, contractor camps, batching plant etc. have not been
obtained as yet. In addition, permits required to cover air emissions, water use etc. have not
been obtained as yet.
3.2
Public Consultations and Disclosure and Dealing with Objections
Stakeholder engagement and the organisation of public hearings are a requirement under
Kazakh national legislation. The Committee for Roads is working in close cooperation with
relevant Ministries, municipal, district and local authorities. Stakeholder engagement is
carried out at a grassroots level strengthening the relationship between communities and
local authorities.
There are no settlements on the given road section. The public hearing for EIA was
organised in August 2014 in the neighbouring village. The public hearing was advertised in
newspapers in two languages. Nine landowners were also invited to the public hearing.
Informal consultations were conducted with the people living in several winter residences
along the road at an early design stage. As a result, places for cattle crossing and turnoffs
have been identified.
Those residents were involved in the public hearing, conducted in the framework of other
projects of EBRD and ADB on the adjacent road segments. In October 2008 people from
neighbouring villages were provided with general information about the project and the
expected impact. In January 2009 the draft EIA and the Abbreviated Resettlement Plan was
presented in 10 communities along the alignment. General information on the project,
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schedules and impacts were discussed. The designers presented the Project that included
maps of the road and planned pedestrian crossings, junctions and cattle crossing locations.
Details of land plots needed for the Project were also discussed with the invited landowners.
According to the EIA the consultations were open, transparent and effective in engaging
affected people who raised concerns about the design, traffic safety (especially pedestrians),
animal crossings, noise protection and community cohesion.
There is currently no formal grievance or complaint mechanism set up, although, affected
people can easily identify the relevant authorities and can directly contact them via
telephone, mail or email to share their concerns and comments. Therefore, as part of the
SEP, a formal grievance mechanism has been proposed with an appropriate form to record
complaints, comments and questions about the project and an institutional framework with
designated roles and responsibilities to manage the process.
The Committee for Roads should encourage local authorities to appoint a Community
Liaison Officer (CLO) who will be responsible for the implementation of the SEP and the
grievance mechanism and who will act as a local focal point for affected people.
ZazAutoZhol based in Almaty is a recently formed body that will be the PIU.
The second public hearing of the Kurty Buribaytal road section was held on 30th March 2015.
The Committee for Roads and other organisations and institutions implementing the Project
were present to share the finalised EIA with the affected people and allow for feedback and
questions. The questions raised covered the issues around land acquisition and related
processes, cattle underpasses and other options for animal crossings and possible business
opportunities along the road after construction. Other environmental and social issues
included in the EIA were also discussed.
As part of SEP an on-going formalised structure of consultations and information disclosure
throughout project implementation has been proposed with adequate channels to reach the
identified stakeholders.
4. Summary of Environmental Benefits, Potential Adverse
Impacts, Mitigation and Management Measures
Climate and Air Quality
There are currently no residential dwellings or businesses adjacent to the road alignment
and therefore significant climate and air quality impacts are not expected. Nonetheless it has
been recommended that baseline air quality data is obtained prior to the start of construction
and that impacts are determined at all relevant receptors including those on Khusandaly
preserved area and any sensitive flora and fauna. It has also been recommended that
greenhouse gas emission and issues of impacts on the microclimate are identified.
Noise and Vibration
Noise and vibration impacts are not expected to be significant, however as above, it has
been recommended that a baseline noise survey is undertaken and that impacts are
determined at all relevant receptors. It has also been recommended that noise and vibration
associated with construction activities should be calculated.
Water and Wastewater
The designed road alignment crosses three river beds which are dry in summer but can
carry significant amounts of water and sediments in spring. There will be 8 bridges
constructed or reconstructed and 69 culverts to be built or upgraded to allow water to flow
under the road. Surface water runoff in spring may flood the south edge of the road after a
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particularly large amount of snow melt on the ground that froze in spring. To combat this,
orthogonal to the road, 2m high dykes are to be constructed to direct this water into a
designated culvert. Groundwater is relatively abundant in the project area, ranging in depth
from shallow aquifers in young sediments, to deep thermal waters.
A number of recommendations are proposed that include an assessment of water impacts to
include the sources, groundwater recharge rates (to avoid depletion of supplies) and how
wastewater will be discharged, the treatment methods and if there are any significant
impacts during construction. During operation and maintenance, an assessment of water
use is also recommended and how wastewater from rest areas will be managed.
Geology and Land
The project corridor runs on flat terrain parallel to the Tien Shan mountain range over its
entire length at a distance ranging from 10 to 30 km. The area’s geology is characterised by
thick accumulations of sediments of glacial and river origins. Korgankum sand massive is 212km north-east of the road, sediments and relief are formed by wind. Soil around the
alignment is poorly developed, protrudes to 20cm and is presented by slightly humid gray
soils.
A significant volume of topsoil will need to be removed for the alignment and diversion
routes. Care will be required for the preservation and reinstatement of top soil. Only licenced
borrow pits / quarries will be used.
It has been recommended that identification or potentially testing for contaminated soils
along the alignment should be undertaken and if the potential for the soil works to impact on
groundwater near the bridges needs to be assessed further. Implementation of monitoring
during the construction phase should take place. Consideration should also be given to
geohazards and if none are anticipated this should be confirmed.
Ecosystems and Flora & Fauna
It has been recommended that an assessment of whether there are a suitable number of
crossing points for wildlife (Jeyran) and herds (cattle) is undertaken. If required further
underpasses and gaps in the road should be introduced with appropriate road safety
measures that should be incorporated into road design. An ecologist should undertake preconstruction surveys to check for the presence of protected species. Any particularly
sensitive habitats should be identified and fenced off prior to the commencement of
construction. Vegetation clearance should not be undertaken during the bird breeding
season.
Waste Management
Inert materials will be re-used within the project. Hazardous material will be disposed of via
existing municipal waste management facilities. Timber from felled trees will be stored
outside the construction zone and sold to the public as firewood.
All materials and wastes stored should be quantified and have containment measures in
place such as for the storage of oils. All wastes should be safely disposed of.
Cultural Resources
The Archaeology Department has undertaken a study to identify all sites and objects that are
of cultural significance. The sites are far enough from the planned road to avoid resettlement
and the appropriate mitigation measures are identified by the Archaeology Department.
Although there are road accidents memorials located in the immediate vicinity of the road, of
which one is noted to be next to the road. They are not associated with the burials but mark
the place of the accident fatalities. It has been recommended that if necessary the
appropriate relocation processes are implemented with the informed consent of the owner of
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the memorial site. It is also recommended that fencing of sites is planned if necessary
ensuring that construction activities will not prevent access to sites or will damage the sites.
In addition, ‘Chance finds’ should be reported to the Institute of Archaeology and other
relevant institutions to undertake excavation and full archaeological assessment of the finds.
Visual Landscape
The road will introduce a raised structure in a relatively flat landscape, therefore the visual
impact should be assessed including tree felling and replacement, stockpiling and
reinstatement of bare ground. It is anticipated that visual impacts will not be significant as
there are no settlements on the road alignment and the sparse landscape with little or no
trees.
Other Considerations
Impacts should be determined if they are direct or indirect; short, medium or long term; or
permanent or temporary and cumulative impacts addressed. Furthermore impacts from
associated operations such as the concrete batching plant should be considered.
All permits and licenses are required to be obtained prior to commencement of activities for
which the permits are required.
5. Summary of Social Benefits Potential Adverse Impacts,
Mitigation and Management Measures
Community Health & Safety
There are anticipated to be no significant impacts on the local communities as there are no
residential dwellings or businesses adjacent to the road alignment. However, there could be
disruption caused during construction that includes limited access to roads, limited livestock
crossing and no alternative routes for connecting dirt roads while intersections are
constructed. Communities should not be cut off during construction and also when the road
has been built. To address these issues, the development of Construction Environmental
Management Plans (inclusive of traffic management plans) is necessary as well as Worker
Safety Action Plans to minimise accidents and incidents resulting from road works. There
will also be Emergency Preparedness and Response Plans that will be developed.
The widening of the road will reduce the number of traffic accidents which have resulted due
to the narrow width of the road which forces drivers to cross into the oncoming traffic lane to
overtake vehicles. However road safety measures for speed control, cattle crossings,
intersection and u-turns, cross sections, roadside hazards, traffic, pedestrians and
enforcement have been proposed for consideration by an independent road safety audit
report. The most appropriate and effective traffic and road safety measures presented in
Independent audit should be undertaken.
Occupational Health & Safety
To ensure effective contractor management, tender documents will be prepared that should
incorporate all mitigation measures that contractors should implement or be aware of. It has
also been recommended that a review of labour and social policies are undertaken and
incorporated into contractual arrangements with contractors. As part of the selection
process, criteria for past performance should be evaluated. Up to two contractors will be
appointed for the road construction and there will also be the appointment of project
management and project supervision roles in the future. In addition, suitably qualified
personnel should be appointed to monitor the different contractors undertaking construction
activities. It is recommended that independent audits are carried out to ensure that
environmental, health and safety standards are complied with and that social issues such as
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the terms and conditions of employment and the standards of the camp that is planned for
workers are compliant with EBRD requirements.
Construction ‘pads’ of which 18 are planned can serve as accommodation for workers,
although it was reported that one camp is planned. The worker numbers to be housed is
currently unspecified (potentially up to 500) and the location is currently unknown. The
workers’ camp will be compliant with International Finance Corporation (IFC) standards. It is
stated that the labour force will come from the closest towns and villages. It is recommended
that a due diligence investigation for all security personnel is conducted to make sure they
have appropriate licensing, experience and training for security contractors.
It has also been recommended that an integrated Occupational Health and Safety Plan that
is compliant with national legislation, monitoring and management systems are in place.
Land acquisition and resettlement
Physical and economic displacement is not expected as a result of the Project, however a
30 m right of way will be acquired along the road. The majority of land plots are state owned,
but 9 affected land plots are privately owned. The akimat has acquired official data from the
Land Registry and has started consultations with affected landowners to inform them about
the Project and potential impacts. The land that will be acquired is used as pasture land for
livestock rearing and not used for agriculture. There is no resettlement or land acquisition
plan prepared as there are only 9 landowners and the economic impacts of land acquisition
are not significantly adverse. The land acquisition process will be undertaken centrally by the
Akimats including the valuation of land, compensation payments and consultation with
landowners. Land acquired for temporary use for construction pads and other facilities will
be re-cultivated, cleaned and returned to the original owner.
Other Socio-Economic Considerations
The existing and planned off-ramps give access to the field roads that connect the Project
road to Almaty-Bishkek highway (south) and Korgankum sand massive (north) used for
storage of hay and the winter residence of cattle herds. The southwards roads have several
small winter farms along them. It is recommended that further information is provided to
demonstrate that none of the isolated communities near to the road will be cut off by the new
rehabilitated road. There are several isolated properties, although none are directly along
the road.
Gender impacts of the project are minimal. The key issues identified relate to the workers’
accommodation and its impacts on local communities and neighbouring settlements. The
appearance of workers’ accommodation often induces the influx of workers that might lead
to harassment, the spread of prostitution and Sexually Transmitted Infections (STIs) in the
area. A strict code of conduct will be enforced to avoid any adverse impacts on women. It is
recommended that women’s employment opportunities on the Project and the related
infrastructure is supported. In case of significant numbers of resident female workers and
employees, the workers’ camp should provide separate facilities for men and women to
avoid any unwanted contact or attention. The engagement of local women and men in
employment is encouraged.
It is considered that it is unlikely that any vulnerable groups will be directly impacted by the
Project. The only people that might be vulnerable are the herders who reside and work –
both formally and informally – on nearby farms. The influx of migrant workers might escalate
the vulnerability of women, though, based on local experts, it is unusual for migrant workers
to target the construction industry for employment. People living with disabilities or other
health issues and the elderly might be more vulnerable to the increased noise and dust
resulting from construction activities, though there are no settlements in the immediate
vicinity of the road.
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6. Communications
6.1
Stakeholder Engagement Plan
A Stakeholder Engagement Plan (SEP) has been prepared for the Committee for Roads (the
Client), within the Ministry of Investment and Development of the Republic of Kazakhstan
identifying relevant stakeholders, defining communication channels and plans regarding the
reconstruction of the Kurty-Buribaytal Road section 2214-2295 km part of the Center-South
Corridor that links Astana to Almaty.
The SEP aims at summarising the methods, procedures, policies and activities that will be
implemented by the Client to inform stakeholders in an inclusive and timely manner about
the potential impacts of the Project.
The SEP contains a stakeholder identification table where all relevant stakeholders are
identified with the most appropriate communication channels and strategies, information
disclosure requirements and grievance processes that will be adopted. If there are
stakeholders who are not included in the SEP they can get in contact with the Client to
receive information about the Project and be added to the stakeholder engagement
programme.
The SEP includes a programme of immediate consultation and engagement activities
required to address current stakeholder concerns, as well as regular consultation and
disclosure activities throughout the project life cycle. In addition the SEP has a grievance
mechanism, the details of which are provided in the next section.
6.2
Grievance Mechanism
A grievance mechanism will be implemented to ensure that the Client is responsive to any
concerns and complaints particularly from affected stakeholders and communities. Special
care will be focused on the training of the designated staff involved in the management of
the grievance mechanism. This grievance mechanism covers both employees and nonemployees (i.e. affected people and other relevant stakeholders).
Any comments or concerns can be brought to the attention of the company verbally or in
writing (by post or e-mail) or by filling in a grievance form included in the SEP. The grievance
form will be made available in the office of local administration, schools, community centres
and other public places that are easily accessible for all relevant stakeholders, alongside
with a description of the grievance mechanism. Grievance forms can then be submitted to
the contact details provided in Section 6.3.
All grievances will be:
■
Acknowledged within 14 working days
■
Responded to no later than within 30 working days
Specifically nominated and trained members of staff will record grievance information in a
grievance log. This will include:
■
Stakeholder name and contact details
■
Details of the grievance and how and when it was submitted, acknowledged, responded
to and closed out
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Individuals can request the right to have their name kept confidential and this mechanism
does not preclude the right for stakeholders to process grievances through other judicial
means.
6.3
Contacts
Contact details and responsibilities for SEP implementation are as follows: <<Please provide
details below>>
Name:
Title:
Telephone:
Address:
Email:
Website:
The local authorities and the CLO will collate any comments and feedback associated with
this project and will document these.
All comments received will be reviewed in accordance with the requirements set out in the
SEP. All communications will be reviewed for the feasibility to make changes to satisfy the
request and interest and the communicator will be informed of the outcome.
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