Planning & Development Board Government of the Punjab Punjab Clean Air Program (PCAP) Stakeholder Engagement Plan (SEP) February 2025 Coordination & Monitoring Unit (PCAP) Punjab Resource Management & Policy Unit Planning & Development Board 1 2 1. Contents 1. Introduction ........................................................................................................................................................4 1.1. Project Description: ....................................................................................................................................4 2. Objective/Description of SEP..............................................................................................................................5 3. Stakeholder Identification and Analysis: ............................................................................................................5 3.1. Methodology ..............................................................................................................................................5 3.2. Affected parties ..........................................................................................................................................6 3.3. Other interested parties .............................................................................................................................7 3.4. Disadvantaged / vulnerable individuals or groups .....................................................................................8 4. Stakeholder Engagement Program.....................................................................................................................9 4.1. Summary of stakeholder engagement done during project preparation ..................................................9 4.2. Summary of project stakeholder needs and methods, tools and techniques for stakeholder engagement......................................................................................................................................................... 10 4.3. Proposed strategy to incorporate the views of vulnerable groups ......................................................... 14 5. Resources and Responsibilities for implementing stakeholder engagement ................................................. 15 5.1. Implementation Arrangements and Resources ...................................................................................... 15 6. Grievance Mechanism ..................................................................................................................................... 16 6.1. Description of Grievance Mechanism (GM) ............................................................................................ 16 7. Monitoring and Reporting ............................................................................................................................... 19 7.1. Summary of how SEP will be monitored and reported upon.................................................................. 19 7.2. Reporting back to stakeholder groups .................................................................................................... 20 Annex 1: Details of Stakeholder Consultations ....................................................................................................... 21 Annex 2: SEP Budget Table ...................................................................................................................................... 24 Annex 3. Sample Table: Monitoring and Reporting on the SEP .............................................................................. 25 3 1. Introduction 1.1. Project Description: Air pollution poses a chronic health threat in Punjab and has become a national and provincial priority. The Government of the Punjab (GoPb) has started to lay the foundation for improved air quality management (AQM) planning and governance, which are essential building blocks for reducing air pollution. Policies and plans such as the 2017 Smog Control Policy, the 2022 Health Advisory System for Critical Air Pollution Events, the 2023 Clean Air Policy and Action Plan, and the new 2024 Smog Mitigation Action Plan demonstrate GoPb's commitment to improving air quality. The plans focus on abating PM 2.5 in the transport, environment agriculture, industry, energy, and municipal sectors, while promoting public awareness and engagement. The Punjab Clean Air Program’s (PCAP), objective is to strengthen air quality management and reduce emissions from targeted sectors across Punjab. The Program will be focused on managing road transport, industrial and agriculture emissions. This operation entitled the “Punjab Clean Air Program (PCAP)� will support the government’s plans to curb emissions across priority sectors, viz. transport, industries and agriculture, with studies in the industry.   PCAP will use a hybrid approach that combines the World Bank’s PforR and IPF instruments. The PCAP PforR Program of US$280 million aims to strengthen AQM and reduce emissions from targeted sectors. It will achieve these objectives through three results area across sectors to tackle air pollution sources by 2035: (i) Air Quality Management Governance and Awareness Raising, (ii) Transport Sector Abatement Measures, and (iii) Agriculture and Industry Sector Abatement Measures. The IPF component of US$20 million will support the technical assistance and studies required to facilitate Program implementation, and design interventions. A full list of activities under this component is included in the table below: Item Description Study to determine business To determine appropriate business models for e-bus deployment in Punjab. model for e-buses as Technical feasibility studies are already underway under the government program approved by T&MD Buyback scheme Consultancy service to design buyback and disposal scheme for polluting vehicles, with detailed stakeholder consultations Battery waste management Consultancy service to develop battery waste management rules and identify strategies for ecosystem development Study on Technical and Legal Consultancy services to develop legal, financial and technical framework for component for two-wheelers inspection and emission certification of two wheelers inspections Electric two- and three- TA/consultancy to design electric two and three-wheeler financing facility wheeler adoption 4 Carbon credits End-to-end process for carbon credits due to GHG emissions reductions from the shift to cleaner vehicles Institutional strengthening The component will support institutional strengthening for transport sector and (transport) its allied agencies with a focus on curbing road transport emissions, bus procurement and contract management, and road safety Industry Detailed Study Mapping and Assessment of Air Pollution Causing Industry in Lahore and Adjacent Districts and Designing of Mitigation Strategies Other studies Any other studies to support Program implementation as necessary Staffing and miscellaneous Staff salaries and miscellaneous expenses, aligned with the institutional Program implementation arrangements described below will also be supported via the IPF component. costs The PforR component of PCAP is being prepared under the World Bank’s PforR Policy, while the IPF component is being prepared under the World Bank’s Environment and Social Framework (ESF). This SEP has been prepared in line with the ESF Environmental and Social Standard 10 (ESS10) for the IPF component of PCAP only. 2. Objective/Description of SEP The overall objective of this SEP is to define a program for stakeholder engagement, including public information disclosure and consultation throughout the entire program cycle. The SEP outlines the ways in which the PCAP Implementing Agencies will communicate with stakeholders and includes a mechanism by which people can raise concerns, provide feedback, or make complaints about the project and any activities related to the project. The SEP specifically emphasizes methods to engage groups considered most vulnerable and that are at risk of being left out of project benefits. 3. Stakeholder Identification and Analysis: 3.1. Methodology In order to meet best practice approaches, the project will apply the following principles for stakeholder engagement: • Openness and life-cycle approach: Public consultations for the project(s) will be arranged during the whole life cycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation. 5 • Informed participation and feedback: Information will be provided to and widely distributed among all stakeholders in an appropriate format; opportunities are provided for communicating stakeholder feedback, and for analyzing and addressing comments and concerns. • Inclusiveness and sensitivity: Stakeholder identification is undertaken to support better communications and build effective relationships. The participation process for the projects is inclusive. All stakeholders at all times are encouraged to be involved in the consultation process. Equal access to information is provided to all stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention is given to vulnerable groups that may be at risk of being left out of project benefits, particularly women, the elderly, persons with disabilities, displaced persons, and communities, and the cultural sensitivities of diverse ethnic groups. • Flexibility: If social distancing, cultural context (for example, particular gender dynamics), or governance factors (for example, high risk of retaliation) inhibits traditional forms of face-to-face engagement, the methodology should adapt to other forms of engagement, including various forms of internet- or phone- based communication. In the context of the Punjab Clean Air Program (PCAP), effective stakeholder engagement is essential for ensuring the successful implementation of the program’s initiatives. Various stakeholders have interests, responsibilities, or impacts on the program's activities, and their involvement needs to be carefully managed to foster cooperation and minimize conflicts. The following stakeholders have been identified and analyzed for the IPF component. These stakeholders include affected parties (as defined in section 3.2), other interested parties (as defined in section 3.3) and disadvantaged/vulnerable individuals or groups (as defined in section 3.4). 3.2. Affected parties Affected parties include institutions, local communities, community members, and other parties that may be subject to direct impacts from the Project. An initial identification of individuals and groups who fall within this category is below. This list is not exhaustive, and further identification will be done at the commencement of the IPF activities: Table 1 List of Affected Parties Sector of Assessment/Support Details Study to determine business • Government departments such as Transport & Masstransit model for e-buses Department (T&MD), Punjab Masstransit Authority (PMA), Punjab Transport Company (PTC) • Staff of relevant government departments who will operate e- buses and associated infrastructure • Urban communities / public transport users Consultancy service to design • Relevant government departments who will implement the buyback scheme for polluting buyback scheme, e.g. T&MD vehicles • Government entities operating vehicles eligible for buyback • Owners of private polluting vehicles • Commercial entities operating polluting vehicles • Entities/companies who will provide services for the decommissioning of polluting vehicles. Consultancy service to develop • Government departments generating battery waste e.g. T&MD 6 battery waste management rules • Private sector entities generating battery waste and identify strategies for • Battery recycling companies ecosystem development • Private and commercial users of e-vehicles and solar systems Study on Technical and Legal • Relevant government departments who will implement component for two-wheelers inspections and financing program inspections. • Users of regular 2 wheelers facing inspection • Individual potential users of electric two and three wheelers TA/consultancy to design electric • Two and three wheeler fleet operators two and three-wheeler financing • Financial Institutions facility. End-to-end process for carbon • Government departments who can claim and trade carbon credits due to GHG emissions credits reductions from the shift to • Private entities who can sell carbon credits cleaner vehicles • MRV companies Mapping and Assessment of Air • Small & Medium Industrial units operating boilers furnaces and Pollution Causing Industry in power systems Lahore and Adjacent Districts and • Workers and Surrounding communities of above industrial units Designing of Mitigation Strategies • Brick kiln owners • Manufacturers/providers of fuel alternatives • • Other studies • To be identified at the commissioning of other studies 3.3. Other interested parties The projects’ stakeholders also include parties other than the directly affected parties. An initial identification of individuals and groups who fall within this category is below. This list is not exhaustive, and further identification will be done at the commencement of the IPF activities: Table 2 List of Other Interested Parties Sector of Assessment/Support Details Study to determine business model • Urban communities and public at large for e-buses • Private public transport operators (buses, vans, taxis, rikshaws etc.) • Government departments providing associated facilities • Relevant CSOs and NGOs working on clean air activities, accessibility for women and disabled etc. • Consultancy service to design • Urban communities and public at large buyback scheme for polluting • Financial institutions vehicles • Used parts dealers and recyclers • Government departments providing associated facilities • Relevant CSOs and NGOs working on clean air activities and advocacy • Mass media Consultancy service to develop • Public at large battery waste management rules • E-bus and e-vehicle manufacturers and identify strategies for ecosystem • Academia/research institutions working on battery waste management development • Government departments providing waste management services 7 • Private e-waste management companies • Government departments providing associated facilities • Relevant CSOs and NGOs working on environmental issues • Mass media Study on Technical and Legal • Public at large component for two-wheelers • Electric two and three wheeler manufacturers inspections. • Ride sharing and delivery services (FoodPanda Bykea, InDrive etc.) • Relevant CSOs and NGOs working on environmental issues TA/consultancy to design electric • Mass media two and three-wheeler financing facility End-to-end process for carbon • Multi-lateral and bi-lateral agencies supporting carbon credits trading credits due to GHG emissions • Government departments providing associated activities reductions from the shift to cleaner • Relevant CSOs and NGOs working on environmental issues vehicles • Mass media Mapping and Assessment of Air • Manufacturers of boilers, furnaces and power systems Pollution Causing Industry in Lahore • Relevant government departments (PEECA, PSIC, Industries Dept, EPA and Adjacent Districts and Designing etc.) of Mitigation Strategies • Financial Institutions • Academia and research institutions • • Other studies • To be identified at the commissioning of other studies 3.4. Disadvantaged / vulnerable individuals or groups Within the Project, the vulnerable or disadvantaged groups may include but are not limited to the following: Vulnerable groups within the communities affected by the project will be further confirmed and consulted through dedicated means, as appropriate. Description of the methods of engagement that will be undertaken by the project is provided in the following sections. Table 3: List of Disadvantaged/Vulnerable Individuals and Groups Vulnerable group Barriers to Accessing Information or Potential Project Benefits Representatives/Partners Women, specifically: Limited mobility due to social norms and Local women’s rights organizations, • Women using public transport; risk of SEA/SH, restricted access to women led civil society • Women with the potential to information channels, and barriers to organizations, societies buy and use electric 2 accessing finance due to stringent representing female students, wheelers; requirements of banks community leaders • Persons with disabilities Physical accessibility issues, limited income, Local NGOs, Disabled Persons’ social stigma, reduced access to financial Organizations (DPOs), Social and informational resources, and limited Welfare & Bait-ul-Maal tailored support for accessing public Department services Students with the potential to buy Barriers to accessing finance due to Students’ in colleges and and use electric 2 wheelers stringent requirements of banks universities Low-income individuals: Financial barriers to accessing subsidies, Local level community 8 • With polluting private vehicles lack of access to information, limited organizations, community centers, • Operating two and three awareness of public support services. local NGOs wheelers for income generation Individuals at risk for losing Lack of access to information, limited Workers unions/organizations, livelihoods due to Change in awareness of public support services. local NGOs and CSOs. business practices of: • commercial enterprises using polluting vehicles • polluting industrial units • informal battery recycling enterprises. Religious, ethnic, sexual and Language barriers, social exclusion, Social Community based organizations, genderminorities stigma, discrimination and marginalization NGOs and CSOs. in accessing public services, and limited engagement with air quality improvement programs 4. Stakeholder Engagement Program 4.1. Summary of stakeholder engagement done during project preparation Consultations with relevant institutions, program affected peoples, experts, and beneficiaries are essential in the proper planning and preparation of development projects and programs, to ensure effective identification and assessment of environmental and social effects, and to recommend measures to improve environmental and social management capacity. During project preparation, a multi-stakeholder workshop was held in Lahore on January 30, 2025. The workshop was attended by 35 stakeholders from government, academia, the private sector, and civil society representing citizens, women and disabled as shown below. A detailed list of participants is provided in Annexure 1: • Government Departments: Planning & Development Board, Transport & Masstransit Department, Agriculture Department, Environmental Protection and Climate Change Department, Energy Department, Industries Department, Punjab Energy Efficiency and Conservation Agency, Special Education Department, Social Welfare & Bait-ul-Mall Department, Lahore Development Authority, Punjab Small Industries Corporation. • E&S Specialists from World Bank Financed Programs and Projects: PIUs staff from the Punjab Green Development Program (PGDP), Punjab Cities Program (PCP), Punjab Affordable Housing Program (PAHP), Punjab Resilient and Inclusive Agriculture Transformation Project (PRIAT) • Civil Society & NGOs: WWF Pakistan, Pakistan Air Quality Initiative (PAQI). • Private Sector: Pakistan Agricultural Machinery and Implements Manufacturers (PAMIMA), Dawood Agro Company (progressive rice farmer) • Academia: Lahore University of Management Sciences (LUMS) Major points raised by the participants can be summarized as follows: • Feedback on Program Design: CSOs and NGO representatives highlighted that the expansion of air quality monitoring stations must be scientifically planned to ensure comprehensive coverage and real- 9 time public access. Multiple stakeholders including government, academia, NGOs and private sector are conducting AQM activities, but are working in silos. Bringing them to one platform is essential. Institutional strengthening of the EPCCD and technical capacity building is essential for effective AQM and monitoring. Private sector representatives in agriculture emphasized that super seeders should be provided in targeted areas / hot spots for crop burning such as Gujranwala Division and Lahore Division which grow 50% of the rice crop of Punjab. This will ensure maximum positive impact to air quality. To encourage production of agricultural machinery to combat crop burning, the program may also consider providing incentives to machinery manufacturers. • Stakeholder Engagement: Feedback received from CSOs and government largely focused on ensuring transparency and accountability of the Program through citizens’ engagement and monitoring. Ensuring that air quality data is real-time accessible and actionable for both policymakers and the public is crucial for behavioral change. • Inclusion of Vulnerable Groups: Government stakeholders from EPCCD and the Social Welfare Department stressed on the importance of ensuring the public transport infrastructure is accessible for disabled persons and the relevant government legislations on ensuring access of public facilities to vulnerable groups are implemented under PCAP activities. Besides the aforementioned formal workshop regular consultation meetings have been conducted between various departments and PCAP CMU. Separate formal meetings were also held with Senior Minister, Punjab and Minister for Transport & Masstransit Department to apprise them about the project design and seek their guidance to further improve it. 4.2. Summary of project stakeholder needs and methods, tools and techniques for stakeholder engagement The Punjab Clean Air Program (PCAP) recognizes the importance of active and meaningful engagement with all relevant stakeholders to ensure the program's successful implementation, sustainability, and equitable outcomes. Effective stakeholder engagement is essential for building trust, addressing concerns, and fostering collaboration. The Stakeholder Engagement Plan below outlines the engagement process, methods, including sequencing, topics of consultations and target stakeholders. The strategy for stakeholder engagement will ensure that all relevant stakeholders, especially disadvantaged and vulnerable groups are consulted during the IPF Component TA assessments, and their feedback and specific needs are incorporated into the Program activities design to ensure they are accessible, inclusive and sustainable. The World Bank and the Borrower do not tolerate reprisals and retaliation against project stakeholders who share their views about Bank-financed projects. Table 4: SEP Summary Table Project stage Target stakeholders Topic of consultation Method Responsibilities Frequency/ / message used Timeline Preparation Government and Present the program, Formal PCAP-CMU Ongoing during Stage institutional receive feedback on meetings preparation stakeholders program activities (Completed) and consult on key One-on-one risks interviews 10 Project stage Target stakeholders Topic of consultation Method Responsibilities Frequency/ / message used Timeline Government; Present the program, Consultative PCAP-CMU Once during institutions; private receive feedback on Workshop preparation sector; NGOs and program activities (Completed) CSOs representing and consult on key general public and risks vulnerable groups. Students, NGOs and Present the program, Virtual PCAP-CMU Once during CSOs representing receive feedback on Consultative preparation general public and program activities Workshop vulnerable groups. and consult on key risks Implementation Government Design of transport Formal Consultants Ongoing while Stage departments such as studies; receive meetings, conducting conducting Transport & feedback and consult one-on-one studies studies Masstransit on key risks interviews Department (T&MD), Punjab Masstransit Authority (PMA), Punjab Transport Company (PTC) Staff of relevant Design of transport Focus Group Consultants Once while government studies; receive Discussions conducting conducting study departments who will feedback and consult studies operate e-buses and on key relevant risks associated infrastructure Vulnerable groups Design of transport Consultative PIU-T&MD; Once while including disabled, studies; receive workshops; Consultants conducting study women, students; feedback and consult FGDs conducting NGOs and CSO on key relevant risks studies representing for inclusion in design vulnerable groups of activities Urban Communities; Design of transport Consultative PIU-T&MD; Once while users of public studies; receive workshops Consultants conducting study transport; users of feedback and consult conducting electric vehicles on key relevant risks studies for inclusion in design of activities Private sector Design of transport Consultative PIU-T&MD; Once while relevant to transport studies; receive workshops; Consultants conducting study studies; feedback and consult FGDs conducting on key relevant risks studies 11 Project stage Target stakeholders Topic of consultation Method Responsibilities Frequency/ / message used Timeline Academia Design of transport Consultative PIU-T&MD; Once while studies; receive workshops; Consultants conducting study feedback and consult FGDs conducting on key relevant risks studies Relevant government Development of Formal PCAP-CMU; Ongoing while departments such as battery waste meetings, Consultants conducting EPCCD, EPA etc. management rules one-on-one conducting studies and strategies for interviews studies ecosystem development Private sector Receive feedback on Consultative PCAP-CMU; Once while relevant for battery battery waste workshop; Consultants conducting study waste management management FGDs conducting ecosystem design, studies consult on key relevant risks NGOs and CSOs with Receive feedback on Consultative PCAP-CMU; Once while relevance to battery battery waste workshop; Consultants conducting study waste management management FGDs conducting ecosystem design, studies consult on key E&S relevant risks Informal sector Consult on key One-on-one PCAP-CMU; Once while involved in battery relevant risks interviews; Consultants conducting study recycling; and FGDs conducting workers studies Relevant government Design of study on Formal PCAP-CMU; Ongoing while departments such as Mapping and meetings, Consultants conducting PEECA, PSIC, Assessment of Air one-on-one conducting studies Industries etc. Pollution Causing interviews studies Industry and Designing of Mitigation Strategies ;receive feedback and consult on key relevant risks Private sector; Design of study on One-on-one PCAP-CMU; Once while industrial units Mapping and interviews; Consultants conducting study operating boilers, Assessment of Air FGDs conducting power systems and Pollution Causing studies furnaces; brick kiln Industry and owners; Designing of manufacturers/provid Mitigation Strategies ers of fuel ;receive feedback and 12 Project stage Target stakeholders Topic of consultation Method Responsibilities Frequency/ / message used Timeline alternatives; workers consult on key of these industrial relevant risks units and surrounding communities Government Receive feedback on One-on-one PCAP-CMU; Once while departments who can end-to-end process interviews; Consultants conducting study claim and trade for carbon credits consultative conducting carbon credits; due to GHG workshop studies private entities who emissions reductions can sell carbon from the shift to credits; MRV cleaner vehicles; companies consult on key relevant risks Government Presentation of Draft Consultative PCAP-CMU; One workshop departments; Study Findings; workshop relevant for each sector/ institutional receive feedback departments; study stakeholders; private consultants sector and academia. Communities; Presentation of Draft Consultative PCAP-CMU; One workshop vulnerable groups; Study Findings; workshop relevant for each sector/ NGOs and CSOs receive feedback departments; study consultants General public and Program information Website, PCAP-CMU; Ongoing during vulnerable groups and GRM mass media, implementation social media; brochures etc. (with focus on accessibility for vulnerable groups Post Government Information on study Launch PCAP-CMU; One event for Implementation departments; outcomes; next steps event relevant each sector institutional departments; stakeholders; private consultants sector; academia; NGOs and CSOs; community and representatives from vulnerable groups General public and Public dissemination Website, PCAP-CMU; Ongoing during vulnerable groups of study outcomes mass media, relevant Program and GRM social media; departments implementation brochures 13 Project stage Target stakeholders Topic of consultation Method Responsibilities Frequency/ / message used Timeline etc. (with focus on accessibility for vulnerable groups General public; Citizen feedback Citizen PCAP-CMU and Yearly during private sector; feedback relevant Program academia; NGOs and surveys departments implementation CSOs; community and vulnerable groups 4.3. Proposed strategy to incorporate the views of vulnerable groups The program will seek the views of vulnerable groups such as women, disabled, low income households, rural communities, workers of impacted industries, and minorities through prioritized engagement. These groups will be reached through community meetings held in accessible locations and focused group discussions with gender and disability inclusivity. To ensure full participation, materials will be provided in local languages and in formats accessible to the illiterate or disabled. A safe space would be created for open dialogue, especially on sensitive issues. The program will also leverage partnerships with local NGOs and CSOs that have experience working with these groups to facilitate meaningful engagement. The program will seek the view of vulnerable groups through the following methods: • Community meetings: organizing meetings at the community level to facilitate direct interaction and feedback. • Focus Group Discussions: conducting discussions with smaller, targeted groups to delve deeper into specific issues and concerns. • Individual Interviews: engaging in one-on-one interviews, particularly for those unable to attend group sessions. • Surveys: distributing written or digital surveys to gather a broader range of responses. • Accessible workshops: hosting workshops that are physically and logistically accessible to all, including persons with disabilities. • Social Media and Online Platforms: utilizing digital platforms for engagement, especially beneficial for tech-savvy youth and those with limited mobility. • Collaboration with Local NGOs and CSOs: partnering with NGOs that have existing relationships with these groups to facilitate engagement. The following measures will be taken in order to remove obstacles to full and enabling participation / access to information: 14 • Provision of Information in Local Languages: translating materials into local languages to ensure understanding. • Accessible Formats: offering information in braille, large print, and audio formats for those with visual or hearing impairments, and pictorial guides and audio-based explanations for the illiterate. Additionally, ensuring the availability of printed signage and flyers for those without digital access. • Convenient and Accessible Venues: choosing meeting locations that are easily reachable and accessible to persons with disabilities and women who may have limited mobility due to cultural norms. • Flexible Timing: scheduling sessions at times suitable for participants, considering work and caregiving responsibilities. • Transportation Support: arranging transportation for remote or mobility-challenged individuals. • Cultural Sensitivity Training for Facilitators: ensuring that those leading sessions are trained in cultural sensitivity and inclusivity • Female inclusion: ensuring enough female staff is available to hold separate sessions for women. • Regular Updates and Feedback Mechanisms: using multiple channels, including community notice boards, to disseminate information and collect feedback. 5. Resources and Responsibilities for implementing stakeholder engagement 5.1. Implementation Arrangements and Resources The PCAP-CMU will be in charge of ensuring stakeholder engagement activities are being carried out as per the SEP. The entities responsible for carrying out stakeholder engagement activities are the relevant government departments involved in the studies/assessments (T&MD, PSIC, EPCCD, EPAetc.) and the consultants/firms hired to conduct the studies/assessments. The Social Specialists within the PCAP-CMU and PIU, or E&S focal points in the relevant government departments will lead the stakeholder engagement activities, with the support of the consultants/firms where needed. The overall responsibility for SEP implementation lies with the Program Director, PCAP-CMU who will ensure integration with the project’s environmental and social management strategies. Stakeholder feedback and engagement outcomes will be systematically documented and reviewed to inform project adjustments and decision-making.1 The stakeholder engagement activities will be documented through: • Detailed records of all engagement activities, including minutes of meetings, attendance lists and feedback received. • Regular reports summarizing the stakeholder feedback, concerns, and suggestions. • Documentation of how stakeholder input has been incorporated into program planning and decision- making. • Ongoing updates in program reports and communications to ensure transparency and accountability in stakeholder engagement. The budget estimate for implementing SEP is 472,000 USD. The budget breakdown can be found in Annex 2. A communication and outreach firm will separately be hired and will also assist in implementing the SEP. 1Integrate provisions for the mobilization of technical expertise for safe consultations with vulnerable groups, and/or on sensitive topics, as and when needed. 15 6. Grievance Mechanism A Grievance Mechanism is a system that allows not only grievances, but also queries, suggestions, positive feedback, and concerns of project-affected parties related to the environmental and social performance of a project to be submitted and responded to in a timely manner. 6.1. Description of Grievance Mechanism (GM) A robust grievance mechanism is an essential part of the Punjab Clean Air Program (PCAP) to address concerns or complaints raised by stakeholders during the project's implementation. The mechanism ensures that stakeholders have a clear, accessible way to voice their concerns and that these are resolved in a timely and fair manner. The proposed grievance mechanism for the PCAP includes the following elements: Table 5: Illustrative Table on the GM Steps Step Description of process Timeframe Responsibility GM Existing GMs are available at the provincial and Ongoing PCAP-CMU, implementation department that may be used by the public to PIU and IAs structure submit grievances. These include the Punjab Portal, Provincial Ombudsman, and separate mechanisms for each of the IAs. A detailed analysis of these GMs is provided in the PCAP ESSA. A GM implementation structure to adequately address and monitor all PCAP related grievances will be established as follows: A Grievance Redress Committee will be formed at the PCAP-CMU, including the PCAP-CMU Program Director, PCAP Focal Points for IAs, Social & Gender Specialist of CMU/GRO, Social & Gender Focal Points from IAs and co-opted members from relevant government departments as required. The Social & Gender Specialist at the PCAP-CMU will be responsible for overall operation of the GM and will be the Grievance Redressal Officer (GRO) of the program. A sub GRC will be formed at T&MD. Social & Gender Specialist at T&MD PIU will be responsible for operation of the GM at PIU level. Grievance uptake Grievances can be submitted via the following Ongoing PCAP-CMU, existing channels. In addition to these, the PIU and IAs 16 Step Description of process Timeframe Responsibility PCAP-CMU may set up additional channels to receive grievances. • Telephone hotline: Provincial 0800 02345 EPCCD 1373 PMA 1762 PTC 111-582-111 Agriculture 0800-15000 and 0800-29000 • WhatsApp EPCCD 0335-9232227 T&MD 0321-0980980 • E-mail EPCCD ddisepa@punjab.gov.pk PTC complaints@ptc.gop.pk • E-Portal Provincial: www.punjab.gov.pk Ombudsman: https://ombudsmanpunjab.gov.pk/register- complaint-residential-pakistanis) • SMS Agriculture 0304-4000172 • In-person at the physical offices of IAs • Grievance or suggestion boxes located at PCMU and PIU • Social media of PCAP and IAs • Tablet/smartphone application – Go Punjab App • Online form on the PCAP or P&D website. Sorting, Any complaint received is forwarded to the Upon receipt PCAP-CMU processing PCAP-CMU GRO and logged in a centralized of complaint GRO database, with a unique reference number assigned to each complaint. This will allow for tracking and transparency throughout the resolution process. Grievances are then categorized and referred to the relevant GFP or GRC for resolution. Grievances will be categorized into the following complaint types: Low; Medium; and High priority. Low priority: these typically involve minor issues that do not significantly impact the overall program or the complainants’ well- being. Examples could include minor administrative errors, delays in non-critical 17 Step Description of process Timeframe Responsibility services, or small-scale individual grievances that can be resolved locally, with the GFP, without extensive intervention. Medium priority: these are more serious than low priority complaints but do not pose immediate or significant risks to the program’s success or stakeholders’ rights and interests. These might include disputes over employment terms, moderate environmental or social impacts, or concerns about program implementation aspects that affect a limited number of stakeholders. High priority: these are critical issues that require urgent attention and could significantly impact the program’s success and the well- being of stakeholders. Examples could include violation of the law of the land, corruption, GBV, SEA/SH (sexual exploitation, abuse and harassment), community rights, significant health and safety concerns, allegations of serious environmental or social harm; complaints regarding minorities, differently abled persons, transgender etc. Acknowledgement Receipt of the grievance is acknowledged to the Within 7 days GRO or GFPs and follow-up complainant via acknowledgement in writing of receipt (through letter, email, whatsApp etc.) . Depending on accessibility, the GRO may instruct the relevant GFP to convey acknowledgement Verification, Low and medium priority grievances may be Within 10 Grievance investigation, working days investigated and resolved directly by the GFP at Focal Persons, action for low and the IAs or the sub-GRC, in consultation with the PCAP-CMU medium; GRO. If the grievance is unable to be resolved, GRC, PIU sub- its priority is upgraded to high priority. specific GRC timeframe for High priority grievances are investigated and high priority resolved by the PCAP-CMU GRC. The GRC may set by PCAP- enlist PIU sub-GRC, and GFPs to assist in CMU GRC verification and identification. For all levels of grievance, the proposed resolution is formulated by the overseeing entity (varying depending on the grievance 18 Step Description of process Timeframe Responsibility priority), and the resolution is communicated to the complainant by the GRC/GFP where the complaint was first received. Monitoring and Data on complaints are collected in a dedicated Bi-annual PCAP-CMU evaluation grievance management system at the PCAP- reporting GRO CMU GRC. Grievance data is reported to the World Bank on a Bi-annual basis Provision of Feedback from complainants regarding their Post- PCAP-CMU feedback satisfaction with complaint resolution is resolution GRO collected through follow-up survey or interview call after the resolution process. Training Training needs for staff/consultants in the At the start of PCAP-CMU PCAP-CMU, PIU, IAs, and consultant firms are the program identified and addressed through regular and capacity-building workshops and on-the-job subsequently training programs, focusing on grievance as needed redress mechanisms, social engagement and environmental compliance. Appeals process The GM will also include a system for appeals. If Within 14 PCAP-CMU a complainant is unsatisfied with the resolution days of of the grievance, they will be able to lodge an appeal appeal, which can be escalated to the Secretary, P&D.. A GM accessible for project labor will be adopted as part of the Labor Management Measures in line with the requirements set out in ESS2 Labor and Working Conditions and provided in the ESCP. To address any complaints related to GBV/SEA/SH, the program will ensure that GBV related grievances received by the GRM are referred to relevant GBV service providers. Dedicated trained female staff will be appointed to receive and process GBV related complaints. Special considerations will be taken to ensure that the complainant’s identity is treated as privileged information, and the option to lodge the complaint anonymously will also be provided. Additionally, all GRM response teams will be trained on GBV, SEA and SH. Detailed protocols for receiving, managing and addressing complaints related to GBV/SEA/SH will be developed in the GBV/SEA/SH Action Plan under the P for R component and added to the GRM. 7. Monitoring and Reporting 7.1. Summary of how SEP will be monitored and reported upon The SEP will be monitored based on both qualitative reporting (based on progress reports) and quantitative reporting linked to results indicators on stakeholder engagement and grievance performance. 19 SEP reporting will include the following: (i) Progress reporting on the ESS10-Stakeholder Engagement commitments under the Environmental and Social Commitment Plan (ESCP) (ii) Cumulative qualitative reporting on the feedback received during SEP activities, in particular (a) issues that have been raised that can be addressed through changes in program scope and design, and reflected in the basic documentation such as the Project Appraisal Document, Environmental and Social Systems Assessment, or SEA/SH Action Plan, if needed; (b) issues that have been raised and can be addressed during program implementation; (c) issues that have been raised that are beyond the scope of the project and are better addressed through alternative projects, programs or initiatives; and (d) issues that cannot be addressed by the program due to technical, jurisdictional or excessive cost- associated reasons. Minutes of meetings summarizing the views of the attendees can also be annexed to the monitoring reports. (iii) Quantitative reporting based on the indicators included in the SEP. An illustrative set of indicators for monitoring and reporting is included in Annex 3. 7.2. Reporting back to stakeholder groups The SEP will be revised and updated as necessary during project implementation. Summaries and internal reports on public grievances, enquiries, and related incidents, together with the status of implementation of associated corrective/preventative actions will be collated by responsible staff and referred. Specific mechanisms to report back to the stakeholders include the following: • Annual Reports: An annual report will be prepared to provide a comprehensive overview of the program’s progress, the outcomes of environmental and social monitoring, and an analysis of the effectiveness of the stakeholder engagement strategy. This report will be made publicly available to ensure transparency. • Transparency and Public Access: Program data, including air quality measurements and progress reports, will be made publicly available on the project website or through other accessible platforms. This will help ensure transparency and allow stakeholders to track the progress of the program. 20 Annex 1: Details of Stakeholder Consultations A stakeholder engagement workshop and disclosure sessions of the Draft ESSA was conducted on 30 th January 2025 from 3-6pm at the Planning & Development Board AKS Auditorium. The agenda of the workshop, feedback received, and list of participants is provided below. Agenda: Time Session Responsibility/Presenter 3:00pm to 3:30pm Arrival and registrations P&D 3:30pm to 3:45pm Welcome by P&D Ahmad Rajwana Managing Director, PRMPU, P&D 3:45pm to 4:00pm Introduction to PCAP and Shafick Hoossein description of program activities – Senior Environmental Specialist & TTL P- PforR and IPF CAP World Bank 4:00pm to 4:30pm Presentation on Draft ESSA Mehrunisa Malik – Social Development Findings and Recommendations; Consultant World Bank and Stakeholder Engagement Plan Shafqat Khan – Environment Consultant World Bank 4:30pm to 5:15pm Feedback from stakeholders P&D and World Bank 5:15pm to 5:30pm Closing Remarks Ahmad Rajwana Managing Director, PRMPU, P&D 5:30pm Refreshments Feedback from Participants Comments/Questions Responses Mariam Shah – Pakistan Air Quality Initiative (PAQI) The recommendations from PAQI are PAQI is a CSO conducting research and awareness activities on appreciated and well received. air pollution in Pakistan. Our work is data centric and Bringing all relevant stakeholders on scientific. We appreciate that PCAP is giving attention to an board is important for PCAP and inclusive design and stakeholder engagement. measures will be taken to ensure this during the program. This will also be We have a set of recommendations (separately available) for ensured through the Stakeholder PCAP that include the following: Engagement Plan. • Air Quality Monitoring & Data Transparency – Expansion of monitoring stations must be scientifically planned to ensure comprehensive coverage and real-time public access. • Regulation of Industrial & Vehicular Emissions – Punjab must establish clear, enforceable limits on industrial and vehicular emissions to reduce PM2.5 pollution effectively. • Public Awareness & Stakeholder Engagement – Ensuring that air quality data is real-time accessible and actionable for both policymakers and the public is crucial for behavioral change. • Institutional Capacity for Air Quality Management – The 21 Environmental Protection & Climate Change Department (EPCCD) must be strengthened with technical expertise, funding, and enforcement mechanisms. PAQI stands ready to support the Punjab Clean Air Program by: • Providing independent data analysis to validate emissions inventories and air quality trends. • Contributing to policy development for air quality monitoring regulations. • Designing and implementing community engagement programs to enhance public awareness of air pollution risks. Sughra Kashif - Social Specialist PGDP All questions and comments were well • The program has many environmental and social risks. noted and responded to by the PCAP- How can it be categorized low risk? CMU team. • Site selection of e-bus depots should be very carefully done to ensure minimal E&S impacts. • Learnings from E&S activities and performance of PGDP must be taken into consideration and built upon for PCAP. • Will the design of the program be inclusive for disabled persons? • Which World Bank ESF standards are applicable for PCAP? • It must be ensured that bus depots have separate toilets for women and disabled persons. • Must ensure that periodic TPV of ESSA is conducted. Adil Farooq Khan - Progressive Farmer and CEO of Dawood Comments are well noted. Agro Company PCAP will focus on identified hot-spots I am the pioneer of rice mechanization initiative of Pakistan. for crop burning for maximum impact. For success and maximum impacts to air quality of super seeders, the initiative should be concentrated in targeted Due to limited resources, transplanters areas / hot-spots such as Gujranwala Division and Lahore are not supported by PCAP. However, Division which grow 50% of the rice crop of Punjab. they are part of the medium and long term plan under a project with ADB. To include unskilled labor, PCAP should consider including rice transplanter machines. This will also benefit women. PCAP should provide incentives for e-bikes manufacturing as well, as e-2 and 3 wheelers have a very usage. Irfan Gondal - DD Planning Social Welfare Dept . Disability inclusion plan will be prepared • Disabilities Act provides clauses on accessibility of public under PCAP. However they will only apply transport for disabled persons. The implementation needs to PCAP financed activities. to be ensured. • Will disability inclusion provisions under PCAP be 22 expanded to general transport as well? • There is no inclusion of disabled persons in the consultations, which is disappointing. Asif Bajwa Chairman PAMIMA Comments are received and well noted. Govt of Punjab is supporting purchase of agricultural Solar units will be provided to SMEs machinery by farmers on subsidized rates. Similarly solar under PCAP. Taxation is beyond the systems are being provided to farmers. None of these benefits purview of PCAP. are extended to manufacturers of agricultural implements. Please consider this. Sales and income tax exemptions for manufacturers of super seeders may also be considered. Rashid Ahmad – WWF Pakistan EP&CCD is implementing SOPs of e- Which department will prepare and implement the e-waste waste. rules? Hassam Ali – WWF Pakistan The SEP will include activities to bring There is a lot of activity on AQM by the government, private together all stakeholders involved in sector and NGOs. But they are all working in silos. How do we AQM. bring all of them together and focus on the hot-spots that PCAP may consider a platform or working have been identified? group on this. E-buses – will there be a separate infrastructure for e-buses? Participants List Sr.# Name Designation/ Department 1 Ahmad Rajwana Project Director PRMP 2 Mehrunisa Malik Social Development Consultant World Bank 3 Shafqat-Ullah Environmental Consultant- World Bank 4 Azher Uddin Khan Environmental Consultant World Bank 5 Noureen Arif Manager environment and social safeguards, Energy Department 6 Sughra Kashif DD Social Safeguards PGDP Environmental Specialist Punjab Small Industries Co-operation 7 Hina Ishaque (PSIC) 8 Rukhsana Shahid Environmental Specialist PMDFC 9 Shahid Imtiaz Consultant accounts PRMPU 10 Hira Ashraf Assistant Manager (Program)/ PEECA 11 Abid Bodla Member (ID) - P&D 12 Jamshed Bashir Assistant Director Special Education Department 13 M.Irfan Gondal DD(P), Social Welfare & Bait ul Maal Department 14 Aadil Farooq Khan CEO Dawood Agro company-Progressive farmer 15 Engineer Sajid Nasir DGA(F)P, Agriculture Department 23 16 Rashid Ahmad Manager, WWF Pakistan 17 Syed Hassam Ali Senior Officer-Sustainability and Climate Change WWF Pakistan 18 M.Ubaid Iqbal Director Environment LDA 19 Nasir Iqbal Assistant Chief P&E cell, Agriculture Department 20 Wasim M. Director (planning) Field Wing of Agriculture Department 21 Faisal Hafeez AD (AFD project) 22 Farah Said Department of Economics (LUMS) 23 Sadiq Ahmed PO (Consultancy I) P&D 24 Azhar Hussain Director Industries Department 25 Mariam Shah Communication Specialist Pakistan Air Quality Initiative (PAQI) 26 Raja Akshaf PO(ECA-IV), P&D 27 Saarya Haider DS(Dev.), Transport Department 28 Hassan Ahmed Assistant Manager/ PEECA Chairman - Pakistan Agricultural Machinery and Implements 29 Asif Bajwa Manufacturers (PAMIMA) 30 Abid Omar Founder - Pakistan Air Quality Initiative (PAQI) 31 Zeeshan Mustafa Maan Environment Specialist PRIAT, Agriculture Department 32 Name Unknown Environment Specialist PAHP 33 SPIU EPCCD 34 Rizwana Online participant 35 Noman Ashraf Online participant Annex 2: SEP Budget Table Times/ Unit costs Total costs Budget categories Quantity (USD) Years (USD) Remarks 1. Estimated Staff salaries* and related expenses 1a. Communications Specialist 1 19,000 5 95,000 1b. Travel costs for staff 1 5000 5 25,000 2. Consultations/ Participatory Planning, Decision-Making Meetings 2a. Stakeholder Workshops and community 1 15,000 5 engagement activities 75,000 24 2b. Launch Events for Study Findings 4 15,000 1 60,000 3. Communication campaigns 3a. Posters flyers etc. 1 15,000 1 15,000 3b. Media campaigns 1 10,000 5 50,000 4. Trainings 4a. SEP Training for IAs and Consultant Firms 2 5000 1 10,000 5. Beneficiary surveys 5a. Citizen Feedback Surveys 1 20,000 5 100,000 6. Grievance Mechanism 6a. Training of GM committees 1 2000 1 2000 6c. GM communication materials 1 10,000 1 10,000 6e. GM Information System (setting up or 1 5000 5 25,000 maintenance) 6f. Other GM Logistical Costs 1 5000 1 5000 TOTAL STAKEHOLDER ENGAGEMENT BUDGET: 472,000 *Note: Salary costs can be indicative Annex 3. Sample Table: Monitoring and Reporting on the SEP Key evaluation Specific Evaluation questions Potential Indicators Data Collection questions Methods GRM. To what • Are project affected parties raising • Usage of GM and/or Records from the extent have issues and grievances? feedback mechanisms implementing agency and project-affected • How quickly/effectively are the • Requests for information other relevant agencies parties been grievances resolved? from relevant agencies. provided with • Use of suggestion boxes accessible and placed in the inclusive means to villages/project raise issues and communities. grievances? Has • Number of grievances the implementing raised by workers, agency responded disaggregated by gender to and managed of workers and worksite, such grievances? resolved within a specified time frame. • Number of Sexual Exploitation, and Abuse/Sexual Harassment (SEA/SH) cases reported in the project areas, which were referred for health, 25 social, legal and security support according to the referral process in place. (if applicable) • Number of grievances that have been (i) opened, (ii) opened for more than 30 days, (iii) resolved, (iv) closed, and (v) number of responses that satisfied the complainants, during the reporting period disaggregated by category of grievance, gender, age, and location of complainant. Stakeholder • Was there interest and support for • Active participation of Stakeholder Consultation engagement the project? stakeholders in activities Attendance Sheets/Minutes impact on project • Were there any adjustments made • Number of actions taken design and during project design and in a timely manner in Evaluation forms implementation. implementation based on the response to feedback How have feedback received? received during Structured surveys engagement • Was priority information disclosed consultation sessions activities made a to relevant parties throughout the with project affected Social media/traditional difference in project cycle? parties. media entries on the project project design and • Number of consultation results implementation? meetings and public discussions where the feedback and recommendation received is reflected in project design and implementation. • Number of disaggregated engagement sessions held, focused on at-risk groups in the project. Implementation • Were the activities implemented as • Percentage of SEP Communication Strategy effectiveness. planned? Why or why not? activities implemented. (Consultation Schedule) Were stakeholder • Was the stakeholder engagement • Key barriers to engagement approach inclusive of disaggregated participation identified Periodic Focus Group activities effective groups? Why or why not? with stakeholder Discussions in representatives. implementation? • Number of adjustments Face-to-face meetings and/or made in the stakeholder Focus Group discussions with engagement approach to Vulnerable Groups or their improve projects’ representatives outreach, inclusion and effectiveness. 26