Ministry of Transport of the Republic of Kazakhstan JSC National Company "KazAvtoZhol" STAKEHOLDER ENGAGEMENT PLAN AND INFORMATION DISCLOSURE (Draft) Transport Resilience and Connectivity Enhancement Project (P500565) (Reconstruction of Zhezkazgan-Karaganda section (km 433-946) of the A17 Highway TABLE OF CONTENTS ABBREVIATIONS ..................................................................................................................................................... 3 1. INTRODUCTION ......................................................................................................................................... 4 2. PROJECT DESCRIPTION ........................................................................................................................... 6 3. TENTATIVE PROJECT TIMELINE............................................................................................................. 11 4. INSTITUTIONAL ARRANGEMENT AND SEP IMPLEMENTATION ............................................................ 11 5. STAKEHOLDER IDENTIFICATION AND ANALYSIS ................................................................................. 14 6. BRIEF SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES .................................... 20 7. STAKEHOLDER ENGAGEMENT DURING PREPARATION OF ENVIRONMENTAL & SOCIAL INSTRUMENTS FOR THE PROJECT ................................................................................................................................ 23 8.STAKEHOLDER ENGAGEMENT DURING ESIA PREPARATION ........................................................................ 26 9. DISADVANTAGED / VULNERABLE INDIVIDUALS OR/AND GROUPS..................................................... 29 10.ESIA ENGAGEMENT AND DISCLOSURE PLAN ............................................................................................... 31 11.STAKEHOLDER ENGAGEMENT PROGRAM .................................................................................................... 33 12.GRIEVANCE REDRESS MECHANISM............................................................................................................... 43 13.MONITORING & REPORTING ........................................................................................................................... 46 APPENDIX 1........................................................................................................................................................... 48 APPENDIX 2........................................................................................................................................................... 50 2 ABBREVIATIONS CLO - Community Liaison Officer CoR - Committee of Roads CSC - Construction Supervision Consultant EIA - Environmental Impact Assessment EA/CR - Executive Agency/Committee for Roads ESMP - Environmental and Social Management Plan ESS - Environmental Social Standards ESF - Environmental and Social Framework E&S - Environmental and Social ESIA - Environmental and Social Impact Assessment FGD - Focus Group Discussion GAP - Gender Action Plan GRM - Grievance Redress Committee GRC - Grievance Redress Committee KII - Key informant interviews LMP - Labour Management Plan MoT - Ministry of transport NC JSC - National Company Joint Stock Company NGO - Non-Governmental Organizations OPBRC - Output Performance-based Road Contract PAP - Project Affected People/Persons PMC - Project management consultant QAJ - QazAutoJol RAP - Resettlement Action Plan RoK - Republic of Kazakhstan SEA - State Environmental Appraisal SEP - Stakeholder Engagement Plan SCS - Construction Supervision Consultant TBD - To be decided 3 1. INTRODUCTION This document has been prepared by the team of consultants employed by the Donsung Engineering Co., Ltd. (“Consultants”). The implementation of the project "Reconstruction of the Zhezkazgan-Karaganda section of A17 (433-946 km) road”, which has a length of 513 km will ensure the solution of the key task of creating an advanced infrastructure of the transport system. The existing road is a two-lane road with an asphalt surface, that is in poor condition and unsuitable for use as a long-distance passenger and freight route. The complete reconstruction of the existing roadway will result in the restoration of driving quality, the improvement of its economic operation, and the reduction of the cost of operating the vehicles of road users. In addition, the implementation of this project will reduce travel time, increase capacity and improve road safety. This document is the Stakeholder Engagement Plan (SEP) for the Transport Resilience and Connectivity Enhancement Project, and it serves a project-level instrument to promote open and transparent engagement between the project and project stakeholders which is an essential element of good international practice. Effective stakeholder engagement can improve the environmental and social sustainability of projects, enhance project acceptance, and make a significant contribution to successful project design and implementation. The SEP is a “living” document and will be updated along with the Project development reflecting the evolving needs for and specific of further engagement with stakeholders. The potential lender is represented by the World Bank. The main parties involved in the Project implementation are shown below (Figure 1). 4 Figure 1. Main Parties Involved in the Project. 5 Stakeholder engagement is an inclusive process conducted throughout the project life cycle. Stakeholder engagement is most effective when initiated at an early stage of the project as it allows for the integration of stakeholder perspectives into the project's early decisions. Furthermore, it is an integral part of the assessment, management and monitoring of the project’s environmental and social risks and impacts. The SEP describes the procedures by which individuals by which people – especially local communities – and other stakeholders are informed about the Project and given the opportunity to provide comments and input to the Project development. In line with the Environmental Social Standards 10 (ESS10), the main purpose of this SEP is therefore to: (i) Establish a systematic approach for identifying stakeholders and maintaining constructive relationships, especially with project-affected parties. (ii) Assess stakeholder interest and support, incorporating their views into project design and performance. (iii) Promote effective, inclusive engagement with project-affected parties throughout the project lifecycle on relevant issues. (iv) Ensure timely, understandable, and accessible disclosure of project information on environmental and social risks and impacts. (v) Provide accessible means for project-affected parties to raise issues and grievances, allowing the borrower to respond and manage them. The Kazakhstani national and ESS requirements for stakeholders’ engagement are presented in Appendix 2 of this SEP. 2. PROJECT DESCRIPTION The national highway designated A17 runs through the heart of the country, from the southwest to the northeast. It connects the cities of Kyzylorda, Jezkazgan, Karagandy, and Pavlodar and, over much of its length, provides a critical road component for the Middle Corridor. As the only east-west route across Karagandy and Ulytau oblasts, the road is also vital for the population’s access to the rest of the country and economic development, with its main freight being metals, manufactured goods, industrial equipment, and food. The sections of the highway linking Karagandy, Jezkazgan, and Kyzylorda are particularly important as they provide transport resilience and improved connectivity to the road network, serving as a second strategic link between Kazakhstan’s southern commercial zone, centered around Shymkent and Almaty and the nation's capital, Astana. The reconstructed section of the road is situated within the administrative boundaries of the Karaganda and Ulytau regions. Implementation of the Karagandy- Jezkazgan project will allow more economical transportation of cargos between the Western, Central and Northern regions. This will result in reduced transportation costs and an additional stimulus to the development of the country's transit potential. 6 For the procurement procedures purposes the route was sub-divided into 6 sections as follows. (Table 1) Table 1. Description of Zhezkazgan-Karaganda Road Sections Section Location, km+ District Lot 1 Km 883 – 946 Ulytau region Length – 63 km Lot 2 Km 833 – 883 Ulytau region Length – 50 km Lot 3 Km 783 – 833 Ulytau region Length – 50 km Lot 4 Km 733 – 783 Karaganda region Length – 50 km Lot 5 Km 683 – 733 Karaganda region Length – 50 km Lot 6 Km 583 – 683 Ulytau region Length 100 km Lot 7 Km 448 – 583 Ulytau region Length – 135 km 7 Figure 2. The Proposed Road Corridor 8 Within the framework of modernization of the road sector, according to the Action Plan for implementation of the Concept of development of transport and logistics potential of the Republic of Kazakhstan until 2030, priority projects requiring reconstruction to ensure the pass ability of the intensive growing traffic flow have been identified. One of the priority projects is the reconstruction of the republican road "Kyzylorda- Pavlodar-Uspenka-Border of RF" section "Zhezkazgan-Karagandy" km 433-946 with a total length of 513 km. The project envisages reconstruction of the road with bringing the parameters up to I-b technical category with separate earth bed (existing road of III technical category). The proposed project consists of the following four components: Component 1: Road Connectivity. The Component involves a substantial capital investment in the country’s primary road network, with the objective of improving connectivity along a strategically important corridor and ensuring its long-term sustainability and climate resilience. 1. Subcomponent 1.1 Road Improvement and Maintenance. This sub-component will support the upgrading of around 513 km section of the strategic A17 Zhezkazgan - Karagandy highway using an integrated design-build-maintain approach. The existing road is a two-lane single carriageway asphalt road in poor condition and not suitable for long distance passenger and freight transport. Full-depth reconstruction of the existing carriageway is required to restore ride quality, make it economically maintainable and reduce vehicle operating costs for road users. In addition, the road will be dualized to provide a four-lane highway that meets the geometric requirements for Category I roads, thereby reducing journey times, increasing capacity and improving road safety. 2. Subcomponent 1.2 Last-Mile Connectivity. This subcomponent focuses on delivering resilient last mile connectivity for rural inhabitants and agricultural producers along and adjacent to the Jezkazgan - Karagandy corridor while also improving road-railways connections. The activity will encompass upgrading or reconstructing around 40 km of local roads and bridges that interlink at least thirteen communities within the Jezkazgan - Karagandy corridor, including improving links to railway stations. Emphasis will also be placed on accommodating pedestrians and cyclists, especially between communities and bus stops along the highway, to make these modes of transport conveniently accessible. At least 30 km of paths and tracks for non-motorized road users are expected to be installed. The benefits arising from this subcomponent will include reduced travel times, enhanced economic sustainability of roads, and the facilitation of year-round access for rural communities. 3. Subcomponent 1.3 Road Sustainability. This sub-component will enhance the upgraded road sections by implementing modern electronic tolling facilities, electric charging stations, and axle load management systems. Introducing tolling aligns with the Ministry of Transport’s plans to expand the toll road network and will use 9 advanced automatic number plate recognition technology for accurate and automated toll collection. 4. Subcomponent 1.4 Safety Audit. This sub-component seeks to quantify and improve road safety of the new infrastructure. This activity will use the International Road Assessment Program (iRAP) star rating system to benchmark project road sections before and after improvement works. This will assist QAJ in systematically managing road infrastructure safety and prioritizing future investments. Component 2: Transport System Development. The component aims to modernize the road sector to make the country’s roads more climate resilient and safer by design amidst growing motorization challenges. The tools required to address current vulnerabilities and meet upcoming challenges will be delivered through targeted technical assistance to where change can best be affected. This component includes: 1. Sub-component 2.1 Framework for Transport Resilience, Decarbonization, and Safer Roads. The project will support a review of the current national road design standards and practices and identify obsolete methodologies not aligned with current best practices for addressing climate change and road safety. Following this review, recommendations for reform will be prepared, and stakeholder consultations will be conducted. Recommendations for climate resilience will also introduce the concept of sustainable management of vulnerable road sections through appropriate tree and grass planting forest belts) in the roadway reserve. Updated resilience and safety focused road design standards will be developed based on the feedback and utilizing the current regulatory framework. 2. Sub-component 2.2 Multimodal Middle Corridor Development . This sub- component will investigate opportunities to improve the multimodality of the Middle Corridor within Kazakhstan to enhance the corridor’s efficiency, functionality, and commercial attractiveness, and reduce the carbon footprint. The technical assistance will explore opportunities to better integrate road, railway, ports, and logistics networks and facilities and identify missing transport links where investment would enhance the corridor. This initiative will pinpoint obstacles to multimodality and devise strategies that prioritize lower-carbon transport options, thereby supporting the decarbonization of freight transportation and mitigating the effects of increased motorization. Component 3: Project Management . This sub-component will support Project implementation by establishing and operating a Project Implementation Unit (PIU) with QAJ and utilizing specialist consulting services. The PIU will employ staff with appropriate skills covering contract preparation, project management, financial management, procurement, and environmental and social risk management. Experienced project management consultants will offer direct guidance and support to the implementation team. Additionally, the component will facilitate the implementation of contracting reforms by providing individual specialists in performance-based contracting, training of QAJ staff, and preparatory studies for further transport sector projects. The component will also 10 support external financial audits and conduct result measurements and impact assessments of the Project. 3. TENTATIVE PROJECT TIMELINE The stakeholder engagement process will continue through all Project implementation stages, including: (i) Preparation stage: 2024-2025: development of Feasibility Study, Detailed Design documentation, setting of funding conditions and schedule; (ii) Construction stage: 2025 – 2028: transferring of utilities, earth works, construction of the roadbed, junctions, viaducts, cattle passes, etc.; (iii) 2028-2030- Guarantee period (iv) Operation stage: Commissioning is expected upon completion of the construction approximately in 2028- 2029 and thereafter there will be a 5-year maintenance period for the road. Specific measures will be implemented at every Project stage aimed at providing continuous information to stakeholders and obtaining feedback from them. The draft SEP for the construction and operation is provided in Section 11. 4. INSTITUTIONAL ARRANGEMENT AND SEP IMPLEMENTATION In order to ensure that all social and environmental safeguards documents, including but not limited to the Environmental and Social Impact Assessment (ESIA), Resettlement Plan (RP), Gender Action Plan (GAP), Labour Management Plan (LMP), and Stakeholder Engagement Plan Plan (SEP), are properly prepared, implemented, monitored, and assessed, it is essential that the relevant organisational and institutional support is in place. The following chart and paragraphs briefly outline the functions of the different parties that are involved in the preparation and implementation of SEP, as well as their responsibilities and roles. The Construction Supervision Consultant (CSC) will also ensure that contractors take all necessary actions properly and provide detailed information in monthly progress reports. In addition, the CSC will be responsible for monitoring the implementation of the 11 safeguards documents and preparing reports thereon. Furthermore, the CSC will assist the CoR/QAJ in resolving grievances that may arise during project implementation. It is recommended that the representative be a member of the Grievance Redress Committee (GRC) at both the project and central levels. Figure 3: Institutional Arrangement for SEP Implementation Project preparation, implementation, funding, implementation of the SEP and other social and environmental safeguards documents. Committee for Roads Project Implementation Unit; responsible for the SEP implementation and reporting to the Director of QAJ. QazAutoJol-Joint Stock Company (i)Aassist the CoR/QAJ and their Akimats of the Karagandy and (i)Participate in public regional representatives in consultation; disclosure conducting consultation; monitoring Ulytau regions issue decrees, activities; grievance redress on redress grievances and consult the implementation of the safeguards regional level documents; assist in grievance with their communities. resolution; Akimats Project Management Consultant Construction Supervision Consultant Committee for Roads The Committee of Roads/QazAutoJol (CoR/QAJ) is the Project Proponent and is therefore responsible for the preparation, implementation, funding, reporting and assessment of all social and environmental safeguards documents. The CoR will ensure that the following occurs: (a) The SEP will be reviewed and endorsed. (i) The decision will be made on hearings, consultations and disclosure of the document. (ii) The SEP will be coordinated with the government agencies and akimats on the implementation of the SEP. (iii) The budget will be sufficient for conducting all hearings and consultations planned throughout the project life. (e) Involve experts/consultants for the SEP update (if necessary), and for monitoring its implementation. (iv) Ensure coordination between other relevant government departments. 12 QazAutoJol NC JSC QazAutoJol-National Company Joint Stock Company (NC JSC) is the Project Implementation Unit and as such, will be responsible for the SEP implementation and reporting to the Director of QAJ. Akimats Although the Coordination of Committee of Roads (CoR/QAJ) will play a pivotal role in the coordination of the implementation of all social safeguards documents, the Akimats of the Karagandy and Ulytau regions will play a crucial role in the issuance of decrees, grievance redress and consultations with their communities. This will ensure the effective implementation of the Stakeholder Engagement Plan (SEP). The detailed descriptions are given in the RP. Project Management Consultant Project management consultant (PMC) will carry out the duties related to monitoring of the social and environmental safeguards documents. Its representative should be a member of the GRC at project and central level. The PMC team will include a full time designated social safeguard and resettlement specialist (engaged for at least the first year of Project implementation) to be responsible for the implementation of these documents. In particular, the PMC will: (i) Participate in public consultation and disclosure activities; (ii) Collaborate with CoR/QAJ to coordinate grievance redress on regional level; Construction Supervision Consultant The Construction Supervision Consultant (CSC) will assist the CoR/QAJ and their regional representative in conducting consultations and other planned engagements with communities. The CSC will also ensure that contractors take all necessary actions properly and provide detailed information in monthly progress reports. In addition, the CSC will be responsible for monitoring the implementation of the safeguards documents and preparing reports thereon. Furthermore, the CSC will assist the CoR/QAJ in resolving grievances that may arise during project implementation. It is recommended that the representative be a member of the Grievance Redress Committee (GRC) at both the project and central levels. 13 5. STAKEHOLDER IDENTIFICATION AND ANALYSIS In accordance with the Potential Lender’s Environmental and Social Standard 10 (ESS10) regarding stakeholder engagement, the Consultants will identify stakeholders, categorizing them as either 'project-affected parties' (those affected or likely to be affected by the project) or 'other interested parties' (those with an interest in the project). A special focus will be placed on identifying disadvantaged or vulnerable groups among the project- affected parties. The Consultants will assess these groups' concerns and priorities regarding project impacts, mitigation, and benefits, ensuring appropriate forms of engagement. The identification of stakeholders in relation to the Project will be carried out based on the following criteria: (i) Impact: the implementation of the Project may affect a certain social group (project-affected stakeholders); (ii) Influence: the social group is able to significantly influence the process of Project implementation; (iii) Partnership: there are opportunities for building partnerships between the social group/s and service providers such as SEA/SH referral services, training services for skills development and other social services; and (iv) Interest: a social group or individuals not necessarily directly affected by the Project may (or may not) show interest in it. The identification of stakeholders and the definition of appropriate methods for engaging with them are prerequisites for effective stakeholder engagement. 5.1 Stakeholder Categories and Groups The Project stakeholders have been classified into two major categories for the purposes of analysis. (i) Internal stakeholders representing the organizations that undertake the Project and those who work within them. These include management, staff, owners, shareholders, as well as contractors and subcontractors involved in the Project implementation and benefiting from it (investors and shareholders); and (ii) External stakeholders representing the groups or individuals that are not part of the organizations implementing the Project but are affected in some way by the decisions and actions of such organizations. To ensure effective and meaningful engagement, the Project’s external stakeholders have been clustered into the following groups: 14 (i) Potentially affected parties/facilities; (ii)Potentially vulnerable groups; State authorities; (iii) (iv)Regional/city/district authorities; (v) Non-commercial organizations (Non-Governmental Organizations (NGOs), mass media, academia etc). (vi) Stakeholder Analysis The interests and / or relation towards the Project of the abovementioned stakeholder groups are analyzed in the Table 2. Any stakeholder that is not included in the table but wishes to receive information about the Project and its E&S aspects and impacts can approach the PMU (QazAutoZhol) with a request to be included in the stakeholders register. Table 2. Stakeholder Groups and Summary of their Interests/relation to the Project Stakeholders Relation to the Project Interests Potentially affected parties/facilities Residents/Land This group could be affected by May be interested in: owners expropriation of their land and assets, • Employment opportunities with potential livelihoods impacts, during the construction and construction related impacts, including operation stages in commercial labor influx, traffic safety, and other facilities (refueling stations, public health impacts associated with shops, cafeteria, etc.) to be generation of pollutants. Public health constructed along the road as risks such as spread of communicable well as jobs to conduct and non-communicable diseases could maintenance works on the be anticipated if labor management road; provisions are not properly enforced. • Information about the Project, Traffic during the construction stage as its progress and its E&S there would be an additional load on the impacts; roads leading to the Project area; • Renting housing to migrant workers as an additional source An increase in the risk of road traffic of income; accidents (RTAs) (during the • Opportunities for an increased construction stage); Improper waste and quicker transportation of management resulting in fires, ignitions, cargo and passengers; etc. during the construction stage and littering along the road during the operation stage; Social tension resulting from competition for jobs at the construction site and for jobs at commercial facilities along the road during the operation stage; Potential disruptions of power supply, wastewater and telecommunication services due to assembling works at the 15 intersection points of the Project with the public utilities and service networks; Residents near May be potentially affected by: May be interested in: facilities necessary noise, vibration, dust emissions and • employment opportunities; for the Project emissions from internal combustion of • information about the Project, construction vehicles (during the construction stage); its progress and its E&S an increase in the risk RTAs (during the impacts. construction stage); increased frequency of congestions on the roads leading to settlements or the roads passing through settlements (during the construction stage); increased load on the roads leading to the corresponding facilities; Farmers who use May be potentially affected by: May be interested in: nearby lands for noise, dust emissions and emissions • information about the Project, pasture of herded from internal combustion of construction its progress and its E&S animals machinery and vehicles transporting impacts; construction materials (during the • tracking how their views / construction stage); loss of pasture land suggestions regarding the and plants (during the construction and Project decisions including the operation stages); road traffic accidents location of passages for herded involving farmers’ herded animals animals, installation of fence (during the construction and operation along the bypass, etc. have stage); been taken into account; • new business opportunities to Project decisions such as the location of occur after the construction of passages for herded animals, the bypass such as commercial installation of fence along the bypass, facilities (shops, cafeteria, etc.; social conflicts with the security refueling stations. etc.). staff of Construction contractor. Service May be potentially affected by: May be interested in: establishments higher workload which might lead to the • increasing their revenues; (catering, increase of the number of workers • providing catering services at accommodation) (during the construction stage); the construction camp. and retail business social diseases as there would be an in the area influx of work force (during the construction stage). Small and medium May be potentially affected by: May be interested in: enterprises and higher workload which might lead to the • information about the Project, their employees increase of the number of workers its progress and its E&S (local building (during the construction stage); impacts; materials social diseases as there could be an • procurement opportunities producers, influx of work force (during the related to the Project; distributors, local construction stage). • Project implementation as there construction would be a better accessibility companies, rent of and trading opportunities within construction 16 vehicles and the region, and with equipment, etc.) neighboring countries; • opportunities for an increased and quicker transportation of cargo and goods. Potentially vulnerable Groups Women headed Maybe potentially affected by: May be interested in employment families/rural This group could be affected by impact opportunities during the construction women in general on their land and assets, with potential stage and operation stage in livelihoods impacts, construction related commercial facilities (refueling stations, impacts, including labor influx, traffic shops, cafeteria, etc.) to be constructed safety, and other public health impacts along the road as well as jobs to associated with generation of pollutants. conduct maintenance works (street Public health risks such as spread of cleaning) on the road. communicable and non-communicable diseases could be anticipated if labor management provisions are not properly enforced, potential increase in GBV risks due to households power dynamics due to job availability, SEA/SH risks due labor influx. Other vulnerable Children, the elderly, people with May be interested in: groups disability and other underlying health • Safe and comfortable road with conditions, etc. could be particularly safe footpaths sensitive to dusts, noises, etc.). • Access for people with disability Non-government organizations (NGOs) National NGOs of No impacts envisaged. May be interested in: environmental and • monitoring the Project progress public orientation and tracking how their views / suggestions regarding the Project implementation have been taken into account; • positive E&S changes associated with the implementation of the Project. Scientific, research No impacts envisaged. May be interested in: and educational • information about the Project, organizations its progress and its E&S (universities, impacts; schools) • participating in the Project consultations/discussions. National, regional No impacts envisaged. May be interested in: and district media • information about the Project, its progress and its E&S impacts; • cooperation with the Company on covering its activities, provision of information to the public and other interested parties. 17 In addition, the SEP also outlines the following state authorities both at the national and regional level along with their roles to inform future engagement. Table 3. List of State Authorities and Their Respective Roles State authorities Roles Ministry of Ecology and Natural Implements state policy, coordination of management processes in Resources of the RoK the areas of environmental protection, development of a "green economy", waste management (except for municipal, medical and radioactive waste), protection, control and supervision over the rational use of natural resources, state geological study of subsoil, reproduction of the mineral resource base, use and protection of water resources, water supply, wastewater disposal, forestry, protection, reproduction and use of wildlife and specially protected natural areas. Ministry of Agriculture of the RoK Implements state policy in the sphere of the agro-industrial complex, irrigated agriculture and land reclamation, land resources, as well as, within the limits stipulated by the legislation, carries out cross-sectoral coordination of state bodies in the field of activities related to its competence31. Other state authorities to various The list of state authorities implementing state policies within their extents related to the Project competence includes, but is not limited to: Ministry of Finance of the RoK; Ministry of Economy of the RoK; Ministry of Healthcare of the RoK, Ministry of Energy of the RoK, etc. Committee for Roads of the Carries out regulatory and implementation functions, as well as Ministry of Transport RoK participates in the implementation of the strategic functions of the Ministry in the area of highways. Committee for Environmental Performs the functions of environmental regulation and control. Regulation and Control of the Ministry of Ecology, Geology and Natural Resources of the RoK Committee for Land Carries out strategic, regulatory, implementation and control and Management of the Ministry of supervisory functions in the field of land management assigned to it Agriculture of the RoK by the Constitution, laws, other regulatory legal acts of the RoK and the Regulations on the Committee. Regional/City/District Authorities Akimats of the Karaganda and In terms of transport infrastructure management, akimats conduct the Ulytau Regions following activities: Ensures road safety in the relevant area; Develops and implements measures to organize road traffic; Provides performance and control over all types of construction, reconstruction, repair, implementation and maintenance of technical means of traffic control on the roads of regional and district significance, streets of settlements; Manages municipal-owned roads and road enterprises; Carries out state control in the course of work on the reconstruction, repair and maintenance of regional highways. 18 Maslikhat of the Karaganda and Local representative body of the Karaganda and Ulytau Regions Ulytau Regions elected by the population of the region. Akimat of Karaganda and Implements state policy in the spheres of agriculture, Zhezkazgan cities entrepreneurship, industry and tourism, transport infrastructure, social protection, etc. Akimat of Districts Ensures the socio-economic development of the districts. Department of Ecology of the The Department is the territorial body of the Committee for Karaganda and Ulytau Regions Environmental Regulation and Control of the Ministry of Ecology, Geology and Natural Resources of the RoK that performs the functions of environmental regulation and control. Department of Land Relations of Manages the regulation of land relations in Karaganda and Ulytau the Karaganda and Ulytau Regions Regions Other departments of the Departments implementing state policies within their competence in Karaganda and Ulytau Region the Karaganda and Ulytau Regions include, but are not limited to: Akimat to various extents related Department of Passenger Transport and Highways to the Project Department of Energy and Housing and Communal Services Department of Internal Policy Department of State Architectural and Construction Control Department of Industrial and Innovative Development Karaganda & Zhezkazgan cities Manages the areas of passenger transport and highways, the Department of Housing and implementation of housing and communal services and housing Communal Services, Passenger stock. Transport, Highways and Housing Inspection Other city departments of the Departments implementing state policies within their competence in Akimat of Karaganda & the cities of Karaganda & Zhezkazgan include, but are not limited to: Zhezkazgan cities to various City Department of Construction; extents related to the Project City Department of Land Relations; City Department of Entrepreneurship, Industry and Tourism, etc. The stakeholder list will be verified and may be updated at each stage of the Project implementation. The initial classification of the stakeholders was undertaken to identify appropriate engagement methods with the various stakeholder groups. Adversely affected stakeholders and/or stakeholders will be closely engaged through direct communication, and information will be disclosed timely to capture their feedback. A particular emphasis will be placed on vulnerable populations through the planning and conducting of focus group discussion (FGDs) and information sharing in a manner that is assessable and safe for them. For example, during the preparation of the SEP and other social safeguard documents, a separate consultation with women was held. There were no individuals with disabilities in the female groups, while male groups had two individuals with disabilities participating in the FGDs. Nevertheless, it is more prudent to tailor engagement with vulnerable groups including standalone FGDs, information dissemination and outreach, thereby enabling them to express their opinions, suggestions and concerns with greater freedom. The vulnerable individuals/groups will be closely engaged through direct communication, and information will be disclosed timely to capture their feedback. 19 6. BRIEF SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES 6.1 Stakeholder Engagement History (2022-2023-2024) The first preliminary public hearings on project information disclosure and presentation of the working design were held in 2022 by QAJ regional branches and representatives of local executive bodies, with the participation of representatives of project organizations. A summary (Table 4) of the public hearings is presented below: Table 4: Preliminary and Current Public Hearings Summary Date Place Participants Agenda February 3, Zhezkazgan Representatives of Kengyr rural area, Presentation of 2022 Ulytau region Sarysu rural area, Zhezkazgan akimats engineering solutions Representatives of Karagandy regional for section km 533-583 branch of QAJ Representatives of the designer LLP “Kazdorproekt” & “Semdorproekt” Local community representatives March 29, Abay town, Abay Representatives of Abay district akimat Presentation of 2022 district, Representatives of Karagandy regional engineering solutions Karagandy branch of QAJ for sections km 925- region Representatives of the designer LLP 946 “Kazdorproekt” Local community representatives March 31, Aktas village, Representatives of Saran town & Aktas Presentation of 2022 Karagandy village akimats engineering solutions region Representatives of Karagandy regional for sections km 925- branch of QAJ 946 Representatives of the designer LLP “Kazdorproekt” Local community representatives September Zhezkazgan, Representatives of Zhezkazgan akimat Presentation of working 1, 2022 Ulytau region Representatives of Karagandy regional design for section km branch of QAJ 433-483 Representatives of the designer LLP “Almatydorproekt” Local community representatives September Batyk village, Representatives of Batyk village akimat Presentation of 13, 2022 Shet district, Representatives of Karagandy regional engineering solutions Karagandy branch of QAJ for sections km 783- region Representatives of the designer LLP 833 “Kostanaidorproekt” Local community representatives 20 September Akoy village, Representatives of Akoy village akimat Presentation of 13, 2022 Shet district, Representatives of Karagandy regional engineering solutions Karagandy branch of QAJ for section km 833-883 region Representatives of the designer LLP “Kostanaidorproekt” Local community representatives September Krasnaya Representatives of Krasnaya polyana Presentation of 13, 2022 polyana village, village akimat engineering solutions Shet district, Representatives of Karagandy regional for section km 833-883 Karagandy branch of QAJ region Representatives of the designer LLP “Kostanaidorproekt” Local community representatives September Yuzhnyi village, Representatives of Yuzhnyi village akimat Presentation of 13, 2022 Shet district, Representatives of Karagandy regional engineering solutions Karagandy branch of QAJ for section km 833-883 region Representatives of the designer LLP “Kostanaidorproekt” Local community representatives September Bidayk village, Representatives of Bidayk village akimat Presentation of 13, 2022 Zhanarka district, Representatives of Karagandy regional engineering solutions Zhezkazgan branch of QAJ for section km 783-833 region Representatives of the designer LLP “Kostanaidorproekt” Local community representatives November Aktubek village, Representatives of Zhanarka district akimat Presentation of 30, 2022 Zhanarka district, Representatives of Karagandy regional engineering solutions Ulytau region branch of QAJ for section km 633-683 Representatives of the designer LLP “Kazdorproekt” & “Semdorproekt” Local community representatives November Yeraliyev village, Representatives of Zhanarka district akimat Presentation of 30, 2022 Zhanarka district, Representatives of Karagandy regional engineering solutions Ulytau region branch of QAJ for sections km 633- Representatives of the designer LLP 683, km 683-733, km “Kazdorproekt” & “Semdorproekt” 733-783 Local community representatives April 7, Batyk & Akoy Representatives of Batyk and Akoy villages Report on potential 2023 villages, Shet akimats impacts, working district, Representatives of Karagandy regional design for section km Karagandy branch of QAJ 783-795 region Representatives of the designer LLP “Kostanaidorproekt” Local community representatives June 24, Zhezkazgan city, KazAutoZhol Zhezkazgan, Dong Song Eng Information about the 2024 akimat LTO, KazDorNII JSC, WB, Department of project, presentations Ecology of Ulytau region, ROO ASBC, ER of environmental and 21 Division of the Department of Ecology of social documents Ulytau region, Zhezkazgan City PT and AD prepared for the Department, IE Ecoland, local resident. project. June 26, Batyk & Akoy KazAutoZhol, Dong Song Eng LTO, Information about the 2024 villages, Shet KazDorNII JSC, WB, Department of project, presentations district, Ecology of Ulytau region, IP Ecoland, of environmental and Karagandy Karaganda OTI LKhZhM social documents region prepared for the project. The stakeholders at all hearings conducted were proactive, they supported the project and asked questions and gave their suggestions. A brief summary of public opinion on the project, based on the public hearings held by the client (based on the minutes of the public hearings held in 2022, 2023 and during the preparation of this document in 2024). Most frequent questions were: Table 5: List of Questions and Suggestions from the Public Hearings When is the start date of construction, duration of the road construction and some technical characteristics of the planned road? Are the cattle passes planned, what size they will be and where they will be located? Can twin-castle passes be constructed? Is fencing around the road planned so the animals cannot get on the road? Will there be U-turns or overpasses, including for agricultural equipment? Will cars be passing through the cattle passes? Will the road lighting be installed? Where are the locations of public transport stops? Where will be the location of quarries? Will the project affect some grave monuments? Will the rest areas be planned, and the crosswalks provided? Will people have exits to their farms? Will the power lines will be re-arranged? Will the local population be accepted to work on the project? Will the car passage be provided during the construction period? Proposals to build an autobahn like Astana-Karaganda instead of reconstructing the existing road. Where do the public can access information about the proposals made and the status of their consideration? Beside saigas, there are also argali and roe deer. Saiga crossings, signs (speed limit/wildlife crossing) are mandatory; Fences should be constructed in accordance with all standards and should prevent the animals from entering the road. No acoustic signals should be used. What is the resettlement plan for? Where can I see the data on the plots under construction? Suggested measures for dust suppression: use special means, as ordinary water is not effective; plant shrubs in 2 rows near settlements for wind and noise suppression; power lines should be safe for birds. All this should be considered in the project. Will there be cattle passes? They are always needed near settlements. Will the road be the same as the one to Astana (in terms of technical parameters and tolls)? When is the construction going to start? Why do we have to wait so long for it to start? Are there any Green Space Survey Acts and how many trees are planned to be cut down? What types of trees are to be felled? Are there plans to replant trees? 22 The above list of questions will inform the approach of the engagement as well as the materials for public communication, particularly at the early stage of the Project implementation. According to the results of the public hearings, the population received answers to all the questions asked. There were no objections, and the minutes have signatures of all the participants of the hearings. 7. STAKEHOLDER ENGAGEMENT DURING PREPARATION OF ENVIRONMENTAL & SOCIAL INSTRUMENTS FOR THE PROJECT A socio-economic study (SES) was conducted between 12 and 23 February 2024 as part of the RAP preparation process. The primary objective of the SES was to disseminate information about the project, elicit suggestions and concerns from the public, identify the project-affected areas and persons (PAPs), collect socio-economic data and, based on the aforementioned activities, determine the baseline conditions available for the project prior to the commencement of construction works. The baseline data collected has been incorporated into the Stakeholder Engagement Plan as Annex 2. It should be noted that due to the short timeframe for the preparation of reports, the time chosen to conduct the survey and interviewing the population was not suitable due to bad weather conditions, which led to the closure of roads, the inability of consultants to reach some settlements, as well as the death of livestock, which in turn led to the fact that the population was busy rescuing them (in Ulytau region). Due to these circumstances, some stakeholder groups were not represented. In order to mitigate these gaps and to reach out to these stakeholders and obtain their views, opinions and suggestions on the project, the project will allocate additional resources in the early stages of project implementation. The consultants also conducted focus group interviews during the period from February 26 to March 7, 2024, as part of the GAP preparation. The results are presented in a separate report and were also included in the Stakeholder Engagement Plan and other social safeguards documents. A Socio-economic Study (SES) was conducted between 12 and 23 February 2024 as part of the RAP preparation. The primary objective of the Socio-economic Study (SES) was to disseminate information about the project, elicit suggestions and concerns from the public, identify the project-affected areas and persons (PAPs), collect socio-economic data, and determine the baseline conditions available for the project prior to the commencement of 23 construction works. The baseline data collected has been included in the Stakeholder Engagement Plan as Annex 2. The primary suggestions put forth by the local population during the SES (similar to questions asked during the earlier public hearing) pertained to the provision of a sufficient number of cattle passes, the construction of overpasses for agricultural machinery, the implementation of U-turns, and the establishment of access points to their farms. The primary concerns expressed by the population related to the potential increase in the number of accidents, the necessity of establishing speed limits, the presence of livestock on the roadway, the amount of compensation to be provided in the event of land acquisition, the fairness of the compensation, the loss of income due to the project, the delay in the start of road construction, and the completion of road construction. It should be noted that all respondents expressed a positive attitude towards the project, agreed with its necessity and perceived positive impact on the regional economic environment, and anticipated a reduction in travel time. Below is a summary table of all meetings with Client's representatives, local executive bodies, population and other stakeholders. Table 6. Summary of Consultations with Local Authorities and Project Communities City/Town/ No of No Target Date Villages Agenda Region/District participants Main objectives of the project, terms of the assignment, Committee identifying the for Roads/ persons who will December 4, 1 NC JSC Astana be in contact 12 2023 QAJ central with the office consultants and assist in the implementation of the project on the ground Forthcoming visit Feasibility of the Study team December 4, consultants and 2 Astana 9 JSC 2023 the start of work KazDorNII on the assignment Introducing the consultants to NC JSC the current QAJ December 4, 3 Karaganda course of action 7 regional 2023 and gathering branch available information 24 Assisting in organizing a meeting with local authorities Karaganda February 12, and PAPs for 4 regional Karaganda 5 2024 conducting SES akimat and appointing responsible persons on the ground Karaganda city Saran town Yuzhnyi Karagandy Kulaigyr PAPs February 12- region 5 Abay town SES 23 interview 16, 2024 Abay district Dubovka Shet district Krasnaya polyana Akoy Batyk Assisting in organizing a meeting with local authorities Ulytau February 19, and PAPs for 6 regional Zhezkazgan 7 2024 conducting SES akimat and appointing responsible persons on the ground Zhezkazgan Ulytau region city PAPs February 19- Ulytau district 7 Sarysu SES 18 interview 21, 2024 Zhanarka Tugusken district Yeraliyev Karagandy Akoy Separate Male February 27, 8 Community region Batyk and Female 30 2024 Shet district FGD Karagandy Kulaigyr Separate Male February 28, 9 Community region Dubovka and Female 21 2024 Abay district FGD Karagandy Separate Male February 29, 10 Community region Aktas and Female 13 2024 Abay district FGD One Mixed male/female Ulytau region Aktubek FGD 11 Community March 4, 2024 Zhanarka 12 Baidaly bi Separate Male district and Female FGD Ulytau region One Mixed Borsengyr 12 Community March 4, 2024 Ulytau district male/female 22 Sarysu FGD 25 Separate Male and Female FGD In conclusion, the results of the consultations and interviews conducted during the survey indicate a generally positive attitude towards the forthcoming implementation of the project among those consulted. However, it is worth noting the few general concerns of those stakeholder representatives with whom the consultants had the opportunity to consult. Local Residents: Concerns about disruptions during construction, such as traffic congestion, noise, and dust. They also had comments and suggestions on the proposed design, such as pedestrian safety provisions, access to businesses, but mainly cattle passages and overpasses. There were no concerns about influx of foreign and regional workers. On the contrary, people see an opportunity to offer their services and earn some additional income. Job expectations are high and readiness to be trained to gain or refresh/update some skills which would enable them to work on the road. Business Owners: Concerns about how construction may affect their operations, access to their establishments, and potential loss of customers due to construction-related difficulties. Although all noted that the implementation of the project will have a positive impact on the economic situation in their region of residence. Local Governments: Feedback on the project's alignment with regional development plans, budget considerations, and coordination with other infrastructure projects in the area. Also, they have concerns about the long-term maintenance costs, project timelines. Executive Agency (Regional branch offices of QAJ): Concerns about ensuring that the project complies with all relevant laws, regulations, compensation negotiations, and any disputes or concerns which can be raised by landowners regarding the acquisition process and mitigation measures. 8.STAKEHOLDER ENGAGEMENT DURING ESIA PREPARATION The project stakeholder identified at this stage are presented in Table 6 below, with an analysis of the best ways to engage with them according to the media that they are likely to use and will be most comfortable with. The identification of relevant stakeholders is of crucial importance for the Project implementation process. The land along the road is sparsely populated with residential buildings and businesses, these stakeholders will be directly affected by the Project. Stakeholders that could not be contacted and/or interviewed were given a contact of the CLO and/or local authorities in case they have feedback or concerns. 26 Table 7. Key Stakeholders Identified and Ways of Engaging Them Type Name Impact/ Influence Preferred method of engagement Project Shareholders Committee for Roads, This group will directly CoR/ QAJ to facilitate / Internal Regional branch offices influence and impact meetings with Stakeholders of QazAutoJol NC JSC, the shareholders and The WB team, project through the employees (preferably Internal employees of decision-making quarterly). QAJ process. They are "Committee of Forestry considered as ‘Primary and Wildlife of the Stakeholders’. Ministry of Ecology and Natural Resources of the Republic of Kazakhstan". Permitting bodies, Ministry of Ecology and This group will have a CoR/ QAJ to write local governmental Natural Resources direct official letters and e- agencies Ministry of Labour and influence/impact on the mails, Social Protection of project through and undertake meetings Population approving with the permitting Ministry of National permits, providing bodies Economy certificates when necessary. Ministry of Agriculture and enforcing new Ministry of Transport regulations and rules. Ministry of National Economy Ministry of Finance Regional Akimats of Karaganda & Ulytau regions - NURA-SARYSUI inter- regional basin Fisheries Inspection - State Institution "Karaganda regional Territorial Inspection of the KVK and the Ministry of Agriculture of the Republic of Kazakhstan" - RGKP "PO Okhotzooprom" Sansyzbaevich) - Institute of Zoology of the University of the Ministry of Education and Science of the Republic of Kazakhstan Communities living Communities Residential households QAJ through local close to the road surrounding the road: might be affected authorities to facilitate The land along the road indirectly because of alignment is sparsely the construction stage 27 populated with and interrupted access regular meetings with residential households to services and farms the impacted and and once the road is communities livestock owners. operational. to address their concerns and issues. Owners of cafés, Businesses will be QAJ through local Businesses along the restaurants, petrol affected indirectly as a authorities to facilitate road stations, and other result of the regular meetings with businesses along the construction stage and the road, recreation areas. once the road is impacted operational. businesses to address - Kazakhstan their concerns and Association for issues. Biodiversity Conservation - Biodiversity Research and Conservation Center, BRCC) - The public association "Karaganda Regional Ecological Museum" Service Providers NGOs and government The relevant Meetings with run organizations, COs, organization could be stakeholders, SEA/SH included in some introduction of trainings, health-related NGOs/COs to the issues at sites and project communities, communities and thus, publishing their services directly affected by the available to the project projet. communities. Vulnerable Groups Families and individuals The vulnerable groups QAJ through local living below the poverty will be directly and authorities to conduct a line (but not recognised indirectly affected as a meaningful consultation or having not requested result of the project with the affected any type of social activities: reduced individuals to identify a allowances); access rights, potential best solution to improve Families and individuals reduced safety, dust their livelihood; or who receive Targeted and noise emissions. provide Social Aid (TSA) an alternative living allowance or other area types of allowances for them. Each Akim such as for disability; oversees all People with dissability communications within and individuals with the village, chronic illnesses; Illegal disseminating households or information to the entire individuals with no legal population via social rights to their land or platforms such as non-land assets (no WhatsApp and other illegal households were applications. They also found within the Project inform the community of area); Women headed public gatherings, households; Large government decisions, families with four or and other matters of 28 more children under the interest to the public. age of 18; Individuals Therefore, all with low levels of gatherings, literacy; and consultations, Households living in information sharing, and water stressed areas. other events should be organised through the village Akim. Consultants conducted information disclosure and public consultations with the interested public on the Report on Possible Impacts to the Feasibility Study initiated by QazDorNII JSC in Zhezkazgan regional center on 24 June 2024. Similar consultations for Karaganda region are yet to be confirmed. Additionally, consultants will facilitate an online workshop with the participation of relevant government authorities and other stakeholders at both regional and local levels. Following the principles of the project objectives, the workshop will focus on the disclosure, dissemination, and consultation of information. 9. DISADVANTAGED / VULNERABLE INDIVIDUALS OR/AND GROUPS Based on the World Bank ESF “Disadvantaged or vulnerable refers to those who may be more likely to be adversely affected by the project impacts and/or more limited than others in their ability to take advantage of a project’s benefits. Such an individual/group is also more likely to be excluded from/unable to participate fully in the mainstream consultation process and as such may require specific measures and/or assistance to do so. This will take into account considerations relating to age, including the elderly and minors, and including in circumstances where they may be separated from their family, the community or other individuals upon which they depend.” Based on field observations and interviews, the following categories have been identified as ‘Vulnerable’ within the project area: (i) Families and individuals living below the poverty line (but not recognised or having not requested any type of social allowances); (ii) Families and individuals who receive Targeted Social Aid (TSA) allowance or other types of allowances such as for disability; (iii) People with disability and individuals with chronic illnesses; Illegal households or individuals with no legal rights to their land or non-land assets (no illegal households were found within the Project area); (iv) Women headed households; (v) Large families with four or more children under the age of 18; (vi) Individuals with low levels of literacy; and 29 (vii) Households living in water stressed areas. Kazakh citizens, Kandas1, refugees, foreigners, and stateless persons who reside in the country and whose average per capita income does not exceed the poverty line are eligible to receive Targeted Social Assistance. The poverty line itself is correlated with the minimum subsistence level (MSL) and is approximately 70% of it. But its size is specified quarterly in each region and published in the media. In the country's budget for 2024, the subsistence minimum is 43,407 tenge, and the poverty line is set depending on the economic capacity of the state. The social assessment, based on consultations, focus group discussions (FGDs) and key informant interviews (KIIs) conducted in the project villages, indicated that the project was highly appreciated and that all people expected to benefit from it. There was no suggestion that the project would exacerbate the vulnerability of those who were already vulnerable. In the event that land was acquired from vulnerable people, land-for-land compensation should be offered. Other measures applicable to vulnerable categories of displaced people will be specified and described in the RAP. During the SES, there were 5 female-owned households among the interviewees, all of whom are married and have sources of regular income. During FGD and KII, 4 low-income female-headed households were identified in Karaganda oblast and 11 in Ulytau oblast. It should be noted that these households are not necessarily included in the group of project affected persons. To ensure that all Project affected residents will have an opportunity to receive Project information, raise concerns or make written or oral comments, special provisions will be taken to consider vulnerable groups in a meaningful way, comprising: (i) Provision of transport to meetings where needed (e.g. for elderly, people with physically disability or other people who wish to access the locations where public meetings are held). Needs for transport on the settlement level will be identified through the akimats and assisted by the project in the context of preparation of the public consultation. (ii) Allowing participants to either make comments formally during the meeting or informally on a one-to-one basis after a meeting. (iii) The option that the participants who are not able to read or write have the opportunity to listen to presentations and provide their concerns verbally to minute takers during or after the meeting. 1 Ethnic Kazakh residing permanently beyond the borders of the Republic of Kazakhstan (Kanda means compatriot in Kazakh language) 30 (iv) A special attention will be given to people with disabilities, and educational engagement through school should be considered and develop in detail in the site- specific management plan (ESMP). 10.ESIA ENGAGEMENT AND DISCLOSURE PLAN Objective of Documents Disclosure The Committee for Roads will review, approve, and disclose project information and all social and environmental safeguards documents (ESIA, ESMP, SEP, LMP, GAP and RAP early to help stakeholders understand risks, impacts, and opportunities. This includes: (i) Project purpose, nature, and scale (ii) Duration of activities (iii) Potential community risks and mitigation measures, especially for vulnerable groups; (d) Stakeholder engagement process (iv) Details of public consultation meetings (v) Grievance procedures Information will be provided in local languages and accessible formats, considering the needs of differentially affected or special-needs groups. Where required, necessary changes will be made to the Draft ESIA and to related documents during their finalization to reflect the comments received during the disclosure. Who will be informed? During the Disclosure Period, information will be provided to stakeholders affected by the Project, those with interests in it, or those who can influence its outcomes. The targeted stakeholder categories for engagement during the ESIA disclosure and throughout the Project lifecycle are: (i) PAPs and the Project affected settlements; (ii) Related NGOs; (iii) Related legal entities; (iv) Vulnerable groups identified in the settlements; (v) Statutory stakeholders (e.g. governmental bodies especially local governments administration). Documents to be Disclosed 31 The Government will be disclosing the Project ESIA in Kazakh, Russian and English languages:  The ESIA Report: I. Volume I - NTS - Non-Technical Summary (all three languages) This will be a stand-alone summary written in a simple language to explain the key points of the ESIA to a wider public; II. Volume II – The Main ESIA Report (all three languages) This is a central document and contains most of the relevant information and key findings for the readers, except for the detailed items in Volume III and related Annexes thereto. This Volume also describes stakeholder engagement activities conducted during the preparation of this ESIA performed to the date; III. Volume III – The ESIA Appendices (all three languages)??? IV. Volume IV – The Framework ESMP (all three languages)??? The relevant mitigation measures and overall monitoring plan will be compiled in the Environmental and Social Management Plan (ESMP) document. This serves as the overarching management plan for the Project, outlining the additional, topic-specific management plans needed to implement and monitor various mitigation measures. V. Volume V – Preliminary RAP (all three languages) This volume comprises the preliminary Resettlement Action Plan (RAP) document, which provides the basis and “road-map” for the subsequent implementation and monitoring of the Resettlement Plan, should any of these will be required for the purposes of the future land acquisition due to changes/amendments of the design; VI. Volume VI- SEP (all three languages) This volume will comprise the Stakeholder Engagement Plan, which describes the stakeholder engagement process to date and details how the Project will continue to engage with external stakeholders during the following stages of its development including establishment of a Grievance Process; VII. Volume VII – Set of Environmental and Social Management Plans (all three languages) This volume is comprised of the environmental and social management plans developed for the Project, including: Biodiversity Management Plan (BMP), Labor Management Procedures (LMP), Occupational Health and Safety (OHS), Gender Action Plan (GAP). In addition, the updated Project information will be made available to the public via the Client’s internet website https://www.gov.kz/memleket/entities/roads?lang=kk for reading online and down-loading. All ESIA documents listed above will be uploaded by the Client on the official website. 32 How and Where will the Public Obtain Information ? Key objective of the disclosure and engagement process is to reach as many people as possible, especially in the affected settlements. All disclosed Project ESIA Documents will be distributed to the Disclosure Locations (CoR & QAJ offices, Regional and districts akimats). Where will Project Documents be Located? During the Disclosure Period, complete copies of a Draft ESIA and other Project Documents, as referred above, will be available in all three languages in Committee for Roads, Central and Regional offices of QazAutoJol and two regional akimats (Karaganda & Ulytau). The ESIA NTS, the SEP and Grievance Form, in Kazakh and Russian language, will be available in the districts akimats. Further, the complete documents will be available for commenting on the official websites https://www.gov.kz/memleket/entities/roads?lang=kk, https://kz.qaj.kz/. The Project Grievance Form will be copied for wider distribution for the Public and will also be available in project related locations (to be agreed with akimats). 11.STAKEHOLDER ENGAGEMENT PROGRAM The Stakeholder Engagement Program (Table 6) is designed to ensure the most effective engagement with all identified stakeholders, to create and maintain respectful relations between the Employer and stakeholders, and to prevent possible conflicts. The Program covers the design and construction stages and should be revised and updated prior to the construction and at least within one year after beginning of the construction stage and then prior to commissioning the Project facilities. It provides a specific action plan with the distribution of responsibilities and a timeline for implementation of the suggested activities. If there would be changes during the Project implementation that require modification of the engagement mechanisms and / or new stakeholders are identified, the Program should also be updated. The budget for the implementation of the stakeholder engagement activities could not be formulated at this stage due to the limited information of the actual risks and impacts at the current stage of the preparation. Further details on budgeting are expected to be formulated as part of the annual budgeting exercise, which will include stakeholder engagement activities, to be submitted by the PIU for the World Bank’s approval. 33 In case of extreme weather or other circumstances that may prevent access to the stakeholders, events requiring gatherings / major meetings should not be cancelled, but, if possible, be conducted online and by using alternative engagement methods and as soon as the weather and any other conditions allow, on-site consultations must be conducted. The Employer will keep track of all engagement activities performed in a Stakeholder Engagement Log, which will include management forms, minutes of meetings and all relevant material used or prepared for the engagement activity (announcements, posters, brochures, presentations, attendees’ sheet, pictures, etc.). The Stakeholder Engagement Log must be updated prior to the construction and after, once every three months to include the data related to the stakeholder engagement activities/events (mostly conducted by the Construction contractor/s) held within the reporting (past) quarters. 34 Table 8. Stakeholder Engagement Program № Activity Target Group Information Timeframe Responsible Means of Notes Materials party communicatio n/ location 1 PROJECT DESIGN STAGE 1.1 Develop and launch All stakeholders E&S and summary Upon signing of the MoT CoR Implementing The SEP and the Project’s (project affected of the general Loan Agreement NC JSC Agencies ESIA developed webpage on the persons, local, Information between the QazAutoJol, websites during the Implementing regional and (including basic Implementing PMU project Agencies national technical Agency and the WB preparation will websites authorities, other information) and then regularly or be published at interested parties, about the Project, when the Project the IA website wide public). FAQ leaflets on the news are available which to be Project’s E&S developed impacts and ASAP (during mitigations, SEP this project (including the preparation grievance phase. The mechanism, general project address, contacts, information will etc.) be published on the website. 1.2 Adoption and All stakeholders Final Draft SEP, Upon approval of the MoT CoR Project disclosure of the (project affected GAP, ESMP, LMP E&S documents by NC JSC webpage on the Project’s E&S persons, local, and preliminary the WB and the QazAutoJol Implementing documents: regional and RAP (in English and Implementing Agencies Environmental and national Russian) Agency websites Social Management authorities, other Hard copies at: plan (ESMP), SEP, interested parties, Office of GAP, LMP, wide public). Karaganda & preliminary RAP Ulytau Regional Branch of QazAutoJol Karaganda & Ulytau Regional Akimat offices 35 Administration offices of the districts 1.3 Establishment of a All stakeholders SEP, notification, Established upon MoT CoR Project To be grievance information bulletins signing of the Loan NC JSC webpage on the established mechanism and Agreement between QazAutoJol Implementing ASAP notification of the the Implementing Agencies irrespective of public on the Agency and WB and websites Office progress of established maintained onwards of Karaganda & other tasks grievance Ulytau mechanism Regional Branch of QazAutoJol Karaganda & Ulytau Regional Akimat offices Administration offices of the districts 36 1.4 Disclose the contact Potentially Notification, Upon readiness of MoT CoR Project The IA website information of the affected parties information the SEP report and NC JSC webpage on the is of the utmost person responsible Other announcement approval by the QazAutoJol Implementing importance and for the stakeholders Implementing Agencies needs to be set implementation of Agency and WB and websites Office up as soon as the SEP and keep disclosed of Karaganda & possible, managing the onwards Ulytau irrespective of grievance Regional the progress of mechanism Branch of other project (community liaison QazAutoJol tasks. officer or CLO) Karaganda & Ulytau Regional Akimat offices 1.5 Media coverage of All stakeholders Announcements in Upon signing of the MoT CoR Respective the Project progress, the newspapers, Loan Agreement NC JSC media planned activities, news channels, between the QazAutoJol channels / achievements and magazines about Implementing CLO means any relevant E&S the Project’s scope Agency and WB and (mirrored at the news and technical then monthly Project’s measures or when the Project webpage) envisioned, FAQ news are available leaflets on the during the Project Project’s E&S life-cycle. The impacts and location will be mitigations, press decided by the media releases as news and Government, appear, and it will depend on announcement the needs to inform about public communities and hearings / other stakeholders. consultations 37 1.6 During the design Affected social Notifications, Prior to the MoT CoR Office of process discussions groups (socially presentations, press construction stage NC JSC Karaganda & with the potentially vulnerable releases / news, QazAutoJol, Ulytau affected and population, people bulletins/ WhatsApp PMU Regional vulnerable social with disabilities) and other social Branch of groups (or their media platforms QazAutoJol representatives) used by all people in Karaganda & the project Ulytau communities. Regional Akimat offices Administration offices of the districts. All communities including vulnerables 1.7 Communication of Residents of the Non-technical Prior to construction Office of Newspapers, potential job regions, service summary (NTS), and as the need for Karaganda & radio, internet, opportunities and establishments grievance goods or services Ulytau local job business and retail mechanism, arises Regional centers, state opportunities business, small vacancies, tender Branch of procurement and medium announcements QazAutoJol web-site / enterprises in the Karaganda & tender regions Ulytau announcement Regional s Akimat offices 2. PRE-CONSTRUCTION STAGE 2.1 Notification on the Residents of the Notifications, Prior to the Regional Project Has to be commencement of project related information commencement of Branch offices webpage on coordinated with construction works areas, farmers bulletins, construction works of the Company the client side using the Project TV, social media, QAJ NC JSC website and the site adjacent areas press releases / CLO Offices of executing as pastureland, new Ulytau & agency visitors of the s and community Karaganda cemetery. outreach. Regional Other interested Branch offices parties of QAJ NC JSC 38 Regional/rural/ village Akimats offices 2.2 Informing the public Residents of the Presentation Prior to the Regional Local media Has to be on the traffic safety project related materials, bulletins construction works Branch offices channels. coordinated with measures to be areas, farmers of Notification regional applied during the using the Project QAJ NC JSC boards at Passenger construction period area and any other CLO the residential Transport and villages through areas Roads which the Project crossed by the Department transport will drive Project (focus on the areas construction along the public transport roads) 2.3 Installation of Residents of the Information boards Prior to the Regional Offices of Has to be information boards project related construction works Branch offices Ulytau & coordinated with with contact details areas, farmers of QAJ NC JSC Karaganda regional akimats of the CLO using the Project Regional and nominated site adjacent areas Branch offices Contractors as pastureland, of visitors of the QAJ NC JSC cemetery. Regional/rural/ Other interested village Akimats parties offices Construction sites 2.4 Assigning the Officials and Information boards Prior to the Contractors Offices of has to be Contractors’ CLO residents of the and bulletins, construction works Ulytau & coordinated with main settlements notifications, social Karaganda regional akimats related to the media accounts of Regional and nominated Project area nominated Branch offices Contractors Regional Branch contractor of offices of (Facebook, Twitter, QAJ NC JSC QAJ NC JSC Instagram, Regional/rural/ WhatsApp etc.) village Akimats offices Construction camps 39 2.5 Holding informative Officials and Mass media, Prior to the Project Regional/rural/ has to be meetings/discussion residents of the information boards construction works Construction village Akimats coordinated with s to present and main settlements and bulletins, (during the contractor/s offices nominated discuss the Project’s related to the notifications, social mobilization period) (CLO) in Contractors EHS impacts, risks Project area, media/ network consultation and opportunities as farmers using the accounts of the with the well to make the Project site Contractors and Regional local stakeholders adjacent areas as Regional Branch Branch offices aware of grievance pasture-land, local offices of of redress principles business QAJ NC JSC QAJ NC JSC applied within the (Facebook, Twitter, Project. Instagram, WhatsApp, community outreach, etc.) 2.6 Prepare Frequently Officials and Mass media, Prior to the CLO of the Regional TBD Asked Questions residents of the information boards construction works Project Branch offices Leaflet outlining: (a) main settlements and bulletins, (during the Contractors in of Project summary, related to the leaflets, mobilization period) consultation QAJ NC JSC (b) EHS impacts, Project area, social with the Regional/rural/ risks and farmers using the media/network CLO of the village Akimats opportunities, (c) Project site accounts of the Regional offices mitigations already adjacent areas as Contractor and Branch offices Construction adopted/to be pasture-land, local Regional of QAJ camps implemented, (d) business, NGOs Branch offices of other questions QAJ asked during the NC JSC Stakeholder (Facebook, Twitter, engagement events Instagram, and in past years community outreach by Facebook, WhatsApp, Tweeter, etc.) 3. CONSTRUCTION STAGE 3.1 Installation of the Potentially Grievance forms Simultaneously with Regional Regional boxes with the affected the start of the site Branch offices Branch offices Public parties; preparation works; of QAJ NC JSC of 40 Grievance forms for other stakeholders the boxes to be CLO QAJ NC JSC suggestions and checked twice a Regional/rural/ complaints week village Akimats offices Construction sites 3.2 Keeping a record of Potentially Grievance Throughout the CLO Regional the received affected (Suggestion and Project cycle Branch offices grievances parties; Inquiry) Logbook of (suggestions and Other QAJ NC JSC inquiries) in the stakeholders specific logbook(s) 3.3 Provision of updates Affected parties; Project’s progress Throughout the Regional Project on the Project’s Regional / rural / publications, radio, construction stage, Branch offices webpage / status / progress District Authorities social media, TV at least quarterly of Company and state announcements, QAJ NC JSC website authorities; community Regional/rural/ Regional NGOs outreach. village Akimats Branch offices Other offices of stakeholders Nominated QAJ NC JSC Contractors Regional/rural/ village Akimats offices 3.4 Organisation of Any stakeholders Specific information Throughout the Regional Various meetings and that raise issues depending on the Project Branch offices locations consultations with (specific attention topics of interest of depending on the to QAJ NC JSC the stakeholders on the the potentially Regional/rural/ originator and topics raised by the affected parties) village Akimats types of stakeholders, offices questions whenever necessary CLO 3.5 Report on MoT CoR Relevant reports On quarterly basis Contractors Email or cloud engagement Regional Branch and starting from the CLO storages activities offices of QAJ NC Stakeholder construction works quarterly to the JSC Engagement Log Client’s CLO so the Client can update SEP on quarterly basis (update will 41 include mostly disclosure of the Stakeholder Engagement Log) 4. OPERATION AND MAITENANCE STAGES OF THE PROJECT Report on Stakeholders and Relevant reports During the operation MoT CoR WhatsApp and engagement of the project and and maintenance Regional other social project communities communities Stakeholder period of the project Branch offices platforms used and other including project Engagement of QAJ NC by the wider stakeholders; affected persons Logbook; JSC, relevant community Disclosure of the Akimats members; other stakeholder media as engagement appropriate; Logbook 42 12.GRIEVANCE REDRESS MECHANISM The Project's Complaints Handling Procedures are designed to provide an effective and methodical mechanism for the Project to respond to enquiries, feedback and complaints from affected persons, other key stakeholders and the general public. The general outline of the Project's GRM is included in the Stakeholder Engagement Plan (SEP). The grievance redressal process for land acquisition and resettlement is detailed in the following section. Levels and Procedure of Grievance Redress The Grievance Redress Mechanism (GRM) is accessible to individuals who reside or are employed in the areas where the project's activities have an impact. Every person who is affected by or concerned with the project's execution has the right to take part in the GRM; people should also be encouraged to use it and have easy access to it. The proposed GRM aims to reduce the use of the public complaints and dispute resolution processes provided by the RoK legal system, without replacing them. CoR and JSC NC QazAutoJol central office and regional branch offices have the primary responsibility for ensuring that the GRM implementation is completed on time. They can be supported by consultants and Construction Supervision Consultant (CSC), who shall be involved in managing and overseeing the construction works and other activities related to the investment program. Related region, district, and community Akimats, who are legally obligated to carry out tasks linked to resolving complaints, and mediators / non-governmental organizations (NGO), who are involved in supporting the negotiation of grievances, are also part of the grievance redress mechanism (GRM). The Grievance Redress Mechanism (GRM) for road sector projects implemented by the Committee for Roads consists of two levels of grievances redressing: the Grievance Redress Committee (GRC) at the regional (oblast) and central (Astana) levels. These levels operate in accordance with the Guidelines on Grievance Redress Mechanism on Environment and Social Safeguards in Road Sector Projects, which were approved by the Committee for Roads in August 2014 (GRM Guidelines). The GRC is composed of members who are appointed from CR, akimats, QAJ, CSC, and the Contractors. At both regional and national levels, the GRC is led by senior managers who are responsible for overseeing the entire operations of the GRM and ensuring its efficient and timely execution. Meanwhile, coordinators are accountable for engaging key stakeholders and overseeing the coordination of GRC activities at both regional and central levels. GRM: Regional (Karaganda & Ulytau regions) Level Initially, the resolution of the grievance will be received through the Grievance Redressal Committee (GRC) at the regional level, following a specific set of stages. Grievance registration. Any individuals can visit, contact, or write and leave a letter in set up boxes in construction sites and local akimats , email, to the district akimats, the grievance coordinator of the Contractor, PMC, and GRC coordinator of QAJ. Receipt of grievances 43 submitted in person, by phone, by letter, by email, shall be acknowledged. At both local and regional, the GRC also takes into consideration anonymous complaints, in situations when the person making the complaint declines to disclose their contact information or where no contact details are included in the grievance received via email, mail. A grievance logbook will be made available for stakeholders attending public consultation meetings and will be available at the akimats offices of each settlement and focal points to record comments anonymously, if preferred. This logbook will be presented in a familiar area that will not be directly monitored by host staff (e.g. by the exit). Complaints will be documented using a predetermined form outlined in (Appendix 1). GRC will be established at the regional level that will include: (a) Representatives of QazAutoJol ’s regional branch (deputy director and a safeguards specialist or lawyer); (b) Consultants’ team representatives (safeguards specialist and public relations specialist) I Representatives of regional and district akimats (one from each Akimat located in the project area); (d) Representatives of the CSC (head / deputy head and protective measures specialist/public relations specialist) I Representatives of the Contractors (head / deputy head and safeguards specialist / community liaison specialist) Grievance processing. Any inquiries or complains that have received clarifications and a decision at the time of submission will be promptly closed. The GRC at the regional level reviews cases that necessitate additional steps. The Regional GRC gathers twice a month meetings and holds special meetings as needed to address specific issues. It promptly reviews and discusses grievances within a period of ten working days and provides recommendations for their resolution to the concerned parties. The regional GRC coordinator offers relevant data to GRC members, compiles meeting minutes and progress reports, and ensures that actions and decisions are accurately recorded. Provision of feedback. Disputes lodged verbally or in writing shall be promptly acknowledged upon receipt. Complaints received via letter, e-mail, or fax and acknowledged via letter, fax, or e-mail within three working days of receipt by the GRC coordinator at the regional level. If the grievance is unrelated to project activities or impacts resulting from project implementation and therefore cannot be addressed under this GRM Guideline, the complaining party will receive a response specifying which entity (Akimat at the community, district, or oblast level, as applicable) received the complaint. The results of any redress for grievances at the regional level will be communicated to the complainant. If the matter is not resolved at the regional level and is instead transferred to the central GRC, the complainant will be formally notified, with the notification specifying the date the case was transferred to the central GRC and the anticipated date of decision-making at the central level. In the event of an anonymous complaint, a paper response will be posted at the information stand of the respective regional branch of JSC NC QazAutoJol, along with the relevant Akimat, to ensure that the complainant has easy access to it. 44 GRM: Central Level After the grievance has been unsuccessfully addressed at the regional level by the GRC, efforts will be made to resolve the complaint at the central level using the measures outlined below. Grievance processing. In the event that the GRC is unable to resolve a grievance at the regional level, it will be transferred to the GRC at the central level for evaluation, accompanied by any relevant documentation. At the central level, the GRC (i) conducts monthly meetings, with the flexibility to schedule ad hoc meetings as required; and (ii) evaluates grievance cases and provides parties with settlement recommendations within a period of twenty working days. The central-level GRC Coordinator is responsible for disseminating pertinent information to GRC members, preparing progress reports and minutes of GRC meetings, and ensuring that actions and decisions are appropriately documented. Also, any individual can submit an electronic appeal to the state authorities on the e-otinish website https://eotinish.kz/kk Provision of Feedback. In the event that the grievance has been successfully resolved, the person who complained shall be formally notified of the resolution's outcome. The complaining party will be furnished with relevant details if the grievance remains unresolved by the GRC at the central level. This information will include the specific reasons for the case's unresolved status, along with a recommendation for further resolution through the RoK legal system. In the event of an anonymous complaint, a paper response will be posted at the information stand of the respective regional branch of JSC NC QazAutoJol, along with the relevant Akimat, to ensure that the complainant has easy access to it. GRM: Legal System In accordance with RoK legislation, if a resolution cannot be reached following discussion and assistance from regional and central GRCs, or if the complainant remains dissatisfied with the grievance redress system, the case shall be referred to the court for resolution. Nonetheless, it should be emphasized that GRC management does not restrict a complainant's initial right to refer the case to court as part of the grievance redress procedure. Grievance Focal Points PAPs and other stakeholders may visit, call, email to, or fax the GRC for the Karaganda and Ulytau region at the regional level. The details of the focal persons in Karaganda and Ulytau region were shared with the stakeholder’s at the hearings conducted in June 2024. Other details will be shared with the stakeholders and the wider public once the project implementation starts. GRC Contact Details (Regional Level): Contact person: Bektimirov Rafael & Rakhimzhanov Sungat Address: Karaganda, Republic ave. 42, 4 floor/ Zhezkazgan, Sary Arka street 82, 2 floor Tel: +7 702 287 90 90/+ 701 916 77 07 Email: karaganda.info@qaj.kz /ulytau.info@qaj.kz 45 The regional GRC for Karagandy and Ulytau region includes the following members: Head of GRC: (to be appointed from CoR/regional Akimat) Coordinator of GRC: (to be appointed from CoR/Contractor/PMC/CSC) Members: Representative of Department of Passenger Transport and Automobile Roads of Karagandy & Ulytau regions; (to be appointed) Representative of Karagandy & Ulytau regional Akimat; (to be appointed) Representative(s) of NGO. (to be appointed) At the Central GRC the key persons are: Head of GRC: (to be appointed) Coordinator of GRC: (to be appointed) GRC Contact Details (Central Level): Contact person: (to be appointed) Address: 32/1 Kabanbay Batyr ave., Astana, 010000, Kazakhstan Committee of Roads, Ministry of Transport of the Republic of Kazakhstan Tel: E-mail: Disclosure of the Grievance Process The public has been and will continue to be informed about the grievance redress procedure under this RAP through the distribution of information brochures and the installation of information stands in rural district/regional akimats and the Executing Agency (or an EA representative at the regional level). During public consultations and unofficial meetings on project-site, representatives of the ESF Consultants team, NC QazAutoJol JSC, and/or an EA regional representative will also present the grievance redress mechanism. The following table presents a template for the grievance registration and resolutions activities. The client/users of the form may amend the form as appropriate, but all grievances/enquiries need to be systematically recorded and reported on in all due reports. A brief overview of grievance redress/project queries will be included in the reports that the EA/CR/PMU and Supervising Engineer teams should prepare and submit to the World Bank for information and approval. A suggested template for the recordings of the GR cases is presented in the following table. 13.MONITORING & REPORTING Regional/ rural akimats and regional branch offices of QAJ and the CLO will monitor the SEP implementation and communication channels used such as media, one-on-one meetings, community consultations and regular meetings with other stakeholders and will provide feedback as appropriate. Regional/ rural akimats and regional branch offices of QAJ and the CLO will record information related to the SEP implementation so that community responses and feedback can be provided for stakeholders. Independent consultants, in line with annual monitoring of 46 the ESAP implementation, should undertake quarterly monitoring of the SEP implementation including the implementation of the grievance mechanism. This will include the examination of documentation on public hearings, information disclosure and any other form of stakeholder engagement undertaken as part of the SEP. The following table presents basic SEP parameters to be monitored and reported on. Table 9: SEP Basic Monitoring Parameters to Monitor Issues Monitoring Indicators Set up of institutional  Establishment of the PMU, focal person for monitoring arrangements implementation of the SEP and other social standards documents Grievance mechanism  Number and type of published information about GM (GM)  Number of complaints/enquiries and its nature  Number of complaints resolved  Number of complaints/ enquiries pending and at what level of the GM Public  Number of types of consultation meetings consultations/stakeholders’  Summary of main issues raised, if any engagement  Number of meeting participants disaggregated by gender  Number and type of the information sharing with project affected people  Number and type of engagement of people with disabilities and other vulnerable groups Budget expenditures  Budget expenditures for the SEP implementation and monitoring  Overall % of budget disbursement assigned for the SEP implementation and monitoring Overall progress against  Any delays and reason agreed SEP implementation schedule; Plan for the future  Number and type of engagement planned stakeholder engagement  Number and type of stakeholders engaged (gender disaggregated)  Any other indicator not envisaged in this plan Others  Check if the outstanding issues raised in the previous monitoring reports have been addressed or not.  Suggested mitigation measures 47 APPENDIX 1 Public Grievance Form Document number: Full name Name Surname Note: please mark, I ask not to disclose my personal details without my consent / I would like to whether you agree to submit this grievance anonymously disclose your personal details to third parties without your consent? Contact details Address Note: Please mark how you wish to be contacted (mail, Telephone / e-mail telephone or e-mail) Preferred Language for □ Kazakh communication □ Russian □ English □ Other (please, specify) Description of an incident/enquiry or a grievance: What has happened? Where did it happen? Who was involved in an incident? What are the consequences? Date of Incident / Please mark the date (month / year) Grievance One time incident (date) Happened more than once (how many times?) Ongoing (current problem) What would you like to see happen to resolve the problem? Signature: Date: Please send this form to the following address: Contact person: Bektimirov Rafael & Rakhimzhanov Sungat Address: Karaganda, Republic ave. 42, 4 floor/ Zhezkazgan, Sary Arka street 82, 2 floor Tel: +7 702 287 90 90/+ 701 916 77 07 Email: karaganda.info@qaj.kz /ulytau.info@qaj.kz 48 49 APPENDIX 2 The Republic of Kazakhstan legislation and World Bank’s Requirements on Stakeholder Engagement The Republic of Kazakhstan (RoK) legislation and International Requirements (including WB ESS 10 and other relevant WB Standards) on stakeholder engagement shall be complied with in the preparation of the SEP. The RoK legislation states that the public should be informed about the Project and have an opportunity to comment on the information provided to it during the development / discussion of the Project. The Environmental Code of 2007 was the key environmental legal document of the RoK before the new Environmental Code adopted in January 2021 entered into force on 1 July 2021, with some articles coming into effect stepwise. The key legal acts related to the Environmental Impact Assessment (EIA) procedure and information disclosure, and applicable to the Project are described below. A national EIA for the Project (including public consultations) was conducted according to the 2007 Environmental Code, with Article 57 of the corresponding Code stating that publicity of the State Environmental Appraisal (SEA) would be ensured through public hearings and that all interested citizens and public associations would be given the opportunity to express their opinion during the SEA. Articles 57-1 and 57-2 of the Code respectively described the means of public participation in the decision-making process on environmental protection issues and the projects for which it is mandatory to conduct public hearings. The latter also stated that "local executive bodies, twenty days prior to the holding of public hearings, provide open access to environmental information related to the EIA procedure of planned economic and other activities and the decision-making process for these activities through an Internet resource, as well as using other methods of information". Since the 2021 Environmental Code provides for the public hearings during the national EIA procedure there are no requirements for accounting public opinion during the post-EIA stage, i.e. during the project construction or operation stages. Article 8 of the Instruction on the EIA elaborates on the accounting public attitudes in the development of the EIA. According to the Instruction, the project sponsor is responsible for organizing and accounting public attitudes through public participation in the development and discussion of EIA materials. The Rules on Access to the Environmental Information Related to the EIA (OVOS) Procedure and Decision-Making Process determine the content and procedure for access to environmental information related to the procedure of EIA (OVOS) for all interested individuals and legal entities and their participation in the decision-making process on the planned economic and other activities. Interested parties/stakeholders can gain access to the materials of the SEA except for the confidential information (draft EIA; conclusions of external experts on the draft EIA; minutes of public hearings on the draft EIA; written requests from stakeholders on the draft EIA; the conclusion of the SEA) by sending a written request to the authorized body. The latter in accordance with the legislation within 15 calendar days gives a written response indicating the place and time where they can get acquainted with the requested materials. 50 The Instruction on conducting the Environmental Impact Assessment defines disclosure process of Project information (environmental and social impacts, risks, etc.) through public hearings, gathering of written proposals and comments from the public as well as through gathering of written proposals and comments through a questionnaire survey of the Project area population. Pursuant the Rules for conducting public hearings the public hearings are conducted through open meetings as well as through surveys. When arranging an open meeting the project owner arranges with the respective local executive body the time and place of public hearings, a preliminary list of attended stakeholders and justifies the optimum approach for notification (announcements in the media, newsletters, stands, written appeals). The local executive body endorses the list of attended stakeholders, the notification method, the time and place of holding public hearings, and appoints the person responsible for holding public hearings. When arranging public hearings through an enquiry the Project owner sent a notification to the respective local executive authority. The Project owner publishes an announcement in the media notifying about the public hearings. An official appointed by the respective local executive authority gathers the stakeholders’ comments and recommendations and sends to the Project owner. Then the stakeholders’ feedback is reviewed and a protocol of holding of public hearings through enquiry is made up. The procedure of public hearings will be determined by an authorized environmental protection authority and will: (i) Identify stakeholders; (ii) Specify locations where information and consultations can be received; (iii) Specify public notification methods (posters, press publications, exhibitions displaying plans, schedules, drawings, models etc.); (iv) Specify public consultation methods (written statements, polling); (v) Duration of the public hearing process. The road construction projects are included in the list of economic operations, which design documents are subject of public hearings. Following the state environmental review, all stakeholders will be able to receive information about the target of the review in the manner prescribed by the Environmental Code. Pursuant to Article 163 of the Environmental Code, environmental information will be public except as required by the applicable laws of the Republic of Kazakhstan. Access to specific data and materials is provided through responses containing such data to requests for information submitted by individuals and legal entities, distribution of such data in the media including special publications and the Internet, and in generally available means of communication. Pursuant to the Instruction on environmental impact assessments of proposed economic and other activities as part of the development of pre-planning, planning, pre-design and design documents (Article 49, Law No 126-VI dated 27 December 2017 (signed into law 29 June 51 2018) of the Ministry of Environmental Protection of the Republic of Kazakhstan), the customer will at all stages of the environmental impact assessment (EIA): (i) Ensure the provision of information to and participation of the interested public in the EIA process; (ii) Provide the interested public with access to the EIA materials. The public hearings is main organizational form of determining the public opinion. The public hearings cover results of the Preliminary EIA and the EIA of proposed economic activities that may have a significant impact on the environmental and human health. Participants of public hearings include: (i) Impacted stakeholders including interested public; (ii) Non-governmental organizations and associations; (iii) Local executive and representative bodies, governmental bodies authorized to make relevant decisions; (iv) Mass media. During the hearings, any participant had the right to express his or her opinion and address questions to – and receive answers from – the speakers. The results of the public hearings are analyzed and presented in this SEP. The public hearing minutes contain private data of the participants and as such, cannot be disclosed but can be access on the request to the QAJ. The client and the EIA developer will review the public hearing results and incorporated public opinions into the SEP and other social and environmental documents prepared for the project. The Project Initiator (QAJ) was responsible for the financing, technical and information support of the public hearings. World Bank requirements in accordance with Environmental & Social Framework 2018. ESS 10 recognizes the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice. Effective stakeholder engagement can improve the environmental and social sustainability of projects, enhance project acceptance, and make a significant contribution to successful project design and implementation. ESS10 Requirements: Borrowers will engage with stakeholders through- out the project life cycle, commencing such engagement as early as possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on project design. The nature, scope and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts. Borrowers will engage in meaningful consultations with all stakeholders. Borrowers will provide stakeholders with timely, relevant, understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. The process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. 52 The Borrower will maintain, and disclose as part of the environmental and social assessment, a documented record of stakeholder engagement, including a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not. Key differences between World Bank’s ESS10 requirements related to Stakeholder Engagement & Information Disclosure and RoK legislation: Table 10: Gaps Between ESS10 and ROK and Measures to Address the Gaps ESS10 RoK Measures to address the gaps TIMING AND NATURE OF STAKEHOLDERS ENGAGEMENT Stakeholder engagement is an Engagement occurs primarily Extend the stakeholder inclusive process which is most during the EIA process, with engagement process beyond the effective when initiated at an emphasis on public hearings EIA stage to cover the entire early stage of the project before project approval. project lifecycle. development process, and is an Employ measures to promote integral part of early project meaningful engagement (engage decisions and the assessment, with stakeholders throughout the management and monitoring of project life cycle, commencing the project’s environmental and such engagement as early as social risks and impacts possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on project design. Engagement is required Kazakhstan may not require Project to provide for ongoing throughout the project lifecycle, ongoing engagement after the consultation with stakeholders, starting as early as possible and EIA stage. particularly those affected by the continuing throughout the project project, and the interested public stages. at all stages of the project. At least one consultation, or more, if necessary, should take place at each stage of the project. The Borrower will identify those Limited requirements to identify Development of targeted project-affected parties and assist vulnerable groups. measures so that adverse (individuals or groups) who, Social allowances are envisaged impacts do not fall because of their particular for the households below the disproportionately on vulnerable circumstances, may be poverty line, large families households, and they are not disadvantaged or vulnerable. having four or more children disadvantaged in sharing the below 18 years of age, benefits and opportunities households with members with resulting from the project. dissability. Tailored/differentiated engagement with vulnerable groups. MEANINGFULL CONSULTATIONS The Bank emphasizes The national legislation Project to ensure that meaningful consultations that are mandates public hearings and consultations are conducted in a free of manipulation and other access to information, ensuring manner that is free of negative influences and requires that stakeholders can express manipulation and coercion and is culturally appropriate methods their opinions. culturally sensitive. The SEP ensures continuation of meaningful and transparent consultations, free of any negative influences. 53 The Bank emphasizes Kazakhstan’s legislation may not Project to ensure that consultations that are free of explicitly address the need for a consultations are free, manipulation and other negative influence-free environment or transparent and culturally influences and requires culturally specify culturally appropriate appropriate. appropriate methods. consultation methods. Information disclosure in a timely, understandable, accessible and appropriate manner and format. PROCESS OF STAKEHOLDERS ENGAGEMENT The Bank specifies a detailed The legislation outlines a Project to develop and process including stakeholder process involving public implement a robust grievance identification and analysis, notification, stakeholder redress mechanism that allows planning, disclosure, identification, and public stakeholders to raise concerns consultation, grievance redress, hearings, but does not explicitly and receive responses and reporting. mention grievance mechanisms. throughout the project. The process may not be as thorough as the World Bank's, Effective, inclusive engagement particularly regarding grievance and grievance management, free redress and ongoing reporting. of retaliation to be established GRM should be accessible and inclusive means to raise issues and grievances. DOCUMENTATION AND DISCLOSURE Borrowers must maintain and There is a requirement for public Project to enhance disclose a record of stakeholder access to information and for documentation and disclosure engagement, including feedback documentation of the public requirements to include detailed received and how it was hearings process, but continuous records of all stages of addressed, throughout the documentation throughout the stakeholder engagement and project. project is not explicitly how feedback has been mentioned. incorporated into project design The national practice may not and implementation. require as detailed documentation and disclosure Establish a reporting back to throughout the project lifecycle stakeholders as the World Bank does. By aligning more closely with World Bank standards, Kazakhstan would not only meet the requirements of international financiers but also improve the overall sustainability and social acceptance of development projects within the country. 54