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Naghlu Hydropower Rehabilitation Project (NHRP) Sub-Project: Sarobi Electrification

Title Naghlu Hydropower Rehabilitation Project (NHRP) Sub-Project: Sarobi Electrification
Attachments fcac83bb1321373a918a3b0f3a8b1079.pdf
Publish Date 2017-12-23





Naghlu Hydropower Rehabilitation Project (NHRP)

             Sub-Project: Sarobi Electrification



Site Specific Environmental & Social Management Plan (ESMP)


For Component-3


Environmental and Social Sustainability, Project Management Support, and Future Project Preparation



Da Afghanistan Breshna Sherkat (DABS)



Table of Contents

List of Acronyms. 5

1.       Executive Summary.. 1

1.2   Project Objective. 1

1.3 Project Components. 1

2.       Environmental and Social Management Plan (ESMP) 3

2.1 Introduction.. 3

2.1     Purpose of the ESMP. 3

The ESMP: Aims and Objectives of the ESMP. 3

2.2 Legislative and Policy Considerations. 3

2.3     Summary of Environmental and Social Impacts. 4

2.3.1 Potential Negative Environmental impacts. 4

2.3.2 Potential Social impacts. 5

2.3.3.       Labour Influx risk assessment 5

3.       Environmental and Social Management.. 6

3.1 ESMP Cost. 6

3.2 Environmental and Social Management Plan.. 7

3.2.1 Pre Construction Phase. 7

3.2.2        Construction Phase. 10

3.2.3        Operational and Maintenance Phase. 16

4        Implementation of the ESMP. 19

5        Grievance Redress Mechanism.. 19

5.1 NHRP Grievance Redress Mechanism (GRM) 19

6        Monitoring and Auditing.. 21

6.1 Introduction.. 21

6.2 Reporting Procedure. 21

7        Capacity Building.. 22

8        Disclosure.. 22

9        Training.. 22


(دسروبی د برق رسونی پروژه) د شکایتونو د ثبت پاڼه. 26










List of Acronyms






AP                   Affected Person(s)

CDC                  Community Development Council

CCMP              Contractor Camp Management Plan

COC                   Code of Conduct

COO                Chief Operating Officer

CV                   Curriculum Vitae

DABS              Da Afghanistan Breshna Sherkat

EHS                 Environmental Health and Safety

ESMF              Environmental and Social Management Framework

ESMP              Environmental Management Plan

ESIA                Environmental and Social Impact Assessment

ESS                  Environmental and Social Safeguards

GOA                Government of (the Islamic Republic of) Afghanistan

GRM                 Grievance Redress Mechanism

GRC                  Grievance Redress Committee 

IFC                  International Finance Corporation

ILO                    International Labor Organization

IR                    Involuntary Resettlement

LV                   Low Voltage

MEW               Ministry of Energy and Water

MV                  Medium Voltage

NDF                National Development Framework

NEPA              National Environmental Protection Agency (Afghanistan)

NGOs              Non-Government Organizations

NHRP              Naghlo Hydropower Rehabilitation Project

PAF                   Project Affected Families

PAP                 Project Affected Persons/population

PCB                 Poly-chlorinated Biphenyls

PIU                    Project Implementation Unit

PM 10                particulate matter 10 micrometres

PPE                   Personal Protection Equipment

QA                  Quality Assurance

SFO                 Safeguards Focal Point

STD                 Sexually Transmitted Disease

ROW               Rights of Way

UNMACA       United Nations Mine Action Center for Afghanistan

UXOs              Unexploded Ordinances

WB                  World Bank


1.      Executive Summary


1.1   NHRP project background ( Sarobi Electrification )


The NHRP Electrification Project includes construction/installation of  distribution network  for the selected communities around Naghlu dam (upstream and downstream residents) of Sarobi district of Kabul province, Afghanistan.

The general aims of project are providing electricity to households, institutions, and businesses in the selected villages of Sarobi district Kabul Province.

The proposed activities are expected to  have overall positive Social and Environmental impacts. However, it will also cause  some limited negative impacts , particularly during implementation phase, for which the following site specific Environmental & Social Management Plan (ESMP) is prepared to outline the types of control measures that must be implemented to reduce environmental and social risks during Construction and distribution of electricity.


1.2   Project Objective

The Project Development Objective is to increase the supply of electricity and to improve dam safety. 


1.3 Project Components


  1. Component 1: Mechanical, Electrical, and Electromechanical Work. This component complements the rehabilitation of the electrical and electromechanical parts of the plant previously undertaken and ensures their sustainable operation. It consists of two subcomponents as follows:
  • Subcomponent 1(a): Rehabilitation of Unit 1 and Balance of Plant. This includes the completion of electromechanical rehabilitation work focused on Unit 1, particularly (i) testing of the existing bent rotor shaft followed by repair if possible or replacement if not; and (ii) completion of rehabilitation of the existing plant.
  • Subcomponent 1(b): Enhancing Maintenance of the Powerhouse. Other units of the power house are in need of regular maintenance. This subcomponent will particularly support provision of spare parts and consumables for three to five years to ensure the sustainable operation and normal maintenance of the existing plant.


  1. Component 2: Dam Safety and Power Generation Capacity Improvement. This component aims to ensure the safe operation of the dam through the two subcomponents as follows:
  • Subcomponent 2(a): Dam Safety Audit and Safety Improvement Measures. This component will finance technical assistance and studies including (i) audit of the dam’s structural and operational safety; (ii) preparation of plans and bidding documents for works to improve safety to acceptable standards, focused on reactivating the bottom outlet, adequacy of auxiliary power and other systems, improvements to the head gates closing system, installation of instrumentation, and clearance of the UXOS from the dam structure; (iii) studies on structural and operational safety considering updated hydrological and seismic data and following relevant international/national standards/guidelines; and (iv) flood routing through Naghlu Dam to Sarobi Dam, including adequacy of its spilling arrangements.
  • Subcomponent 2(b): Optimization of Power Generation. This component aims to examine the potential for increasing power generation at NHPP. This would identify options for sustainable sediment management and for increasing the amount of electricity produced by the dam. It consists of (a) Feasibility study to examine the feasibility of various options to increase power generation and (b), Detailed design which supports the preparation of detailed designs should the feasibility study return a positive result, and will be closely guided by the findings of Environmental and Social Impact Assessment (ESIA), resettlement and livelihoods restoration, environment and social management plans, health, and other related action plans.
  1. Component 3: Environmental and Social Sustainability, Project Management Support, and Future Project Preparation .This component includes two subcomponents:
  • Subcomponent 3(a): Environmental and Social Sustainability. This subcomponent aims to ensure the environmental and social sustainability of the dam through (a) Local Development Assistance which will promote benefit sharing with local communities and will support electrification in the project area and improved access to skills training for local communities: (b) Supporting environmental and social management to ensure the effective planning, implementation and monitoring of all safeguards instruments across all project components.
  • Subcomponent 3(b): Project Management Support and Future Project Preparation. aims to ensure that DABS receives advice on good international practices.


2.      Environmental and Social Management Plan (ESMP)

2.1 Introduction

The following site specific Environmental & Social Management Plan (ESMP) is prepared to outline the types of control measures that must be implemented to reduce environmental and social risks during the implementation of the Sarobi electrification and its construction, electrical and electromechanical parts of the project at Sarobi and Naghlu hydropower plant area (component 3). The potential environmental and social risks for construction of Sarobi electrification project were identified during preparation of Environmental and Social Management Framework and consulted with relevant stakeholders including community representatives and affected persons from upstream and downstream of Naghlu Dam area .  The mitigation measures identified during that process are listed as specific commitments to direct performance criteria within the site specific ESMP for the electrification project.

The mitigation measures identified during that process are listed as specific commitments to direct performance criteria within the updated site specific ESMP for component 1.

The updated ESMP complies with the principles and policies of the ESMF for NHRP.


2.1       Purpose of the ESMP

The primary purpose of an ESMP is to mitigate/reduce potential environmental and social impacts of planned activities and to ensure that all identified environmental and social risks expected to occur during construction and electromechanical works at Sarobi electrification project are reduced to an acceptable level.


This will be achieved through engagement of all relevant parties in environmental and social management. In particular, this will include integrating environmental and social management planning with design, construction methods and operation planning.

The requirements of this plan are applicable to all on-site work carried out. The contractor will be bound to comply with the requirements of this plan, in so far as they are applicable to the nature and scope of their work.

The scope of this plan embraces the risks created by the design of the Project, the short-term risks that will arise during the construction (the works the project is paying for) and any long-term risks that are influenced by the construction methods.

The ESMP: Aims and Objectives of the ESMP


  • Draws together the measures proposed to mitigate negative, and to maximize positive, environmental and social impacts, and groups them logically into component-3 with common themes;
  • Define a proposed institutional structure to govern the implementation of the ESMP;
  • Defines the specific actions required, roles and responsibilities for these actions, timetables for implementation, and associated costs; and
  • Describes capacity building and training requirements for the implementation of the ESMP.


2.2 Legislative and Policy Considerations

Legislation and policies that are relevant to implementation of Sarobi distribution and erection of electric poles and its other electrical and electromechanical parts at the Sarobi and Naghlu hydropower plant area are summarized in Table 1.1.

Table 1.1: Summary of relevant legislation and policies



Legislation or Policy



World Bank

Operational Policy 4.01

Operation Policy 4.12

Environmental and Social assessment

Involuntary Resettlement


Environmental and Social Management Framework

Resettlement Policy Framework

Govt of Afghanistan

Environmental Law (2006)

ESIA Regulation (2017), NEPA


IFC EHS guideline

Environmental impact assessment and management

Environmental health and safety

NEPA Pollution Control and Management in



Policy discussion


Afghanistan Labor law

Land Acquisition Law (2017)

Land Management Law (2017)


MEW- Energy sector

Environmental and Social Safeguards Guideline (ESS- guideline)

Hygienic & Safety measures





2.3       Summary of Environmental and Social Impacts

2.3.1 Potential Negative Environmental impacts

The impacts associated with the electromechanical works will mainly be noise, dust, and the handling, storage and disposal of used oils. These impacts are expected to be small, localized, and temporary and thus should be able to be effectively managed with tangible and easily applied mitigation measures.

Experience shows that, the environmental and social impacts of rural electrification projects are rather limited and manageable


There are further some concerns on how pollutants and oils used in the transformers etc. will be managed. These impacts will need to be addressed in line with the ESMF and RPF for the project.

The environmental impacts associated with the Sarobi electrification and its construction ,electro-mechanical works include:  tree cutting, a number of medium and small age non fruit trees will be removed these trees are private property along the distribution line in Loy Kalai, another impact is limited damage to landscape and green cover of the near surroundings of the proposed project activities due to traffic of heavy machinery, storage of construction material and equipment’s in the area and workforce density, managing removal, storage, handling and disposal of used oil’s and lubricants, and petroleum products. Other impacts are loud noises and dust. These impacts are low to medium level and thus readily reversed or effectively managed with mitigation measures outlined in the relevant table. DABS will conduct a brief workshop to undertake risk assessment impacts of project activities under component-3 including appropriate mitigation measures. For detailed of risk assessment process refers to Annex 1- Risk Assessment Identification and Mitigation Measures, which also includes the potential social risk assessments.

2.3.2 Potential Social impacts

The electrification of villages around the Naghlu and Sarobi reservoirs has the potential to provide tangible benefits and should help counter the major grievance voiced by the local communities i.e. that, to date, they have not received any benefit from the Naghlu HPP. While limited environmental and social impacts are anticipated by this activity, some small plots of land will need to be acquired for the electricity poles and some easement acquired for the distribution lines.

Limited social safeguards impacts are predictable under local electrification of villages around Naghlo and Sarobi reservoirs \, because most of the construction and electro-mechanical work will be implemented in the premise of governmental as well as communal land for example most of the electric poles will be erected along the main road and hill tops as well as secondary road between the villages, the transformers will also built in the premises of communal land.

The overall implementation risk for this project is low, mainly due to less engagement with private cultivable lands and low tree cutting chance. Ten electric poles were planned to be erected in private cultivable thus the ESS team recommended the survey team to change the direction and erect the poles along the main road because there is the possibility which is economically friendly and socially acceptable.

Since the project presently limits its intervention to 3 km zone around the dam, the excluded villages and communities will feel unsatisfied and they might rise their voice and possibly the project implementation will experience social disputes and problems.

Experience shows that, an unsupported delimitation of beneficiary villages entails significant societal and operational risks as villages, which are not benefiting from the electrification.


Absence of adequate measures considered to reduce impacts during construction (e.g., noise, vibrations, dust, and wastes) and construction activities may adversely affect the natural environment.

there might be community safety issues-labor influx risks, and dispute and or local demand to push for hiring local residents, instead of hiring labors from outside. There can also be disputes arise over whether a hiring or firing of an employee was proper.

In addition there might be workplace complaints arising during installation activities, for which DABS has established Grievance Redress Committees both in community level and project level and will train them in grievance redress mechanism, complaint  registration method, grievance services according to project ESMF ,for more details refer to annex 7 on Grievance Redress Committee (GRC) and annex 8 on summary of consultation meeting with stakeholder and CDCs. 

 The GRM procedures as outlined in the approved ESMF will be followed.

2.3.3.   Labour Influx risk assessment


The construction and implementation of Sarobi electrification project does not require a large influx of labour from outside the project area. Most of the unskilled workers will be recruited locally in the project area- only specialized staff are expected to be recruited from outside.  The specialized staff from outside will make about 20 per cent and will be residing in labour camps in the selected district- electrification area. There will be proper location selected for labour camps, which will be away from the residential areas. Given that workers under the sub component “construction of electrification” are expected to be largely recruited locally, the overall social impacts anticipated from the labour influx of workers and followers in the selected district are rated to be low. Therefore, the labour influx related mitigation measures are likely able to be addressed solely through this site-specific ESMP. This site specific ESMP includes the employee code of conduct (see annex 9), which will be followed.




3.            Environmental and Social Management

DABS safeguards team during the process of risk assessment and preparation of ESMP identified environmental and social risks arising from all phases of the activities under component 3. The team also recommended adoption of specific mitigation measures to either:

  • Reduce risks assessed as high or medium to low, or
  • Ensure that risks assessed as low do not increase.

The following sections provides guidance to relevant parties for implementation of the mitigation measures for each project phase:

The risk level associated to component-3 Social and Environmental impacts are defined based on the assessment, during updated the Site Specific ESMP, and carried out by DABS team. 


3.1 ESMP Cost

The ESMP matrix includes estimated cost various activities under component-3. The cost will be based on the assumption of DABS team which could be varied based on the specific mitigation activities and the contractor financial estimate, which will be submitted during bidding process.


3.2 Environmental and Social Management Plan


   3.2.1 Pre Construction Phase

Table 1.2a – Implementation of Tendering Phase Mitigation Measures



Potential impacts

Assessed Risk level

Mitigation measures



Institutional Responsibilities

Estimated Cost




-Submission of tenders that fail to address environmental and social issues.


- contractor failure to attend pre bid

meeting and

-contractor failure to understand

all social and environmental

issues relating to bid



Introduce requirement for mandatory

attendance at pre-bid meetings as a

requirement for submission of a conforming


- Include site inspection on pre-bid meeting


- Provide details of environmental and social

requirements to Contractors in the bidding


Potential bidders advised in writing of mandatory attendance at pre-bidding meetings as a requirement of tender.






Site inspection included as part of pre-bid meeting


ESMP included in bidding documents

DABS  NHRP project Manager and DABS

Procurement Manager





DABS Safeguard team

Contractor to include  Social and Environmental mitigation measures in bidding  documents 


Bid evaluation

-Selection of Contractor with little or no understanding of

environmental and social


- Selection of Contractor that has made no allowance for

environmental and social

requirements in determining bid


- Limited implementation of

environmental and social


- failure to take environmental

and social requirements into

account during bid evaluation


-Include environmental and social

requirements in BOQ

- Provide recognition of contractor costing of

environmental and social items in bid


- Include environmental / social expertise on

the bid evaluation committee.

Modified BOQs include environmental and social mitigation measures


Bid evaluations include assessment of contractors’ costs for implementing environmental and social mitigation measures.


DABS safeguards focal point sits on the bid evaluation panel

DABS NHRP project managers, DABS procurement manager











Table 1.2b – Implementation of Pre- construction Phase Mitigation Measures



Potential impacts

Assessed Risk level

Mitigation measures

Monitoring Indicators

Institutional Responsibilities

Estimated costs/USD



Preparation of




Plan (CCMP)

- Increased risk of workforce


- Increased risk of damage to

built environment;

-failure of contractor to prepare

an acceptable CCM


-Include requirement for CCMP in


- Apply QA principles to CCMP acceptance

-Discuss contractor proposals with DABS

Acceptable CCMP drawing included in specifications





Written confirmation of CCMP acceptance by DABS/ NHRP Safeguard team+ consultant prior to works on site







DABS/ NHRP Safeguard team.

Contractor to include training for safety labor influx risk and community safety

Contractor will conduct training for community local government representatives in Env.&Social issues ( gender and social inclusion included ) Public awareness of beneficiaries to use the grievance(8600 )

Erection of




Location in unsuitable site


-Identify suitable camp site in consultation with Sarobi power department officials

- Obtain relevant approvals for camp location

Suitable camp site identified



Relevant approvals obtained for camp site.





DABS Sarobi power department officials.





evidence of key



Low quality \ unacceptable


- failure of Contractor to provide

evidence of key staff



-Include requirements for key staff

qualifications in bidding documents;

- Non-acceptance of Contractor work plan until

evidence is provided

Bidding documents include requirement for contractors to provide documentary evidence of key staff qualifications



DABS /NHRP Safeguard team



3.2.2          Construction Phase

Table 1.2c – Implementation of construction Phase Mitigation Measures



Potential impacts

Assessed Risk level

Mitigation measures

Monitoring Indicators



Estimated costs/USD




Operation of




Increased levels of PM10 in the

Power plant site especially

during summer

- Community inconvenience;



- uncontrolled dust generated

from operation of Contractor



Undertake watering of camp site

-Implement approved work plan

-Submit regular monitoring reports

Existing of proper ventilation


Regular measurement of PM10



-Include requirement for regular watering of

camp site and construction sites during

summer in bidding documents

- During summer Contractor to undertake

water spraying each day before start of work

and regularly throughout the day thereafter

and as otherwise directed by the site


- Implement approved work plan

- Monitor and submit monthly reports on

contractor implementation of approved work

plan and mitigation measures

DABS/NHRP Safeguard team.
















Contractor to consider  ventilation and watering of the camp site and construction sites.

Operation of




-Contamination of soil, surface

and groundwater;


- pollution and nuisance to the

community from lack of latrines,

Bathrooms, potable water and medical equipment.


Include requirement for implementation of

mitigation measures in the bidding


- Provide workers with appropriate facilities;

-Undertake regular monitoring;

- Implement QA requirements

Check of data collection and log book for leakage


Number of sanitation facilities in the site


Quality and quantity of water point in the site

Bidding documents to include requirements

for workers to be provided with the following


− Adequate numbers of functional

bathrooms and latrines (latrines may

be portable)

− Covered rubbish bins for scraps

− Adequately stocked first aid medical kit

− Trained person to provide first aid

assistance if required

- Bidding documents to include requirement for

provision of facilities for collection and

regular disposal of solid and liquid wastes

- Undertake regular disposal of solid & liquid


- Undertake regular monitoring to ensure

compliance with requirements

- Issue NCR and CAR for non-compliances

- CAR not to be released until non-compliance

is addressed


























Management of

spills and



- Contamination of soil, surface

water and groundwater;

- Increased risk of injury;


- failure to promptly attend to spills;

- failure to appropriately dispose

of construction debris.


Include requirements relating to spill

management and debris- old spare parts removal in bidding


- Include spill and debris/waste removal in Contractor

work plan;

- Promptly attend to oil spill

- Collect and dispose of construction debris in designated locations

- Monitor performance in accordance with QA


Existing of the primary and secondary collection point


Availability of First Aid kit


Availability of trained First Aid provider in the work force

-Ensure that requirements relating to spill management and debris are included in bidding documents;

- Ensure that the Contractor addresses spill

management and debris removal as

inclusions in acceptable Contractor work


- Include requirement for Contractor to

promptly attend to oil spills in bidding


-Ensure any oil spills are attended to promptly

- Ensure Contractor collects and disposes of

construction debris in designated locations

- Monitor Contractor performance in

accordance with QA requirements







Sarobi power department with Safeguard team from DABS












DABS/NHRP Safeguard team


Removal of some existing old poles.






















Social impacts




























































Installation/ erection of distribution network

Risk of injury

-the newly hired workers face a higher injury rate





















-Community Safety issues.


-Labor influx risk.

















-Community Disputes.





-Local community complaints and inconvenience from project activities


-Local community to push for hiring local residents instead of outsiders.


-Community inconvenience from delay in project implementation







Land acquisition impact


Contractor to comply with health, safety requirements of GoA and the IFC/WB.


-Contractor to ensure to ensure that All employees practice and demonstrate a high standard of personal safety and hygiene.


-DABS’s SFO with Sarobi power department officials to monitor Contractor

performance and implement

- QA provisions as required


- Contractor to comply with safety guideline.


 –Undertake community and stakeholders consultation

The employee code of conduct (see annex 9) includes measures which will be applied.



-establishing GRC at community and project level to register and address the complainants













- GRC committee to satisfied community



EHS guideline are provided and staff are trained





















- Monitor contractor performance related to safety and health issue





-Implement the modified community consultation plan







-Assure from performance and activation of GRC




-insure to follow up the mandate clause by contractor


- Monitoring of GRC performance

Ensure that requirements of relating to safety and hygienic included in bidding documents.


Ensure that all project staff follows safety measures.


-ensure all newly hired staff received training on safety and health issue.


Monitor contractor performance related to safety and health issue.







NHRP staff,

DABS Social Safeguard team.





NHRP Staff

DABS Social Safeguard team.














-DABS social safeguard team


















Sarobi power department officials and Safeguard team




DABS Social and Environmental safeguard team,




-NHRP manager ,DABS Social Safeguard team.


















-NHRP manger and Social safeguard team.

Contractor to conduct health and safety training to their workforce

(2000 )



















 Contractor to conduct community safety and Labor influx risk training


DABS will conduct training for GRC members regarding the Grievance Redress Mechanism and Grievance Registration 


3.2.3          Operational and Maintenance Phase

Table 1.2d Implementation of operational Phase Mitigation Measures


Potential impacts

Assessed Risk level

Mitigation measures





Estimated Cost



Installation/ erection of electric poles and transformers, distribution of power cable and power line


 risk of injury and health issue


Contractor to comply with health and safety duty under IFC EHS guideline.

-contractor to comply with health and safety law of Afghanistan

-Ensure all newly hired staff received training on safety and health issue.


Monitor contractor performance related to safety and health issue





Sarobi power department officials

Contractor and DABS /NHRP

Contractor to conduct health and safety training to the project staff

Storage and stock-pilling

Leakages of chemical.

Risk of injury.

Health and hygienic issue


Contractor to comply with health and safety requirement under IFC EHS guideline.

Failure to comply with GoA law

Ensure reference is made to relevant guideline in the bidding documents.


Ensure all employees received training on handling and storage of equipment and spare  parts



Monitor contractor performance related to safety and health issue











Sarobi power department officials +DABS Safeguard team


Contractor and DABS/NHRP


Maintenance of the


Electric poles,

Distribution line

Contamination of soil, surface

water & groundwater

-Increased risk of injury


Employee of(Sarobi power department who will be responsible for maintenance)  to promptly operate and maintain the

Distribution network  and to appropriately dispose the use oils and

or replace of spare part

Ensure all staff working in the Sarobi power department received training in safety and hygienic issues.


Ensure to follow safety and health requirements outlined in the IFC ESH guideline and Afghanistan safety law.

Monitor contractor performance related to safety and health issue





Sarobi power department officials









Contractor to conduct training to their staff about IFC and EHS regulations


4              Implementation of the ESMP

DABS- NHRP team will be responsible for ensuring implementation of the ESMP. Other key parties in the ESMP implementation will be Sarobi power department Manager and the Contractor. Contractor will be responsible for implementation of this site-specific ESMP. 

The DABS- safeguards focal officers and contractor assigned Social and Environmental focal point will be responsible for ensuring appropriate corrective action is taken by the Contractor for any failure to implement required mitigation measures during construction of electrification and it’s electrical and electromechanical parts of Sarobi electrification.

Where contractual agreements are entered into for work associated with rehabilitation work under component 3, NHRP will:

  • include the ESMP in contract documents for all work to be undertaken by the contractors
  • ensure that the contractor comply with the requirements of the ESMP


5              Grievance Redress Mechanism  

All complaints about construction works under component 3 will be directed to and recorded by the DABS safeguard focal specialist. The safeguards focal specialist will maintain a complaints register that records details of all complaints received, the action taken in response, where necessary, and any corrective actions or procedural changes implemented to prevent recurrence. The initiator of the complaint will be advised of the results of all investigations and actions taken. The register will be regularly audited by the NHRP Project Manager (PM) to ensure timely response to complaints.

The safeguards focal specialist will review the register daily and advise NHRP PM of any relevant complaints. The Project Manager will then investigate the complaint and instigate any corrective action required.

NHRP grievance redress mechanism described in the ESMF will be strengthened by inclusion representatives from the Sarobi power department officials.

In case of an appeal, the appellant will have the option to approach the DABS CEO.


5.1 NHRP Grievance Redress Mechanism (GRM)

The approved ESMF for NHRP outlined GRM process, as following:  

The GRM covers grievances related to both environmental and social concerns, including workplace complaints. The elements of the project’s GRM conducted or accessed at the following different levels are:

  • Efforts made to resolve issues at community level
  • A Grievance Redress Committee at district/project level
  • Appeal mechanism to DABS management
  • Local GRC members with responsibilities.
  • Capacity building support.
  • Information sessions for local communities and contractor staff to use grievance service.
  • Uptake channel for grievance registration- multiple uptake channels for grievance registration will be in place. For example, grievance registration form (please see annex 2 “sample grievance registration form. 
  • Local grievance logbook to log grievance.
  • Registration of all grievances in the central GRM database of excel sheet to enable tracking and review.

These processes need to be applied for local electrification component.

Where an individual has a grievance she or he,   should, in the first instance, be encouraged to make use of existing local-level structures (e.g. CDCs/shura and village leaders) to try to resolve quickly any concerns or grievances related to project development and implementation.  The GRM structure that outlines the grievance handling process is shown below. It is worth mentioning the activities under component three will be happing within the premise of the Naghlu and Sarobi power plants area; where the Sarobi power department officials will act to address grievances at level 1 (power plant official will be acting in place of community or CDC).

Please refer to annex-2 GRM form, to be used by complainants.


GRM process outlined in Figure 1.1 below














Resolution Measures




Grievance Redress Committee

(Project Level)


Solved in 10 days?


DABS Management /COO


Solved in 20days?




If still unresolved, APs may choose to exercise their right under Afghanistan law to refer the matter to a court of law.




6              Monitoring and Auditing

6.1 Introduction

Monitoring and auditing will be undertaken to determine the impact as a consequence of the rehabilitation, and maintenance of the electro-electromechanically work. General monitoring and auditing will be conducted weekly throughout the rehabilitation stage and annually during the operation and maintenance phase.

Routine monitoring and reporting will be undertaken by safeguard focal specialist and the contractor. DABS will develop an auditing schedule and undertake audits in accordance with the schedule.

DABS staff will be responsible for undertaking environmental audits. DABS will maintain all audit records and will be responsible for scheduling follow up inspections to ensure that corrective actions are implemented for any identified non-compliances.

DABS will be responsible for determining severity of non-compliance and may instruct works to cease until the non-compliance is rectified. A non-compliance register will be established and maintained by DABS and all non-compliances recorded there-in.


6.2 Reporting Procedure

The Contractor will be required to report any environmental or social incidents to the (DABS safeguard focal specialist).

The contractor will report to the DABS Safeguards Focal Specialist (SFS) and the NHRP Manager. The DABS Manager will advise the contractor about appropriate mitigation measures and the DABS ESS team will direct the contractor to undertake these mitigation measures.

If there are complaints from the public during the construction phase, the DABS Manager is to be notified immediately. The following information should be recorded by the Consultant.

  • Time, date and nature of the incident / report;
  • Type of communication (e.g. telephone, personal meeting);
  • Contact details with telephone number of person making the complaint. If this person
  • wishes to remain anonymous then “not identified” i