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

Title Naghlu Hydropower Rehabilitation Project (NHRP) Sub-Project: Sarobi Substation
Attachments 0a4011d949df3547f10cda5c90cf0364.pdf
Publish Date 2017-12-23





Naghlu Hydropower Rehabilitation Project (NHRP)


Sub-Project: Sarobi Substation



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)
















September 2017


Table of Contents

List of Acronyms. 0

1. Executive Summary

      1.1 project Background.. 1

      1.2 Project Objective.. 1

1.3 Project Components. 1

2.       Environmental and Social Management Plan.. 2

2.1 Introduction.. 2

2.2     Purpose. 2

    2.3Aims and Objectives of ESMP………………………………………………………………………...3

2.4 Legislative and Policy Considerations. 3

2.5     Summary of Environmental and Social Impacts. 4

2.5.1 Potential Negative Environmental impacts. 4

2.5.2 Potential Negative Social impacts. 4

            2.5.3 Labour influx risk assessment………………………………………………………………...5

3.       Environmental and Social Management.. 6

3.1 ESMP Cost. 6

3.1 Environmental and Social Management Plan.. 7

3.1.1 Pre Construction Phase. 7

3.1.2.      Construction Phase. 10

3.1.3.      Operational and Maintenance Phase. 16

4. Implementation of the ESMP. 19


 5.1 NHRP Sarobi substation 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

Annex 1- Risk assessment identification and mitigation measures. 24

Annex 2: NHRP Sarobi substation Sample Grievance Registration Form... 35

Annex 3: Monitoring Plan.. 36


                    Other necessary safety signage……………………………………………………………..….42

ANNEX 5: Procedures for Mine Risk Management………………………………………...50

Annex 6: Environmental and Social Guidelines for Contractors……………….56

Annex 7: Environmental and Social Checklist for Screening of sub-projects under NHRP project……………………………………………………………………………….....58

ANNEX: 8 Grievance Redress Committee (GRC)………………………………………………………....63

Annex 9 Summary of consultation meetings with communities-CDCs………………………………….…66

Annex 10: Employees’ Code of Conduct………………………………………………………………………………………..….67

Annex 11: on public information poster on grievance service………………………………………………....70


List of Acronyms






AP                   Affected Person(s)

CCMP              Contractor Camp Management Plan

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 and Social 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 Committees

IFC                  International Finance Corporation

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

PAP                 Project Affected Persons

PCB                 Poly-chlorinated Biphenyls

PM 10                 particulate matter 10 micrometers

PPE                     Personal protection Equipment 

QA                   Quality Assurance

SFO                 Safeguards Focal Point

SMEC                Snowy Mountains Engineering Corporation

STD                 Sexually Transmitted Disease

ROW                Rights of Way

UNMACA         United Nations Mine Action Canter for Afghanistan

UXOs               Unexploded Ordinances

WB                  World Bank


1.          Executive Summary



1.1 NHRP project Background (Sarobi Substation)

The Naghlu Hydropower Rehabilitation Project component -3 construction of substation in Sarobi district of Kabul  province, Afghanistan.

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

commonly  it  have no potential adverse Social and Environmental impacts ,but some little negative impacts is predicated during implementation and operation 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 of the substation



1.2 Project Objective

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


1.2 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

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 implementation and Construction of the Sarobi Substation and its electrical and electromechanical parts of the Substation at Naghlu hydropower plant area (component 3). The potential environmental and social risks for component-3 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, The mitigation measures identified during that process are listed as specific commitments to direct performance criteria within the updated site specific ESMP for component 3.

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


2.2 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 works at Sarobi Substation 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. All contractors and suppliers 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.

2.3 The ESMP Amis and Objectives:

  • 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.


2.4 Legislative and Policy Considerations

Legislation and policies that are relevant to construction of Sarobi Substation and its electrical and electromechanical parts of the Substation at the 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

Environmental/social assessment


Environmental and Social Management

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


MEW- Energy sector

Environmental and Social Safeguards Guideline (ESS- guideline)

Hygienic & Safety measures




2.5       Summary of Environmental and Social Impacts

2.5.1 Potential Negative Environmental impacts

The environmental impacts associated with the construction and electro-mechanical works include: tree cutting, around 110 medium and small age non fruit trees will be removed these trees are inside the compound of former oxygen factory where the substation will be built in, these trees are belongs to NHRP property, another impact is limited damage to landscape and green cover of the near surroundings of the proposed substation 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 refer to Annex 1- Risk Assessment Identification and Mitigation Measures, which also includes the potential social risk assessments.

2.5.2 Potential Negative Social impacts

Limited social safeguards impacts are predictable under construction of the substation in component 1, because the construction and electro-mechanical work will be implemented in the premise of Naghlo power plant area near to a small local village and still not electrified , while upon completion of the substation the villager will ask for electricity. As per Naghlo officials these villagers are illegally living in the vicinity of NHRP thus they are not eligible for electrification and the project wouldn’t cover them ,but it will be better to distribute electricity for the villagers by providing document according to DABS administrative regulations and law which don’t prove their eligibility of the mentioned place because it is important for Dam and plant security and humanitarian of the villagers  . Moreover, there might be community safety issues-labor influx risk, 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.  

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.

In addition there might be workplace complaints arising during rehabilitation activities, for which DABS has established Grievance Redress Committee both in community level and project level and trained them in grievance redress mechanism, complaint  registration method, grievance services according to project ESMF ,for more details refer to annex 8 on Grievance Redress Committee GRC and annex 9 on summary of consultation meeting with stakeholder and CDCs. 

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


2.5.3.   Labour Influx risk assessment


The construction of substation does not require a large influx of labour from outside of 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 percent and will be residing in labour camps in the selected district- substation 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 substation” are expected to be largely recruited locally, the overall social impacts anticipated from the labour influx of workers and followers in the selected site of Sarobi 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 10), 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 impact 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.

3.1 Environmental and Social Management Plan


3.1.1 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






Contractor to include  Social and Environmental mitigation measures in design 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





Contractor to Include environmental and social

requirements in BOQ




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



Potential impacts

Assessed Risk level

Mitigation measures

Monitoring Indicators

Institutional Responsibilities

Estimated costs



Preparation of




Plan (CCMP)

- Increased risk of workforce


- Increased risk of damage to

built environment;

-failure of contractor to prepare

an acceptable CCM


-community safety- labor influx risk


-Risk of social conflict


-Include requirement for CCMP in


- Apply QA principles to CCMP acceptance

-Discuss contractor proposals with DABS





A clause to be included in the contract to mandate hiring of local over those from other areas.

-Discussion with community representatives and provide common awareness regarding the project

Acceptable CCMP drawing included in specifications





Written confirmation of CCMP acceptance by SFO+ consultant prior to works on site

-insure to follow up the mandate clause by contractor.




Discuss contractor proposals with community



DABS Naghlo project manager and social safeguard team

Undertake consultation with CDC member as part of the CCMP acceptance





















- consultant firm














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

DABS will conduct session and training for common awareness , social conflict resolving and community safety

Erection of




Location in unsuitable site





-Identify suitable camp site in consultation with Naghlo power plant official

- Obtain relevant approvals for camp location

Suitable camp site identified



Relevant approvals obtained for camp site.





DABS Naghlu plant manager.





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






3.1.2.   Construction Phase

Table 1.2c – Implementation of construction Phase Mitigation Measures



Potential impacts

Assessed Risk level

Mitigation measures

Monitoring Indicators



Estimated costs




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



Making GRC at community and project level to register and satisfied the complainants


Existing of proper ventilation


Regular measurement of PM10


-Establish and maintain a register for

recording public complaints about Contractor



-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
















Consultant firm

Contractor to include estimated ventilation and watering cost in bidding document.

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






















DABS- consultant firm



Contractor to include requirements facilities of workers in bidding documents

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/ spare parts


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







Consultant firm with SFO from DABS












Consultant firm with SFO from DABS

Contractor will include requirements of spill and debris in bidding documents

Dismantling of existing old building of former oxygen factory.

Risk of injury

-the newly hired workers face a higher injury rate


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


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


-DABS’s SFO with consultant firm to monitor Contractor

performance and implement

- QA provisions as required


EHS guideline are provided and staff are trained

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


Ensure that all project staff follow safety measures.


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


Monitor contractor performance related to safety and health issue.



















Consultant firm and SFO


Contractor to include health and hygienic safety training in bidding documents

Social impacts

-Arising Social dispute from ineligible living of villagers in vicinity of substation.

-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.



Discuss with villagers to resolve their issues and replace to legible place

- Contractor to comply with safety guideline.

-A clause to be included in the contract to mandate hiring of local over those from outside


- Undertake community and stakeholders consultation


-Making GRC at community and project level to register and satisfied the complainants



-A clause to be included in the contract to mandate hiring of local over those from outside


Inspection of document






- 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

 ,NHPRP manager.

Social Safeguard team






NHPRP manager







-NHRP plant staff,

DABS Social Safeguard team.





NHPRP plant Staff

DABS Social Safeguard team.








DABS Social and Environmental safeguard team,




-NHPRP manager ,DABS Social Safeguard team.








Contractor to include community safety and Labor influx risk training to bidding document


DABS will conduct training for GRC members regarding the Grievance Redress Mechanism ,Grievance Registration   and community disputes resolution



3.1.3.   Operational and Maintenance Phase

Table 1.2d Implementation of operational Phase Mitigation Measures


Potential impacts

Assessed Risk level

Mitigation measures





Estimated Cost



Construction of Substation

 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





Consultant firm

Contractor and DABS SFO

Contractor to conduct Safety and health training  to all project  staff , especially for newly hired

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











Consultant firm + SFO


Contractor and DABS SFO

Contractor to include health and safety requirements in project documents

Maintenance of the


Contamination of soil, surface

water & groundwater

-Increased risk of injury


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

substation and to appropriately dispose the use oils and

or replace of spare part

Ensure all staff working in the substation 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





Naghlu power plant staff










Local electrification issues

Arising Social issue the resident of Small village in vicinity of Naghlo plant ( informal area) will demand to be connected to power grid.


Making GRC at community and project level to register and satisfied the complainants

Inspection of document and performance of GRC

NHPRP manager.

Social Safeguard team





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 Naghlu Power Plants Manager and the Contractor.

The DABS- safeguards focal officer 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 Substation and it’s electrical and electromechanical parts of Sarobi Substation.

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 officer. The safeguards focal officer 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 officer 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.

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 three different levels are:


  • Local GRC members with responsibilities.
  • Efforts made to resolve issues at community level/project level
  • A Grievance Redress Committee at district/project level
  • Appeal mechanism to DABS management
  • Capacity building support.
  • Information sessions for local communities and contractor staff to use grievance service.
  • Uptake channel for grievance registration.
  • Local logbook ,who should maintain local logbook.
  • Registration of all grievances in the central GRM database of excel sheet to enable tracking and review.


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 one will be happing within the premise of the Naghlu power plant area where the former oxygen factory was located in; where the power plant official 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.

DABS- NHRP will conduct public information to inform local communities in Sarobi district to use grievance service – please see annex 11 on public information poster on grievance service


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 officer 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 officer).

The contractor will report to the DABS Safeguards Focal Officer (SFO) 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” is to be recorded;
  • Details of response and investigation undertaken as a result of the incident / complaint;
  • Name of person undertaking investigation of the incident / complaint;
  • Corrective action taken as a result of the incident / complaint.

The consultant will prepare and submit weekly monitoring reports to the DABS Manager.


7.          Capacity Building


Capacity building measures will be required to ensure that institutions involved in implementing the various ESMP components have the technical, management and other skills to fulfill their roles. The key focus areas for capacity building will be:

  • The DABS Local Safeguards team
  • NHRP technical and engineering staff
  • Naghlu power plant staff & Sarobi Substation Staff
  • Local GRC members


Other institutions will require more specific and targeted training and awareness raising, e.g. the contractor and workforce,


8.          Disclosure

This Environmental and Social Management Plan (ESMP) for (Sa