Aquanova Development Solar Project Stakeholder Engagement Plan (SEP)

1 Introduction

1.1 Background

The project developer Aquanova Development LLC has approached the European Bank for Reconstruction and Development (EBRD) for financing the construction of Shalanky solar photovoltaic power plant (the Project) in Zakarpatska Oblast of Ukraine. The project is thus subject to the EBRD’s 2014 Environmental and Social Policy, and has been determined as a Category B project. EBRD’s consultants have conducted an environmental and social due diligence assessment of the project and supported the development of applicable environmental and social documentation, namely, an Environmental and Social Action Plan, a Non-Technical Summary of the environmental and social considerations, and a Stakeholder Engagement Plan.

The project developer considers stakeholder engagement as an essential part of good business practices and corporate citizenship, and a way of improving the quality of projects. In particular, effective community engagement is central to the successful management of risks and impacts on communities affected by projects, as well as to achieving enhanced community benefits. To meet the EBRD requirements for stakeholder engagement, public consultation and information disclosure1, a stakeholder engagement process with development of a Stakeholder Engagement Plan (SEP) is being applied to this project. These details are laid out in this document, the SEP.

1.2 The Project

The project will put in 12,600 photovoltaic modules and associated equipment, which will provide an installed capacity of 3 MW AC, and approximately 3.6 Gigawatt-hours of net electricity generated per year.

The plant will be operated on an area of 5.624 hectares that is subleased for the project. A new 1,050m-long and 4.5m-wide road made of gravel will be constructed to access the project site. The plant will be connected to the distribution grid at an existing 110/10kV substation “Shalankyowned by Oblenergo, by two paralell 10kV aerial transmission lines, approximately 1,395m-long each. Electricity will be sold to the national grid at the “green tariff”.

The Project will be located at Salva street 100, Shalanky Village (3,110 residents) in Vynohradiv District of Zakarpatska Oblast. The nearest residential properties of Shalanky are located at approximately 950m north of the project site. The location of the project site is shown on the Figures 1 and 2 below.

The plant will be constructed, commissioned and operated by Aquanova Development Limited Liability Company, which was established in 2008, or its contractors.

By employing the renewable solar power, the project will provide significant environmental benefits over other types of energy generation, such as those using fossils fuels (gas, coal) or nuclear. It will contribute to the reduction of emissions of greenhouse gases (expected annual emission reductions are 2,745 tons of carbon dioxide equivalent), create some temporary construction jobs, and improve the security of energy supply in the area.

1.3 Requirements for Stakeholder Engagement and Public Consultation

Ukraine is a signatory of Aarhus Convention on Access to Information and Public Participation (UNECE)2. The convention is designed to improve the way ordinary people engage with government and other decision-makers on environmental matters. Consequently, people are entitled to be informed about environment related issues pertaining to the project. National legislation also provides for public involvement in decision-making process.

As per EBRD’s Environmental and Social Policy of 2014, the project funded by the Bank must meet the best international practices and requirements for stakeholder engagement and public consultations. The principles, requirements, methodological and procedural aspects of stakeholder engagement for EBRD projects are described in detail in Performance Requirement (PR) 10 “Information Disclosure and Stakeholder Engagement”3. This requirement outlines a systematic approach to stakeholder engagement that will help clients build and maintain over time a constructive relationship with their stakeholders, including the locally affected communities.

The following elements shall be implemented for the project engagement and consultation process:

  • Identification of project stakeholder groups, including members of the public who could be affected by the Project construction and operation.

  • Stakeholder engagement/consultation process and information disclosure. During this stage, Aquanova Development LLC will ensure that identified stakeholders are appropriately engaged on environmental and social issues that could potentially affect them through a process of information disclosure and meaningful consultation. The disclosed information will include the Project activities and operations. The consultation process will be undertaken in a manner that is inclusive and culturally appropriate for all stakeholders, including effected communities and vulnerable groups.

  • Grievance mechanism, by which the general public and other stakeholders can raise concerns, and which will be handled in a prompt and consistent manner, is another key element of stakeholder engagement.

1.4 Previous Stakeholder Engagement Carried out by the Developer

The developer has informed the general public about the planned project and carried out public consultation meetings, as follows:

    • The local community was informed about the preparation of project siting plan (DTP) and public consultations thereof in an announcement in local newspaper “Novyny Vynogradivschyny” No 45 published on 18 Nov 2017 (copy is attached as Annex A).

    • A public meeting on siting of the project (DTP) was held in Shalanky village on 19 Dec 2017. According to the minutes, the meeting was attended by 42 participants, including members of the Council, Head of the Council, representatives of the Developer, and local residents of Shalanky (Minutes of the meeting are attached as Annex B).

    • During the site visit on 21 Feb 2018, the Consultant met with the Head of Shalanky Council, Mr Victor Alyokhin, to discuss the project implementation issues and any concerns thereof. The Head expressed his support to the project, and mentioned no concerns from the local community or any potentially conflicting issues in this regard.

    • A statement about the environmental impacts of the planned activities was published in local newspaper “Novyny Vynogradivschyny” No 26 (8580) on 7 July 2018 (copy is attached as Annex C).

    • A public meeting on “green” tariff was held in Shalanky village on 14 Nov 2018. According to the minutes, the meeting was attended by 60 people; all voted to support the assigning of “green” tariff (Protocol of the minutes is attached as Annex D)

Also, Aquanova Development LLC has been discussing the project with local government, regulatory authorities and other stakeholders on an ongoing continuous basis.

1.5 SEP Objectives

This SEP has been developed with the aim of describing how Aquanova Development LLC will continue to communicate with people and institutions that may be affected by, or interested in the Project, at various stages of project preparation and implementation. The Plan also includes a grievance mechanism for stakeholders to raise any concerns related to the project for Aquanova Development LLC’s attention.

2 Stakeholder Identification and Assessment

In order to define a communication process in line with EBRD PR10, Aquanova Development, with assistance from a consultant, has identified key stakeholder groups that may be interested in, and/or affected by the Project. They include:

  • Internal stakeholders, such as Aquanova Development’s employees and construction contractors’ workers;

  • Local residents and land owners/users in the project vicinity;

  • Government administrations and regulatory authorities of various levels;

  • Local media and internet sites with coverage of local and regional affairs;

  • Non-governmental organisations (NGOs), scientific research community.

Table 2.1 below provides the details of the Project stakeholders. It will be further developed and continuously updated by the project developer, as the project progresses.

Table 2.1 Project Stakeholders

Name of Stakeholder


Contact Person

Contact Details




Employees of Aquanova Development LLC

Ms. Permiakova O.V. General Director

Address: 03040, Kyiv, Vasylkivska str. 1

Phone: +38 (044) 333 39 30

Local residents and land owners/users


Residents of Shalanky village

Local residents

Alyohin V.V.

Head of village council

Address: 90311, Zakarpattya region, Vynogradivsky district, village Shalanky, Myru str., 5, phone: +38 03143-44422

Government and regulatory authorities


Zakarpatska Oblast Administration

Regional government

Moskal G.G. , Head of Administration

Address: 88000 Uzhhorod city, Narodna sq, 4, Zakarpattya region


Environmental department of Zakarpatska Oblast Administration

Regulatory agency

Rishko S.V., Head of Department

Address: 88000 Uzhhorod city, Narodna sq, 4,

Zakarpattya region

Media and internet


Newspaper “Novyny Vynogradivschyny”

Local newspaper (Vynogradivskyi District)


Address: Zakarpattya oblast, Vynogradisvkyi district, city Vynogradiv, Myru str., 39

Phone:+38 (095) 596 15 71

+38 (097) 358 32 16

NGOs and research community


Environmental NGOs

3 Disclosure of Information and Stakeholder EngagementProgramme

3.1 Disclosure of Information Relevant to Project

To meet the environmental and social requirements and performance standards of EBRD, the Non-Technical Summary of environmental and social considerations (NTS) and the SEP (this document) are being disclosed to the public on USELF web site and

developer’s web site

Printed copies of the NTS and SEP will also be made available to the public at Shalanky Village Council and from Aquanova Development offices upon request.

The local population will be receiving timely information about planned construction activities, safety measures in the vicinity of the construction site, traffic management, employment and business opportunities and other relevant information through the local media listed in the table above. Publicly shared information will also include summaries of annual project progress reports, incorporating environmental and social impacts, health and safety performance and implementation of the external grievance mechanism.

Any public comments or complaints will be reported following the grievance procedure described in Section 4 below.

3.2 Stakeholder Engagement Programme

A provisional Stakeholder Engagement Programme is provided in the Table 3.1 below. This programme will be further discussed by the parties involved, and updated accordingly.

Table 3.1 Provisional Stakeholder Engagement Programme




Means of Communication


Project Preparation (Pre-construction) Phase


All stakeholders

  • Publish NTS and SEP (in English and Ukrainian), and inform all stakeholders through local media

  • Local media publications;

  • Publications on web site.



Statutory stakeholders (regulatory agencies)

  • Obtain all necessary permits for project construction

  • Official correspondence;

  • Meetings.



Construction contractors, temporary workers

  • Agree construction related grievance management procedure and code of conduct for temporary workers;

  • Provide training to contractors on the code of conduct.

  • Meetings;

  • Official correspondence;

  • Trainings.

Before the start of construction


Local population

  • Provide information on safety measures and traffic management procedures during construction;

  • Provide information on employment

  • Big boards at the construction site;

  • Safety signs posted on roads

Before the start of, and during, construction

opportunities and opportunities for service provision, if any;

  • Provide information on construction related grievance procedure.

at dangerous sites;

  • Newspaper announcements;

  • Web site announcements.

Construction Phase


All stakeholders

  • Provide information on implementation of the ESAP, SEP, revision of documents, and new impacts (if any);

  • Provide information on processing and responding to grievances.

  • Newspaper publications;

  • Web site announcements.

Continuously during construction phase


Construction contractors, temporary workers

  • Monitor the performance of contactors and their implementation of the agreed plans and procedures;

  • Provide additional training as required.

  • Meetings;

  • Official correspondence;

  • Trainings.

Continuously during construction phase


Local population

  • Collect and address any grievances.

  • Official correspondence;

  • Meetings.

Continuously during construction phase

Operation Phase


All stakeholders

  • Ongoing interaction and cooperation with stakeholders;

  • Continue to provide information on the implementation of the ESAP;

  • Collect and address any grievances.

  • Media publications;

  • Meetings;

  • Correspondence.

Throughout the lifetime of the project

3.3 Roles and Responsibilities

Aquanova Development will appoint a suitably qualified person who will have the overall responsibility for handling the consultation and information disclosure, including organisation of consultation process, communication with identified stakeholder groups, collecting and processing comments/complaints, and responding to any such comments and complaints.

Depending on the nature of a comment/complaint, some of them may be forwarded to the appropriate person within the company for a response.

Name of the person and title

Affiliation and contact information

Olena Permiakova, General Director

Iryna Tymchenko, Project Manager

Company: Aquanova Development LLC

Postal Address: 03040, Kyiv, Vasylkivska str. 1

Phone: +38 (044) 333 39 30

Mobile phone: +38 (095) 284 62 73


4 Public Grievance Procedure

The objective of a grievance procedure is to ensure that all comments and complaints from any project stakeholder, including residents of nearby residential areas, Aquanova Development employees, contractors’ staff, local/regional authorities and other interested parties, are considered and addressed in an appropriate, consistent and timely manner. All grievances will be acknowledged and responded to within a reasonable timeframe.

Aquanova Development will accept all comments and complaints associated with the project. A proposed template of a Comments and Complaints Form is shown in Annex E. The comments and complaints will be summarised and listed in a Complaints and Comments Log Book, containing the name/group of commenter/complainant, date the comment was received, brief description of issues, information on proposed corrective actions to be implemented (if appropriate), and the date of response sent to the commenter/complainant. Any person or organisation may send comments and/or complaints in person or by post, email, or facsimile using the contact information specified in the Form.

All comments and complaints will be responded to either verbally or in writing, in accordance with preferred method of communication specified by the complainant in the Comments and Complaints Form. Comments will be reviewed and taken into account in the project preparation and implementation, however, they may not receive an individual response unless requested.

Individuals who submit their comments or grievances have the right to request that their name be kept confidential.

All grievances will be registered and acknowledged within 5 days and responded to within 20 working days. Aquanova Development will keep a grievance log and report on grievance management, as part of annual project progress reports.

During construction, grievances in relation to construction activities will be managed by Aquanova Development and their construction contractor. People may also submit their complaints via the local government representation in Shalanky Village Council.

Annexes A to D Copies of project publications in local media and public consultation minutes

Annex E Public Grievance Form (Form for public comments, complaints and reports)

Reference No:

Full Name:


Contact Information and Preferred method of communication

Please mark how you wish to be contacted (mail, telephone, e- mail).

By Post: Please provide mailing address:

By Telephone: By E-mail

Description of Incident or Grievance:

What happened? Where did it happen? Who did it happen to? What is the result of the problem? Source and duration of the problem? Etc.

Date of


One time incident/grievance (date_________________________ )

Happened more than once (how many times?_______________ )

On-going (currently experiencing problem)

What would you like to see happen to resolve the problem?

Signature: ______________________________________________________________________

Date: ________________________________________________________________________

Please return this form to:

Permiakova Olena, General Director

Aquanova Development LLC

Postal Address:

03040, Kyiv, Vasylkivska str. 1

Phone: +38 (044) 333 39 30



1 EBRD Performance Requirement PR10

2 UNECE Aarhus Convention on access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters.

3 EBRD Environmental and Social Policy 2014 ( policies.html).