PS1: Social and Environmental Assessment and Management Systems
Akenerji has an existing corporate-level Quality Policy addressing customer satisfaction, optimum technology choice, participation of employees, process improvement and environmental responsibility. Akenerji has also Environmental, Health and Safety (EHS) Policies which include commitments to comply with the regulations as a minimum requirement, to continuously improve environmental performance on pollution prevention and resource conservation, to provide healthy and safe working environment and to make the employees part of the management process. Akenerji like the other AKKOK Group companies, has been granted with several environmental awards in Turkey, from 2008 to date.
The Company has competent management staff and senior specialists at the corporate level to provide support for, and coordinate with individual projects and their environmental, health and safety aspects. Akenerji is in the process of integrating its management system in accordance with the international standards of ISO 9001 (Quality Management System), ISO 14001 (Environmental Management System) and OHSAS 18001 (Occupational Health and Safety Management System). Given its ambitious targets and ongoing expansion projects, Akenerji is in the process of hiring support staff to its Quality and EHS Department.
Akenerji has established EHS procedures and instructions in place for pollution control, wastes, effluents and emissions management; follow-up of legal obligations and other requirements; chemical materials management; sub-contractor and contractor management; occupational health and safety; accidents/incident investigation and reporting; fire prevention; fire fighting; corporate emergency preparedness and response and auditing of the EHS performance. As indicated in the Supplemental Action Plan, Akenerji will further develop its EHS procedures and control mechanisms. Akenerji will integrate IFC’s Performance Standards on Social and Environmental Sustainability into its corporate management systems. Prior to development of any kind of power projects, relevant EIAs will cover potential impacts in accordance with all IFC’s Social and Environmental Performance Standards, with particular attention on involuntary resettlement, natural habitats / biodiversity, cultural heritage, socio-economic impacts, cumulative impacts as well as trans-boundary impacts.
In conducting acquisition or development of power projects, Akenerji carries out environmental impact assessments (EIA) in accordance with the EIA regulations in Turkey. Up until 2008, hydropower projects of 50MW or more required an EIA; those developed thereafter require an EIA if 25MW or over. Transmission lines with a voltage of 154 kV or more and a length of longer than 15km are required to conduct EIAs. Formal EIAs were prepared for three of the projects to be financed by IFC as per national regulatory requirements, but not for Feke-I as it was approved before 2008 and is less than 50 MW. Nevertheless, Feke-I’s Project Information File includes proposed environmental mitigation measures and a monitoring program which are similar to those included in the EIAs for the other projects. Mitigation measures and monitoring programs derived from the EIAs collectively form Akenerji’s (Environmental & Social) Action Plan. This will be supplemented by Akenerji’s Supplemental Action Plan agreed with IFC to ensure that the projects are developed in accordance with IFC’s Performance Standards. The preparation of the EIA reports related to the transmission lines and substations is continuing.
A number of projects developed by Akenerji, as well as by other private enterprises or the government, are located close to each other in relevant river basins of Turkey, posing cumulative impact concerns. The major concern is related to the Seyhan River Basin within Adana Province, in which the much smaller Goksu River – on which the five hydropower plants are being constructed - is located. According to several reports, which focus on or include coverage on the potential cumulative impacts of hydroelectric plants and dams in the Seyhan River Basin, the following overall conclusions can be drawn:
Cumulative air quality impacts (during construction) are not anticipated due to the distance between project sites;
Cumulative water quality impact during the construction phase of the projects is likely to be moderately adverse, given the need for in-stream construction and associated turbidity; however this should not be an issue once the projects reach operational stage;
Although there will be a cumulative loss of agricultural land due to the creation of a number of reservoirs, the reservoirs are relatively small and the overall impact on livelihoods in the river basin is not anticipated to be significant (refer to Performance Standard 5 section below for further information and discussion);
Cumulative impacts on important bird species are likely to be of low significance because the hydropower projects are located in valley bottoms whilst these species frequent high cliff faces and mountain tops;
Cumulative impacts on important fish species are likely to be of low significance as the majority of these species inhabit the upper reaches of the Zamanti River, where no hydro projects are planned;
In general, adverse cumulative impacts can be mitigated to acceptable levels through proposed mitigation measures for each project, although some potential residual adverse impacts exist which will require coordinated management by all water resources users in the basin;
These residual impacts include: a) change of flow regime from fast-flowing rivers to dam environments which will affect aquatic and terrestrial ecosystems in the vicinity of the various plants; b) loss of vegetation communities, flora and terrestrial fauna habitats resulting from construction of project facilities and inundation; and c) change of water quality resulting from reduced sediment load downstream of the dams.
These residual impacts need to be monitored and necessary management measures taken as appropriate by the responsible parties involved in the river basin.
As indicated in the Supplemental Action Plan, Akenerji is committed to establishing and implementing a cumulative impact monitoring program both for run-of-river and reservoir type HPPs to manage and monitor residual cumulative impacts.
PS2: Labor and Working Conditions
Akenerji currently has 264 permanent employees. Construction of two of the five hydroelectric projects to be supported by IFC is currently underway, and involves approximately 880 contractor personnel. The company has a Human Resources (HR) Policy and procedures which deals with its own employees, describing national labor requirements, hiring and terminating of contracts, working terms and conditions, employee motivation and awarding processes, occupational health and safety rules etc. The policy is publicly available and attaches highest importance to the participation of the employees to the management and development of professional skills
Akenerji does not discriminate on the basis of personal beliefs or characteristics, does not employ child or forced labour, and does not anticipate any retrenchment in the near future; in fact, the company is currently in an expansion phase.
There are no trade unions currently active at Akenerji, primarily because permanent staffs at power generation side are predominantly technical and administrative professional persons forming part of a management cadre and current work at the site level. There is actually not any union active in Akenerji. The Company management reported that the membership to the union is not prohibited or discouraged. Employee grievances – mostly those of contractor and sub-contractor staff members - are addressed directly to site management including supervisors from both Akenerji and the contractor companies. Akenerji will update its Human Resources Policy and procedures to include structured internal grievance redress mechanisms for its own workers and contractors at its sites as well as to ensure that all IFC Performance Standard 2 requirements are formalized within the policy and procedures.
Contractors working for Akenerji’s power project constructions are required to work in accordance with Akenerji’s Subcontractor and Contractor Management Procedure that includes occupational health and safety good practices. An Occupational Health and Safety Manual is distributed to all staff and contractors, who are also provided with the requisite training and personal protective equipment. Contractors are required to have their own occupational health and safety oversight personnel at project sites. In addition, third party consultants are employed at most of the sites to undertake regular inspections of site level occupational health and safety compliance. Occupational health and safety statistics provided to IFC for review purposes indicate a low injury frequency rate at the two hydroelectric power projects to be supported by IFC under construction by Akenerji on the Goksu River. There has been a single fatality to date at Feke I, associated with tunneling activities. Nevertheless, Akenerji will review its contract requirements and make sure that working conditions and EHS rules are comprehensively included in the contracts. In addition, inspection and control mechanisms by the corporate Akenerji will be strengthened in order to maintain workplace safety consistent at all sites, as indicated in the Supplemental Action Plan.
Labor camps are, in general, satisfactorily serviced and maintained for Akenerji and main contractor staff while some improvement needs were identified for the sub-contractors working at the site. Akenerji will take necessary action to extend good practices in labor accommodation to sub-contractor employees.
PS3: Pollution Prevention and Abatement
Akenerji has programs to implement pollution prevention and mitigation measures that were recommended in each power project’s environmental assessment. Akenerji requires that all contractors comply with these measures as well as its detailed EHS procedures.
These measures and procedures are most relevant during the construction phase of Akenerji’s hydropower projects. Key mitigation measures are focused on reducing or controlling air emissions (dust and vehicle exhaust emissions, especially in tunneling operations), minimizing noise and vibration associated with blasting and earth moving, liquid and solid waste management and active erosion/sediment control. Waste management includes the management and disposal of tunneling spoil in such a manner as to protect the river systems from excessive sedimentation. The volumes and storage areas for such spoil have been defined for each construction site and these are managed in accordance with permissions provided by the authorities. Sanitary wastewater generated at construction camps is either treated by package treatment systems or disposed of in septic tank systems which are emptied regularly under agreement with the local municipalities in which each project is located. Domestic solid waste is likewise collected and disposed of at municipal landfills. Small volumes of hazardous waste, such as used oil, are collected and disposed of or recycled offsite under Turkish hazardous waste control regulations.
Dust emissions are minimized by spraying access roads and excavated materials collection points and by a requirement to use canvas covers on certain transport vehicles. Excavated materials are stored and then delivered to final disposal areas in such a manner as to minimize the chance of accidental spillage into local watercourses. Emergency preparedness and response are currently managed by contractors at each of the construction sites and are focused primarily on treatment and evacuation of personnel injured in workplace accidents during construction.
Operations-phase pollution risks will be significantly lower and comprise mainly waste management associated with maintenance of key infrastructure, management of human wastes associated with the small permanent workforces at each plant and noise from the power house turbines.
Greenhouse gas (GHG) emissions: Currently, average CO2 emissions performance from the electricity generation sector in Turkey is 448 gCO2/kWh (2005-2007 average, according to the latest 2009 Edition of International Energy Agency''s statistics). Through development hydropower plants, it is expected to improve climate change footprint in countries where the power generation is heavily dependent on fossil fuels. The five hydropower plants under development by Akenerji are predicted to generate 563 GWh per year. Compared to the conventional thermal power plants of similar capacity, the five hydropower plants are expected to avoid GHG emissions by an estimated amount of 250,000 tons CO2 per year.
PS4: Community Health, Safety and Security
Although the area in which the hydroelectric power plants are being constructed has a relatively low earthquake risk (fourth grade in the Turkish system), all structures are required to be designed to withstand a first grade (maximum credible) earthquake. Akenerji has its own on site laboratory to test the steel and cement/concrete being used for the project; these materials must be certified as being fit for purpose for this application in Turkey. There are no villages located immediately downstream of either of the two projects with high dam walls. An independent review of dam safety measures will be commissioned for the large (> 15 m high wall) dams being supported by IFC and Akenerji will implement associated recommendations, if any.
Given the altitude of the project sites, waterborne diseases such as bilharzias and mosquito breeding (malaria) are not considered to be risk factors for these plants. Warning signs will be erected around the reservoir margins prohibiting swimming. Very few households reside in the vicinity of the valley bottom dam sites and the risk of accidental drowning is considered to be low; however, awareness will be raised at nearby village schools.
Traffic safety during construction is being managed by the main contractors, and there have been no serious incidents to date at the project sites to be supported by IFC. Flagmen and warning signs are utilized to restrict traffic movements during construction activities which might pose a risk to road users. Site visits identified the need for improved protection from rock falls along with newly constructed roads and the Company will deal with this issue. At projects where conventional tunneling methods are used, drilling and blasting schedules are well established and publicly announced in advance through the project area and its surroundings. Vibration measurements conducted at the closest residential area to each site, as per Turkish regulations are part of the EHS management activities. Security at sites is ensured by trained, unarmed security staff. No security concerns have been identified at any of the construction sites to date.
With regard to the operational phase, Akenerji will study the potential impacts of electromagnetic hazards in order to develop relevant mitigation measures as necessary, as defined in the Supplemental Action Plan.
PS5: Land Acquisition and Involuntary Resettlement
Akenerji’s initial approach for every project is to avoid, to the extent possible, social impacts, particularly physical or economic displacement. For instance, the original design of the project was one Feke Dam that would have inundated a town. The project was split into Feke I and Feke II to avoid this situation.
As mentioned above, construction of two of the projects to be supported by IFC is currently underway, whilst the construction of the remaining three schemes will begin shortly. The land acquisition process is at an early stage for Yamanli III and has not yet begun for the transmission lines. Displacement may be described as follows:
Physical Displacement (relocation of houses): Four to fifteen households are expected to be relocated due to the construction of the IFC-supported hydro projects. Among these, three have been compensated and have already relocated. One of the household heads is a handicapped person who owns a small store and is hesitant to move away from his current premises. The negotiation process related to this person is continuing. As reported by the Company management, Akenerji has offered special concessions and assistance due to his condition, including re-establishment of another premises close by once construction is completed.
Land Acquisition: Approximately 10 % (44 ha) of the land being acquired for the five projects is privately owned, with the remainder owned by the State and being leased to Akenerji. The bulk of affected private land is currently not used for agriculture or other productive purposes. In the majority of cases, households whose land is being acquired have land elsewhere and will also be able to replace the acquired land elsewhere in the immediate area if so desired. Thus the economic impacts of land acquisition are deemed to be limited. Nevertheless, the Company will provide detailed documentation about the status of the relevant socio-economic impacts in Compensation and Resettlement Action Plans which is part of the Supplemental Action Plan agreed with IFC. Land acquisition figures for the projects which IFC proposes to support are provided below:
Feke I: 39 ha of land affected, of which ̴ 13 ha belongs to the Forestry Department, ̴ 6 ha to the Treasury and 20 ha is privately owned. The private land comprises 11 plots, in which land acquisition has been completed for 6 and the remainder is being negotiated;
Feke II: 344 ha of land affected, of which ̴ 225 ha belongs to the Forestry Department, ̴ 109 ha to the Treasury and just under 10 ha of which is privately owned. The private land comprises 21 plots, in which land acquisition has been completed for 7 and the remainder is being negotiated;
Yamanli III (Gokkaya, Himmetli and Saimbeyli): For Gokkaya and Himmetli, 136 ha of land affected, of which ̴ 105 ha belongs to the Forestry Department, 23 ha belongs to the Treasury and 14 ha is privately owned. The private land comprises 61 plots and compensation discussions have only recently been initiated. The detailed study on land acquisition for Saimbeyli has not yet initiated. Akenerji will provide IFC with the relevant report once available.
According to the Turkish energy sector regulations, Energy Market Regulator Agency (EMRA), established in 2001 to support and monitor development of the energy sector, has the authority to expropriate land for power projects. EMRA in practice requires private sector investors to carry out land acquisition and provide the necessary resources for compensation. The Expropriation Law encourages fair and timely compensation with reference to market values by establishing a valuation committee and requires evaluation to be made by applying several different sources. The compensation amount defined by the expert committee is deposited in a bank account for the owner and the title is transferred to the investor. Land cannot be acquired physically before the compensation amount is deposited. If the land owners disagree with the compensation amount, they have the right to bring their cases to a different court. The Company states that there are a number of ongoing court applications in relation to the five hydro projects, in which landowners are seeking additional compensation or the legal right to claim compensation for Government-owned lands they have been cultivating.
Crops and trees are compensated with reference to values provided by the provincial directorates of the Ministry of Agriculture. The Ministry updates these values on annual basis. In cases where values remain below market values, inflation rates are used to update values of crops. Also, a through a capitalization formula, farmers are compensated for a transition period until they acquired new land and started receiving yields. Project affected people who do not have free-hold titles, but have been using Forestry or Treasury land on an informal basis for a set period of time may apply to be compensated for the structures and crops/trees based on values set up by provincial directorate of Ministry of Agriculture and the Ministry of Public Works.
Other economic impacts: There are two fish farms downstream of the Yamanli III project sites, one of which relies on river water and the other on spring water. It is currently assumed that the minimum flow requirements calculated for the Goksu River will allow the river-dependent fish farm to continue its operations as before. However, should subsequent environmental monitoring indicate otherwise, Akenerji will compensate the owner(s) for loss of business.
The project sponsors are committed to complying with PS5, and any gaps with respect to this Performance Standard that may occur through the process of land acquisition will be addressed as per the Supplemental Action Plan. This will include a process to better document the magnitude of physical and economic displacement associated with these and other Akenerji projects as well as any associated community concerns, mitigation measures and so forth in Resettlement and/or Compensation Plans.
PS6: Biodiversity Conservation and Sustainable Resource Management
The five sites are located along the Goksu River course in the Taurus Mountains in Adana Province. (NB: there is another Goksu River in South Eastern Turkey which flows directly into the Mediterranean Sea and has a delta which is a listed Ramsar Wetland site important for bird breeding: this should not be confused with the Goksu River named in this document).
The entire Seyhan River Basin and Mediterranean region of Turkey fall within Global 200 Priority Areas for Conservation defined by World Wildlife Fund. There are two ecosystem components of this list in the region, namely “Mediterranean Forests, Woodlands and Scrub” and “Anatolian Freshwater”. Three different terrestrial eco-regions involved are Southern Anatolian montane conifer and deciduous forests, Central/Eastern Anatolian deciduous forests. A significant portion of the project areas belongs to the Forestry Department and is logged. Akenerji pays a reforestation fee to the authorities for the number of trees affected from project activities. The Company has established land rehabilitation programs to be implemented at the end of construction processes.
The Aladaglar Important Bird Area, which is a part of the Aladaglar Key Biodiversity Area (KBA), is located close to the Akenerji project sites but will not be directly impacted. The projects are not expected to cause adverse impacts since key bird species frequent high mountain tops whilst the projects are located in the valley bottoms. The Ministry of Environment and Forestry of Turkey defined one Wildlife Improvement Area (WIA of Hencerderesi) close to the Yamanli III, in accordance with Terrestrial Hunting Law. The project is not anticipated to have direct adverse impacts on this area.
The projects are located nearby potable water basins, therefore, the construction is undertaken with a special permit and closely controlled by local authorities as reported by Akenerji and government officials. The Seyhan River Basin is known to have one critically endangered, three endangered and six vulnerable fish species. As mentioned in the cumulative impacts section above, most of the endangered fish species reside mainly in the upper reaches of the Zamanti River, which are not planned to be developed for hydroelectric power purposes. Few species inhabitating overall Seyhan basin are expected to migrate to the tributaries discharging into reservoirs in order to breed as they prefer fast flowing water. Fish ladders (access) have been incorporated into the design of each of the dams/weirs. Minimum flow calculations have been made to ensure that sufficient base flow is available in the Goksu River to sustain life and basic usage requirements.
The projects’ environmental assessment identified additional fauna listed within the IUCN List or in the Bern Convention Annexes with regard to the project areas. Environmental assessment relevant to each project of Akenerji concludes that potential impacts on the identified sites and species are minimal. Nevertheless, cumulative impacts which are anticipated by the ensemble of the projects need to be monitored as mentioned in the Section related to PS1.
Akenerji will participate in monitoring of the cumulative impacts of water flow regime and water quality changes brought about in the Goksu River on fauna and flora due to project development. The key impacts will include increases in sediment during the construction phase, followed by significant decreases in sediment load once the first dam wall (Feke II) is completed, as well as changes to oxygen and temperature levels in Goksu River water.
