Performance Standard (PS) 1 – Social & Environmental Assessment and Management Systems
EnerjiSA has an Environmental Policy and has developed an ISO 14001 certified environmental and social management system (ESMS) to manage its projects’ impacts. The company is aiming to obtain OHSAS 18001 certification for Occupational, Health & Safety. Responsibility for ESMS implementation is spread across the company, but is driven primarily by separate Corporate and Projects Environmental and Social Groups as well as project-specific Environmental and Social field advisors. As per the requirements of IFC and other lenders in the EnerjiSA 1 transaction, this ESMS has been designed to ensure compliance with both Turkish and IFC environmental, health and safety and social requirements. The system incorporates systematic training, monitoring and reporting procedures. Environmental, health and safety and social monitoring data for all EnerjiSA projects are submitted to the Energisa 1 lender group on an annual basis. To date, the quality of this data has been satisfactory. This monitoring will continue, in expanded form, under the proposed EnerjiSA 2 transaction.
EnerjiSA commissions qualified independent consultants to carry out Environmental Impact Assessments (EIAs) for all of its power and transmission line projects in compliance with Turkish regulations. In addition, as per agreements reached in the EnerjiSA 1 transaction, EnerjiSA commissions any additional work deemed necessary by the lenders to meet IFC Performance Standards and Environmental, Health & Safety Guidelines requirements. As was the case in the first EnerjiSA transaction, IFC and the other lead arrangers have retained an independent firm of engineers and Environmental, Health and Safety consultants (Sargent & Lundy) to review design and EHS documentation for each project in relation to IFC Performance Standards. Under this agreement, which will be replicated for the EnerjiSA 2 transaction, EHS documentation for each project is reviewed against IFC requirements prior to disbursement of project-specific funds. Additional documentation mentioned above which will be prepared (as appropriate to individual projects) prior to disbursement includes a Resettlement Action Plan or Social Impact Assessment, Dam Safety assessment, additional Stakeholder Engagement activities and/or compilation of a project-specific Environmental Management Plan (EMP). The EMP captures all the mitigation measures required to meet Turkish, IFC and Equator Principle lender requirements for a given project.
All of the proposed Phase 2 projects are Greenfield in nature and at various stages of pre-construction development. EnerjiSA has obtained EIA clearances for the Yamanli II and Dogancay HPPs from the Ministry of Environment and Forestry. The Yamanli II EIA and a non-technical summary of the Dogancay EIA are attached to this ESRS, together with the environmental assessment report for the Dagpazari WPP. The EIA for the Bandirma II NGPP is currently underway and the final documentation will not be ready for several months. The EIA application file and supporting appendices are attached to this ESRS, providing a description of the proposed project, detailed location characteristics and a description of likely impacts. As this project will be almost identical to the Bandirma I NGPP project, the Bandirma I EIA and Environmental & Social Management Plan including supporting appendices are attached to this ESRS for reference purposes.
Transmission line EIAs for all projects have not yet been commissioned, as the transmission line corridors have not yet been finalized or approved by the relevant authorities. The expected range in transmission line length is between 1 – 60 km. EnerjiSA will ensure that the impacts and mitigation measures associated with each transmission line are assessed and managed in accordance with IFC requirements, as per the attached Supplemental Action Plan.
Environmental, Health & Safety (EHS) requirements are built into key construction contracts from the early stages (bidding). EnerjiSA provides bidders with a Health & Safety Manual and an environmental commitments register for each project. These are discussed during contract negotiations and bidders are required to demonstrate sufficient experience and capacity in these fields to meet the necessary standards and commitments.
The two proposed EnerjiSA 2 HPPs (Dogancy and Yamanli II) fall within the Seyhan River Basin, as do a number of EnerjiSA 1 HPPs as well as several projects being constructed by other developers. This poses potential cumulative impact risks, especially on the Goksu River – on which EnerjiSA and other developers will construct a total of 10 – 12 HPP projects – and the Seyhan River downstream. EnerjiSA commissioned a Cumulative Impact Assessment (Dokay, 2008) of all known / planned HPP projects in the Seyhan River Basin in 2008. This report – attached to this ESRS - has subsequently been updated to reflect the status quo in 2010 and to include quantitative monitoring data collected by EnerjiSA in the interim. The cumulative impact assessment concludes that cumulative air quality impacts are not anticipated due to the distance between project sites; that cumulative water quality impact during the construction phase of the projects are 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; that 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; that 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 and that 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, the report finds that adverse cumulative impacts associated with multiple HPPs can be mitigated to acceptable levels through standardized mitigation measures for each project, although some potential residual adverse impacts exist which will require coordinated management by HPP developers 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. The report confirms that EnerjiSA will effectively manage these impacts, and emphasizes that other HPP developers would need to adopt similar measures in order for cumulative impacts to be appropriately mitigated in a coordinated manner. EnerjiSA has undertaken quarterly bio-monitoring at its existing HPP sites in the Seyhan Basin to monitor potential impacts on aquatic ecology.
PS 2 – Labour and Working Conditions
EnerjiSA currently employs 485 staff. In addition, around 3850 contractor staff are currently working at EnerjiSA construction sites in Turkey. The company has well established Human Resources policies and procedures, some of which are publicly available on the EnerjiSA website. All employees are informed of their rights and responsibilities prior to the commencement of employment, and individual job descriptions, salary and entitlement details are set forth in employment contracts. Working conditions clauses in these contracts contain detail on working hours, overtime and vocational rights, performance related expectations, disciplinary procedures and occupational health and safety rules.
EnerjiSA is not currently engaged in any collective bargaining agreements, though its employees are free to join workers organizations per Turkish labour law. The lowest wages offered by EnerjiSA are well above the prescribed minimum wage determined by the Government and the company offers fair working conditions and benefit packages as determined by periodic compensation and performance surveys. EnerjiSA has an Ethics Code which guides its HR performance, and each employee is required to undergo related training. The code contains clear language committing EnerjiSA to a fair and non-discriminatory working environment. Child and forced labour is expressly prohibited.
EnerjiSA has an Occupational Health & Safety (OHS) Policy which is shared with all key stakeholders. The Ethics Code also contains OHS conditions. The company has developed procedures and instructions dealing with aspects such as identification of potential hazards, preventive and protective measures, training, documentation, use of personal protective equipment, management of contractor works, response to chemical spills and leaks, operation and testing of fire prevention equipment, noise protection, safe welding instructions, investigation and reporting of occupational accidents, disease prevention, incidents and emergency response. Contractor OHS requirements are built into contractor bidding and award monitoring processes, and site monitoring is conducted by EnerjiSA and/or its OHS consultants. Contractors are also required to have their own occupational health and safety oversight personnel at project sites and before commencing site work are required to prepare a Project OHS Management Plan including risk assessment and control plans, safe work methods for risky activities, site safety rules, designation of OHS responsibilities on site and a plan for conducting OHS induction training. Company-wide accident frequency rates, at 3.3 occupational accidents per million man hours for operational sites and 3.4 for construction sites in 2009, were below EU rates for the electricity and gas supply industry in 2009. Contractors OHS and EHS requirements are built into the contractor bidding and award / monitoring process.
PS 3 – Pollution Prevention and Abatement
EnerjiSA has ESMS procedures in place to manage its emissions, hazardous materials and waste streams as well as emergency planning and response in keeping with IFC PS 3. These are cascaded down into contractor requirements, so as to ensure compliance at the site level during project construction periods. Construction phase impacts associated with the pending Phase 2 projects will be very similar to those associated with Phase 1 projects, i.e. control of air emissions such as dust and exhaust emissions associated with vehicle movements and earthworks, control of noise and vibration associated with tunneling operations for the HPPs and liquid and solid waste management (especially tunneling spoil) and associated erosion control measures.
There will be no operational phase green house gas emissions from the Dagpazari WPP, and green house gas emissions from the two HPPs are will be very low as most of the vegetation will be removed from reservoir sites prior to commissioning. EnerjiSA pays the Forestry Department to plant replacement trees elsewhere, to offset those cleared at its project sites. EnerjiSA has calculated that the avoided CO2 emissions associated with its planned Yamanli II and Dogancay HPP projects will amount to 186,000 and 82,000 tonnes CO2 per annum, respectively.
Carbon dioxide emissions from combined cycle natural gas power plants are lower than those from coal-burning power plants because of the higher heat content of natural gas, the lower carbon intensity of natural gas versus coal, and the higher overall efficiency of NGCC power plants versus coal-fired power plants. Combustion of natural gas for power generation produces approximately half the CO2, less than a third as much NOx and less than one percent of both particulates and sulphur dioxide than combustion of coal according to the US Environmental Protection Agency. Combined cycle natural gas power plants generate the least greenhouse gas emissions of available natural gas power plant technologies. The Bandirma II NGPP will be the most efficient combined cycle natural gas power plant of its kind at 59 % efficiency, and will be designed to meet both EU and IFC air emissions limits for particulates, SOx, and NOx. Estimated emissions from the proposed Bandirma II power plant will be approximately 2.5 million tonnes CO2 per annum. The incremental impact on ambient air quality of NOx emissions from Bandirma II will be modeled taking anticipated Bandirma I emissions into consideration, allowing EnerjiSA to ensure that the combined impact does not exceed ambient air quality limits.
Enerjisa recently won an EU Environmental Award for its energy efficiency initiatives and prevention of production energy losses in 2009-10.
PS 4 – Community Health, Safety and Security
All HPP structures are required by Turkish law to be designed to withstand the maximum credible earthquake. EnerjiSA commissions independent dam safety reviews, as per IFC requirements, for all reservoir structures over 15 m in height. In the case of the Phase 2 projects, only the Yamanli II structures will require such a review. The lenders independent engineer will also review dam safety aspects of the Yamanli II project. There are no villages immediately downstream of either of the proposed HPP projects. No risk of waterborne diseases such as bilharzia or malaria has been identified in relation to the HPP projects. Very few households reside in the vicinity of the proposed reservoir sites, which are small and located in remote, inaccessible places, and hence the risk of drowning is deemed to be low. Traffic safety during construction is managed by contractors, via the use of flagmen and warning signs. Procedures are in place to manage and monitor construction phase noise and vibration levels associated with HPP tunneling activities, as well as explosives handling and blasting safety. Specially designated vehicles and storage sites are used for explosives, as per Turkish regulations, and notices and alarms are utilized to warn people in advance of blasting. All EnerjiSA drivers receive special training on traffic safety and are periodically tested for alcohol usage. Safety ropes are installed wherever flood risks are anticipated, and early warning systems are put in place to cater for such eventualities.
Security personnel are outsourced to private security companies and receive training on appropriate conduct towards community members including use of force. The risk of clashes between security providers and community members is considered to be low in the project areas concerned, and no incidents have been recorded to date. Access control measures are implemented at construction sites to prevent unauthorized or unsafe access to hazardous sites.
PS 5: Land Acquisition & Involuntary Resettlement
EnerjiSA has incorporated the requirements of IFC PS 5 into its Environmental Management System as a condition of the EnerjiSA 1 transaction. The company avoids and/or minimizes the need for resettlement wherever possible and commissions Resettlement Action Plans (RAPs) where resettlement cannot be avoided. Examples of such plans are available in English and Turkish on EnerjiSA’s website, the link to which is provided at the end of this ESRS. Based on available information, there will be no physical displacement associated with any of the four Phase 2 projects. In addition, no economic displacement will be required for the development of the Dagpazari WPP and Bandirma II NGPP projects. It is likely that very minor economic displacement, involving small plots of private land, will be necessary for the two HPP projects. Resettlement associated with the proposed transmission lines is yet to be established due to the early stage of associated planning, but prior experience has shown that physical displacement can generally be avoided and economic displacement can be limited through careful route alignment. The final extent of economic displacement will be confirmed via land acquisition studies required under Turkish law. Compensation planning and associated stakeholder engagement will be completed to IFC’s satisfaction as a condition of disbursement for these two projects (and T-lines), as noted in the attached Action Plan.
PS 6: Biodiversity Conservation & Sustainable Natural Resource Management
A significant portion of the HPP and WPP project areas belong to the Forestry Department and are logged. EnerjiSA pays a reforestation fee to the authorities for the number of trees affected from project activities. The Company has established land rehabilitation and slope stabilization programs to be implemented at the end of construction processes.
No protected areas or endangered species have been identified within or in the immediate vicinity of the Bandirma II NGPP or Dogancay HPP sites. Part of the Yamanli II HPP site overlaps with a Wildlife Development Area for wild goat conservation. EnerjiSA has supported local authorities for the past two years to document the movements and habits of the population of seven wild goats, using photo- and satellite-tracking techniques and analyzing birth and death rates. Based on the information gathered, EnerjiSA has agreed to implement a series of ongoing steps during the construction phase of the Yamanli II project so as to minimize potential impacts on the wild goat population. No protected areas or endangered species have been identified at the Dagpazari WPP site, though a Wild Boar hunting zone is partially impacted. Expert studies contained in the impact assessment concluded that the impact would be minimal. There are no migratory bird routes affected by the WPP, according to specialist reviews. The nearest route is located 7.5 km away over the Goksu River and migrating birds fly at altitudes of 1 to 2 km above ground level, versus turbine heights of approximately 100 m above ground level.
The two HPP projects are located nearby potable water basins and as a result no discharge of waste water is permitted. The Seyhan River Basin, in which the HPPs are located, is known to have one critically endangered, three endangered and six vulnerable fish species. As mentioned in the cumulative impacts section, 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. One endangered species (Alburnus orontis) is found in the Goksu and Seyhan Rivers. EnerjiSA has been undertaking quarterly bio-monitoring at several locations in the Seyhan Basin as part of its Phase 1 commitments – as described in the attached Cumulative Impact Assessment report - and no adverse impacts have been identified to date. Monitoring will be expanded to cater for new projects as these are constructed, and to incorporate hydrological data, as captured in the attached Supplemental Action Plan. Minimum flow calculations have been made to ensure that sufficient base flow is available in the Goksu River to sustain ecosystem functions and community water needs. All necessary measures, such as construction of fish passages, will be implemented in order ensure ecological continuity of the affected river system.
At a regional scale, the entire Mediterranean region of Turkey falls within a Global 200 Priority Area 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”. Whilst this characterization is not officially recognized and does not impose specific conservation-related restrictions to the proposed developments, Enerjisa recognizes the need to construct and operate its projects in a responsible manner in this context.
PS 8: Cultural Heritage
Cultural heritage studies form part of the environmental impact assessments for all projects undertaken by EnerjiSA, as per Turkish regulations. No cultural assets have been identified at the Bandirma II NGPP, Dogancay HPP or Dagpazari WPP project sites. Chance Find procedures are incorporated into all construction contracts, to cater for unexpected finds. A ruined castle has been identified roughly 400 m from the Yamanli II Stage 2 power station location, and some previously inhabited caves are located 600 m away from this same location. The Ministry of Culture & Tourism and the Adana Regional Committee of Cultural and Natural Assets protection have given EnerjiSA the go-ahead to construct the project under certain conditions, for example a restriction on blasting activities in the vicinity of the old castle and the proper disposal of tunnel spoil material such that archaeological sites are not in any way impacted.
