Environmental and Social Assessment and Management System and Policy: 

Antalya Ulasim has ISO 9001, quality management system, and 14001, environmental management system, as well as OHSAS 18001, occupational health and safety management system certificates in place. MMA does not have a documented Environmental and Social Assessment and Management System (ESMS). MMA will hire a construction supervision consultant to oversee engineering and construction works as well as implementation of environmental, social, health and safety (ESHS) measures during the construction phase including implementation of contractors’ ESHS plans. 

At the time of the appraisal, MMA was preparing tender documents to select the EPC contractor for the construction of tramway line and procurement of tram vehicles. As per the ESAP item 1, MMA will ensure that the EPC contractor has its own construction phase Environmental, Social, Health and Safety Management Plan (ESMP) compliant with IFC’s Performance Standards. The ESMP will include, but not limited to, safety and environment monitoring including specifically construction phase noise and vibration measurement, inspection and reporting; hazard prevention and control; accident prevention, control and reporting; use of personal protective equipment; life and fire safety; emergency preparedness and response procedures; electrical safety; excavation safety; tunneling procedures, including OHS, workplace monitoring, management of waste rock, management of industrial effluents and dewatering, noise and vibrations monitoring; waste management plan; first aid; ESHS and OHS training programs; chance find procedure; construction area safety and historical buildings protection measures and traffic management.

Identification of Risks and Impacts and Management Program:

In line with Turkish Environmental Impact Assessment Regulations, a “project description” was prepared by a third-party consultancy company, Cinar Engineering & Consultancy A.S., as the first step for the Environmental Impact Assessment (EIA) application. This document provides a preliminary environmental impact assessment and mitigation measures for both construction and operational phases, including resource consumption, waste management, noise and vibration assessment, land use, impacts on flora and fauna, and management of effluents. Because of the scope and characteristics of the project, relevant mitigation measures are already included in the project description document. The document was submitted for review to the Ministry of Environment and Urban Planning (MoE), General Directorate of Environmental Impact Assessment and Monitoring, in April 2016; and a response from MoE indicating that the project does not need to proceed with a full EIA was received in January 2017.  MMA submitted revised project description to MoE after the project design change for its final evaluation and the response from MoE validated the previous decision of no full EIA is required in May 2017.

The median of the roads where the tramway line will be constructed are green areas planted with trees. MMA is planning to temporarily relocate these trees to a designated area under the control of its Parks and Gardens Department. At the end of the construction, trees will be replanted on available areas along the tramway line. As per the ESAP item 2, MMA will assess the number and quality of trees to be relocated and develop a tree relocation and replantation implementation plan. Should tree avoidance or relocation be not feasible, MMA will ensure through consultation and engagement with interested stakeholders that mitigation and compensation measures are identified, developed and implemented in concert with the stakeholders as described under the Client’s Stakeholder Engagement section below.

Organizational Capacity and Competency: 

The Directorate of Transportation Planning and Railway Systems Department of MMA has overall responsibility for the construction of the tramway line system including management of contractors and ESHS issues. The Directorate of Railway Systems Section of the department employs 8 technical specialists. As per the ESAP item 3, MMA will nominate a dedicated and qualified ESHS officer responsible for overseeing ESHS management and mitigation during the construction phase in order to ensure compliance of the contractors with the ESHS requirements. 

As per the EPC contract being prepared by the MMA, the contractor’s responsibility will cover managing day-to-day ESHS issues, implementing the required mitigations, providing EHS training to its workforce, including its subcontractors, and reporting regularly to MMA. MMA will ensure that the EPC contractor will have a dedicated EHS manager and team with adequate technical knowledge of good international industry practice to implement the ESMP and comply with project’s requirements, consistent with IFC Performance Standards (ESAP item 4).  

Antalya Ulasim will manage operation of the Phase-3A tramline. The company has an organizational structure with clear roles, responsibilities and authority to implement the ESMS that includes a dedicated ESHS team with the necessary technical knowledge and experience. The company has a qualified OHS specialist (C Class according to Ministry of Labor and Social Security) who conducts daily inspections and organize OHS trainings as part of the onboarding and training programs.

Emergency Preparedness and Response: 

MMA will ensure that the construction phase ESMP, which will be developed by the EPC contractor, will include relevant emergency preparedness and response plan. For the two operating tramway lines, Antalya Ulasim has documented emergency preparedness and response plans including firefighting, response to flood and adverse weather conditions, earthquake, sabotage and response to spills, in line with IFC’s requirements. The company will review and update these plans to include Phase-3A line. As per local regulation, Antalya Ulasim conducts emergency drills at least once a year.

Monitoring and Review: 

The EPC contractor’s ESMP will include a monitoring and reporting framework covering, among others, energy consumption, waste management, traffic management, life and fire safety, emergency and fire drills, safety performance, incidents and near misses, personal protective equipment, and training for the construction phase. MMA will monitor EPC contractor’s performance and compliance via its engineering consultant. At the operational phase, Antalya Ulasim will be responsible to monitor and review ESHS performance, consistent with the system adopted for the lines already in operation. The technical team periodically records energy consumption, incident rates and generated wastes and reports to company management and MMA.

Human Resources Policies and Procedures/Working Conditions and Management of Worker Relationship: 

MMA has specific types of employment contract for public officials, long-term public workers and contracted workers. As of November 2, 2016, MMA employs a total of 2,213 staff of which 18% are women while outsources most municipal services; the total number of contracted workers is approximately 5,600. Antalya Ulasim employs 416 staff of which 55 (13%) are women. Out of the 46 tramway drivers, eight are women. Once operational, it is expected that the project will employ an additional 90 people including tramway operators, maintenance and administrative personnel. During the construction period, it is expected that 420 workers will be employed by the EPC contractor. Terms of employment and benefits for staff of MMA and Antalya Ulasim are defined and provided according to local public employee personnel regulation; they are generally consistent with IFC PS2 requirements. 

Workers’ Organizations / Non-Discrimination and Equal Opportunity / Retrenchment:

MMA has a collective bargaining agreement with the Hak-Is worker union. Public officers and contracted public workers are represented by Bem-Bir Sen and Memur-Sen unions, but, as per local regulation, trade unions representing public employees are not allowed to be party to collective bargaining agreements. Some 175 workers of Antalya Ulasim are members of Belediye-Is union. 

No retrenchment is expected as a result of this project. MMA is planning to restructure the bus and minibus services operating along the tramway line alignment. However, buses presently covering the future Phase-3A line will be redeployed as feeder routes; therefore, no retrenchment is anticipated for the workforce involved with the bus services, either privately operated or provided by MMA and operated by Antalya Ulasim. 

Grievance Mechanism: 

Employees of MMA and Antalya Ulasim have several mechanisms in place for raising employment related grievances, including reaching directly to managers for immediate concerns or anonymously through Antalya Metropolitan Municipality Communication Center (ABIM) or their respective trade unions. The complaints are handled and monitored by discipline committees where workers’ representatives are also included. MMA will ensure that EPC contractor’s HR policy and procedures have relevant grievance mechanism consistent with IFC’s requirements or that their employees including sub-contractors have access to MMA’s existing grievance mechanism.

Protecting the Work Force / Forced and Child Labor:

Both at MMA and Antalya Ulasim, the minimum working age is 18 years. The HR policy of EPC contractor will include a statement indicating minimum working age as 18 years. 

Occupational Health and Safety: 

In line with local regulation, MMA and Antalya Ulasim employ occupational health and safety consultancy services for regular audit and reporting of their OHS performance. Antalya Ulasim has OHSAS 18001 certified management system to ensure occupational health and safety for its employees. Mitigation measures related with the workplace risks such as work equipment improvement, personnel protective equipment and OHS trainings are implemented. The workers go through annual health tests according to the legislation in force. 

Antalya Ulasim keeps records of incidents in line with the OHSAS 18001 requirements. According to their statistics, the most severe incidents are traffic accidents involving tramway vehicles, as discussed under PS4 section on community health and safety below.

Existing tramway vehicles are maintained according to relevant tender technical specifications requirements. Preventive maintenance procedures include daily, monthly and yearly (80,000 km) and 600,000 km maintenance checks of the tram vehicles that include wheel periodical maintenance (such as profile maintenance).  Other maintenance procedures include tramway tracks and line, power supply, signalization and communication systems, electrical and technical rooms at stations, and firefighting system. Periodic inspections of equipment, including forklifts and cranes, are performed by third party institutions accredited by Chamber of Mechanical Engineers as required by national legislations. Forklifts and cranes are operated by certified personnel.

Antalya Ulasim provides orientation and technical training program to candidate tramway operators. This program includes one-month classroom technical training and 40 hours of day and night driving practice. Tramway drivers are also provided with OHS, security management system, firefighting, and first aid trainings. Need-base refresher trainings are conducted for the tramway drivers and training logs are kept.

Project construction work will entail work at high, scaffolding, excavations, trip and fall, lifting, working in confined spaces, safe working with electrical equipment, chemical safety and other OHS risks that will need to be supervised and mitigated, including workplace air quality (e.g., dust and silica dust) and noise and vibration monitoring for tunneling works, adequate training and PPE. The ESMP of EPC contractor will include relevant OHS procedures for safe working instructions, work permits, incident reporting, emergency response, PPE requirements, machinery and equipment inspections and training programs. 

Workers Engaged by Third Parties: 

The EPC contractor will integrate sub-contractor’s supervision and compliance in its ESMS and will assess their capacity and performance  in accordance with relevant items delineated in the ESMP and relevant management plans. The EPC contractor will also develop procedures to ensure sub-contractors,  are aware of and abide to environmental and social, OHS, and labor policies, including effective grievance mechanisms for their workers.

Resource Efficiency and Green House Gases (GHG):

Tramway vehicles will be powered by a 750 V DC system with 14 electrical energy supply points, connected to the national grid. The feasibility report estimates a total electricity consumption for Phase-3A line operations as 332,000 kWh/year/per tram car. The report also estimates that, as a result of the expected reduction in automobile traffic due to commuting, the project will achieve almost 35,000 tonnes over the 24 years CO ₂  reduction from urban traffic mobile sources _.  Additional savings in energy consumption (in terms of energy per km travelled) are expected due to the purchase and operation of new tram cars, but no estimates have been provided by Antalya Ulasim.

During the construction phase, water will be supplied for domestic use by workers and for concrete production. During the operational phase, water consumption will be mainly related to cleaning of tramway cars. The water consumption during construction and operation phases is expected to be about 162 m ³ /day and 24 m ³ /day respectively, and will be provided by municipal water network.

Pollution Prevention:

The technical specifications of heat, ventilation and air conditioning systems of the new tram cars will be compliant with European Union Norm 14750 and will ensure that ozone depleting substances such as HCFC and CFC are not used in any equipment. Technical specifications for tramway cars and related electro mechanical equipment require that all materials be free of asbestos, lead and polychlorinated terphenyls. 

The environmental assessment estimated that, during construction, about 0.65 kg/hour dust emission will be due to earthworks, an emission level that is below the national law requirements of 1 kg/hour. The contractor will implement dust suppression techniques, such as water spraying, if necessary mixed with non-toxic dust suppressants, to surfaces where vehicle movements are frequent. 

Wastewater: 

Wastewater discharges from sanitary facilities (both for construction and operational phases) and from dewatering of tunneling operations will be discharged into the municipal sewerage network in line with the permits to be received from MMA. The existing depot and maintenance facility has a filtering system for the pre-treatment of wastewater used for tram car cleaning before discharge to the municipal system. A similar system will be installed at the new depot and maintenance facility.

Wastes and Hazardous Materials Management: 

During the construction phase, the project is estimated to generate 732 kg/day of domestic waste, whereas the total amount of excavation will likely produce 354,196 m ³  of earth and rock material including 1.3 km tunnel section. MMA will ensure that the waste rock will be disposed in a manner which is environmentally safe and with due consideration of landscape.

Operational phase domestic waste generation is estimated to be around 113 kg/day. Antalya Ulasim has an effective waste segregation system in place. Wastes are transported, recycled and/or disposed by a third party licensed waste company. The Phase-3A line will be included in the current waste recycling and disposal system. Hazardous materials will mainly include machinery oil, batteries and paints and will be managed in line with national requirements. All wastes will be managed as per the required waste management plan and will be disposed/recycled in line with Turkish Environmental Legislations by licensed companies at licensed sites; hazardous material and waste management will comply with IFC PS3 requirements. 

Noise and Vibration: 

During routine operations, noise is generated by the contact between wheel and rail, braking, and/or aerodynamic noise generated by the train itself; and/or noise generated by the engine and cooling fans. 

Technical specifications of the new tramway vehicles require all rolling stock to be compliant with national regulatory requirements and threshold internal, 70 dBA, and external, 75 dBA, noise level values. These limits are in line with ISO 3095 acoustic measurement of noise emitted by rail bound vehicles and ISO 3381 acoustic measurement of noise inside rail bound vehicles.

According to the noise modelling study conducted to assess noise levels in residential areas, the predicted noise will be around 63 dBA within 50 m radius from the source during construction period and between 35 dBA and 42 dBA during operational phase. The EPC contractor’s ESMP will include a construction phase noise and vibration monitoring plan to ensure residential noise guideline levels, as identified in WBG General EHS Guidelines, Table 1.7.1, are met.

Community Health and Safety: 

Phase-3A tramway line will be constructed within a highly populated city center.  EPC contractor’s ESMP will have detailed procedures to minimize and monitor noise and vibration impacts including monitoring of buildings and structures and construction area safety measures to protect the citizens, including barricading, control of the access to the construction areas, traffic safety, control of the construction vehicles, signposts and clear demarcation of construction areas, proper illumination of construction areas and their immediate surroundings; deployment of flagmen, coordination with traffic  police, and provision of safety information to the public and the visitors. 

The operational speed of the tramways is planned to be 29 km/hr with a maximum speed of 70 km/hr on the fenced sections. Operating speed on the non-fenced sections is reported to be in the 20-50 km/hr range and speed limits will be assigned based on line geometry, interferences with other urban infrastructure and safety considerations. 

Traffic Safety:

Since the operation of Phase 1 tramway line initiated in 2010, an average of 18 accidents involving tram cars and vehicular traffic have occurred each year. Most of these accidents are crashes with private vehicles mainly at the junctions/intersections. Each incident was carefully investigated and documented. According to the records of Antalya Ulasim six of these accidents resulted in fatalities while another six resulted in severe injuries. As per the ESAP item 5, MMA and Antalya Ulasim will undertake – with support from the IFC’s Cities Platform - an operational and traffic safety and accessibility review of its current tramway network (including the proposed Phase-3A line), and develop a traffic safety policy including speed limits and an action plan including a timeline to improve operational and traffic safety, passenger safety and accessibility; and emergency response and preparedness. The action plan will also cover training programs including periodic refresher training sessions for all drivers and maintenance crew.

Life and Fire Safety:

Technical specifications covering health, safety and environmental requirements for the tram vehicles require satisfying the requirements of European Union Norms, International Union of Railroads Standards (UIC) and International Organization for Standardization (ISO). All materials used in the production of tramway vehicle will be fire resistant in line with European Union Norm 45545: fire protection of railway vehicles. 

Security Personnel:

Antalya Ulasim outsource security services and has 73 unarmed security personnel, all working at tramway stations. During the construction period, EPC contractor is expected to deploy its own unarmed security personnel at the project site.