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43007
ALMATY INTERNATIONAL AIRPORT JSC
Oct 29, 2020
Kazakhstan
Central Asia and Turkiye
Mar 7, 2022
B - Limited
Active
Approved : Jan 14, 2021
Signed : Sep 27, 2021
Invested : Dec 21, 2021
other
Infrastructure
Regional Industry INF MCT
The Project involves a senior loan of up to USD 150 million from IFC’s own account, a senior syndicated loan of up to USD 100 million and a senior loan of up to USD 50 million from IFC acting in its capacity as implementing entity for the Managed Co-Lending Portfolio Program (“MCPP”). The Project consists of (i) financing the capital expenditure program to modernize Almaty International Airport JSC (“AIA”) and (ii) refinancing of the acquisition of AIA and the associated fuel business entity Venus Trading LLP (“VT,” together with AIA, the “Airport”) from a private party. The capital expenditure program involves a new passenger terminal to address capacity constraints, relocation of VIP terminal, refurbishment of existing AIA terminal, and environmental, health and safety enhancement works such as rehabilitation of infrastructure, installation of a noise barrier, noise insulation program, energy efficiency investments, life and fire safety (LFS) improvements at the existing terminal and airport hotel’s building, which will be converted into the office premises. Construction works are expected to commence in 2020 and be completed over three years. Project Sponsors are TAV Havalimanlari Holding A.S. (“TAV,” 85 percent) and Kazakhstan Infrastructure Fund C.V. (“KIF”) managed by VPE Eurasia GP Limited (15 percent). The Sponsors are currently finalizing the acquisition of AIA from its current private owner.
AIA is the largest international airport in Kazakhstan, served 6.4 million passengers in 2019, and is situated 15km northeast of Almaty city center. It has been operational since 1935 and has held an international categorization since 1998. The airport is certified by the International Civil Aviation Organization (ICAO). It consists of two close parallel runways and associated taxiways, 5 apron areas, and various auxiliary facilities required for the operation of the airport such as wastewater treatment works, fuel storage area, laboratory and car parks. The area surrounding the airport is a mixed-use area comprising residential, commercial and agricultural land uses, including residential buildings in close proximity to the airport, as discussed below.
IFC’s environmental, health, safety and social (E&S) review was supported by an external consultancy firm who carried out an Environmental and Social Due Diligence (ESDD) of the project. A visit to the project site and its surrounding areas was conducted by IFC’s E&S specialist on November 13-14, 2019. During the site visit, meetings were held with the representatives of the Sponsors, AIA management, EHS team and operational personnel of fire department, wastewater treatment plant, maintenance department, fuel farm and laboratory.
Key documents reviewed by IFC during appraisal were:
- E&S Due Diligence Assessment report, prepared by Waterman Infrastructure & Environment Limited, September 2020;
- Stakeholder Engagement Plan, prepared by Waterman Infrastructure & Environment Limited, September 2020.
- AIA Noise Study by Frekans Environmental Acoustics Modeling Lab, June 2020;
- AIA Safety Study by TYPSA (Spain), May 2020;
- AIA Cultural Heritage assessment, prepared by ERM, July 2020;
- AIA Life and Fire Safety (LFS) Audit, prepared by TAV, April 2020;
- Land Acquisition and Resettlement Framework prepared by an independent consultant July 2020.
- The documentation received at appraisal by IFC also included the Environmental Impact Assessment (EIA), prepared for AIA in 2008 in the context of the reconstruction the passenger terminal and the expansion of the apron in 2007. The EIA is not relevant to the proposed project, but was reviewed by IFC as background material.
IFC has also reviewed environmental and social performance of previous IFC’s projects with TAV. All projects showed good E&S performance:
- Tbilisi Airport #24628 : https://disclosures.ifc.org/#/projectDetail/ERS/24628
- TAV Tunisia #26913 : https://disclosures.ifc.org/#/projectDetail/ESRS/26913
- Zagreb Airport #31969 : https://disclosures.ifc.org/#/projectDetail/ESRS/31969
After COVID-19 related travel restrictions are removed and post-acquisition, IFC will visit the project, as part of the regular portfolio monitoring activities. The field activities will include a review of the implementation of stakeholder engagement practices and relations with the local communities and meetings with relevant stakeholders.
Based on IFC’s review of the project, no impacts are expected that must be managed consistent with the following Performance Standards:
PS 5: Land Acquisition and Involuntary Resettlement, as the project does not require land acquisition – the project will not lead to any expansion of the airport footprint and there is no resettlement required within the airport footprint. The sponsor’s commitment in the event of government-led resettlement to enforce any zoning caused by the airport operations is described in the PS1 section below.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, because AIA is long established airport in a mixed use area and there will not be any expansion of the footprint;
PS7: Indigenous Peoples, as there are no indigenous peoples in the project area, as per the definition used by the World Bank Group.
Key E&S issues reviewed at appraisal included health and safety of surrounding communities, including noise impacts from ground and aircraft operations, and airport operation safety; emergency response and LFS for existing and new terminals; impacts on cultural heritage associated with the impact on the historical VIP terminal which is listed as architectural monument of local importance by the Almaty City Council; risk of legacy contamination with hazardous materials (jet fuel, PCBs, etc.); and potential retrenchment due to optimization.
With no expansion of the footprint and no land acquisition impacts identified, no planned retrenchment of AIA current workforce, identified measures reflective of good international industry practice for airport operations to mitigate noise impacts and community safety risks, and agreed practical solution to minimize the project’s impact on cultural heritage – the project is categorized as B according to IFC’s Policy on Environmental and Social Sustainability. Construction impacts will be addressed through the implementation of good international industry practices.
The sponsor has corporate Environmental and Sustainability Policies which are publicly available on their website: http://www.tavhavalimanlari.com.tr/en-EN/about-tav/policies-about-tav.
In 2015 TAV signed up to the UN Global Compact’s environmental principles. Performance improvements program developed for airports operated by TAV are focused on reduction of water and energy consumption, improvement of waste sorting and recovery, noise management, biodiversity protection and preventing environmental contamination. TAV will apply similar principles and approaches when developing the project and as operator of AIA.
AIA currently manages the E&S aspects of its operations in accordance with relevant national requirements. AIA has also established Management Systems and is currently accredited to ISO 9001, ISO14001, OHSAS 18001 and ISO 50001. During 2019 an ISO certification surveillance audit was conducted by an independent auditor as a result of which AIA retained its certification with no major compliance issue identified. As outlined in the ESAP item 1, during post-acquisition process of integration, TAV will evaluate the ESMS of AIA against their own policies and systems and will make upgrades, if and as needed, to align the ESMS with TAV corporate policies and IFC’s Performance Standards requirements. As first step, TAV will review and update AIA overarching Environmental and Social Policy defining the environmental and social objectives and principles. TAV will review the current management systems documentation, which focus largely on environmental and occupational health & safety, to ensure all aspects including social requirements of IFC are covered. TAV will raise awareness of the management systems across the airport relevant departments and ensure all departments are aware of their roles and responsibilities in meeting legal and IFC requirements, targets and objective.
Identification of Risks and Impacts
As outlined within the Kazakhstan’s Environmental Code (2007), Environmental Impact Assessments (EIAs) are mandatory for all economic or other activity which may have direct or indirect impact on the environment. EIAs are in integral part of the planning procedure and form a key part of project documentation, which must be submitted for approval by the State Environmental Expertise. As outlined in ESAP item 3, TAV will develop an EIA (OVOS) for the proposed development and growth of air traffic at AIA, to meet national requirements. The EIA will also be aligned and cover the scope of the IFC Performance Standards, including the requirement for a social baseline as well as assessing potential social risks and impacts. National and IFC’s requirements on public information, consultation and disclosure during EIA process will be fully met. The EIA will be disclosed as soon as it is available, as part of this ESRS.
Management Programs
There have been no environmental, health and safety and social management plans developed yet for the construction phase. As agreed in ESAP item 4, once the EIA is finalized, TAV will develop and implement a project specific construction Environmental and Social Management Plan (ESMP) that takes into account the mitigation measures and monitoring requirements set out in the EIA and the project ESDD and includes site specific procedures/plans for the development phase. An ESMP will also be developed for operations, which covers noise and vibrations, air emissions, stormwater management and wastewater discharges, greenhouse gas emissions, waste and hazardous waste management, hazardous material management, resources usage in relation to electricity, natural gas, water consumption, and stakeholder engagement. Occupational and community health and safety management programs for operations are described under Performance Standards 2 and 4 below.
As agreed in ESAP item 5, as part of Environmental Management System, TAV will produce an overarching Operational Environmental Monitoring Program six months prior to the operation of the new and refurbished terminals. This program will include but not limited to monitoring of ambient air quality, noise and vibrations, stormwater discharges, soil and groundwater as discussed in PS3.
Organizational Capacity & Competency
There is currently an Environmental, Health and Safety (EHS) Department at the airport with two staff including an EHS Manager. To strengthen the E&S organization and meet TAV corporate policies and IFC requirements, as outlined in ESAP item 2, TAV will appoint qualified E&S Manager(s) with experience in the application of E&S standards of international finance institutions and knowledge of sector-specific E&S issues.
TAV will also review AIA’s current resource capability against project E&S commitments to determine the requirement for additional role(s) in relation to the project and airport operations. Environmental and social roles and responsibilities of the EHS department and all personnel, including employees and contractors, will be clearly defined as part of the ESMPs for both the development and operational phases. The review will include the assessment and the appointment of adequate resources to implement the Stakeholder Engagement Plan.
Contractor Management
At this stage the Engineering, Procurement and Construction (EPC) contractor has been selected and draft contract documentation prepared for the construction phase of the project. Contracting documentation includes provisions that EPC contractor and their subcontractors will be required to (i) comply with national legislation, (ii) adhere to TAV environmental and health & safety management systems, (iii) implement relevant mitigation measures and actions set out in the ESMP; and (iv) report to TAV management. The construction ESMP will include procedures for TAV management and E&S representatives to oversee and supervise the E&S performance of EPC contractor and sub-contractors to ensure they are complying with the aforementioned. TAV’s EHS representatives will inspect contractors’ working areas; stop works at any time if unsafe condition is observed; and report on E&S performance and compliance by the contractors.
As operator of AIA, TAV will apply similar principles and approaches to all operations and maintenance (O&M) contractors and subcontractors.
Emergency Preparedness & Response
One of the key emergency scenarios in the airport is the risk of airside accidents. To provide coverage of the airport there are three fire depots to respond to such accidents. A site fire brigade also coordinates with local fire departments in case of interventions required on other areas of the airport. There is a schedule of internal fire training and drills on site for the internal fire team, and, as required, for all personnel.
In addition to airside accidents and fires, the existing AIA’s Emergency Preparedness and Response Plan (EPRP) outlines other emergency events, including natural disasters, and supporting procedures are in place. However, IFC’s review identified that not all operations or facilities of AIA have been covered by the EPRP. For example, no consideration is given in the plan to a fuel release or explosion at the fuel farm.
As outlined in ESAP item 6 TAV will review and update the EPRP to include all operations, including the fuel farm, and ensure that all credible emergency scenarios are covered, including onsite and offsite emergencies, and be aligned with the relevant requirements of IFC Performance Standards under PS1 and PS4, the WBG General EHS Guidelines and WBG EHS Guidelines for Airports, including business continuity, emergency response training, including all personnel and contractors; and an emergency communication procedure with local authorities and local communities. TAV will liaise with local emergency service to assess their capacity and resources and to ensure coordination in case of both onsite and offsite emergency. Joint drills will be undertaken on a regular basis. This assessment and the relevant actions by TAV will be developed as part of revised EPRP.
Monitoring & Review
AIA have established procedures and allocated resources, including an internal audit department, to monitor and measure the effectiveness of their management systems. In addition, there are scheduled formal internal audits and spot audits conducted by AIA personnel. These audits cover technical, environmental, health and safety issues. AIA management receives audit results and there is a formal process of reviewing, responding and closing the report’s findings through a corrective action system.
Under ESAP item 1, TAV will integrate AIA’s existing EHS risk management with TAV’s corporate risk management, internal audit and compliance functions’ work programs; and ensure that monitoring and review of E&S risks and impacts is carried out as per IFC’s Performance Standards. TAV Airports Audit Committee Charter will include periodic oversight of internal audit’s actions related to AIA’s E&S risk management. Compliance with IFC Performance Standards will be integrated in the management reviews at TAV corporate level.
Land Acquisition and Involuntary Resettlement
As discussed above, construction of new terminal does not require land acquisition and resettlement as the terminal will be built within the exiting footprint of the airport. TAV will implement several measures to improve aviation and related public safety, discussed in PS4 section below, none of which are expected to result in economic or physical displacement.
Although potential land acquisition related to the operation of the airport imposed by the Government of Kazakhstan (GoK) is currently not envisioned and is considered an unlikely scenario in future, TAV has developed a Land Acquisition and Resettlement Framework (LARF) which outlines the requirements for land acquisition and resettlement based on the national legal framework and IFC’s PS 5. As outlined in ESAP item 7, in case of government-led resettlement, TAV will work closely with the GoK to ensure that the process is in line with the LARF and, if necessary, prepare a Supplemental Resettlement Action Plan which will complement the compensation provided by the GoK to achieve outcomes consistent with IFC’s requirements.
Human Resources Policies and Procedures
AIA has a human resources (HR) Policy. The current version was approved in June 2019 and covers all employees including management. The Policy indicates the company employ best candidates for roles regardless of age, race, gender, religion or nationality, and the company operates to all national requirements including the Labor Code of the Republic of Kazakhstan. AIA’s current HR policy and procedures are not fully aligned with PS2 requirement as they don’t cover 3rd party workers and don’t have explicit reference to child and forced labor but indirectly through reference to the Labor Code.
Kazakhstan ratified the ILO core labor standards and they are incorporated in the national labor laws. Hereby the core labor standards, as defined in Performance Standard 2 are part of the national requirements which AIA is required and committed to follow for its employees, as defined in the Policy.
As agreed in ESAP item 8 TAV will review the HR procedures and policies right after the acquisition of the airport and, as required, update these to meet IFC’s PS2 requirements, including a policy on forced labor, child labor and sexual harassment. Conditions for workers employed by contractors for the construction and the operation of the airport will also be required to be consistent with requirements of the updated TAV HR Policy.
There are about 3,200 people employed by the current airport operator, with a staff turn-over rate of 11% in 2019 (15% in 2018 and 11% in 2017). In terms of vulnerable groups within the current workforce, about 40 persons with disabilities are employed by AIA as well as about 104 single mothers or mothers with children under the age of 14 (or children under 18 with disabilities) and about 108 mothers of three or more children.
Working Conditions and Terms of Employment
The employee rights and duties (including wages, working hours, overtime arrangements and compensation, benefits etc.) are communicated at employment and documented in individual contractual agreements signed with each employee and which are clearly spelled out in a Collective Bargaining Agreement (CBA).
Employee compensation is contractually set and cannot be altered due to employee discipline or quality of work. Any changes to compensation levels will have to be approved by the AIA Board. All employees currently have access to HR documentation related to their employment held by AIA.
Workers’ Organization
In November 2016, AIA signed a CBA with the Trade Union of Almaty International Airport. The CBA underwent a minor amendment in 2018 and is in line with the applicable national legislation including the Labor Code and the Law on Trade Unions outlining communication, right and responsibilities between administration and union employees.
The percentage of union members among AIA’s workforce is close to 100%. AIA reported that no labor disputes including strikes have occurred during the last two years.
TAV will engage with the union as soon as the operatorship will be transferred from the current owner and will continue on-going consultations onwards. TAV is not planning re-negotiation of the CBA before the end of its term.
Non-discrimination and Equal Opportunity
As per the Human Resources Management Policy, the working relationship is based on equal treatment and non-discrimination based on criteria including gender, age, nationality, race, religion, political affiliation, social origins, and family conditions. Wage levels are set in the CBA and are determined based on education, position, specific requirements and responsibilities for the position and experience. These are in line with nondiscrimination principles and does not consider gender, nationality, religion or other personal aspects of the employees. As agreed in ESAP item 8 TAV will develop and implement a policy on sexual harassment.
Child and Forced Labor
All employees in the company, as well as employees of contracted companies, must be of legal working age as defined by the Kazakhstan legislation and the International Labour Organization (ILO).
Currently, AIA do not permit employment contracts with persons under the age of 18; however, the HR policy does not include an explicit requirement. The HR policy, under ESAP item 8, will be updated to include an explicit requirement that TAV will not employ child and forced labor, and relevant procedures will be developed to prevent such risk, also with respect to the company’s contractors.
Retrenchment
Within the first 3 month of acquiring the airport TAV will conduct an assessment to determine their restructuring plans for staffing optimization, which is essential to operational cost-efficiency. In order to avoid retrenchment TAV will aim at redeploying staff to other internal roles and positions, which will be required for the expansion of operations of the airport under the new ownership. As per ESAP item 8, TAV will develop a retrenchment policy with a commitment to conduct any future retrenchment in line with PS2 requirements.
Workers Grievance Mechanism
AIA have a grievance procedure, in which grievances are logged and reported to the President of AIA, senior management and relevant departments heads to be closed out. All grievances are subject to mandatory review by the Conciliation Commission which consist of representatives from employers and employees of AIA. As outlined in ESAP item 9, TAV will review and update the grievance procedure to ensure it is compliant with IFC PS2 requirements, including relevant procedures and resources to address anonymous complaints and grievances related to sexual harassment.
Contractor Management
As indicated above, the ESMPs for construction and operations will include a contractors management plan for construction and O&M contractors respectively. The contractors’ management plan will outline how TAV will monitor compliance with the E&S policies and standards by EPC and O&M contractor and its sub-contractors.
To manage OHS and labor standards during the construction phase, as outlined in ESAP item 4, TAV will require the EPC contractor to develop an HSE and labor management plan and relevant procedures for demolition/construction activities. TAV will approve the EPC contractor’s management plans before contractor’s mobilization and will ensure that they are aligned with TAV’s E&S and HR policies and the project ESMP.
Where applicable, TAV will monitor and ensure that accommodations for construction workers (contractors and sub-contractors) are in line with IFC and EBRD Good Practice Note on Workers’ Accommodation.
Occupational Health and Safety
As noted above, the airport operates an accredited Health & Safety Management System which includes risk assessments, management plans and mechanisms for reporting and managing incidents. A set of OHS policies and procedures have been developed by the current operator.
Per the information reviewed by IFC, there have been no H&S claims made against the airport and accident statistics have recorded only four (4) lost time accidents (LTA) in the past three years. There have been no recorded fatalities or disabilities for the recorded period.
Based on the nature of the site, low level of recorded LTA suggests that reporting of accidents may need to be revisited and strengthened. There is no process currently in place for recording near miss incidents. In addition, no details are available regarding accidents involving airport users (non-employment related) and occurred within the premises of the airport.
As outlined in ESAP item 10, TAV will review and update the AIA OHS Management System, to align with TAV corporate OHS Management system, in compliance with IFC’s PS1 and PS2; and consistent with International Standard ISO 45000, and will adopt procedures aimed at ensuring incident and near miss reporting by the staff and contracted workers.TAV will also include the reporting of contractor accidents and accidents involving airport users.
Personal protective equipment and annual medical examinations are provided to personnel, according to their functions, including personnel working in hazardous working conditions and exposed to high noise levels in the workplace. TAV will ensure that workplace monitoring and occupational disease surveillance are carried out as part of the airport management system.
Health and Safety (H&S) inductions are provided to both AIA and employees of third parties working at the airport. Training is provided based on the job roles and written procedures are in place. Going forward, TAV will review and update the relevant training programs and will conduct H&S training ensuring site specific and critical role specific training needs are analyzed. The training programs will be reviewed annually throughout construction phase and for operation.
COVID-19: AIA have developed OHS procedures on how to prevent and respond to COVID-19 risks for its workforce. COVID-19 procedure have been developed covering airport passengers and employees. Measures include regular cleaning and disinfection, PPE requirements, medical support, and compliance with general biosecurity measures. No job losses have occurred to date due to COVID-19.
Resource Efficiency:
AIA developed and is implementing a certified ISO 50001 energy management system. Examples of energy efficiency improvements include the modernization of the runway lighting signal equipment (implemented with support from the UNDP Global Environmental Finance (UNDP-GEF) under the framework of the Sustainable Cities for Low-Carbon Development project) and LED replacement program which prioritized the terminal building initially with external lighting to follow. TAV will follow this systematic approach in achieving continual improvement of energy performance. New passenger terminal will be also designed to be resource-efficient, aiming at achieving at least 20% savings in operational energy consumption, water use and embodied energy of materials as compared to typical local practices and, thus, meeting IFC’s EDGE (Excellence in Design for Greater Efficiencies) certification criteria.
GHG Emissions: Direct ground-based AIA airport GHG emissions are caused by gasoline and diesel fuel for airport vehicles and ground support equipment (GSE), and jet fuel for auxiliary power units (APUs). Indirect emissions are associated with the company’s purchase of electricity and heat from generating companies. Based on AIA data from 2019, GHG emissions in 2019 are estimated by IFC as 24,600 tons of CO2 eq.
As agreed in ESAP item 11, TAV will review and update the GHG reporting by the airport and will integrate it with the relevant figures associated with the new terminal once operational. One of project’s noise mitigation measures discussed under PS4 is to reduce the time APUs are run (whilst aircrafts are being prepared on stand for departure or following arrival) through substitution of the APU’s appropriate function (be this electrical power and/or air conditioning) by airport based support systems. This measure, once implemented, will have both noise reduction as well as GHG reduction benefit.
Pollution Prevention:
Air Emissions, Noise and Vibrations
Limited air emissions and relevant impacts are expected from the construction of the project. Air emissions will be typical of a construction site (e.g., dust, exhaust gases from vehicles and equipment) and managed according to mitigation measures, which will be defined in the construction ESMP.
According to air emissions permit (valid to February 2021) held by the airport, there are 173 air emission sources within the airport. Pollutants include nitrogen dioxide, carbon monoxide, sulfur dioxide, toluene, xylene, acetone, butyl acetate, suspended particles and oil overspray. Total annual emissions of regulated air pollutants are restricted to 142 tons/year. The permit only covers ground sources (fixed and movable) and does not include emissions from aircrafts before landing or after take-off.
The Sanitary Protection Zone (SPZ) required in relation to air emissions is defined as the area within a distance of 300 m from the emission sources. According to the modeled concentrations of air pollutants in the ambient air (including background concentrations) from the ground sources included in the permit, those do not exceed relevant maximum permissible concentrations (MPC) for residential areas, according to the national standards. However, ambient air quality measurements at or beyond the site boundary to ensure the MPC are in fact being met, especially in residential areas, have not been carried out by the current operator. As required by the national legislation, TAV will carry out verification monitoring to confirm the 300 m SPZ is adequate and will work with authorities to finalize the establishment of SPZ. Going forward, TAV will include ambient air monitoring in its Operational Environmental Monitoring Program as required in ESAP item 5. Noise and vibration monitoring and impact due to airport operations are discussed under PS 4 section below.
Soil and Groundwater:
There is limited information regarding soil and groundwater conditions at the airport and potential historical contamination, which may occur at airports as a result of fuel storage, stormwater runoff and drainage systems, fuel transport and refueling, firefighting training areas, winter operations, electrical substations and storage of hazardous materials. While soil environmental sampling data available at AIA do not indicate elevated levels of hydrocarbons in soil, no groundwater monitoring data is available.
Fuel storage tanks are mostly dated from the 1970s and therefore may be approaching the end of their life. Wet stock monitoring is undertaken at the existing aboveground fuel storage tanks. The potential for product loss from the two underground tanks used for the storage of oily residue has not been assessed. No integrity testing or maintenance has been undertaken on those underground tanks.
Surface water run-off drainage channels on the site are also dating from 1970s and in poor condition.
As addressed in the ESAP item 12, as the matter of priority, TAV will assess the conditions of existing infrastructure, including drainage infrastructure, fuel tank farms, and other containments with the potential to pollute groundwater and implement a preventative maintenance program identifying priority actions according to an agreed time-bound plan.
All surface water run-off generated at the airport is treated at the airport wastewater treatment plant (WWTP) on site (holding/settling tank and two step oil/water interceptors). The quality of the water is tested bi-annually for hydrocarbons. No other chemicals that are used routinely at the airport are included in the scope of monitoring. However, other sources of potential current and historical ground and soil contamination include glycols (deicing agents), PFOS (perfluorooctanoic sulfonate) and PFOA (perfluorooctanoic acid) (fire-fighting foam). Treated wastewater is reused on site, however, it is unclear based on current sampling regime if the water is suitable for reuse. Under the updated monitoring program as agreed in ESAP item 5, TAV will increase the frequency and scope of wastewater monitoring to include other target polluting substances present in surface water run-off.
A total of 35 oil-filled transformers are currently in operation at AIA and a small number have been decommissioned and stored within the maintenance compound. It is unknown if these units contain PCBs; however, based on their age, it cannot be discounted. As such, the oil within decommissioned and operational equipment will be tested for PCBs by TAV. If PCBs are detected, TAV will develop a time-bound Action Plan, including treatment & disposal options, and estimated budgets. This will be addressed as per ESAP item 14. This is in line with the national Environmental Code, which requires the safe storage of waste containing PCBs.
During disarmament period, after the break of the Soviet Union, the airport was used for the temporary storage of radioactive materials prior to being transported by air out of Kazakhstan. There were no further shipments of radioactive materials after 1995. Whilst the airport still has the equipment and storage premises which comply with the radioactive materials licensing requirements, TAV has confirmed they plan to discontinue the license and decommission the former handling facilities. Based on information currently available, the potential for radioactive contamination at such facilities due to temporary storage cannot be discounted. As outlined in ESAP item 15, TAV will conduct a radioactivity survey prior to demolition works. If radioactive contamination is detected, TAV will develop and implement a relevant management plan to ensure safety of the operators and adequate disposal of the debris and dismantled equipment.
As addressed in ESAP item 13, TAV will develop a contaminated land map for AIA identifying high and medium risk areas in relation to current and historical hazardous material storage and use. TAV will undertake environmental assessments as part of any geotechnical site investigations, especially in high or medium risk areas.
If, based on the assessment, historic pollution is detected, liabilities will be resolved by TAV in accordance with the conditions agreed in the legal documentation with the current owner and national law, or where this these are is silent, in accordance with GIIP. Remediation action plans (including defined budgets) will be developed and remedial actions implemented to avoid or minimize significant adverse impacts on human health and the environment.
Hazardous materials
While the current operator of AIA reported that no asbestos was present at the airport, TAV will carry out a detailed asbestos survey prior to demolition works. If asbestos is detected, it will be handled and disposed of as per an agreed asbestos management plan. This will be addressed by TAV as per ESAP item 16.
TAV will also carry out a review of all air conditioning equipment across AIA site and prepare a register of refrigerant gases used within the airport and identifying the eventual presence of hydrofluorocarbons (HFCs) which have been phased out by international conventions. If any HFCs phased out or to be phased out are identified, as agreed in the ESAP item 17, TAV will prepare a time-bound plan to substitute them.
Waste Management:
The site holds a waste permit. As part of the construction and operations ESMPs under ESAP item 4, TAV will develop site-specific waste management plans for construction and operations to monitor and record estimated and actual waste volumes as well as to define waste treatment/disposal options and disposal routes, with preference given to waste recycling and reuse of material where possible.
Construction impacts
The proposed development areas are located within the boundary of the operational airport and, therefore, community health and safety risks and impacts are expected to be typical of large construction sites and their interaction with populated areas. As part of the construction ESMP, consideration will be given to any construction activities, including onsite construction and construction traffic, that could have consequences off site. Procedures for disclosing information to local communities relevant to the construction activities will be developed by TAV and included in the construction ESMP. TAV will also assess the risk of labor influx and, as part of the construction ESMP, will develop and implement measures to monitor and minimize potential impacts on local communities, including measures for contractor monitoring, training and awareness and relevant code of conducts for contractor workforce.
No information is currently available in relation to traffic routes for construction vehicles carrying demolition, excavated materials and building material. Traffic will be restricted to the main highways and designated routes. A consideration will be given to the use of the railway siding located at the fuel farm to alleviate road transportation during the construction phase. Prior to development, as part of the construction ESMP under ESAP item 4, TAV will produce and implement a Traffic Management Plan, which outlines the mitigation, control and monitoring measures, including road safety measures, to ensure that health and safety risks to communities are mitigated.
Operations Noise:
AIA did not undertake all required steps in the past to apply for a Sanitary Protection Zone (SPZ) which is, therefore, still to be established. The requirement for a SPZ around airports is aimed at establishing land use restrictions and preventing the exposure of residential receptors to noise (and air emission) levels above the applicable and relevant national standards. As a result, significant development has been undertaken in the vicinity of AIA, resulting in large number of residents currently exposed to ambient noise levels above national levels. The national standards for residential ambient noise in Kazakhstan are generically applicable and do not differentiate by noise sources. In addition, there are no local noise standards limiting values specifically for airport operations in the local legislation, unlike legislation in various countries around the world which define specific regulations governing noise levels from airport operations. Noise monitoring and modelling, which was undertaken by the independent consultant on behalf of TAV, indicate that more than 3,000 and 9,000 households are currently exposed above national noise levels at day and night time respectively, and forecasted traffic growth in 2040, if no mitigations are implemented, would result in further increase of exposed population.
Consistent with the ICAO Resolution A33/7, Balanced Approach to Aircraft Noise Management (the “Balanced Approach”) and WBG EHS Guidelines for Airports, TAV has agreed, under ESAP item 18, to develop a Noise Management Plan and implement a number of noise management practices, including construction of a noise barrier, implementation of APU time management to reduce ground noise and independent monitoring of ambient noise to confirm effectiveness of implemented measures. The Balanced Approach consists of identifying the noise problem at a specific airport and analyzing various measures available to reduce noise which can be classified into four principal elements (Reduction of Noise at Source, Land-use Planning and Management, Noise Abatement Operational Procedures, Operating Restrictions), in coordination with the Civil Aviation Authorities responsible for flight operations. The goal is to address noise problems on an individual airport basis and to identify the noise-related measures that achieve maximum environmental benefit most cost-effectively using objective and measurable criteria.
As a result of the noise management practices which will be developed by TAV, impacts from ground sources (operations and equipment) including aircraft taxiing; operation of ground support vehicles (e.g. passenger buses, mobile lounges, fuel trucks, aircraft tugs, aircraft and baggage tractors, and dolly carts); aircraft auxiliary power units (APUs); and aircraft engine testing activities in airports with aircraft maintenance activities, will be mitigated. According to the model prediction, ambient noise impacts of ground operations, which are under direct control of TAV, will be kept within 3 dBA increase (outdoor) at the nearest receptors, which is consistent with the requirements of the WBG General EHS Guidelines; and noise levels at some residential receptors will be brought into compliance with national standards. However, most of the currently affected receptors (residential and commercial) will remain exposed to noise levels above national ambient standards due to aircraft noise during landing and take-off (LTO) cycles. As part of the company’s actions under the Balanced Approach, under ESAP item 18, TAV will implement a voluntary Nighttime Noise Insulation Program during 2023-2040 to minimize sleep disturbance of population exposed to nighttime noise levels above Lnight 60 dBA as a result of the aircraft noise during LTO cycles, with target noise level of at least 40 dBA and, in any case, a minimum of 5 dBA noise level reduction for interior habitable area during night time. Based on the analyses done by TAV, there are currently 460 households and, based on projected traffic growth and expansion capacity, an estimate of about 1290 households in 2040 that would be eligible for such program. As the matter of priority, the company will also work with authorities to establish the SPZ around the airport with the purpose of preventing any new construction encroaching the higher noise impact zones and further increase of exposed population within it. However, the project cannot fully comply with national standards related to residential noise due to proximity of residential areas to the airport and lack of practicably achievable technical solution to mitigate noise during aircraft LTO cycles, and the Board approved a waiver of certain requirements of the Sustainability Policy and Performance Standards with respect to compliance with such noise standards.
Based on instrumental measurements conducted during noise study, there was no measurable vibration effect detected on closest receiving bodies.
Public Safety
Aviation safety investigation (initiated by the GoK after the plane crash in December 2019) identified 6,700 dwellings outside of the airport’s fence, which are located within a zone which would have required the application for a relevant building permit from aviation authorities. To address this risk, TAV initiated an aviation safety study, which was focused on current and long term community safety situation due to airport operations. The study involved an assessment of the risk associated with the four ends of the existing runways, the affected land plots and their use. The study concluded that there are no affected land plots in the higher risk contour of 1 in 10,000, neither in current nor long-term scenario. The conclusion of the assessment is that AIA is in compliance with international aviation safety requirements imposed by the ICAO.
To further minimize risks of aeronautical operations on local communities, beyond the airport’s boundaries, TAV has agreed (ESAP item 19) to initiate and work with the authorities on establishment of Public Safety Zones (PSZ), which are designated areas of land at the end of airport runways within which development may be restricted in order to control the number of people on the ground at risk of injury or death in the event of an aircraft accident on take-off or landing. The implementation of the PSZ will not impose restrictions to existing properties or activities which were identified by the study as being located in a lower risk zone of 1 in 100,000 (54 plots in 2020 and 194 plots in 2035). The scale of risk to the public will be reduced by appropriate conditions on future development approvals (e.g. a condition preventing the storage of hazardous materials in an industrial development) which will be defined by relevant authorities. New developments which may increase the number of people living in PSZ will not be allowed within the PSZ.
Wildlife controls are in place to reduce bird strikes. AIA has a grass management plan and pesticides are reportedly used to reduce insect populations thereby reducing feeding grounds for birds. Under ESAP item 4, TAV will review and update the grass management plan and pesticides management to ensure their use and management comply with IFC’s PS3 requirements.
A Traffic Management Plan will be developed for the operations phase and will envisage measures to address vehicle movements to and from the airport associated with increased airport traffic volumes, and mitigate impacts on mobility and road safety in the area surrounding the airport and for the local community.
Life and Fire Safety
Based on the audit report received from TAV, conditions of existing public terminal and the airport’s hotel are not in compliance with the LFS requirements of the WBG General EHS Guidelines.
As outlined in ESAP item 20, TAV will include the required LFS improvements, covering fire detection, alarm systems and smoke exhaust, in the passenger terminal and in the airport hotel’s building according to its new type of occupancy, in CapEx program and implement needed corrective actions, according to an agreed time-bound plan.
Life and fire safety requirements will be incorporated in the design of the new terminals to meet internationally recognized LFS standards (NFPA 101). As outlined in the ESAP 20, the design will be certified by an accredited LFS professional. TAV will also ensure new terminal design will be in accordance with the relevant national and international structural/building standards, taking into account the potential for seismic activity and universal access principle, as outlined in ESAP item 21 and 22 accordingly.
Security Personnel
Security personnel are directly employed by AIA. The current operator reported that there were no security accidents or any allegations of abusive acts of security personnel. It is anticipated additional security staff will be required once the terminal development is operational and air traffic increases. For the development and operational phases, TAV will conduct a security risk assessment and based on the outcome will develop and implement a Security Management Plan, consistent with the requirement of this Performance Standard s. As part of the plan, TAV will train security staff, including in relation to use of force in line with the Voluntary Principles on Security and Human Rights. This is addressed in ESAP item 23.
Based on the information available and following an analysis of alternative options, TAV has determined that the preferred location proposed for the new terminal is the location currently occupied by the existing VIP terminal, which, as indicated, is listed as architectural monument of local importance by the Almaty City Council since 1979. According to national legislation, the decision regarding delisting a site from the list of the sites of cultural importance could be made only based on the conclusion of a historical and cultural expert review (which is in process), approved by local authorities (AKIMAT).
While the review by the authorities is ongoing, the sponsor has engaged an external expert to carry out an assessment and evaluate the cultural value of the building and its replicability as per PS8. Based on the outcomes of the assessment, the external expert indicated that VIP building is to be considered a replicable cultural heritage. According to PS8 definition, historical sites may be considered replicable where the particular eras and cultural values they represent are well represented by other sites and/or structures. The assessment also concluded the VIP terminal was a strong candidate for reconstruction/restoration either in situ or at a different location. If the GoK approves the removal of the historical building, as agreed in ESAP item 24, prior to any works, TAV will ensure meaningful consultations with Affected Communities and other relevant stakeholders to incorporate their views; explore options for maximum preservation of the building/elements; employ suitably qualified heritage experts to develop a reconstruction plan that captures the historical character of the original structure; and engage specialized contractors/techniques to remove and relocate the VIP building. The work will be monitored by an international heritage specialist to ensure that the approach of the relocation of the VIP building is compliant with PS8 requirements.
A chance find procedure will be included into the construction ESMP (ESAP item 4) which will be adhered to in the event that cultural heritage is discovered during construction works at the site. TAV will not disturb any chance find further until an assessment by competent professionals is made and actions consistent with the requirements of this Performance Standard are identified.
Given the stage of the project, to date no stakeholder engagement has been undertaken in relation to the proposed development. The national EIA process requires the developer to disclose project information and consult with relevant stakeholders as early as possible in the process to incorporate their views into decision-making process.
A Stakeholder Engagement Plan (SEP) has been developed by the external consultant hired by TAV, which outlines the proposed stakeholder engagement throughout the duration of the development and operation of the project, including engagement activities required during the EIA process, to ensure that it is fully aligned with IFC’s PS requirements. As per ESAP item 25, TAV will assign a full time Community Liaison Officer to implement SEP and disclose information about the main environmental and social impacts of the project. TAV will conduct regular meetings, at least on a quarterly basis, with local communities to update them about the project status and the implementation/update. The SEP will be periodically reviewed and updated to ensure that it is fully reflective of the current situation.
A grievance procedure and comments/feedback mechanisms are in place in AIA for passengers/customers within the airport terminal. However, such procedure / mechanisms are not directed to handle community grievances. As agreed in ESAP item 25, TAV will establish and maintain the community grievance mechanism (CGM) process, which will be outlined in the SEP and publicly disclosed. The CGM will also be designed to receive and address complaints of sexual harassment or gender-based violence from survivors and members of the community. This will include a mechanism that ensures confidentiality and adequate resources for effective referrals to support services or the provision of support services.
| S.no | Description | Anticipated Completion Date | Status |
|---|---|---|---|
| 1 | TAV to revise AIA current ESMS to align with TAV corporate E&S policies and management systems, and with IFC’s Performance Standards; and consistent with International Standard ISO 14001. TAV will integrate AIA’s existing EHS risk management with TAV’s corporate risk management, internal audit and compliance functions’ work programs; and ensure that monitoring and review of E&S risks and impacts is carried out as per IFC’s Performance Standards. TAV Airports Audit Committee Charter will include periodic oversight of internal audit’s actions related to AIA’s E&S risk management. Compliance with IFC Performance Standards will be integrated in the management reviews at TAV corporate level | 12/20/2021 | Completed |
| 2 | Appoint suitably qualified Environmental, Social, Health and Safety Manager(s) at AIA with experience in the application of E&S standards of IFIs and knowledge of sector-specific E&S issues. TAV will review AIA’s current resource capability against project E&S commitments. This will include adequate resources to implement the Stakeholder Engagement Plan. | 08/30/2025 | Completed |
| 3 | Develop a national level EIA (OVOS) in support for the proposed development and increase of air traffic at AIA to meet national requirements. - The EIA will also be aligned and cover the scope of the IFC Performance Standards, including the requirement for a social baseline as well as assessing potential social risks and impacts. The EIA process will include consultation in line with PS1 requirements. | 01/28/2021 | Completed |
| 4 | Develop and implement project specific ESMPs for construction and operations that take into account the mitigation measures and monitoring requirements set out in the EIA, the ESDD, and include site specific procedures/plans for the development and operation phases respectively, including but not limited to: 1. Air quality management plan; 2. Noise management plan; 3. Stormwater management plan; 4. Waste management plan; 5. Hazardous material management; 6. Spill response plan; 7. Topsoil management plan; 8. Archaeological chance find protocol; 9. Traffic management plan; 10. Accommodation Plan 11. Stakeholder engagement and grievance management plan. 12. Health and Safety Plan, Including specific prevention and control plans for pandemics such as Covid-19. 13. Grass management plan and pesticides management The ESMPs for the construction and operations phase will include a contractors management plan that will outline how TAV will monitor compliance with the E&S policies and standards by EPC and O&M contractor and its sub-contractors. TAV will require the EPC contractor to develop an HSE and labor management plan and relevant procedures for demolition/construction activities. TAV will approve the EPC contractor’s management plans before contractor’s mobilization and will ensure that they are aligned with TAV’s E&S / HR policies and the project ESMP | 01/01/2023 | Completed |
| 5 | TAV to produce and implement an overarching Operational Environmental Monitoring Program | 12/26/2023 | Completed |
| 6 | TAV to review the EPRP to include all operations, including the fuel farm, and ensure that all credible emergency scenarios are covered, including onsite and offsite emergencies, and be aligned with the relevant requirements of IFC Performance Standards under PS1 and PS4, the WBG General EHS Guidelines and WBG EHS Guidelines for Airports, including business continuity, emergency response training, including all personnel and contractors; and an emergency communication procedure with local authorities and local communities. TAV will liaise with local emergency service to assess their capacity and resources and to ensure coordination in case of both onsite and offsite emergency. Joint drills will be undertaken on a regular basis | 06/30/2021 | Completed |
| 7 | In case of government-led resettlement, TAV will work closely with the GoK to ensure that the process is in line with the LARF and, if necessary, prepare a Supplemental Resettlement Action Plan which will complement the compensation provided by the GoK to achieve outcomes consistent with IFC’ requirements | 01/01/2026 | Pending |
| 8 | Review and where required update human resource (HR) policy and procedures to meet IFC’s PS2. - HR Policy to include but not limited to requirements for 3rd party workers, and policy on forced labor and child labor. - Develop a policy on retrenchment outlining the commitment to develop a retrenchment plan in line with PS2 requirements if needed. - Develop a policy on sexual harassment | 06/30/2021 | Completed |
| 9 | Develop and implement labor grievance mechanism which is compliant with IFC’s PS2 standards. The GM will ensure worker's confidentiality and allow for anonymous grievances. The GM will be adequate to receive and manage grievances related to gender-based violence and sexual harassment. | 06/30/2021 | Completed |
| 10 | Review and update the AIA OHS Management System, to align with TAV corporate OHS Management system, in compliance with IFC’s PS1 and PS2; and consistent with International Standard ISO 45000. Adopt procedures aimed at ensuring incident and near miss reporting by the staff and contracted workers. TAV will also include the reporting of contractor accidents and accidents involving airport users. | 12/30/2021 | Completed |
| 11 | TAV will review and update the GHG reporting by the airport and will integrate it with the relevant figures associated with the new terminal once operational | 06/30/2025 | Completed |
| 12 | Assess the conditions of existing infrastructure, including drainage infrastructure, fuel tank farms, and other containments with the potential to pollute groundwater and implement a preventative maintenance program identifying priority actions according to an agreed time-bound plan | 09/30/2025 | Pending |
| 13 | Develop a contaminated land map for AIA identifying high and medium risk areas in relation to current and historical hazardous material storage and use. Conduct soil and underground water sampling as part of geotechnical surveys required for new development. If any contamination detected, prepare and implement a time-bound remedial action plan | 09/30/2025 | Pending |
| 14 | Test waste transformer oil to establish if Polychlorinated Biphenyls (PCBs) are present. If present, prepare and implement a time-bound remedial action plan. | 12/30/2021 | Completed |
| 15 | Complete risk assessment prior to the decommissioning of the historic radioactive material handling facility. Carry out environmental sampling of soil if deemed necessary based on the assessment. | 06/30/2022 | Completed |
| 16 | TAV will carry out a detailed asbestos survey prior to demolition works. If asbestos is detected, it will be handled and disposed of as per an agreed asbestos management plan | 06/01/2022 | Completed |
| 17 | Carry out a review of all air conditioning equipment across AIA. If any HFCs phased out or to be phased out are identified, TAV will prepare and implement a time-bound plan to substitute them | 12/01/2021 | Completed |
| 18 | Develop a Noise Management Plan including defined sanitary zoning, mitigation measures both planned and alternatives, noise targets, noise and complaint monitoring (2023). 2. Implement noise mitigation measures to reduce impacts on residential receptors from Auxiliary Power Units (APU) and taxiing, including noise barrier and limiting APU usage time. 3. Examine possibility (2021) and implement tailored night hour route selection and direction of aircrafts through runway 05 in coordination with relevant authorities. 4. Confirm effectiveness of implemented noise mitigation measures by an independent ambient noise monitoring. 5. Implement a voluntary nighttime noise insulation program for local residents impacted by exceedances of 60 dBA: (1) Phase I: 2023-2025 Total of ~426 buildings (2) Phase II: 2025-2030 Total of ~885 buildings (3) Phase III: 2030-2040 Total of ~ 1290 buildings by 2040 | 12/31/2026 | Pending |
| 19 | Initiate and work with the authorities on establishment of PSZ within which development may be restricted in order to control the number of people on the ground at risk of injury or death in the event of an aircraft accident on take-off or landing | 06/30/2026 | Pending |
| 20 | 1.A suitably qualified professional acceptable to IFC will review a Master Plan/engineering design of new terminals and provide a professional certification that the design of life and fire safety systems is in accordance with an internationally accepted life and fire safety (L&FS) standard. As needed a corrective Action Plan with a time frame for implementation will be submitted. L&FS design will not be certified until the professional has received confirmation of satisfactory incorporation of corrective actions. 2.A suitably qualified Life and Fire Safety professional acceptable to IFC will conduct a review, as part of the project completion test, at the time of the L&FS systems testing and commissioning, and will certify that the construction of these systems has been carried out in accordance with the accepted design and the L&FS section of the WBG General EHS Guidelines. As needed a corrective Action Plan with a time frame for implementation will be submitted after the professional’s first review. Completion will not be certified until the professional has received confirmation of satisfactory completion of the Action Plan. 3. Conduct technical inspection of fire safety systems in existing passenger terminal that are critical from a Life Safety perspective (fire detection and alarm, accessibility of exits & evacuation signalization; smoke extraction) against national standards, with a firm statement on the current operational condition of the system / components in terms of performance & reliability. Undertake all measures to obtain a fully operational fire detection and alarm system, unblocked means of egress and unlocked exit doors. 4. Existing terminal and the airport hotel’s building will be upgraded as part of refurbishment programme to address findings of the L&FS audit against national requirements and good international practice. | 03/01/2024 | Completed |
| 21 | TAV to ensure that buildings design complies with national and international seismic building code requirements | 06/01/2021 | Completed |
| 22 | TAV to develop a strategy to implement universal access principle and incorporate the findings into the new and refurbished terminal designs | 06/01/2021 | Completed |
| 23 | TAV will conduct a security risk assessment and based on the outcome develop and implement a Security Management Plan | 01/01/2021 | Completed |
| 24 | Management of cultural heritage relocation - VIP terminal building - TAV will conduct consultations with relevant stakeholders and obtain the required permits from regulatory bodies for the deconstruction and relocation of the VIP building. - TAV will appoint local cultural heritage (CH) experts to provide input into the final master plan design, to oversee enhancement options, to complete a Significant Fabric Assessment, to prepare a Heritage Interpterion Plan and assess suitability of reconstruction/restoration techniques. - The relocation process will be conducted under monitoring of international Cultural Heritage expert acceptable to IFC. | 01/01/2021 | Completed |
| 25 | TAV will assign a full time Community Liaison Officer to implement SEP and disclose information about the main environmental and social impacts of the project. TAV will conduct regular meetings, at least on a quarterly basis, with local communities to update them about the project status and the implementation/update. - TAV will develop and implement an CGM which will be effectively disseminated among effected communities and wider group of stakeholders | 01/01/2021 | Completed |


