This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. The environmental and social risks and impacts associated with this project are limited, site-specific, largely reversible, and can be readily addressed through generally accepted mitigation measures and good international industry practices (GIIP).

Environmental and Social Assessment and Management System

Izsu has a documented and functioning environmental and social management system (ESMS) consisting of identification of risk and impacts in line with Turkish environmental and occupational health and safety legislation, safe working practices, potable water treatment plant operational procedures, evaluation of legal compliance, emergency preparedness, monitoring and reviewing environmental performance, and communication with interested parties. Izsu annually discloses its performance on its website, http://www.Izsu.gov.tr which includes key performance indicators related with potable water resources, water treatment plant projects and distribution system improvement.

In compliance with Turkish legislation (Law No:6331 dated 6/20/2012) and consistent with PS2, Izsu has an internal OHS regulation which defines structure of monthly OHS committee meetings, training needs, methodology for risk assessments, permit to work system, number of OHS personnel and OHS requirements. Relevant requirements are included in the terms of references for contractors.

Through IFC’s investment in the previous two wastewater treatment projects (project #32078 and #36080), Izsu’s environmental and social management system, specifically E&S monitoring and reporting, has been strengthened to meet IFC’s Performance Standards.

The project contractors have their own E&S and health and safety management systems and have extensive working experience with Izsu in the past.

Identification of Risks and Impacts

An Environmental Impact Assessment (EIA) is not required for this project under Turkish regulations and each individual project has been approved by the General Directorate of Environmental Management of the Ministry of Environment and Urbanization. Specialized consultancy firms hired by Izsu for the design of each individual project conducted required geological, technical and E&S assessments during the project design stage.

The General Directorate of Hydraulic Works (DSI) has the overall authority to protect the water resources of the country. This includes assessing the capacity of the underground aquifers and surface water basins, planning water consumption and providing permits to possible users. Izsu holds legal rights to use the water resources in its service area as per the permission received from DSI. Izsu has conducted required geological surveys, water capacity and quality assessments for each water source and has received the required permits from DSI for the amount of water to be taken from the sources included in each of the individual projects.

Organizational Capacity and Competency

The Projects Department and Water and Construction Department of the company have the overall responsibility for the design of wastewater and potable water collection, treatment and distribution network projects. Contractor selection and construction monitoring are performed by Investments and Constructions Department. Wastewater collection and potable water distribution networks are operated by the Sewerage Department Water Pipelines and Distribution Department, respectively while the Wastewater Treatment Department and Potable Water Treatment Department are responsible for operation of WWTPs and PWTPs. The Environmental Protection and Control Department, consisting of environmental permitting, license and control, and laboratory branches with capable and technically competent staff, reports to a Deputy General Manager and has the overall responsibility of ensuring relevant measures are considered and implemented in line with national regulations during the design, construction and operation stages of the projects. Similarly, the Occupational Health and Safety Unit with five full time OHS experts, 12 part-time OHS experts and four doctors, oversees OHS management and practices at the company’s construction and operational sites. Construction contractors and service provider companies have their own environmental, health and safety management arrangements as per the respective local regulations and their contractual requirements with Izsu.

At various levels within Izsu there is adequate technical and E&S competency. As per the ESAP item #1, Izsu will assign a competent and dedicated E&S specialist who will coordinate all necessary mitigations, monitoring, data collection and reporting requirements among the respective departments during the construction and operation phases of the projects under the scope of this investment.

Emergency Preparedness and Response

Izsu has a documented emergency preparedness and response plan including firefighting and spill management in line with IFC’s Performance Standards and Turkish legal requirements. Emergency plans including COVID-19 related risks and measures are readily available at contractors’ construction sites and operational facilities.

Monitoring and Review

Izsu has a weekly and monthly treated wastewater and potable water quality analysis program in place and the results are disclosed on its webpage. Water quality parameters are benchmarked with WHO requirements. Izsu also reviews and inspects the quality of the construction materials and pipes used by the contractors. Safety and maintenance of equipment/vehicles, employee health examinations, non-revenue water rates and lost time accidents (LTAs) are among the regularly monitored parameters. Izsu will ensure that all contractors’ accident reports and preventive actions are included in Izsu’s OHS reporting system, lost time injury frequency (LTIFRs) calculated and all lost time accidents, including contractors’ LTAs, are recorded consistently, and reported to Izsu senior management as per the ESAP item #2.

Training

Izsu has a comprehensive training program which is presented in its annual strategy reports disclosed on its website. Each department identifies the training needs of the staff according to technical and OHS qualifications required for executing departmental responsibilities. The workforce, including contractors, are trained on the work hazards present (such as confined space entry, work at height, excavation), correct use of equipment, OHS procedures relevant to the tasks, and use of personal protective equipment (PPE).

As of the end of 2020, the total number of employees working for Izsu was 1,832 of which 380 (21 percent) were women. Izsu procures numerous services from other subsidiaries of IMM. Izdoga, with 2,245 employees, and Izelman, with 625 employees, provide operation and maintenance (O&M) and technical support services of WWTPs and PWTPs. Izenerji provides meter reading services with 407 employees and security services with 835 employees. The share of women employees in service provider companies’ workforce is around 10 percent. The average construction workforce expected at peak for each individual project is around 70 workers.

Working Conditions and Management of Worker Relationships

As Izsu is a 100 percent owned subsidiary of IMM, recruitment, terms of employment and working conditions are defined and provided according to Turkish “Public Employees Personal Regulations”. There is a documented Human Resources (HR) and Training Procedure and Disciplinary Regulation defining the responsibilities of all staff as well as general ethical rules. As clearly stated in the internal regulation, the company does not discriminate with respect to any aspects of the employment relationship on the basis of personal beliefs, race, ethnical identity or sex.

Workers’ Organizations Izsu employees and its service provider contractors are members of trade unions which are active in municipal services, including Belediye Is, Tum Bel-Sen, Tum Yerel Sen, Turk Yerel Hiz-Sen, Bel-Bir-Sen, DISK and employees holding civil servant status have collective bargaining rights and have additional benefits called social balance rights including compensation for commuting, lunch and daily child care facilities.

Non-Discrimination and Equal Opportunity: Three of the five board members, the general manager and one of the four deputy general managers of Izsu are women as well as several department heads despite the lower rate (21 percent) of women participation in the workforce at lower positions. Non-discrimination and equal opportunity are covered in the existing policies and code of conduct. As identified in ESAP item 3, Izsu will conduct an assessment of gender equity in the work environment including hiring policies, mechanisms and channels and legal, economic, or sociocultural barriers that can be addressed to support recruitment and retention of women and will develop a gender action plan to identify actions to be taken for improvements that could be made in making jobs equally accessible to both men and women and finally, to increase the number of women employees in each service areas of Izsu.

Grievance Mechanism There is a documented formal internal grievance system in place where employees can raise and register their concerns, including through anonymous reporting. Grievances raised using this mechanism are reportedly limited to around 10 per year and generally related to behaviors of other employees.

Protecting the Work Force Izsu verifies the age, social security coverage and/or work permits of new employees and its contractors. and therefore, do not engage in child or forced labor. There are no employees under the age of 18.

Workers Accommodation The majority of the contractor workforce consists of local workers. Worker camps were installed at the construction sites of Karaburun Mordogan, Kemalpasa II and Foca PWTP projects. Each camp has adequate space per worker, safe potable water, sanitation and clothes changing facilities.

Trainings and other consultancy services In addition to onboarding and in service trainings provided to employees, the human resources department recently hired a psychologist to provide the employees with additional training and consultancy services on areas such as stress control and anger management. As per the ESAP item 4, Izsu, in order to raise corporate awareness of gender-based violence (GBV) and sexual harassment at workplace, will engage with external experts to develop and implement a training program for managers and a training of trainers program for the HR personnel to provide further trainings to all employees including service provider contractors.

Occupational Health and Safety (OHS)

Construction contractors are contractually required to follow Turkish OHS legislative requirements and Izsu has a set of instructions in the terms of reference for contractors to ensure occupational health and safety measures are taken based on job hazard and job safety analysis. The contractors have their own OHS procedures including risk assessment and provide OHS and environmental awareness training for employees. Site supervisors of Izsu and the contractors are present at construction sites to ensure implementation of OHS procedures, equipment safety and safe use of equipment and to monitor performance. Licensed consulting companies were hired by the contractors to provide regular site OHS inspections, training, and medical health services to contractors’ workers.

COVID-19 protection measures have been implemented, and no COVID-19 positive cases have been identified at construction sites.

Izsu has detailed maintenance programs for equipment, vehicles and hand tools. Preventive maintenance programs are in place and regularly tracked. Medical examinations of the employees are carried out at intervals defined by the Turkish legislation, and necessary vaccination programs are implemented according to risk analyses.

Lost time, first aid accidents and near misses are closely monitored by Izsu OHS unit. Incidents are categorized and reported to OHS management and each lost time incident is investigated through root-cause analysis and corrective actions are identified.

The majority of the wastewater pipe network (40 km) which was constructed around 50 years ago in Ulucak, Kuyucak, Damlacik and Ansizca neighborhoods in Kemalpasa district contains asbestos cement. Izsu reported that existing pipelines in their networks are abandoned-in-place under the ground and only rarely removed and replaced. The contractor has a procedure/instruction for safe handling of asbestos cement pipes (PPE, dust control, certified staff) in case of damage or removal and for their safe disposal to designated disposal facilities and the workers are provided with a specific training on this procedure.

Being subsidiaries of IMM, Izsu’s main service providers for operations (Izelman, Izdoga and Izenerji) adopt the same OHS policies.

Energy Efficiency

Energy consumption is recorded at the project level; energy consumptions for all construction equipment are logged and analyzed to control and improve efficiency.

Air Emissions and GHGs (Green House Gas) Emissions

Air emissions from combustion sources are limited to a few emergency generators which are small, and below the size threshold at which IFC or local regulators require emissions monitoring. Izsu will account for greenhouse gases emissions annually as per ESAP item #5.

Solid Waste Management

Management of solid non-hazardous waste and limited amount of hazardous waste was found adequate at the construction sites with adequate waste segregation and reduction. Construction waste is either disposed of at designated disposal areas or following aggregation it is incorporated into structural earthworks. Secondary containment (drip trays and concrete containment) was available for the storage of oil and chemicals. Management of sludge and sludge cake at the treatment plants is executed by environmental engineers.

Sludge cake produced in Foca PWTP will be analyzed and, depending on the arsenic content, it will be disposed of at either the non-hazardous cell or the hazardous waste (if >0.2 mg/l) cell of Harmandali landfill of IMM. The sludge cake produced in Mordogan and Ulucak WWTPs will be transported to sludge drying and disposal facility of IMM in Cigli.

The construction schedule of each individual project was planned in accordance with the regulatory requirements for construction activities in touristic areas of Urla, Karaburun, Foca and Odemis districts to minimize public disturbance and impact of the construction works to businesses during the tourism season.

Construction routes of pipelines and excavator/crane working areas are demarcated by safety tape, barricades -as required - and necessary signage. Signboards to inform the community are in place at all construction sites. Izsu ensures and monitors that its contractors immediately backfill and cover all open excavations and trenches. Izsu has provisions to regularly inspect conditions of the work areas to minimize pedestrian and traffic risks and risks to the infrastructure and residences.

Water Availability, Quality and Treatment

Turkish legislation is in line with World Health Organisation (WHO) and European Commission parameters for drinking water quality and the Foca PWTP is designed to meet the required standards.

The design flowrate of the Foca plant will be 30,000 m3/day (or 1,250 m3/hour for a 24-hour operation), and water will be pumped from 19 existing wells located in Foca, Yeni Foca and Musabey area. Auxiliary units will include sludge thickener basins and sludge dewatering building/filter press, flowmeter room, chemical storage room, chlorination room, and generator room.

Arsenic trivalent (arsenite) concentration levels measured at eight wells are averaging 14 µg/l, higher than the WHO limit of 10 µg/l for drinking water, due to the naturally occurring high levels of arsenic in the regional aquifer. Aluminum and iron levels are also higher than the standards in one and three wells respectively. Following an assessment of alternative treatment methods in terms of operational efficiency, investment and operational costs, the company selected to implement conventional chemical treatment (coagulation, flocculation and sedimentation) and filtration for removal of arsenic. Back wash and blow down water from filter beds and water from filter presses and sludge thickener will be returned to a contained basin for retreatment in a closed circuit.

Noise and Dust:

Izsu limits the hours of operation of noisy equipment during the construction and construction works in proximity of communities except for urgent repair works. Dust is suppressed by regular watering of construction areas. The contractors have to obey the ban of local regulations for construction activities during touristic season from mid May to end of September.

Security

Izsu has its own 184 security personnel and contracts out 834 armed security personnel through Izenerji which is a subsidiary of IMM. All security personnel is certified after a background screening and regularly trained as per the local regulatory requirements. These trainings include conflict resolution, crowd management, exercising restraint in the use of force and principles of human rights.

The Karaburun Mordogan wastewater and stormwater networks and Mordogan WWTP are located within the vicinity of the Karaburun Peninsula which was declared as Karaburun Ildir Bay Special Environmental Protection Area (SPA) by a Presidential Decree dated March 14, 2019. In addition, both the Mordogan and Urla wastewater and stormwater collection networks are located within a Natural Protected Areas (NPA), the former within a Strict Protection Area (corresponding to IUCN Category Ia), and the latter within a Sustainable Use and Controlled Management Area. These two project areas also fall within the Karaburun and Ildir Strait Islands Key Biodiversity Area (KBA), which is also designated as an Important Bird Area (IBA). Kemalpasa I and Kemalpasa II wastewater and stormwater networks overlap with three KBAs: the former with Spil Mountain KBA, and the latter with Nif Mountain KBA and Boz Mountains KBA. All three KBAs were originally designated as Important Plant Areas due to the diversity of range-restricted plant species mostly found within sub-alpine and montane habitats that will not be impacted by the project.

The majority of the project is situated within modified terrestrial habitats, with pipeline infrastructure being installed along existing road networks in either urban or farmland contexts. Small areas of East Mediterranean phrygana natural habitat (~7 ha) will be lost due to the construction of the PWTP, as well as pipeline extensions at Mordogan. The 500 m offshore discharge pipe installed for Karaburun Mordogan WWTP is in an area of critical habitat for the Mediterranean Monk Seal (Monachus monachus), and has the potential to impact marine natural habitats off the coast of Mordogan and Urla including Posidonia seagrass beds during construction. Posidonia seagrass beds in the Mediterranean infralittoral zone are assessed as Vulnerable by the European Red List of Habitats. If confirmed to be present, Fan Mussel (Pinna nobilis) would also be treated as a critical habitat species. In other natural habitats, impacts of pipeline extensions can be minimized through effective management practices.

As per the ESAP item #6, Izsu will establish an organizational and managerial capacity by assigning a biodiversity management coordinator to ensure the development and implementation of relevant mitigation measures, including the development and implementation of a Biodiversity Action Plan (BAP). Izsu will develop the BAP which will include an implementation program,  with a timeline for the identified actions to include development and implementation of i) additional conservation programs to promote and enhance the conservation aims and effective management of the Karaburun Ildir Bay SPA, Karaburun and Ildir Strait Islands KBA and relevant NPAs through continuous engagement with the respective Non-governmental organizations (NGOs) and the General Directorate for Protection of Natural Assets – Department of Conservation and Monitoring to get involved in the SPA management process; ii) feasible offsets options to achieve no net loss of East Mediterranean phrygana natural habitat and its associated significant biodiversity values, iii) mitigation measures designed to achieve no net loss of important marine natural habitat and its associated significant biodiversity values; iv) identification of conservation priorities for Monk Seal within the Karaburun Ildir Bay SPA/KBA; iv) additional conservation programs designed to achieve a net gain for the Monk Seal as well as Fan Mussel, if surveys confirm presence of the latter (as discussed below); and vi) evaluation and monitoring plan (ESAP item #7).

As per ESAP item #8, a marine survey of the pipeline route will be carried out to map the extent and condition of natural habitat, as well as confirm whether Fan Mussel is present. The results of the survey will inform the design and implementation of appropriate mitigation measures for the construction of the Mordogan WWTP and offshore discharge pipeline, in accordance with the mitigation hierarchy, and the finalization of the BAP.

The Urla district Gulbahce neighborhood and Kemalpasa district have several protected archaeological sites and out of 58.8 km sewer lines, 2 km of the line in Urla and 300 m of the line in Kemalpasa I are located within a 3rd degree archaeological protection area, according to the national categorization of such areas. Izsu received required approvals from Ministry of Culture and Tourism, Regional Council of Protection of Cultural Assets for both projects.  In line with the permit given by the council, excavation and construction works at the both sites were done under the control of archaeologists assigned by the Provincial Directorate of Museums. Construction works in these sections have already been completed.

In keeping its project executions in line with national laws on cultural heritage, Izsu has a chance find procedure and will provide appropriate protection in the events of unexpected discoveries of cultural heritage items at all project sites.