PS7: Indigenous Peoples is not considered applicable as there are no indigenous people in Turkey. PS 8: Cultural Heritage are not considered applicable to the project, because OEDAS transmission lines are generally co-located along highway, road, and other rights-of-way. As noted under PS 1 below, procedures for dealing with chance finds of cultural heritage were incorporated into OEDAS’s management systems.

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 and can be readily addressed through generally accepted mitigation measures as described in this document and the attached Environmental and Social Action Plan (ESAP).

OEDAS has established an effective E&S management system (ESMS) and dedicated E&S teams to manage and monitor their E&S performance. Thus, the key Environmental and Social (E&S) issues associated with this project as identified during IFC’s review are related to (i) OEDAS’s corporate capacity and competence and implementation of the ESMS to manage E&S risks in its operations, (ii) fair and safe working conditions and management of OHS aspects including response to the COVID crisis in terms of job protection and worker safety;(iii) contractor management in terms of working conditions and OHS (iv) emergency response and preparedness; (v) gender, sexual harassment and GBV issues at the workplace; (vi) resource efficiency and energy efficiency, management of waste and emissions; (vii) land acquisition; (viii) biodiversity screening and management; and (ix) stakeholder engagement.

Environmental and Social Assessment and Management System:

Policy

Through IFC’s investment in the previous three projects (135MW Rotor Elektrik wind project in Turkey (Project #27191) and 56MW wind project in Pakistan (Project #29251), Zorlu Disco (Project #39691) the sponsor’s environmental and social performance has been strengthened to meet IFC’s Performance Standards and its E&S Policy has been applied to OEDAS as well as their respective contractors. The Company established an Environmental Policy and Occupational Health and Safety Policy along with Quality Policy, Customer Satisfaction Policy, and Security Policy. The policy documents are displayed on the corporate website, intranet, and across facilities in five regions. OEDAS will develop an overarching corporate social policy to guide the company’s E&S management system as per ESAP item #1.

Contractor Management

OEDAS regularly engages several contractors for construction works (investment projects and KET projects) small additional works and meter reading services.

The company integrates its Contractor Environment and Social Management Plan Procedure in request for proposals for contractors and bid evaluation committees consist of representatives of Q&E, OHS, Operation and Procurement Units. E&S requirements and procedures are included in each contract and are legally binding. Contractors are required to commit to adapt and implement the company’s ESMS and the requirement therein.

A platform module within the OEDAS QDMS system has been developed for the contractor’s approved officials who can access E&S plans and procedures to ensure effective contractor E&S management. (e.g., Contractor’s OHS responsible can upload accident reports and dangerous situation notifications). OEDAS closely monitors Contractor’s activities on site. A field inspection program was developed and is being implemented as part of OEDAS ESMS.

As part of IFC’s investment, OEDAS will review and improve its contractor management plans and procedures in line with IFC’s Good Practice Note (GPN) Managing Contractors' Environmental and Social Performance as per ESAP Items #2.

Management Systems and Organizational Capacity and Competency

OEDAS has operational procedures, instructions and other relevant documents related to environmental and social matters.  OEDAS is currently certified for ISO 900:2015, ISO 14001:2015 and OHSAS45001: 2018, ISO10002:2018 and ISO27001:2013 management system standards. The Company has established and maintains a QDMS (Quality Document Management System) where the environmental and social management programs are monitored, applicable national laws and regulations are followed up, and project related E&S information is shared with all employees.  An annual integrated audit of ISO 9001-14001-1002 and ISO 45001 management systems was carried out by a third-party auditor, Vericert, in November 2020. No major non-compliances were identified.

Responsibility for E&S management documentation resides with the Quality and Environmental (Q&E) Manager. The Q&E Manager directly reports to the Electrical Distribution Director. The Q&E department comprises of a total of 3 employees including the QHSE Manager, Quality Expert and Environment Expert. An OHS manager assigned in April 2021 who directly reports to the director. The following capacity increase measures have been taken since 2018:  OHS department has four internal and fourteen external OHS Experts, one full time and four part-time doctors and five health officers. The day-to-day OHS issues at each site are handled by the four OHS Experts with support of the other team members.

The company developed and implemented a procedure for construction works in forest areas that identifies contractor EHS requirements. In addition, as construction activities may accidentally lead to the uncovering of cultural heritage, a chance find procedure is implemented by OEDAS and its construction contractors.

Identification of Risks and Impacts

As electricity distribution lines and relevant facilities are exempted from Turkey’s Environmental Impact Assessment (EIA) Regulation, OEDAS operations are not required to undertake EIAs. In certain cases, forest areas are used as rights-of-way for electrical distribution lines to supply electricity to rural areas within the OEDAS region. The construction of these lines does not fall within the Turkish EIA regulations since they are typically 34.5 kV or <1 kV which is below 154kV (the lower limit for EIA studies).

OEDAS internally assesses the E&S impacts of its investments on a site-by-site basis during the design stage and identifies mitigation measures to be implemented during the construction and operation activities. As part of its ESMS, the company has E&S risk and impacts analysis procedure in line with IFC PS1.

As part of its Management System, the company developed and implements a biodiversity screening procedure and conducts a high-level assessment on a site-by-site basis to evaluate the ecological potential of the areas. As per ESAP item #17, the procedure will be reviewed and updated to clearly differentiate natural and critical habitats as explained under PS6 section below.

Community Health and Safety Risk Assessment focuses on the construction and operation aspects (e.g., restriction of unauthorized entry, use of appropriate transformers), as well as emergencies.

Management Programs

The company’s corporate Environmental, Social, Health and Safety Management Programs and Plans include risk assessment, solid and hazardous waste, ozone depleting substances phase out, biodiversity, site preparation and construction, emergency preparedness and response, workforce including a recruitment plan, gender equality, induction, vocational and E&S trainings, security forces, contractors, land acquisition, customer relations, community awareness and stakeholder engagement including grievance mechanism. These programs and plans are in line with the certified corporate ESMS of the company and with the IFC requirements. They include details on monitoring actions, frequency of monitoring along with performance indicators and are reviewed and revised regularly.

Training

Pursuant to the relevant legislation (Regulation on Procedures and Principles of Health and Safety Training of Employees; OG Date/Number: 15.05.2013/28648.), workplaces conducting ‘very dangerous works are required to ensure that the employees who are engaged in these tasks receive necessary vocational trainings, as well as standard 16-hour OHS training every two years. Induction and periodic OHS trainings are provided to the OEDAS employees within the relevant regulatory framework. Annual training programs are prepared by the Q&E and H&S Manager. The operation and safety training programs include the following subjects: Regulatory OHS trainings (including OHS law, legal rights and responsibilities of employees, safety rules and culture, personal protective equipment, electrical hazards and risks, accident prevention measures); operation simulation training for circuit breakers; grounding of electrical pole (wooden, metal and concrete) installations; connection/disconnection in electrical installations; meter reading operations in electrical installations; work at heights; arc flash and electrical safety training; biodiversity and critical species awareness and emergency response plan. OEDAS will ensure that particular training needs for contractor’s employees including third party risks are included in the contract and contractor’s employee receives necessary trainings as per ESAP Item #3.

A new training center (3 training fields and one conference room) in Eskisehir was constructed in 2019. All OEDAS electrical technicians hold valid EKAT certificates (i.e., vocational certification required as per the Regulation on Electrical High Current Facilities) and attend refreshment courses offered by TEDAS every 5 years, as legally required.

Emergency Preparedness and Response

OEDAS has an Emergency Response Plan which sets instructions to assist employees and the emergency response teams in case of an emergency. The emergency procedure includes fire and explosion, serious work injury accident, natural disaster (earthquake) sabotage and terror, flood, chemical spill, food poisoning, traffic accident and evacuation.

Turkey is a seismically active area within the complex zone of collision between the Eurasian Plate and both the African and Arabian Plates, it is seismically one of the most active countries in Europe. A detailed survey was conducted by the Company to assess the seismic risks for OEDAS facilities. Building physical state report for all operation facilities and associated action plan has been prepared in line with the Regulation on Buildings to be Built in Seismic Zones (Official Gazette date/no:06.03.2007/26454). In line with the action plan, the Company’s Eskisehir Province Operation Office, Kütahya Head Quarter, Usak Head Quarter were moved to safe new buildings in 2020. Bilecik and Afyon Head Quarters have plans to move to new office locations.

Training is provided for emergency response team members according to legislation requirement. Emergency drills were performed annually. OEDAS prepared an Exceptional Circumstances Plan for severe weather condition which covers alternate routes, emergency contact cards that contain information about company OHS contacts, municipality contacts, first aid, vehicle rescue services, repair and maintenance services, and road safety.

Monitoring and Review

The company has a monitoring and review program which is adequate to satisfy IFC PS requirements. This includes monitoring for non-technical electricity losses, annual losses of SF6 circuit breakers, hazardous and non-hazardous waste, GHG Emissions, exhaust emission measurement of vehicles, safety and maintenance equipment/vehicles, employee health examinations and exposures to workplace dust, noise, and vibration, lost time accidents including contractors, near miss accidents and winter ornithology at the sensitive (wetlands) areas. 

Zorlu Enerji has issued annual sustainability report since 2014. OEDAS will determine its own KPIs and be fully integrated in the report by 2022. Sustainability report of the sponsor for 2020 can be found on the following link: (https://www.zorluenerji.com.tr/uploads/pdf/pdflist/surdurulebilirlik-raporu-2020.pdf).

The company has a Key Performance Indicator (KPI) monitoring program for various parameters as well and will include relevant OHS (e.g., LTIFR) and environmental performance indicators in the KPI list as per ESAP Item #4.

The company employs a total of 1,242 people of which 146 (13%) are female as of August 2021. The female workforce of the company was 9%, 11% and 12% in 2018, 2019 and2020 respectively.

Human Resources Policies and Procedures, Working Conditions and Terms of Employment, Workers’ Organization:

HR Policies and Procedures OEDAS has documented Human Resources (HR) policies and procedures covering recruitment, company rules, freedom of association, child labor, discrimination, harassment, ethics, performance evaluation, legal rights, safe working conditions, employment agreements and conditions, equal opportunity, disciplinary actions, grievance, and compensation. The HR policy and procedures are consistent with the national labor regulations and IFC PS 2 requirements, applying to all employees. OEDAS will develop an anti-sexual harassment policy including a clear complaint procedure for handling complaints and carrying out investigations as per the ESAP Item #7.

Each worker receives a written contract covering the requirements of the local regulation. Working hours, shift arrangements, rest periods, paid leaves and overtime work are monitored and compensated as per national regulations. OEDAS will commission a labor audit to assess labor practices of the company and its contractors. The findings of the labor audit will be reflected in the company’s HR procedures and in the Labor Code of Conduct which will be developed as per the requirements of PS2, ILO and local regulatory requirements. Contractor labour audit will be conducted every two years. An employee handbook will also be prepared and distributed aligned with the labour code of conduct as indicated in the ESAP Items #8, #9 and #10.

Workers’ Organizations A total of 751 out of 827 OEDAS operational employees are members of the Trade Union of Energy, Water and Gas Workers of Turkey (TES-IS). A collective bargaining agreement was signed between OEDAS and Tes-Is on 03.05.2021, which is valid till 28.02.2023. To establish an effective relationship with the union, an Industrial Relations Management Procedure was established in February 2021. The company will make sure that the contractor employees are represented by their designated representatives (e.g., in monthly OHS meetings) as per ESAP Item #11.

Protecting the Work Force

OEDAS does not engage in child or forced labor. The company maintains copies of ‘statement of employment’ for contractor employees and ensures by reviewing these records that the contractors also apply the same conditions on child and forced labor.

Non-discrimination and Equal Opportunity:

The HR policy of the company clearly identifies respect of differences of race, origin, religion, gender, social class, nationality, age, physical disability and disadvantage during recruitment and career advancement of its employees as per non-discrimination principles. OEDAS commissioned a consultant to undertake an assessment and to develop an action plan to improve awareness of gender equality and to increase the share of women workforce in the company. The company will monitor the gender equality action plan implementations and monitoring results will regularly be submitted to IFC as part of E&S Performance Annual Monitoring Report (AMR).

As per ESAP Item #12, OEDAS will i) develop a corporate GBV and sexual harassment policy including senior management’s mission statement, intended outcome for handling GBV and sexual harassment at the workplace and clearly identified grievance procedure allowing anonymous grievances, including handling complaints and carrying out investigations; ii) assign a person in senior management to be responsible for GBV and sexual harassment related issues and iii) establish a committee consisting of management, workers representative, union representative and external parties, if possible, that will be responsible for implementation of policy requirements. In order to raise corporate awareness of gender-based violence (GBV) and sexual harassment at the workplace, the company 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 contractors (ESAP Item #13).

Grievance Mechanism:

The company has a documented grievance mechanism for employees in line with its HR policy. As per ESAP #12 the company will ensure that grievance mechanism allows for submission of anonymous grievances which is suitable to capture harassment related issues and is also available to the contractor’s workers and all employees including contractors are aware of and trained on the grievance mechanism. The company will also ensure that contractors also have their own grievance mechanism for their employees and will closely monitor the grievances at contractors in terms of OHS, environment and labor issues in line with PS2 and Good Practice Note (GPN) Managing Contractors' Environmental and Social Performance (ESAP Item #14).

Workers Engaged by Third Parties

OEDAS engages with several contractors on a regular basis including construction works (both above and below ground) and meter reading. There was a total of 120 full time staff and 461 contractors employed as of May 2021 at OEDAS investment projects. Contractor management practices and monitoring mechanisms are considered to have improved since privatization and relevant contracts include necessary clauses to ensure safe working and fair labor conditions.

All tender processes regarding the contractors are carried out by the Distribution Department. The contracts for construction works are signed on a project basis and contractors are evaluated by QEHS, Operation and Procurement Units. The contractors are liable to take all necessary OHS measures as per national OHS legislation and ensure that its personnel use personal protective equipment (PPE) during work. According to the requirements of the contract agreement, OEDAS reserves the right to inspect the activities of the contractor on-site and may fine the contractor in case of non-compliance with health and safety requirements. The company will undertake a third-party audit of long-term contractors every two years to review labor practices according to PS2 requirements as per ESAP Item #15.

Occupational Health and Safety (OHS):

OEDAS has established its OHS management system along with the ISO 45001:2018 management system and certified in November 2020. The OHS performance is managed and monitored through the internal QDMS system.

OEDAS has a written ‘OHS Policy’ statement in place showing the management’s commitment to protect health and safety of its employees and stakeholders in line with Turkish OHS Law (No: 6331) depending on the danger class of the workplace operations. Accordingly, site operations are classified as ‘very dangerous’ for OEDAS. As a high-risk activity, the construction and operation of the transmission lines includes working with live electrical equipment, circuit isolation, working at heights, hazardous chemicals, lifting and hoisting of equipment, as well as the transportation of massive items. These risks are covered in company’s current risk analyses.

The Company has developed several OHS procedures such as Hazard Identification and Risk Assessment Procedure, Incident and Accident Management Procedure, Work Permit Procedure including work at height, LOTO Procedure, Job Safety Analyzes, Lifting Load Procedure, Safe Material Use Procedure, Repair and Maintenance Procedure, Construction Operations Procedure, Vehicle Driving and Maintenance Procedure, Expropriation Process Procedure, Contractor Management Procedure, Workplace Industrial Hygiene Management Procedure; First Aid Procedure, and Emergency Procedure. There are also health and safety-related instructions, such as Personal Protective Equipment (PPE) Instruction, Night Work Instruction, Emergency Response Plan, Electric Network Maintenance Instructions, and OHS Committee Instruction. Visual confirmation system instructions have been fully implemented in five provinces starting from in April 2021.

Lost time injury frequency rates (number of incidents per million work hours, LTIFR) was 7,8 in 2018. It improved to 6,33 in 2019 and 2.03 in 2020. There is an improvement trend and the LTIFR is low compared to good international industrial practice for electricity distribution industry (3.6) (www.safeworkaustralia.gov.au). With a slight decrease trend LTIFRs were reported as 7.93, 7,64, 7,37 in 2028, 2019, 2020 respectively for the contractors.

The company has two fatal accidents caused by electrocution occurred in 2018 and 2019. Following the fatalities, the company commissioned an OHS audit in February 2020. As required in the OHS action plan, a visual confirmation system was decided to be adopted with the telephone where all employees are monitored before starting and during the task using visual communication with the operation centre. LOTO procedure will be integrated to visual confirmation system and recently commissioned SCADA system as per ESAP Item#16. No Contractor fatality has occurred last three years. The high frequency of work of height lost time accidents (13) were reported for the same period. The work at height permit system will be revised and issued daily/weekly depending on the nature of the contracted work as per ESAP Item #16. OEDAS includes in the contracts the requirement to prepare and implement a Construction Environmental and Social Management Plan (CESMP) and reviewed and updated asset signage and identification list to ensure zero-fault implementation. To strengthen its contractor management and enhance OHS practices, the company will improve its contractor management practices and contractor management plan including worker’s grievance mechanism in line with IFC’s Good Practice Note: Managing Contractors' E&S Performance (http://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/publications/publications_gpn_escontractormanagement) as per ESAP Item # 16.

Many operational vehicles (330) are used by OEDAS employees and its contractors. In the last 3 years, OEDAS has experienced over 40 road accidents (no third-party injury reported). OEDAS developed a Road Safety Policy and a safe driving regulation. The company started a Defensive Driving Training program carried by ‘Turk Surus Academy’ for 400 employees and provided defensive and off-road related practical and theoretical training including driver assessment. OEDAS Road Accident Frequency Rate decreased between 2018-2021 time periods and however, contractor’s rate has increased. No fatal accident was reported. The company will ensure that necessary precautions are taken to reduce road accident of contractors as per ESAP Item #16.

Resource Efficiency

OEDAS has provided percentage of overall distribution losses as targets for each year of the CAPEX investment program. These targets are agreed with EMRA and are understood to be achievable with OEDAS having demonstrated historical outperformance in this area. In 2020, the Company’s energy losses in the distribution network were estimated around 6.54% against a target of 7.2%, which is the total of technical loss and commercial loss (theft, or not billed). The average losses among all 21 distribution companies in Turkey was about 11%. The company has a team responsible for monitoring technical and commercial losses by performing regular inspections of the distribution network and there are ongoing efforts to decrease the technical losses in each province. OEDAS’s applications on new renewable energy sources generation are currently in progress. A total of 206.9MW generation both at LV and HV levels is provided by solar, geothermal, biomass and hydro power sources through 344 connections.

Water, Wastewater and Storm Water

Water is supplied from city networks and mainly used for domestic purposes in the OEDAS facilities. OEDAS operations are not under the scope of Environmental Permit and License Regulation and there is no direct discharge of wastewater into receiving bodies that would require control under an environmental permit. Wastewater generated from the office buildings and other facilities is discharged to municipality sewerage systems and finally city wastewater treatment plants for each city. There is no construction camp or accommodation is required for the construction workers. Access to clean drinking water is provided on a daily basis and mobile toilets are used on site. Wastewater from mobile toilets is regularly disposed to city sewage system.

Stormwater is generated from rainfall events when surface water runoff occurs at the site. Stormwater runoff is generated particularly in waste storage areas and warehouses, particularly at the Sultandere main warehouse in Eskisehir which has a large open space with steep slopes. A stormwater management procedure and program has been developed and implemented covering the operational warehouses and storage areas with potentially contaminated runoff in line with Turkish water pollution control regulation. Periodic testing including transformer storage areas are performed.

Hazardous Wastes

Waste Oil

Polychlorinated biphenyls (PCBs) are typically present in oil-cooled electrical equipment such as transformers or condensers. The distribution network includes approximately 22,450 of transformers ranging in age from 0 to 55 years.  An inventory of transformers containing PCBs has been prepared to date and waste oils have been typically disposed of based on a one-time analysis of a composite of oils from different transformers. The use of PCBs in new electrical equipment has been prohibited in Turkey since 1996 by the Hazardous Materials Regulation. The PCBs are currently regulated under the Regulation on the Control of Polychlorinated Biphenyls and Polychlorinated Terphenyls, which requires the development of an inventory program for identifying PCB levels in transformer oils to ensure the protection of the environment and human health. In accordance with the regulation, PCB containing materials and equipment should be purified or disposed of until 2025.

A random transformer oil sampling of 116 transformers (out of 165 old transformers produced before 1990) were conducted in 2018 and the Company has identified three PCB containing transformer equipment. As a result, a phase-out action plan for the identified transformers has been prepared. The Company will continue to maintain the inventory as they identify the types and manufacturing years that are highly likely to contain PCB content.

OEDAS improved chemical storage practices including secondary containment, developed an inventory of materials and chemicals used in all operations, ensured that MSDS forms of all chemicals (e.g. transformer oil, diesel oil, engine oil, paints, lubricants and cleaning agents) are available in Turkish at the facilities in accordance with the relevant regulation; and developed hazardous material handling procedures including requirements for housekeeping and storage conditions. The company has received the temporary waste storage area permits for Eskisehir, Afyon, Usak, Kutahya and Bilecik in March 2019, January 2020, January 2020, June 2019, and March 2020, respectively.

Air Emissions

OEDAS operations are not under the scope of Environmental Permit and License Regulation and there are no industrial emissions of concern that would require control under the ‘Environmental Permit’. Nevertheless, OEDAS performed an inventory and then identified the thermal power and fuel type of all boilers for heating purposes and identified that there is no need for air quality testing with respect to WBG General EHS Guidelines (Table 1.1.2 Small Combustion Facilities Emission Guidelines applicable for facilities > 3MWth and operating more than 500 hours per year with an annual capacity utilization factor of more than 30%).

Greenhouse Gases

One of the important aspects related to greenhouse gas emissions is the use of Sulfur Hexafluoride (SF6) circuit breakers in OEDAS system. SF6 is an extremely potent greenhouse gas with a global warming potential of 23,900 times that of CO2. There are 11,731 circuit breakers in the OEDAS network, among which 4,739 of them are SF6 circuit breakers. Several factors affect SF6 emissions from electrical equipment, such as the type and age of SF6-containing equipment and the handling and maintenance protocols utilized by electric utilities. OEDAS has improved inventory records of SF6 circuit breakers which includes information such as their location and production information. In addition, OEDAS uses low leakage rate equipment and conducts leak checks for SF6 Circuit Breakers. Maintenance is not conducted for SF6 circuit breakers and when broken, they are properly disposed and replaced with a new SF6 circuit breaker. Annual losses and procurement quantities are monitored.

There is an inventory of the air conditioners in all five provinces of OEDAS. There is a total of 74 air conditioners with HCFC-22 type refrigerant which is a restricted HCFC gas. The company plans to replace all the R-22 equipment by the end of 2024 as per its phase out plan.

GHG emission reporting by OEDAS has been verified by a third party (BSI) along with ISO 14064-1:2018 Greenhouse gases requirements. GHG emissions for the period from 01/01/2020 to 31/12/2020 is 212.215 tons of CO2 equivalent. OEDAS reported that it is the only electricity company which verify carbon emissions by an independent institution.

Climate Change

Turkey, as being a part of the southern belt of Mediterranean Europe, is vulnerable to climate change. OEDAS will conduct a climate change risk assessment study in terms of environment and OHS matters as OEDAS operations will be subject to risks from climate change as per ESAP Item #17 (increasing frequency of severe weather events may create abnormal risks particularly in terms of OHS).

Third-party safety issues are included in OEDAS Operation Risk Assessment Procedure. Instructions to be implemented for the safety of life and property of third parties and a separate network maintenance and fault repair third party risk assessment report has been prepared. A community accidents investigation and reporting system was established to identify and take actions to prevent accidents. No accidents were reported for last three years. 

Pedestrian routes are carefully planned and then isolated using stronger materials such as rigid security barrier fences are procured by OEDAS and their contractors, especially for excavation pits instead of safety plastic strips and plastic reflective cones. People entering the construction site is prevented by plastic rigid, barriers and illuminated warning signs. OEDAS has placed security sensors at critical and recently invested locations under SCADA scope.

Facilities located in residential/commercial areas or at open public space have safety warning signage to remind the public of potential hazards associated with these facilities. There has never been a third-party fatal incident to date.

Energy transmission lines produce electric and magnetic fields in their surroundings because of high voltage and current. External accredited laboratories have taken measurements at locations such as step-down transformers, distribution lines, pole transformers nearby the public areas in 15 locations of five provinces. The measurements were between 12 µT and 22 µT, which is lower than the limits of national regulation and WBG Environmental Health and Safety Guidelines for Electric Power Transmission and Distribution limits of 100 µT with a frequency 50 Hz. In addition, a safe working distance of electromagnetic field was measured for 15 transformers.

The company reported that electromagnetic field measurements are continued to be carried out for new transformers to be installed in populated areas.

Forest Fires

Climate change has been a key factor in increasing the risk and extent of wildfires in Turkey with the increased drought in recent years. If underlying growth is left unchecked, or slash from routine maintenance is left to accumulate within right-of-way boundaries, sufficient fuel can accumulate that may promote forest fires.

The company, in collaboration with  the Ministry of Agriculture and Forestry, will ensure  measures are taken to prevent and control risk of forest fire which include but not limited to: monitoring right-of-way vegetation according to fire risk;  removing blowdown and other high-hazard fuel accumulations; time thinning, slashing, and other maintenance activities to avoid forest fire seasons; disposal of maintenance slash by truck;  planting and managing fire resistant species (e.g. hardwoods) within, and adjacent to, rights-of-way; and clearing land to slow progress of fires and allow firefighting access. Construction and operation of transmission lines in forest areas procedures and instructions will be reviewed and updated accordingly as per ESAP Item #18.

Security

OEDAS has its own 73 security personnel who work full time in three shifts. OEDAS security staff carry firearms. They are certified and regularly trained as per the local regulatory requirements and UN Voluntary Principles on Security and Human Rights. The company developed a security policy including requirement for background screening to ensure that candidates do not have any criminal record or record of abuse or violation of human rights and to provide relevant trainings to security personnel on; conflict resolution, crowd management, restraint exercise of the security activity, proportional use of force (if allowed) and basics of human rights; and keep records of training sessions.

The project is located in three Anatolian ecoregions (per WWF classifications): The Central Anatolian steppe and woodlands, the Anatolian conifer and deciduous mixed forests and the Central Anatolian steppe.  The broader region is also a known corridor for migratory soaring birds, especially for White Storks (Ciconia ciconia, IUCN Least Concern [LC]) and Egyptian Vultures (Neophron percnopterus, IUCN Endangered [EN]).  In this section, the project and its biodiversity commitments are described with respect to (i) existing power lines, (ii) planned power lines in 2021 and (iii) power line development beyond the 2021 timeframe.

With respect to legally protected areas (LPAs) and Key Biodiversity Areas (KBAs, including Important Bird Areas - IBAs), the following is relevant. For existing power lines, the client has mapped the extent of overlap with LPAs / IBAs in the provinces of Afyonkarahisar (eight LPAs and six KBAs), Bilecik (one LPA and one KBA), Eskisehir (five LPAs and six KBAs), Kütahya (six LPAs and five KBAs) and Usak (three LPAs and one KBA). With respect to the power lines planned, some segments will be located within 1 km from and/or overlapping with the following areas:

-          Uludag National Park (IUCN Cat II) and KBA:  Transmission line segments Muratdere-Kozpinar ENH (10.4 km); Saridayi Bransmani (2.6 km); Cihangazi KOK - Dombaycayiri Koyler Grubu ENH (13.4 km); and Duzagac Bransmani (0.88 km)

-          Aksehir Golu Natural Protected Area (IUCN Category Ia), Eber Goluand (IUCN 1b/VI) and Aksehir and Eber Golleri KBAs:  Transmission line segment Uckuyu KOK - Karapinar - Karakisla ENH (22km)

-          Harmankaya Kanyonu (IUCN Cat V):  Transmission line segment Esenkoy KOK - Kusca Grubu ENH (12. 5 km)

-          Kutahya Tavsanli Catak (IUCN Cat 1a/VI) and Altintas Ovasi KBA:  Transmission line segment Toklar ENH (1.37 km)

-          Kutahya Merkez Altintas (IUCN Cat 1b/VI) and Karamik Sazligi KBA:  Transmission line segment Altintas DM Gecek Grup Koyler ENH (10 km)

-          Karamik (IUCN Cat 1b/VI): Transmission line segment Karacaoren-Kocbeyli ENH (11.5 km)

-          Eskisehir Mihaliccik Catacik Natural Protected Area (IUCN Category Ib/VI) and Sundiken Daglari KBA:  Transmission line segments Gokcekaya ENH (14.1 km) and Taycilar Branch (6 km)

-          Murat Dagi KBA:  Transmission line segment Altintas DM Gecek Grup Koyler ENH (8.18)

Routing is not yet available for powerlines planned beyond 2021.  Building off the company’s existing biodiversity-related procedures, a biodiversity policy will be developed, and existing procedures strengthened as part of ESAP Item #20. As part of the updated procedure, a biodiversity screening process will be developed that includes a set of high-risk biodiversity criteria (such as LPAs/KBAs) that will be used to screen the locations of all newly proposed powerline routes. The criteria will be developed with reference to habitat classifications per PS6. The procedure will include requirements to flag high-risk locations to the company’s design and engineering teams so that these sites could be either avoided or mitigated, depending on the relative biodiversity risk present. The procedure will be developed to be compatible with the company’s existing ESMS and technical risk review processes.

The existing and planned power lines extend across several provinces, characterized by a mosaic of Modified, Natural and some Critical Habitat per PS6. With respect to existing power lines, the project has mapped high biodiversity value habitats (e.g. areas that are important for migratory birds, areas known for the occurrence of plants that have Critically Endangered [CR] or Endangered [EN] IUCN status and/or that are restricted range), some of which may qualify as Critical Habitat, e.g.  areas located in Sündiken Mountains, Acikir steppes, Türkmenbaba mountain, Aksehir -Eber Lakes, Murat Mountain, Aliken Steppes, and Uludag are known for restricted range plants. The company has also screened the location of powerlines on a site-by-site basis to consider biodiversity aspects and determine if additional field surveys and mitigation measures are required (see below comment on mitigation measures). As part of continuous improvement, the project will review its mapping of existing and planned powerlines to ensure alignment with PS6 habitat definitions per ESAP Item# 20.  About 80 percent of power lines planned for 2021 will be located in Modified Habitat. The rest will largely be in Natural Habitats with some segments in Critical Habitats due to the presence of KBAs as well as the presence of priority biodiversity values including: a restricted range amphibian species, Beysehir (Anatolian) Frog (Pelophylax caralitanuan, IUCN Near Threatened [NT]); several fish species (IUCN CR, EN, Vulnerable [VU] and restricted range); several restricted range insect species as well as a plant (Amblyopyrum muticum, IUCN EN). Further assessment will be carried out by the client to define the extent of the different types of habitat aligned with PS6 definitions (see ESAP Item# 21).

Infrastructure planned for beyond 2021, will be screened, assessed and developed in accordance with an updated company biodiversity policy and procedure (see ESAP Item#20).

For all existing powerlines and those planned in 2021, mitigation measures will entail electrocution safe designs and fatality monitoring in high-risk segments to birds. These measures will be prescribed based on the refined mapping and developed into a Biodiversity Management Plan (BMP) per ESAP Item #21. For power lines traversing KBAs, PAs or Critical Habitats, the project will develop a Biodiversity Action Plan (BAP) in line with PS6 requirements and define offset actions and financial commitments commensurate with predicted impact per ESAP Item #22.