gürmat 2 geothermal power plant...turkey, 110 km south west of izmir (see figures 1.1 and 1.2). in...

Gürmat 2 Geothermal Power Plant Social Impact Assessment Gürmat Elektrik Üretim A.Ş

22September 2014

Gurmat 2 Geothermal Power Plant

Social Impact Assessment

Notice This document and its contents have been prepared and are intended solely for Gürmat Elektrik Üretim A.Ş information and use in relation to the potential investment in the Gürmat 2 GPP by the EBRD and the IFC.

WS Atkins International Ltd assumes no responsibility to any other party in respect of or arising out of or in connection with this document and/or its contents.

This document has 42 pages including the cover.

Document history Job number: 5122671 Document ref:EFE Guris GPP SIA Rev 4

Revision Purpose description Originated Checked Reviewed Authorised Date

Rev 1.0 Client Review Link011 AGI AGI AGI 05/08/14

Rev 2.0 Issue Review Link011 AGI AGI AGI 04/09/14

Rev 3.0 Issue Link011 AGI AGI AGI 16/09/14

Rev 4.0 Issue Link011 AGI AGI AGI 22/09/14

AtkinsG2 GPP SIA | Version 4 | September 2014 | 5122671 1



Table of contents Chapter Pages 1. Introduction 4 2. PROJECT DESCRIPTION 5

3. LEGISLATION, POLICY AND GUIDANCE 9

3.1. National Legislative Framework for Land Acquisition and Stakeholder Engagement 9 3.2. International Standards and Policy Requirements 11

4. ASSESSMENT METHODOLOGY AND SIGNIFICANCE CRITERIA 13

4.1. Scope of the Assessment 13

4.2. Extent of the Study Area 13

4.3. Method of Baseline Data Collation 13 4.4. Significance Criteria 14

5. SOCIO ECONOMIC BASELINE CONDITIONS 15

5.1. Administrative Institutions in Turkey 15

5.2. General Socio – Economic Environment 15

5.3. Land Use and Land Tenure 17

6. LAND ACQUISITION FOR THE PROJECT 19

6.1. Land Acquisition for EFE 1, 2, 3, 4 and the Wells 19 6.2. Land Acquisition for the Pipe Network 20

6.3. Land Acquisition for the Electricity Transmission Lines 20

7. PROJECT RELATED TRANSPORT 22 8. STAKEHOLDER ENGAGEMENT 25

9. ASSESSMENT OF IMPACTS, MITIGATION AND RESIDUAL EFFECTS 27

9.1. Construction 27 9.2. Mitigation 30

9.3. Operation 32

9.4. Mitigation 33

9.5. Monitoring and Follow Up 34 10. REFERENCES 39

11. Limitations and Assumptions 39

Tables Table 4-1 Matrix for determining the significance of impacts 14 Table 5-1 Demographic data on Incirliova and Germencik municipalities 16

Table 5-2 Population in communities surrounding the project site 16

Table 5-3 Unemployment rate in Incirliova and Germencik municipalities 17




Table 5-4 Land use in Aydin province 17

Table 5-4 Vehicle count on the D-550 closest to the project site and foreseen transport for the project 23

Table 9-1 Summary of Impacts 34

Figures Figure 1-1 Project site location in Turkey 4 Figure 1-2 Project site location in Turkey 4

Figure 2-1 Satellite image showing the Gürmat 1 and Gürmat 2 licence areas 5

Figure 2-2 Satellite image showing the final Gürmat 2 GPP locations 6 Figure 2-3 Location of the overhead power line connecting EFE 2 and the main power plant (EFE 1) to the Germencik main transformer station 7

Figure 2-4 Location of existing and planned production and reinjection wells 7

Figure 3-1 Land acquisition process for Gürmat 2 10

Figure 7-1 Satellite image showing the location of EFE 1, 3 and 4 to the D-550 highway and local access road 22 Figure 7-2 Satellite image showing the location of EFE 2 close to the D-550 highway and local Turanlar village road 23




1. Introduction Gürmat Elektrik Üretim A.Ş. (“Gürmat” or “the Company”), established by the Guris Group of Companies, is planning to construct and operate a new 123.3 MWe (possibly increased to an installed capacity of 162.3 MWe in the future) geothermal power plant (“Gürmat 2” or the “Project”), near the town of Aydin in Turkey, 110 km south west of Izmir (see Figures 1.1 and 1.2). In addition to this new geothermal power plant, since 2009 Guris has been operating an existing Gürmat 47.4 MWe geothermal power plant (“Gürmat 1”) in the project area.

Figure 1-1 Project site location in Turkey

Figure 1-2 Project site location in Turkey

Gürmat Elektrik Üretim A.Ş. has applied for financing from the European Bank for Reconstruction and Development (EBRD) and the International Finance Corporation (IFC) (jointly referred to as “the Banks”) as well as a number of commercial banks. Gürmat 2 is classified as a Category ‘A’ project and it is to be developed and implemented in accordance with Equator Principles, the EBRD Environmental and Social Policy (2008) and IFC Performance Standards on Environmental and Social Sustainability (2012).




In accordance with Turkish legislation, an Environmental Impact Assessment for Gürmat 2 GPP was approved by the local authorities in November 2012. Construction of certain project components is already underway and the power plant’s commercial operation is planned to start in 2014.

An Environmental and Social Impact Assessment (ESIA) disclosure package is also being prepared for the Project to meet the Banks’ policies for “A” category projects as well as Equator Principles1. This Social Impact Assessment (SIA) Report will be a part of the ESIA disclosure package. It has been developed with a view of assessing the impact of Gürmat 2 on communities and individuals, as well as social and economic assets within the Project area of influence, as required by the Banks. A separate Stakeholder Engagement Plan (SEP) has also been developed and will be implemented throughout the life of the Project.

This SIA should be read in conjunction with the local EIA and other documents included in the ESIA disclosure package.

2. PROJECTDESCRIPTION Gürmat 2 is being constructed within an already established concession area of 28.3 km2 (see Figure 2.1). Most of the concession area (approx. 75%) is on the territory of Germencik district, while the rest territorially belongs to Incirliova district. Within this concession area is also the already operational Gürmat 1. The green line in Figure 2.1 shows the boundary of the concession area while the red line shows the boundary of the Gürmat 1 Generation Licence.

The Company has been licensed to use the geothermal energy within this concession area for 49 years and the power plant has therefore been designed with an operational life of 49 years. Land used for Gürmat 2 is located on a broad, alluvial plain that is used for agricultural purposes.

Figure 2-1 Satellite image showing the Gürmat 1 and Gürmat 2 licence areas

Gürmat 2 will consist initially of four power generating units as well as the associated boreholes, pipelines and transmission lines as follows: • Main power plant (EFE 1) of 47.4 MWe (dual flash) and three flash binary plants (EFE 2, 3, and 4),

each with a capacity of 25.3 MWe (123.3 MWe in total).

1The disclosure package will comprise the following documents: the Non-Technical Summary, the Environmental Impact Assessment Addendum, the Social Impact Assessment, the Environmental and Social Action Plan and the Stakeholder Engagement Plan.




• Fifty four production and reinjection wells. • Network of interconnecting pipework pumping the geothermal fluid from the wells to the power houses

and back to the reinjection wells. • Transformer station (within the boundary of the main power plant). • 154 kV power line to connect EFE 2 with the main power plant and then with the Germencik main

transformer station (5.7 km). • Access roads that main connect the boreholes and power plants with public roads. • Administrative offices and control rooms at the main power plant and the binary plant installations.

Gürmat 2 will occupy two locations, with the main plant being accessed directly from the Aydın-İzmir Highway (D550), (see Figure 2.2). The main plant will include units EFE 1, 3 and 4 (shown in red on Figure 2.2). EFE 2 is located on its own, about 3km to the south east of the main plant (shown in blue on Figure 2.2). The Gürmat 2 pipework network is expected to be largely to the east Germencik town and to the south of the D550. The overhead power line for EFE 2 will connect to the GPP sub-station at the main plant and then a 154 kV power line will connect the GPP substation to the Germencik main transformer station. The location of the overhead power line is provided in Figure 2.3, while the locations of existing and planned production and reinjection wells are provided in Figure 2.4.

Figure 2-2 Satellite image showing the final Gürmat 2 GPP locations




Figure 2-3 Location of the overhead power line connecting EFE 2 and the main power plant

(EFE 1) to the Germencik main transformer station

Figure 2-4 Location of existing and planned production and reinjection wells

The construction of Gürmat 2 is expected to take approximately 68 months. The pre-construction phase of the project is planned to be completed within 22 months and the construction work will last approximately 46 months. At the time of writing this document in July 2014, the construction of the GPP plant sites was well advanced with major plant items being delivered, about 30 wells drilled and the pipe network for EFE 2 in place.

The G2 GPP construction programme is expected to be:

EFE 1: 47.4 MW Double Flash - April 2015

EFE 2: 25.3 MW Flash Binary - August 2014




EFE 3: 25.3 MW Flash Binary - September 2014

EFE 4: 25.3 MW Flash Binary - May 2015

The first component to come on-line will be EFE 2, which is expected to begin the export of electricity during autumn of 2014. The Company also has plans to build a fifth unit (EFE 5), a 47.4 MWe double flash plant identical to EFE 1 (increasing the total installed capacity to 162.3 MWe), however this is not included in the Project and therefore is not the subject of this impact assessment.

Since the approval of the EIA for Gürmat 2, and the issuing of the Environmental License, the design of the project changed. Originally, Gürmat 2 plants were to be situated in four different locations. As explained above, with this current design, all plants will be situated in two locations, significantly reducing the amount of land take and having a number of other benefits. The Ministry of Environment and Infrastructure has approved amendments to the Environmental License which reflect the new project design and therefore a new EIA is not required.




3. LEGISLATION, POLICY AND GUIDANCE 3.1. National Legislative Framework for Land Acquisition and

Stakeholder Engagement Land acquisition for the Project is guided by the Electricity Market Law No. 4628, amended by law No. 5496 (Article 15, clause c) and the Expropriation Code No. 2942. Land can be expropriated for the project within the 28km2 concession area defined by the generation license. However, according to representatives of Gürmat 2, certain restrictions exist in terms of expropriating land in residential and forest areas within this concession area. The project will not cause any physical displacement of people, as only agricultural land is being acquired. Details on land acquisition are provided in section 6 ‘Land Acquisition for the Project’.

It should be noted that before initiating expropriation under the Expropriation Code No. 2942, the Company attempts to reach negotiated settlements with all affected landowners. The Company prepares technical designs and the lists of land plots that are needed for construction. The Company first investigates prices of land and crops/trees in the area and prepares offers which are then approved by management and offered to the affected land owners. After that, expropriation is initiated for acquiring plots for which negotiated settlements could not be reached.

Expropriation is led by the responsible government agency, in this case the Energy Market Regulatory Authority (EMRA). Costs of expropriation are borne by the Company, which also has the right of use of expropriated land for the same period as the generation license (49 years), while ownership of land is transferred to the Treasury.

In accordance with Article 27 of the Expropriation Code, land acquisition is done through an immediate expropriation procedure. The steps in the expropriation process are as follows:

• The Company applies to EMRA, providing a list of needed land plots. • EMRA takes a decision for immediate expropriation under Article 27 of the Expropriation Code No.

2942, after the decision of the Council of Ministers. • EMRA then turns to the local court with requests to determine the price of affected land plots and to

give the Company (Gürmat 2) the right to use the land plots. • The court assigns at least 5 technical certified experts for assessing the land and includes in the group

any additional local persons who know the prices of land in the area, if needed. The village headmen (muhtars) are also required to attend the appraisal.

• The experts prepare reports and send them to the court. • The court takes a decision on the immediate expropriation of the land plots and on the basis of expert

reports, determines the price for each land plot. • The Company opens up accounts in the name of the landowners and deposits the court specified

amounts in their bank accounts. • The courttakes a decision for immediate expropriation after the Company makes the payment. • The Company then has the right to begin construction on the acquired land plots. • EMRA sends an invitation letter to the landowners to attend negotiation meetings. The letter is

accompanied by the court decision, the expert appraisal report and proof of payment of the expropriation price.

• At the negotiation meetings the Company can choose to provide higher amounts of compensation, so that an agreement can be reached.

• If an agreement is not reached, EMRA turns to the local court again, with requests to determine the price of needed land and to transfer title to the Treasury (with the right of use for the Company).

• New valuations are organized with a new group of court appointed experts.




• The owner and the Company can agree on a price up until the end of this second trial • If the owner is not satisfied with the final price determined by the court he/she can appeal to the

Supreme Court against the decision of the local court.

Figure 3-1 Land acquisition process for Gürmat 2

As per Code No. 2942 (Article 11), valuations of properties are done through field assessments and the experts carrying them out must consider criteria which include the type and quality of the property, the surface area, the location, all property components (including vegetation, structures, water sources, etc.), tax statements, the net revenue to be obtained from a property or a water source on land, the estimated amount made by official authorities during previous valuations, the price of similar land sold before the date of expropriation and any other objective measurements that can be used to determine the compensation amount. The value of agricultural land is based on the net income approach and includes all on-land physical assets and the value of crops based on the annual yield (three year average).

Stakeholder engagement activities for projects in Turkey are organised under the EIA regulation from 2008 and these are the main relevant features of that process:




• The EIA Application file is submitted to the Ministry of Environment and Urbanisation (MoEU). This

document is made available online and open to comments. It serves as an opportunity for the public to comment on environmental and social issues that need to be included in the EIA.

• A public participation meeting is advertised in at least one national and one local newspaper. The meeting is attended by a committee of experts (Inspection and Evaluation Commission) of the MoEU and its purpose is to provide stakeholders with a description of the project and the opportunity to comment on it. Feedback is used to determine the structure and scope of the EIA.

• The draft EIA is disclosed to the public through the MoEU website and is available for public comments. Comments are evaluated by the Inspection and Evaluation Commission, during their review of the EIA report.

• The final EIA is made available to the public for review.

3.2. International Standards and Policy Requirements This SIA has been developed in accordance with international standards, particularly the Equator Principles, underpinned by EBRD Performance Standards and IFC Performance Requirements. The Equator Principles are standards developed by the international finance community for application to the approval of lending for development projects.

The project has been categorised as A and therefore apart from the environmental impact assessment, a social impact assessment must be carried out to address social impacts and risks and propose mitigation and management measures, within a dedicated Action Plan. Applicable EBRD Performance Requirements and IFC Performance Standards cover the following issues:

• Social Assessment and Management Systems • Land Acquisition and Involuntary Resettlement • Community Health, Safety and Security • Labour and Working conditions

Stakeholder engagement for the project must be an ongoing process which involves:

• the client’s public disclosure of appropriate information so as to enable meaningful consultation with stakeholders

• meaningful consultation with potentially affected parties, and • a procedure or policy by which people can make comments or complaints (grievance mechanism).

In relation to land acquisition, the key objectives and requirements of EBRD’s Performance Requirement 5 and IFC’s Performance Standard 5, applicable to this project can be summarised as follows:

• avoid, or at least minimise, permanent or temporary project induced economic displacement whenever feasible by exploring alternative project designs;

• develop appropriate livelihood restoration action plans where significant displacement is unavoidable;

• improve or, at a minimum, restore to pre-project levels livelihoods and income earning capacity of affected persons, including those who have no legally recognisable rights or claims to land and support them during the transition period;

• mitigate adverse social and economic impacts from land acquisition or restrictions on affected persons’ use of and access to land, physical assets or natural resources by:

- providing compensation for loss of assets at replacement cost prior to taking possession of acquired assets; and

- ensuring that compensation and livelihood restoration activities are planned and implemented with appropriate disclosure of information, consultation, and the informed participation of those affected,




• make special provisions for assisting disadvantaged or vulnerable individuals or who may be more

adversely affected by economic displacement than others and who may be limited in their ability to claim or take advantage of compensation, livelihood assistance, and related benefits;

• establish a grievance mechanism to receive and address in a timely fashion specific concerns about compensation and relocation that are raised by displaced persons; and

• monitor and evaluate the implementation and results of implementation measures.




4. ASSESSMENT METHODOLOGY AND SIGNIFICANCE CRITERIA

4.1. Scope of the Assessment This document considers the potential socio economic impacts as a result of the proposed project, associated with the following issues:

• Land use • Employment and procurement opportunities • Livelihoods • Community health, safety and security • Revenue generation for the local government / community • Infrastructure

Impacts and mitigation measures associated with community health, safety and security, as well as occupational health and safety are addressed in the local EIA and EIA addendum, while this document focuses on social impacts associated with the influx of labour and the increase in traffic. Impacts on infrastructure are also addressed in the local EIA, while this document focuses on impacts associated with use of roads and access tracks, as well as irrigation channels and how they relate to possible impacts on livelihoods.

4.2. Extent of the Study Area The project site is located in the Aydin province, occupying territories that belong to the Germencik and Incirliova districts and is surrounded by nearby local communities – Germencik town, Ömerbeyli, Reisköy, Turanlar (Germencik district), Sinirteke and Erbeyli (Incirliova district).

The study area covers the project site and the surrounding villages, all within approx. 3.5 km of the project site.

4.3. Method of Baseline Data Collation

4.3.1. Site Visit A site visit was undertaken to the project affected area from May 26 to May 30 2014. Apart from interviews with relevant Company representatives, meetings were held with the village headman of Ömerbeyliand the Mayor of Germencik. Meetings were also held with four landowners, one of whom sold his land through an amicable process and three (out of eleven) whose land is currently under expropriation. The purpose of these meetings was to discuss possible social impacts of the project and determine how land acquisition was and will be undertaken for the project. The issues discussed at these meetings are described in section 8 ‘Stakeholder Engagement’.

4.3.2. Desk Study Secondary data for this document was collected via a desk study, including statistical information available from the Turkish Statistical Institute (TurkStat) and other international and national databases. Additional data was obtained from documents and sources provided by the Company. Data from the project EIA was also used, particularly the Social Impact Report (Appendix 10 of the local EIA).

For the development of the local EIA Social Impact Report, a household survey was undertaken in March 2012 with a sample of 75 households residing in villages in the vicinity of the project area to determine their socioeconomic profile, the current situation in their living environments, their opinions about the project and expectations from the project.




4.4. Significance Criteria The assessment of potential impacts as a result of the project has taken into account both the construction and operational phases. The significance level attributed to each impact has been assessed based on the magnitude of change due to the proposed project and the sensitivity of the affected receptor to change. Magnitude of change and the sensitivity of the affected receptor are both assessed on a scale of high, medium, low and negligible (as shown in Table 4.1 below).

Table 4-1 Matrix for determining the significance of impacts

The following terms are used to assess the significance of impacts, where they are predicted to occur:

• Major positive or negative impact - where the proposed development would cause a significant improvement or deterioration to the existing environment;

• Moderate positive or negative impact - where the proposed development would cause a noticeable improvement or deterioration to the existing environment;

• Minor positive or negative impact - where the proposed development would cause a barely perceptible improvement or deterioration to the existing environment; and

• Negligible - where the proposed development would result in no discernible improvement or deterioration to the existing environment.

Sensitivity of Receptor to Change

High Medium Low Negligible

Magnitude of Change

High Major Moderate to Major Minor to Moderate Negligible

Medium Moderate to Major Moderate Minor Negligible

Low Minor to Moderate Minor Negligible to Minor Negligible

Negligible Negligible Negligible Negligible Negligible




5. SOCIO ECONOMIC BASELINE CONDITIONS This section provides an overview of the socio economic baseline conditions in the project area. Information is provided on the level of Aydin province, the two affected districts and where available, at the level of villages surrounding the project site. More information on baseline conditions can be found in the local EIA.

5.1. Administrative Institutions in Turkey The project site is located in Aydin province, within the boundaries of the Germencik and Incirliova districts. The project site is closest to Germencik town and surrounded by several other villages – Turanlar, Reisköy, Ömerbeyli, Erbeyli and Sinirteke.

The provincial organization of the central government has been created to administer public services to its citizens throughout the entire country and there are three kinds of provincial administrations: province, county, and district. The province is the largest provincial administrative unit of the central administration and it is headed by a governor appointed by the central government. There are 81 provinces in Turkey and one of them is Aydin province. Provinces are divided into districts, headed also by governors appointed by the central government and in Aydin province there are 17 such districts, two of which are Germencik and Incirliova.

Local government organisations are public legal entities that have been established outside the central government to meet the common needs of provincial, municipal, and village residents. They have separate legal personalities from that of the state, a certain degree of autonomy and their members are locally elected. There are three kinds of local government organizations: provincial administration, municipality and village administration.

Municipal governments exist in each provincial and district capital, as well as in all communities with at least 5,000 inhabitants. Each municipality is headed by a mayor, who is a chief executive and representative of the municipality. The mayor is elected by the citizens for a five-year term. Municipal administration also includes an assembly and a council. Germencik and Incirliova are both municipalities.

The smallest and most common type of local government in Turkey is the village administration. The principal authority in a village, the headman (muhtar) is chosen by an assembly of all the village's adults. The assembly also makes decisions pertaining to village affairs and elects a council of elders. The headman supervises the planning and operation of communal projects and services and administers directives from higher authorities (central administration). The headman receives government officials, maintains order, collects taxes, and presides at civil ceremonies. The village council supervises village finances, purchases or expropriates land for schools and other communal buildings, and decides on the contributions in labour and money to be made by villagers for road maintenance and other community improvements. The village council also arbitrates disputes between villagers and imposes fines on those who fail to perform the services allotted to them.

5.2. General Socio – Economic Environment Aydin province is located in the Aegean region, in southwestern Turkey and its capital is the city Aydin with a population of close to 200,000. Aydin is one of the better developed provinces in Turkey, with a high development index according to the Directorate General of Regional Development of the Turkish Ministry of Development (May 1st 2013). Aydın is Turkey's leading producer of figs and within the province, the best figs are reputed to be grown in Germencik. Aydın also produces olives, chestnuts, cotton, citrus fruits, water melons and other fruits.

The project is being implemented on the territory of two Aydin districts – Germencik and Incirliova. Both Germencik and Incirliova have a population between 40,000 and 50,000. Some basic demographic data is provided in Table 5.1 below.




Municipality Population Age % Average age

Average number of family members

Male Female Total 0-17 18-34

35-64 >65 Male Female

Incirliova 22,221 22,346 44,567 28.84 25.28 36.11 9.77 32.84 34.50 3.34

Germencik 21,292 21,679 42,971 27.80 24.38 35.28 12.56 34.21 36.30 3.37

Table 5-1 Demographic data on Incirliova and Germencik municipalities

Source: National Accounts and the Ministry of Economy and Finance, processed by Urbistat on ISTAT data (2012)

The total population of villages surrounding the project site is 16,640 people, with the largest population in Germencik town – 12,000. Table 5.2 below provides information about the population in each village.

Male Female Total

Germencik district

Germencik city approx. 12,0002

Ömerbeyli 373 404 777

Reisköy 236 226 462

Turanlar 531 575 1,106

Incirliova district

Sinirteke 553 596 1,149

Erbeyli 573 573 1,146

TOTAL 2,266 2,374 approx. 16,640

Table 5-2 Population in communities surrounding the project site

Source: Project EIA, table IV.3.2.2. (Data from 2011)

According to the household survey carried out as part of the local EIA, the average size of a household in surveyed villages was 3.43, while the majority of those interviewed completed primary level education (47%). The average number of persons who work in the household is 0.92. The average monthly income is USD 1,165.

Farming is a main source of income for households living in villages around the project site. As approximately one fifth of the interviewed population belongs to the over 60 age group, it was reported that another important source of income are pensions. People mostly sell their products to agricultural cooperatives, while keeping some for household consumption. The average household owns between 1.5 and 2 ha of land. Households mainly work on the land by themselves and use machines. Help is only sometimes hired for harvesting crops / fruits.

2Sum of population in the corresponding city quarters




The survey also reveals that, apart from farming the land, many people depend on breeding of animals for livelihoods. The majority breed animals both for sale and for household consumption (approx. 58%). Approx. 33% only sell animals and animal products and the remaining 9% use them only for household consumption.

According to the survey and discussions with village headmen, one of the most significant issues in the area is a high unemployment rate. Unemployment rates for Germencik and Incirliova are provided in table 5.3 below. There are high expectations for employment opportunities on the Project, particularly for young people.

Municipality Unemployment rate

Incirliova 11%

Germencik 12%

Table 5-3 Unemployment rate in Incirliova and Germencik municipalities

Source: National Accounts and the Ministry of Economy and Finance, processed by Urbistat on ISTAT data (2012)

5.3. Land Use and Land Tenure The total area of Aydin province is 831,900 ha (8,319 km2) and almost half is cultivated land, as seen in Table 5.4 below. The total area of Germencik district is 407 km2 and the total area of Incirliova district is 214 km2.

Land use in Aydin province Area (ha) %

Cultivated land 395,494 48% (approx. half is irrigated land)

Grassland/pasture 24,705 3%

Forests 319,177 38%

lakes and marshes 14,271 2%

Non-agricultural land 78,253 9%

831,900 100%

Table 5-4 Land use in Aydin province

Source: Project EIA, Table IV.2.8.1 (Aydin Governorship, Aydin Province Environment Report, 2010)

The Project site is located within a concession area of 2,800 ha (28 km2) and agriculture is the dominant land use. Approx. three quarters of the concession area is on the territory of Germencik and the remaining quarter is on the territory of Incirliova district. Whilst the majority of the land within the concession area is agricultural, there are areas within that area that cannot be developed (and expropriated), i.e. residential and forest areas. In addition the Company avoids acquiring land with olive and fig trees, as the cost of acquisition is significantly higher than for other land and is subject to special environmental permitting. To reduce the amount of land acquisition, the Company also uses existing roads and access tracks as much as possible, as well as public land and land that has already been acquired for other project components.

According to the household survey carried out as part of the local EIA, people in villages surrounding the project area cultivate mainly olives (27%) and figs (25%), followed by corn, cotton, clover, wheat, beans,




peppers, strawberries, aubergines, tomatoes, apples, plums, apricots and barley. A lot of the land is irrigated in the area and as per the local EIA, measures have been undertaken to ensure that irrigation and drainage channels are not damaged and/or water quality compromised during construction, in cooperation with the General and Regional Directorates of State Hydraulic Works (SHW).

All lands in the area are registered in the cadastre. Farmers hold title deeds for their lands and informal agreements for land use are not common in the area. Buying, selling and renting of agricultural land is generally made through the Land Register Office. Formal rent agreements are also a condition of obtaining agricultural subsidies. Males and females are usually treated equally regarding property and land ownership.




6. LAND ACQUISITION FOR THE PROJECT The construction and operation of Gürmat 2 GPP requires acquisition of land3 for: • Facilities, i.e. EFEs 1, 2, 3 and 4, including access roads (18 plots of land) • Wells, including access roads (43 plots of land) • Pipe network

- EFE 2 pipework (2 plots of land, one of which is already acquired for two wells)

- EFE 1, 3 and 4 (unknown number of plots of land)

• 154 kV overhead Electricity transmission lines (ETLs) – one line from EFE 2 to EFE 1 (3.2 km) and the second line from EFE 1 to the Germencik-Tire national grid (2.5 km)

- OHL pylons and foundations (17 plots)

- Land below the transmission lines on which easements are established (884 plots)

Some additional land will be needed during construction of the Project, for the establishment of the pipework for EFEs 1, 3 and 4, as well as for additional wells. Gürmat 2 will prepare a land acquisition plan as per IFI requirements for this newly needed land.

6.1. Land Acquisition for EFE1, 2, 3, 4 and the Wells A total of 61 plots of land (c. 69.4 ha) are needed for the power houses and wells (for EFE 1, 2, 3 and 4). Gürmat started the acquisition process in February 2013 and by the end of May 2014, fifty plots (57 ha) had been acquired through amicable agreements. For the remaining 11 plots (c.12.35 ha) Gürmat were not able to reach negotiated settlements and judicial proceedings in order to obtain the immediate expropriation decision from the local court were initiated on 11.09.2013. These plots are owned by 13 individuals and territorially within the village Ömerbeyli. They are all needed for the construction of EFE 1 plant. One plot of approx. 2.25 ha is owned by 4 landowners and one plot of approx. 0.48 ha is owned by 2 landowners. The price offered by Gürmat varied from 13 to 14 TL per m2.

Fifty plots of land were acquired through amicable purchase and the total area of these plots is 57.06 ha. The land plots territorially belong to the following villages: • Ömerbeyli (30) • Camikebir (3) • Hürriyet (2) • Mesudiye (4) • Sinirteke (5) • Turanlar (6)

Sinirteke is the only village that belongs to the Incirliova district, while all others are a part of the Germencik district.

The 11 plots of land (approx.12.35 ha) which are subject to expropriation are owned by 13 landowners and territorially all belong to the village Ömerbeyli. They are all needed for the construction of EFE 1 plant. One plot of approx. 2.25 ha is owned by 4 landowners and one plot of approx. 0.48 ha is owned by 2 landowners. At the same time, two landowners each have two plots which are subject to expropriation. The price offered by Gürmat 2 varied on average from 13 to 14 TL per m2. Detailed assessments were

3 The term land acquisition refers to both outright purchases of property and purchases of property rights (i.e. rights of way), as defined in the EBRD 2008 Environmental and Social Policy, PR5. 4 17 plots for pylons are included in the total number of 88 plots, as these plots are not only used for the construction of the pylon but are also partly affected by easements




carried out by court valuators and for 12 of the owners, a slightly higher price was established than the one originally offered by Gürmat. Only three landowners were offered a higher price by Gürmat 2 in comparison to the subsequently carried out official court valuation.

As of the date of writing this document, owners of 8 out of 11 plots have confirmed their participation in hearings before the court and are currently waiting for EMRA to set a date. Three have not replied. The consultants developing the SIA met with one of these owners, who stated that him and his family have not replied because they have decided to accept the amount that has been deposited in their accounts.

When expropriation was initiated, the owners were allowed to collect the following harvest, however they did not plant anything further as Gürmat 2 had deposited the funds in their account and thereby gained the right to access the land, as defined by the procedure of immediate expropriation under the Turkish Expropriation Act. Gürmat 2 deposited funds in the owners’ accounts in November 2013.

It has been confirmed by Gürmat 2 that of the 69.4 ha of land which have been acquired for the power houses and wells, 24.56 ha will remain permanently occupied after construction. Previous owners/users will be allowed to continue using the remaining 44.84 ha, as before acquisition, for agricultural activities. Contractual arrangements will be put in place between Gürmat 2 and previous land owners/users to reflect this arrangement.

6.2. Land Acquisition for the Pipe Network Parts of land plots needed for the construction of the pipe network are acquired permanently. The Company acquires six metres of land in width within which the pipeline is installed. The actual pipe takes up only 1 to 2 metres, while the rest of the land can continue to be used by the landowner. With the fact that Gürmat compensates for six metres, they reserve the right to access this land for repairs and maintenance (i.e. the protection zone), without compensating the landowners for any affected crops or trees. Gürmat tries to negotiate with landowners to acquire the land for the protection zone and if this fails, immediate expropriation is initiated. To ensure that the least amount of land is affected, Gürmat tries to follow roads and plot borders when constructing the pipework. Gürmat also takes into account the fact that people must have access to their land, which is why they raise the pipeline at plot entrances above ground so that plots can be accessed by people, animals and machines or other vehicles.

For the EFE 2 pipework, the Company used land it already acquired for wells and needed only a part of one additional plot (approx. 250 m2). A total of 0.65 ha of land were acquired for the EFE2 pipework. The rest of the pipework was constructed along the channels and roads, which belong to the General Directorate of Hydraulic Works (GDHW). A protocol regarding the use of this land was signed between Gürmat and the GDHW.

At the time of developing this impact assessment information on land plots needed for the pipework for EFE 1, 3 and 4 was not known. However, the Company have confirmed that in determining the future layout of pipes, they will attempt to use land which they have already acquired to the extent possible and they will follow borders of plots and roads to the extent possible to avoid impacts on land and landowners/land users.

6.3. Land Acquisition for the Electricity Transmission Lines Land plots needed for the construction of the ETLs are being acquired in a specific procedure. For the construction of pylons (and their foundations), parts of land plots are permanently acquired (17 plots, 0.44ha).

In a preliminary procedure, Gürmat is contacting the landowners and offering them a fee for the right to construct the pylons on parts of their land, which will become inaccessible to them when construction is finalised. When such an agreement (i.e. act of settlement) with the landowner is reached and money paid, Gürmat begins construction. This is being done by Gürmat 2 to speed up the construction process, as expropriation lasts a longer period of time, regardless of the fact that Gürmat will have to pay twice to the landowners, as explained further in the text. At the time of developing this document, Gürmat had already signed acts of settlements with all owners of land on which pylons have been or are being constructed.

After land has already been acquired by Gürmat through acts of settlement, an expropriation procedure is initiated by the relevant agency. For the main line between EFE 1 and the National Grid, expropriation will be carried out by TEIAS (Turkish Energy Transmission Company). For the internal line between EFE 2 and EFE 1, expropriation will be carried out by EMRA (Energy Market Regulatory Authority). Expropriation




will be carried out in accordance with Turkish law and the final determined price will be paid again to the owners, from funds provided by Gürmat 2. TEIAS will become the owner of the ETL and will grant Gürmat 2 the permit to formally use the ETL.

After construction of the pylons and their connection with transmission lines, an easement has to be established on land below the transmission lines, as per Turkish legislation. A total of 88 plots (18.4 ha) will be affected by this process. An expropriation procedure will be initiated for obtaining these easements on the affected land plots. The expropriation procedure for obtaining easements is the same as for obtaining permanent ownership rights over land needed for the construction of pylons. The right to an easement is compensated to landowners in one instalment and they can continue to use their land below the transmission lines as before.

Gürmat is trying to limit the amount of new land acquisition and therefore impacts on individuals and households, by using land the Company already owns as well as state owned land. Out of 88 plots of land, 17 are already owned by Guris and 24 are publicly owned.




7. PROJECT RELATED TRANSPORT Transportation to the Project area will be carried out via existing roads, mainly the Izmir – Aydin D-550 Highway. Some local (village) roads in the Project area will be used as presented in Figures 7.1 and 7.2 below. Measures for reducing impacts of project transportation, including safety measures, are listed in the local EIA.

Figure 7-1 Satellite image showing the location ofEFE 1, 3 and 4 to the D-550 highway and local

access road




Figure 7-2 Satellite image showing the location ofEFE 2 close to the D-550 highway and local

Turanlar village road

According to the 2013 Traffic and Transportation Survey of Highways Report produced by the Turkish General Directorate for State Highways, a total of 12,223 vehicles pass the section of the D-550 State Highway which is closest to the project area. A breakdown of vehicles, as well as additional vehicles which are expected to be used for the project during the construction and operation phase is provided in Table 7.1 below.

Information on anticipated numbers and types of vehicles needed for the project has been taken from the local EIA. However, it should be noted that these estimates were done in accordance with the previous design, where units (EFEs) were to be constructed in several locations, within the concession area, rather than in the two locations where they are now being constructed.

Vehicle count

(2013)

Project vehicles

(construction)

Increase in vehicles

during project construction

Project vehicles

(operation)

Increase in vehicles during

project operation

Car 9,259 20 0.22% 30 0.32%

Medium Goods Vehicle 1,219 10 0.82% 2 0.16%

Bus 71 - - - -

Truck 1,143 5 0.44% 2 0.17%

Articulated Truck 531 - - - -

Total 12,223 35 0.29% 34 0.28%

Table 7-1 Vehicle count on the D-550 closest to the project site and foreseen transport for the project

Source: 2013 Traffic and Transportation Survey of Highways Report, produced by the Turkish General Directorate for State Highways and Project EIA, table V.1.3.2.




8. STAKEHOLDER ENGAGEMENT Guris has been present in the project area since the construction of Gürmat 1, which came into operation in 2009. The Company has been communicating with local authorities and residents of directly affected communities, including with directly affected landowners in connection to land acquisition for the project. Consistent with local cultural patterns, the village headmen often liaise between the Company (i.e. the representative of Guris in charge of community contacts) and village residents, including landowners.

In accordance with Turkish law, in the scope of developing the Project EIA a public meeting was held on 19.03.2012 in Aydın Province, Germencik District, Umit Wedding Hall (Germencik town). The meeting announcement was placed in two newspapers, one local (published in the province centre and in the districts) and one national. Apart from Gürmat 2 and the Company who developed the EIA, participants included representatives of the Ministry of Environment and Urban Planning, Aydın Provincial Directorate of Environment and Urban Planning, the Regional Directorate of SHW, the District Directorate of SHW, village headmen (muhtars) and the local community. The meeting served as an opportunity to present the project and answer stakeholders’ questions. According to the meeting minutes provided in the local EIA social assessment report (Appendix 10), issues which were brought up at the meeting included the following:

• Provision of information to landowners in advance of any drilling activities near their land; • Mitigation measures for any adverse impacts on fig and olive trees; • Opportunities for designing a heating system for settlements in the project area; • Compensation of losses associated with decreasing olive and fig production; • Opportunities for further economic development for the region.

A household survey was carried out for the development of the local EIA. According to the survey, information about the project was obtained by households from a number of sources. The majority of people obtained information on the project from their village headmen (approx. 47%) or from friends and neighbours (approx. 31%). Approx. 19% received information directly from Gürmat and approx. 3% from the media (newspapers). The conclusion of the social impact report was that more information should be provided directly by Gürmat, as the most reliable source.

During the development of this SIA, meetings were held with the village headman of Ömerbeyli and the Mayor of Germencik. Meetings were also held with four landowners, one of whom sold his land through an amicable process and three (out of eleven) whose land is currently under expropriation. The purpose of these meetings was to discuss possible social impacts of the project and determine how land acquisition was and will be undertaken for the project.

During these meetings, stakeholders highlighted the following issues:

• more interaction and cooperation between Guris and local communities is needed; • affected landowners must be informed in more detail about expropriation and compensation to prevent

rumours; • views exist that dust and steam from the existing Gürmat 1 plant could be damaging crops and if that

is the case, the company should compensate losses; • there is concern about pipelines being above ground, for safety reasons and effects on agriculture; • all affected communities must be properly informed which plants are being managed by Guris, i.e.

Gürmat 1 and 2, what are the impacts (or possible impacts) associated with the operation of these plants and how they are/will be monitored and mitigated;

• expectations exist for more job opportunities, particularly for young people and women;




• community investments are needed from Guris and communities should be consulted on what priority

investments they need5.

Guris has no formal grievance mechanism for receiving and responding to community concerns and grievances. Therefore a grievance mechanism, as required by the IFIs, has been established and presented as part of the Stakeholder Engagement Plan (SEP). Further details on information disclosure and planned consultations are also provided in the SEP.

5 Gürmat expressed an interest in building a local school in Germencik, while the mayor stated that the construction of a hospital is a greater priority for local residents at the moment. The interviewed muhtar also stated that reconstruction and upgrading of village roads is a high priority for the local residents.




9. ASSESSMENT OF IMPACTS, MITIGATION AND RESIDUAL EFFECTS

9.1. Construction

9.1.1. Land Use In total about70 ha of agricultural land has been acquired for the G2 GPP. Of this, 25ha will remain permanently occupied leaving about 45 ha that will remain available for agriculture after construction (see Section 9.3.1). This 70 ha translates to 2.5% of the concession area, 0.11% of the total area of Germencik and Incirliova districts and 0.008% of the area of Aydin province. Therefore the total land which will be affected during construction is only a small portion of agricultural land in the area. This impact is assessed as minor negative. About 18 ha of land will be affected by easements, underneath the overhead transmission lines, however land users will have continued access to this land. More land will be acquired for laying down the pipework for EFEs 1, 3 and 4, as well as some additional wells, however the details of needed land are not available at present.

Local roads and access tracks are being and will continue to be used for the transport of materials, equipment, workers, etc. which increases the amount of traffic in the construction area. As a result of increased traffic, particularly the presence of heavy vehicles some of the local land users may have temporary difficulties accessing plots of land. This impact is assessed as minor negative, as it may occur only occasionally, under certain circumstances.

Certain construction activities could have an impact on nearby land, i.e. increased dust emissions, disturbance of neighbouring land by machines, etc. which could further damage trees, crops and or other assets. However, with proper mitigation measures this impact is likely to occur in a limited number of cases and is therefore assessed as minor negative.

9.1.2. Employment and Procurement Opportunities Guris currently directly employs 69 workers, 23 of whom are registered in Aydin (33%) and only three of whom are women (4%). Together with contractors the number of people working on the project rises to 5346. Construction is expected to last until the second quarter of 2015.

The workforce needed during the construction phase of the Project has been and will continue to be sourced from local communities as much as possible, particularly for unskilled work. This also helps to reduce costs associated with travel and accommodation. At present, unskilled labour opportunities are not announced and these positions are filled in based on recommendations of the local village headmen or the mayor. Interested candidates are also applying directly to Gürmat by submitting their CVs which are kept on file by the HR Department and used in case an adequate job opportunity arises. At present, Gürmat has approx. 150 applications on file.

In discussion with the village headman of Ömerbeyli, it was stressed that people are expecting more job opportunities in Gürmat 2, both for the construction and operation phases of the project. He stated that there are very few job opportunities for women, whereas they could be employed in the preparation of food and provision of other services such as cleaning and maintenance.

Employment of local people will have a significant effect on those who are employed however this will be a small portion of the total population and will not significantly reduce unemployment in the area. The employment of individuals from local communities will however be beneficial as it is expected to lead to improved relationships between the Project and local communities and improved local skill set which may be valuable for future projects. This impact has been assessed as minor positive.

It will be important to encourage employment of women and to inform local communities of the realistic number of job opportunities that will be available during construction, to manage expectations and prevent any tensions between the local communities and the Project.

6 Source: EFELER (162.5 MWe) JES PROJECT Daily working report, July 8th 2014.




The creation of indirect employment opportunities is associated with:

• the project’s supply chain (goods and services) • spending of project employees in local communities

Materials and equipment for the Project will be procured locally whenever possible. Companies supplying construction materials, selling and leasing machinery and equipment, performing repair and maintenance of machinery and equipment, the local food industry etc. will be positively impacted by the project.

Employment of non-locals, as well as the increase of incomes of local employees, may also bring in some minor benefits for local communities, associated with increased spending in the project area, i.e. in small shops, bars and restaurants. Indirect employment is likely to provide more opportunities for women, as opposed to direct employment which is expected to involve more men.

Impacts of indirect employment will depend on the availability of required goods and services in the Project area and ways in which employees choose to spend their earnings. Although construction is expected to last a total of 68 months, taking into account the technical nature of procurement requirements and the number of employment opportunities, impacts related to indirect employment are assessed as minor positive.

All contractors and suppliers have to abide by the Turkish Law on Labour and other relevant legislation, which is mostly in agreement with IFI labour related requirements. This includes specific requirements in relation to provision of accommodation of workers, i.e. that such accommodation must be in accordance with national legislation and international good practice. Any additional measures that must be undertaken will be described in the mitigation section.

9.1.3. Livelihoods Gürmat has the right to expropriate land for the Project within the concession area and therefore all land acquisition within this area is considered involuntary resettlement, as defined by the relevant IFI policies (PR 5 and PS 5). Nevertheless, most of the land has been acquired through negotiated settlements, as Gürmat had flexibility of selecting alternative, nearby plots of land, i.e. for wells. At present 11 plots of land are in the process of being expropriated.

Involuntary resettlement may negatively affect people’s livelihoods, particularly if they are not able to replace the land plots they lost with the compensation they receive. Available data suggests that compensation was paid at market value, i.e. the quality of land was valuated, as well as all assets on the land, such as crops and assets were compensated at market prices. Transaction costs associated with transferring ownership to Gürmat 2 were also borne by the Company. However, there was no provision for transaction costs or registration fees in the compensation for people who planned to buy new, replacement land. This suggests that replacement cost, as required under the respective IFI policies was not achieved. In addition, for those who did not manage to buy replacement land with the compensation they received at the end of 2014, at least one season of crops has been lost.

A Livelihood Restoration Plan was not produced for the Project, as required by IFIs and therefore a census and survey were not carried out. As a result of that, there is no detailed information about affected people. For example, it is unknown if all affected people were identified, including any formal or informal users of land, which should have been compensated for the crops they lost. There is also no data on whether among the affected people there were some that as a result of vulnerability or other factors (i.e. not owning any other land and being severely impacted), were not or will not be able to restore their livelihoods with the compensation they received.

During the field visit for the development of the SIA, only four landowners were available for meetings with the consultants, one who sold land to Gürmat through a negotiated settlement and three whose land is currently in the process of being expropriated. Interviewed landowners had different views as to the adequacy of compensation which was offered and paid by Gürmat. The landowner who sold land to Gürmat through a negotiated settlement declared that he was able to buy even more land than he lost with the compensation he received. On the other hand, those who have refused offers from Gürmat stated that the compensation amounts were not adequate to enable them to buy replacement land. According to other stakeholders interviewed in the SIA development process, there was an expectation among some affected landowners that they will be receiving much higher compensation amounts, as the resources found below their land are so valuable and the Company will make a significant profit from exploiting it. Some landowners were not happy with the compensation they were offered only because their neighbours were




getting higher compensation, regardless of the fact that there were other factors influencing the price of land, such as proximity to a road.

As mentioned earlier, only 11 landplots are in the process of expropriation at the moment of developing this SIA, while the majority of land has been acquired through negotiated settlements. The issue of how land acquisition for a Project is handled and whether or not affected people are able to restore their livelihoods with the compensation they receive is important for IFI involvement in Projects, as it could pose a reputational risk for the banks. In light of all this, this impact is considered moderate negative and must be mitigated in accordance with IFI requirements. Due diligence of previous land acquisition must be carried out, including all affected landowners whose land is being expropriated, to determine if there are corrective measures that need to be undertaken to bridge any gaps in relation to fulfilling IFI requirements. A livelihood restoration plan also needs to be prepared for all additional land acquisition for the project.

During construction damages to nearby plots, including assets on these plots, are possible. Gürmat will compensate all lost crops and damages at full replacement value to land users7. The implementation of measures for ensuring that construction workers are aware of boundaries of construction sites as well as the implementation of a project grievance mechanism should assist in managing impacts on livelihoods. This impact is assessed as being minor negative, as it is expected to occur only occasionally, under certain circumstances.

Reduction in land available for agriculture is not expected to have an impact on livelihoods of the majority of those farming the land, due to the limited number of plots being acquired and the availability of agricultural land in the area. However, it is presently unknown if any individuals are severely impacted due to the fact that the acquired land may be the only land they own or have access to for livelihood generation. This impact must be investigated in more detail as part of the due diligence process mentioned earlier in this section.

Increased incomes generated through direct and indirect employment may have a positive effect on livelihoods in the local area. A number of local households whose members will be employed by the project, will have increased incomes and consequently improved standard of living. Although this may be significant for the households in question, it is not significant to the population as a whole. Some increased spending of these households together with non-local employees in the local area could further positively benefit the local economies, although this is not expected to have a significant effect. This impact is assessed as minor positive.

Transport and increased traffic are not expected to have impacts on livelihoods. Difficulties in accessing land described in the section on land use may only be occasional and may impact only individuals. Most of the transport will be carried out via the D-550 highway. Traffic volumes on this road are presented in section 7 ‘Project Related Transport’. The average daily number of vehicles is 12, 223. The estimated daily number of vehicles on this road during construction is 35, meaning an increase in traffic of only 0.3% per day. The impact on local roads will however be more significant, particularly the road connecting the village Turlanar and the D-550 highway. It will be important to inform people how they can submit any grievances they have and how these will be managed and responded to by the Company. This information is included in the Project Stakeholder Engagement Plan.

9.1.4. Community Health, Safety and Security The availability of temporary construction employment opportunities is sometimes associated with an increase in vulnerability and susceptibility of local communities to increased crime, alcoholism, etc. There is a clear preference on the Project for employing local people and therefore not many people have been hired from the outside. The presence of these workers may cause some disturbances in the Project area, however these are expected to be minor and as a result, the impact on local communities in relation to social pathologies is assessed as minor, noting that the occurrence of any serious incidents could lead to tensions between the community and Gürmat.

Transport and increased traffic can lead to more possibilities for accidents for the local population. These impacts have been assessed as minor negative, however accidents involving local community members will have serious effects on the individual or his/her household.

7 Stakeholders interviewed in the SIA development process stated that during construction works for Gürmat 1, if there were any damages to trees or crops, the Company compensated them appropriately.




9.1.5. Infrastructure Construction will require the use of some local roads and access tracks through agricultural fields. Section 7 ‘Project Related Transport’ explains the road requirements for the transport of construction materials and equipment.

The upgrading of some local roads and access tracks needed for the project during construction will benefit local farmers as it will lead to improved access to their agricultural plots. The impact has been assessed as minor positive. On the other hand, damages to road surfaces during transport of heavy machinery, leading to damages to motor vehicles, road accidents and the increase in costs for governments, are also possible. Gürmat will make all necessary repairs in accordance with the Protocol signed with the General and Regional Directorate of Highways.

The Project will not place any additional demands on community infrastructure during construction, as utility infrastructure will be secured locally on the project site, i.e. water, electricity, sewage, medical assistance.

Land in the project area is heavily farmed and according to information in the local EIA, some people have expressed their concerns about irrigation channels and the water quality being compromised during construction. The local EIA states that the project will not have an impact on irrigation channels and the water quality. The Company is adhering to the Circular of the Ministry on River Beds and Floods and cooperating with the General Directorate of SHW and the Regional Directorate to ensure that impacts on irrigation channels are avoided.

9.2. Mitigation

9.2.1. Land Use During construction the project will cause a reduction in land available for agriculture. Certain measures will be implemented to mitigate it, as well as prevent any impacts to livelihoods. These measures include:

• Minimise the amount of land occupied/disrupted during construction, by clearly marking construction areas, where movement of workers and machines is allowed, i.e. on land which has been acquired and compensated by Gürmat

• In case of any damages or disruptions of land, crops, trees during construction activities, fully reinstate all land and compensate any affected assets

• Difficulties in accessing land as a result of increased traffic and access track upgrades will be managed by the implementation of following measures:

- Provide timely information to users of land of when access to their land might be more difficult (e.g. scheduled road/access track upgrades)

- Establish and implement a community grievance mechanism

9.2.2. Employment and Procurement Opportunities The project will create some direct employment opportunities, however this impact may not be significant for local communities. To manage unrealistic expectations, the Company will provide clear information to local communities on the number and types of employment opportunities that will be available on the Project.

The engagement of all employees and non-employee workers will follow international best practice, with the main measures comprising the following:

• Implement transparent and fair recruitment procedures • Actively encourage direct and indirect employment of women • Ensure that all employees and non-employee workers are engaged in line with both national

legislation and applicable international (ILO) standards and recommendations • Ensure that accommodation for all employees and non-employee workers complies with national

legislation as well as international good practice • Provide a grievance mechanism for workers




To foster the creation of indirect employment opportunities, the Project will procure goods and services locally whenever possible.

9.2.3. Livelihoods Carry out due diligence of previous land acquisition, particularly for plots which are subject to expropriation, to determine the following:

• If affected people were able to purchase adequate replacement land (those that decided to continue agricultural activities) with the compensation they received

• Compensate for any additional costs they had or discrepancies in livelihoods, including any harvests they missed

• Consider and respond to all grievances and compensate all reasonable and documented requests.

When details regarding land plots needed for the remaining pipework and new wells become known, a Livelihood Restoration Plan will be developed in accordance with IFI policies, prior to further land acquisition.

Any loss of livelihoods as a result of loss of land available for agriculture will be mitigated by undertaking the following measures:

• Minimise the amount of land occupied/disrupted during construction, by clearly marking construction areas, where movement of workers and machines is allowed, i.e. on land which has been acquired and compensated by Gürmat

• Provide timely information to users of land how lost crops and damages will be compensated • Compensate all users of land for lost crops and any other damages at full replacement value, in

accordance with IFI policies • Fully reinstate any land temporarily disrupted • Establish and implement a grievance mechanism

To mitigate any livelihood losses as a result of transport and increased traffic, a grievance mechanism will be established and all reasonable and documented requests for compensation will be accepted.

9.2.4. Community Health, Safety and Security The influx of workers into the Project area causing disturbances for the local population, will be minimised by the implementation of the following measures:

• Encourage contractors to hire local workforce, i.e. give preference to suitably qualified and experienced applicants from the local communities.

• Enforce workers code of conduct • Cooperate and coordinate with local health and safety facilities

Increase in traffic (bringing equipment and materials to the site and employee travel) could lead to more accidents in the local communities. These impacts will be managed with the implementation of the following measures:

• Enforce workers code of conduct (guidance on safe driving) • Cooperate and coordinate with local health, safety and security facilities

9.2.5. Infrastructure Transport of heavy machinery could lead to damages of road surfaces, further causing accidents, vehicle damages, etc. The following measures will be undertaken to mitigate these impacts:

• Restoration of roads to at least pre-construction level

To ensure that impacts on irrigation channels/water quality are avoided, Gürmat will comply with measures listed in the Circular of the Ministry on River Beds and Floods and cooperate with the General Directorate of SHW and the Regional Directorate. In case of any damage to irrigation channels or impacts on the water quality, Gürmat will take immediate measures/repairs to mitigate such impacts. In case they lead to




further impacts on land use (i.e. crops) and livelihoods, Gürmat will compensate all losses at full replacement cost.

9.2.6. Residual Effects In total 25 ha of land will remain permanently unavailable for agriculture after construction (24.56 ha for EFE 1, 2, 3, 4 and wells and 0.44 ha for OHL pylons).

Even with the implementation of mitigation measures to reduce impacts associated with transport and increased traffic, individuals may still occasionally experience difficulties in accessing land.

Any incidents or accidents involving local community members could lead to tensions between the community and Gürmat 2, which is why they will be prevented to the greatest extent possible.

If roads used during construction are not fully restored, this could also lead to tensions between Gürmat 2 and the local communities.

9.3. Operation

9.3.1. Impacts to Land Use As mentioned in the previous section of this chapter, 25 ha of land previously occupied for construction will remain permanently unavailable for agriculture during operations (24.56 ha for EFE 1, 2, 3, 4 and wells and 0.44 ha for OHL pylons). This translates to 0.89% of the concession area, 0.04% of the total area of Germencik and Incirliova districts and 0.003% of the area of Aydin province. Therefore the total land which will be permanently affected by the project and no longer available for agriculture is only a small portion of agricultural land in the area. This impact is assessed as minor negative. No further impacts on land use are foreseen during the project operation phase.

9.3.2. Employment and Procurement Opportunities The life of the project is expected to be at least 49 years and during that time about 80 employees will be needed. It is the Company’s intention to employ as many local people as possible permanently for the operation phase of the project. This will give long term stability to the full time employees and will have a significant effect on their lives. However, within the local communities and even more at the national level, this number is very low and the impact has been assessed as minor.

Indirect employment may occur as a result of increased spending of those employed by Gürmat 2, however since this number is relatively low, this is also assessed as a minor positive impact. The procurement of local goods and services is also likely to be minimal and have a minor effect on local economies.

9.3.3. Livelihoods During the operational phase, crops and trees within the protection zone may be damaged or lost if land plots are accessed by Gürmat 2 for maintenance and repairs of the pipe network. Gürmat 2 has already compensated owners of land for all lost crops and damages in this zone and therefore no further compensation will be provided. However, this has to be clearly explained to all owners of land where this zone has been established, so that they understand that any land use in these zones is done at their own risk. This impact has been assessed as minor negative.

Some stakeholders have stated that there are raised concerns among local farmers that steam is damaging their crops, particularly fig and olive trees, reducing production. Even if these are only perceived (and not realistic) impacts, t will be important for Gürmat to discuss these issues with local communities, as part of the required stakeholder engagement process and if possible, provide evidence that steam is not having an impact on agricultural production in the area.

9.3.4. Revenue Generation and Other Benefits for the Local Government / Community

In accordance with Article 10/1 e) of the Law Code No. 5686 on related to Geothermal Resources and Mineral Waters, after commissioning, 1% (approx. 259.500 USD) of the Gürmat 2 gross proceeds from




geothermal resources will be paid annually to the Governorship of Aydin. One fifth of that amount will be transferred by the Governorship of Aydin to the local municipality Germencik.

It will be important to cooperate with local communities throughout the life of the Project and consult them on priorities for any planned community investments8.

9.3.5. Infrastructure Gürmat will have to carry out regular maintenance of access roads/tracks needed to access facilities and wells for operation, repairs and maintenance. This in turn will have a minor positive impact on local farmers’ access to their plots of land.

9.4. Mitigation

9.4.1. Land use Gürmat 2 have confirmed that previous land owners / users will be allowed to continue using 45 ha (out of the acquired 70 ha) for agricultural activities. Contractual arrangements will be put in place between Gürmat 2 and previous land owners/users, to reflect this arrangement and define the terms and conditions for continued land use.

9.4.2. Employment and Procurement Opportunities As for construction related employment, the contracting of any individuals for the operation of the plant will follow principles of international best practice. To foster the creation of indirect employment opportunities, the Project will continue to procure goods and services locally whenever possible.

9.4.3. Livelihoods As explained earlier, landowners will be allowed to use any land they can in the pipeline protection zone (up to the pipeline), however any damages to crops or trees within that zone will not be compensated, as this land is being acquired and compensated by Gürmat so that it can be accessed for repairs and maintenance of the pipeline. This needs to be clearly explained to all affected landowners so that they understand that any land use in the protection zone is done at their own risk.

The issue of steam damaging agricultural activities in the area must be discussed with local farmers as part of the stakeholder engagement process, even if it is only a perceived impact. Gürmat should try to provide evidence that their operations are not causing this impact, if possible. The Company should also consider and respond to all received grievances and compensate all reasonable and documented requests.

9.4.4. Revenue Generation for the Local Government / Community Gürmat will ensure that all payments of applicable taxes are made in a timely and transparent manner.Gürmat is planning to continue supporting local initiatives and in doing so, it will be important to consult with local communities.

9.4.5. Infrastructure Regular maintenance of access roads/tracks will be carried out to contribute to improved access to agricultural plots.

8 Corporate and social responsibility activity by the Company for Gürmat 1 has included: • Loaning of construction vehicles and maintenance equipment to the villages when requested; • Provision of water pipes to the Alangullu Village; • Alangullu residents are cultivating Gürmat’s olive field and selling the products at the local market.




9.5. Monitoring and Follow Up Grievance management (both community and workers’ grievances) needs to be monitored to ensure that all received complaints are addressed as described in the Project SEP.

Complaints and grievances submitted through the Project grievance mechanism will also be regularly monitored, to alert Gürmat of any problems or issues that need to be dealt with, on an individual or community level. For example, frequent grievances regarding damaged crops may indicate that the contractors are not being careful to avoid disrupting land which has not been acquired and compensated during construction and that their plans and activities need to be re-evaluated. Execution of compensation payments for lost crops and damages must be monitored to prevent any loss of livelihoods.

Reinstatement of roads upon completion of construction activities also needs to be monitored. Proper reinstatement is key to ensuring that people can continue to use these roads, so that their livelihoods do not suffer. This needs to be monitored at the end of construction, to ensure that all roads have been reinstated to at least pre construction level and all throughout operations, i.e. road repairs and maintenance.




Table 9-1 Summary of Impacts

Key to table:

P/T = Permanent or Temporary, D/I = Direct or Indirect, ST/MT/LT = Short Term, Medium Term or Long Term

N/A = Not Applicable

Description of Likely Significant Effects

Significance of Impacts Summary of Mitigation / Enhancement Measures

Significance of Residual Effects

(Major, Moderate,

Minor, Negligible)

Positive / Negative

(P/T) (D/I) ST/MT/LT) (Major, Moderate,

Minor, Negligible)

Positive / Negative

(P/T) (D/I) ST/MT/LT)

Construction

Loss of 70 ha of agricultural land (25 ha permanently and 45 ha temporarily)

Minor Negative T&P D LT Minimise the amount of land occupied during construction

Fully reinstate land and compensate damaged crops, trees, etc.

Sign contracts with previous land owners/users to allow them to continue using 45 ha of land for agriculture.

Minor Negative P D LT

Difficulties in accessing land

Minor Negative T D ST Provide timely information to users of land

Grievance mechanism

Negligible Negative T D ST

Impacts on land near construction sites

Minor Negative T D ST Minimise the amount of land occupied during construction by marking construction








(Major, Moderate,

Minor, Negligible)

Positive / Negative


Minor, Negligible)

Positive / Negative


areas


Grievance mechanism

Creation of direct employment opportunities

Minor Positive T D ST Inform local residents of realistic number and type of job opportunities

Organise transparent and fair recruitment

Encourage employment of women

Follow national and international standards in employment (including for accommodation)

Workers’ grievance mechanism

Minor Positive T D ST

Creation of indirect employment opportunities

Minor Positive T I ST Procure goods and services locally

Negligible Positive T I ST

Involuntary resettlement

Moderate Negative P D LT Carry out due diligence and identify corrective actions, if

Minor Negative T D LT







(Major, Moderate,

Minor, Negligible)

Positive / Negative


Minor, Negligible)

Positive / Negative


any

Develop a Livelihood Restoration Plan for future land acquisition

Impacts on livelihoods resulting from crop damages / losses

Minor Negative T D ST Minimise the amount of land occupied during construction by marking construction areas


Grievance mechanism


Increased incomes generated through employment

Minor Positive T I ST Encourage local hiring Negligible Positive T I ST

Impacts on community health, safety and security as a result of the influx of workers

Minor Negative T I ST Encourage contractors to hire local workforce

Enforce workers code of conduct

Cooperate and coordinate with local health and safety facilities

Negligible Negative T I ST







(Major, Moderate,

Minor, Negligible)

Positive / Negative


Minor, Negligible)

Positive / Negative


Transport related accidents and nuisances

Minor Negative T I ST Workers code of conduct (guidance on safe driving)

Cooperate and coordinate with local health and safety/security facilities

Negligible Negative T I ST

Impacts on infrastructure (roads and irrigation channels)

Minor Negative T D ST Restore roads to at least pre-construction level


Operation

Creation of direct employment opportunities

Minor Positive P D LT Follow national and international standards in employment

Workers’ grievance mechanism

Minor Positive P D LT

Creation of indirect employment opportunities

Minor Positive P I ST Procure goods and services locally

Negligible Positive P I ST

Impacts on livelihoods resulting from crop damages /

Minor Negative T I ST Clearly inform affected people that any crop/tree damages in the protection zone will not be

Minor Negative T I ST







(Major, Moderate,

Minor, Negligible)

Positive / Negative


Minor, Negligible)

Positive / Negative


losses compensated

Minimise the amount of land disrupted during repairs

Discuss with local communities impact of steam on agricultural production

Grievance mechanism

Revenue generation for the local government / community and community investments

Minor Positive P D LT Ensure all payments are made in a timely and transparent manner

Consult local communities on their priorities for any planned community investments

Minor to Moderate

Positive P D LT

Improved access to land resulting from maintenance of roads

Minor Positive P D LT Regular maintenance of access roads

Minor Positive P D LT




10. REFERENCES • EFE Geothermal Power Plant Project, Environmental Impact Assessment Report, Ankara, August

2012 (including all EIA Report Appendices) • National Accounts and the Ministry of Economy and Finance, processed by Urbistat on ISTAT data

(2012) • 2013 Traffic and Transportation Survey of Highways Report, produced by the Turkish General

Directorate for State Highways • EFELER (162.5 MWe) JES PROJECT Daily working report, July 8th 2014. • Electricity Market Law No. 4628, amended by law No. 5496 (Article 15, clause c) • Expropriation Code No. 2942 • Valuation reports for land plots currently under expropriation and land acquisition tables for various

project components, provided by Guris • Guris GPP ESDDA Report Rev.4

11. Limitations and Assumptions The key assumptions that have been made and any limitations that have been identified, in producing this SIA are set out below. • Data that has been supplied to Atkins regarding land acquisition, employment estimates, etc. is

complete and accurate; • The scheme description will be as outlined in Section 2 ‘Project Description’; • The statistical data from the 2011 census is available at province and district level and very rarely at

local community level. Where possible data specifically relating to affected communities was sought from other sources i.e. the local EIA survey, interviews with affected people and other stakeholders, etc.

• The mitigation and enhancement measures stipulated in this chapter will be implemented as appropriate.


Anthony G Iles

WS Atkins International Ltd

The Hub, 500 Aztec West,

Almondsbury,

Bristol

BS32 4RZ

UK

Email: [email protected]

Telephone: 0044 (0) 1372 726140

Direct telephone: 0044 (0) 1454 662334

© Atkins Ltd except where stated otherwise.

The Atkins logo, ‘Carbon Critical Design’ and the strapline ‘Plan Design Enable’ are trademarks of Atkins Ltd.

gürmat 2 geothermal power plant...turkey, 110 km south west of izmir (see figures 1.1 and 1.2). in...

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