Environmental and Social Management Framework Document for the Additional Finance for the Renewable Energy Integration Project (REIP) Supported by the World Bank in Turkey 1 1. INTRODUCTION ............................................................................................................ 4 1.1 Objectives of the Additional Finance of the Renewable Energy Integration Project ........ 4 1.2 The Purpose and Scope of the ESMF Document ............................................................ 11 2. ENVIRONMENTAL AND SOCIAL ASSESSMENT .................................................. 13 2.1 Turkey's EIA Regulation ................................................................................................. 13 2.2. National Legislation Concerning Social Impacts ........................................................... 14 2.3. World Bank Policies Applicable to the Project .............................................................. 15 2.3.1 Environmental Assessment Policy OP. 4.01 ............................................................ 15 2.3.2 The World Bank Operational Policy OP 4.11 on Physical Cultural Resources ....... 20 2.3.3 The World Bank Operational Policy OP 4.04 on Natural Habitats .......................... 20 2.3.4 World Bank Operational Policy OP 7.50 on International Waterways .................... 21 2.3.5 World Bank Operational Policy OP 4.12 on Involuntary Resettlement ................... 24 3. POSSIBLE ENVIRONMENTAL AND SOCIAL IMPACTS OF THE PROJECT AND MITIGATIONS ..................................................................................................................... 25 3.1 Social and Environmental Impacts .................................................................................. 25 3.2 Stakeholder Engagement and Information ...................................................................... 36 3.3 Grievance Mechanism ..................................................................................................... 39 4. INSTITUTIONAL ARRANGEMENTS IN VIEW OF ENVIRONMENTAL AND SOCIAL MANAGEMENT ................................................................................................... 41 2 List of Acronyms EIA Environmental Impact Assessment FD Framework Document ESMP Environmental and Social Management Plan SC Submarine Cable WB World Bank GIS SS Gas Insulated Substation ESIA Environmental and Social Impact Assessment REIP-AF Renewable Energy Integration-Additional Finance SS Substation TEİAŞ Turkish Electricity Transmission Corporation UGC Underground Cable 3 1. INTRODUCTION Increasing the capacity of the REIP project will enable a stronger transmission system and help expand the automated controls, improve management and protect the stability of the high- voltage grid and prevent the widespread of sizable disruptions, which will supply protection of the systems. In view of connection of renewable power plants to the national grid as well as ensuring improved security and reliability of the electrical power system, the scope of the project concerns the construction of two submarine cables, Gas Insulated Substations (GIS) and underground cables. REIP has been designed as series of projects and this Environmental and Social Management Framework (ESMF) has been prepared for the additional finance of the REIP project. 1.1 Objectives of the Additional Finance of the Renewable Energy Integration Project As part of its principal remit, TEIAS has made most investments regarding substations, power transmission lines, underground and submarine cables as well as investments for materials and equipment in relation with the planning, projecting, erection, operation and maintenance of the national interconnected system with the overarching aim to renovate and improve the performance of the electrical power system and increasing capacities between consumption areas as well as to ensure security and reliability of the electrical power system, with some investments still ongoing. Lapseki 1 and 2 and Sutluce Submarine Cable projects built and system-integrated by TEIAS have all been financed by the World Bank. With their great input to the security of supply in the Thrace region have been commissioned in 2016 and 2017, respectively. Similarly, the 380 kV Lapseki 3 - Sutluce 3 Submarine Cable and the Gulf of Izmit Submarine Cable crossing projects included in the Investment Program for 2018, when built, shall free the transmission system from operational bottlenecks and the plan seeks also transmit electrical power generated in renewable energy plants already available, that are being and will be built in Southern 4 Marmara and Western Anatolia regions to Thrace and Istanbul Anatolian side that are quite needy in terms of generation plants. The scheme for REIP as the first of the series of projects is composed of the components below: Component 1: Development of transmission infrastructure to facilitate faster development of Wind Power Plants (WPPs). Within the Aegean and Marmara regions that hold the highest wind energy potential in Turkey, the provinces of Izmir, Canakkale and Kirklareli rank among the highest with installed wind capacity of 877 MW, 407 MW and 382 MW respectively. The wind power investments in these three provinces together constituted nearly 70 percent of the installed wind capacity in Turkey in 2012. Due to their high wind potential, these provinces will continue to attract more investments in WPPs. Availability of upfront transmission infrastructure to cater to growing needs of new WPPs in these provinces could enable faster implementation of wind energy projects. The first component of this project would therefore develop three 380kV 500 MVA highly digitalized sub-stations with associated grid connection structures for evacuation of wind power in the areas of Can, Izmir and Vize. The proposed structures would include high voltage (HV) substations, HV grid interfacing equipment, smart-metering systems, feeders (underground cables), tele-metered dispatch systems, digital protection systems, supervisory systems, and automatic voltage control systems. Component 2: Smart-grid investments to strengthen grid operation and management in face of higher wind energy generation. These investments will enable TEIAS to monitor network status in real-time and operate entire network reliably and securely. It would enable TEIAS to handle the increasing amounts of wind energy. It consists of:  Upgrade of hardware and software of the National Control Center (NCC), Emergency National Control Center (ENCC) and 9 Regional Control Centers (RCCs) in TEIAS’ 5 existing SCADA/EMS system and the addition of Renewable Energy Resource (RER) Operator Desk on SCADA system to manage rapidly increasing WPP.  Remote Terminal Unit (RTU) installation to substations and power plants to monitor and control them from dispatching centers.  Digital Protection Relay deployment which will make faster fault clearing in order to minimize network disturbance and outage area.  Shunt Reactor installation to bulk-transmission network to secure appropriate system voltage among network. Component 3: Lapseki 2-Sutluce 2 380 kV Submarine Power Cable to better inter- connect wind energy locations with other parts of Turkey. As the second double-circuit submarine cable route having 4.35km length across the Dardanelles strait, this cable will connect Anatolian side and Thrace side of Turkey with a capacity of 2GW. Along with the first submarine cable being implemented under APL-6, the aggregate submarine cable capacity across the Dardanelles strait will be 4GW, connecting wind power sub-stations in provinces of Can, Izmir and Istanbul. As a result of this sub-component, the 380kV bulk-transmission network to Istanbul across the Bosphorus and Dardanelles straits will form a secure strong loop network around Marmara Sea. Component 4: Strengthening of Transmission Networks to cater to growing demand and supply of electricity in Turkey This component will cater the investment needs for 380kV bulk-transmission and 154 kV sub-transmission network expansions to meet rapidly increasing demand and supply. This component consists of the 380kV Yeni Ambarli– Yenibosna single-circuit underground cable (route length 16.7km), four 380kV substations (total transformer’s capacity is 2100MVA), four 154kV substations (total transformer’s capacity is 800MVA), and four 154kV single-circuit underground cable (total route length is 31.2km). For the sake of urgent requirement, procurement of the 380kV Yeni Ambarli – Yenibosna underground cable has been initiated under APL-6 though most of the investment will be financed by this REIP. 6 Component – 5: Supporting implementation of smart grid technologies and strengthening regulation and support to wind power market In addition to the abovementioned components, the following activities are foreseen: (i) designing and implementation of smart grid systems and capacity development, (ii) simplification of regulation and market processes regarding obtaining licenses for wind power (and other renewable energy types), (iii) strengthening of wind power market and (iv) strengthening of environmental and social safeguards with respect to cumulative impact assessment in wind power projects (WPP). Power security has been one of the priorities in Turkey, to meet the soaring requirement for power and the number of projects concerning the use of renewable energy sources multiplied, which, in turn, necessitated that TEIAS reinforces the transmission network and further integrates renewable energy sources. Therefore, the additional finance of the REIP has been evoked. With the additional finance project, the high-capacity renewable energy in Marmara Region shall be safely and effectively connected to the national grid, which will both strengthen the national transmission network, prevent shortages and ensure system continuity as well as security. Within this scope, the additional finance project is looking into the components below: Component 1: Development of transmission infrastructure to facilitate faster development of WPPs. This component will construct the 380 kV Ciftlikkoy Gas Insulated Switchgear (GIS) substation which will collect electricity generated by WPPs in southern Marmara region and transfer to the consumers in Bursa, Istanbul and Kocaeli. This is also the southern connecting point of Izmit Gulf Crossing sub-project below. It will be equipped with three transformers and one reactor. This will be a fully digitalized substation by way of the substation automation system (SAS) and the digital protection relay (DPR) using smart grid technologies, and it will be monitored and surprised by the national control center (NCC) through RTU and supervisory control and data acquisition (SCADA) system. 7 Component 2: Submarine power cables to better inter-connect wind energy locations with other parts of Turkey. i. Lapseki 3-Sutluce 3 380 kV Submarine Power Cable: As the third double- circuit submarine cable route having 4.5 km across the Dardanelles strait, 380 kV Lapseki 3 – Sutluce 3 submarine cable will connect Anatolian side and Thrace side. Along with the first and the second submarine cables implemented under the APL-6 and REIP projects, the increased transmission capacity across the Dardanelles strait will allow to transfer more electricity generated from WPPs in southern Marmara and western Anatolia provinces to Thrace region through a shorter route. As a result of this sub-component, the 380kV bulk-transmission network will form a secure strong loop network around Marmara Sea. ii. Izmit Gulf Crossing Sub-Project: This sub-project will construct seven new 380 kV cable transmission lines. Southern Marmara and western Anatolia regions have high wind energy potential. Some new WPPs are expected to be operational soon in Canakkale, Balikesir, Izmir and Manisa (total is nearly 2850 MW). The Izmit Gulf Crossing sub-project consists of 380 kV double circuit submarine cable and related connection structures and will help evacuate power to Kocaeli and İstanbul Anatolia side through the shortest path. This sub-project consists of the following parts: a. Hersek - Dilovasi Submarine Cable, 380 kV, 2x1600 mm² Submarine Cable, 3.5 km b. Deri OIZ GIS – Tepeoren Substation Cable, 380 kV, 2000 mm² Cable, 11.3 km c. Gebze GIS – Kroman Celik GIS Cable, 380 kV, 2000 mm ² Cable, 12 km d. Kroman Celik GIS – Deri OIZ GIS Cable, 380 kV, 2000 mm² Cable, 11 km e. Gebze GIS – Dilovasi Cable, 380 kV, 2000 mm ² Cable, 9.65 km f. Diliskelesi GIS – Dilovasi Cable, 380 kV, 2000 mm² Cable, 4.5 km g. Izmit Gulf Crossing Interface Point – Hersek Cable, 380 kV, 2x2000 mm² Cable, 2.4 km Component 3: Strengthening of Transmission Networks to cater to growing demand and supply of electricity in Turkey. This component will cater the investment needs for 380kV bulk-transmission network expansions to meet rapidly increasing demand and required supply 8 capacity in the north-east Marmara region and compensate reactive power created by the transmission line and cable expansion. This component consists of two 380 kV GIS substations, namely Deri OIZ GIS substation (four transformers and one reactor), and Gebze GIS substation (two transformers and one reactor). Gebze GIS substation is one of the northern connecting points in the Izmit Gulf crossing sub-project for wind power evacuation from the southern Marmara region to Istanbul Anatolia side. They will be also fully digitalized substations by way of the SAS and DPR, and they will be monitored by the NCC through RTU and SCADA system. These investments are tentative and can be flexibly replaced by similar cables, substations, transformers and reactive power compensation system in different place(s) contributing to the supply capacity increase, the connection point and the reactive power compensation in the region due to land availability, change of load condition derived from development program change. The Bank financed components explained above, specifically Izmit Gulf Crossing and Lapseki 3-Sutluce 3 submarine cable, will be connected to the national grid through the overhead lines with TEIAS’ own financing sources. These facilites are being built to improve the security of the system. A transmission grid often needs these security-centric investments essentially to make the high voltage grid more meshed so that there are alternative paths. There are several alternative routes for establishment of the connection lines. It should be noted that the connection lines are constructed not only for connecting the Bank financed components to the national grid (which could be implemented with other alternative routes), but also ensuring security of the whole system. Therefore, the selected alternative routes are based on the two targets explained above. Given the description of the associated facility according to World Bank policies, these facilities are not considered as associated facilities for the REIP additional finance. Investments to be implemented under REIP Additional Finance shall be in line with Turkey's national legislation as well as the World Bank Safeguard policies. TEIAS shall be the implementing agency. In addition to requirements in Turkey, TEIAS, as the implementing agency shall ensure that World Bank policies on environmental and social issues are pursued as 9 specified in this framework document. Projects under REIP Additional Finance are given in Table 1. As a general policy, TEIAS shall only focus on projects that satisfy the requirements of the Environmental Impact Assessment (EIA) Regulation in Turkey, irrespective of the projects' source of finance. In other words, before TEIAS’s assessment, all sub-component projects shall meet the requirements of the EIA Regulation of Turkey and EIA positive, EIA not required or EIA not relevant decisions should be taken. Furthermore, no sub-project shall be approved until Turkey's national and World Bank environmental and social safeguards policy/legislation requirements have been successfully met. Table 1. Projects Proposed for REIP Additional Finance Project No. Name of Project Project Characteristics No. Lapseki 3-Sutluce 3 380 kV 1 17D000330 380 kV, 2x1600 mm² cable, 4.5 km Submarine Power Cable Hersek - Dilovasi Submarine 2* 17D000343 380 kV, 2x1600 mm² cable, 3.5 km Cable Deri OIZ GIS – Tepeoren 3* 18D000990 380 kV, 2000 mm² cable, 11.3 km Substation Cable Gebze GIS – Kroman Celik GIS 4* 17D000340 380 kV, 2000 mm ² cable, 12 km Cable Kroman Celik GIS – Deri OIZ 5* 18D001250 380 kV, 2000 mm² cable, 11 km GIS 6* 17D000341 Gebze GIS – Dilovasi Cable 380 kV, 2000 mm ² cable, 9.65 km 7* 17D001320 Diliskelesi GIS – Dilovasi Cable 380 kV, 2000 mm² cable, 4.5 km Izmit Gulf Crossing Interface 8* 17D001330 380kV, 2x2000 mm² cable, 2.4 km Point – Hersek Cable 380/154 kV, 2x250 MVA + 420 kV, 160-250 MVAr Adjustable 9 17D000980 Deri OIZ GIS Reactor + 380/33 kV, 2x125 MVA + 154/33 kV, Transformer Feeder 1 and 2. 380/154 kV, 2x250 MVA + 420 kV, 160-250 MVAr Adjustable 10 18D000490 Ciftlikkoy GIS Reactor + 154/33 kV, 50 MVA + Transformer Feeder 2. 380/33 kV, 2x125 MVA + Transformer Feeder 3 + 420 kV, 160- 11 17D000860 Gebze GIS 250 MVAr Adjustable Reactor *Projects marked are defined under Izmit Gulf Crossing Project 10 TEİAŞ's assessment of alternatives during survey stages; Number one priority for TEIAS, during route-selection for power cable projects is to find and use the shortest and the most economical route over government land between SSs to be erected. Since the project locations are selected considering the government lands as priority, no expropriation works are required and hence the social impacts are minimized. In accordance with the identified route of the cables, relevant infrastructure agencies are contacted and their official views and opinions are obtained. In line with the views and opinion from respective agencies, the route is finalized through partial modifications, as required. As such, first, TEIAS determines the the electrically most suitable route, views and feedback from public bodies responsible for public land along the route are obtained and in line with thse views and feedback, the route is finalized. 1.2 The Purpose and Scope of the ESMF Document The environmental and social safeguards policies of the World Bank require the borrower to prepare an ESMF document in observance of the EIA Regulation (published in the Official Gazette No. 29186 and dated 25.11.2014) and the Environmental Assessment Operational Policies of the World Bank for REIP additional finance. Since the exact locations, design and technical details of some sub-projects under the additional finance of REIP are unknown at this stage, this ESMF is the key document that is shared with stakeholders before implementation. On the other hand, the design and feasibility studies for some of the sub-projects have been completed and the environmental and social assessment of these are ongoing, and the outcomes of these works, until the stage of project appraisal, shall be presented in respective environmental and social assessment documents (such as the ESIA, ESMP, etc.) Although the ESMF provides the framework of the comprehensive environmental and social management approach agreed to identify the potential environmental and social impacts of the additional finance, it also provides guidance as to how to identify the environmental and social impacts of the sub-projects of which are yet to be determined and against which principles as well as how such impacts can be prevented or mitigated. The ESMF seeks to amalgamate all 11 project-related policies and regulatory tools in the Turkish legislation with the World Bank safeguards and to make sure that they are well-understood. For the exact location and design of the technical details of some sub-projects planned in connection with the project are not yet clear, a detailed assessment of the environmental and social impacts of sub-projects can only be performed once the projects and design details have been clarified. The ESMF, at the same time, shall also cover those projects that are not on the additional finance project list but that can be added. Yet, the ESMF covers the entire environmental framework of the previous REIP project as well as the impacts from novel finance options. Then, for those projects the impacts of which are known, Environmental and Social Management Plans (ESMPs) in line with the principles defined in this ESMF shall be prepared, which shall be shared with respective stakeholders and final documents published on the TEIAS and World Bank’s websites, before the project approval. The ESMF functions as a general and systematical guide composed of policies, procedures and provisions that shall be integrated to the project lifecycle to ensure that environmental and social issues are systematically handled at the sub-project level. Furthermore, it also provides guidance and technical input to the REIP Additional Finance project from the perspective of environmental and social management perspective. Accordingly, ESMF practices and implementation shall also provide guidance to the integration of environmental and social issues to the decision-making processes regarding the planning, design, implementation, operation and maintenance of sub-projects by way of identification, prevention and/or minimization of adverse environmental and social impacts at the early stages of the project cycle. Procedures specified in this Framework Document provide further details on the World Bank Operational Policy OP/BP/GP 4.01 (Environmental Assessment), OP/BP 4.04 (Natural Habitats), OP/BP 4.11 (Physical Cultural Resources), and OP 4.12 (Involuntary Resettlement) which are the three principles triggering environmental policies during project planning phase as well as the Turkish Environmental Legislation and Procedures. This document sets forth the variations between the requirements of Turkey and those of the World Bank and defines steps to fill in the gaps in between. 12 2. ENVIRONMENTAL AND SOCIAL ASSESSMENT 2.1 Turkey's EIA Regulation TEIAS shall determine the route of underground cables and the location of substations. TEIAS, during the planning phase, shall contact all official bodies concerned (Ministry of Culture and Tourism, Ministry of Environment and Urbanization, etc.) regarding the location and the routing of the right of way. In line with official correspondence, TEIAS shall endeavor to refrain from any protected and/or archaeological sites, etc. As a requirement of Turkish EIA Regulation, the Environment and Expropriation Department of TEIAS shall satisfy all environmental assessment requirements including obtainment of relevant EIA official letter from the Ministry of Environment and Urbanization. In line with the Turkish EIA Regulation (Annex 1 Projects in the Regulation) power transmission line projects above 15 km and 154 kV require a full EIA process and a full EIA report. Annex 2 of the Turkish EIA Regulation provides a list of projects requiring the preparation of a Project Information File, which is a simpler form of the Environmental Impact Assessment Report providing a summary of the main features, the location of the project, as well as mitigation measures identified in relation thereto, on the basis of which the Ministry of Environment and Urbanization shall scan these projects and determine whether or not a full EIA is required. This Annex covers power transmission lines that are longer than 5 but shorter than 15 km and with a voltage level beyond 154 kV. The Environment and Expropriation Department of TEIAS, EIA-competency certified by the Ministry of Environment and Urbanization shall execute Environmental and Social Impact Assessment works in relation with sub-projects. In parallel with environmental assessment requirements and the national EIA Regulation, the same TEIAS department shall be responsible for determination of the environmental category of the sub-projects in negotiation with the World Bank, as per OP 4.01. As mentioned 13 before, the REIP Additional Finance project is classified as Category B and in the event that, it is found that another sub-project experiences graver problems or is classified as Category A, TEIAS shall exclude this project from the WB finance scheme or require a restructuring of the REIP Additional Finance. Also, ESIA/ESMPs shall also include additional information regarding the characteristics and EIA status of the project. 2.2. National Legislation Concerning Social Impacts Although Turkey’s EIA Regulation is short of fully satisfying international standards in terms of social impacts, it still provides certain legal arrangements regarding the management of a variety of social impacts. As such, a brief list of the legal framework regarding the social impacts of the project is as follows:  Labor Law No. 4857 published in the Official Gazette No. 25134 of June 10, 2003.  Occupational Health and Safety Law No. 6331 published in the Official Gazette No. 28339 of June 30, 2012.  Regulation on Contractors and Sub-contractors published in the Official Gazette No. 27010 of September 27, 2008. Turkey's legal arrangements regarding Involuntary Resettlement can be summarized as follows:  Expropriation Law published in the Official Gazette No. 18215 of November 8, 1983.  Law Regarding the Amendment of the Expropriation Law published in the Official Gazette No. 24393 of May 5, 2011. 14 2.3. World Bank Policies Applicable to the Project 2.3.1 Environmental Assessment Policy OP. 4.01 Project Categories and Screening: Projects under the Environmental Assessment system of the World Bank (OP. 4.01) are classified as Category A, B, or Category C in view of the estimated potential risk. Category A projects are those that can negatively impact environmentally and socially- important areas such as humans, forest areas and other natural habitats. These impacts, in general, are large scale impacts and irreversible, sensitive, diverse, cumulative, exemplary and might be impacting an area larger than the location and facility financed under the project. For example, Category A projects can display one or more of the characteristics below: significant transformation or destruction of natural habitats; extraction, consumption or transformation of significant amount of forests, mines and other natural resources; direct discharge of pollutants as a result of which air, soil and air quality has been deteriorated; generation, storage, use or disposal of hazardous materials or wastes. Category B projects have less negative potential environmental and social impacts. These impacts are area-specific and can be reversed and mitigation measures might seem simpler than those in Category A projects and can be planned. Category B can include projects with a variety of potential environmental and social challenges on a larger scale. In fact, Category B includes all projects that are not as complex and as risky as to require EIA (demonstrating larger potential outcomes and including detailed alternative analyses as well as environmental and social baseline data). However still, in order to be able to determine suitable mitigation measures and monitoring indicators, analyses of potential environmental and social impacts are also needed. Although not defined as such in the OP, Category B projects can, among themselves, be bifurcated as Low B and High B projects. Projects considered as High B have relatively larger impacts than those that are Low B and include a higher number of mitigations, yet these impacts and mitigations are not as important as to require classification as Category A. Different types of environmental and social assessment documents can be required depending on the level of significance of the limited 15 impacts from Category B projects. A basic ESMP or an ESMP checklist may suffice for the construction/rehabilitation of really simple projects however, in the event of projects with limited but significant impacts, an environmental and social assessment document (similar to a detailed ESMP) may be needed. Category C projects include no activities that might have a negative impact on the environment. Thanks to the integration of good practices, potential impacts of such projects in this category can be almost zeroed-out. There are differences between the environmental selection/eligibility criteria of the World Bank and those provided in national legislation. For example, one cannot presume that Annex I corresponds to World Bank's Category A or Annex II to Category B. Differences between the two systems might emerge and some Annex I projects can correspond to Category B or some Annex II projects can correspond to Category A if planned for sensitive areas. Again, in cases where some projects that can be treated as 'out-of-scope' as per the Turkish legislation have limited and short-term impacts, these can be classified as Category B. The Scope of the Environmental and Social Assessment: The scope and type of the Environmental and Social Assessment (ESA) varies between Category A and Category B projects. An ESIA to analyze the potential negative and positive as well as the social impacts of the sub-project, that compares the impacts thereof with those of feasible alternatives (including no- project option) and one that makes recommendations as to the prevention, minimization, reduction or remedy of negative impacts and to multiply environmental and social performance shall be prepared for sub-projects under Category A. One of the outstanding features of an ESIA is the analysis of alternatives. The ESIA, at the same time, covers an explanatory Environmental and Social Management Plan (ESMP) setting forth measures needed during the implementation and operation phases of the (sub)project so as to eliminate, mitigate or balance negative environmental and social impacts; steps needed to implement those measures and monitoring 16 indicators, actions and liabilities (for ESMP format, see. Annex -A&B) Sample tables provide a list of possible environmental and social impacts likely to encounter in sub-projects as well as determine mitigation methods for each of the impacts presented. A sub-project shall not necessarily be limited to all of the impact categories specified in this table nor subject to those. So, a separate ESMP shall be prepared specific to the impacts of each sub-project. The scope of the environmental assessment document of a Category B sub-project can differ between projects, but it is still of a lesser scope than a Category A ESIA. Similar to a Category A ESIA, this one also analyzes the potential negative and positive environmental and social impacts and makes recommendations to minimize, reduce or remedy such negative impacts and to improve environmental and social performance. In the event that the project has been categorized as a Category B project, and when site-specific problems requiring a site- specific analysis are unavailable, the ESMP can also provide such data as required. An example can be the construction of a medium-scale building in an urban environment that would require only one ESMP when, normally, there are no site-related environmental issues that are known. In cases where this construction is carried out in greenfield, an ESA shall be performed to clarify whether or not there are any site specific environmental or social issues. In cases where the outcome of the ESA reveals significant damage to natural habitats, the project category can be modified as Category A. On the other hand, in cases where the project has been categorized as Category B, an ESIA shall be prepared so as to satisfy specific requirements. Within the scope of the said project, any sub-projects identified as Category A shall not eligible for financing. Project components need to be Category B or a lower risk class. Accordingly, site-specific ESMPs as environmental and social impact assessment tools (mostly for substations and underground cables) and ESIAs (for submarine cables) are envisaged in addition to this ESMF. 17 Public Consultation and Disclosure As a requirement of the World Bank policies, for all Category A and B sub-projects proposed for Bank finance, TEIAS shall consult with the affected groups and civil society organizations impacted by the environmental and social aspects of the sub-project and takes their views into consideration during the ESIA process. At least one meeting with affected groups and civil society organizations shall be carried out for Category B sub-projects, when the ESIA repost has been completed (together with the ESMP). In addition, TEIAS shall also consult with these groups during project implementation so as to table issues in relation with the ESA documents, which affect them. In order to be able to have meaningful consultation with the project-affected groups and civil society organizations in relation with Category B and Category B sub-projects proposed for World Bank financing, TEIAS shall present related materials (in Turkish) before such meetings. These materials shall be in the language and form that negotiation parties can understand. At the same time, TEIAS shall hand out to the public posters, fliers, brochures, etc. to provide information about the sub-project before such meeting and make also a presentation regarding possible environmental and social impacts, mitigations proposed, monitoring of the project as well as the Grievances Mechanism to handle complaints and requests regarding the project. TEIAS shall ensure that a printed copy of each ESA documents and the Abbreviated Land Acquisition Plans (ALAPs), as applicable, and in Turkish, are displayed and remain accessible by the people before public consultation. Following consultations, TEIAS shall revise final draft documents and feedback and views collected through such consultations. TEIAS shall submit both Turkish and English versions of ESA and other environmental and social documents to the World Bank for approval. 18 Prior to the project appraisal, the final versions of the ESAs and ALAPs shall be published in-country in both Turkish and English. English versions of ESAs and ALAPs shall be published on the external WB website. Preparation, Review and Approval of Environmental and Social Assessment Documents: TEIAS, before commencement of construction activities shall prepare all social and environmental documents in relation with the WB Safeguard Policies. Documents prepared as such regarding all safeguard policies shall be approved by the Republic of Turkey and the World Bank and published in Turkish on the World Bank external website and the official website of TEIAS, in a way all stakeholders can understand. Finance support requires the implementation of the ESIA or the ESMP. Within this scope, ESA documents concerned shall be included in tender documents and shall become a part of the contract of the contractor selected to execute the sub-project. Monitoring: In order to ensure that ESA documents are duly implemented, TEIAS shall regularly inspect sub-projects during construction and operation phases. When any problems regarding the implementation of ESA documents are identified, TEIAS shall determine steps needed to remedy such problems. Specifically, in the event of any environmental events such as death, other events leading to lost working days, spill of materials hazardous for the environment, etc.) the contractors shall notify TEIAS in 3 working days regarding the matter, who shall further notify the Bank. The detailed accident report including root-cause analysis, measures taken and compensation measures shall be submitted to TEIAS in 30 working days and TEIAS shall forward this report to the Bank. TEIAS shall present its findings in the six-monthly project progress reports or more frequently, as required, to the World Bank. The World Bank project team shall visit project sites as part of project supervision and as required. 19 2.3.2 The World Bank Operational Policy OP 4.11 on Physical Cultural Resources Cultural assets are critical for economic and social development, hence shall be taken into consideration in all project practices. Potential impacts are demonstrated as integral parts of the environmental assessment process. For many cultural inheritances not documented or not protected by law, consultations with project-affected groups, authorities of respective institutions and civil society organizations are used to determine measures to identify potential impacts and preventive measures. A cultural heritage management plan seeking to prevent negative impacts on cultural resources and to strengthen monitoring and institutional capacity, as an integral part of the environmental assessment document shall be developed in the scope of the environmental assessment process. The gist here is bi-dimensional: (i) identification of chance-finds during construction and (ii) the potential impact of the project on known cultural assets. Laws in Turkey, especially the Law No. 2863 dated 21/07/1983 on the Protection of Cultural and Natural Assets (together with the amendment as published in the Official Gazette dated 27/07/2004) and related practices are satisfactory in view of World Bank requirements. TEIAS shall be responsible for the enforcement of the legislation concerned and to prevent or reduce the impacts of projects financed on physical or cultural resources. As such, TEIAS shall not maintain sub- project financing until all legislative requirements have been satisfied. Also, measures to be employed shall be included in ESA documents concerning follow- up and also the monitoring plan. 2.3.3 The World Bank Operational Policy OP 4.04 on Natural Habitats There is the possibility that construction works within the scope of the project can affect critical or not-critical natural (as per the definition in OP 4.01) habitats. Sub-projects, which have a significant impact of an accepted critical habitat or an eco-system shall be considered 'ineligible' for financing under OP 4.01 and the main topic to be covered under the ESIA shall be the determination of project alternatives in view of its location and scope. 20 2.3.4 World Bank Operational Policy OP 7.50 on International Waterways The Sea of Marmara as an inland sea is related with the World Bank's Policy of International Waterways however, for the submarine crossing sub-projects under this project have almost zero impact on the aquatic receiving environments, the World Bank deems that shall be observed as per OP 7.50. The 380 kV Lapseki 3-Sütlüce 3 Submarine Cable Route is closely positioned with the submarine pipeline project (SPP) which has been planned to transport the natural gas extracted from various gas fields in other countries including the Azerbaijan Shah Sea 2 field, to Europe via Turkey. For this reason, SPP Sediment Plume Modeling Report represents a model for reviewing the impact of TEIAS Project on sediment. The open sea pipeline route of SPP passing through the Marmara Sea has a length of approximately 17.6 km, and its maximum depth is around 70 m. The 380 kV Lapseki 3 – Sütlüce 3 Submarine Cable is planned to have a length of approximately 4.75 km, and to be laid 1.00 m below the sea bed. A numerical distribution modeling study has been conducted to quantitatively identify the expected distribution of the suspended and settled sediments as a result of the trench excavation envisaged at two land approaches of submarine pipeline. The study has used existing data recorded in the close vicinity of project site in addition to the global forecast (hindcast) datasets in order to create a hydrodynamic model for ensuring the environmental guiding conditions and meteorological-oceanographic guiding conditions for distribution modelling. The seabed sediment data have been derived from the geotechnical information obtained from the geophysical and geotechnical surveys conducted in the field. Modelling conditions included representative summer and winter scenarios and the modeling considered calm (waveless) state and habitat wave conditions. Distribution modeling revealed the following results: 21 1. Under different scenarios reviewed for each land approach, there is no significant difference between the trench excavation plume formation amounts in affected areas, during summer and winter periods, wavy and waveless states, for similar quantities and total suspended solid matters (TSSM). 2. There is no significant difference between the trench opening and closing scenarios. 3. In some wavy state scenarios, some insignificant re-suspension states are observed after the trench excavation is completed, which are not always observed in calm (waveless) state scenarios. However, since they are short-term (usually a few hours) these are not considered significant. 4. At the land approach on the Anatolian side, plumes disperse along the coast and laterally off the shore. 5. At the land approach on the European side, plumes are driven towards the west with the dominant wave, with a certain amount of interference observed from the east of the footprint of trench excavation. 6. At the land approach on the Anatolian side, the areas defined with 1 mg/L total suspended solid matter (TSSM) and 50 percent contour lines ranges from 150 ha to 212 ha in all scenarios. At the 95 percent level this range is 231 ha to 369 ha. 7. At the land approach on the European side, the areas defined with 1 mg/L TSSM and 50 percent contour lines range from 510 ha to 573 ha in all scenarios. At the 95 percent level, the range is 1133 ha to 1280 ha. 8. During trench opening and closing, at the land approach on the Anatolia side, the peak levels of suspended sediment concentration reaches the value of approximately 250 mg/L at 100 meters to the footprint of trench excavation. 9. During trench opening and closing, at the land approach on the European side, the peak levels of suspended sediment concentration usually reaches the value of approximately 250 mg/L at 100 and 200 meters in the west, but short-term sudden increases occur exceeding 1000 mg/L under winter and summer conditions including wavy and waveless states. 10. The period of time in excess of 1 mg/L suspended sediment concentration does not exceed 5 days at the land approach on Anatolian side, however the summer time wavy state trench closing scenario were this period is exceeded on a land of approximately 13 ha is excluded from this. Under the summer time trench opening and closing scenarios (usually an 22 area of approximately 30 ha), the value of 5 mg/L is exceeded for up to 3 days around the footprint of trench excavation. 11. The 1 mg/L and 5 mg/L suspended sediment concentration excess times exceed 10 days, in the range of 478 ha and 574 ha for the 1 mg/L level and in the range of 10 ha and 262 ha for the 5 mg/L level under all scenarios at the land approach on the European side. The areas where the 10-day time is exceeded are larger under winter scenarios (above 200 ha) than under summer scenarios (between 10 ha and 33 ha). 12. The sediment settlement area with 1 mm layer thickness at the land approach on the Anatolian side disperses laterally towards the cape in the west from the footprint of trench excavation, and approximately 500 meters in the east, also towards the open sea at depths in excess of 30 m. 13. The areas covered with 1 mm of material range from 114 ha to 138 ha at the land approach on the Anatolian side in all model scenarios. 14. Under all model scenarios, an area of approximately 3.3 ha is covered with 100 mm of material near the land approach on the Anatolian side. 15. At the land approach on the European side, the sediment settlement area with 1 mm layer thickness disperses approximately 2 km towards the west along the coast, 1 km towards the east and towards the open sea by approximately 500 meters where depth is around 30 m. 16. Under all model scenarios, the areas covered with 1 mm of material range from 440 ha to 600 ha at the land approach on the European side. 17. Under all model scenarios, the areas covered with 100 mm of material range from 14.5 ha to 17.5 ha at the land approach on European side. In line with the data provided in SPP Sediment Plume Modeling Report, it is anticipated that the suspended and settled sediments of 380 kV Lapseki 3-Sütlüce 3 Submarine Cable Project will remain within the borders of Turkey and will be dispersed much less. It is considered that the approximately 4.2 km long planned 380 kV İzmit Gulf Crossing will be located on the east end of Marmara Sea and thus the project construction will not cause any environmental problem with regard to sediments as it is far away from the Dardanelles Strait. 23 2.3.5 World Bank Operational Policy OP 4.12 on Involuntary Resettlement Since land-acquisition-related impacts of some sub-projects are not yet clear and in view of the possibility of future sub-project modifications during the project implementation period, TEIAS has prepared a Land Acquisition Policy Framework (LAPF) in observance of the requirements of OP 4.12. The purpose of this LAPF is to define the land-acquisition-related impacts of the sub-projects under the Additional Finance as well as to assign mitigations and determine to which impact group such mitigations should be assigned and in cases where these impacts are unmitigable then, to define reduction methodology and tools for those impacts. As detailed in the LAPF prepared, depending on the magnitude of livelihood impacts, the LAPs or ALAPs shall be prepared for sub-projects with known impacts on land but land acquisition works under which have not started and also Ex-Post Social Audits seeking to make an assessment of works under sub-projects with land acquisition work ongoing will be prepared. Although sub-projects shall refrain from land acquisition as much as possible, there might still be certain construction works to require additional land acquisition. In such cases, TEIAS shall evaluate alternative government land that can be allocated for the purposes of the project. Since sub-projects shall establish servitude right generally for overhead lines and that fixed facilities take up much space, no significant land acquisition requirement is foreseen. In cases where land acquisition is inevitable, project design shall be so arranged as to keep land acquisition at a minimum. In cases requiring additional land acquisition, TEIAS shall prepare an (A)LAP in line with the LAPF. This (A)LAP, before start of construction works, shall be subject to approval by the World Bank. Similarly, TEIAS shall get World Bank approval for social audit reports it has prepared for sub-projects land acquisition works of which have either kicked-off or completed. 24 3. POSSIBLE ENVIRONMENTAL AND SOCIAL IMPACTS OF THE PROJECT AND MITIGATIONS 3.1 Social and Environmental Impacts Potential impacts in relation with this REIP Additional Finance could arise from substations, submarine and underground cables. Project activities concerned shall have similar impacts and mitigation and monitoring measures. These impacts concern dust, noise, solid waste and wastewater to generate, loss of habitat, hydrology and fauna/flora (Annex-E) for submarine cables, seabed geology, quality of sea water, etc. Also, other critical issues concern management of occupational health and safety issues and traffic and community health and safety. Within this scope, TEIAS, as required by World Bank environmental and social policies, shall promote certain good practices that can provide some guidance for both its own staff and project contractors regarding gender issues. Impacts during operation are generally about the management of the SF6 gas, disposal of waste oils and lubircants during the maintenance of the substation, etc. Environmental and social impacts that can be encountered during the project are discussed in following sections. Air Quality: Formation of dust is expected during the scraping of top soil and as a result fo other excavation activities during site preparation and construction activities under the project. Also, dust shall generate during the production, dismantling, loading and transport of such materials, which shall be possibly used as sand, gravel and lime. Vehicles dumpers shall be covered during transport and operators shall seek to load-offload so smoothly as not to cause any dust. Furthermore, exhaust emissions are also expected from construction machinery and equipment. Measures against the generation of dust and exhaust gases shall be employed. Within this scope, construction machinery, equipment and vehicles shall be periodically checked. Therefore, impacts are expected to be low. However, in the event of negative impacts on sensitive receiving environments and near-by communities, measures shall be employed as required. Noise: Noise from construction equipment and vehicles is expected to have adverse impacts on sensitive receiving environments adjacent to the project. Construction works shall 25 be carried out during the day between 07:00-19:00 hrs so as to minimize such impact. Then, noise levels in sensitive receiving environments shall be monitored and additional measures shall be employed as required. Water and Wastewater: Requirement for water shall mostly concern the daily requirement of workers and for other uses at the camp site. Ready-mixed concrete shall be used at the facility, and since concrete shall retain water, no wastewater shall be generated. Water shall also be used to wash down concrete mixers and dust to form on other machines as well as during the dampening of roads and cleaning of other equipment. TEIAS and the subcontractor shall be liable to satisfy their water requirement without causing any negative impacts on ground and surface waters. The quality of water needed (service water and water used for concrete) shall be periodically monitored. Wastewaters will generally be of domestic nature and generated at the camp site and the construction worksites. Wastewaters shall be firstly dumped in the sewage system as per the national local legislation and the WB criteria and in cases where such systems are not available, such waters shall be stored in mobile WCs or in impermeable septic tanks to be collected regularly by licensed companies and discharged to the sewage system for treatment, after which they shall be discharged to the receiving environment. Water to be used for spraying of the project site to prevent generation of dust will not result in generation of wastewater. Domestic wastewaters during operations shall be disposed of as per the requirements of the Water Pollution Control Regulation and the Regulation on the Protection of Basins for Water for Drinking and Service Purposes. Community Health and Safety: Throughout site preparation and construction works, TEIAS shall ensure that such health and safety measures as due information of the public of the construction plan and locations, due availability of signposts to delineate construction sites as well as due spraying and dampening in dry season and ensure that these rules and procedures are observed by subcontractors as well. In addition, since there will be entry and egress of vehicles at the construction site during works, a local congestion in traffic is also expected. Accidents to threaten community health and safety might occur as a result of inadequate fencing of worksites and lack of appropriate signature. 26 Occupational Health and Safety (OHS): Construction works can lead up to accidents to threaten the health and safety of workers unless required measures are in place. In this context, TEIAS and subcontractor companies are liable to provide a safe and healthy working environment to workers. Workers shall be knowledgeable, hence duly informed regarding job descriptions, responsibilities and risks that might translate into threats on health and safety. Workers shall be provided with personal protective equipment, as required, and updated regarding occupational health and safety through regular trainings. Camp sites shall be fitted with facilities to meet any requirements of workers. Project works shall be conducted in observance of the provisions of the Occupational Health and Safety (OHS) Law No. 6331. All works to be carried out within the scope of the said law, risk assessment shall be carried out, the roll out of which TEIAS shall oversee. Also, activities carried out under the project shall be performed in line with OHS policies and procedures set forth in the TEIAS Occupational Health and Safety Regulation. There are available procedures prepared in view of vocational and OHS training of workers personal protective equipment (PPE) and OHS materials, site work, work with chemicals, working at heights, OHS inspections, periodical health examinations, work accidents and near miss notifications. Field of activity of TEIAS is categorized under very dangerous works, requiring that OHS issues be prioritized. One of the principals of TEIAS is to reduce work accidents below scientifically acceptable limits to protect its staff from all sorts of possible risks. In line with its OHS policy, TEIAS undertakes to ensure that its workers, subcontractors, visitors and other TEIAS staff employed at other premises will employ all measures per the current OHS legislation, keep accessible tools, equipment and personal protective equipment as well as used. Another target is also to carry out a risk assessment before works start to identify and eliminate conditions that can lead to work accidents and vocational diseases, to monitor OHS practices at sites under TEIAS' supervision and to ensure that the OHS system in place is sustained. OHS performance in relation with projects sites under TEIAS responsibility that have been financed by the World Bank shall be monitored by TEIAS' regional offices and reported to TEIAS and the World Bank. These reports shall provide information on the use of personal 27 protective equipment (PPE), site observation regarding the use of signages, OHS training records, drill logs, risk assessment practices, emergency action plan updates and statistical data such as Lost Time Injury Frequency Rate (LTIFR). Reporting shall be quarterly. Hazardous Materials: Presently, the plan is not to have on-site fueling and vehicle maintenance at the construction site. However, this will be a requirement in the event that heavy machinery are used on construction site. TEIAS and subcontractors shall take measures required for the storage and use of hazardous materials to go into operations. Furthermore, chemical spills and other possible accidents involving hazardous materials shall be incorporated in emergency management plan scenarios and equipment required shall be made available on site as well as drills concerned shall be carried out. Waste Management: Wastes generated during construction shall be stored and disposed of in compliance with the national legislation as well as the WB criteria. As top soil shall be used for rehabilitation purposes after the construction phase, generation of excavation wastes is not expected. However, in the event that the amount of excavation material is in excess of the actual requirement, the excess portion shall be duly disposed of. In addition to excavation wastes, generation of domestic and hazardous solid wastes is also expected. Those wastes shall be separately stored at camp and construction sites as per national legislation and transported to licensed facilities for due disposal. TEIAS and the sub- contractor shall be responsible for all communication with licensed facilities as well as that all wastes have been disposed of in observance of the national legislation and the procedures of the WB. Natural Habitats, Flora and Fauna: Location and the footprint of sub-projects shall be determined in view of natural habitats. Within this scope, during environmental and social assessments natural habitats under national/international protection that can be impacted by project sites and activities shall be taken into consideration, potential impacts of the project footprint thereupon shall be evaluated and measures to prevent/minimize negative impacts shall be determined. Furthermore, monitoring of these measures shall also be listed in documents concerned. No sub-project with the possibility to negatively impact and critical habitat shall be financed under the project. Similarly, flora and fauna species in project activity areas that can 28 be negatively impacted shall be determined, impacts on these species that can be negatively affected by construction activities and other operations shall be identified as well as measures to minimize/prevent these impacts determined, and other information regarding monitoring activities shall also be included in the environmental and social impact assessment activities. Infrastructure: Existing roads shall be used during construction. The construction contractor shall rehabilitate possible damages on road surfaces from heavy machinery traffic. In cases where infrastructure elements on private property are damaged as a result of construction activities, implementation of the mitigation measures shall be the responsibility of the contractor. Infrastructure requirements of camps to be erected as part of construction activities shall be satisfied separately, without impacting the existing infrastructure. For this reason, the impact of the project on local infrastructure shall be insignificant. Land Acquisition: The ultimate goal is to refrain from land acquisition to the extent possible. However, in some sub-projects where land acquisition is unavoidable, TEIAS will take measures in line with its LAPF prepared as per WB OP 4.12. Economic resesttlement is foreseen for the project, including minimal physical displacement on public land. In the event that ad hoc or permanent acquisition of land is required for certain components of the project, although small in scale, some livelihoods might still be compromised. In observance of project principles, use of government land shall be prioritized over use of private property and agricultural land. In cases where expropriation of private property is inevitable, and expropriation is needed, works shall proceed after the Bank approved (A)LAPs are implemented by TEIAS. Immovables and Livelihoods: The project will lead to minimal economic displacement, which have already taken place before Bank financing. Future land acquisition will take place and also project has encounteres physical displacement to minimal extent, which led to losses on buildings or other structures. Project design is based on use of existing roads for access. Depending on the condition and use of land needed for the project, some crops and trees with economic value can also be lost. There is also the possibility that project activities might affect land-reliant livelihoods in areas the project also trespasses agricultural land. In such cases, compensation and livelihood restoration measures regarding damages on and loss of immovables and livelihoods affected by the project shall be detailed in (A)LAPs to be prepared. 29 Local Employment and Procurement: Workforce required throughout construction works shall be supplied through the locals affected by the project to the extent possible. However, in view that the skill-set and the level of knowledge of the locals might be insufficient for the technical construct of the project, required labor can be supplied also regionally or nationally, as required. Since construction activities will also require procurement of local products and services for a limited amount of time, it is also expected to create a positive impact in these regards. Procurement of construction machinery and equipments, construction materials and transportation, catering as well as laundry, food supplies and security services shall be supplied through local suppliers to the extent possible. Other Stakeholders including farmers, local people and sensitive groups: In cases where construction activities coincide with rural areas used for agricultural purposes, agricultural workers (i.e. seasonal and daily workers) and women involved in agricultural activities can also be impacted by the project as the project may temporarily limit such demands regarding irrigation, cultivation and harvesting. Seasonal workers move around with their families and are involved in agricultural activities also with their families. On the project site where there is a requirement for seasonal workers, children are not salary-workers but just helping their families. This modality of work is not considered as forced labor. Then, there is also the national legislation banning all sorts of child labor. On these grounds any kind of forced or child labor will be banned as per the national labor law. The fishing activities may be adversely affected due to construction activities of the submarine cable and interfaces for a short time. The impacts will be assessed throughout the project lifetime starting from pre-construction phase and appropriate mitigation measures will be taken, based on the results of the assessment, if required. In cases where sensitive groups have been identified during the project, all project stakeholders including these groups shall be consulted and informed about the impacts of the project and the construction schedule as well as damages applicable for project affected people as a result of loss of land or livelihoods. Gender Impact: The national law has equal provisions for women and men, and hence there are no limitations for women owners or tenants of land. TEIAS and contracting companies shall employ measures as required so as to ensure that women right-holders, who are actively involved in activities to be carried out are involved in all consultative processes and equally 30 informed, especially in activities to be carried out in rural settings. TEIAS shall separately monitor project-affected women right-holders for the purposes of certain data provided in monitoring reports (ex. number of project-affected women, number of women participating in consultation meetings, grievances from women, etc.) Working Conditions, Influx of Workers and Child Labor: A camp site shall be set up for sub-projects. Camp site shall extend over a minimum amount of land and distant to the local residential areas as possible and with the capacity to house workers. Camp site shall be located as far from the locals and local settlements as possible so as to minimize community interaction. Camp sites shall be equipped with such amenities and utilities, electricity, sewage and communications networks, etc. Although the camps are mostly male dominant in this sector, for camps where female workers are hired and/or visiting, contrators will ensure that camp amenities will be accessible for women with appropriate health and safety conditions provided. Camp sites shall have road access, using the existing roads to the extent possible. In cases where accommodation is provided on project site(s), TEIAS shall ensure the observance by contractors of code of conduct and that workers are trained on the provisions of the labor law on good behaviours and harassment-free workplace, interaction with the locals (including women and children) as well as before the job starts. Facilities to be used on project site(s) (health facilities, galleys, etc.) shall be in compliance with the WB standards. The project shall fully observe international labor standards and, as a party to ILO standards, the Turkish Labor Law. Accordingly, child labor, forced labor and discrimination on the basis of race and gender shall not be tolerated. SF6: SF6 is a non-toxic, inert, insulator, coolant, colorless, odorless and non-flammable gas with high dielectric resistance and thermal stability. With a molecular mass 5 times heavier than air, SF6 is one of the known heavy gases, also with a dielectric resistance (at 50 Hz and 1 bar) 2.5-3 times greater than that of nitrogen and air. These values increase in tandem with pressure exceeding the dielectric resistance of the transformer insulation lube at 3 bars. SF6 is a perfect arc-suppression capability thanks to its electronegativity. As the temperature increases as a result of the arc during breaking, this disintegrates SF6, releasing sulphur and fluorine atoms. Flourine atoms with high electro-negativity catches-up with free 31 electrons, reducing arc current down to zero. Following the break, the SF6 gas heats-up (2000 °C) and cools down and fluorine and suplhur atoms reintegrate to form SF6 again, which restores the dielectric environment. Chemically very-stable, SF6 are used in breakers and other installations alike, as well as GIS assemblies in GIS Sub-stations. At its pure state, SF6 gas is not poisonous and enables a safe working environment and therefore, is preffered. 5 times heavier than air, SF6, when released into the atmosphere, is inclined to fill lower spaces. A mix of 20% oxygen and 80% SF6 can be inhaled without detrimental impacts. In the event of any leaks, one must be protected from SF6 that collects above the ground. High concentration of SF6 leakages in closed environments can cause the risk of asphyxiation for staff due to reduced level of oxygen. In this case contaminated area has to be ventilated and evacuated, and proper PPE must be used before re-entry. Vitiated and stale SF6 to fill the environment after the arc can be intoxicating. In this case, OHS principles shall be observed through out work performed with SF6. Furthermore, 1 kg of SF6 released into the atmosphere triggers an un-natural greenhouse effect similar to that of a mid-class gasoline car through 120.000 km (185 g CO2/km). SF6 emissions shall be refrained from as much as possible. Amount of SF6 needed to perform certain tasks shall be minimized. Cultural Assets: Studies for Natural and Archaeological Sites on and adjacent to the project site shall be carried out within the scope of respective Law and regulations. No work shall be carried out on protection sites identified or to be identified on the project site(s). In view of this aim, such areas shall be cordoned off and fitted with signposts and markings, and staff access to these areas shall be restricted. In the event that such measures have been employed by the project, there shall be no significant impacts on cultural and natural assets. 32 A chance-find procedure in line with the Turkish legislation shall be prepared in view of possible chance-finds on the project site, per which respective authorities in the event of a chance-find shall be contacted to ensure that the respective legislation is enforced. Submarine Cables and Interfaces: Forecasted impacts from submarine cables and interface activities include generation of wastes and other impacts on hydrology, flora and fauna, habitat, protected areas, air quality, noise and vibration, traffic, landscape, seabed geology and the quality of seawater. Majority of these impacts are related with conventional construction works but still can be minimized through appropriate mitigations. In addition, physical damages are only possible along the route of the submarine cable and during the laying of the submarine cable on the seabed. Then, there might be low levels of noise and vibration on the seabed. Such impacts as noise, vibration and turbidity that might adversely affect species of marine flora and fauna can also be encountered. Sedimentation and sea-bottom creatures can also be subject to negative impacts during the construction of the submarine cable route. Again, works concerning the submarine cable can possibly affect maritime traffic. There is also the possibility to observe construction-related sedimentation and increased turbidity. However, level of turbidity of the seawater is expected to return to normal once construction works are over. Moreover, other negative impacts such as oil, loubricants and chemical spills from maritime traffic and potential accidents that might negatively impact the quality of seawater. All these impacts have been taken into consideration and it is deemed possible that these impacts can be minimized with appropriate mitigations. Impacts from proposed project activities, mitigations and monitoring requirements are provided in further detail in Annex-A&B 'Sample Mitigation and Monitoring Chart.' This sample chart shall avail as a guide and ESMPs of sub-projects shall be project-specific, with some room also for additional/lesser mitigation and monitoring requirements. Impacts covered under OP 4.12 on Involuntary Resettlement, as indicated before, are discussed also in the project-specific LAPF. Environmental and social assessment documents prepared for sub-projects shall include an impact assessment of the outlines, OP 4.11 on Physical and Cultural Resources and OP 4.04 33 on Natural Habitats. Although this is not a requirement per the Turkish law and regulations in view of the project's servitude right or in cases of presence of cultural heritage within the project's impact zone, it still requires that the environmental assessment touches upon the sensitivity of such an asset as well as makes reference to the correspondence between TEIAS and the Ministry of Culture and Tourism, mitigations as well as monitoring procedures identified. National legislation on chance-finds can be used as it complies with the WB policies. In brief, work on site shall be stopped and Directorates of Culture at the provincial/municipal level shall be promptly notified should any cultural or archaeological assets be encountered. Nobody shall be allowed to move such findings or disrupt the find area, which would otherwise entail ousting or termination fo the contract. Construction shall resume once inspection has been carried out and upon written approval of the authorities. All ESIA/ESMP/Prevention Plan/Checklist documentation for the sub-projects shall include procedures and responsibilities concerning accidental or chance find of cultural assets regardless whether or not the sub-project concerned is in a historical sight. The announcement for the meetings on the 380 kV Lapseki-Sutluce Submarine Cable Project was published in the national daily Star (17.7.2011), local paper Lapseki Gazetesi (District of Lapseki-11.7.2011) and the local paper Ay Yıldız Gazetesi (District of Gelibolu- 16.7.2011). Public consultation meeting regarding the 380 kV Lapseki-Sutluce Submarine Cable Project took place at 10:30 hours on 27.7.2011 in the District of Lapseki, at the Lapseki Municipal Meeting Hall and at 18:00 hours at the coffeehouse of the Sutluce Village in the District of Gelibolu. Public consultation meeting for the 380 kV Lapseki 2- Sutluce 2 Submarine Cable Project, for this very reason, was deemed unnecessary since both locations were in the same vicinity 1 km apart as adjacent settlements. TEIAS shall commission a submarine survey on the impacts on seabed geology, marine habitat (flora and fauna) and seawater quality of the 380 kV Lapseki 3 - Sutluce Submarine Cable and Izmit Gulf Crossing submarine cable. The survey shall also include aquatic flora and 34 fauna data in addition to benthic fauna. Issues pertaining to natural habitats shall be provided in detail in the ESIAs and ESMPs. TEIAS shall employ Turkish and the World Bank standards (whichever is stricter) for sub- projects. These standards, in essence, are related but not limited to issues here-below:  Environmental and Social Impact Assessment  Solid and Hazardous Waste Management  Level of Noise (during construction)  Intense electrical and magnetic fields at the subgrade level (transmission/distribution) and the fence-line (substations)  Use of polychlorinated biphenyls (PCB) in any equipment (ex. transformers, condensators) or in spares. No PCB or PCT shall be used.  Selection of Right of Way  Environmental Audits  Health and Safety  Site Cleaning  Cultural Heritage  Natural Habitats Criteria and standards and other issues pertaining to issues specified above can be found in the Turkish legislation, Pollution Prevention and Reduction Manual of the World Bank and the Environmental Health and Safety Guidelines of the World Bank Group (WBG EHS Guidelines). Requirements of the Turkish legislation in relation with these issues must be fully complied with. In cases where the Turkish legislation does not provide neither any standards or requirements or in cases where the standards of the WB are stricter, then World Bank standards shall be observed. World Bank documents in relation with these matters are the Bank's Safeguard Policies, EA Source-book and Updates, the Pollution Prevention and Reduction Handbook and the Environmental Health and Safety Guide accessible at the World Bank Web. 35 3.2 Stakeholder Engagement and Information Through stakeholder engagement, TEIAS seeks to establish a seamless and mutual process of interaction between parties, who will be potentially impacted by the projects and those that are somehow related to the project (i.e. stakeholders). This process ensures that throughout the project life-cycle (design, pre-construction, construction, operation and decommissioning) a robust participatory process is wee-established to improve active participation of all project stakeholders through the use of a variety of tools and activities. Accordingly, a timely and sustained dialogue between the project affected people and the stakeholders shall be ensured, which would, in turn, make sure that they have equal and ample opportunity to provide their views and feedback. For this project TEIAS shall focus on aspects below as part of stakeholder engagement:  To ensure and sustain a constructive stakeholder engagement process with all stakeholders concerned.  To assess the level of stakeholder interest in and support for the project and ensure that stakeholder views are taken account during project design and the assessment of environmental and social performance.  Throughout the life-cycle of the project, to ensure an effective and comprehensive participatory process involving project-affected people and on matters with the potential to create impact, and to enable instruments required.  To ensure that technically and culturally important project particulars regarding environmental and social risks have been relayed in a timely, understandable and accessible manner.  To provide project affected parties an accessible and comprehensive feedback mechanism enabling them to forward their problems and grievances. Effective stakeholder engagement ensures a 'social license' to further project activities, which is based on mutual trust an, respect and transparent communication between TEIAS and stakeholders. A well-designed stakeholder engagement process shall at once improve decision- 36 making processes as well as project performance through cost and risk management, prevents conflict, enhances corporate policies, provides continuous feedback on matters pertaining to governance, project implementation and impacts and the opportunity to manage stakeholder interactions. In this project TEIAS defines stakeholders concerned as follows: Respective Government Agencies, Governor’s office, Municipalities and the project affected people. With the aim to draw a deadline for public consultation regarding Category B projects that require ESMP or ESIA, coordination with TEIAS Group Directorates shall be ensured, as always been the case, concerning the distribution of brochures about the project and mukhtars shall be provided with respective contact information and feedback from the people shall be collected for a duration of at least fifteen days, which, if applicable, shall then be included in the ESMP. Project-specific information shall be accessible to people through brochures or news pieces including information as to how to relay feedback to the project through the mukhtars. Accordingly, there shall be no deadline for the provision of feedback and other views and grievances, which would facilitate communication with the people in a more flexible time frame. Detailed meetings shall also be arranged for as required for public information. Once the draft ESMP (or the ESIA) has been prepared for the project, it must be made available at mukhtar's offices, together with the brochures introducing the project. At the same time a text along the lines of the sample text below shall be put up on TEIAS website: "The brochure and/or the draft ESMP document in relation with Project XXX is now available at the XXX mukhtar's office. Please notify the mukhtar directly of any comments, ideas you might have or as well the respective TEIAS Transmission and Facility Operations Department or the TEIAS Department of Environment and Expropriation. You can also download the document at: XXX website." Furthermore, an announcement shall also be made on TEIAS' corporate social media accounts that the document is available on the project website. 37 This shall enable stakeholders (government bodies, NGOs, locals, universities, etc.) to have easy access to TEIAS to provide their feedback and views, which should provide them also with further details regarding the project or the ESMP and additional meetings etc. can be arranged for as required. TEIAS held a stakeholder consultation meeting on 25 October 2019 in Ankara. Officials of General Directorate of Highways and General Directorate of Land Registry and Cadastre attended the meeting. In the meeting, the framework documents prepared within the scope of the REIP-AF loan package, the environmental and expropriation processes of the planned projects and the contents of the environmental and social documents were presented. Minutes of the stakeholder engagement meeting, the list of participants and photographs are given at Annex D. The Department of Environment and Expropriation has made a presentation to meeting participants about WB policies including the framework document prepared in relation with the REIP-AF project as well as TEIAS projects. Issues discussed at the meeting were as follows:  Projects included in the REIP-AF package and the ESMP and ESIA reports to be prepared for these projects,  İzmit’te halkın katılımı toplantısı düzenleneceğinden  The previous submarine flora and fauna surveys carried out for SMC projects,  Ulusal mevzuat kapsamındaki projeler için ÇED Yönetmeliği gereğince “ÇED Gerekli Değildir” kararlarının alındığından  The guarantee to employ any and all safety, environmental and social measures throughout construction and operational phases of projects,  Projelerin inşaat süreleri boyunca her 3 ayda bir yüklenici tarafından uygulama raporları hazırlanacağından ve TEİAŞ Bölge Müdürlüklerince yerinde kontrolünün sağlanmasının ardından Genel Müdürlükçe tetkik edileceğinden,  That TEİAŞ's GRM and communication capabilities shall be made available to locals on- site,  and that the final version of the FD shall be published on TEİAŞ and WB websites. 38 Also, satellite images of planned projects have been screened. 3.3 Grievance Mechanism In addition to the nationwide grievance mechanism (Presidential Communication Center) TEIAS also has its own mechanism composed of Feedback/Grievance Boxes used during Environmental and Social Management Plan implementation activities. In this project, TEIAS has so far registered grievances collected in writing and on the phone and notified the World Bank accordingly. Similarly, TEIAS shall make other arrangements regarding the collection, handling and resolution of grievances concerning sub-projects during project activities. Concerns, requests and complaints and grievances project affected people might have regarding the environmental and social impacts of the project shall be handled through the grievance mechanism. Information regarding pre-construction activities such as land acquisition (land consolidation, land acquisition, etc.), the construction schedule and how to access the grievances mechanism of the project as well as other consultations and participatory activities shall be announced to affected communities through TEIAS web site, regional offices concerned. Although not compulsory, a grievance notice has been prepared and provided here (see. Annex C) to facilitate the process. All grievances, recommendations and concerns collected through the grievance mechanism shall be archived for a pre-determined period and resolved. Grievance related statistics shall be continuously notified to the WB. The first draft of the ESMF is published on TEIAS’ web site on 23.10.2019 before stakeholder engagement and public consultation meetings so that respective stakeholders can examine and provide their feedback thereupon. Then, stakeholders’ feedback are feed into the ESMF and the agreed version shall be announced to the public on media and as specified above. Similar to the ESMF, sub-project-specific ESA documents shall also be prepared in English and Turkish before stakeholder engagement meetings in a timely manner to allow people to examine 39 and provide their feedback. Final versions of the site-specific ESA documents shall also be made publicly available once they are revised. TEIAS feedback/grievance boxes shall also be available on site throughout the construction phase of the project, where people will be able to provide their feedback anytime. Sample grievance forms are provided as an attachment to this ESMF. Public consultation meetings schedule as planned by TEIAS before the signature of the loan agreement: 1) Public consultation meeting, Sutluce 2) Public consultation meeting, Izmit Apart from these meetings, TEIAS shall consult with the people on a regular basis, organizing face-to-face meetings as required. Responsible parties as specified in the monitoring plan shall monitor contractor's performance throughout the construction period. TEIAS' Environment and Expropriation Department shall be responsible to carry out the final review of the contractor's bidding documents and ESMP performance against respective specifications. In the event of EIA (as per the EIA regulation in Turkey) TEIAS shall have top responsibility to ensure that the EIA is streamlined with the ESMP. However, the Ministry of Environment and Urbanization shall have the final say on matters regarding the streamlining of the Turkish version of the EIA with specifications. Thus, in the event of variation between the EIA document that has been prepared for the WB and the one prepared for the Ministry of Environment and Urbanization, ultimate authority to review that the EIA document prepared in observance of the provisions of the Turkish legislation as well as the authority to ensure that the two documents are streamlined shall rest with the Ministry of Environment and Urbanization whereby TEIAS shall bear the responsibility to monitor that works progress in tandem with both the EA document prepared as per the Turkish legislation and the ESMP/ ESIA of the WB. 40 4. INSTITUTIONAL ARRANGEMENTS IN VIEW OF ENVIRONMENTAL AND SOCIAL MANAGEMENT As elaborated here-above, in line with WB Safeguard Policies a special assessment shall be carried out on the construction site and site-specific ESAs shall be prepared, which shall essentially be TEIAS' responsibility. This document shall be available in construction tender dossiers. During the construction phase, TEIAS Environment and Expropriation Department shall cooperate with regional directorates to monitor and control the performance of the contractor so as to ensure that works performed are satisfactory in terms of meeting the requirements specified in the EIA performed and TEIAS as the lead authority shall be expected to remedy any discrepancies, if any. From this perspective, quarterly reporting of contractor and site control activities is deemed necessary. TEIAS' Environment and Expropriation Department during operation shall assist the operations department and oversees performance as to its compliance with the requirements specified in the ESA for the operation phase of the project. Authorities at the TEIAS and the Department of Environment and Expropriation shall monitor the environmental and social management performance of project-related TEIAS regional offices. TEIAS shall submit to the World Bank the quarterly monitoring reports for all Category B sub-projects (as per the approved ESA). 41 Table 1. Roles and Responsibilities Responsible Duties/Responsibilities Party The World  Reviewing ESIAs and ESMPs, LAPFs and ALAPs. Bank  Support missions to make sure that the project fits in with WB OPs.  Making the ESMF and the LAPF available to public on WB official website. Contractors  Site-implementation of ESIAs and ESMPs, and update of ESMP, as required, in cooperation with TEIAS.  Acceptance and implementation of respective laws and regulations that have been defined by TEIAS and also covered in tender documents in consultation with the WB.  Sharing ESMPs before construction starts.  Develop 'Chance Find Procedures' as required.  Collecting and resolving all grievances regarding construction.  Ensure continuity of the Grievance Mechanism.  Regular (daily, weekly, monthly, etc.) monitoring of activities defined in ESIA and ESMPs.  Prepare ESMP implementation reports (ESMPIR) TEIAS  Sharing and effective implementation of both the Turkish and English versions of the ESMF, ESIAs and ESMPs, (A)LAPs and LAPF.  Project implementation and management of funds.  Ensure that funds are utilized as per policies and procedures as well as for respective cost items specified in the loan agreement.  Collect field data (using external resources as required) for outcome indicators through the Monitoring and Evaluation unit, which shall be quality-checked and evaluation of the results.  Monitor project progress and report to government bodies concerned as well as the WB management regarding progress, outcomes, possible challenges and solutions.  Ensure correspondence with government bodies, which, also need to be monitored.  Review and approve data in reports for submission to the WB and assess results.  Establish a standalone accounting system to track cash fund flows.  Prepare data required for regular reports as requested by stakeholders.  Employment through the PIU.  Prepare the Project Operational Guidelines in consultation with the WB.  Establish the grievance mechanism and resolve grievances and concerns on both provincial and national levels.  Determine construction contractors.  Reporting to the WB regarding compliance with the safeguards that are directly implemented. 42 ANNEX A. SAMPLE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN FORMAT (ESMP) Responsible Party Indicate name and title of the person/institution to prepare the ESMP and the date the ESMP was prepared. Project Description Provide a brief description of the project. This definition shall include the content of investment, the location and project-specific significant features (such as an adjacent protected area, or other areas of historical, cultural or religious importance) as listed in Annex A. In addition, a brief description of general land use status (agriculture, industry, etc.) and closest settlements shall be elaborated. Locate the project site on the map, if possible. Provide site specific environmental and social baseline data, impacts pertained to the project. Within the scope of the Project, ESIAs shall be prepared for UCs and SCs as well as ESMPs for GIS SSs among the projects included in the REIP-AF loan package. Such information as the project location, environmental and social impacts, near-by settlements, etc. shall be provided in detail in the said documents. For projects requiring land acquisition, also, LAP and ALAP shall be preapared as per O.P. 4.12. 1. MITIGATION PLAN Stage Issue* Mitigation Measures Responsible Body** Construction      43 Operation      *Issues the construction contractor is responsible for shall be specified in tender documents **Issue and measures shall be project-specific (based on an assessment of the location or route of the project). 44 2.MONITORING PLAN When to monitor Why Cost Responsible Party How to monitor parameters - Monitor What are the Where to parameters/variet frequency of parameters? Stage Parameters to monitor ies of monitoring measurements to monitor? parameters? equipment? monitor/continuo us measurement? Construction Operation NOTE: For each bullet in the mitigation plan there shall be a corresponding bullet provided in the monitoring plan. For example, one bullet concerns something specified in mitigation plan regarding noise, it shall appear also in the noise monitoring plan. 45 3. SCHEDULE Start and completion dates for activities below shall be indicated (preferably in graphic format):  Mitigation measures  Monitoring 4. INSTITUTIONAL ARRANGEMENTS Section on this topic shall provide the details of the issues below, including supporting organograms:  Institutional responsibility and procedures regarding measures to be taken and monitoring, their links to environmental management.  Flow of environmental data (reporting, issuers and recipients and the frequency of reports).  Decision-making hierarchy regarding environmental management (sanctions, penalizing decision-making, decision to shut-down, etc.) In brief, here, issues pertaining to how to use monitoring data for a reasonable environmental and social program, who has collected and analyzed such data, who prepared the reports, to whom these reports have been submitted and how frequently, who the initial recipient of these reports have forwarded the reports or what the initial recipient has done with these reports, who is responsible for facility shut-down, operational amendments and expenditures shall be defined. 5. CONSULTATIONS WITH PROJECT AFFECTED PEOPLE AND LOCAL VOLUNTEERING BODIES Public Consultation Meetings to be carried out as part of the EIA process shall be considered within this scope. However, the process below shall be followed for projects requiring the preparation of a PIF. Issues below shall be recorded:  Date of consultations  Venue of consultations  Invitees Name, Institution or Occupation, Tel./Fax./E-mail/Address (home or work)  Participants Name, Institution or Occupation, Tel./Fax./E-mail/Address (home or work) 46  Meeting/Schedule/Calendar, as required What is to be presented, by who?  Brief Meeting/Minutes of the Meeting (Views, Questions and Responses by Presenters), as required. The minutes of the meeting shall also include the names of the TEIAS staff to attend  Activities agreed upon or an agreed monitoring activity and the schedule thereof 47 ANNEX B. SAMPLE MITIGATION MEASURES TABLE FOR UNDERGROUND CABLES, SUBMARINE CABLES AND SUBSTATIONS MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party**  In the event of encountering any cultural assets construction shall stop and respective Cultural and Natural Asset Conservation Boards shall be notified. Cultural and Historical Then, works on site shall stand-by until the response from the Conservation No additional Start of construction Completion of Contractor Assets Board. There shall be no construction. cost. works construction works PRE-  Construction can resume upon affirmative response. INSTALLATION 48 MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party** AND  All unnecessary equipment and wastes shall be separately collected and those, INSTALLATION Disassembly of the which can be recycled shall be forwarded to recycling by a licensed recycling Included in the Completion of existing substation company. Contractor Start of dismantling contract dismantling (substations only)  Asbestos-containing materials shall be disposed of by companies licensed for the disposal of hazardous wastes.  The limit value 1.0 kg/hr. as specified in Table 2.1 in the Regulation on the Control of Air Pollution from Industry regarding emissions from sources other than shafts shall be adhered to for dust and particulate emissions. There shall be spraying/dampening in dry season  There shall be no scattering/blowing during loading and/or unloading. These works shall also be performed in special areas allocated for this purpose so as to prevent scattering/blowing of dust and particles. Also, water shall be sprayed for dampening during such works. Furthermore, workers shall be Completion of Dust-particulate warned for caution during loading and/or unloading. Limit-heights shall be Included in the Contractor Start of excavation excavation determined for loading and/or unloading of materials that can blow off. Wind contract direction shall also be considered during loading and/or unloading.  Trucks shall be covered and there shall be speed limits imposed. Speed limit on project site shall be 30 kmh and 50 kmh in the city.  Exhaust emission permits shall be obtained for all vehicles to be used on project site.  Tires of trucks operated on site shall be washed down before leaving premises (for the streets). 49 MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party** Noise  Work shall be carried out between 7:00 AM to 7:00 PM. In cases where work is required outside of these hours, the local authority and public institutions concerned as well as citizens shall be duly notified in advance.  Those living close-by shall be notified informed throughout construction.  Continuous noise from the worksite shall be compliant with the level (70 dBA) stipulated in the Regulation on the Measurement and Management of Ambient No additional Start of construction Completion of Contractor Noise for daytime. To ensure this, the substation shall be fenced off and walled cost. works construction works off with a protective concrete wall.  Also, in cases where the noise level has increased such measures as not operating heavy machinery simultaneously shall be taken in addition to replacing old machinery with new ones to the extent possible for wear and tear FACILITY is directly proportionate with level of noise. The 3 mg/Nm3 threshold, which is the limit value for dust and particulate emissions stipulated in the Regulation on the Control of Air Pollution from Industry shall not be exceeded. To ensure this;  Spraying and damping shall be ensured in dry season.  There shall be no scattering/blowing during loading and/or unloading. These works shall also be performed in special areas allocated for this purpose so as to prevent scattering/blowing of dust and particles. Also, water shall be No additional Start of construction Completion of Air Quality sprayed for dampening during such works. Furthermore, workers shall be Contractor cost. works construction works warned for caution during loading and/or unloading. Wind direction shall also be considered during loading and/or unloading.  Trucks shall be covered and there shall be speed limits imposed. Speed limit on project site shall be 30 kmh and 50 kmh in the city.  Exhaust emission permits shall be obtained for all vehicles to be used on project site. 50 MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party**  Wastewaters from the construction site shall be discharged to the sewage Wastewaters generated system through the connection that shall be built and in places without sewage, Start of construction Completion of Not high Contractor on construction site such wastewaters shall be collected in impermeable tanks to be emptied with works construction works vacuum/sewage trucks.  Excavation wastes shall be disposed of at the closest licensed dump-site. Not high although  Solid wastes from the use of construction materialssuch as wood and metal and might differ packaging wastes such as glass, paper and plastics shall be collected separately Excavation, solid and depending on the and handed either over to the municipality or a recycling company. Start of construction Completion of hazardous wastes from municipality Contractor  Domestic organic wastes shall be given to the municipality concerned for to works construction works the construction site and/or the be dumped at the Solid Waste Landfill concerned. licensed recycling  Wastes such as oil, paint, etc. shall be separately collected in labeled, metal facility. containers and handed out to a licensed recycling company.  To the extent possible, vehicle maintenance shall not be carried out on the construction site.  Waste oils, grease, etc. from construction machinery and vehicles shall be collected in stainless barrels and disposed of by the contractor, who shall ensure that these wastes are collected by licensed companies. Wastes from the Parking  Barrels shall be stored on impermeable grounds protected from rain and the Start of construction Completion of Not high Contractor Lot sun, and in a covered area, with adequate fire protection. The area housing works construction works such barrels shall be cordoned off. Firefighting kit (buckets, axes, shovels, pick-axes and hoes) shall be available on site.  Such materials as batteries, tires, etc. to generate from the operation of machinery and vehicles shall be handed over to licensed companies for disposal. 51 MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party**  Sub-projects shall be designed in a way to minimize involuntary land acquisition.  An Abbreviated Land Acquisition Plan shall be prepared for a project requiring land acquisition. Involuntary Land  Damages to arise from land acquisition shall be remedied as per legislation Acquisition/Impacts on Included in TEIAS and Upon completion of and the WB policies. Before construction Livelihoods  If there are persons with special needs, who will be negatively impacted by construction costs contractor land acquisition construction works such as the elderly, women and children or persons with disabilities, ad hoc measures shall be put in place so as to ensure that accessibility is sustained.  The impacts of the construction activities on the fishing cooperatives will be assessed. 52 MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party**  Workers shall be provided with all required personal protective equipment such as hard-hats, safety harnesses, OHS overalls, goggles, gloves, hard-shoes, etc.  Signposts that read 'Caution,' 'No trespassing,' 'Restricted Entry;' etc. shall be placed in view of safety of the locals.  Workers shall receive 'Occupational Health and Worker Safety' training. Before construction starts, all workers shall be informed about statutory safety and security issues to observe on site, and about risks throughout the construction period as well as regulations in relation thereto.  Measures against landslides or subsidence shall be ensured (such as using aluminum, steel or wooden supports). No worker shall be allowed on site until Occupational Health and Within project Start of construction Completion of required measures have been taken. Contractor Worker Safety budget works construction works  The contractor shall take measures in line with respective regulations so as to protect and improve occupational health and safety as well as to ensure good working conditions.)  The contractor shall treat all workers equally and fairly, ensuring equal conditions for all.  In the event of any incidents to threaten the environment or occupational and/or public health and safety, the contractor shall expeditiously notify TEIAS therof, who shall further notify the World Bank in three days. Detailed report on the accident including the root-cause analysis as well as information on post-accident measures employed and on damages and remedies shall be submitted to TEIAS and the World Bank in 30 days. 53 MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party**  Construction site shall be restored. Within project Completion of Commissioning of Landscaping  No hazardous, solid, liquid and/or construction wastes shall be left behind Contractor budget construction works the substation inside the area.  All agreed natural habitats, wetlands and protected areas in the vicinity of the work site shall be protected and not exploited or used in ill faith. Staff shall not hunt, go about looking for food, cut trees or act in other detrimental ways, which shall be strictly prohibited. Within project Start of construction Commissioning of FACILITY Habitat (flora/fauna)  Such measures as use of bales of hay or silt curtains/fences shall be employed Contractor budget works the substation against erosion and subsidence so that wetlands and streams are protected against flows from the construction site.  No unlicensed quarries, material pits or waste dumps shall be availed around the vicinity and especially around protected areas. 54 MITIGATION MEASURES Responsible Stage Issue Measures*** Cost Starting Date Completion Date Party**  The ESMP shall be made available to the public for ease of receiving feedback from the people.  Project info-sheets including the construction schedule shall be prepared (such as Public Consultation and posters, fliers, brochures, etc.) No additional Contractor Start of construction Completion of Access to Information  A grievance mechanism shall be established and promoted to the people. cost. TEIAS works construction works  Meetings will be conducted with the locals about project components and project activities.  People shall be informed about traffic arrangements The contractor shall be responsible to duly secure the construction site as per national legislation as well as to regulate construction-related traffic. Related measures shall include but not limited to the following:  Traffic signposts, warning signs, barriers and service roads; the site shall be clearly visible and people shall be warned regarding potential dangers.  Staff shall be trained especially about site access and the heavy traffic around the site and a traffic management system shall be established. In areas where Traffic and Pedestrian construction traffic crosses paths with the locals, safe crossing facilities and zebra Within project Start of construction Commissioning of Contractor Safety crossings shall be provided for pedestrians. budget works the substation  Working hours shall be arranged in view of local traffic. For instance, significant transports shall be refrained from at times of commute and movement of herds.  Trained and visible on-site staff shall ensure active traffic management at times when people require safe and due crossing.  In cases where building rehabilitated are open and continue receiving people, safety and security of access to offices, shops and residences shall be ensured at all times and without interruption. 55 Responsible Stage Issue Measures*** Cost Starting Date Date of Completion Body**  Regulatory thresholds (Ldaytime:65 dBA, Lnight time:55 dBA) shall not be exceeded with reliance on the Regulation on Measurement and Management of Ambient Noise. Under operation Commissioning of End of economic life Noise  Substation equipment shall be compliant to the International Electric TEIAS budget the substation of substation Commission (IEC) 60076-10 standards as well as other international standards to ensure (≤70 dBA).  The perimeter of the substation shall be fenced-off.  Such limit values specified in the International Commission on Non- OPERATI Ionizing Radiation Protection (ICNIRP) as 5 kV/m electrical field (for ON people), 1000 mG (24 hrs/d) for magnetic fields, 10 kV/m electrical field (for workers) and 5000 mG (8 hrs/d) for magnetic field shall be satisfied. To ensure this;  During the procurement of all substation equipment (transformer, breaker, separator, surge protector, current voltage transformer, etc.) the IEC or other EMF (Electrical and international standards shall be observed. Reinforcement on this basis shall Under operation Commissioning of End of economic life TEIAS Magnetic Fields) follow controls and renovation. budget the substation of substation  A wall shall be built around the substation to prevent entry, approach and settlement.  The substation building, equipment, the wall and the fence shall be grounded. In the event of any signs (such as malfunction of equipment, increased contact currents, electrical arcs, local heating, etc.) the grounding voltage shall be measured and unfit grounding shall be rectified through local replacement/renovation and by ensuring seamless connectivity, etc.  Teams to operate, maintain and repair the substation shall be trained on such Not high Commissioning of End of economic life Health and Safety issues as electrical safety, firefighting, working at heights and first-aid. (Under operation TEIAS the substation of substation  Around the substation shall be warning signs and mounting preventers. budget) 56 Responsible Stage Issue Measures*** Cost Starting Date Date of Completion Body**  The substation to be set up as per the fire safety principles set out in the Regulation on Electrical High Current Facilities shall be regularly controlled including control, test, maintenance, repair and replacement of Not high Commissioning of End of economic life Risk of fire all equipment (bushing, SF6, insulation oil, cable terminal caps and gas (Under operation TEIAS the substation of substation seeps, etc.) budget)  All equipment are tested per national as well as international standards against arc and sparks.  SF6 gas shall be continuously monitored through heat-reasistant pressure devices and gas seeps shall be inspected. In the event of any gas seeps Not high (under Commissioning of End of economic life SF6 Gas (Before SF6 gas density drops below critical level) the system shall TEIAS operation budget) the substation of substation automatically turn on and block-close. OPERATI  Workers shall be informed about safe operations. ON  Physical and chemical analyses of oils shall be carried out on a regular basis Not high Commissioning of End of economic life Transformer Oil and in the event of expiry of usability, such oils shall be replenished. (Under operation TEIAS the substation of substation  Waste oil shall be tested for category determination and duly disposed of. budget)  Solid wastes and scrap materials as well as construction wastes shall be Not high although separately collected for disposal by municipalities or licensed recyclers. varies between Solid, Liquid and Commissioning of End of economic life  Pick-up by the municipality of domestic organic wastes shall be ensured, municipalities TEIAS Hazardous Wastes which shall be dumped at the Solid Waste Landfill concerned. the substation of substation  Wastes such as oil, paint, etc. shall be separately collected in labeled, metal and/or licensed containers and handed out to a licensed recycling company. recycling plant **Applies when works concerned are awarded to any Contractor. Otherwise, responsibilities defined for the Contractor shall rest with TEIAS. ***All Regulations concerned shall be observed as these measures are employed (i.e. Regulation on the Control of Air Pollution from Industrial Facilities, Regulation on Control of Water Pollution, Regulation on the Assessment and Management of Ambient Noise, Regulation Concerning Pits to be Built in Areas where Sewage Construction is not Possible, Regulation on the Control of Solid Wastes, Regulation on the Control of Soil Pollution, Regulation on the Control of Excavated Soil and Demolition Debris, Regulation on Packaging and Control of Packaging Wastes, Regulation on the Control of Hazardous Wastes, Regulation on Grounding in Electrical Facilities, Occupational Health and Safety Regulation, Regulation on Safety and Health Signage, Regulation Regarding the Use of Personal Protective Equipment at Workplaces, Regulation on Health and Safety Conditions Regarding the Use of Work Equipment, etc.). 57 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue Solid Waste Regulation on the Control of Excavation Soil and  Adequate solid waste collection shall be ensured on Construction and project site. Demolition Debris  Excavation wastes generated during the construction Regulation on the Control Within of interfaces shall be disposed of at licensed dump- Completion of of Solid Wastes project Excavation start Contractor sites. excavation Regulation on the Control budget  Recyclable packaging wastes shall be handed over of Packaging Wastes to licensed recyclers for recycle and those that cannot In view to minimize Regulation on the Control be recycled shall disposed of at dump-sites licensed environmental impacts, to of Hazardous Wastes by the Lapseki and/or other municipalities. ensure disposal as per Construction respective regulation of Wastes Waste Oil/Fuel excavation and solid and  Used oils from vehicles or equipment shall be stored hazardous wastes to temporarily in barrels. generate during project  Barrels shall be stored on impermeable grounds construction. protected from rain and the sun, and in a covered area, Within with adequate fire protection. Barrel storage area shall Regulation on the Control Completion of project Excavation start Contractor be fitted with warning signs and the set of fire of Waste Oils excavation budget extinguishers must be available.  Vehicle maintenance shall not be performed on site except for emergencies.  Waste oils shall be given to PETDER for disposal through recycling or reuse. 58 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue Solid and liquid waste from workers In view to minimize  Domestic wastes shall be disposed of landfills environmental impacts, to licensed by the municipality. ensure disposal as per Regulation on the Control Within  Wastewaters from the construction site shall be respective regulation of of Solid Wastes Completion of Wastes project Excavation start Contractor connected to the municipal sewage (through existing excavation and solid and Regulation on Water excavation budget toilets if possible and if not through mobile on-site hazardous wastes to Pollution toilets). generate during project construction.  3 mg/Nm3 limit value for dust and particulates shall not be exceeded.  Spraying and damping shall be ensured in dry To reduce emissions of season. dust from excavation on Construction  There shall be no scattering/blowing during project site and to ensure loading and/or unloading. These works shall also be that limit values specified performed in special areas allocated for this purpose in the regulation are not so as to prevent scattering/blowing of dust and exceeded. In addition, to Regulation on the Control Within particles. Also, water shall be sprayed for dampening gauge emissions from Completion of Air Pollution of Air Pollution from project Excavation start Contractor during such works. Furthermore, workers shall be vehicles and equipment to excavation Industry budget warned for caution during loading and/or unloading. reduce the emission into Wind direction shall also be considered during the atmosphere of exhaust loading and/or unloading. CO2 and other substances  Trucks shall be covered and there shall be speed so as to minimize limits imposed. Speed limit on the project site and its fluctuation of ambient air vicinity shall be 30 kmh and 50 kmh in the city. quality.  Exhaust emission levels for all vehicles to be used shall be approved and permitted. 59 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue  In the event of encountering finds of cultural or Historical, archaeological values during project excavation No Cultural and works, all works shall be suspended and the Ministry Aim is to conserve and Completion of ― additional Excavation start Contractor Archaeologic of Culture and Tourism shall be notified and protect cultural assets. excavation cost. al Assets construction activities shall resume only after permission.  Work shall be carried out between 7:00 AM to 7:00 PM. In cases where work is required outside of these hours, the local authority and public institutions To ensure that locals concerned as well as citizens shall be duly notified in around the vicinity of the advance. project site are not  People living around the vicinity of the project site Regulation on the Construction impacted by way of Noise and shall be informed throughout construction. Measurement and No additional Completion of ensuring the level of noise Excavation start Contractor Vibration  The level of noise pollution from the construction Management of Ambient cost. excavation and vibration pollution of interfaces, laying of the submarine cable and Noise during works is well during excavation shall not be exceeding 70 dBA. beyond the values  Heavy machinery and vehicles shall be specified in the regulation. periodically inspected so that specified noise levels are not exceeded and new machinery shall be used to the extent possible. 60 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue  Risk assessment studies will be implemented. Workers shall be provided with all required protective equipment such as hard-hats, safety harnesses, OHS overalls, goggles, gloves, hard-shoes, etc. To prevent possible work Community  Staff shall be trained on occupational health and accidents during the laying and Within safety. Throughout the construction phase, all staff of cables and connectivity Occupational Health and Completion of Occupationa project Excavation start Contractor shall be informed about security rules on-site as well work during construction Safety Regulation excavation l Health and budget as risks and other regulations to follow. as well as to ensure safety Safety  Along the excavation route warning signs shall be of workers and the people. placed for public security and entry to the construction site shall be controlled and prevented by tapes, barriers and phosphorescent warnings.  Transportation of materials for use during project construction and building works outside of the project Aim is to prevent possible Within Traffic Completion of site might impact traffic in the area. traffic accidents in and ― project Excavation start Contractor Safety excavation  Speed limit on the project site and its vicinity shall around the project area. budget be 30 kmh and 50 kmh in the city.  Lower limit values specified for electrical and Regulation on Measures EMF To ensure that magnetic fields regarding cables and materials used to be Employed for the (Electro- international thresholds Under Expiry of the shall be ensured in respect of international standards Protection of Environment Commissioning magnetic regarding the impact on the operation economic life TEIAS Operation Phase (Electrical field 5 kV/m and magnetic field 1000 mG; and People from the of the cable Field environment of budget of the cable for workers electrical field 10 kV/m and magnetic Effects of Non-ionizing Strength)* electromagnetic fields. field 5000 mG). Radiation To prevent possible work Not high Community  Teams to carry out the maintenance, control, Expiry of the accidents during Occupational Health and (under Commissioning and repair and operation of the submarine cable, interface economic life TEIAS maintenance/repair and Safety Regulation operation of the cable Occupationa locations and connection lines shall be selected from of the cable operation of cables during budget) 61 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue l Health and among those trained on such issues as electrical operation as well as to Safety safety, firefighting and first-aid. ensure safety of workers  Warning signs shall be placed along the cable and the people. route. Regulation on the Control of Solid Wastes To prevent damaging Regulation on the impacts of wastes on Solid, Liquid Control of Packaging  Solid wastes to generate during the maintenance people and the Within Expiry of the and Wastes Commissioning of the cable shall be collected separately and handed environment as well as to project economic life TEIAS Hazardous Regulation on the of the cable over to the respective municipality. ensure that wastes are budget of the cable Wastes Control of Hazardous disposed of in observance Wastes of regulations. Regulation on Water Pollution Plan of Measures Concerning the Laying of the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue Target is to provide regular Regulation on the Control Air Pollution  Vehicles, equipment and motors to be used during maintenance for power of Air Pollution from and Construction the laying of the submarine cable shall be regularly engines, UPSs and other Industry Pollution Within project Completion of maintained. equipment to be used Regulation on the Excavation start Contractor from Noise budget excavation  New equipment and vehicles shall be used to the during the laying of the Measurement and and extent possible. submarine cable so as to Management of Ambient Vibration reduce exhaust/smoke Noise 62 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue emissions and pollution from noise. To protect biological and Impact on  With reliance on data from surveying of the physical aspects of the No additional Completion of seabed project route, geologically sensitive areas shall be project are and to minimize ― Excavation start Contractor. cost. excavation Geology refrained from to the extent possible. damages thereupon throughout construction.  Works concerning the laying of the submarine cable and during the connection of the latter to the underground cable shall be carried out with utmost Impact on caution and in the event of any damages on the coast Not to incur permanent the Marine or on the near-coastal areas at the end of such works damages on the marine No additional Completion of Environment in these areas, rehabilitation shall follow. environment and not to Bern Convention Excavation start Contractor. cost. excavation , Flora and  In view to prevent any accidents during the laying disrupt the marine Fauna** of the submarine cable (such as any spills or leaks into ecosystem. the marine environment of oil/fuel from vehicles), cable-laying vessel shall be equipped with barriers, booms and other emergency equipment.  The cable route has been so selected as not to be To ensure that maritime Maritime No additional Completion of in the vicinity of the transportation network (access traffic is not hampered and ― Excavation start Contractor. Traffic cost. excavation points, ferries, speed boats, etc.). to prevent accidents at sea. 63 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue  Ministry of Transport, governors concerned, and Provincial Maritime Undersecretaries shall be informed regarding the cable route and works in relation thereto.  Stakeholders concerned in the field of impact of works (locals, fishing ports, etc.) shall be informed.  The impacts on the fishing cooperatives will be Impacts on To prevent adverse Pre- assessed and appropriate mitigation measures will be No additional Operational TEIAS and local impacts on fishing - construction taken, based on the results of the assessment, if cost phase Contractor fisheries activities phase required.  Turbidity on the seabed from excavation shall clear away naturally in a matter of days. To prevent sudden Quality of Regulation on the Control No additional Completion of  There shall be no unnecessary excavation, which disruption of the quality of Excavation start Contractor. Sea Water of Water Pollution cost. excavation shall not lead to significant turbidity and impact the sea water. quality of the seawater.  Lower limit values specified for electrical and Regulation on Measures to EMF To ensure that magnetic fields regarding cables and materials used be Employed for the Operati (Electro- international thresholds Under Expiry of the shall be ensured in respect of international standards Protection of Environment Commissioning on magnetic regarding the impact on the operation economic life TEIAS (Electrical field 5 kV/m and magnetic field 1000 mG; and People from the of the cable Phase Field environment of budget of the cable for workers electrical field 10 kV/m and magnetic Effects of Non-ionizing Strength)*** electromagnetic fields. field 5000 mG). Radiation 64 Mitigation Plan for the Submarine Cable Environmen MEASURES Dates Project Responsible tal Cost Phase Measures Purpose of Measures Regulations to Follow Start Completion Party Impact/Issue  Teams to carry out the maintenance, control, To prevent possible work Community repair and operation of the submarine cable, interface accidents during Not high and locations and connection lines shall be selected from maintenance/repair and Expiry of the Occupational Health and (under Commissioning Occupationa among those trained on such issues as electrical operation of cables during economic life TEIAS Safety Regulation operation of the cable l Health and safety, firefighting and first-aid. operation as well as to of the cable budget) Safety****  Warning signs shall be placed along the cable ensure safety of workers route. and the people. 65 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? In the event that cultural assets have been encountered, Not high in the Provincial New cultural To ensure streamlining Cultural and monitoring shall event that any Directorate of assets possible to At the construction with the Law on the Start of construction Completion of FACILITY Historical Visual monitoring be carried out by cultural assets Culture and encounter in the site Conservation of Cultural works construction works Assets authorities from have been Tourism project area and Natural Assets the Cultural and damaged Natural Assets Conservation Boards. 66 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? Substation components and installation TEIAS Dismantling of No additional At the construction Throughout Environmental Law and Start of construction Completion of the existing Visual monitoring costs (within site dismantling Regulations Concerned Regional works construction works substation project budget) Unnecessary Directorate equipment and wastes 67 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? Dust from the mobility and exhaust of Visual monitoring Weekly during TEIAS No additional excavation and excavation/during Regulation on the Control At the construction cost. Start of Completion of Dust-particulate construction Interviews at near- intensive of Air Pollution from Regional site Within project construction works construction works machinery by settlements construction/upon Industry Directorate budget (mg/Nm3) complaint Public grievances Sound measurement using audiometer Weekly visual TEIAS Level of noise Regulation on the (noise level observations Measurement and Start of construction Completion of FACILITY Noise On construction site measuring device) Not high Regional Management of Ambient works construction works Upon people's Directorate Public grievances Noise Interviews at near- complaint by settlements 68 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? Visual observation (of whether or not waste waters are Connection to the discharged in areas TEIAS sewage system where discharge is To ensure adherence to the Connection to the Wastewater not permitted and of Weekly (flash Regulation on the Control of No additional Regional sewage system Start of construction Completion of FACILITY from Pollution, turbidity, documents checks and Water and Soil Pollution costs (within Directorate and substation works construction works construction site smell in water and regarding whether or controls) and on Locally Polluted project budget) soil at the not waste waters Sites substation area have been disposed Municipality of through connection to the sewage system) 69 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? To ensure compliance with Regulation on the Control of TEIAS Solid Wastes, Regulation on the Control of Soil Pollution Regional Excavation, and Locally Polluted Sites, Directorate solid and Smell, Storage and Regulation on the Control of No additional On construction and Start of construction Completion of FACILITY hazardous Conditions for Visual Weekly (flash Hazardous Wastes, costs (within Contractor. dump sites works construction works wastes from the Disposal checks and Regulation on the Control of project budget) construction site controls) Excavation Soil, Construction and Municipality Demolition Debris and the Regulation on the Control of Waste Oils 70 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? To ensure disposal of wastes in observance of regulations on the control of hazardous wastes, on the control of waste oils, waste batteries, Wastes from the Start of construction Completion of FACILITY At the car park expired tires Contractor. car park works construction works Waste oils, Not high batteries, expired Inspection and During breakdown although might tires and scrap control of vehicle or periodical differ depending electronic on-board inspection maintenance on the a licensed materials documentation recycling facility. 71 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? Documentation for training on health and safety At the beginning of Training each work certificates to prove training No additional TEIAS To ensure adherence to the Health and participation At the construction cost. Start of construction Completion of Visual Regulation on Occupational Safety site Within project Regional works construction works Health and Safety Safety equipment budget Directorate used on construction site Daily such as hard hats, gloves, shoes, safety harnesses, etc. 72 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? Land acquisition TEIAS Upon completion of Land acquisition No additional Involuntary Land reports, court files and economically construction works Acquisition/Impa At and around the and registries, As a requirement of cost. Before construction displaced people cts on facility complaints received Continuous Regional and during (impacted legislation and OP 4.12 Within project works Livelihoods in relation with livelihoods) Directorate operation phase, as livelihoods budget required Wastes (excavation, solid, TEIAS No additional liquid, hazardous, To ensure adherence to the During site close- cost. Completion of Commissioning of Landscaping etc.) At substation area Visual Environmental Law and Regional down Within project construction works the substation regulations Directorate CONSTRUCT budget Excavated/dug ION roads and areas TEIAS No additional Negative impacts To ensure adherence to the cost. Start of construction Completion of Habitat on the flora/fauna at Project Site Visual Continuous Environmental Law, Regional Within project works construction works project site regulations and the ESMP Directorate budget 73 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? TEIAS No additional To ensure adherence to the Placement of signs, cost. Start of construction Completion of Traffic Project Site Visual Continuous Environmental Law, Regional vehicle speed, etc. Within project works construction works regulations and the ESMP Directorate budget 74 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? On the border of the TEIAS Level of noise substation Interviews with Control of whether or not Upon complaint (as Commissioning of End of economic Noise dwellers of near-by values specified in the Not high Regional required) the substation life of substation In near-by settlements regulation have been met Directorate Public grievances settlements Distance from substation wall/fence Visual monitoring Before the To ensure adherence to the OPERATION Documentation commissioning of TEIAS Inside and in the Interviews with Regulation on Measures to regarding the the substation area of the dwellers of near-by be Employed for the Commissioning of End of economic EMF procurement of Not high Regional substation settlements Protection of Environment the substation life of substation substation When there is a Directorate and People from the Effects equipment and problem with Grounding of Non-ionizing Radiation fittings grounding measurement Ground resistance (ohm) 75 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? Technical Training (Operation and Maintenance) TEIAS To ensure adherence to any No additional Throughout Health and and all Occupational Health cost. Commissioning of End of economic Protective At substation area Visual operation (at Regional Safety and Safety-related (Under operation the substation life of substation equipment and suitable intervals) Directorate regulations budget) overalls (whether or not used by workers) 76 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? OPERATION Upon risk of fire SF6 gas pressure, cable terminal caps, Once every six TEIAS With technical tests No additional months in the event To ensure adherence to fire and standard cost. Commissioning of End of economic Risk of fire insulators, At substation area of aby failures or as safety principles specified in Regional maintenance works (Under operation the substation life of substation required by the the Regulation on Electrical Directorate performed by budget) cable connections electrical system High Current Facilities, for control teams the maintenance of worn Primary and out, broken sections, as well secondary controls as to prevent the risk of accidents and shortages To ensure adherence to the TEIAS Environmental Throughout To ensure adherence to Law and Commissioning of End of economic SF6 Gas SF6 gas pressure At all sections With pressiometer operation Regional regulations concerned regulations the substation life of substation (continuous) Directorate As a requirement of operations 77 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? TEIAS Characteristic Transmission features of oil Construction and daily/weekly/mont No additional (density, acidity, Operation Group Transformer hly as a result of a costs (within Commissioning of End of economic fluidity, spark In transformers Test Methodology Oil quality control Directorate Oils failure every two operational the substation life of substation point, corrosive years budget) sulphur, PCB, Department of color) Transmission Line Operation and Maintenance 78 MONITORING TABLE When to monitor How to monitor parameters - What are the Where to monitor parameters/varieti frequency of Why monitor Control Date of Stage Issue Cost Starting Date parameters? parameters? es of monitoring measurements to parameters? authority Completion equipment? monitor/continuo us measurement? Pollution generated within the Throughout substation area operation To ensure adherence to Not high (wastes, smell, etc.) Regulation on the Control of although varies Soil Pollution and Locally between Solid and Visual Polluted Areas, Regulation municipalities TEIAS hazardous Upon failure, on the Control of Hazardous and/or licensed wastes Wastes from failed breakdown and Wastes and the Regulation recycling plant Transmission generated equipment and At substation area expiry of economic on the Control of Waste Oils Construction and Commissioning of End of economic OPERATION during fittings life of equipment Operation Group the substation life of substation operations Directorate (batteries, waste oils) Pollutants in waste To ensure adherence to the Not high transformer oils Upon expiry of the Regulation on the Control of although depends (Arsenic, Test methodology economic life of Waste Oils on the Cadmium, Lead, transformer oils measurement Total Halogens, company PCB, spark point) 79 Submarine Cable Monitoring Plan Dates Environment When to monitor Project Where to al What parameters to Why monitor How to monitor parameters? Cost Completio Control authority Stage monitor Start Impact/Issue be monitored? parameters? parameters? (measurement n parameters? frequency) In the event that cultural assets have Not high in To ensure been encountered, the event Provincial streamlining with monitoring shall be Cultural and New cultural assets that any Completion Directorate of the Law on the Along the carried out by Excavation Historical possible to encounter in Visual monitoring cultural of Culture and Conservation of cable route authorities from the start Assets the project area assets have excavation Tourism Cultural and Cultural and been Natural Assets Natural Assets damaged Conservation Boards. Construction Dust from the mobility During excavation No TEIAS and exhaust of Application of Visual monitoring Weekly during additional excavation and the Regulation on Completion Dust Along the excavation/during cost. Excavation 2. Transmission construction machinery the Control of of Emissions cable route Interviews at near-by intensive Within start Construction and (mg/Nm3) Air Pollution excavation settlements construction/upon project Operation Group from Industry grievances budget Directorate Public grievances Application of Interviews at near-by TEIAS Weekly visual the Regulation on settlements Air Quality Public grievances observations Within Completion the Measurement Along the Excavation 2. Transmission and Noise and project of and Management cable route Sound measurement using start Construction and Vibration Level of noise (dBA) Upon public budget excavation of Ambient audiometer (noise level Operation Group grievances Noise measuring device) Directorate 80 Documentation for training on health and To ensure No TEIAS Community safety On adherence to the At the beginning of additional and construction Completion Regulation on each work cost. Excavation 2. Transmission Occuparitonal Safety equipment used sites (along Visual Monitoring of Occupational Within start Construction and Health and on construction site by the cable excavation Health and Daily project Operation Group Safety workers such as hard route) Safety budget Directorate hats, gloves, shoes, safety harnesses, etc. To ensure TEIAS adherence to the Plastic tape, barriers, Traffic Safety Environmental 2. Transmission phosphorescent No Completion and Law and Along the Throughout Excavation Construction and warning lights Visual Monitoring additional of Maritime regulations cable route construction start Operation Group cost. excavation Traffic* Directorate Traffic load To ensure public safety Municipality To ensure that The measures identified local fisheries are No as a result of the impact Cable Discussions with the fishing Throughout project Prior to TEIAS Livelihoods not adversely additional Operation assessment are locations cooperatives lifetime construction Contractor affected from the cost implemented project activities To ensure TEIAS compliance with Regulation on the 2. Transmission Solid, Liquid and Control of Solid Cable route Construction and Construction Solid, Liquid Hazardous Wastes Within Completion Wastes, (on Visual and with Weekly (flash Excavation Operation Group and Hazardous project of Regulation on the construction documentation check checks and controls) start Directorate Waste Storage and Conditions budget excavation Control of Soil site) for Disposal Pollution and Contractor. Locally Polluted Sites, Regulation Municipality 81 on the Control of Hazardous Wastes, Regulation on the Control of Excavation Soil, Construction and Demolition Debris and the Regulation on the Control of Waste Oils TEIAS No Discharge to Observance of additional 2. Transmission the sewage Completion Liquid Waste the Regulation on Visual and discharge permit Weekly (flash costs Excavation Construction and system of (wastewater) the Control of or sewage documents checks and controls) (within start Operation Group excavation Water Pollution project Directorate Cable route budget) Municipality To ensure waste disposal as per Inspection and control of regulations on Waste oils, batteries, vehicle inspection the control of During breakdown Within Completion expired tires and scrap At the car documentation Excavation waste oils, or periodical project of Contractor. vehicle parts and park start batteries and maintenance budget excavation materials Control of documentation on control of waste management batteries and expired tires 82 To control TEIAS Public grievances whether End of EMF (Electro- Within Commission international and Interviews with dwellers in economic 2. Transmission magnetic Field Electronic field (V/m) Cable route Upon grievances project ing of the national near-by settlements life of Construction and Strength)** and magnetic field budget cable reference values substation Operation Group (Amperes) strengths are met or not Directorate Technical Training Before operation (Operation and To ensure Maintenance) During No TEIAS Community adherence to any maintenance and additional End of and and all Cable Commission Protective equipment repair cost. economic 2. Transmission Occupational Occupational route/connect Visual and document checks ing of the and overalls (whether (periodically as (Under life of Construction and Health and Health and ions cable or not used by workers) required) operation substation Operation Group Safety*** Safety-related budget) Directorate regulations Operation Phase Signposts/warning Once before signs commissioning To ensure adherence to the Regulation on the Control of Solid TEIAS Wastes, Regulation on the During the 2. Transmission Failed equipment Control of Soil End of Solid, Liquid maintenance of the Within Commission Construction and wastes Pollution, Visual and checking the waste economic and Hazardous Cable route cable project ing of the Operation Group Regulation on management documents life of Waste budget cable Directorate Used cable wastes Locally Polluted substation During breakdown Sites, Regulation on Water Municipalities Pollution, and the Regulation on the Control of 83 Hazardous Wastes 84 ANNEX C. GRIEVANCES FORM AND GRIEVANCE CLOSEURE Grievance Form Ref.No. Name and Surname Although provision of a name and surname is not mandatory, one must not forget certain problems might be experienced as a result of lack of information during the process of assessment of grievances and the provision of feedback in relation thereto Please Specify how you would like to be Please provide details as to contacted your preferred method of contact E-mail Telephone Mail Other Province/District/Village/Neighborhood Tarih Complaint Category 1. Leaving (hospital, condo) 2. Project impacted assets/property 3. Infrastructure 4. Reduced/entire loss of income 5. Environmental problems (ex. pollution) 6. Employment 7. Traffic, transportation and other risks 9. Other (please specify) Description of Complaint What Happened? When? Where? What are the outcomes from this matter? What would you like done to resolve this matter? Signature: Date: 85 Grievance Closure Form Grievance Closure No. Emergency Action: Actions in the long run (if needed): Any requirement for [ ]Y [ ]N damages? CONTROL OF REMEDIAL ACTION AND DECISION Stages of Remedial Action Deadline and Responsible Bodies 1. 2. 3. 4. 5. 6. 7. 8. DAMAGES AND FINAL STAGES This section shall be filled in and undersigned by the complainant after receipt of payment for damages and upon remedy of the concern of the complaint. Notes. Complainant Authorized Body/Company Name-Surname and Signature Representative Title, Name-Surname and Signature Date: .../.../...... 86 ANNEX-D MINUTES OF THE STAKEHOLDER ENGAGEMENT MEETING AND THE LIST OF PARTICIPANTS 87 88 89 90 91 ANNEX E. METHODOLOGY OF FLORA/FAUNA STUDIES At the initial preparatory stage of Flora-Fauna studies, the impact zone and the study area are determined on Google Earth by taking into consideration the '.kml satellite data file' for the Power Transmission Facility concerned. Feedback from institutions regarding the Power Transmission Facility (UC, PTL, SS) are examined. Before commencement of field works, information on such topics as topography, the climate and existing meteorological conditions in the area are studied, which are the determinants of site preparation criteria. Literature review of the flora and fauna aspects of the work site is carried out for further information on species of plants and animals that will be encountered. Flora (Vascular Plants) - Working Methodology The work of literature that provides the basis for literature reviews regarding Turkey's flora is the Türkiye Bitkileri Listesi-Damarlı Bitkiler (List of Plants of Turkey-Vascular Plants) by Güner et al. published by the Turkish Flora Studies Association in 2012, the website at https://www.tubives.com and the book entitled Flora of Turkey and the East Eagean Islands (Davis 1965-85; Davis et al., 1988; Güner et al., 2000). Such organs as roots, stems, leaves and flowers of plants required for type definition of herbacious or arboreal plants are studied during site studies to determine taxons of plants as well as bulbs of underground species. Species identified during such field research are then photographed for further use in literature studies. Regarding plant samples to be collected during field work such information as to their range, habitat, elevation and date of collection are entered in the field log. Samples pressed on-site as per herbarium technique are dried. Study area shall be meticulously scanned to determine species that are classified as endangered or endemic as per IUCN. Data on the flora of the research area pepared following field work and literature review is presented in the report prepared for EIA purposes, in a table format. 92 Methodology of Fauna Studies Such data as droppings, footprints, remnants of food of mammals encountered in the study area are examined to determine mammal species in the area of work. Questionnaires are also carried out in the study area for further information on mammal populations in the area of work. Also, information regarding possible mammals in the area of work is obtained from http://www.tramem.org/. The number of tracks and signs observed throughout the field work also provide information on the mammal population in the area. Birdwatch activities are carried out from dawn until dusk inside the PTL area for an inventory of birds living in the area. Furthermore, scientific studies previously carried out in the area are reviewed. In general, for birds, crest and/or linear observations are carried out. Field studies concerning the determination of reptilian and amphibian species start with the identification of such habitats along the study-line at the PTL and research is focused accordingly. Before field work information on reptilians and amphibians possible to encounter in the study are is obtained from www.turkherptil.org. Since such field work purports the risk of injuries, researchers shall wear thick gloves and work with a stick to work with reptilians. Study area shall be meticulously scanned to determine species that are classified as endangered or endemic as per IUCN. Data on the fauna of the study area compiled through field work and literature review is provided in the ESIA in table format. 93 ANNEX F. Format of ESIA 1. REGULATIONS, LAWS AND LEGAL FRAMES 2. PROJECT DEFINITION 2.1 The Overall Objective and Description of the Project 2.2. Basic Information on Project Sites 2.2.1 Project Routes 2.2.2. Project Area 2.2.3. Characteristic Features of the SC 2.2.4. Project Technical Information 2.2.5. Characteristics of Interface Locations 2.2.6. Marine Works 2.2.7 Project Stages 3. ENVIRONMENTAL IMPACT OF THE PROJECT 3.1 Impact Classification per Impact 3.2 Potential Environmental Impacts During Construction 3.3 Potential Environmental Impacts During Operations 3.3.1 Interface Locations: 3.3.2 Sub-marine Cable: 3.3.3 Underground Cable: 3.4 Potential Environmental Impacts During Maintenance/Repair and Decommissioning 4 MITIGATIONS PLAN 4.1 Project Site Seismicity and Measures to be Employed 5 MONITORING PLANS 6 INSTITUTIONAL ARRANGEMENTS 6.1 Measures to be Employed and Corporate Responsibility for Monitoring, Procedures and Linkages with Environmental Management 6.2 Flow of Environmental Data (Reporting, the frequency of report submission and recipients, etc.) 6.3 Flow of Environmental Data 7 PUBLIC CONSULTATIONS ANNEXES PREPARED BY 94