English

STAKEHOLDER ENGAGEMENT PLAN FOR
İç Anadolu 840 MW CCGT PROJECT
July, 2015
ANKARA
STAKEHOLDER ENGAGEMENT PLAN FOR IC ANADOLU CCGT PROJECT
July 2015
REVISION LOG
Revizyon Numarası
Revision Number
0
Tarih
Date
16.02.2015
Rapor Adı
Report Title
Stakeholder Engagement Plan
for Ic Anadolu CCGT Project
Hazırlayan(lar)
Prepared by
Teknik Kontrol
Technical
Control
Doruk Bilge Tuncer
Kalite Kontrol
Quality Control
Yönetim
Kurulu Başkan
Yardımcısı
Vice Chairman
1
Graham Traynor
13.07.2015
İzlem Aydın
13.07.2015
Ahmet Ligvani
13.07.2015
2
1
TABLE OF CONTENTS
Page
1.
INTRODUCTION ....................................................................................................31
1.1
Background ......................................................................................................31
1.2
Objectives of the Plan ......................................................................................31
1.3
Scope of the Plan .............................................................................................41
2. PROJECT DESCRIPTION .....................................................................................41
2.1
Overview of the Company and Project .............................................................41
2.2
Project setting ..................................................................................................51
2.3
Project Location: ..............................................................................................61
3. REGULATORY REQUIREMENTS .........................................................................81
3.1
National Requirements .....................................................................................81
3.1.1
The Turkish Environment Law ...................................................................81
3.1.2
The Turkish EIA Regulation ......................................................................91
3.2
EBRD Requirements for Stakeholder Engagement and Public Consultation ....91
4. STAKEHOLDER IDENTIFICATION ......................................................................101
4.1
Identification of main stakeholders .................................................................101
Table 1: Stakeholders and Other Key Affected Parties ............................................111
5. IC ANADOLU ENERGY’S STAKEHOLDER RELATIONS ....................................131
5.1
Previous Stakeholder Engagement Activities .................................................141
5.1.1
Consultation Meetings during Scoping Phase: ...............................................141
5.1.2
Public Hearing and Public Disclosure .............................................................151
5.1.3
Evaluation and Assessment Committee Meeting during EIA Process ............191
5.1.4
Stakeholder Engagement during Construction ...............................................191
Community Consultation Committee ............................................................................211
5.1.5
Consultation during Operation ........................................................................211
6. MONITORING, REPORTING AND FEEDBACK MECHANISMS ..........................221
7. GRIEVANCE MECHANISM ..................................................................................231
8. COMPANY CONTACT INFORMATION................................................................261
LIST OF APPENDICES
APPENDIX 1: List of Participants to the Consultation Meeting……………………….26
APPENDIX 2: Sample Public Grievance Form……………………………………………28
ABBREVIATIONS
2
GEAS
GAMA Energy A.S.
Ic Anadolu Energy İçanadolu Doğalgaz Elektrik Üretim ve Ticaret A.Ş.
BOTAŞ
Petroleum Pipeline Corporation
TEIAS
Turkish Electricity Transmission Company
EMRA
Energy Market Regulatory Authority
Km
Kilometer
kV
Kilovolt
2
m
Square meter
MW
Megawatt
etc.
Et cetera
%
Percent
EBRD
European Bank for Reconstruction and Development
CCGT
Combined Cycle Gas Turbine
EIA
Environmental Impact Assessment
ESIA
International Environmental and Social Impact Assessment
MEU
Turkish Ministry of Environmental and Urbanization
SEP
Stakeholder Engagement Plan
ESAMP
Environmental and Social Management and Monitoring Plan
PPM
Public Participation Meeting
NTS
Non-Technical Summary
3
1.
INTRODUCTION
1.1
Background
The document is the Stakeholder Engagement Plan (SEP) of İç Anadolu Doğalgaz
Elektrik Üretim ve Ticaret A.Ş. (İç Anadolu Energy) for the development of the 840 MW
natural gas combined cycle power plant (CCGT) together with 12.6 km NGPL and also
58 km overhead transmission line in Kırıkkale province of Turkey. This plan presents the
specific stakeholder engagement activities that İç Anadolu Energy (the Company) has
undertaken during the design, EIA I and early construction phases of the CCGT Project.
It also describes the processes for ongoing and future stakeholder engagement activities
in line with the requirements of the European Bank of Reconstruction and Development
(EBRD).
1.2
Objectives of the Plan
The overall objective of the Stakeholder Engagement Plan (SEP) has been prepared to
document the methods and process by which local communities, stakeholders and
interested parties are consulted in relation to Ic Anadolu Energy’s CCGT Project in
Kirikkale, the associated overhead trasnmission line and the natural gas pipeline.
This SEP highlights the way the company communicates with people and stakeholder
groups who may be affected by or interested in İç Anadolu Energy’s operations and
activities during scopıng, land acquisition, construction and operation of the CCGT. The
end goal is to build a trusting relationship with the host community and other interested
stakeholders based on a transparent and timely supply of information and open dialog.
The SEP and the process defined therein are therefore a means to this end.
Numerous stakeholder engagement activities have been and will be conducted within the
scope of İç Anadolu CCGT Project in order to:
•
Gather baseline information about the project-affected settlements,
•
Promote and provide means for adequate engagement with affected communities
throughout the project cycle on issues that could potentially affect them and to
ensure that meaningful environmental and social information is disclosed to the
project’s stakeholders,
•
Learn major concerns (if any) of local residents and other stakeholders about the
Project,
•
Provide further input for the ESIA process in terms of identification of potential
impacts, design of measures to mitigate adverse impacts and enhance beneficial
ones during construction and operation of the facilities.
•
Ensure that grievances from affected communities and other stakeholders are
responded to and managed appropriately
4
Within this framework, this plan includes the regulations and requirements relating to
stakeholder engagement, a summary of former stakeholder engagement activities, the
identified list of project stakeholders and finally, the stakeholder engagement program for
opereations phase of the CCGT Project.
It also includes a grievance mechanism for stakeholders and the public to raise any
concerns, provide feedback and comments about the company’s operations and how
those complaints/comments will be handled.
1.3
Scope of the Plan
This SEP focuses only on the construction and operation of the 840 MW CCPP together
with 12.6 km NGPL and also 58km overhead transmission lines.
The SEP takes into account best international practices as summarized in the European
Bank for Reconstruction and Development (EBRD) Performance Requirement 10 on
Stakeholder Engagement and Information Disclosure in relation to information disclosure
and outlines the general engagement principles that the company will adopt and those
which will be used for major investment programmes.
The SEP will be reviewed and updated on a regular basis by the Company. If activities
change or new activities relating to stakeholder engagement commence, the SEP will be
brought up to date and shared with project stakeholders.
2.
PROJECT DESCRIPTION
2.1
Overview of the Company and Project
Gama Energy, established as a separate entity from Gama Holding in 2002, primarly
develops, owns and operates power generation projects as well as water harvesting and
conveyance project. Gama Energy currently has seven operational projects consist of
three HPPs (Birecik, Lamas, Cakirlar) and three WPPs (Sares, Karadag, and Gokres),
and a groundwater harvesting and conveyance project (Disi) in Jordan.
İç Anadolu Energy, which is established by GAMA Energy Inc. (GAMA), will be
responsible for the construction and operation of the natural gas combined cycle power
plant (CCGT) in Kirikkale province of Turkey. The proposed plant will be a typical 2 +1
single shaft (2 gas turbines and 1 steam turbine) configured natural gas-fired power
plant.
2.1.1 Status of the Natural Gas Combined Cycle Power Plant (CCGT) Project:
The Power Plant’s 420 MW Generation License has been granted by the Energy Market
Regulatory Authority (EMRA) on March 16th, 2011 and has a term of 49 years which will
expire in 2060. An application to increase the capacity has been made on Apr 8th, 2011
and EMRA board approved the extension to 840MW on May 31st, 2012.
5
An EIA report was prepared and submitted to the MoEU on June 15, 2012 for the 840
MW CCPP. The EIA report has been accepted as the final report by the review
committee and “EIA Affirmative” decision was issued by the MOEU in 19.03.2013.
The Construction of the CCGT will be completed in three years and the operation period
of the project will be 49 years. The construction of the CCGT has been initiated in early
2014 and estimated COD will be in August 2016.
2.1.2 Overhead Transmission Line:
A 58 km energy transmission line will be built as part of the Project. An “Electric Power
Generation License” from the Energy Market Regulatory Authority (EMRA) has been
secured for the proposed project for 49 years. The Turkish Electricity Transmission
Corporation (TEIAS) has also approved the connection to the national grid.
Detailed design of the NGPL has been approved by TEIAS in 12.05.2014. The EIA for
the overhead line has been finalized, approved by the Ministry of Environment.
Preparations of Expropriation files have been completed. Contract signed with the
Contractor Company in 07.03.2014.
Overall OHL Project was completed by early May 2015
2.1.3 NGPL:
An affirmative decision of Petroleum Pipeline Corporation (BOTAŞ) has been obtained
for a 12.6 km pipeline connection to Samsun - Ankara Natural Gas Pipeline. Land
acquisition and construction activities initiated for the NGPL and construction is planned
to be completed by 25.07.2015.
2.2
Project setting
Initially the CCGT project was designed with a capacity of 420 MWe. Then the project
design was revised and the capacity of the Project was increased to 840 MWe. Details of
the CCGT Project are presented below.
Installed capacity :
PP Type :
Unit configurations: 209FB-MS
Guaranteed efficiency :
Guaranteed Output:
Annual production amount :
Estimated construction period
Estimated COD :
Fuel type :
Transmission over-headlines:
864MWm / 840MWe
Combined Cycle Gas Turbine PP
Multi-Shaft configuration with 2 gas
turbines and 1 steam turbine
Gas Turbines: (2x288) MWm / (2x280)
MWe (PG9371FB.03)
Steam Turbine: (1x288) MWm /
(1x280) Mwe (D-11)
%58,21
810 MW
6,3 TWh
32 months
August 2016
Natural gas only
1272 MCM 380 kV 58 km OHL to
6
Natural gas pipelines:
Site Conditions:
Gölbaşı/Ankara
Hot-tap connection to 48’’ SamsunAnkara Natural Gas pipeline
In PP : 12,6 km 16’’ X52 pipeline
15 °C, 0,9231 bar, %60 RH
2.3
Project Location:
The project is located in Hacılar Town of Kırıkkale Province which is situated in the
central part of Turkey. The project site is approximately 3.2 km away from the center of
Hacılar Town which is the closest settlement.
The project area is located in an industrial zone and the land is owned by GAMA. A fuel
oil-fired 153 MW Barmek-GAMA Power Plant, which has been dismantled, was located
to the southwest of the project site. The Tüpraş Orta Anadolu Refinery is located
approximately 500 m to the southeast of the project site. Panoramic view of the project
site can be seen in Figure 2-2 and satellite images of the project site can be seen in
Figure 2-1, Figure 2-3 and Figure 2-4 below.
Figure 2.1: Location Map of the Project Site
7
Figure 2.2: Panoramic View of the Project Site
Figure 2.3: Satellite Image of the Project Site
8
Figure 2.4 View of the CCGT Construction
3.
REGULATORY REQUIREMENTS
Stakeholder consultations and information disclosure undertaken by İc Anadolu Energy
will comply with the requirements of the legislation of Turkey and best international
practice, as described in the requirements of the European Bank for Reconstruction and
Development (EBRD) and Performance Requirements engagement is an essential
requirement of PR 10: Information Disclosure and Stakeholder Engagement.
Information on the EBRD’s Environmental and Social Policy (May 2014) can be found on:
http://www.ebrd.com/news/publications/policies/environmental-and-social-policy-esp.html
(English)
http://www.ebrd.com/news/publications/policies/environmental-and-social-policy-esp.html
(Turkish)
3.1
National Requirements
3.1.1 The Turkish Environment Law (2872)
The Environment Law (law no: 2872) includes the general guidelines for the protection
of the environment and people. In particular, Article 10 of the Law states that investors
who may create adverse environmental impacts as a result of their planned activities
must prepare a comprehensive Environmental Impact Assessment (EIA) Report. This
report must take into consideration all of the possible impacts on the environment and
9
must also identify the measures that should be taken in order to prevent or mitigate the
potential impacts.
3.1.2 The Turkish EIA Regulation
The types of projects for which an EIA report is required, the specific topics that should
be covered for different cases, and the authorities to approve the reports are described in
the "EIA Regulation" (revised on July 17, 2008) issued by the Turkish Ministry of
Environment and Urbanization (MEU).
The EIA Regulation requires that a public participation meeting be held for the Project.
As stated in the regulation, the main purpose of this meeting is (i) to inform the public (in
particular the local residents) about the project, and (ii) to receive the comments and
recommendations of the public regarding the proposed investment project.
The public participation meeting must be organized in the area of the proposed project
site, and the place of the meeting must be accessible by all interested parties. The place
and the date of the meeting must be approved by the Governor of the Province and then
announced (by the project owner) in one local and one national newspaper at least ten
days prior to the meeting. Similar announcements must also be posted in near towns and
villages by the staff of the Governor’s Office.
The comments and recommendations of the public raised in the public participation
meeting should be recorded carefully by the local representatives of the Turkish MEU.
These written concerns and recommendations are reviewed during the EIA process.
Once the EIA Report is prepared, public disclosure period of 10 days is started and
announced by the posts at Governor’s Office and via website of the Turkish MEU.
The EIA of the Ic Anadolu CCGT Project, which was prepared in in line with the Turkish
EIA Regulation is completed in 15.06.2012 and the “EIA Positive Certificate” was issued
by the Turkish MEU in19.03.2013.
3.2
EBRD Requirements for Stakeholder Engagement and Public Consultation
It is assumed that one of the financiers with significant input to the Project financing will
be European Bank of Reconstruction and Development (EBRD). EBRD is committed to
promoting environmentally sound and sustainable development. As such, taking into
consideration a possible EBRD participation in the Project financing scheme, the Project
will be governed by the EBRD Environmental and Social Policy (May 2014) and the
subsequent Performance Requirements (PR) during the Project development and
implementation.
The principles, requirements, methodological and procedural aspects of stakeholder
engagement for EBRD Category A and B projects are described in detail in PR10
“Information Disclosure and Stakeholder Engagement”. PR10 outlines a systematic
approach to stakeholder engagement that will help clients build and maintain over time a
constructive relationship with their stakeholders, in particular the locally affected
communities.
10
Stakeholder engagement is a constant process which should involve: (i) the public
disclosure of appropriate information to allow stakeholders in meaningful consultation,
and (ii) probably significantly affected parties to be engaged in meaningful consultation,
and (iii) the people who can make comments or complaints can do so through an
ongoing process that requires a stated procedure or policy. The process of stakeholder
engagement should begin at the earliest stage of project planning and continue
throughout the life of the project. It is an integral part of the assessment, management
and monitoring of environmental and social impacts and issues of the project.
The consultation process during the ESIA has to ensure free, previous and informed
consultation of affected groups and facilitate their informed participation. On a practical
level, the sponsor has to ensure that:
•
All stakeholders have access to project information;
•
The information provided can be understood;
•
The locations for consultation are accessible to all who want to attend;
•
Measures are put in place which ensure that vulnerable or minority groups are
consulted (inclusiveness in representation of views, including ages, women and
men, vulnerable and/or minority groups);
•
Clear mechanisms established for responding to people’s concerns, suggestions
and grievances;
•
Where appropriate and feasible, feedback is incorporated into project or program
design, and reported back to stakeholders.
Ic Anadolu Energy’s stakeholder engagement activities will be carried out bearing in mind
the spirit and principles of the UNECE Convention on Access to Information, Public
Participation in Decision-Making and Access to Justice in Environmental Matters
throughout the lifetime of the project in line with the EBRD performance requirements.
4.
STAKEHOLDER IDENTIFICATION
4.1
Identification of main stakeholders
Stakeholder identification and analysis are some of the most critical first steps of a
project. Within the context of the specific management issues to be addressed,
stakeholder identification and analysis provide a basic understanding of the social and
institutional context in which the planning process will take place.
This section of the document identifies interested parties i.e. stakeholders and others
affected at a local, district, regional, national and international level. Stakeholders could
also be individuals and organizations that may be directly or indirectly affected by the
project either in a positive or negative way, who wish to express their views.
Stakeholders have been identified by Ic Anadolu Energy within the following groups:
•
International Stakeholders
11
•
Government (national and regional level)
•
Internal Stakeholders Employees)
•
Local community representatives (i.e. Mayor)
•
Project affected people; landowners
•
Public groups - nearby hospital, local schools, institutions of national heritage.
•
NGOs
•
Institutions (universities, think tanks, etc.)
•
Media
•
Client
•
Services and suppliers
•
The construction sector
•
Lenders
List of key stakeholders identified and type of specific issues discussed with them
throughout the Project design, EIA and early construction phases are presented in Table
1 below.
Table 1: Stakeholders and Other Key Affected Parties
Stakeholder
Group
Key Stakeholders
EMRA
Market
Authority)
Summary of Specific Interests
(Electricity Eligible Consumer Agreement, Licensing Application
Regulatory
Ministry of Labour and
Social Security
Ministry of Environment
and Urbanization
Government
Work Permit and Residence Permit for Foreign
Personnel,n a Notification of work place.
EIA Report review and approval, Temporary Activity
Permit, review and approval of EIA and Environmental
Permit,
MENR
(Ministry
of Emergency Diesel Group Permit, Pre-Approval of
Energy and Natural project documents, Design Approval, Provisional
Resources)
Acceptance, Final Acceptance Process
Administration of Social SSA Notification , local employment issues
Security Organisation
Turkish General Staff
Military Approval for project locations and security
measures
General Directorate of Transportation related issues; Approval of Permit for
Highways
Long Vehicles and/or Heavy Loads
Ministry of Health
Protection of employee and public safety; establishment
of health and protection zones around the power plant,
NGPL and energy transmission lines.
12
Governorship
of
Kirikkale,
Provincial
Directorate
of
Environmental
and
Urbanization
Provincial Directorate
(Science, industry and
Technology Regional
Directorate
in
Governorship)
Temporary Waste Storage issues and provision of
Permit for Hazardous Waste, Emission Permit, Waste
water Discharge Permit
Hacılar Municipality
Domestic Solid Waste Undertaking, Water Usage
Undertaking, Shelter Permit, possible joint project for
public benefit, local employment and procurement
issues, building use permit, fuel storage permit,
temporary waste storage permit, trial operation permit,
operation permit, registration to water works,
wastewater connection permit
Industry Registry Document
Jobs and other economic benefits, Social/community
investment opportunities/initiatives
Municipality
Fire Notification Of Establishment And Usage Of Fire
Directorate
Fighting Equipment
Special
Provincial Determination of Health Protection Strip
Administration
BOTAŞ
TEİAŞ
Provincial
Directorate
Crossing of Gas Supply Lines, Approval of Natural Gas
Pipeline Route and Gas Connection Permit, Connection
to High Pressure National Grid, Expropriation
Procedure regarding Natural Gas Pipelines
System Usage Agreement, System Connection
Agreement, Expropriation Procedure regarding Energy
Transmission Lines (located outside the Project Site),
Approval of Overhead Energy Transmission Line Route,
Overhead Energy Transmission Line Engineering
Design Approval
Cadastral Approval of Cadastral Maps
Tax Office
Local Gendarme
Employees
Internal
Stakeholders
Land Owners
Tax requirements and registration to the Tax Office
Security
measures to be implemented during
construction and operation phase of the CCGT
Code of conduct, Trainings, health and safety issues,
migrant workers etc.
and Business opportunities
HSES and technical requirements of the project
Contractors
subcontractors
(MOTTS
McDonalds,4N
Consultancy,
ENVY,
AECON,
GELİŞİM OSGB etc)
Land owners on the Environmental and social impacts of the project and
NGPL and Overhead mitigation measures during construction and operation,
13
Transmission Lines
Consultation with landowners on permanent land
acquisition through BOTAS and TEIAS
Additional land owners Rental Agreements for usage of
for temporary land take construction contractors
by
contractors
(for
offices, storage area
etc)
Kırgaz
Kırşehir
Dağıtım
A.Ş.
lands by the
Kırıkkale Gas Supply Agreement and operation of RMS-A Station
Doğalgaz
Pazarlama
TÜPRAŞ
Potential impacts on their operations
Cumulative impacts of both facilities in the region
Cooperation opportunities in emergency cases
All vendors
Kirikkale University
Universities
Printed Press
Media
Visual Press
National
International Banks
Lenders
Trade opportunities
Feedback on environmental and social impacts and
mitigation measures, project benefits etc.
News related with İç Anadoolu and CCPP Project,
public interest
News related with İç Anadoolu and CCPP Project,
public interest
and Project Finance
5.
IC ANADOLU ENERGY’S STAKEHOLDER RELATIONS
The Company has undertaken engagement activities including consultation with certain
Stakeholders during the early stages of development of the project which will continue
throughout the project lifetime.
The Company use different consultation approaches and methods for different
stages of the project activities and stakeholder groups. The main communication
methods and mechanisms that are used to consult with external stakeholders are:
•
Face to face and group meetings with key stakeholders
•
Project website (http://www.icanadolu.gama.com.tr/index.php)
information/updates about the Project
•
Public meeting to disclose the ESIA report and progress on management of
mitigation measures during construction
•
Disclosure of ESIA, NTS and community leaflets both in English and Turkish
•
Media, Newsletters etc.
for
providing
14
The Company has developed separate communication tools and mechanisms for internal
stakeholders (employees, contractor workers, subcontractors etc.) such as;
•
weekly, monthly meetings, tool box,
•
internal announcements,
•
hand-outs, bulletin board,
•
trainings,
•
code of conduct, and
•
grievance procedure etc.
5.1
Previous Stakeholder Engagement Activities
Gama Energy has been operating in the region for more than 10 years and has already
established strong relationships both with communities, local authorities and with the
neighbouring industries due to their previous operations in Kirikkale.
In addition, the Company has undertaken various field studies, detailed surveys and
conducted comprehensive consultation meetings during the design, land acquisition and
early construction of the CCGT. Some of these consultation meetings are summarised
below.
5.2
Consultation Meetings during Scoping Phase:
The projects that are listed in Annex I of the EIA Regulation are directly subject to
preparing an EIA Report. As the first requirement, an Environmental Impact Assessment
Application File was prepared and submitted to the Ministry of Environment and
Urbanization. The MoEU reviewed the EIA Application File and established a committee
to review and evaluate the EIA report. Before the first meeting of the committee, the
Company conducted a public participation meeting at the proposed project location to
inform the stakeholders about the project and receive feedback on their major concerns
and expectations with regards to the planned project. The Company has conducted
separate consultation meetings with the stakeholders for both phases; first for the initial
project (with 420 MWe) and then for the capacity increase project (840 MWe). Details of
these public consultation meetings presented below (Section 5.1.2).
The list of review and evaluation committee for both phases is presented in the Table 2
below. The committee members were provided with the Environmental Impact
Assessment Application File, they reviewed the potential environmental and social
impacts of the proposed Project and provided their official opinions in the meeting
conducted in April 29, 2010 at MoEU and in January 25, 2012.
Table 2: List of Participants in the EIA Review and Evaluation Committee
Ministry of Energy and Natural Resources
General Directorate of Electricity Generation Corporation (EÜAŞ)
Petroleum Pipeline Corporation (BOTAŞ)
General Directorate of Mineral Research & Exploration (MTA)
15
Ministry of Health
Basic Health Services General Directorate
General Directorate of Forestry
State Hydraulic Works General Directorate
Meteorological Service General Directorate
Environmental Management General Directorate
Air Management General Directorate
Water Soil Management Directorate
Waste Management Directorate
General Directorate of Nature Conservation and National Parks
Kırıkkale Governorate
Provincial Environment and Urbanization Directorate
Provincial Agricultural Directorate
Secretary General of Provincial Special Administration
Provincial Health Directorate
Kırıkkale Municipality
Planning and Strategical Environmental Assessment Directorate
Environmental Inventory Directorate
5.2.1 Public Hearing and Public Disclosure
People living in Hacılar town which is the closest residential area to the project site are
expected to be potentially affected by İç Anadolu CCGT.
In line with Article 9 of the Environmental Impact Assessment Regulation, public
consultation meetings were organized in both phases of the project in order to inform
people about the project activities, potential impacts during construction and operation
and obtain their opinions, concerns and suggestions prior to finalisation of the EIA.
Prior to the meeting, the EIA Application Files were posted on the internet site of the
MoEU Environmental Impact Assessment Directorate, the Kırıkkale Governorship
announcement board for public review. Meeting dates, times and venues were also
disclosed as April 24, 2010 and January 23, 2012; 14:00, Kırıkkale University Hacılar
Hüseyin Aytemiz Vocational School by the Kırıkkale Governorate Provincial Environment
and Urbanization Directorate.
In addition, public announcements, including meeting dates, times and venues were
published on the national and local newspapers (İl Gazetesi and Akşam Gazetesi in
12.01.2012) before the meetings. Please see the advertisements below.
16
Figure 5.1: Advertisements for Public Participation Meeting
İl Newspaper 12.01.2012
Akşam Newspaper 12.01.2012
In order to ensure active participation of local stakeholders in the consultation meeting, a
bus on which an announcement was attached, was organized to transport people to the
meeting place from the Hacilar town center.
Community pamphlets were distributed to the stakeholders in order to provide
information on the proposed project, its potential impacts and proposed mitigation
measures in local language prior to the public consultation meetings.
During the public disclosure and consultation meetings, a detailed presentation including
information on detailed project activities, environmental and social impacts of the project
and mitigation measures was provided by the Company and its environmental and social
experts. Then opinions of stakeholders were received and their questions were
answered. List of people participating to the meeting is provided in Annex 1. Photos from
the meetings are provided in Figures 5-1, 5-2, 5-3, 5-4 below.
17
Figure 5-1 Public Participation Meeting 1 View 1
Figure 5-2 Public Participation Meeting 1 View 2
18
Figure 5-3 Public Participation Meeting 1 View 3
Figure 5-4 Public Participation Meeting 2 View 1
During these public consultation meetings, local participants asked questions generally
on employment opportunities during construction and operation of the CCGT and
environmental impacts of the project. The Mayor of Hacilar raised his expectation with
regards to prioritisation of local people living in Hacilar town for recruitment during
construction and operation of the CCGT. The Company representatives responded that
stating that qualified work force is needed for the project. However, they also committed
that work force in the Hacılar Town will be prioritized in case of a need for semi-skilled
and unskilled work force by the contractors. Other issues discussed during this meeting
were as follows:
19
•
•
•
Impacts of the project on community health and safety,
Assurance role and monitoring mechanisms of the Company on Contractors with
regards to implementation of health, safety, environment and social impact
mitigation measures
Monitoring frequency
The Company representatives stated that, in addition to the Company’s internal
monitoring and auditing mechanisms, the project will also be monitored in the periods
determined by the MoEU by the an independent firm in accordance with the monitoring
parameters stated in the EIA report and the project will also be monitored by the
Provincial Environment and Urbanization Directorate.
5.2.2 Evaluation and Assessment Committee Meeting during EIA Process
The EIA was prepared in accordance with the requirements of the MoEU and submitted
to the MoEU for their review and approval. For the first phase of the project, the EIA was
distributed to the committee members for their review and an evaluation meeting was
held on September 02, 2010. As a result of the evaluation meeting by the MoEU and the
evaluation committee, the evaluation process was finalized, the EIA report was found to
be appropriate by all of the committee members and the project owner was requested to
submit the final EIA report by incorporating the necessary additional information
requested during the meeting.
After the approval of the evaluation and assessment committee, the final EIA was made
available for public review for 10 days in the MoEU web page and the Kırıkkale
Governorate announcement board. No feedback or objections were received during this
period from the stakeholders. The final report was reproduced for committee members
and submitted to the MoEU. Finally, the MoEU issued the final opinion as “Affirmative
Opinion on Environmental Impact Assessment’’.
For the capacity increase project, similarly the EIA was distributed to the committee
members for their review and an evaluation meeting was held on January 25, 2012. As a
result of the evaluation meeting by the MoEU and the evaluation committee, the
evaluation process was completed, the report was found to be appropriate by all of the
committee members and the project owner was requested to submit the final report by
incorporating the necessary additional information. The process for obtaining “Affirmative
Opinion on Environmental Impact Assessment’’ is finalised for the capacity increase
project.
5.2.3 Stakeholder Engagement during Construction
Ic Anadolu Energy has continued its stakeholder engagement activities during
construction of the CCGT. There have been several meetings held both with local
authorities, landowners, general community members, state authorities and local
companies prior and during the pre-construction phase. Some of these meetings are
20
summarised below:
•
•
•
•
•
•
•
Meetings with various state institutions both at national and regional level to
discuss environmental, social, health and safety impacts and permitting
requirements for the project.
Meetings held with neighbouring industries such as TUPRAS refinery regarding
the potential cumulative impacts of the project and possible cooperation
opportunities between two major plants during emergency cases.
Face to face consultation meetings conducted with the land owners on the route
of the overhead line and on the NGPL route to inform them about the land
acquisition process, landowners’ rights under the Turkish expropriation law and
nature and timing of planned construction activities, potential impacts of project
activities and mitigation measures through İç Anadolu’s contractor. The Company
representatives were also engaged in these meetings to observe and monitor the
implementation by its contractors.
There have been various meetings held with the Municipality of Hacilar town and
other local authorities in the region. In these meetings, potential impacts of the
plant as well as potential job opportunities for local people and local companies
have been discussed. In addition to local employment and procurement
opportunities, expectations on social investment projects were also discussed in
detail. As a result of these consultation meetings with the Hacilar Municipality
management, the Company agreed to contribute to the improvement of the local
infrastructure in Hacılar town such as increasing the capacity of the sewage
system in the town, building a new water intake line and reservoirs which will
jointly be used both by the CCPP and the local people.
Various meetings held with BOTAŞ (state owned gas Pipeline Company) to
coordinate the design, route selection, land acquisition and construction issues
for the proposed NGPL route and the RMS-A station.
Various coordination meetings conducted with TEİAŞ and still ongoing for the
overhead transmission line route and related construction activities.
Face to face meetings with local people who seek for employment opportunities
at the CCGT Project.
The Company will continue to engage the stakeholders throughout the construction
phase and will continue to ensure that it’s EPC Contractor and its subcontractors also
comply with the requirements of this Stakeholder Engagement Plan in line with the
national and international requirements. The implementation of mitigation measures by
the EPC Contractor and its sub-contractors will be closely monitored, audited by the
Company during construction. İç Anadolu Energy will ensure that:
The community members have been and will be informed prior to the commencement of
any project activity.
Consent of landowners/users will be obtained prior to land entry and exit protocols will be
signed by the Contractor with the landowners/users around the power plant, along the
21
routes of NGPL and overhead transmission line to ensure that landowners/users’
consent is gained prior to land exit and no grievances are left behind after construction of
the Power plant and its associated facilities. The Company will assign an experienced
social coordinator who will work closely with the HSE, land acquisition teams and
construction contractors to ensure that the requirements of the stakeholder engagement
plan is met throughout the project lifetime.
The complaints raised by the stakeholders are and will be managed in line with the
grievance management procedure of the Company. During construction of the CCGT,
grievances in relation to construction activities will be managed by the EPC contractor
which will be closely monitored by the Company.
Residents of the Hacilar town, local authorities and other stakeholders were already
informed about the contact details of the Company and EPC Contractor before the
commencement of construction through local consultation meetings and announcements
in public places. However, the Company will refresh communities with regards to the
grievance mechanism and contact details of the company on regular basis through
posters during construction and operation phases.
The Company will also ensure that the stakeholder engagement activities, feedback
received from various stakeholders, complaints and expectations of communities are
registered and tracked on a systematic basis.
Community Consultation Committee
If considered appropriate with the local community, a Consultation Committee will be set
up in cooperation with the local host community in Hacılar, Kırıkkale. This will include a
number of key community representatives, may include the Municipality Head, informal
herding community representatives, representative of chambers of commerce and
industry, a representative from the regional authority and from the local school. Local
business people and other groups such as young persons and landowners will also be
invited to participate in these meetings. The group will coordinate on-going discussions
on evolving issues, be consulted on the planned stakeholder engagement activities and
provide a mechanism to feedback to the project team on the requirements and concerns
of the community.
5.2.4 Consultation during Operation
The Company will continue its stakeholder engagement activities during operation of
CCGT in order to maintain its good relationships with the neighbouring communities but
also to manage operational risks in an effective way. Types of the stakeholder
engagement activities are summarised below however a SEP will be updated for the
operation phase and will continuously be revised based on needs of the Company and
changes in the region in future.
22
•
The communities in the vicinity of the project units will be informed on the health
and safety risks and potential impacts of the operation of CCGT and its
associated facilities such as the NGPL and overhead transmission line.
•
The Company will conduct regular awareness raising campaigns and basic
trainings in all project affected settlements to ensure that communities and local
authorities understand the land use restrictions, health and safety zone
constraints as well as other operational impacts of CCGT, NGPL and
transmission lines.
•
The compliance of the landowners with the land use restrictions will be
maintained through close monitoring of the power plant by the Company, NGPL
by BOTAS and electricity transmission line by TEIAS. The Company will work
closely with BOTAS and TEIAS to establish and maintain an effective dialogue
between these institutions and the communities during operations phase.
•
The Company will also inform local communities on future employment
opportunities, skills required, training and support which will be provided during
operations phase in an open and transparent way. Every individual in Hacılar
town will be given equal opportunity to apply for jobs during the operations.
•
In addition, the Company will coordinate with the Hacılar Municipality,
Governorship of Kirikkale, local state security officers and neighbouring industries
such as TUPRAS to ensure that health, safety, environment and security risks of
the CCGT is managed effectively during the operations phase.
All stakeholder engagement activities will be recorded and tracked by the Company in
line with the SEP. In addition the Company will maintain its complaint management
mechanism as well as its incident and accident reporting mechanism during the
operation period.
6.
MONITORING, REPORTING AND FEEDBACK MECHANISMS
The Company will register and report the feedback they receive from communities, local
authorities, landowners, other companies, NGOs, media, academic institutions and other
interest groups on a systematic basis through an effective consultation and complaint
mechanism which will be developed and used by the Company and its contractors
throughout the project lifetime.
EPC Contractor is responsible for reporting of its social KPIs including stakeholder
engagement activities, status of complaints, temporary land take and compensation etc.
on monthly basis to the Company.
Feedback and complaints received through consultation meetings, websites, telephones
etc. and actions undertaken both by the EPC Contractor and by the Company will be
maintained in the master tracker by the Company.
On annual basis, the Company will produce a public report on their social and
environmental performance, including a non-technical summary of the Environmental
23
and Social Action Plan (ESAP) and progress made with the implementation of the ESAP,
against agreed indicators and targets.
The Company will conduct regular internal monitoring activities and audits on
environmental and social performance of the EPC Contractor and its subcontractors.
The Company will ensure compliance with external monitoring requirements such as
regulatory monitoring on environmental performance, H&S audits and employee
standards reviews by third parties as well as lenders audits during construction and
operation of the CCGT Project.
7.
GRIEVANCE MECHANISM
The objective of a grievance procedure is to ensure that all comments and complaints
from any project stakeholder, including local, regional authorities, residents of nearby
residential areas, Ic Anadolu Energy employees, EPC Contractor and subcontractors’
staff and other interested parties are considered and addressed in an appropriate and
timely manner. All grievances will be acknowledged and responded to within a
reasonable timeframe.
The Company will implement a formalised approach to the management of responses to
enquires and grievances in relation to the Project. This is considered to be essential to
understand, respond and effective resolve issues of stakeholder concern.
The grievance mechanism will be made public through the on-going consultation
meetings, Company website, posters and community leaflets which will be distributed in
all project affected settlements during construction phase and will be maintained during
the operation. The grievance mechanism will also be available for the project labour,
including non-employees engaged though sub-contractors.
The grievance mechanism is presented in Figure 7.1 below. The grievance form that will
be used is also presented at Appendix 2.
Grievances will be managed in line with the procedure summarised below:
•
All stakeholders are welcomed to report any concerns, grievances or other
comments to use in writing, by email, by telephone, in person at the Project
offices or during public meetings.
•
The Company will take full details of these concerns expressed and ensure that
the Company’s designated point of contact is made fully aware of the
communication so that a formal assessment will commence.
•
The Company will record the date and contact information on the standard
grievance form and place a copy in the project grievance register. Individuals who
submit their comments or grievances have the right to request that their name be
kept confidential.
•
Alternatively, the Company or its contractors can provide the complaint form
which can also be used to report a concern by the stakeholders.
24
•
Completion of this form will ensure the Company have all information necessary
to effectively conduct an investigation. This form can be completed anonymously
if necessary.
•
The Company will ensure one of these forms is completed for all grievances
related to the project and these forms will be placed on the project grievance
register.
•
Complainants are welcome to propose to the Company what they would like to
happen in response to the issue
•
The Company will undertake an investigation to assess what corrective and
preventive action, or further investigation, is necessary as part of the investigation
•
The Company will ensure that all grievances will be:
o Acknowledged within 7 days; and
o Responded to no later than 30 days.
•
The Company will place details of the completed corrective and preventive
actions within the Grievance Register. If a longer term programme is required to
provide an adequate solution then this programme will be detailed on the register
against the specific grievance.
•
Overall, grievances will be registered and will include all grievances, whether
received in writing or verbally. The complainants will receive an
acknowledgement of the receipt of the complaint within a reasonable timeframe
explained above. Complaint close out form will be signed after the successful
closure of the grievance.
Important Note: The grievance mechanism does not preclude the right for
stakeholders to process grievances though other judicial means.
25
Figure 7.1: Flowchart for Processing Grievances
Grievance received
(in verbal or written format)
Record the date in the
Grievance Register
Acknowledge all complaints within 7 days.
YES
NO
Immediate action
enough to satisfy
complaint
Record the date in the
Register
Identify any long-term corrective
action required
Inform complainant of the
proposed corrective action or
clarify why action is not required
within 30 days
Inform complainant of corrective
action
Record the date. Close the case.
Implement the corrective action
and carry out the follow-up of
the corrective action
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8.
COMPANY CONTACT INFORMATION
Communication records will be maintained by the E&S Department at İç Anadolu,
specifically through the E&S Manager. Key information will be clearly communicated to
stakeholders and also the key incoming communications (i.e. general questions,
complaints, etc.) will also be maintained including a summary of actions to be taken.
As part of this communications procedure, the E&S Manager at İç Anadolu will record
and update these ongoing stakeholder engagement activities on an ongoing basis.
Company contact information is provided in Table 3 below.
Table 3:
Company Contact Details
Company Name
Ic Anadolu Dogalgaz Elektrik Uretim ve Ticaret A.S.
Company Contact
Mr. Doruk Bilge Tuncer, HSE Manager
Postal Address
Saglik Mah. Abdi Ipekci Cad. No:45 Hacilar
Kasabasi/Kirikkale-Turkey
Telephone Number
Hot line: +(90) 318 297 43 97
Fax Number
Reception: +(90) 318 297 43 98
Email Contact
[email protected]
Company site
www.gama.com.tr
Online Inquiry Form
http://www.icanadolu.gama.com.tr/sikayet.php
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APPENDIX 1: List of Participants of Public
Consultation Meeting
Name and Surname
Hacı İbrahim GÜNDOĞDU
Gürses DEMİRTAŞ
Mevlüt YURDAKUL
Ahmet ALTINTAŞ
Aytekin GÜNDOĞDU
Aydın ALAKUŞ
Mehmet ULUSOY
Cemil BEKTAŞ
Ali KOYUNCU
İlhan YAĞIZ
Mehmet ALTINTAŞ
Zübeyde GÜNDOĞDU
Ayşegül GÜNDOĞDU
Zeliha GÜNDOĞDU
Makbule KOYUNCU
Cengiz ÜST
İsa KOYUNCU
Üzeyir KOYUNCU
Nuri TUNCEL
Ömer KARAGÖZ
Mehmet Akif GÜNDOĞDU
Fatih KARAGÖZ
Dursun KARAGÖZ
Kemal KARAKOÇ
Burhan GÜNDOĞDU
Şerafettin DURMAZ
Turgut ÜNAL
Murat ERDOĞAN
Muran İNCE
Atilla GÜNDOĞAN
Osman BAĞCI
Yakup GÜNDOĞDU
Ümit GÜNDOĞDU
Duran YILDIRIM
Mehtap GÜNDOĞDU
Hasan YILDIRIM
Duran GÜNDOĞDU
Türkan GÜNDOĞDU
Dursun ALAKUŞ
Ahmet GÜNDOĞDU
Ayşe KARABULUT
Mehmet KARABULUT
Mevlüt KARABULUT
Tevhide KARABULUT
Teslime KARABULUT
Hakan ERTUĞRUL
Tolga GÜNDOĞDU
Gürkan KUNTASAL
Institution/Title
Mayor of Hacilar Town
Municipality Officer
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Kırıkkale Provincial Directorate of Environment
and Forestry
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Kırıkkale Provincial Directorate of Environment
and
Forestry/Department Chief
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Village Resident
Student
Village Resident
AECOM
28
Ümit KÖSE
Neslihan AYVAZ
Hayrettin ACAR
GAMA Enerji
AECOM
EÜAŞ
29
APPENDIX-2
Grievance Form
30