Environmental & Social Due Diligence Environment and Social Action Plan
Environmental & Social Due Diligence Environment and Social Action Plan
Environmental & Social Due Diligence Environment and Social Action Plan
Due Diligence
Environment and Social Action
Plan
Prepared for:
EBRD
1 Exchange Square, London, UK
Prepared by:
ENVIRON UK Limited
Box House, Bath, UK
Date:
May 2013
(signature):
This report has been prepared by ENVIRON with all reasonable skill, care
and diligence, and taking account of the Services and the Terms agreed
between ENVIRON and the Client. This report is confidential to the client,
and ENVIRON accepts no responsibility whatsoever to third parties to
whom this report, or any part thereof, is made known, unless formally
agreed by ENVIRON beforehand. Any such party relies upon the report at
their own risk.
Contents
Page
Table 8.2 summarises the action required for identified environmental, health, safety and social issues to meet applicable legislative
requirements, EBRD performance requirements, IFC Performance Standards and international good practice associated with Izdeniz A.S
operations.
Note that the World Bank Group Environmental and Health and Safety guidelines are incorporated by reference into IFC Performance Standard
3.
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
Environmental Management
1 Conduct Ensure compliance with national, EU and Turkish and EU Municipality Construction Prior to first EIA prepared in
Environmental EBRD/IFC requirements regarding identification regulations. EBRD disbursement accordance with
Impact of significant environmental impacts associated PR1& PR6, IFC PSs € national regulations
Assessment with a new development. The EIA should and GIIP and EBRD
100,000
for repair and incorporate an alternatives assessment and an Performance
maintenance assessment of cumulative impacts. The EIA to Requirements
yard should address noise, wastewater, dust/air 200,000 (PRs) and IFC
emissions, solid waste, dredging, historical Performance
contamination, biodiversity, resource efficiency Standards and
and any other identified potential environmental accepted by the
interactions. Additionally, to conform with Ministry of
international standards (EBRD & IFC) social Environment and
impacts should be identified and stakeholder the EBRD
engagement and consultation should form part of
the EIA.
2 Prepare Ensure compliance with national, EU and Turkish legal Municipality Construction Prior to first Project Description
Project EBRD/IFC requirements regarding identification requirements EBRD disbursement. Files accepted by
Description of significant environmental impacts associated PR1&6, IFC PSs and € 50,000 the Municipality
Files for the with a new development. The project description GIIP and the EBRD
to
floating wharf files (PDF) should address noise, wastewater,
developments dust/air emissions, solid waste, dredging, 100,000
biodiversity, resource efficiency and any other
identified potential environmental interactions.
Additionally, to conform to international standards
(EBRD & IFC) social impacts should be identified
and stakeholder engagement and consultation
should form part of the PDF.
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
3 Obtain Ensure compliance with national, EU and Turkish legislation, Municipality Construction Prior to first Construction Permit
construction EBRD/IFC requirements. No construction can EBRD PR1, IFC PS1 disbursement. issued by the
permits proceed without a construction permit. and GIIP. € 20,000 authorities.
to
40,000
4 Include in To improve EH&S management and risk control EBRD PR1 and PR3, Municipality Operation Prior to tender Develop an Use of internal
tender by providing a system(s) to drive continual IFC PSs and GIIP documents integrated personnel and
documents improvement, identify and manage key EH&S being issued management external
that aspects and impacts, manage contractors, system to comply specialists.
Contractor monitor and review performance and ensure with ISO 14001 and
must develop compliance with Turkish legislation, permits and OHSAS 18001
and implement international environmental requirements (e.g. standards, or
an EH&S MARPOL 73/78, ISPS code etc.). equivalent.
Management The EH&S management system will act as an Annual EH&S
System umbrella framework co-ordinating all Report to the Bank
management plans mentioned within the ESAP. on ESAP progress.
Municipality to
Develop and Start of monitor to confirm
Construction compliance
implement an construction
Contractor
EH&S and continuous
and
Management afterwards
consultant
System
support
€40,000 to
€60,000
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
5 Include in To define the environmental and social objectives EBRD PR1, IFC PSs Municipality Construction Prior to tender EH& S policies Use of internal
tender and principles for the project. This should be and GIIP documents prepared and personnel and
documents endorsed by senior management to show the being issued endorsed by senior external
that Municipality’s commitment to sound management. specialists.
Contractor environmental and social performance Municipality to Implementation
must prepare monitor to confirm by the contractor
EH&S Policies compliance should be: Within
2 weeks of
Prepare EH&S Construction Within 2 weeks construction
Policies Contractor of construction commencing
commencing
Mgt cost
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
6 Include in Ensuring compliance with national and Turkish legislation, Municipality Construction Prior to tender Implementation of Use of internal
tender international environmental & social guidelines EBRD PR1 and PR3, documents CESMP and personnel and
documents (e.g. MARPOL 73/78) as well as EIA IFC PSs and GIIP. being issued periodic updates as external
that commitments, by formalising environmental & applicable. specialists.
Contractor social management and risk control. The CESMP Municipality to
must develop would co-ordinate / dovetail with other relevant monitor to confirm
and implement management plans, including those of compliance
a Construction contractors. CESMP would address key aspects
Environmental (air, water, hazardous materials, waste, noise
& Social etc.) and impacts, identify appropriate measures
Management and monitoring plans and promote improved
Plan (CESMP) performance through monitoring and evaluation of
the Municipality and contractors.
Develop and Construction
contractor and 1 month prior to
implement a
consultant construction
Construction
support commencing
Environmental
€10,000 to and continuous
& Social
€20,000 afterwards
Management
Plan (CESMP)
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
7 Include in To ensure compliance with Turkish legislation and EBRD PR1 and PR3, Municipality Construction Prior to tender Appointment of an The post could
tender international guidance and oversee development IFC PSs and GIIP documents Environmental be fulfilled by
documents and implementation of the CESMP, management being issued Officer/Manager. either an internal
that system and actions identified within this ESAP in Municipality to appointment or
Contractor relation to the repair and maintenance yard and monitor to confirm external expert.
must appoint a the floating wharves. compliance
qualified and
trained
Environmental
Officer/
Manager
Construction
Appoint a Before
Contractor
qualified and construction
trained commences
Environmental Mgt cost
Officer/
Manager
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
8 Include in Initially to support the CESMP and ensure Turkish legislation, Construction Prior to tender Commencement of
tender compliance with national standards as well as the EBRD PR1, PR3, PR4 documents monitoring
documents reduction in environmental and social impacts. and PR6, IFC PSs, being issued programme and
that Based on the results of the monitoring (e.g. air, GIIP and commitments revision for
Contractor waste and water quality, noise, vibration, light / operation to
must develop illumination and biodiversity). incorporate any
and implement permit
an requirements.
Environmental Municipality to
& Social monitor to confirm
Monitoring compliance
Programme
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
9 Develop and To ensure compliance with Turkish regulatory and Turkish legislation, Municipality Construction ( Within 2 weeks A formalised and Use of internal
implement a permitting requirements, including the monitoring EBRD PR1 and PR3, repair and of contracts documented audit / personnel.
Contractor of housekeeping and contractor permits and IFC PSs, GIIP and maintenance commencing monitoring
Monitoring contractual requirements to reduce 3rd party risk commitments yard, wharves and continuous programme
Programme exposure. Will also support the EH&S Indicative and vessels) afterwards implemented.
management system compliance requirements. annual cost
The contractor management programme should €10,000 to
include monitoring of shipyard Environment and €15,000
Social performance during vessel building
contracts
10 Include in To ensure compliance with national and Turkish legislation, Municipality Construction Prior to tender Develop and To include project
tender international environmental guidelines. The EBRD PR1, IFC PS1 documents implement specific issues,
documents environmental training should be tailored to the and GIIP being issued Environmental the CEMP/ EMP
that audience, and include senior management to Training Program and emergency
Contractor ensure they are aware of their responsibilities, for various grades spill response.
must develop BAT concepts and emergency response. of staff and Use of internal
and implement contractors. and/or external
an Municipality to expert.
Environmental monitor to confirm
Training compliance
Programme
Construction
Develop and Within 1 month
contractor and
implement an of construction
consultant
Environmental start date and
support
Training continuous
Programme afterwards
€10,000 to
€30,000
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
11 Include in To ensure compliance with national and Turkish legislation and Municipality Construction Prior to tender Develop and Use of internal
tender international environmental guidelines, including international documents implement WMP and/or external
documents MARPOL 73/78, on minimisation, segregation, requirements, EBRD being issued and update for specialists.
that use of licensed contractors and disposal facilities, PR1 and PR3, IFC operation and as
Contractor consideration of waste hierarchy. The WMP PS1 & PS3 and GIIP required.
must develop should include both non-hazardous and Municipality to
and implement hazardous waste and co-ordinate with other monitor to confirm
a Solid and management plans. Communication of the plan compliance
Liquid Waste and changes should be to all parties.
Management
Plan (WMP)
Construction
Develop and 2 weeks prior to
contractor and
implement a
consultant construction
Solid and
support commencing
Liquid Waste
and continuous
Management
€10,000 to afterwards
Plan (WMP)
€15,000
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
12 Include in To ensure co-ordinated and effective responses Turkish legislation, Municipality Construction Prior to tender Develop and Use of internal
tender to emergencies, both man-made and natural EBRD PR1, PR 2, PR3 documents implement ERP and/or external
documents including fires, spills, earthquakes etc., and and PR4, IFC PSs 1-4, being issued and update specialists.
that compliance with national and international GIIP and EIA whenever
Contractor guidelines. As well as ensuring the safety of its commitments necessary.
must develop employees and contractors, it will also safeguard Municipality to
and implement the local community and include an Oil Spill monitor to confirm
an Emergency Response Plan (OSRP). compliance
Response
Plan (ERP) for
all foreseeable
emergency
situations
Construction 2 weeks prior to
contractor and construction
Develop and commencing
implement an consultant
support and continuous
Emergency afterwards
Response
Plan (ERP) for €15,000 to
all foreseeable €25,000
emergency
situations
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
13 Include in To ensure compliance with national and Turkish legislation, Municipality Construction Prior to tender Develop and Use of internal
tender international environmental guidelines on the international documents implement HMMP and/or external
documents management of hazardous materials including requirements, EBRD being issued and update as specialists.
that their safe storage and handling, refuelling PR3, IFC PSs 1-4 and required.
Contractor procedures and secondary containment. Co- GIIP Municipality to
must develop ordinate with other management plans (i.e. monitor to confirm
a Hazardous CESMP, EMP and ERP) and be communicated to compliance
Materials all parties.
Management
Plan (HMMP)
Construction
Develop a Contractor 1 month prior to
Hazardous and construction
Materials consultant commencing
Management support and continuous
Plan (HMMP) afterwards
€10,000 to
€15,000
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
14 Include in To ensure compliance with national and EBRD PR1, PR3, PR4 Municipality Construction Prior to tender BCMS in place and Use of internal
tender international environmental guidelines and and PR6, IFC PS1, documents implemented. and external
documents precautionary principles, and either confirm no PS3 & PS6 and GIIP. being issued Municipality to specialists.
that discernible impact or minimise any impacts to monitor to confirm
compliance
Contractor biodiversity.
must develop
and
Implement
Biodiversity
Conservation
& Monitoring
Plan (BCMP)
Construction
Develop and 1 month prior to
Contractor
Implement and construction
Biodiversity consultant commencing
support and continuous
Conservation
afterwards
& Monitoring
Plan (BCMP) €5,000 to
€10,000
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
15 Include in In order to comply with Turkish legal requirements Turkish legislation, Municipality Construction Prior to tender Chance finds
tender identify the potential for culturally significant EBRD PR8, IFC PS1 documents procedure.
documents artefacts being found during construction. and PS8 and GIIP being issued Municipality to
that Prepare a chance finds procedure. monitor to confirm
Contractor compliance.
must prepare
a Chance
Finds
procedure
Construction
Prepare a Contractor 1 month in
Chance Finds Mgt cost advance of
procedure construction
commencing
and continuous
afterwards
Health & Safety and Employment Management
16 Include in To ensure compliance with Turkish regulations on Turkish legislation, Construction Construction Prior to tender Appointment of a Consider
tender the employment of a qualified and certified H&S EBRD PR2, IFC PSs Contractor documents qualified H&S appointment of
documents officer/expert, and oversee development and 1-3 and GIIP Mgt cost being issued expert in external H&S
that implementation of the HSMP and actions accordance with advisor in short
Contractor identified within this ESAP in relation to the repair Turkish regulations. term.
must employ a and maintenance yard and wharf construction. Municipality to
H&S Officer monitor to confirm
compliance
Employ a H&S Before
Officer construction
commences
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
17 Include in To ensure compliance with Turkish regulations Turkish legislation, Municipality Construction Prior to tender Develop and Use of internal
tender and international H&S guidelines. The HSMP will EBRD PR1, PR2 and documents implement HSMP and/or external
documents assist with the implementation of the EH&S PR4, IFC PS1-4, GIIP being issued and update the specialists.
that management system and should be and commitments plan as necessary.
Contractor communicated to all parties. The HSMP will Municipality to
must develop oversee the activities of the repair and monitor to confirm
and implement maintenance yard and the new wharves and its compliance
a Health & contractors and will also consider community H&S
Safety requirements.
Management
Plan (HSMP)
Construction
Develop and 1 month before
Contractor
implement a construction
Health & commences
Safety €20,000 to and continuous
Management €40,000 afterwards
Plan (HSMP)
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
18 Include in To ensure compliance with Turkish regulations Turkish legislation, Municipality Construction Prior to tender Commencement of Use of internal
tender and international H&S guidelines. Based on the EBRD PR1, PR2 and documents monitoring and/or external
documents results of the monitoring, relevant preventive and PR4, IFC PS1-4 and being issued programme. specialists.
that corrective actions and updates should be GIIP Municipality to
Contractor implemented. monitor to confirm
must develop Aspects to be monitored include accidents, compliance
and implement incidents, training needs, contractor inspections,
a H&S chemical exposure, working conditions etc. during
Monitoring construction activities.
Programme
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
19 Include in To ensure compliance with Turkish legislation and Turkish legislation, Municipality Construction Prior to tender Develop and Use of internal
tender international H&S guidelines. RAs should EBRD PR2 and PR3, documents implement RAs and personnel and
documents consider all physical, chemical and biological IFC PS1-4 and GIIP being issued SOPs and update external
that hazards associated with the construction periodically as specialist.
Contractor operation activities and its contractors. Based on required. Implementation
must develop the findings appropriate preventive and protective Municipality to by the contractor
risk measures and SOPs should be implemented and monitor to confirm should be: Before
assessments communicated to all parties. compliance construction
(RAs) and commences and
safe operating continuous
procedures afterwards
(SOPs)
Construction Before
Develop risk construction
assessments contractor and
consultant commences
(RAs) and and continuous
safe operating support
afterwards
procedures
(SOPs) €5,000 to
€15,000
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
20 Include in To comply with Turkish legislation and GIIP, Turkish legislation, Municipality Construction Prior to tender Develop and Use of internal
tender provide a safe work environment and prevent EBRD PR2, IFC PS1-3 documents implement training and/or external
documents accidents or injuries from occurring. and GIIP being issued program and trainers.
that H&S training should cover job specific hazards, update the program First Aid training
Contractor as well as use of PPE, site rules and compliance as necessary. should be a short
must develop with SOPs. Municipality to term priority.
and implement Other specific training should also be provided monitor to confirm
H&S Training (e.g. fire fighting and spills) and at least 1 in every compliance
Programme 10 workers should receive First Aid training as a
matter of urgency to comply with Turkish Construction
Develop and legislation. Contractor Within 1 month
implement and of construction
H&S Training consultant start date and
Programme support continuous
afterwards
€10,000 to
€30,000
21 Include in To ensure compliance with Turkish regulations Turkish legislation, Municipality Construction Prior to tender All necessary Use of internal
tender and GIIP. Establishment of a H&S Committee will EBRD PR2, IFC PS1-3 documents actions should be resources.
documents improve worker relations, assist with the and GIIP being issued taken immediately
that communication of H&S issues and raise its by construction
Contractor profile. A H&S committee is also required to contractor.
must establish comply with Turkish regulations, and should be at
a H&S least monthly with worker representatives. Municipality to
Committee monitor to confirm
Construction compliance
Establish a contractor Within 2 weeks
H&S Mgt cost of construction
Committee start date.
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
22 Include in To ensure compliance with Turkish regulations Turkish legislation, Municipality Construction Prior to tender Develop and Use of internal
tender and international H&S guidelines. Will ensure that EBRD PR2, IFC PS1-3 documents implement the resources and
documents equipment is appropriately maintained and that and GIIP being issued program and external
that the periodic inspections required under Turkish ensure that periodic specialists.
Contractor legislation (e.g. every 3 months by MEC certified inspections are up
must develop engineers for cranes) are completed by to date to comply
and implement construction contractor and its contractors. with regulatory
an equipment requirements.
/ machinery Municipality to
inspection and monitor to confirm
planned compliance
preventive
maintenance
(PPM)
programme.
Construction
Develop and contracting Commencemen
implement an with specialist t of
equipment / support Construction
machinery and continuous
inspection and afterwards
€10,000 to
planned
€20,000
preventive
maintenance
(PPM)
programme.
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
23 Include in To ensure conformance to international marine International Municipality/ Operation Prior to tender Tender documents
tender standards vessels that are scrapped as a result of Standards, EBRD PR2 Izdeniz documents referencing
documents for new vessels being introduced should be scrapped & PR3, IFC PSs 1-4 being issued requirements
scrapping in compliance with IMO Guidelines for Safe and and GIIP. Cost no regarding IMO
vessels the Environmentally Sound Recycling of Ships known Guidelines for Safe
requirement to and
comply with Environmentally
IMO Sound recycling of
guidelines. Ships.
Municipality to
monitor to confirm
compliance.
24 Require To ensure that ferry, wharf and maintenance yard Turkish legislation, Municipality Operation May 2013 Implementation of
Izdeniz to operations are conducted in accordance with international all elements of the
implement the legislation, international standards, EBRD standards, EBRD PRs, ESAP within the
Ferry and Performance Requirements, IFC Performance IFC PSs and GIIP defined timetable.
Wharf Standards and GIIP. This will also reduce Municipality to
Operation reputational risks and work towards increased monitor to confirm
ESAP efficiency of operation of Izdeniz with regard to compliance.
Environment, Health & Safety and Social issues.
Social Management
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
25 Adopt and To complement, enhance and formalize ongoing EBRD PR1 & PR10, Municipality Construction Q3 2013 SEP in place and Includes
implement the stakeholder engagement and reporting of social IFC PS1, PS4 & PS5 with implemented. establishing a
Stakeholder and environmental issues. Improved relations with and GIIP. consultant A suitable set of SEP team to
Engagement the community and stakeholders and decreased support key performance oversee charge
Plan (SEP) complaints. indicators (KPI) will of stakeholder
developed by €10,000 to be used by the engagement
Environ €20,000 Municipality to
monitor stakeholder
engagement.
26 Develop and To ensure that compensation was reasonable EBRD PR5 and IFC Municipality Construction Within 3 months RAP in place and Use of external
implement during expropriation of land adjacent to the PS1 & PS5. €5,000 after implemented specialists
elements of a terminal and that the former owners are satisfied / confirmation of
Resettlement livelihoods restored. location of
Action Plan Requirement applies where resettlement is repair and
(RAP) as necessary following confirmation of development maintenance
required under locations and if any physical or economic yard
EBRD PR5 (if displacement is necessary.
required)
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
27 Include in To ensure compliance with Turkish regulations Turkish legislation, Municipality Construction Prior to bid HR policies Use of internal
tender and GIIP. Establishment of a HR policy will EBRD PR2, IFC PSs documents (endorsed by resources and
documents improve worker relations, assist with the 1&2 and GIIP being issued. senior external HR
that communication of work related issues such as management) and advisors.
Contractor equal opportunities and non-discrimination; procedures
must develop worker rights; hours of work; working conditions; prepared and terms
and maintain and anti-harassment. of appointment
HR policies provided.
and Municipality to
communicate monitor to confirm
terms of compliance
appointment
to employees
Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building
Legislation
Requirement / EBRD
Responsible Target and
Performance Applicable to
Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Requirement //IFC Construction Comments
Resources / completion for successful
Performance or Operation
Investment implementation
Standard/ Good
Practice
28 Include in Where security personnel are being appointed EBRD PR4, IFC PS 1& Municipality Construction Prior to bid Security plan Apply the
tender conduct an assessment potential risks to those 4 and GIIP. documents agreed by senior principles of
documents within and outside the project site being issued management. proportionality to
that Municipality to preparation of
Contractor monitor to confirm this plan.
must develop compliance
and implement
a security plan
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
Environmental Management
1 Obtain To ensure compliant operations of the new repair Turkish legal Municipality Operation Prior to Operating permit
operating and maintenance yard. requirements. EBRD PR1, Izdeniz commencing covering integrated
permit IFC PSs and GIIP € operation of environmental
the yard impacts.
2 Develop and To improve environment management and risk EBRD PR1 and PR3, IFC Izdeniz and Operation Q1 2014 Develop an Use of
implement an control by providing a system(s) to drive continual PSs and GIIP consultant integrated internal
Environmental improvement, identify and manage key support management system personnel and
Management Environment aspects and impacts of both off to comply with ISO external
System shore and on shore activities, manage €25,000 to 14001 standard, or specialists.
contractors, monitor and review performance and €35,000 equivalent, and seek
ensure compliance with Turkish legislation, certification.
permits and international environmental
requirements (e.g. MARPOL 73/78).
The Environment management system will act as
an umbrella framework co-ordinating all
management plans mentioned within the ESAP.
3 Appoint a To ensure compliance with Turkish legislation and EBRD PR1 and PR3, IFC Izdeniz Operation Q2 2013 Appointment of an The post
qualified and international guidance and oversee development PSs and GIIP Environmental could be
trained and implementation of the EMS, management Mgt cost Officer / Manager fulfilled by
Environmental system and actions identified within this ESAP in either an
Officer / relation construction and future operation. internal
Manager appointment
or external
expert.
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
4 Develop and Ensuring compliance with national and Turkish legislation, EBRD Izdeniz and Operation Q1 2014 Implementation of Use of
implement an international environmental & social guidelines PR1 and PR3, IFC PSs consultant EMP and periodic internal
Environmental (e.g. MARPOL 73/78), by formalising and GIIP support updates as and/or
& Social environmental management and risk control. applicable external
Management ESMP will assist with the implementation of the (cost included specialists.
Plan (ESMP) Environmental management system, co- within budget
ordinating with other relevant management plans for Action 2)
(e.g. for air, waste, water, noise, traffic,
biodiversity etc.) and specifying monitoring
requirements.
5 Develop and To ensure co-ordinated and effective responses Turkish legislation, EBRD Izdeniz and Operation Q3 2013 Develop and Use of
implement an to emergencies for both on shore and off shore PR1, PR 2, PR3 and PR4, consultant implement ERP and internal
Emergency activities, both man-made and natural including IFC PSs 1-4 and GIIP support update whenever and/or
Response fires, spills, earthquakes etc., and compliance necessary external
Plan (ERP) for with national and international guidelines. As well €15,000 to specialists.
all foreseeable as ensuring the safety of its employees and €25,000
emergency contractors, it will also safeguard the local
situations community and include an Oil Spill Response
Plan (OSRP).
6 Develop and To ensure compliance with national and Turkish legislation, Izdeniz and Operation Q4 2013 Develop and Use of
implement a international environmental guidelines on the international requirements, consultant implement HMMP, internal
Hazardous management of hazardous materials both on EBRD PR3, IFC PSs 1-4 support including register and and/or
Materials shore and off shore including their safe storage and GIIP update as required. external
Management and handling, refuelling procedures and €10,000 to specialists.
Plan (HMMP) secondary containment. Co-ordinate with other €15,000
management plans (i.e. ESMP and ERP) and be
communicated to all parties.
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
7 Develop and Initially to support the ESMP and ensure Turkish legislation, EBRD Izdeniz and Operation Q4 2013 Commencement of
implement an compliance with national standards as well as the PR1, PR3, PR4 and PR6, consultant monitoring
Environmental reduction in environmental and social impacts. IFC PSs, GIIP and support programme and
& Social Based on the results of the monitoring (e.g. air, commitments revision for operation
Monitoring waste and water quality, noise, vibration, light / Indicative to incorporate any
Programme illumination and biodiversity), review management annual cost permit requirements.
plans and develop improvement programmes. €20,000 to
€40,000
8 Improve the To ensure compliance with Turkish regulatory and Turkish legislation, EBRD Izdeniz and Operation Q4 2013 A formalised and Use of
Contractor permitting requirements, including the monitoring PR1 and PR3, IFC PSs, consultant documented audit / internal
Monitoring of housekeeping and contractor permits to reduce GIIP and commitments support monitoring personnel.
Programme 3rd party risk exposure associated with both off programme
shore and on shore activities. Records should be Indicative implemented.
retained for all contractors. Will also support the annual cost
EH&S management system compliance €10,000 to
requirements and reduce risk of reputational €15,000
issues associated with employed contractors.
9 Improve, To ensure compliance with national and Turkish legislation, EBRD Izdeniz and Operation Q4 2013 Develop and To include
develop and international environmental guidelines. The PR1, IFC PS1 and GIIP consultant implement project
implement an environmental training should be tailored to the support Environmental specific
Environmental audience, and include senior management to Training Program for issues, the
Training ensure they are aware of their responsibilities, €10,000 to various grades of EMP and
Programme BAT/IMO/MARPOL concepts and emergency €30,000 staff and contractors emergency
response. The training should be applied to on for on shore activities spill
shore activities. response.
Use of
internal
and/or
external
expert
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
10 Develop a To ensure compliance with national and Turkish legislation and Izdeniz and Operation Q3 2013 Develop and Use of
Solid and international environmental guidelines, including international requirements, consultant implement WMP and internal
Liquid Waste MARPOL 73/78, on minimisation, segregation, EBRD PR1 and PR3, IFC support update for operation and/or
Management use of licensed contractors and disposal facilities, PS1 & PS3 and GIIP and as required external
Plan (WMP) consideration of waste hierarchy, incorporating €3,000 to specialists.
both off shore and on shore activities. The WMP €7,000
should include both non-hazardous and
hazardous waste and co-ordinate with other
management plans. Communication of the plan
and changes should be to all parties.
11 Compliance To ensure compliance with international marine Turkish legislation, Izdeniz Operation Q3 2013 Procedures that
with all IMO standards/laws and EBRD Performance international standards demonstrate
and MARPOL requirements and IFC Performance Standards. and EBRD PR1, PR2, €10,000 to compliance e.g. Air
requirements IMO and MARPOL requirements for environment PR3, PR4, PR6, IFC PSs €30,000 quality procedure to
as they relate and health & safety for passenger and vehicle and GIIP. meet MARPOL
to passenger ferries should be implemented, including Annex VI: Air
and vehicle elements that have not entered into Turkish law. pollution.
ferry
operations.
12 Develop and To ensure compliance with national and EBRD PR1, PR3, PR4 and Izdeniz and Operation Q4 2013 BCMS in place and Use of
Implement international environmental guidelines and PR6, IFC PS1, PS3 & PS6 consultant implemented. internal and
Biodiversity precautionary principles, and either confirm no and GIIP. support external
specialists.
Conservation discernible impact or minimise any impacts to
& Monitoring biodiversity. €5,000 to
€10,000
Plan (BCMP)
Health & Safety and Employment Management
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
13 Improve on To improve H&S management and risk control by Turkish legislation and Izdeniz and Operation Q3 2013 Develop an Use of
the ISM providing a system(s) to drive continual international requirements, consultant integrated internal
extend improvement, identify and manage key health and EBRD PR1&2, IFC PSs1-2 support management system personnel and
implementatio safety risks associated with shore based activities and GIIP. to comply with external
n of the Health in addition to the ISM system for ferries, manage €20,000 to OHSAS 18001 specialists.
and Safety contractors, monitor and review performance and €40,000 standards, or
Management ensure compliance with Turkish legislation, equivalent, and seek
System permits and international H&S requirements (e.g. certification.
(HSMS) MARPOL 73/78, SOLAS).
The HSMS will act as an umbrella framework co-
ordinating all management plans mentioned
within the ESAP.
14 Develop and To ensure compliance with Turkish regulations Turkish legislation, EBRD Izdeniz and Operation Q4 2013 Develop and Use of
implement a and international H&S guidelines. The HSMP will PR1, PR2 and PR4, IFC consultant implement HSMP internal
Health & assist with the implementation of the EH&S PSs 1-4, GIIP and support and update the plan and/or
Safety management system and should be commitments as necessary external
Management communicated to all parties. The HSMP will Cost included specialists.
Plan (HSMP) oversee the activities of the ferry and in 11
wharf/terminal operations and its contractors and
will also consider community H&S requirements.
15 Improve and To ensure compliance with Turkish regulations Turkish legislation, EBRD Izdeniz and Operation Q4 2013 Commencement of Use of
extend and international H&S guidelines. Based on the PR1, PR2 & PR4, IFC consultant monitoring internal
implementatio results of the monitoring, relevant preventive and Pss1-4 and GIIP support programme and/or
n of the H&S corrective actions and updates should be external
Monitoring implemented. Indicative specialists.
Programme Aspects to be monitored and associated records annual cost Should
to be retained include accidents, incidents, €15,000 to include
training needs, inspections, occupational €30,000
exposure, chemical exposure, working conditions
etc. operation of the wharves and repair and
maintenance yard.
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
16 Develop risk To ensure compliance with Turkish legislation and Turkish legislation, EBRD Izdeniz and Operation Q3 2013 Develop and Use of
assessments international H&S guidelines. RAs should PR2 and PR3, IFC PSs1-4 consultant implement RAs and internal
(RAs) and consider all physical, chemical and biological and GIIP support SOPs and update personnel and
safe operating hazards associated with the ferry and terminal periodically as external
procedures operation activities and its contractors. This €5,000 to required specialist
(SOPs) should include a flammables/explosive €15,000
atmospheres assessment (ATEX). Based on the
findings appropriate preventative and protective
measures and SOPs should be implemented and
communicated to all parties.
17 Improve and To comply with Turkish legislation, international Turkish legislation, Izdeniz and Operation Q4 2013 Develop and Use of
extend standards and GIIP, provide a safe work international standards, consultant implement training internal
implementatio environment and prevent accidents or injuries EBRD PR2, IFC PS1 & support program and update and/or
n of H&S from occurring. PS2 and GIIP the program as external
Training H&S training should extend to cover all onshore €10,000 to necessary trainers.
Programme and off shore job specific hazards, as well as use €30,000 First Aid
of PPE, site rules and compliance with SOPs. training
Other specific training should also be provided should be a
(e.g. fire fighting and spills) and at least 1 in every short term
10 workers should receive First Aid training as a priority.
matter of urgency to comply with Turkish
legislation.
18 Develop and To ensure compliance with Turkish regulations Turkish legislation, EBRD Izdeniz with Operation Q1 2014 Develop and Use of
implement an and international H&S guidelines. Will ensure that PR2, IFC PSs1-3 and GIIP specialist implement the internal
equipment / equipment is appropriately maintained and that support program and ensure resources and
machinery the periodic inspections required under Turkish that periodic external
inspection and legislation (e.g. every 3 months by MEC certified €10,000 to inspections are up to specialists
planned engineers for cranes) are completed by Izdeniz €20,000 date to comply with
preventive and its contractors. regulatory
maintenance requirements
(PPM)
programme.
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
19 Obtain legal Legal compliance to allow ferries to be Turkish and international Izdeniz Operation First vessel Operating licences
authorisations operational. Delivery of all ferries (passenger and legal requirements. EBRD delivery for each vessel.
for the vehicle) should be accompanied by the PR1and IFC PS1.
operation of appropriate licences from international and
each ferry as it Turkish shipping authorities.
becomes
available.
Social Management
20 Adopt and To complement, enhance and formalize ongoing EBRD PR1 and PR10, IFC Municipality Operation Q3 2013 SEP in place and Includes
implement the stakeholder engagement and reporting of social PS1, PS4 & PS5 and GIIP. with implemented. establishing a
Stakeholder and environmental issues. Improved relations with consultant A suitable set of key SEP team to
Engagement the community and stakeholders and decreased support performance oversee
Plan (SEP) complaints. indicators (KPI) will charge of
developed by €10,000 to be used by the stakeholder
Environ €20,000 Municipality to engagement
monitor stakeholder
engagement.
21 Develop a Currently Izdeniz has a relatively low number of Turkish legislation, Izdeniz Operation September Gender diversity plan
gender women within certain positions across the international standards with 2013 in place. Increase
diversity plan company despite having women in a larger EBRD PR2, IFC PS1 & consultant proportion of women
number of upper management and board level PS2 and GIIP. support working across the
positions. A plan could include the understanding company divisions.
of the needs and interests of working women,
current recruitment procedures, current career €5,000 to
development for women and the possibility of €10,000
mobility in order to identify whether there is
progressive and adequate recruitment and/or
mobility of females across the company; provision
of facilities for women within the ferry and terminal
operations and ferry/terminal safety and security
arrangements for women travellers.
Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation
Legislation Requirement Responsible Target and
Applicable to
/ EBRD Performance Party / Timetable for evaluation criteria
No. Action Environmental Risks / Liability / Benefits Construction Comments
Requirement / Good Resources / completion for successful
or Operation
Practice Investment implementation
22 Develop and A formal mechanism for workers to raise EBRD PR2 and IFC PS1 & Izdeniz Operation Q2 2013 A documented
implement a reasonable workplace concerns. This should PS2. internal grievance
formalized involve an appropriate level of management and Mgt cost procedure describing
internal address concerns promptly, be transparent and the process in place.
grievance provide feedback.
mechanism.