Gaziantep Healthcare Hospital Property Yatirim A.S.

A.  Project Description

Samsung Asset Management (SAM), acting in its capacity as fund manager for Samsung Gaziantep Trust Fund (SGTF), has requested the Multilateral Investment Guarantee Agency (MIGA) to provide political risk insurance for its equity investment and shareholder loan into the Gaziantep Integrated Healthcare Campus (IHC) PPP Project (hereafter referred to as “the Project”) in Turkey. The Project is part of the Turkish Health Public-Private Partnership Program (PPP Program) developed by the Turkish Ministry of Health (MoH) to increase capacity of public hospital infrastructure in the country.  

In the specific context of Gaziantep, the Project would increase the efficiency of health services in a rapidly growing region in Turkey. Gaziantep has a high population density compared with the rest of Turkey, and has recently experienced a significant influx of Syrian refugees. MIGA has previously supported the PPP Program by issuing guarantees for investment in the Adana Integrated Health Campus and Yozgat Education and Research Hospital.

The Project site is a vacant land plot in the Sahinbey District of Gaziantep Province in southeast Turkey, approximately 40 km from the Syrian border. The site was formerly under the ownership of Ministry of Finance, and was given to the Ministry of Health (MOH) for construction of the Project.  MOH has leased the land to the Project. The Project area is surrounded by five neighborhoods: Akkent, Karataş, Güneş, 75 Yıl and Dumlupınar. The key human receptors in the vicinity of the Project are the developed residential areas and the educational and recreational facilities that surround the Project site. There are large numbers of high-density existing residential properties located to the west of the site and to the south of the site. Recreational and educational facilities are also located to the west and on the site boundary. The closest sensitive receptor is TOBB High School, which is located immediately adjacent to the Project site. The High School has 600 students, including 200 boarders.

The Project involves the construction of a 1,875 bed Healthcare Campus over an area of 330,091 m2. The Project will include four tower buildings with a main hospital core with a total bed capacity of 1,625 beds; a 100 bed High-Security Forensic Hospital; and a 150 bed Rehabilitation Hospital. In addition, there will be administrative buildings, car parking areas, a helipad and a tri-generation plant (17 MWth capacity). A concrete batching facility with a production capacity of 240 m3 per hour will also be installed onsite for the construction phase. Mobilization and early works commenced in March 2016. Construction will take approximately three years to complete. During operation, the workforce is anticipated to be approximately 6,100, of which approximately 3,600 will be healthcare professionals and 2,500 operational and maintenance staff.

The Project will be undertaken by Gaziantep Healthcare Hospital Property Yatirim A.S. (the “Project Company”). The Project Company is a special purpose vehicle incorporated under the Turkish Commercial Code, which is owned by Samsung C&T Corporation of Korea (“SCT”), Salini Impregilo of Italy (“Salini”), Kayi Construction Inc of Turkey (“Kayi”), and Samsung Private Equity Investment Funds of Turkey (“SPEIF”). SPEIF is an investment vehicle managed by RHEA, a Turkish asset management company. The Project Company will be responsible for the construction, maintenance, and management of the facilities and for providing medical support services. The Project Company has engaged an Engineering, Procurement and Construction (EPC) contractor, CCN Insaat, as the main contractor to undertake construction of the Project. The MoH will deliver medical care services once the hospital becomes operational, and the Ministry of Justice will have a role in managing the High-Security Forensic Hospital. At the end of the Project’s operating 25-year period, the facilities will be transferred to the MoH.

Potential lenders to the Project include multilateral and bilateral financial institutions, including European Investment Bank (EIB), the European Bank for Reconstruction and Development (EBRD) and The Export and Import Bank of Korea (Korean Exim Bank).

B.  Environmental and Social Categorization

The Project is a Category B under MIGA’s Policy on Environmental and Social Sustainability (2013) because the potential environmental and social impacts are limited, site-specific, largely reversible, and can be readily addressed through mitigation measures.

Key environmental and social issues during construction include effects on air and water quality, soil and vegetation removal, increased noise levels and vibration, solid and liquid domestic and hazardous waste management and incidents related to occupational and community health and safety.  During operation, key environmental and social risks include generation of general solid and liquid waste, generation of hazardous waste (including medical waste and residual pharmaceutical waste), air emissions, life and fire safety risks, and adequacy of emergency response.

C.  Applicable Standards

While all Performance Standards (PS) will be applied to the Project, based on current information, it is expected that the Project will be managed in accordance with the following PSs:

• PS1: Assessment and Management of Environmental and Social Risks and Impacts
• PS2: Labor and Working Conditions
• PS3: Resource Efficiency and Pollution Prevention
• PS4: Community Health, Safety, and Security

PS5 (Land acquisition and Involuntary Resettlement) does not apply to this investment.  The Project site is owned by the Treasury and allocated to the MoH for the Project. As the site is vacant, no physical or economic resettlement is required. 

The development of the Project is not expected to have adverse impacts on biodiversity and PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not applicable. PS7 (Indigenous Peoples) is not relevant to this project since indigenous communities are not present in the area. While impacts on cultural heritage are not anticipated, as part of the ESMS, MIGA will require a chance finds procedure in accordance with PS8 (Cultural Heritage).

In addition, the following World Bank Group Environmental, Health, and Safety (EHS) Guidelines are applicable to the Project:

• World Bank Group General EHS Guidelines
• World Bank Group EHS Guidelines for Health Care Facilities

D.  Key Documents and Scope of MIGA Review

MIGA’s review consisted of appraising environmental and social information submitted by the Project. The following documents have been reviewed by MIGA:

• Environmental and Social Impact Assessment (ESIA) for the Gaziantep Integrated Health Campus (ERM, September 2016);
• Environmental and Social Action Plan for the Gaziantep Integrated Health Campus (ERM, September 2016);
• ESIA Annexes A – H for the Gaziantep Integrated Health Campus (ERM, September 2016);
• ESIA Annex I Stakeholder Engagement Plan for the Gaziantep Integrated Health Campus (ERM, September 2016);
• Monthly Construction Monitoring Report (HSE Section) – Gaziantep IHC (June 2016);
• Monthly Construction Monitoring Report (HSE Section) – Gaziantep IHC (July 2016);
• Monthly Construction Monitoring Report (HSE Section) – Gaziantep IHC (August 2016).

In addition to reviewing the above documents, MIGA’s environmental and social specialist visited the Project site in December 2015. The visit included a walk-over of the Project site and meetings with representatives of the Project sponsors, local government officials and local communities. The site visit also included a tour of the local medical waste facility and meetings with engineer in charge of the facility.

E.  Key Issues and Mitigation

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment:

Though the Project does not fall under the scope of the Turkish Environmental Impact Assessment Regulation (refer to the section on Environmental Permitting below), an Environmental and Social Impact Assessment (ESIA), Environmental and Social Management Plan (ESMP) and Environmental and Social Action Plan (ESAP) were completed for this project in September 2016. The Project Company retained an independent environmental consulting firm (ERM) to undertake the environmental and social assessment and prepare the documents in line with IFC Performance Standards (2012), EBRD Performance Requirements (2008) and applicable sub-sectoral environmental and social guidelines, and WBG EHS general and sector-specific guidelines. The ESIA presents baseline information, identifies potential impacts and risks, and mitigation measures for the Project. The ESMP provides a framework for developing required management and monitoring plans per the risks identified for both construction and operations. The ESIA also included consideration of potential cumulative impacts to determine the effect of the Project together with other planned and proposed development in the project area. 

Key risks and impacts identified for the construction phase of the Project include health and safety risks intrinsic to construction activities such as physical hazards related to the use of machinery and vehicles; management of hazardous substances; increase of dust emissions from excavation; noise emissions from vehicular traffic and machinery operation; risks associated with the presence of the construction workforce (including the accommodation camp); and community safety risks associated with unauthorized site access and increased traffic. During operation of the Project, key potential environmental and social risks include: exposure and spread of infectious diseases induced by handling of materials and improper waste contaminated with blood-borne pathogens; exposure to hazardous materials and waste including specific toxic chemicals and gases used in sterilization of medical equipment, formaldehyde, mercury, solvents, etc.; inadequate solid and liquid waste management; and risks associated to inadequate discharge of contaminated wastewater. Traffic related accidents and security management were also identified as risks during operations. It is expected that proper implementation of an Environmental and Social Management System (ESMS) and ESMP during the construction and operation of the Project will avoid and/or minimize risks and impacts to the extent possible ensuring safe working conditions for the workers and neighboring community. Potential cumulative impacts identified included the impacts associated with increased traffic, from both the project and other development in the area, and interactions between the local community and construction workers. Measures were identified to address these potential cumulative impacts.

The ESIA also identified several potential positive impacts of the project, including: improved health services, employment opportunities and local economic development.

Management Program:

The Project Company has issued Health, Safety and Environment, Quality, Human Rights, Human Resources and Corporate Social Responsibility Policies. The following management plans and procedures have also been developed, and are being implemented during construction: Health and Safety Management Plan; Emergency Preparedness and Response Plan; Environmental Leakage Management; Air Quality Control Monitoring Plan; Noise Control and Monitoring Plan; HR Management Plan; Grievance Management Plan; Protection and Security Plan; Traffic Management Plan; Archeological Chance Finds Management Procedure; Accident / Incident Investigation Procedure; Waste Management Procedure; and Annual Training Plan. These plans are supported by forms, follow-up charts, control lists, presentations and handbooks, as appropriate.

Prior to operations, detailed environmental, social, health and safety (ESHS) management plans will be prepared based on the framework ESMP by the Project for construction and operations. 

Organizational Capacity:

All three Project sponsors are experienced construction companies and all have obtained ISO 14001 Environmental Management and OHSAS 18001 Occupational Health and Safety Management certifications. The main EPC contractor, CCN Insaat, is a newly established company, and therefore does not yet have ISO 14001 and OHSAS 18001 certifications. They are, however, using the policies, systems and procedures of their parent company, which does have ISO 14001 and OHSAS 18001 certifications. The Project Company is in the process of establishing institutional arrangements for implementing the ESMS, and will establish an EHS department and appoint a director with responsibility, sufficient authority, and resources for all EHS matters. The EHS department may also recruit additional EHS officers as deemed necessary to achieve effective and continuous E&S performance. EHS orientation and training programs are conducted during construction, and will be conducted during the operations phase of the project.

As of the end of August 2016, the Project had 43 EHS staff on site, including 4 chiefs, 3 supervisors and 17 inspectors.

Emergency Preparedness and Response:

An Emergency Preparedness and Response Plan (EPRP) has been developed for the construction phase. The plan details management procedures for issues related to occupational accidents, fire, fuel and chemical spills, natural disasters such as flooding and earthquakes, as well as relevant roles and responsibilities.  Contractors and sub-contractors are also required to develop and prepare their own site-specific EPRPs in line with the overarching plan in the ESMS. The EPRP may be updated throughout the project lifetime as necessary, and the EPRP for operations will consider the forensic hospital in detail for all types of incidents, accidents and disasters.

Monitoring and Review

The ESMP has been prepared in order to define key environmental, health and safety (EHS) and social aspects, and ensuring operation within the applicable laws and regulations of Turkey, as well as the policies of international financial organizations for the Project and will align operations within the applicable laws and regulations of Turkey, as well as the policies of international financial organizations. For the construction phase, detailed monitoring plans for air quality and noise have been prepared, as well as a procedure for monitoring waste generation and disposal. The Project has also developed a template for annual environmental and social reporting.

MIGA will require Annual E&S Monitoring Report (AMR) throughout the guarantee period on environmental, health & safety and social performance, regularly in accordance with the MIGA’s PSs and relevant World Bank Group (WBG) EHS Guidelines.

PS2: Labor and Working Conditions

It is anticipated that the Project will create employment opportunities during the construction and operation phases. It is estimated that the construction phase will require approximately 3,000 workers.  The expected workforce requirement during the operation phase is anticipated to be 3,600 health care professionals and up to 2,500 operational and maintenance staff. First priority will be given to a local workforce while providing equal employment opportunities to women. Benefits to the local economy are expected due to the potential influx of immigrant workers.

The Project is also likely to create job opportunities for Syrian refugees living in the area. As Syrian refugees are considered a vulnerable group with respect to employment, the Project Company will ensure that they only recruit refugees who have an official residency permit and identity card. Refugees will not be paid less than other staff for doing the same job and will not be recruited informally.

During construction, the Project will construct worker camps (nine dormitories) on site for approximately 3,000 construction workers. Workers’ living conditions will comply with Turkish law and the performance requirements of EBRD (PR 2) and IFC (PS 2) as well as the joint EBRD / IFC Workers’ Accommodation: Processes and Standards Guidance Note (2009). The Camp Management Plan will include a Workforce Code of Conduct, reference to the Project’s Occupational Health and Safety Management Plan and provisions for induction and training. Workers’ accommodation arrangements will not restrict their freedom of movement or of association.  

As the Project is being constructed to address a shortage of hospital beds in Gaziantep, it is unlikely that the Project will result in any retrenchment or closure of existing hospitals in the area. 

Human Resources (HR) Policies and Procedures

Labor practices in Turkey are regulated by the Labor Law No. 4857 of 2003, which standardizes employees’ work-related rights, working conditions and stipulates obligations of employers and employees. Turkey also has an Occupational Health and Safety (OHS) Law and a Regulation of Workers Health and Safety that stipulate detailed criteria for safe working conditions at job sites.  The Project Company has in place a Human Resources (HR) Policy and HR Management Plan in accordance with Turkish law and PS2 requirements. The HR Management Plan includes an employee grievance mechanism. The HR Policy, Management Plan and grievance mechanism are communicated to all employees, including contractors and sub-contractors, during site induction training.

Occupational Health and Safety

A Health and Safety Management Plan, which is consistent with the requirements of OHSAS 18001, has been prepared and is being implemented for the construction phase of the Project. Since the beginning of construction, 3 Lost Time Incidents have been reported. Health and safety statistics are reported on a monthly basis in the Construction Monitoring Report. The Project Company provides staff with Personal Protective Equipment and employees are provided with training in all relevant environment, social, health and safety management topics, in particular OHS for handling hazardous materials and medical waste for workers and contractors.  A Health and Safety Plan will also be prepared for operations.

PS3: Resource Efficiency and Pollution Prevention

Baseline conditions were established for the study area through field measurements for air quality, noise, hydrology, hydrogeology, geology, soil quality, and terrestrial ecology (see ESIA Annexes for more details). This section summarizes key ESIA findings and proposed mitigation measures to avoid and control potential impacts related to emissions and air pollution, noise and vibration levels, wastewater discharge, and solid, medical, and hazardous waste management among others, as identified in the ESMP.

Wastewater

During the Project construction and operation phases the total daily domestic wastewater generation of the Project is estimated to be around 500 m3/day and 3,000 m3/day, respectively. All wastewater produced by the Project during construction and operation will be filtered through a decontamination tank and oil catcher before being discharged to the municipal sewage pipeline. Wastewater will then be treated by the Gaziantep Municipal Wastewater Treatment Facility. The existing capacity of the treatment facility is 400,000 m3/day, and it is currently treating 300,000 m3/day, and therefore has the capacity to manage the additional domestic wastewater during construction and operations. The Project Company will obtain a wastewater connection permit since all domestic wastewater during all project phases will be discharged into the existing municipality sewer lines in accordance with Waste Management Regulation (Official Gazette No: 02.04.2015/29314) and WBG EHS Guidelines. 

Wastewater contaminated with radioactive substances will be collected separately and will be monitored prior to being discharged into the sewer system per conditions set under the Regulation on Wastes Generated upon Usage of Radioactive Substances (Official Gazette Date/No02.09.2004/25571). Approval from the municipality will be required prior to discharging radioactive wastewater, per the referenced law. This authorization will be obtained during the licensing process. Per the WBG EHS Guidelines for Health Care facilities the capacity of the municipality to receive this type of wastewater must be confirmed and a wastewater management plan completed.

Waste Management and Disposal

The Project will produce hazardous medical wastes (from activities in labs, departments of pathological anatomy and expired medication), other wastes (including toners, neon light bulbs and batteries) and general wastes (such as kitchen and cafeteria wastes, paper, plastic, glass and aluminum). Estimated volumes of waste to be produced during construction and operations is provided in the ESIA.

A Waste Management Procedure has been developed for the construction phase, and a project-specific Waste Management Plan (WMP) will be prepared for the operations phase. The ESIA identifies all waste streams and some anticipated waste quantities, describes transportation and disposal requirements, and outlines waste management responsibilities. All waste streams will be managed and disposed of in accordance with Turkish regulation and WBG EHS Guidelines for Health Care Facilities. Wastes will be collected, segregated, stored, and transported separately from other wastes based on their physical, biological and chemical characteristics.  Disposal of medical waste will be done by a third party company and will consist of delivering it to the Gaziantep Municipality medical waste collection system, which has the required permits and capacity to handle the wastes generated. All domestic waste will be disposed at the Gaziantep Solid Waste Disposal Facility.

Site preparation and construction include soil excavation activities which have largely been completed at the Project site. It is estimated that up to 645,000 m3, some of which was reused on site for backfilling and levelling. The remaining 470,000 m3 will initially be stored on site, and then transferred to an area identified by Gaziantep Metropolitan Municipality. Soil sampling conducted at the Project site during the ESIA phase did not show any sign of contamination.  

Domestic waste generation during construction will include contaminated soils, sanitary and domestic wastes, and clean-up materials from accidental spills.  The estimated domestic waste generation during the construction phase is 3,593 kg/day.  Domestic waste during construction will be stored in waste containers and will be collected by the Gaziantep Municipality garbage trucks and transported to the Gaziantep Solid Waste Disposal Facility. During operation, it is estimated that the hospital will produce approximately 4,406 kg/day.

Generation of hazardous wastes, including medical and radioactive waste, will be a key impact during the operation of the hospital. The medical waste stream is expected to include infectious and pathologic, pharmaceutical, and sharp waste proceeding from various processes at the hospital. Medical waste will be collected from the hospital and transported to the Gaziantep Medical Waste Sterilization Facility prior to being disposed in the municipal landfill. The annual medical waste generation for the Project was estimated at 1,556 kg/day. Collection and disposal of the medical wastes in the Project will be done in line with Regulation on Medical Wastes Control-Official Gazette Date/No: 22.07.2005/25883.

The radioactive waste stream is expected to include residual radionuclides proceeding from unused liquids from radiotherapy or laboratory research; contaminated glassware, packages or absorbent paper; urine and excreta from patients treated or tested with unsealed radionuclides, etc. A Radioactive Substance Management Plan will be prepared prior to the start of operations. Clean-up materials such as spill kits will also be managed as hazardous waste.  Disposal will be done by firms authorized by Turkish Atomic Energy Authorization in accordance with regulation on Secure Transfer of Radioactive Materials and the Regulation on Management of Radioactive Wastes.  In addition to Turkish regulations, the Project will follow waste management practices stipulated in WBG general and sector-specific EHS guidelines.

Air Emissions

Main sources of air pollution during the construction phase were identified as excavation works and movement of vehicles, and engine emissions from exhaust gas from construction equipment and road traffic. Principal pollutants resulting from these sources are dust and particulate matter (PM) from soil excavation and removal; and nitrogen oxides (NOx), sulphur dioxide (SO2) and carbon monoxide (CO) from exhaust of vehicles.  Measurements for PM10 and a dust dispersion modeling study, as well as NO2 were completed to establish baseline conditions and potential impacts within the study area. Ambient air quality monitoring data indicates that the site location is an undegraded airshed for NO2. For PM10 however, ambient concentrations are consistently above the Turkish, EU and WBG EHS Guideline air quality Limit Values, which is related to natural background dust associated with the arid environment.

Impacts on the air quality during the operation phase will be mainly related to the emissions from the tri-generation plant and boiler system. A dispersion modeling study was undertaken for NO2, the most significant emission source from the mentioned systems. Modelling indicated that emissions from the tri-generation plant had the potential to exceed the Turkish, EU and WBG EHS Guideline air quality limit values, and therefore modifications and mitigation measures were proposed in order to minimize the potential impact. Modelling further indicated that implementation of the proposed mitigation measures, including increasing the stack height and combining the stacks for the tri-generation and boiler plants, would ensure that the emissions would not exceed guideline values.

Greenhouse Gas Emissions

During construction, greenhouse gas emissions associated with vehicle use are expected to be a total of 1,340 tCO2e for the 3 year construction period. Generation of greenhouse gas emissions during the operation of the tri-generation and boiler systems is expected to be 138,644 tCO2e/year. The project will be required to quantify the direct and indirect emissions annually per PS3 requirements. The Project will be expected to meet this requirement and undertake necessary actions to minimize these emissions.

Noise and vibration

Baseline measurements were taken for three representative points at the Project site, which indicated that existing day and nighttime values exceed WBG EHS standards. Impacts from noise and vibration are expected to be moderate during the construction and operation of the hospital. Impacts during construction will be temporary and will result from earthworks, blasting, construction traffic and the operation of construction equipment. A Noise Control and Monitoring Plan has been developed and is being implemented for the construction phase. The ESAP further requires the Project to develop and implement a monthly noise monitoring program at sensitive receptors.

Impacts during operation of the hospital will be caused by traffic, helicopter movement and ambulance movements and will have longer lasting effects. Noise impacts will be mitigated through the construction of buffers and earthen bunds, enforcement of speed limits and road surface modification and maintenance.

Water and energy use

Drinking and potable water during the construction and operation phases of the Project will be provided from the Gaziantep municipal water system. Water will also be required for other construction-related activities such as dust suppression, spraying concrete, site clean-up, etc. It is estimated that approximately 300 m3/day of water is required for construction. During the operation phase, there will be water uses related to general domestic and sanitary use, food preparation, sterilizers and autoclaves, etc. The water consumption rate for the Project is estimated to be 3,000 m3/day, which is within the range of typical water use per bed for a hospital of this size. Municipal water supply has been deemed adequate to fulfill these estimated requirements.

The estimated energy requirement for the hospital operation is 30 MW and the estimated annual electricity usage will be 262,800 MWh, equivalent to 446 kWh/m2 (which is below the average (591 kWh/m2) for health care facilities defined in U.S. Energy Information Administration. A tri-generation plant, with boiler capacity of 40 MW and tri-generation capacity of 17 MW will be constructed on site to supply all energy, heating, and cooling needs during the hospital operation. Diesel fueled emergency generators located within central energy plant will be used to provide 100% backup power supply for the hospital buildings. During construction, the main energy source during construction will be diesel fuel for construction equipment and vehicles. Thus, safety instructions for storage, transportation and usage of Hazardous Materials have been prepared for the construction phase.

Energy and water efficiency have been considered in the design and operation of the Project, for example, the Project includes solar panels as part of the design to support energy requirements. Energy and water resources management plans have been recommended as part of the ESMS, in conformance with PS3, to optimize resources use.

PS4: Community Health, Safety & Security

Typical risks associated with the construction of this project are safety risks, increased traffic of heavy machinery, noise, dust, hazardous material handling, and fire and life safety. The Project Company is implementing construction area safety measures to protect the citizens, including barricading, control of the access, traffic safety, control of the construction vehicles, clear signage and demarcation of areas and provision of safety information to visitors.

Life and Fire Safety

The Project is being designed and constructed in accordance with Turkish Regulation on the Protection of Buildings from Fire (issued on: 19.12.2007, Official Gazette (“OG”) No: 26735). Relevant technical requirements, including those delineated in applicable international standards, were integrated into the Project design and construction tender documents, e.g. fire suppression systems will be available throughout the hospital and a fire alarm system will be designed and installed.  Fire control and mitigation measures for the construction phase of the Project are contained in the Emergency Preparedness and Response Plan that has been prepared by the Project Company.  During the operation, the Project will comply with Turkish regulations on worker health and safety and fire signage and provisions for life and fire safety under PS4 and the WBG EHS Guidelines.

A Life and Fire Safety Master Plan will be developed for the Project in accordance with WBG EHS Guidelines. A third party audit will be conducted to assess gaps in local life and fire safety requirements and identify acceptable international standards to furnish such gaps. Per WBG EHS Guidelines, the Project will obtain the design and post-construction life and fire safety certifications from a professional acceptable to MIGA.      

The project is located in the 3rd degree earthquake zone per local classification (with 1st degree zones being at the highest risk and 5th degree zones being the lowest risk). Necessary criteria (e.g. appropriate standards, regulations, etc.) will be taken into account in the design of the facilities to address the seismic risks considering the specific parameters defined for the design of structures located in seismic zones. The Hospital will be constructed in line with the Turkish Regulation on the Buildings to be Built in Seismic Zones (Official Gazette date/no: 06.03.2007/26454).  

Traffic

The project location is in a relatively residential area and hence will result in traffic impacts during both construction and operation phases of the project. During the construction phase, traffic increase in the local environment is anticipated to be the one of the major impacts of the project due to the construction vehicles and trucks carrying constructional materials. It is estimated that up to 510 trucks would be travelling to and from the construction site during the first 6 months to 1 year of construction. Approximately 220 trucks would be travelling to and from the construction site during years 2 and 3 of construction. In the operation phase, there will be significant increase in traffic load due to transportation of employees, patients and visitors. According to the preliminary traffic assessment conducted by the Project Company, it is estimated that the Project will have over 50,000 daily users, and therefore during peak hours there will be a maximum two-way flow of approximately 5,147 cars contributing to local traffic loads. The Project Company will develop a Health Campus Internal Traffic Management Plan for the Project in consultation with local authorities in order to manage traffic within the Project site.

Security

Security personnel will be required throughout the duration of the construction period.   While there is no history of violence or negative interactions between security and local populations in Gaziantep, the Company has developed and is implementing a Protection and Security Plan to manage security services.

Security for the hospital will consist of an access control system of electronic card readers and electronic identification cards for employees, alarms, telecommunication devices and closed-circuit television cameras to be operated on a 24 hours basis. The high security psychiatric unit will be enhanced with security guards to be managed directly by the gendarme, a branch of the Turkish armed forces, in accordance with a triple protocol between the Turkish Ministry of Justice (MoJ), Ministry of Interior, and the MoH. A security plan, containing a security risk assessment, will be developed. The Project Company, together with the MoJ and MoH, will develop a Security Policy and Plan for the Project, which will detail the company’s position and measures to address the use of force, training, equipping and monitoring security guards as well as investigating reports of unlawful behaviour and preventing recurrence. All security personnel from private companies will be trained and will operate in accordance with local laws and international codes of conduct (i.e. International Code of Conduct for Private Security Providers; Voluntary Principles on Security and Human Rights; UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials; and UN Code of Conduct for Law Enforcement).

F.  Environmental Permitting Process and Community Engagement

Hospital projects do not fall within the scope (Annex 1 or 2) of Turkey’s EIA Regulation (Official Gazette Date November 24, 2014); however, as the production capacity of the concrete batching plant is greater than 100 m3, which is considered an Annex 2 project under the regulation. A separate ‘Project Information File’ (first step in obtaining an EIA decision) has been prepared for the concrete batching plant, and was submitted to the Ministry of Environment and Urban Development (MEUD) at the end of June 2016. An exemption application for the rest of the Project has also been submitted. The Project is waiting for a formal opinion from MEUD on both applications.

The Project has obtained a construction permit, as well as permits for domestic wastewater discharge during construction, and will obtain the operational environment permit, as required per the MEUD, which will cover wastewater discharge, air emissions, noise, and the temporary waste storage.  Prior to excavation, the Project also obtained an excavation permit as required by local authorities. The Construction Monitoring Reports include a table of all of the environmental permits requirement for the Project, including the status of permits. This table is updated on a monthly basis.

Client’s Stakeholder Engagement

A Stakeholder Engagement Plan (SEP) has been developed for the Project. The SEP clearly identifies all project stakeholders including government agencies, NGOs, neighboring communities, and the general public. It includes a grievance mechanism that provides an open channel for continuous and structured communication between management and the general public and describes a detailed strategy to place, investigate, respond, and file a given complaint and the expected timeline associated with these actions. Through this process, the public can express individual and collective concerns and issues regarding the construction and operation of the facility. The SEP also outlines communication methods appropriate for each Project phase, including publications through a corporate website.

Stakeholder engagement activities for the Project started during the scoping stage and continued during the preparation of the ESIA report. A public consultation meeting on the draft ESIA was held on November 24, 2015 at the Provincial Directorate of Health in Gaziantep, where 52 people (33 men and 19 women) attended. The meeting was announced via various advertisements in two newspapers and through handouts. Face-to-face meetings were also held with community leaders. Focus group discussion meetings were held with Syrian refugees (one with men and one with women) to understand any vulnerabilities around employment and using hospital services. Project details, ESHS risks and impacts, project delays, and other relevant topics were discussed during the meetings.  Additionally, public participation was requested through the distribution of feedback forms. While some concerns over potential impacts, such as noise and dust during construction, were expressed by stakeholders, in general, local stakeholders are aware of the public benefit of the Project. All of the concerns expressed by stakeholders were addressed in the final ESIA.

MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman

International Finance Corporation

2121 Pennsylvania Avenue NW

Room F11K-232

Washington, DC 20433 USA

Tel: 1 202 458 1973

Fax: 1 202 522 7400

E-mail: cao-compliance@ifc.org

G.  Availability of Documentation

The following documentation is available electronically as PDF attachments to this ESRS at www.MIGA.org. 

• Non-Technical Summary of Environmental and Social Impact Assessment (ESIA): Gaziantep Integrated Health Campus, September 2016
• Environmental and Social Impact Assessment (ESIA): Gaziantep Integrated Health Campus, September 2016
• ESIA Annexes A – H: Gaziantep Integrated Health Campus, September 2016
  • Annex A – Administration Framework
  • Annex B – Social Assessment
  • Annex C – Air Quality
  • Annex D – Noise and Vibration
  • Annex E – Waste Management
  • Annex F – Traffic Assessment
  • Annex G – Water Resources
  • Annex H – Geography and Soils
• Environmental and Social Action Plan: Gaziantep Integrated Health Campus, September 2016
• Stakeholder Engagement Plan: Gaziantep Integrated Health Campus, September 2016

It is also available for viewing at the following locations:

http://gaziantepihcproject-com.jimdo.com/english/esia/