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Turkey

Bursa Integrated Health Campus

$117.5 million
Services
Environmental and Social Review Summary
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modern hospital building

Project Facts

Project Facts

Project Facts

Turkey
Project ID
14743
Strategic Priority Area
Middle Income
Guarantee Holder
Meridiam Eastern Europe SarL
Investor Country
Luxembourg
Environmental Category
B
Date SPG Disclosed
February 10, 2017
Projected Board Date
March 30, 2017
Project Type
Non-SIP
Fiscal Year
2017

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only. Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.

Project Description

Meridiam Eastern Europe SARL Luxembourg (Meridiam) has asked the Multilateral Investment Guarantee Agency (MIGA) to provide political risk insurance for its investment in the Bursa Integrated Health Campus (Bursa IHC or Project). 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. MIGA has previously supported the PPP Program by issuing guarantees to Meridiam for its investment in the Adana Integrated Health Campus, Yozgat Education and Research Hospital and Elazig Integrated Health Campus.

The Project site is located on undeveloped land in the Dogankoy neighborhood within the Nilufer district of Bursa province. The land was given to the Ministry of Health by the Ministry of Forest and Water Works for the development of the health campus. The Project site consists of two parts: northern and southern parts separated by Bursa Ring Road.

The project footprint will cover 459,588 m2 (including enclosed car parking area). It comprises the development of an integrated health campus with a total capacity of 1,355 beds that consist of three hospitals: Main Hospital, Physical Therapy and Rehabilitation Hospital, and High-Security Psychiatric Hospital. The Main Hospital will include: General Hospital (275 beds); Cardiology and Cardiovascular Hospital (275 beds); Oncology Hospital (252 beds); Maternity and Pediatric Hospital (253 beds); 200-bed Physical Therapy and Rehabilitation Hospital and a 100-bed High Security Forensic. The complex will also include health support facilities, a technical unit building, possibly a commercial area, a helipad, and a tri-generation plant. The tri-generation system will have a total electrical capacity of 8.8 MW that will consist of four gas engines using natural gas with a capacity of 2.2 MW each.

The Project sponsors are a consortium of Meridiam Eastern Europe S.a.r.l and five Turkish companies, Ronesans Holding, Ronesans Saglik Yatirim A.S., Sila Danismanlik Bilisim Saglik Insaat Ticaret A.S. (“Sila”), Sam Yapi ve Sanayi Ltd. Sti (“Sam”) and TTT Saglik Hizmetleri Egitim Insaat Sanayi Ticaret A.S. (“TTT”). Under the Project Agreements, Bursa Sağlık Yatırım A.Ş. (BRS), a special purpose vehicle (SPV) created for the Project and jointly owned by Meridiam, Ronesans Holding, Ronesans Saglik Yatirim, Sila, Sam and TTT, will be the Project enterprise and will be responsible for the construction, maintenance, and management of the facilities and for providing medical support services. The MoH will deliver medical care services once the hospital becomes operational. At the end of the Project’s operating 25-year period, the facilities will be transferred to the MoH.

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 impacts include generation of general solid and liquid waste, generation of hazardous waste (including medical waste and residual pharmaceutical waste), air emissions, and occupational and community health, safety and security.

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
  • PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

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. However the landowners and tenant cultivating the land plot right next to the Project area will need to be closely monitored to ensure that their livelihoods are not affected.

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 ESMP, a Chance Find Procedure was developed and is currently being implemented on site.

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

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

Key Documents and Scope of MIGA Review

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

  • Environmental and Social Impact Assessment (ESIA): Bursa Integrated Health Campus  – July 2016
  • Environmental and Social Action Plan: Bursa Integrated Health Campus – July 2016
  • Stakeholder Engagement Plan: Bursa Integrated Health Campus – July 2016
  • Bursa Integrated Health Campus Environmental and Social Due Diligence Report – September 2016

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 July 2016.  The Project Company retained an independent environmental consulting firm (ELC Group – Royal Haskoning DHV) 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. An independent consultant (Mott MacDonald) was also engaged to undertake a due diligence review of the ESIA and associated documents against the IFC and EBRD requirements. 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 and noise emissions from vehicular traffic and machinery operation.  During operation of Bursa IHC, potential ESHS risks include: 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.

Management Program

BRS has a Health, Safety and Environment (HSE) Policy that is compliant with the requirements of PS 1. RMI Ronesans Medikal Taahhut Insaat A.S. (“RMI”), which will be responsible for construction, has obtained ISO 9001 Quality Management, ISO 14001 Environmental Management and ISO 18001 Occupational Health and Safety Management certifications. The ESMP delineates responsible parties for the implementation of the mitigation measures, the timing, monitoring, and audit requirements. The ESMP focuses on the avoidance of impacts, and where this is not possible, presents technically and financially feasible and cost-effective mitigation measures to minimize or reduce possible impacts to acceptable levels. As part of the ESMP, the following subject specific management plans and procedures were also prepared for the construction phase:

  • Air Quality Control and Monitoring Plan
  • Noise Control and Monitoring Plan
  • Waste Management Plan
  • Hazardous Material Management Plan
  • Emergency Response and Preparedness Plan
  • Construction Camp Management Plan
  • Community Health and Safety Management Plan
  • Site Security Procedure
  • Archaeological Chance Find Management Plan
  • Human Resources Management Plan
  • Health and Safety Management Plan
  • Subcontractor Management and Monitoring Plan
  • Traffic Management Plan

Organizational Capacity

RMI currently has an HSE department on site comprised of an HSE Manager, one HSE instructor and two HSE inspectors. At peak construction, it is estimated that EPC Contractor will have 39 EHS personnel on site. In addition, a Health & Safety (HS) subcontractor (Sıla Common Health and Safety Unit) has also been appointed. The subcontractor has four personnel including two HS Specialists, a workplace doctor and a nurse on site.

Emergency Preparedness and Response

As indicated above, an Emergency Response and Preparedness Plan (ERPP) has been developed for the construction phase of the Project. 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. An ERPP will need to be prepared for the operations phase of the Project.

Monitoring and Review

For the construction phase, monitoring plans are included in the subject specific management plans that have been prepared as part of the ESMP. These plans include monitoring procedures for key parameters and indicators to evaluate potential adverse social and environmental impacts. The plans also identify responsible parties, timing and reporting requirements. MIGA will also require annual monitoring reports throughout the guarantee period.

PS2: Labor and Working Conditions

The Project will create employment opportunities during the construction and operation phases. During peak construction, the workforce is anticipated to be about 3,000 people. When the Project starts to operate at full capacity, it will have approximately 4,568 employees: 1,961 health service personnel and 371 administrative personnel to be employed by MoH and 2,217 service employees and 19 administrative personnel to be employed by BRS A.Ş. 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 workers from other parts of Turkey.

A Worker’s Accommodation Plan has been prepared in accordance with IFC and EBRD

Workers’ Accommodation and Processes Guidance. Worker accommodation, in the form of a pre-fabricated building, has been constructed on site.

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.  RMI has developed a Human Resources (HR) Policy, Management Plan and Procedures in accordance with Turkish law and PS2 requirements.

A Health and Safety Management Plan has been prepared for the construction phase of the Project. As described under ‘Organizational Capacity’ above, a H&S subcontractor has been engaged to monitor H&S performance on site (as is required by law). Project HSE staff are also responsible for providing training on implementing safe operating procedures and following reporting requirements for accidents, incidents, and safety non-compliances. Construction workers will be required to attend certified occupational health and safety trainings per local law requirements and will be provided competency-specific technical and awareness training related to their responsibilities on site. Prior to the start of operations, BRS will assign an OHS manager, and will develop relevant procedures and plans for the operations phase. Employees will be provided 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.

Worker Grievance Mechanism

An employee grievance mechanism has been established by RMI to ensure that all workers (including those employed by sub-contractors) can adequately voice their concerns anonymously. Grievances are discussed on a weekly basis at the management meeting. The grievances are all logged in a grievance register. A grievance mechanism will be established for the operations phase.

Supply Chain

RMI HR Management plan includes consideration of third party workers and supply chain. The potential for child and forced labor in the supply chain will be monitored and contracts with sub-contractors and suppliers will include EHS requirements and provisions consistent with PS2 to address labor issues including child and forced labor.

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 765 m3/day and 2,168 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 Bursa West Wastewater Treatment Facility. The existing capacity of the treatment facility is 87,500 m3/day, and it is currently treating 51,205 m3/day, and therefore has the capacity to manage the additional domestic wastewater during construction and operations. The Wastewater Treatment Facility has also been constructed to consider population growth in the area, with a second phase ready to come online if and when needed. BRS will obtain a wastewater connection permit since all domestic wastewater during all project phases will be discharged into the existing sewer lines in accordance with Waste Management Regulation (Official Gazette (O.G.) 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 (O.G. Date/No02.09.2004/25571). Approval from the Bursa Provincial Directorate 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 province to receive this type of wastewater must be confirmed and a wastewater management plan completed.

Waste Management and Disposal

The production of solid, hazardous, medical and radioactive wastes is expected throughout different phases of the Project. Thus, a project-specific Waste Management Plan (WMP) covering site preparation, construction and operation phases of the hospital has been completed. The plan 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 will be done by a third party company and will consist of delivering it to the Yenikent Solid Waste Disposal facility, approximately 6 km from the Project site. There is also a licensed medical waste sterilization facility within the Yenikent site. The EIA indicates that both facilities have sufficient capacity to handle the waste generated by the Project.

Site preparation and construction include soil excavation activities which have already started at the Project site. It is estimated that 1,410,000 m3 of excavation wastes will be generated during the construction phase. This waste will be picked up by a contractor, and disposed of in an authorized disposal area in Bursa province.

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 Medical Waste Sterilization Facility at Yenikent Solid Waste Disposal facility.   The annual medical waste generation is estimated at 1,558 kg/day (assuming 1,355 beds).   Collection and disposal of the medical wastes in the Project will be done in line with Regulation on Medical Wastes Control (O.G. 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 were completed to establish baseline conditions and potential impacts within the study area. Test values are significantly below the associated limit values stipulated in the national regulations (Industrial Air Pollution Control Regulation (IAPCR) and Regulation on Assessment and Management of Air Quality (RAMAQ)), EU directive and WHO (which is consistent with the WBG General EHS Guidelines). Additionally, a vehicle movement analysis was performed to estimate baseline conditions for NOx, SO2, and CO emissions associated with construction activities. All values were under the maximum permissible limits in the national regulation (IAPCR).

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. Hourly and annual values of NO2 estimated from the tri-generation system are significantly below the associated limit values defined in the national regulations (IAPCR and RAMAQ), EU Directive and WHO Guidelines. Thus, impacts from pollutant and dust emission to the atmosphere is expected to be minimal during all phases of the Project. Monitoring and implementation of mitigation measures for the control of exhaust from all vehicles will be adopted per the ESMP.

Generation of greenhouse gas emissions during the operation of the tri-generation and boiler systems is expected to be 111,556 tons CO2/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

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 the operation of construction equipment. Impacts during operation of the hospital will be caused by the emergency generators, helicopter movement and ambulance movements and will have longer lasting effects. Baseline measurements were taken for three representative points at the Project site and indicated that existing day, evening, and nighttime values comply with Turkish regulatory limits and IFC standards. Per the ESAP, a Noise and Vibration Management Plan containing adequate monitoring procedures and mitigation measures (per local legislation and PS3) will be required for the Project as part of the ESMS.

Water and energy use

Drinking and potable water during the construction and operation phases of the Project will be provided from the Bursa municipal water system. A 150 liters/day per capita consumption rate was selected yielding a daily water requirement of 450 m3/day assuming 3,000 workers. Water will be required for other construction-related activities such as dust suppression, spraying concrete, site clean-up, etc. An additional 315 m3/day water consumption rate has been assigned for construction activities.  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 Bursa IHC was estimated to fluctuate between 1,694 and 2,168 m3/day. Municipal water supply has been deemed adequate to fulfill these estimated requirements.

The estimated energy requirement for the hospital operation is 41 MW (consumption of approximately 114,897,000 kWh annually). A tri-generation plant, with a thermal capacity of 18 MW and boilers with a total thermal capacity of 44.7 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. Each generator will be equipped with a day fuel tank that will be sized to operate the engine for a minimum of 2 hours continuous operation at full load. During construction, the main energy source during construction will be diesel fuel for construction equipment and vehicles.  Thus, a procedure will be developed to safely handle and store diesel fuel on site.

Energy efficiency will be considered in the design and operation of the Project. 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

Community health and safety risks associated with the Project include safety risks from unauthorized access and increased traffic, health risks associated with dust and noise, life and fire safety, infrastructure safety and security. The Project site is vacant, and is primarily surrounded by agricultural lands. The closest settlement to the northern part of the Project site (i.e. Balat neighborhood) is to the east with 1.5 km distance. The closest settlements to the southern part of the Project site include residential area at a distance of 50 m, Dogankoy Neighborhood at a distance of 1.5 km and some individual houses located in between residential area and Dogankoy Neighborhood. Dogankoy Primary School is located in central Dogankoy neighborhood at a distance of approximately 1.5 km to the southern part of the Project site. The site has been declared a “health facility area” according to the municipal zoning plan, and the surrounding land has been zoned for urban residential development.

The risks and impacts of the Project, in the context of health and safety of off-site communities, will be managed through a Community Health and Safety Management Plan, which has been developed BRS. A separate Traffic Management Plan has also been developed, which includes information on responsibilities for the implementation of the plan, instructions for safe movement of vehicles and pedestrians, driving rules, training requirement, road and vehicle maintenance and safety equipment requirements and auditing.

The Project is being designed and constructed in accordance with Turkish Regulation on the Protection of Buildings from Fire (issued on: 19.12.2007, O.G. No: 26735). Relevant technical requirements, including those delineated in applicable international standards, were integrated into the Bursa IHC 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 in accordance with the requirements of U.S. National Fire Protection Agency (NFPA) Code 72. Fire control and mitigation measures for the construction phase of the Project are contained in the Emergency Preparedness and Response Plan prepared by BRS. 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 operation of 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 a 1st degree seismic zone per local classification. Necessary criteria (e.g. appropriate standards, regulations, etc.) have been 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 Constructed in Seismic Zones (06.03.2007 O.G. No: 26454). In addition, an earthquake isolation system, by means of installation of seismic isolators, will be implemented in the Main Hospital building. This will minimize the occurrence of incidents and ensure that the risk of structural failures is as low as reasonably practicable in the event of natural hazards.  

For construction, a comprehensive site security plan has been developed, and a private security contractor has been engaged to secure the site 24 hours a day. 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.  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, Ministry of Interior, and the MoH.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Baseline studies undertaken as part of the ESIA process identified 235 individual trees on the Project Site. The trees were from common species including stone pine (pinus pinea), Mediterranean cypress (Cupressus sempervirens) and black locust (Robinia pseudoacacia). Prior to the start of construction, the trees were removed from site by the local Forestry Directorate. The Project will provide the Forestry Directorate with funds to undertake replacement planting. The site for the replacement planting will be selected by the Forestry Directorate. The Project will also monitor to ensure that replanting activities are undertaken.

Environmental Permitting Process and Community Engagement

The Project was processed under the Turkish EIA Regulation issued on 25 November 2014, which indicated that hospital projects are exempt from preparation of an EIA report. The Bursa Provincial Directorate of Environment and Urbanization (PDEU) issued a letter to the Project confirming its exempt status in April 2015. The concrete batching plant for the construction phase was also considered exempt from preparing an EIA report (confirmed in a letter from the PDEU dated January 2016).

Under the Regulation, however, the tri-generation plant for the Project is subject to the preliminary EIA procedure. The Project will submit a ‘Project Description Report’ to the PDEU for approval prior to installation of the system.

Prior to operations, per Turkish regulations operational permits will be required for wastewater connection and discharge, air, noise, and temporary hazardous waste storage. Annual environmental audits are also required under the same regulation. A temporary permit for operation of the concrete batching facility was issued in May 2016.

Stakeholder engagement activities for the Project started during the scoping stage and continued during the preparation of the ESIA report. A public consultation meeting was held on 25th November 2015 in Dogankoy Neighborhood, where approximately 50 people attended. The meeting was announced twice via advertisements in 2 newspapers: one national and one local. The meeting was also announced through handouts distributed to local people. Face-to-face meetings were also held with community leaders and social surveys were undertaken in 10 neighborhoods within the project area. Project details, ESHS risks and impacts, site alternatives and other relevant topics were discussed during the meetings and surveys. Additionally, public participation was requested through the distribution of feedback forms. Key concerns raised by attendees included noise during construction; the need for facilities around the IHC to accommodate patient’s families; ensuring student access to the primary school is not affected; and closure of existing hospitals. All of the stakeholder concerns were subsequently addressed in the EIA and management plans. In general, local stakeholders are aware of public benefit of the Project. 

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.

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