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GAP Analysis Report“Compliance of Environmental and Social Precautions in Karacabey WindPower Project with World Bank‘s Safeguard Policies and Environmental andHealth and Safety Guidelines“
By:FutureCamp İklim ve Enerji Ltd. Şti.Çetin Emeç Bulvarı 19/18, 06460 Çankaya / AnkaraTel: 0312 481 21 42 Fax: 0312 480 88 10info@futurecamp.com.trOctober 2013page 1/42
ContentContent . 2Executive Summary . 31Introduction . 42Methodology . 52.1345Document Review. 5Description of the Project . 63.1Location of the Project . 63.2Technical Description of the Project . 9Summaries of the Studies done By Yalova . 114.1Ornithology Report .114.2Floristic Diversity and Fitoecological Assessment Report .114.3Fauna of Terrestrial Vertebrate and Ecosystem Assessment Report .12Matrix of Comparisons . 135.1Table 3: Matrix of Comparisons for Natural Habitats, Forests, Cultural Property,Involuntary Settlement, Indigenous Peoples .145.2Table 4: Matrix of Comparisons for Environmental Analysis; Environmental,Health, and Safety Guidelines for Wind Energy .206Recommendations . 337Conclusion . 338APPENDIXES. 34Page 2/42
Executive SummaryYalova Rüzgar Enerjisinden Elektrik Üretim Anonim Şirketi (Yalova) plans to invest intoKaracabey WPP (hereafter refers Karacabey WPP) in the district of Karacabey, Bursa,Turkey. The proposed project has 27.9 MW installed capacity with 12 turbines having 2.5MW power capacities each.The report at hand provides a gap analysis which results from comparison of World BankSafeguard Policies and Environmental and Health and Safety Guidelines of the WorldbankGroup and the documents listed under section 2. The reports prepared by Yalova coversecosystem of the project region which are Ornithology Report, Floristic Diversity andFitoecological Assessment Report, Fauna of Terrestrial Vertebrate and EcosystemAssessment Report. Thus, aforementioned reports, documents and studies are reviewedin details with parallel to safeguarding policies of the World Bank targeting to putsimilarities and gaps in comparison.The result of the gap analysis report outlines that there is compliance of the project withrequirement of World Bank by safeguarding policies and Environmental and Health andSafety Guidelines for wind power projects.Page 3/42
1 IntroductionYalova Rüzgar Enerjisinden Elektrik Üretim Anonim Şirketi (Yalova) aims to invest into anew wind power plant called Karacabey Wind Power Project (hereafter refers KaracabeyWPP) in Karacabey district of Bursa city, Turkey. While the proposed project will have27.9 MW installed capacity with 12 turbines, each turbine ranks 2.5 MW power.With an aim to analyse the environmental and social impacts, Yalova had alreadyconducted several environmental and social analyses which are the subject of this report.The most important studies done by Yalova for Karacabey WPP are three reports whichconsists of Ornithology Report, Floristic Diversity and Fitoecological Assessment Report,Fauna of Terrestrial Vertebrate and Ecosystem Assessment Report.The aim of this Gap Analysis Report is to provide a detailed analysis on the compliance ofthe reports prepared by Yalova for Karacabey WPP with World Bank Safeguard Policiesand the Worldbank Group Environmental and Health and Safety Guidelines for WindPower Project. For this reason, the aforementioned reports are analysed in details withparallel to safeguarding policies of the World Bank targeting to put similarities and gapsin comparison.As the first section of the Gap Analysis Report describes the project by location sshortsummariesoftheaforementioned reports prepared by Yalova. The third section goes in details to comparethe requirements by World Bank’s safeguarding policies with existing reports of theproject and commitments of Yalova to mitigate negative impacts of the project. The aimof the third section is to put forward the gaps in between and create a base for thereportconsistsofrecommendations for the gaps found with the comparisons of the World Banksafeguarding policies and commitments of the project.Page 4/42
2 MethodologyGap Analysis consisted of the following phases:-Listing of requirement by World Bank Safeguarding Policies and the WorldbankGroup Environmental and Health and Safety Guidelines for Wind Power Project-Reviewing environmental reports and studies done by Yalova for Karacabey ttocomplywithenvironmental and health and safety requirements.-Analysing and stating the gaps between reviewed documents which are listed intable 1 and requirements of World Bank2.1Document ReviewFollowing table provides the list of the documents that were reviewed during GapAnalysis:Table 1: Documents reviewedDocuments1Ornithology Report by Prof. Dr. Levent Turan, December 2011.2Floristic Diversity and Fitoecological Assessment Report, Biologist Prof. Dr.Latif Kurt, 20113Fauna of Terrestrial Vertebrate and Ecosystem Assessment Report,December 20114Karacabey WPP Project Introduction File by PPM, which is prepared to get“EIA is not required document”, December 2012.5Commitments by Yalova for Wildlife Development Zone which is submittedto Ministry of Environment and Forestry, Directorate of Nature Protectionand National Parks6Implementation Regulation for 17th and 18th article of Forestry Law7The map of the road and commitment of the engineering company8Visual Impact and Prevention – Control Measures Study, EnergyGY, 20139Shadow Flicker and Balde Glint Validation and Mitigation Study, EnerGY,2013Environmental, Health, and Safety Guidelines for Wind Energy, IFC, April10200711World Bank Safeguarding Policies ( OP 4.36 – Forests, OP 4.04 – NaturalHabitats)Page 5/42
3 Description of the ProjectYalova won the licence right of Karacabey WPP in the tender of TETC (Turkish ElectricityTransmission Company) in September 2011. The licence of the project allows forconstruction of a plant with 27.9 MW installed capacity, where the capacity of eachturbine and micrositting of the project could be altered as it is required. The project hadinitially been designed with 27 turbines in the year of 2011. However the design isrevised with less turbines and higher capacity each.This section of the report provides a detailed description of the project location andtechnical specification about the project.3.1Location of the ProjectKaracabey WPP is located 8 km in the north of Karacabey district and 30 km in the southeast of Bandırma district of Bursa City. The project area lies in between of Akçakoyun,Güngörmez, Yarış and Çarık villages as a corridor from north to south.Map 1: Location of the project and closest settlement to the project.Page 6/42
The closest settlement to the turbine is located in Güngörmez village and the distance is756 metre per map below.Map 2: Closest Settlement and Micrositting of the ProjectThe Project area consists of forestry and private lands where the location of 1-4. ldlifeDevelopmentArea”and1“Sustainable Usage Region” . The closest wetland to the project is Bayramdere SmallLake which is 2 km is far from the turbines.Some pictures from project area are as follows:Fauna of Terrestrial Vertebrate and Ecosystem Assessment Report of the Karacabey Project,page: 15.1Page 7/42
Picture 1: A general picture from forestry and private lands.Picture 2: A view from Karacabey Karadağ Ovakorusu Wild Life Development AreaPage 8/42
Picture 3: Bayramdere Small Lake which is 2 km far from project.As a conclusion the project area consists of different properties located on hilly regionwhich belongs to forestry and private owners. While some part of project locationsituated in wildlife development zone, the revision of the project reduced the number ofturbines that exist in this area. Reduction in the number of turbines from 27 to 12 piecesexpected to reduce environmental and social impact as well.3.2Technical Description of the ProjectThe initial design of the Project consist of 27 turbines which are rated 900 kW and 1.5MW. The design change has reduced numbers of turbines to 12 pieces rated 2.5 MWeach. Specification of the turbines which are planned to be contracted is as below:Table 2: Wind Farm SpecificationWind Farm SpecificationWind Turbine ManufacturerNordexWind Turbine ModelN100Page 9/42
Wind Turbine rated Power2500 kWQuantity of Wind Turbines12Hub Height80 mRotor Diameter99.8 mThe project is plannedto be connected via a34.5 kV h is 11 km awayfrom the project. Themapoftransmissionrouteoflineisprovided below, wherethe line passes overforestryandagricultural lands.Map 3: The route oftransmission line.Page 10/42
4 Summaries of the Studies done By YalovaAlthough the project has “Environmental Assessment is not required” document, Yalovaalready undertook several studies to analyse the impact of the project on localenvironment. These studies are Ornithology Report, Floristic Diversity and FitoecologicalAssessment Report, Fauna of Terrestrial Vertebrate and Ecosystem Assessment Report.This section of the Gap Analysis Report will provide short summaries of the reports beforepassing to the analysis of the gap in following section. The requirements stated inecosystem assessment reports were already committed by Yalova as notarized deed ofcommitment which is submitted to Ministry of Forestry and Waterwork, GeneralDirectorate of Nature Conservation and National Parks14.1Ornithology ReportThe ornithology report for Karacabey WPP project is prepared by Ornithology Prof. Dr.Levent Turan in the year of 2011. The report was aimed to analyse the impact of theproject on local and migrating birds in Ovakorusu Wildlife Development Zone and projectarea.Besides a part of Karacabey WPP being in the wildlife development zone, there are alsowetlands such as Ulubatlı Lake (14 km) and Manyas Bird Lake (27 km) close to projectarea, which are important habitats for local and migrating birds. While the report list allspecies of local birds in the region, it underlines that the turbine being built on hills givesroom of a safe route in valleys for local and migrating birds and do not create animportant barrier for their mobility.According to the report, the target species of the wildlife development zone is Phasianuscolchicus and capreolus capreolus which are not expected to be negatively impacted bythe Project activity. Ornithology report also underlines that there is no endemic speciesliving in the Project area and neighbouring areas.4.2Floristic Diversity and Fitoecological Assessment ReportFloristic Diversity and Fitoecological Assessment report was prepared by Biologist Prof.Dr. Latif Kurt in the year of 2011. The report aims to analyze floristic and fitoecologiccharacter of the project area by a field research and literature review.While the report analysis floristic diversity of project area, the list of floristic species areprovided in the report which is based on both literature review and field research.According to the report, while there are 8 endemic floristic species in the project area,1Complete set of commited measures is given in Appendix 2 ( in Turkish)Page 11/42
there is also 1 species which is protected by Bern Convention. The report also highlightsthat the specie protected by Bern Convention is not under endemic danger.Floristic Diversity and Fitoecological Assessment report analysis the impact of the projecton flora in two categories such as electro mechanic and loss of habitat. According to thereport there is no negative impact of electro mechanic while the electricity lines withinthe project and between turbines will pass underground, but there will be loss of ereportprovidessomerecommendation during both construction and operation which are collection of seedsand transfers to seed’s bank, precautions to avoid erosion and enabling ecologicalrestoration in the project area.4.3Fauna of Terrestrial Vertebrate and Ecosystem Assessment ReportFauna of Terrestrial Vertebrate and Ecosystem Assessment Report was prepared byZoolog Prof. Dr. Ali Erdoğan in December 2011. Main aim of the report is to analyze theimpact of the project on fauna of the region which includes Terrestrial Vertebrate of theregion. For this reason, the team of the report had conducted a field research includingmeeting with local people from villages of Güngörmez, Yarış, Kulakpınar and Dağesemen.The report provides a list of Terrestrial Vertebrate which categorized according to IUCN,Bern Convention, CITES and Ministry of Forestry and Waterwork, General Directorate ofNature Conservation and National Parks. The report also analyzes whether there isendemic species in the region besides providing recommendation for negative impacts ofthe project on fauna of the region.Through the research and field work of the report, it is concluded that the location of theturbines is far from the habitat of mammals, thus the project is expected to haveminimum impact on habitat of mammals. While the most important group of mammalsaffected by wind energy stated in the report is bats, there is no habitat of bats aroundproject location. Thus, there is no expected negative impact of project on bats either.The final part of report provides analysis on birds where a negative impact is notexpected for local and migrating birds.The next section of the report provides a matrix that compares the requirements byWorld Bank’s safeguarding policies with existing reports of the project and commitmentsof Yalova to mitigate negative impacts of the project.Page 12/42
5 Matrix of ComparisonsThere are 10 safeguard policies, comprising the World Bank's policy on EnvironmentalAssessment (EA) and policies on: Cultural Property; Disputed Areas; Forests; IndigenousPeoples; International Waterways; Involuntary Resettlement; Natural Habitats; PestManagement; and Safety of Dams.As the project activity is electricity generation using wind energy, to be built in Bursaprovince of Turkey, safeguard principles below are not applicable to the project:1) Disputed Areas: The project area is not a disputed area2) International Waterways: The project does not involve use or potential pollution ofinternational waterways,3) Pest Management: The project activity does not use pesticide.4) Safety of Dams: The project facilities do not include any dam.For the following 5 principles, an assessment and gap analysis is provided in Table 2 ofMatrix of Comparisons:1) Natural Habitats2) Forests3) Cultural Property4) Involuntary Settlement5) Indigenous PeoplesFor the Environmental Analysis; Environmental, Health, and Safety Guidelines forWind Energy is used and analysis is performed separately in Table 3.Page 13/42
5.1Table 3: Matrix of Comparisons for Natural Habitats, Forests, Cultural Property, Involuntary Settlement, Indigenous rojectNaturalHabitatsNatural habitats are land and iesare formedlargely by native plant and animalspecies, and (ii) human activity has notessentially modified the area's primaryecological functions. (OP 4.04 paragraph1(a))RELEVANTtoPart of the project arealocated in ne which is alsocalledsustainableUtilization Zone.Critical natural habitats are:(i) existing protected areas and areasofficially proposed by governments asprotected areas (e.g., reserves N]classifications2),areasinitiallyrecognized as protected by traditionallocal communities (e.g., sacred groves),and sites that maintain conditions vitalfor the viability of these protected areas(as determined by the environmentalassessment process3); or(ii) Sites identified on supplementarylists prepared by the Bank or anauthoritative source determined by theRegionalenvironmentsectorunit(RESU). Such sites may include areasrecognizedbytraditionallocal1theSee: http://www.milliparklar.gov.tr/belge/yhgs.pdf (No:31)Page 14/42Assessment of the project withregards to the principlesConclusionSome of the project area and turbinesof the project stay in “BursaKaracabeyKaradağ–OvakorusuWildlife Development Zone“, which isa nationally development zone withtarget species of pheasant1.NO GAPBeing one of the administrative unitsfor the development zones, noobjection letter of General Directorateof Nature Conservation and NationalParks (“General Directorate”) needsto granted in order to startimplementation of project activity.Preliminary letter of the GeneralDirectorates indicates that the projectactivity in the area is permitted onlyif the assessment reports to beprepared for the project activity by anOrnithologist, a Zoologist and hattheproject activity will not pose anythreat to the target species or otherspecies in the development zone andwill not have negative impact to theecosystem or migrating any negativeAlthough the projectarea partially with inthe Bursa KaracabeyKaradağ–OvakorusuWildlifeDevelopment Zone“,expertreportsprepared abitats,providedthatidentifiedmeasures will beimplementedappropriately yhassufficient ecologicalstudies to fulfil the
communities (e.g., sacred groves);areas with known high suitability forbiodiversity conservation; and sites thatarecriticalforrare,vulnerable,migratory, or endangered species.4Listings are based on systematicevaluations of such factors as speciesrichness; the degree of endemism,rarity, and vulnerability of componentspecies;representativeness;andintegrity of ecosystem processes. (OP4.04 Annex A Definitions)impacts with appropriate measures ispossible1.Three assessment report is preparedfor the project activity and impact ofit on environment:(1) Fauna Report: Karacabey WPPand Terrestrial Vertebrate Fauna andEcosystemAssessmentReport,prepared by Prof. Dr. Ali Erdoğan,Akdeniz University in December2011.The Bank does not support projects that,in the Bank's opinion, involve thesignificant conversion or degradation3 ofcritical natural habitats. (OP 4.04paragraph 4)(2) Flora Report – Karacabey WPPFloristic Variety and FitoecologicalAssessment Report, prepared by Prof.Dr. Latif Kurt, Ankara University inDecember 2011.(3) Ornithology Report: KaracabeyWPP Ecosystem Assessment Report Ornithology Section, prepared byProf. Dr. Levent Turan, HacettepeUniversity in December 2011.All of the reports given aboveconclude that the project is cantnegative impacts on the ecosystemprovided that identified measures tobeimplementedappropriately.Complete set of measures, identified1Please see Appendix 1.Page 15/42requirements of thisprinciple.
by these reports for protection ofecosystem are combined within anotarized deed of commitment andsubmitted to Ministry of Environmentand Forestry, Directorate of NatureProtection and National Parks1Finding the reports and conclusionssatisfactory and receiving the deed ofcommitments,theGeneralDirectorate provided no-objectionletter to the project company.2ForestsThe Bank does not finance projects that,in its opinion, would involve significantconversion or degradation4 of criticalforest areas5 or related critical naturalhabitats.6 If a project involves thesignificant conversion or degradation ofnatural forests or related naturalhabitats that the Bank determines arenot critical, and the Bank determinesthat there are no feasible alternatives totheprojectanditssiting,andcomprehensive analysis demonstratesthat overall benefits from the projectRELEVANTSome of the projectarea is in the forests.1Complete set of commited measures is given in Appendix 2 ( in Turkish)2See Appendix 3 for the letter.3See letter of Regional Branch of Ministry of Forestry, dated 12/11/2008.Some of the project area is identifiedas forest area.3 Pictures of the projectarea shows areas where some of theturbines will be installed covered bytrees.Although,thereisnoinformation and study on how manytrees will be affected by constructionof the project activity, the relatedregulation to get permission fromforestry enforce Yalova to identify thenumbers of trees to be cut down and4pay the fee for replantation .NO GAPSome of the projectarea is in the forestsand thus may affecttrees negatively.Thenumberofaffected trees andmitigation measureisdefinedwithregulation.Thusthere is no gap.Please see the link fort he ddelerinin%20Y%C3%B6netmeli%C4%9Fi.pdf4Page 16/42
substantially outweigh the environmentalcosts, the Bank may finance the projectprovided that it incorporates appropriatemitigationmeasures.76. The Bank does not finance projectsthat contravene applicable internationalenvironmental agreements.8PhysicalCulturalResourcesPhysical cultural resources, are definedas movable or immovable objects, sites,structures, groups of structures, andnatural features and landscapes thathave archaeological, ,aesthetic, or other cultural significance.Physical cultural resources may belocated in urban or rural settings, andmay be above or below ground, or underwater. Their cultural interest may be atthe local, provincial or national level, orwithin the international community.When the project is likely to haveadverse impacts on physical culturalresources,theborroweridentifiesappropriate measures for avoiding ormitigating these impacts as part of theEA process.NOT REVELANTAccording to letter ofRegionalBranchofCultural and NaturalAssetsProtectionCommission, there arenotanyphysicalcultural resources in theproject area.1These measures may range from full siteprotectiontoselectivemitigation,including salvage and documentation, incases where a portion or all of the1Appendix 4Page 17/42N/AN/A
physical cultural resources may be lost.InvoluntaryResettlementInvoluntary resettlement may ironmentaldamage unless appropriate measuresare carefully planned and carried out.For these reasons, the overall objectivesof the Bank's policy on involuntaryresettlement are the following:(a) Involuntary resettlement should beavoided where feasible, or minimized,exploring all viable alternative projectdesigns.2NOT RELEVANTN/ANo resettlement in theproject area.1Being a wind roadsandtransmissionlines.None of these facilitiesneeds or results withresettlement.(b) Where it is not feasible to avoidresettlement,resettlementactivitiesshould be conceived and executed assustainabledevelopmentprograms,providing sufficient investment resourcesto enable the persons displaced by theproject to share in project benefits.Displacedpersons3 shouldbemeaningfully consulted and should haveopportunities to participate in planningandimplementingresettlementprograms.(c) Displaced persons should be assistedin their efforts to improve theirlivelihoods and standards of living or atleast to restore them, in real terms, topre-displacement levels or to levels1Please refer to Project Description section for further information on the project area.Page 18/42N/A
prevailing prior to the beginning ofproject implementation, whichever ishigher.4IndigenousPeoplesA project proposed for Bank financingthat affects Indigenous Peoples requires:(a) screening by the Bank to identifywhether Indigenous Peoples are presentin, or have collective attachment to, theproject area (see paragraph 8);NOT RELEVANTThere are noindigenous people inthe project area.(b) a social assessment by the borrower(see paragraph 9 and Annex A);(c) a process of free, prior, and informedconsultation with the affected IndigenousPeoples’ communities at each stage ofthe project, and particularly duringproject preparation, to fully identify theirviewsandascertaintheirbroadcommunity support for the project (seeparagraphs 10 and 11);(d) the preparation of an IndigenousPeoplesPlan(seeparagraph12and Annex B) or an Indigenous PeoplesPlanning Framework (see paragraph 13and Annex C); and(e) disclosure of the draft IndigenousPeoples Plan or draft Indigenous PeoplesPlanning Framework (see paragraph 15).Page 19/42N/AN/A
5.2Table 4: Matrix of Comparisons for Environmental Analysis; Environmental, Health, and Safety Guidelines for Wind EnergyIndicatorsDescription of PrinciplesAssessment of the project andprojectdocumentswithregards to the principlesConclusionThe distance of the turbines to theclosest settlement is around 760m (Güngörmez village). There aresomeagriculturallandsandforests in the project area.No GAPEnvironment (Industry-Specific Impacts andManagement)VisualImpactsDepending on the location and local publicperception, a wind farm may have an impact onvisual resources. Visual impacts associated with windenergy projects typically concern the turbinesthemselves (e.g. colour, height, and number ofturbines) and impacts relating to their interactionwith the character of the surrounding landscape.Prevention and control measures to address visualimpacts include:· Consult the community on the location of the windfarm to incorporate community values into design;· Consider the landscape character during turbinesiting;· Consider the visual impacts of the turbines from allrelevant viewing angles when considering locations;· Minimize presence of ancillary structures on the siteby avoiding fencing, minimizing roads, burying intraproject power lines, and removing inoperativeturbines;· Avoid steep slopes, implement erosion measures,and promptly revegetate cleared land with nativespecies only;· Maintain uniform size and design of turbines (e.g.direction of rotation, type of turbine and tower, andheight);Yalova undertook a study on yEnerGY in the year of 2013.The study analyses visual impactof the project and providesmitigation measures.According to the study, the projecthas visibility from two closevillages,namelyYarişandGüngörmez. The study claims thatwhile the view from Güngörmez isnegligible because only top of 4turbines are visible. Whereas inYarış village, all turbines arevisible from the centre but theyconstitute continuity only in westpart of the village.The visual impact study hasanalysed the impact of the Projecttaking into consideration followingPage 20/42The study carried out by Energy forYalova on visual impacts of the projectfacilities, especially turbines, on the localpeople and surrounding landscape takesinto account the control measures toaddress visual impacts and includerecommendations for mitigation ofpossible negative impacts. For thisreason there is no identified gapbetween indicator and study.
· Paint the turbines a uniform color, typicallymatching the sky (light gray or pale blue), whileobserving marine and air navigational markingregulations;· Avoid including lettering, companyadvertising, or graphics on the anceandLandscape :visual diversity, intactness(order), focal points andunique visual resources-Assessment of AestheticImpact:Landscapecharacteristics (Duration,Angle of view, PanoramicversusNarrowview,Scenic Quality view, Focalpoint within a view andnumber of observers) andProjectCharacteristics(scale, number of turbinesin view, visual clutter,visibilityofprojectinfrastructure)The study concludes that As far asKaracabey Project is considered,the visual impact of the Project isneglible to its surrounding and itcan be an acceptable Project. Italso states that as a result of theanalysis with stated indicators, itcan be argued that, the Projecthas minimal visual impact both tothe nearest residential areas andits surrounding.The study also provide mitigationmeasures such as appropriatePage 21/42
color and Minimizing VegetationRemovalNoiseMeasures to prevent and control noise are mainlyrelated to engineering design standards. Forexample, broadband noise is generated by airturbulence behind the blades and increases withincreasing blade rotational speed. This noise may becontrolled through the use of variable speed turbinesor pitched blades to lower the rotational speed.Additionalrecommendedmeasures include:noisemanagement1) Proper siting of wind farms to avoid locations inclose proximity to sensitive noise recep
The report at hand provides a gap analysis which results from comparison of World Bank Safeguard Policies and Environmental and Health and Safety Guidelines of the Worldbank Group and the documents listed under section 2. The reports prepared by Yalova covers ecosystem of the project region which are Ornithology Report, Floristic Diversity and
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