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Biodiversity Offset Strategy

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CONTENTS

List of Acronyms and Abbreviations ...... 5

1. Introduction ...... 7

1.1 Purpose ...... 7

1.2 Scope ...... 7

1.3 Project Description ...... 9

1.4 Relationship With Other Documents ...... 10

2. Roles and Responsibilities ...... 11

3. Biodiversity Offset Objectives ...... 13

1.5 Biodiversity Offsets Programme Aspects ...... 13

1.6 Biodiversity Offsets Components ...... 20

4. Residual Impacts Assessment ...... 24

1.7 Preconstruction Biodiversity Baseline ...... 24

1.8 Preconstruction Predicted Residual Impacts ...... 24

1.9 Biodiversity Baseline Verification Surveys ...... 24

1.10 Implementation of the Mitigation Hierarchy ...... 25

1.11 Construction Compliance Monitoring ...... 28

1.12 REIR residual impacts protocol ...... 29

5. Residual Impacts ...... 31

1.13 Location of Residual Impacts ...... 31

1.14 Summary of Residual Impacts ...... 34

6. Offset Design ...... 37

1.15 Direct Offsets ...... 37

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1.16 Discharge of Residual Impacts at Offset Sites ...... 40

1.17 Indirect Offsets ...... 43

7. Loss Gain And Viability Analysis ...... 44

1.18 Loss Gain Analysis ...... 44

1.19 Viability Analysis ...... 48

8. Monitoring And Reporting ...... 49

1.20 Method ...... 49

1.21 Frequency and Duration ...... 49

1.22 Reporting ...... 49

9. Engagement ...... 50

1.23 Direct offsets ...... 51

1.24 Direct offsets – Greece ...... 51

1.25 Direct offsets – Albania ...... 54

1.26 Indirect Offsets ...... 55

10. Long Term Protection Of Afforestation Sites ...... 56

1.27 Greece ...... 56

1.28 Albania ...... 57

1.29 TAP monitoring, long term commitment and risks ...... 58

11. Implementation ...... 59

1.30 Implementation of Direct Offsets ...... 59

1.31 Implementation of Indirect offsets ...... 60

1.32 Schedule ...... 60

12. Next Steps ...... 62

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13. References ...... 63

14. APPENDIX 1 – Example BOMP contents page ...... 64

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LIST OF ACRONYMS AND ABBREVIATIONS

BOMP Biodiversity Offsets Management Plan BOS Biodiversity Offset Strategy CHA Critical Habitat Assessment CH Critical Habitat dbh Density by hectare DMU Discrete Management Unit EBRD European Bank of Reconstruction and Development EIB European Investment Bank EMP Ecological Management Plan EPC Engineering, Procurement and Construction ESAP Environmental and Social Action Plan ESCH Environmental, Social and Cultural Heritage ESIA Environmental and Social Impact Assessment ESMS Environmental and Social Management System ESMM Environmental and Social Management Manual EU European Union fKBA freshwater Key Biodiversity Area GIS Geographical Information System KBA Key Biodiversity Area KP Kilometre Point KPI Key Performance Indicator IBA Important Bird Area IPA Important Plant Area IFC International Finance Corporation NNL No Net Loss NG Net Gain NGO Non-governmental Organisation PBF Priority Biodiversity Feature PPS Pipeline Protection Strip PR Performance Requirement PS Performance Standard

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PRT Pipeline Receiving Terminal REIR Route Environmental Impact Register ROW Right of Way SEA Supplementary Ecological Assessment SPA Special Protection Area SRG Snam Rete Gas TANAP Trans Anatolian Pipeline TAP Trans Adriatic Pipeline

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1. INTRODUCTION

1.1 Purpose

This document presents a strategy to compensate for the residual biodiversity impacts of the Trans Adriatic Pipeline (TAP) after avoidance, minimization, and restoration efforts have been undertaken. Its geographic scope is Greece and onshore Albania. There are no residual biodiversity impacts in onshore Italy. The Offshore BOS will be developed in Q4 2021. The overall goal is to achieve no net loss (NNL) if not a net gain (NG) of biodiversity features of concern.

This document provides details on the residual biodiversity impacts of the TAP pipeline project that require offsetting, the design concept for those offsets (method, site selection, offset stakeholders, indicative budget), analysis of the sufficiency of the offset (i.e. loss-gain analysis), and legal means to protect and the long-term arrangements to manage the offsets.

1.2 Scope

Residual impacts of the project are 46.2 ha of natural habitat, including impacts to the following vegetation communities: • EU Annex 1 Habitat 9130 Asperulo-Fagetum beech forests • EU Annex 1 91KO Illyrian Fagus sylvatica forests (aremonio-Fagion) • EU Annex 1 9250 Quercus trojana woods • EU Annex 1 Habitat 9270 Helenic beech forests with Abies borisii-regis • Greek Habitat 924A Thermophilous oak woods of E Mediterranean and Balkans • EU Annex 1 Habitat 9340 Quercus ilex forests • EU Annex 1 Habitat 9530 (Sub)-Mediterranean pine forests with endemic black pines • EU Annex 1 Habitat 9540 Mediterranean pine forests with endemic Mesogean pines

This offset strategy compensates for these residual impacts by restoring and ensuring the long-term protection of natural habitats at multiple sites on state-owned lands.

Three mammal species of concern inhabit 24.5 ha of the above natural habitats, including:

• Brown bear (Ursus arctos) • Wolf (Canis lupus) • Wildcat (Felis silvestris)

Residual impacts to these species are fully compensated by the offsets for the natural habitats listed above.

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In addition, TAP is qualitatively and semi quantitatively characterizing potential indirect residual impacts to large carnivores in Albania, as a result of facilitated access to forests by small-scale illegal loggers. This assessment will be completed end of Q1 2021.

TAP’s impact occurs in the right of way (ROW) of the pipeline, where natural habitat was removed during construction (Figure 1a). Once the pipeline is installed, the majority of the ROW is restored to natural habitat, although an 8m wide pipeline protection strip (PPS) centred on the pipeline portion must remain permanently cleared. The portion that is not restored constitutes the residual impact of the project. To compensate for this residual impact, TAP will implement biodiversity offsets in the form of off-site afforestation projects in collaboration with national forest authorities (Figure 1b). The net outcome of biorestoration and offsets together should be no net loss (NNL) if not a net gain (NG) of biodiversity features of concern (Figure 1c).

a. TAP ROW

impact

b. Biorestoration PPS

Afforestation (Offset)

c. Biorestoration PPS

no loss loss

Offset

No net loss or Net gain

Figure 1 – Conceptual diagram showing net outcomes of biorestoration and offsets

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1.3 Project Description

The Trans Adriatic Pipeline (TAP) is designed to transport natural gas from the Shah Deniz II development in Azerbaijan to the European market by supplying gas to the Italian network.

TAP connects with the TANAP pipeline at Kipoi on the Turkey-Greece border and will transport the gas through northern Greece to enter Albania east of Korça. The pipeline continues through Albania and reaches the Adriatic coastline near the city of Fier. It crosses the Adriatic and comes ashore in southern Italy at Melendugno, near the town of San Foca. TAP terminates at the Pipeline Receiving Terminal (PRT), 8.2km inshore, close to the city of Lecce, where the gas is tied into the Snam Rete Gas (SRG) network. The total length of the TAP pipeline system is approximately 878km including the offshore pipeline section of 105km.

Figure 2 – TAP Pipeline route

The project is executed through a series of contracts with suppliers for the provision of certain equipment and materials and with engineering, procurement and construction (EPC) contractors for the execution of project construction in the host countries.

Individual Environmental and Social Impact Assessments (ESIAs) were produced for project infra- structure in Greece, Albania and Italy, with the latter two also addressing the crossing of the Adriatic Sea. The ESIAs comply with the legislative frameworks of TAP’s host countries, the European Union (EU) regulatory impact assessment and environmental framework, and the European Bank for Re- construction and Development (EBRD) Performance Requirements (2008 edition).

All project activities must comply with the applicable standards, which comprise:

• Applicable International standards and guidelines. • Applicable national legislation and standards in Greece, Albania and Italy. • Relevant conditions arising from the host-country Environmental and Social Impact Assess- ments (ESIAs) and project permits. • Applicable Lender standards.

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• Applicable TAP standards. These are described in detail in the Supplementary Ecological Assessment (Ref. 5)

1.4 Relationship With Other Documents

This BOS has been developed to outline the implementation of TAPs biodiversity offsets commit- ments within the Project Environmental, Social and Cultural Heritage (ESCH) Standards and Speci- fications defined in the TAP Environmental and Social Management Manual (Ref 1.) and the Ecolog- ical Management System described in Section 8 of the Ecological Management Plan (Ref. 2).

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2. ROLES AND RESPONSIBILITIES

TAP is ultimately responsible for ensuring that the Project and its Contractors comply with TAP ESCH Management Documents, including this BOS, and TAP ESCH Standards and Specifications.

TAP will ensure this by:

• Providing and maintaining adequate resources for the successful implementation of this BOS • Identifying residual impacts to Critical Habitats (CH) and Priority Biodiversity Features (PBF) as defined in the relevant performance standards) • Identifying biodiversity offsets for identified residual impacts • Developing site-specific KPIs for the long-term monitoring of biodiversity offset success • Ensuring no net loss (NNL) of PBFs and net gain (NG) of CH through a long-term monitoring plan and biodiversity offsets where residual impacts are identified • Maintaining the Route Environmental Impact Register (REIR) and Level 3 Site Files1 for all PBF and CH • Closing all Level 3 Site Files.

Overall TAP Environmental Social and Cultural Heritage (ESCH) roles and responsibilities are presented within the Environmental and Social Management Manual (ESMP) (Ref. 1).

Key roles and responsibilities for the implementation of the BOS are summarised in Table 1.

Table 1 - TAP roles and responsibilities

Role Responsibility

TAP E&S Compliance and Assur- Ensuring project compliance with the Project Standards ance Manager and Specifications and other requirements set out in this BOS and accountable for implementation of associated assurance activities Providing resources for the implementation of this BOS Developing and controlling a budget for biodiversity offsets implementation and management Reporting to TAP leadership progress and performance associated with implementation of this document

1 The fucntion of the Route Environmental Impact Register (REIR) and Level 3 Site Files is described in section 8.7 of TAP Ecological Management Plan (Ref. 2).

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Role Responsibility

TAP Environmental Advisor Reporting project compliance with this BOS to TAP E&S Compliance and Assurance Manager Providing functional support to in-country ESCH teams to implement this BOS Coordination of Route Environmental Impact Registers (REIR) and associated Level 3 site files Coordinating biodiversity offset assurance activities of the Implementing Contractors in conjunction with the country E&S teams Coordination and management of surveys and long-term biorestoration and biodiversity offsets monitoring programs Support TAP biorestoration and biodiversity offset assurance activities

External Biodiversity Specialists Providing biorestoration and biodiversity offset support to the TAP Environmental Advisor Execution of verification surveys, monitoring, audits and residual impact assessments for each REIR entry Supports Environmental advisor with development, implementation and monitoring of the BOS and BOMPs

External Biodiversity Offsets Advisor Supports the Environmental Advisor in coordination and implementation of the BOS

Implementing Contractor Implementation of TAP afforestation activities

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3. BIODIVERSITY OFFSET OBJECTIVES

This section details the objectives and key performance indicators (KPIs) of the TAP Biodiversity Offsets Strategy (BOS).

The overall goal of TAP’s BOS is to demonstrate how any unavoidable significant residual project impacts to biodiversity features can be compensated through the establishment of biodiversity offsets in a manner that achieves NNL if not NG. EBRD’s Performance Requirement 6 categorizes biodiversity features of concern as either Priority Biodiversity Features (PBFs) or Critical Habitat (CH) and requires NNL and NG of these features, respectively.

TAP’s specific objectives are:

A. Complete residual impact assessments of flora PBFs and CH and assign Restoration scores to each REIR entry for eventual close out and review. B. Complete residual impact assessments of fauna PBFs and CH and assign Restoration scores to each REIR entry for eventual close out and review. C. Design biodiversity offset programs for PBF and CH flora where residual impacts are identified during residual impact assessments and post construction monitoring. D. Design biodiversity offset programs for PBF and CH fauna where residual impacts are identified during residual impact assessments and post construction monitoring E. Implement biodiversity offset programs for PBF and CH flora where residual impacts are identified and demonstrate NNL or NG. F. Implement biodiversity offset programs for PBF and CH fauna where residual impacts are identified and demonstrate NNL or NG.

1.5 Biodiversity Offsets Programme Aspects

The biodiversity offset program has two main aspects:

• Residual impacts assessment - aimed at ensuring residual impacts as a result of construction activities are identified and quantified. • Biodiversity Offsets - aimed at ensuring NNL and NG where residual impacts are identified as a result of construction activities.

1.5.1 Residual Impacts Assessment Aspect (Objectives A-B)

The Residual impacts assessment aspect consists of the objectives, components and key performance indicators (KPI) for monitoring and reporting detailed in Table 2. These are discussed in further detail at Section 4.2. TAP will prepare quarterly reports to support performance management of this document.

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1.5.2 Biodiversity Offsets Aspect (Objectives C-F)

The Biodiversity Offsets aspect consists of the objectives, components, actions and key performance indicators (KPI) for monitoring and reporting detailed in Table 3. These are discussed in further detail in Section 4.2. TAP will prepare quarterly reports to support performance management of this document.

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Table 2 - Biodiversity Offset Aspect Objectives A-B

Objective Component Actions KPI Review method

A. Complete residual A1. Post con- Complete residual impact % of residual impact as- Annual review of surveys conducted struction re- assessments for all PBF and sessment completed for by external biodiversity specialists impact assessments to sidual impact CH. each REIR entry within 12 and update of REIR residual impacts PBF / CH Flora and as- assessment months of final reinstate- register by TAP Environmental Advi- sign Restoration score and survey ment sor, supported by external biodiversity (1-6) to each REIR en- offsets advisor try. Assign Restoration score (1- % of REIR entries with Res- Annual review of surveys conducted 6) to each REIR entry toration scores assigned by external biodiversity specialists and update of REIR residual impacts register by TAP Environmental Advi- sor, supported by external biodiversity offsets advisor A2. Closure of Complete Level 3 site file for % of Level 3 site files for Incorporation of annual survey results Level 3 site each REIR entry with resto- REIR entries with restoration update of level 3 site files for REIR files for REIR ration score assigned 1 score 1 or 3 completed entries with restoration score 1 or 3 entries with by TAP Environmental Advisor, sup- restoration ported by external biodiversity spe- score 1 or 3. cialists Close site file in accordance % of Level 3 site files for Annual review of REIR residual im- with the REIR residual im- REIR entries with restoration pacts register and update of level 3 pacts protocol score 1 or 3 closed site files for REIR entries with restoration score 1 or 3 by TAP Environmen- tal Advisor B. Complete residual B1. Post con- Complete residual impact % of residual impact as- Annual review of surveys conducted struction re- assessments for all PBF and sessment completed for by external biodiversity specialists impact assessments to sidual impact CH. each REIR entry within 12 and update of REIR residual impacts PBF / CH Fauna and assessment months of final reinstate- register by TAP Environmental Advi- ment sor, supported by external biodiversity TAP AG CAL00-PMT-601-Y-TVS-0001 Rev. No.: 0 Doc. no.:

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Objective Component Actions KPI Review method assign Restoration and survey offsets advisor score (1-6) to each Assign Restoration score (1- % of REIR entries with Res- Annual review of surveys conducted REIR entry. 6) to each REIR entry toration scores assigned by external biodiversity specialists and update of REIR residual impacts register by TAP Environmental Advi- sor, supported by external biodiversity offsets advisor B2. Closure of Complete Level 3 site file for % of Level 3 site files for Incorporation of annual survey results Level 3 site each REIR entry with resto- REIR entries with restoration update of Level 3 site files for REIR files for REIR ration score assigned 1 score 1 or 3 completed entries with restoration score 1 or 3 entries with by TAP Environmental Advisor, sup- restoration ported by external biodiversity spe- score 1 or 3. cialists Close site file in accordance % of Level 3 site files for Annual review of REIR residual im- with REIR residual impacts REIR entries with restoration pacts register and update of Level 3 protocol score 1 or 3 closed site files for REIR entries with restoration score 1 or 3 by TAP Environmen- tal Advisor

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Table 3 - Biodiversity Offset Aspect Objectives C-F Objective Component Actions KPI Review method

C. Design biodiversity C1. Biodiversi- Design biodiversity offset to % of REIR entries where re- Annual review of REIR residual im- ty offset de- ensure NNL / NG where residual impacts have been pacts register by TAP Environmental offset programs for signed to en- sidual impacts are identified identified that biodiversity off- Advisor, supported by external biodi- PBF and CH flora where sure NNL / sets have been designed versity offset advisor. residual impacts are NG where re- Development of Biodiversity % of flora REIR entries Annual review of REIR residual im- identified during resid- sidual impacts Offsets Management Plans where residual impacts have pacts register by TAP Environmental ual impact assess- are identified (BOMPs) for identified resid- been identified that biodiver- Advisor, supported by external biodi- ments and post con- ual impacts sity offsets have been de- versity offset advisor. signed struction monitoring C2. Engage- Engage with identified Com- % of planned engaged com- Annual review of engagement pro- ment with petent Authorities and other pleted. vided in each BOMP by TAP envi- identified interested parties ronmental advisor. Competent Authorities Obtain forest permits and % of permits obtained for Maintenance of Permit Register by and other in- approved reforestation stud- each BOMP designed TAP Permit Lead terested par- ies to guide reforestation. ties

D. Design biodiversity D1. Biodiversi- Design biodiversity offset to % of REIR entries where re- Annual review of REIR residual im- ty offset de- ensure NNL / NG where residual impacts have been pacts register by TAP Environmental offset programs for signed to en- sidual impacts are identified identified that biodiversity off- Advisor, supported by external biodi- PBF and CH fauna sure NNL / sets have been designed versity offset advisor. where residual impacts NG where re- Development of Biodiversity % of fauna REIR entries Annual review of REIR residual im- are identified during residual impacts Offsets Management Plans where residual impacts have pacts register by TAP Environmental sidual impact assess- are identified (BOMPs) for identified resid- been identified that biodiver- Advisor, supported by external biodi- ments and post con- ual impacts sity offsets have been de- versity offset advisor. signed

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Objective Component Actions KPI Review method struction monitoring D2. Engage- Engage with identified Com- % of planned engaged com- Annual review of engagement pro- ment with petent Authorities and other pleted. vided in each BOMP by TAP envi- identified interested parties ronmental advisor. Competent Obtain forest permits and % of permits obtained for Maintenance of Permit Register by Authorities approved reforestation stud- each BOMP designed TAP Permit Lead and other in- ies to guide reforestation. terested parties E. Implement biodiver- E1. Execution Offset / afforestation activities % of Afforestation activities in Ongoing regular assurance visits sity offset programs and verifica- of BOMP areas in accord- accordance with reforestation conducted by TAP for PBF and CH flora tion of offset ance with Competent Au- plans, by BOMP activities thority permits. where residual impacts Monitoring of afforestation n % Monitoring completed vs Ongoing regular assurance visits are identified and activities. planned conducted by TAP demonstrate NNL or Replacement of any dead % plant survival over 80%, by Ongoing regular assurance visits NG plants exceeding 20% failure BOMP conducted by TAP rate for 3 years. Competent Authority approv- Obtain cessation confirma- Maintenance of Permit Register by al for completion of afforestation from relevant Competent TAP Permit Lead tion activities. Authority. E2. Monitoring Monitoring to measure suc- % of flora PBF/ CH REIR en- Annual review of REIR residual im- and reporting cess of each BOMP vs NNL / tries that have achieved off- pacts register by TAP Environmental success of NG offset liability set liability objective through Advisor offsets vs NNL biodiversity offsets. and NG Submission and lender ap- % of flora PBF / CH REIR en- Annual review of ESCH lender report proval of BOMP close out tries that have approved by TAP E&S Compliance and Assur- evaluation report. BOMP close out evaluation ance Manager. reports.

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Objective Component Actions KPI Review method

F. Implement biodiver- F1. Execution Offset / afforestation activities % of Offset / afforestation ac- Ongoing regular assurance visits sity offset programs and verifica- in accordance with BOMP tivities completed, by BOMP conducted by TAP for PBF and CH fauna tion of offset and Forest authority permits. activities where residual impacts are identified and Monitoring of offset activities % Monitoring completed vs Ongoing regular assurance visits demonstrate NNL or implementation. planned conducted by TAP NG Replacement of any dead % plant survival over 80%, by Ongoing regular assurance visits plants exceeding 20% failure BOMP conducted by TAP rate for 3 years. Competent Authority approv- Obtain cessation confirma- Maintenance of Permit Register by al for completion of afforestation from relevant Competent TAP Permit Lead tion activities. Authority. F2. Monitoring Monitoring to measure suc- % of fauna PBF/ CH REIR Annual review of REIR residual im- and reporting cess of each BOMP vs NNL / entries that have achieved pacts register by TAP Environmental success of NG offset liability offset liability objective Advisor offsets vs NNL through biodiversity offsets. and NG Submission and lender ap- % of flora PBF / CH REIR en- Annual review of ESCH lender report proval of BOMP close out tries that have approved by TAP E&S Compliance and Assur- evaluation report. BOMP close out evaluation ance Manager. reports.

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1.6 Biodiversity Offsets Components

This section provides a more detailed description of the Biodiversity offsets components discussed above. The biodiversity offsets aspect targets four key categories of Project-Affected biodiversity, specifically:

• CH Flora • PBF Flora • CH Fauna • PBF Fauna.

Where residual impacts remain following biorestoration, for instance the 8m Pipeline Protection Strip (PPS), biodiversity offsets will be implemented to ensure NNL of PBFs and NG of CH.

1.6.1 Objective A. Complete residual impact assessments to PBF and CH Flora and assign Restoration scores to each REIR entry

A1. Post construction residual impact assessment and survey

Each REIR entry has been analysed by TAP biodiversity experts to assess residual impacts. The residual impact assessment has taken into consideration predicted residual impacts in the SEA, verified biodiversity baselines which include post SEA EPC data and TAP verification survey data, construction performance and initial post construction monitoring data.

The residual impact assessment process considers likelihood of success of all biorestoration activities in order to achieve NNL and NG. This includes a full review of all biorestoration proposals against the verified baseline. The residual impact assessments will be recorded within the relevant Level 3 site file and summarized in the REIR residual impacts register.

Post construction monitoring of all CH and PBF flora sites where residual impacts are currently un- verified (restoration score 4) will be conducted in accordance with Appendix 7 of the BMP (Ref 4). Restoration scores (see section 4) will be reviewed on a quarterly basis to incorporate the latest monitoring data and included in the quarterly revisions of the REIR residual impacts register.

A2. Closure of Level 3 site files for REIR entries with restoration score 1 or 3.

The Level 3 site files for REIR entries that have achieved restoration score 1 or 3 will be updated with data and justification that demonstrate no residual impacts and closed in accordance with section 5.

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1.6.2 Objective B. Complete residual impact assessments to PBF and CH Fauna and assign Restoration scores to each REIR entry.

B1. Post construction residual impact assessment and survey

Post construction monitoring of all CH and PBF fauna sites which are not restoration score 1 or 3 will be conducted in accordance with Appendix 7 of the BMP (Ref. 4). Restoration scores (see section 4) will be reviewed on a quarterly basis to incorporate the latest monitoring data and included in the quarterly revisions of the REIR residual impacts register.

B2. Closure of Level 3 site files for REIR entries with restoration score 1 or 3.

The Level 3 site files for REIR entries that have achieved restoration score 1 or 3 will be updated with data and justification that demonstrates no residual impacts and closed in accordance with section 5.

1.6.3 Objective C. Design biodiversity offset programs for PBF and CH flora where residual impacts are identified during residual impact assessments and post construction monitoring

C1. Biodiversity offset designed to ensure NNL / NG where residual impacts are identified

Following identification and quantification of residual impacts. The biodiversity offsets required to discharge offset liability will be presented in individual Biodiversity Management Plans (BOMPs) that will demonstrate how quantified offset outcomes discharge quantified residual impacts. Each BOMP will be provided to the lender group for review and approval.

C2. Engagement with identified Competent Authorities and Interested third parties.

Following the identification of biodiversity offsets, statutory and non-governmental consultees will be engaged. The specific engagement process and records will be provided in each respective BOMP.

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est laws of each host country. TAP Country Permit Leads ensure permits are obtained prior to works within each forestry jurisdiction.

1.6.4 Objective D. Design biodiversity offset programs for PBF and CH fauna where residual impacts are identified during residual impact assessments and post construction monitoring D1. Biodiversity offset designed to ensure NNL / NG where residual impacts are identified

Following identification and quantification of residual impacts. The biodiversity offsets required to discharge offset liability will be presented in Individual Biodiversity Offset Management Plans (BOMPs) that will demonstrate how quantified offset outcomes discharge quantified residual impacts. Each BOMP will be provided to the lender group for review and approval.

D2. Engagement with identified Competent Authorities and Interested third parties.

Following the identification of biodiversity offsets, statutory and non-governmental consultees will be engaged. The specific engagement process and records will be provided in each respective BOMP.

In accordance with national forestry legislation, afforestation plans are required prior to activities related to BOMP implementation. TAP will obtain permits for afforestation as required by national forest laws of each host country. TAP Country Permit Leads ensure permits are obtained prior to works within each forestry jurisdiction.

1.6.5 Objective E. Implement biodiversity offset programs for PBF and CH flora where residual impacts are identified and demonstrate NNL or NG

E1. Execution and verification of offset activities

BOMP implementation activities will be executed in accordance approved forest permits, afforestation plans and the BMP (Ref. 4). TAP will execute afforestation, monitoring and maintenance of all BOMP implementation activities conducted outside the RoW. BOMP implementation activities will be regularly monitored by TAP.

TAP will employ qualified foresters familiar with local practices and standards to manage the afforestation activities and oversee the monitoring and maintenance periods to ensure compliance with permit requirements. This will include monitoring of workmanship, quality, quantity, species and plant survival. Following completion of the afforestation, monitoring and maintenance activities, TAP will seek formal agreement that afforestation has been successfully completed in accordance with national forest laws and the relevant accompanying permits.

E2. Monitoring and reporting success of offsets vs NNL and NG

BOMP implementation activities and trajectory towards NNL/NG will be regularly monitored by TAP, supported by a forestry and biorestoration specialist. Failed plants will be replaced, where neces-

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sary, to ensure 80% survival rate within the first three years and any further remedial work will be agreed with the Forestry Authority.

Additionally, the objective of each biodiversity offset will be defined within each BOMP. Site specific KPIs will be developed against which success can be measured.

TAP will report monitoring results and KPIs in the annual ESCH report.

BOMP close out evaluation reports will be submitted when NNL / NG objectives have been achieved in each specific BOMP.

1.6.6 Objective F. Implement biodiversity offset programs for PBF and CH fauna where residual impacts are identified and demonstrate NNL or NG

F1. Execution and verification of offset activities

F2. Monitoring and reporting success of offsets vs NNL and NG

BOMP implementation activities and trajectory towards NNL/NG will be regularly monitored by TAP, supported by a forestry and biorestoration specialist. Failed plants will be replaced, where necessary, to ensure 80% survival rate within the first three years and any further remedial work will be agreed with the Forestry Authority.

Additionally, the objective of each biodiversity offset will be defined within each BOMP. BOMP specific KPIs will be included for each REIR entry requiring offsets in order to measure success against NNL / NG obligations.

TAP will report monitoring results and KPIs in the annual ESCH report.

BOMP close out evaluation reports will be submitted when NNL / NG objectives have been achieved in each specific BOMP.

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4. RESIDUAL IMPACTS ASSESSMENT

The following section addresses measures implemented in accordance with biodiversity offset component objective A and B.

1.7 Preconstruction Biodiversity Baseline

Prior to construction a program of biodiversity surveys was conducted as follows:

• at the pre-ESIA stage to support the preparation of the ESIA and inform project routing decisions • post ESIA surveys to increase the resolution of biodiversity data and inform construction planning • pre-construction surveys by the EPC Contractors to support further validation of local sensitivities. The biodiversity baseline is presented in section 7 of the EMP (Ref. 2) and listed by kilometre point (KP) in the Route Environmental Impact Register (REIR) which is provided in Appendix 1 of the EMP (Ref. 2)

1.8 Preconstruction Predicted Residual Impacts

Section 11 of the SEA (Ref.5) presents a summary of the preconstruction predicted residual impacts and impact area calculations for terrestrial critical habitat (CH) triggers and priority biodiversity features (PBF). This presents the preconstruction predicted biodiversity offsets considered likely to be required as a result of construction impacts in order to achieve net gain for critical habitat and no net loss for natural habitats and priority biodiversity features, as indicated in the tables. The preconstruction predicted residual impacts in section 11 of the SEA (Ref. 5) are based on the precautionary CHA (Ref. 3).

1.9 Biodiversity Baseline Verification Surveys

TAP has undertaken a program of verification biodiversity surveys and construction compliance monitoring in order to: • Support validation of the CHA (Ref. 3) • Resolve biodiversity baseline uncertainties attributable to the precautionary approach adopted during development of the CHA (Ref. 3) • Determination of extent and quality of species and habitats present • Confirm impacts as a result of realignments, micro-siting and any additional land take associated with construction activities • Confirm impact avoidance and minimisation as a result of the successful implementation of the mitigation hierarchy

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• Conduct focused surveys and studies with the benefit of EPC Contractor monitoring data • Identify any baseline changes attributable to external factors • Early post construction monitoring. Species and habitat specific verification survey information is provided in section 4.1.2 and 4.2.2 of the BMP (Ref. 4) for flora and fauna respectively.

1.10 Implementation of the Mitigation Hierarchy

The mitigation hierarchy was applied to avoid, mitigate and rehabilitate potential impacts to biodiversity features identified in the CHA. Specific mitigation measures are outlined in detail in the EMP (Ref. 2). Figure 3 illustrates how the mitigation hierarchy has been applied to a generic section of the pipeline.

Avoid – e.g. realignment of the pipeline corridor or selection of trenchless construction

technique (i.e. no impact to the biodiversity feature)

Minimise – e.g. narrowing of the ROW

Rehabilitate – e.g. restoration of habitat within the ROW Extent of clearing for Offset – Compensate significant residual ROW impacts e.g. loss of habitat within the PPS

Figure 3 - Mitigation hierarchy for pipeline ROW

1.10.1 Avoid

Examples of how significant impacts on biodiversity have been avoided include:

• Route realignments • Trenchless watercourse crossings • Restrictions on construction hours/seasons • Additional onshore micro-siting during EPC Contractor site establishment

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Figure 4 - Avoidance of impacts on riparian corridor of ‘Aliakmonas 2’ watercourse at KP535 in Greece by applying a trenchless methodology.

1.10.2 Minimise

Examples of how significant impacts on biodiversity have been minimised include:

• Narrowing of working strip (area within the ROW where vegetation is cleared) • Watercourse crossing method statements • Implementation of marine megafauna and turtle mitigation protocols

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Figure 5 - Minimisation of impacts on fish at ‘Phillipi 9’ watercourse at KP211 in Greece by applying electrofishing prior to trenching.

Figure 6 - Minimisation of impacts on fish at ‘Phillipi 9’ watercourse at KP211 in Greece by applying robust silt management measures

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1.10.3 Rehabilitate

The majority of the onshore pipeline working strip, with the exception of the 8 m PPS, will be rehabilitated on completion of construction, with pre-construction habitats condition allowed to regenerate (i) naturally from the seed bank and (ii) through biorestoration in sensitive areas. Examples of how significant impacts on biodiversity have been rehabilitated include:

• Translocation and reseeding (incl. seed collection) • Revegetation / biorestoration of RoW • Retention of habitat features (coarse woody debris) for use in reinstatement

Figure 7 - Rehabilitation of watercourse at KP359 in Greece by best practice reinstatement

1.10.4 Offset

TAP have committed to establishing a network of offset sites in Greece and Albania for compensation afforestation, in accordance with the host nation’s legislative and permit requirements.

Assessments have been completed by TAP biodiversity offset team to determine which offset sites have a predicted contribution to achieving NNL/NG for the fauna / flora residual impacts. These sites will be used as direct offset sites for flora and included in the specific BOMPs.

1.11 Construction Compliance Monitoring

Construction compliance monitoring was conducted by TAP throughout construction to ensure compliance with the EMP (Ref. 2) and the successful implementation of the mitigation hierarchy in order to reduce impacts to biodiversity features.

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1.12 REIR residual impacts protocol

The following section describes measures implemented in accordance with biodiversity offset component objective C and D.

Biodiversity baseline verification surveys and construction compliance monitoring data has been analysed in order to assign 2020 restoration scores to each REIR entry.

1.12.1 Restoration scores 1. No residual impact - where the Project avoided impact to the feature, or the feature was not deemed present following verification surveys. Monitoring will cease and the Level 3 site file will be closed. 2. No residual impact predicted – where the project avoided impact to the feature, but further monitoring is required to confirm the residual impact assessment. Upon confirmation of no residual impacts after further monitoring, restoration score will be reassigned as 1. 3. Biorestoration and/or offsets complete, NNL or NG can be demonstrated, with the biodiversity level confirmed. Monitoring will cease and the Level 3 site file will be closed. 4. Biorestoration not complete, further monitoring and / or intervention required until no residual impacts, NNL or NG can be demonstrated. When No residual impacts, NNL or NG can be demonstrated restoration score will be reassigned 3. Where further monitoring identify residual impacts, or NNL and NG cannot be demonstrated the restoration score will be reassigned 5. 5. Biorestoration failed, NNL or NG is not considered achievable. Biodiversity offsets to be implemented as an additional offset to achieve NNL / NG. When NNL or NG can be demonstrated through offsets restoration score will be reassigned to 3. 6. NNL or NG is not considered achievable via biorestoration. Biodiversity offsets already designed. When NNL or NG can be demonstrated through offsets, restoration score will be reassigned to 3.

Data from TAP’s biorestoration monitoring program Appendix 7 of the BMP (Ref. 4), and for linear habitats, TAP Linear Habitats Monitoring Plan (Ref. 6) will be analysed by TAP biodiversity offset team on an annual basis against the KPIs in order to determine the quarterly restoration score of each REIR entry.

The REIR and corresponding Level 3 Site File will be updated following annual reviews to record the current restoration score of each REIR entry.

• Where REIR entries are assigned a restoration score 5, the new residual impacts will be included in the TAP biodiversity offset accounting system. The Level 3 Site File shall be updated with the residual impact assessment and offsets required to ensure NNL / NG.

• Where REIR entries are assigned a restoration scores 2 or 4 – 6, the Level 3 Site Files will be updated with site specific monitoring results, monitoring plans and recommended interventions, including offsets where deemed necessary to achieve NNL / NG.

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• Where restoration score 1 or 3 is achieved, the REIR entry and corresponding Level 3 site file will be considered closed and post construction monitoring will cease. The Level 3 Site File shall be updated with the residual impact assessment and monitoring data that demonstrates no residual impacts, NNL or NG.

Level 3 Site File close out will be subject to an evaluation and close-out review by an independent consultant prior to cessation of the monitoring efforts. The evaluation and close-out will include an audit of the corresponding Level 3 Site Files that demonstrates no residual impact, NNL or NG. Where considered necessary a close-out site visit will be completed to support the close out.

Annual restoration scores will be reported in the TAP annual self-monitoring ESCH report, followed by Annual reports during the operational phase. The content of a Level 3 Site File is described within the EMP (Ref. 2).

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5. RESIDUAL IMPACTS

The following section addresses biodiversity offset component objectives A and B2.

TAP has analysed the verified biodiversity baseline and construction compliance monitoring data against the preconstruction biodiversity baseline and preconstruction predicted residual impacts in order to identify biodiversity features with a restoration score 6, i.e. those having verified residual impacts as a result of TAP activities.

1.13 Location of Residual Impacts

Tables 4, 5, 6 and 7 summarize the location of the residual impacts, organized according to vegetation community and species of concern. The kilometre points in these tables represent the indicative location or range of the specific vegetation types or species impacted, detailed construction data have been analysed to quantify the area of residual impacts.

These residual impacts occur at a number of discrete sites along the length of the pipeline. Figure 8 is a map that identifies the impact sites in Greece. Figure 9 is a map that identifies the impact sites in Albania.

Table 4 - Location of residual impacts to critical habitat deciduous forests

Habitat type KP location or range (site file code)

Greece Albania - 9270 Helenic beech forests with Abies KP 70 – 78 (9110 Al 3) borisii-regis

Table 5 - Location of residual impacts to critical habitat pine forests

Habitat type KP location or range (site file code)

Greece Albania

9540 Mediterranean pine forests with en- - KP 27 – 31.5 (9540 Gr 1) demic Mesogean pines

2 Tables in section 5 will be updated if additional residual impacts arise from realisation of Restoration Score 5 sites. This BOS will be updated and reissued for lender group review in this event.

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Table 6 - Location of residual impacts to PBF deciduous, pine and mixed forests

Verified Habitat type KP location or range (site file code)

Greece Albania

9130 Asperulo–Fagetum beech forests KP 437.8 – 441 (9130 Gr 1) -

91KO Illyrian Fagus sylvatica forests KP 85.5 - 87.8 (9110 Al 1) (aremonio-Fagion) -

KP 118 - 122 (91MO Al 1) 924A Thermophilous oak woods of E KP 48 - 50 (*new4) KP 122 - 124 (91MO Al 2) 3 Mediterranean and Balkans KP 56 - 59 (924A Gr 4) KP 125 - 131 (9340 Al 5) KP 303 (924A Gr 6) KP 430 - 438 (924A Gr 7) KP 443 - 445.2 (924A Gr 8) KP 445.2 - 446.2 (*new5) KP 446.2 - 448.9 (924A Gr 9) KP 545 - 547 (924A Gr 10)

9340 Quercus ilex and Quercus rotundi- fola forests - KP 103 - 104 (9340 Al 2) KP 125 - 131 (9340 Al 5)

9540 Mediterranean pine forests with endemic Mesogean pines (Pinus brutia KP 50 – 56 (9540 Gr 2) - with Pinus nigra/Quercus sp locally) (mixed deciduous)

Table 7 - Location of residual impacts to large carnivores

Species KP ranges (site file code)

Greece Albania KP 495 – 503 (Gr EBB 2) KP 62 – 66 (Al EBB 3) Brown bear (Ursus arctos) KP 545 – 550 (Gr EBB 4) KP 70 – 78 (Al EBB 4) KP 495 – 503 (Gr WOL 5) KP 62 – 66 (Al WOL 2) Wolf (Canis lupus) KP 545 – 550 (Gr WOL 7) KP 70 – 78 (Al WOL 3) - KP 62 – 66 (Al CAT 3) Wildcat (Felis silvestris) KP 70 – 78 (Al CAT 4)

3 Habitat 924A is the same habitat type as the new code 91MO within this document 4 *new relates to habitat which was not originally assigned a site file code due to the Palagia reroute. 5 *new relates to habitat which was not originally assigned a site file code due to the Grammatiko reroute.

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Figure 8 – Geographical locations of residual impacts in Greece

Figure 9 – Geographical locations of residual impacts in Albania

1.13.1 Grouping of Vegetation communities

TAPs right-of-way biorestoration and biodiversity offset restoration programs focus on restoring the natural habitats that were impacted by the pipeline using one of two strategies:

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1. Assisting natural regeneration by planting supplementary diagnostic species of the impacted habitat type along the ROW i.e. Quercus, Carpinus and Cornus saplings in deciduous forest, Pinus brutia and Quercus coccifera saplings in pine forest 2. Assisting natural regeneration at offset sites by planting species that promote forest establishment and initiate ecological succession. Over time, this will create suitable conditions for desired late-succession forest species. Competent forest authorities have developed site-specific strategies that consider local conditions and historical data on forests that previously occurred in these areas. Examples include planting shrub species6, black pine, and Robinia pseudoacacia7 to improve site conditions and initiate forest restoration.

All of the forest PBF habitats impacted belong to either Fagus, Quercus or Pinus forests. These occur in the ROW as mixed forests along a gradient of similar structure and composition. In other words, it is not common to find well defined areas that are strictly definable as a single distinct forest type. As a result, it is more accurate to group forest types into three broader categories: Deciduous, Pine and Mixed habitats. (In all cases, the success of biorestoration and offset sites will be deter- mined based on measures of similarity to impact sites of species composition and structure in order to ensure that the broader categorization of forest types continues to adhere to the principle of like- for-like restoration and offsets. This approach is detailed in Section 8.)

Further information on natural regeneration and successional processes is provided in Appendix 7 of the BMP (Ref 4).

1.14 Summary of Residual Impacts

TAP implemented measures to manage the impacts of the project following the mitigation hierarchy described in Section 4. With those measures in place, the project estimates that the residual impacts summarized in tables 8, 9, 10 and 11 remain.

6 Castro, J. et al. 2004. Benefits of using shrubs as nurse plants for restoration in Mediterranean mountains: a 4-year study. Restoration Ecology 12(3): 352-358. 7 Mantovani et al (2015): Carbon allocation, nodulation, and biological nitrogen fixation of black locust (Robinia pseudoacacia L.) under soil water limitation Annals of Forest Research 58(2)(2) DOI: 10.15287/afr.2015.420

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Table 8 - Summary of residual impacts to CH deciduous forests

Project activity Residual Impact Residual Impact area (ha)

Site / ROW preparation (including Direct loss/ disturb- Greece vegetation removal, topsoil strip- ance/degradation/ fragmenta- ping) within suitable vascular plant tion of habitat - habitat

Albania

5.7

Table 9 - Summary of residual impacts to CH Pine forests

Project activity Residual Impact Residual Impact area (ha)

Site / ROW preparation (including Direct loss/ disturb- Greece vegetation removal, topsoil strip- ance/degradation/ fragmenta- ping) within suitable vascular plant tion of habitat 2.9 habitat

Albania

Table 10 - Summary of residual impacts to PBF deciduous, pine and mixed forests

Project activity Residual Impact Residual Impact area (ha)

Site / ROW preparation (including Direct loss/ disturb- Greece vegetation removal, topsoil strip- ance/degradation/ fragmenta- ping) within suitable vascular plant tion of habitat 23.6 habitat

Albania

Table 11 - Summary of residual impacts to large carnivores

Project activity Residual Impact Residual Impact area (ha)

Site clearing and pipeline trenching Loss or conversion of forag- Greece within known or potential bear ing habitats 14.5

Albania

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Project activity Residual Impact Residual Impact area (ha)

Creation of new access roads (Al- Facilitated access for illegal Greece bania only) / upgrading existing ac- loggers cess roads - Avoidance of upgraded roads by large carnivores following construction Albania

TBC8

8 TAP is conducting an illegal logging assessment to quantify the residual impacts. TAP will consult with the lender group during the assessment process and update this BOS when the quantification is complete.

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6. OFFSET DESIGN

The following section describes measures to achieve biodiversity offset component objectives C and D.

1.15 Direct Offsets

1.15.1 Greece

In Greece, the competent forestry authorities selected a total of 19 sites for afforestation in which TAP is obligated to reforest as according to the terms of the Ministerial Decision for the Approval of the Environmental and Social Impact Assessment (ESIA) of the Greek section of the TAP Pipeline by the Minister of Environment, Energy and Climate Change (Decision No 174848) and the Ministe- rial Decision nr. 117653/6833 (Government Gazette 3302/B/9.12.2014) regarding “Environmental Approval of projects and activities, regulation of illegal structures in correlation with the creation of environmental balance and other provisions of the jurisdiction of the Ministry of Environment”.

A portfolio of fifteen of the afforestation sites will serve as biodiversity offsets and will include restoration of habitats that correspond to the project’s residual impacts. They total 234.9 hectares. Table 12 provides details on the area, habitat type, and the competent forest authority responsible for each site. Figure 10 is a map of their locations.

Four of the 19 afforestation sites were not deemed suitable due to their monoculture design destined for eventual wood harvesting.

Table 12 – Greece Offset sites

Site9 Area Forest authority Offset Correlation (ha)

Trigonometriko- Gr 3 18.7 Alexandroupolis PBF deciduous, pine and mixed forest

Kleftis- Gr 4 9.3 Alexandroupolis PBF deciduous, pine and mixed forest

Chloi- Gr 5 20.6 Alexandroupolis PBF deciduous, pine and mixed forest

Rema – Gr 6 39.8 Alexandroupolis PBF deciduous, pine and mixed forest

Myrtiski – Gr 7 5.1 Rhodopi PBF deciduous, pine and mixed forest

Kokkinochori – Gr 8 25.3 Kavalla PBF deciduous, pine and mixed forest

Podochori – Gr 9 10.8 Kavalla PBF deciduous, pine and mixed forest

9 Offset sites Gr 1, Gr 2, Gr 10 and Gr 14 are not currently intended to be included within the current loss / gain analysis.

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Site9 Area Forest authority Offset Correlation (ha)

Paleochori Charavgis 1 – 22.1 Lagkadas CH pine forest Gr 11

Paleochori Charavgis 2 – 12.6 Lagkadas CH pine forest Gr 12

Paleochori Charavgis 3 - 13 Lagkadas CH pine forest Gr 13

Metalliko – Gr 15 3.7 Kilkis PBF deciduous, pine and mixed forest

Foufas – Gr 16 12.3 Kozanzi PBF deciduous, pine and mixed forest

Variko – Gr 17 3.3 Florina PBF deciduous, pine and mixed forest

Sinoro – Gr 18 2.3 Florina PBF deciduous, pine and mixed forest

Lefki – Gr 19 36 Kastoria PBF deciduous, pine and mixed forest

Figure 10 – Geographical location of offset sites in Greece

1.15.2 Albania

In Albania, the competent forestry authorities selected a total of 11 sites for afforestation in which TAP is obligated to reforest as according to the terms of the Ministerial Decision for the Approval of

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the Environmental and Social Impact Assessment (ESIA) of the Albanian section of the TAP Pipeline by the Ministry of Environment, Ministry of Environment, Forestry and Water Administration, the Min- isterial Decision No 3 and relevant Albania Forest Legislation.

All eleven of the afforestation sites will serve as biodiversity offsets and will include restoration of habitats that correspond to the project’s residual impacts. They total 130.7 hectares. Table 13 provides details on the area, habitat type, and the competent forest authority responsible for each site. Figure 11 is a map of their locations.

Table 13 – Albania Offsets Sites

Site Area (ha) Forest authority Offset Correlation

Maliq – Al 1 1 Maliq PBF deciduous, pine and mixed forest

Polene – Al 2 5 Korce PBF deciduous, pine and mixed forest

Shtylle – Al 3 5 Korce PBF deciduous, pine and mixed forest

Voskopoje – Al 4 35.8 Korce PBF deciduous, pine and mixed forest

Devoll – Al 5 1 Korce PBF deciduous, pine and mixed forest

Zogas – Al 6 30.6 Skrapar PBF deciduous, pine and mixed forest

Veleshnje – Al 7 20 Skrapar PBF deciduous, pine and mixed forest

Buzuq Therepele - Al 8 10 Skrapar PBF deciduous, pine and mixed forest

Polican – Al 9 15 Polican PBF deciduous, pine and mixed forest

Ura- Vajgurore – Al 10 0.8 Ura-Vajgurore PBF deciduous, pine and mixed forest

Berat – Al 11 6.5 Berat PBF deciduous, pine and mixed forest

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Figure 11 – Geographical location of offset sites in Albania

1.16 Discharge of Residual Impacts at Offset Sites

Tables 14-17 show the anticipated discharge of offset liabilities for the project’s residual impacts.

Table 14 - CH deciduous forest impact and offset sites

Residual Impact (ha) Offset

Location Area (ha) Total (ha)

Greece

- - - -

Albania

5.7 EPC trading up outside of DMU10 7.2 7.2

10 No offset site used to discharge CH deciduous residual impacts. EPC trading up accounts for a 7.2 ha offset. This was achieved by EPC replanting Fagus sylvatica in areas outside of the Critical Habitat Discrete Management Unit (DMU), in accordance with Competent Authority approved reforestation plans

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Table 15 - CH pine forest impact and offset sites

Residual Impact (ha) Offset

Location Area (ha) Total (ha)

Greece

Paleochori Charavgis 1 – Gr 11 22.1 2.9 47.7 Paleochori Charavgis 2 – Gr 12 12.6

Paleochori Charavgis 3 - Gr 13 13

Albania

- - - -

Table 16 - PBF deciduous, pine and mixed forest impact and offset sites

Residual Impact (ha) Offset

Location Area (ha) Total (ha)

Greece

Trigonometriko - Gr 3 18.7

Kleftis - Gr 4 9.3

Chloi - Gr 5 20.6 Rema - Gr 6 39.8

Myrtiski - Gr 7 5.1

23.6 Kokkinochori - Gr 8 25.3 187.2 Podochori - Gr 9 10.8

Foufas - Gr 16 12.3

Metalliko - Gr 15 3.7

Variko - Gr 17 3.3

Sinoro - Gr 18 2.3

Lefki - Gr 19 36

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Residual Impact (ha) Offset

Location Area (ha) Total (ha)

Albania

Maliq - Al 1 1

Polene - Al 2 5

Shtylle - Al 3 5 Voskopoje - Al4 35.8

Devoll - Al 5 1 14 130.7 Zogas - Al 6 30.6

Veleshnje - Al 7 20

Buzuq Therepele - Al 8 10

Polican - Al 9 15

Ura- Vajgurore - Al 10 0.8

Berat - Al 11 6.5

Table 17 – Large Carnivore impact and offset sites

Residual Offset Impact (ha) Location Area (ha) Total (ha)

Greece

Bear and wolf – collocated

Mouries – Gr 2 0.4

Myrtiski – Gr 7 93.6

Foufas – Gr 16 12.3 111.9 14.5 Variko – Gr 17 2.3

Sinoro – Gr 18 3.3

Bear (only)

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Residual Offset Impact (ha) Location Area (ha) Total (ha)

Lefki – Gr 19 36 36

Wolf (only)

Kleftkis – Gr 4 9.3 9.3

Albania

Bear, wolf and wild cat - collocated 10 Shtylle – Al 3 5

40.8 Voskopoje – Al 4 35.8

1.17 Indirect Offsets

Potential indirect offsets have been identified, these will be developed in consultation with relevant stakeholders and the lender group. This BOS will be updated when the indirect offsets have been finalised. A BOMP will be developed for each indirect offset.

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7. LOSS GAIN AND VIABILITY ANALYSIS

1.18 Loss Gain Analysis

The following section describes measures to achieve biodiversity offset component objectives E and F.

Measuring progress toward NNL and NG requires a framework that combines measures of vegetation condition (quality) and area. Examples include Habitat Hectares11, Biocondition12, and Quality Hectares13,14.

Vegetation quality is generally measured by the similarity of indicators of composition, structure and function to benchmark values of those same indicators in undisturbed native vegetation of the same type. Quality expressed as a quality coefficient (QC) that varies between 0 and 1, where 0 is com- pletely denuded or degraded and 1 is indistinguishable from benchmark. Various approaches to cal- culating indicator quality have been developed. These range from simple ordinal categories of relative difference from benchmark15 to more complex approaches based on distribution overlap16.

The quality-hectares (QH) of a given class or unit of vegetation is the area of that vegetation (in ha) discounted by its overall quality. For example, 50 ha of habitat with a quality of 0.8 (80%) has a QH value of 40 (50 x 0.8). In general, QH is measured relative to a baseline of the original QH present before all project impacts. As shown in Figure 12, successive QH assessments are used to measure progress toward NNL (current QH = baseline QH) or NG (current QH > baseline QH).

11 Parkes, D., and G. Newell. 2003. Assessing the quality of native vegetation: the “habitat hectares” approach. Ecological Management & Restoration 4:29–38. 12 Eyre, T. J., A. . Kelly, V. J. Neldner, B. A. Wilson, D. J. Ferguson, M. J. Laidlaw, and A. J. Franks. 2011. BioCondition: A Condition Assessment Framework for Terrestrial Biodiversity in Queensland. Assessment Manual. Version 2.1. Page Department of Environment and Resource Management (DERM), Biodiversity and Ecosystem Sciences. Brisbane. 13 Rabenantoandro, J. Randriatafika, F., and P. P. Lowry II. 2007. Floristic and Structural Characteristics of Remnant Littoral Forest Sites in the Tolagnaro Area. Pages 65–93 in J. U. Ganzhorn, S. M. Goodman, and M. Vincelette, editors. Biodiversity, Ecology and Conservation of Littoral Ecosystems in Southeastern Madagascar; Tolagnaro (Fort Dauphin. Smithsonian Institution, Washington DC. 14 Rio Tinto. 2008. Rio Tinto and biodiversity: achieving results on the ground. Rio Tinto plc and Rio Tinto Limited. 15 Parkes, D., and G. Newell. 2003. Assessing the quality of native vegetation: the “habitat hectares” approach. Ecological Management & Restoration 4:29–38. 16 Boyle, B. L., R. E. Gullison, D. J. Vasiga, G. L. Luini, and W. F. Franklin. 2018. Vegetation Quality Assessment: Measuring Quality of Vegetation Communities to Support the Accounting Metrics of the Biodiversity Vision of Net Positive Impact for a Large-Scale Mining Operation. Page 41st Annual TRCR Mine Reclamation Symposium. Fort Williams, BC, Canada.

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Figure 12 – Illustrative program of tracking progress to no net loss (NNL) and net gain (NG) of vegetation quality hectares (QH), by means of multiple QH assessments. Red line measures quality at the project site. Green line shows additional QH gains from offset sites. Losses, gains, and NNL are measured relative to a baseline of QH present prior to project start.

For TAP, quality will be based on at least 9 indicators of habitat composition, structure and demography. Table 18 details those indicators. Monitoring and analysis methods are detailed in TAP Linear Habitats Monitoring Plan (Ref. 6).

Table 18 – Habitat Quality indicators

Indicator Details

Native Species Richness Total species recorded in cover plot

Taxonomic Composition Multivariate indicator measured relative to benchmark vegetation.

Percent Cover Grass Cover of native herb species, scaled to maximum possible value.

Percent Cover Forbs Cover of native herb species, scaled to maximum possible value.

Percent Cover Shrubs Cover of native shrub species, scaled to maximum possible value.

Percent Cover Trees Cover of native tree species, scaled to maximum possible value.

Total Basal Area (M2/Ha) Summed basal area of all stems in plot

Small Tree Abundance Abundance of trees 2.5-10 cm dbh

Large Tree Abundance Abundance of trees ≥10 cm dbh

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To calculate overall quality, indicators are first grouped into functional groups of related indicators. This prevents correlated indicators from dominating overall quality and obscuring variation in other, relatively independent indicators. Functional group quality is calculated as the arithmetic mean of all indicator qualities in that group. Finally, overall quality is calculated as the geometric mean of the functional group qualities. The geometric mean drops to zero if quality of any functional group drops to zero, thus preventing the complete substitution of one functional group for another17. Table 19 provides an example calculation of functional group and overall quality, based on hypothetical indicator qualities.

Table 19 – Example calculation of functional group and overall quality

Indicator Functional group Indicator Quality Functional Group Means

Native Species Richness Composition 0.65 0.717 Taxonomic Composition Composition 0.55

Basal Area (m2) Structure 0.95

Percent Cover by Growth From - Grass Structure 0.89

Percent Cover by Growth From - Forb Structure 0.96 0.93 Percent Cover by Growth From - Structure 0.94 Shrubs

Percent Cover by Growth From - Trees Structure 0.99

Abundance - Small Tree Demography 0.75 0.775

Abundance - Large Tree Demography 0.8

Overall quality 0.8

Such quantitative measures provide a precise and repeatable method to measure changes in quality of restored areas over time. The strategy is to use this measure to verify that restored areas are in- creasing in quality over time. If this is occurring, the restored area should be on a trajectory towards eventually achieving a score of 1 – the same quality as the benchmark site. The quality-hectares approach accommodates not achieving a score of 1 where offset areas are larger than impact sites, but there is not a priori established minimum acceptable quality score in this system. As a result, any quantitative demonstration of NNL or NG must be corroborated by an experienced ecologist that vis-

17 McCarthy, M., and K. Parris. 2004. The habitat hectares approach to vegetation assessment: An evaluation and suggestions for improvement. Ecological Management & Restoration 5:24–27.

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its the sites and validates that the offsets are indeed providing reasonable ecological benefits and that the vegetation is on an acceptable restoration trajectory.

Because quality gains are measured relative to a benchmark site in the same landscape, the effects of external environmental stresses (e.g., periods of drought, pest infestations) can be somewhat normalized and will continue to reflect the trajectory of restoration relative to the benchmark given those shared environmental conditions.

Table 20 presents an example of how a loss-gain table can demonstrate a quantitative achievement of NNL or NG, the results of which would be supported by a qualitative assessment by an ecologist that visits the sites and verifies the ecological benefits and restoration trajectory. For TAP, both the quantitative and qualitative assessments will be carried out by qualified and experienced botanists and ecologists.

Table 20 – Example loss-gain analysis demonstrating quantitative achievement of NNL or NG

Vegetation Residual Resid- Residual Offset Ar- Offset Q Offset QH NNL/NG Type Loss Area ual Loss QH ea (Ha) (Ha) Loss Q

CH Decidu- 5.7 1 5.7 7.2 0.8 5.8 Yes ous Forest – Albania

CH Pine 2.9 1 2.9 47.7 0.8 38.2 Yes Forest – Greece

PBF Decidu- 23.6 1 23.6 187.2 0.8 149.8 Yes ous, Pine, Mixed Forest – Greece

PBF Decidu- 14 1 14 130.7 0.8 104.6 Yes ous, Pine, Mixed Forest – Albania

Bear and 14.5 1 14.5 157.2 0.8 125.8 Yes wolf habitat – Greece

Bear-wolf- 10 1 10 40.8 0.8 32.6 Yes wildcat habitat – Albania

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1.19 Viability Analysis

In addition to achieving NG for CH, it is also essential to verify that the viability of threatened species or ecosystems is not jeopardized by project impacts, even when they are offset. This would result by overly reducing the habitat size (and resident populations) between the time of project construction and the achievement of NNL or NG via offsets. For example, if the habitat for a restricted-range Crit- ically Endangered species is reduced, even if temporarily, it may reduce the ability of that species to maintain a viable population in the habitat that remains. Good practice dictates that if there is any risk of this occurring, avoiding such impacts is more appropriate than offsetting them.

It is more common that a biodiversity value is sufficiently extensive/abundant in the larger landscape to ensure its long-term viability or function while project mitigation is undertaken. In these cases, the time lag for an offset to generate the desired improvements in quality is not an ecological concern18.

In the case of TAP, there is no reason to believe that the habitat types and fauna species catego- rized as PBF or CH are so limited in the landscape that the proposed temporal loss of habitat will af- fect their long-term viability. As such, the requirements for CH are expected to be met.

18 Hardner et al. 2015. Good Practices for Biodiversity Inclusive Impact Assessment and Management Planning, pub- lished by the Multilateral Financing Institutions Biodiversity Working Group (including EBRD, EIB, and IFC).

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8. MONITORING AND REPORTING

The following section describes measures to achieve biodiversity offset component objectives E and F.

1.20 Method

Monitoring and analysis methods are detailed in TAP Linear Habitats Monitoring Plan (Ref. 6).

1.21 Frequency and Duration

Botanical monitoring will be conducted in accordance with Section 5 of TAP Linear Habitats Monitor- ing Plan (Ref. 6) until 15 years or until NNL/NG is achieved for each habitat category. Thereafter, the offset areas will be visited annually to ensure they continue to be adequately managed and con- served by the respective forestry authorities.

1.21.1 Insufficient Improvement in Quality

Success of the offsets relies on improving habitat quality (Q) at the offset sites. If monitoring does not reveal that overall Q scores are on a reasonable trajectory towards their necessary minimum scores over a 15-year period, interventions may be necessary. Tables 5-3 and 5-4 in TAP BMP (Ref. 4) present the biorestoration interventions and triggers

If growth and/or recruitment of native species stalls (for two or more years), the project will examine options such as: a) enrichment planting; b) changing management of the site; or b) dropping the site as an offset and re-allocating effort to other sites19.

1.21.2 Invasive Species

If invasive species cover increases significantly at a site, controls should be implemented to remove them. Specifically, for Robinia pseudoacacia, a species that will be planted intentionally to establish conducive site conditions for afforestation and fire control, if species cover increases disproportion- ately to its establishment density, it should be managed by removing individuals. If Robinia pseudoacacia begins to occur in the periphery of the afforested area, those individuals should be removed.

1.22 Reporting

TAP will report the monitoring results of the success of this BOS to the lender group in the annual self-monitoring ESCH report during the operational phase.

Botanical monitoring reports, KPIs and the overall all trajectory towards NNL / NG will be provided.

19 In this case, any sampling plots for monitoring must be relocated to remaining offset sites of the same habitat category in order to maintain adequate sampling intensity for that habitat category.

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9. ENGAGEMENT

The following sections describes measures implemented in accordance with biodiversity offset component objectives E and F.

The identification and implementation of measures set out in this BOS will require the active partici- pation and approvals including national, regional and local governments and authorities; NGOs and conservation groups; academic institutions; Project lenders; and other potentially affected and interested parties.

TAP has identified three broad categories that require engagement to ensure the successful implementation of this BOS:

• Statutory organisations • Non-Statutory Organisations • Potentially affected third parties

Table 21 summarises these engagement categories and purposes for each.

Table 21 – Engagement categories

Engagement Categories

Statutory organisations: Non- Statutory organi- Potentially affected third sations: parties: National, regional and local governments and authorities NGOs, research centres Local communities, shep- and education institu- herds, cultivators. tions

• Legal compliance • Collaboration in con- • Community health and servation actions safety • Issuance of land for afforestation • Identify research op- • Communication of portunities planned activities • Approval of afforestation design • Data sharing • Grievance resolution Purpose • Issuance of afforestation permits • Afforestation works su- pervision and compliance assurance • Issuance of afforestation works completion certifi- cates. • Long term site management

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1.23 Direct offsets

TAP’s direct offsets will be accomplished through afforestation of degraded sites selected by the competent forestry authorities of Greece and Albania to compensate for impacts to forest land during pipeline construction and operation activities.

In both countries, the afforestation activities are required by national law to compensate for impacts to state forest land as a result of TAP. Activities within state forest land are strictly regulated by the competent forest authorities, underpinned by legislative requirements, permissions and permits. Complying with the national legislation and ensuring the satisfaction of the competent forest authorities is the primary function of the engagement process in both Greece and Albania as such engaged parties are mainly the competent Forest Authorities, local and regional, and their executives in charge for the delivery and approval of the afforestation activities.

1.24 Direct offsets – Greece

1.24.1 Applicable legislation

State forest areas are afforded constitutional protection in Greece, with the primary protection mechanism being the following Acts:

• Law 998/1979 - "On protection of forests and forest areas of the country” • Law 1650 / 1986 – “On protection of the environment”

These are supplemented by subsequent acts, Presidential decrees and Ministerial and Joint Ministe- rial Decisions (MD/JMD):

• MD 117653/6833/28-11-2014 (GG 3302/Β/09-12-2014) - “Readjustment of the amount owed for return of use for permitted operations on forests, forestry areas or public land as defined in the art. 3, par. 5, cases (a) and (b) of the Law 998/1979 (GG 289/A/29-12-1979), as in force” • Law 4014/2011 (GG 209/Α/2011) - “Environmental Approval of projects and activities, regulation of illegal structures in correlation with the creation of environmental balance and other provisions of the jurisdiction of the Ministry of Environment” • MD 174848 – “Approval of the Environmental and Social Impact Assessment (ESIA) of the Greek section of the TAP Pipeline”

In compliance with the above legislation TAP is required to obtain the necessary permits for interventions on state forest land and perform reforestation works in areas designated by the competent Forest Authorities equal in area to the forest areas affected by the construction works of the Project.

1.24.2 Governance

In Greece, the competent forestry authorities selected a total of 19 sites for afforestation in which TAP is obligated to reforest in accordance to the terms of the relevant Greek Forest Legislation. Fif-

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teen of these sites will be used in the Greece direct offsets program in order to comply with Lender performance standards.

The following competent forest authorities are responsible for regulating TAP afforestation activities in Greece.

Table 22 – Competent authorities – Greece

No Level Authority

1 Decentralized Administration of Macedonia and Thrace

2 Decentralized Administration of Epirus and Western Macedonia

General Department of Forestry and Rural Affairs of Macedonia 3 and Thrace Decentralized Gov- General Department of Forestry and Rural Affairs of Epirus and 4 ernment Western Macedonia

Directorate of Coordination and Inspection of Forests of Mace- 5 donia and Thrace

Directorate of Coordination and Inspection of Forests of Epirus 6 and Western Macedonia

7 Directorate of Reforestations of Central Macedonia Regional 8 Directorate of Reforestations of Eastern Macedonia and Thrace

9 Forest Department of Evros

10 Forest Department of Rodopi

11 Forest Department of Xanthi

12 Forest Department of Kavala

13 Regional District Forest Department of Drama

14 Forest Department of Serres

15 Forest Department of Kilkis

16 Forest Department of Thessaloniki

17 Forest Department of Pella

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No Level Authority

18 Forest Department of Imathia

19 Forest Department of Kozani

20 Forest Department of Florina

21 Forest Department of Kastoria

22 Forest Authority of Soufli

23 Forest Authority of Alexandroupolis

24 Forest Authority of Xanthi

25 Forest Authority of Kavala

26 Forest Authority of Drama

27 Forest Authority of Serres Local 28 Forest Authority of Kilkis

29 Forest Authority of Lagadas

30 Forest Authority of Thessaloniki

31 Forest Authority of Edessa

32 Forest Authority of Naoussa

33 Forest Authority of Kozani

TAP is required to submit individual Afforestation studies for each area to the respective competent forest authority which detail the afforestation activities required to comply with TAP legal obligations.

Upon approval of the Afforestation Study, the competent forest authority will issue an ‘Installation Protocol’ which approves and permits the TAP afforestation activities to commence in line with the approved procedures and schedules.

Upon completion of the afforestation activities a Declaratory Act will be issued by the competent forest authority, per afforestation area, which certifies that TAPs legal obligation towards afforestation has been satisfied in accordance with the installation protocol.

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1.25 Direct offsets – Albania

1.25.1 Applicable legislation

State forest areas are afforded robust legal protection in Albania, with the primary protection mechanism being the following Acts:

• Law 9385 / 2005 – “Law on forest and pastures in the Republic of Albania” • Law 5 / 2016 – “On the proclamation of the moratorium on forests in the Republic of Alba- nia”. These are supplemented by Ministerial Orders and Decision of Council of Ministers (DCMs).

• Ministry of Environment Order 1937 /2014 - “On defining the obligation of the companies to replace forest areas and improve pasture areas that are removed from the forest and pasture fund, through reforestation, afforestation and improvement activities. • Decision of Council of Ministers 50 21 /2015 - “On the removal from the forest and pastoral fund of the surface that will be used by the company “TAP-AG”, for the construction of the road “Pronovik-Zgërbonjë-Antena”; • Decision of Council of Ministers 92 / 2017 - “On the removal of the public forest and pastoral fund and volume reduction of the surface of the public forest and pastoral fund that will be used by the company “TAP-AG”, for the construction of the onshore section of TAP gas pipeline, for sectors 5B and 5C in the district of Korca and Berat”; • Decision of Council of Ministers 248 /2016 “On the removal of the forest and pastoral fund and reduction of the surfaces that will be used by the company TAP-AG for the extension of the TAP gas pipeline, for sectors 4A, 4B and 5A in the district of Korca, Berat and Fier; • Decision of Council of Ministers 366 /2014 - “On the removal of the forest and pastoral funds of the forest and pastoral surfaces that will be used by the company TAP-AG for the construction of the road network” • Decision No 3 – “Approval of the Environmental and Social Impact Assessment (ESIA) of the Albania section of the TAP Pipeline”

In compliance with the above legislation, TAP is required to obtain the necessary permits for interventions on state forest land and perform reforestation works in areas designated by the competent Forest Authorities, equal in area to the forest areas in the state forest fund permanently affected by the construction works of the Project in the following ratios (impact : compensation), under the direc- tion of the Ministry of Environment Order 1937 /2014:

• 1:3 – ‘high forest’ habitats • 1:1 – ‘coppice’ habitats

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1.25.2 Governance

In Albania, the competent forestry authorities selected a total of 11 sites for afforestation in which TAP is obliged to reforest in accordance to the terms of the relevant Albanian Forest Legislation. All these sites will be used in the Albania direct offsets program in order to comply with Lender performance standards.

The following competent forest authorities are responsible for regulating TAP afforestation activities in Albania.

Table 23 – Competent authorities – Albania

No LEVEL COMPETENT AUTHORITY

1 Central Government Ministry of Tourism and Environment

2 Forest Authority of Maliq Municipality

3 Forest Authority of Korce Municipality

4 Forest Authority of Skrapar Municipality Local 5 Forest Authority of Polican Municipality

6 Forest Authority of Devoll Municipality

7 Forest Authority of Berat Municipality

Upon approval of the Afforestation Plans, TAP and the competent authority will sign an ‘Approval of Reforestation and Afforestation Works’ agreement which approves the TAP afforestation activities and the act of land handover to permit works to commence in line with the approved procedures and schedules.

Upon completion of the afforestation activities the Handover Act of the land back to the competent forest authority, per afforestation area, will certify that TAPs legal obligation on regards afforestation has been satisfactory fulfilled in accordance with the approved Afforestation Plans.

1.26 Indirect Offsets

The relevant Competent Authorities, interested parties and implementing partners will be identified and actively engaged during the design and implementation of the indirect offsets. The engagement process will be described within the respective BOMP.

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10. LONG TERM PROTECTION OF AFFORESTATION SITES

The following sections describes measures implemented in accordance with biodiversity offset component objectives E and F.

As described in Sections 10.2 for Greece and 10.3 for Albania, TAP is legally obliged to conduct afforestation at sites selected by the Competent Authorities to compensate for impacts to state forest land as a result of construction activities. In compliance with the national forest legislation and following the state approval of Afforestation Plans, TAP is legally permitted to enter the afforestation sites and complete the reforestation activities in accordance with those plans. Following the completion of the afforestation implementation activities, the Competent Authorities will confirm the successful afforestation and conclusion of TAPs legal obligations. The Competent Authority will retake custody and control of the Sites by integrating them back into protected State forest land.

The long-term protection of the afforestation sites relevant to this BOS is critical in fulfilment of TAPs commitment to No Net Loss / Net Gain to biodiversity.

Pressures to forest land and therefore the success of this BOS vary on a local, regional and country level, in both size and type. Pressures include:

• Illegal logging o Timber harvesting ▪ Enterprise: manufacturing, firewood ▪ Local: firewood, cooking o Clearing ▪ Cultivations ▪ Livestock ▪ Dwellings • Overgrazing • Fire

The following sections briefly sets out the main legal mechanisms in place to protect the state forest land and describes the measures TAP will take in to ensure the long-term net gains of biodiversity.

1.27 Greece

1.27.1 Legal Protection • Constitution ▪ The country forest and other wooded land are protected by articles 24 and 117 of the 1975 Constitution. o Article 24 ▪ Requires the state to protect forests

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o Article 117 ▪ Declares forest damaged by forest fires must be reforested • Law 86/1969: The Forest Code o This law constitutes the Forest Code of the country and regulates matters concerning the protection, management, real property rights on forest land, taxation, exploitation of state and privately-owned forests, forest improvement works etc. o Introduces permits for logging • Law 998/1979: On protection of forests and forest areas of the country o Determines the specific protection measures for maintaining, developing and improving forest and other forest land of the country. o Introduces regulations for forest fire suppression o Introduces penalties for breach of protective measures • Law 1650/1986: “On protection of the environment” o Proposes new categories of protected areas and introduces changes in the administration and management of protected areas

The above-mentioned laws for protecting and managing forests were supplemented by Presidential decrees and Ministerial decisions.

1.27.2 Enforcement

The main body for protecting and managing the country's state forests is the Forest Service which is part of the Ministry of Agriculture. Each Local forest authority maintains a group of officers called the ‘Forest Guard’ who enforce forest protection laws by activity monitoring and deterring breaches within their municipality, while also coordinating the forest fire suppression and response.

1.28 Albania

1.28.1 Legal Protection • Law 9385 / 2005: “On forest and pastures in the Republic of Albania” o Prohibits exploitation activities in state forest land throughout the Republic of Albania, including the trade in forest products, timber exports, construction logs, firewood, and charcoal. • Law 5 / 2016: “On the proclamation of the moratorium on forests in the Republic of Albania” o Establishes rules on the relationships, rights, obligations and responsibilities of the State institutions, local government, Non-governmental Organizations and private business owners for the protection, administration, management and usage of the State forestry land.

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1.28.2 Enforcement

The Forestry Police is the law enforcement agency under the authority of the Ministry of Environ- ment, responsible for forest legislation enforcement. The Forestry Police officers have the same sta- tus as the State Police and Judiciary Police. The forestry police enforce the forest laws through active monitoring within their municipality, while also coordinating the forest fire suppression and response.

1.29 TAP monitoring, long term commitment and risks

TAP direct offsets are afforestation programmes required by host country law that will have full legal approval of all aspects of the design and execution thus removing risk of offset implementation failure.

TAP offset sites will be afforded the full legal protection as described above. TAP has confidence that the legal protection mechanism outlined above will ensure the sustainability of TAPs biodiversity offsets and achievement of its NNL and NG goals for biodiversity.

TAP will monitor each Offset Site on an annual basis in order to identify excursions and potential threats or pressures to the objectives of this BOS and which may be in contravention of the legal protection afforded by law, for example:

• Uncontrolled overgrazing • Development • Theft and vandalism • Natural disaster, e.g. disease, landslides or fire.

Using the relationships formed during the implementation phase of the afforestation works, TAP will actively engage the Competent Authorities to resolve any issues identified during the annual monitoring.

In accordance with TAPs adaptive management approach, vegetation monitoring results may be used to weight the importance of the Offset Sites. Focus will be placed on sites that perform well and will continue to provide the greatest gains to biodiversity over the long term.

In the event that the direct offsets described within this BOS fail to discharge TAPs overall NNL / NG obligations, TAP will engage the Competent Authorities in order to identify, obtain permission and implement additional offsets targeted towards the species or habitat that has not demonstrated NNL / NG.

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11. IMPLEMENTATION

The following sections describes measures implemented in accordance with biodiversity offset component objectives E and F.

1.30 Implementation of Direct Offsets

1.30.1 Forest Establishment Phase (0-3 years)

This phase relates to physical establishment of vegetation at the afforestation sites detailed in Sec- tion 6.1 in accordance with the approved afforestation plans and as required by national forestry legislation and TAP Environmental Terms.

TAP will contract the forest establishment phase to national specialist reforestation contractors.

The scope of the Forest Establishment phase includes:

• Engagement • Site establishment • Procurement of materials • Monitoring • Maintenance • Replacement of failed plants

The specific forest establishment details for each site will be detailed in the respective BOMP, these details will include:

• Implementing contractor details • Detailed budgets and schedule • Engagement details • Physical characteristics of the site • Afforestation objectives • Afforestation species and number • Site monitoring and KPIs

An example BOMP contents page is provided in Appendix 1 of this document.

1.30.2 Long Term Monitoring and Management Phase (>3 years)

The scope of the Long-Term Monitoring and Management Phase is to:

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• Monitor habitat development at the Afforestation sites • Measure habitat quality at Afforestation sites • Statistical analysis of monitoring results to demonstrate long term net gains • Ensure security of TAPs net gain through remediation of degradation and resolution of potential threats to the afforestation sites.

TAP will contract the long-term management and monitoring to national and international consult- ants.

1.31 Implementation of Indirect offsets

The assessment of indirect residual impacts will be completed end of Q1 2021. TAP indirect offsets will be finalised by end of Q2 2021 and included in the next revision of this document.

1.32 Schedule

1.32.1 Direct Offsets - Greece

Table 24 outlines the schedule for direct offsets in Greece. Offset site-specific schedules will be provided in the respective BOMPs.

Table 24 – Schedule for direct offsets in Greece

Activity Start End

Forest establishment phase (0-3 years)

Planting 08 / 2018 03 / 2019

Monitoring and maintenance 02 / 2019 03 / 2022

Long term monitoring and management phase (> year 3)

2036 or until Loss / gain account accounting and reporting 2021 NNL/NG is met

2036 or until Vegetation monitoring 2021 NNL/NG is met

Annual site security monitoring 2030 2040

Site interventions 2021 2036

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1.32.2 Direct Offsets - Albania

Table 25 outlines the schedule for direct offsets in Albania. Offset site-specific schedules will be provided in the respective BOMPs.

Table 25 – Schedule for direct offsets in Albania

Activity Start End

Forest establishment phase (0-3 years)

Planting 12 / 2020 03 / 2022

Monitoring and maintenance 03 / 2021 03 / 2025

Long term monitoring and management phase (> year 3)

2036 or until Loss / gain account accounting and reporting 2021 NNL/NG is met

2036 or until Vegetation monitoring 2021 NNL/NG is met

Annual site security monitoring 2030 2040

Site interventions 2024 2036

1.32.3 Indirect Offsets The schedule for indirect offsets implementation will be developed in Q2 2021 and included in the next revision of this document.

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12. NEXT STEPS

The following section describes measures implemented in accordance with biodiversity offset component objectives E and F.

The offsets will be established in the planned locations and managed according to site-specific biodiversity offset management plans (BOMPs). The following BOMPs listed in Table 26 are being developed.

Table 26 – TAP BOMPs

Greece BOMPs Albania BOMPs

Trigonometriko - Gr 3 Maliq - Al 1

Kleftis - Gr 4 Polene - Al 2

Chloi - Gr 5 Shtylle - Al 3

Rema - Gr 6 Voskopoje - Al4

Myrtiski - Gr 7 Devoll - Al 5

Kokkinochori - Gr 8 Zogas - Al 6

Podochori - Gr 9 Veleshnje - Al 7

Paleochori Charavgis 1 - Gr 11 Buzuq Therepele - Al 8

Paleochori Charavgis 2 - Gr 12 Polican - Al 9

Paleochori Charavgis 3 - Gr 13 Ura- Vajgurore - Al 10

Metalliko - Gr 15 Berat - Al 11

Foufas - Gr 16

Variko - Gr 17

Sinoro - Gr 18

Lefki - Gr 19

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13. REFERENCES

The BOS is part of TAP’s overarching Environmental and Social Management System (ESMS) and as such interfaces with several other management plans. It should be read in conjunction with all the following documents.

Table 27 – Reference documents

Ref Document Number Document Title No.

1 CAL00-TAP-QHSE-Y-TMT-0001 Environmental and Social Management Manual

2 CAL00-PMT-601-Y-TTM-0007 Ecological Management Plan

3 CAL00-C5577-640-Y-TRB-0001 Critical Habitat Assessment

4 CAL00-PMT-601-Y-TTM-0002 Biorestoration Management Plan

5 CAL00-C5577-640-Y-TRS-0002 Supplementary Ecological Assessment

6 CAL00-PMT-601-Y-TTM-0009 TAP Linear Habitat Monitoring Plan

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14. APPENDIX 1 – EXAMPLE BOMP CONTENTS PAGE