Stakeholder Engagement Plan Bursa Integrated Health Campus Project
July 2016
BRS SAĞLIK YATIRIM A.Ş.
ELC GROUP A COMPANY OF ROYAL HASKONINGDHV
Rüzgarlıbahçe Mah. Çınar Sok. No:2 Address
Energy Plaza Kat:6 84805 Kavacık-Istanbul-Turkey
+90 (0)216 465 91 30 Telephone
+90 (0)216 465 91 39 Fax [email protected] E-mail www.elcgroup.com.tr Internet www.royalhaskoningdhv.com
Document title Bursa Integrated Health Campus (IHC) Project Stakeholder Engagement Plan Document short title Bursa IHC Project Stakeholder Engagement Plan Status Final Draft Report Date July 2016 Project name Bursa IHC Project Project number HA1056 Client BRS Sağlık Yatırım A.Ş.
This report has been prepared by ELC Group Consulting and Engineering Inc. with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between ELC Group Consulting and Engineering Inc. and the Client. This report is confidential to the client, and ELC Group Consulting and Engineering Inc. accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by ELC Group Consulting and Engineering Inc. beforehand. Any such party relies upon the report at their own risk.
ELC Group Consulting and Engineering Inc. disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services.
TABLE OF CONTENTS
1.0 INTRODUCTION ...... 1 1.1 Project Information ...... 1 1.2 Project Program ...... 4 2.0 NATIONAL REGULATORY REQUIREMENTS AND INTERNATIONAL PRACTICE ...... 5 3.0 STAKEHOLDER IDENTIFICATION ...... 7 3.1 Introduction ...... 7 3.2 Neighbouring Land Users ...... 7 3.3 Local Communities ...... 7 3.4 Hospitals ...... 8 3.5 Governmental Organizations ...... 8 3.6 Non-Governmental Organizations ...... 10 4.0 STAKEHOLDER ENGAGEMENT APPROACH ...... 13 5.0 STAKEHOLDER ENGAGEMENT ACTIVITIES UNDERTAKEN TO DATE ...... 14 6.0 STAKEHOLDER ENGAGEMENT ACTIVITIES DURING FINAL DRAFT ESIA DISCLOSURE ...... 20 7.0 STAKEHOLDER ENGAGEMENT ACTIVITIES DURING CONSTRUCTION AND OPERATION PHASES . 21 8.0 SCHEDULE FOR ESTABLISMENT OF THE PROJECT ...... 24 9.0 GRIEVANCE MECHANISM ...... 25 10.0 RESOURCES AND RESPONSIBILITIES ...... 28 11.0 REPORTING ...... 28
ANNEX A – Photographs from Public Consultation Meeting on 14.11.2015 ANNEX B – Comment/Complaint Form ANNEX C – Complaint Action Form
1.0 INTRODUCTION
This document presents the Stakeholder Engagement Plan (SEP) for the Bursa Integrated Health Campus Project (IHC or Project). The Project will be developed by BRS Sağlık Yatırım A.S. (BRS A.S.) who will be responsible for the design, construction, equipping and maintenance of the IHC within a project period of 28 years, under a Public Private Partnership Agreement with Ministry of Health (MoH). The IHC will involve a Main Hospital, a Physical Therapy and Rehabilitation Hospital and a High Security Forensic Psychiatric Hospital (FRH) with a total capacity of 1,355 beds.
The SEP is a public document, which presents plans for stakeholder engagement, consultation and disclosure, and is to be updated for each phase of the Project. The main goal of the SEP is to ensure that Project-affected people and other stakeholders are provided relevant, timely and accessible information so that they have an opportunity to express their views and concerns about the project and its impacts and mitigation measures. Stakeholder engagement process helps to: • identify and involve all potentially affected stakeholders including the vulnerable groups, • generate a good understanding of the Project amongst those that will be affected, • identify issues early in the project cycle that may pose a risk to the Project or its stakeholders, • ensure that mitigation measures are appropriate (implementable, effective, and efficient), • establish a system for long-term communication between the Project and communities that is of benefit to all parties.
This version of the SEP is related with the consultation activities of Environmental and Social Impact Assessment (ESIA) study prepared for the Project. SEP also summarizes consultation that has been undertaken during the preparation of the ESIA Report and briefly outlines engagement activities related to the construction and operation phases of the Project. SEP is being published at the same time as the Final Draft ESIA Report in order to provide an opportunity for people to comment on the plans related to engagement as well as on the Project. The SEP is the responsibility of BRS A.S. and BRS A.S. is fully committed to undertaking necessary engagement activities in a manner that is consistent with international good practice as outlined in next sections.
1.1 Project Information
The healthcare system in Turkey is being developed under the Health Transformation Program which was initiated in 2003. The purpose of this program is to increase the quality and efficiency of the healthcare system and enhance access to healthcare facilities with the introduction of a number of reforms. Within the scope of the Health Transformation Program, Ministry of Health (MoH) has planned to develop 31 Health Campuses of different sizes and bed capacities in 27 provinces to serve 29 health regions among Turkey, which were determined based on the need for health services, geographical structure, patient flow, accessibility and socioeconomic conditions. Until now, bidding process has been completed for 18 health campus projects and the other health campus projects are currently at different stages of planning. Bursa IHC Project is one of these 18 projects and has been proposed by MoH to serve the 19th health region that covers Bursa, Balikesir, Yalova and Canakkale provinces with a total population of 4,775,585 (Turkish Statistical Institute – TUIK, 2015). Among these four provinces, Bursa has been identified as the center of the 19th region considering the population density, the ease of road transport, presence of health manpower, conditions and service delivery capacity of the existing health facilities. Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 1 July 2016
A bid was tendered by MoH for the Construction Works and the Provision of Products and Services for Bursa Integrated Health Campus, and awarded to a joint venture whose pilot members built the current partnership structure in time and established a Special Purpose Vehicle (SPV) named BRS Sağlık Yatırım A.S. (BRS A.S.) which is comprised of Rönesans Holding A.S., Rönesans Sağlık Yatırım A.S., Sıla Danışmanlık Bilişim Sağlık İnşaat Ticaret A.S., ŞAM Yapı Sanayi ve Ticaret Ltd. Şti. and TTT Sağlık Hizmetleri Eğitim İnşaat Sanayi Ticaret A.S. Meridiam Eastern Europe Sarl received approval from MoH in 27.04.2015 for joining the SPV and will officially join the SPV before Financial Close. The Project’s agreement has been signed between MoH and BRS A.S. on 19 June 2015.
Under the terms of the agreement with MoH, BRS A.S. will be responsible for the detailed design, construction, equipping, financing, maintenance and operation of the IHC for a 28-year project period (covering a construction period of 3 years and operation period of 25 years), while the provision of medical services will be the responsibility of MoH. At the end of the project period, IHC will be transferred to MoH.
The Project is located in Dogankoy neighborhood within Nilufer district of Bursa province. The Project location is shown in Figure 1-1.
Figure 1-1: Project location (red shahed area and red lines indicate the boundaries of the Project site)
The Project comprises of the development of an Integrated Health Campus with a total capacity of 1,355 beds consisting of three hospitals. These are the 1,055-bed Main Hospital, 200-bed Physical Therapy and Rehabilitation Hospital and 100-bed High Security Forensic Psychiatric Hospital. Main hospital will include: • 275-bed General Hospital • 275-bed Cardiovascular Diseases Hospital • 252-bed Oncology Hospital • 253-bed Women and Pediatric, General and Psychiatric Hospital Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 2 July 2016
Main Hospital will consist of four patient tower blocks surrounding a common core and will have eight floors, two entrance levels (higher and lower entrance) and three basement floors. In addition to the hospitals, there will be a helipad, a technical service building and a trigeneration system building. The layout of the hospitals is shown in Figure 1-2.
Figure 1-2: Layout of the hospitals and other units within the IHC (the junction on the Bursa Ring Road and the junction at the southeast boundary of the Project site are not part of the Project and were previously planned by the General Directorate of Highways and Bursa Metropolitan Municipality, respectively) Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 3 July 2016
1.2 Project Program
BRS A.S. is planning to approach multinational financial institutions (FIs) to fund the development of the Project. One of the requirements of these FIs for granting loans is the preparation of an ESIA Report for identifying potential environmental and social impacts and risks of the Project and developing mitigation measures appropriate to the nature and scale of the Project. An ESIA Report has been prepared to comply with the requirements of International Finance Corporation’s (IFC) Performance Standards (PSs) on Social and Environmental Sustainability (dated January 2012), European Bank for Reconstruction and Development’s (EBRD) Performance Requirements (PRs) (dated May 2008) for key areas of environmental and social issues and European Investment Bank’s (EIB) Environmental and Social Standards (ESSs) (dated December 2013). In addition to the IFC PSs, EBRD PRs and EIB ESSs; IFC Environmental, Health and Safety (EHS) General Guidelines, IFC EHS Guidelines for Healthcare Facilities, EBRD Sub-sectoral Environmental and Social Guidelines for Health Services and Clinical Waste Disposal and other relevant international guidelines were taken into account during the ESIA process.
The ESIA Report is accompanied by an Environmental and Social Management Plan that identifies how significant impacts will be mitigated, managed and monitored during the construction and operation phases of the Project. The ESIA process for the Project started in September 2015 and is planned to be completed in the third quarter of 2016. The planning of the Project is still ongoing. The construction schedule on which the ESIA study is based on is given in Table 1-1, it assumes a 36 months of construction period following the occurrence of the Site Delivery Date as defined in the Project Agreement. Since then the Contractor of BRS A.S. has already started pre-construction works (i.e. site preparation, mobilization and earthworks) and the construction is now planned to be completed in 30 months from the Site Delivery Date which is expected to occur in third quarter of 2016.
Table 1-1: Tentative Construction Schedule
1st year 2nd year 3rd year 4th year
Works to be undertaken quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter
st st st st th th th th rd rd rd rd nd nd nd nd 1 1 1 1 4 4 4 4 3 3 3 3 2 2 2 2
Contractual Processes Design Processes Mobilization Earth & Infrastructural Works (North) Earth & Infrastructural Works (South) Structural Works External Site Works (Landscaping) Mechanical & Electrical Works Automation & Furnishing
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 4 July 2016
1st year 2nd year 3rd year 4th year
Works to be undertaken quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter quarter
st st st st th th th th rd rd rd rd nd nd nd nd 1 1 1 1 4 4 4 4 3 3 3 3 2 2 2 2
Testing & Commissioning
2.0 NATIONAL REGULATORY REQUIREMENTS AND INTERNATIONAL PRACTICE
Turkish Environmental Impact Assessment (EIA) Regulation (Official Gazette date and number: 25.11.2014/29186) includes provisions for public consultation and disclosure of project information for projects listed in Annex-1 of the regulation. However, hospital projects do not fall within scope of the Turkish EIA Regulation. This is also verified in the official letter obtained from Bursa Provincial Directorate of Environment and Urbanization (PDEU) dated 16.04.2015. In terms of EU EIA Directive, the Project would have been covered by Annex II of the EIA Directive with respect to urban development, if it were located within the EU. In order to ensure that the Project meets environmental and social standards as mentioned above, an ESIA study is being conducted.
Apart from the main hospital components previously discussed, there will be a trigeneration plant, boilers and concrete batching plant to be used as auxiliary facilities within the scope of the Project. The capacity of the concrete plant (90 m3/h) is lower than the 100 m3/h threshold that would have triggered the EIA Regulation requirements (i.e. Annex-2 of the EIA Regulation). For this reason, concrete plant will be exempt from the requirements of the Turkish EIA Regulation. This is also confirmed with an official letter (dated 11.01.2016) issued by Bursa PDEU to Bursa Beton Santrali San. Tic. A.S. which will be operating the concrete batching plant during the construction of the Project. The trigeneration system and the boilers will be subject to EIA Regulation requirements according to the 20 MW threshold mentioned in Annex-2 of the EIA Regulation, for which stakeholder engagement is not required.
As BRS A.S. is planning to approach international financial institutions for the development of the Project, the Project needs to comply with the requirements of IFC PS 1, EBRD Environmental and Social Policy, EBRD PR 10 and EIB ESS10. IFC, EBRD and EIB are committed to stakeholder engagement that is free of manipulation, interference, coercion, and intimidation, and conducted on the basis of timely, relevant, understandable and accessible information, in a culturally appropriate format.
IFC PS1 (Assessment and Management of Environmental and Social Risks and Impacts), EBRD PR10 (Information Disclosure and Stakeholder Engagement) and EIB ESS10 (Stakeholder Engagement) describe stakeholder engagement as an on-going process and in summary require the following: (i) identification of stakeholders that are or could be affected by the project, as well as other parties that may have an interest in the project (affected people, communities, businesses and relevant governmental bodies, general public), (ii) ensuring that such stakeholders are appropriately engaged on environmental and social issues that could potentially affect them through a process of information disclosure and meaningful consultation, (iii) maintain a constructive relationship with stakeholders on an ongoing basis through meaningful engagement during project implementation.
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 5 July 2016
In summary, stakeholder engagement should start at an early stage of the ESIA process and continue during project implementation. A grievance mechanism needs to be established as well to facilitate resolution of stakeholder’s concerns and grievances about the client’s environmental and social performance. According to best practice and the EBRD/IFC/EIB requirements, BRS A.S. is now offering consultation opportunities for stakeholders as described in the following sections.
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 6 July 2016
3.0 STAKEHOLDER IDENTIFICATION
3.1 Introduction
For the purposes of this plan, a stakeholder is defined as any individual, organization or group who is potentially affected by the Project or who has an interest in the Project and its impacts. The purpose of stakeholder identification is to identify and prioritize project stakeholders for consultation who may be affected (either directly or indirectly in positive or negative way) by the Project or who have an interest in the Project but are not necessarily directly impacted by the Project. It is important to note that stakeholder identification is an ongoing process, and thus stakeholders will continue to be identified during different stages of the Project.
The key primary stakeholder group will be the local communities around the Project site including neighboring land users (particularly related to impacts during construction) and the general public. Other important stakeholders include authorities at national, regional and district level, and non- governmental organizations (NGOs). A number of different stakeholders (as outlined in sections 3.2 to 3.6) have been identified for the Project with responsibilities and interests relevant to the Project and its impacts. A stakeholder database has been established including the name of the representatives and contact details of each stakeholder identified. This database will be reviewed and updated as the project proceeds.
3.2 Neighbouring Land Users
The closest settlement to the northern part of the Project site (i.e. in Balat neighborhood) is to the east at 1.5 km distance. The closest settlements to the southern part of the Project site include residential areas at a distance of 50 m, Dogankoy Neighbourhood at a distance of 1.5 km and some individual houses located in between the residential area and Dogankoy Neighbourhood. In addition, there is a private land located adjacent to the northern part of the Project site which is being partially cultivated. As reported, the private land has 11 owners. In addition to the above, the following facilities are identified in the immediate vicinity of the Project site: • Cemetary (eastern boundary of the southern part of the Project site) • Warehouses (east and south of the southern part of the Project site) • Dogankoy Primary School (in central Dogankoy at an approximate distance of 1.5 km to the Project site) • Plastic/glass greenhouses (300 – 600 m to the southern part of the Project site) • Ceremony hall (600 m to the southern part of the Project site) • Football ground (600 m to the southern part of the Project site)
These are considered as important stakeholders particularly related to impacts during construction phase such as noise and air quality impacts, potential traffic increase during construction and operation phases and security of High-Security Forensic Psychiatric Hospital during operation.
3.3 Local Communities
Neighbourhoods around the Project site and at a wider distance (approximately within 10 km diameter considering the potential for traffic impacts to be felt up to this distance) were considered that include
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 7 July 2016
a total of 49 neighborhoods under the jurisdiction of Nilufer, Mudanya and Osmangazi Districts. These neighborhoods are as follows: Bademli, Haskoy, Mursel and Dedekoy within the administrative borders of Mudanya district; Gorukle, Yolcati, Dogankoy, Balat, Ahmetyesevi, Ozluce, 19 Mayis, Yuzuncuyil, Mineralicavus, Altinsehir, 29 Ekim, Ertugrul, Fethiye, Isiktepe, 23 Nisan, Ataevler, Cumhuriyet, Baris, Esentepe, Ihsaniye, Karaman, Odunluk, Camlica, Konak, Kultur, Besevler, Ucevler, Alaaddinbey, Urunlu and Yaylacik within Nilufer district; Sogukkuyu, Istiklal, Hurriyet, Adalet, Yenikaraman, Baglarbasi, Hamitler, Akpinar, Yenibaglar, Emek Adnan Menderes, Emek Zekai Gumusdis, Emek Fatih Sultan Mehmet, Gecit, Niluferkoy and Yenikent within Osmangazi district.
3.4 Hospitals
In Bursa, there are currently 17 public hospitals (11 State Hospitals - 2 in central Bursa and 9 in other districts-, 1 Higher Education and Research Hospital, 1 Oncology Hospital, 1 Chest Diseases Hospital, 1 Oral and Dental Hospital, 1 Pediatric Hospital and 1 Spastic Children Hospital) that are affiliated with MoH as well as 3 Integrated District Hospitals (in Harmancık, Buyukorhan and Keles Districts), 1 Military Hospital, 19 private hospitals and Uludag University Faculty of Medical Sciences Hospital. Moreover, there are 3 Oral and Dental Health Centers, 26 Medical Centers, 12 private dialysis centers, 13 polyclinics, 9 in-vitro fertilization centers and 3 genetic diagnosis centers in Bursa province.
Consultation was conducted with Bursa Provincial Directorate of Health as part of the ESIA consultation process in order to understand the current planning for the potential closure of existing hospitals. Based on this consultation, it is understood that there is a need for hospitals in Bursa province and accordingly, there are currently no plans for closing any hospitals. Although plans were previously made for Bursa province to close and/or move some of the hospitals either in full or partly and/or to make alterations in the existing hospitals, this might not fully be the case for the current conditions and can only be clear with additional planning considering the current need for health services.
3.5 Governmental Organizations
Governmental organizations can be grouped as national, regional, provincial, district and neighbourhood/village levels. These organizations include authorities with statutory responsibilities relevant to the Project or to environmental or social issues, and other bodies responsible for providing infrastructure relevant to the Project. A list of governmental agencies relevant to the Project is prepared as given below:
GOVERNMENTAL BODIES Level Organization Relation to the Project Ministry of Health (MoH), General Directorate of Health Investments MoH, General Directorate of Management Services The Project has been proposed by MoH, Public Hospitals Institution MoH. MoH will be responsible for the MoH, General Directorate of Health Services provision of medical services during operation phase of the Project. National MoH, General Directorate of Emergency Health Services MoH, Public Health Agency of Turkey Ministry of Environment and Urban Planning (MEUP), General MEUP has regulatory functions in Directorate of EIA, Permit and Audit relation to the Project such as MEUP, General Directorate of Environmental Management environmental impact assessment MEUP, General Directorate of Spatial Planning permits and environmental permitting. MEUP, General Directorate of Protection of Natural Assets Ministry of Forestry and Water Affairs (MoWA), General Directorate of These organizations may have specific State Hydraulics Works (DSI) views on protected sites, lakes and National MoWA, General Directorate for Nature Protection and National Parks dams close to the Project site.
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 8 July 2016
GOVERNMENTAL BODIES Level Organization Relation to the Project Ministry of Labor and Social Security (MoLSS), General Directorate of MoLSS may have specific views on labor Labor and working conditions, and health and MoLSS, General Directorate of Occupational Health and Safety safety of healthcare personnel. MoLSS, Social Security Institution This organization may have specific 1st Regional Directorate of DSI ( State Hydraulic Works) views about water courses running close to the Project area. This organization may have specific views on the protected areas close to 2nd Regional Directorate of Ministry of Forestry and Water Affairs (MFWA) the Project area and the status of the trees in the Project Area. Opinion may be provided related to the Regional Bursa Regional Directorate of Labor and Social Security regional healthcare workforce. The organization may provide opinion 14th Regional Directorate of General Directorate of Highways regarding roads and highways related to Project area. This organization is an important stakeholder to identify and clarify the Bursa Regional Board Directorate of Cultural Assets Protection archaeological potential of the Project site. The governorship representing the The Governorship of Bursa national government is the highest authority in the province. Bursa Metropolitan Municipality (BMM) BMM, Directorate of Environmental Protection and Control, Waste Management Branch BMM, Directorate of Environmental Protection and Control, The metropolitan municipality and its Environmental Control Branch relevant departments will have BMM, Directorate of City Planning and Development responsibilities in relation to the BMM, Directorate of Transportation, Transportation Coordination Project. Branch BMM, Directorate of Transportation, Rail Systems Branch BMM, Directorate of Transportation, Infrastructure Coordination Branch Bursa Governorship Provincial Directorate of Health These organizations are involved in the Bursa Governorship Provincial Directorate of Public Health provision of health services and Bursa Province General Secretariat of Public Hospitals healthcare workforce in the province. Bursa Provincial Directorate of Social Security Institution PDEUP has regulatory functions related to the Project such as environmental Bursa Provincial Directorate of Environment and Urbanization (PDEUP) Provincial impact assessment permits and environmental permitting. This organization may provide specific 2nd Regional Directorate of MFWA Bursa Branch Directorate opinion on the landuse and status of trees within the Project area. This organization may provide Bursa Provincial Directorate of Food, Agriculture and Livestock provincial-specific and/or site-specific views on the Project. This organization will provide security Bursa Provincial Command of Gendarmerie services to High Security Forensic Psychiatric Hospital This organization has a function to manage and respond to emergency Bursa Disaster and Emergency Management Directorate situations.
This organization may provide an opinion related to archaeological Bursa Provincial Directorate of Culture and Tourism potential of the Project site.
The Local Governorship of Buyukorhan, The Municipality of Buyukorhan The project site is located in Nilufer District The Local Governorship of Gemlik, The Municipality of Gemlik district and the local governorship, the The Local Governorship of Gursu, The Municipality of Gursu central municipality and their related
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 9 July 2016
GOVERNMENTAL BODIES Level Organization Relation to the Project The Local Governorship of Harmancik, The Municipality of Harmancik departments are stakeholders The Local Governorship of Inegol, The Municipality of Inegol regarding obtaining relevant permits, The Local Governorship of Iznik, The Municipality of Iznik approvals during planning, construction The Local Governorship of Karacabey, The Municipality of Karacabey and operation phases of the Project. The Local Governorship of Keles, The Municipality of Keles The other local governorships and The Local Governorship of Kestel, The Municipality of Kestel municipalities are also related to the The Local Governorship of Mudanya, The Municipality of Mudanya Project as the Project will cover several The Local Governorship of Mustafakemalpasa, The Municipality of hospitals which are also important for Mustafakemalpasa the other districts. The Local Governorship of Nilufer, The Municipality of Nilufer The Local Governorship of Nilufer, Disaster and Emergency Management Center The Municipality of Nilufer, Transportation Services Branch The Municipality of Nilufer, City Planning and Development Branch The Municipality of Nilufer, Environmental Protection and Control Branch The Local Governorship of Orhaneli, The Municipality of Orhaneli The Local Governorship of Orhangazi, The Municipality of Orhangazi The Local Governorship of Osmangazi, The Municipality of Osmangazi The Local Governorship of Yenisehir, The Municipality of Yenisehir The Local Governorship of Yildirim, The Municipality of Yildirim Bursa Water and Sewer Association (BUSKI)
3.6 Non-Governmental Organizations
A list of key NGOs (including women associations and public education centers) that may have an interest in environmental and social aspects of the Project is also prepared as given below:
NON-GOVERNMENTAL BODIES Level Organization Relation to the Project Turkish Medical Association has previously filed a lawsuit for other three hospitals that are planned to be built through a PPP model and towards Turkish Medical Association the PPP model in general. It is important to engage with this association to understand their concerns. Trade Union of Public Employees in Health and Social Services These associations together with Trade Union of Revolutionary Health Workers Turkish Medical Association has
Association of All Technicians of Radiology published a notice on negative aspects National Turkish Nurses Association of PPPs. Turkey Trade Union of Health Workers Trade Union of Employees of Health and Social Services Trade Union of All Employees of Health and Social Services Trade Union of Health and Social Service Employees Rights Trade Union of Turkish Public Employees in Health and Social Service Trade unions are important Branch stakeholders representing the labor
Trade Union of Anatolian Health and Social Service Employees rights of health sector personnel. Trade Union of Active Health Independent Trade Union of Public Workers in Health and Social Services Trade Union of Democratic Employees of Health and Social Services United Trade Union of Public Workers in Health and Social Services
Turkish Red Crescent These associations are social Pediatric Nurse Association organizations working on different Oncologic Nurse Association aspects of healthcare sector and may Urology Nurse Association provide important opinion on their Obstetricians and Nurses Association areas of specialization. Turkish Intensive Care Nurses Association Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 10 July 2016
NON-GOVERNMENTAL BODIES Level Organization Relation to the Project Doctors’ Rights Association Doctors Association Psychiatric Association of Turkey Turkish Society of Anesthesiology and Reanimation National Association of Health Employees The Health Foundation of Turkey Health Tourism Association of Turkey Turkey National Pediatric Association Turkish Pediatric Association Turkish Association for Supporting Public Hospitals and Patients Turkey Confederation of Disabled Requesting opinion of these associations is important to understand Turkey Handicapped Association their expectations. Turkish Medical Association Bursa Chamber of Medicine Turkish Red Crescent – Bursa Branch Trade Union of Employees of Health and Social Services - Bursa Branch Turkey Trade Union of Health Workers Bursa Branch Trade Union of Public Employees in Health and Social Services Bursa Branch United Trade Union of Public Workers in Health and Social Services Bursa These organizations are representatives Branch of their national organizations and may Trade Union of Turkish Public Employees in Health and Social Service provide specific opinion regarding Branch - Bursa Branch different issues within the province.
Turkey National Pediatric Association Bursa Branch Turkey Handicapped Association Bursa Branch Turkish Society of Anesthesiology and Reanimation - Marmara Branch Turkish Pediatric Association Bursa Branch Turkish Association for Supporting Public Hospitals and Patients – Bursa Branch Bursa Health Sector Employees Association Global Medical Doctors Bursa Health Association Turkish Association for Nurses - Bursa Branch Turkish Association for Psychologists - Bursa Branch Turkish Psychological Counseling Association - Bursa Branch Provincial Turkish Psychiatry Association - Bursa Branch Bursa Family Practitioners Association
Bursa Private Health Institutions Association Bursa Association for Health Tourism Bursa Chamber of Pharmacists Bursa Kidney Foundation Bursa Association for Fighting Tuberculosis Requesting opinion of these health
Bursa Association for Multipl Skleroz associations is important to understand Bursa Down Syndrome Solidarity Association their views and expectations. Uludag Oncology Solidarity Association Bursa Association for Fighting Cancer Child Infectious Diseases Association
Pediatric Clinic Protecting and Improving Child Health Association Solidarity Association for Protecting the Rights of Patients and Relatives Bursa Association for Solidarity with Physically and Mentally Disabled People Association for Education Culture and Solidarity for Mentally Disabled
Solidarity Association for Schizophrenia and Similar Disorders Six Dots Association for Blind - Bursa Branch Solidarity Association for Physically Disabled Chamber of Environmental Engineers Bursa Branch Chamber of Forests Engineers Bursa Branch These chambers may provide Chamber of City Planners Bursa Branch provincial-specific and or site-specific Chamber of Civil Engineers Bursa Branch views related to the Project. Chamber of Architects Bursa Branch Chamber of Geophysics Engineers Bursa Branch
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 11 July 2016
NON-GOVERNMENTAL BODIES Level Organization Relation to the Project Chamber of Geology Engineers Bursa Branch Bursa Occupational Health and Safety Association Turkey Association for Agriculturists - Bursa Branch Association for Protecting Nature and Environment and Nature Sports Marmara Environment Association International Environment Association
Equal Rights Association Provincial Bursa City Council Requesting opinion of these Nilufer City Council associations is important to understand Bursa Public Employees Association their views and expectations. Bursa Association for Muhtars Bursa Nilufer Muhtars Association Muhtars Union Association - Bursa Branch Nilufer Muhtars Association Turkish Muhtars Association - Bursa Branch Turkish Muhtars Association - Nilufer Branch All Active Businessmen and Businesswomen Associations Federation
Women's Associations and Public Education Centers Level Organization Relation to the Project Bursa Solidarity Association for Craftswomen Bursa International Women Association Bursa Productive Women Association Active Women Culture and Communication Association Women Associations Federation Women Economy Platform Association Association for Improving Women Entrepreneurs Turkish Women Unions Association - Bursa Branch Turkish Women Council Association - Bursa Branch Turkish Women Culture Association - Bursa Branch Women's Turkish Association for University Graduate Women - Bursa Branch Associations Supporting and Educating the Women Candidates Association - Bursa Branch Koza Women Association Republican Women Association - Bursa Branch Women tend to attend sick family Republican Women Association - Nilufer Branch members to visit a hospital and their Disabled Women Association views on the IHC are important. International Business World Development, Women and Disabled Association Nilufer Women Solidarity and Culture Association Nilufer Women Entrepreneur Solidarity Association Bursa Gemlik Public Education Center Bursa Harmancik Public Education Center Bursa Iznik Halk Public Education Center Bursa Karacabey Public Education Center Public Bursa Keles Public Education Center Education Bursa Kestel Public Education Center Centers Bursa Mustafakemalpasa Public Education Center Bursa Nilufer Public Education Center Bursa Orhaneli Public Education Center Bursa Yenisehir Public Education Center
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 12 July 2016
4.0 STAKEHOLDER ENGAGEMENT APPROACH
This section provides an overview of the stakeholder engagement approach for different phases of the Project as described below: • Phase 1: ESIA Study Consultations (current phase) • Phase 2: Final Draft ESIA Disclosure (near future consultations) • Phase 3: Construction (future consultations) • Phase 4: Operation (future consultations)
Phase 1 is ongoing and the existing results of stakeholder engagement activities in this phase are explained in Section 5. Engagement activities for Phase 2 and Phase 3/Phase 4 are provided in Section 6 and Section 7, respectively.
BRS A.S. has used/will use different consultation approaches and methods for different phases of the Project activities and for different stakeholder groups. The main communication methods and mechanisms that have been and/or will be used to consult with key stakeholders in each phase are summarized in Table 4-1. Table 4-1: Project phases and proposed engagement approach Project Phase Engagement Approach Phase 1: ESIA • Face-to-face meetings with selected governmental authorities Study • Face-to-face meetings with muhtars of the surrounding neighborhoods and with the deputy principal of Consultations Dogankoy Primary School • Face-to-face meetings with the surrounding facilities, if needed • Sending out Project Information Documents to selected governmental and non-governmental organizations • Sending out Project Information Document and Project Information Leaflet to selected neighborhoods • Newspaper advertisements • Handouts distributed to public to inform them about public consultation meeting • Phone calls to muhtars of selected neighborhoods to inform them about the Project and invite them to the public consultation meeting • Phone calls to the land owners of the private land adjacent to the Project site to get their views regarding the Project • Public consultation meeting • Using an email address to collect views • Disclosure of information in the Project website • Setting up a Grievance Mechanism
Phase 2: Final • Disclosure of Final Draft ESIA Report, ESMP, ESAP and SEP in the Project website Draft ESIA • Distribution of hard copies of Non-Technical Summary of the Final Draft ESIA Report to district heads of Disclosure Bursa • Newspaper announcements • Public consultation meeting (including a dedicated slot for women) • Reaching out to women in Dogankoy Neighbourhood through Dogankoy School Principal • Phone calls to muhtars of selected neighborhoods to invite them to the public consultation meeting • Consultation with landowners who own the land adjacent to the northern part of the Project site • Face-to-face meetings with officials of the schools in the vicinity of the Project site • Engagement with vulnerable groups, if any, through relevant muhtars • Information disclosure to vulnerable groups, if any, through muhtars
Phase 3: • Project website to disclose Project information and Project updates Construction • Newspaper announcements, if needed • Face-to-face meetings with adjacent private land owners during construction as needed Phase 4: • On-going communications with relevant regulatory stakeholders and public, as necessary Operation • Implementation of a Grievance Mechanism • Operation of a call center during operation
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 13 July 2016
5.0 STAKEHOLDER ENGAGEMENT ACTIVITIES UNDERTAKEN TO DATE
Stakeholder engagement activities for the Project have started during the scoping stage of the ESIA study and continued during the preparation of the ESIA report. A Project Information Document and Project Information Leaflet was produced in English and Turkish and were sent to identified stakeholders (as provided in Section 3) as explained below: • Identified governmental authorities (a total number of 77) and NGOs (a total number of 121) were sent a Project Information Document together with a cover letter and asked to comment on the Project, its potential impacts and to provide information that may be important for the ESIA study. The letters were sent as certified mail with return receipt requested to ensure that all the letters were delivered. • A project information pack (including 5 Project Information Documents, 25 Project Information Leaflets and 25 Comment/Complaint Form) were sent together with a cover letter to muhtars of 49 neighborhoods (including surrounding neighborhoods and neighborhoods at a wider distance within approximately 10 km) to provide information on the planned Project and related impacts, ongoing environmental and social impact assessment and to provide opportunity to express views and concerns about the Project, and to inform how views/concerns can be submitted. The letters were sent as certified mail with return receipt requested to ensure that all the letters were delivered. Prior to sending the information, the muhtars were contacted by phone to inform them about the aim of the project information pack and they were requested to distribute the leaflets in their neighborhoods. • A Public Consultation Meeting was held on 25th November 2015 in Dogankoy Neighborhood, Nilufer District. Approximately 50 people attended the meeting. The meeting was announced via advertisements in one national and one local newspaper eleven days in advance on 14th November 2015 and the advertisement was repeated at the same newspapers a week later on 21st November 2015. The meeting was also announced through handouts distributed to local people. The meeting was opened by the General Director of Ronesans Saglik Yatirim A.S. (RSY) followed by the presentation of the ESIA team. Five representatives from BRS A.S. and three representatives of the ESIA team were available during the meeting. Photographs from the public consultation meeting are presented in Annex A. • The owners of the land adjacent to the Project site are contacted through phone call interviews in June 2016 in order to inform them about the Project, get an understanding of their agricultural activities (e.g. cultivation pattern, cultivated crops, ease of access to the land etc.) and get their views regarding the Project activities. Within this context, two landowners and one tenant were interviewed. • In order to collect opinion letters via email, [email protected] was/is being used. • A Project specific website (www.pppbursahastanesi.com) was established where the Project Information Document and Comment/Complaint Form are made available to the public.
In addition to the abovementioned consultation activities, face-to-face meetings were held with the following governmental authorities: • Bursa Provincial Directorate of Health • BMM, Transportation Coordination Branch • BMM, Environmental Protection Directorate • Nilufer Municipality, City Planning and Development Branch Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 14 July 2016
Furthermore, a social survey was conducted in 10 neighborhoods which were selected based on the distance of the neighborhood to the Project site and the population density of the neighborhood. The survey was conducted with the muhtars of selected neighborhoods between 17th-19th November 2015. The selected neighborhoods are as follows: • All neighborhoods that are up to 2 km distance to the Project site. These neighborhoods are Dogankoy, Bademli and Balat. • Neighborhoods that are 2 - 5 km away from the Project site. The selected neighborhoods are Ozluce, Ahmetyesevi, Altinsehir and Yolcati. • Neighborhoods that are 5 - 10 km away from the Project site. The selected neighborhoods are Gorukle, Besevler and Cumhuriyet.
The key issues that were raised during the face-to-face meetings with governmental authorities, muhtars and Dogankoy Primary School, outcomes of the phone call interviews with the landowners of the adjacent land and key issues that were mentioned in the official response letters and during the public consultation meeting are presented below.
Face-to-face meetings with governmental authorities • Alternative sites considered for the Project location • The current and planned transport systems in Bursa province including the road networks and public transportation routes • Planning related to hospital closures • Necessary permits for disposal of excavated materials and construction wastes • Capacity of BMM to handle wastewater and wastes • The zoning plans for the region
Face-to-face meetings with muhtars • Location of the health campus, project site alternatives • Timing of the construction activities of the Project • Positive impacts including job opportunities and access to high quality health services • Closure of existing hospitals • Need for additional facilities such as accommodation for the patients’ relatives and commercial facilities • Baseline socio-economic conditions of the neighborhoods
Face-to-face meeting with Dogankoy Primary School • The means of transportation for students while accessing the school (i.e. most of the students access the school on foot) and possible interference of the IHC development, particularly during construction with the movement of construction vehicles through central Dogankoy. • The noise that will potentially be created during construction of the IHC in particular as a result of the movement of construction vehicles. • Suggestions on taking the necessary security measures around the Project site during construction so that the students are kept away from the construction area.
Phone call interviews with the landowners of the adjacent land
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 15 July 2016
Landowners • The total area of the private land is approximately 50-55 hectares. • The land is currently being cultivated and cultivation did not stop due to Project activities. • Part of the land (i.e. 17,700 m2) is owned by a number of people (as reported, 6 people in total) from one family (to be referred to as family below). The remaining of the land is owned by other three people. • After the Project activities started, the land is accessed through the main entrance of the Project site. Landowners are accompanied by the security staff until they enter their land. • There were no problems during the entrance and exit of the equipment that are used in the land. • There were no grievances to date related to Project activities. • . • It was reported that there is one tenant cultivating the land of one of the owners apart from the family (i.e. phone call interview was made with this tenant and information is provided below). It was further indicated that there might be another person cultivating the land of one other owner, however this is not clear.
Tenant • After the Project activities started, the land is accessed through the main entrance of the Project site. The tenant is accompanied by the security staff until he enters the land. It was indicated by the tenant that there were cases when he needed to wait at the main entrance for approval to enter the site. Apart from the entrance to the land takes longer compared to the past, there are no changes related to the Project activities. • There were no grievances to date related to Project activities. It was indicated that although the Project activities are close to the land, the agricultural activities were not affected. As the tenant reported, the other owners also do not have any grievances. • It was indicated by the tenant that the land is visited and cultivated by two members of the family (i.e. information obtained from these two members are summarized above under landowners) and himself, and there are no other people visiting and cultivating the site frequently.
Based on information given above, the private land is currently being visited and cultivated by three people. The contact information of these people is known by a staff at the Project construction site. There is no other contact information that the Project construction site holds which can confirm that the land is being used by the three people who have provided the information given above.
Response letters from governmental authorities • Environmental and occupational health and safety related issues to be considered during the construction and operation of the Project. • Compliance with relevant environmental regulations and obtaining necessary permits during construction and operation phases. • Importance of adequate public transportation connections from the city center to the IHC site.
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 16 July 2016
• Need for considering the setback distances as stated in the Regulation on the Facilities to be constructed and opened near Motorway while planning the Project • Need for placement of traffic warning signs as necessary • Need for getting the opinion of 14th Regional Directorate of Highways as necessary • Importance of conducting an EIA study for such large-scale hospitals in Turkey in the sense that EIA is a planning phase that discusses the environmental and social impacts of the Project together with relevant mitigation measures. • Suggestions on mitigation measures for environmental and social impacts. • Waste management and disposal practices supported by examples from other hospitals in the region. • Need for discussing transportation related issues such as, how the transportation demand to the IHC site will be satisfied and the provision of necessary car parking areas within the IHC site. • Location of the health campus as well as alternative Project sites. • Opinion about the Project site that the Project site is not a part of any protected area and no wetland is present within the boundaries of the Project site • Need for taking necessary precautions against the pollution of surface and groundwater sources as a result of any solid or liquid waste discharge and disposing all the wastes in accordance with the relevant regulations.
Response letters from Non-Governmental organizations • Critical comments regarding the Public Private Partnership model and its implementation. Several aspects of the model are identified as problematic including finance management, site selection, access to site, hospital closures and the condition of medical and support services within closed hospitals • Various recommendations as to how the health investments in Bursa should be carried out together with questions regarding the tendering process and tendering agreement such as, rental cost of the site and how and for how long it will be paid, number of staff to be employed, the guarantees (such as bed occupancy guarantee) given by the Ministry or other public institutions to the company winning the tender, presence of a plan to construct hotels or other accommodation facilities within the IHC and close vicinity, the number of patients/people expected to visit the IHC, routes of access to the site, operation of the parking areas, presence of a plan to construct commercial areas within the IHC, availability of a contingency plan in case the IHC goes bankrupt and the impact of bankruptcy on the employees, financing of the Project, the date when the IHC will become operational, the companies involved in the tendering process, plans for the agricultural/sunflower field adjacent to the Project site, plans for existing hospitals, plans for the buildings and land areas of the hospitals to be closed, presence of a plan for bringing doctors from out of town, the amount of greenhouse gases to be generated, the liabilities of the contractor in terms of construction and furnishing/equipping the hospital, the responsible bodies auditing the operations of the Company, etc. • Critical comments on the process of changing the zoning plans of the region to include the health campus area by stating the need for reflecting the results of scientific studies into the zoning plans during site selection
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 17 July 2016
• Critical comments regarding the designation of a forest area for the development of the Project • Information on the ongoing lawsuit for the cancellation of the zoning plans (based on the official letter (dated 23.05.2016) issued by the Legal Department of MoH to Health Investments General Directorate of MoH, the lawsuit has been cancelled by the Bursa 1st Administrative Court (cancellation decision date: 15.04.2016, decision no: 2016/437)). • Criticization of the Project in terms of its public benefit • Importance of the Bursa IHC for transfering blood to the hospitals with its centeralized position within the health region comprising not only Bursa province but also Yalova, Balikesir and Canakkale provinces • Importance of EIA studies and site selection process • Importance of conducting EIA studies for energy generation systems (i.e. trigeneration system using natural gas) within the scope of the Project • Importance of stakeholder engagement and public participation during the decision-making process is emphasized. • Several questions were raised regarding (i) safe and easy access to the site by the pedestrians and by using public transportation, (ii) road network around the Project site and (iii) ease of access to the social services (e.g. restaurants, pharmacies) from the Project site
Feedback Forms from Public (collected during the Public Consultation Meeting and from the muhtars) • Difficulty of access to the Project site by public transportation (considering the current situation) • Importance of arranging the appointments online through Central Medical Appointment System • Potential negative effects of the Project for the environment of the region, particularly on Dogankoy pasture land • Conditions of the roads in Dogankoy and potential negative effects of the construction activities of the IHC on the roads together with the need for fixing the roads damaged by the construction vehicles • Need for the construction of a new mosque in Dogankoy after the IHC is in operation
Public consultation meeting • Positive view of the local people from Dogankoy • Negative views on not undertaking a Turkish EIA Study (it should be noted that this is not under the control of BRS A.S. As explained previously, hospital projects are out of the scope of the Turkish EIA Regulation and this was confirmed by Bursa PDEU upon the application of Bursa Provincial Directorate of Health to Bursa PDEU for the evaluation of the Project as per Turkish EIA Regulation. Instead, BRS A.S. has undertaken this ESIA study)The ongoing lawsuit regarding suspension of execution and cancellation of the zoning plans in relation to the Project site • Difficulties for accessing the site (considering the current situation) • Criticism of the site selection process and its inconsistency with the urban planning principles • Comments on construction works and possible nuisance to be created during construction phase • Contract value and bidding process
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 18 July 2016
• Bed occupancy limit guarantee given by the government • Road developments around the Project site
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 19 July 2016
6.0 STAKEHOLDER ENGAGEMENT ACTIVITIES DURING FINAL DRAFT ESIA DISCLOSURE
The disclosure period for the Final Draft ESIA Report is expected to start in late July 2016 for a period of 30 days. The objective of the disclosure period is to inform the stakeholders about the Project activities, impacts, proposed mitigation measures and monitoring.
The following Project documents will be disclosed in English and Turkish languages in the Project website (http://pppbursahastanesi.com/): • Final Draft ESIA Report – consisting of main text and supplementary annexes including ESMP • Non-Technical Summary (NTS) of the Final Draft ESIA Report • Stakeholder Engagement Plan • Environmental and Social Action Plan (ESAP)
In addition to the disclosure of documents in the Project website, the following activities will be conducted: • The hardcopies of the Non-Technical Summary of the Final Draft ESIA Report will be distributed to district heads of Bursa. • Newspaper advertisements will be placed within the first week of the disclosure period announcing the publication of the Final Draft ESIA Report and the commencement of the consultation phase. • Within the disclosure period, a public consultation meeting will be held in Dogankoy Neighbourhood in Nilufer District to explain the outcomes of the ESIA study and to address questions raised. The public consultation will be announced in the same way as was done during the ESIA studies. During the public consultation meeting, a dedicated slot for women will be arranged. In addition, women in Dogankoy neighborhood will be contacted through Dogankoy School Principal in order to invite them to the public consultation meeting, to inform them that there will also be a dedicated slot for women during this meeting and to encourage their participation.
With the start of the disclosure period, comments can be submitted via email or in writing to: BRS Sağlık Yatırım A.S. Refik Belendir Sok. No: 110/2 Yukarı Ayrancı - ANKARA E-mail: [email protected] Telephone: 0 312 441 31 41 Fax: 0312 442 59 48 On completion of the disclosure period, the ESIA Report will be finalized by reflecting the comments received during the disclosure period where required. The Final ESIA Report will then be published on the Project website.
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 20 July 2016
7.0 STAKEHOLDER ENGAGEMENT ACTIVITIES DURING CONSTRUCTION AND OPERATION PHASES
Stakeholder engagement activities will continue during the construction period which will then be followed by engagement activities during 25-year operation period. Consultation activities during construction and operation phases are important in order to maintain constructive relationships both with the local communities and other stakeholders. There will be a Liasion Officer during construction and operation phases who will be the main contact person to handle comments and grievances. BRS A.S. will be responsible for updating SEP on a regular basis during construction and operation phases. Although not finalized yet, planned engagement activities are briefly outlined below. The main engagement methods for different types of stakeholders are also summarized in Table 7-1.
Construction Phase • Project information will be disclosed at the Project website and in the Project leaflets distributed to muhtars which will be updated as deemed necessary. • A noticeboard will be kept present at the entrance of the Project site in order to share the Project information with the local people and to provide the name of site manager or community liaison officer where complaints can be submitted in person, not only in writing. • The Contractor will liaise with Dogankoy Neighborhood school students to raise awareness in relation to road safety. • The contractor will engage in dialogue with local authorities and implement physical road safety measures in Dogankoy neighborhood, particularly in the vicinity of the school. • Meetings, as deemed necessary, with national and local authorities will continue during construction phase related to permitting and other issues. • The stakeholder list will be updated regularly and any new stakeholder identified will be included in the list. • Any activities likely to cause particular disturbance (such as noisy activities etc.) to the nearby neighbourhoods will be announced through handouts to be distributed to local people via muhtars offices. This information will also be provided in the Project website. • BRS A.Ş. will engage in dialogue with adjacent private land owners and users in relation to potenrtial free access to the agricultural land at project operational stage. • All comments and grievances will be managed in accordance with the Grievance Mechanism described in Section 9. • The security staff at the construction site will be informed about the Grievance Mechanism and in case a local person wants to submit a comment or grievance, the security person will be able to convey this person to the responsible staff. • In order to ensure maintaining the grievance mechanism, there will be clear and visible information on the Project website and phone numbers for people to submit their grievances. In addition, phone numbers and website information will be posted on the construction site signs.
Operation Phase • The Project website will be updated to include information on operation activities and any changes in environmental policy, plans and procedures that are followed. • BRS A.Ş. will liaise with Dogankoy Neighborhood school students to raise awareness in relation to road safety. Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 21 July 2016
• Ongoing meetings, as deemed necessary will be conducted with the national and local communities to inform them of any changes in project activities and related to permitting. • Ongoing meetings with the Ministry of Health will be conducted as necessary. • The stakeholder list will be updated regularly and any new stakeholder identified will be included in the list. • All comments and grievances will be managed in accordance with the Grievance Mechanism described in Section 9. • The security staff at the hospital will be informed about the Grievance Mechanism and in case a local person wants to submit a comment or grievance, the security person will be able to convey this person to the responsible staff. • In order to inform people widely about the grievance mechanism, there will be clear and visible information on the Project website. In addition, there will be a call center to manage the grievances.
Table 7-1: Engagement methods during construction and operation phases
Project Phase Stakeholder Type Engagement Approach Responsibility
• Project website for Project updates • Noticeboard to share Project information with the local people and to provide the name of site manager or community liaison officer Neighboring land • Implementation of grievance mechanism users and local • Making comment/complaint forms available at the BRS A.S. and communities construction site office Contractor of • Face-to-face meetings with adjacent private land owners/local residents/muhtar/nearby facilities upon a BRS A.S. Construction grievance or if needed • Newspaper advertisements if needed • Face-to-face meetings with MoH as needed and other Governmental authorities related to permitting issues authorities • Official written correspondence with authorities • Implementation of grievance mechanism • Training on environmental, health and safety aspects Construction Contractor of • Consultation related to implementation of relevant workers BRS A.S. management plans (i.e. Construction Camp Management Plan) • Making comment/complaint forms available at the Service Provider security gates of BRS A.S. or
Neighboring land MoH – users and local depending on communities the subject of
comment/ Operation complaint
• Project website to disclose Project information and Employees of Project updates BRS A.S. BRS A.S. and • Newspaper announcements, if needed (including sub- Service Provider • On-going communications with relevant regulatory contractors and stakeholders and public, as necessary of BRS A.S. their staff) • Implementation of the Grievance Mechanism
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 22 July 2016
Project Phase Stakeholder Type Engagement Approach Responsibility
• On-going meetings with the administrative staff of MoH BRS A.S. and MoH staff Service Provider of BRS A.S. Operation • Implementation of grievance mechanism MoH staff
• Establishment of a Patient Communication Unit inside the MoH Patients and IHC in line with Patient Rights Regulation Patients’ visitors
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 23 July 2016
8.0 SCHEDULE FOR ESTABLISMENT OF THE PROJECT
The schedule for consultation and disclosure activities and the proposed tentative timeline for future activities of the Project are provided below:
Milestone Schedule Development of the Draft ESIA Report May, 2016 Development of the Final Draft ESIA Report Late July, 2016 (version for disclosure) Final Draft ESIA Report disclosure Late July 2016 for a period of 30 days Public consultation meeting During the disclosure period of Final Draft ESIA Report Early third quarter of 2016 for a period of maximum 3 Start of construction activities years Start of operation activities First quarter of 2019 for a period of 25 years
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 24 July 2016
9.0 GRIEVANCE MECHANISM
A grievance mechanism will be established in order to ensure that all comments, suggestions and objections received from the project stakeholders especially from the nearby surrounding communities and facilities are dealt with appropriately and in a timely manner. It is important to note that there will also be a separate grievance mechanism for workers/employees during construction and operation phases and for patients during operation phase. It is important to mention that BRS A.S. will only be responsible for the management of grievances related with the services it provides and also grievances of workers that are working at these services. Grievances related with the health services or grievances by the health personnel will be under the responsibility of MoH.
Local communities will be informed about the grievance mechanism during the consultation and disclosure activities. All grievances will be recorded, responded and resolved in a defined timeframe. The planning of the grievance mechanism is currently at a planning stage. It is expected that comments and grievances can be sent to BRS A.S. via mail, e-mail or fax during the construction and operation stages as well as through the Project website and telephone numbers/call center. A Comment/Grievance Form is presented in Annex B.
The anticipated procedure to handle grievances during construction is described below: 1. All grievances submitted by the stakeholders in verbal and written will be considered. Verbal grievances will be written on grievance forms by the responsible person (i.e. liaison officer). 2. All grievances will be reflected in a grievance log to ensure that each grievance is assigned an individual number and that consistent tracking and corrective actions are carried out. The grievance log will contain: o Date of submission of the grievance o Reference number o Contact details of the complainant o Content of the grievance o Identification of parties responsible for the resolution o Dates when the investigation was initiated and completed o Findings of the investigation o Proposed corrective action o Date of response sent to the complainant (unless it is anonymous) o Statement of satisfaction of the complaninant o Date of closing out the grievance o Any outstanding actions for non-closed grievances 3. The grievance will be formally acknowledged within a week after submission. If the grievance is not well understood or if additional information is required, complainant will be contacted for clarification. 4. The grievance will first be evaluated by the liaison officer and then conveyed to the relevant staff and management, if necessary to identify what actions need to be taken, and an appropriate response will be developed. The complaint action form will be filled in as presented in Annex B. 5. The complainant will be informed about the proposed corrective action in writing three weeks after the grievance is acknowledged and the date of response to the complainant will be recorded in the grievance log. Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 25 July 2016
6. The complainant will be contacted through telephone or face-to-face meeting, if needed to confirm that the proposed corrective action taken is satisfactory, and the complainant’s response will be recorded in the grievance log. 7. The grievance will be closed out and the close out date will be recorded, if the complainant is satisfied with the action taken. If not, further assessment is needed and reevaluation of the grievance is required. 8. It is envisaged that the grievances will be resolved within one month after receipt. If this is not possible, the complainant will be informed about the progress on a regular basis. 9. Any grievances related to subcontractors’ activities will be managed in line with the mechanism described here.
In addition to grievances, comments will be reviewed once a week to identify if they require a response. In case the comment requires a response, an appropriate response will be developed by the Project team in a month after the submission date of the comment. Comments will be reflected to a comment log that will include information on the date of the comment submission, details of the person submitting the comment, issue of comment, response required or not, and date of response.
A flowchart for processing grievances is given below.
The planning of the grievance management process particularly for operation phase is still ongoing. It is expected that a call center will manage the grievance system of BRS A.S during operation phase. If
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 26 July 2016
any grievance related with health services is obtained, the grievance will be conveyed to MoH and people giving the grievance will be informed about this action accordingly. It is important to note that there is already a hotline (184) known as ‘MoH communication center’ which is used to submit grievances related with health services all over Turkey. It is expected that this hotline will continue to be used during the operation of Bursa IHC through which MoH can receive grievances.
The contact details for submitting grievances are provided below:
BRS Sağlık Yatırım A.S. Refik Belendir Sok. No: 110/2 Yukarı Ayrancı - ANKARA E-mail: [email protected] Telephone: 0 312 441 31 41 Fax: 0312 442 59 48
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 27 July 2016
10.0 RESOURCES AND RESPONSIBILITIES
The implementation of this SEP will be conducted and monitored by BRS A.S.
The contact details of the Community Liaison Officer (CLO) are given below:
Arif Gül
Address: Doğanköy Mahallesi Gümüş Cad.No:10 Nilüfer/BURSA
Phone: +90 531 306 7875 Email: [email protected]
11.0 REPORTING
All comments and grievances received will be recorded in a comment log and grievance log, respectively. SEP monitoring and evaluation reports including general performance/sustainability aspects of the Project will be disclosed to stakeholders periodically by BRS A.S.
Bursa Integrated Health Campus Project ELC Group – HA1056 Stakeholder Engagement Plan 28 July 2016
ANNEX A Photographs from the Public Consultation Meeting on 14.11.2015
ANNEX B Comment/Complaint Form
BURSA INTEGRATED HEALTH CAMPUS PROJECT- COMMENT/COMPLAINT FORM
INFORMATION ABOUT THE PERSON SUBMITTING COMMENT AND/OR COMPLAINT (Please leave blank if you wish to remain anonymous. Your comments/complaints will still be considered by BRS A.S.)
Full Name: Date:
Contact Information: (Please provide necessary information based on how you wish to be contacted)
By mail …………………………………………………………………………………………………………. By phone ………………………………………………………………………………………………………. By e-mail......
Indicate your purpose: □ Comment □ Complaint Signature confirming receipt of completed Recorded by: □ Person submitting comment/complaint Comment/Complaint Form copy □ Other (please specify who) ……………………………………………………..
YOUR COMMENTS ON THE PROJECT (Continue on the back of the sheet if required)
INFORMATION ABOUT YOUR COMPLAINT
Describe the Complaint (Continue on the back of the sheet if required)
Date of Incident Regarding Complaint □ One time incident/grievance (Date ……….……….) □ Happened more than once (how many times? …..……..…) □ On-going (currently experiencing problem)
What would you propose to resolve the problem? (Continue on the back of the sheet if required)
This section will be filled by BRS A.S. STATUS OF COMMENT Comment Logged (Y/N) Date of submission: Logged by: Response Required (Y/N) Date of response sent: STATUS OF COMPLAINT Complaint Logged (Y/N) Date of submission: Logged by: Date of Response sent: Complaint closed (Y/N): Close out date and signature:
BRS Sağlık Yatırım A.S. Refik Belendir Sok. No: 110/2 Yukarı Ayrancı/ANKARA Email: [email protected] Tel: 0312 441 31 41 Fax: 0312 442 59 48
ANNEX C Complaint Action Form (to be used by BRS A.S.)
COMPLAINT ACTION FORM
Information about the complainant
The reference number of the complaint (taken from the grievance log) Date of grievance submission
Describe all the details relevant to the complaint
Describe apparent cause of incident
Immediate action required
Identify preventative action (if required)
Continue on seperate sheets as required. Desicion of the Name Signature and date measures to be taken by HSE responsible Person responsible for Name Signature and date corrective action Completion by Name Signature and date
Verification by Name Signature and date