Final Report Mid Size Sustainable Energy Financing Facility (MidSEFF) Alages Solar Energy Power Plant: Non-Technical Summary (NTS)

November 2020

Project ID: IS 45

Final Report Alages Adilcevaz Solar Energy Power Plant: Non-Technical Summary (NTS)

November 2020

This report has been prepared by “Golder Associates Ltd. Şti.” and reviewed by Stantec Mühendislik ve Müşavirlik Ltd. Şti, for the European Bank for Reconstruction and Development (EBRD) in relation to the above-captioned project and is confidential to the client. Neither the Companies nor any person acting on their behalf, including any party contributing to this report, makes any warranty, expressed or implied, with respect to the use of any information disclosed in this report; or assumes any liability for direct, indirect or consequential loss or damage with respect to the use of any information disclosed in this report. Any such party relies upon this report at their own risk.

Prepared by Golder Associates Ltd. Şti.

Revised Approval Date Prepared by Approved by Document version by K. 27.11.2020 G.Altınkaya Kurtulmuş Davityan G. D. Sener 00 Glistau

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Table of Contents

Acronyms ...... iv

1. General Plant Description ...... 5

2. Environmental and Social Baseline ...... 10 2.1 Environmental Description of the Project Area ...... 10 2.2 Social Condition of the Project Areas ...... 12

3. Social and Environmental Impacts ...... 14 3.1 Land Use ...... 14 3.2 Water Use & Wastewater Management ...... 14 3.3 Waste Production and Management ...... 15 3.4 Emissions: Noise and Particulate ...... 16 3.5 Landscape ...... 17 3.6 Summary of Environmental and Social Impacts ...... 17

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Acronyms

CIA Cumulative Impact Assessment EAR Ecological Assessment Report EBRD European Bank of Reconstruction and Development EIA Environmental Impact Assessment EMRA Energy Market Regulatory Authority EN Endangered ESGA Environmental and Social Gap Analysis Report ESMP Environmental and Social Management Plan ETL Energy Transmission Line ha Hectares IUCN International Union for Conservation of Nature kV Kilovolts kWh Kilowatt hour LC Least Concern MidSEFF Mid-Size Sustainable Energy Financing Facility MoCT Ministry of Culture and Tourism MoENR Ministry of Energy and Natural Resources MoEU Ministry of Environment and Urbanization MWe Megawatt electrical MWm Megawatt mechanical NT Near Threatened PA Project Advisor (Golder Associates Ltd. Şti.) PC Project Consultant (Stantec Müh. ve Müş. Ltd. Şti,) Project Alages Adilcevaz SEPP Project RCIAP Regulation on Control of Industrial Air Pollution SEPP Solar Energy Power Plant Sponsor Göktekin Enerji A.Ş. Sub-Borrower Gülbahar Elektrik Üretim A.Ş. TSI Turkish Statistical Institute VEDAŞ Vangölü Elektrik Dağıtım A.Ş. (Electricity Distribution Company) VU Vulnerable

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1. General Plant Description The Alages Adilcevaz SEPP Project is planned to be constructed under the legal status of Gülbahar Elektrik Üretim A.Ş. (the Sub-Borrower), established to build and operate the Project which is located in with a total installed capacity of 24.193 MWm/16 MWe. The Sponsor of the Project is the Göktekin Enerji A.Ş. and Gülbahar Elektrik Üretim A.Ş. is the Sub-Borrower company of the Sponsor. Gülbahar Elektrik Üretim A.Ş. is a 100% owned company by Göktekin Enerji A.Ş. The land acquisition process has been completed for the Adilcevaz SEPP Project Area in accordance with the national regulation. The easement right for the project area was granted for 49 years to the Sub-Borrower. The “Electricity Production License” has been obtained by the Sub-Borrower on 16.01.2020 for 49 years for the Project with 31,956,480 kWh/year capacity. An amendment application was later made to Energy Market Regulatory Authority (EMRA) on 23.06.2020 to add the mechanical capacity (24.193 MWm) based on the final project design, and to revise the production license accordingly. The final “Electricity Production License” with 24.193 MWm/ 16 MWe capacity was issued by EMRA for “Alages Adilcevaz SEPP” on 30.07.2020 (issue number: 9476-17). The related licence shared with the Project Advisor. As part of the EIA process, the Sub-Borrower has submitted the EIA Report (which is prepared by 2U1K Mühendislik ve Danışmanlık A.Ş.) to the Ministry of Environment and Urbanization (MoEU) in January 2019 and has obtained the “EIA Positive” decision on 20.02.2019. After the EIA Positive decision, an official approval from the MoEU stating that the “EIA Positive” decision is still valid for the specified mechanical capacity (24.193 MWm) was obtained on 11.06.2020. An Energy Transmission Line (ETL) has already been constructed for the Project to provide the connection to the F-3 Malazgirt Feed Line from the Adilcevaz Substation Centre grid connection point. The estimated total length of the ETL is 5.6 km of a 31.5 kV overhead line. In accordance with EIA Regulation, the 31.5 kV and 5.6 km ETL of the Project does not require an EIA procedure. A Connection Agreement has been signed with Vangölü Elektrik Dağıtım A.Ş. (VEDAŞ) on 19.08.2020. Land parcels that the ETL passes include both private lands and pasture lands. Expropriation processes are ongoing and are under the responsibility of the VEDAŞ. According to the latest Project schedule provided by the Sponsor, the construction of the Project has started in June 2020. The 2.75 MWe of the Project was commissioned in October 2020 and 5.5 MWe in November 2020.The Project Area is still under construction based on the latest information obtained from the Sponsor. The full plant is expected to be commissioned in December 2020. The detailed information related to Alages Adilcevaz SEPP Project is presented in Table 1-1.

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Table 1-1: Alages Adilcevaz SEPP Project Detail Information

Place/ EIA Exemption Date of EIA Capacity Connection Project Approval Project Name / Company Names

Parcel Letter or Decision decision (kW) Agreement Date from MoENR

Alages Adilcevaz SEPP / Gülbahar Elektrik 222 EIA Positive 20.02.2019 16,000.00 19.08.2020 19.10.2020

Bitlis Üretim A.Ş.

Total capacity 16,000.00

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For the Alages Adilcevaz SEPP, the following PV technology was selected for the solar panels: “Hanwha Q Ces” brand, “Q.PEAK DUO L-G8.3 / BFG” model monocrystalline modules with 415 Wp output and a “SMA – Sunny Central 2750-EV” model Solar Inverter. The total number of modules and inverters planned to be installed are 58,296 modules and 7 inverters. According to the information provided by the Sponsor, the procurement process for the modules and the inverters started in June 2020 and already finalized. The supplier and the origin details of the modules and the inverters are presented in the table below. Table 1-2:Equipment Characteristics

Equipment Manufacturer Origin Planned number of Use

Module Hanwha Q Cells South Korea 58,296

Inverter SMA Solar Germany 7

Alages Adilcevaz SEPP is located in Cihangir Village, Adilcevaz District, . The Project location is presented in Figure 1-1.

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Figure 1-1: Project Location of Alages Adilcevaz SEPP

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According to the current Google Earth views, the closest settlement (Cihangir Village) from the Project Area is about 700 m distance to the Project Area and the closest building is located 125 m north east of the Project Area. The location of the closest building (a house belonging to a villager) is presented in Figure 1-2

Figure 1-2: Closest Building to The Project Area Table 1-3: Key project summary data Key Project Summary Data Project Gülbahar Elektrik Üretim A.Ş. Borrower Project Sponsor Göktekin Enerji Üretim A.Ş. Project The licensed Alages Adilcevaz SEPP project with 16 MWe installed capacity is Description / planned to be built in Bitlis Province, Adilcevaz District, Cihangir Village. The annual Business energy production is expected to be 31,956,480 kWh/year based on the Electricity Purpose: Production License. Key Parties European Bank for Reconstruction and Development (EBRD) Involved: Euopean Investment Bank (EIB) Türkiye İş Bankası A.Ş. Project Name Alages Adilcevaz SEPP Project Type Solar Energy Power Plant Base Case Scenario: Installed 16 MWe Capacity, MWe Annual Electricity 36,425,000 kWh/year (P50) Production, kWh/year

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2. Environmental and Social Baseline 2.1 Environmental Description of the Project Area The project with 16 MWe installed capacity is planned to be built in Bitlis Province, Adilcevaz District, Cihangir Village by Göktekin Enerji A.Ş. The construction works for the project started in June 2020 and the project started to generate electricity since October 2020 for 2.75 MWe and November 2020 for 5.5 MWe. The plant will start to generate electricity with full capacity in December 2020. A summary of the environmental characteristics of the Project is given in Table 2-1. Table 2-1: Summary of environmental characteristics

ENVIRONMENTAL PRESENCE COMMENTS ASPECTS /DISTRIBUTION The Project Area was classified as Pastureland Restoration Project is prepared by pasture land according to the official letter third party company in 2019 in accordance with (dated 18.07.2017) obtained from the 4342 numbered Pasture Law and related Adilcevaz District Governorship. Status Pasture Regulation (Official Gazetted date: change application was made for the 31.07.1998 Number: 23419) in order to change Project Area and it is registered as state the pastureland status of the Project Area as treasury land by Bitlis Governorship. Land state treasury land. acquisition process has been already The sponsor will follow the requirement in the Land use been completed for the Project Area and Pastureland Restoration Project Report which the easement right of the parcel number determines the measures to be taken for the 222 was granted for 49 years to the Sub- recreation of the pastureland at the end of the Borrower. Project Life and restoring the land so that Land parcels that the ETL passes include animals can graze again. both private land and pasture land. Land Since land acquisition for ETL is ongoing, the acquisition process is ongoing and the Sponsor is required to inform the PC regarding process is under the responsibility of the the land acquisition process of ETL. VEDAŞ. The Project Area is located within the buffer zone of the Batmış Lake Wetland Two Ecosystem Assessment Reports (EARs) and there are seasonal dry creeks were prepared in line with the requirements within/around the Project Area which the stated in the Regulation on the Protection of status of the dry creek could change Wetlands (Official Gazette Date: 04.04.2014, seasonally. 28962) during the EIA process. Addition to the Batmış Lake Wetland the Necessary measures regarding the protection Water surfaces closest wetlands are; located of Batmış Lake Wetland will be implemented as approximately 13 km south, defined in the EAR to mitigate the impacts of located 23 km west, Sarısu Plain Project activities on the lake as it is an important Wetlands located 25 km northeast, Lake habitat for many species during all phases of Haçlı located 25 km northwest, Bulanık the project. Plain wetlands located 28 km north and Sodalı Lake located 30 km southwest of the Project Area.

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There will not be any interaction with any protected areas during the project works. Ecosystem Assessment Reports in line with the requirements stated in the Regulation on the Protection of Wetlands (Official Gazette Date: 04.04.2014, 28962) during the EIA process and The Project Area is located within the a Flora & fauna Survey Report (conducted in buffer zone of the Batmış Lake Wetland. October 2020) were prepared for the Project. Other than Batmış Lake Wetland, the Protected areas All mitigation measures described in the EIA closest protected area is the Süphandağı Report and EARs will be implemented and Wildlife Improvement Area located 5 km monitored during all phases of the Project. east of the Project Area. The Sponsor will plan and conduct Flora&Fauna Monitoring Studies and Ornithological Monitoring Studies for the construction and operation phases by considering the monitoring requirements and mitigating measures defined in the EIA Report and EARs.

According to Ecosystem Assessment Ecosystem Assessment Reports (December Reports prepared in December 2017 and 2017 and July 2018) as part of the EIA process July 2018 by the NAZKA Çevre Müh. San. have been prepared. Tic. Ltd. Şti within the scope of EIA Mitigating and preventive measures defined in Report: the EIA and EARs will be considered by the Sponsor: • 220 flora species were identified in the Project Area and its close vicinity. Out • Information/training about the general of these 220 flora species, 3 (located characteristics and protection of all the outside the Project Area), were species in the Project Area and its close identified as endemic. 2 of these vicinity will be provided to all Project workers species were identified as LC by the experts and will be repeated (Dianthus masmenaeus Boiss. subsp. periodically. At every stage of the Project, glabrescens Boiss and Papaver fugax information and awareness activities are Poir. var. platydiscus Cullen) and the necessary including briefings about the third specie was classified as NT natural importance of the site to the workers (Cephalaria sparsipilosa V. A. by the experts. Matthews) by the IUCN. • Excavated material during construction • 223 fauna species (3 Amphibian, 16 activities will be used to cover the excavation Reptilian, 27 Mammalian and 177 Bird areas and no other filling material must be Flora and Fauna species) were identified (as per used. literature findings in the EAR) within or • Night work will not be carried out during around the Project Area. The EAR breeding periods in order to reduce noise to stated that some of the bird migration a level that will not disturb nocturnal fauna routes pass near the Project Area. The species. following information are identified • In order to restore the landscape and regarding the fauna species defined in geomorphological changes that will be the EAR: created by the facilities and activities within • There are 3 amphibian species the scope of the Project, planting and as per literature findings in the landscaping arrangements will be made EAR. The risk category listed in where necessary, with species suitable for the IUCN Red List is LC for both the region. Marsh Frog (Rana ridibunda) According to the EAR, for all activities to be and Brusa Frog (Rana carried out in the Project Area, the process macrocnemis). Brusa Frog must be started by checking the work area (Rana macrocnemis) was under the control of a vertebrate expert. observed during the site visits. According to the information provided by the • There are 16 reptilian species: Sponsor, the project area wasn’t screened The Common Tortoise (Testudo under the supervision of a vertebrate expert from the beginning of construction and no graeca, classified as VU in the action was taken as requested by the EAR. A

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IUCN Red List) and the Eastern flora & fauna expert proceeded the assessment Four-Lined Ratsnake (Elaphe activities for the project site in October 2020 to sauromates, classified NT). Both determine if there is any risk on the species due species were observed during to the project activities. According to the the site visits. October 2020 dated Survey report: • There are 27 Mammalian • Flora species and endemic flora species species as per literature findings identified in the EARs were not observed in in the EAR. The risk categories the Project Area but were observed within listed in the IUCN Red List for the close vicinity of the Project Area. No Schreiber’s Bent-winged Bat population different from the species (Miniopterus schreibersii) is NT identified in EAR has been observed. • No deterioration has been detected in the and for the Marbled Polecat vegetations around the Project Area. (Vormela peregusna) is VU. • Other than the fauna species identified in the Vormela peregusna was EARs, no other species was observed in the observed during the site visits; Project Area, and it was determined that the Miniopterus schreibersii was not identified fauna species preserved their observed. existence in alternative habitats around the • There are 9 Project Area. endangered/vulnerable/near- • Important alternative areas for wildlife threatened bird species specified in EARs are preserved, and no within/around the Project Site; 2 negative impact has been observed on are Endangered (Neophron Batmış Lake. • The natural environment of the area is percnopterus, and Falco preserved. cherrug), 3 are Vulnerable (Aquila clanga Otis tarda and This Survey Report was prepared to determine Streptopelia turtur) and 4 are if there is risk on the species due to the Project Near Threatened (Aythya activities. nyroca, Limosa, Larus The Sponsor will conduct monitoring studies armenicus and Coracias and prepare: garrulus) as per IUCN Red List • Flora&Fauna Monitoring Reports during • Monitoring frequency and construction and operation for at least 2 recommendations for flora and years, seasonally fauna species are also defined in • Ornithological Monitoring Report including the EAR. According to the EAR, the requirements in the EARs, during flora species must be monitored construction and first 2 years of operation. every 3 months (except winter season), fauna species (amphibian, reptilians) must be monitored every 3 months except winter season (spring, summer and autumn) for 2 years starting from the construction phase, mammalian species must be monitored monthly every season for 2 year starting from the construction phase and ornithological monitoring (both at the Project Area and Batmış Lake) must be conducted every two months for 2 years starting from the construction phase by relevant experts.

2.2 Social Condition of the Project Areas The Alages Adilcevaz SEPP Project is planned to be constructed and operated with a total installed capacity of 16 MWe in Cihangir Village, Adilcevaz District, Bitlis Province.

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The population of the Adilcevaz District is 30,499 according to the 2019 data of the Turkish Statistical Institute (TSI). The population of the Adilcevaz District decreased between 2007 (40,464 people according to the 2007 TSI data) and 2019. The population of the nearest settlement (Cihangir Village) is 184 according to the 2019 TSI data and the population decreased since 2008 (353 in 2008). The main economic activities in the Adilcevaz District and the settlements close to the Project Area are agriculture and animal husbandry. In addition, residents of the village work in construction in metropolitan areas during the summer months. Both sheep and cattle breeding are carried out throughout the district. About 4,100 hectares of agricultural land are used for irrigated agriculture and rest of the land is used for cereal agriculture. In the irrigated area, sugar beet and various vegetables are grown, which are important industrial plants. There is a large cultivation area of wheat on the agricultural land. There are no industrial facilities located in the close vicinity of the Project area. The closest settlement (Cihangir Village) from the Project Area is about 700 m distance to the Project Area and the closest building is located 125 m north east of the Project Area. The other closest settlements to the Alages Adilcevaz SEPP are Karakol Village with 2.6 km and Mağalcık Village with 3 km distance. Land parcels that the ETL passes include both private lands and pasture lands. Expropriation processes are ongoing and are under the responsibility of the VEDAŞ. According to the official letter (numbered as E.537645 and dated 26.06.2018) obtained from the General Directorate of Cultural Heritage and Museums, there is no cultural heritage in the Project Area. However, the Project Area is within the boundaries of the “Kuzey Van Gölü Selçuklu Culture and Tourism Protection and Development Region”. For this reason, the Sub-Borrower made an application to the General Directorate of Investments and Businesses of the MoCT on 15.08.2019 in order to get approval for the new zoning plans of the Project Area. The approval letter was obtained from the General Directorate of Investments and Businesses of the MoCT on 25.11.2019 for the 1/5000 scale Master and 1/1000 scale Implementation Zoning Plans.

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3. Social and Environmental Impacts 3.1 Land Use The Project covers an area of 30.6 ha located within the borders of land parcel number 199. The land parcel 199 with 121.7 ha in total was classified as pastureland according to the official letter (dated 18.07.2017) obtained from Adilcevaz District Governorship. In order to realize the SEPP in the Project Area, a Pasture Land Restoration Project was prepared by a third party company in 2019 in accordance with the No. 4342 Pasture Law (Official Gazette Number:23272 Date:25.02.1998) for the status change of the pasture land to state treasury land (for 30.6 ha). The related status change application was made to the Bitlis Governorship and the status change considered appropriate by the Bitlis Governorship in a decision of 16.04.2019 (issue no: E.1238851). After the status change of the 30.6 ha part of the 199 numbered parcel, the Adilcevaz Land Registry Directorate made the parcel change of the 199 numbered parcel and the parcel number of the Project Area was changed to 222 (which is 30.6 ha part of parcel 199). The No. 222 parcel was registered as state treasury land and the title deed of the Project Area was issued as parcel number 222 on behalf of the State Treasury. The easement right of the parcel number 222 was granted for 49 years to the Sub-Borrower.The preparation of a Soil Protection Project has not been requested by the Bitlis Provincial Directorate of Food, Agriculture and Husbandry since the Project Area classified as pastureland. Therefore, there is no soil protection assessment conducted for the Project. Pastureland Restoration Project is prepared by third party company in 2019 in accordance with 4342 numbered Pasture Law and related Pasture Regulation (Official Gazetted date: 31.07.1998 Number: 23419) in order to change the pastureland status of the Project Area. ETL (5.6 km of a 31.5 kV overhead) has been constructed for the Project. Land parcels that the ETL passes include both private lands and pasture lands. Expropriation processes are ongoing and are under the responsibility of the VEDAŞ. During the Project activities, existing roads will be used. Only four 10 metre access roads to the Project Area will be constructed in order to be able to enter and exit the Project Area from the Cihangir-Karakol Village Road. No private property (land) will be affected by construction of these 10 metre access roads. There is no settlement in the Project Site. There will be no involuntary resettlement nor economic displacement as part of this project. The closest settlement (Cihangir Village) from the Project Area is about 700 m distance to the Project Area. 3.2 Water Use & Wastewater Management During construction, water will be used for dust suppression, construction and domestic purposes. There will be approximately 80 people will be employed in total during construction. Daily water needs (both drinking water and domestic water) per person are assumed to amount to 346 litres based on the TUIK (TSI Bitlis Province Water Consumption Statistics) 2016 data, total of 27.68 m3/day for drinking and domestic water would be used during the construction period. Drinking water will be provided from suppliers (bottled water) from the Adilcevaz District and water used for construction activities and domestic purposes will be supplied with water tankers from the water network of Cihangir Village. The wastewater generated during the construction phase of the Project will be domestic wastewater. Daily wastewater generation per person is assumed as 206 litres and 16.48 m3/day of wastewater is expected to be generated during the construction phase of the Project. During the operation period of the Project, approximately 3 people will be employed, and 1.04 m3/day water (both drinking water and domestic water) would be used during operation and 0.618 m3/day of wastewater is expected to be generated during the operation phase.

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Similar to the construction phase, drinking water will be provided by suppliers (bottled water) from the Adilcevaz District. Groundwater well will be drilled during the operation phase and domestic water will be supplied from groundwater well if the well water quality is suitable to use as domestic purposes. All relative legislative application will be done and needed permits will be collected before any drilling operation for a groundwater well. The domestic wastewater generated during the Project activities, both in the construction and operation phases of the Project, is/will be collected in septic tanks. One concrete septic tank was already constructed in the Project Area. This septic tank will be regularly collected by vacuum trucks. The panels will be washed approximately once a year as a part of maintenance and repair activities. According to the Sponsor, approximately 160 tons of distilled water will be used in each washing activity. No detergent or chemicals will be used during panel cleaning. The resulting wastewater will not include any chemical or hazardous material. Water discharge from the panels is likely to evaporate or be absorbed into the soil after draining from the panels. However, the panel washing frequency is not clearly defined. A Wastewater Management Activities will be included in the ESMP prepared for the construction and operation of the Project (including ETL) to identify wastewater sources origination from the construction and operation works, and define management actions and methods including responsibilities, prevention, minimization, disposal and monitoring of the wastewaters generated. This ESMP will cover the SEPP and associated facilities (ETL, road construction etc.) including the cumulative impacts of the project and 5.6 km ETL construction works if any. The Sponsor must follow the requirements stated in the ESMP to prevent and / or minimize the adverse impacts to the environment. that may be resulted from the project activities. Any discharge of wastewater to the receiving environment must be prevented in all phases of the Project. 3.3 Waste Production and Management The main types of the wastes generated during the construction and operation phase of the project are: • Domestic solid waste • Packaging waste • Hazardous Wastes The volume of domestic solid waste depends on the number of persons employed. A total of approximately 61.6 kg/day (for 80 people) of domestic solid waste will be generated during construction and 2.31 kg/day (for 3 people) will be generated during the operations phase of the Project. Domestic wastes must be collected separately according to their type and characteristics. The wastes will be delivered to the municipal waste collection system by the Sub-borrower. Packaging wastes will be collected separate from other wastes in and will be handed-over to licenced collection companies or to the municipality. Within the scope of the Project, it is possible to generate limited amounts of hazardous waste, waste oil, waste batteries and accumulators from construction activities during the construction phase and from the maintenance and repair operations of the plant equipment and machinery during the operations phase. These types of wastes must be collected separately and disposed according to related regulations by licensed disposal companies. The total excavation material will amount to a maximum 200 m3 and all of the excavated material will be used within the Project Area for refilling and landscape restoration. Thus, production of excavation wastes is not expected. A temporary site waste storage area will be constructed in the Project Area. The storage area shall have impermeable ground to prevent possible leakage. Different types of wastes must be stored separately in the waste storage area and a register of waste generation, storage and disposal must be kept during construction and operation. A register of all wastes and their disposal data must be kept.

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A formal ESMP (including waste management, wastewater management, air, noise, topsoil management) for both project and ETL area will be prepared and implemented at the project site during all phases of the project. Mitigation measures regarding wastes will be addressed and implemented as defined. All staff will be trained in order to comply with waste management requirements. Daily environmental monitoring must be carried out by the HSE supervisor during construction activities. 3.4 Emissions: Noise and Particulate The source of noise will be mainly related to constructions machinery and construction activities such as excavation and piling. According to Sponsor, there is no night work to be performed for the Project. The closest building found using Google Earth and verified by Site Representatives is located at a distance of 125 m to the Project Area. The noise level is calculated as 59.90 dBA at 100 m distance during construction which is also lower than the regulatory limit (70 dBA). Consequently, the noise level at 125 m distance is below the regulatory limit. The following measures will be taken to prevent noise impact during construction activities by the Sponsor: • Appropriate personal protective equipment and materials such as helmets, ear protectors or ear plugs will be provided to protect workers from noise. • There will not be any construction activities and construction vehicles will not pass through settlement during the night-time (between 23:00 to 07:00) on weekdays and weekends. • The following control measures will be applied; - selection of equipment with lower sound levels; - installing suitable mufflers on engine exhausts and compressor components; - limiting the hours of operation for specific types of construction equipment, especially mobile sources operating through community areas; - reducing project traffic routing through community areas wherever possible; - developing a mechanism to record and respond to complaints. • In addition, regular maintenance will be carried out on all construction equipment to ensure that noise levels are kept to a minimum. Noise measurements will be carried out in case of any complaints during the construction phase. There will not be any activity which will cause noise generation during the operation phase. Potential impacts on air quality can arise from the use of construction and earthmoving machinery and from trucks and cars. Impacts will be air pollutants from combustion engines and dust generation/release. Construction activities will affect air quality mainly through emissions of dust from excavation, storage and transport of soil and vehicle traffic on unpaved roads. There will also be particulates from vehicle exhausts (mainly diesel engines) and from stationary sources such as power generators. Emissions of gaseous pollutants, particularly NOx and SO2, will be from vehicle and machinery exhausts and also from stationary sources (power generators). Total dust emission was calculated as 0.302 kg/hour. Dust from excavation works during construction phase was calculated based on the Regulation on Control of Industrial Air Pollution (RCIAP) (Official Gazette Number: 27277 date: 03.07.2009). The calculated dust emission values are below the limit value (1 kg/h) as per the RCIAP. For this reason, a modelling study is not considered to be necessary and was not carried out. According to information provided by the Sponsor; the following mitigation measures will be considered relevant during construction phase to mitigate dust and exhaust gas dispersion: • wetting and covering powdery materials transported on trucks (e.g. excavation spoil); • reduce truck and vehicle speed; • periodic wetting of the stockpiled material to maintain a humidity of about 5%; • periodic wetting of the construction areas and site access roads;

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• use of working machinery with low emissions (and good maintenance); • vehicles will be maintained in good condition to ensure they are no louder than similar vehicles on the roadways; • use of diesel with low sulphur content. Considering the limited scope of the construction activities, the impact on air quality will be low and temporary. Electricity will be generated at the SEPP based on photovoltaic technology, and no air emissions will occur during operation because of the plant processes. There will be very limited air emissions from the vehicles during the operation phase. Environmental and Social Management Plan (ESMP) will be prepared for the Project. Mitigation measures regarding air emission must be detailly defined in the ESMP. Related ESMP will cover the SEPP and associated facilities (ETL, road construction etc.) including the cumulative impacts of the project and 5.6 km ETL construction works if any. 3.5 Landscape The land of the Project area is almost flat. The Project will change the current landscape with the placement of large areas of dark coloured flat solar panel arrays. During construction of the Project, excavated materials to be used for filling will be collected temporarily on the Project Area in order to preserve current soil condition and landscape. In the area where administrative units will be built, various green areas will be created outside the energy production area. Within the scope of these studies, attention will be paid to the selection of plant species specific to the region. Invasive species will not be used. After the operational activity is over, the panels will be completely removed before the land is abandoned. No waste will be left, and land rehabilitation works will be performed based on the current topographic structure of the land and within the framework of the relevant legislative provisions and EARs. According to the information obtained by The Sponsor, there will not be any tree felling activities for the Project or ETL. The Sponsor informed the PA that reflection caused by the PV panels will be insignificant due to the anti-reflective coatings on the solar PV panels. The technical specification document of the solar panels as provided by the Sponsor specifies that the front cover of the panels has anti-reflection technology. Based on the aerial/satellite images, there is no sensitive receptor (airport, high road, etc.) in the close vicinity of the Project Area. Therefore, no significant adverse impact is expected regarding the glint and glare. In case of complaints, the need for screening will have to be assessed. The visual impacts can be significant for solar projects since large lands (15,000-20,000 m2/MW capacity) are required for solar panels. Although there is no national regulatory requirement, a Visual Impact Assessment will be prepared prior to the construction works for the Project. Photo simulations must be made, and these materials must be used during the stakeholder engagement meetings/activities. The topography of the Project Area is almost flat, erosion events were not seen in the Project Area and its close vicinity in accordance with the erosion map presented in the EIA. However, according to the soil level of the Project land defined in the EIA, there is slight risk of erosion. Therefore, an Erosion Control Management must be prepared for the Alages Adilcevaz SEPP within the Landscape Restoration Report. Requirements stated in the EARs must be considered in the Landscape Restoration Report. 3.6 Summary of Environmental and Social Impacts A summary of the impacts with their quantifications is given in the table below.

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Table 3-1: Impact Quantification COMPONENT IMPACT QUANTIFICATION The Project Area covers 30.6 ha which was classified as pastureland according to the official letter (dated 18.07.2017) obtained from the Adilcevaz District Governorship. Status change made for the Project Area and it is registered as state treasury land. Land acquisition process has been completed for the Project Area and the easement right of the parcel number 222 was granted for 49 years to the Sub-Borrower. Easement Use of agricultural Land use land right for the project area (parcel number 222) was granted for 49 years to the Sub-Borrower. Land parcels that the ETL passes include both private land and pastureland. Land acquisition is ongoing and the process is under the responsibility of the VEDAŞ. Since land acquisition for ETL is ongoing, the Sponsor is required to inform the PC regarding the land acquisition process of ETL. Produced wastewater will be: 16.48 m3/day domestic wastewater during the construction phase and 0.618 Utilization and Water/Wastewater m3/day domestic wastewater during operation phase Discharge (assuming 80 workers in the construction phase and 3 workers in the operation phase). Produced domestic solid waste will be 61.6 kg/day during Production of solid the construction phase and 2.31 kg/day domestic waste waste during the operation phase (assuming 80 workers in the construction and 3 workers in the operation phase) Waste Total excavation material amount will be 200 m3 and all of the excavated material will be used within the Project Excavation waste Area for refilling and recreation purposes. Thus, production of excavation wastes is not expected.

The Sponsor is required to conduct Flora&Fauna Monitoring Reports and Ornithological Monitoring Reports during construction and operation for at least 2 Interference with years, by considering the requirements, monitoring Fauna and flora flora-fauna frequency and measures defined in the EARs. species The Sponsor is required to prepare Landscape Restoration Report by considering requirements stated in the EARs as well. The noise level is calculated as 59.90 dBA at 100 m distance during construction and the closest building found using Google Earth and verified by Site Representatives is located at a distance of 125 m to the Emissions Noise Project Area. Consequently, the noise level at 125 m distance is below the regulatory limit (70 dBA). Noise measurements will be carried out in case of any complaints during the construction phase.

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There will not be any activity which will cause noise generation during the operation phase. Dust emission result has been calculated as 0.302 kg/hour and is defined as lower than the regulatory limit (1kg/h). For this reason, a modelling study is not Particulate considered to be necessary and not carried out. Mitigation measures regarding air emission must be addressed in the Environmental and Social Management Plan (ESMP). A Visual Impact Assessment must be prepared on Changes in the Landscape sensitive points (the closest settlements or public roads) aspect of the area with a photomontage study for the Project. According to the official letter of the General Directorate of Cultural Heritage and Museums, there is no cultural heritage in the Project Area. However, the Project Area is within the boundaries of the “Kuzey Van Gölü Selçuklu Disturbance of the Culture and Tourism Protection and Development Cultural Heritage cultural heritage Region” A Chance Finds procedure must be prepared and implemented considering that the project area is within the boundaries of the “Kuzey Van Gölü Selçuklu Culture and Tourism Protection and Development Region”.

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