Kizildere III GPP Capacity Extension Project

Supplementary Lenders Information Package (SLIP) ESIA Addendum

December 2016

Kızıldere III GPP Capacity Extension Project

Quality information

Prepared by Checked by Approv ed by AECOM Dr. Hande Yükseler Uygar Duru ESIA and EDD Section Manager Regional Director, Environment and Ground Engineering, Environment BL

Revision History

Rev ision Rev ision date Details Authorized Name Position

0 December 2016 December 2016 Dr. Hande Yükseler ESIA and EDD Section Manager

0 February 2017 Permit status February 2017 Dr. Hande Yükseler ESIA and EDD updated Section Manager

AECOM

Kızıldere III GPP Capacity Extension Project

Prepared for:

Zorlu Doğal Elektrik Üretimi A.Ş. (to enable disclosure in line w ith European Bank for Reconstruction and Development (EBRD) requirements)

Prepared by:

Ahmet Korkmaz, As., Bba, GIS and Environmental Modelling Expert, Project Specialist

Başak Şentürk, Biologist, Bsc.

Begüm Avcı, Biologist, Bsc.

Esmanur Selçuk, Environmental Engineer, BSc. Gönül Ertürer, Senior Environmental and Social Expert, MSc, BSc. EnvE

İrem Bozoğlu, Environmental Expert, BSc, CheE

Mertcan Özbakır, Hydrogeological Engineer, MSc. BSc HydE

Taylan Aşkın, Geological Engineer, MSc, BSc

AECOM Turkey Danışmanlık ve Mühendislik Ltd. Şti Mustafa Kemal Mahallesi Dumlupınar Bulvarı Tepe Prime No:266 B Blok No:50-51 06800 Çankaya Ankara Turkey

T: +90 312 4429863 aecom.com

© 2016 AECOM Turkey Danışmanlık ve Mühendislik Ltd. Şti. All Rights Reserved.

This document has been prepared by AECOM Turkey Danışmanlık ve Mühendislik Ltd. Şti (“AECOM”) for sole use of our client (the “Client”) in accordance w ith generally accepted consultancy principles, the budget for fees and the terms of reference agreed betw een AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherw ise expressly stated in the document. No third party may rely upon this document w ithout the prior and express w ritten agreement of AECOM.

AECOM

Kızıldere III GPP Capacity Extension Project

Table of Contents

1. Executive Summary...... 6 2. Project Description...... 7 3. Project Alternatives ...... 13 3.1 Site Location ...... 13 3.2 GPP Technology ...... 13 3.3 Other Energy Generation Alternatives ...... 14 3.4 No Action Alternative ...... 17 4. Corporate Environmental and Social Management System ...... 18 4.1 Zorlu Energy Corporate Governance Structure ...... 18 4.2 Zorlu Sustainability Management ...... 18 4.3 Ethics and Compliance...... 19 4.4 Risk Management...... 19 4.5 Environmental Policy ...... 20 4.6 Occupational Health and Safety ...... 20 5. Compliance w ith EBRD Performance Requirements ...... 22 5.1 Air Emissions ...... 22 5.2 Greenhouse Gas Emissions ...... 22 5.2.1 GHG Emissions from GPPs ...... 24 5.2.2 Baseline (Reference) Emissions ...... 24 5.2.3 Exploration Phase of Kizildere III GPP Capacity Extension Project ...... 25 5.2.4 Construction Phase of Kizildere III GPP Capacity Extension Project ...... 26 5.2.5 Operation Phase of Kizildere III GPP Capac ity Extension Project ...... 26 5.2.6 Carbon Offset Strategy ...... 27 5.2.7 GHG Emissions Summary of Kizildere III GPP Capacity Extension Project ...... 27 5.2.8 GHG Emissions Assessment of Kiz ildere III GPPs ...... 28

5.2.9 CO2 Evolution over Time ...... 28 5.3 Surface Water and Groundw ater Env ironment ...... 31 5.4 Biodiversity and Living Natural Resources...... 31 5.4.1 Baseline Biodiversity Assessment in line w ith EBRD PR6 ...... 32 5.4.2 Overall Biodiversity Assessment...... 35 5.5 Labour and Working Conditions...... 38 5.6 Health and Safety ...... 39 5.7 Land Acquisition, Involuntary Resettlement and Economic Displacement ...... 41 5.8 Cultural Heritage ...... 41 5.9 Information Disclosure and Stakeholder Engagement ...... 41 6. Cumulative Environmental and Social Impact Assessment ...... 43 6.1 Introduction ...... 43 6.2 Policy and Regulatory Framew ork...... 43 6.3 Limitations of the CIA ...... 44 6.4 Projects Covered in the CIA Study ...... 44 6.5 Selection of Key Environmental and Social Issues for the CIA Study ...... 46 Appendix A Updated Fauna and Flora Tables ...... 49

AECOM

Kızıldere III GPP Capacity Extension Project

Figures

Figure 1. Main Geothermal Fields of Western Anatolia ...... 9 Figure 2. Geothermal Pow er Plants on Büyük Menderes Graben (Zorlu Enerji, 2016) ...... 10 Figure 3. Project Area and its Vicinity ...... 11 Figure 4. Estimates of Lifecycle GHG Emissions (IPCC, 2012) ...... 15 Figure 5. GHG Emiss ions by Lifecycle Stage (US Department of Energy, Argonne National Laboratory, 2010) ..15 Figure 6. Global Levelized Cost of Energy in Q2, 2013 (USD/MWh) (World Energy Council, 2013) ...... 17 Figure 7 Sustainability Goals and Related Actions...... 19 Figure 8. Overview of Scope 1, Scope 2 and Scope 3 Emissions across a Company’s Value Chain ...... 23 Figure 9. Production and Reinjection Flow rate History (ITU, 2016) ...... 29 Figure 10. Effects of CO2 Content of the Reinjection Water and the Existence of Natural Recharge on the Reservoir Water CO2 Content as a Function of Time (ITU, 2016) ...... 29 Figure 11 Habitat Assessment Map (derived from Corine Satellite) ...... 36 Figure 12 Cumulative Impact Assessment Map ...... 45

Tables

Table 1. Distances betw een the Project Area and Surroundings ...... 8 Table 2. Comparison of Air Emissions (kg/MWh) from Coal, Oil, Natural Gas and Geothermal Plants ...... 16 Table 3. Global Warming Potentials ...... 24 Table 4. Exploration Phase Combustion Related GHG Emissions ...... 25 Table 5. Exploration Phase Combustion Related GHG Emissions ...... 25 Table 6. Exploration Phase Information for Venting of NCGs ...... 25 Table 7. NCG Information (for exploration phase) ...... 26 Table 8. Construction Phase Combustion Related GHG Emissions ...... 26 Table 9. Operation Phase Information...... 27 Table 10. NCG Information (for operation phase) ...... 27 Table 11. Carbon Offset Strategy ...... 27 Table 12. Summary of GHG Emissions of Kizildere III GPP Capacity Extension Project ...... 27 Table 13. GHG Emissions Assessment of Kizildere III GPPs ...... 28 Table 14. % of NCG Change w ith Time ...... 30 Table 15. CO2 Evolution of Kizildere GPPs ...... 30 Table 16. Assessment of Priority Biodiversity Features in the Project Area and its Vicinity ...... 33 Table 17. Assessment of Critical Habitat Features in the Project Area and its Vicinity ...... 34 Table 18 Land Cover Assessment due to Habitat Loss ...... 37 Table 19. Cumulative Environmental and Social Impacts ...... 47

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Kızıldere III GPP Capacity Extension Project

1. Executive Summary

Zorlu Enerji Elektrik Üretim A.Ş. (Zorlu Enerji) w as established in 1993 to meet the electricity and steam requirements of Zorlu Group’s industrial plants and in 2011, Zorlu Enerji has become the first energy company in Turkey to calculate its corporate carbon footprint. Zorlu Doğal Elektrik Üretimi A.Ş. (Zorlu Doğal) on the other hand, w as established in 2008 for the purposes of developing projects to supply steam and heat, to carry out feasibility studies for hydroelectric and especially geothermal pow er plants and for electricity generation plants based on all forms of renew able energy.

Zorlu Enerji is planning to increase the capacity of the 100 MW Kizildere III GPP (Unit 1) to 165 MW through the construction and operation of Kizildere III GPP (Unit 2). Kizildere III GPP (Unit 1) is currently under construction since April 2016. The capacity extension Project is planned to be in the borders of Kizildere III GPP located in Buharkent District of Aydın Province. The new plant w ill utilize much of the existing infrastructure.

The capacity extension Project (the ‘Project’ hereinafter) consists of a pow er plant, fourteen production w ells, eight re-injection w ells, one observation w ell, pipelines, service roads, an electric transmission line and other supporting infrastructure necessary for its construction. The Project has been subject to previous environmental and social studies to meet Turkish regulatory requirements.

The European Bank for Reconstruction and Development (EBRD) together w ith Akbank T.A.Ş. (“Akbank”), Garanti Bankası A.Ş (“Garanti Bankası”), Türkiye İş Bankası A.Ş. (“İş Bankası”) and Türkiye Sınai Kalkınma Bankası (“TSKB”) (together the ‘Lenders’) are considering providing a loan to Zorlu Doğal for the development of the Project.

In line w ith the EBRD’s Environmental and Social Policy (2014), and its associated Performance Requirements (PRs), a project of this type and scale requires a fit for purpose Environmental and Social Impact Assessment (ESIA). Follow ing a review of the previous environmental impact assessment (EIA) report prepared for the Project to meet National requirements, additional supplementary environmental and social studies have been developed by independent consultants to meet the EBRD PRs and international good practice. The Project ESIA, therefore, consists of the previous EIA report and the supplementary studies.

This ESIA Addendum is prepared to provide an additional assessment of the supplementary studies conducted w ithin the Supplementary Lenders Information Package (SLIP).

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2. Project Description

Kizildere geothermal field is located at the eastern end of an east-w est trending extensional tectonic valley know n as the Büyük Menderes Graben (Şimşek, 1985). Main geothermal resources of Western Anatolia is given in Figure 1. Several flash and binary geothermal pow er plants have been installed in various high enthalpy geothermal fields located in Büyük Menderes and Gediz grabens as given in Figure 2.

The first geothermal pow er plant of Turkey w as established in Kizildere region, Sarayköy District of Province, in 1984 w ith a total capacity of 17.4 MWe. The plant w as operated at around 6 MWe before it w as tendered by the privatization directorate. Zorlu acquired the concession rights of the field for 29 years for utilization and development purposes. After privatisation of the Kizildere geothermal field and the 17.4 MWe Kizildere I GPP in 2008 (in operation since 1984), 80 MWe Kizildere II GPP become operational in 2013.

Kizildere II GPP is an integrated geothermal facility w ith the follow ing features:

 Geothermal fluid is also used in dry ice production

 Geothermal fluid is currently used for heating 200 decares of greenhouses and planned 1,000 decares.

 A total of 3,000 households at Sarayköy are heated w ith geothermal.

 Hot w ater is supplied to tw o thermal hotels.

Kizildere III GPP Project is under construction since April 2016 and is located in Buharkent District of Aydın Province, Turkey. The capacity increase is planned to be in the borders of Kizildere III GPP. The capacity of the plant is planned to be increased from 100 MWe to 165 MWe. The capacity extension Project covers a total area of 84,700 m2. The Company holds a concession at the Kizildere field. Kizildere III GPP (Unit 1) is approximately 100,000 m2.

Kizildere III GPP Project is designed to produce 80 MWe energy through triple flash system and 20 MWe energy through binary cycle system. Together w ith the capacity extension Project, Kizildere III GPP Unit 1 and Unit 2 w ill collectively produce 165 MWe energy, 130 MWe through triple flash system and 35 MWe energy through binary cycle system.

The plant integrates tw o systems: flash steam generation system that uses steam under high pressure; plus binary cycle pow er generation system that uses HP flash turbine exhaust steam to vaporize a w orking fluid w ith a low er boiling point and use it to drive a turbine.

The capacity extension Project includes the construction and operation of:

 Main pow er plant (Kizildere III GPP Unit 2) – binary system, steam turbine, cooling tow er, condenser and NCG removal system,

 Fourteen production w ells (the depths of the production w ells are expected to be around 2,000-3,000 m and the temperature of the geothermal fluid obtained from drilling w ill be around 230 °C.),

 Eight re-injection w ells,

 Emergency pond,

 One observation w ell (to be opened w ithin the scope of Kizildere III GPP Unit 1),

 Pipelines (to transfer the geothermal fluid from production w ells to the plant site, and the reject fluid (geothermal fluid that remains after energy generation purposes) from the plant to the re-injection w ells, drainage channels w ill be provided below the pipelines to avoid contact of geothermal fluid w ith soil, in case of equipment failure), and

 Service roads.

The capacity extension Project w ill use the existing sw itchyard of Kizildere III GPP, w hich relays the generated electricity to the sw itchyard of Kizildere II GPP via a 154 kV Energy Transmission Line (ETL) to be constructed betw een Kizildere III GPP and Kizildere II GPP. The length of the ETL w ill be approximately 2 km.

Project area is surrounded w ith fig gardens and olive groves. It is located approximately 950 m w est of the Kizildere II GPP and 180 m north of Denizli-Aydın Motorw ay. Nearest residential area is the Kizildere Neighbourhood, located approximately 2,600 m northw est of the Project area. The distances betw een the Project area and the surrounding properties are provided in Table 1

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Table 1. Distances betw een the Project Area and Surroundings

Direction with respect to the Property Project Area Distance (m)

Kizildere Neighbourhood Northwest 2,600 Karakıran Neighbourhood Southeast 3,200 Aydın-Denizli Motorway South 180 Railway South 360 Sarayköy Agriculture-Based Organized Industrial Zone Southeast 1,000 Kizildere I GPP Northeast 1,850 Kizildere II GPP East 950 Drying Channel Southeast 600 Irrigation Channel Southeast 200 Büyük Menderes River South 1,250

Zorlu Enerji’s land acquisition policy is to acquire lands on w illing selling basis, hence avoid involuntary resettlement through expropriation. As of November 2016, all of privately ow ned 42 parcels (mostly used for agricultural purposes before) required for the Project have been purchased on w illingness basis. There w ill be no additional land acquisition. There w ill be no physical displacement as a result of the land acquisition process.

The milestones of the Kizildere III GPP (Unit 1) Project and Kizildere III GPP capacity extension Project are as follow s:

 According to Turkish EIA Regulation (Official Gazette No. 29186, date November 25, 2014), Kizildere III GPP (Unit 1) Project is included under Annex-I (Item 44: Extraction and use of geothermal fluid w ith thermal capacity 20 MW and more). A local EIA process w as carried out for Kizildere III GPP in 2015 and EIA Positive Certificate w as secured on October 08, 2015.

 The construction activities of Kizildere III GPP (Unit 1) started in April 2016.

 Feasibility study for the capacity extension Project w as issued in May 2016.

 The local EIA Report for the capacity extension Project, in line w ith the Turkish EIA Regulation, w as submitted to the Ministry of Environment and Urbanization for the GPP Project in October 2016.

 A “Public Participation Meeting” for the capacity extension Project w as organized on 19 th July 2016 in a community center in Kizildere village, w ithin the scope of EIA preparation process. Approximately 40 stakeholders amongst the local community participated in the meeting together w ith participants from local authorities.

 EIA Positive Certificate for the capacity extension from 100 MWe to 180 MWe have been acquired as of 9 December 2016.

 Existing Energy Market Regulatory Authority (EMRA) License is updated to 165 MWe to include both Unit-1 and Unit-2 pow er generation capacities.

 Construction permit to be acquired in Q1 2017.

 Preliminary site preparation w orks started as of December 2016.

 Commercial operation is scheduled to January 2018 for the steam turbine and March 2018 for the binary turbine and the complete system.

 The electrical energy generated by the Project w ill be transferred to the national grid through the approximately 2 km, 154 kV Energy Transmission Line (ETL) to be constructed betw een Kizildere III GPP and Kizildere II GPP. According to the Turkish EIA Legislation, 154 kV voltage ETL projects w ith lengths less than 5 km are exempt from EIA process.

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Figure 1. Main Geothermal Fields of Western Anatolia

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Figure 2. Geothermal Power Plants on Büyük Menderes Graben (Zorlu Enerji, 2016)

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Figure 3. Project Area and its Vicinity

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Production Process

The Kizildere III GPP Capacity Extension Project w ill make use of Triple Flash-Binary Combined Cycle system, w hich is currently the most efficient GPP Technology in use. The energy generation process of the Project is described below.

The amount of maximum geothermal fluid to be used in Kizildere GPP Capacity Extension project w ill be 2,800 tons/hr. Thermodynamically, the geothermal fluid w ill reach the w ell head as liquid and vapour mixture due to the effect of pressure loss and friction. The geothermal fluid w ill be transferred from production w ells to the system under high pressure, via pipelines to enter the flash system. Here, the geothermal fluid w ill first be diverted to high pressure separator and its gas/vapour and liquid phases w ill be separated. The gas/vapour phase w ill be sent to high pressure turbine w hile the liquid phase w ill enter low er pressure separators. This process w ill be repeated in intermediate and low pressure separators. The high pressure, intermediate pressure and low pressure gasses collected from the separators w ill enter the turbine system separately and w ill generate electricity; w hereas, the fluid phase collected from the final (low pressure) separator w ill be reinjected to the geothermal reservoir through reinjection w ells.

Energy generation process in the HP turbine unit w ill reduce the temperature of the gas/vapour phase to about 100°C and this exhaust steam/gas w ill be sent to the binary cycle unit. The remaining intermediate and low pressure vapour/gas mixture w ill be sent to condenser unit and the w ater that w ill be formed in the turbine unit during energy generation w ill be collected separately.

The binary unit uses a w orking fluid in a closed cycle. The exhaust steam/gas phase coming from the HP turbine w ill heat this fluid and the heated fluid w ill evaporate to generate electricity through a different turbine.

The condenser that w ill be used by the Project is an advanced, direct contact, spray jet type condenser. The w ater, vapour and gas mixture leaving the low pressure side of the turbines is sent to the condenser to be condensed by w ater coming from the cooling tow er. From here, the condensed fluid is sent to the cooling tow er for further cooling, w hereas noncondensable gasses are sent to noncondensable gas removal system. The noncondensable gas removal system increases these gasses’ pressure to a level above atmospheric pressure and the gasses leave the system here. A hybrid steam-gas ejector system that utilizes both the steam jet ejectors and Liquid Ring Vacuum Pumps (LRVPs) w ill be used.

Other units of the plant include the cooling tow er, the close cycle w ater system (the system that condenses the gasses as described above), the cooling w ater system (a separate system for cooling mechanical equipment) and the oil/w ater separator (a system designed to separate oils from w ater in case of accidents/equipment failures etc.).

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3. Project Alternatives

It is important to note that the proposed area has been chosen taking into account the geological and physical factors that favour the geothermal potential of Kizildere III GPP Site. The site does not only feature a prominent geothermal resource but also indicates a significant contribution to the economy.

Considering the geological and physical structure of the site that limits the number of alternatives to the Project, identified project alternatives are listed below :

 Site Location

 GPP Technology  Other Energy Generation Alternatives

 No Action Alternative

3.1 Site Location

Numerous location alternatives have been evaluated to provide basis for the feasibility studies carried out so far. Geothermal resource area located w ithin the Geothermal Resource Operating License Area (License #48) and hence w ithin the Project Area of the planned Kizildere III GPP, is know n to be the largest geothermal site in Turkey and the first site evaluated for energy purposes.

With regard to the feasibility and EHS performance of a GPP investment, the selected site requires to be in the same place w ith the location of the geothermal resource. Locating a GPP close to the geothermal resource it w ill also minimize occupational and community health and safety risks, since the required length of pipelines betw een the plant and the w ells can be significantly reduced, w hich in turn reduces potential of pipeline failures and associated occupational and community health and safety risks such as exposure to hot surfaces.

Follow ing aspects gain importance in site selection:

 Proximity of the pow er plant to production w ells,

 Elevation difference betw een the pow er plant site and the production w ells, effective on fluid pressures and pump suction pressure,

 Proximity of the pow er plant to re-injection w ells,

 Proximity of the pow er plant to energy transmission lines,

 Structure of land and land acquisition

 Transportation and community safety (including increased traffic load and related community health and safety risks)

Site selection and associated environmental and social impacts have been assessed by taking the account of the above aspects and considering the completed EIA and subsequent capacity increase processes.

The shortest and most secure pipeline route design w as selected to ensure minimum interaction of routes w ith communities and w ild life. In addition, construction of elevated/overhead pipelines w ill be considered in case the selected pipeline routes cross other existing infrastructure such as roads.

The selected location of the Project does not require construction of additional access roads and therefore, related emissions and traffic related risks w ill be avoided.

The Project w ill use the sw itchyard of Kizildere III GPP, w hich relays the generated electricity to the sw itchyard of Company’s Kizildere II GPP. Therefore, there is no need for a grid connection (ETL route) alternatives assessment.

3.2 GPP Technology

Prior to geothermal investments, a detailed evaluation of the data produced from production and re-injection w ells is fundamental for specification of the process technology. Geothermal pow er plants today utilize one or a combination of three categories of pow er cycles: dry-steam, flash-steam, or binary. Depending on the reservoir conditions, all these three cycles can emit GHG.

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Non-condensable gases (NCG) content is a key factor in designing turbines, condensers, gas removal systems, and hydrogen sulfide abatement systems for geothermal pow er plants. In dry and flash steam cycles, NCGs are separated from the steam turbine exhaust in the plant condenser and are either discharged to the atmosphere (air, carbon dioxide, and other nontoxic components) or removed by an abatement system (hydrogen sulfide is usually converted to solid elemental sulfur). Under certain designs, binary pow er plants retain NCGs in a closed loop system w hilst the geothermal brine is being utilized for electricity production. Eventually, if the reservoir contains higher NCG values the above mentioned closed loop is not applicable.

Three different cycle options w ere evaluated for the development of Kizildere III GPP Project considering the estimated enthalpy, chemical characteristics, and capacity of the resource: triple flash combined cycle (similar to Kizildere II), double flash combined cycle and binary cycle.

The reservoir’s temperature, pressure, fluid chemistry, including NCG content, all impact the type of pow er plant, abatement, and cooling system design appropriate for that site. GPPs that utilize an open system, such as steam and flash pow er plants, generally vent emissions to the atmosphere. Pow er plant design, in turn, also affects the amount of gaseous emissions released.

Feasibility studies indicate that the most efficient alternative for the Kizildere III GPP Project is to set up a “triple flash + binary cycle” w ith a re-injection system that w ill allow significantly high efficacy and further financial viability. Since this system reinjects the reject fluids back into the reservoir w ith no discharge to receiving environments, impacts on soil, surface w ater and groundw ater environments are avoided completely. The Project w ill also utilize drainage channels below its pipelines and tw o emergency ponds that w ill collect geothermal fluids in case of equipment failure. The collected fluids w ill also be reinjected. Reinjection practice also minimizes impacts on geothermal resource and any potential subsidence risk that may occur due to reservoir depletion. On the other hand; use of binary cycle technology together w ith triple flash technology w ill greatly increase resource efficiency. Since binary cycle technology requires significantly low er temperatures to w ork, the heat remaining in the geothermal fluid after flash steam processes can be used by binary cycle processes.

It is of technical requirement for the geothermal pow er plant investments to assess the results of short term tests among the w ells in order to specify design parameters for pow er plants. Therefore, necessary notifications w ill be made in the case of a potential change in process technology in line w ith the data obtained from drilling locations.

3.3 Other Energy Generation Alternatives

The Turkish Energy Policy draw s attention to concentrating on domestic resources for meeting the increasing energy demands through use of resource diversity. The Strategic Plan (2015-2019) of the Ministry of Energy and Natural Resources aims to encourage use of renew able energy potentials in Turkish economy. In terms of geothermal potential, Turkey ranks the 7th in the w orld and the 1st in Europe. As for electricity generation from geothermal resources, Turkey is the 12th in the w orld in terms of electrical energy production from geothermal resources w ith 490 GWh/year.

Geothermal resources and hence geothermal pow er plants provide renew able and sustainable energy capabilities that are implemented for various areas of use (e.g. Heating, greenhouse cultivation, energy generation etc.). Considering the overall impacts of energy projects on air quality, w ater quality, noise levels and other environmental components, geothermal pow er plants are know n to bring several benefits compared to its potential alternatives such as natural gas or coal plants. GPPs do not have emissions to air associated w ith the combustion of fossil fuels such as sulphur dioxides, nitrogen oxides, soot and particulate matter.

Geothermal energy helps to compensate energy-related carbon dioxide emissions, therefore has a signif icant role in improvement of public health and associated costs. Noise levels can be controlled using several methods for drilling and construction phases to effectively reduce the impacts of the Project activities.

Estimates of lifecycle greenhouse gas (GHG) emissions (gCO2 eq/kWh) for various types of electricity generation technologies are presented in Figure 4 in terms of total estimates and in Figure 5 as segregated by life cycle stage. As can be seen from the figure, renew able sources have low er GHG emissions compared to non- renew able sources.

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Figure 4. Estimates of Lifecycle GHG Emissions (IPCC, 2012)

Figure 5. GHG Emissions by Lifecycle Stage (US Department of Energy, Argonne National Laboratory, 2010)

Coupled w ith its very high capacity factor, the low er air emissions sourced from geothermal pow er technologies’ provide highly favorable benefits. Emissions from flash and dry-steam plants are approximately 5% of the carbon dioxide, 1% of the sulfur dioxide, and less than 1% of the nitrous oxide emissions from a coal-fired plant of equal energy capacity; w hereas emissions from binary geothermal plants are near zero (Holm et. Al., 2012; from GEA; 2013). Comparison of air emissions from coal, oil, natural gas and geothermal plants are summarized in Table 2.

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Table 2. Comparison of Air Emissions (kg/MWh) from Coal, Oil, Natural Gas and Geothermal Plants

System Nitrogen Oxides Sulfur Dioxide Carbon Dioxide Particulate Matter Coal 1.95 4.71 993.82 1.01

Oil 1.8 5.44 758.41 NA

Natural Gas 1.34 0.10 549.75 0.06

Geothermal/flash 0 0.16 27.22 0

Geothermal/flash+binary 0 0 0 0

System Nitrogen Oxides Sulfur Dioxide Carbon Dioxide Particulate Matter Source: Modified from GEA, 2007

Studies show that the geothermal development activities result in low er long-term land disturbance than other technologies such as coal, solar and w ind energy. Over 30 years (the period of time commonly used for comparison of life cycle impacts of various pow er generation technologies), a geothermal facility uses 404 m2 of land per gigaw att hour, w hile a coal facility uses 3632 m2 per gigaw att hour (Geothermal Energy Association, 2016). The activities that w ill be carried out in the site include exploration, drilling and construction for w hich the significant portion of the site can be reclaimed after the construction phase.

Water in geothermal systems is of primary importance as it is pumped from the geothermal system and reinjected back to the reservoir to maintain the underground pressure and prevent the depletion of the source. This makes the geothermal energy unique in providing a renew able energy using a sustainable resource, unlike fossil fuel reserves.

Another benefit of GPPs derive from the fact that w hile utilizing geothermal as a base-load operation is typical, they can also be used as flexible operations. With their very high capacity factors for energy generation, GPPs require much less transmission capacity to deliver the same amount of energy as other types of renew able resources. In addition, once the plant is operational it can be expected to provide electricity for many decades if maintained properly (GEA, 2013).

The Levelized Cost of Energy (LCOE) for a w ide range of energy generation technologies is presented in Figure 6 . As can be seen in this figure, cost of energy generation w ith flash system geothermal plants is amongst the low est in all technologies, including conventional fossil fuel pow ered plants. Cost of energy generation w ith binary system geothermal plants is a little higher; how ever, it is still significantly low er than most of the other renew able energy technologies and is still below 100 USD/MWh. In consideration of this information, it is clear that energy generation w ith geothermal is highly competitive w ith energy generation w ith fossil fuel combustion and nuclear plants, w hich have very low costs due to being established technologies that are being used for tens of years.

Considering the fact that a geothermal pow er plant’s efficiency and HSE performance significantly increase w hen it is operated in an area close to its resource and considering all of the above mentioned aspects, technical solution taken for generating geothermal energy comes out as the most convenient and efficient w ay of producing energy for the Kizildere III Project Site.

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Figure 6. Global Lev elized Cost of Energy in Q2, 2013 (USD/MWh) (World Energy Council, 2013)

3.4 No Action Alternative

In case of no action alternative, no changes w ill take place at the Project Site. This w ill eliminate the opportunity of producing energy from the regional natural resources available, w hich subsequently increases the region’s dependency on other energy sources. The socioeconomic benefits expected mainly from the operational phase and partially from the construction phase due to increase in local employment opportunities w ill not have been achieved as no area of employment for the locals and national professionals w ill be established for Kizildere III GPP.

The Project’s expected contribution to the local economy (e.g. heating/energy source for greenhouses, touristic facilities etc.) w ill not be established as it w ill further effect future investments on geothermal energy. The Project is believed to be a good opportunity for implementation of a clean, renew able and sustainable energy production alternative, w hich w ill serve as a model for future projects. This makes Kizildere III particular in creating the know - how for prospective geothermal sites to be operated.

On the other hand, the Project has low to medium level impacts on land use, air quality and community health and safety w hich w ould not have happened in its absence.

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4. Corporate Environmental and Social Management System

The operations and investments of Zorlu Enerji, as highlighted in Zorlu Enerji 2014-2015 Sustainability Report, are managed w ithin the framew ork of company’s environmental policy and principles to use energy efficiently, control emissions and protect social values including natural and cultural assets, for the ultimate purpose of sustainable grow th.

Zorlu Enerji operates in accordance w ith integrated management systems that support company’s sustainability efforts, including the ISO 9001 Quality Management System, OHSAS 18001 Occupational Health and Safety Management System, ISO 27001 Information Security Management System and ISO 14001 Environmental Management System. Pursuant to these systems, internal and external audits are conducted and annual employee trainings are organized. In addition, Zorlu Enerji Elektrik Üretim A.Ş. is the only energy company that holds an ISO 14064-1 Greenhouse Gas Emissions Standard certificate.

The detailed information regarding the corporate policies and management system of Zorlu Enerji is provided below.

4.1 Zorlu Energy Corporate Governance Structure

The Board of Directors of Zorlu Enerji Elektrik Üretim A.Ş. is responsible for corporate governance practices in line w ith the company’s economic, environmental and social performance; Chairman of the Board of Directors and Chief Executive Officer are different roles. The Chief Executive Officer (CEO) of Zorlu Energy Group is fully authorized and responsible for the management and coordination of daily activities, to the greatest extent possible. With this managerial arrangement, the executive role has been assigned to the CEO since the Board Chairman is also the Co-Chairman of the Board of Directors of Zorlu Holding. The Chairman of the Board of Directors has no executive duties. The Board of Directors consists of tw o independent members, three non- executive directors and tw o executive directors. Independent Board Members meet the criteria of independence defined in the Corporate Governance Principles of the Capital Markets Board (CMB), are selected from among business community professionals and offer an objective and independent perspective in the decision-making process for company-related matters. Board Members are remunerated in consideration of such factors as their duties, know ledge, skills and experience and the time they spend for this role, in line w ith the company’s remuneration policy. The Group’s long-term goals are taken into consideration w hen determining the principles and criteria associated w ith the remuneration of Board Members and proposing their w ages. Shareholders can contact the company directly by using the contact form on the w ebsite w hich is managed by the Corporate Communications Department. Weekly Coordination Meetings are held so that representatives from all companies and bodies of the Group can communicate, exchange information and represent their respective organization.

4.2 Zorlu Sustainability Management

According to the information provided in Zorlu Energy Group 2014-2015 Sustainability Report, the operations of Zorlu Group have been based on the principle of sustainability, encompassing its social, environmental and economic responsibilities tow ards its stakeholders. Zorlu has been implementing their principles and values on the level of global social responsibility since they signed the UN Global Compact during the foundation as part of Zorlu Holding in 2007. By signing the Global Compact, w hich is based on respect for human rights and the environment, creation of a healthy w orking environment, anticorruption, quality production and aw areness of social responsibility, Zorlu commit themselves to “being a good corporate citizen”. The companies w hose shares are traded under the BIST 100 Index at Borsa w ill be included in the BIST Sustainability Index as of October 2016. As part of the company’s sustainability efforts, Zorlu Enerji voluntarily made an application to be evaluated before that date. Accordingly, the company w as included in the “List of Companies to Be Evaluated In 2016” announced by BIST in December 2015 and the evaluation process started.

In the strategy of Zorlu Group, sustainability goals and related actions are divided into 5 main groups (See Figure 7).

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Figure 7 Sustainability Goals and Related Actions

A Sustainability Committee consisting of managers from different units of the Group w as established so that the sustainability issues in the group level could be managed more effectively and comprehensively. The Sustainability Committee of Zorlu Energy Group is chaired by the Environmental and Corporate Responsibility Manager and gathers every 3 months w ith the participation of a representative from each of the Human Resources, OHS and Quality Management Systems, Accounting, Purchasing, Investments, Electricity and Natural Gas Trade, GAZDAŞ, Risk Management, Internal Audit & Control and Legal departments and representatives of pow er plant managers.

4.3 Ethics and Compliance

Zorlu Enerji, conducts its operations in accordance w ith Zorlu Energy’s Code of Ethics, w hich has been developed by the Board of Directors and disclosed to the public via the company’s w eb site. Zorlu Energy’s Code of Ethics covers Compliance, Confidentiality and Protection of Trade Secrets, Compliance w ith Corporate Governance Principles, Employees, and Responsibilities tow ards Stakeholders, Customer Relations, and Relations w ith Competitors, Social Responsibility and the Environment.

Zorlu Energy’s Code of Ethics includes set of rules w hich have been developed in order to regulate internal relations and the relations betw een the Company and its employees and relations w ith customers, suppliers and other stakeholders, improve quality of service, ensure efficient utilization of resources and become more effective in the prevention of unfair competition.

The ethical approach of Zorlu Energy Group is founded on legal requirements and on public conscience, and all its operations are developed and guided accordingly.

Zorlu Energy Group’s Corporate Principles Document, w hich is based on the UN Global Compact, regulates the conduct of Group companies and draw s attention to business ethics under the topics of anti-corruption and respect for the environment and human rights.

4.4 Risk Management

The Corporate Risk Management applied by the Holding represents a framew ork or set of rules w hich ensures that all events w hich may hinder the Holding and Holding companies from achieving their goals are identified, evaluated and managed in a consistent, comprehensive and economical w ay. Development of this framew ork w as based on globally recognized Corporate Risk Management bodies and standards such as COSO (Committee of Sponsoring Organizations) and ISO 31000.

All risks w hich Zorlu Energy Group are exposed to be managed at a certain risk tolerance level by the Corporate Risk Management framew ork, helping the Group realize its goals and targets. With this approach, risks are not

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managed individually but as a portfolio, w ith a comprehensive assessment in w hich the relationships betw een risks are taken into consideration. In risk assessment, risks are evaluated and measured by their probability of occurrence and impact. Corporate Risk Management is intended to be independent, continuous, proactive and dynamic so that risks w hich may present a hindrance to the Group’s pursuit of its objectives can be understood, measured and assessed by the company and the necessary actions can be taken.

The Early Risk Detection Committee of Zorlu Enerji Elektrik Üretim A.Ş., w hich has been operational since 18 February 2013, is also w orking to ensure compliance w ith Article 378 of the Turkish Commercial Code, Law No. 6102, early detection of risks w hich compromise the existence and continuity of relevant companies, implementation of necessary measures and remedies, and coordinated management of such risks.

4.5 Environmental Policy

Zorlu Enerji operates w ithin the framew ork of an environmental management system that is based on raising environmental aw areness and protecting the environment and natural resources for a more livable w orld. Accordingly, in all operations of Zorlu Enerji:

 Materials and technologies are selected to minimize negative environmental impact.

 Optimum use of energy and natural resources is ensured.

 Systems are developed to prevent contamination at the source.  Wastes (solid, liquid and gaseous) are controlled and disposed of w ith no harm to the environment.

 Applicable national and international legal regulations and legislation about the environment are complied w ith.

 Employees and subcontractors are trained to raise environmental aw areness.

 Environmental impact analyses are made for new investments; technologies w hich can minimize such impact are used; and environmental management plans are prepared and implemented.

 Greenhouse gas emissions are reported, monitored and managed in a transparent w ay to reduce the impact of global climate change.

 The company’s sustainability performance is shared w ith stakeholders every tw o years in a transparent w ay in accordance w ith GRI (Global Reporting Initiative).

 Zorlu Holding is a participant of the UN Global Compact and Zorlu Energy Group annually shares its performance in this area w ith its stakeholders in a transparent manner.

 The Company has an Integrated Management System and holds TS/EN ISO 9001-2000, OHSAS 18001, ISO 14001, ISO 27001 and ISO 14064-1 certificates.

4.6 Occupational Health and Safety

At Zorlu Energy Group, utmost significance for the health and safety of the employees have taken place w ithin the framew ork of the company’s Occupational Health and Safety (OHS) Policy and OHS management system practices. There are hazard identification and risk assessment practices in place at all facilities.

According to the 2014-2015 Sustainability Report of Zorlu Enerji, in the implementation of the TS 18001 OHS Management system, the follow ing materials are prepared in accordance w ith the OHS policy and management system standard:

 OHS Project Plan

 OHS Procedures

 OHS instructions and forms.

Legal compliance charts are used to ensure that all operations of Zorlu Enerji are conducted in accordance w ith the Occupational Health and Safety legislation, and field managers are informed about any changes in legislation and actions required to be taken.

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Accident investigations and root cause analyses are made after occupational accidents to find out the real causes of incidents and accidents and prevent them from reoccurring; reports so prepared are submitted to senior management.

Occupational Safety Specialists, On-Site Physicians and healthcare staff provide their services and risk analyses and emergency plans are prepared by the teams at all facilities. OHS training is provided to all employees of sub- contractors.

In order to ensure that risky tasks are handled under safer conditions, Task Authorization Procedure is taken in place and task authorization forms are used before starting risky tasks.

Trainings such as emergency intervention, firefighting, and w orking at heights, first aid and behavior-based occupational safety trainings are offered.

The Zorlu Enerji “Emergency Management and Intervention Procedure” has been prepared and all locations are in the process of preparing their ow n specific emergency action plans in accordance w ith the legislation. In accordance w ith the emergency action plans, periodic drills are done according to a scenario and periodic hands - on fire-fighting trainings are given. All employees have been informed about the emergency management system.

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5. Compliance with EBRD Performance Requirements

5.1 Air Emissions

Primary pollutants for the Project w ith regards to air quality w ill be dust (PM10 and settled dust) generated during land preparation and construction activities and H2S emissions during operation phase. Emissions of CO2 are addressed in terms of their contribution to greenhouse gas emissions.

The dust associated w ith the construction phase of the Project is estimated using AERMOD w ithin the scope of Turkish EIA for Kizildere III GPP Capacity Increase Project.

According to the modelling results for land preparation and construction periods of the Kizildere III GPP (unit 1 and unit 2), short term value of PM10 (13.87 µg/m3) does not exceed the limit stated Turkish Industrial Air Pollution Control Regulation (IAPCR) w hich is 50 µg/m3 . Long term value of PM10 (1.79 µg/m3) is below the IAPCR limit (40 µg/m3).

Short term value of settled dust (48.24 mg/m3day) is below the IAPCR limit w hich is 390 mg/m3day and long term value of settled dust (9.16 mg/m3day) does not exceed the limit stated in IAPCR as 210 mg/m3day.

Modelling studies for H2S emissions w ere conducted considering cumulative impacts due to operation of Kizildere I, II, III (unit 1 and unit 2) and IV. Short term value of H2S emissions (66.43 µg/m3) is below the IAPCR limit w hich is 100 µg/m3 and long term value of H2S (6.55 µg/m3) does not exceed the limit stated in IAPCR as 20 µg/m3.

5.2 Greenhouse Gas Emissions

This section presents an assessment of the potential greenhouse gas (GHG) emissions associated w ith the exploration, construction and operation phases of Kizildere III GPP Capacity Extension Project. The baseline conditions and existing carbon offset strategies have been taken into consideration in order to assess the total annual GHG emissions per MWh energy produced from Kizildere III GPP (including unit 1 and unit 2 corresponding to the capacity extension phase) projects.

EBRD’s Methodology for Assessment of GHG Emissions (Version 7, 6 July 2010) w as used as guidance in the assessments carried out in this section of the report. GHG emissions are categorized into three different scopes – Scope 1, Scope 2 and Scope 3 – according to the GHG Protocol, developed by World Resources Institute (WRI) and World Business Council on Sustainable Development (WBCSD):

 Scope 1 describes ‘direct’ greenhouse gas emissions from sources that are ow ned by or under the direct control of the company. The quantification of Scope 1 emissions is considered mandatory by the GHG Protocol.

Scope 1 emissions are included w ithin the scope of this study.

 Scope 2 describes ‘indirect’ greenhouse gas emissions associated w ith the Project that are a consequence of the activities of the company, but occur at sources ow ned or controlled by another company. Emissions associated w ith the generation of purchased electricity that is consumed by the reporting company are reported in scope 2. The quantification of Scope 2 emissions is also considered mandatory by the GHG Protocol.

Since the facility consumes the electricity it produces and does not purchase electricity, Scope 2 emis sions are not included in this study.

 Scope 3 describes w ider greenhouse gas emissions that occur along the value chain. The quantification of Scope 3 emissions considered optional by the GHG Protocol.

Scope 3 emissions consisting of the upstream emissions associated w ith the provision of materials used by the project and the dow nstream emissions from the use of the goods and services generated by the project are not included w ithin the scope of this study.

Figure 8 provides the relationship betw een Scope 1, Scope 2 and Scope 3 emissions and the activities that generate direct and indirect emissions along a company’s value chain.

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Figure 8. Overview of Scope 1, Scope 2 and Scope 3 Emissions across a Company’s Value Chain

Source: Greenhouse Gas Protocol Corporate Accounting and Reporting Standard

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GHGs include not only carbon dioxide emissions, but five of the six gases addressed in the Kyoto Protocol. These gases are:

 Carbon dioxide (CO2);

 Methane (CH4);

 Nitrous oxide (N2O);

 Sulfur hexafluoride (SF6);  Hydro fluorocarbons (HFC); and

 Per fluorocarbons (PFC).

It is noted that HFC and PFCs are not emitted by any process associated w ith the Project; thus, are not considered any further w ithin the assessment.

Non-CO2 GHGs are calculated as “CO2-equivalence” (CO2-e) based on their contribution to the enhancement of the greenhouse effect. The CO2-equivalence of a gas is calculated using an index called the Global Warming Potential (GWP). The GWPs for a variety of non-CO2 GHGs are contained w ithin IPCC Guidelines for National Greenhouse Gas Inventories (IPCC, 2006) 1. The GWPs of relevance to this assessment are presented in Table 3 below.

Table 3. Global Warming Potentials

Gas Chemical Formula IPCC 2014 Global Warming Potential

Carbon dioxide CO2 1

Methane CH4 28

Nitrous oxide N2O 265

Source: IPCC Fifth Assessment Report, 2014 (AR5)

5.2.1 GHG Emissions from GPPs

Geothermal utilization, particularly pow er production, may result in some GHG emissions. GHG emissions from geothermal pow er production is generally small in comparison to traditional base load thermal energy pow er generation facilities (ESMAP, 2016).

The unique resource chemistry associated w ith individual geothermal field, including the resource temperature and rock type in the reservoir, and other factors such as the type of GPP technology built-in (dry steam, flash, binary), affects the amount of GHGs emitted into the air.

Geothermal systems are natural sources of GHGs, thus, understanding how natural emissions are altered by industrial utilization w ould require a baseline determination prior to GPP development since GHGs are present in both producing and non-producing geothermal fields.

Kizildere Geothermal Field is the first field developed in Turkey. The field is situated in the Büyük Menderes graben, near the city of Denizli in w estern Anatolia. Kizildere has been proven as a high temperature, hot-w ater dominated geothermal field (Şimşek, Ş, 1985).

Assessment of the potential GHG emissions associated w ith the exploration, construction and operation phases of Kizildere III GPP capacity extension Project have been made taking into account baseline conditions and existing carbon offset strategies.

EBRD’s Methodology for Assessment of GHG Emissions (Version 7, 6 July 2010) w as used as guidance in the assessments. Projects in the medium-high and high categories are subject to mandatory GHG assessment under the EBRD Environment and Social Policy (2014).

5.2.2 Baseline (Reference) Emissions

The baseline emission is a representative pre-project emission, usually zero w here the project is a green-field development or the facility annual emissions pre-investment w here the project comprises upgrading or refurbishment.

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For the purposes of this report, the baseline emissions are taken as the GHG emissions originating from Kizildere I and Kizildere II GPPs that are in operation and presented in Table 4 below.

Table 4. Exploration Phase Combustion Related GHG Emissions

Total Annual Emissions from Total Output *Total Output Project Operation MWe GWh (tonnes CO2-e)

Kizildere I 15 121 52,508 Kizildere II 80 645 379,020 TOTAL 95 766 431,528 *According to Energy Market Regulatory Association, Council Decision No: 4709 -2 dated October 21, 2013), capacity factor for geothermal is 92%.

Source: Zorlu Doğal Elektrik Üretimi A.Ş

For the baseline conditions, GHG emissions per MWh energy produced for Kizildere I and Kizildere II projects is calculated as 0.56 tonnes CO2-e (per year) per MWh.

5.2.3 Exploration Phase of Kizildere III GPP Capacity Extension Project

Scope 1 GHG emissions resulting from the combustion of diesel fuel during the exploration phase of the Project have been accounted for using emission factors in IPCC (2006) and presented in Table 5 below.

Table 5. Exploration Phase Combustion Related GHG Emissions

Estimated *Emission Factor (kg/TJ fuel) Total Emissions Total (tonnes CO -e/month) Source 2 Fuel Use (kL/month) CO2 CH4 N2O

Service vehicles and rental 3 74,100 3.9 3.9 8 trucks Generators for drilling rigs 270 74,100 3.0 0.6 736.49 TOTAL 744.77

*IPCC 2006

Information related w ith venting of NCGs during exploration phase is presented in Table 6.

Table 6. Exploration Phase Information for Venting of NCGs

Total Geothermal NCG Percentage NCG Stream Well Test Duration for Fluid Flow Rate of Geothermal Fluid (tonnes/hour) Each Well (tonnes / hour) (Mass Percentage) (days)

2,209 2.9 % 64.04 5

Source: Zorlu Doğal Elektrik Üretimi A.Ş

Information on NCG (including CO2 and CH4) emitted during exploration phase is presented in Table 7 below.

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Table 7. NCG Information (for exploration phase)

Molecular Weight of Mol per Hour Mol Percentage Tonnes per Hour One Mole NCG

CO2-e CH4 CO2 CH4

43.85* 1,460,464 0.99275 0.00286 63.7945 0.0668

* Molecular Weight of CO2 =44 gr/mol, Molecular Weight of CH4 =16 gr/mol

Source: Kizildere III GPP Capacity Extension Project National EIA Report (2016)

As a result:

 The GHG emission equivalent for the exploration phase of Kizildere III GPP Capacity Extension Project from combustion related emissions is calculated as 8,937 CO2-e for 12 months.

 The GHG emission equivalent for the exploration phase of Kizildere III GPP Capacity Extension Project from NCGs is calculated as 7,880 CO2-e.

5.2.4 Construction Phase of Kizildere III GPP Capacity Extension Project

Kizildere III GPP Capacity Extension Project w ill result in emissions of GHGs during the construction phase. Potential effects may occur from increased fuel consumption during the construction phase due to the increased amount of vehicles and diesel-run equipment. The construction activities involved in the construction phase w hich have the potential to contribute to existing GHG levels include general earthw orks for w ell areas and plant site preparation and construction.

These construction activities w ill require the use of a number of pieces of heavy construction equipment and vehicles. The large diesel pow ered equipment w ill generate combustion gases including CO2 and N2O. In addition, the use of vehicles w ill also generate CO2 and N2O emissions as they travel to and from, as w ell as on, the construction site. Total emissions generated due to the use of heavy construction equipment and vehicles for pow er plant construction and commissioning and the use of generators are presented in Table 8 below.

Table 8. Construction Phase Combustion Related GHG Emissions

Estimated Total Total Emission Factor (kg/TJ fuel) Emissions Source Fuel Use (tonnes CO2-e)

(kL/month) CO2 CH4 N2O

Pow er Plant Construction 19 74,100 3.9 3.9 1,049 and Commissioning Generators 1 74,100 3.0 0.6 55 TOTAL 1,104

Source: IPCC 2006

As a result:

 The GHG emission equivalent for the construction phase of Kizildere III GPP Capacity Extension Project from combustion related emissions is calculated as 1,104 CO2-e for 20 months.

5.2.5 Operation Phase of Kizildere III GPP Capacity Extension Project

Kizildere III GPP Unit 1 and Unit 2 w ill collectively produce 165 MWe energy, 130 MWe through triple flash system and 35 MWe energy through binary cycle system.

The plant integrates tw o systems: flash steam generation system that uses steam under high pr essure; plus binary cycle pow er generation system that uses flash turbine exhaust steam to vaporize a w orking fluid w ith a low er boiling point and use it to drive a turbine.

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Information related w ith geothermal fluid is given in Table 9 below.

Table 9. Operation Phase Information

Total Geothermal NCG Percentage NCG Stream Fluid Flow Rate of Geothermal Fluid (tonnes/hour) (tonnes / hour) (Mass Percentage)

2,209 2.9 % 64.04

Source: Zorlu Doğal Elektrik Üretimi A.Ş

Information on NCG (including CO2 and CH4) emitted during operation phase is presented in Table 10 below.

Table 10. NCG Information (for operation phase)

Mol Percentage Tonnes per Hour **Tonnes per Year Molecular Weight Mol per of One Mole NCGs Hour CO2 CH4 CO2 CH4 CO2 CH4

43.85* 1,460,463.9 0.9928 0.0029 63.79 0.0668 514,132.81 538.60

* Molecular Weight of CO2 =44 g/mol, Molecular Weight of CH4 =16 g/mol **Capacity factor is 92% (Energy Market Regulatory Association, Council Decision No: 4709 -2 dated October 21, 2013)

Source: Kizildere III GPP Capacity Extension Project National EIA Report (2016)

As a result:

 The GHG emission equivalent for the operation phase of Kizildere III GPP Capacity Extension Project from NCGs is calculated as 529,213.69 tonnes CO2-e (per year).

5.2.6 Carbon Offset Strategy

Within the scope of Kizildere GPP Projects, the Company has already in place carbon offset strategies as summarized in Table 11 below.

Table 11. Carbon Offset Strategy

Offset Strategy Offset Amount (tonnes CO2-e)

CO sales to Linde (per 2 110,000.00 year)

Source: Zorlu Doğal Elektrik Üretimi A.Ş

As an offset strategy, the gas captured at Kizildere II GPP is commercialized for dry ice production. This amounts to 110,000 tonnes CO2-e per year. Kizildere III GPP (Unit 2) w ill operate at a load factor of 92%.

5.2.7 GHG Emissions Summary of Kizildere III GPP Capacity Extension Project

The summary of the GHG emissions originating from the exploration, construction and operation phases of Kizildere III GPP Capacity Extension Project is given Table 12 below.

Table 12. Summary of GHG Emissions of Kizildere III GPP Capacity Extension Project

Project Phase Duration Total Emissions (tonnes CO2-e) Exploration Phase 12 months 8,937 (Non-road Diesel Engines Combustion)

Exploration Phase (NCGs) 5 days 7,880 Construction Phase 20 months 1,104 (Non-road Diesel Engines Combustion) Operational Phase 529.213 (per annum)

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Project Phase Duration Total Emissions (tonnes CO2-e)

5.2.8 GHG Emissions Assessment of Kizildere III GPPs

A summary of GHG emissions from Kizildere GPPs is given in Table 13 below.

Table 13. GHG Emissions Assessment of Kizildere III GPPs

Item Total Output tonnes CO2-e tonnes CO2-e per MWh GWh

Baseline Emission 121 52,508 0.43 (Kizildere I GPP) Baseline Emission 645 379,020 0.59 (Kizildere II GPP) Kizildere III GPP (unit 767 733,089 0.96 1) Kizildere III GPP 564 529,214 0.94 Capacity Extension (unit 2) Carbon Offset - -110,000

Total Balance 2,097 1,583,831 0.76

Annual GHG emissions per MWh energy produced for Kizildere III GPP Project (including both Unit 1 and Unit 2 corresponding to capacity extension) is calculated as 0.76 tonnes CO2-e per MWh.

The CO2 grid emission factor in Turkey is around 0.5 t CO2/MWh (Development of the electricity carbon emission factors for Turkey, EBRD, 2015).

5.2.9 CO2 Evolution over Time

The initial CO2 concentration and evolution over time diverges per w ell and reservoir. The trend in Kizildere geothermal field for the period 1987-2007 has been reported previously under PLUTO framew ork (EBRD, 2016). Additionally, recent measurements (mid 2012 to mid 2016) at the Kizildere field reveal the reduction trend in w eight of CO2.

“Modeling Study on the Production and Reservoir Performance of the Kizildere Geothermal Reservoir” study w as conducted by Istanbul Technical University (ITU) in October 2016.

A lumped parameter model w as run using historic production, reinjection and net production rate data as given in Figure 9.

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Figure 9. Production and Reinjection Flow rate History (ITU, 2016)

As indicated in the report, good history match w as obtained and the model w as calibrated accordingly. An advantage of the lumped parameter model is highlighted as the fact that it can be used to estimate the magnitude of the production operations in the neighboring lease (tw o pow er plants each w ith an installed capacity of 13 MWe).

The modeling study predicted the effects of CO2 content of the reinjection w ater and the existence of natural recharge on the reservoir w ater CO2 content as a function of time as given in Figure 10.

Figure 10. Effects of CO2 Content of the Reinjection Water and the Existence of Natural Recharge on the Reservoir Water CO2 Content as a Function of Time (ITU, 2016)

As given in Figure 10, the initial CO2 in reservoir w ater is 2.1%. Taking a reinjection ratio of 0.5%, the CO2 in reservoir w ater is estimated as 1.7%, 1.45% and 0.9% for the 5th, 10th and 30th years of operation, respectively, as given in Table 14.

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Table 14. % of NCG Change w ith Time

Item Current (% of NCG) Year 5 (% of NCG) Year 10 (% of NCG) Year 30 (% of NCG)

Model Value 2.1 1.7 1.45 0.90

Kizildere I 0.58 0.58 0.58 0.58

Kizildere II 1.98 1.70 1.45 0.90

Kizildere III (Unit 1) 2.90 2.35 2.00 1.24

Kizildere III Capacity 2.90 2.35 2.00 1.24 Extension (Unit 2)

Taking into account the dissolved CO2 content change, the CO2 reduction trend for the Kizildere GPPs and the resulting CO2 emission after 5, 10 and 30 years of operation is estimated as given in Table 15.

Table 15. CO2 Evolution of Kizildere GPPs

Item Year 5 Year 10 Year 30 tonnes CO2-e per MWh tonnes CO2-e per MWh tonnes CO2-e per MWh

Kizildere I 0.43 0.43 0.43

Kizildere II 0.51 0.43 0.27

Kizildere III (Unit 1) 0.77 0.66 0.41

Kizildere III Capacity Extension 0.76 0.65 0.40 (Unit 2)

Carbon offset -110,000 -110,000 -110,000

TOTAL GPPs 0.62 0.52 0.32

As can be seen from Table 15 above, in the long run, the CO2 emissions w ill be approaching the existing CO2 grid emission factor in Turkey w hich is 0.5 t CO2/MWh (Development of the electricity carbon emission factors for Turkey, EBRD, 2015).

In 2011, Zorlu Enerji has become the first energy company in Turkey to calculate its carbon footprint. Zorlu Doğal, a subsidiary of Zorlu Holding, has seven hydroelectric pow er plants (HPP) and three GPPs. An assessment for Kizildere III GPP has been conducted taking into account overall footprint of Zorlu Doğal energy projects. Taking into account all the Projects of Zorlu Doğal, the annual GHG emissions per MWh energy produced for Kizildere III GPP Project (including both unit 1 and unit 2 corresponding to capacity extension) is calculated as 0.65 tonnes CO2-e per MWh.

According to the “EBRD Methodology for Assessment of Greenhouse Gas Emissions (Version 7, 6 July 2010)”, projects are categorized in terms of annual GHG emissions as:

 Negligible (no GHG assessment necessary)

 Low (< 20 kt/y CO2-equivalent per year)  Medium-Low (20 – 100 kt CO2/yr)  Medium-High (100 kt – 1 Mt CO2/yr)  High (>1 Mt CO2/yr)

Kizildere III GPP Capacity Extension Project has total annual GHG emission of 529,214 tonnes CO2-e. Thus, the Project falls under Medium – High Category (100 kt - 1 Mt CO2-e per year) according to the EBRD Methodology for Assessment of Greenhouse Gas Emissions (2010) guideline.

The total GHG emissions of Zorlu Doğal energy generation facilities including GPPs is calculated as 1,583,831 tonnes CO2-e per year and falls under High Category.

Projects in the medium-high and high categories are subject to mandatory GHG assessment under the EBRD Environment and Social Policy (2014).

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5.3 Surface Water and Groundwater Environment

There are various issues associated w ith GPPs’ construction and operation phase activities, regarding w ater use and surface w ater/groundw ater quality. Any potential impact on w ater quantity/quality that may potentially be sourced from Kizildere III GPP’s construction/operation activities are summarized below.

 Both construction phase and operation phase utility w ater and drinking w ater for the personnel w ill be supplied by purchasing and no groundw ater or surface w ater resource w ill be used for this purpose.

 A closed cooling system that circulates the cooling w ater w ill be used during the operation phase of the Project to reduce the temperature of geothermal fluids. Therefore, the w ater required for the cooling unit w ill be procured just once and the system w ill not require any additional w ater afterw ards.

 Ponds covered w ith impermeable geomembrane layers w ill be constructed in drilling locations to collect drilling mud. The drilling mud collected in these ponds w ill be analyzed by licensed laboratories for identification of their storage classes. In case the related analysis results prove the mud in question is nonhazardous, the ponds w ill be covered w ith excavation materials below and topsoil at top and w ill be vegetated. In case the mud is classified to be hazardous, it w ill be sent to licensed disposal firms.

 The Project w ill utilize deep, high temperature groundw ater for energy generation, w ith fourteen production w ells. Eight reinjection w ells w ill be used to reinject the spent fluids back in to the deep reservoir. The w ells w ill be constructed w ith leak-proof w ell casings in order to ensure no interaction of deep and shallow groundw ater resources. In addition to the 20,000 m3 capacity storage pond that is being constructed w ithin the scope of Kizildere III GPP Unit 1, an additional 10,000 m3 capacity storage pond is planned to collect geothermal fluids in case of a rare emergency such as a w ell blow -out. In addition, all production w ill be halted in case of any emergency situation w here this storage capacity is likely to be surpassed. The fluid w ithheld in the emergency pond w ill be reinjected back to the system.

 Some test studies w ill be conducted for determination of characteristics of geothermal w aters that w ill be utilized. The test w ater w ill be stored in the above mentioned ponds and w ill be reinjected through reinjection w ells. In case the total capacity of the ponds is surpassed during tests, an additional impermeable pond w ill be constructed to collect test w aters. The w ater collected in this additional pond w ill be discharged to receiving environments only after the limit values provided by related national legislation for geothermal energy generation facilities are achieved.

 A package w astew ater treatment plant w ill be constructed for treatment of domestic w astew ater that w ill be generated during construction and operation phases of the Project. The treated w astew ater w ill be discharged to the nearest surface w ater body, in compliance w ith limit values provided by national legislation.

 Hazardous w aste w ill be temporarily stored in temporary storage areas and w ill be disposed of by licensed disposal firms. These storage areas w ill be constructed in line w ith national legislation to avoid any leakage. It should be noted that no hazardous materials w ill be used for energy generation purposes. In addition, the fuel requirements of construction vehicles and vehicles that w ill be used during operation phase w ill be supplied from nearby fuel stations and therefore, there w ill be no fuel storage on site.

5.4 Biodiversity and Living Natural Resources

This section of the report outlines the biodiversity assessment of Kizildere III GPP Capacity Extension Project in line w ith EBRD PR6. Within the scope of this Project, a local EIA study w as conducted and baseline biodiversity assessment in line w ith the Turkish EIA legislative requirements w as made. Flora/fauna surveys w ere conducted in May 2014.

The European Bank for Reconstruction and Development’s (EBRD) Environmental and Social Policy (ESP, 2014) commits the Bank to “be precautionary in its approach to the protection, conservation, management and sustainable use of living natural resources and w ill require relevant projects to include measures to safeguard and, w here feasible, enhance ecosystems and the biodiversity they support.”

To help implement these commitments at the project level, the ESP includes Performance Requirement (PR) 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources (EBRD Guidance Note, Biodiversity Conservation and Sustainable Management of Living Natural Resources). This Performance Requirement (PR) recognizes that the conservation of biodiversity and sustainable management of living natural

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resources are fundamental to environmental and social sustainability (EBRD Performance Requirement 6, Biodiversity Conservation and Sustainable Management of Living Natural Resources).

The objectives of this PR are to:

- Protect and conserve biodiversity using a precautionary approach

- Adopt the mitigation hierarchy approach, w ith the aim of achieving no net loss of biodiversity, and w here appropriate, a net gain of biodiversity

- Promote good international practice (GIP) in the sustainable management and use of living natural resources.

Some key concepts relevant to PR6 are summarized below.

Mitigation hierarchy - A tool commonly applied in Environmental Impact Assessments (EIAs) w hich helps to manage biodiversity risk. Includes measures taken to avoid impacts to biodiversity from the outset of development activities and, w here this is not possible, to implement measures that w ould minimize, then reinstate and, as a last resort, offset any potential residual adverse impacts

Biodiversity offsets - Measurable conservation outcomes resulting from actions designed to compensate for significant residual adverse biodiversity impacts. These residual impacts may result from projec t development after appropriate prevention and mitigation measures have been taken into account. The goal of biodiversity offsets is to achieve “no net loss” (see definition below ) and preferably a net gain of biodiversity on the ground. The characteristics of offsets could include those designed to improve species composition, habitat structure and ecosystem function and people’s use and cultural values associated w ith biodiversity.

No net loss - The point at w hich project-related impacts on priority biodiversity features are reduced by avoidance, minimization and/or reinstatement measures, and offsetting compensates fully for all significant residual impacts – that is to say, no significant net impacts on biodiversity remain.

Net gain - Going beyond “no net loss”, through achievement of additional conservation outcomes for the biodiversity features for w hich critical habitat w as designated. Net gains w ill usually be achieved through the development of a biodiversity offset.

The below subjects outline the baseline biodiversity assessment given in this report:

1. Update of flora/fauna species identified in the Project Area and its vicinity

2. Identification of Priority Biodiversity Features

3. Identification of Critical Habitats

4. Habitat Assessment in the Project Area and its vicinity

5.4.1 Baseline Biodiversity Assessment in line with EBRD PR6

Flora/fauna Species

Flora/fauna survey results given in the local EIA Report is review ed and updated taking into account CITES, EU Habitats and Birds Directives. This w as also review ed by AECOM. Summary of the findings are given in Appendix A

Identification of Priority Biodiversity Features

Priority biodiversity features have a high, but not the highest, degree of irreplaceability and/or v ulnerability. Although a level below critical habitat in sensitivity, they still require careful consideration during project assessment and impact mitigation. The assessment of priority biodiversity features in the Project Area and its vicinity is given in Table 16

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Table 16. Assessment of Priority Biodiversity Features in the Project Area and its Vicinity

Priority Biodiversity Features Kizildere III GPP Capacity Extension Project and its vicinity

(as per EBRD PR6, 2014)

Threatened habitats No natural and/or priority habitats identified under the EU Habitats Directive (Annex I) occur w ithin the Project area.

Vulnerable species Testudo graeca (Spur-thighed Tortoise) is a reptilian species listed as Vulnerable (VU) by the International Union for Conservation of Nature (IUCN).

Significant biodiversity features There are tw o nationally protected areas w ithin 100 km radius identified by a broad set of surrounding the Project area w hich are Çağlayan Nature Park (at 29.5 stakeholders or governments km distance) and Şarlan Nature Park (at 64.2 km distance). These areas are already mentioned in the local EIA.

In addition to these areas, Akdağ Key Biodiversity Area (KBA) is located at approximately 7 km distance on the southern w est side of the Project.

Most of the species triggering the determination of the KBA are not considered to be occurring in the Project area due to non-suitable habitat characteristics and elevation for these species. How ever, Montivipera xanthine (Ottoman viper) (endemic) should be monitored periodically during the lifetime of the Project w hether it is observed w ithin the Project area. Since the species is poisonous and there is a potential of people to kill it for safety reasons, the increased human activity in the vicinity due to the Project might be threatening for the species.

Ecological structure and NA functions needed to maintain the viability of priority biodiversity features

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Identification of Critical Habitats

Areas identified as critical habitat hold the highest tier of irreplaceable (existing in few places) and vulnerable (at high risk of being lost) biodiversity features. The assessment of critical habitat features in the Project Area and its vicinity is given in Table 17

Table 17. Assessment of Critical Habitat Features in the Project Area and its Vicinity

Critical Habitat Features Kizildere III GPP Capacity Extension Project and its vicinity

(as per EBRD PR6, 2014)

Highly threatened or unique No EN or CR species identified. ecosystems

Habitats of significant importance Pelobates syriacus, Hyla arborea, Pseudepidalea viridis, Ablepharus to endangered or critically kitaibelii have Annex IV status according to EU Habitats Directive List. endangered species

Habitats of significant importance Akdağ – Denizli KBA (at 4 km distance to the Project) to endemic or geographically restricted species Boz Mountains KBA (at 35 km distance to the Project)

None of the above listed KBAs are global-level KBAs

There isn’t an Alliance for Zero Extinction site

Habitats supporting globally No w etlands in the Project Area and its vicinity. significant migratory or congregatory species

Areas associated w ith key NA evolutionary processes

Ecological functions that are vital NA to maintaining the viability of biodiversity features described (as critical habitat features)

Invasive Alien Species

Invasive alien species are defined as non-native species that pose a risk of spreading quickly can create significant environmental and socioeconomic impacts (for example, crop pests, disease vec tors, new predators). None identified during the local EIA and in the databases as referred in EBRD PR6.

Habitat Assessment

The habitat assessment and the land cover classes revealed that the dominant habitat type in the Project area is modified habitat. Although there are small patches of natural habitats mixed w ith the modified habitats, they don’t constitute a significant ecological importance. According to the results of the habitat assessment considering mainly the Corine Satellite Land Cover Map (see Figure 11), the total calculated habitat loss can be considered of minor importance as the total habitat loss of the three main habitat types due to construction w ill not be more

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than 2% in Denizli and 0.2% in Turkey (see Table 18). Moreover, the pipeline w ill not have a habitat loss impact since its relationship w ith the ground w ill be minimum.

A major fragmentation in the habitat is not considered to occur due to the pipeline since the design of the pipeline layout enables the w ildlife passage.

Zorlu Enerji w ill ensure that the existing biodiversity elements identified during the local EIA process are assessed in line w ith EBRD PR6 requirements including habitat assessment and species distributions. Depending on the results of the assessment Biodiversity Management Plan and/or Biodiversity Action Plan for the management of biodiversity elements w ill be prepared.

According to the results of the habitat assessment considering mainly the Corine Satellite Land Cover Map (see Figure 11).

5.4.2 Overall Biodiversity Assessment

The habitat assessment and the land cover classes revealed that the dominant habitat type in the Project area is modified habitat. Although there are small patches of natural habitats mixed w ith the modified habitats, they don’t constitute a significant ecological importance. According to the results of the habitat assessment, the total calculated habitat loss can be considered of minor importance.

Amongst the bird species identified in the local EIA study; Rock Partridge (Alectoris graeca) is a coincidental migrant species in Turkey and the habitat preferences of the species do not entirely overlap w ith the Project Area.

It has NT (Near threatened) status according to its last assessment in 2012 by IUCN Red List despite it is given as it has LC (Least concern) status according to IUCN Red List in the EIA report.

It is advised to monitor the existence of this species in the Project Area during w inter. The species is an altitudinal migrant that migrates to low altitudes and might be seen at low altitudes w here the Project area is located in only in w inter period.

Depending on the results of the assessment Biodiversity Management Plan and/or Biodiversity Action Plan for the management of biodiversity elements w ill be prepared.

The impact on living natural resources (agricultural lands, fruit trees and berry plantations that the w ells w ill be operating) is considered to be minor as the percentage of loss of these habitat types w ill not be more than 2% in Denizli in total. Moreover, the management of the living natural resources through the application of national regulatory requirements and relevant EU substantive environmental standards, as applicable w ould enable no net loss on them.

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Figure 11 Habitat Assessment Map (deriv ed from Corine Satellite)

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The total calculated habitat loss can be considered of minor importance as the total habitat loss of the three main habitat types due to construction w ill not be more than 2% in Denizli and 0.2% in Turkey and is given in Table 18 below.

Table 18 Land Cover Assessment due to Habitat Loss

Land Cover of the Facility Type Corine Land Land Cover in Land Cover in Construction in Percentage of Percentage of EU Habitat ID Corine Land Cover Class 2 2 leading to Cover Code Turkey (m ) Denizli (m ) the Project Area Loss in Denizli Loss in Turkey 2 Habitat Loss (m )

212 EU-669834 Permanently irrigated land 69,809,952,002.55 1,205,682,736.86 95,430 1.727 0.0001 Well

65,941 0.063 0.0005 Well

Fruit trees and berry 222 EU-670117 12,286,964,217.31 104,995,399.28 Capacity Increase plantations 178,760 0.170 0.1703 Area and Sw itchyard

Land principally occupied by 243 EU-673835 agriculture, w ith significant 72,530,195,437.38 1,259,475,868.37 10,001 0.001 ~ 0 Well areas of natural vegetation

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5.5 Labour and Working Conditions

Zorlu Energy Group has in place a comprehensive Human Resources Policy that is responsible tow ards group companies, sensitive to employees and respectful to all stakeholders. The HR policy is based on quality w ork on human resources, regularly updated, aims to increase effectiveness and efficiency in all matters of human resources, uses technology and advanced methods in servicing and communicating w ith employees and developing systems and establishing suitable w ork environments.

Based on its HR Policy, Zorlu Enerji aims to safeguard convenient w ork environment and equal opportunity to its employees, and to ensure their health and safety and invest in their development.

Employees’ health and safety is one of the fundamental elements of priority in Zorlu Energy Group’s activities. Zorlu Energy Group has carried out hazard identification and risk assessment studies in all sites of activity w ith respect to Occupational Health and Safety.

Based on its corporate level Health and Safety Policy, Zorlu Energy includes all employees in identifying hazards; mitigates the negative impact of activities on health, all employees, contractors, clients; ensures that subcontractors are informed on health and safety systems, and prevents the recurrence of incidents and accidents. Zorlu Enerji rew ards persons contributing to the improvement of health and safety issues. Corporate HS policy also aims that OHS Management System practices are constantly and regularly revised, supervised and improved.

Managers assigned to all w ork sites of Zorlu Energy Group are responsible for ensuring the implementation of the group policies in their units and taking necessary actions in relation to their operations.

Observing fundamental human rights established by international rules and supporting the protection of such rules are the prime principles of Zorlu Energy Group. Respecting the variety of employees including race, origins, religious belief, gender, social status, nationality, age, physical disabilities and deficiencies and opposing all forms of discrimination, Zorlu Energy Group offers, as part of its employer commitment, equal opportunity to all employees, evaluating all based on performance rather than origins and beliefs. Protecting the reputation, privacy and personal rights of individuals, Zorlu Energy Group offers the same reflection as the organization to all employees.

Zorlu Energy Group safeguards Labour conditions by a series of principles adopted at all projects, including:

No Forced Labour: No individual is forced against their w ill to perform tasks outside their terms of reference,

No Child Labour- No one under age 18 is employed by Zorlu Energy and its contractors

Ethical Code: Employees are not allow ed to accept or request gifts, personal benefits or accommodation from any internal or external party w hich may influence the business and processes in breach of applicable law s and customary business practices.

Human Rights: Group accepts every employee’s right to support social movements as citizens. How ever, employees cannot offer or provide any moral or material commitments to such political activities on behalf of the company. The Company pays attention to the complete and timely fulfillment of the employee rights and benefits attained under the related acts.

Equal Opportunity: Zorlu Enerji respects the variety of employees including race, origins, religious belief, gender, social status, nationality, age, physical disabilities and deficiencies and opposing all forms of discrimination. The Group offers, as part of its employer commitment, equal opportunity to all employees, evaluating all based on performance rather than origins and beliefs.

The Corporate Principles Manual of Zorlu Group includes ethical rules and human rights w hich set the frame for labour policies in general. According to the manual, Zorlu Group does not limit freedom of its employees for association and right to organize, and does not practice any type of forced labour. The Group companies comply w ith national law s and regulations w ith respect to w orking hours, w ages, minimum age limitations and elimination of child labour.

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5.6 Health and Safety

Zorlu Enerji has in place an HSE Management Plan for the Project. The management plan is inclusive of, but not limited to:

 Organizational setup that describes in detail the responsibilities for each person assigned,

 Contractor and sub-contractor responsibilities,

 Procurement management,

 Hazardous Chemicals Management Plan,

 Site control and monitoring procedures,

 Traffic Management Plan,

 Training Procedures.

HSE Management System specification for contractors, as a separate document, details contractor responsibilities in relation to HSE management activities. The specification is based on the Quality, Health, Safety and Environment Policy and HSE Commitment of Zorlu Industrial. Zorlu Industrial holds certifications for OHSAS 18001, ISO 9001 and ISO14001 management systems.

The HSE System requires the contractor to prepare project specific HSE Plan, to undertake regular HSE audits, providing the necessary trainings, safety w arnings and taking pre-cautions in its responsibilities for preventing dangerous situations and actions.

As for compliance w ith national legislation, the EIA Report for the Extension Project commits that H&S measures w ill be taken in all types of operations, including the construction stage, in compliance w ith pertinent national legislation under the Labour Law (No. 4857) of 2003. A medical unit w ill be provided for small accidents. Access w ill be ensured to nearest health organizations in case of major accidents.

Community Health and Safety

H2S Emissions

Despite having significantly low er emissions in comparison to traditional fossil fuel plants, GPPs emissions can still be substantial. In particular, dissolved NCGs such as CO2 and H2S w ithin geothermal fluids have led to increased interest in developing methods for decreasing these emissions through abatement systems, or potentially using these gases to generate value for use in industrial processes.

H2S is a malodorous toxic gas emitted from GPPs and w ell field operations posing health and safety problems if not monitored and managed appropriately.

At some GPP locations, H2S is present in sufficient quantities to represent a reasonable raw material for producing elemental sulfur, w hich can be sold as a product for producing sulfuric acid or fertilizers.

Under normal conditions, H2S is released through NCG uptake system and vent system of the binary unit. As H2S is heavier than air, there is a risk of its accumulation at low er spots of the GPP. In order to ensure that potential health and safety risks are managed appropriately, H2S sensors are installed w ithin the Kizildere II GPP. There is an online monitoring system in place to detect H2S concentrations. If the value is above the limits then alarm system w ill be on at the GPP. To date such an exceedance has not taken place. Additionally hand-held H2S detectors are also utilized by the operators.

Infrastructure Safety

Hazards associated w ith contact w ith active w ells and related pipelines, equipment failures and abandoned w ells constitute infrastructure related hazards of the Project.

Locating a GPP close to the geothermal resource it w ill utilize also minimizes occupational and community health and safety risks, since the required length of pipelines betw een the plant and the w ells can be significantly reduced, w hich in turn reduces potential of pipeline failures and associated occupational and community health and safety risks such as exposure to hot surfaces.

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In terms of infrastructure safety, follow ing measures w ill be applied to avoid community health and safety r isks:

 Shortest and safest routes w ill be determined for pipeline route design.

 Insulated pipes w ill be used to avoid thermal loss and hazards associated w ith contact w ith hot surfaces. Pipeline routes w ill be fenced off w ith necessary cautionary signs.

 When necessary measures are not implemented, carbonate and sulphate accumulate and create a crust on inner w alls of pipes. This phenomenon limits the flow rate of geothermal fluid and may result in leakages or broader pipeline failures. Chemical dosing and/or inhibitor injection w ill be applied at each w ell head to avoid calcification. The injection system is a closed circuit system and therefore, the chemicals that w ill be used by the system w ill not interact w ith environment.

 The spill containment system of the pipelines consists of drainage channels that w ill collect geothermal fluids in case of a pipeline failure and a by-pass pond that the drainage channels discharge to. Since the Project is located in a 1st degree earthquake zone, the design of the pipelines and the drainage channels w ill ensure safety in case of a failure that may be triggered by earthquakes.

 The Project commits to compensate for any potential damage on access roads during construction and operation phase of the Project.

Induced Seismicity

Seismic activity may at times be induced by development of geothermal energy. Drilling w orks for establishment of production and reinjection w ells during construction phase and especially production and reinjection activities that are conducted during the operation phase may cause stress patterns of the area rock formations to be altered and seismicity to be induced as a result (Geothermal Energy Association, 2009; US Department of Energy; 2012). How ever, in almost all of the cases, these seismic events are of small magnitudes and are rarely felt by communities (Majer et al., 2007; from US Department of Energy; 2012). Geothermal Energy Association (2009) states that the micro-earthquakes that may be induced by GPP activities contribute to increased seismic activity in the region (generally in the close vicinity of reinjection w ells); how ever, these micro-earthquakes have magnitudes of 1 to 3 on Richter scale, w hich are too low to be felt by communities. Similarly, Bromley (2012) states that no induced seismicity w as reported in majority of the conventional GPPs and the reported ones are small or micro scale earthquakes. How ever, still, there have been some grievances of communities and therefore, some protocols and GIIPs w ere developed to address the issue. The areas w here such grievances w ere reported are considerably larger geothermal fields w ith high number of operational GPPs. It should also be noted that geothermal fields are located in seismically active zones and some seismic events recorded in these areas are natural events and not induced by GPPs.

Natural Hazards

The main natural hazard risks are associated w ith earthquakes, since the Project is located in a 1 st degree earthquake zone according to the Earthquake Zones Map of Aydin province. Detailed geological and geotechnical surveys and earthquake risk assessments are provided in the scope of the Project’s Geological and Geotechnical Survey Report and the EIA Report. Measures regarding occupational and community health and safety risks associated w ith earthquakes are design measures, w hich are laid out in detail by related national legislation. The Project w ill be in full compliance w ith provisions of national legislation regarding constructions on 1st degree earthquake zones and further geotechnical surveys w ill be conducted to ensure safe design parameters.

The other natural hazard type w ith potential risks is floods. Necessary drainage systems w ill be constructed to avoid flooding and all drainage systems w ill be designed to accommodate largest standard rainfall values. No excavation w aste w ill be disposed of/stored in river beds.

The Geological and Geotechnical Survey Report of the Project states that the Project area is not prone to other natural hazards such as landslides, rock fall events and avalanches.

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5.7 Land Acquisition, Involuntary Resettlement and Economic Displacement

Zorlu Enerji’s land acquisition policy is to first negotiate w ith land ow ners and agree on a mutual price, hence avoid involuntary resettlement through expropriation. As of November 2016, all of 42 parcels required for the Project have been directly purchased on w illing- selling basis. There w ill be no additional land acquisition through expropriation. There w ill be no physical displacement as a result of the land acquisition process.

5.8 Cultural Heritage

The official letter of Aydın Regional Board Directorate for Conservation of Cultural and Natural Assets states that no cultural heritage w ith archaeological, historical, natural values is present at the Project area.

In case of any chance finds of a cultural heritage during land preparation and construction stage, immediate communication w ill be established w ith the nearest Museum Directorate or Regional Board Directorate for Conservation of Cultural and Natural Assets. A chance find procedure w ill be developed and implemented to ensure Contractors follow the legal requirements.

The Project site remains w ithin the boundaries of “tourism area” based on geothermal reserve w here geothermal pow er production is allow ed. As a result of the correspondence betw een Ministry of Culture and Tourism and General Directorate of Mining, it has been agreed that the Site can be used for geothermal pow er production. Zorlu Enerji w ill promote a detailed analysis of cumulative impacts of geothermal pow er plants on environment, agriculture, tourism etc. in close coordination w ith local authorities and other industries in the region and develop a cumulative impact management plan for the Project.

5.9 Information Disclosure and Stakeholder Engagement

Project, organized a stakeholder consultation meeting in 19 July 2016 w ithin the scope of the local EIA process. During this meeting most of the questions and concerns w ere about potential impacts of the Project on agricultural production and on regional flora and fauna. Local people also raised concerns about the effluent discharge from drilling w orks and how the effluent w ill be managed.

It is understood that local communities have negative impressions due to their negative experiences w ith other geothermal projects in the region, particularly because of poor EHS practices such as discharge of geothermal effluent directly on soil and into creeks. Zorlu Enerji is in close contact w ith the local communities to ensure that they are w ell informed about the Company’s EHS policies and practices.

During the consultation process a group of 17 locals signed a note entitled “We are against geothermal pow er”. The concerns raised by locals are mainly about climate change, disturbed moisture balance in the atmosphere, etc. This rises as an issue of opposition and is to be managed w ith a w ell-planned stakeholder engagement process including disclosure of objective and reliable data about project impacts on environment.

There are also concerns that fugitive emissions from geothermal w ells can be carcinogenic, and this could result in increased mortality rates w ith the geothermal pow er production in the region. A claim w as also made that olive trees and fig trees have already been disturbed by other geothermal pow er activities in A ydin province.

This also brings about the importance to ensure that cumulative environmental and social impacts of GPPs and other projects operating w ithin a geographical context (that is considered reasonable to create potential cumulative impacts together w ith Kizildere III GPP capacity extension Project) are assessed in a w ell-structured, technically and scientifically correct manner through engagement w ith key stakeholders.

Up to date, as part of stakeholder engagement, the Company has addressed these issues in public meetings w ith stakeholder groups and through thematic meetings on geothermal energy w ith the local communities and local authorities as provided in the SEP. Zorlu Enerji together w ith other developers in the region, local authorities, and industry associations w ill continue to monitor the issues, concerns raised by local population and undertake corrective actions and raise aw areness w ithin the stakeholders w ith regards to GPP operations based on scientific data on regular basis. Zorlu Enerji w ill promote a detailed analysis of cumulative impacts of geothermal pow er plants on environment, agriculture, tourism etc. in close coordination w ith local authorities and other industries in the region and promote development of a cumulative impact management plan for the Project. Meetings on a regular basis w ill be organized w ith key stakeholders such as local authorities, university representatives, opinion makers and other industry representatives in the region as w ell as the Association of

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Geothermal Electrical Plant Investors (JESDER) to identify and manage the cumulative environmental and social impacts of the GPPs and other developments in the region.

A SEP is in place, identifying primary stakeholders and pertinent engagement methods for each stakeholder, including information disclosure, regular meetings, Community Investment Programme, grievance mechanism, netw orking and cooperation activities, etc. The existing grievance mechanism is w orking and is compliant w ith EBRD PR10.

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6. Cumulative Environmental and Social Impact Assessment

6.1 Introduction

A Cumulative Impact Assessment (CIA) Study w as prepared for identification and assessment of the potential cumulative environmental and social impacts (both positive and negative) that may result from Kizildere III GPP (including its capacity extension), acting together w ith other existing and reasonably foreseeable future projects located w ithin a geographical scope.

A detailed CIA is not aimed, since detailed CIA studies are conducted to provide an overarching, supplementary management tool and therefore, any such study is the responsibility of governmental organizations (policy makers) that have jurisdiction over the assessed area. Any such study requires collaboration of all related stakeholders such as the local and national authorities, NGOs and all Project ow ners in the assessed area. With these considerations in mind, the assessment presented here is conducted from a broad perspective and only Projects that utilize geothermal resources w ere taken into account.

In order to assess the cumulative environmental and social impacts, the list of existing and reasonably foreseeable projects that w ill potentially create cumulative impacts w ere identified.

The potential cumulative environmental and social impacts have been assessed only for operations phases of the GPPs, since construction phase impacts are relatively insignificant and temporary, compared to impacts caused during the long operation phase. Some of the impacts identified here stem from construction activities (e.g. impacts on land use, visual impacts etc.), and persist during the operation phase. Any such impact is also included in the operation phase impacts identified in this study.

It should be noted that mitigating the potential negative cumulative impacts are not solely the responsibility of Zorlu. Therefore, other project ow ners, relevant local and national authorities should also take responsibility to mitigate the potential impacts.

For the long run, it is important to ensure that cumulative environmental and social impacts of GPPs and other projects operating w ithin a geographical context (that is considered reasonable to create potential cumulative impacts together w ith Kizildere III GPP capacity extension Project) are assessed in a w ell-structured, technically and scientifically correct manner through engagement w ith key stakeholders.

Meetings on a regular basis w ill be organized w ith key stakeholders such as local authorities, university representatives, opinion makers and other industry representatives in the region as w ell as the Association of Geothermal Electrical Plant Investors (JESDER) to identify and manage the cumulative environmental and social impacts of the GPPs and other developments in the region. Zorlu Enerji w ill undertake a detailed analysis of cumulative impacts in close coordination w ith local authorities and other industries in the region and develop a cumulative impact management plan for the Project.

Zorlu Enerji has extensive and long years of experience in operating GPPs in the region and w ould contribute substantially if a regional industrial netw ork w ill be established to discuss cumulative HSE and socio-economic issues and opportunities for the region w ith the aim of setting up HSES standards for GPPS and common environmental and social monitoring programs. Ultimately regional action plans could be developed to clearly define roles and responsibilities of each party involved.

The Company w ill therefore facilitate in such a study, but this needs to be done in conjunction w ith the regulators and other GPP operators.

6.2 Policy and Regulatory Framework

The concept of cumulative impact assessment (CIA) has been recently inserted into Annex 3 (General Format of the EIA) of the Turkish EIA Regulation (Official Gazette No. 28784, dated 3 October 2013). How ever, the description requirements or methods of CIA are still not provided in the current EIA Regulation (Official Gazette No. 29186, dated 25 November 2014) or in any other regulations. Therefore, in defining the process for implementing a Cumulative Impact Assessment (CIA), international guidelines and standards are taken into consideration.

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EBRD PR 1 references the need for the environmental and social assessment process to consider cumulative impacts of the project in combination w ith impacts from other relevant past, present and reasonably foreseeable developments as w ell as unplanned but predictable activities enabled by the project that may occur later or at a different location.

6.3 Limitations of the CIA

There are a number of limitations to the assessment of the cumulative impacts of the Project w ith other projects over a w ide area and over a long period of time. Most of these limitations w ould apply to many projects of similar scale and duration. The main limitations are:

 The available information on future projects is variable and in many cases very limited. Therefore, their physical characteristics are uncertain or subject to change. The timing of many future projects is also uncertain and subject to change. Additionally, any planning documentation regarding these projects can be confidential.

 Some of the other projects have not been subject to environmental and social impact assessments (or the assessments are not accessible) as yet and the effects of these possible developments have therefore not been documented.

 There are a number of unknow ns associated w ith the baseline conditions in the CIA study area.

 Cumulative impacts w ill be influenced by policies and developments outside of the study area.

Given the limitations described above, this CIA has been prepared to establish at a very broad level the types of effects that could occur as a result of the Project in addition to other projects.

6.4 Projects Covered in the CIA Study

Considering the limitations regarding the currently available information, a list of existing projects have been identified as show n in Figure 12. There are no reasonably foreseeable projects identified in the CIA study area. Production licenses provided by Energy Market Regulatory Authority, on its w ebsite w ere used to confirm the identified projects.

Existing Projects Existing projects are defined as the projects that are in operation or under construction in 2016. The identified existing projects for the CIA study are:

 Kizildere I GPP: 17.4 MW installed capacity, also ow ned by Zorlu.

 Kizildere II GPP: 80 MW installed capacity, also ow ned by Zorlu.  Bereket GPP: 6.85 MW installed capacity, ow ned by Bereket Jeotermal Enerji Üretim Anonim Şirketi

 Greeneco GPP: 25.6 MW installed capacity, ow ned by Greeneco Enerji Elektrik Üretim Anonim Şirketi. It is unknow n if this Project is currently operational, how ever, it has a currently valid generation license provided by EMRA and therefore, it is included in existing projects.

 Two hotel projects that utilize geothermal resources are also included in the CIA area.

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Figure 12 Cumulativ e Impact Assessment Map

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6.5 Selection of Key Environmental and Social Issues for the CIA Study

This section identifies the potential environmental and social issues that are of relevance to the CIA study. All environmental and social issues w ithin the scope of the Project ESIA have been screened against the existing and reasonably foreseeable future projects so as to identify the potential cumulative environmental and social impacts that could occur.

The key environmental and social (E&S) issues w here cumulative impacts could potentially occur, i.e. E&S issues w here project(s) in combination w ith the Kizildere GPP III Project have the potential to result in cumulative impacts, are as follow s:

 Air emissions (NCGs)

 Air Emissions (GHGs)

 Terrestrial flora/fauna

 Land use

 Landscape and visual impacts

 Induced seismicity

 Economy (services sector and employment)

 Quality of life (community investments, emissions)

The potential cumulative environmental and social impacts of the Project are given in Table 19.

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Table 19. Cumulative Environmental and Social Impacts

Key Issues Cumulativ e Env ironmental and Social Impacts

The main NCG emission of concern is H2S, which is a toxic gas and which may also affect local communities due to its malodorous chara cter. The Project

utilizes H2S abatement techniques and therefore its contribution to cumulative H2S emissions will be very small. Nonetheless, cumulative H2S emissions, specifically in terms of impacts on local communities due to odor, shall be investigated by a detailed cumulative impact study to be conducted by related authorities, since existence of abatement techniques of the other projects are unknown. Additional organizational measures/li mits may be proposed as a result of any such detailed study. Air emissions (NCGs) Cumulative visual impacts caused by emission of steam plumes from GPPs in the area is already a significant issue. The Company received some grievances from local communities, where they stated that they are concerned of health impacts of air pollution. The company conducts pollution monitoring and according to the monitoring results, the impact is only a visual impact (there is no health risk). This issue shall be addressed collectively by all projects in t he area, by providing awareness and knowledge increasing information to communities through meetings and other material. See landscape and visual impacts below.

The total GHG emissions from the existing projects was assessed to be already significant, since the Project’s GHG emission rate alone falls under Medium – High Category according to the EBRD Methodology for Assessment of Greenhouse Gas Emissions (2010) guideline. A detailed, regi onal cumulative study to Air emissions (GHGs) be conducted by related authorities is required in this aspect. However, it should also be noted that the contribution of the Project to GHG emissions will decrease in time, as described in the related section of this SLIP.

Conversion or degradation of the habitats is an issue mainly for the modified habi tats (since this is the main habitat type in the vicinity) and the Project has a minor contribution to habitat loss; however, the total area of lost habitat cumulatively has a larger importance. The identified critical habitat (where plant species of Pelobates syriacus, Hyla arborea, Pseudepidalea viridis, Ablepharus kitaibelii that have Annex IV status according to EU Habitats Directive List exist) would be more vulnerable considering especially the topsoil removal for existing projects.

Habitat fragmentation would be an issue considering the increased barriers within a continuous habitat. Terrestrial flora/fauna Due to traffic load and poaching causing direct mortality and loss of percentage of local population (or range) with relation to global and/or regional population numbers (or range). This would be the most important for the Testudo graeca (Spur-thighed Tortoise) that has VU status.

The impact of lighting at night and noise has a larger impact cumulatively. The displacement of the wildlife fauna will be a subject of a larger area.

There could be increased impact on agricultural plants and the wild flora elements due to precipitation or dry deposition of the contaminants sourced from emissions.

There will be some change in the land use characteristics in the area that will start with construction activities and persist partially during operation phase. The permanent land use characteristic change is especially important in terms of loss of agricultural land. However, the ETLs and pipelines of the projects only use Land use easement rights instead of acquisition of the entire land where these components’ routes passes from and therefore, agricultural activities can continue around the small footprint corridors of these components. Consequentlly, cumulative impact on agricultural production is limited to plant size areas. Cumulative impacts expected on loss of agricultural lands due to other project developments.

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Key Issues Cumulativ e Env ironmental and Social Impacts

Cumulative impacts of GPPs on landscape would result from the presence of facility structures and increased traffic load, as well as releases of steam plumes, which is a visual impact especially important for GPP developments. Detailed site planning, facility design, materials selection are measures that can be applied Landscape and v isual impacts specifically by each facility; and revegetation programs and adjustment to transmission line routing are measures that can be applied following a cumulative assessment.

Induced seismicity is an issue of importance at geothermal sites where there are a la rge number of operational GPPs with very high generation capacities. Therefore, a cumulative impact study is not of importance for the Project area and the determined CIA area. Induced seismicity The issue should be reevaluated and seismic monitoring should be applied in case multiple new plants are planned in the future years and or any grievances are received.

Cumulative economic impacts of geothermal power plants in the region will be positive in terms of providing employment opportunities for the local work force and stimulating local markets that deliver services (transportation, housing, catering, etc.) and commercial dynamics (i.e. sales of goods, food, fuel, construction Economy (services sector and materials, equipment, etc.). It is anticipated that competitive markets will result in improved level of services, while new businesses will also be developed employment) based on particular demands of geothermal projects. CO2 end-use applications such as greenhouse applications, enhanced oil recovery, dry ice production, beverage applications, anti-fire applications are potential industries to develop. - It is significant that the geothermal power plants in the region cooperate with regional development agencies for guiding new businesses and increasing the quality of labor force through joint training activities.

The impact of GPPs in the region is positive on quality of life in general, mainly in terms of community investment programs that aim to improve current conditions of facilities such as schools, healthcare organizations, community centers, mosques, etc. Quality of life (community inv estments, emissions) Cumulative adverse impacts in the form of general nuisance and concerns can be observed in time, if mitigation measures again st emissions to air are not- taken by all plants contributing and also if the mitigations are not well -communicated with local communities.

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Appendix A Updated Fauna and Flora Tables

Flora/fauna survey results given in the local EIA Report is review ed and updated taking into account CITES, EU Habitats and EU Birds Directives.

The EU Habitats Directive ensures the conservation of a w ide range of rare, threatened or endemic animal and plant species. Over 1,000 animal and plant species, as w ell as 200 habitat types, listed in the Directive's annexes are protected in various w ays:

 Annex II species (about 900): core areas of their habitat are designated as sites of Community importance (SCIs) and included in the Natura 2000 netw ork. These sites must be managed in accordance w ith the ecological needs of the species.

 Annex IV species (over 400, including many annex II species): a strict protection regime must be applied across their entire natural range w ithin the EU, both w ithin and outside Natura 2000 sites.

 Annex V species (over 90): Member States must ensure that their exploitation and taking in the w ild is compatible w ith maintaining them in a favourable conservation status.

The EU Birds Directive aims to protect all of the 500 w ild bird species naturally occurring in the European Union. The 500 w ild bird species naturally occurring in the European Union are protected in various w ays:

 Annex 1: 194 species and sub-species are particularly threatened. Member States must designate Special Protection Areas (SPAs) for their survival and all migratory bird species.

 Annex 2: 82 bird species can be hunted. How ever, the hunting periods are limited and hunting is forbidden w hen birds are at their most vulnerable: during their return migration to nesting areas, reproduction and the raising of their chicks.

 Annex 3: overall, activities that directly threaten birds, such as their deliberate killing, capture or trade, or the destruction of their nests, are banned. With certain restrictions, Member States can allow some of these activities for 26 species listed here.

 Annex 4: the directive provides for the sustainable management of hunting but Member States must outlaw all forms of non-selective and large scale killing of birds, especially the methods listed in this annex.

 Annex 5: the directive promotes research to underpin the protection, management and use of all species of birds covered by the Directive, w hich are listed in this annex.

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Updated Fauna Tables

Amphibians

Scientific Name of the Turkish Name of the English Name of Identificatio EU Habitats Family Bern IUCN CITES species species the species n Method Directive

PELOBATIDAE Pelobates syriacus Toprak Kurbağası Eastern Spadefoot II LC L Annex IV -

European Tree HYLIDAE Hyla arborea Yaprak kurbağası II LC L Annex IV - Frog

BUFONIDAE Bufo bufo Kara Kurbağası Common Toad III LC O - -

European Green BUFONIDAE Bufotes viridis Gece Kurbağası II LC L Annex IV - Toad

Reptiles

Spur-thighed Appendix TESTUDINIDA E Testudo graeca Tosbağa II VU O - Tortoise II

GEKKONIDAE Hemidactylus turcicus Geniş parmaklı keler Turkish Gecko III LC L -

AGAMIDAE Stellagama stellio Dikenli keler Starred Agama II LC L - -

European Copper SCINCIDAE Ablepharus kitaibelii İnce Kertenkele II LC L Annex IV Skin

No further SCINCIDAE Trachylepis aurata Tınaz Kertenkele Levant Skink III LC L conservation actions are needed

European legless ANGUINIDAE Ophisaurus apodus Oluklu Kertenkele II - L - - lizard

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Reptiles

Scientific Name of the Turkish Name of the English Name of Identificatio EU Habitats Family Bern IUCN CITES species species the species n Method Directive

BOIDAE Eryx jaculus Mahmuzlu Yılan Javelin sand boa III - L - -

Ring-Headed COLUBRIDAE Eirenis modestus Uysal Yılan III LC L - - Dw arf Snake

Schmidt's Whip COLUBRIDAE Dolichophis schmidti Hazer Yılanı III LC L - - Snake

Eurasian Blind TYPHLOPIDAE Typhlops vermicularis Kör Yılan III - L - - Snake

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Birds Red Scientific Name of Turkish Name English Name Id EU Birds Family Data Bern Status CHC IUCN CITES the species of the species of the species Method Directive Book Ak Gözlü Eastern Orphean SYLVIDAE Sylvia hortensis - II Y - LC L - - Ötleğen Warbler Eurasian Skylark Annex II – ALAUDIDAE Alauda arvensis Tarlakuşu - III Y Annex-I LC L - Part A Melanocorypha Ak Kanatlı White-w inged ALAUDIDAE - II G - LC L - - leucoptera Toygar Lark HIRUNDINIDAE Hirundo rustica Kırlangıç Barn Sw allow - II G - LC O - - Delichon urbica Common House HIRUNDINIDAE Ev kırlangıcı A.4 II G - LC O - - (urbicum) Martin Rock Partridge Annex- PHASIANIDAE Alectoris graeca Taşkekliği A.2 III Y NT L Annex I - II Common Quail Annex- Annex II PHASIANIDAE Coturnix coturnix Bıldırcın A.4 III Y,G LC L -- II Part B TURDIDAE Erithacus rubecula Kızılgerdan European Robin - II Y - LC L - -- Luscinia Common TURDIDAE Bülbül A.3 II G - LC L - -- megarhynchos Nightingale Fieldfare Annex II TURDIDAE Turdus pilaris Tarla ardıcı - III KZ Annex-I LC O -- Part B Common Annex- Annex II TURDIDAE Turdus merula Karatavuk - III Y LC L -- Blackbird II Part B Common Wood Annex- Annex III COLUMBIDAE Columba palumbus Tahtalı - - Y LC O -- Pigeon II Part A European Turtle Annex- Annex II – COLUMBIDAE Streptopelia turtur Üveyik - III Y LC L - Dove II Part B Eurasian Annex II – SCOLOPACIDAE Scolopax rusticola Çulluk A. 3 III Y,KZ,T - LC L - Woodcock Part A FALCONIDAE Falco tinnunculus Kerkenez Common Kestrel A. 4 II Y - LC L - App-II FALCONIDAE Falco peregrinus Gökdoğan Peregrine Falcon A. 2 II Y,KZ - LC L Annex I App-I Eurasian ACCIPITRIDAE Accipiter nisus Atmaca A. 4 II Y,KZ - LC L Annex I App-II Sparrow haw k ACCIPITRIDAE Buteo buteo Şahin Common Buzzard A. 3 II Y,KZ,T - LC O - App-II

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Birds Red Scientific Name of Turkish Name English Name Id EU Birds Family Data Bern Status CHC IUCN CITES the species of the species of the species Method Directive Book Long-legged ACCIPITRIDAE Buteo rufinus Kızıl Şahin A. 2 II Y,KZ - LC O Annex I App-II Buzzard ACCIPITRIDAE Aquila chrysaetos Kaya kartalı Golden Eagle A. 3 II Y,KZ - LC O Annex I App-II Kulaklı STRIGIDAE Asio otus Long-eared Ow l A. 2 II Y - LC L - App-II Ormanbaykuşu STRIGIDAE Strix aluco Alaca Baykuş Taw ny Ow l A.1.2. II Y - LC L - App-II Kızıl Sırtlı Red-backed LANIIDAE Lanius collurio - II G Annex-I LC L Annex I Örümcekkuşu Shrike Kara Alınlı Lesser Grey LANIIDAE Lanius minor - II G - LC L Annex I Örümcekkuşu Shrike Kızıl Başlı LANIIDAE Lanius senator Woodchat Shrike - II G - LC L - - Örümcekkuşu Annex- Annex II CORVIDAE Corvus monedula Küçük Karga Western Jackdaw - - Y LC O II Part B Annex- Annex II CORVIDAE Corvus frugilegus Ekin Kargası Rook - - Y, KZ LC O II Part B Annex- Annex II CORVIDAE Corvus corone Leş Kargası Hooded Crow - - Y LC O II Part B Annex- Annex II CORVIDAE Pica pica Saksağan Eurasian Magpie - - Y LC O - II Part B Emberiza Black-headed EMBERIZIDAE Karabaşlı çinte A. 3 II G - LC L - - melanocephala Bunting EMBERIZIDAE Emberiza hortulana Kirazkuşu Ortolan Bunting A 3 III G Annex-I LC L Annex I - Common FRINGILLIDAE Fringilla coelebs İspinoz - III Y Annex-I LC L Annex I Chaffinch European FRINGILLIDAE Carduelis chloris Florya A. 4 II Y - LC L - Greenfinch European FRINGILLIDAE Carduelis carduelis Saka A. 4 II Y - LC O - - Goldfinch Annex II STURNIDAE Sturnus vulgaris Sığırcık Common Starling - - Y Annex-I LC O - Part B

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Birds Red Scientific Name of Turkish Name English Name Id EU Birds Family Data Bern Status CHC IUCN CITES the species of the species of the species Method Directive Book Annex- PASSERIDAE Passer domesticus Serçe House Sparrow - - Y LC O - - II Büyük PARIDAE Parus major Great Tit - II Y - LC L - - baştankara

Mammalian EU Scientific Name of the Turkish Name of the English Name of the Id Family Bern CHC IUCN Habitats CITES species species Species Method Directive

ERINACEIDAE Erinaceus concolor Kirpi European Hedgehog - - LC O - -

SORICIDAE Crocidura leucodon Tarla sivrifaresi Bicolored Shrew III - LC L - -

TALPIDAE Talpa levantis Körköstebek Levantine Mole - - LC L - -

SPALACIDAE Spalax leucodon Kösnü Lesser Mole Rat - - DD L - -

MUSTELIDAE Mustela nivalis Gelincik Least Weasel III Annex-I LC L - -

CRICETIDAE Cricetulus migratorius Cüce avurtlak Gray Dw arf Hamster - - LC L - - Annex- Lepus europaeus Yabani tavşan European Hare III LC L - - LEPORIDAE II

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Updated Flora Table

Scientific Name of Turkish Name Family Endemism Element IUCN CITES Id Method Distribution Abundance the species of the species

Non- Central and Eastern Apiaceae Artedia squamata Karabenek Non-existence- - - L - endemic- Anatolia

Non- Eastern North-w est, Western and Araceae Dracunculus vulgaris Yılanbıçağı - - L - endemic- mediterranean Central Anatolia

Non- South-w est and South- Asteraceae Pulicaria arabica Arap yaraotu Non-existence- - - O 2 endemic- east Anatolia

Anthemis coelopoda Non- Northern, Western and Asteraceae Papatya Non-existence- - - L - varyete coelopoda endemic- Terrestrial Anatolia

Matricaria Non- Thrace, Western and Asteraceae chamomilla varyete Papatya Non-existence- - - O 1 endemic- Southern Anatolia chamomilla

North-w est, Western, Non- Asteraceae Notobasis syriaca Yavan kenger Mediterranean - - O Southern and Eastern 2 endemic- Anatolia

Tragopogon Non- North-w est, Western and Asteraceae longirostis varyete Teke Sakalı Non-existence- - - L - endemic- Eastern Anatolia longirostis

Echium Non- Boraginaceae - Mediterranean - - O Thrace and Anatolia 2 plantagineum endemic-

Non- North-w est and Western Boraginaceae Cerinthe major Alacakız Mediterranean - - L - endemic- Anatolia

Non- Eastern Boraginaceae Nonea obtusifolia - - - L Thrace and Anatolia - endemic- mediterranean

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Scientific Name of Turkish Name Family Endemism Element IUCN CITES Id Method Distribution Abundance the species of the species

Non- Thrace, Western and Brassicaceae Sinapis alba Turp Otu Non-existence- - - O 3 endemic- South Anatolia

Raphanus Non- Brassicaceae Turp Otu Non-existence- - - L Anatolia - raphanistrum endemic-

Capsella bursa- Non- Brassicaceae Kuşkuş Otu Non-existence- - - O Turkey 2 pastoris endemic-

Northern, Western, Sisymbrium Non- Brassicaceae Ergelen otu Non-existence- - - L South and Central - altissimum endemic- Anatolia

Minuartia hybrida Non- South and Western Caryophyllaceae Çayır tıstısı Mediterranean - - L - alttür hybrida endemic- Anatolia

Non- South and Western Caryophyllaceae Dianthus tripunctatus Benekli karanfil Mediterranean - - O 2 endemic- Anatolia

Silene squamigera Non- Eastern South and Western Caryophyllaceae Salkım Çiçeği - - L - alttür squamigera endemic- mediterranean Anatolia

Non- South, South-east and Caryophyllaceae Silene colorata Salkım Çiçeği Non-existence- - - L - endemic- Western Anatolia

Western, Central, Non- Caryophyllaceae Silene subconica Salkım Çiçeği Non-existence- - - L Southern and Eastern - endemic- Anatolia

Non- Northern, Western and Cistaceae Cistus creticus Pamuk Otu Mediterranean - - L - endemic- Southern Turkey

Non- Eastern Western and South-w est Dipsacaceae Scabiosa reuteriana Uyuz Otu LR(lc) - L - endemic- mediterranean Anatolia

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Scientific Name of Turkish Name Family Endemism Element IUCN CITES Id Method Distribution Abundance the species of the species

Non- Euphorbiaceae Euphorbia agraria Sütleğen Euro - Siberian - - O North-w est Turkey 3 endemic-

Lathyrus Non- Fabaceae inconspicuus varyete - Non-existence- - - L Turkey - endemic- insconspicuus

Pisum sativum alttür Non- Fabaceae elatius varyete - Mediterranean - - O Thrace and Anatolia 1 endemic- elatius

Non- Fabaceae Ononis pubescens - Mediterranean - - L North-w est Turkey - endemic-

North-w est, South, Non- Fabaceae Trifolium spumosum Yonca Mediterranean - - O Western and east 1 endemic- Anatolia

Trifolium stellatum Non- Eastern Fabaceae Yonca - - L Western Anatolia - varyete xanthinum endemic- mediterranean

Non- Fabaceae Trifolium pilulare Yonca Non-existence- - - L Western Turkey - endemic-

Non- Eastern Northern and Western Fabaceae Trigonella balansae - - - L - endemic- mediterranean Anatolia

Non- Western and South Fabaceae Trigonella aurantiaca - Irano - Turanian - - L - endemic- Anatolia

Non- Fabaceae Trigonella gladiata - Mediterranean - - L North-w est Turkey - endemic-

Medicago Non- Eastern Fabaceae Çevrince - - O North-w est Turkey 1 granadensis endemic- mediterranean

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Scientific Name of Turkish Name Family Endemism Element IUCN CITES Id Method Distribution Abundance the species of the species

Northern, South, Geranium molle Non- Geraniaceae Itır Non-existence- - - L Western and Southeast - alttür molle endemic- Anatolia

Western, Northern, Geranium tuberosum Non- Geraniaceae Çakmuz Non-existence- - - L Central and South - alttür tuberosum endemic- Anatolia

Western, Northern, Non- Geraniaceae Erodium hoefftianum İğnelik Non-existence- - - L Central and South - endemic- Anatolia

Western, Northern, Non- Geraniaceae Erodium ciconium İğnelik Non-existence- - - L Central and South - endemic- Anatolia

Lamium moschatum Non- Eastern Western and South Lamiaceae Ballıbaba - - L - varyete moschatum endemic- mediterranean Anatolia

Trakya, Western and Marrubium Non- Lamiaceae - Non-existence- - - L NorthernWestern - peregrinum endemic- Anatolia

NorthernWestern, Non- Lamiaceae Sideritis lanata Dağ Çayı Mediterranean - - L Western, SouthWestern - endemic- and Orta Anatolia

Sideritis montana Non- Thrace and Orta Lamiaceae Dağ Çayı Mediterranean - - L - alttür remota endemic- Anatolia

Ballota nigra alttür Non- Western and South Lamiaceae Yalancı Isırgan Mediterranean - - O uncinata endemic- Anatolia Non- Malvaceae Althaea hirsuta Hatmi Non-existence- - - L Western, Northern, - endemic- Central and South

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Scientific Name of Turkish Name Family Endemism Element IUCN CITES Id Method Distribution Abundance the species of the species

Anatolia

Ficus carica alttür Non- Moıraceae İncir Non-existence- - - O Turkey 2 carica endemic-

Olea europaea Non- Oleaceae Zeytin Mediterranean - - O Anatolia 2 varyete europaea endemic-

Thrace, Western, Non- Papaand raceae Fumaria densiflora Şahtere Otu Non-existence- - - L Southern and Central - endemic- Anatolia

Bromus hordeaceus Non- Poaceae - Non-existence- - - L Turkey - alttür hordeaceus endemic-

Bromus japonicus Non- Poaceae - Non-existence- - - L Turkey - alttür japonicus endemic-

Catapodium rigidum Non- Poaceae alttür rigidum varyete - Non-existence- - - O Turkey 3 endemic- majus

Non- Western and South Poaceae Setaria adhaerens - Non-existence- - - L - endemic- Anatolia

Thrace, Western, North- Non- Polygonaceae Rumex pulcher Tirşo Non-existence- - - O w est, Southern and 2 endemic- South-east Anatolia

Rumex Non- Northern, Western and Polygonaceae Labada Mediterranean - - L - bucephalophorus endemic- Southern Anatolia

Nigella arvensis Non- Ranunculaceae Çörek Otu Non-existence- - - L Western Anatolia - varyete involucrata endemic-

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Scientific Name of Turkish Name Family Endemism Element IUCN CITES Id Method Distribution Abundance the species of the species

Consolida phrygia Non- Western and South-w est Ranunculaceae - Non-existence- - - L - alttür phrygia endemic- Anatolia

Ranunculus Non- Ranunculaceae Düğün Çiçeği Non-existence- - - O Anatolia 1 muricatus endemic-

Non- Western and South Rosaceae Eriobotrya japonica - Non-existence- - - O 3 endemic- Anatolia

Verbascum Non- Eastern Northern and Western Scrophulariaceae Sığır Kuyruğu - - O 3 mucronatum endemic- mediterranean Anatolia

Verbascum Non- Eastern Western, South-w est and Scrophulariaceae Sığır Kuyruğu - - O 2 splendidum endemic- mediterranean Central Anatolia

Non- Scrophulariaceae Linaria bipartita - Non-existence- - - L Western Anatolia - endemic-

Non- Solanaceae Datura stramonium Boru Çiçeği Non-existence- - - L Turkey - endemic-

Abundance values: 1. Wide 2.Medium 3.Low Status: Y= Resident species, G= Migrant species that arrive Turkey to breed, KZ= Species that arrive in Turkey in winter, T= Passage migrant, R= Coincidental species, N= Rare species L: Literature O: Observation Other Abbreviations: IUCN : The International Union for Conservation of Nature CITES : The Convention on International Trade in Endangered Species of Wild Fauna and Flora CHC: Central Hunting Committee References Alliances for Zero Extinction, http://www.zeroextinction.org/ CITES, The Convention on International Trade in Endangered Species of Wild Fauna and Flora, https://www.cites.org/ EBRD, PR 6 and GN6, Biodiversity Conservation and Sustainable Management of living Natural Resources, 2014. 39-41. EDGE, Evolutionarily Distinct and Globally Endangered Species, http://www.edgeofexistence.org/species/ Eken, G., Bozdoğan, M., İsfendiyaroğlu, S., Kılıç, DT., Lise, Y., (editors) 2006. Türkiye’nin Önemli Doğa Alanları. Doğa Derneği. Ankara. Invasive Alien Species, http://ec.europa.eu/environment/nature/invasivealien/index_en.htm IUCN, The International Union for Conservation of Nature, http://www.iucnredlist.org/search The GIASIPartnership Gateway, Invasive Alien Species Information Services, http://giasipartnership.myspecies.info/en/country/TR

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