Tenagi Route Alternatives – Summary of consultation upon route alternatives as part of ESIA process

Document title Tenagi Route Alternatives ESIA Consultation Document no. TAP-CEA-BN-0044 Rev 00 Classification External

1. Introduction

This document summarises the additional stakeholder consultation and disclosure that took place in relation to Tenagi route alternatives that were proposed and considered as part of the ESIA process, prior to EIA approval on 12th September 2014.

This activity was in addition to that conducted upon the original 2013 ESIA basecase route where the various stakeholder meetings and feedback were included with the submissions at that time, namely;

• An overview of feedback received was given in ESIA Section 7, • Details of the meetings held and stakeholder feedback was given within the ESIA Annex 7 https://www.tap-ag.com/resource-library/reference-documents/esia-documents/esia--in-english

Additional consultation on alternative routes took place during mid-February – early September 2014 including five meetings with representatives from TEE, GeoTEE and Farmers Union (KFU) representatives. Additional consultation with the public in communities affected by this rerouting took place in late September – early October 2014 as part of the Greece ESIA Addendum public disclosure and consultation process. Seven meetings were held including with the communities and/or representatives in Kalamonas, Kalampaki , Kryoneri, Nerofraxtis Philippoi, Prosotsani,and .

The route alternatives themselves were described in detail at the time within the ESIA Addendum – Alternatives in Tenagi area https://www.tap-ag.com/resource-library/reference-documents/esia-documents/esia-greece-in-english- additional-documents

The consultation and disclosure meetings were also outlined at the time within the ESIA Addendum and subsequent ESIA Amendment submissions, namely;

• Meetings held were listed within the ESIA Addendum – Alternatives in Tenagi, Appendix 4.1 https://www.tap-ag.com/resource-library/reference-documents/esia-documents/esia-greece-in-english- additional-documents

• Meetings held were listed within the ESIA Amendment Annex 7 • Stakeholder engagement was described within the ESIA Amendment Annex https://www.tap-ag.com/resource-library/reference-documents/esia-documents/esia-greece-amendment-in- english

The consideration of the routing within the Tenagi area and associated consultation and disclosure is included within the overall TAP Routing Report https://www.tap-ag.com/resource-library/reference-documents/project-finance-disclosure?page=3

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1.1 Route alternative designations

The various designations of route alternatives considered during the ESIA consultation process are shown in Figure 1.

Figure 1 - Tenagi Route Alternatives considered during ESIA consultation process

DESFA Alternative - Running parallel to the DESFA line (route suggested at scoping stage) 2013 Base Case - Submitted by TAP in 2013 ESIA South Alternative - TEE and GEOTEE proposal suggestion that runs south of the route in TAP’s original ESIA, submitted June 2013 North Alternative - Proposed by TAP during ESIA consultation North-North Alternative - Proposed by TAP during ESIA consultation (submitted by TAP in 2014 as the updated basecase and subsequently approved)

The North and North-North routing identification names in Figure 1 were those used during the consultation process. Upon submisison of the ESIA Amendment the North-North Alternative was simply referred to as the North Alternative.

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2. Meeting schedule, attendance & issues

Meetings held as part the consultation and disclosure process have already been included in the ESIA Addendum – Alternatives in Tenagi, Appendix 4.1 and ESIA Amendment Annex 7, and are summarised in Table 1. This summary highlights the issues that were raised by stakeholders;

Table 1 – Meeting Summary

Date Attendance (No.s) Issues raised 1 26/09/2013 TEE and GeoTEE • Why has the route changed from following the DESFA pipeline, mentioned at ESIA scoping stage? • Risks of subsidence, self-ignition, flooding and impact on land of high productivity • Restrictions on future development and reduction of land resources • Safety issues due to self-ignition, proximity to residential areas • Route crosses/fragments valley • No benefit to Greece nor local communities as only transit pipeline • Noise, air emissions, visual impacts and safety concerns re Serres Compressor Station 2 27/01/2014 Minister of • Same concerns as those mentioned in 26/09/2013 meeting Environment and • TEE, GeoTEE & KFU preference was for the South alternative interested parties to resolve the Tenagi Proposal from Ministry that TAP, TEE and GeoTEE work together issue at technical level and come back to the Ministry within a (included Region of reasonable time period with alternative proposals. Eastern Macedonia and Thrace, Mayors of Kavala and , MPs from Kavala, TEE, GeoTEE and KFU (17)

3 14/02/2014 TEE, GeoTEE East • Same concerns as previous meetings relating to crossing Macedonia Branch in Tenagi Turf Zone and location of CS at Serres the framework of • TEE, GeoTEE & KFU preference was for the South alternative trilateral Committee to resolve the Tenagi and CS issue and KFU (15) 4 24/07/2014 TEE, GeoTEE and • TAP presented two new alternatives North and North-North new Mayor in the • TAP explained why both the DESFA route and South framework of trilateral Alternative cannot be further considered Committee to resolve the Tenagi and KFU (30)

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5 07/08/2014 TEE, GeoTEE, • TAP again presented the two alternatives North and North- Regional Governor North. Mention was made of an unspecified alternative route and new Mayor in the that would be North of the North-North proposal. framework of trilateral • Similarly, as before TAP explained why the DESFA route Committee to resolve originally envisaged at the scoping stage cannot be considered the Tenagi and KFU further. (25)

6 30/08/2014 TEE, GeoTEE, • TAP again presented the two alternatives North and North- Regional Governor North. Mention was again made of an unspecified alternative and new Mayor in the route that would be North of the North-North proposal framework of trilateral Committee to resolve the Tenagi and KFU and Deputy Regional Governor (9)

7 03/09/2014 Minister of • Why had TAP rejected the DESFA route or the idea of an Environment and unspecified route North of North-North interested parties to • Previously mentioned risks and impacts upon the Tenagi resolve the Tenagi • Impact on future prospects of developing a lignite field in the issue, including area Regional and local • Impact on archaeology politicians, GeoTEE, • Pipeline is not re-routed outside peat zone TEE and KFU • Safety risks (16) • Additional pipelines will follow same route in future (A written statement of 20 outstanding questions was submitted to TAP – see Chapter 3.3) 12/09/2014 ESIA Signed 8 24/09/2014 Kalampaki Majority attendees wanted meeting to be cancelled due to Community with KFU objection to the approved route, these opposing stakeholders left present the meeting (27) • Concern that route change was sudden, unjustified and suspicious • Rejection of DESFA and South route alternatives • Pipeline route will destroy or negatively affect land redistribution • Pipeline will be fenced, land owners will lose the ownership of the land, and that TAP will have the right to cross their land without prior permission • Impact on local irrigation network. • Pipeline depth insufficient to protect from farming activities at the surface. 9 25/09/2014 Municipality Kavala • Route change in Tenagi area 10 25/09/2014 Zygos Community • Object to new basecase with KFU present • Rejection of DESFA alternative and South alternative (60) • Request to pursue the TEE alternative • Request completely avoid any agricultural land • Risks of CH finds/ impact on CH • Additional pipelines will follow same route in future

11 26/09/2014 Prosotsani Mayor • Route change in Tenagi area

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(4) • Level of engagement with local stakeholders • Health impacts from construction activities (related to dust), • Impact on high productivity agricultural land • Conflict with future development plans e.g. future exploitation of peat area. • Implications for OPEKEPE land subsidy 12 29/09/2014 Community • Message conveyed to TAP that there were many Presidents Zygos, misconceptions regarding the project, the way the pipeline will Kryoneri, Philippoi be constructed and potential impacts that may arise during and Krinides construction, or any limitations that the pipeline will impose to (4) the farmers. • Impacts during construction • Various concerns around land compensation 13 02/10/2014 Kalamonas • Rejection of TEE-AM and GEOTEE alternatives Community • Restrictions during construction (16) • Quality of land restoration • Health and safety impacts during pipeline operation. 14 30/09/2014 Mayor Doxato • Uncertainty of pipeline route preventing finalisation of future development plan in Doxato municipality 15 01/10/2014 Nerofraxtis • Depth of the pipeline and likely risks from agricultural activities community • Impact on local irrigation network (30) • Limitations during operational phase • Impact of soil subsidence

After the ESIA approval, at the end September 2014 a meeting was held at Parliament with the Mayor of Kavala, the MPs for Kavala and the KFU. In this meeting a request was made that TAP investigate a ‘further north’ routing which avoids the high-productivity land. While TAP was requested during this meeting to evaluate a “further north route” there was no formal submittal nor was a precise route noted on a map.

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3. Supporting Material

The following sections summarise the specific supporting material, in relation to route alternatives used in the consultation and disclosure meetings.

3.1 Consultation Meetings Figure 2 - The map used to discuss route alternatives during the tri-partite consultation meetings

DESFA Alternative - Running parallel to the DESFA line (route suggested at scoping stage) 2013 Base Case - Submitted by TAP in 2013 ESIA Tenagi Alternative Route 1 or North Alternative - Proposed by TAP during ESIA consultation Tenagi Alternative Route 2 or North-North Alternative - Proposed by TAP during ESIA consultation (submitted by TAP in 2014 as the updated basecase and subsequently approved)

3.2 Disclosure Meetings - Extract from presentation The following slides are an extract focussing on the route alternatives, taken from a wide-ranging presentation given during the disclosure meetings. The slides summarise information contained within the ESIA Addendum submission that was made available on TAPs website at the time.

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Other generic material used in the meetings was also made available on the TAP website; https://www.tap- ag.com/resource-library/marketing-materials/leaflets

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3.3 Disclosure Meetings - Written and published answers

During the meeting of 3rd September 2014 the KFU raised a series of questions to which TAP provided a response that was widely published and distributed at the time, for example; http://www.komotinipress.gr/topikes-kinonies- ke-agogos-tap/

The questions and answers given in 2014 are reproduced here;

Question 1: Is the TAP alternative proposal in the area of Tenagi crossing the turf area?

Answer 1: No. The north alternative of the TAP route is located outside the peat area.

According to the data of the soil study for Tenagi that has been performed by ETHIAGE this alternative route, which passes south of the villages of and Krinides, is located completely outside the peat area and is routed through a flat, farmed land, with annual cultivations and few irrigation channels. Based on the recent geophysical surveys it is confirmed that the new route is avoiding the peat area passing through soils with typical Quaternary sediments. After an additional optimization, the route runs predominantly along existing roads at the side of the land plot limits (i.e. avoids the diagonal crossing), thus minimizing the impact to cultivated farm land.

Question 2: Why has the route parallel to DESFA pipeline been rejected?

Answer 2: The reasons for the rejection of this alternative have been analyzed already, since the submission of the ESIA in June 2013. The main reasons are summarized in the following two key points:

1. Lack of space for the construction and installation of a second pipeline in total parallelism with the DESFA pipeline in the area south of the Antifilippoi hill. The crossing north of the hill is impossible due to the Archaeological Site of Paggaio and the mandatory crossing through a peat area with great depth.

2. The crossing of the Amygdaleonas area is not possible, since at the only point where the route is feasible there is not an adequate safety distance from a hospital. The new attempt to find a solution at the north is also not feasible due to the existing mall and the airport.

Question 3: Value reduction of complete and buildable land plots

Answer 3 After the installation of the pipeline, no plot loses its completeness and, with very few exceptions, neither do they lose their building rights. In case of a proven loss of right of constructability, the owner is compensated according to TAP’s compensation program.

Question 4: Will there be a reduction of the possibility to create commercial facilities and working place at a radius of 200m right and left of the pipeline, for example wood factories, cement and frames factory? Such businesses have more work positions than TAP will offer throughout Greece during its operation

Answer 4: There is no reduction in the perspective of creating commercial facilities at a distance of 200m left and right of the pipeline for the simple reason that the only restriction regarding building applies to the 20m zone on either side of the pipeline. The 200m zone right and left of the pipeline applies only to the potential expansion of a town plan or a settlement.

Question 5: During the last years, it has been observed that there has been an increase in processing facilities by farmers, it will not be possible for those persons that you will take their plots in these areas to construct such facilities.

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Answer 5: As it was mentioned above, there is no restriction in the development of such facilities. The pipeline installation neither changes the land uses nor the proprietary status of the land plots.

Question 6: The area is bound from the development of tree cultivations which is the trend of the last years. This means loss of income from the production and the added value of the products and of course loss of employment positions.

Answer 6: Restrictions in tree cultivations apply only on the 8m zone (4+4=8m in total on either side of the pipe), where planting of deep-routed plants is not allowed. Existing tree cultivations will be fully compensated. The exact prices and procedures will be given in the detailed compensation plans, which will be communicated to all affected land owners and user prior to the signing of any agreement. The basic principal applied is that no one will suffer any loss of income as a result of TAP’s activities. This principal will apply throughout the construction period, where the impact will be temporary, and also during operation, where there will be a limited but permanent restriction to the planting of deep-routed plants inside the 8 meter safety zone.

The Tenagi area is covered mainly with annual crops and not deep rooted, i.e. mostly maize, sunflowers, wheat etc. Hence, the construction of the pipeline does not impose restrictions to the existing cultivations.

Question 7: A corridor opens for the passing of another pipeline, with the well known results of occupation and restriction of our land from companies.

Answer 7: As it has been mentioned by the Minister, Mr. Maniatis himself in the meeting of 3/9/2014 in MEECC there is no strategic development plan for any other pipeline in the TAP corridor for the next 30 years.

Question 8: In case of an accident, the pipeline passes near several facilities, where people are working inside and near the Tenagi of Philippoi. In the former case there will be casualties while in the latter the whole Plain will burn without anyone being able to do something.

Answer 8: TAP pipeline will be constructed at a safe distance from populated areas and installations, according to most stringent requirements following both international and Greek regulations and best practice. The pipeline operation will be monitored on a 24 hour basis and precautionary measures will be adopted in any indication of abnormal operation.

The north alternative route avoids completely the main peat area, passing through typical Quaternary sediments. These soils do not present a self-ignition potential.

Question 9: In case of an accident there is no prediction for immediate response measures

Answer 9: TAP will ensure that it has all necessary systems, resources and trained personnel in order to deal effectively with any emergency incident that may occur. During the pipeline’s lifespan TAP will also cooperate with local fire brigades, police, health services etc. throughout the pipeline’s lifespan to provide the emergency preparedness required.

Question 10: The area is bounded from future, more lucrative, new dynamic cultivations.

Answer 10: There is no such restriction. As it has been mentioned earlier, the only restriction applicable is the one concerning the deep routed cultivations in the 8m zone.

Question 11: The employment places that will be lost due to the construction and the operation are more than those that will be created. 200-100 IENE, 39.7 hectares in Kavala corresponds to 23 employment positions during operation.

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Answer 11: It is not anticipated that there will be a loss of employment positions during the construction as well as during the operation. The temporary use of the 38m construction zone during construction does not imply loss of employment spots, since the rest of the agricultural land will be cultivated normally. The area of Tenagi is covered with annual intensive, irrigated cultivations and not trees, thus after the construction of the pipeline is completed the agricultural activities will continue as usual. Therefore, there will not be any loss of employment during the pipeline operation. Thus, the example of the 39.7 hectares in Kavala that equals to the loss of 23 employment positions is completely erroneous. Out of the 397 hectares necessary for the 8m zone (49.6 km x 8m = 39.7 hectares, 22.5 km in Nestos Municipality and 26.7 in Kavala Municipality, including the part of the mountainous route through the Kavala Mountains), it is estimated that only 0.5 hectares concern tree cultivations, thus the 23 spots become 23 x (0.5/39.7) = 0.3. We should repeat that neither this employment position will be lost because the whole assumption is erroneous.

Additionally, as it has been noted any loss of livelihood will be fully compensated according the Livelihood Restoration Plan.

TAP recognizes the great importance of the agricultural community and is therefore committed that:

• After construction is completed, land will be reinstated following the best possible standars.

• All impact on land and cultivations will be compensated based on “replacement values”, while it is TAP’s intention to pay all compensation prior to pipeline construction.

• In most cases construction usually lasts for some months. However, farmers will be compensated for 2 years in order to assure that the land productivity is fully reinstated and that no one will suffer a loss of income.

• After the end of construction and the reinstatement, the agricultural activities in general will be restored as before. However some restrictions will apply due to national safety regulations such as the planting of deep rooted plants in the 8m zone (4+4 meters). In case that these restrictions have an impact on any farmer, he will be compensated. The rest of the land plot will be cultivated as before.

Question 12: Internal safety zone – construction by third parties

Answer 12: There is no internal safety zone. As it has been mentioned above, the 40m safety zone (20+20 m) refers to the building restriction that is imposed by the Greek Technical Regulation and is obviously mandatory to be followed (as in any pipeline in the Greek territory). Moreover, it is allowed inside the 40m zone to construct new greenhouses and not only to reconstruct them as it is mentioned.

Question 13: Depreciation of the Archaeological Site and direct risk that it will not be included as a protected archaeological area by UNESCO.

Answer 13: The pipeline is underground, thus there will not be any (visual) impact on the Archaeological Area of Phliippoi. Additionally, the Ministry of Culture has assured TAP that there will be no problem whatsoever with the candidacy of the Archaeological Area of Phliippoi as a UNESCO cultural heritage monument. In parallel, the precautionary surveys that will take place prior to construction (trial cuts etc.) and the works supervision by competent employees is possible to lead to the discovery of more findings, helping even further in the highlighting of the archaeological treasures of the area.

Question 14: High productivity land is protected by law as a common good, there are references of the Prime Minister, of Ministers and Parliament Members that the primary sector along with tourism are the main pillars of growth for the country and for exiting the crisis. The land is also protected, where redistribution of land and land reclamation has taken place, like in our area.

Answer 14: The pipeline installation doesn’t change the land uses of the area. As it has been mentioned above, with a further optimization of the routing, the issue of the impact on the use of agricultural land in minimized

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at the best possible extent since the pipeline in the Plain of Philippoi is following mainly existing roads, irrigation channels and along the borders of land plots.

Question 15: In the ESIA a 8m zone is foreseen that will always be accessible for the monitoring and the maintenance of the pipeline, in many sections it is mentioned that monitoring and maintenance will be performed with vehicles, therefore the land will not be cultivated. This way not only will the land be cut up, but the area will be bisected.

Answer 15: The assumption that the agricultural land in the 8m zone will not be cultivated (for accessibility purposes) is erroneous. The pipeline monitoring will be performed by cars using only existing roads near the pipeline.

Question 16: They are designing the pipeline in plots or next to plots, while at the same time they are telling us it cannot pass next to the Egnatia Highway for safety reasons. Obviously, we are expendable.

Answer 16: TAP pipeline, in a great length, is route parallel to Egnatia Highway (outside the expropriation zone) by applying the infrastructure bundling principal (where it is feasible).

Question 17: The total income from processing and the added value that will be lost during construction from the occupied land including compensations, is almost the same as the financial benefits for my Homeland from the passing of the pipeline. In order to have a substantial profit, the pipeline should pass from points where the occupied land is not productive.

Answer 17: As it has been previously mentioned, there will be no loss of income coming for processing or added value for the simple reason that TAP will provide compensations for all impacts on land and cultivations and will ensure the reinstatement of livelihoods. Land owners and users, whose land and cultivations are affected by the Project will be compensated based on the “Replacement Value” and will receive their compensation prior to construction in order to ensure that no one will suffer any difficulty due to loss of income. After the construction is completed, agricultural activates will in most cases be restored as before, but some restrictions will still apply in the 8m zone (4+4m), where the planting of deep-routed plants is not allowed. In case of permanent restrictions in the exploitation of land, it will be ensured by acquiring easement rights and TAP will compensate the farmer according to Greek Legislation and international standards. In contrary, the benefits for Greece are important both in geostrategic level as well as in the creation of employment positions.

Question 18: Future necessary infrastructure projects in the area will have an additional cost and it will take TAP’s consent, it is not foreseen anywhere who will bare this additional cost.

Answer 18: This issue is dealt with as for all existing infrastructure projects in the Greek territory.

Question 19: The data that TAP is presenting are selective and unreliable with the intention to cheat us; we explained in our previous meeting some points and today there is more--- IGME, ETHIAGE, topographical service of Drama.

Answer 19: All data and information that have been collected by TAP during the development of the Project and especially those included in the ESIA come from the most reliable, official and valid Greek and European sources, the quality of whose is at the highest possible level. In particular, the new north alternative route has been designed taking into account the data available from the soil study of Tenagi, which was performed by ETHIAGE in 2001, the corresponding data of IGME and the data from the Topographical Service of Drama. It is noted that these data have also been provided to TAP by GEOTEE-AM.

Question 20: The energy future of our Country is put at stake and this arises from the JV’s persistence in passing the pipeline from specifying points; the need to exploit energy reserves in the future is mentioned in the statements of various members of Ministries.

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Answer 20: As it has been mentioned by the Minister Mr. Maniatis in the meeting of /9/2014 in MEECC, there is no strategic plan for exploiting any other energy reserves in the area and specifically the lignite field of Drama for the next 30 years.

Question 21: With land occupation in many cases there will be a loss of livelihood of some farmers; this is proven by statements of members of the JV, Ampeli in Kastoria (the substantial decrease of the farmer’s income because of the pipeline passing through cultivated land, which constitutes an income production tool. Besides that, the JV indirectly admits that the compensations will not counterbalance the loss of income in the long term).

Answer 21: TAP recognizes the great importance of the agricultural community and is therefore committed that:

• After construction is completed, land will be reinstated following the best possible standards.

• All impact on land and cultivations will be compensated based on “replacement values”, while it is TAP’s intention to pay all compensation prior to pipeline construction.

• In most cases construction usually lasts for some months. However, farmers will be compensated for 2 years in order to assure that the land productivity is fully reinstated and that no one will suffer a loss of income. The rental fee for the construction strip will be calculated based on the anticipated income of the affected land for two years.

• After the end of construction, land is reinstated according to the best possible standards, like for example by assuring that top and sub soil have been stored separately and are placed back in the right order, ensuring that agricultural activities will be restored as before. In some cases however, because of national safety regulations some restrictions will apply, such as the planting of deep rooted plants in the 8m zone (4+4 meters), the affected farmer will be fully compensated. The rest of the land plot will be cultivated as before.

• Expropriation for land acquisition or easement rights through properties are an alternative for TAP. However, according to international standards and the principal for socioeconomic protection that TAP has chosen to adopt, before carrying out expropriation procedures TAP will seek to establish commonly accepted agreements with the affected land owners, proposing compensations that are calculated in such a way that no one will suffer a financial loss because of the Project.

• During the Project’s construction a 38m wide “construction corridor” will be required. Access to this area will be limited and land cannot be used for agricultural activities, like cultivations and cattle breeding. Any land owner that will be affected by this restriction will be fully compensated.

• If the construction corridor or the 8m safety zone leave sections of land on either side that will not be required for the Project, making the remaining part of the land might too small to make cultivation economically viable, then these parts are classified as “orphan land”. Owners of this land will be compensated in the same way as for the land directly affected by the construction corridor.

TAP will only purchase land for the compressor stations and block valves. Instead, TAP will rent the land for as long as the construction and the reinstatement to the previous situation require. TAP will commit in compensating land and cultivations for the zones where permanent restrictions for the ensuring of Health & Safety of everyone are required.

We note (for the example mentioned in the question) that the irrigated plot can be newly cultivated over the 8m safety zone.

Question 22: In the previous meeting, the Minister gave a direct order to reach a commonly accepted solution, a fact that is not the case now. Any routing proposal that exists is not being accepted by the company (TAP) if it does not route through farmed land.

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Answer 22: All alternative proposals have been thoroughly investigated and assessed by TAP, but their acceptance was not possible due to the fact that they didn’t meet the minimum requirements for a technically safe and environmentally acceptable route according to the international pipeline best practice. It is aimed by all means to constitute the north alternative route (that successfully addresses the issues of the peat avoidance and the use of agricultural land) as the commonly accepted proposal.

Question 23: Compensations

Answer 23: TAP will only purchase land for the construction of the compressor stations, the block valves or any other above ground installation. All other land required for the construction of the pipeline will either be rented by TAP or submitted to an easement status.

In such cases compensation is calculated as follows: • Compensation for land at replacement value. • Compensation for any standing annual or perennial crops at replacement values. • Compensation for standing annual or perennial crops at replacement values.

The compensation is foreseen during construction and it will be calculated based on leasing the 38 m wide construction strip for two years. The occupation of a plot is not expected to exceed 6 months. After the construction is completed the land is returned to the user for cultivation. For the 8m safety zone some restrictions will apply for safety reasons and the construction of buildings, deep ploughing and planting of deep-routed trees will not be allowed.

Where the owner and the actual user of the affected land plot is the same individual, this person will receive all elements of compensation as per the Compensation Program.

Where land is farmed by a land user separate from the landowner, the share between the landowner and the land user will be the following:

In permanently acquired land by TAP: • Compensation for land to landowner. • Compensation for crops to land user.

In cases of temporarily occupied land: • Land rental fee to landowner. • Livelihood restoration allowance to land user. • Compensation for crops to land user. • Compensation for restrictions to land owner.

Compensation for any structures and developments on land (irrigation, drainage) will be paid to the owner of such structures and developments.

The following are clarifications/updates to the answers given in 2014;

Question 13: Philippoi CH is now included as a UNESCO World Heritage Site

Question 23: The compensation for trees is paid to the owners and not the users, as trees are considered to be components of the land and are compensated together with the land, as per Greek law.

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