TUZ GÖLÜ UNDERGROUND NATURAL GAS STORAGE PROJECT. E Issued for approval E.D. / B.E E.D M.Ş. D Issued for approval E.D. / B.E E.D M.

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1 Public Disclosure Authorized SFG2284 TUZ GÖLÜ UNDERGROUND NATURAL GAS STORAGE PROJECT E Issued for approval E.D. / B.E E.D M.Ş Public Disclosure Authorized Public Disclosure Authorized D Issued for approval E.D. / B.E E.D M.Ş C Issued for review B.S. / B.E. B.S. M.Ş. B A Inter-discipline check Discipline internal check Rev.No. Date Description SIGNATURE B.S. / B.E. B.S. M.Ş. B.S. / B.E. B.S. M.Ş. Prepared Checked Approved BOTAŞ BOTAŞ PETROLEUM PIPELINE CORPORATION Public Disclosure Authorized CINAR Engineering Consultancy Inc. Org. Code Document Title TUZ GOLU UNDERGROUND NATURAL GAS STORAGE PROJECT RAP COMPLETION REPORT Doc. Type Document No. Disc. Code Geog. Area Ser. No. Rev. No. Total pages (without attachments) CNR REP ENM ADD 13/001 E 28

2 2 / 28 TABLE OF CONTENTS Page Table of Contents 2 List of Tables 3 List of Figures 3 List of Photos 3 Abbreviations 4 1. EXECUTIVE SUMMARY INTRODUCTION Project Description Land Acquisition Plan and Monitoring Studies Objectives LAND ACQUISITION PROCESS PROJECT- AFFECTED POPULATIONS SUMMARY OF PREVIOUS ENGAGEMENT ACTIVITIES Consultation Meetings Surveys GRIEVANCE MECHANISM ADDITIONAL SOCIAL SUPPORTS CONCLUSION APPENDIX... 28

3 3 / 28 LIST OF TABLES Table 3.1. Amounts of Different Compensation Types... 8 Table 3.2. Data on Land Acquisition Profile and Affected Landowners... 9 Table 4.1. Project-Affected Settlements...15 Table 5.1. Details on Consultation Meetings...22 Table 6.1. Process of Grievance Mechanism...18 Table 6.2. Registered Complaint List...22 Table 7.1. Number of Local Employment...22 Table 7.2. Local Subcontractors...21 LIST OF FIGURES Figure 3-1 Main Sources of Income Reported by Surveyed Landowners...19 Figure 3-2 Attitudes of Surveyed Landowners towards Land Acquisition...20 Figure 3-3 Intensions of Surveyed Landowners about Compensation...20 LIST OF PHOTOS Photo 4-1 Snapsot from Land Acquisition Consultation Meeting (1)...16 Photo 4-2 Snapshot from Land Acquisition Consultation Meeting (2)...16 Photo 4-3 Snapshot from Land Acquisition Consultation Meeting (3)...17

4 4 / 28 ABBREVIATIONS BOTAS LAP PAPs UGS BOTAS Petroleum Pipeline Corporation Land Acquisition Plan Project Affected Populations Underground Gas Storage

5 5 / EXECUTIVE SUMMARY Tuz Gölü Underground Natural Gas Storage Project which is located in Sultanhanı locality of Aksaray province, at about 40 km south of Tuz Gölü, aims to answer the increased energy demand by storing and using natural gas underground. The components of the project are pipelines (fresh water line, brine discharge line and natural gas branch line), pump stations, storage tanks, energy transmission lines, surface facilities and UGS sites. The construction of the natural gas, water and brine pipelines, the pumping stations and gas storage areas including 12 wells all require acquisition of about 749 hectares (ha) of land in the Project, either temporarily (382 ha) or permanently (367 ha). The components which require permanent acquisition of land are pump stations and well areas. Energy transmission lines, water lines and brine lines require long term easement. Among the land required for the project, 44% is public whereas the remaining 56% is private, affecting 4,061 number of landowners. The land acquisition activities were commenced on 3 rd October The public has been informed about the land acquisition process via announcements, consultation meetings, brochures etc. %57 of lands were acquired through negotiations, while the %43 were acquired through court cases. Court cases were opened for 438 parcels and they all have been finalized. The methodology used for the appraisal of immovables, namely the appraisal criteria, is based on the market price criterion and income capitalization criterion. Appraisal criteria vary according to the type, purpose and marketing status of the property subject to appraisal. Both criteria were jointly used for appraisal during expropriation and partial expropriation proceedings. The appraisal expert has used a direct comparison method and taken into account the latest purchasing/sales prices of plots similar to that subject to appraisal. There are currently 27 settlements which are affected by the Project since the plots which are subject to land acquisition for all Project components are within the territorial jurisdiction of those villages. Land acquisition activities undertaken for the Project has resulted in the economic displacement of PAPs. There has been no physical displacement due to land take. The potential impact on livelihoods due to loss of land has been kept to a minimum by BOTAŞ through the selection of barren lands. Currently there are no households whose livelihoods were affected severely, as the majority of the land owners have other investments with highly paid compensations. Additionally, PAPs have multiple sources of income, and use farming as supplemental income, which has also reduced the level of impact of acquisition activities. The total amount of compensation paid to landowners is 4,521,808.51TL as of March The total amount paid for permanent land acquisition is 3,178,605,37 TL, while the total amount for permanent easement is TL. The remaining 675, TL covers the costs of temporary easement, outhouse acquisition and seasonal crops. The acquisition of land was carried out in line with the Turkish Legal Framework as well as World Bank Policy (OP 4.12) on Involuntary Resettlement and compensation. Compensation for land acquisition under Tuz Gölü Underground Natural Gas Storage Project has been carried out in compliance with Expropriation Law (Law No.2942, dated

6 6 / 28 8/11/1983). These laws and regulations, in essence, intend to ensure that PAPs can rapidly restore their work and living to the level before the impacts, and restoration costs should be deemed as the evidence to justify the compensation standards. Prior to construction only crops and trees have been removed. Affected persons have been and will be compensated for all the trees and crops that are likely to be destroyed during the construction and those that were destroyed during the survey. The compensation is equal to the full replacement cost as determined by the District land Board. It is to be noted that the district rates are annually adjusted to try and provide compensation at replacement cost for crops and trees. Also, a grievance mechanism has been set up to implement Community Grievance Procedure which was developed by BOTAŞ during the execution of LAP. The information about this mechanism has been provided to PAPs during the consultation meetings and all the complaints which registered in the system were resolved in a timely manner.

7 7 / INTRODUCTION 2.1 Project Description As a result of energy demand which is brought about by population increase and resultant increase in natural gas usage, it is of vital importance for Turkey to store and use natural gas underground. A variety of projects are being developed in line with this increased demand which aim to prevent any potential seasonal fluctuations in the future as a result of increasing natural gas demand by the residential sector. One of these projects is the Tuz Golu Underground Natural Gas Storage Project developed by BOTAS. The Project is located in Sultanhani locality of Aksaray Province, at about 40 km south of Tuz Golu. Within the scope of the Project, salt cavern storage facilities will be developed by melting a portion of extensive underground natural salt structure that exists at a depth of around metres below the ground level through leaching with fresh water in a controlled manner. In this context, it will be ensured that surplus natural gas supplies which particularly emerge in summer months nationwide are diverted for storage in salt caverns to be developed, through an off-shoot from Kayseri Konya Seydişehir section of the Eastern Anatolia Natural Gas Main Transmission Line crossing from about 14 km north of the project site. It will further be achieved upon accomplishment of the project that the natural gas stored in the salt caverns is withdrawn and supplied into the Kayseri Konya Seydişehir section of the Eastern Anatolia Natural Gas Main Transmission Line in order to meet the increasing natural gas demand in the intensive periods nationwide. The Project consists of the following components: Pipelines; - Fresh Water Line from Hirfanlı Dam to Underground Gas Storage (UGS) Sites, - Brine Discharge Line from UGS sites to Tuz Golu, and - Natural Gas Branch Line to Eastern Anatolia Natural Gas Main Transmission Line Pump Stations and Storage Tanks, Energy Transmission Lines, Surface Facilities, and UGS Sites. 2.2 Land Acquisition Plan and Monitoring Studies ÇINAR Mühendislik and Müşavirlik A.Ş. has been commissioned by BOTAS Petroleum Pipeline Corporation (BOTAS) to undertake resettlement monitoring of Tuz Golu Underground Gas Storage Project.

8 8 / 28 A Land Acquisition Plan (LAP) was prepared for the Project in June 2005 which describes the framework and procedures that the Project will follow for the acquisition and compensation of land and assets, both for permanent and temporary uses. The 2005 LAP was disclosed in BOTAS web page and World Bank s info shop in June The 2005 LAP was then revised as of February 2013 in order to; Reflect the changes in land acquisition strategy for well areas; Incorporate the land acquisition for the energy transmission line for the pump stations of water supply line and facilities; and Incorporate the land acquisition for the access roads to pumps stations of water supply line and facilities. In line with the revised LAP document, an external social monitoring study was conducted between January 2013 and March 2016 mainly to: Summarize progress against the LAP, Inquire about feedbacks/concerns of the PAPs about the Project, Make an assessment of the impacts of land acquisition on socio-economic wellbeing of the PAPs, Monitor the implementation of Grievance Mechanism, and Provide input for further monitoring studies. Based on the information gathered through the external monitoring study, this RAP completion report was prepared. 2.3 Objectives This report sets out to assess the implementation of actions which are described in LAP, the efficiency of compensations in providing a sustainable solution for the impacts on PAPs, the satisfaction from the reinstatement of lands and positive or negative impacts of land acquisition on local settlements and people. Land acquisition process and project affected people have been described and previous engagement activities such as consultation meetings and surveys, an assessment of grievance mechanism, registered complaint list and additional social supports are presented. The main objective of this Report is to provide information on land acquisition activities undertaken to date, to put forth the needs for any on-going acquisition works, to describe the magnitude of displacement, activities undertaken, grievances and key issues addressed and still outstanding, and describe the on-going monitoring and evaluation process. In this respect, the report includes the following information:

9 9 / 28 Background of the RAP preparation including a description of the project activities, scope of impacts, number of affected persons Implementation with actual numbers of displaced persons by segments, compensation paid, issues/complaints raised and solutions provided Complaints status Assessment of the impacts compensation on affected categories at the time of the report production Ongoing land acquisition activities and its monitoring process The report is based on; Assessment of BOTAS social management system, Review of available documents including LAP, and Review of field practices and pertinent outputs.

10 10 / LAND ACQUISITION PROCESS As provided in LAP, the local legislative framework provides adequate compensation to affected private and public parties in a fair and transparent manner [Ref: Land Acquisition Plan, Section 6]. With respect to the Turkish legislation, BOTAŞ is responsible for the implementation of all land acquisition and resettlement activities of the Project. The land acquisition process was initiated by the Department of Land Estate and Expropriation within BOTAŞ in accordance with Approval number 1423 on October 3, First compensation payments were made in December The process was finalized when compensation payments were completed on March Table 3.1 below shows the distribution of acquired land for each Project component in terms of ownership type, amount of land required and impacted parcels. Table 3.1. Data on Land Acquisition Profile and Affected Landowners SECTIONS NO.OF PARCELS AREA (ha) NO. OF LANDOWNERS TOTAL Private Public Temporary Permanent Section 1* Section 2** Section 3*** Section 4**** Surface Facility Sub Total (1) Private Public Private Public Well Area Energy Transmission Sub Total (2) TOTAL (1+2) *Hirfanlı Dam- Natural Gas Pipeline **Natural Gas Pipeline (Parallel Section) ***Natural Gas Pipeline Storage Area ****Storage Area Disposal Area All project components including the construction of the natural gas, water and brine pipelines, the pumping stations and gas storage areas 12 wells require acquisition of about 749 hectares (ha) of land in the Project, either temporarily (382 ha) or permanently (367 ha). Total amount of land acquired is 44% public and 56% private, affecting a total of 4,061 landowners. The amount of private land subject to acquisition was 1,036 plots. Since permanent land acquisition is only required for surface facilities and UGS sites and 64 (61+3) landowners were affected out of a total of 4,061 landowners. A significant part of the lands expropriated are for temporary use. The acquisition of public land was carried out from General Directorate of National Real Estate. 749

11 11 / 28 Prior to acquisition of private lands, land and product valuations were conducted by the Commission of Appraisal and an Expert. In line with the appraisal made, land owners were contacted for negotiations. The majority (%57) of the lands required were obtained through negotiated settlements. In cases where negotiations failed, the expropriation process was commenced based on Article 10 of the Expropriation Law. Compensation to all affected landowners was disbursed from the beginning of 2012 to Compensation for land acquisition under Tuz Gölü Storage Project was carried out in strict compliance with The Expropriation Law (No. 2942); the compensation agreements reached between BOTAŞ and the involved provinces, and the compensation standards defined in LAP. Subject law and regulations, in essence, intend to ensure that PAPs can rapidly restore their work and living to level before the impacts, and restoration costs should be deemed as the evidence to justify the compensation standards. During the process of land acquisition, different types of compensation have been provided to affected land owners: Permanent Land Acquisition Prices (Pump stations and well areas) Permanent Easement Prices (Energy transmission lines, water lines, brine lines) Temporary Easement Prices Outhouse Acquisition Prices Seasonal Crop Payments The appraisal of land was based on an appraisal criteria. Appraisal criteria vary according to the type, purpose and marketing status of the property subject to appraisal. There are 2 criteria used for appraisal: Market price criterion, Income capitalization criterion. Both criteria were jointly used for appraisal during expropriation and partial expropriation proceedings. A direct comparison method taking into account the latest purchasing/sales prices of plots similar to that subject to appraisal was used by the appraisal expert. Factors affecting the value of a plot include: location, shape, physical structure of the soil, road frontage; width of the road by the plot, restraining provisions of the city plan.

12 12 / 28 A price survey was done at this time by keeping in mind all the criteria listed above. A site visit was conducted by a committee and according to the law, the prices were determined. Appraisal experts have evaluated the average price per square metre to be calculated on the basis of purchasing/sales prices of similar plots- by taking into account all the positive and negative features affecting the value of the plot subject to appraisal. In addition to the land market price, the Committee took into account the crop on the land and compensated crop loss without seed expense. Trefoil, white beet, wheat and barley were compensated according to the rates identified by Chamber of Agriculture. Since there has been no urgent expropriation and judicial registration of lands during the acquisition process, the normal procedure (Article 10 of the Law 2942) was followed. The amount of compensation provided to landowners can be seen in Table 3.1. Table 3.2. Amounts of Different Compensation Types Total of Permanent Land Acquisition Price TL Total of Permanent Easement Price TL Total of Temporary Easement Price TL Total of Outhouse Acquisition Price TL Total of Seasonal Crop Payment TL Total of Urgent Acquisition Price 0.00 TL Total of Judicial Registration Price 0.00 TL Total of Paid Compensation TL The court cases were opened for 438 parcels and they all have been finalized. There is no open case currently.

13 13 / PROJECT- AFFECTED POPULATIONS As mentioned in the section above, a total of 4,061 landowners have been affected by the project. Among these PAPs, 3,413 of landowners were affected by pipelines while 587 were affected by energy transmission lines. Only 64 landowners were affected by the well area and surface facilities. The plots which are subject to land acquisition for all Project components are within the territorial jurisdiction of 27 villages. These villages are in the boundary of Ankara and Aksaray provinces (see Table 4.1.) Table 4.1. Project-Affected Settlements Province Districts Number of Villages Names of Villages / Sub-districts Ankara Evren 1 Çatalpınar Aksaray Sarıyahşi 2 Boğazköy Bekdik Ağaçören 8 Kütüklü Camili Kederli Abdiuşağı Çatalçeşme Hacıismailli Yenice Kaşıçalık Ortaköy 6 Hacımahmut Uşağı Hacıibrahim Uşağı İsaklı Hıdırlı Oğuzlar Camızlık Merkez 10 Sapmaz Baymış Yeşiltepe Cerit Yeşilyurt Bostanlık Yenikent Sultanhanı Yeşilova Sarayhan The Project involves economic displacement of 4,061 landowners. There is no physical displacement within the scope of the Project. Hence, no people have lost their dwellings and were not required to move involuntarily. The impacts of the land acquisition activities of the Project can be listed as: Loss of land for agricultural cultivation; Loss of grazing and pasture land; Reduced livelihoods or productivity loses.

14 14 / 28 However, it is possible to say that there is no major impact on livelihoods by the Project. The people whose land were expropriated usually have other lands to continue their agricultural activities and there are also additional areas for animal grazing. The impacts on animal husbandry and agriculture activities have been mitigated by the compensations. Land acquisition largely involves easement on land which enables the PAPs to use their land after the reinstatement of land followed by the completion of construction. Permanent land acquisition is only required for surface facilities and UGS sites in which 64 landowners affected out of a total of 4,061 landowners. All the lands which have easement, have been returned to their owners with certain limitations such as planting deep and strong rooted plants, building structures and drilling. There were no renters on the lands which were subject to land acquisition.

15 15 / SUMMARY OF PREVIOUS ENGAGEMENT ACTIVITIES 5.1 Consultation Meetings A number of consultation meetings were held up to date and pertinent details are given in Table 5.1. below: Table 5.1. Details on Consultation Meetings Date Venue Participants Scope of Meeting Sultanhani Municipality Meeting Room Sub-governors, muhtars Brief presentation to give information about the project Sultanhani Municipality Meeting Room Muhtars and local people General description and scope of the project, need for the project, the project site Sultanhani Municipality Meeting Room Muhtars and local people The project site, duration of the project Sultanhani Municipality Meeting Room Sub-governors, muhtars and the land owners Description of the land acquisition process Construction Site Office Land owners Potential impacts of the project and proposed mitigation measures Construction Site Office PAPs Potential impacts of the project and proposed mitigation measures Construction Site Office PAPs Current positive or negative impacts of the project Construction Site Office PAPs Current positive or negative impacts of the project Construction Site Office PAPs Current positive or negative impacts of the project Construction Site Office Landowners, local employees and muhtars A general assessment of how land acquisition process has affected the local people The meeting on was mainly about land acquisition issues and announced on The main issues listed below were discussed during the meeting: Land expropriation and compensation (private, pasture lands, crops and assets etc.) Damage to infrastructure (roads, irrigation channels, etc.)

16 16 / 28 Reinstatement (this was raised especially by the Muhtars of the villages which are on the gas line route) Impacts on livelihoods (i.e. animal husbandry; access to grazing lands) Photo 5-1 Snapsot from Land Acquisition Consultation Meeting (1) Photo 5-2 Snapshot from Land Acquisition Consultation Meeting (2)

17 17 / 28 Photo 5-3 Snapshot from Land Acquisition Consultation Meeting (3) The LAP was distributed to sub-governors and Muhtars who requested to review the document and convey questions and comments to BOTAS. The officials were also requested to make the document available in a place accessible to the public at each location. BOTAS received no comments on the document during land acquisition process. Latest meeting was held on with Sultanhanı muhtar, a local security employee and landowners. The main issues discussed during the meeting were; Adequacy of the compensations provided to landowners Land expropriation and compensation (private, pasture lands, crops and assets etc.) Overall satisfaction from the reinstatement of land Positive or negative impacts of land acquisition on local settlements and people Sultanhanı Muhtar mentioned that the land acquisition process and the Project had some positive impacts on their settlement. He stated that 5 people started doing animal husbandry with the compensation and approximately 150 people (of which almost 50 are women) from Sultanhanı were employed by the Project up to now. It was learned that the migration rate in Sultanhanı had decreased compared to the previous years. During the interviews it was mentioned that the lands used for agriculture were not fertile due to the high salt rate, therefore only wheat and barley could be cultivated. Additionally, the lack of rainfall would generally result in loss. It was highlighted that the compensation made for this type of land was higher to the average market price and many of the villagers were satisfied.

18 18 / 28 BOTAŞ has implemented a community relation program (CR) for the communities that may be affected directly or indirectly by land acquisition and construction activities. The primary goal of this program is planned to reduce adverse impacts of the land acquisition and construction activities on these communities and bring positive outcomes, so that community support to the project is maintained. Through successful community relations program, there has been an effective mechanism provided to communicate local concerns and grievances and to address these concerns. During the execution of project, community relation supervision team (has contacted with affected landowners periodically to identify any community concerns or complaints of the project affected communities to encourage them to raise their concerns. No specific complaint has been recorded from affected land owners. However, some grievances were received during consultation meetings regarding the remaining part of land after acquisition or damage to lands/crops. BOTAS and its subcontractors have resolved these grievances by compensating damages to crops and by taking other relevant measures. BOTAS has ensured that landowners informed throughout the process and been satisfactorily compensated. 5.2 Surveys For the private parcels to be acquired permanently for UGS sites, surveys were conducted with the landowners by BOTAS personnel during the period of March 2013 December 2013 to collect socio-economic information about the landowners before their land is acquired. There are total 64 land owners who are affected from permanent land acquisition. Since 33 landowners whose lands were subject to permanent acquisition cannot be reached due to living in other cities or residing abroad, the surveys were conducted with the remaining 31 PAPs currently living in the Project area. None of the 31 landowners have homes on the parcels acquired. In fact, many of the PAPs live 15 to 20 kilometres away from the subject parcels, and some live even farther in the nearest city Nigde (about 160 kilometres away). The lands are farmland used for dry agriculture. Wheat and barley are the most common crops. 16 of the interviewees responded that they farm the land themselves, 10 responded that the land is not used / vacant, and 5 responded that they rent their lands. For all 31 landowners, the entire (100%) parcel was acquired. Although the entirety not required for well areas, BOTAS decided to acquire the whole entire parcel since the remaining areas would not be feasible for any purpose. Nevertheless, 16 of the landowners cultivating the acquired lands, already have other lands in the area.

19 19 / 28 Main sources of income reported by the surveyed landowners are depicted in Figure 5-1. As seen from the figure, 18 landowners reported that their main source of income is dependent on farming while 10 of the landowners have a main source of income that is not dependent on land (government job, trade, carpet selling, housewife and pension payments). Figure 5-1 Main Sources of Income Reported by Surveyed Landowners When the surveyed landowners were asked how land acquisition will affect them, 19 respondents stated that they will be affected positively by the land acquisition and the compensation (see Figure 5-2). 7 respondents reported that land acquisition will have no effects on their lives. 2 respondents assume they will adversely be affected by land acquisition 1. 1 person was unclear since she said she is not sure what effect it will have on her yet. 1 Among these 2 respondents, 1 of them stated that there will be a reduction in the size of planting area. The other respondent mentioned that he needs to re-establish his life. 2 hectares of land belonging to this person was expropriated and he has 9.5 hectares land in the vicinity. The well he used for irrigation was on the expropriated land and he stated that he will need to dig a new well on his remaining land.

20 20 / 28 Figure 5-2 Attitudes of Surveyed Landowners towards Land Acquisition According to the data gathered from the surveys, it is conceivable to think that the landowners whose land were acquired permanently are satisfied with the compensation in regard to their answers on what will they do with the compensations. Whereas some of them are planning to buy other land, some others stated that they will establish small scale businesses with this money and start trade activities. There is also a group of landowners who plan to buy a car or real estate, or expand their herds by buying additional animals (see Figure 5-3). Figure 5-3 Intensions of Surveyed Landowners about Compensation Long-term easement has been acquired along the route of fresh water and brine discharge pipelines and energy transmission lines, rather than purchasing property outright. All impacted property owners were contacted and informed regarding the process. During the easement acquisition process, negotiations took place with owners of land to settle all adverse impacts caused by the lines on affected property. Prior to construction activities, land easement and product valuation were completed and eligible compensation to all affected land owners was disbursed. After completing any work on the lines, the surface of the easement property was reinstated; and landowners continue to use the property for activities such as farming as long as the activity does not interfere with operation and maintenance of pipelines and transmission lines. An additional survey was conducted between March in order to retrieve feedback from landowners regarding the completed land acquisition process (see Appendix). The survey was conducted with 8 people whose land were subject to permanent (fully or partially) land acquisition or easement (permanent or temporarily). The results of this survey can be summarized as;

21 21 / 28 7 out of 8 people interviewed stated that they were using their lands (subject to acquisition) for agricultural purposes. Only 1 person stated that he was not farming and the land was currently uncultivated. When the interviewees were asked for their ideas about how they were affected by land acquisition, all of them stated that it affected them positively but in different ways; I m currently doing trade. My income increased with the compensation. I bought a new irrigated farm land with the compensation. I m still dealing with agriculture. Actually there has been no significant impact. But my land was too dry and I wasn t getting efficiency. The compensation was higher than its real value. Now that I bought an irrigated farm land, I m making profit. It affected me positively. My income has been increased. I bought two houses. 3 out of 8 interviewees stated that they purchased new irrigated farming lands and that their income had increased since their former lands were already arid and infertile. Other interviewees indicated that they used the compensation for buying a house, for trade or to meet their needs. All of the interviewees stated that the compensation was adequate and allowed them to increase their income. All of the interviewees stated that they had no problems or complaints regarding the land acquisition process. As an overall assessment of the last survey conducted, it is possible to say that landowners have been affected positively from the land acquisition process since the agriculture activities were not productive and they had a chance to use the compensations in different ways to increase their incomes. It was also observed during the interviews that the landowners were pleasant about land acquisition and has no problem or complaints regarding to the process.

22 22 / GRIEVANCE MECHANISM During the execution of LAP, BOTAŞ has developed a Community Grievance Procedure that lays down clear process at three levels described in Table 6.1. This procedure has been disclosed extensively through the consultation meetings and the commitment of resolution of grievances at reasonable and realistic timelines has been met so far. Whereas there were no complaints at the beginning of acquisition process, some complaints occurred later about the lack of payment caused by restrictions such as hypothec, inheritance, etc. But these issues resolved and they received the compensations. Six (6) construction related complaints have been received due to construction activities in different sections of the project site. The actions have been taken in order to resolve grievances in cooperation with the Contractor aiming at high satisfaction of complainants. There was a case of sheep death near project area in which the complainant has gone to local land court; and currently BOTAŞ has appealed against this case and judicial process is still proceeding (See Table 6.2.). Apart from this case, there have been no overdue grievances or grievances where no consensus is foreseen to be reached with the complainants so far. Table 6.1. Process of Grievance Mechanism Levels of Grievance redress order Complainant submits his/her complaint to: Form of submission Steps of grievance management Time for review of the complaint 1) Muhtar refers grievance to BOTAS. Level 1 Mr. Ozcan Ozdemir (Gazi Mahallesi - Muhtar) Phone: Oral 2) Case is considered and grievance addressed within 1 week. Records are kept in the General Directorate. Complainants are contacted via phone, mail or official letter. 5 days

23 23 / 28 Level 2 Mr. Suleyman Lala (Department of Land Estate and Expropriation vicepresident) / Ms. Ilayda Yanarates (Legal Consultant) BOTAS General Directorate Phone: ugs@botas.gov.tr By phone, mail, and person 1) Immediate advisory and legal counseling. 2) If not resolved immediately, case is considered and grievance addressed within 1 week. Records are kept in the General Directorate. Complainants are contacted via phone, mail or official letter. 5 days In writing Level 3 Aksaray Asliye Hukuk Mahkemesi (Local Land Court) Procedures work according to applicable law, depending on the type of case. Duration dependent on case Table 6.2. Registered Complaint List Complaint Number Date Received Date Replied Complainant Subject Resolving Action An electricity pylon has been set up on his land but no information or compensation was provided. An electricity pylon has been set up on his land and damaged his farming activities. But no information or compensation was provided. An electricity pylon has been set up on his land and damaged his It was decided that the landowner has an easement right and the legal process have been initiated. The process has been finalized and the compensations have been fully paid. It was indicated that the contractor company has been informed about the complaint which occurred during the construction activities. The process has been finalized and the compensations have been fully paid.

24 24 / standing crops. But no compensation was provided before the set up activity. An electricity pylon has been set up on his land and damaged his farming activities. But no information or compensation was provided. An electricity pylon has been set up on his land and damaged his farming activities, and his trees had been cut by contractor company. But no compensation was provided. Complainant claimed that 32 animals from his herd perished after getting in contact with the wastes falling of the trucks during the shipments. Valuation process of his property has been completed and an invitation for compromise according to related provisions of Expropriation Law has been sent. The process has been finalized and the compensations have been fully paid. It was determined that the seasonal crop payment for his standing crops will be provided. Also, valuation of his property was completed and an invitation for compromise according to related provisions of Expropriation Law has been sent. The process has been finalized and the compensations have been fully paid. Judicial process is still proceeding. 2 2 He had been put into contact with the personnel of the contractor company (TCC). According to the report prepared by Council of Protection for Agricultural Properties, the number of dead animals is not 32 but 22. Furthermore the venue of incident is within the borders of expropriation site of Botaş Sultanhanı UGS Project and Ahmet Özuslu had been warned before about his trespasser status. The wastes in question are nonhazardous wastes within the class of second grade stockpiling according to the report of Segal Environmental Analysis and Evaluation Lab with the date of It was stated that those wastes will be transferred to an appropriate place out of site in accordance with the regulations. An autopsy of animals has been performed and the judicial process is still proceeding.

25 25 / 28 In addition; a survey was carried out with the landowners in which they were asked if they know whom to contact when they have questions or grievances and whether they can easily access these persons. All respondents stated that they are informed of whom to contact and can access them easily by phone, in person or online. 7. ADDITIONAL SOCIAL SUPPORTS Some additional supports have also been provided to local communities in order to enhance the positive impacts of the Project. Prior to and during construction BOTAS and its subcontractors have provided employment opportunities to neighbouring Project affected settlements as much as possible. Where appropriate, local companies and suppliers were contracted, additionally local people as well as local employees were provided with skills training on operation of heavy machinery. Small contributions have also been made for the maintenance of roads and utility services. During the construction activities 482 local people in total have been employed by the contractor and subcontractor companies (see Table 7.1). Local employees received some skills training such as social inductions, safety trainings, certificated hygiene trainings for employees in food sector, certificated first-aid trainings and instruction trainings for construction workers. Additionally, local suppliers have been used by the Project for security, catering and cleaning services (see Table 7.2). The Project has added value and contributed to the regional economy by procuring goods and services from the local artisans and local industry. Number of employees until now Current number of employees Table 7.1. Number of Local Employment SCC Emin İnşaat SSCC SBDC SERHAT TCC Table 7.2. Local Subcontractors SCC* Yücel Vinç Ulubaş Construction TCC** Ataroğlu (Cleaning and catering services) EMTA (Electricity works)

26 26 / 28 Solunay Construction HSK Engineering *Sixth Construction Company **China Tianchen Engineering Corporation AKG (Security) In addition to the above, upon the demand of local people, some recycling material support (wood, etc.) and levelling activities on the lands via Project equipment have been provided to villages.

27 27 / CONCLUSION As an overall assessment of land acquisition process, it is observed that BOTAS has carried out the process successfully considering the activities implemented both before and after the land acquisition activities. Consultation meetings have been held and PAPs have been informed about the process and the communication channels in case of any concerns or inquiries. Considering the sizes of lands that are acquired for the project components, most of the project-affected lands are subject to temporary acquisition. Hence, PAPs were able to reuse their lands after the completion of construction activities. The restrictions for recultivation practices on such lands include planting trees with deep and strong root, building structures and drilling. In the lands acquired, no cases exist for these restrictions because all farming activities are dry agriculture. Land owners are mainly planting wheat, barley and corn etc. Therefore, there is no implementation of planting trees with deep and strong root and no cases where the easement restrictions are observed to interfere with the preferred land use. After the reinstatement land owners and renters continue agricultural activities on their lands. On the other hand, permanent land acquisition was limited to surface facilities and UGS sites which had affected 64 landowners only. All landowners have received their compensations fully through bank transactions. Considering that there are plenty of unused lands as reported by one third of surveyed landowners and that the surveyed current users already have other lands elsewhere, no significant impacts have been upon the socio-economic well-being of PAPs. Moreover it was learned in consultation meetings that some of affected landowners have found other alternative lands around the region to continue farming. The execution of Tuz Gölü Storage Project has acquired large pieces of land along the lines and surface facilities and inevitable effects on local communities. All land acquisition and installation works have been undertaken in a manner that minimizes adverse impacts to the local communities and close coordination was facilitated between BOTAŞ and affected landowners and interested parties. The Project, having provided employment opportunities, skills training for locals and utilized local suppliers, has positively influenced the perception of local community members towards the Project. The positive impacts of the Project and support from the PAPs were observed by the monitoring team through the meetings with PAPs and surveys conducted.

28 28 / APPENDIX Additional survey sheets (8 pages)

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