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Lessons of Experience | September 2006 | Number 2

The Baku-Tbilisi-Ceyhan (BTC)


Pipeline Project

T he planning, design and


construction of the Baku-Tbilisi-
Ceyhan (BTC) pipeline provides a
and, community investment. The project
also yielded many valuable “process”
lessons that may be useful to IFC staff and
Lessons of Experience

good example of an IFC-financed project clients working on future projects.


that faced a wide variety of complex and
often difficult social and environmental The BTC pipeline was developed by a
challenges. From the outset, both the company (BTC Co.) formed by the
sponsor and the lenders were committed affiliates of eleven national and
to achieving sustainable outcomes and international oil companies with BP as the
striving to ensure that the project was majority shareholder and operator of the
constructed and operated to international company. Construction began in spring
best practice environmental and social 2003 and export from the new terminal at
standards. At the time of its Ceyhan commenced in June 2006.
commencement, BTC was the largest Approximately 70% of the project costs
cross-border infrastructure construction were funded by a group of lenders
project in the world. The scale and including IFC, the European Bank for
multitude of environmental and social Reconstruction and Development (EBRD),
aspects on such a mega-project should the export credit agencies of seven
not be underestimated nor should the countries, and a syndicate of fifteen
amount of resources and level of effort commercial banks. Financing was agreed
expended by BTC staff during the in February 2004 after over two years of
planning and construction phases, or IFC appraisal of the potential environmental
staff during project appraisal and and social impacts relating to the project.
supervision.
The pipeline is over 1,760 km long and is of
This Lessons of Experience has been regional significance as it provides the first
prepared by staff of the Environmental direct transport link for exporting crude oil
and Social Development Department of between the land-locked but hydrocarbon
the IFC for the purposes of internal
learning throughout the institution. While
it is impossible to capture all the CONTENTS
complexities and challenges encountered
during the design and construction phase
3 Environmental and Social Impact
of the BTC project, this paper focuses on Assessment and Management
six key areas where lessons learned were
11 Regional Review
thought to be most valuable and
applicable to other IFC-financed projects. 14 Stakeholder Engagement and Disclosure
These are: environmental and social
19 Land Acquisition and Compensation
assessment and management (including
contractor management); the regional 22 Monitoring and Reporting
review; stakeholder engagement and
27 Social License to Operate
disclosure; land acquisition and
compensation; monitoring and reporting; 32 Acknowledgements
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

Source: BTC Co.


rich Caspian Sea and the Mediterranean. small and medium sized enterprises, have the
Running through Azerbaijan and Georgia to potential to contribute to economic stability
a terminal facility at Ceyhan on the Turkish and sustainable development within each
Mediterranean coast, the pipeline has the country, as well as promote regional
1
capacity to transport one million barrels of integration and interdependence.
crude oil every day. The pipeline is buried
along its entire length, however, the pipeline The pipeline route passes through a wide
system requires more than a hundred above range of land-use types impacting over
ground installations of varying types. 17,700 parcels of land utilized by local
households in 515 villages. Social and
Until now, countries in the region such as environmental issues encountered included:
Azerbaijan, which have oil reserves far severely limited regional routing options due
exceeding their domestic requirements, to complex environmental, social, geo-
have had to rely on a combination of hazard and geo-political constraints;
pipelines, rail and shipping potential impacts on sensitive flora and fauna
to export oil to world markets. A large habitats as well as on groundwater resources;
percentage of these exports passes through temporary land acquisition under complex
the narrow and congested Turkish Straits, land tenure systems; disturbance to local
posing an increasing environmental and livelihoods and activities affecting large
public safety risk to the city of Istanbul and numbers of people; community safety; local
surrounding areas. The BTC pipeline offers an employment; potential impacts to
inherently safer means of transporting oil marginalized and vulnerable groups
over long distances and relieves further (including ethnic minorities, women and the
congestion through the Turkish straits. elderly); and, the implementation of a major
Azerbaijan will derive substantial economic public consultation and disclosure program.
benefits through the generation of royalty The project also attracted intense scrutiny by
and tax revenues, while Georgia and Turkey stakeholders, press, and civil society,
will gain financial benefits through transit including international NGOs.
fees. These revenues, combined with the
indirect benefits associated with the IFC and the wider lender group worked
purchase of local goods and services, closely with the sponsor in designing an
employment, and specific programs
designed to encourage the development of
1
Source: Environmental and Social Overview, BTC, September 2002.
Page Two
Lessons of Experience | September 2006 | Number 2

oversight mechanism to address the


potential environmental and social impacts
of the project and to monitor performance.
This included the development of a
comprehensive environmental and social
action plan, the design and implementation
of a transparent land acquisition and
compensation program, local employment The end result of
and training, community investment
the ESIA was
programs, and NGO capacity building. In

R. Wyness
many areas, the BTC construction program thirty-eight
exceeded expectations in terms of volumes of
environmental and social management, Pipeline construction passes near a hillside community in Turkey. publicly disclosed
setting new benchmarks in transparency and
environmental and social standards for documentation
construction programs, and developing covering 1,760 km
innovative practices along the way. Among wider institution. Although the project
of pipeline and
the highlights of the BTC project was a sponsor has been consulted and BTC
ground breaking Regional Review which environmental and social staff have 515 villages
addressed macro-issues of concern such as contributed their perspective to the issues stretched over
human rights, revenue management, and raised, the content of this paper reflects the
three culturally
security; an extensive public consultation opinions of its authors.
and disclosure program; a 25 million dollar diverse countries.
Community Investment Program undertaken
on a scale unprecedented in BP's history; a Environmental and Social
program of NGO capacity building; an 8.8
million dollar Environmental Investment
Impact Assessment and
Program, and the enhancement of Management
development impacts through linkages with
small and medium enterprises (SMEs). Both the Environmental and Social Impact
Assessment (ESIA) and the Environmental
For IFC as a lender, the process of capturing and Social Action Plan (ESAP) were
lessons of experience from projects is an considerable undertakings for the BTC
important one in which the objective is not project and a number of lessons were
to criticize or dwell on shortcomings but to learned along the way and in looking back.
learn. Analyzing events in retrospect and This section focuses on six key areas of
with hindsight is, of course, always easier than assessment and management where
taking action and making difficult choices in process lessons and good practice were
real time. The sponsor deserves significant thought to be most relevant and applicable
credit for its management of the to future projects. These include: (i) ESIA
environmental and social aspects of the scoping; (ii) Commitments Register; (iii)
project and our attempt to distill lessons from Environmental and Social Action Plan; (iv)
BTC for future projects should not in any way Management of Change; (v) Contractor
detract from this fact. In the pages that Management; and, (vi) Contracting
follow, IFC environmental and social staff Strategy.
look back on an extremely challenging
process and endeavor to extract some of the The ESIA program carried out for the BTC
key operational lessons and good practices pipeline project was an enormous task and
for the benefit of colleagues, clients and the in many ways a remarkable achievement in

Page Three
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

its scope and comprehensiveness. The This poses a risk because, in scoping, one is
process was unique in that there were three designing a data gathering process that will
separate ESIAs, one for each country, done extend far beyond the ESIA through to
by different consultants—a fact that led to implementation and monitoring. As such,
variations in quality and contributed to the having a credible baseline against which to
complexity of the process. The end result was monitor future impacts is vital. For these
thirty-eight volumes of publicly disclosed reasons it is critical that the most experienced
documentation covering 1,760 kilometers of specialists familiar with the project area be
pipeline and 515 villages stretched over sought to provide input to the scoping
three culturally diverse countries. The Turkey process.
ESIA, in particular, is considered by IFC
technical staff to be “best in class.” One example from the BTC project relates to
However, all involved agree that in hindsight the collection of social baseline data
there were aspects of the process that could appropriate to the project. The sponsor
be addressed differently in future projects. invested substantial resources in collecting
social baseline data. However, there was a
sense at the end of the ESIA process that
ESIA Scoping while this exercise yielded good basic
information on affected villages, too much
unnecessary social data might have been
A valuable lesson learned was that effective collected in some areas while not enough in
“scoping” of an ESIA program for a complex others. This highlighted the importance of a
project such as BTC is critically important. good scoping process at the beginning to
The objective of scoping is to set the terms of help focus the data collection. Prioritizing the
reference for subsequent ESIA studies. It key social issues for investigation at the study
involves four main elements: characterization design stage, and clearly defining what the
of the project and the region; an initial information collected will be used for during
screening and prioritizing of issues; the implementation, will narrow the focus and
defining of project boundaries; and, the help clients save on both time and money.
design of any studies required for the analysis While it is unlikely that every impact and issue
of potential impacts and opportunities can be accurately predicted ahead of time,
associated with the project. How scoping is targeting social data collection as much as
done in the beginning largely determines the possible is particularly important for a large
focus, quality and utility of the future ESIA. project like BTC with over 515 villages
(comprising nearly one million people) in the
Despite the importance of scoping in the project affected area. For example, the BTC
ESIA process, IFC experience has shown that ESIA program could have benefited from a
on many projects the scoping stage is not clearer identification at the scoping stage of
allocated the sufficient time, budget or the complexity of the land use and land rights
expertise required to get it right. In some issues that would be encountered during the
cases this may be due to the uncertainty of subsequent land acquisition and construction
whether the project will actually go forward, phases of the project. (Discussed further on
or the importance of scoping may be page 19.)
underestimated resulting in insufficient
resources being committed. In other cases, While more effective scoping may have
the time allocated for the scoping phase helped focus the social baseline data
may get squeezed within the overall gathering requirements, it is also true that at
timetable of the project. the time of the BTC project there was a
growth in interest (by NGOs and other parties)

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Lessons of Experience | September 2006 | Number 2

in certain types of social issues that had not mitigation measures that the sponsor had
traditionally been included in past impact committed to implement. These
assessments. Given the complex and often commitments were scattered across various
sensitive cultural, social and political issues sections of the documentation and, initially,
surrounding the BTC project, new and the sponsor experienced difficulty organizing
emerging issues arose such as worker welfare, these commitments into actions, so that the
human rights, and security which neither the environmental and social management
sponsor nor the lenders had foreseen at the program for the project could be developed. Effective “scoping”
time of the ESIA as requiring significant To overcome this, a comprehensive list of all
of an ESIA program
additional attention. This demonstrates that of the commitments was developed in a
for both sponsors and lenders alike, keeping “Commitments Register”. The register clearly for a complex
up with an ever evolving range of social issues laid out each commitment, its original source, project such as BTC
that may need to be covered as part of the and where in the management program the
is critically
scoping and assessment process can be a commitment would be covered.
challenge. Indeed since the time of the BTC important.
project appraisal, IFC's own Performance Once established, the commitments register
Standards have been expanded to include was a valuable tool in the development of
issues such as labor, community health and the environmental and social management
safety, and security based on the structure and arrangements necessary for the
corporation's experience of many recent project. It served as a link between the ESIA
projects including BTC. IFC has also documentation and management system
developed good practice guidance for its and provided a mechanism whereby
clients on undertaking social impact commitments made could be followed
assessment entitled, “Addressing the Social through to actions on the ground.
Dimensions of Private Sector Development.”
However, extracting the commitments into a
This is not to say, however, that all of the issues register for the BTC project after the fact was
identified during scoping must be covered in a time-consuming process. It was also found
the subsequent ESIA. Rather, early that once extracted from the original
identification of potential issues through a documentation the commitments were often
robust scoping process will allow an early vague or poorly phrased, responsibility for
judgment on the approach required. It will implementation of the commitment was not
help determine whether additional studies always clear, and there was significant
might be necessary and if so, what form they duplication of the same commitment
might take. For example, because the BTC throughout the ESIA documentation.
project involved three countries and
numerous cross-border issues, the company In future, commitments being developed as
chose to address the analysis of macro-level part of the ESIA should be carefully reviewed
regional and strategic topics in a separate as they are included in the project
“Regional Review” document. (Discussed documentation. Clear and concise
further on page 11.) language should be used and a register of
commitments is recommended as part of the
ESIA documentation deliverable. Ideally,
Commitments Register commitments registers could then be
organized into a structure that is in line with
the project phases (e.g. construction or
The BTC ESIA documents provided a wealth of operations) and sorted by issue (e.g. waste
baseline information and impact analysis management) to provide greater clarity for
along with numerous management and both the sponsor and the contractor as to
responsibilities for implementation.
Page Five
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

The Environmental and Social Action From IFC's perspective, an ESAP needs to
Plan (ESAP) have legal teeth when things go wrong but
sufficient flexibility to anticipate issues that
were missed or come up later during
An essential component of an ESIA is the implementation. Change is inevitable
specific measures and actions developed to particularly in large construction projects such
mitigate and manage the environmental as BTC. At certain milestones in a project of
and social impacts identified in the this scale there should be a means to review
assessment and committed to by the the management arrangements in an ESAP
sponsor. These measures are typically and make changes if necessary. Unfortunately
organized into a management plan for in the case of BTC, the ESAP became a legally
implementation. IFC and the other lenders binding document and the difficulties of the
required that BTC prepare an ESAP which negotiations during the ESAP development
comprised the environmental and social made both the sponsor and some of the
actions and mitigation measures to be taken lenders unwilling to reopen the agreement to
for the project before financial closure. potential renegotiation and changes in the
However, an ESAP was not included in the future. This made change difficult to
initial ESIA documents submitted by the implement which undermined the objective
sponsor. Final management arrangements of having a “dynamic” environmental and
were yet to be developed based on the social management mechanism within the
commitments included in the ESIA and ESAP that can change and respond to
other project documentation. developments on the ground as needed.

In the case of BTC, what would otherwise be Based on BTC and other experiences, IFC
a straightforward ESAP or management should exercise caution in future when
system evolving out of the ESIA, became agreeing the legal requirements of an ESAP.
complicated by a range of factors unique to Legal language should be separate from the
the project, including: timing issues, the large environmental and social management
volume of ESIA documentation and related system, plans, and policies. In future, clients
documents containing the management should be encouraged to limit the
commitments for all three countries, the involvement of their legal representatives in
multiplicity of lenders involved, and the drafting of environmental and social
management arrangements for the management system language and action
numerous contractors involved. As a result, it plans.
was initially difficult for all parties to
determine how to establish an appropriate
action plan. The ESAP content negotiation Management of Change
process between the project sponsor and
the lenders became protracted and overly
legalistic and the final ESAP, while containing While the above may suggest that changes to
a useful framework for an environmental and the environmental and social management
social management system, turned into a procedures were not made as circumstances
long, negotiated legal document whose changed on the ground, this in fact was not
provisions were in many ways quite rigid and the case. Change is inescapable and not
did not possess the flexibility needed to surprisingly the project had to make numerous
respond to the changing realities of the changes to its original planning during the
project on the ground. construction program using their
Management of Change (MoC) mechanism.

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Lessons of Experience | September 2006 | Number 2

MoC is essential, it ensures that significant


changes are managed and recorded and
that all project disciplines are consulted and
agree to the change. A single unified project
MoC is required which recognizes that
whatever the source of the change (e.g.
design, engineering, construction, health and
safety or environmental and social issues) the An ESAP needs to
implications of the change are assessed
have legal teeth
by all.

R. Wyness
when things go
IFC and the other lenders needed to be wrong but
notified of any material changes to project Pipeline construction operations.
sufficient flexibility
implementation that would result in
significant environmental or social impacts to anticipate
that might not have been sufficiently issues that come
covered in the ESIAs or catered for in the One of the reasons for disagreements among
up later during
ESAP. A specific MoC mechanism was the parties on this issue was that any change
therefore included in the ESAP and used to that triggered notification to the lenders implementation.
notify lenders. While the inclusion of an MoC required a review of MoC documentation by
process was necessary, the criteria the Independent Environmental Consultant
developed to determine when a “change (IEC) and confirmation by them to the wider
notification” to the lenders should be lender group that the changes were being
triggered did not work particularly well in accompanied with appropriate mitigation
practice. The criteria were somewhat measures. While a system of review was
ambiguous and, as such, open to necessary, the process specified in the ESAP
interpretation. They were also too narrowly was not entirely satisfactory. In particular, the
focused on pipeline route changes and not IEC found it difficult to be flexible when
other possible changes. The ambiguity led to responding to change since their principal
disagreements between BTC, the lenders requirement was to ensure compliance with
(including IFC) and the independent the ESAP. In some cases, however, flexibility
environmental consultant (commissioned to was necessary so that pragmatic solutions to
monitor compliance with the ESAP) as to ground conditions could be quickly agreed.
what constituted a “significant” change and
whether lender notification was warranted. In The MoC process on BTC was a clear
future, criteria need to be better defined to example of an aspect of the ESAP that was
differentiate between what is considered a not flexible enough to respond to the
minor change and what is significant across measures required by changes during project
all project related activities. From a lender's implementation and which led to an overly
perspective, the MoC mechanism should be cumbersome process for all parties. While
able to identify any changes in project MoC is an essential component of a
implementation that would require an company's environmental and social
amendment to the provisions of the original management program, the mechanism to
ESAP and allow for the adjustment of ESAP notify lenders of changes to the project
procedures to effectively deal with needs to be carefully considered. In
environmental and social impacts on the particular, criteria that trigger notification of
ground. change should be developed with
unambiguous language, and the “change

Page Page
SevenSeven
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

BTC Project Operator Responsibility

Environment & Social Commitments

Contractor Control Plans (CCP) BTC Management Plans

Contractor Responsibility

Contractor Implementation Plans


and Procedures (CIPP)

review procedure” should be sufficiently environmental and social staff on the ground
flexible to enable a discussion of the issues in all three countries. BTC had initially
and timely agreement on the best way presumed that the environmental and
forward. social management requirements to be
implemented during construction were the
responsibility of the contractors since these
Contractor Management contractors had signed up to the project's
environmental and social commitments
included in their contracts. Once the
In pipeline projects such as BTC, the contracts were awarded however, it quickly
construction phase usually carries the highest became apparent that many of the
risk of potential environmental and social contractors did not in fact have a full
impacts and unforeseen events. As such, understanding of all of their commitments
substandard performance by the with respect to environmental and social
construction contractors involved in a management (which, for BTC, were set at a
project can lead to adverse impacts and very high standard) and they did not
the exposure of both the project sponsor necessarily appreciate what the requirements
and project lenders to financial and entailed in terms of implementation. For
reputational risks. Active management by example, as is typically the case, the
the project sponsor of contractor contracts included a requirement for the
performance on environmental and social contractor to develop measures to meet their
issues is therefore critically important to environmental and social commitments and
ensure successful outcomes, and to prevent document these in management plans
subsequent time consuming and expensive before they started construction. But the
corrective action. contractors, in reality, lacked the capacity to
develop and implement the type of
There were numerous contractors involved management plans BTC required. At the
in the BTC construction program. The same time, the lenders required that the
amount of time and level of effort required contractor's management plans be ready for
by the sponsor for effective contractor inclusion in the ESAP before financial closure.
management was underestimated at the
outset of the project. As a result, BTC had In order to ensure contractor compliance
to significantly increase its number of with their environmental and social

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Six
Lessons of Experience | September 2006 | Number 2

commitments, and at the same time For future projects where there is significant
demonstrate to the lenders how they contractor involvement, a similar control
intended to manage their contractors, BTC mechanism is recommended as good
had to find a simpler way of communicating practice. However, the CCPs would be of
to the contractors what their obligations greatest benefit if they were included from
were. A mechanism was developed the beginning as part of the initial contracts.
whereby a series of “Contractor Control
Plans” (CCPs) were prepared by BTC that A more general lesson for both IFC and their Passing all the
contained detailed and specific control and clients is that passing all the environmental
environmental
mitigation measures that each contractor and social requirements to the contractor
must implement in order to meet their and making it their responsibility, involves risk. and social
contractual obligations. These specific Sponsors need to be sure of the contractor's requirements to
measures then allowed the contractor to in capacity in this area and understand that in
the contractor
turn develop “Contractor Implementation the lenders' eyes it is they, and not the
Plans and Procedures” (CIPP) that contained contractor, who will ultimately be held involves risk.
procedures and method statements responsible for meeting lender commitments
specifying how the contractor would and ensuring positive outcomes. In order to
implement the measures included in the effectively manage this risk, the sponsor
CCPs. needs to actively monitor contractor
implementation on the ground by having a
Individual CCPs were developed based on “contractor control system” in place, and if
specific environmental and social areas that necessary, as was the case for BTC, be
needed to be managed (e.g. waste prepared to step in with training and
management). The main benefit of the CCPs technical assistance as required.
was that they clearly translated the many
commitments made in the ESIA
documentation into specific actions; Contracting Strategy
assigned responsibilities between the
contractor and the sponsor; and, provided a
means to monitor contractor performance For all projects, getting the right contractors
while at the same time providing assurance on board and avoiding problems down the
to the lenders that the environmental and line requires that environmental and social
social commitments made by the sponsor considerations fit within a company's overall
were being implemented by the contractor. contracting strategy. The Invitation to Tender
The CCPs followed a “performance based (ITT) documentation for BTC consisted of a
approach” so that contractor compliance series of documents describing the
and performance could be monitored and environmental and social management
measured using key performance indicators, requirements to be met by each contractor
inspections and audits. throughout the contract term which the
contractors agreed to implement. However,
Although the CCP mechanism of contractor as outlined above, many of the contractors
control was considered a very useful tool for initially did not have the capacity or
the BTC project construction program in understanding to meet these obligations.
working with the contractors on The costs of not spending sufficient time and
implementation requirements, the plans were focus on contractor environmental and
developed and issued retroactively, after the social management and capacity issues
main construction contracts had been upfront proved substantial to all parties
awarded and as a response to contractor involved. Both BTC and its lenders were
management difficulties and capacity issues. exposed to non-compliance risks, while the

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SevenNine
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

financial consequences of retrofitting, cost


» To assess whether adequate funds have
overruns, and delays were borne by BTC and
been allocated for environmental and
its contractors.
social management in a tender submission,
the sponsor should consider requesting an
It is not the role of IFC to dictate a sponsor's
itemized budget for environmental and
contracting strategy, however, certain
social expenditures given as line items as
lessons from the BTC project have led to a
part of the “lump sum” contract, or
number of very useful contracting strategy
consider a provision for environmental and
suggestions by the sponsor which may be
social management separate from the
appropriate for future projects. For example:
“lump sum” contract.

» The sponsor should ensure that specific, » Sponsors should consider involving their
clear and consistent information is
environmental and social staff in drafting
included in the ITT in relation to
the environmental and social portions of
environmental and social requirements so
the ITT and in reviewing tenders submitted
that contractors know what their
by contractors.
obligations are upfront. (Contractor
Control Plans provide a good mechanism
» Depending on the extent of environmental
for this.)
and social obligations involved in the
contract, the sponsor should consider
» The sponsor should, where possible,
requiring the contractor to have a qualified
schedule the ESIA program so that it has
Environmental and Social Manager.
been completed and the environmental
and social commitments identified before
» The sponsor should consider sub-
the ITT is released so that all contractor
contracting specialist companies for some
environmental and social obligations can
of the more specialized aspects of
be included in the ITT documentation.
environmental and social management
such as waste water treatment or waste
» In the absence of a completed ESIA, the
management and disposal.
sponsor should include as many standard
environmental and social measures in the
ITT as possible based on previous projects Summary of Key Lessons
or past experience, but should keep close and Future Recommendations
track of any commitments arising from the
final ESIA which were not included in the » Scoping is a strategically important component
ITT or contractor's tender. In this case, the of the ESIA program, it should be considered an
sponsor should make sure these important milestone in the program and
outstanding obligations are managed, sufficient time and expertise (including input
either by themselves or by specific from experienced specialists familiar with the
agreement with the contractor. project area) should be allocated to get it right.

» The BTC project demonstrated that the social


» The sponsor should make best efforts to
aspects of a project can cover many issues that
ensure that the contractors have a clear
have not traditionally been covered in impact
understanding of what is expected of assessments. Future scoping exercises should be
them from a technical, resource broadened to identify all potential social issues
allocation, time input, and cost that might be important to the project including
perspective, as well as the capacity to new and emerging issues such as worker
deliver. welfare, human rights and security.

Page Ten
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Lessons of Experience | September 2006 | Number 2

» All the issues identified during scoping do not » A “contractor control” mechanism should be in
necessarily need to be covered in the ESIA place as part of the management
program but the results of the scoping exercise arrangements and sponsors must be prepared
should include an early judgment on the most to step in with training and technical assistance
appropriate approach for each issue and as required.
should establish any studies in addition to the
ESIA that will be required for the project. » The contractor control mechanism developed
by BTC is considered good practice. It
Macro-level
» The ESIA documentation should contain a translated the commitments made in the ESIA
“register” of environmental and social documentation into actions to be assessment is
commitments made by the sponsor. Clear and implemented on the ground. The mechanism
particularly
concise language should be used for the consisted of a series of Contractor Control Plans
project commitments with a clear indication of containing the mitigation measures that the relevant in
responsibility for implementation. contractor must implement. The contractor
emerging markets
then developed Contractor Implementation
» The legal language in a project ESAP should be Plans and Procedures (CIPPs) that specified where complex
kept separate from the environmental and how the contractor would implement the
cross-border
social management program in order to allow measures laid out in the CCPs.
for sufficient flexibility in the management projects raise
procedures to respond to the changing realities
sensitive issues that
of the project on the ground. IFC should
exercise caution when agreeing the legal have implications
requirements within an ESAP. Flexibility is Regional Review beyond the
particularly important in a large scale project
such as BTC where change is inevitable. usual project
One of the clear good practices to emerge
from the BTC project was the preparation of boundaries.
» A Management of Change (MoC) mechanism
is an essential component of a project a Regional Review. The sponsor assembled a
management system (and ESAP). The criteria well-qualified team and devoted
that signal a change (and the trigger for the considerable time and resources to
notification of a change) should be carefully undertake what has proven to be a ground
considered and the criteria should contain breaking approach. Originally suggested by
unambiguous language.
IFC, the Regional Review provided a much
needed contextualization of the project
» The arrangements for an MoC document review
procedure in the ESAP should be carefully
within the larger geopolitical setting of
considered and, if possible, should not be Azerbaijan, Georgia and Turkey. While
entirely based on compliance. The procedure perhaps not needed for all projects, this
should be sufficiently flexible to enable macro- level assessment is particularly
discussion of the issues and timely agreement relevant in emerging markets where
between all parties involved on the best way complex cross-border projects raise sensitive
forward.
issues that have implications beyond the
usual project boundaries. On BTC, the
» Sufficient time and focus on contractor
environmental and social management and
Review undertook a higher level analysis of
capacity issues upfront (and prior to contract regional issues, documenting considerations
award) is critical. The sponsor should be sure of and actions taken with respect to macro
the contractor's capacity in this area and that concerns such as: regional export options
the contractor fully understands what is examined in pipeline route selection;
expected of them. revenue management; local employment
and supply chain management; the non-oil
» Active management and monitoring of
economy; poverty and inequality; access to
contractor performance on environmental and
social issues is vital and sufficient resources
energy; climate change; governance and
should be allocated to this activity. corruption; and human rights, among other

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The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

issues. As such it addressed issues not Review was a less important document than
covered in the project-specific ESIAs the ESIA. However other staff reflect that, in
undertaken for each of the three countries, retrospect, doing a Regional Review made
but nevertheless important enough to the company focus on difficult issues that
warrant a separate study. were not necessarily covered in the ESIAs
(e.g. governance, human rights, the oil fund,
Given the numerous geo-political concerns security, private sector vs. government
and constraints in the region related to responsibility) and that they benefited from
exporting oil from the landlocked Caspian the process of having to think through these
Sea, as well as the sensitivities involved in questions in depth. In addition, BP, as the
publicly disclosing them, there had not been project operator, garnered significant praise
sufficient public discussion about pipeline in terms of external reputation for undertaking
route selection or the alternatives the review. Carrying out the process on a
considered. This sparked criticism of the voluntary basis demonstrated leadership by
project from the international media and the company and a willingness to be
NGO community, along with concerns about progressive, open, and forward-looking in
the lack of discussion of cumulative impacts. their approach. If done at the earliest stages,
In this respect a Regional Review can be an this type of advance preparation can also
important discussion tool for the sponsor and help to pre-empt and allay many of the
the project by: (i) providing a coherent concerns expressed by the shareholders of
explanation of the impact of oil the lending institutions, civil society, and
development on the region and the NGOs. Although some BTC staff felt that no
alternatives considered; (ii) serving as a amount of effort to provide information
baseline of sorts for assessing the cumulative concerning the regional context of the
effects of other pipeline projects in the project would alter the views of certain NGOs
region; (iii) proactively demonstrating that fundamentally opposed to the project, IFC
the sponsor is aware of and committed to staff believe that the value of the Regional
addressing some of the broader Review process lies in laying the groundwork
environmental, socioeconomic, and to interact with those stakeholders and
development issues; and, (iv) contributing to interested parties who do want to engage
the project's desire to be transparent. constructively to find solutions.

Another lesson learned by the sponsor had to


The Benefits do with balancing the demands of NGOs with
positions outside the mainstream who wanted
BTC to assume responsibilities far beyond
In the case of BTC, the Regional Review those of a private sector company. By
proved particularly important given the lack consulting and soliciting views of a wide array
of formal Strategic Environmental Assessment of stakeholders (more than 100 organizations
(SEA) studies by the relevant governments were interviewed as part of the Regional
available for any of the three host countries. Review process) the company gained a
From IFC's perspective, the Review filled a more moderate and pragmatic set of
critical information gap and bolstered the recommendations from the majority of
development justifications for project stakeholders as to what they thought BP's role
financing which was extremely important to should be with respect to issues such as
its Board of Directors. For some BTC staff who human rights and corruption. This helped to
were focused on day-to-day issues at the demonstrate that the views of some of the
project level rather than the larger strategic more extreme critics were not representative
questions faced by the project, the Regional of the larger majority.

Page Twelve
Six
Lessons of Experience | September 2006 | Number 2

Timing those with sensitive issues and that generate


significant revenues and/or involve more than
one country. The practice is already being
While BTC assembled a multi-disciplinary team replicated in other private sector projects not
of experts and devoted considerable time being financed by the IFC. Another
and resources to producing this important approach, building on the BTC experience,
document, both the sponsor and IFC agree has been to bring the big picture issues such
that the Regional Review came too late in the as revenue management, security, and The Regional
process. The exercise did not begin until much human rights into the ESIA rather than
Review filled
of the ESIA work was well underway and the undertake a separate regional review
Review itself was not released until much later. exercise. Either way, such practices a critical
Part of this had to do with the fact that this demonstrate an increasing recognition of the information
was a new approach without examples for need to broaden the scope of issues to be
gap and bolstered
BTC to draw upon. Many of the issues assessed on projects of this nature beyond
addressed in the Regional Review (especially the set of typical environmental and social the development
on the social side) were new, sensitive, and issues covered in an ESIA. justifications
outside the scope of traditional ESIAs, and for project
therefore required careful consideration prior
to publication. In hindsight, the delayed Summary of Key Lessons financing.
timing reduced the overall effectiveness of and Future Recommendations
the document as an informational tool and
ideally would have commenced prior to, or in
parallel with, the early scoping and pre- » From IFC's perspective, the BTC Regional Review
feasibility studies for the project. provided an important analysis of macro
regional issues relevant to the project. The
document complemented the ESIAs, filled
It is likely that having BTC publicly state its
information gaps, increased transparency, and
position on a number of these issues early on
publicized some of the important issues with
would have saved much time and effort on
respect to crude oil export options in the region
the part of both the sponsor and lenders in and pipeline route alternatives.
providing responses to NGO concerns since
certain potentially controversial topics would » The BTC sponsor benefited from discussions with
have already been addressed publicly. a wide array of stakeholders in the preparation
Timing issues aside, the Regional Review of the Regional Review as well as from having to
think through a number of difficult and sensitive
was nevertheless successful in complementing
issues not traditionally considered as part of a
the work done through the ESIA process and
project impact assessment such as revenue
in providing insights into key risks and
management, governance, human rights and
opportunities at the national and regional security among others. This provided a better
levels. From the lenders' perspective it had understanding of the key risks and opportunities
great value in providing further comfort that presented by the project.
these larger issues were being considered
seriously. » A Regional Review should be considered for
complex projects in emerging markets. For
maximum effect, the timing of the review is
important. Early preparation of a review that
Replicability considers sensitive and difficult issues in the
region can help pre-empt and allay many of
the concerns expressed by the shareholders
In terms of replicability of this good practice, of lending institutions, civil society and the
the IFC would recommend that such a review international NGO community. Ideally the
Regional Review would be most effective if
be considered for large scale complex
commenced in parallel with the earliest scoping
projects in emerging markets, particularly
and feasibility studies for the project. Page Page
SevenThirteen
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

data collection phase of the ESIA. IFC's


Stakeholder Engagement perspective on this early consultation was that
and Disclosure the scope was very impressive. Every affected
community within 2 km either side of the
International standards for public pipeline right-of-way and within 5 km of
consultation and disclosure for private sector permanent facilities was contacted via initial
projects in emerging markets are meetings and then a second time once the
continuously evolving. In this respect, BTC draft ESIA was produced. To achieve this, BTC
was perhaps precedent-setting among brought in local academics to provide
projects of this type and size in terms of the knowledge of the area and socio-cultural
extent of local consultation carried out and issues as well as a social research company,
the amount of information disclosed as part and undertook training of these teams.
of the ESIA process. IFC staff (and in However, due to the logistics and personnel
particular social development and demands of consulting along 1,760 kilometers,
environmental specialists) spent a BTC had to subcontract and, as a result, the
considerable amount of time meeting with quality of consultation in some locations may
BTC and their specialists, affected have been inconsistent. In addition, given the
communities, and other interested parties amount of information that had to be
along the pipeline route over a period of provided in a short time, there were inevitably
eighteen months before presenting the significant information gaps. From IFC's
project to IFC's Board. IFC and EBRD set a perspective, the amount of time and
precedent as well through the Multi- resources put into the consultation process by
Stakeholder Forum in which a series of BTC was commendable. However, one
meetings were held in all three countries to recommendation for future projects would be
enable the lenders to hear feedback directly to incorporate more participatory techniques
from members of affected communities, civil and methodologies into the consultation
society, local authorities and other process in order to create more opportunities
stakeholders. From both the client and IFC for meaningful interaction and two way-
perspective, the comprehensive stakeholder dialogue between the project and affected
engagement process yielded a number of stakeholders.
valuable lessons including good practices in
some areas and ways to improve in others. One aspect that was not fully addressed in
Overall, the considerable amount of IFC staff these early consultations was the complex set
engagement with the sponsor, affected of issues around impacts to land use and land
communities, and interested parties in- acquisition which was a primary concern of all
country helped IFC achieve an in-depth affected communities. This was due in part to
understanding of the key issues and BTC concerns about managing expectations
concerns relating to the project. This when there was still uncertainty about the final
enabled IFC staff to respond effectively to routing of the pipeline. The consultation
intense scrutiny and questioning by the exercise was undertaken based on a 500
World Bank Group's Executive Directors and meter corridor, so the company was unable to
international NGOs during the disclosure tell the communities at that time exactly
period, which ultimately facilitated support where the pipeline and permanent facilities
for the project by allaying the concerns of would be within this corridor. However, once
IFC's Board. the details and complexities of the land
acquisition and pipeline right-of-way issues
Because IFC involvement came later in the were more clearly understood by both the
process, BTC had already commenced an sponsor and their consultants, a separate and
initial program of consultation as part of the very comprehensive process of consultation

Page Fourteen
Six
Lessons of Experience | September 2006 | Number 2

Learning from Criticism

In addition to consultations with locally


affected communities, BTC consulted
extensively through workshops and face to
face meetings with local, regional and
BTC was
national government authorities; national,
regional, and international NGOs; academic precedent-setting
T. Pollett institutions and other interested parties. in terms of the
However, despite the extensive consultation
extent of local
carried out and the considerable effort by
Consultation meeting with villagers in Turkey. consultation
BTC, much criticism of the local consultation
process was received from international carried out and
NGOs. In hindsight, perhaps more should
the amount of
have been done to publicize the local
on compensation and land acquisition
public consultation process on a national information
commenced. BTC carried out its
and international scale, and to engage disclosed.
commitment that every individual whose
directly with those international NGOs willing
land was affected by the project would be
to discuss the issue constructively. This is an
contacted and consulted—no small feat for
area where the client expressed the
over 100,000 people with claims to land.
frustration that, with certain organizations
fundamentally opposed to the project, no
IFC social development and environmental
amount of time and effort devoted to
specialists visited a large sample of villages
dialogue would change their position or
along the pipeline route and were able to
understanding of the project, or result in a
observe many of the ESIA consultations,
constructive dialogue. While such frustrations
particularly around the time of disclosure of
are understandable, IFC continues to hold
the draft ESIA. They also observed on several
the view that the process of engaging all the
occasions the interaction between the
project's critics is an important one and
sponsor’s land acquisition and compensation
ultimately valuable to the client because it
program teams, and affected households.
demonstrates a willingness to listen, learn,
The lesson here is that a thorough process of
and discuss possible solutions.
consultation benefited the project by
providing valuable information that informed
the project planning process and helped to
improve outcomes, for example: in helping The Multi-Stakeholder Forum
to identify re-routes for the pipeline to avoid
sensitive cultural and archaeological sites,
and contributing to the formulation of There were a number of factors that led to
employment, community relations, and IFC and EBRD jointly carrying out a Multi-
community investment initiatives. Stakeholder Forum (MSF) consisting of
meetings with local stakeholders in
Azerbaijan, Georgia, and Turkey, which cost
a significant amount in terms of resources
and staff time. During lender appraisal of
the project, concerns and criticisms by
international NGOs were escalating in
anticipation of the date for loan approval

Page Page
SevenFifteen
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

by IFC's board. Ultimately, the MSF resulted vocal international NGOs. The lesson learned
from pressure from IFC's Senior Management by IFC in this case is that while international
to have an “independent process” to assess NGOs can often help in giving voice to the
local community support for the project concerns of the local population, this is not
along the BTC pipeline by creating a direct always the case when agendas and interests
platform for discussion. differ. Moreover, in certain situations, local
public opinion in support of the project does
The purpose of the meetings was to allow IFC not receive attention at the international level
and EBRD staff to hear directly from local and the voices of local communities go
stakeholders about issues related to their unheard in the international media.
potential financing, and present their
respective Boards with firsthand information On the downside of the process, the MSF
before making final lending decisions. The caused tension between IFC/EBRD and the
exercise was not meant in any way to sponsor for a number of reasons. BTC rightly
supplant or detract from the comprehensive felt that they had already undertaken an
process of consultation undertaken by BTC. extensive consultation process and that this
In the run up to Board approvals, these had already been verified on a number of
meetings were intended to provide the occasions by field visits of IFC and EBRD
lenders access to local communities specialists. In this respect, the MSF risked
affected by the pipeline and to allow undermining the sponsor's own program and
verification of opinions of local people. This creating expectations by being perceived as
constituted an important component of the an alternative consultation and grievance
lender’s 120 day public disclosure period. process. The sponsor also expressed a
Consequently, two separate day-long legitimate complaint about double standards:
meetings were held in each of the three BTC had undertaken a thorough, in-depth and
countries with a total attendance of over ongoing process of consultation (some of
800 people. which was considered best practice by the
lenders) whereas IFC/EBRD's own stakeholder
Reviews on the effectiveness and value of engagement through the MSF was one-off
the MSF are mixed, and vary significantly and superficial by comparison. IFC specialists
depending on whom one asks. On the agree that while the concepts of stakeholder
positive side, the MSF helped to facilitate engagement and lender verification of broad
board approval to finance the project by community support for prospective projects
giving needed additional comfort and (now a requirement in IFC's new Sustainability
confidence to the lenders and their Policy) are good and necessary, more
shareholders. While the process was not thought is needed on how best to achieve
perfect, it did increase stakeholder these objectives. The model of large public
participation and access to IFC by ensuring forums, as embodied by the MSF process,
that the Corporation widened its circle might not be the only nor most effective
beyond a small cadre of international NGOs means of engendering meaningful interaction
and created a forum in which to hear local between lenders (including members of their
NGO and civil society concerns directly. senior management) and local stakeholders.
Many of the more critical international NGOs For example, rather than public meetings with
declined to participate in the MSF, but this hundreds of people, smaller focus groups with
facilitated local civil society organizations key representatives—as was done as a
speaking for themselves. In fact, in Georgia follow-up to the MSF in Georgia—might be a
in particular, the MSF meetings revealed that more productive way of fostering dialogue on
there was little local support for some of the key issues. In either case, care must be taken
positions advocated by some of the most not to duplicate or undermine the work of the
sponsor.
Page Sixteen
Six
Lessons of Experience | September 2006 | Number 2

Other IFC Lessons on Engaging “consultation tracker” and spent much time
with Stakeholders responding to issues raised by stakeholders.
A key lesson is that the time and resources
required to initiate and maintain a robust
Separate from the sponsor's process, IFC staff process of consultation with stakeholders
spent considerable time engaging with should not be underestimated.
stakeholders. This occurred on two levels:
in the field and in Washington, D.C. IFC's The time and
Executive Vice President at the time wanted Disclosure of Documents resources required
IFC staff in the field as often as possible in
to initiate and
order for the Corporation to gain its own
independent understanding of the issues on The quantity of environmental and social maintain a robust
the ground. As a result, IFC environmental information on the BTC pipeline that was process of
and social development specialists disclosed locally and in the IFC's InfoShop
was vast (38 volumes). The documents were
consultation with
undertook close to twenty field visits during
project appraisal, often remaining in country translated into local languages and made stakeholders
for two or three weeks at a time and available at local libraries, regional centers, should not be
spending time in the villages along the and offices of local government, NGOs, and
BTC in all three countries. These locations
underestimated.
pipeline. While this is costly from a resources
point of view, it proved extremely beneficial were announced through the national and
in terms of IFC's ability to respond to questions local newspapers and through radio. A lesson
and critiques. Direct experience enabled learned during this process was that the
staff to respond with confidence (i.e. “this is disclosure of excessively large volumes of
what villagers told me.”) information does not necessarily facilitate
effective communication with, and use by,
IFC staff also spent an enormous amount of affected stakeholders. The quantity and
time responding to comments from NGOs presentation of relevant material for
prior to and during the 120 day disclosure disclosure must receive special attention,
period for the ESIAs and related documents. particularly on large complex projects.
One month prior to Board, the team Where possible there is a need for more
prepared a 60-page response to NGO focused summary reports to be disclosed that
questions and continued responding to local people can readily digest and
comments right up to the eve of the Board understand, rather than the voluminous suite
date. Again, from a resources point of view, of technical documents that have been
this response proved very time-consuming, prepared. (The latter can always be made
but it was very effective in addressing the available upon request.) To help address this,
concerns of IFC's Executive Directors. BTC produced community pamphlets, non-
technical summaries, posters and case
Another practical tool that the team found studies on specific issues, and held many
useful in managing the engagement process village meetings on disclosure of information.
was maintaining a “Stakeholder Log” which In Turkey, for example, simplified
tracked every meeting IFC staff held with presentations were made at the village level
interested parties, including the date, as it was found that oral communication was
location, and key issues discussed. A written a more effective means of conveying key
record or “paper trail” is important both to ESIA findings.
retain institutional memory and to be able to
demonstrate the frequency of engagement This is a view shared by the sponsor who felt
and range of stakeholders with which IFC that some of IFC's disclosure requirements
dealt. The sponsor also developed a regarding what to disclose, and to whom,

Page Page
SevenSeventeen
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

were overly burdensome and in certain


» The independent Multi-Stakeholder Forum
cases not sensible. They found the logistics
carried out by IFC and EBRD to communicate
and relevance both difficult and the lenders' position on the potential financing of
questionable especially with an ESIA the project and to listen to stakeholder views
document numbering over eleven thousand helped facilitate board approval for the project
pages. The cost to the client of printing, by confirming that the project did have local
photocopying, translation, and dissemination community support. However, in undertaking
of the documentation was considerable. such initiatives, IFC must take care not to
duplicate or undermine the sponsor’s own
Some of these concerns have been recently
consultation program by raising expectations, or
addressed in IFC's new Disclosure Policy.
giving the perception of being an alternative
grievance channel.

» In addition to the MSF program, significant IFC


Summary of Key Lessons time and resources were invested in engaging
and Future Recommendations with the sponsor, affected communities, and
NGOs during project appraisal. This level of
engagement provided in-depth understanding
of the project and improved IFC's ability to
» The BTC project benefited greatly from the
respond to questions and critiques which was
comprehensive process of consultation with
a significant factor in facilitating board support
affected communities that the company
for the project.
carried out. Consultation provided valuable
information that informed project planning
» IFC staff developed a “Stakeholder Log” for the
(such as route selection to avoid cultural and
BTC project which tracked every meeting IFC
archaeological sites) and contributed to the
staff held with interested parties, including the
formulation of employment, community
date, location, and key issues discussed. This
relations, and community investment initiatives.
written record was important in retaining
institutional memory and demonstrating the
» In addition to the community consultation, BTC
frequency of engagement and range of
consulted extensively with local, regional and
stakeholders IFC dealt with during project
national government, national academics,
appraisal and supervision. This should be
specialist organizations, and national, regional,
considered as good practice for future projects.
and international NGOs regarding the project.
BTC personnel were not always convinced that
» The disclosure of excessively large volumes of
the effort expended in their interaction with
information as was the case for BTC does not
certain international NGOs fundamentally
necessarily facilitate effective communication
opposed to the project was worthwhile, but
with, and use by, affected stakeholders. IFC
IFC specialists maintain that the process of
should be attentive to the quantity and
engaging with all of the project's critics is an
presentation of relevant and appropriate
important one. It demonstrates a willingness to
material in summary form to ensure meaningful
listen, learn and discuss.
disclosure.

» For a project of this scale, the extent of the


public consultation process should be
publicized both nationally and internationally
to reduce potential criticism of the process
due to lack of awareness.

» Skilled consultants with experience in


participatory techniques and methodologies
are needed to facilitate an effective two-way
dialogue between the project and affected
communities.

Page Eighteen
Six
Lessons of Experience | September 2006 | Number 2

required temporarily for construction


Land Acquisition and
purposes and will be returned to the original
Compensation land right holders. All land users on the more
than 17,700 affected land parcels along the
A key principle in land acquisition (which is route (many with multiple owners) were
also a requirement under IFC policy) is to try visited by BTC land acquisition teams, and
to avoid or minimize the physical considerable effort was made to contact
resettlement of households to the greatest absentee land owners. The land teams were The land
degree possible. BTC successfully achieved assisted by local NGOs, and NGOs in each
acquisition and
this objective through careful initial planning country were also commissioned to give
that avoided all villages and towns, and by independent advice and counsel to land compensation
making subsequent minor route changes to owners and users. process for
avoid any homesteads that were
BTC was
encountered in finalizing the pipeline right-of-
way. Given the statistics involved—a 1,760km Timing Issues complicated,
pipeline, 515 villages, and land acquisition difficult, and
affecting over 17,700 parcels of land and
not without
more than 100,000 people—it is remarkable In hindsight it is fair to say that, at least
that not a single household was forced to initially, BTC underestimated the scale and
problems.
move on account of the project. This was complexity of the land acquisition process
achievable because the BTC pipeline and how much lead time and resources this
traverses mainly a rural environment with few would require in countries where land
large settlements, and may not be possible registration systems and land records were
for other projects in more densely populated weak or non-existent. Part of this resulted
areas. Nevertheless, the BTC example from the fact that such a comprehensive
serves to demonstrate that taking social land acquisition process for a pipeline
considerations into account in project design project (including compensation for physical
can significantly reduce impacts to the local and livelihood impacts) had not been
population. Other notable good practices undertaken in any of these countries before,
emerging from the BTC land acquisition so there was no direct experience to draw
process include the preparation of a “Guide upon. In many cases BTC found they had to
to Land Acquisition and Compensation” start from scratch, initiating land survey work
(GLAC) as a supplement to traditional and identifying thousands of rights holders,
Resettlement Action Plans (RAPs), and the which ultimately resulted in a significantly
development of a RAP Fund to cover improved land management system, but
miscellaneous impacts not covered by took considerably longer than originally
Turkish legislation. anticipated. Contributing to the timing issue
was the fact that the original scoping studies
The land acquisition and compensation had not sufficiently emphasized the extent
process for BTC was complicated, difficult, and nature of the land issue early on
and not without problems. A comprehensive (although it was known that this was an
program was required to address mostly important issue) and that the subsequent
temporary impacts to the livelihoods and ESIA and RAP studies were not integrated.
activities of a very large number of Instead, much of the data on land issues
households, exacerbated by complex land required for the RAP was not collected
tenure systems in all three countries. A specifically as part of the ESIA process but
relatively small proportion of land was undertaken separately and later on by
required permanently for above ground different consultants with specialized
installations such as pump stations and block expertise. While this approach seemed to
valve stations. Most land acquisition was
Page Page
SevenNineteen
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

make sense to the sponsor at the time, in they needed from the sponsor before any
retrospect, integrating the two processes land acquisition took place.
would have likely been more efficient from
both a timing and resources point of view.
The lesson here is that land acquisition and The GLAC
resettlement should be addressed as part of,
or in parallel with, the ESIA process.
The “Guide to Land Acquisition and
Disclosure issues also affected timing. For Compensation” (GLAC) came into being as
example, there was a lack of clarity a practical compromise between IFC and
between IFC and the sponsor over when the the sponsor to prevent the resettlement plan
resettlement action plan had to be timetable from bringing project construction
disclosed. On BTC, the ESIA reports and the to a costly halt, while at the same time,
RAPs were required to be disclosed for 120 safeguarding the rights of project affected
days before IFC's Board decision. However people to receive key information prior to the
the sponsor wanted to commence land commencement of land acquisition. In
acquisition in advance of the 120 day advance of the full resettlement plans, GLACs
disclosure date and hence, before the were prepared for each of the three
relevant reports were ready. At the time, countries traversed by the pipeline and
IFC's policy was not explicit about the need translated into local languages. They
to disclose RAPs before commencement of consisted of a shortened and easily digestible
land acquisition, and only stipulated summary of the land acquisition and
disclosure requirements in terms of the Board compensation process, targeted at the level
date. IFC, however, insisted on the need for of the individual farmer. The GLACs
RAP disclosure to precede the land summarized the project land needs for the
acquisition (in the event this was to happen pipeline and the compensation framework.
before the Board date) based on the Key areas covered were clear descriptions of
principle that affected people needed to the terms of eligibility for compensation; land
have such information in advance of valuation; and the calculations to be used for
2
agreeing to compensation packages. compensation of crops, pasture loss and
This misunderstanding caused a timing crisis damage to orchards, trees and so on.
for the sponsor because work on the RAPs Methods to be used for compensation
had started late and time for completion payment to affected households, and
and disclosure could delay implementation restrictions to land use and access during the
of construction contracts, which had already pipeline construction and operational
been awarded, and could result in costly phases, were also summarized in each GLAC
contractual penalties. as well as other practical information such as
whom to contact and how to register
In the end, construction was delayed for grievances.
other reasons, but in the meantime a solution
to ensuring adequate disclosure of land Although, in the end, the complete and
acquisition information was found. BTC detailed resettlement plans were actually
prepared and disclosed a concise “Guide to released before land acquisition
Land Acquisition and Compensation” commenced, the GLACs proved extremely
(GLAC) to affected villages so that land useful for local households since they
owners and users had the basic information presented the information in a clearer and
simpler form than the detailed resettlement
plans, and did much to clarify compensation
2
IFC's new Disclosure Policy is now much more explicit issues and avoid misunderstandings. As such
concerning timing and disclosure of environmental and
Page Twenty
Six social documents, including RAPs.
Lessons of Experience | September 2006 | Number 2

address gaps between the provisions of


Turkish legislation and the requirements of
IFC/WB Safeguard Policies and set up a
separate “RAP Fund” to facilitate
implementation of these measures.
Essentially the RAP Fund was a pool of extra
budgetary resources made available by the
sponsor, but its success in the BTC project BTC developed
was ultimately determined by what these
innovative
funds were spent on. The RAP fund covered
T. Pollett
extras such as expenses incurred by approaches to
affected people including legal, registration address gaps
Herder affected by land acquisition in Azerbaijan. and transportation costs, or compensation
between the
for grazing land or forest products which
were not covered under Turkish law. (This is provisions of Turkish
also the case in many other countries.) In legislation and the
IFC now recommends the supplemental Turkey, inherited land is commonly not
requirements
production of GLACs as good practice for registered and this presents a particular
summarizing relevant resettlement problem in formalizing ownership, especially of IFC.
information (particularly in cases of complex when the process involves resolving
land acquisition situations) for ease of use by entitlements over generations and large
affected households. The BTC project extended families. The RAP Fund was used
demonstrated that, from the community's to cover miscellaneous expenses incurred to
perspective, GLACs may prove more useful formalize ownership and registration and
than the more technical resettlement plans. greatly facilitated the land acquisition
Detailed resettlement plans are nevertheless process. In particular, a ground breaking
essential to record relevant baseline data, approach was developed to compensate
regulatory and policy requirements, and fishermen/farmers for partial impacts to the
analysis of compensation requirements. They extent of their available fishing grounds
also provide details of the total extent and caused by the construction of the oil
cost of compensation as well as the terminal and jetty at Ceyhan. This included
measures to implement compensation, measures to improve and further develop
including establishing land valuation teams, their existing agricultural activities, purchase
liaison and grievance mechanisms, and vehicles and agricultural equipment to
monitoring and evaluation systems. diversify economic activities, and contribute
to household income. They also received
assistance to construct houses, pay their
debts to social security institutions to
The RAP Fund
become eligible for retirement, and establish
additional entrepreneurial opportunities
(e.g. a transportation co-operative which
Turkish law does not provide for
would receive some contracts from the
compensation of certain losses, including:
project). Fifteen fishermen were also
loss of use of some communal lands used for
employed during construction of the
livestock grazing (particularly where
project. These measures developed to
ownership of the land resides with the state);
mitigate impacts to fishermen are a first for
informal land users using land owned by the
Turkey and likely set a benchmark
state or others; loss of fishing grounds; and,
internationally as they have rarely been
other miscellaneous claims. As such, BTC
addressed as comprehensively elsewhere.
developed innovative approaches to

Page Page
SevenTwenty-one
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

Summary of Key Lessons additional compensation to mitigate losses not


and Future Recommendations covered under Turkish legislation. A similar
funding mechanism should be considered for
» The scale and complexity of the land future projects to address gaps between the
acquisition process should be clearly identified provisions of host country legislation and IFC
as early as possible in project planning (ideally requirements on land acquisition.
during the ESIA scoping exercise); especially
where there are weak or non-existent land
registration systems as was the case for the BTC
project. This will help establish the lead time
and resources required to formally register the Monitoring and Reporting
land.

» Land acquisition and resettlement should be Due to the size and complexity of BTC and
addressed as part of, or in parallel with, the ESIA the high level of international interest it
process. These were separate for BTC but in
attracted, there were multiple stakeholders
hindsight, integrating the two processes would
who wanted to be able to monitor the
have resulted in efficiencies of resources and
timing, in particular with respect to baseline
project's environmental and social risks over
data gathering. In this way, data on land and and above the internal management and
households collected for the ESIA can also be assurance mechanisms put in place by IFC
used for the resettlement plan. and the overall lender group. As a result there
were multiple layers of internal and external
» Land acquisition can be a lengthy and monitoring and oversight being carried out at
complicated process. To avoid delays, work
any given time during the construction phase
on the RAP should begin far in advance of
of the project. This included monitoring by the
breaking ground and construction.
lenders, government regulatory bodies,
» Project land acquisition teams should consider independent monitors, NGOs, contractor
assistance from local NGOs in providing personnel, BP corporate, and BTC's own staff,
independent advice and counsel to land among others.
owners and users. The BTC project experience
in this regard was mainly positive. The general conclusion to emerge from the
construction phase is that monitoring did
» IFC should ensure that the sponsor is clearly
indeed result in better environmental and
informed of the RAP disclosure requirements in
terms of the timing required prior to the IFC
social outcomes for the project by helping to
board approval of financing and/or actual focus management attention on issues that
land acquisition proceedings. needed to be addressed. The public
disclosure of all external monitoring reports for
» The BTC project prepared a concise Guide to BTC is also considered international good
Land Acquisition and Compensation (GLAC) practice for a project of this nature and
document that summarized relevant
should be replicated for similar projects.
resettlement information for distribution to
However, from the sponsor's point of view the
affected communities. The ease of use of the
GLACs by the affected households indicated
number of layers of oversight, the frequency
that they were more useful than the more of monitoring visits, and the quarterly
technical resettlement plans. As a result, IFC reporting requirements imposed by lenders
now recommends the supplemental production during construction came at a significant cost
of a GLAC as good practice, particularly in in terms of time, level of effort, and resources.
complex land acquisition situations such as BTC.

In terms of external parties, the monitoring


» A RAP Fund set up by BTC proved an important
that stands out as having provided the most
tool and budget mechanism in meeting the
social objectives of the project by providing
value were the three independent monitoring

Page Twenty-two
Six
Lessons of Experience | September 2006 | Number 2

Multi-layer Monitoring, Assurance and Oversight of BTC

CONSTRUCTION PHASE OPERATIONS PHASE

Layer 10 Caspian Development Advisory Panel (CDAP)


E
X Layer 9 Lenders’ Independent Environmental Consultant (IEC) The public
T
E disclosure of
Layer 8 Lenders’ Social & Resettlement Action Plan Panel (SRAP)
R external monitoring
N
A Layer 7 Security monitoring and implementation reports is
L considered
Azerbaijani Regulatory Georgian Regulatory Turkish Regulatory Regulatory Monitoring
Layer 6 Monitoring Monitoring Monitoring Az, Geo, Tk international
NGO Monitoring NGO Monitoring NGO Monitoring Long-term stakeholder good practice.
Layer 5 Azerbaijan Georgia Turkey
dialogue
Az, Geo, Tk

I Layer 4 BP and BTC Shareholder Monitoring


N
T Operations
Layer 3 BTC Co. Project Monitoring
Management
E
R BTC Assurance Team BTC Assurance Team BTC Assurance Team Tk
N Layer 2 Azerbaijan Georgia Botas Assurance Team Tk
A
Construction Contractors Construction Contractors Construction Contractors
L Layer 1 Azerbaijan Georgia Turkey

Source: BTC Project Environmental and Social Annual Report (Construction Phase) 2004.

panels—the Caspian Development Advisory On BTC, IFC drew on a number of monitoring


Panel (CDAP), the Independent lessons from its experience with the Chad-
Environmental Consultant (IEC) to the lender Cameroon Pipeline project. (For more
group, and the Social and Resettlement information, see IFC’s Lessons of Experience:
Action Plan (SRAP) panel. Multiple field visits External Monitoring of the Chad-Cameroon
were also undertaken by IFC social Pipeline Project.)
development and environmental staff and
are viewed by IFC as necessary and
beneficial due diligence for a project of this The Caspian Development Advisory
size. In addition, support to local NGOs to Panel (CDAP)
enable them to undertake their own
monitoring was a good practice initiative
piloted during the BTC construction phase CDAP (comprised of members with well-
with positive results. With respect to internal established international standing) was
monitoring, it was felt that BTC assurance commissioned as an independent, external
teams operating in each country to supervise body reporting directly to BP's Chief Executive
the work of the contractors on the ground Officer, Lord Brown, with the objective of
were the most effective at identifying issues providing advice on the economic,
and finding solutions.
Page Page
SevenTwenty-three
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

environmental and social aspects of all of where integrated monitoring worked well) the
BP's developments in the region, including two teams were separate for the BTC project.
the BTC pipeline, in order to ensure The division of labor in this case assisted with
implementation according to world class complex logistics to enable field visits to
standards. Unlike other monitoring bodies, specific sites and communities all along the
the value of CDAP is that it took a “10,000 1,760km pipeline. The SRAP panel, which
foot view” of the project and focused on a visited the project every six months, had its
number of big-picture, strategic items that hands full dealing with large-scale land and
did not get covered elsewhere. For example, compensation issues, and spent the bulk of
the Regional Development Initiative (RDI), their time with directly affected communities
referenced further on page 29, is a direct and households. The IEC panel made
result of CDAP recommendations. The panel quarterly visits, monitoring the implementation
travels along the pipeline once a year and of environmental management measures
their reports are made public. included in the ESAP for the construction of
the pipeline and associated above ground
By reporting directly to BP's CEO and having installations and workforce camp sites. The
a different monitoring emphasis (i.e. viewing separated monitoring also lent itself well to
issues through a lens other than compliance) BTC's organizational structure in Azerbaijan
the CDAP approach has some apparent and Georgia which had separate team leads
advantages. These include the sponsor's for environment and social issues. The
ready acceptance of the advisory panel disadvantage of a separate approach,
concept and a willingness by BP Senior however, is the possibility that overall
Management to proactively address CDAP coordination and communication may suffer.
recommendations, which has not always To avoid this, special attention may be
been the case on other projects. This is a needed to foster regular dialogue between
different model from the well known Chad- the two teams through integration meetings
Cameroon International Advisory Group and coordination of field visits.
(IAG) which reported directly to the World
Bank Group (WBG) President. A possible
disadvantage with the CDAP approach is Costs and Effectiveness
that some civil society organizations may not
perceive the panel as sufficiently
independent, however this has not emerged Perhaps the single most important factor in
to date as an issue on BTC. independent monitoring effectiveness is the
skill and technical competence of the
monitoring team. In order to draw
The Independent Environmental and management attention to critical issues and
Social Monitoring Panels: IEC and SRAP influence decision-making on actions to be
taken, the monitoring team members must be
respected for their professional judgment and
The Independent Environmental Consultant be able to engage in constructive feedback
(IEC) to the Lender Group and the Social and dialogue with the company. Effective
and Resettlement Action Plan (SRAP) panel monitors recognize that projects cannot be
were contracted as independent third-party 100% compliant all of the time, but work to
monitors, a requirement by the lenders. identify and prioritize key issues for attention.
Whereas in most cases IFC recommends The identification of risks and continuous
integrated environmental and social improvement in compliance are key to
monitoring as good practice, (the Chad- ensuring the adequate performance of a
Cameroon pipeline project is an example of project. Both IFC and BTC staff agree that the

Page Twenty-four
Six
Lessons of Experience | September 2006 | Number 2

NGO Monitoring in Azerbaijan and Georgia

Monitoring of the Project by national NGOs was a vital funds to support the participating NGOs. It
recommendation made by the CDAP panel in also established a registration, training and
2004 and supported by IFC and EBRD. BTC took up mentoring system for the NGOs. Azeri NGOs
this recommendation, with a view that subsequently identified five monitoring themes
constructive and well-informed NGO monitoring (social, land and worker rights, local content,
could be useful to the company in helping to cultural heritage, and environment), formed a
improve the performance of the project. group for each theme, and created smaller
However, a number of NGOs in the pipeline working groups to perform the monitoring on
countries lacked the experience and financial behalf of the others. They also took part in training BTC took a view
resources to effectively perform a monitoring role. on monitoring, evaluation and reporting
The challenge for BTC was to find a way to provide techniques and received presentations about the that constructive
a learning process and financial support for the BTC project. and well-informed
NGOs without financing them directly in order to
preserve their independence. Sharing Experience with the NGO monitoring
Chad-Cameroon Pipeline
To achieve this, BTC engaged third-party could be useful in
organizations to facilitate the implementation of
the NGO monitoring program in Azerbaijan and
OSI brought in Catholic Relief Services to provide helping to improve
training in monitoring techniques, using the
Georgia. (In Turkey, a facilitating organization was expertise of an NGO monitor on the Chad- the performance
not engaged because the experience and Cameroon pipeline project. There are few
capacity of Turkish NGOs was generally greater projects equivalent to the BTC pipeline, so this
of the project.
than in Azerbaijan and Georgia and a number of was an opportunity to share valuable experience
Turkish NGOs were already involved in the Project.) from a comparable project. The Chad-Cameroon
The facilitating organizations were able to establish NGO monitor continued to support the Azeri
a number of Working Groups in both Azerbaijan NGOs while they prepared and implemented
and Georgia. Members of each Working Group their monitoring plans and wrote their reports. In
received training in monitoring and audit five years' time perhaps the Azeri NGOs, like those
techniques, as well as presentations and monitoring Chad-Cameroon, will be asked to
information sessions about the Project from BTC travel to other countries to train their local NGOs
staff. Throughout the monitoring period, BTC in monitoring. The Chad-Cameroon NGO
provided access to construction sites and monitoring experience has led to greater
documentation, supported by meetings with dialogue and a relationship of mutual respect
relevant BTC and contractor personnel. The between the operating company and the NGOs,
objectives of the program were as follows: and the same long term result is hoped for in
Azerbaijan.
» to enable participating NGOs to acquire the skills
to plan and implement a program of objective
Georgia
monitoring and reporting of the BTC pipeline to
international standards.
In Georgia, the NGO monitoring facilitating
organization is the Eurasia Foundation whose
» to provide the NGOs with transferable skills to
Pipeline Monitoring and Dialogue Initiative (PMDI)
monitor environmental and social impacts of
is assisting NGOs in Tbilisi and along the pipeline
other projects.
corridor. PMDI is a “facilitated monitoring”
program to build an expert cadre of NGO
» to demonstrate to Lenders, CDAP, partners, the
monitors and encourage informed participation
public and the international community that BTC
by a wide variety of NGO representatives in
is taking their commitment to transparency
monitoring the impact of the pipeline route. Many
seriously.
NGOs responded to the initial invitation to register,
and a selection process resulted in the formation
Participants from the Azerbaijan program visited
of three Working Groups: Waste Management,
Georgia during March 2005 to share their
Reinstatement, and Social and Human Rights. IFC
experiences, and this cooperation between the
provided direct funding to Eurasia Foundation
two countries is expected to continue as the
and an additional grant to BTC towards the first
programs progress. This level of formal
component of PDMI. NGO training and
collaboration between industry and civil society is
monitoring was successfully achieved in
seen as providing a model for future developments
December 2005 and further capacity building is
in the Caucasus region.
underway in 2006.

Azerbaijan

In Azerbaijan BTC formed a partnership with Open Source: BTC Project E&S Quarterly Reports (Q2 2004 and
Society Institute (OSI) Azerbaijan. OSI acted as a Q2 2005), BTC; Social Responsibility Program (Corporate
coordinator for the NGOs as well as contributed Citizenship Facility), IFC.
Page Page
SevenTwenty-five
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

external monitors were generally successful Reporting


at catalyzing management action on a
number of environmental and social issues,
and some made helpful recommendations The sponsor also expressed similar views when
that positively influenced project outcomes. it comes to reporting requirements. BTC was
A key lesson here is that external monitors required to produce quarterly and annual
are most effective when they can go E&S reports for the lender group during the
beyond monitoring and assist the client by construction program. Some found quarterly
providing technical advice and helping find reporting to be excessive, suggesting that this
pragmatic solutions to identified problems. level of frequency was “overkill” and that the
level of effort put into producing such
Overall, it is felt that external audits quarterly reports was not commensurate with
produced a number of benefits. The very the number of people who actually read it.
process of having to prepare for an audit is On the positive side there are benefits to such
an important driver for senior management, reporting. For lender purposes—as well as its
prompting internal focus, prioritizing of issues own needs—BTC has developed robust
and reaction to findings. Environmental and internal monitoring, tracking, and data
social staff say that external monitoring tends recording systems. The company has set
to strengthen their position internally by benchmarks in terms of the quality and
giving them greater leverage with their own comprehensiveness of its environmental and
management to act on various issues. social reports which constitute an excellent
historical record of the project. Such reports
Based on the BTC experience, IFC staff have proved useful in tracking issues over
believe that regular third-party monitoring time, demonstrating positive outcomes
visits to the sites during construction were and/or defending the project if needed. BTC
extremely valuable and significantly helped has also used case studies in their reporting to
the lenders demonstrate compliance and document some of the innovations and
keep track of a myriad of issues on a project achievements on the ground.
of this scale. The monitoring gave lenders the
insight required to allow them not only to
measure performance but to better Summary of Key Lessons
understand the constraints under which the and Future Recommendations
operator was working. While the sponsor
agrees with the value of external monitoring, » Frequent monitoring of the BTC pipeline
they expressed the view that quarterly visits construction program by internal and external
were excessive and overly burdensome on monitors resulted in better environmental and
BTC staff and that these should be reduced social outcomes for the project by helping to
to a maximum of three times a year. They focus management attention on issues that
also point to the significant addition of needed to be addressed.

personnel (close to 20 extra people had to


» Frequent monitoring and independent
be hired for this purpose) and resources
verification visits during the construction phase
necessary to accommodate lender of large scale projects should be carried out;
monitoring requirements. In hindsight, IFC however the frequency of monitoring should be
staff agree that three times per annum commensurate with the scale and complexity of
would have been sufficient and should be the project. BTC agreed to a quarterly
recommended for future projects of this environmental monitoring schedule and social
scale. monitoring every six months during the
construction program with the lender group. In
practice, the frequency of the external
environmental monitoring was considered to be

Page Twenty-six
Six
Lessons of Experience | September 2006 | Number 2

management and mitigation of “non-


too high and three times per year would have
technical risk” (i.e. social risk); ensuring the
been more appropriate.
project's license to operate and expand;
» External monitoring teams should be carefully enhancing reputation and shareholder
selected for their ability to exercise professional value; improving community and
judgment and be able to engage in stakeholder relations; and, promoting a
constructive feedback and dialogue with the stable operating environment. Making this
sponsor. External monitoring teams were most level of commitment was also in keeping External monitors
effective on the BTC project when they were
with BP's stated ethic of bringing real and
able to go beyond monitoring compliance and are most effective
measurable benefits to those communities
provide technical advice and solutions to
adjacent to its businesses. when they can
problems.
go beyond
» External reporting on environmental and social
monitoring and
management activities and performance Community Investment Program
should be conducted. BTC reports were help find solutions
comprehensive and provided an excellent
to identified
record of the project; however the frequency of
reporting requested by the lender group was In establishing a multi-million dollar problems.
perhaps excessive at four times a year during Community Investment Program (CIP), BTC
the construction phase. decided to go beyond simply providing
philanthropic contributions and sponsorship
donations. The pipeline traverses some of
the most economically disadvantaged
regions in Azerbaijan, Georgia and Turkey
Social License to Operate
and the CIP aimed to provide long-term
sustainable development projects in the
In order to improve conditions for local
local communities while at the same time
populations living near to the pipeline route,
supporting local social infrastructure
BTC broadened its scope from typical project
development and stimulating economic
impact mitigation and compensation
opportunities. The CIP specifically targeted
requirements, to a wider concept of
income generation and employment
sustainable development among locally
creation (including strengthening local
affected communities. This type of
agricultural development), infrastructure
sustainable approach to project
rehabilitation, health and sanitation
development is becoming an increasingly
programs, capacity building programs
important aspect of IFC-financed projects.
and training.
However, this approach posed several
challenges for the sponsor. First, community
From the outset, the approach has been to
investment on such a scale had never been
avoid fostering dependency by helping to
done before by BP. Secondly, the entire
build the skills and capacity of local
community liaison and community
communities, NGOs and other local
investment program was outside the
organizations to implement community-
traditional skill set of both the BTC project
identified projects. The community projects
teams and the contractors. To address this,
have been designed in consultation with
BTC hired personnel with specific skills in these
local communities and other stakeholders
areas to manage the programs.
and, following community needs assessment
studies, investments were selected from
From the sponsor’s perspective there were a
proposals submitted by potential
number of objectives in undertaking broad-
implementing organizations. To implement
based community initiatives in each of the
the programs, BTC partnered with a number
three countries. These included the
Page Page
SevenTwenty-seven
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

of international and local NGOs in Azerbaijan


Environmental Investment Program
and Georgia and with local NGOs in Turkey.
A great deal of effort went into managing
expectations on all sides. This was BTC has contributed $8.8 million to an
accomplished in part by the integration of environmental investment program which
BTC's Community Liaison and Community aims to promote and conserve biodiversity.
Investment programs in order to facilitate a A number of projects are underway and,
holistic approach to the company's where possible, projects have been
selected to complement national and
externally-focused activities. In this way CIP
regional biodiversity strategies. Projects
benefits could be leveraged to help
range from the conservation of vulnerable
manage community liaison beyond and floral and faunal species and their habitats
outside of the project’s official grievance in each country, forestry projects, and
mechanism. public awareness programs. A number of
implementing partners are involved
In the early phases of implementation, there including NGOs, universities, consultancies
were a number of lessons learned by BTC and foundations.

staff working on the community side of


operations, the first of which is that CIP does
not guarantee good community relations in
and of itself, but if done right can help foster
long-term trust and goodwill with affected
communities and other stakeholders. By training and livestock vaccination programs
contrast, one can have an extremely as well as numerous examples of micro-
successful community development financing. The CIP has provided a wide
program, but if the community liaison side variety of training and capacity building
is not working well, relations can be activities in relation to project planning and
problematic. In other words, the two implementation. BTC staff point to the
initiatives go hand in hand. This underscores importance of communicating the
a second important lesson: social risk achievements and benefits of the CIP both
mitigation is not only about providing money. internally and externally to raise awareness of
There are many other intangibles involved the many positive things happening on the
when dealing with communities such as ground.
communication, transparency, relationships
and trust without which no CIP can succeed.
BTC staff also emphasize the necessity of Promoting Economic Opportunities
having qualified field personnel in both the at the Local Level
CIP and community liaison areas and in
hindsight would have put their Community
Liaison Officers in place sooner. BP, as the operator of BTC, has also taken
measures to facilitate the participation of
Independent monitoring has shown that the local companies in the supply of services and
CIP has resulted in significant progress. Over goods for project construction. In 2002, BP
500 communities have benefited from the opened an Enterprise Centre in Baku,
program. Community members involved Azerbaijan. This center has served as a focal
with the program are supportive and point for efforts to enhance local business
satisfied with the programs accomplishments capacity with the aim of helping local
in terms of community mobilization and companies develop their business in support
capacity building, medical training and of the BTC development and other major oil
support, infrastructure upgrades, farmer and gas developments in the region.

Page Twenty-eight
Lessons of Experience | September 2006 | Number 2

Typically the center assists local companies in


understanding BP's contracting policies and
standards, provides advisory services and
training in the competitive tender process as
well as in finance and accounting skills. The
center also informs these companies of
contracting opportunities.
Social risk
IFC partnered with BP and others in late 2002
mitigation is
to implement a small and medium sized
not only about

T. Pollett
enterprise (SME) linkage program specifically
related to the BTC project and other BP providing money.
operated projects in the region. Operating Georgian women returning from the fields.
from BP's Enterprise Centre, this program is
part of IFC's ongoing strategy of working
closely with its clients to provide
developmental support through linkages to
IFC's investment projects. The purpose of this
SME linkage program is to direct support to

Grievance Mechanism

An effective and well-functioning grievance mechanism is an essential part of managing community


relations. For BTC, the sponsor developed a separate grievance process for each country to manage
complaints arising from the project. The objectives were to: (i) provide affected people with
straightforward and accessible avenues for making a complaint or resolving any dispute that may
arise during the course of the project; (ii) ensure that appropriate and mutually acceptable corrective
actions were identified and implemented; and (iii) verify that complainants were satisfied with
outcomes of corrective actions. In addition, a parallel grievance process was developed by the BTC
construction contractors.

Some key elements of BTC's grievance mechanism included:

» Community Liaison Officers (CLOs) based in the field and responsible for receiving complaints and
coordinating responses.
» A “Complaints Log” recording individual complaints, corrective actions taken and responses to
complainants.
» A two-week response time to all complaints (even if just a summary of proposed actions that will be
taken to resolve the complaint.)
» All complaints responded to in writing (or verbally where circumstances warrant.)
» Recourse to pre-judicial and judicial process under host country law in cases where satisfactory
response to the complaint cannot be negotiated.
» Weekly and monthly reports prepared by the lead CLO detailing the number and status of
complaints and any outstanding issues sent to the BTC Community Relations Manager in each
country.

During the construction program BTC had to continually augment their CLO resources in some
locations to manage their response to the number of complaints received by project affected
communities in a timely manner. A general lesson learned is that despite extensive community
consultation carried out, significant complaints may still arise. Sponsors and contractors need to be
prepared for this possibility and be able to source additional skilled resources.
Page Twenty-nine
Twenty-seven
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

expanding local supply and distribution


» Community investment programs do not
chains and to create more opportunities for
guarantee good community relations, but if
smaller businesses as well as assist in done right they can help foster long-term trust
sustainable community development efforts. and goodwill with affected communities. Good
Specifically, the program was designed to community relations and successful community
improve the capacity and know-how of investment programs go hand in hand and
local companies active in the oil and gas should be integrated from the beginning.
service and supply sectors in order to help
» Social risk mitigation is not only about providing
them benefit from investments in the industry.
money. There are many other intangibles
Many local companies have already
involved when dealing with communities such as
received technical assistance and training communication, transparency, relationships and
and several additional projects are in active trust without which no CIP can succeed.
implementation since the start of this
program. » The approach to community development
should be participatory and should avoid
Following a recommendation made by the fostering dependency.

CDAP panel, BP decided to also develop an


» Local NGOs and other local organizations should
additional program, the Regional
be invited to participate as partners in the
Development Initiative (RDI). Working in design and implementation of the community
partnership with other international development initiatives.
development institutions, this program is
being designed to contribute to various » Personnel with experience in community liaison
selected long-term sustainable development and community investment initiatives are
initiatives in the region. The program will essential to successful community interactions
and these personnel should be put in place in
continue through BTC operations and will
the field as early as is practical.
focus on enterprise development, effective
governance and access to energy. » Communicating the achievements and benefits
of community programs both internally and
externally is important.
Summary of Key Lessons
and Future Recommendations

» An effective and well-functioning grievance


mechanism is an essential part of managing
community relations. Despite extensive
community consultation, significant complaints
may still arise. Sponsors need to be prepared for
this possibility and be able to source additional
skilled resources to manage the process.

» BTC broadened its scope from typical project


impact mitigation and compensation
requirements, to a wider concept of sustainable
development among locally affected
communities. This type of sustainable approach
to project development is becoming an
increasingly important aspect of IFC-financed
projects.

Page Thirty
Lessons of Experience | September 2006 | Number 2

CIP Mobilizing Communities in Turkey

If local development is to be sustainable, cooperatives has been strengthened.


there must be capacity locally to manage Although initially villagers were suspicious
and drive such progress. Community about the burdens a cooperative might
Investment Program (CIP) projects have bring, their concerns faded once they
Community
been developed to encourage the experienced the advantages.
involvement of community members to investment
improve their own living conditions. SURKAL An example of the success of the programs do not
and PAR, two CIP Implementing Partners in cooperatives was facilitated by the Kars
guarantee good
north-east Anatolia, have successfully branch of Ataturkcu Dusunce Derneði
inspired villagers to do just that. They have (ADD), a local NGO. ADD requested
community
been through the challenging process of training in project development and relations, but if
bringing people together to identify management to develop projects done right they
solutions, agree responsibilities and make addressing the needs of society,
can help foster
things happen. particularly children, and to give them
access to modern education techniques long-term trust
SURKAL has organized an intra-village thereby generating resources for local and goodwill.
platform so that Village Development development. With training, communities
Councils can discuss their joint problems were able to form new cooperatives. Over
and Council members get to know each time, several agricultural cooperatives
other. The intra-village meetings have also have been awarded significant donations
been used as an opportunity to carry out from the Ministry of Agriculture and Rural
interact and participatory training sessions Affairs totalling nearly US$1.5 million. These
through which Council members came to achievements do not only contribute to
understand the meaning of community the rural development of the affected
development, community organization villages and increase local income levels,
and the importance of participation in but also encourage cooperatives in other
development. project affected villages by showing them
that such community mobilization can
PAR has held community meetings to attract external financial support.
encourage villages to set up their own
cooperatives as a means to progress local
sustainable development. As a result of
PAR's initiative, ten new village
cooperatives have been established Source: Excerpted from the BTC Project Environmental and
Social Quarterly Report (Construction Phase) 2005-Q1.
and the capacity of three existing

Page Thirty-one
Twenty-seven
The Baku-Tbilisi-Ceyhan (BTC) Pipeline Project

Acknowledgements

The BTC Pipeline Project: “Lessons of Experience” is the second in a new publication
Lessons of Experience

series prepared by the Environment and Social Development Department of the IFC for
the purposes of internal learning and knowledge sharing with clients and the wider
private sector. The publication was written by a team of senior specialists comprising
Debra Sequeira (Task Manager), Richard Wyness, and Ted Pollett, and carried out under
the general direction of Rachel Kyte (Director). Patty Miller provided valuable input and
guidance. Vanessa Manuel was responsible for design and layout.

A special acknowledgement is due to the BTC Co. Environmental and Social Team who
shared their knowledge and experiences and provided critical insights from the project
sponsor's perspective.

The authors would also like to thank the following IFC colleagues who reviewed
earlier drafts: Rachel Kyte, Richard Caines, William Bulmer, Felicia Swanson,
Christopher Frankel, and Lucie Giraud.

IFC Good Practice Publications available at:


www.ifc.org/enviropublications

External Monitoring of the Chad-Cameroon


Pipeline Project: Lessons of Experience
“External Monitoring of the Chad-Cameroon Pipeline
Project: Lessons of Experience" provides lenders and
project sponsors with an understanding of the business
case for employing an external monitor, as well practical
advice regarding the major steps and key issues for
designing, implementing, and operating an external
monitoring mechanism for complex projects. To highlight
the practical challenges and value of the external
monitoring mechanism, the publication draws illustrative
examples from the experiences of IFC during the Chad-
Cameroon Pipeline Project.

For more information, please contact: International Finance Corporation,


Environment and Social Development Department, 2121 Pennsylvania Avenue, N.W.,
Washington, D.C. 20433, U.S.A.

Disclaimer

The views expressed in this publication are those of its authors and do not necessarily reflect the views of the wider institution.
Some of the information used in this document may come from publicly available sources such as company websites and
publications. The Lessons of Experience series does not represent a commitment by IFC to require projects it finances to take
certain or all of the actions specified in this publication. Instead, any issues arising in an IFC-financed project will be evaluated
and addressed in the context of the particular circumstances of the project.

Page Thirty-two

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