DESCRIPTION
The Project involves design, finance, construction, operation, maintenance and repairs of the Antalya – Alanya motorway in Türkiye’s Mediterranean coast (the Project). The motorway is 117.8 km in length with mostly 3 lanes in each direction (2x3). The new proposed motorway will run parallel to the existing toll-free D400 state highway. It will not only provide a faster direct connection between the regions of Antalya and Alanya, but also significantly alleviate the congestion on the state highway, thus improving travel time and road safety for both the residents and the tourists.
Antalya is the fifth most populated city in Türkiye, given its proximity to the Antalya international airport, a major international hub (ranked second in terms of the number of foreign visitors in Türkiye and the third busiest airport in the country). The Antalya province has witnessed a significant increase in foreign tourist arrivals, reaching over 20.6 million (in 2023), making it the fourth most visited city in the world. As such, the location of the Project strategically addresses a need for an efficient motorway in the region, which is experiencing a rapid growth of tourism, both from local and international traffic.
The Sponsor of the Project is Limak Insaat Sanayi ve Ticaret A.S. (Limak Insaat or the Sponsor), the construction arm of Limak Holding. Limak Insaat is the largest contractor in Türkiye and has extensive experience in infrastructure sectors such as highways, bridges, airports, ports, dams and hydroelectric power plants.
The Project was awarded to the Sponsor by the General Directorate of Highways (the KGM or the Authority) under a Build-Operate-Transfer (BOT) model. The Implementation Contract (IC) between the Sponsor and the KGM was signed on October 14, 2024. The concession period is 15 years, which includes 3 years of construction followed by 12 years of operation period, post which the Sponsor shall transfer the motorway back to the KGM free of charge. As per the IC, the Project benefits from Traffic Guarantee Revenue from the KGM, which covers 100,000 automobile equivalent per day. If, at any point throughout the concession period, the actual traffic is less than the guaranteed level, the KGM will guarantee a shortfall of up to 100,000 automobile equivalent per day. The Project benefits from the Debt Assumption Agreement (DAA) from the Turkish Treasury.
ENVIRONMENTAL AND SOCIAL INFORMATION
Applicable Policy and Categorization. The Bank’s Environmental and Social Policy (ESP), including the Environmental and Social Standards (ESSs) and the Environmental and Social Exclusion List (ESEL), will apply to the Project. Based on the Bank’s ESP and the preliminary screening, the proposed Project is categorized as A as it is likely to have significant adverse environmental and social (ES) impacts that are irreversible, cumulative, diverse, or unprecedented. The Project involves the design and construction of approximately 117.8 km (in length) of motorway along with ancillary facilities connecting the Antalya and Alanya regions. ESS1 (Environmental and Social Assessment and Management) and ESS2 (Land Acquisition and Involuntary Resettlement) will apply as the proposed activities will involve major civil works that require the acquisition of land. ESS3 (Indigenous Peoples) will not apply as no Indigenous Peoples will be affected by the Project.
Environmental and Social Instruments. As per Turkish EIA Regulations 2014, the Project Company had prepared an Environmental Impact Assessment (EIA) report that was submitted in 2016, and subsequently, environmental clearance was obtained from the Ministry of Environment, Urban and Climate Change in August 2018. The positive decision of the Ministry is valid, and construction work has been initiated. An ES Due Diligence (ESDD) has been conducted by WSP, an independent international ES consultancy firm. The Borrower is updating the ES Impact Assessment (ESIA) and Non-Technical Summary of the ESIA based on the lender’s requirements. The draft version of the ESIA is supplemented with Resettlement Action Plan (RAP), Stakeholder Engagement Plan (SEP), Biodiversity Action Plan (BAP), Cultural Heritage Management Plan (CHMP) and other Management Plans are under final review stage. A draft ES Action Plan (ESAP) has also been prepared to identify and address identified gaps based on the ESDD conducted by the lender’s independent consultant. The Bank has conducted field-based ES examinations during project preparation as part of the due diligence. A number of qualified resources have already been assigned, and additional resources will be engaged as required to implement the ES Management Plan (ESMP).
Environmental Aspects. The proposed Project is expected to bring environmental benefits by improving traffic flow through a sustainable infrastructure in a high tourism catering region. The motorway alignment will be a new linear infrastructure proposed through natural (forests, wetlands, rivers etc.) and modified habitats such as agricultural lands, urban centers etc. The ancillary components of the Project during construction will be camp sites, batching plants, quarries, material storage areas, etc. The construction activities will involve removal of vegetation, grading of land, stripping of topsoil, earthwork, asphalting, civil constructions, blasting operations at quarries, increased vehicular movements etc. This will lead to potential adverse effects such as habitat destruction, instability in landforms, change in landscape, increase in noise and vibration level, dust emissions, waste generation, and will potentially impact the wildlife and community in and around the construction area. In the operation stage, the key potential adverse impacts anticipated are related to vehicular and dust emissions and an increase in noise levels. In addition, the Project overlaps with a single protected area/internationally recognized area – Antalya Plains KBA/IBA. Baseline field studies have been undertaken through 2024 and 2025 spanning seasons and sampling points (36 chosen for habitat/flora and fauna, and 14 for fishes), located in the area of influence that was defined as a 400 m buffer zone around the proposed motorway route. Critical Habitat Assessment (CHA) identifies maquis habitat as Critical Habitat due to the presence of Pyrus serikensis. Those risks and impacts in the period of construction and operation will be addressed by the implementation of ESMP, ESAP, BAP, and other relevant plans and procedures.
Social and Gender Aspects. The Project is expected to bring positive social impacts to the local population by enhancing road conditions and safety and reducing travel time in a congested area. The main social risks and impacts are associated with land acquisition, physical and economic displacement, informal land use, and livelihood impacts. The total area to be expropriated is approximately 1,560 hectares, of which 53.9% is agricultural land. Further, a total of 304 houses will be relocated, 831 greenhouses, and 37 commercial facilities to be affected. A draft RAP has been prepared to define mitigation, compensation, and livelihood restoration measures according to Bank’s ESS2. Another key risk and potential impact relate to cultural heritage. To date, a total of 55 archaeological cultural heritage resources have been identified through targeted walkovers and desktop reviews, including seven previously recorded sites and 23 newly identified ones within the Project footprint. Robust measures are needed to avoid or minimize impacts, which are being developed in a CHMP. The potential impacts of Project activities on women both in the community and among the Project workforce are being assessed as part of a Gender Action Plan (GAP). In consultation with relevant stakeholders, appropriate measures are being implemented, such as Labor Management Procedures, Community Health and Safety Management Plan and a Code of Conduct with provisions on GBV, to prevent and mitigate potential negative impacts associated with labor influx, including risks of gender-based violence.
Occupational Health and Safety (OHS), Labor and Working Conditions (LWC). The construction of a new motorway will necessitate the engagement of a substantial workforce for a duration of a minimum of three years. The potential OHS risks associated with construction activities are assessed during the preparation of the ESIA. To mitigate these risks, relevant policies and procedures related to OHS, labor standards, and working conditions were reviewed, and necessary mitigation measures are incorporated into the relevant ESMPs. LWC risks and impacts are being and will be managed through the implementation of HR Policy-LMP. The provisions of the HR Policy-LMP will be implemented by the contractor during both the construction and operation phases. Relevant policies and procedures related to OHS, labor standards, and employment conditions will be reviewed, and necessary mitigation measures will be incorporated into the ESMP.
Stakeholder Engagement, Consultation, and Information Disclosure. A draft SEP has been developed to guide meaningful and inclusive engagement with a broad range of stakeholders including project-affected people and the vulnerable groups identified. The SEP outlines the approach, methods and tools that are being used throughout project cycle. Consultations on the updated draft ESIA, ESMPs, and RAP will be carried out during the development of these instruments. The Project’s draft ES package which includes ESIA and its NTS, RAP, Management Plans and ESAP has been disclosed by AIIB and the Project Company on the websites in English and Turkish on July 15, 2025. The final ES documentation will be disclosed as appropriate.
Project Grievance Redress Mechanism (GRM). A multi-tier project-specific GRM has been established to handle complaints and issues. The SEP defines multiple GRM communication channels, including in-person, comment box, email, online, and telephone options. A worker’s GRM is also being established in accordance with ESP’s requirements. The mechanism provides the option for stakeholders to submit complaints anonymously. Dedicated communication materials about the GRM have also been developed in the local language and shared with the communities.
Monitoring and Reporting Arrangement. The Project Company will take responsibility for the overall management of ES risks and impacts associated with activities designed, constructed and operated. The Borrower will be required to prepare the ES monitoring report quarterly during the construction phase, and semiannually during the operational phase, which must be based on the agreed format and submitted to AIIB and other lenders for review. The Borrower has/is recruiting an EHS consultant to supervise and monitor the implementation of the plans and procedures. AIIB will conduct onsite supervision missions as and when applicable in the implementation stage of the project.
