US embassy cable - 03ANKARA3937

UNCLAS SECTION 01 OF 02 ANKARA 003937 
 
SIPDIS 
 
 
STATE FOR EUR/SE, EUR/PGI, OES/PCI 
PLEASE PASS EPA/OIA (HHUYNH, WFREEMAN) 
 
 
E.O.12958: N/A 
TAGS: SENV, TU 
SUBJECT: TURKEY'S ENVIRONMENTAL REVIEW PROCESS NEEDS TO BE 
STRENGTHENED 
 
 
REF. ANKARA 2712 
 
 
1.  Summary. Even though Turkey's environmental laws are 
written to produce environmentally sound economic 
development, regulations fall short of providing the uniform 
standards and technical criteria for preparing environmental 
impact assessments (EIAs). The government's technical staff 
is insufficiently trained to assess EIAs and developers seek 
to circumvent the process.  As a result, many facilities in 
Turkey are constructed without a professional environmental 
review.  Turkey needs to strengthen its EIA infrastructure 
to foster sustainable economic development. End summary. 
 
 
2.  Since 1993, the Ministry of Environment (now Ministry of 
Environment and Forestry (MOEF)) has reviewed 815 EIAs. 
Only 20 have been rejected. Turkey updated its 1993 EIA 
regulations in 1997 and then again in 2002 but the new 
regulations do not provide sufficient guidance for 
professionals to produce effective EIAs, according to 
several professional engineers who write EIAs. 
 
 
CONCERNS WITH EIA REGULATIONS 
----------------------------- 
 
 
3.  The biggest flaw in the regulations, according to a 
consulting engineer from ENCON, is that the regulations 
include no guidelines, review criteria or technical 
specifications for EIA preparation.  This makes EIA 
approvals arbitrary and subject to corruption.  The 
regulations diminish the EIA process, equating it with a 
common permit-issuing system.  Most importantly, they do not 
allow an EIA to focus on its intended goals -- identifying 
and mitigating potential negative environmental impacts. 
 
 
4.  Environmental engineers identified many other concerns 
with existing regulations: 
 
 
-- Double standards seem to apply, as only projects that 
receive international funding require a second environmental 
review (by the international funder). Locally funded 
projects are reviewed only by the MOEF. 
 
 
-- The regulations are fraught with exemptions for favored 
industries and projects.  Among the favored are floating and 
mobile power plants and oil and mineral exploration.  In 
protest, the Chamber of Environmental Engineers filed nearly 
a dozen legal suits in the past two years targeting each 
type of exemption. 
 
 
-- Time allotted for public discussion is limited to what 
another consulting engineer referred to as "an impossible 30 
work days."  Public discussion on large public works 
projects (pipelines, power plants) can require up to six 
months for adequate public review and discussion. 
 
 
-- The regulations require the MOEF, headquartered in 
Ankara, to audit EIAs.  To former consultant to Parliament's 
Environment Commission Nuran Talu, the absence of on-site 
auditing forces an unhealthy reliance on written reports and 
detracts from the effectiveness of the EIA process. 
 
 
-- The regulations include no provision for the government 
to fortify its central human resource pool. The level of 
expertise varies dramatically among provincial experts who 
are also required to review EIAs. The head of an 
environmental consulting firm said he spends a good chunk of 
his time teaching EIA reviewers and government officials 
about what to look for in an EIA review. 
 
 
5.  Since project owners must finance their EIAs, many seek 
to circumvent what they consider a burdensome, non- 
productive barrier that can delay a project by a year and 
cost tens of thousands of dollars.  This obviates the 
government's ability to review environmental impact and 
implement planned development.  When combined with a large 
number of projects legally exempt from EIA preparation, 
projects completed without EIAs further frustrate progress 
towards sustainable economic development. 
 
 
WHAT'S NEXT 
----------- 
 
 
6.  Turkey is moving towards requiring an even more 
demanding version of the EIA, the Strategic Environmental 
Assessment (SEA).  Turkish engineers expressed concern that 
their lawmakers do not fully comprehend the burden of the 
stringent requirements, the breadth of the SEA, or the 
expertise required to administer the program effectively. 
SEAs require a very geographically broad review of an 
expanded array of potential impacts.  If Turkey cannot 
adequately manage its existing EIA responsibilities, 
effective implementation of SEA requirements is doubtful, 
one engineer commented.  However, Turkey was not among the 
35 countries that signed the SEA protocol at the Kiev 
Environment for Europe Ministerial last month. 
 
 
THE U.S CONNECTION 
------------------ 
 
 
7.  Three of Turkey's hottest EIAs under current 
consideration involve or could involve U.S. companies. 
 
 
-- Yusufeli Dam.  The Yusufeli Dam is one of 10 projects on 
the Coruh River on the eastern Black Sea coast.  The 
efficient operation of all projects is dependent on 
Yusufeli's future energy generation. France, Spain, Belgium 
and Britain had considered funding the project, then 
declined.  U.S. companies may be approached to provide 
funding. 
 
 
-- Hydropower Plants.  Alparslan-II and Durak are two BOT 
hydropower plants that were awarded to consortia that 
include Harza Engineering, a U.S. company.  No EIA has yet 
been prepared for either project. 
 
 
-- BTC.  Although the EIA process for the BTC pipeline was 
completed and construction began in April 2003, 
consultations continue. 
 
 
8.  COMMENT.  Turkey's most vexing environmental issues 
arise from uncontrolled development and urbanization. 
Heeding the advice of environmental engineers and other 
concerned professionals -- to strengthen the EIA 
infrastructure further -- could fortify Turkey's ability to 
achieve sustainable economic development 
 
 
PEARSON