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Cablegate: Turkey's Environmental Review Process Needs to Be

This record is a partial extract of the original cable. The full text of the original cable is not available.




E.O.12958: N/A


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.


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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.


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.


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

-- 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


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