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RELATIONSHIP between WB and NATIONAL REQUIREMENTS ENVIRONMENTAL ASSESSMENT. Esra ARIKAN Environmental Specialist. Overview of the Presentation. SUMMARY OF TURKISH EIA REGULATION OVERVIEW OF ENVIRONMENTAL SAFEGUARDS APPLIED TO WB FINANCED PROJECTS IN TURKEY
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ECA Safeguard Training for PIUs,
Pulp and paper industry with capacity>40.000 tons/year
Pulp and paper industry with capacity<40.000 tons/year
Public Participation Meeting
Evaluation Committee Meeting
The Bank classifies the proposed project into one of four categories, depending on the type, location, sensitivity, and scale of the project and the nature and magnitude of its potential environmental impacts.
1. Category A
2. Category B
3. Category C
4. Category FI
The categorization of the projects based mainly on type and scale of the projects.
There are 2 categories:
Annex I: EIA mandatory
Annex II: EIA preliminary study
(project introduction file)Gaps Between National Systems and WB Requirements
National laws/regulations generally have environmental screening lists focusing on the sector/size of the project but the project location/site sensitivity is only dealt under some headings of the EA document
Screening for WB 4.01
Screening for Turkish EIA
This is very important for the ‘PROPER’ categorization of sub-projects of FI type projects by the PIU/PFI.
PIUs should be guided (through trainings by WB, OMs, etc.) regarding the WB environmental categorization and they have to be encouraged to consult the environmental specialist of the WB team when necessary.
The EMP is an integral part of Category A EAs (irrespective of other instruments used).
For Category B projects there can be either a partial EA or a separate EMP, covering mitigation measures, monitoring, and institutional strengthening;
The format is provided in Annex C of the OP 4.01.
No separate EMP
But, requirement for «follow-up/monitoring program» during and after construction, operation and decommissioning.Gaps Between National Systems and WB Requirements
EMP for WB 4.01
EMP for Turkish EIA
The quality of the PIF documents prepared for Annex II Projects vary among the preparers.
Some PIFs can serve as Category B Partial EA / EMPs but not all of them.
It depends on the scope and level of detail in the PIF. Generally PIFs lack a detailed impact assessment, detailed remedial measures, and monitoring requirements.
The ‘EIA Not Necessary’ decision is not based on risk and complexity of impact (it ignores cumulative impacts). As a consequence the WB would need to require that borrowers follow its approach and fully assess the social and environmental impact of each sub-project, even when this is an incremental task in addition to ensuring compliance with national requirements.Gaps Between National Systems and WB Requirements
OP 4.01 does indicate that for Category B projects a “limited EA” or in some cases a free-standing Environmental Management Plan (EMP) may be prepared.
Under Turkish law a Project Introduction File (PIF): is required for all Annex II projects as the basis for determining whether an EIA is required.
Preparation of an EMP rather than / in addition to an EIA - since the EIA is usually required by country system
PIUs should be guided with sample EMPs and it should be explained that when a nationally cleared EA is ready, the work is just to summarize the key points in an EMP, which will act as a handbook both for the contractor for implementing and the PIU for monitoring.
When EIA is prepared according to the Turkish EIA Regulation in many cases it does not encompass all the project activities
(example: EIA for HEPP but the access roads, material borrow sites are not taken into consideration)
Suggestion: Although the national regulations are not covering the auxiliary components of the projects PIU should guide the sub-borrower during the scoping phase of the EA document which will be prepared for WB projects
Alternative Analysis has a narrower scope in Turkish EIA
In Turkish EIAs mostly technology alternatives are provided (briefly) and location alternatives are not detailed.
An executive summary is required which can be categorized as a non-technical summary as in EU requirements.
The EIA report requires a conclusion to be made which cannot be evaluated as an executive summary.Gaps Between National Systems and WB Requirements
Differences in the general outline or table of contents
Executive Summary for WB 4.01
Executive Summary for Turkish EIA
Conducting public participation meetings (generally 2 meetings for Category A’s and 1 for Category B’s) - since the country systems mostly have less public participation requirements
Public Consultation Outputs in a Natural Gas Storage Project In Turkey
Turkish disclosure requirements also differ from WB operational policies.
Requirements for EIA Preparers
EIA Not Necessary
QUESTIONS ?? COMMENTS??