Turkey: How To Get Environmental Impact Assessment- OpEd


In this article we shall try to explain how to get your Environmental Impact assessment certification for your new thermal power plant investment in a country which is desperately in need of more energy generation.

An Environmental Impact Assessment (EIA) report is a written document of the possible impact—positive or negative—that a proposed project may have on the nearby environment, together consisting of the natural, social and economic aspects, plus populations, fauna, flora, air, soil, water, humans, landscape, cultural heritage.

The purpose of the assessment is to ensure that decision makers consider the ensuing environmental impacts to decide whether to proceed with the project. Our local norms are copied from the current European Union norms in principle, even a bit more flexible. Any new thermal power plant project needs EIA certification for initiation of the investment in our local market. It is certified under the scrutiny and supervision of the EIA general Directorate of Ministry of Environment and Forestry. There is a public regulation for that process.

You should first find a competent environmental engineering company, preferably based in the capital city, with good relations in the respective Ministries, and Public workers, close to the current administration, with many similar references in the past. Those companies are all well known by the sector. You can reach them by simple Google search.

That engineering company normally has sample master EIA document with approximately 200-300 pages, created with copy/ paste method, from various similar sources. They use “replace” mode in “word” software and create a new version for the new thermal power plant investment. In this report, you read local populations, fauna, flora, air, soil, water, humans, landscape, cultural heritage, simply speaking insects, birds and flowers of the subject environment. Then the document starts to describe the thermal power plant in loose format, with general explanations of the technical details with no commitment no binding to any technology now to any supplier. Graphs, drawings, charts are all in primitive format, too simple in appearance, within capability of high school education.

These explanations are so simple and so funny that you will enjoy a lot while reading. Those are written usually by social scientists with non-technical educations, from non-related Internet sources. Many technical terms are false. It is clearly written that the investor does not have any commitment to any supplier nor to any technology, all loose information. There is plenty of talk about local employment opportunities with no firm commitment. In project execution, the investor places the order to the lowest price supplier, mostly to the cheapest Far East company with one third of the world prices as if it is a virtue without caring the technical details, then the plant will be constructed by 2000+ Chinese leaving no employment opportunities to the job hungry locals, whereby it is worse to see that the same plant is operated by foreign workers of the same foreign contractor for the next years.

EIA reports declare that you will create employment for the local people. In the end, the investor creates employment for the foreign workers with the lowest ridicules price declaring Far East company. The cheap price will certainly have lower life time in operation just to pass the guaranteed period of 2-3 years.

All these documents are collected, and shall be submitted to the public authorities. The technical details are not important, so are the company’s financial status, or experience, or past references. The important thing is creating the required documents in full compliance to the regulations. If there is a certified commercial company in application, then it is enough to have certification for competence.

The authority reads and evaluates the EIA report in a certain period of time. Normally they do not read the same wording on birds, insects, and flowers since they have had enough exposure to that rubbish wording so many times in the past. The important thing is to satisfy a higher authority.

Then a “Public information Meeting” is scheduled in the nearest settlement town or village close to the thermal power plant site, serving tea, coffee, and cakes and empty wording, with explanations how wonderful and friendly would be the thermal power plant for the locals. The EIA report is released in the Internet with the possible short period of time, without awakening the local NGOs nor the chambers of engineers, nor environmental organizations.

If those environmental organizations, Chambers of Engineers somehow learn and attend the meeting, and if they declare their objections on the EIA, lack of necessary filtration, lack of enough space for ash dam, inability to conform with deep sea water discharge, danger to underground water for the nearby agricultural activities in one place, danger to the air traffic in the nearby airport landing corridor in another, these objections will be noted with care and said to be evaluated. As in one case, “Public right not to get informed” is noted, or in  the statement “the meeting will be on hold”, enters into the public record.

Then that EIA report is approved, and certified, so EMRA (Energy Markets Regulatory Agency) license is released based on that EIA certification together with many other registration forms already filled in full compliance with the regulation without sound scrutiny of financial status, or capability, or experience or similar references in the past. Public disapproval to the application is so rare.

The investor asks the public administration to expropriate the land they require for the power plant without caring the chosen land covering forest or agricultural activities. That is so easy.

Investors’ consultants will then go to the market for shopping for the cheapest price without caring the quality, appropriate technology. They can not monitor or evaluate the technology since all technical drawings are in the original language of the cheap Far East contractor, only a few English wording appears on the title block of the technical drawings. There is limited, or mostly no access to the technical manuals since they are all in the foreign language of the Foreign Far East company with no intention to make English translations. These cheap Far East originated plants operate for almost 2-3 years just to past the guaranteed period under the full operation with the foreign crew of 500+ foreign contractor/ operator team. Then the failures start in the dust filters, in the safety valves, in the fuel injection burners, then in the coal mills, in the ash disposal systems. Most of the time the plant has no spares since there is no emergency spare-part policy of the contractor. The investor does not request one because they do not know that they will need spare parts in the long run. These are all new for the investor, and spare part list is an unnecessary cost item in the initial cost of the plant in early comparison.

The Thermal Plant starts to pollute the nearby environment, local people react in desperation, in the mean time, the investor generates electricity and sells in the local market with a high market price while polluting the air, sea and the land. Penalties are not deterrent, the plant is never closed due to ever increasing electricity demand f the local market. The plant shut down is temporary. It is normally re-opened in a short period of time after paying the ridiculous penalties.

Coal power plants are operated with a staff of approximately 500 employees, similar output capacity combined cycle power plant works with 50 qualified staff. Local people can only work at the door and just outside of the fence as security personnel.

For how long? Until the time comes for a new political formation which protects the local employment, which restricts the employment of foreign workers, cares the expectations of the local community and responds to the local voters.

There are cheap 135 MWe CFB and 600 MW pulverized Chinese design thermal power plants with lots of construction and operational problems. All technical drawings are in Chinese, so there is no possibility of local workers to operate the plants.

We Mechanical Engineers, are not against the construction of thermal power plants. We are educated to make construction of the thermal power plants in compliance with the technical quality of our local coal. We want to use the maximum local engineering, local design, local resources, local fabrication and local manpower, in compliance with environmental norms and regulation with the least harm to the nearby environment.

We try to design the environmentally friendly equipment to collect maximum amount of dust, ash, NOx, SOx, reduce the noise to lowest level, appropriate and clean deep sea water discharge, collect all ash and bottom ash in ash dams, keep the air clean, stack clean, coal stock area non-polluting.

EIA approvals, environmental controls are too important and should not be left only to the care and regulations of the public agencies. Turkey’s energy policy, should not be “more energy and electricity generation no matter what the cost to the nearby environment” as the public institutions have now been implementing.

Our energy policy should be, “to generate energy and electricity in respectful to the environment, with maximized use of local fuel, with best local design engineering, fabricated with maximized local portion, installed by the local contractors, with local labour, built at environmental appropriate areas”.

We engineers cannot be against the thermal power plants. On the contrary it is engineers’ job to design with the latest engineering and the best capability to meet the firing maximized local coal, to inform and enlighten the society how to reach to that target.

Pulverized coal-fired thermal power plant coal combustion technologies should be abandoned, new clean coal technologies, CFB, IGCC, Oxy-firing, underground gasification systems must be applied. Combined cycle power plants should be designed to have the best sea water plant cooling system, with minimum damage to marine life, with deep sea discharge properly designed, to the sea water temperature. Dust, ash, NOx, SOx emissions should be kept under control. The plant should not be placed in the forest land.

Without energy and electricity production, a society can not develop, can not raise the level of her prosperity. You can not live comfortable life. You can not watch opera, cinema, TV, without electricity. You can not drive on the freeway without traffic lights, you can not live warm, comfortable environment in your home at night. Newspapers can not be printed, Planes can not fly nor land.

More energy production is essential, increase in power production is required. Everybody wants electricity, want more power, but no one wants the thermal power plant in their own backyard, even wind power plants since they make too much noise.

How shall we fix this dilemma? This dilemma will be fixed. Investors will make investments on appropriate design plants in correct place, environmental friendly, employ more local people, with sufficiently big dust filters in operation, designed to deep sea discharge properly. They will not cheat the local people. Plant will not be in the forest land, nor in agricultural neighborhood. All depreciation of the nearby land value will be repaid. A new thermal power plant can be constructed next to an old thermal power plant since the local plant around an old plant is used to the presence of a thermal power plant. They worked there for many years. They accept the investment much faster.

Investors are to pay attention to the environmental issues, care to respond to local engineering and local employment expectations, if they wish to have minimum problem with the locals in the long term operation of the plant. We engineers want all parties to earn money. If the local people can not earn money, while only investor earns money, this is not fair. This one-way happiness can not continue forever. We engineers want all parties to earn money, and the thermal power plant investment should bring wealth to the community and o the investor both. Local NGOs and chambers of engineers should have regulatory and supervisory role for the project at all times.

What happens next after all? If the local people are mostly comprised of highly educated retiree/ pensioner population with sufficient environmental organizations, fully informed of the details of the new investment project, they apply to local courts for cancellation of the investment certificate. Since the EIA report is not so complete, it is weak in content, ill-prepared, with many deficiencies in technology, courts declare cancellation of execution.

However the construction is not ceased. Investor and the constructor continue the site activities. The investor completes the deficiencies and applies to the administration for renewal of the certification and the license. The public office re- issues the certification in time. The investor spends a little more money, without any change in design and details of the equipment at site.

The investor with no care in public relations, continues to make mistakes with applications to courts for compensation of the extra costs. It is funny, but a reality. It there any other similar court case in the world that an investor goes to court to sue a local person who goes to the court to ask real value for the land which is expropriated??

That is poor practice public relations, too absurd, and the initiator pays back unnecessary consequences in the long term at all times, since be sure that nobody gets intimidated.

We engineers would not ride on trains if we were scared of the iron, we would not go to mines if we were scared to get dirty, we would not work on off-shore platforms if we were scared from water. (This is a local saying created in recent years). May God give wisdom to investors for better risk assessment in their thermal power plant investments. Your comments are always welcome.

Haluk Direskeneli

Haluk Direskeneli, is a graduate of METU Mechanical Engineering department (1973). He worked in public, private enterprises, USA Turkish JV companies (B&W, CSWI, AEP, Entergy), in fabrication, basic and detail design, marketing, sales and project management of thermal power plants. He is currently working as freelance consultant/ energy analyst with thermal power plants basic/ detail design software expertise for private engineering companies, investors, universities and research institutions. He is a member of Chamber of Turkish Mechanical Engineers Energy Working Group.

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