Environmental Assessment

T.R.

ISTANBULMETROPOLITANMUNICIPALITY

ISTANBUL MUNICIPAL INFRASTRUCTURE PROJECT (IMIP)

“Closure of

Existing Illegal Waste Sites”

ENVIRONMENTAL ASSESSMENT REPORT

AND MANAGEMENT PLAN

Category B

Prepared By: Aqwadem Consulting

Date: January 31, 2007

TABLE OF CONTENTS

I. BACKGROUND

II.POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

III.ISTANBUL MUNICIPAL INFRASTRUCTURE PROJECT (IMIP) DESCRIPTION

IV.CLOSURE OF EXISTING ILLEGAL WASTE SITES

ANNEX A- Baseline information on the European side Wild Dumps23

ANNEX B - Environmental Management Plan for 40

Closure of Existing Illegal Waste Sites

Istanbul Municipal Infrastructure Project1

Environmental Assessment

I. BACKGROUND

Solid Waste In Turkey : In Turkey, the solid waste management issue is getting more important each year for the last decade, because of the increasing population and changes in lifestyle which give rise to increase in solid waste generation and changes in the composition. TThe increasing waste quantities (from 15 million tonnes in 1991 to 25.0 million tonnes in 2004 and reaching to an anticipated 30 million ton levels in 2010 has become a major environmental concern.

Turkey’s municipal solid waste generally consists of wastes generated from residential and commercial areas, industries, parks and streets, and is not sorted at the source effectively; despite presence of .the recent Packaging Waste Control Regulation (2004) Composting plants have been installed in some cities while in other centers disposal practices vary from landfilling to dumping in quarries, stream and even the sea.

Responsibility related to collection, transportation, sanitary disposal and recovery of solid wastes belongs to municipalities and metropolitan municipalities as per the applicable legislation. The Ministry of Environment and Forestry has the role to regulate the system.

In Turkey, waste management refers to collection, transportation and disposal of the wastes and city street cleaning in most municipalities. Currently, with the exception scavenging, reuse or recycling and sanitary disposal of municipal wastes are not widely used practices.

YEAR / 1994 / 1995 / 1996 / 1997 / 1998 / 2001 / 2002 / 2003 / 2004
Number of municipalities receiving solid waste services / 1,985 / 2,126 / 2,172 / 2,275 / 2,579 / 2,915 / 2,984 / 3,018 / 3,028
Population served (%) / 71 / 72 / 71 / 71 / 72 / 75 / 76 / 77 / 77
Quantity of solid waste collected (1000 tonnes/year) / 17,757 / 20,910 / 22,483 / 24,180 / 24,945 / 25,134 / 25,373 / 26,118 / 25,014
Solid waste generated per capita (kg/capita-day) / 1.10 / 1.27 / 1.37 / 1.48 / 1.51 / 1.35 / 1.34 / 1.38 / 1.31
Number of Regulated landfills / 2 / 6 / 6 / 8 / 8 / 12 / 12 / 15 / 16

Source: State Statistical Institute of Turkey, Environmental Statistics

According to surveys conducted by the State Statistical Institute (SSI), total waste collected by municipalities in Turkey is around 25 million tonnes since 1998. The amount of waste per capita is around 1,34kg/capita-day. These figures correspond to Domestic / municipal waste sourced from:

  • Houses (approx. 80%)
  • Commercial and domestic industrial (approx. 15%)
  • City maintenance wastes (parks, street cleaning, etc.)(approx. 5%)

As far as general situation is concerned, Turkey has a quite effective waste collection and transport system. However the final disposal aspect is deficient. There are only 16 sanitary landfills (SSI, 2004) and mainly in the major municipalities corresponding to 28% of the total municipal waste collected. The landfills with no sanitary conditions have started to create water, air and soil pollution concerns. Wild dumps are also causing risk of landfill gas blasts, fire risks, health problems, easthetic problems, bad odor, etc.

Currently, with the establishment of the unions of municipalities, final disposal has become a major agenda item.

In big municipalities the collection and transportation is made in better conditions comparing to small to mid size municipalities. While standard bins and sanitary compression trucks are used in big municipalities, this is usually in the form of old and open bins and tractors in small municipalities.

Solid Waste Management in Istanbul : Istanbul, whose 2006 population is estimated at about 12.5 million, is the largest city of Turkey and its main center of industrial, financial, service and other economic activities. Administratively, both a State province and a metropolitan municipality, Istanbul covers an area of 5,349 km2 (or only about 0.7% of the surface of Turkey). Yet among all provinces of Turkey, it makes the by far single largest contribution (23%) to the country’s Gross Domestic Product (GDP).

Rapid population increase over the past few decades – essentially owing to the attraction which Istanbul’s expanding labor market exerted on Turkey’s internal migration - has severely taxed the capacity of the Istanbul Metropolitan Municipality (IMM) to deal with urban development problems. One of the biggest problems being to handle the increasing amount of solid waste in an proper and environmentally friendly way. In order to tackle with this situation and alleviate any negative environmental impact IMM has invested on many facilities and infrastructures especially in last decade. These investments include: solid waste sanitary landfills, composting facilities, wastewater treatment plants, cleaning of Haliç bay, medical waste incineration facility and rehabilitation of old solid waste dump sites.

Collection and Transportation: The collection of solid waste is the responsibility of the 32 boroughs and 41 smaller municipalities located within IMM. These local authorities collect the solid waste themselves or have contracts with local private companies to collect the waste. The local authorities also have the responsibility to transport the waste to one of six area transfer stations.

Transfer Stations: IMM is responsible for consolidation and transfer of waste from the individual local authorities. IMM currently maintains six transfer stations (three on the European side of IMM and three on the Asian side). The transfer stations include systems for vehicle weighing, offloading of solid waste collection vehicles, waste compaction into transfer vehicles, and then offsite transport to the area landfills. Waste is consolidated and compacted into 35 m3 waste containers for transport to the landfills. The transfer stations are operated by private contractors. Five additional transfer stations are planned within IMM.

Landfills: IMM currently owns two active solid waste landfills (one on European side of Istanbul and one on Asian side) both constructed in 1994. The landfills currently manage about 13,000 tons per day. The landfills were designed in 1994 by CH2M and consist of a composite liner system (60 cm clay, geomembrane, and then drainage layer). Leachate is collected and receives pretreatment (via aerobic treatment) prior to discharge to the ISKI (the Istanbul Water and Sewerage Department) wastewater collection system. Based on current design and usage, the landfill capacity is expected to last until about 2008 or 2009. Also being considered is an upgrade of the leachate collection system to include membrane treatment technologyis planned to eliminate IMM’s reliance on ISKI. Inclusion of landfill gas collection and energy production is also planned at the landfills. The landfills are not operated by IMM but by ISTAC, the municipal utility that is 99% owned by IMM.

Waste Segregation. IMM does not currently have a formal program for waste segregation of recyclables. ISTAC is currently working with four of the local authorities in implementing source segregation programs for recyclables. ISTAC will be implementing similar programs with 11 other local authorities. Assistance with public education for waste source segregation is a high priority.

Sea Vessel Waste. Under an international treaty, IMM is required to provide solid and liquid waste collection services for the ships navigating through Istanbul. This includes ship-board generated solid waste petroleum residue, bilge water, sewage, sludge, dirty ballast, waste lubricating oil, petroleum contaminated rags, and petroleum sediment. Sea vessel waste collection is conducted by ISTAC. ISTAC currently uses 12 barges to collect the above waste and transport it to a recently completed port waste processing facility in Haydarpasa. Each barge can only store one specific waste type which is an inefficient system. ISTAC is proposing to purchase two additional barges that can handle multiple waste streams. Monitoring for illegal dumping by sea vessels is also performed by ISTAC. They maintain two airplanes for monitoring the ports and seas. It should be noted that the fees for sea vessel waste collection are significantly less than the cost for the service (cost of service is about 4 times fee charges). IMM purposefully charges this lower fee as an incentive to encourage use of their facilities in order to deter illegal dumping.

Industrial Waste. Laws and regulations established by the government currently provide the regulatory framework for the generation, transport and disposal of industrial wastes. This establishes disposal requirements and licensing procedures for generators, transporters, and treatment facilities for industrial wastes. Despite the recent revisions to the Environmental Law of 5491 dated 26/4/2006 does not impose any responsibility regarding building and operation of hazardous waste disposal facilities, currently, IMM plans to take on responsibility for disposal of industrial waste within Istanbul. The individual companies have the responsibility for coordinating transport and disposal of the industrial waste they generate. Licensed private transporters transport industrial waste for disposal. Currently, there are no licensed industrial (hazardous) waste disposal facilities in Istanbul and all industrial hazardous waste is transported to a facility in Kocaeli, Izmit for disposal. It is suspected that the high transportation costs as well as general lack of environmental protection awareness of industrial facilities in Istanbul on waste segregation and disposal has caused improper disposal of industrial waste to be a prevalent practice within the region. IMM estimates that industry generates about 75,000 tons of industrial waste per year in the region, yet the hazardous waste treatment and disposal facility in Izmit has a design capacity to treat only about 35,000 tons per year. IMM indicated that specific investigations into current industrial waste disposal practices by industry are ongoing. Establishing a new and effective industrial waste management program is the highest priority for IMM. This will include construction of a new industrial waste treatment, storage, and disposal (TSD) facility within the IMM service area as well as implementing a training program for industry.

Other wastes include construction and demolition debris, composting materials, medical wastes and industrial wastes. Construction and demolition debris are disposed of separately at the two existing landfills. Medical wastes (about 24 tons per day) are currently disposed at a medical waste incinerator located at the Odayeri landfill. IMM also maintains one composting facility (1,000 tons per day) for disposal of biodegradable wastes. This is also located next to the Odayeri landfill. A new medical waste facility is planned for the Asian side of Istanbul.

Wild (unregulated) dumpsites: Subject of this report, existing wild dumpsites within the boundaries of Istanbul, create a major risk for the environment and people. These dump sites are located in neighboring small municipalities and serving a population around 550,000 people. The amount of generated and wild dumped wastes is estimated to be around 566 tons per day during winter and 862 tons per day during summer.

Environmental Consequences: Proper Solid Waste Management practices are crucial for preventing any harm for environment. Poor implementations yield in water, air and soil pollutions hence jeopardizing the community health as well. In this respect, illegal dumpsites, which are mainly close to water creeks and settlements, are an important source of pollution and risk holder for environment and community health.

II.POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

Although there are many attempts in Turkey to improve the municipal/local solid waste management practices, these efforts are limited to collection, transportation and recently landfill construction and operation. The governments’ efforts are also in this direction. Moreover, they encourage small municipalities and rural settlements to union for a common solid waste management strategy mainly starting with establishment of a sanitary landfill. However, waste minimization efforts are limited such as recycling, composting, etc. On the other hand, another critical deficiency in the current policies is regarding illegal dump sites and wild dumping. Lack of financial and technical capacity, together with poor regulatory environment has yield in wild dumping /illegal dumpsites in most of the municipalities in Turkey. However, the worse is that current improvement policies do not prioritize the rehabilitation of these dumps.

The Metropolitan Municipality Law No.5216, passed on July 23, 2004 expanded the geographical area of IMM from 1,830 km2 to 5,349 km2. The Law also required IMM to prepare both a Metropolitan Strategic Development Plan (Strategic Plan) and an Environmental Plan to reflect the demands of the expanded area identify the corresponding investment needs and explore possible sources of financing. The Strategic and Environmental Plan was completed in July, 2006 and has been approved by the Municipal Council of the MetropolitanMunicipality.

IstanbulMetropolitanMunicipality, is far advanced of the average level of the Turkish municipalities in solid waste management. They have invested and operating sanitary landfills, composting facilities, medical waste facilities, etc. But, they are still beyond a full and proper solid waste management system especially in respect to industrial wastes and rehabilitation of existing wild/illegal dumpsites. Hence, with the recent strategic planning, IMM has put its strong willingness to invest on the deficient components of the solid waste and other environmental management issue.

To address its multiple needs, as well as solid waste management needs, IMM has requested the Bank to assist it in the financing of an investment program, the proposed Istanbul Municipal Infrastructure Project (IMIP). The program would focus in particular on investments addressing priority infrastructure needs for improving environmental management and increasing preparedness for possible natural disasters of seismic origin.

According to the recent Strategic Plan prepared by IMM, the environmental management issues are summarized as follows:

  • It is projected that statutory powers and responsibilities of public administrations will increase in the short and medium run, the increase in cultural investments and socio-cultural development will raise the environment awareness of the people, and as a natural consequence of this, the participations of civil society organizations will increase. Civil society organizations with increased activity will have close and organic cooperation with public organizations. About the same period, it is contemplated that the “polluter pays” principle will be replaced by the principle of “preventing pollution” predominantly. It is expected that rational creation of environmental revenues and the necessity of compliance with EU Directives will positively affect reaching a sustainable urban development performance.
  • It is expected that investments will increase in using clean production technologies and developing renewable energy resources starting mainly from the public agencies.
  • It is inevitable to create an integrated solid waste management system for Istanbul in light of the fact that recycling and regaining has emerged as a significant potential by effective use of environmental resources by way of integrated environmental management, and international trends and expectations of the people.
  • The trend of increasing the share of mass transport aimed at controlling and alleviating the air pollution in Istanbul will be strengthened, and the use of biogas/bio-diesel in municipal mass transport vehicles will be increased. Institutional capacity will be built to control more effectively the industrial air pollutant emissions, and by the institutionalization of inspections and delegating this function to local governments, more efficient and cleaner burning technologies will be spread.
  • The green spots in the city will be transformed into urban green fields, alternative solutions to alleviate the risk of drought will become more important and legal regulations will be created to prevent construction pressure in the water basins. It is highly likely that policies to ensure attainment of EU beach water standards quality will be formulated to prevent pollution in the MarmaraSea and straits.

On the other hand, on national level Turkey’s Ninth National Development Plan (2007-2011) calls for more strategic policymaking and stronger implementation capacity in public administration. The Plan states that comprehensive reforms started in public administration and public financial management should focus on strengthening public confidence in administration, ensuring financial efficiency and the provision of effective municipal services by local governments.

Legislative Framework :Main legislation governing solid waste management in Turkey consists of Environmental Law, Municipal Law, Metropolitan Municipality Law, and Ministry of Environment and Forestry regulation for “Control of Solid Waste” and other relevant regulations.

1)Environment Law (No 2872, Date 9.08.1983): This law describes the framework for protection of the environment, prevention of pollution and provision of sustainable development through environment friendly applications. There are various clauses in this law related wastes :

a)Article 8: For any kind of waste, it is forbidden to dispose them directly or indirectly, to dump, to transport, and etc., in a way to harm environment and in violation of the standards and procedures set by the relevant regulations.

b)Article 9: “ It is forbidden to bring any kind of wastes from other countries as to harm the ecologic system of the country.

c)Article 11: The responsible institutions for treatment, disposal of the waste are obliged to take related precautions for not polluting the environment while performing related services.

The rules and technical procedures for direct or indirect disposal of the wastes to the environment are determined by related regulations.

d)Supervision (Article 12): The supervision of waste treatment, disposal and importing are made by DG Environment. The procedures for the supervision and qualifications required for the supervisors are set by relevant regulations.

2)Municipal Law (Law No: 5393 - Date: 03.07.2005) :

a)Article 14 (Tasks and Responsibilities of Municipalities): Item a) of this Article states that “ Municipalities do directly or outsource the services for urban infrastructure such as settlement, water and sewerage, transportation; geographical and urban information systems; environment and environmental safety/health; cleansing and solid waste; municipal police, fire brigade, emergency aid, rescue and ambulance; in-city traffic; cemetery, forestation and parks, housing; culture and art, tourism and promotion; youth and sports; social services and social aids, wedding, vocational training and skill development; development of local economy and trade. Metropolitan municipalities and municipalities over 50.000 population establish women and children protection shelters.”