Impact Assessment and Project Appraisal

ISSN: 1461-5517 (Print) 1471-5465 (Online) Journal homepage: https://www.tandfonline.com/loi/tiap20

Environmental impact assessment in Turkey:

capacity building for European Union accession

Sally E. R. Innanen

To cite this article: Sally E. R. Innanen (2004) Environmental impact assessment in Turkey:
capacity building for European Union accession, Impact Assessment and Project Appraisal, 22:2,
141-151, DOI: 10.3152/147154604781765987

To link to this article: https://doi.org/10.3152/147154604781765987

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Impact Assessment and Project Appraisal, volume 22, number 2, June 2004, pages 141–151, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK
Turkey
Environmental impact assessment in Turkey:
capacity building for European Union accession
Sally E R Innanen
This article analyses the environmental impact
assessment (EIA) system in Turkey with refer-
ence to the outcomes of a capacity-building pro-
ject aimed to assist the implementation of the
European Union EIA regulations. It discusses
key challenges facing EIA in Turkey, and practi-
cal recommendations on streamlining and par-
tially decentralising the EIA procedures to
increase their effectiveness. The main problems
with EIA in Turkey include insufficient capacity
of environmental authorities at national and
provincial levels; weaknesses in the system of
public participation, the review process and the
set-up of the EIA Scope Determination, Inspec-
tion and Evaluation Commission; and problems
with the quality of EIA reports.
Keywords: capacity building, EIA, SEA, Turkey, EU
accession, EU legislation
Sally E R Innanen is with DHV Water BV, Consultants Depart-
ment, Laan 1914 nr 35, 3818 EX, Amersfoort, The Netherlands,
Tel: +31-33 468 2589; Fax: +31 33 468 3945; E-mail: sally.
innanen@dhv.nl; Website: www.dhv.nl.
The author is grateful to her fellow team members from DHV
(Netherlands), R&R Bilimsel ve Teknik Hizmetler (Turkey) and
the Regional Environment Centre (REC), and her Ministry of
Environment and Forestry colleagues in Ankara for their co-
operation. She also thanks ENCON Environmental Consultancy,
Ankara, and Dr Aleg Cherp for feedback. The views expressed
or possible errors are the sole responsibility of the author.
Impact Assessment and Project Appraisal June 2004
T
URKEY FACES DIVERSE environmental
problems, including water pollution from
dumping of chemicals and detergents; air pol-
lution, particularly in urban areas; deforestation, and
oil spills from the increasing Bosphorus ship traffic.
Many of these concerns relate to the country’s stra-
tegic location: bordered by the Black, Mediterranean
and Aegean Seas, Turkey has thousands of kilome-
tres of coastline and a beautiful interior containing
numerous archaeological and World Heritage sites.
Turkey is currently experiencing a rapidly growing
tourist industry. Of particular concern, therefore, is
the environmental well-being of the coastlines and
protected areas.
Turkey has an official national policy goal to
accede to the European Union (EU) in the next few
years (EC, 2001d). In the meantime, it must harmo-
nise all its laws with the EU. Because of their hori-
zontal (that is. cross-sectoral and cross-media)
nature, the EU Environmental Impact Assessment
(EIA) Directives are among the most important ele-
ments of the environmental acquis.1 Turkish EIA
law must meet the requirements of these Directives,
and be shown to be functioning effectively, as part
of the prerequisites to join the EU.
The purpose of the project, entitled “Approxima-
tion and implementation of the EIA Directive in
Turkey”, was to assist the Ministry of Environment
and Forestry (MoEF) in more effective implementa-
tion of its EIA legislation, in accordance with the
EU Directives. The project, funded by Senter Inter-
national, an agent of the Ministry of Economic
Affairs of The Netherlands, was carried out between
January 2002 and May 2003. The project aimed to
achieve four results, and included a number of
activities as described below.
1461-5517/04/020141-11 US$08.00  IAIA 2004 141
EIA in Turkey: capacity building for EU accession
Result 1 (Training) involved providing up-to-date
knowledge on the foundations, methodology and the
role of EIA to the MoEF and other stakeholders. The
training focused on EIA and strategic environmental
assessment (SEA) methods and on integration of
EIA and SEA into planning and policy development
and implementation. The training programme was
based on outcomes of an assessment of training
needs and implemented as a series of interactive
training seminars for the MoEF, other ministries and
agencies, non-governmental organisations (NGOs),
provincial Environment Boards, and the private sec-
tor in Ankara and other selected cities.
To achieve this result, an evaluation of EIA
processes in Turkey was carried out, together with an
evaluation of a number of past EIA reports to assess
their merits and the need for improvement. Identifi-
cation of stakeholders in EIA and the establishment
of an inter-departmental EIA working group to
target co-operation and cohesion among the different
players in EIA, and to be involved in project imple-
mentation, evaluation and monitoring, were also
undertaken. A study tour to The Netherlands for
relevant staff from the MoEF was arranged to intro-
duce Dutch methodologies and to visit such institu-
tions as the Dutch/International EIA Commission.
Result 2 (Handbook and Guideline Development)
was formulated in response to the previously ob-
served lack of sectoral EIA guidelines in Turkey (see,
for instance, METAP and University of Manchester
2001). The project resulted in producing a general
procedural and methodological handbook on EIA and
three sectoral guidelines (addressing highways, haz-
ardous waste and harbours). All these documents
were prepared in consultations with the departments
within the General Directorate on EIA and Planning.
Result 3 (Pilot Project Execution) involved
facilitating effective co-operation among different
governmental parties with regard to EIA. To demon-
strate ‘good practice’ examples of such co-operation
and strengthen the MoEF’s capacities in practical
execution of EIA, two pilot projects (one addressing
EIA, the other SEA) were carried out in different cit-
ies. One of these (EIA) was for a medical waste dis-
posal facility in Ankara, while the other (SEA)
involved development in three sectors (tourism, ag-
riculture and energy) in the town of Canakkale on
the west coast of Turkey.
Result 4 (Awareness Raising) involved achieving a
better understanding of the importance of EIA in three
particular sectors: the business community, NGOs and
the general public. This meant training for promotion
of public awareness and participation, and dissemina-
tion of the project information. In particular, partici-
pants learned how to develop a communications
strategy and how to make effective use of the media.
It should be noted that, at present, Turkey has no
formal SEA provisions; however, the development of
SEA legislation was underway at the time of writing.
While SEA training and a pilot SEA did take place
in the context of the Senter-funded project, it was
142
decided to keep the main focus on EIA in the con-
text of this project and undertake a specific SEA-
focused project in the future.
The author’s work in the context of this project
has provided the basis for this paper. The informa-
tion was collected during numerous interviews with
EIA officials, practitioners and participants, review-
ing EIA documentation and observing implementa-
tion of the pilot projects. The paper consists of four
main parts. First, a brief history of EIA in Turkey is
provided. A detailed description of the current EIA
system is followed by a description of EIA practice.
Finally, recommendations for further development
of the EIA system in Turkey, and conclusions, are
presented.
A history of EIA in Turkey
In Turkey, as in many other countries, awareness
about environmental issues significantly increased in
the 1970s. As a result, at that time, the main envi-
ronmental issues were identified, some framework
environmental policies drawn up and administrative
structures to implement these policies established.
The 1983 Environment Act (Ministry of Envi-
ronment no 2872, 1983) is Turkey’s first framework
environmental legislation. It is based on the ‘polluter
pays’ and ‘user pays’ principles and handles the en-
vironment holistically and in rather broad terms. It
continues to provide a legal framework for many
regulations scattered throughout Turkish legislation
that seek to clarify and elaborate its intentions, in-
cluding that for EIA. The aim of the Law is not only
to prevent and eliminate environmental pollution,
but also to ensure management of natural and his-
toric assets and the land in such a way as to utilise
its richness and preserve it for future generations
(after Yilmaz et al, 2002; World Bank, 2002).
Before the establishment of the national environ-
mental authority, a General Directorate of Environ-
ment was designated under the Prime Ministry in
1978. In 1991, this organisation was reorganised as
the Ministry of Environment (MoE). In 2003, the
MoE was amalgamated with the Ministry of Forestry
In Turkey, awareness about
environmental issues significantly
increased in the 1970s: at that time,
the main environmental issues were
identified, some framework
environmental policies drawn up and
administrative structures to
implement them established
Impact Assessment and Project Appraisal June 2004
 EIA in Turkey: capacity building for EU accession

to form what is now the Ministry of Environment Table 2. Overview of EIA reports prepared in the period
1993–2001
and Forestry. The former MoE and the present
MoEF have been responsible for the formulation of
policy, strategies and standards on pollution preven- Sector Number of EIA reports
tion and environmental protection.
The EU EIA Directive (85/337/EEC) was issued on Approved Rejected
3 July 1985 and amended by Council Directive 97/
Industry 108 2
11/EC (14 March 1997) and Council Directive 2003/ Energy 54 1
35/EC (25 June 2003). Deadlines for transposition Mining and petroleum 208 9
were 3 July 1988, 14 March 1999 and 25 June 2005 Waste and chemicals 62 0
Agriculture and food 35 0
respectively for each Member State. The National Transportation and coastal structure 40 2
Programme for Adoption of the Acquis (NPAA) for Tourism 94 2
Turkey formally states that the adoption of the EU Di- Total 614 16
rectives for EIA is a national priority (EC, 2001d). Source: Senter International (2001)
In Turkey, the EIA Regulation was drafted by the
former MoE based on US and EU procedures and
enacted on 7 February 1993 (Official Gazette, 1993; fully harmonised with the EU EIA Directives, ex-
George, 2000; Ahmad and Wood, 2002). This was cept for issues related to transboundary EIA (article
the first piece of EIA legislation in Turkey, although 7, Directive 97/11/EC). Although it has been a
the practice of EIA had begun in a somewhat less member of the United Nations Economic Commis-
formal manner in 1992 at the former MoE (MoEF, sion for Europe (UNECE) since 1947, Turkey has
personal communication). This legislation was neither signed nor ratified the Espoo or Aarhus
amended on 23 June 1997 (Official Gazette, 1997). Conventions. Especially with regard to the Espoo
It had been planned that the Government of Tur- Convention, given the tensions that exist in the re-
key would complete the adoption of the EU Direc- gion, full implementation of the requirements of a
tive for EIA by the end of 2001 by enacting a transboundary environmental agreement would not
revised EIA regulation. In practice, this adoption be fully feasible at this time.
occurred on 6 June 2002 (Official Gazette, 2002). Table 1 demonstrates that the compatibility be-
Because of some practical problems, especially as tween the EU and Turkish EIA provisions has sig-
regards the length of the review period provided for nificantly increased between 1997 and 2003. Table 2
the Scope Determination, Inspection and Evaluation provides an overview of EIA reports produced be-
Commission, the 2002 Regulation was further re- tween 1993 and 2001 in Turkey (Senter International,
vised on 16 December 2003 (Official Gazette, 2003). 2001). In comparison to numbers of EIAs executed
This version remains in force at the time of writing. per year in other countries (Wood et al (1996),
At present, in its wording, the 2003 Regulation is Cherp, 1999), these numbers are fairly small. As of

Table 1. Overview of Turkish EIA legislation as compared to key EU EIA requirements

EU legislative requirements 1997 regulation 2003 regulation

EIA is mandatory for all projects listed in Annex I of the Directive Yes Yes
For those projects listed in Annex II, the Annex III selection criteria must be used to determine No Yes
whether or not an EIA is required
Member States may decide which Annex II projects are to be subject to EIA either on a case-by- Yes Yes
case basis and/or by setting thresholds or criteria
The competent authority must make available to the public the decision on whether an Annex II No Yes
project shall be subject to an EIA or not
The developer must provide relevant Annex IV information to the competent authority: this must Yes Yes
include information on alternatives considered and the main reasons for their choice
A public consultation process must be established and the results of any consultation must be Yes Yes
taken into account by the competent authority in deciding whether to grant development
consent
There is a requirement to consult with other Member States if the proposed project may have No No
transboundary impacts (the provisions of the Espoo Convention)
The competent authority must make available to the public the following: applications for Partial Yes
development consent and other information within a reasonable time to give them an
opportunity to express an opinion before development consent is granted; the content of their
decision and any conditions attached; the main reasons and considerations on which the
decision was based; a description, where necessary, of the main measures to limit the
environmental impacts of the development
Amendments to the EIA Directive intended to implement the provisions of the Aarhus Convention, No Partial
which has been ratified by the Community
Strengthens the rights of public involvement in the decision-making process; also extends public Partial Partial
participation procedures into a series of environmental directives under which plans or
programmes must be drawn up

Source: After Yilmaz et al (2002)

Impact Assessment and Project Appraisal June 2004 143

EIA in Turkey: capacity building for EU accession

the beginning of 2004, over 900 EIAs have been car-
ried out in Turkey (MoEF, personal communica-
tion). The vast majority of EIAs are undertaken in
the western, more affluent provinces of the country,
and the economic situation has likely not allowed for
full implementation of EIA legislation in all areas.
Present EIA process in Turkey
The flowchart in Figure 1 illustrates the current
(after 16 December 2003) EIA process in Turkey.
For projects with major environmental impacts
and national significance, the MoEF, through its

Application made by
Resubmission
developer

MoEF decision as to whether Editing and correction by the

application is appropriate developer
3 NO
business YES
days
Commission formed with
appropriate specialists
MoEF sends copies of report
for each member of
Commission
Public participation and other
dates and times set
Possible site inspection by
12 Commission
business
days
Advertisement for public
hearing placed

Public hearing held

Commission Meeting 1:
Scoping
Format valid 1
EIA report writing year; possible
6-month
postponement
Submission of EIA report to
3 MoEF
business
day
checking
period NO
Checking by MoEF for
Editing and corrections OR Void
adequacy and completeness

YES

Copies mailed to Commission

with invitation to next meeting

Public viewing of EIA report

(Unspecified)
period to
Submission of views from
submit views public in writing and
and examine examination by Commission Commission Meeting 2: Commission work
report of report examination of report: stops until report
complete? NO complete
10 business YES
day period
for review by
Commission Review completed based on
five parameters

5 business
day period Corrections based on review
for and resubmission by
corrections
developer. On time? NO
by
developer
YES
5 business days
EIA positive order EIA negative order

Figure 1. EIA process in Turkey as of 16 December 2003

144 Impact Assessment and Project Appraisal June 2004


General Directorate of EIA and Planning (reporting
to a deputy undersecretary) and its local organisa-
tions, is responsible for co-ordinating EIA matters
and related matters of permission with other gov-
ernment agencies, particularly the Ministry of
Health, Ministry of Agriculture and Village Works,
Ministry of Tourism and so on, as well as provincial
governors. The MoEF is also the responsible body
for examination of Annex II activities that have ex-
pected impacts of a more minor nature.
It is notable that the 1997 Regulation includes a
requirement for certification of consultants; this has
been removed in a temporary amendment, but may
eventually be re-introduced (METAP/Manchester
University, 2001).
Screening
In Turkey, a two-stage screening mechanism is in
place (also see Ahmad and Wood, 2002). If the activ-
ity was planned before 1993 (the date of the initiation
of the formal EIA process), it is unnecessary to pre-
pare an EIA (Official Gazette, 2003, temporary article
3). Further screening is guided by lists of activities in-
cluded in Annexes I and II to the 2003 EIA Regula-
tion, as well as by the criteria specified in Annex IV.
Note that Annex I and Annex II of the Regulation are
reflective of Annexes I and II of Directive 97/11/EC,
respectively. Annex I projects listed in the Regulation
require a full EIA regardless of circumstances, while
listed Annex II projects may or may not require full
EIA, as explained below.
During the screening process, the MoEF makes a
decision on whether or not an EIA is required for a
given Annex II project. This may happen when the
MoEF receives notification of the intention to sub-
mit a development consent application, or the devel-
oper may make an application for a screening
opinion (in fact a decision), which must be recorded
and made public. The screening process is as
follows:
• if the project is listed in Annex I of the EIA Regu-
lation, it requires an EIA, and the MoEF will be
the Competent Authority;
• if the project is listed in Annex II, the MoEF
decides on a case-by-case basis whether an EIA is
required, based on several “selection and elimina-
tion” criteria stipulated in Annex IV of the Regu-
lation. There is an ongoing discussion on whether
to return this responsibility to the provincial Envi-
ronment Boards, which have held it in the past.
Annex IV includes requirements for descriptions
of the site itself, the nature of the project, the po-
tential impacts on the environment, and the poten-
tial alternatives. Annex V, a listing of areas
classified as “sensitive” in Turkey, must also be
taken into account in the screening process.
Preparing such descriptions is referred to as a
preliminary EIA report (‘pre-EIA’); and
• if it is in neither Annex, no EIA is required.
Impact Assessment and Project Appraisal June 2004
EIA in Turkey: capacity building for EU accession
A central role is played by a Scope Determination,
Inspection and Evaluation Commission, formed by
the MoEF (Official Gazette, 2003, article 3) sepa-
rately for each case and involving representatives of
related institutions and organisations, MoEF offi-
cials, the developer and/or its representatives as ap-
propriate (hereafter referred to as “the Commission”).
The Commission may also include representatives of
the scientific community or other specialists that the
MoEF views as necessary to review the EIA report
accurately. These participants must be authorised to
give an opinion on behalf of their organisation and
act as expert witnesses. Chairing and secretarial
functions for the Commission are the responsibilities
of the MoEF. The full EIA process includes five
principal stages: application, scoping, reporting, re-
viewing and decision-making, as outlined in more
detail below and summarised in Figure 1.
Without a positive opinion from the MoEF, no
permits or licenses can be issued or obtained by a
proponent. The approval of the EIA report amounts
to granting a licence from an environmental view-
point to the developer of the project, and this is one
of many licences that a developer requires in Tur-
key. Upwards of 30 permits have been known to be
required for development consent (MoEF, personal
communication). However, paradoxically, many
projects are constructed before the consent decision
is officially made. Given the current economic cli-
mate in Turkey, this practice may be viewed as un-
derstandable to some degree.
Application
The developer files an application to execute the pro-
ject according to the format specified in Annex III of
the EIA Regulation of 2003. The application should
include general information on the project location,
the nature of the project, environmental baseline
characteristics, expected significant environmental
impacts, proposed methods for public participation,
a non-technical summary, and various attachments.
The MoEF examines this application and decides
whether it is complete. It has the right to return any
inappropriately prepared applications to the devel-
oper, who may then resubmit it after revision.
If the MoEF decides that the application is prop-
erly prepared, it forms a Commission and sends its
members copies of the application along with an
invitation to the first meeting of the Commission.
Invitations are also sent for the public participation
meeting at this time.
If either before or after the completion of the EIA
the proposed project is found to violate applicable
legislation, the MoEF issues an official statement
and informs the developer that this is the case. In
case the EIA report has already been submitted, the
MoEF issues an EIA negative order.
A public participation meeting is held to obtain the
views of interested parties regarding the project. The
Commission inspects the project site and its members
145
EIA in Turkey: capacity building for EU accession
or assigned experts attend the meeting. Any costs in-
curred for these purposes are paid by the developer.
The location of the public participation meeting must
be convenient for interested parties and is assigned by
the developer and the provincial governor’s office
working together. The developer advertises the inten-
tion to hold such a meeting in advance through a
national newspaper, with a clear indication of date,
place, time and subject of the meeting.
The meeting must give a clear indication of the
precise construction, operation, closure and related
activities that will occur during project implementa-
tion and must give ample opportunity for the public
to react; furthermore, the statements made by the
public must be recorded. Views in writing may be
requested from the public, and minutes of the meet-
ing must be sent to the MoEF, with a copy remain-
ing at the provincial governor’s office. The public’s
views must be taken into account during the scoping
and review/assessment phase. Secretarial functions
are performed by the involved provincial Environ-
ment Board.
Scoping
Scoping is the responsibility of the Commission. It is
performed in the first meeting of the Commission,
taking into account the inputs from the public con-
sultation meeting. During this meeting, the signifi-
cant environmental impacts to be addressed are
identified and the specific contents to be included in
the terms of reference (referred to as the “special
format”) are determined. The Commission also
decides what additional expertise will be necessary
in the preparation of the EIA report. The MoEF
communicates this information to the developer.
The special format prescribed for the particular pro-
ject is valid for one year. If the EIA report is not sub-
mitted within this period, the application is deemed
void unless an additional period of up to six months is
granted (if the appropriate request is submitted by the
developer and is deemed to be appropriate).
Reporting
The EIA report is submitted by the developer to the
MoEF, which then checks as to whether the report is
properly prepared according to the required format.
If it is found that the EIA report is not properly pre-
pared, a period for corrections of up to three months
may be assigned; after this, the project will be de-
clared void.
If the EIA report is in compliance with the format,
it is copied for each member of the Commission, and
mailed with an invitation to the next meeting for the
examination of the EIA report.
Reviewing
The MoEF and the provincial Environment Board in
question then notify the public through an appropriate
146
medium that the EIA report review is occurring, and
that the report is available for public scrutiny. Any
interested party may view the document at either the
MoEF or at the Provincial Environment Directorate
and submit his/her views in writing to either author-
ity within the review period.
The Commission examines the EIA report. At the
second Commission meeting, the members must
express their views on behalf of the organisation
they represent. The Commission chair may ask for
these views in writing. The Commission may ask the
developer for detailed information on what meas-
urements and analyses were performed, and, in case
of doubt, the project site may be visited, samples re-
taken, or other expert advice sought. All expenses
for the work of the Commission are paid by the de-
veloper.
If there are major elements lacking in the report,
the work of the Commission will cease until these
elements have been added. Meetings with the Com-
mission resume as necessary when the report is
complete.
The EIA report is reviewed from five perspectives
(Official Gazette, 2003, article 12):
• whether the report as a whole and its attachments
are appropriate and correct;
• whether the scientific calculations and analyses
are correctly and appropriately executed, and
based on appropriate information and reports;
• whether the possible impacts are thoroughly as-
sessed;
• whether mitigating measures have been taken up
to minimise environmental impacts; and
• whether adequate public consultations have been
held and public inputs have been taken into ac-
count properly.
The report on the review process is prepared and
signed by the Commission members.
The developer then corrects the EIA report, taking
into account the findings of the review meetings and
resubmits it. In addition, the developer submits a
signed document stating that the final EIA report
and annexes are his/her responsibility, along with a
The EIA report must be appropriate
and correct; the scientific calculations
correctly and appropriately executed;
the possible impacts thoroughly
assessed; mitigating measures taken
up to minimise environmental
impacts; and adequate public
consultations must have been held
Impact Assessment and Project Appraisal June 2004

notarised circular of signatures. If these items are not
submitted by the specified time, the order EIA nega-
tive is given.
Decision-making
The MoEF takes into account all the studies brought
forth by the project and the history of the meetings
during the process, and issues an EIA positive or an
EIA negative order. It notifies the developer, the
concerned provincial Environment Board and other
parties. The provincial Environment Board an-
nounces the decision through appropriate media to
the concerned public.
If an accepted project is not initiated within a
five-year period, the positive order is deemed null
and void. If all the aspects in the project design that
contributed to the EIA negative order are changed,
the developer may submit a new application. The
MoEF decision is final and no appeals may be made
(Ahmad and Wood, 2002).
Problems facing the EIA system
This section outlines the problems facing the Turk-
ish EIA system from the perspectives of an inter-
national aid agency (Senter International, acting on
behalf the Dutch Ministry of Economic Affairs) and
EIA experts and practitioners from Turkey (from the
MoEF and the private sector). These problems are
considered both pre- and post-implementation of the
capacity-building project implemented by Senter
International.
Perspective of an international aid agency
The terms of reference for the project (Senter Inter-
national, 2001) listed a number of obstacles to effec-
tive implementation of the EU EIA Directive in
Turkey. First, these included “insufficient experience
and expertise in the MoE(F)”and at the provincial
Environment Boards, which also lacked “competence
in terms of administrative and technical expertise”.
The lists of projects subject to EIA and preliminary
EIA needed to be “adjusted in accordance with An-
nexes I and II of the Directive”. Similarly, the system
of public participation at all steps of the EIA process
needed to be strengthened by improving the required
administrative procedures.
The quality of EIA reports was often insufficient.
The EIA reports and development projects fre-
quently lacked adequate institutional and legal fol-
low-up in terms of enforcement of environmental
regulations and monitoring, and, once the EIA report
was completed, its findings were sometimes ignored
in project execution. Occasionally an EIA was
prepared after completion of a project.
The EIA review process was often of little value
as a result of lack of skills and appropriate guide-
lines. A Commission was, and is, often composed of
Impact Assessment and Project Appraisal June 2004
EIA in Turkey: capacity building for EU accession
20 or more people, one of which is the developer;
this group size makes consensus and decision-
making challenging. Moreover, the Commission is
only able to say ‘yes’ or ‘no’ to an EIA, but cannot
revise the environmental standards or conditions re-
quired for updating a specific EIA.
The EIA system also suffered as a result of a lack
of supplementary documents, including general and
sectoral guidelines. EIA effectiveness was further
compromised by the lack of integration of the EIA
system with the land-use and sectoral planning sys-
tem and poor inter- and intra- (within MoEF) minis-
terial co-ordination.
In spite of broad-based training aimed at more
than 500 people from various sectors and levels of
government throughout the project, the problems re-
lating to lack of more advanced knowledge of EIA
methodologies by the MoEF expert staff, as well as
technical and administrative expertise at the provin-
cial Environment Board level, remain. The system of
public participation through the required steps in the
EIA process should be strengthened still further. In
addition, the quality of EIA reports is not always
sufficient and the quality of the review phase should
be improved through the provision of guidelines.2
Perspective of Turkish EIA experts
When the Senter project consultants questioned a
group of experts from the MoEF, they generally
agreed with the issues identified above, with one
rather outstanding exception: the experts did not
view themselves as being inexperienced with EIA.
Many of them had been present from the inception
of EIA at the former MoEF in the early 1990s, and
had been involved in the initial research into EIA
methodologies and approaches, especially those of
the EU. Therefore, they rightly considered them-
selves to be at the forefront of the field in Turkey.
According to the MoEF experts themselves, the
main problems of the EIA system could be summa-
rised as follows: unclear screening procedures for
various sectors; limited public hearings and deci-
sion-making mechanisms; weak monitoring and
auditing systems; lack of a systematic review proce-
dure; lack of EIA training for a wide variety of
stakeholders; and lack of EIA expertise in general.
The weakness of the Commission in performing
its activities was also of concern. In particular, some
members had been inactive (for instance, they had
not attended meetings), whereas the Commission as
a whole had often been unable to follow a systematic
review process, relying instead on the views of its
individual members.
Therefore, the weaknesses of the Turkish EIA
system were well understood by the MoEF experts,
and there was considerable willingness to improve
the system’s performance through co-operation and
co-ordination among the various stakeholders.
According to METAP/University of Manchester
(2001), Turkish EIA practitioners from the private
147
EIA in Turkey: capacity building for EU accession
sector considered that the scoping format laid out by
the Commission resulted in effort and money being
wasted on collecting and reporting data on irrelevant
aspects of the environment. Turkish practitioners
also observed that, in order to execute the EIA study
properly, they had to investigate matters not covered
by the format, and thereby run the risk of being un-
dercut on price by competitors who strictly adhered
to the approved terms of reference (‘special format’).
Quality of EIA reports
As mentioned above, the quality of EIA reports in
Turkey has often been perceived as weak and in-
consistent. To acquire a more specific view of the
state-of-the-art in EIA reporting in Turkey, nine EIA
reports for a variety of sectors (waste management; a
copper mine’s development; the development of two
holiday resorts; setting up a food processing plant;
setting up a textile plant; the construction of a dam;
construction of a shipyard; and construction of a
highway) were reviewed.
The methodology provided in the EU “Guidance
on EIA: EIS review” (EC, 2001a) was used and
eight people participated. The international consult-
ant performed reviews for two English EIAs, while
the MoEF staff (one representative of each depart-
ment in the General Directorate of EIA and Plan-
ning) performed seven reviews. The MoEF staff
were introduced to the methodology using a Turkish
translator and were asked to follow the “Guidance”
to review a recent ‘typical’ EIA report of their
choice from their department.
The results of the EIA reports review are pre-
sented in Table 3. While the methodology in the
“Guidance” is clear for an English speaker, it should
be noted that the language is often subtly nuanced.
Translation of this document must be carefully done
to derive accurate information effectively. The
Table 3. Average quality of EIA reports in Turkey
Section Review topic
1 Description of the project
2 Consideration of alternatives
3 Description of environment likely to be affected by the
project
4 Description of the likely significant effects of the project
5 Description of mitigation
6 Non-technical summary
7 Quality of presentation
Note: The grading of EIAs was conducted in accordance with the Guidance on EIA: EIS Review (EC, 2001a): the quality of individual
EIAs in given areas was marked on a five-letter scale from ‘A’ (excellent) to ‘E’ (very poor); for the purpose of averaging, the
letters were given numerical values (A=1, E=5) and averaged, then converted as closely as possible back to letters
148
MoEF staff performed the analysis using the English
version, as a Turkish version was not yet available at
the project’s inception.3
Overall, the grades given by the MoEF personnel
to the EIA reports ranged from average to low. Of
the seven topic areas, project description (area 1),
description of the environment likely to be affected
(area 2), and quality of presentation (area 7) received
a higher average mark (C). These results reflect re-
sults for western countries in Lee et al (1999).
As a result of this review, it became obvious that
a genuine scoping phase as well as consideration of
alternatives were almost completely lacking in the
process. Prioritisation of environmentally significant
aspects of the project was not always properly con-
ducted, with excessive concentration on one or two
particular technical areas to the exclusion of other
aspects.
Few of the Turkish EIA reports had non-technical
summaries. Presentation quality and relevance of the
information provided required improvement. In par-
ticular, much of the information in the text could be
more effectively moved to annexes to keep the nar-
rative flowing smoothly. It appeared to be important
that practitioners and MoEF experts were trained to
see the EIA process as a whole and allow the EIA
report to reflect the process.
Improving EIA in Turkey
Channelling knowledge
There is already a great deal of technical EIA
knowledge in Turkey. One problem, however, is to
ensure that such knowledge is properly channelled
so that it is actually made useful for decision-making
purposes. The establishment of an entity to play an
intermediary role between the policy arena and the
Overall grade Comment
C Highly variable with no particular trends – C is an
average grade
D Variable with mainly D and E grades – except for the
Dam report, which was marked with As: most
respondents marked this based on the fact that
real scoping does not occur at all in the reports
C Highly variable with no particular trends
D Some specific areas in specific reports were marked
high – sometimes with an A: generally marks
range from C to E
D Highly variable with no particular trends
E Non-technical summaries were generally not made
in EIA reports in Turkey: some respondents may
not have interpreted this question as “is there a
non-technical summary, and how good is it?”
C Highly variable answers.
Impact Assessment and Project Appraisal June 2004

The considerable technical EIA
knowledge in Turkey should be
properly channelled so that it is made
useful for decision-making purposes:
an entity should be established to play
an intermediary role between the
policy and the scientific arenas
scientific arena would be helpful. This entity could
play a role in individual EIA processes, for example,
by providing expertise to the Commission.
Capacity building
It is necessary to continue with capacity-building ef-
forts. There are Turkish EIA experts who are able to
carry these efforts further, possibly under the guid-
ance of international experts. Such capacity-building
could take on a number of forms. For example, at the
time of writing, the MoEF was in the process of im-
plementing a new Senter project entitled “Establish-
ing an EIA training and information centre”. This is a
follow-up to the project described in this article.
The centre would enable the institutionalising of
training within the MoEF. There would be a possi-
bility for this entity to grow eventually into a facility
similar to that existing in, for example, the Envi-
ronmental Impact Assessment Centre at Manchester
University (UK), the Institute of Environmental
Management and Assessment in Lincoln (UK), or
the EIA Commission in Utrecht (The Netherlands).
The new centre would produce sectoral EIA
guidelines, which would continue the series of
guidelines prepared within the first Senter project; it
may also implement more advanced training, as well
as on-the-job training. The MoEF staff has had prac-
tice in training hundreds of participants in the con-
text of the “Approximation and implementation of
the EIA Directive” project. These trainers are now
capable of developing, organising and executing
various training sessions, including for provincial
Environmental Boards and other audiences on more
specific aspects of EIA, and are thus also capable of
supporting the new centre.
Communication
It has been noted by the project consultant, MoEF
staff and other observers (for instance, METAP/
University of Manchester (2001)) that communica-
tions are a major problem within the MoEF and at
inter-ministerial level. Continuous attention to, and
work on, capacity building and improved communi-
cations would be of great value to the MoEF as a
whole and the EIA process in general.
Impact Assessment and Project Appraisal June 2004
EIA in Turkey: capacity building for EU accession
Strengthening capacity of MoEF
While training can improve expertise at national and
provincial levels, the capacity of the MoEF should
also be strengthened in relation to its human
resources. The number of projects in Turkey that re-
quire EIA is also too large to be handled in full detail
and adequately with the present administrational ca-
pacity and the accompanying demands on this capac-
ity. While the number of projects is not overly high,
the capacity at the MoEF is low given the volume of
work. The number of MoEF experts is too small.
This problem is likely to become more severe
when the economy recovers from its present low. It
is not possible to expand the administrative capacity
for conducting EIAs in a short period, even if fund-
ing were not a problem. It is therefore recommended
that the available capacity be used in a prudent man-
ner, and to be selective.
It is also suggested that a detailed work plan be
drawn up, indicating the capacity needed for each
step of the EIA process, the number of expected
EIAs, and the types of EIA that are most urgent from
environmental and public involvement points of
view. The most urgent EIAs should be selected, and
relatively more time spent on their effective imple-
mentation and thorough post-analyses. The MoEF
should then evaluate these cases at high level, to de-
termine internal policies, and to develop and pro-
mote good EIA practice at different administrative
levels. As capacity increases, more EIAs, as needed,
can be taken on. Post-project analysis may aid in
comparison of the quality of different EIA reports.
Decentralisation of EIA responsibilities
Decentralisation of EIA responsibilities may be in
order. Turkey is a large country with many internal
differences. It is a difficult challenge to manage all
EIAs from Ankara, as the MoEF is fully aware. It is
therefore recommended that a few regions of Turkey
be selected as pilot regions, where capacity building
would be given more urgency during the coming
years. They should be areas in which the most de-
velopment projects are expected, and where the pub-
lic has a relatively high awareness of environmental
issues. Some autonomy should be given to the local
authorities to develop their own learning process,
with the help of the MoEF. Future international as-
sistance could potentially be provided to these re-
gions directly, with the MoEF in an initiating and
advisory role.
Alternatives to the current highly centralised proc-
ess include the development of roles for EIA experts
at national level as co-ordinators in the decision-
making process, rather than the continuation of their
current task, which essentially involves supplying
environmental opinions, which could be left to the
provincial Environment Boards whose expertise and
capacity should be appropriately strengthened. The
challenge to the Ministry could also be formulated
149
EIA in Turkey: capacity building for EU accession
as the need to help improve awareness of EIA as a
decision-making tool, as opposed to an approval
tool, at all levels of government and with other in-
terested parties. This process of change in the per-
ception of EIA in Turkey would have to start with
the environmental experts at Ministry and provincial
Environment Board levels.
Systematic review
It has been noted that the scoping phase is virtually
non-existent in the Turkish EIA process. The scop-
ing currently performed by the Commission is non-
systematic and thus may become unfocused during a
meeting of 20 or more experts. Regular use of the
EU “Guidance on EIA: scoping” (EC, 2001b) would
add a systematic approach to this task and allow for
a clearer view of what the scoping process is meant
to do, which is to focus the report and to form a
terms of reference or ‘special format’ that will ad-
dress the most important issues in an EIA.
Similarly, emphasis has been placed on the lack
of ability of the Commission to put a given EIA re-
port through a rigorous evaluation, or review, pro-
cess. To address this problem, as well as the poor
and varying quality of EIA reports, a process by
which review may be carried out in a systematic
manner should be put into place, using an appropri-
ate Turkish version of the EU “Guidance on EIA:
EIS review” (EC, 2001a). Using this in a systematic
manner to conduct the review process would allow
for a strengthening of the Commission’s activities as
well as more uniform reporting.
Streamlining
At present, the complexity of government decision-
making about investment projects remains an obstacle
to economic growth in Turkey (World Bank, 2003).
Large numbers of permits are generally required to
develop projects. EIA, if not properly streamlined
with environmental and non-environmental permit
procedures, adds to this problem.
The “Approximation and implementation of the
EIA Directive” project has contributed to awareness
in other ministries that co-operation with the MoEF
on the development of streamlined joint procedures
is an urgent need. EIA is presently not attached to an
integrated consent decision, but rather to an envi-
ronmental “statement of no objection”. This greatly
reduces the potential of EIA as a decision-making
tool to encourage more strategic alternatives to pro-
posed projects. The MoEF should stress the issue of
streamlining on the cabinet agenda.
Conclusions
Turkey is a country with extremely diverse ecologi-
cal conditions and varied economic, social and cul-
tural structures. This causes variation in the
150
dynamics of environmental awareness. Since envi-
ronmental problems result from the interaction of
development activities and ecological conditions,
measures for their prevention and elimination must
be planned and implemented using an integrated and
dynamic approach to EIA.
The project “Approximation and implementation
of the EIA Directive” addressed some obstacles to
establishing an effective EIA system in Turkey. A
number of observations have been made in the
course of project implementation and have been fur-
ther discussed in this paper.
There are a few pronounced differences between
the sponsor of the EIA capacity-building project and
the MoEF in their perspectives on the real problems
regarding the EIA process in Turkey. It is further no-
table that the terms of reference were prepared by
the sponsor along with input from the MoEF, so dif-
ferences should not be, and are not, very significant.
However, the differences in perspective also proba-
bly indicate, to some degree, the difference between
western and transitional countries’ approaches to
EIA. The attention to problems in some rather dis-
jointed aspects of the EIA process on the Turkish
side may reflect the developing country’s tendency
to approach EIA as a bureaucratic series of steps.
Turkey's governance still has to be modernised in
many ways before EIA can fulfil a role in decision-
making comparable to western countries.
EIA, if prudently applied, might function as a
lever to increase transparency and aid in driving the
general modernisation process. However, the Turk-
ish perspective also reflects a more pragmatic ap-
proach towards making its own EIA process work,
on its own terms. Also, the black-and-white ‘yes or
no’ answer that the Commission can provide for an
EIA report is perceived to be problematic by western
standards, but not Turkey’s. Perhaps the Turkish ap-
proach to EIA should not be judged purely from an
EU or other perspective on effectiveness. The cul-
tures are so different that what works in certain EU
Member States may not be possible to implement in
Turkey, and vice versa.
Indeed, in some cases in countries in transition, it
has been noted that so-called ‘advanced’ EIA law
has resulted in poorer-functioning EA systems and
that, in other situations, less advanced EIA law did
not prevent relatively effective functioning of EA
systems (Cherp and Antypas, 2003). In Turkey, ad-
aptation of the EU “Guidance on EIA: screening”
(EC, 2001c), “scoping” (EC, 2001b) and “EIS re-
view” (EC, 2001a), translated into Turkish and
worded in such a way that they are as useful as pos-
sible to the parties that need to use them, would be
of support to the EIA process because they would
make these activities more systematic. Perhaps it
would be the most sensible approach to harmonise
with the EU requirements in law, but to find ways of
implementation and enforcement of this law that
truly complement the Turkish approach to govern-
ment and the country’s culture.
Impact Assessment and Project Appraisal June 2004

Notes
1. Acquis communitaire is a French term used by the EU to de-
scribe the sum total of all the EU Directives and regulations that
must be taken over by any Member State to fulfil its legislative
obligations to the EU. The ‘environmental acquis’ is the fraction
of the acquis communitaire that applies to the environment.
2. The EU “Guidance on EIA. EIS review” questionnaire was
eventually translated into Turkish and incorporated into the
Handbook on EIA prepared under the auspices of the project.
3. Turkish versions of the EU “Guidance” were provided in the
course of the project.
References
Ahmad, B, and C Wood (2002), “A comparative evaluation of the
EIA systems in Egypt, Turkey and Tunisia”, Environmental Im-
pact Assessment Review, 22, pages 213–234.
Cherp, A (2001), “Environmental assessment in countries in
transition: evolution in a changing context”, Journal of Envi-
ronmental Management, 62, pages 357–374.
Cherp, A (1999), Environmental Assessment in Countries in
Transition, PhD thesis, University of Manchester, Faculty of
Arts, Manchester.
Cherp, Aleg, and Alexios Antypas (2003), “Dealing with continu-
ous reform: towards adaptive EA policy systems in countries in
transition”, Journal of Environmental Assessment Policy and
Management, 5(4), pages 455–476.
EC, European Commission (2001a), “Guidance on EIA: EIS re-
view”, Office for Official Publications of the European Commu-
nities, Luxembourg.
EC, European Commission (2001b), “Guidance on EIA: scoop-
ing”, Office for Official Publications of the European Communi-
ties, Luxembourg.
EC, European Commission (2001c), “Guidance on EIA: screen-
ing”, Office for Official Publications of the European Communi-
ties, Luxembourg.
EC, European Commission (2001), “Turkish National Programme
Impact Assessment and Project Appraisal June 2004
EIA in Turkey: capacity building for EU accession
for the Adoption of the Acquis”, Secretariat General for EU Af-
fairs, Ankara,Turkey.
George, C (2000), “Comparative review of environmental pro-
cedures and practice”, In N Lee and C George (editors),
Environmental Assessment in Developing and Transitional
Countries )John Wiley and Sons, Chichester).
Lee, N, R Colley, J Bonde and J Simpson (1999), “Reviewing the
quality of environmental standards and environmental ap-
praisals”, Occasional paper no 55, Department of Planning
and Landscape, University of Manchester.
METAP, Mediterranean Environmental Technical Assistance Pro-
gramme and Manchester University (2001), Evaluation and
Future Development of the EIA system in Turkey, report pre-
pared under the METAP EIA Institutional Strengthening Project.
Official Gazette (1993), “Environmental impact assessment regu-
lation”, Turkish Official Gazette, 21489, 7 February.
Official Gazette (1997), “Environmental impact assessment regu-
lation”, Turkish Official Gazette, 23028, 23 June.
Official Gazette (2002), “Environmental impact assessment regu-
lation”, Turkish Official Gazette, 24777, 6 June.
Official Gazette (2003), “Environmental impact assessment regu-
lation”, Turkish Official Gazette, 25318, 16 December.
Senter International (2001), “Terms of reference for the project
‘Approximation and implementation of the EIA Directive in Tur-
key’”, Senter International/Ministry of Economic Affairs, The
Netherlands.
Yilmaz, H, A Albayrak, S Ataman, A Beba and S Innanen (2002),
“The EIA process in Turkey”, paper presented to IAIA Con-
gress 2002.
Wood, Christopher, Adam Barker, Carys Jones and Johanna
Hughes (1996), “Evaluation of the performance of the EIA
process. Final report”, Report to Contract B4-3040/95/451/
MAR/B2, Manchester, University of Manchester.
World Bank (1999), The World Bank’s Study of Environmental
Assessment systems of 28 Countries of Europe and Central
Asia (World Bank, Washington DC).
World Bank (2002), “Environmental impact assessment systems
in Europe and Central Asia Countries”, Europe and Central
Asia Environmentally and Socially Sustainable Development
Department, Washington DC.
World Bank (2003), “Turkey corporate sector impact assessment
report”, Report no 23153-TU, Private and Financial sector De-
velopment, Europe and Central Asia Region.
151