World Bank Documentdocuments.worldbank.org/curated/en/968701468779179501/...Pamukkale) are to be newly developed for the proposed project activities, then, govemment procedures require

E562March 2002

THE WORLD BANK

TURKISH REPUBLICMINISTRY OF CULTURE

COMMUNITY DEVELOPMENT AND HERITAGE PROJECT

ENVIRONMENTAL MANAGEMENT PLAN

DRAFT REPORT

March 2002

Prepared by

R. Sinan Erer

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CONTENTS

1 INTRODUCTION .................................................. 2

1.1 Legislative Base .................................................. 2

1.2 Environmental Mandate .................................................. 3

2 ENVIRONMENTAL EVALUATION ................................................ 4

2.1 Pamukkale Component .................................................. 4

2.1.1 Resettlement .................................................. 4

2.1.2 Water Management .................................................. 5

2.1.3 Carrying Capacity .................................................. 7

2.1.4 Impact of Project Investment Items ................................................ 7

2.2 Mardin Component .................................................. 8

2.2.1 Needs for Upgrading of Infrastructure ................................................. 10

2.2.1.1 Water Supply and Distribution Network ................................................. 102.2.1.2 Sewerage System and Wastewater Management ......................................... 112.2.1.3 Solid Waste Management ................................................. 12

2.2.2 Impacts of Project Investment Items ....................................... 12

2.2.2.1 Masonry work ................................................. 122.2.2.2 Cleaning of stone walls ................................................. 132.2.2.3 Public Spaces and Buildings - Street improvement ..................................... 13

3 CONCLUSION ................................................. 14

4 RECOMMENDATIONS: ................................................. 14

5 TRAINING: .................................................. 14

6 MONITORING: ................................................. 15

ENVIRONMENTAL MANAGEMENT PLAN FOR PAMUKKALE .. 16

A. MITIGATION PLAN .. 16

B. MONITORING PLAN FOR PAMUKKALE...........................17

ENVIRONMENTAL MANAGEMENT PLAN FOR MARDIN ............ 19

A. MITIGATION PLAN .............................................. 19

B. MONITORING PLAN FOR MARDIN .............................................. 22

ANNEX 1: LIST OF BACKROUND REPORTS REVIEWED ............................................. 23

ANNEX 2: PUBLIC CONSULTATION MEETING .............................................. 24

1 INTRODUCTION

This report presents the findings and suggestions of the Consultant for the EnvironmentalManagement Plan of the "Community Development and Heritage Project" in Turkey.

The Consultant studied thoroughly the World Bank Publication "Environmental AssessmentSourcebook" and its updates as well as the World Bank Operational Policy 4.01 onEnvironmental Assessment to get proper guidance and to be able to evaluate and present hisfindings in the expected way. The consultant initiated the work with a review of theproposed project components and an assessment of their potential environmental impact. TheEnvironment Management Plan was elaborated based on this assessment, followingconsultations with relevant stakeholders and discussions with national and local govemmentofficials, Project Management Unit Staff, and World Bank staff.

The ToR describes the activities envisaged in the project and cites several investment itemssuch as establishment of a visitor center, resettlement of 95 households in Pamukkale, andstreet improvements, upgrading basic infrastructure, buildings and public spaces renovationin Mardin. The Consultant is expected to assess the impacts on the environment and provide amanagement plan, and recommend measures to prevent, minimize, mitigate or compensatefor any adverse impacts.

Consultant's study was based on;* Thorough a review of reports/papers related to the project concept/activities (A list is

provided in Annex 1);* Consultation with Project Management Unit, World Bank staff, UJNDP, project

related Government Agencies* Field trips to Mardin and Pamukkale* Consultations in the field including; govemors, mayors, provincial departments of

Ministries, stakeholders, representatives of citizens. (Summaries of publicconsultations in Pamukkale and Mardin provided in Annex 2)

1.1 Legislative Base

None of the project activities require environmental impact assessment review, according tothe Environmental Impact Assessment Regulation of Turkey. (published in Resmi Gazette,dated June 27, 1997).

If the stone quarry for Mardin component and the sand quarry (for construction activities inPamukkale) are to be newly developed for the proposed project activities, then, govemmentprocedures require a review of environmental impacts. The contractors will be responsible forcontacting quarries. In Pamukkale, given the relatively routine nature of the construction, itis expected that existing quarries will be used, which already have the necessaryenvironmental clearances. In Mardin, the need for additional stones is not large, and it is alsoexpected that the need will be covered from existing quarries. The Contractor will need toapply to the corresponding Governorates in Mardin and Denizli to obtain the relevantpermits. According to the EIA regulation, the provincial environmental committees decidewhether the environmental impacts of the quarries in question are significant or not, based onreview of the environmental reports.

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Environmental issues such as noise, dust, air pollution, water pollution, solid wastemanagement, are dealt with in accordance with corresponding regulations in effect.

Without exception, the construction/restoration plan of each individual unit in Mardin issubject to prior approval of the Preservation Council for Cultural and Natural Assets.

In Pamukkale/Hierapolis, after the review of the Preservation Council for the Cultural andNatural Assets, Authority for the Specially Protected Areas (ASPA) under Ministry ofEnvironment has the final authority to approve plans. (1/25000; 1/5000; 1/1000 scale plans).

Impact of the project on culture. The objective of the project is to protect and enhacecultural heritage management through the engagement of local communities to sustain theprotection efforts and to benefit them from the proposed investments. The activities underthe project address the objective, and will adhere to national and intemational standardrequirements for the protection of cultural heritage. The Site Management Plan itselfproposes modem management techniques fo cultural heritage sites. For example, Pamukkalewill be surveyed to record the significance of the site, and to ensure appropriate treatment ofany chance finds during construction; also contracts for construction and supervision shouldbe clear about environmental and cultural aspects. Similarly in Mardin, the interventions,will to the extent possible aim to preserve the architectural and heritage specificities of theold city, by using traditional materials. Turkish law requires the reporting of any finds duringconstruction. The Ministry of Culture has the main responsibility for the project.

1.2 Environmental Mandate

As a matter of fact, considering the objectives, approach and methodology of the "TurkeyCommunity Development and Heritage Project" and evaluating the components, theConsultant considers that the Project itself is an environmental rehabilitation project.Environmental soundness and sustainability of the project is assured and further reinforcedowing to following facts:

* Ministry of Culture, jurisdictionally a conservation agency, owns the Project,* Preservation Council for Cultural and Natural Assets will have to approve all the

interventions,* Agency for Specially Protected Areas, under the Ministry of Environment, has the

final authority to approve all physical plans (in Pamukkale),* Both of the sites are world cultural heritages (Pamukkale is officially recognized by

UNESCO and Mardin is on the candidate list),* Participation mechanisms both in Pamukkale and especially in Mardin through

Citizen's Council, function efficiently.

Therefore, the Environmental Management Plan and the corresponding assessments of theProject have been considered to cover additional, if any, components to complement the"environmental rehabilitation approach" of the project. The Consultant used some outsideexpertise and assistance to be able to complete his assignment within the contract periodwhich seemed to be tight due to the time constraints of project preparation.

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2 ENVIRONMENTAL EVALUATION

2.1 Pamukkale Component

Pamukkale component will be evaluated under the sub-components of:

* Resettlement

* Water Management

* Carrying Capacity

* Impacts of Project Investment Items

2.1.1 Resettlement

This Component is defined in the ToR as "In addition, the Project will relocate 95households from the Oren district, which lies within the protected archeological areadesignatedfor Pamukkale in 1981. For this, it will provide the necessary infrastructure andhousing construction, and would also aim to integrate the resettled residents of Oren into theeconomic activities of the Pamukkale site through providing possibilities to develop relatedtouristic and commercial activities". The ToR also asks the Consultant to evaluate theadequacy of infrastructure of the resettlement.

The Resettlement Action Plan (RAP) is being prepared as a separate component of theproject. The implementation of RAP should incorporate appropriate environmentaldimensions into different stages and activities. The RAP approach also necessitates athorough understanding of the values, expectations and life styles of the residences of Orenand their relations with their immediate environment. Consequently, all environmentalparameters or factors affecting, shaping, defining and contributing to the living environmentor to the quality of the resettlement area are taken into account at earlier stages ofresettlement actions.

In other words, initially during selection and planning of the site, and later, during planningand construction of dwellings it is important to make all environmental considerationsintrinsic components of the Resettlement. The RAP considers these issues during differentstages of resettlement through;

* Site selection to be executed appropriately taking into account;- soil characteristics (preferably unarable land)- vegetation- geology, hydrogeology, topography of the site- microclimatic conditions, water regime, seismic characteristics, nearby

habitats- proximity and connections with project related activities to benefit from

community development efforts- proximity and relation with environmentally sensitive areas

* Site planning taking into account;- health, education, transportation, communication, employment, investment,

recreational, socio-cultural needs of the society

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- water, sewer, electricity, communication, infrastructure (such as, roads,pavements, bike-paths, parks, needs of handicapped, etc.

- potential for solid waste management including:- minimizing wastes- training of citizens

Planning and construction of dwellings considering;- size, orientation, density of dwellings- dimensions, layouts, relationships between spaces- climate, sunlight, wind, rainfall and storms- selection of appropriate material and construction technology

The RAP describes why, how, when and where the citizens will move to and also considershow they will become real partners of the project. This plan is being prepared andimplemented with a participatory approach. Citizens' ownership and integration with projectobjectives will promote partnership enhancing socio-economic development, eventuallyminimizing negative connotations of the involuntary aspects of the resettlement.

Such a "voluntary" resettlement can only be realized through a long process that is defined asa component and as an intermediate objective of the project, rather than a condition for it.Otherwise, dissatisfaction of these stakeholders poses a threat to the sustainability of theproject and so to the environment.

The RAP has been submitted separately. It addresses the basic needs of the population interms of infrastructure and other services including water, wastewater and sewerage to restoreor improve their living standards to levels prevailing prior to the resettlement. In addition,Turkish legislation regulating resettlement and construction activities requiresenvironmentally sound site selection, site development and construction of dwellings.

2.1.2 Water Management

The project does not propose any activity which will change the relative uses of the existingwater resources. So it is not expected to face conflicts in water use. Ongoing whiteningschedule of travertine terraces will not be negatively affected.

Pamukkale component is mainly based on the preservation of the natural and cultural heritagei.e. springs and travertine formations on which the historical settlement had been structured.Therefore Environmental Management Plan should be mainly based on the concept ofsustainable management of the water (hot springs) within the area and protection of travertineterraces while ensuring sustainable promotion of them and the historical heritage.

The baseline study enabling decisions for Sustainable Water Management was conducted byHacettepe University, International Karst Water Sources Application and Research Center(UKAM), which was completed in July 1996. The major approach and the findings of thisstudy in relation to Sustainable Water Management can be outlined as follows:

* The study mainly approached water management in terms of rehabilitation andpreservation of the natural heritage - the travertine terraces.

* The study suggested demolition of existing hotels and prohibiting direct utilization oftravertine terraces (i.e. bathing and wading)

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* A conceptual plan was prepared for a channel distribution system that enables evensupply of water on the travertines so as to rehabilitate and sustain their bright white color.

* A stormwater management plan was suggested.

* A main conveyance channel is suggested to collect the overflow from the travertines andstormwater from the area.

Already implemented suggestions are:

* Four motels have been demolished. Concrete basements and pools (empty) are leftremaining. One facility that belongs to the Provincial Special Administration is partlydemolished and is still under operation. The demolition of the last facility is part of theenvironmental mitigation plan, and is included in the government's program for the firstand second year of the project.

* The channel and stormwater system designs are under review by Pamukkale University.

* Entering travertine terraces has been prohibited.

The Assessment and Update Report of the Pamukkale 1992 Master Plan prepared by EmreMadran and Nimet Ozgonul for the Ministry of Culture and the recently completed"Pamukkale Site Management Plan" prepared by Akan Mimarlik, OAU and Past Forwardpartnership both suggest that a 1/5,000 scale master plan for land management and utilizationbe prepared for the region defined by historical and natural sites, as well as Pamukkale andKarahayit settlements.

As previously mentioned, the study executed by Pamukkale University covers the designs ofthe channels to manage the water (hot springs) onto the travertines and overflow from thetravertines to be used by the farmers. On the other hand, UKAM study suggested restrictionof water for agricultural use which could have a negative impact on a major stakeholder, thecommunity of farmers, possibly jeopardizing local ownership. This suggestion has not beenimplemented. A participatory study is suggested to be conducted with a view to prepare a"Water Management Plan" considering relative uses for water preservation of travertines,touristic activities (on-site), agriculture, thermal tourism and residents.

This study should cover the following components* Determination of water demand for each category of use (annual, seasonal, daily,

fluctuations etc.)* Determination of water characteristics for each category of use (temperature,

chemical and physical properties etc.)* Carrying capacity analysis* Need/Possibility of reuse/recycle* Need for treatment between different uses* Need/Possibility of storing water

The Regional Water Management Plan study if properly coordinated with the LandManagement and Utilization Plan to be prepared by Authority for the Specially ProtectedAreas (ASPA) together will constitute a "Comprehensive Land and Water ManagementPlan" ensuring interalia "Sustainable Water Management".

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2.1.3 Carrying Capacity

The ToR also asks for the evaluation of the carrying capacity for the Pamukkale site."Pamukkale Site Management Plan" evaluates the carrying capacity of the site with aniterative methodology, which is considered to be very appropriate by the Consultant. Is is truethat a sound plan also enables management of the visitations so prudently that carryingcapacities are not exceeded and sustainability is assured.

The target visitation rates envisaged in Pamukkale Site Management Plan are estimated to bewell below the carrying capacity of the natural site and travertine area,

Water supply and wastewater systems should be appropriately designed and implemented toensure that water quality is not deteriorated and carrying capacity not negatively affected. Onthe other hand, owing to the historical nature of the site it is not possible to install a properunderground sewage system. Therefore alternatives should be considered:

* Utilization of transportable toilets as suggested,

* Design of a small bore system, where cesspits and shallow piping network can be usedunder strict guidance of the excavation team,

* Location of the toilets, to be mainly outside of the site at the service areas, and tolocations with less environmental risks within the site boundaries,

* Combination of these conceptual ideas.

2.1.4 Impact of ProjectInvestmentItems

The main investment items for the Pamukkale Component are presented in the "PamukkaleSite Management Plan". The plan report covers suggestions, general description of theseitems and approximate locations. The Consultant doesn't envisage adverse impact of thesestructures on biodiversity and to cause any noise, air and land pollution. However, if notlocated and constructed properly there may be adverse effects on the water quality and alsothe quality of travertines. To prevent any such negative impact, Consultant suggests that thelocation of these structures should be determined in close cooperation with the sitemanagement team during later stages of project implementation.

The other major recommendation of the Site Management Plan is to enable visitors to makeuse of hot springs and baths because this is considered to be an attraction for tourists. On theother hand, UKAM Report suggests that no bathing should take place to ensure preservationof the quality of travertines. Consultant is of the opinion that, if properly designed andmanaged, travertine terraces can be protected while providing limited use. The possibledesign criteria can be:

* provision of shower facilities to be used before entering the pool for minimizing pollutionfrom the bathers,

* provision of a separate discharge system so that the overflow of water from the bathpools is not discharged on to the travertines but possibly directly to the agricultural areas

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Any decision on the location and design of the bathing facilities should be reviewed byenvironmental specialist. The proposals to direct water from the travertines to the historicBath, while building conveyance channels to collect water and distribute it to framers is notexpected to have negative environmental impact if designed and implemented correctly.Water management and site management plans can be complimentary to each other.

Other activities presented in the Site Management Plan and their correspondingenvironmental issues are listed below:

Access to Bus Arrival Area (preferably not through the Pamukkale town)* Traffic congestion* Exhaust gases* Noise* Safety

Parking Area

* Selection of an appropriate location* Provision of adequate infrastructure (water and sewer system)* Provision of services to the visitors (bathrooms, solid waste collection -type, size and

quantity of solid waste containers is important enabling sorting at the source)* Greening of the area that will provide a natural shelter from sun and also serve as a

carbon sink.

Overall Site Activities

* Solid waste management should be designed- to keep the site clean- to provide convenience to the tourists- to provide ample capacity- to provide sorting at the source enabling recycling- to enable easy collection- to use collection bins obeying international color coding and respecting site values

* Considering the hot and humid summer months, mosquitoes will be a nuisance factor forthe visitors. Unless all other alternative methods and techniques are exploited, use ofinsecticides should be avoided.

2.2 Mardin Component

This component of the Project envisages rehabilitation and upgrading of the old town ofMardin thus improving livability and urban conditions in the area. It is expected that theproject starts contributing to socio-economic development at earlier stages of projectimplementation through measures to utilize project resources mainly in Mardin by the peopleof Mardin.

Approaches of the Consultant, as delineated in the Work Methodology Report, have beenaugmented and developed with the consultation process in Mardin. Prior to the consultationwith individuals, the Consultant participated in a meeting of the Citizen's Council on 17 and18 January 2002.

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The Citizens' Council is a self organized group composed of representatives of Mardin's civilsociety and NGOs, ex officio members from the provincial bureaucracy including theGovemor. The Council is formally headed by the Mayor, though spokespersons for theCouncil's consultative processes and its day to day leadership ranges from the BarAssociation to the Architects Association. Since its foundation, the council has met regularlyto establish a city vision and to advocate for Mardin at various political and economicplatforms. The Council embraces some 60 institutional and personal participants includingthe govemor, mayor, public officials and participants from local civil society (Chambers ofCommerce, Trade, Industry; craftsmen, artisans, business associations; professional chambersof architects, engineers; cultural and religious foundations, etc.).

The Citizens Council has been discussing participatory urban rehabilitation in Mardin eversince it was founded. One of the main areas of focus for the Council has been its participationin the formulation of the UNDP proposal to the MoC for the Mardin Component under thecultural heritage. So, the proposed World Bank financed project is a proper instrument for thepeople of Mardin in facilitating their long-term objectives. That is why the Council dedicatedtwo of its "extraordinary" sessions, one in October and one in November 2001, to review theWorld Bank's cooperation with the MoC targeting Mardin.

The decisiveness of Mardin people, local ownership and leadership exemplified in CitizensCouncil activities will certainly contribute to socio-economic development through protectionand promotion of cultural heritage in the long run.

Members of the Citizen's Council are very eager to proceed with the project implementationand are keen to ensure the project's efficient implementation and sustainability. Their visionfor Mardin is to stimulate the tourism potential of the town based on its cultural heritage.They place their infrastructural needs for adequate sanitation and access to regular andsufficient water at the top of their list of priorities. It is evident that the civic platformestablished via the Local Agenda 21 process will be very much strengthened with theCommunity Development and Heritage Project.

The assessment of the project's potential environmental risks and impacts in the urban area ofMardin has brought about issues significant to the decision making toward sound andsustainable outcomes of the project.

The following sections highlight the public health implications of the current problems in theavailable infrastructure system, as well as the significance of synchronicity between civilworks in street upgrading (mainly geared to the visible supra-structure) and unavoidableupgrading of infrastructure (mainly geared to water supply lines, sewerage as well asconcealing electricity and telecommunication cables).

Mardin component will be evaluated under the sub-components of:

* Needs for Upgrading of Infrastructure

* Impacts of Project Investment Items

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2.2.1 Needs for Upgrading of Infrastructure

Assessment of the existing environmental situation and available infrastructure reveals thecurrent problems in buildings and in infrastructure. Needs for upgrading of infrastructure areconsidered below in three major areas:

* water supply and distribution network,

* sewerage system and wastewater management,

* solid waste management.

2.2.1.1 Water Supply and Distribution Network

Concerns about the existing infrastructure highlights a major priority of the city: Regularsupply of water has been a big problem in Mardin for years. Although, not directly relevant tothe project itself, water supply is an important factor to be solved in terms of the expectedoutcome of the project which is to contribute to the tourism potential of Mardin. Becausewater leakages are affecting the historic structure and bad drainage leakages are notappropriate for the architectural city ambiance.

There is a consensus that highest priority should be given to solving this chronic issue. It isobvious that, first, for the people of Mardin and then if Mardin is to become a touristattraction, regular supply of clean water and efficiently operating sewer network are sinequanons. This point has also been depicted in the social assessment research.

In the old town of Mardin, water supply was recorded to be wisely engineered to meet theneeds of the citizens for centuries. This important task was accomplished through a specialstate of mind, respecting sustainability and balance between supply and demand sides ofwater management. All available resources were tapped by means of wells in the courtyards,cisterns to collect rain water and snow, water galleries going deep in the mountain (some aresaid to be 2m x 2m), and fountains. The Yahudiyye and the Cevheriye fountains are reportedto be within the neighborhood which houses the Synagogue, the Zeyd Mosque and SurpKevork Church. Neighbours from different religions have shared a scarce natural resourcenever making it an issue of conflict. Most probably those people in the past never thoughtthat their co-existence in harmony would one day be admired at this level.

The consultant proposes that water supply and sewer network characteristics of the old towncould further be studied and be included in site presentation plan. It is assumed that, as inPamukkale, a site presentation plan be prepared and implemented in Mardin. The heritage inthis area is an integral part of the other assets which people are trying to mobilize to increasetourism incomes and socio-economic development.

On the other hand during discussions with the municipality, it was mentioned that watersupply to the town was at 250 liters/second which meant close to 300 liters of water perperson per day. The Bank of Provinces in Turkey accepts that in a household with a shower,daily water consumption is between 80-115 liters. So, the reason why water could only besupplied to some households once a week, needs further in-depth engineering studies andanalysis. The authorities later reported that the actual water supply was 1501/s as against2501/s capacity.

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A deeper assessment of the water supply system reveals some handicaps in the urban watermanagement. Water is supplied to the town from wells at the northem part and pumped tostorage tanks. Water is transmitted through the main trunk that lies beneath the main streetand connects to the secondary lines in the inner roads. Water distribution starts at the upperelevations and flows in decreasing amounts towards the lower end. Lack of control valvesand single trunk surrounding the town accounts for the irregular and inequitable water supplyto the citizens. As a preliminary engineering approach, the project aims to provide a waterstorage unit (estimated at 1500 cubic meters) to be constructed at the northeastern part of thetown. This can be an intermediate solution to supply equivalent amount of water to the twosections of the city on the basis of population. In the medium term, the distribution networkfor the whole town has to be studied thoroughly to detect leakages and improve the systemaccordingly. Upgrading of the system will not require additional water supply requirement,and may in fact cause some water savings

In upgrading of infrastructure, the project should also consider that the inner alleys arenarrow, about 1 meter in width, and that there is evidence of contamination of tap water fromsewage leaks. The project should address this issue in its intervention, and the city shouldlook into this risk and assess it in details in an attempt to eliminate this risk. Thenarrowness of the roads is a factor to be considered in terms of civil works that may beconducted in parallel to the street upgrading schedule.

Discussions with the Authorities led to considering different alternatives to solve theproblem. Constructing a water tank on the eastern part of the town, close to the Citadel, andworking on demand side of water management also, instead of million dollar worth watersupply projects to be realized in the future, were among the alternatives considered. Theconsultant is not saying at all that there is an easy, one -minute, solution to a decades lastingproblem of a big town, however it is worthwhile to study different aspects of watermanagement in Mardin. Otherwise it will be ironic to be proud of a heritage, which hassolved water issues ingeniously many centuries ago, while suffering from lack of qualityservices today.

2.2.1.2 Sewerage System and Wastewater Management

The project addresses the leakages in the water supply and sewerage networks that frequentlycause humidity at the basements of the buildings and damage building walls. This drawsconcerns on the quality of the infrastructure and the plumbing inside the buildings. Duringthe Consultant's consultations with people from Mardin, especially the elderly, it wasmentioned that at the beginning of the last century, Mardin old town had a remarkable and anefficiently operating sewer system collecting all the sewage to the foot of the mountainwhere, in today's terminology, primary treatment was done in a stabilization pond. Finally,wastewater was used for irrigation purposes. Further details of the system regarding itshistory, its plan, dimensions etc. could not be obtained. While it is worthwhile to study andinvestigate it for its historical value and demonstrate as part of the cultural heritage, it is alsoessential to consider repair of the plumbing in the houses as well. Health risks rising from theintrusion of leaks into the water supply lines indicate the need to consider respective locationsof the water supply and sewerage lines. The project will address this problem in the sectionsof the street improvements that is included in the project, and the city should undertake adeeper study and actions to eliminate this risk (see section above on water supply system)

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2.2.1.3 Solid Waste Management

As for collection and sanitary disposal of solid wastes, Mardin was one of the five pilot citieswhere the GAP Regional Development Administration had contracted a Feasibility Study forUrban Sanitation and Planning Project, Consultancy Services in 1998-1999, with financialassistance of the World Bank. Results of the Study component for Mardin can be outlined asfollows:

* The optimum solution appropriate for the narrow and partly steep alleys of the upper,historic part of the town, is to collect waste by donkeys equipped with baskets.

* From a hygienic point of view, the problem lies in the transfer of waste from donkey totruck (loaded by tractor loader) which is currently done at 6 points in the city. Theupgrading of these points is recommended by using curbs specially designed for donkeys.

The solid waste management topic was contemplated by the UNDP Technical AssistanceTeam (TAT) with a view toward ensuring complementarities in relation to the StreetImprovement component of the Project, and supporting the overall cultural preservationnecessities of the site. The Consultant has reviewed TAT's project framework based on aparticipatory approach, and agrees on the overall context, but with the incorporation of thecurb system and sanitary transfer points as recommended in the GAP RDA Study Reportmentioned above. Sorting of recyclables can be made at the transfer points as the same reportsuggests.

2.2.2 Impacts of Project Investment Items

Major project investment items with potential environmental impacts will take place at theconstruction phase under the small grants scheme in which the project will provide funds to:

* Residents to upgrade the exterior of their homes,

* Traders in the commercial district to make improvements to the exterior of their shops,

* New entrepreneurs in culture based industries such as arts, crafts and stone-cutting tomake improvements to the exterior of their shops,

The beneficiaries will be using the project funds (sometimes with cost-sharing) for suchactivities as masonry work, terrace insulation, blasting, chemical cleaning of facade walls,constructional repairs, and home sanitation. Environmental aspects of such activities areoutlined in the following sections.

2.2.2.1 Masonry work

Stones used in Mardin architecture needs thorough analysis in a specialized laboratory, andcertain tests have to be performed. Based on this information, the closest alternative stonequarries should be determined. (Some studies have been reported to be carried out by UNDP)

Cutting this stone to size and transporting it and other construction material to the site whiletransporting in the reverse direction inappropriate concrete or other cladding, insulationmaterial, from removal of inappropriate units, terrace insulation, etc. will be a source of seriesof environmental problems such as noise, dust, transporting possibly up to a certain point onhorse-back and then by tractors or/and trucks.

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2.2.2.2 Cleaning of stone walls'

Facade walls have been cleaned by using hand tools until now. However, considering theimmense work to be conducted during the project, the experts propose a suitable blastingtechnique. Consultant proposes that while conducting tests to the Mardin stone, proper type,intensity, depth and technique for blasting, should be determined by conducting special testsunder expert supervision. This will naturally be a trial and error procedure. Blastingequipment manufacturers recommendations for worker safety and health should be strictlyfollowed. Should any additional measure be determined based upon the tests performed, theyshould also be taken into account.

During preparation of the project, experts mentioned the use of some protective chemicalsand chemicals for cleaning purposes. Although the type, amount and place for thesechemicals have not been determined, it is recommended to use less of them, with caution,preferably biodegradable types, without altering fundamental characteristics of the basematerial (stone or wood). Their containers should also be disposed of properly A list ofchemicals that are not to be used are mentioned in the Mitigation Plans in tabular formsattached.

2.2.2.3 Public Spaces and Buildings. Street improvement

Street areas including neighborhood squares amount to about 15,000 m2 horizontal area. Mostof this surface is covered by inappropriate concrete which needs to be removed. The debristhat has to be removed will be between 6,000 to 10,000 tons. It is important to note here thatbulk of this load will have to be first carried on horse-back, to possibly a tractor and then to abig truck to benefit from transportation cost. Nevertheless over 1000 truck-loads of debris is ahuge amount especially when one considers the conditions in old Mardin.

It is also environmentally important to determine a suitable site out of town for the debris tobe transported. This requires further analysis and official consultations with relatedgovemment agencies such as environment, health, agriculture, forestry housing andconstruction departments under the Govemors office and other stakeholders. The publicshould also be involved in the decision-making.

The stone and other material required for street surfaces will double the transportationproblems and amounts. Street improvement includes approximately 24,000 m2 of verticalstonewalls to be cleaned and repaired. The environmental aspects of blasting to clean publicspaces and building should also be considered during this process as mentioned above forhouseholds and shops.

It is of utmost importance to thoroughly upgrade the water piping, sewer network, and layingelectricity and communication cables under the ground while conducting the streetimprovement program. This in tum will remove visual barriers to the exciting silhouette ofMardin. Repair and upgrading of infrastructure is also justifiable from the point of view ofdecreasing water losses and leakages (clean and waste) resulting in humidity problems in thehouses and shops, also mentioned in the social assessment report.

Last but not least, urban greening should also be considered through a participatory approach.Plants, flowers particular to the region and those locally endemic (if any) should be givenhighest priority.

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3 CONCLUSION

The Consultant is satisfied and feels confident in concluding that the project isenvironmentally sound and sustainable, and all the unwanted effects can be avoided,minimized, mitigated or compensated as foreseen in the project design and the report. This isbasically because of the:

* Sensitivity of all the agencies and individuals active in the formulation of the Project(MoC, municipalities, governor offices and the World Bank staff)

* The approach and methodology of the World Bank and the Ministry of Culture,* Protectionist nature of the approval procedure of proposed activities through the

Preservation Council for Cultural and Natural Assets and Agency for Specially ProtectedAreas

* Participation strategy of the Project to include all the stakeholders including publicagencies and segments of the civil society, as the most important safeguard of the project

In order to give a brief summary of recommendations in the Report, a tabular representationof the environmental assessment and management issues is presented in the Mitigation Plansin tabular forms.

4 RECOMMENDATIONS:

It is not expected to face serious environmental challenges during implementation of theproject activities because project objectives do not have any conflicting issues withenvironmental sustainability. However, in order to strengthen the comprehensiveness andintegrity of the project it is highly recommended to prepare;

* A regional Water Management Plan for Pamukkale/Hierapolis/Karahayit region.* Monitoring plan for alternative water uses in Pamukkale.* Site Presentation Plan for Mardin.* A Water Management Plan for Mardin.* Documentation on heritage issues of water management in Mardin (historical water

management).* A report on characteristics of Mardin Stone.* Manual for Citizens Council/Mayor/Governor to effectively monitor compliance and

enforce laws, regulations and decisions in Mardin.

5 TRAINING:

During project implementation, highest level of citizens/stakeholder participation should besought and these efforts should be strengthened via awareness-raising and training activitiesin such areas as;

* New skills required for emerging occupations and expected behavioral changes,* Materials and techniques,* Solid waste management,* Water management,* Relations with visitors,* Urban greening.

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6 MONITORING:

Project components include allocations for environmental monitoring for each site. Higherlevels of environmental soundness of the project can be effectively realized by integratingenvironmental aspects into different activities and decisions of the project. Review of biddingand contract documents by an environmental specialist can be a very instrumental solution toachieve this target.

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ENVIRONMENTAL MANAGEMENT PLAN FOR PAMUKKALEA. MITIGATION PLAN

Institutional ResponsibilityPhase Component/issue Prevention / Mitigation Measure Install Operate

* Resettlement Action Plan (RAP) is being prepared as a separatereport.

Loss or deterioration * Turkish legislation regulating resettlement and construction activities No additional cost MoC/Demolition of ecologically requires environmentally sound site selection, site development and / included in the Govenorate/ Municipality

sensitive areas construction of dwellings project ContractorThreats to biodiversity * All environmental concems addressed through adherence toNoise, dust, legislation, project implementation and monitoring. No need forconstruction debris additional mitigation measure.

* Design of onsite sanitation system considering alternatives such as* Transportable toilets* Cesspits with vacuum truck transportation

Pollution of the water Small bore systemand travertines * Sewerage No additional cost

anraets* Combination of above / included in the Mo C Governate* Design of offsite sanitary facilities should be preferred with proper project

~ Construction sewerage connections (preferable use of them encouraged during siteof touristic presentation and orientations)facilities Dust * Water spraying to prevent dust

f Use of curtains and screening of the construction area* Use of machines equipped with appropriate mufflers and located No additional cost

Noise appropriately / included in the Mo C Governate* Work schedule should be determined to cause least disturbance to project

visitors; this may vary according to seasons* Use of trucks with covered dumpers No additional cost

Additional traffic load * Optimal use of alternative roads to prevent disturbance to the visitors / included in the Mo C Governateo and residents project

o : Specific onsite Visual and physical * Appropriately designed, manufactured and installed with due No additional costinetmns disturbance aesthetics attention paid to:Q (fencing, dsubneashtcatetopido:/ included in the Mo C Governate(fecig,size, color, material, design, location

ed signage, waste Maintenance replacement safetyofthestructures projectbins, etc.) Disharmony with site ,

values

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Institutional ResponsibilityPhase Component/issue Prevention/ Mitigation Measure Cost Install Operate

Pollution threat to the water of Timely maintenance of the system and follow-up No additional cost MoC/*: Pol klution threat to the waterofEnforcement of measures (do's and don'ts, forbidden activities and / included in the MoC/ Municipality

recommendations) envisaged in the Site Management Plan project

Design and implementation of waste handling system on sitesorting at source No additional cost

z *: Solid waste generated by visitors economic and rapid collection and removal from site / included in the MoC Municipalitytransportation to sanitary landfill under construction by Denizli Municipality project0) Providing information and encouraging participation through messages

O ____________________________________ incorporated into the site presentation

*: Threats to archeological and natural Strict obedience to recommendations of the site Management Plan (regarding No additional cost M Cvalues of the site maximum number of visitors at site any time and the allowed activities) project

Waste-water Determine the municipal administration to which the new resettlement areabelongs to and which will provide the infrastructure services.

Solid waste Resettlement Action Plan (RAP) is being prepared as a separate report and No additional cost* Resettlement provides for the necessary infrastructure (water, wastewater, solid waste) for / included in the Mo C Municipality

Noise the residents to be resettled. The undertaking of such activities and their projectenvironmental impact and mitigation will be included in design and

Traffic construction work.

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B. MONITORING PLAN FOR PAMUKKALE

Time CostEnvironmental Assessment of bidding and contract documents:Design consultants and contractors should be required to haveenvironmental skills on their team in order to pay particular attentionto environmental aspects including cultural protection and adherence 25.000 $ and more is implied as ongoing contractor and Ministry ofto local laws in undertaking their tasks. Project Management Units As required Environment Costsshould have access to environmental skills and advice where needed.ASPA, Ministry of Environment, will also have responsibility forreviewing and accepting plans in Pamukkale for construction andoperationsEnvironmental monitoring of the whole Pamukkale component Continuous $10,000 per yearincluding Resettlement

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ENVIRONMENTAL MANAGEMENT PLAN FOR MARDIN

A. MITIGATION PLAN

Cost Institutional ResponsibilityPhase Component/ ssue Prevention / Mitigation Measure Install Operate

Visual * Construction of the tank underground or camouflaging it

* Use of appropriate containers and vehicles whiletransporting the debris

* Use of water spraying to prevent dust during debris transportDebris * Selection of a suitable site for debris disposal, ensuring Provincial

*: Construction of active public participation No additional cost SpecialWater storage tank * Site rehabilitation of the debris site (leveling, alternative use, / included in the Administration, Municipality

e.g. park) project Municipality

. 0 Use of machines equipped with appropriate mufflers

c Noise * Operating times limited to normal working hours to bedetermined with due sensitivity to the citizens private life3 (such as, working on Saturdays near schools)

X Dust * Use of water spraying system, and curtains as required* Use of masks, work gloves and clothes by workers

Visual andphysical * Review and approval of design, construction and installation

* Street furniture disturbance starting with the stage of design TOR, procurement No additional cost Provincial

fenin, sigtnange, documents, and supervision.: No , , . Prov. Residents,fencing, signage, ,in./ cluded In the Special..waste bins, etc.) Aesthetics * size, color, material, design, location Visitors

waste bins, etc.) Aestheticsm* maintenance, replacement, safety of the structures project AdministrationDisharmonywith site values

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Cost Institutional ResponsibilityPhase Component/Issue Prevention / Mitigation Measure Install Operate

* Higher use of hand tools preferred to heavy machines* Use of machines equipped with appropriate mufflers

* Removal of street Noise * Engines of the drillers to be located appropriatelysurfaces * Operating times limited to normal working hours to be

Removal of determined with due sensitivity to the citizens private lifeinappropriate units, (such as, working on Saturdays near schools) Provincialinsulation material, * Use of water spraying system, and curtains as required No additional cost Ministry of Specialetc. from houses, Dust Use of masks, work gloves and clothes by workers included in the Culture, Administration,terraces and shops poetPUMunicipality

m Upgrading of water Use of appropriate containers and vehicles (donkey / tractor! project M cU

an eeag iigtruck)and sewerage pipng * Use of water spraying to prevent dust during debris transport

excavating Debris disposal * Selection of a suitable site, ensuring active public authorityapproval

* Site rehabilitation of the debris site (leveling, alternative use,X_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ e.g. park)

C * Use of water spraying to prevent surface dust." Dust * Use of masks, work gloves and clothes by workers

* Selection of a suitable technologyNoise - low impact blast method

* Cleaning of stone - non-toxicwalls, facades of - avoid harsh abrasives No additional cost Ministry of Residences,homes, religious Waste-water - easily portable equipment / included in the Culture, Municipalitybuildings, shops, etc. - biodegradable materials project PIU

- less wasteDebris - effluent safely disposable to sewerage system

preferablyAbrasion of - low water requirementstone surfaces

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Cost Institutional ResponsibilityPhase Component/Issue Prevention/ Mitigation Measure Install Operate

Use of environmentally sound protectives with followingproperties;

- biodegradable- non-toxic No additional cost

* Deterioration of restored stone - water-based (instead of solvent-based) inoldediin cos MoC, Residences,surfaces - non-flammable, fire resistant, non-sparking project PIU Visitors

- breathable to allow vapor out but impermeable to Jprevent moisture trapping

- antistatic- ultraviolet radiation protection

* Selection of appropriate design, size, color and material(timber, iron, copper, alloys, steel, etc.) respecting sitevalues

* Loyalty to original design and material in fenestration ofbuildings

* Use of local production techniques* Avoid using;

g - aluminum, PVC window frames- any pieces of asbestos emitting material

X A o m - mass production hinges and portals and windows(Approplateness of materal i grants - prefabricated and painted metal doors No additional cost M C.CD (replacement of doors, windows - laminated wood for doors / included in the oc, Residentsframes, shop windows, house and shop - aluminum doors project PIUimprovements - false material (stone-like, wood-looking, etc..)

- door, window frame paints and colors of choice- visible water containers, plumbing ,tanks,

destructing the aesthetics of the town (metal,plastic, PVC tanks, painted metal barrels, etc...)

- TV antennas on roofs / terraces- Bricks, concrete bricks, ceramic tiles, instead of

stone- Stone different from Mardin stone

* Use only Mardin stone or similar

* Better management through fixing of leaks and better No additional costo Depletion of water resources distribution of water will avoid waste, and enable more / included in the MoC Municipality

efficient use of existing resources. project

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Cost Institutional ResponsibilityPhase Component/issue Prevention / Mitigation Measure Install Operate

* Pollution caused by additional sewage * The project will not cause sewerage increases. No additional costreleased into the sewer system included in the Moc Municipality

* Improve solid waste collection and disposal system* Minimize wastes and sorting at source, enabling reuse and

* Low standard and capacity for solid recycling No additional cost* Improve the waste transfer points and transfer to disposal / included in the MoC Municipalitywaste handling site project

m * Design and implement an awareness raising to enhance localparticipation

* Compliance monitoring and enforcement by citizens councilO and municipality (Preparation and issuance of guidelines is

* Preservation of the restored important) No additional coststructures/surfaces * Prevention of vandal behavior and looting through public / included in the MoC Municipality

* Protecting heritage information and engagement of community, especially the projectyouth

* Preventing unauthorized construction, through publicinformation and strengthening municipality

B. MONITORING PLAN FOR MARDIN

Time Cost*: Environmental Assessment of bidding and contract documents. Design As required 50.000 $

consultants and contractors will be required to have skills that can addressenvironmental aspects, including cultural protection, and adherence tolocal laws. PMU will have access to advisory services on environment.

*: Environmental Assessment of materials to be procured, through the As required 50.000 $establishment of a negative list and adhering to it in the technicalspecifications. In addition, conservations laboratories in Turkey will beengaged to determine the quality and authenticity of the material as well astheir environmental impact..

*: Environmental monitoring of all Mardin Component related activities Continuous 5000 $ / month

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ANNEX 1: LIST OF BACKROUND REPORTS REVIEWED

1. Tunisia Cultural Heritage Project. World Bank 2000. PID 6985.2. Bosnia-Herzegovina Pilot Cultural Heritage Project. 191153. Pamukkale Physical Conservation Plan, Evaluation and Update Report. Emre Madran

and Nimet Ozgonul. 1992. (In Turkish).4. Scientific-Technical Research and Consultancy Services Project for the Conservation

and Development of the Proposed Travertines in the Pamukkale PhysicalConservation Plan Final Report. International Kars Water Resources Implementationand Research Center (UKAM) at Hacettepe University. July 1996. (In Turkish).

5. Oren-Pamukkale Baseline Survey Final Report. Sevin Osmay. September 15, 2001.6. Social Assessment Research. NUVIS Research Team.7. Karst Waters and Environmental Impacts. A.A. Balkema. Rotterdam, Brookfield

1992. Edited by Gultekin Gunay.8. Assessment and Update report of the Pamukkale 1992 Master Plan.9. Pamukkale Physical Conservation Plan, Working Group Report. June 31 - July 3,

1991. (In Turkish).10. Assessment Report for Environmental Rehabilitation of Pamukkale. TEMPO&UTTA11. GAP- Urban sanitation and Planning Project, Solid Waste Management, Waste

Collection and Transport, Final Report. J.V. Posch and Partners, TBU EnvironmentalEngineering Consultants, Kentkur, Su-Yapi. May 1999.

12. Turkey Community Development and Heritage Project Pamukkale Site managementPlan Draft Report, AKAN Mimarlik, December 2001.

13. Pamukkale Conservation and Development Project, Consultancy and ControlServices. 1st Interim Report. Hidrojeoloji, January 2002. Pamukkale University.

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ANNEX 2: PUBLIC CONSULTATION MEETING

PAMUKKALE(Summary minutes and conclusions of the meeting)

The consultant attended a stakeholder workshop in Pamukkale on 14th of February, 2002. Theattendants were as listed. The main outcomes of this workshop are as follows:

1. Tourists visit Hierapolis because of the uniqueness of the natural heritage, springwater and travertines besides historical ruins.

2. The old Hierapolis was also mainly structured on the healing properties of the hotsprings.

3. Prohibiting tourists from bathing and getting into physical contact with water withinthe Hierapolis area, will seriously affect the touristic potential of the area.

4. Damage to the travertines should be avoided through a well-monitored and managedsystem.

5. After demolishing the hotels within the Hierapolis area Karahayit had been designatedand constructed as the new hotel region.

6. Hot springs not related to Hierapolis within the Karahayit region are transferred to thehotels for bathing.

7. This minimizes the amount to be used for agriculture where dissatisfaction exists.8. Infrastructure of Karahayit settlement needs to be upgraded to be able to serve the

increase touristic stays in the region.9. Centralized decision-making should be minimized.

These main remarks are not any objections for the defined project, however, reflect veryvaluable ideas to be incorporated to enhance the environmental rehabilitation characteristicsof the Project.

List of Participants of the stakeholders workshop in Pamukkale

Name Institution, PositionAylin Tan World Bank/Cultural Heritage Project

Project Manager

Filiz Ozsuca World Bank/Cultural Heritage Project

Project Assistant

Douglas Comer CSRM, Contractor Cultural Site Management

Ministry of Culture

Eric Peterson World Bank Project Team

Maha Armaly World Bank Project Team

Muge Bahceci Ministry of Culture,

General Directorate of Monuments and Museums

Seda Aroymak World Bank

Buket Coskuner World Bank

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Ali Kal Karahayit Municipality. Council Member

M. Fahri Sapmaz Karahayit Municipality. Council Member

Hulisi Tosun Karahayit Municipality. Council Member

Osman Aca Karahayit Municipality. Council Member

Mehmet Efe Karahayit Municipality. Council Member

Ilkay Cibik Karahayit Municipality. Council Member

Mehmet Dere Karahayit Municipality.

Kenan Tufekci Patlio Co. Inc. General Director

Nureddin Kocak Pamukkale Tourism Association. Chief of Directorate

Abdi Simsek Anatolya Hotel Pamukkale Municipal Council Member

Halit Durmus Koray Hotel (Misling Tour)

Pamukkale Municipal Council Member

Veli Ates Pamukkale Municipal Council Member

Sait Yalcin Buldan Society for the Conservation of Natural and Cultural Life.

Chief.

Mesut Kuruoglu Denizli Weavers Association. Chief.

Avni Ocakcioglu Buldan Weavers Association. Chief.

Halis Yildiz Citizen of Oren District

Huseyin Acar Carpet Seller

Mehmet Durak Pamukkale Tourism Society. Accountant

Isa Levent Gurcadi Association of Tourist Guides. Member of Board of Directors

Tilen Kocasaban Patero Co. Inc.

Ali Akturk Turas Co. Inc. Manager.

Mehmet Yildiz Herakles Thermal Hotel. Manager

Osman Akkucak Pamukkale Municipality. Major

Fusun Ersoy Ministry of Culture. Advisor of Minister

Yahya Ozpinar Pamukkale University. Pamukkale Project Administration

Ahmet Daldaban Provincial Directorate of Culture. Director

Ibrahim Basgul Rural Affairs, Director

Mehmet Korkmaz Provincial directorate of tourism. Director

Ozden Candir Pamukkale University, Public Relations Office. Director

Inan Ozer Pamukkale University, Department of Economy and

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Administration, Dean of Faculty

Berkay Civicioglu Akan Architecture

Zafer Suzer Akan Architecture

Ercan Demirci Pamukkale University. Computer Center

Erkan Ceylan Lycus River Hotel

M. Mumin Kaya Pamuksu Hotel

Anir Balkanay Denizli Association of Architects, Chief.

Ahmet Yoldas Cekul, Representative of Denizli

Dr. Sakir Bayur Pamukkale Health Responsible

Pamukkale Tourism Society. Member of Board of Directors

Hikmet Sevil Pamukkale Tourism Society. Member of Board of Directors

Ihsan Demirhan Richmond Hotel General Director

Ali Riza Tekin Denizli Commerce Union. General Secretariat Deputy

A. Erhan Sarica Denizli Industrial Union. General Secretor

Fettah Anli Pamukkale Tourism Society. Member of Board of Directors

Mehmet Sarikligil Karahayit Municipality, Chief of Beyazit District

Sefa Bayaltun Tourism - Geology

Hacer Bayalter Demir Chemist in Pamukkale

Volkan Ucyildiz Architect

Mustafa Dasci Traverten Hotel Pamukkale

H. Huseyin Baysal Denizli Museum. Director

Mesut Bayram Architect, Denizli Union of Architects Member

Huseyin Gokdagsi Municipal Council Member

Kadir Sarac Pamukkale Municipal Council Member

Ayhan Turkmen Denizli Union of Civil Engineers. Department Secretary

Samil Cinar Denizli Union of Civil Engineers. Department Head

Sinan Erer Project Environmental Consultant

Abdullah Kaya Yoruk Hotel Director

Hasim Yildiz Directorate of Museum Archeologist

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CONSULTATIONS IN MARDIN

(Summary minutes and conclusions of the meeting)

The consultant made a field trip to Mardin, on 17 and 18 January 2002 and on 17 January

2002 attended to Citizens Council meeting, the citizens Council implementing the Local

Agenda 21 in Mardin, facilitated an efficient platform for consultations with the key

stakeholders on main issues with regards to the Community Development Project. The

meeting was chaired by the Mayor, and other participants represented various disciplines and

sectors of the local economy. The acting Secretary General of the Citizens Council was an

architect who gave particular concern on the restoration projects in the town. The meeting

agenda was based on the Consultant's description of the Community Development Project

and his questions on the cross-cutting issues. The discussion platform provided a

comprehensive understanding of the historical values and issues that relate to sustainability in

preserving these values. Sanitary infrastructure was one of the main topics, on which the

Mayor explained the needs for improving the sewerage network and supplying adequate

amount of water to the citizens.

Further consultations with the Mayor, his staff at the municipality and the Governor indicated

at deficiencies in the existing water management system that could be solved with basic

engineering solutions.

The Consultant visited the pilot street selected for the street improvement component. The

site visit was assisted by architects and members from the Citizen's Council, that gave

explanations on the conditions of the buildings and the needs of the street improvement

process. The site visit was very indicative in terms of estimating extent of possible impacts of

the improvement works. The Consultant also paid a visit to the Merdinar, a historical building

restored with the support of UNDP and allocated as the Local Agenda 21 office. The site

visits were completed with the end point of the pilot street, where a semi-close market space

was restored within the scope of the Local Agenda 21 efforts.

27