Turkey - Community Development and Heritage Project : environmental management plan

E562 March 2002 THE WORLD BANK TURKISH REPUBLIC MINISTRY OF CULTURE COMMUNITY DEVELOPMENT AND HERITAGE PROJECT ENVIRONMENTAL MANAGEMENT PLAN DRAFT REPORT March 2002 Prepared by R. Sinan Erer FILE COPY  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 ................................................. 10 2.2.1.2 Sewerage System and Wastewater Management ......................................... 11 2.2.1.3 Solid Waste Management ................................................. 12 2.2.2 Impacts of Project Investment Items ....................................... 12 2.2.2.1 Masonry work ................................................. 12 2.2.2.2 Cleaning of stone walls ................................................. 13 2.2.2.3 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 Environmental Management Plan of the "Community Development and Heritage Project" in Turkey. The Consultant studied thoroughly the World Bank Publication "Environmental Assessment Sourcebook" and its updates as well as the World Bank Operational Policy 4.01 on Environmental Assessment to get proper guidance and to be able to evaluate and present his findings in the expected way. The consultant initiated the work with a review of the proposed project components and an assessment of their potential environmental impact. The Environment Management Plan was elaborated based on this assessment, following consultations with relevant stakeholders and discussions with national and local govemment officials, Project Management Unit Staff, and World Bank staff. The ToR describes the activities envisaged in the project and cites several investment items such as establishment of a visitor center, resettlement of 95 households in Pamukkale, and street improvements, upgrading basic infrastructure, buildings and public spaces renovation in Mardin. The Consultant is expected to assess the impacts on the environment and provide a management plan, and recommend measures to prevent, minimize, mitigate or compensate for 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 public consultations in Pamukkale and Mardin provided in Annex 2) 1.1 Legislative Base None of the project activities require environmental impact assessment review, according to the 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 in Pamukkale) are to be newly developed for the proposed project activities, then, govemment procedures require a review of environmental impacts. The contractors will be responsible for contacting quarries. In Pamukkale, given the relatively routine nature of the construction, it is expected that existing quarries will be used, which already have the necessary environmental clearances. In Mardin, the need for additional stones is not large, and it is also expected that the need will be covered from existing quarries. The Contractor will need to apply to the corresponding Governorates in Mardin and Denizli to obtain the relevant permits. According to the EIA regulation, the provincial environmental committees decide whether the environmental impacts of the quarries in question are significant or not, based on review of the environmental reports. 2  Environmental issues such as noise, dust, air pollution, water pollution, solid waste management, are dealt with in accordance with corresponding regulations in effect. Without exception, the construction/restoration plan of each individual unit in Mardin is subject 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 and Natural Assets, Authority for the Specially Protected Areas (ASPA) under Ministry of Environment 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 enhace cultural heritage management through the engagement of local communities to sustain the protection efforts and to benefit them from the proposed investments. The activities under the project address the objective, and will adhere to national and intemational standard requirements for the protection of cultural heritage. The Site Management Plan itself proposes modem management techniques fo cultural heritage sites. For example, Pamukkale will be surveyed to record the significance of the site, and to ensure appropriate treatment of any chance finds during construction; also contracts for construction and supervision should be 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 the old city, by using traditional materials. Turkish law requires the reporting of any finds during construction. 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 "Turkey Community Development and Heritage Project" and evaluating the components, the Consultant considers that the Project itself is an environmental rehabilitation project. Environmental soundness and sustainability of the project is assured and further reinforced owing 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 the Project have been considered to cover additional, if any, components to complement the "environmental rehabilitation approach" of the project. The Consultant used some outside expertise and assistance to be able to complete his assignment within the contract period which seemed to be tight due to the time constraints of project preparation. 3  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 95 households from the Oren district, which lies within the protected archeological area designatedfor Pamukkale in 1981. For this, it will provide the necessary infrastructure and housing construction, and would also aim to integrate the resettled residents of Oren into the economic activities of the Pamukkale site through providing possibilities to develop related touristic and commercial activities". The ToR also asks the Consultant to evaluate the adequacy of infrastructure of the resettlement. The Resettlement Action Plan (RAP) is being prepared as a separate component of the project. The implementation of RAP should incorporate appropriate environmental dimensions into different stages and activities. The RAP approach also necessitates a thorough understanding of the values, expectations and life styles of the residences of Oren and their relations with their immediate environment. Consequently, all environmental parameters or factors affecting, shaping, defining and contributing to the living environment or to the quality of the resettlement area are taken into account at earlier stages of resettlement actions. In other words, initially during selection and planning of the site, and later, during planning and construction of dwellings it is important to make all environmental considerations intrinsic components of the Resettlement. The RAP considers these issues during different stages 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 4  - 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 considers how they will become real partners of the project. This plan is being prepared and implemented with a participatory approach. Citizens' ownership and integration with project objectives will promote partnership enhancing socio-economic development, eventually minimizing negative connotations of the involuntary aspects of the resettlement. Such a "voluntary" resettlement can only be realized through a long process that is defined as a 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 the project and so to the environment. The RAP has been submitted separately. It addresses the basic needs of the population in terms of infrastructure and other services including water, wastewater and sewerage to restore or improve their living standards to levels prevailing prior to the resettlement. In addition, Turkish legislation regulating resettlement and construction activities requires environmentally 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 existing water resources. So it is not expected to face conflicts in water use. Ongoing whitening schedule of travertine terraces will not be negatively affected. Pamukkale component is mainly based on the preservation of the natural and cultural heritage i.e. springs and travertine formations on which the historical settlement had been structured. Therefore Environmental Management Plan should be mainly based on the concept of sustainable management of the water (hot springs) within the area and protection of travertine terraces while ensuring sustainable promotion of them and the historical heritage. The baseline study enabling decisions for Sustainable Water Management was conducted by Hacettepe University, International Karst Water Sources Application and Research Center (UKAM), which was completed in July 1996. The major approach and the findings of this study in relation to Sustainable Water Management can be outlined as follows: * The study mainly approached water management in terms of rehabilitation and preservation of the natural heritage - the travertine terraces. * The study suggested demolition of existing hotels and prohibiting direct utilization of travertine terraces (i.e. bathing and wading) 5  * A conceptual plan was prepared for a channel distribution system that enables even supply 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 and stormwater from the area. Already implemented suggestions are: * Four motels have been demolished. Concrete basements and pools (empty) are left remaining. One facility that belongs to the Provincial Special Administration is partly demolished and is still under operation. The demolition of the last facility is part of the environmental mitigation plan, and is included in the government's program for the first and 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 Emre Madran and Nimet Ozgonul for the Ministry of Culture and the recently completed "Pamukkale Site Management Plan" prepared by Akan Mimarlik, OAU and Past Forward partnership both suggest that a 1/5,000 scale master plan for land management and utilization be prepared for the region defined by historical and natural sites, as well as Pamukkale and Karahayit settlements. As previously mentioned, the study executed by Pamukkale University covers the designs of the channels to manage the water (hot springs) onto the travertines and overflow from the travertines to be used by the farmers. On the other hand, UKAM study suggested restriction of water for agricultural use which could have a negative impact on a major stakeholder, the community of farmers, possibly jeopardizing local ownership. This suggestion has not been implemented. 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 Land Management and Utilization Plan to be prepared by Authority for the Specially Protected Areas (ASPA) together will constitute a "Comprehensive Land and Water Management Plan" ensuring interalia "Sustainable Water Management". 6  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 an iterative methodology, which is considered to be very appropriate by the Consultant. Is is true that a sound plan also enables management of the visitations so prudently that carrying capacities are not exceeded and sustainability is assured. The target visitation rates envisaged in Pamukkale Site Management Plan are estimated to be well below the carrying capacity of the natural site and travertine area, Water supply and wastewater systems should be appropriately designed and implemented to ensure that water quality is not deteriorated and carrying capacity not negatively affected. On the other hand, owing to the historical nature of the site it is not possible to install a proper underground 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 used under strict guidance of the excavation team, * Location of the toilets, to be mainly outside of the site at the service areas, and to locations 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 "Pamukkale Site Management Plan". The plan report covers suggestions, general description of these items and approximate locations. The Consultant doesn't envisage adverse impact of these structures on biodiversity and to cause any noise, air and land pollution. However, if not located and constructed properly there may be adverse effects on the water quality and also the quality of travertines. To prevent any such negative impact, Consultant suggests that the location of these structures should be determined in close cooperation with the site management team during later stages of project implementation. The other major recommendation of the Site Management Plan is to enable visitors to make use of hot springs and baths because this is considered to be an attraction for tourists. On the other hand, UKAM Report suggests that no bathing should take place to ensure preservation of the quality of travertines. Consultant is of the opinion that, if properly designed and managed, travertine terraces can be protected while providing limited use. The possible design criteria can be: * provision of shower facilities to be used before entering the pool for minimizing pollution from the bathers, * provision of a separate discharge system so that the overflow of water from the bath pools is not discharged on to the travertines but possibly directly to the agricultural areas 7  Any decision on the location and design of the bathing facilities should be reviewed by environmental specialist. The proposals to direct water from the travertines to the historic Bath, while building conveyance channels to collect water and distribute it to framers is not expected 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 corresponding environmental 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 for the visitors. Unless all other alternative methods and techniques are exploited, use of insecticides should be avoided. 2.2 Mardin Component This component of the Project envisages rehabilitation and upgrading of the old town of Mardin thus improving livability and urban conditions in the area. It is expected that the project starts contributing to socio-economic development at earlier stages of project implementation through measures to utilize project resources mainly in Mardin by the people of Mardin. Approaches of the Consultant, as delineated in the Work Methodology Report, have been augmented and developed with the consultation process in Mardin. Prior to the consultation with individuals, the Consultant participated in a meeting of the Citizen's Council on 17 and 18 January 2002. 8  The Citizens' Council is a self organized group composed of representatives of Mardin's civil society and NGOs, ex officio members from the provincial bureaucracy including the Govemor. The Council is formally headed by the Mayor, though spokespersons for the Council's consultative processes and its day to day leadership ranges from the Bar Association to the Architects Association. Since its foundation, the council has met regularly to establish a city vision and to advocate for Mardin at various political and economic platforms. The Council embraces some 60 institutional and personal participants including the govemor, mayor, public officials and participants from local civil society (Chambers of Commerce, Trade, Industry; craftsmen, artisans, business associations; professional chambers of architects, engineers; cultural and religious foundations, etc.). The Citizens Council has been discussing participatory urban rehabilitation in Mardin ever since it was founded. One of the main areas of focus for the Council has been its participation in the formulation of the UNDP proposal to the MoC for the Mardin Component under the cultural heritage. So, the proposed World Bank financed project is a proper instrument for the people of Mardin in facilitating their long-term objectives. That is why the Council dedicated two of its "extraordinary" sessions, one in October and one in November 2001, to review the World Bank's cooperation with the MoC targeting Mardin. The decisiveness of Mardin people, local ownership and leadership exemplified in Citizens Council activities will certainly contribute to socio-economic development through protection and promotion of cultural heritage in the long run. Members of the Citizen's Council are very eager to proceed with the project implementation and are keen to ensure the project's efficient implementation and sustainability. Their vision for 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 and sufficient water at the top of their list of priorities. It is evident that the civic platform established via the Local Agenda 21 process will be very much strengthened with the Community Development and Heritage Project. The assessment of the project's potential environmental risks and impacts in the urban area of Mardin has brought about issues significant to the decision making toward sound and sustainable outcomes of the project. The following sections highlight the public health implications of the current problems in the available infrastructure system, as well as the significance of synchronicity between civil works in street upgrading (mainly geared to the visible supra-structure) and unavoidable upgrading of infrastructure (mainly geared to water supply lines, sewerage as well as concealing electricity and telecommunication cables). Mardin component will be evaluated under the sub-components of: * Needs for Upgrading of Infrastructure * Impacts of Project Investment Items 9  2.2.1 Needs for Upgrading of Infrastructure Assessment of the existing environmental situation and available infrastructure reveals the current problems in buildings and in infrastructure. Needs for upgrading of infrastructure are considered 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: Regular supply of water has been a big problem in Mardin for years. Although, not directly relevant to the project itself, water supply is an important factor to be solved in terms of the expected outcome of the project which is to contribute to the tourism potential of Mardin. Because water leakages are affecting the historic structure and bad drainage leakages are not appropriate for the architectural city ambiance. There is a consensus that highest priority should be given to solving this chronic issue. It is obvious that, first, for the people of Mardin and then if Mardin is to become a tourist attraction, regular supply of clean water and efficiently operating sewer network are sine quanons. 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 the needs of the citizens for centuries. This important task was accomplished through a special state of mind, respecting sustainability and balance between supply and demand sides of water 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 are said to be 2m x 2m), and fountains. The Yahudiyye and the Cevheriye fountains are reported to be within the neighborhood which houses the Synagogue, the Zeyd Mosque and Surp Kevork Church. Neighbours from different religions have shared a scarce natural resource never making it an issue of conflict. Most probably those people in the past never thought that 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 town could further be studied and be included in site presentation plan. It is assumed that, as in Pamukkale, a site presentation plan be prepared and implemented in Mardin. The heritage in this area is an integral part of the other assets which people are trying to mobilize to increase tourism incomes and socio-economic development. On the other hand during discussions with the municipality, it was mentioned that water supply to the town was at 250 liters/second which meant close to 300 liters of water per person 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 be supplied to some households once a week, needs further in-depth engineering studies and analysis. The authorities later reported that the actual water supply was 1501/s as against 2501/s capacity. 10  A deeper assessment of the water supply system reveals some handicaps in the urban water management. Water is supplied to the town from wells at the northem part and pumped to storage tanks. Water is transmitted through the main trunk that lies beneath the main street and connects to the secondary lines in the inner roads. Water distribution starts at the upper elevations and flows in decreasing amounts towards the lower end. Lack of control valves and single trunk surrounding the town accounts for the irregular and inequitable water supply to the citizens. As a preliminary engineering approach, the project aims to provide a water storage unit (estimated at 1500 cubic meters) to be constructed at the northeastern part of the town. This can be an intermediate solution to supply equivalent amount of water to the two sections of the city on the basis of population. In the medium term, the distribution network for the whole town has to be studied thoroughly to detect leakages and improve the system accordingly. 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 are narrow, about 1 meter in width, and that there is evidence of contamination of tap water from sewage leaks. The project should address this issue in its intervention, and the city should look into this risk and assess it in details in an attempt to eliminate this risk. The narrowness of the roads is a factor to be considered in terms of civil works that may be conducted in parallel to the street upgrading schedule. Discussions with the Authorities led to considering different alternatives to solve the problem. Constructing a water tank on the eastern part of the town, close to the Citadel, and working on demand side of water management also, instead of million dollar worth water supply projects to be realized in the future, were among the alternatives considered. The consultant is not saying at all that there is an easy, one -minute, solution to a decades lasting problem of a big town, however it is worthwhile to study different aspects of water management in Mardin. Otherwise it will be ironic to be proud of a heritage, which has solved water issues ingeniously many centuries ago, while suffering from lack of quality services today. 2.2.1.2 Sewerage System and Wastewater Management The project addresses the leakages in the water supply and sewerage networks that frequently cause humidity at the basements of the buildings and damage building walls. This draws concerns on the quality of the infrastructure and the plumbing inside the buildings. During the Consultant's consultations with people from Mardin, especially the elderly, it was mentioned that at the beginning of the last century, Mardin old town had a remarkable and an efficiently operating sewer system collecting all the sewage to the foot of the mountain where, 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 its history, its plan, dimensions etc. could not be obtained. While it is worthwhile to study and investigate it for its historical value and demonstrate as part of the cultural heritage, it is also essential to consider repair of the plumbing in the houses as well. Health risks rising from the intrusion of leaks into the water supply lines indicate the need to consider respective locations of the water supply and sewerage lines. The project will address this problem in the sections of the street improvements that is included in the project, and the city should undertake a deeper study and actions to eliminate this risk (see section above on water supply system) 11  2.2.1.3 Solid Waste Management As for collection and sanitary disposal of solid wastes, Mardin was one of the five pilot cities where the GAP Regional Development Administration had contracted a Feasibility Study for Urban Sanitation and Planning Project, Consultancy Services in 1998-1999, with financial assistance of the World Bank. Results of the Study component for Mardin can be outlined as follows: * 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 to truck (loaded by tractor loader) which is currently done at 6 points in the city. The upgrading of these points is recommended by using curbs specially designed for donkeys. The solid waste management topic was contemplated by the UNDP Technical Assistance Team (TAT) with a view toward ensuring complementarities in relation to the Street Improvement component of the Project, and supporting the overall cultural preservation necessities of the site. The Consultant has reviewed TAT's project framework based on a participatory approach, and agrees on the overall context, but with the incorporation of the curb system and sanitary transfer points as recommended in the GAP RDA Study Report mentioned above. Sorting of recyclables can be made at the transfer points as the same report suggests. 2.2.2 Impacts of Project Investment Items Major project investment items with potential environmental impacts will take place at the construction 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 to make improvements to the exterior of their shops, The beneficiaries will be using the project funds (sometimes with cost-sharing) for such activities as masonry work, terrace insulation, blasting, chemical cleaning of facade walls, constructional repairs, and home sanitation. Environmental aspects of such activities are outlined in the following sections. 2.2.2.1 Masonry work Stones used in Mardin architecture needs thorough analysis in a specialized laboratory, and certain tests have to be performed. Based on this information, the closest alternative stone quarries 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 while transporting in the reverse direction inappropriate concrete or other cladding, insulation material, from removal of inappropriate units, terrace insulation, etc. will be a source of series of environmental problems such as noise, dust, transporting possibly up to a certain point on horse-back and then by tractors or/and trucks. 12  2.2.2.2 Cleaning of stone walls' Facade walls have been cleaned by using hand tools until now. However, considering the immense work to be conducted during the project, the experts propose a suitable blasting technique. Consultant proposes that while conducting tests to the Mardin stone, proper type, intensity, depth and technique for blasting, should be determined by conducting special tests under expert supervision. This will naturally be a trial and error procedure. Blasting equipment manufacturers recommendations for worker safety and health should be strictly followed. Should any additional measure be determined based upon the tests performed, they should also be taken into account. During preparation of the project, experts mentioned the use of some protective chemicals and chemicals for cleaning purposes. Although the type, amount and place for these chemicals have not been determined, it is recommended to use less of them, with caution, preferably biodegradable types, without altering fundamental characteristics of the base material (stone or wood). Their containers should also be disposed of properly A list of chemicals that are not to be used are mentioned in the Mitigation Plans in tabular forms attached. 2.2.2.3 Public Spaces and Buildings. Street improvement Street areas including neighborhood squares amount to about 15,000 m2 horizontal area. Most of this surface is covered by inappropriate concrete which needs to be removed. The debris that has to be removed will be between 6,000 to 10,000 tons. It is important to note here that bulk of this load will have to be first carried on horse-back, to possibly a tractor and then to a big truck to benefit from transportation cost. Nevertheless over 1000 truck-loads of debris is a huge 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 to be transported. This requires further analysis and official consultations with related govemment agencies such as environment, health, agriculture, forestry housing and construction departments under the Govemors office and other stakeholders. The public should also be involved in the decision-making. The stone and other material required for street surfaces will double the transportation problems and amounts. Street improvement includes approximately 24,000 m2 of vertical stonewalls to be cleaned and repaired. The environmental aspects of blasting to clean public spaces and building should also be considered during this process as mentioned above for households and shops. It is of utmost importance to thoroughly upgrade the water piping, sewer network, and laying electricity and communication cables under the ground while conducting the street improvement program. This in tum will remove visual barriers to the exciting silhouette of Mardin. Repair and upgrading of infrastructure is also justifiable from the point of view of decreasing water losses and leakages (clean and waste) resulting in humidity problems in the houses 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 given highest priority. 13  3 CONCLUSION The Consultant is satisfied and feels confident in concluding that the project is environmentally 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 is basically 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 Protected Areas * Participation strategy of the Project to include all the stakeholders including public agencies 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 representation of the environmental assessment and management issues is presented in the Mitigation Plans in tabular forms. 4 RECOMMENDATIONS: It is not expected to face serious environmental challenges during implementation of the project activities because project objectives do not have any conflicting issues with environmental sustainability. However, in order to strengthen the comprehensiveness and integrity 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 be sought and these efforts should be strengthened via awareness-raising and training activities in 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. 14  6 MONITORING: Project components include allocations for environmental monitoring for each site. Higher levels of environmental soundness of the project can be effectively realized by integrating environmental aspects into different activities and decisions of the project. Review of bidding and contract documents by an environmental specialist can be a very instrumental solution to achieve this target. 15  ENVIRONMENTAL MANAGEMENT PLAN FOR PAMUKKALE A. MITIGATION PLAN Institutional Responsibility Phase Component/issue Prevention / Mitigation Measure Install Operate * Resettlement Action Plan (RAP) is being prepared as a separate report. 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 Contractor Threats to biodiversity * All environmental concems addressed through adherence to Noise, dust, legislation, project implementation and monitoring. No need for construction 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 system and 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 site of 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 Governate o and residents project o : Specific onsite Visual and physical * Appropriately designed, manufactured and installed with due No additional cost inetmns 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 project bins, etc.) Disharmony with site , values 16  Institutional Responsibility Phase 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 site sorting at source No additional cost z *: Solid waste generated by visitors economic and rapid collection and removal from site / included in the MoC Municipality transportation to sanitary landfill under construction by Denizli Municipality project 0) 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 C values 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 area belongs 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 project environmental impact and mitigation will be included in design and Traffic construction work. 17  B. MONITORING PLAN FOR PAMUKKALE Time Cost Environmental Assessment of bidding and contract documents: Design consultants and contractors should be required to have environmental skills on their team in order to pay particular attention to environmental aspects including cultural protection and adherence 25.000 $ and more is implied as ongoing contractor and Ministry of to local laws in undertaking their tasks. Project Management Units As required Environment Costs should have access to environmental skills and advice where needed. ASPA, Ministry of Environment, will also have responsibility for reviewing and accepting plans in Pamukkale for construction and operations Environmental monitoring of the whole Pamukkale component Continuous $10,000 per year including Resettlement 18  ENVIRONMENTAL MANAGEMENT PLAN FOR MARDIN A. MITIGATION PLAN Cost Institutional Responsibility Phase Component/ ssue Prevention / Mitigation Measure Install Operate Visual * Construction of the tank underground or camouflaging it * Use of appropriate containers and vehicles while transporting the debris * Use of water spraying to prevent dust during debris transport Debris * Selection of a suitable site for debris disposal, ensuring Provincial *: Construction of active public participation No additional cost Special Water 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 be determined with due sensitivity to the citizens private life 3 (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 and physical * 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 Administration Disharmony with site values 19  Cost Institutional Responsibility Phase 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 appropriately surfaces * Operating times limited to normal working hours to be Removal of determined with due sensitivity to the citizens private life inappropriate units, (such as, working on Saturdays near schools) Provincial insulation material, * Use of water spraying system, and curtains as required No additional cost Ministry of Special etc. 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 authority approval * 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 technology Noise - low impact blast method * Cleaning of stone - non-toxic walls, facades of - avoid harsh abrasives No additional cost Ministry of Residences, homes, religious Waste-water - easily portable equipment / included in the Culture, Municipality buildings, shops, etc. - biodegradable materials project PIU - less waste Debris - effluent safely disposable to sewerage system preferably Abrasion of - low water requirement stone surfaces 20  Cost Institutional Responsibility Phase Component/Issue Prevention/ Mitigation Measure Install Operate Use of environmentally sound protectives with following properties; - 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 J prevent moisture trapping - antistatic - ultraviolet radiation protection * Selection of appropriate design, size, color and material (timber, iron, copper, alloys, steel, etc.) respecting site values * Loyalty to original design and material in fenestration of buildings * 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, Residents frames, shop windows, house and shop - aluminum doors project PIU improvements - 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 cost o Depletion of water resources distribution of water will avoid waste, and enable more / included in the MoC Municipality efficient use of existing resources. project 21  Cost Institutional Responsibility Phase Component/issue Prevention / Mitigation Measure Install Operate * Pollution caused by additional sewage * The project will not cause sewerage increases. No additional cost released 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 Municipality waste handling site project m * Design and implement an awareness raising to enhance local participation * Compliance monitoring and enforcement by citizens council O and municipality (Preparation and issuance of guidelines is * Preservation of the restored important) No additional cost structures/surfaces * Prevention of vandal behavior and looting through public / included in the MoC Municipality * Protecting heritage information and engagement of community, especially the project youth * Preventing unauthorized construction, through public information 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 address environmental aspects, including cultural protection, and adherence to local 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 technical specifications. In addition, conservations laboratories in Turkey will be engaged to determine the quality and authenticity of the material as well as their environmental impact.. *: Environmental monitoring of all Mardin Component related activities Continuous 5000 $ / month 22  ANNEX 1: LIST OF BACKROUND REPORTS REVIEWED 1. Tunisia Cultural Heritage Project. World Bank 2000. PID 6985. 2. Bosnia-Herzegovina Pilot Cultural Heritage Project. 19115 3. 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 Physical Conservation Plan Final Report. International Kars Water Resources Implementation and 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&UTTA 11. GAP- Urban sanitation and Planning Project, Solid Waste Management, Waste Collection and Transport, Final Report. J.V. Posch and Partners, TBU Environmental Engineering Consultants, Kentkur, Su-Yapi. May 1999. 12. Turkey Community Development and Heritage Project Pamukkale Site management Plan Draft Report, AKAN Mimarlik, December 2001. 13. Pamukkale Conservation and Development Project, Consultancy and Control Services. 1st Interim Report. Hidrojeoloji, January 2002. Pamukkale University. 23  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. The attendants were as listed. The main outcomes of this workshop are as follows: 1. Tourists visit Hierapolis because of the uniqueness of the natural heritage, spring water and travertines besides historical ruins. 2. The old Hierapolis was also mainly structured on the healing properties of the hot springs. 3. Prohibiting tourists from bathing and getting into physical contact with water within the Hierapolis area, will seriously affect the touristic potential of the area. 4. Damage to the travertines should be avoided through a well-monitored and managed system. 5. After demolishing the hotels within the Hierapolis area Karahayit had been designated and constructed as the new hotel region. 6. Hot springs not related to Hierapolis within the Karahayit region are transferred to the hotels 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 very valuable ideas to be incorporated to enhance the environmental rehabilitation characteristics of the Project. List of Participants of the stakeholders workshop in Pamukkale Name Institution, Position Aylin 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 24  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 25  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 26  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