Turkey - Anatolia Watershed Rehabilitation Project : environmental assessment (Vol. 2 of 2) : Dam safety for disclosure

ANATOLIA WATERSHED REHABILITATION PROJECT Dam Safety For Disclosure E695 vol. 2 2003 Summary Under the income generation component, the project will finance small scale irrigation, including the construction of concrete ponds, diversion weirs and small dams. Highest priority will be given to irrigation ponds at strategic places throughout microcatchment areas as this will allow the project to reach the largest number of beneficiaries. The construction of dams will only occur only in microcatchments with extreme water shortage. Based on the experience with the earlier East Analtolia Watershed Project (EAWP), these dams are expected to be small dams, less than 15 high. The implementing agency for this component, KHGM, has long experience with the design, construction and maintenance of over 600 small dams throughout the country. During project preparation and appraisal, it was determined that KHGM has the relevant knowledge and experience to design, construct and maintain small dams and that it has proper design standards to guarantee the safety of small dams. Operation and routine maintenance of irrigation infrastructure will be the responsibility of beneficiary communities under the supervision and guidance of KHGM. Under the project KHGM will provide relevant local communities with training on dam surveillance, operation and management to assure that they can effectively carry out their responsibilities. Although it is unlikely that the project will include construction of dams higher than 15 meters, a panel of independent experts, consisting of a dam engineer and a hydrologist with qualifications satisfactory to the Bank, has been designated who would be called upon to carry out an independent review of the investigation, design, and construction of the dam and the start of operations, as spelled out in OP 4.37. No private land will be acquired for the construction of dams and resettlement is therefore not an issue.   ANATOLIA WATERSHED REHABILITATION PROJECT Dam Safety For Disclosure Under the income generation component, the project will finance small scale irrigation, including the construction of concrete ponds, diversion weirs and small dams. Highest priority will be given to irrigation ponds at strategic places throughout microcatchment areas as this will allow the project to reach the largest number of beneficiaries. The construction of dams will only occur only in microcatchments with extreme water shortage. Based on the experience with the earlier East Analtolia Watershed Project (EAWP), these dams are expected to be small dams, less than 15 high. The implementing agency for this component, KHGM, has long experience with the design, construction and maintenance of over 600 small dams throughout the country. During project preparation and appraisal, it was determined that KHGM has the relevant knowledge and experience to design, construct and maintain small dams and that it has proper design standards to guarantee the safety of small dams. Operation and routine maintenance of irrigation infrastructure will be the responsibility of beneficiary communities under the supervision and guidance of KHGM. Under the project KHGM will provide relevant local communities with training on dam surveillance, operation and management to assure that they can effectively carry out their responsibilities. Although it is unlikely that the project will include construction of dams higher than 15 meters, a panel of independent experts, consisting of a dam engineer and a hydrologist with qualifications satisfactory to the Bank, has been designated who would be called upon to carry out an independent review of the investigation, design, and construction of the dam and the start of operations, as spelled out in OP 4.37. No private land will be acquired for the construction of dams and resettlement is therefore not an issue.   ANATOLIA WATERSHED REHABILITATION PROJECT Pest Management and the Use of Pesticides For Disclosure Summary The only sub-component of the Anatolia Watershed Rehabilitation Project which may involve the use (but not the purchase with IBRD or GEF funds) of abiotic pesticides is the component which results in the production of tree seedlings. The project will not be directly financing the purchase of pesticides, but the agents contracted for nursery production may use pesticides in conjunction with tree seedling production. The Regional EA reviewed current practice in the use of pesticides for tree seedling production in Turkey. The REA describes 'best practice' pesticide handling in tree seedling production, and recommends that these practices are incorporated into the contracts of sub-contracted agents. Other project components seek to reduce the use of abiotic pesticides in farming systems in Turkey, by providing training in safe handling and management. The project will not, however, be financing the purchase of any pesticides. (It should be noted that early plans to involve the use of biotic controls of forest pests have been dropped.) Pesticide Use and Agricultural Policy in Turkey The fundamentals of Turkish agricultural policy is determined according to commitments stemming from the World Trade Organization- Agreement on Agriculture, developments in the EU common agricultural policy (CAP) during the pre-accession period, and finally, developments in international trade. Turkey's VIIIth. Five-year Development Plan adopted in the year 2000 in the Grand Assembly, comprises agricultural policies to be implemented between 2001-2005. Priority will be given to alternative combat methods, particularly to the Integrated Pest Management (IPM) methods and biological control methods. Minimizing the negative environmental impacts of agricultural production is a policy priority. In addition to the measures that will be taken in this respect, for application of fertilizers, pesticides and irrigation will focus on being natural and environment friendly. Input subsidies for fertilizers and pesticides will gradually be decreased and phased out. In compliance with EU legislation, production of organic (ecological) products that respect plant, animal and human health will be encouraged. Legal Framework Regulating Pesticide use in Turkey Turkey is a signator of the Rotterdam Convention covering the use of chemical control agents (CCA). In compliance with the National Environmental Action Plan (NEAP) of Turkey, the pesticide supports were differentiated according to the toxicity of active gradients of the pesticides with the issued communiques, in order to phase out the use of pesticides, which are hazardous for the environment and human beings.' The Aqua Products Law (No. 1380 of 1995) i The use of following pesticides is banned in Turkey: 2,4,5-T, Aldrin, Binapacryl, Captafol, Chlordane, Chlordimeform, Chlorobenzilate, DDT, Dieldrin, Dinoseb and its salts, HCH (mixed isomers), Heptachlor, Hexachlorobenzane, Lindane, Pentachlorophenol, Hg (Mercury) compounds, Endrin, Leptephos, As (Arsenic) comnpounds, Fluorodifen, Chlorpropylate, Daminozide (Alar 85), Taxophane, Zineb, Azinphos  gives a list of pesticide concentrations allowed in inland water bodies, and is appended to this document. There is a guideline on products for phyto-sanitation published by the MARA General Directorate of Protection and Control (Plant Protection Products 2002, MARA, TISIT, Istanbul, 2002). Also, there is legislation regulating the certification of pesticides and limitations to their use. These are: * Directive On The Method And Principles Of Registration Of Pesticides And Similar Agents Used For Plant Protection. * Regulation on Labelling of Pesticides. * Instruction on Prospectus for Pesticides. * Instruction for the Toxicological Classification of Pesticides. * Directive on Whole and retail Sales of Agrochemicals. * Directive on Control of Agrochemicals. * Pricing of the Imported or Locally Formulated Products. The Soil Pollution Control Regulation was enacted by end 2001. It aims to regulate all activities, which cause soil pollution and delineate the technical, administrative principles as well as criminal sanctions related to discharging, throwing, leaking of hazardous substances and wastes into soil, use of sludge from industrial and sewage treatment plants and compost on soil. Limits of the heavy metals, sodium, chlorine ion, pesticides, PCBs and some aromatic hydrocarbons in the soil are listed in the Annexes of the regulation. Beside the above-mentioned environmental legislation, there is some agricultural legislation, which is related to nutrient and pesticide use: Inspection of Chemical Fertilizers, Permit Regulation for Pesticides Production, Storage and Sale. Screening Project activities for Environmental Impacts related to Pesticide Use The use of pesticides during project implementation was considered during preparation. The only component in which pesticides may be used by agents who are contracted by the project is with respect to the production of tree seedlings in forest nurseries. The screening matrix and proposed mitigation steps are outlined in Table 1. The more general issue of pesticide use in farming systems in Turkey will be addressed through various other project activities to promote reduced - and safe -- pesticide use. Many farmers are unfamiliar with storage, the correct application rate or the clothing that should be worn during application. They also have superficial knowledge about the storage and use of fertilizers, especially organic fertilizers, and its application on rainfed and irrigated land. The project will seek opportunities to train staff about these important elements as well as the need to test soils. There should also be general environmental training and field visits. The training of trainers (extension workers etc.) in the above topics should be undertaken twice a year for the first four years with refresher courses once per year for the last three years. This may be combined with other training. Each course should last about one week, including visits to demonstration units. The cost of such training courses including CCA handling consultants, fertilizer experts, and trained staff from MoE, MoF and MARA should be between US$ 20,000 to 25,000 per course. ethyl, Dibromochlorpropan (DBCP), Methylarsenic (MSMA). From the list of pesticides, which are subject to PIC (Prior Informed Consent) according to the international legislation only some preparatives, which are in compliance with the PIC limitations of the following CCA are not banned, and the rest are either banned or not licensed at all: Monocrotophos, Methamidophos, Phosphamidon, Methyl parathion, Parathion.  These trainers will then train the farmers. In addition, as part of the project's activities, farmers will be taken to field demonstrations. All farmers that use or will use permitted herbicides, insecticides and pesticides on their arable and horticultural crops should have the correct training in storage, handling and use of these chemicals as well as the careful disposal of the containers and the project will develop opportunities for this training. Alternatives to chemicals, such as disease resistant strains (from local wild varieties) and integrated pest management could be demonstrated. Local people may know of natural predators and plants with naturally occurring insecticide properties: such indigenous knowledge should be tapped. The control of ticks and other parasites is important in animal husbandry; therefore, the project will seek opportunities for training pastoralists in the handling and use of control agents. These activities aim to improve sustainable farm production, while decreasing erosion on farm and increasing the beneficial soil properties. There will be complementary activities such as soil testing, advice on the correct dosage of fertilizer especially organic fertilizers and the promotion of integrated pest management and apiculture. Table 1. AWRP: Environmental Screening Matrix: Application of Herbicides, Insecticides and Pesticides in Tree Nurseries. Project Project Relevant Potential Nature, Scope Mitigation Key Component Activity Environ- Field & Time-frame Proposed Assumptions mental Actions of Potential Indicators Env Impacts Tree nursery Application Negative: Only use May be Enforce use of Govemment seedling of chemical Overapplica- permitted continual permitted only allows production control tion and chemicals. build-up of chemicals production / agents. inappropriate Train people in potentially only. Provide import of use can have storage, dangerous on-going certified adverse effect handling, use toxic and training in chemicals. on ground & and disposal of hazardous storage, Smuggling river water. containers. chemicals in handling and controlled. Can affect Demonstrate water and soil use to negate International people alternatives to if not toxic buildup. handling /use spraying or chemicals such controlled. Demonstrate standards nearby. as IPM. alternative applied. Positive: techniques to Farmer Can remove chemicals. training and noxious weeds Monitor participation and control ground and essential. harmful river water. Monitoring insects' etc. Site sheep dips budget Can kill to avoid conta- approved. parasites on mination of farm animals. groundwater. Assessment, Mitigation and Monitoring It is envisaged that the project will only be supporting the use of pesticides in tree nurseries. Tree seedling production is to be contracted out to private sector agents, who may in turn choose to use pesticides to in nursery management. The Bank's safeguard policy guidelines on Pest Management (OP 4.09) have been addressed by ensuring that there will be proper storage, handling, use and container disposal of authorized chemicals.  Planned activities to assess, mitigate, and monitor the use of pesticides in tree nurseries are summarized in Table 2. In addition, because farmers are using pesticides and herbicides on their own land within the project area, training will be given in storage, handling, use and container disposal. The project will ensure that through the MoE, only allowable chemicals are used. There is differentiation in agricultural s ubsidies for pesticides i n d irect correlation w ith their toxic ingredients. There i s legislation regulating pest control in the Law for Pest Control and Agricultural Quarantine (1957). This law regulates imports, exports, production, sale and control of pesticides. A Regulation on Labelling of Pesticides ( 1983), the Code of Conduct for Pesticide Prescription ( 1984) and the Code of Conduct for Toxicological Classification of Pesticides (1984) are other legislations applied to pest control activities. Table 2: Assessessment, Mitigation, and Monitoring of Tree Nursery Application of Pesticides Parameter(s Cost Responsibility Phase What Where How When Why Install Operate assessed? assessed? assessed? assessed? assessed? Install Baseline CCA, At each Assess IPM Before To compare to Use Contractors, PMU, sprayers, nursery option. operations internationally existing MoF, MoE clothing, site. Examine CCA begin. acceptable facilities drum etc. Compare standards. storage/ to acceptable disposal. standards. Ban Training, application of WHO IA and IB list chemicals. Construction N/A Operate Method of At each Physical During To ensure that Included As above. application site. inspection. application standards are in the .___________ .being met. project. Decommission. N/A  Table 3: Pesticide Concentration Limits in Inland Water Bodies. Banned (1) Tolerable limit International name of active ingredient Allowed (2) microgaml 1- ALDRIN (2) 0.04 2- BHC (I) 2.0 3- CLORDANE (I) 37.5 4- CPYONRAHE (1) 2.0 5- ENDRIN (0) 0.2 6- HEPTACHLOR (1) 0.2 7- LINDANE (1) 0.2 8- DDT (1) 0.6 9- DICOFOL (2) 100.0 10- DIELDRIN (1) 0.3 11- ENDOSULFAN (2) 0.2 12- PERTHANE (1) 3.0 13- TDE (DDD) (1) 3.0 14- TOXAPHENE (1) 3.0 15- CHLOROBENZILATE (1) 550.0 16- DILAN (1) 16.0 17- TETRODIFON (2) = 18- STROBAN (1) 2.5 19- PARATHION-ETHYL (I I.0 20- MONOCHROTOPHOS (2) 7000.0 21- DICROTOPHOS (2) 600.0 22- DIOXATHION (2) 14.0 23- DIAZINON (2) 0.9 24- DICHLORVOS (2) 0.07 25- EPN (2) 0.1 26- ETHION (2) 0.01 27- AZINPHOS-METHYL (2) 0.2 28- MALATHION (2) 1.8 29- PARATHION-METHYL (2) 96.0 30- MEVINPHOS (2) 0.16 31- PHOSPHAMIDON (2)_3.8 32- TRICHLORPHON (2j 8.1 33- CARBARYL (2) 1.3 34- ANILAZINE (2) 15.0 35- ATRAZIN (2) 12600.0 36- CUPPER SULFATE (2) 150.0 37- 2, 4-D ISOPROPYLESTER (2) 800.0 38- 2, 4-D BUTYLESTER (2) 1300.0 39- 2,4-D BUTYL+IZOPROPYLESTER (2) 1500.0 40- DALAPON (2) 6000.0 41- DICAMPA (2) 5800.0 42- CAPTAFOL 31.0 43- DIQUAT X X X X X <(2) 12300.0 44- DIURON (2) 380.0 45- FENTIN HYDROXIDE (2j 33.0 46- PARAQUAT (2) 3700.0 47- SILVEX (2) 1200.0 48- SIMAZINE (2) 5000.0 49- SODIUM ARSENITE (1) 36500.0 50- TRIFLURALIN (2) 11.0 51- VERNOLATE (2) 5900.0 Note: (1). These chemicals are banned in Turkey. They are included in the Table, since they have long-term residual impact on the environment. (2). Chemicals, which are licensed and used in Turkey.