The Turkish government has designated 21 beaches as sea turtle conservation sites, per the conservation circular drafted with reference to the Bern Convention in Turkey.
The coal plant is located in a protected area recognized under Turkish law, per Circular no. 2009-10 on the Protection of Sea Turtles. It was issued by the Directorate General of Nature Conservation and National Parks (DKMP). This law recognizes and protects the existence of both turtle species in this area, and thus does not allow for power plant construction within the area. However, the coal plant spans across 41 hectares, which directly overlaps and surrounds sea turtle nesting sites. Due to the far ranging impacts of coal plants in general, the Emba Hunutlu coal plant will likely cause even broader impacts beyond the project site itself from related activities such as shipping, embankment, cooling water withdrawal and discharge, lighting, and noise pollution in both marine and land zones.
The Emba Hunutlu coal plant is located in an area with both endemic and endangered species. Endemic species are plants are animals that are only found in one geographic area. As such, they are particularly at risk to habitat changes, as any habitat loss may jeopardize their long-term survival. For instance, the area hosts endemic species such as the dune cricket (schizodactylus inexpectatus) and three plant species which are only found in this area, including the Aleppo Pine, Misis Milkwitch, and Hare’s ear (Bupleurum polyactis). In addition, the project site contains two other rare, endemic plants, the Turkey yellow and dock.
The area also hosts a number of endangered species. According to the Bern Convention, the green sea turtle and loggerhead sea turtle are strictly protected species. With regards to birds, this area contains a total of 17 different species which use the site as wintering ground and/or reproduction site. The jungle cat (felis chaus), a mammal living in this area, is also listed as endangered by the IUCN.
Turkish law Circular No: 2009/10 formally recognizes and protects coastlands for nesting turtle sites, in accordance with the Bern Convention and states the conditions of the Convention regarding those sites.
The 1,320 MW Emba Hunutlu Coal Plant is located in Yumurtalık, Turkey. Despite strong local opposition and lawsuits, the Turkish government has allowed the $1.7 billion USD project to move forward in a region already beset with numerous coal plants. Environmental studies have shown that air pollution already exceed limit values. According to the expert report of the lawsuit filed to cancel the electricity license, cancer rates have increased by 11 fold in the region between 2009-2014, which roughly correspond to the operations of nearby coal plants. As such, it is likely that the construction of the Emba Hunutlu Coal Plant will further drive environmental health impacts on the local population. The modeling, conducted by the Center for Research on Energy and Clean Air (CREA) and the Health and Environment Alliance (HEAL) reveals that air pollutant emissions from the project would likely be responsible for a projected 2,000 premature deaths in the operating life time of the plant.
In addition, the area is a biodiversity hotspot protected under the Bern Convention on the Conservation of European Wildlife and Natural Habitats. The area contains several reptiles, plants, and invertebrates that are classified as either under threat per the Red List of the International Union for Conservation of Nature (IUCN) or endemic to this region. Endemic species are plants are animals that are only found in one geographic area. As such, they are particularly at risk to habitat changes, as any habitat loss may jeopardize their long-term survival. Yumurtalık is also the nesting area of the endangered green turtle (Chelonia mydas), and the critically endangered African softshell turtle (Trionyx triunguis). According to a recent report by the IUCN, stronger protections are needed to successfully conserve marine turtles in the Mediterranean. Endemic species include the dune cricket, and three plant species: Aleppo pine, Misis milkwitch, and the rare Hare’s ear (Bupleurum polyactis). In addition, the site contains two endangered plant species, iris xanthospuria and rumex bithynicus.
Concerningly, the project does not comply with current Turkish and European Environmental and Air Pollution Limits. For instance, the project violates Turkish law Circular No. 2009/10 of the Ministry of Forestry and Water Affairs on the protection of sea turtles, and the 2014 measures of Turkish Industrial Air Pollution Control Regulation (SKHKKY). The project’s environmental impact assessment also contains a number of flaws and gaps. For example, although the EIA mentions assessing the cumulative impacts of air pollution in the region, it does not comprehensively report findings, nor did the EIA disclose the methodology behind the findings. Moreover, the company recently changed the stack technology of the coal plant, which should trigger an additional impact assessment. The study conducted by Turkish NGOs HEAL and CREA indicate that the health impacts are expected to be much higher with this new stack design, considering the PM2.5 increase.
Local communities and groups not only strongly oppose the construction of not only the Emba Hunutlu Coal plant, but also any further coal project development due to the well-established negative climate, public health and social impacts. The controversy over coal has already led companies to withdraw from coal plant development in the area. For instance, in 2015 French utility Engie decided to pull out of a coal project in Iskenderun Bay due to opposition on local and international levels.
In 2017, the Hunutlu coal project was sued by civil society organizations on the basis of negative cumulative pollution impacts. Court experts ultimately accepted local organizations’ claims that the project would negatively impact public health, agriculture, and increase pollution as valid and credible. In June 2020, more than 20 Turkish NGOs called on the project’s financiers, which include China Development Bank, ICBC, and Bank of China, to withdraw from the coal plant. According to Dr. Sadun Bölükbaşı from the East Mediterranean Platform of Environment Associations, the project’s Chinese financiers bear a responsibility to ensure their loans are sustainable and beneficial to Turkish people:
“An investment at this scale needs to benefit both China and Turkey, most importantly the local communities that will bear the impacts of the coal plant. We do not believe that the project that will operate on imported coal will provide any benefit to our communities and our country due to the negative impacts on the environment, climate, and biodiversity. We demand support for clean sectors such as solar and wind which would benefit stakeholders in Turkey and China and we ask the Chinese banks to act on the basis of sustainable development and comply with China’s green financing policies”.
