Nuclear developments currently play a front-role in political discussions in Turkey. In this article, we give a sketch of the situation around the most advanced of the three proposed nuclear plants – the Russian build, owned and to be operated project at Akkuyu. We will reflect on methods used during this process, transparency, involvement of civil society, public participation and access to justice.

 Nuclear in Turkey

Being one of the first countries to sign an agreement based on to the “Cooperation With Other Nations” article 123 of the US Atomic Energy Act of 1954, establishing US President Dwight D. Eisenhower’ s Atoms for Peace programme, different Governments of Turkey have pushed nuclear energy as the “development key of the country”. Turkey established an Atom Energy Commission as early as 1956 to work on nuclear energy and radiation safety, which in 1982 was transformed into the current nuclear regulator and licensing authority TAEK (Turkish Atomic Energy Commission). Today there are two research reactors at the Nuclear Research and Training Centre in Istanbul.[1] For further development of the sector, bidding processes were started in 1965, 1972, 1982 and 1993 respectively, but they were never realized due to political and economical uncertainties formed in the atmosphere of military coups that happened almost every 10 years.[2]Also, a strong anti-nuclear movement played an important role. This started in the 1970’s with protests of fishermen and citizens in Mersin and was enhanced by the Chernobyl disaster in 1986. In the end of the 2000s, the plans were once more revived and currently three projects are being pursued: Akkuyu in the South-East, Sinop in the North-East and Igneada in the West. The official justification is a need to reduce dependence on foreign sources.[3]

 By the end of July 2017, Turkey is 74% dependent on imported energy sources [4]. Of its electricity generation, 34% is from natural gas, 31% from coal, 24% from hydraulic power, 6% from wind, 2% from geothermal energy and 3% from other sources.[5]70% of its natural gas comes from Russia.

 In 2010, Turkey signed an Intergovernmental Agreement with Russia to have a nuclear power plant established near Mersin, on a site at the Mediterranean coast. This agreement lets the Russian company Rosatom establish the four-reactor Akkuyu Nuclear Power Plant under a so-called Built-Own-Operate (BOO) model, the first example realised in the world.[6] Under this scheme, the estimated cost of the Akkuyu project is 22 billion dollars for four reactors of the VVER1200 design, and electricity produced by Akkuyu will be bought at a guaranteed price of 12,35 Dollarcent per kWh for 15 years.*

As an international agreement, this deal was reached outside of the public eye and cannot be evaluated within the constitutional rules.

 Although Turkey is not a signatory of the Aarhus and Espoo Conventions, which oblige public participation and an Environmental Impact Assessment (EIA), Turkish law does enshrine the need for an EIA. On the basis of the negotiations for accession to the EU, this law reflects much of the EU EIA Directive. The EIA report of the Akkuyu project was twice refused by the Ministry for Environment and Urbanisation. A third application was approved in the end of 2014, within a week after president Vladimir Putin visited Turkey.

Around the entire process, there was strong public debate. In reaction to the approval of the EIA, a group of 13 civil society organisations and 80 individuals, including physicians, lawyers and engineers associations, environmental organisations and local associations, filed an appeal. Despite local and national public discontent, feasibility studies for the nuclear power plant site were started on 14 April 2015.[8]

Sinop and Igneada – the other Turkish nuclear projects

The Akkuyu nuclear power plant is the first one to enter the construction phase. But in 2013, Turkey signed an intergovernmental agreement with Japan for a second nuclear power station near Sinop, a city on the Black Sea coast. Also here, a Build-Own-Operate (BOO) agreement is foreseen. The Atmea reactors are to be delivered by Mitsubishi in cooperation with French Areva. The Atmea design so far only exists on paper and Turkey is currently the only interested country. The nuclear reactors, according to the agreement, should be capable of using mixed oxide (MOX) fuel, including plutonium from reprocessed spent nuclear fuel. In spite of the project still being in a very early stage and no related permits being given, 600 thousand trees were cut on the land that was transferred from the Ministry for Environment and Urbanisation to the Energy Ministry.

In 2016, the government announced a third project, potentially in cooperation with Chinese nuclear constructor CNG. Igneada is famous for its rainforest nature, located at the border with Bulgaria on 220 kilometres from Istanbul.

The use of three different technologies, implemented and owned by three different countries, raises serious concerns about whether different safety procedures and rules will fit in the still infant nuclear legal infrastructure in Turkey.

Problems around Akkuyu

Although it was envisioned in the BOO model that Rosatom would become the sole owner of the project, difficulties for Russia in financing its part forced it to sell in November 2017 49% of shares[9] to CKK, a consortium of three Turkish companies: Cengiz, Kolin and Kalyon, who currently demand an equal say in the management of the project.[10]

In 2014, an “Integrated Nuclear Infrastructure Overhaul” (INIR) mission from the IAEA concluded that the Turkish legal and procedural structures needed improvement.[11] The findings of this mission were only leaked six months after the report date. One of the central critiques in the mission report was the lack of independence of the nuclear regulator TAEK as prescribed in the Convention on Nuclear Safety (CNS).

Although Akkuyu is far away from most of its neighbouring countries, because Turkey is not a signatory of the Espoo and Aarhus Conventions even 100 km far Cyprus was not able to participate in the EIA procedure.[12]

The project is situated on a remote piece of Turkey’s Mediterranean coast. Critics allege that during the project preparation too little attention is given to nature protection. This includes threats to the wetlands around the Göksu River, and to important Mediterranean red-listed species like loggerhead turtles (caretta caretta) and monk seals (Monachus monachus).[13] There are furthermore concerns about the effects of a 2 degree temperature increase in the waters surrounding the plant due to cooling water.[14]

Turkey is situated in an active earthquake zone and its coasts have an elevated tsunami risk. The civil society appeal of the EIA report highlights the risk of an active fault line at 30 kilometre distance from the Akkuyu project site.

High level radioactive waste from the Akkuyu nuclear power plant

The EIA report contained no explanation regarding radioactive waste issues. At the expert review process of the EIA court case, Rosatom clarified that Russia would, under art. 12 of the Russian Constitution, never take nuclear waste for final storage from foreign sources. There is therefore no clarity about how especially spent nuclear fuel will be treated and high-level waste will be disposed of. Concerns exist in this respect especially about the high seismic risk in the entire Turkish territory, that makes finding a safe final deep depository virtually impossible.

The Turkish-Russian agreement seems to foresee reprocessing of spent nuclear fuel in Russia with repatriation of resulting vitrified high-level waste. There is, however, no clarity about the transport of spent nuclear fuel and vitrified waste, which might have to pass the highly inhabited area of Istanbul through the narrow Bosporus strait.

Concerns about transparency development

In March 2017, the Turkish government took a decision to start the project in spite of the EIA appeal still pending in court.[15] A decision on this EIA appeal is expected in late December 2017 or early 2018. However, president Erdoğan dashed any hopes on substantial changes to the project or a sincere assessment of its justification by declaring that the Akkuyu nuclear power plant project will be realized despite any environmentalist concerns. This message of the President was interpreted as a directive given to judicial bodies.[16]

NGOs and professional organisations also severely criticise the quality and insufficiency of the information shared with the public around the project, among others in their EIA complaint.

Government seems to attempt to reduce civil society participation in nuclear power plant decisions in other ways. It declared nuclear power plant projects as strategic mega projects, and decisions, including environmental ones, will directly fall to the Prime Minister and the President.[17]

Environmental NGOs, but also professional associations and media that have brought themselves into the public debate around Akkuyu and other nuclear projects, have faced strong verbal attacks by regime-friendly media and on social media, including from the President himself. As a result, they have become extremely careful in their activities and communication around nuclear issues, fearing it might be used as a reason for further intimidation or even legal steps endangering their very existence. Where nuclear power for more than 40 years was a strongly visible element of environmental debates in society, the civil society movement now turns to international solidarity to help save at least a bare minimum of transparency and public participation.

by Pınar Demircan

project coordinator of Nukleersiz.org & Nuclear Energy Editor at Yesil Gazete

 Jan Haverkamp (editor)

vice-chair Nuclear Transparency Watch

[1]             http://www.taek.gov.tr/kurumsal/birimler/bagli-kuruluslar/cnaem.html

[2]             http://www.nukleersiz.org/dosya/tr-nuekleer-karsiti-hareket

[3]             http://aa.com.tr/tr/politika/basbakan-yildirim-enerjide-disa-bagimliligi-azaltacak-projeler-uzerinde-calisiyoruz/680440

[4]             http://www.mfa.gov.tr/turkiye_nin-enerji-stratejisi.tr.mfa

[5]             http://www.enerji.gov.tr/tr-TR/Sayfalar/Elektrik

[6]             The first BOO was to be signed in the US to have one reactor of the Calvert Cliff nuclear power plant by Japanese Mitsubishi, but this was refused because of military security interests under section 104 of the Atomic Energy Act of 1954

[7]                     * 1 Dollar was 1,9 Turkish Lira when the project was started in 2010 and in 2017 1 Dollar is 3,8 Turkish Lira

[8]                     https://yesilgazete.org/blog/2015/04/14/son-dakika-akkuyuda-nukleer-karsitlarina-polis-mudahalesi/

[9]                     https://yesilgazete.org/blog/2017/06/19/rosatomdan-bile-tehlikeli-akkuyu-nukleer-santralinin-yuzde-49u-cengiz-kolin-ortakligina-satiliyor/

[10]                   https://tr.sputniknews.com/ekonomi/201706291029067022-turk-sirketler-akkuyu-esit-yonetim/

[11]                   https://yesilgazete.org/blog/2015/06/01/uluslararasi-atom-enerjisi-ajansinin-akkuyu-raporu-ortaya-cikarildi/

[12]                   https://yesilgazete.org/blog/2015/06/01/uluslararasi-atom-enerjisi-ajansinin-akkuyu-raporu-ortaya-cikarildi/

[13]                   http://chk.barobirlik.org.tr/dokuman/makaleler/3.pdf

[14]                   http://chk.barobirlik.org.tr/dokuman/makaleler/3.pdf

[15]           https://yesilgazete.org/blog/2017/02/27/akkuyu-nukleer-santral-projesini-aklayan-bir-bilirkisi-raporu/

[16]           https://yesilgazete.org/blog/2017/11/23/bu-dava-siyasidir-akkuyu-ngs-ced-iptal-davasindan-degerlendirmeler/

[17]           https://yesilgazete.org/blog/2017/04/11/akkuyu-yer-lisansinin-iptali-davasina-sipsak-bilirkisi-incelemesi/

Recent climate change research suggests that, over the next few decades, there will be unprecedented global change, consequently affecting European human welfare and environmental systems. European Union (EU) policy already seeks to mitigate change through low-carbon, energy reduction and efficiency policies – but adaptation will clearly be necessary. Achieving this transition and adaptation at the pace and scale required will not be straightforward, and public knowledge, views and values about energy futures choices and ‘trade-offs’ will play a critical role, with significant implications for EU energy policy.

Creating a low carbon and resource efficient economy will involve major structural changes to the way EU States work and live, including how we source, manage and use our energy – and an ambitious long-term target of 80-95 % reductions in greenhouse gases by 2050 have been set by the EU[1]. In order to start to achieve this, the EU concludes that we need to collectively triple our annual investment in low-carbon technologies over the next decade to EUR 8 billion and make a EUR 20 billion annual investment in energy infrastructure.

The challenge of achieving a transition to sustainable energy will involve different supply and distribution options combined with centralised forms of renewable energy; new European-scale networks for energy distribution; large-scale infrastructures for carbon sequestration; bridging combined heat and power (CHP) gas generation; local scale distributed energy; coal and nuclear fission (with their associated proposals for carbon sequestration and nuclear waste management); significant restructuring of our transmission networks and changes to our transport systems and built. However, these developments will vary in their acceptability to differing sections of the public and for different stakeholders, and will also vary from country to country.

So, we are faced with collective choices – and the purpose of energy appraisal is to inform these choices. Long-term decisions across the entire field of industrial strategy depend on the resulting pictures. It is in this way that we justify scientific research programmes, technology development projects, infrastructure investment portfolios and the implementation of entire suites of policy instruments like taxes, standards, regulations and subsidies. Taken across the full range of public and private actors engaged in energy systems, annual commitments of many billions of Euros rest (directly or indirectly) on the framing of energy policy appraisal[2].

Given the size of the long-term investments that are now needed across low carbon ‘energy futures’ options, European citizens should play a key role in taking these critical, social, environmental and economic decisions. The EU has recognised in the Lisbon Treaty this capacity-building of knowledge and trust via involvement and dialogue between statutory and non-statutory civil society actors at pan-EU, State, Region, and Local levels[3]. The EC Energy Road Map 2050[4]concludes that:

“The current trend, in which nearly every energy technology is disputed and its use or deployment delayed, raises serious problems for investors and puts energy system changes at risk. Energy cannot be supplied without technology and infrastructure. In addition, cleaner energy has a cost. New pricing mechanisms and incentives might be needed but measures should be taken to ensure pricing schemes remain transparent and understandable to final consumers. Citizens need to be informed and engaged in the decision-making process, while technological choices need to take account of the local environment.”

There is a range of strongly EU centred drivers to this dynamic, based on a perceived crisis of legitimacy in ‘top-down’ decision-making models. As a result, throughout the EU, there are clear policy moves to integrate public and community knowledge into decision-making processes. This shift has seen moves toward a two-way dialogue between specialists and non-specialists as a means of forging a more lasting consensus by increasing social involvement and participation, thereby fostering a sense of community[5].

The underlying social force that underpins this move is the drive for more accountable, transparent, and publicly acceptable decision making, with participatory dialogue no longer seen as an optional ‘add-on’ to policy making. It is in this context that civil stakeholder involvement provides a way forward to ensure that future policy solutions meet the needs of the public, and that these solutions are socially, culturally and politically acceptable as well as technologically feasible.

What is participation and involvement?

Participation and involvement is an approach to decision making that allows people to come together to consider information, discuss issues and options and develop their thinking together. Building on dialogue and consensus-building techniques, this kind of engagement provides policy and decision makers with much richer data on stakeholders knowledge, views and values, offers opportunities to more fully explore and express people’s thoughts and ideas, and allows the time to develop options and priorities. For participants, the experience helps them collectively develop their views with experts and decision makers. Participants can also take their recommendations forward to inform policy, which can encourage shared responsibility for implementation[6].

Dialogue about complex and controversial issues, such as energy futures, can also enable greater public confidence in eventual policy decisions. This is because dialogue allows a diverse mix of civil society stakeholders with a range of views and values to:

• Learn from written information and experts.
• Listen to each other, share and develop their views in discussion with experts and energy 
sector researchers.
• Arrive at thought-through collective conclusions, and communicate those conclusions directly to inform decision making.[7]
• It is important that dialogue should be face-to-face, in order to give all sides the chance to speak, question and be questioned by others. It should take place far enough ahead of policy being made to be able to have some influence over eventual decisions[8].

Involvement methods and tools

There are a very broad range of involvement methods, including: stakeholder dialogues, public meetings, citizens’ panels, events, forums, workshops, ‘kitchen round-tables’, ‘test-beds’, mentoring, ‘visioning’, peer exchange, interactive web-sites, and external communication through press and media.

Central to these involvement methods are practical decision support dialogue tools, and a number of projects applied them very well through framing boundaries, exploring scenarios, quantitative modelling, and evaluation and review. Decision support tools work well, especially in exploring ‘what if’ questions and resulting ‘trade-off’ options, risks and outcomes. Some specific tools are key, including: Scenario building and modelling, participatory multi criteria analysis (PCMA), virtual reality techniques (including 3D visualization and geographic information systems [GIS] mapping), life cycle analysis (LCA) and quantitative environmental assessment.

Of these decision-support tools, the most commonly used is scenario-building. Here, project findings suggest that complex energy and climate change information can be successfully applied and understood through use of coherent scenarios. This is because scenarios shed light on the long- term impacts of energy pathways decisions, especially infrastructure change. It’s also interesting to note that the EC Energy Roadmap 2050 has also used scenario-building as a way to better inform and involve people.

Participatory multi criteria analysis (PMCA) tool is employed in trying to balance and account for both quantitative data and social values. PMCA is used to test technical options and choices, and the social acceptance of change and adaption strategies. Although PMCA is resource intense, it encourages learning, and allows for the acknowledgement of uncertainties, and multiple legitimate perspectives. However, care should be taken in ‘weighting’ options, as this can impact significantly on eventual outcomes.

In terms of digital innovation, virtual reality techniques help people visualize alternative energy transition and climate adaption, mitigation scenarios and the potential consequences of those responses.

Stakeholders and the public can work with complex data

Independent expert involvement is a key part of an even-handed process. Dialogues draw on differing sets of stakeholder knowledge, experience and values. Working with, and integrating, diverse streams of information from multiple sources, sectors and disciplines forges better dialogues and results in more practical outcomes. By adding this element, an important step is made by distinguishing between what is technically and economically possible to what is feasible and acceptable to stakeholders. Encouragingly, in the right circumstances, civil society stakeholders are able to analyse, understand, respond and act on complex data.

‘Better practice’ involvement mobilises people

A very broad range of statutory and non-statutory stakeholders and civil society organisations should be enabled to actively engage in energy futures dialogue, including: policymakers, government departments, devolved administrations, local government and local authorities, energy regulators, transmission system operators, industrial corporations and businesses, trade associations, non-governmental organisations (NGOs), local community based organisations (CBOs), independent energy sector experts, and academic institutions.

But there are challenges to involvement

It is not always a simple task to encourage citizens and the industry to participate co-operatively, and it can be complicated to combine several different tools for decision making into a single coherent process. Tensions have arisen over a number of issues, including: the framing of boundary conditions for dialogues, whether all main stakeholders were included in discussion, the acceptance of all stakeholders as equal contributors, levels of planning options offered, and over perceived openness to serious policy influence.

Given that dialogue should happen over a reasonably extended time frame, an important cause of lack of local acceptance is the absence of a coherent and timely ‘upstream’ and on-going involvement strategy. Although participation of civil society is considered crucial for the implementation of ambitious involvement strategies, a few implementation programs and activities have not yet consistently involved all main stakeholders – focusing more on the business, industrial and research sectors.

So can involvement enable low carbon transition?

‘Business as usual’ energy policy will not deliver sufficient change at the rate and scale required to lower climate change emissions – and public, energy sector, and government stakeholders will all need to play their part in transitioning to low-carbon economies.

The published literature suggests that involving the public in dialogue around complex and technical policy issues is an important contribution to a more transparent and open way of governing – demonstrating that members of the public have the ability to engage with and contemplate large quantities of complex information, and provide detailed responses that inform and enhance governmental decisions.

Holding dialogue on difficult and controversial issues is a fundamental enabler for decision-makers to feel confident in the public’s ability to hold the Government to account. There is also clear evidence that engaging people in a meaningful way has the potential to change attitudes, behaviours and actions. In order to better enable participatory deliberation, dialogue should be well informed and appropriately connected to representative democratic decision-making processes. Effective involvement results from a holistic set of pre- conditions, working best when informal non-statutory civil society networks are empowered to interact with formal statutory networks.

Involvement-led innovation can be a powerful means for agreeing and/or delivering national, regional, city, and local strategic objectives, at a lower cost to the public purse and with less bureaucracy than traditional processes. However, formal mechanisms for energy futures involvement, and linking that involvement to policy and decision-making structures, are not yet in place within all EU states.

Whereas the goal in the scientific-technical community is to find the single best solution to a problem, the facilitation of public debate has a broader function – to find a workable process that holds the participants together in a ‘safe space’ and encourages collective negotiation within the bounds of scientific, technical, economic and political feasibility.

[1]1 EC Communication (2009): IP/09/1431, 07/10/2009.

[2]Stirling (2007): Choosing Energy Futures: Framing, Lock-in, and Diversity, In: Dorfman (Ed) Nuclear Consultation: Public Trust in Governance, NCG.

[3] This is underpinned by the Directive on Public Participation in Environmental Plans and Programmes, the EU Public Participation Provisions of the Aarhus Convention, and the EU Directive on Strategic Environmental Assessment. Other public participation related EU legislation includes Directives on Integrated Pollution and Prevention Control and Environment Impact Assessment.

[4] EU, EESC & CR (2011): A Roadmap for moving to a competitive low carbon economy in 2050, Communication from the Commission to the European Parliament, The Council, The European Economic and Social Committee and the Committee of the Regions, COM/2011/0112 final, Brussels.

[5]Dorfman P. et al (2011): Enhancing consultation practices on Air Quality Management in local authorities, Journal of Environmental Planning and Management, 53 (5) pp. 559-571.

[6] Involve, NCC (2008): Deliberative Public Engagement: Nine Principles, NCC. 7 Sciencewise-ERC, Guiding Principles for Public Dialogue:

[7]http://www.sciencewise-erc.org.uk/cms/assets/Uploads/Publications/Guiding-PrinciplesSciencewise-ERC-Guiding- Principles.pdf

[8] Sciencewise: The Government’s Approach to Public Dialogue on Science and Technology, UK BIS:http://www.sciencewise-erc.org.uk/cms/assets/Uploads/Publications/Guiding-PrinciplesSciencewise-ERC-Guiding- Principles.pdf