Sibel Paralik, the President of the Chamber, highlighted that the Ministry of Finance and the Exchange Development Department had announced the tender for the project in September, with the bid submission deadline approaching. The Chamber had set up a technical committee to contribute to the preparation of the technical and administrative specifications. They participated in many meetings organised by the Ministry during the summer of 2023 and provided both written and verbal feedback for a fair and workable outcome. However, Paralik stated that their written comments and example specifications were not taken into account.
Paralik pointed out that many issues could arise regarding the sustainability of the project after the facility is tendered. They noticed that their proposed technical conditions for rehabilitating the waste site were removed from the documents. The criteria for rehabilitation, which should have been included after the approval of the Environmental Impact Assessment (EIA) report, were also missing. The project documents did not address the waste hierarchy principle, nor did they include any waste management policies for the next 49 years, which seems to encourage more waste production and energy generation instead.
Paralik also criticised the omission of recycling technology definitions, criteria for evaluating recycled products, and the removal of specific sections about final waste disposal areas. Key details about waste processing at transfer stations, waste segregation, and compliance with related regulations were excluded from the documents. She raised concerns about the lack of clarity on whether the energy produced would come from biodegradable or renewable sources. There are also worries that municipalities struggling with financial issues might not be able to transport waste to the Güngör site or transfer stations, which could jeopardize the project’s sustainability.
The feasibility reports and evaluation criteria were deemed insufficient and lacking in essential queries. Additionally, the planned locations for transfer stations have not been expropriated, which could threaten the project’s viability if not addressed before the tender is finalised. The requirement for environmental engineers and the need for KTMMOB’s approval were also removed from the documents.
Paralik criticised the proposed penalty for non-compliance, arguing that it is not substantial enough to be a deterrent. She emphasised that rules, standards, and regulations should be comprehensive and clearly outlined.
Ongoing Problems with the Waste Site:
- Lack of Rehabilitation Plan: The technical specifications for rehabilitating the waste site have been removed from the project documents.
- Missing Waste Hierarchy and Policies: The project lacks policies to reduce waste generation and does not incorporate the waste hierarchy principle.
- Omissions in Recycling and Disposal Technology: Definitions for recycling technologies and criteria for evaluating recycled products are absent.
- Energy Production Source lacking clarity: It is unclear whether the energy produced will come from biodegradable or renewable sources.
- Financial and Logistical Issues: Municipalities may struggle to transport waste to the site, threatening the project’s sustainability.
- Inadequate Evaluation and Compliance Criteria: The feasibility reports are insufficient, and necessary compliance and expropriation measures are missing.
These issues highlight significant gaps in the planning and execution of the waste management project, potentially impacting its effectiveness and long-term viability.