EIA Monitoring and Control: A Guide to Inspection Readiness

Why doesn't the work end with the EIA decision?

Obtaining an EIA (Environmental Impact Assessment, known in Turkey as ÇED) decision does not bring a project's environmental responsibilities to a close; the real follow-up takes place through the EIA monitoring and control process that begins after the decision. This article is written for project owners, facility managers and environmental officers whose projects have received an "ÇED Olumlu" (EIA Positive) or "ÇED Gerekli Değildir" (EIA Not Required) decision. We explain what inspectors look at, which records need to be kept and how to manage the process step by step.

What is the EIA monitoring and control process, and who does it concern?

The EIA monitoring and control process is the follow-up, during the construction, operation and, where necessary, closure phases, of whether the project is being implemented as described in its EIA Report or Project Introduction File (Proje Tanıtım Dosyası). The Çevre, Şehircilik ve İklim Değişikliği Bakanlığı (Ministry of Environment, Urbanisation and Climate Change) and its provincial directorates carry out this follow-up under the EIA Regulation (ÇED Yönetmeliği) in force.

The process concerns every project that has received an EIA decision. Quarries and mining sites, crushing and screening plants, tourism facilities, energy investments, waste facilities, livestock operations and industrial investments are among the most prominent. Whatever the type of decision, every measure written in the file counts as a commitment on the part of the project owner.

The point that is often overlooked is this: the document used as the basis for inspection is your own file. Capacity, project area, the technology used and the measures to be taken must be seen on site exactly as they are written in the file.

How is the post-EIA monitoring process carried out step by step?

The monitoring process is managed by listing the commitments, assigning responsible people, having monitoring reports prepared on time and keeping records in order. The five steps below make the process part of day-to-day operations.

1. Draw up a commitments table

Once the decision becomes final, the first task is to read the report or file from start to finish and collect all the commitments made into a single table. Topics such as dust suppression, noise measures, wastewater management, topsoil protection, rehabilitation and capacity limits should each have their own row. Each row should also state the phase in which the commitment applies.

2. Assign responsible people and set up a record-keeping system

Every commitment should have someone responsible for it on site. Evidence such as watering records, waste delivery documents, measurement reports and training records should be stored in a single folder, in date order. During an inspection it is not enough to say that a measure has been implemented; you need to show it with documents.

3. Have monitoring reports prepared on time

The Regulation requires monitoring reports to be prepared at certain stages after the decision. These reports are prepared by an organisation holding an EIA competency certificate and cover the current state of the site, the status of compliance with commitments and photographic evidence. The current legislation should be followed for the reporting periods and format.

4. Be prepared for site inspections

Teams from the provincial directorate may visit the site to examine the project in person. The inspection checks the boundaries of the project area, capacity, whether environmental measures are actually being applied and the records; the outcome is recorded in an official inspection report. If deficiencies are noted in the report, they must be remedied and documented within the time given.

5. Notify changes before implementing them

If you are planning a capacity increase, an extension of the site area, or a change of process or technology, submit it to the provincial directorate for assessment before putting it into practice. Changes made without approval are regarded as a serious non-compliance in the monitoring process and may require a new EIA assessment.

Which documents should be ready before an inspection?

Keeping the following documents and information ready in a single file ahead of the EIA monitoring and control process makes inspections noticeably easier:

• The EIA decision together with the finalised Final EIA Report or Project Introduction File

• The commitments table and evidence showing that each item has been met

• Project area coordinates, the approved site plan and up-to-date site photographs

• Documents relating to the environmental permit or to whether a permit is required

• Waste declarations, delivery documents to licensed companies and UÇBS (Ulusal Çevre Bilgi Sistemi – National Environmental Information System) records

• Dust, noise, emission and wastewater measurement reports, where required for your project

• Watering, maintenance, rehabilitation and afforestation records

• Records of environmental training given to staff

• Previous monitoring reports, inspection reports and evidence of deficiencies that have been remedied

Common mistakes and points to watch

A common mistake is to treat the EIA decision as the end of the process and file the report away. When the team that prepared the file and the team managing the site are different, the commitments may never reach the construction site, and the problem only comes to light during an inspection.

Other points that need attention in practice are:

• Actually exceeding the capacity or area limits set out in the file

• Applying daily measures such as dust suppression and watering but not recording them

• Not storing topsoil separately, or leaving rehabilitation until the end of the project

• Not keeping track of monitoring report periods

• Not remedying deficiencies noted in the inspection report within the time given

• Not notifying administrative changes such as a change of company name, authorised representative or project owner

Remember: if there is no record of a measure applied on site, there is a risk that it will be treated as not applied during an inspection. That is why keeping records is as important as the measure itself.

Notes for projects in Antalya

In Antalya, because tourism, mining and agricultural investments sit side by side, the EIA monitoring and control process becomes particularly important for projects close to the coast and to protected areas. For hotel and holiday village projects near the coast, commitments on wastewater management and coastal use come to the fore.

In quarries and crushing and screening plants, dust, noise and site rehabilitation are closely monitored; in greenhouses and agriculture-based industrial facilities, the focus is on wastewater and waste management. During construction work carried out in the tourist season, dust and noise are sensitive issues for nearby businesses and residents and can lead to inspections following complaints.

You can find the details of our EIA consultancy service on our website.

You may also want to read our related article, "EIA Regulation: Recent Changes You Need to Know".

Frequently Asked Questions

Do I need to do anything else after receiving an EIA Positive decision?

Yes. The decision is valid together with the commitments you made in the report, and compliance with these commitments is monitored throughout the project. You need to have monitoring reports prepared on time and keep on-site records in order.

Are projects with an EIA Not Required decision also inspected?

Yes. The measures written in the Project Introduction File are also commitments, and the provincial directorate may check them on site. Although the type of decision is different, the obligation to operate in line with the file is the same.

What happens if deficiencies are found during an inspection?

Any deficiencies identified are recorded in the inspection report, and a period is usually given for remedying them. Where deficiencies are not remedied in time, or in cases of serious non-compliance, administrative sanctions may be imposed under the legislation in force.

I want to increase my project's capacity. What should I do?

Before implementing the change, you should apply to the provincial directorate to clarify whether a new EIA assessment is required. A capacity increase made without approval is regarded as a serious non-compliance in the monitoring process.

Conclusion

With a properly prepared commitments table and well-kept records, the EIA monitoring and control process becomes a routine task. You can access the current text of the relevant regulations via the Mevzuat Bilgi Sistemi (Legislation Information System). To plan your project's monitoring period together, take a look at our EIA consultancy service, and get in touch with us with any questions.

Written by Selin Sevinç, Environmental Engineer (MSc), Asel Çevre Danışmanlık.