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Energy and the environment

Turkey’s position with regard to Climate Change

The United Nations Framework Convention on Climate Change (UNFCCC) was adopted by and came into force in Turkey on May 24, 2004. However, Turkey chose not to sign the Kyoto Protocol as it considers that reducing its GHG emissions to the 1990 level is not viable for its economy. While Turkey was initially included as an Annex I and II country under the UNFCCC, it obtained to be removed from Annex II and to be recognised as an Annex I country under “special circumstances”. The reason being that Turkey’s main economic and industrial development happened after 1990, making it all the more challenging to reduce emission levels down to 1990 levels. At the same time, Turkey has not yet reached the degree of industrialisation of most other OECD countries.

As an Annex I country, Turkey is a potential carbon credit buyer. Turkey has however not set any emission reduction target, hence, it is not listed as an Annex B country of the Kyoto Protocol and cannot participate to the Clean Development Mechanism (CDM) nor to the EU Emissions Trading Scheme (EU-ETS).
Recently, The Turkish Environment and Forestry Ministery, announced that Turkey was ready to sign the Kyoto Protocol but keeping in consideration the country’s “special circumstances” (Turkish Daily News, May 2008).
The draft law for ratification of Kyoto Protocol is prepared and approved by related committees of Turkish National Assembly (June 4, 2008) . It is expected to be enacted in next season’s sessions of the General Assembly. However discussions are still ongoing about Turkey’s position with regard to Kyoto convention, no one knows whether Turkey will be eligible to a carbon compliance market after 2012 but it is expected.
Hence, Turkey is calling for “equality of sacrifice” rather than equal reduction in emissions. The required obligations ought to reflect the different structures and capabilities of countries’ economies. In that respect, Turkey claims that it should be compared to developing countries, not listed in Annex I.

Studies with regard to Climate Change

Following the ratification of the UNFCCC, and with technical support of UNDP, the Ministry of Environment and Forestry initiated a project with the objective to define a climate change mitigation strategy and compile the country’s first national communication to the UNFCCC . Within this framework, a Technical Commission within the Climate Change Coordination Council was established that gathers and coordinates the eight working groups, namely:
• Researching the Effects of Climate Change
• Inventory of Greenhouse Gasses
• Mitigation of GHG from Industry, Building, Waste Management and Service Sector
• Mitigation of Greenhouse Gasses from Energy Sector
• Mitigation of Greenhouse gasses from Transportation
• Land use, Land Use Change and Forestry
• Development of Policies and Strategies
• Education and Public Awareness

This national communication along with a national greenhouse gas inventory were submitted in January 2007 to the UNFCCC Secretariat.
Turkey already adopted a large number of EU acquis communautaire related to the environment. While the current regulation imposes SO2, NOx and dust emission limitations (but no tax on emissions). Current emission limits require that all new coal-fired power plants have flue gas desulphurisation but lots of investment needs are expected in order to upgrade equipments to the upcoming new standards aligned with EU ones.
Inventory of Greenhouse Gas Emissions and Removals
Turkey possesses the lowest per capita fossil-fuel-based CO2 emissions amongst OECD countries; 3.3 tons per capita (TURKSTAT 2006). The OECD average is 11.1, the world average is 4.0 and the EU 25 average 9.0 (2003).

The country is listed at the bottom of OECD countries. EU-15 countries and also below the world levels, having the respective ratios of 11.1 and 9.0 and 4.0 ton CO2 per capita in 2003.


The GHG emissions of Turkey rose steadily between 1990 and 2004 due to Turkey’s steady population growth and industrialization after mild-1990s. Between 1990 and 2004, GHG emissions from fuel combustion increased by 73.1 per cent, from 130,698.13 Gg CO2 equivalent in 1990 to 226,200.42 Gg CO2 equivalent in 2004, mainly due to increases in emissions from energy industries and manufacturing industries and construction. However, the share of emissions from the energy sector within the total GHG emissions (without LUCF) fell from 77.7% to 76.7% during this period. This fall is a result of several changes including:
i) A shift from coal to natural gas in electricity generation and residential consumption.
ii) Introduction of alternative fuel sources
iii) New engine technology in the transport sector and the removal of old, polluting cars from the register.

Total Emissions stemmed from energy consumptions

2004, the energy sector accounted for 76.7 per cent of Turkey’s total national GHG emissions. Emissions of CO2 from fuel combustion contributed 74.9 per cent of total national emissions.In 2004, CO2 is the largest proportion of Turkey’s total emissions, accounting for 81.5% while CH4 has a share of 15.6%. In Turkey, CO2 emissions arise largely from the combustion of fossil fuels, reaching 222.3 Tg and having a share of 92% of total CO2 emissions in 2004. The largest single contributor to CO2 emissions was electricity generation Net emissions account for 167.8 Tg since 74.1 Tg emissions removed by sinks. Energy sector emissions grew steadily during 1990-2004 except in some years in which fluctuations are observed. The factors giving rise to these fluctuations include economic crises, climate variations affecting hydraulic power, and the impact of taxes and measures introduced in the sector. Declines in emissions observed during 1994, 1999 and 2001 are the results of economic crises, while the increase in 2000 was due to rising demand for electricity generation by thermal plants as a result of a deficit in hydro power caused by dry climatic conditions. The energy sector showed the highest emission increase at 124% between 1990 and 2004. It is followed by the manufacturing sector (82%), transport (55.9%) and others (27.9%). The total CO2 increase in 2004 is 75.4% compared to 1990. With regard to electricity generation, CO2 emissions due to combustion of hard coal, lignite and natural gas showed a remarkable increase during the period in question. However, the replacement of lignite and coal with natural gas resulted in a decrease over the emission trend after 1998. The emission from lignite production in 2004 was 25.4 Tg, accounting for 11.41% of total CO2 emissions, while the share of hard coal was only 4.36%. Unlike the increasing share of emissions from industry and electricity generation, the share of the transport sector in total energy sector emissions fell from 20% to 18% over the same period.

Carbon dioxide emissions, 2004

In the energy sector, electricity production is the greatest contributor to GHG emissions, followed by industry and transport. In 2004 the use of lignite accounted for 11.41% of total CO2 emissions from the energy sector (25.4 Tg of CO2) and the share of hard coal was only 4.36%.

In the industrial sector in 2004, 93.9% of industrial GHG emissions came from the manufacturing of mineral products, the biggest portion of which is due to the cement industry and the production of clinker – The cement industry alone accounted for 85% of industrial GHG emissions in Turkey. The chemical industry only accounts for 3.6% of industrial GHG emissions in 2004 followed by metal production with a share of 2.5%.

Note that, although the cement industry is a big contributor to GHG emissions, cement plants in Turkey has a higher energy efficiency compared to most plants from European countries due to the great competitiveness of the sector and constant quest for energy cost cutting.

The share of the transport sector to GHG emission has been decreasing as a result of government-led programs and policies to promote diesel and increase fuel-efficiency in passenger car fleets.

Emissions trading

Under the circumstances, the non-Kyoto market, which involves Voluntary Emission Reductions (VERs), is slowly emerging in the country. As of today, VERs cannot be converted to Carbon Emission Reductions (CERs, traded within the CDM framework) nor to EURs (traded within the EU-ETS system) to cover legal reduction requirements.

Emission certificate trading seems to be the one of the supporting environment for deployment of GHG reducing technologies and also financial incentives for applications and practices in Turkey. There are some examples of Voluntary Emission Reduction certificates trading, which are issued for projects realised in Turkey and traded in the global marketplace. But these cannot really provide an incentive for a wide expansion of GHG reducing projects as VER prices are too low. There is a big potential in the electricity sector. Power generation has the highest share in Turkey’s CO2 emissions, 34% in 2005 and there is an big potential to develop renewable energy project and industrial energy efficiency especially in energy intensive industries. However some of the renewable plants has already sold their emissions with in the scope of VER.
Also iron and steel sector and cement sector are being made surveys on carbon potentials with energy efficiency implementations.

Air pollution

In Turkey especially during the months of winter air pollution makes itself felt due to the intensive urbanization, rapid population increase and industrialization, wrong placement of the cities according to the topographic and meteorological conditions. The main reasons for the pollution in winter that originates from heating is the utilization of low grade fuel without being subjected to the improvement processing, application of wrong burning techniques and the lack of maintenance on the furnaces that are used. However with the utilization of natural gas and other high grade fuel in heating, some improvement has been seen in the air pollution in the big cities compared to the 1990s. The wrong location selection by the industrial facilities in their establishment stage also contributes to the air pollution in the thermal power stations that are based on coal; the SO2 emissions originating from high sulphur content of domestic lignite constitute a risk.
With respect to the air pollution that is faced with in the cities, the harmful exhaust gases released by the ever increasing motor vehicles play an important role and precautions must be taken in this area. Generally the 70-90 percent of carbon monoxide emissions (CO), 40-70 percent of nitrogen oxide, 50 percent of hydrocarbon (HC) emission, as well as 100 percent of lead emissions in the city centers are caused by the motorized vehicles.

The air quality in the country in general is measured by using the semi-automatic measurement devices that belong to the Ministry of Health and it is observed in 31 fully automated measurement stations that were established in 2005 by Ministry of Environment and Forestry, the fully automated air quality measurement stations are planned to be used widely in 81 provinces in year 2006.

With the purpose of harmonizing the legislation of EC on air quality to a framework legislation a Project named ‘’Support to Turkey in the field of Air Quality, Chemicals and Waste Management’’ was started in year 2004, and with the first component of this Project, Air Quality, it is aimed to reflect the contents of EC Framework Air Quality Directive on our National Air Quality Act and to the activities for measuring the air quality along with the reflection of the provisions of The Directive of Large Combustion Plants Directive on our domestic legislation. New draft regulations were prepared for limiting emissions arising from The Large Combustion Plants and to ensure air quality and these were submitted for the approval of the related institutions. The Draft By-law on Air Quality Assessment and Management were prepared such that it covers four daughter directives (99/30/EC, 2000/69/EC, 2002/3/EC and 2004/107/EC) other than 96/62/EC numbered Air Quality Framework Directive. The new draft by-law sets the implementation calendar for implementation and harmonization for 13 pollutants that are defined under the framework directive and the daughter directives. By-law also aims to strengthen the monitoring, sanctioning and institutionalization in the area of controlling the pollution and air quality. Furthermore, one of the requirements of the directive that is air quality preliminary assessment study has started, and this study has already been completed in the provinces of Ankara, Karabük and Kütahya.

The Ministry of Environment and Forestry is determined as the responsible institution for the 98/70/EC numbered EU Directive under the heading of Turkish National Program Adoption of the Acquis. On this purpose, in the scope of harmonizing the Directive about the quality of fuel and diesel used at motor vehicles due to the 2/95 numbered Customs Union Agreement signed with EU, the 98/70/EC numbered EU Directive which came into force in 2000 in Europe, is prepared by The Ministry of Environment and Forestry by receiving approvals of related institutions and organizations, especially by taking the approval of TÜPRAS and it is transferred in Turkish laws as By-law on The Quality of Petrol and Diesel Fuels by being published on 11.06.2004 dated and 25489 numbered Official Gazette.

gedruckt am: 09.09.2010