The “Regulation on Reclamation of Lands Disturbed by Mining Activities,” published in December 2007 and amended in January 2010, is a milestone toward establishing requirements for mine closure planning in Turkey. It requires that reclamation plans for mining projects be appended to the Environmental Impact Assessment (EIA) reports.
The regulation provisions do pose general mitigating actions, such as post-mining safety of the land and acid rock drainage prevention and mitigation, but the process is still in its infancy and shows some limitations. First, as evidenced in its title, the concept of “reclamation” is rendered in Turkish as “restoring to nature.” In general, the approach addresses the impacts of the earth-moving aspect of mining, rather than those arising from recognising the need to explore after-use opportunities. Perhaps understandably, at this stage, there is little encouragement for considering alternatives in post-mining land use that add value to post-industrial landscapes, whether through governmental guidance or community consultation and regular closure planning. However, there are mentions, in passing, of the creation of recreational ponds being governed by the relevant regulations, and the utilisation of infrastructure after the mining activity, even though they appear in the regulation’s appendix. Secondly, as the regulation focuses on mining activities only, there have been examples of EIA processes allowing tailings dam expansions to operations or otherwise benefiting from “grandfather provisions” to the EIA regulation or where stand-alone mineral processing facilities have been exempt from the official requirement for closure planning.
Reclamation plans are currently submitted to the authorities on a once-only basis without a requirement to update, include cost estimates and post bonds, or conduct community consultation about post-mining land use expectations. And the published views of some chambers to the regulation’s draft amendment sanction the impression that interested parties view its purpose as parallel to that of an EIA. Nonetheless, we must not lose sight of the landmark status of the regulation. Potentially, a broader understanding of closure could develop through Turkey’s efforts toward accession to the European Union and the transposition of the Mine Wastes Directive and Environmental Liability Directive to eventually converge with internationally accepted best practice.
