From ... in Environmental — Sep 2, 2024

Türkiye: Plans for Harmful Coal Expansion

(Istanbul) – Türkiye’s Environment Ministry should not approve the planned addition of two more units at Afşin-Elbistan coal power plant A in the southeastern Kahramanmaraş province in view of the serious harm the plant has caused the surrounding community, Human Rights Watch said today. Human Rights Watch research found that air pollution levels near plant A – and the later built plant B located two kilometers away – are dangerously high and that residents are experiencing health conditions that academic studies have attributed to toxic air. Despite an early government warning that a cancer explosion was expected in Afşin-Elbistan, the government has failed to monitor and reduce the harm with more stringent regulations and enforcement. “Toxic air from coal power plants is killing thousands of people every year in Türkiye while authorities do little to prevent the problem or even to warn people of the harm to their health,” said Hugh Williamson, Europe and Central Asia director at Human Rights Watch. “Instead of authorizing the expansion of polluting coal power plants, the Turkish government should strengthen and enforce air quality standards and enable a just transition from coal to renewables by 2030.” The government is continuing to expand coal plants notwithstanding significant progress in Türkiye’s renewable energy sources that research has shown would enable Türkiye to exit coal by 2030. Renewable energy sources currently make up 54 percent of Türkiye’s installed electricity capacity, significantly above the global average of about 30 percent, and the International Energy Agency projects renewable energy use to increase 50 percent between 2021 and 2026. In May 2024, Human Rights Watch interviewed 28 residents about their experiences of air pollution in Afşin-Elbistan, including 11 women and 4 older people; 2 elected village headmen from nearby villages; the mayor of the nearby town of Elbistan, 2 academics, 5 health professionals working in the region, 2 lawyers, 1 public official, and 6 local activists. Human Rights Watch also reviewed and analyzed recent air quality data from the closest governmental monitoring station whose data is publicly available, satellite data of air pollution from the EU Copernicus program, and official government documents. Human Rights Watch wrote letters to the relevant seven divisions at the Health Ministry and that the parent company of the firm operating coal plant, which had applied for the additional units; to the state-owned electricity generation company; and to local government authorities. It also wrote to the Turkish Statistical Institute requesting health data related to Afşin and Elbistan districts. None have responded. Residents living near the coal plants said that friends, family, and neighbors had died from cancer and cardiovascular or respiratory ailments they believe were attributable to or exacerbated by the pollution from the nearby plants. A 57-year-old man in a village about 500 meters from coal plant A has had respiratory illness for the past 13 years: “I have asthma, and my doctor says I need clean air. But there is no clean air. We are all ill here.” Health care workers interviewed said they had seen increased rates of respiratory problems in areas surrounding the plants.

The coal mine feeding the power plants in Afşin-Elbistan is a so-called carbon bomb, one of the world’s largest fossil fuel production projects with a coal extraction capacity of 4.09 gigatons of carbon dioxide. Expanding the coal plant threatens Türkiye’s energy transition and jeopardizes Türkiye’s obligations under the Paris Agreement on Climate Change. Despite substantial investment in renewable energy sources, including solar and wind energy, Türkiye’s 2022 National Energy Plan makes no mention of a planned phaseout from coal-based electricity generation.

The country became Europe’s largest coal-fired electricity producer in early 2024 and accounts for 73 percent of planned but not-yet-constructed coal projects within the Organization for Economic Cooperation and Development (OECD) and the EU that are actively seeking necessary approvals and financing. Based on the World Health Organization (WHO) estimates, more than 35,000 people died from air pollution in 2019 in Türkiye. Türkiye should address air pollution as part of its constitutional and international legal obligations to realize the human rights to health, life, and a healthy environment and stop the expansion of coal plants in line with the duty to prevent exposure to toxic substances.

The government should tackle the root causes of air pollution by drastically reducing the release of harmful pollutants, including with concrete actions to phase out coal by 2030 and refraining from expanding existing operations. It should also take concrete steps to better monitor air quality and make the results easy to access and understandable by everyone, and by improving and applying rigorous air quality standards in line with WHO recommendations, especially in areas affected by coal plant emissions.

The government should promptly introduce limits for PM2.5 – polluting particulate matter – concentrations in line with current EU regulations, and further strive to update its air quality standards to comply with proposed new EU standards expected to be adopted later in 2024. Data of emissions from large combustion plants should be made public. “People in Afşin-Elbistan have been paying the price of coal-based electricity generation for decades,” Willamson said. “Instead of expanding a coal plant in an area where people have been exposed to high levels of pollution, the governments should urgently protect their lives and realize their right to a healthy environment.” For additional details about air pollution and the situation in Türkiye, please see below. Scientific research has found that exposure to air pollutants from coal power plants is associated with a risk of mortality more than double that of exposure from other sources and that canceling new coal plants would reduce air pollution related mortality globally.

The use of coal for electricity generation, alongside the domestic residential use of coal and wood for heating, creates heavy air pollution in Türkiye’s coal regions. Türkiye produces electricity by burning lignite, a low-quality polluting type of coal found in abundance throughout the country, in outdated coal plants. Over four decades, successive Turkish governments have built and expanded two of the country’s biggest coal power plants, plants A and B, in Afşin-Elbistan. Emissions from plant A, which lacked technology to reduce emissions from its inception in 1984 through its temporary closure in 2023, are of particular concern, Human Rights Watch said. Plant A is 2.5 kilometers from plant B, which was built in 2004 using newer technologies. Despite this, the Turkish authorities are due to be presented with an environmental impact assessment that gives the go-ahead for the construction of two additional units at power plant A, with an additional capacity of 688 MW and an investment cost of 37.5 billion Turkish Lira (at the time approximately 1.1. billion USD). A 2022 study commissioned by Greenpeace Mediterranean estimates that the planned expansion of the plant will lead to about 1,900 premature deaths over its 30-year economic lifespan. Human Rights Watch analysis of air quality data from January 2021 to June 2024 found dangerously high levels of air pollution in the area surrounding the Afşin-Elbistan coal plants. Analysis of satellite data from the Copernicus Sentinel-5P mission shows that the average concentration of sulfur dioxide (SO2) was significantly higher over the plants and in the surrounding villages than over Elbistan, the location of the closest air quality monitoring station whose data is published. Residents living in villages close to the coal plants said they have not received any information about the risks from the plants in the region or how to help protect themselves. Türkiye’s air quality standards are less strict than those recommended by WHO and do not include a limit for the harmful PM2.5 pollutant, responsible for the most deaths worldwide of any pollutant, leaving a major regulatory gap. Coal, Health, and Climate Change Globally, coal plants are responsible for over 20 percent of the world’s greenhouse gas emissions: more than any other single source contributing to the climate crisis. Burning coal, and in particular lignite, releases significant pollutants including particulate matter and sulphur dioxide (SO2), each of which can significantly harm health.

The impact of particulate matter of less than 10 micrometers (PM10) and of less than 2.5 micrometers (PM2.5) on human health is substantial. PM2.5 can reach deep into the lower respiratory tract, leading to serious respiratory and cardiovascular problems, and can easily enter the bloodstream and penetrate the lungs. Another pollutant of concern is SO2 which can cause harmful effects to the lungs, damage the cardiovascular and nervous systems and contribute to type 2 diabetes and even death. Although Türkiye’s updated 2023 Nationally Determined Contributions, its climate action plan under the Paris Agreement, aims to increase the share of renewable energy sources in electricity generation, the country has not set a date for a coal exit. Allowing the addition of two new units with a total capacity of 688 MW to the existing 1.355 MW at the coal power plant Afşin-Elbistan A could undermine efforts to phase out coal. Despite these advances, government data indicates that 36 percent of the electricity produced in Türkiye in 2022 was generated by coal plants. Türkiye’s operating coal fleet grew by 34 percent between 2015 and 2023.In the first quarter of 2024, the total installed capacity of coal plants was 20.2 GW, with an additional 2 GW capacity expected by 2035. Coal Feeding Toxic Air According to 2019 Turkish Health Ministry data air pollution is among the most important factors affecting life expectancy in Turkey. A 2001 scientific study found that communities near coal plants in the western province of Kütahya are more likely to experience health problems such as respiratory problems and reduced lung function, conditions commonly linked to air pollution. Another study, first published in 2010, found that the impact of air pollution on people in villages near the Bursa Orhaneli coal plant in northwest Türkiye was dependent on their proximity to the coal plant as a predictor of various respiratory diseases. Children living in Türkiye’s coal-mining areas are also at higher risk of exposure to dangerous heavy metals. Türkiye has f 380 air quality monitoring stations across the country; the closest to Afşin-Elbistan coal plant A with publicly available data is in Elbistan, 22 kilometers away. Other stations are within 3 kilometers of the plant produce no publicly available data. Human Rights Watch analysis of SO2 concentrations recorded at the Elbistan ground monitoring station between 2019 and June 2024 shows that pollution levels started to decrease when operations of plant A temporarily ceased between February and May 2020 because the government said it had failed to comply with regulatory requirements. Pollution levels decreased even more significantly when operations of plants A and B ceased for most of 2023 after the two earthquakes of February 6, 2023, affecting the entire region and slightly damaging the plant.

The Right to Clean Air Platform (CAP), a national network of environmental groups and health professionals, similarly found that Afşin-Elbistan was a pollution hotspot in 2019.

The SO2 values recorded at the government ground level monitoring station in Elbistan are very likely to be much lower than at the levels at locations closer to the plant.

The average SO2 vertical column density at ground level from January 1, 2019, to June 1, 2024, over the village of Çoğulhan, directly adjacent to the plant, was almost three times higher than the average density recorded over the monitoring station in Elbistan during that period.

The Afsin-Elbistan A plant had been allowed to operate without filters required by environmental regulations for many years. Despite repeated legal challenges and campaigning that resulted in its closure on January 1, 2020 for failure to comply with environmental regulations, the government permitted the plant to reopen in May 2020 and to continue operating until the earthquakes, which damaged the plants. As of December 26, 2023, only one of four A plant units, for the first time fitted with a desulfurization filter, had been permitted to restart. While the best available technology for desulfurization can drastically lower SO2 emissions, it is unclear whether this technology is used at the unit that has been permitted to restart.

There are also concerns that air pollutant filters lose performance efficiency over time. As is acknowledged in the environmental impact assessment, if new units are added to the existing coal plant, SO2 pollution levels in the area will rise. In addition, while the best available desulphurization technology can significantly limit exposure to SO2, it cannot undo the health harm caused by prior exposure. In November 2018, Çelikler Holding, a private company, took over Afsin-Elbistan A plant, from the state company (EÜAŞ), which previously operated it. Human Rights Watch does not know the terms of the agreement between the state company and Çelikler Holding and key details of the agreement should be made public. Çelikler Holding says on their website that they “aim to prevent negative impacts on the environment and society and to take appropriate measures [to reduce such impacts] where they cannot be prevented.” The company did not respond to questions about the measures taken to minimize the release of harmful air pollutants and requested projections once filtration is fully installed at the plant. Human Rights Watch analysis of PM2.5 levels recorded at the government monitoring station in Elbistan from January 2021 to June 2024 found that the average PM2.5 concentration was more than five times the annual WHO recommended level and almost three times the proposed 2030 EU standard. Türkiye has not established PM2.5 limits under its pollution control laws/standards aligned with the EU limits. Human Rights Watch analysis of PM10 concentrations at the Elbistan air quality monitoring station between January 2021 and June 2024 also shows that pollution levels have remained high in recent years, with an average PM10 concentration more than four times the annual WHO recommended level and 1.75 times the 2019 Turkish standard. Health Impacts of Toxic Air Fed by Coal in Afsin-Elbistan The United Nations Committee on Economic, Social and Cultural Rights has told governments that to protect and fulfil the right to health governments are required to implement policies to reduce and eliminate air pollution. People living in the vicinity of the coal plants in Afşin-Elbistan described health problems that they believe could be related to the toxic air they are breathing. Hacıkız Savran, 70, who lives less than 500 meters from the power plant and can see the plant’s chimney belching out smoke from her living room, said she has had severe asthma for more than 7 years: “[My] doctor was surprised to hear that I had never smoked in my life. He said, ‘Why did you become [this sick] if you never smoked?’” Fatma (real name withheld for her own protection) 55, lives in Çoğulhan, has had asthma for 4 years and lost her son to lung cancer which she believes was linked to pollution from the plant. She worries about the impact of air pollution on women: “There is a lot of asthma and a lot of chest and lung conditions among women in the village.... Men can go off in their cars to other places but we as women are always at home. We have to suffer the dirt of the plant.” Children from Çoğulhan and six neighboring villages attend schools close to the plant. A health professional in Elbistan told Human Rights Watch that they had observed a high incidence of respiratory diseases, particularly among children. People with certain health conditions, such as asthma or cardiovascular problems, children, older people, pregnant women, workers, those living in poverty, and members of other socially and economically marginalized groups are among those most at risk of exposure and adverse effects of air pollution. Scientific research drawing on data from 83 countries suggests that the more a country relies on coal power plants to generate energy, the greater the lung cancer risk. While research specific to the health impacts of air pollution for people in surrounding areas of the Afşin-Elbistan coal plant is scarce, a 2009 PhD thesis found that nonsmokers in nearby villages were more likely to experience genotoxic damage than those further away from the plant, which may increase the risk of cancer. Similarly, a 2007 academic study found nonsmoking workers employed in the transportation of fly ash at Afşin-Elbistan A power plant to be more likely to experience cytogenetic damage (changes in their chromosomes which can lead to cancer). Several people interviewed expressed concern about high numbers of cancer cases in their families.In 2002, the head of the Health Ministry’s Cancer Control Department stated that a cancer explosion was expected in Afşin-Elbistan, in the ensuing five years.

The official noted that a coal power plant had been built there 30 years earlier and that the coal plant poses a serious danger to the people of the region. A 2017 report by the same ministry identified Elbistan as a priority region for establishing an oncology service, a recommendation that has not been followed.

The Health Ministry did not respond to questions regarding cancer prevalence in Afşin and Elbistan districts and whether further studies had been carried out. Lack of Sufficient Monitoring of Air Quality In 2019, the UN special rapporteur on human rights and the environment published a report focused on the right to breathe clean air as one of the components of a right to a healthy environment. He outlined key steps governments to take in fulfilling the right to a healthy environment by ensuring clean air, the first of which is to monitor air quality and its impact on health. Over the years, Türkiye has invested in developing its air quality monitoring systems, supported by EU accession funds. Yet the number of stations remain insufficient and data from areas at high risk of pollution is not available to the public. While the Turkish government air quality monitoring website provides measurements from ground level monitoring stations across the country, the historic data is at times incomplete and pollution hotspots like Afşin-Elbistan are not closely monitored. According to analysis of 2016-2019 data, conditions in at least 21 of 81 provinces could not be adequately assessed because data was available for fewer than 75 percent of days, a criterion of the European Environment Agency. Residents of Çoğulhan said that a monitoring station in the village was no longer operational, and no data from the station is publicly available. Human Rights Watch wrote in May 2024 to government and to the state-run electricity production company (EÜAŞ) seeking any data from the station, but received no reply.

These shortcomings prevent the Turkish government from reliably monitoring the impact of coal plants on air quality. Lack of Information, Consultation about Power Plant Expansion Another key step for governments to take to fulfill their human rights obligations is to share information in a timely, accessible way, educating the public about health risks and issuing health advisories. Yet there is a dearth of information about the real extent of air pollution in the region and related health risks. In addition to the lack of effective monitoring of ground level air pollution, the emissions from large combustion plants, including coal plants, are not publicly available in Türkiye. Even when courts have ordered the government to provide emissions data of coal plants publicly, the authorities have not revealed the data. Residents in Çoğulhan, Berçenek, and Altunelma, said they have not received any information about the extent of environmental problems in the region, possible health effects, or how to participate in decisions around the coal plant that would enable them to address prevent health risks and seek remediation for health harms suffered.

The Environment Ministry provides some health advice on a website, such as suggesting that members of sensitive groups limit outdoor activities when air pollution levels are high, but it does not provide detailed practical advice for at risk groups. Residents also raised concerns about their lack of information about the planned expansion of the coal power plant. “They don’t ever tell us anything,” said Savran, the 70-year-old resident. “Everything is decided in Ankara.” The newly elected mayor of Elbistan said that even municipal authorities were not consulted during the expansion approval process, an apparent violation of Turkish regulations governing the process. Human Rights Obligations and Air Pollution Human rights obligations to respect, protect, and fulfil rights including those to life, to bodily integrity, to health, to information and to a healthy environment require governments to take action to prevent air pollution and strive to ensure clean air.

The UN Human Rights Committee, in its comment on obligations on the right to life noted that implementation of the obligation to respect the right to life, depends, among other things, on governments taking measures to protect the environment against pollution caused by public and private actors.

The UN special rapporteur on human rights and the environment has set out how states must not only not violate the right to breathe clean air through their own actions but also protect the right from being violated by third parties, especially businesses. To do so, governments must establish, implement and enforce laws, policies and programs to fulfil the right.

They also have duties to promote education and public awareness; provide access to information; facilitate public participation in the assessment of proposed projects, policies and environmental decisions; and ensure affordable, timely access to remedies.

The European Court of Human Rights has found in several cases that severe environmental pollution affecting individuals’ well-being violated their rights to privacy and family life. In finding violations of human rights, the court has taken into account the proximity of homes to the source of pollution. In its case-law, the court has established that governments have a positive obligation to undertake due diligence with respect to pollution hazards, weigh the impact they have on personal and family lives against any competing interests, and take effective measures to protect people’s lives and health, including by preventing or reducing the harmful impacts and providing adequate information to people.

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Türkiye: Plans for Harmful Coal Expansion

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