While in Turkey over the winter 2009/2010, we took an active part in a campaign to persuade the Turkish authorities to modify the proposed Blue Card scheme. The representations made by cruising organisations and others were successful in obtaining a delay to their implementation. Mo and I left Turkey in 2010 and are heading out of the Mediterranean. We are not therefore able to follow developments directly. We will however try to keep our ear to the ground and maintain the notes while they are helpful.
The proposals have from the outset caused considerable and perhaps some unneccessary grief and confusion. The main reason for this has been a complete absence of detailed and authorative information from the Turkish authorities. Such information that has become available has dribbled out, usually from people with one kind of an axe or another to grind. Where plans have been delayed, modified, or even rescinded, there has been no definitive statement made.
Proposals were published in 2009 by the Mugla Governor, requiring all boats in Mugla province (north of Bodrum to south of Fethiye) to carry a Blue Card. Restrictions were also introduced in 'Gocek Dalaman bays' known as Skopea Limani and its offlying islands, and these were supposed to be in effect from August 2009.
The present position, as we now understand it, is that the original legislation for both the Blue Card dealing with disposal of waste water and sewage, and also the Skopea Limani restrictions remains in place. The Blue Card theoretically relates to the whole of Mugla province, north of Bodrum to just north of Kas.
There appears to be an acceptance by the authorities that the collection of grey water and its disposal by pumping ashore is impracticable in smaller yachts, and this is not presently being enforced.
The Blue Cards were manufactured and are available. Marmaris Yat Marine have issued them, reports suggest that these being variously issued free, and other reports of a variable charge being made. Other marinas appear to be neither issuing nor demanding them.
There remains a dirth of pump out points available to use, and little authorative information as to location and charges. The mobile pumping equipment does not appear to be fit for pumping rapidly at the high volume necessary. Where people have used the pump out facilities, charges have varied considerably, one boat being charged 80 euros for a pump out.
It is not clear what criteria will be used in assessing whether a boat has conformed. Original suggestions that 50litres per person per day were indicated were clearly absurd. For the moment, it appears, no one is enforcing the use of Blue Cards/pumpouts. In this context, common sense and sensitivity to Turkey's environmental concerns is necessary. Heavy fines are imposed if yachts are seen to dump black water, or even 'suds', and the authorities are on the look out.
In Skopea Limani, a Turmepa sponsored pump out boat has been operating. For a period in 2011, its services were provided free of charge for an experimental period. It has been observed servicing gulets, but no reports of actively approaching yachts.
In Skopea Limani there are some additional buoys and mooring posts provided: use of trees is forbidden. Reports of confusion with regard to the buoys. There have been no other reports of enforcement measures.
In January 2011, a DVD and booklet outlining the Blue Card and Skopea Limani restrictions was distributed to berth holders at Netsel and to visitors to LIBS. There have been no reports of enforcement.
As a result of the representations a number of meetings were held in 2010 to discuss the regulations, culminating in meetings between the Governorship in Mugla, and the ministries of Transport and of Tourism in Ankara. The implementation of the Blue Card scheme was deferred for 'one year', and is unlikely to go ahead as originally envisaged.
Unfortunately no official statement of the position has been published, as far as we know. People who were concerned about coming cruising in Turkey remain so, and many are still being deterred. The nearest we have is an article in a local newspaper, where the official from the Environment Ministry admits to the delay. Unfortunately the article goes on to display considerable confusion as to the real implications of installing grey water tanks in small boats.
There is general support amongst the organisations to improve and control the environmental impact of boats using Turkish waters, and therefore it is planned to proceed with the implementation of the Blue Card Scheme in some form. Particular emphasis was placed on controls within Gocek-Dalaman bays (in practice Skopea Limani and offlying islands). We understand now that some limited changes may be made to the restrictions in Skopea Limani. How these may affect cruising in this area this season remains to be seen.
The authorities now recognise some of the practical issues relating to the application of the proposed regulations. It is likely that changes will now be phased in gradually, and a recognition that shoreside facilities must be provided first.
The main 'open issue' is the application of the Blue Card scheme to the vast majority of boats without deck pump out facilities. Interestingly, one of the main contributions to the debate was a realisation that detergents and other pollutants are more serious than black water waste, so that promotion of appropriate 'eco-friendly' products might be one way to go.
The Blue Card was said to be charged at 70 YTL, to last indefinitely. All boats will be required to discharge both 'grey' and 'black' water at designated locations, and volumes discharged will be recorded on the Blue Card. You will not be allowed to discharge at all within Turkish territorial waters. Considerable fines for contravening the regulations will apply, with a hint that boats might be impounded for repeat offences. It is difficult to see how many boats can comply, nor how the infrastructure can be in place to enable the number of boats cruising in this area of Turkey to be pumped out. The relevant regulations are posted here, together with notes of a meeting on the subject held at Marmaris Yat marine in October 2009, a letter of concern from the Cruising Association, and other references as they become available:
An acknowledgement was received by the Cruising Association, and it alluded to "difficulties at the beginning, but we can overcome those by mutual good will by time and while overcoming them we develop more our schedules". A reply was sent asking for a positive statement of what was intended.
Rumours abound: the regulations are unlikely to be implemented in their current form, next year, this year. They will not apply 'retrospectively' (what does that mean) or to older boats (ditto).
If the authorities do have second thoughts, what is now needed is a positive statement to that effect, so that people can continue to plan to enjoy Turkey and its magnificent cruising areas. That may not be readily forthcoming.
Much of Skopea Limani and the outlying islands are now subject to special environmental protection regulations. These seek to limit the number of vessels in the area to 1112 boats. Mooring will only be allowed to buoys, bollards etc. and anchoring will be prohibited.