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Convention on the Conservation of European Wildlife and Natural Habitats COMPLAINT FORM First name: Lily Surname: Venizelos On behalf of (if applicable): Â MEDASSET-Mediterranean

Association to Save the Sea Turtles

Address: c/o 24 Park Towers, 2 Brick St Town/City: London County/State/Province: Westminster County Postcode: W1J 7DD Country: UK. Tel.: 0044 2076290654 Fax: 0044 2076290654 E-mail: Web site:


1. Please state the reason of your complaint in detail (refer also the Contracting Party/es involved). This complaint addresses the threats facing the loggerhead sea turtle (Caretta caretta) nesting beaches in Fethiye, Muğla province of Turkey, due to unplanned construction and developments to accommodate tourism. Turkey is a Contracting Party to the Bern Convention which incorporates the protection of sea turtles and their habitats. The whole bay area was designated as Fethiye-Göcek Specially Protected Area (Council of Ministers’ Decision 88/13019, 12.06.1988 ). The threats to the nesting population have continuously been increasing since the first assessment conducted in 1988 (Baran & Kasparek 1989). Nesting on this beach has been deteriorating since 1993 (Türkozan, 2000; Oruç et al. 2003). The three beach sections in Fethiye are: Çalış, Yanıklar and Akgöl (Please see Fig. 1). Çalış (2.5 km) is separated from the other two beaches by a small rocky peninsula. Yanıklar (4.5 km) and Akgöl (1 km) are separated by a stream (Kargı) leading to the sea. The problems outlined below are merely a selection of the most serious current threats Fethiye’s nesting beaches face. An increasing number of snack bars are being set up in various parts of the beach, lights are attached to trees, quads are increasingly using the beaches, giant picnic areas occupy the beach especially during the weekends, there is direct car access to virtually every beach, the garbage problem is entirely unsolved, there has been sand removal and fishing occurs directly off all three of Fethiye’s nesting beaches. All beaches are experiencing an ever increasing number of beach bars, lights, watersports rental stands and dense rows of beach chairs and umbrellas. The damage has occurred despite the fact that the region is a Specially Protected Area (SPA). In general, the number of nests has been declining since first records in the early 1990s (peak 191 nests in 1995, lowest value 58 in 2004; see Fig. 2 from Ilgaz et al. 2007 for illustration of trend and Türkozan, 2003 for exact nest numbers). Fethiye is one of over a dozen major Caretta caretta nesting beaches in Turkey and, in spite of the dramatic drop in nesting, the high average number of nests for 12 consecutive years still makes this beach one of the most important nesting sites in Turkey (Ilgaz et al 2007). Specific, selected threats to the three beaches are presented separately below. Çalis Calış beach is about 2.5 km long and 17–19 m wide. Over about half its length is lined by a concrete wall, topped by a broad promenade with tourist infrastructures (hotels, restaurants, bars, etc.). Nesting occurs mostly along the promenade stretch where the beach is sandy and gently sloping. Elsewhere, the beach is steeper and consists of pebbles, but certain stretches are still used for nesting every year. (See Fig. 1) 1. The promenade part of the nesting beach has the best sand quality for nesting (i.e. fewer stones and cobbles) and is intensively used by tourists both day and night. During the last three years, several bars, 2

hotels and apartment complexes have increased their illumination with powerful lighting. In some areas, the beach is illuminated as if it were daytime. Sunbeds along this part of the beach are not removed or stacked at night and are sometimes used by tourists during the night (Fig. 6). In 2008, only one rusty ASPA (Authority for Special Protected Areas) sea turtle sign remained along the promenade (Fig. 23); in 2009 it was entirely missing. Additionally, during the daytime, motorboats collect people from Çalis Beach for water skiing (Fig. 7). An Ottoman “gondola” with illumination and loud music on board, rows along Çalis Beach every 3rd night from Fethiye harbour. 2. The major wetland at Calış has been bulldozed (starting in 2004), filled with rubble and used as the site of a large apartment complex (Sunset Beach). This complex has encroached far onto the beach (Fig. 3, 4 and 5). In 2009, Sunset Beach Apartments placed a children playground directly onto the nesting beach, including large pillows that remain on the beach during day and night (Fig. 8). Furthermore, a brand new wooden boat jetty has been built in front of “their“ beach area. (Fig. 9) Only a small stretch is now available for nesting between this complex and the adjoining Surf Café. At least 20 cars have been reported to cross this sandy area every night! (Fig. 10) Although in previous years some nests were recorded on this small beach section, in 2009 not a single Caretta caretta nest was found. 3. “Surf Cafe”: Before the construction of the “Surf Café”, the area was used for nesting by loggerhead turtles; approximately three to five nests occurred. Nowadays about 2-3 nests are deposited, but in 2008 only one nest was found. This snack bar, sport centre and camping ground complex has been continuously expanding its occupation of the beach for years. It began by placing a wall of boulders along the midline of the beach to cordon off “its” area. It culminated by installing a continuous series of sunbeds, umbrellas, wooden walkways and by laying down on the beach extensive plastic carpeting to accommodate windsurfers, kite surfers and kayakers when entering and exiting the sea. Here, beach bonfires and parties take place every week throughout the summer, during the day till late at night. The new major expansion onto the beach is the main problem as the few remaining nesting turtles are struggling to nest in the small remaining spaces between sunbeds, boats, acacia trees and the camping site! (Fig 11 & 12.) 4. At the beach section not lined by the promenade, in 2008 at least three large new snack bars opened on the beach with accompanying beach chairs and umbrellas. These new sunbeds (150) and umbrellas (66) now form a continuous beach obstruction over hundreds of metres along the sea front, directly impairing nesting; although there are many adult turtle emergences (demonstrated by the many tracks found on the beach) much fewer nests are recorded than previously. These beach facilities (officially part of Çiftlik village) now cover a major part of the Çalış beach section not lined by the promenade. (Fig. 13 and 14). In 2009, between the ‘Surf Café’ and the northern end of the Çalış beach, two new businesses have been established: a bar with sunbeds on the beach, and a bar-restaurant that has placed tables and sunbeds on the beach. (Fig. 15) A new beach bar is under construction, artificially introducing sand on the beach (Fig. 16) and constructing an artificial pond (Fig. 17) after the 3rd row of planted acacia trees (see below). 3

5. In 2001, fourteen rows of about 800 acacia trees (an introduced species), known for their extensive rooting, were densely planted along a 150 metre stretch of Çalis (Ciftlik) beach. The first row begins on the sandy part of the beach, immediately after the band of cobbles along the waterline. The trees occupy the entire sandy part of the beach and their close spacing and dense roots have made a long stretch of this beach (more than 200m) inaccessible to nesting turtles. The first two rows of acacia trees and other introduced plants in Ciftlik must be urgently uprooted and removed, as well as the stones around them. (Fig 18 &1 9.)

Yanıklar This beach, the core nesting site of Fethiye, is approximately 4.5km long and its width varies between 50m and 80m. The first few metres of the beach gently slope up from the sea and consist of pebbles. Behind this zone, sand becomes the dominant substrate. 1. Although Lykia Botanika Hotel is situated about 150 metres inside the forest behind the beach, a long walkway through the forest leads to the beach. The first development occurred with the construction of the Lykia Botanika Hotel’s beach bar, including 7 deck chairs and 3 umbrellas. Please note that construction started after the beach had been declared a Specially Protected Area. Between 2007 and 2008, the hotel increased the number of sun beds from 134 to 191, from only 3 umbrellas in 1995! Continuous expansion (e.g. volley ball courts) of this huge hotel complex and Fun Club has reduced the nesting grounds and/or disturbed nesting females and/or hatchlings. In addition to the construction of wooden huts and small bars, trees, bushes and lawn have been planted on the beach! Wooden walkways between the walls of sun beds deter adult turtles from nesting and are traps for hatchlings. Moreover, the hotel’s disco, located 25 m from the waterline, uses bright lights to produce special effects which light up the surrounding beach, aiming to attract guests from the main hotel grounds, accompanied by very loud music every night, from approximately 10 pm to 2 am (Fig. 21). 2. The boat jetty of the Lykia Botanika Hotel has been considerably extended over the years (Fig. 20). This now enables larger tourist boats and speed boats to jetty and serves as an exchange site for boats and jetskis between the Botanika Club and the nearby Majesty Club Tuana Hotel. Jetskis and boats (for water skiing and “bananas”) now speed between the two hotels all day long, directly along the shore, i.e. well inside the stipulated 1 mile zone. 3. Another holiday club “Majesty Club Tuana”, located 500 metres from the Lykia Botanika Hotel, has an even larger and more massive cement jetty, extending at least 30 m into the water. This is a centre of motorized water sport activities during the day and of beach discos, fireworks and illuminated piers at night (Fig. 22). In 2009, “Majesty Club Tuana” reportedly regularly emptied its soapy residual water into streams leading to the sea along the nesting beaches. (Fig. 25) 4

4. Sand extraction has been recorded as a considerable problem for several years. In 2009 the beach was heavily polluted due to discarded rubbish and marine debris that washed ashore (Fig. 26). The last standing ASPA (Authority for Special Protected Areas) sea turtle sign in Yanıklar is poorly positioned, far away from any tourist activity (Fig. 24). 5. Vehicle tracks can be seen every year along Yanıklar beach, mostly from farmers’ tractors who visit their fields via the beach, but also increasingly from tourists and locals attempting to cross the entire beach with 4-wheel drive cars and trucks. Hatchlings fall victims under the wheels of these vehicles or die desiccated under the blazing sun, unable to reach the sea having followed the vehicle ruts parallel to the sea. (Fig 27, 28 & 29.)

Akgöl The beach extends from Uzun Cape in the north to the mouth of Kargı stream in the south. It is approximately 1 km long and 50 m wide. The front of this beach consists of pebbles of up to 2 cm diameter. Behind this zone, the beach becomes much steeper and is composed of a mixture of sand and pebbles: sand is the dominant substrate at some places. Except for short yet very important stretches of sand at both ends, this beach is less suitable for nesting as about 300–400m are mostly covered with pebbles. This section is under threat because road access to the beach has been substantially enlarged. A new camping site has been created at one end of the beach and has already installed a volleyball court directly on the beach, as well as a wooden walkway made of pallets on top of the part of the beach where several nests were deposited each year (no nesting was recorded the last few years). Beyond the existing degradation, a serious threat has been announced: the approval of the construction of a shipyard/small marina, which would permanently and irrevocably destroy the key nesting area of Akgöl beach. This opposes all sea turtle conservation laws and Conventions and is fully incompatible with Fethiye’s SPAstatus. In 2008, two-thirds (75%) of all nests in Akgöl were laid in the planned project area, i.e. on the sandy end section of the beach. We are unaware of the existence of an Environmental Impact Assessment. References Baran İ, & M. Kasparek. 1989. Marine turtles Turkey. Status survey 1988 and recommendations for conservation and management. WWF, Verlag, Heidelberg, Germany. Ilgaz, C., Türkozan, O., Özdemir, A., Kaska, Y. & M. Stachowitsch. 2007. Population decline of loggerhead turtles: two potential scenarios for Fethiye beach, Turkey. Biodiversity and Conservation 16: 1027 – 1037 (DOI 10.1007/s10531-006-9040-2). Oruç, A., O. Türkozan & H. Durmuş. 2003. In the Tracks of Marine Turtles: Assessment of Marine Turtle Nesting Sites 2003. WWF, Istanbul. 96pp. Türkozan, O. 2000. Reproductive ecology of the loggerhead turtle, Caretta caretta, on Fethiye and Kızılot beaches, Turkey. Chelonian Conservation and Biology 3:686-692. 5

Witherington B.E. & A.B. Bolton (eds.). 2003. Loggerhead Sea Turtles. Smithsonian Books, Washington D.C., 319 pp.

2. Which are the specific specie/s or habitat/s included in one of the Appendices of the Bern Convention potentially affected? (Please include here information about the geographical area and the population of the species concerned, if applicable) Loggerhead (Caretta caretta) sea turtles nesting at Fethiye are included in Appendix II of animal species requiring special protection. Please see Fig. 1 for a map of the geographical area. Nesting: the 12-year average (1993–2004) is 112 ± 34.9 nests (range: 58–191) per season with an average density of 14 ± 4.4 nests/km (Ilgaz et al., 2007). Nesting follows a negative trend indicating a serious decline in nesting (Fig. 2).

3. What might be the negative effects for the specie/s or habitat/s involved? The drop in nesting at Fethiye has already been documented and does not correspond to a visible increase at neighbouring beaches, leading to the interpretation that the number of nesting turtles here is declining (Fig 12). The overall decline indicates poor sea turtle conservation measures in this region. Apart from natural causes (e.g. severe winter storms have altered certain beach sections, replacing sand with pebbles and cobbles) the decline is caused by the anthropogenic impacts described in section 1. The destruction of nesting beaches in Fethiye, combined with the ongoing destruction of immediately adjoining wetlands for major upcoming construction projects, are incompatible with the Special Protected Area status of Fethiye beach. In addition, it must be emphasized that should nesting continue to deteriorate or even cease in Fethiye (see scenarios in Ilgaz et al, 2007), the genetic diversity of loggerhead sea turtles in the Mediterranean will also decrease (Yılmaz et al, 20081). Genetic diversity of species is extremely important for their survival in evolutionary terms. The more genetic diversity, the more chance for the survival of these species. This is one of the most important beaches for Caretta caretta sea turtles in the Mediterranean. Throughout the Mediterranean the stress on the species is already enormous and beaches as important as Fethiye should be meticulously protected through implementation and enforcement of national and international conservation legislation.

4. Do you know if potentially affected species or habitats also fall under the scope of other international Conventions, (for instance: RAMSAR, CMS, ACCOBAMS, Barcelona Convention, etc) or if the area has been identified as a NATURA 2000/Emerald network site? The Parties to the Barcelona Convention included among their priority targets for the period 1985-1995 the protection of Mediterranean marine turtles (Genoa Declaration, September 1985) and to this end the Mediterranean countries adopted in 1989 the first Action Plan for the Conservation of Mediterranean Marine Turtles within the framework of the Mediterranean Action Plan. In 1996, the Parties confirmed 1

Yılmaz C. ,Türkozan O. ,Bardakçı F. Population genetic structure of loggerhead turtles, Caretta caretta, in Turkey

based on mtDNA sequences ,3rd Mediterranean Conference on Marine Turtles, 22/10/2008



their commitment to the conservation of marine turtles by including the 5 species of marine turtle recorded for the Mediterranean in the List of Endangered and Threatened Species annexed to the Protocol concerning Specially Protected Areas and Biological Diversity in the Mediterranean (Barcelona, 1995). Turkey is a signatory to these international Treaties and the affected species fall under their scope. As mentioned, Fethiye-Gรถcek is designated as a Specially Protected Area in the framework of the Barcelona Convention. Caretta caretta turtles are included in Appendix I (Endangered migratory species) of the Convention on the Conservation of Migratory Species of Wild Animals (also known as CMS or Bonn Convention) They are also protected by the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES - Appendix I for the most endangered species).

5. Do you know if there are any pending procedures at the national or international level regarding the object of your complaint? Recommendation No. 66 (1998) on the conservation status of some nesting beaches for marine turtles in Turkey (Adopted by the Standing Committee on 4 December 1998) has been made towards the Government of Turkey, recommending to: -Take urgent necessary measures to fully implement the protection status of Special Protected Areas (SPAs); - Take urgent and stringent measures to enforce legislation against illegal sand extraction on the 17 nesting beaches; assure that penalties for illegal sand extraction are dissuasive enough by raising the amount of penalties, or by the application, where appropriate, of criminal law, or by the use of any other effective legal or administrative measures; - Regulate and, where necessary, prohibit speed boats, jet skis and para-gliding during the nesting season; ensure respect of low speed limits set and reinforce controls on all off-shore areas of 17 nesting beaches; Specifically for Fethiye it was then recommended to: secure the remaining unbuilt beach plots against development.


6. Any other information (existence of an Environmental Impact Assessment (EIA), size of projects, maps of the area, etc)

Fig. 1: General map of Fethiye beach showing the three beach subsections (Ilgaz et al., 2007)

Fig. 2: The downward trend in nest numbers of loggerhead turtles at Fethiye beach. (Ilgaz et al, 2007)


Fig. 3: August 2004. Fethiye, SPA. Çalis. Freshly bulldozed wetland in Çalis. Narrow green belt between beach and wetland has now also been ploughed under and covered, ready for development.

Fig. 4: Around 2006. Fethiye, SPA. Çalis. Same bulldozed wetland in background (brown strip) as in Fig. 3. Also note new building complex in photo centre.



Soft chairs

Palm trees

Potted banana trees

Fig. 5: August 2008. Fethiye SPA, Çalis. New apartment complex, Sunset Beach Apartments, built on former wetland, has placed onto the beach 80 new sunbeds, 30 new umbrellas, large soft chairs and potted banana trees onto the beach. Several large palm trees have been planted in front of the complex; a new concrete road along the beach in front of the walled-in apartment complex has been opened and new lamp posts/spotlights have been installed. Fig. 6: July 2009. Fethiye, Çalis, Specially Protected Area (SPA). Çalis Beach along the broad promenade in the early morning. Beach furniture remains on the nesting beach 24 hours a day and waste is not collected.

Fig. 7: July 2009. Fethiye, SPA. Çalis. During the daytime, motorboats collect people from Çalis beach for water skiing.


Large pillows

Fig. 8: July 2009. Fethiye SPA, Çalis. Sunset Beach Apartments have produced a children playground right on the nesting beach. The large pillows and playground equipment remain on the beach throughout the day and night.

Fig. 9: July 2009.Fethiye SPA, Çalis. Sunset Beach Apartments’ new wooden boat jetty.

Fig. 10: July 2009. Fethiye SPA, Çalis. Car tracks on the nesting beach between Sunset Apartments and Surf Café, visited every night by at least 20 cars.

Fig. 11: July 2002. Fethiye SPA, Çalis. Earlier stage of Surf Café (formerly Hang Loose Surf Café).

Large stones Large stones


Fig. 12: July and August 2008. Fethiye SPA, Çalis. Overview of beach occupation by Surf Café. Note extensive carpeting on beach, as well as kayaks and other sea sport vessels pulled onto the beach and the plastic carpets.

Fig. 13: August 2008. Fethiye SPA, Çalis. Continuous wall of sunbeds and umbrellas along Çalis (Ciftlik) beach section where nesting occurs.

Fig. 14: July 2009. Fethiye SPA, Çalis. At the end of Çalis promenade, each restaurant or cafe owner has set out furniture onto the beach. Sunbeds are densely positioned forming an impenetrable obstruction for turtles attempting to nest on the beach.


Fig.15: July 2009. Fethiye SPA, Çalis. Another brand new restaurant (“Mutlu”) now provides dinner on the beach – note the tables. Sunbeds are very close to the water line and densely positioned.

Gravel Artificially introduced sand

Fig. 16: July 2009. Fethiye SPA, Çalis. Between Surf Cafe and Sunset Cafe, the pebbly part of the beach was overspread with sand in order to accommodate visitors (see border between sand and gravel strips).


Fig. 17: July 2009. Fethiye SPA, Çalis. Behind the new, artificially sandy beach area, a new bar or restaurant and an artificial pond are under construction.


Fig. 18: July 2001. Fethiye SPA, Çalis. Newly planted acacia trees. Note tracks of vehicles (trucks) used to water plants and trees.

Fig. 19: August 2008. Fethiye SPA, Çalis. Roots from each acacia tree spread up to 4 metres in all directions. Note that the sandy part of nesting beach is now fully occupied by trees.

Fig. 20: Fethiye SPA, Yanıklar. Lykia Botanika jetty:in 1995 (left) and in 2007 (right)


Fig. 21: August 2008. Fethiye SPA, Yan覺klar. Several continuous rows of sunbeds with wooden walkways in between, are obstructions which prevent turtles from nesting and hatchlings from emerging and/or reaching the sea. Lykia Botanika jetty in background. wooden walkways

Fig. 22: July 2004. Fethiye SPA, Yan覺klar. Majesty Club Tuana massive cement jetty, extends at least 30m into the water. This area is a centre of motorized water sport activities during the day and of beach discos, fireworks and illuminated piers at night.


Fig. 23: August 2007. Fethiye, SPA. Çalis. Desolate and poorly positioned sign towards the end of Çalis beach. In 2009 it was entirely missing. There is no adherence to any of the rules or regulations on the signs. Note the bus parked on the nesting beach.

Fig. 24: August 2009. Fethiye SPA, Yanıklar. This last standing sign in Yanıklar is located far from any tourist activities. No new or renovated conservation signs exist at Fethiye nesting beaches, while those in Çalis have disappeared altogether.

Fig 25. July 2009. Fethiye SPA, Yanıklar. Majesty Club Tuana regularly empties its soapy residual water into streams leading to the sea along the nesting beaches.

Fig. 26: July 2009. Fethiye SPA, Yanıklar. Discarded rubbish and marine debris pollute the beach. 16

Hatchling tracks

Fig. 27: July 2005. Fethiye SPA, Yan覺klar. Tracks of hatchlings trapped in vehicle rut running in parallel to the water line, thus never reaching the sea.

Fig. 28: July 2006. Fethiye SPA, Yan覺klar. Light-disorientated hatchlings, on road behind beach, run-over by vehicle.

Fig. 29: July 2009. Fethiye SPA, Yan覺klar. Vehicle ruts along the whole nesting beach. Caretta caretta nest marked with stones, directly between tire tracks: vehicle passed right above the nest!


Date and signature: 31. 08. 2009


Complaint to the Bern Convention addressing the threats facing the loggerhead sea turtle  
Complaint to the Bern Convention addressing the threats facing the loggerhead sea turtle  

Author: L. Venizelos, MEDASSET