Recently the Georgian authorities have been making statements about the plans to launch the construction of the Namakhvani HPP Cascade on the Rioni River that is the territory of historical Lechkhumi.

We would like to state that an optimal decision for the country and its population, whether to construct a large HPP or not, should be made through taking into consideration the environmental, social, economic, political and other arguments as well as through active public participation. Without this process, making an announcement about launching the construction will go beyond any legal and good governance framework. The above mentioned emphasizes the faulty practice established in Georgia during last years, when assessment of impacts of the planned projects has a formal nature and is applied not for making optimal decisions, but for “substantiation” of the decisions already made by the government in favor of the project implementation. Like the residents of Mestia, Anaklia, Lilo, Avchala, Khaishi and other Georgian settlements, the rights of the Lechkhumi population are violated under the pretext of the need to implement the projects of obscure “state importance”.

Thus, we have the following situation in respect of the construction of Namakhvani HPP Cascade: Environmental and Social Impact Assessment (ESIA) report under consideration does not provide comprehensive and reliable information about what impact the project will have on the local population, natural environment and generally, on the region. Furthermore, a great part of environmental and social impacts either are not studied at all (for example, health impacts, waste management, impact on micro-climate, climate change impacts, cumulative impacts, agro-biodiversity, etc.) or are studied and analyzed insufficiently (impact on flora and fauna, protected areas, forest ecosystems). Hence, the conclusions made in the report are groundless and biased in favor of the launch of construction, since they are not strengthened by relevant researches1. According to the project, 14 villages will fall under direct or indirect project impacts; it means that the issue of further existence of Lechkhumi, one of the major parts of Georgia, will be put under question. In spite of this, neither the resettlement plan, nor even guiding principles have been submitted for consideration. It should be noted that the plan has been mentioned for several times in the social-economic part of the document in order to strengthen the idea of construction. Even this shortcoming is already enough to consider the public hearing held this June inadequate and launch public discussions anew.

It is not true when the authors of the report claim that the draft ESIA report was prepared in compliance with the policies of international financial institutions; the project does not also meet the guidelines of the World Commission on Dams2 and the International Hydropower Association (IHA)3.

According to the official information, Namakhvani HPP Cascade Project is a private investment; a private investor submits construction project to the government and in case of approval, implements it. As soon as the construction is over, the investor will receive HPP management rights. In this process, the role of the Ministry of Energy and Natural Resources is absolutely unclear. The latter is openly lobbying the project by lending active support to the project through participating in public discussions or making press statements, and voicing groundless criticism towards environmental organizations. It is absolutely clear that both central and local authorities are using administrative resources in favor of private investor’s interests. As for the Ministry of Environment Protection, it has traditionally chosen a strategy of tacit consent.

The ongoing processes once again clearly demonstrate the deplorable tendencies existing in Georgia: disregard for environmental issues, including in the process of planning and implementing large scale projects; disregard for constitutional rights of the project-affected communities and generally of the citizens; disregard for their property rights; as well as the rights to receive environmental information, to participate in decision-making process and to live in a safe environment.

Exacerbation of these tendencies will negatively influence the social and demographic situation in Georgia’s mountainous regions and will cause irreversible damage to natural resources and cultural heritage of the country.

Hence, in order to avoid the mistakes made in the past while planning energy sector and to provide sustainable development of Georgia’s energy sector:

• We urge to thoroughly study and substantiate the necessity of implementation of Namakhvani HPP Cascade project through giving due consideration to all environmental, social and economic aspects; to publish final version of the Namakhvani HPP Cascade project documents along with the Resettlement Action Plan; to launch real and not profanation public hearings through using the best international practice; 
• We call on the representatives of the Ministry of Energy and Natural Resources as well as other public agencies to stop lobbying of Namakhvani HPP Cascade project through using administrative resources; 
• We call on the administration of the Ministry of Environmental Protection and its staff to perform the job for which they receive their salaries from the taxes paid by us; 
• We also call on international financial institutions to impose a moratorium on the construction of large dams in Georgia, including on financing Namakhvani HPP Cascade unless the national strategy for the development of Georgia’s energy sector is developed with broad public involvement; as far as the infrastructural and energy projects are concerned, it is essential to implement the projects on protection of ecosystems and their services (development of protected areas and other conservation measures) to compensate the damage caused to the environment as a result of implementation of these projects (as an indisputable condition for implementing these projects).

We believe that the fulfillment of the above mentioned recommendations is an essential minimum to achieve the goal set by the President of Georgia – to turn Georgia into a model green economy country throughout the region. 

1. Association Green Alternative;
2. Association of Disabled Women and Mothers of Disabled Children – DEA;
3. Association for Civil Society Development of Georgia;
4. Association Bethlehem;
5. Argomedia;
6. Center for Regional Initiatives – Bright Future;
7. Club of Environmentalists;
8. Community Development Association; 
9. Community Union Sadmeli;
10. Journalists’ Independent Union;
11. Kutaisi Information Center;
12. Meokhi – 2010;
13. Newspaper Samkhretis Karibche; 
14. Stepantsmida;
15. Svaneti Tourism Center;
16. Union of Teachers – Education and Universe;
17. Young Conservationists Group;
18. Georgian Regional Media Association;
19. Georgian Media Monitoring Center;
20. Newspaper "Guria News";
21. Youth Center "Progress";
22. Union, "Community and Self-governance";
23. Wine Club;
24. Irakli Lomouri;
25. Urban Environmental Laboratory;
26. Nino Malashkhia;
27. Tsira Barbakadze;
28. Nana Ioseliani; 
29. Marina Lapauri-Burk;
30. Ekaterine Kakabadze;
31. Rusiko Amirejibi;
32. Lasha Babuadze;
33. Alisa Dobgson;
34. Mzia Nozadze;
35. “Zekari”
36. Tamaz Tordia;
37. Maia Gedevanishvili;
38. Mariam Goduadze;
39. Lela Nikuradze;
40. Giorgi Cincadze;
41. Aleksandre Kurkhuli;
42. Irma Iromashvili;
43. Tata Khvedelidze;
44. Rati Jafaridze;
45. Ilia Jgharkava;
46. Maia Vashakidze;
47. Darejan Kikoliashvili;
48. Eka Tsereteli.

[1] For example: “The project will not lead to a significant change in the climatic conditions of the area or the region,” or “the waste will be collected and disposed properly by the closest responsible municipality”. 

[2] World Commission on Dams, 2001,  http://www.dams.org/index.php?option=com_content&view=article&id=48&Itemid=28

[3] International Hydropower Association (IHA) Sustainability Guidelines, 2004: