In March 2009 Georgian Railway LLC (100% of its shares are state-owned) applied to the European Bank for Reconstruction and Development (EBRD) and the European Investment Bank (EIB) to allocate Euro 350 million for financing the Tbilisi Railway Bypass Project.
The main goal of the project is to relocate transit of hazardous good (crude oil and oil products) from the densely populated area outside the capital with the purpose of increasing the efficiency and safety of railway operations. The project envisages the construction of a new railway section bypassing the central area of the capital city and modernization of the Didube and Navtlugi railway stations. According to the project, the redevelopment of freed-up territories will promote the development of the northern part of the capital.
The project envisages the construction of 18-20 meter high embankments in the densely populated Avchala district, where the trains loaded with hazardous freights (crude oil and oil products) will be moving. The project does not discuss adequate safeguard measures for the population living along the route. Neither has it studied the negative impact of brake fluid on living conditions in the area.
The minimal distance of the railway project from the Tbilisi Sea is 900 meters. According to the project design, a great part of the railway section will be located in a ditch and in case of oil spill the Tbilisi Sea will be polluted. Even in case of spilling half a cistern, i.e. 30 thousand liters, about 50% of useful capacity of the reservoir will become useless that will leave the population of three districts of Tbilisi as well as about 20 thousand ha of agricultural lands of the Gardabani district without water. Moreover, the proposed railway crosses a number of small and large dry ravines across the Tbilisi Sea; however, the project does not envisage any measures for flood prevention.
The proposed railway also crosses the traditional use and visitors’ zones of the Tbilisi National Park that is a violation of the Georgian legislation according to which the construction of a railway does not belong to those activities that are allowed in the National Park.
Several important issues were neglected in the process of project development, such as proper waste disposal and location of the railway-related energy facilities (high voltage transmission lines, transformers, etc.) as well as their possible environmental impacts. The boundaries of the construction corridor have not been determined either. The amount of inert materials needed for the construction and the environmental issues related to their extraction have not been determined either.
And finally, the proposed alternatives of the project route were rejected at an early stage of public discussions. Nevertheless, other alternatives were not studied at any further stages of project development.
Advocacy campaign and its results
Although, the general project goal – increasing safety and efficiency of railway operations – was acceptable for Green Alternative, because of the above mentioned problematic issues, Green Alternative launched advocacy campaign to prevent irreversible environmental and social impacts.
Along with studying the project documentation, Green Alternative was conducting field visits to the Avchala and Akhali Samgori settlements to provide the project-affected population with the project-related information, on the one hand, and to reveal their concerns, on the other. As a result of effective information campaign, a significant part of the project-affected communities managed to get involved in public discussions and to raise the issues of their interest before the project proponents.
Simultaneously, Green Alternative and CEE Bankwatch Network prepared remarks concerning the project, where the project shortcomings were thoroughly described. The document was sent to the project proponents and their consultants as well as to the European Bank for Reconstruction and Development (a responsible person from the management).
Since the Georgian legislation does not oblige the authority granting environmental permits – the Ministry of Environmental Protection and Natural Resources – to ensure public participation in the decision-making on permitting, Green Alternative applied to the Ministry with the request to involve it in the administrative proceeding on making a decision about permit issuance. In December 2009, with the help of Green Alternative, 354 residents of the Avchala district addressed a letter to the Ministry of Environmental Protection and Natural Resources also requesting their involvement in the administrative proceeding on issuing an environmental permit for the implementation of the Tbilisi Railway Bypass Project. However, unlike Green Alternative, the Avchala population was not given an opportunity to get involved in the administrative proceeding. On initiative of Green Alternative a roundtable was arranged at the Aarhus Center in February 2010 to promote the dialogue among the stakeholders; the representative of the European Bank for Reconstruction and Development also participated in the meeting.
In April 2010 the Ministry of Environmental Protection and Natural Resources issued an environmental permit. The remarks submitted by Green Alternative during the administrative proceeding were taken into consideration and reflected in the legally binding conditions of the permit. Later, Georgian Railway hired a new consulting company to meet the permit requirements.
Despite a number of unanswered questions and disputable issues related to the project, in May 2010 the EBRD still approved the project. Thus, Green Alternative filed a complaint to the EBRD’s Project Complaint Mechanism (PCM) and demanded to investigate the efforts made for addressing the project-related problematic environmental and social issues, in terms of their compliance with the Bank’s standards. Green Alternative also helped the project-affected communities to submit two complaints to the Bank.
Presently, three complaints are under consideration. Because of these complaints, the EBRD carried out the project’s internal audit to verify whether the project was in line with the Bank’s environmental and social standards. It should also be noted that the Bank postponed allocation of the first disbursement to the Georgian Railway company