Complaint on Possible threat to Rioni River from the Namakhvani Hydropower Project (Georgia)

Namakhvani Project encompasses two HPPs on the Rioni River: Lower Namakhvani HPP (324 MW with reservoir area of 510 ha) and Upper Namakhvani HPP (86.8 MW with area of 100 ha). The preliminary construction works started in 2020 without the completion of several studies required by law. There are 4 run-of-river hydropower dams on Rioni and tributaries constructed during 1933 – 1976 that only partially destroyed sturgeons’ habitats. Spawning of sturgeon was still possible downstream because all these relatively low dams did not entirely modify the hydrological flow regime of the river. The Namakhvani Project with its planned high water storage type dams (101 m for Lower Namakhvani) will modify the natural seasonal hydrological flow pattern of the Middle and Lower Rioni. Thus, it will adversely affect:

a)the effectiveness of reproduction of sturgeons – in the absence of seasonal flood peaks, which clean the hard substrate of the bottom of the river of fine sediments, sturgeons cannot spawn because their eggs cannot adhere to the substrate and will die;

1. the available habitats in the downstream sections and natural hydro-ecological processes;
2. the annual temperature cycle through deep water discharge from the reservoir;
3. the disruption of the ecological flows of the river during the first phase of operation;
4. the daily water level fluctuations (hydropeaking) which will affect both the habitats and the faunal elements inhabiting the river sections below the facility;
5. the sediment transport into the lower river sections resulting in incision of the river into the landscape and the loss of its connection with its floodplain;
6. the migration of the sturgeon and other fish species for reproduction;
7. the food base for young sturgeon during the early life phases and for other species.

Additionally, a colony of griffon and Egyptian vultures nesting close to Tvishi village would be highly threatened by the construction of new transmission lines for the project (financed by EBRD) just above the cliffs where the birds breed and construction of Upper Namakhvani HPP below the cliffs. Old-growth Forest habitats, inaccessible up to now, would also be destroyed, flooded by the two new reservoirs, and logged for the new transmission lines. These are steppingstone habitats for large mammals. River and riparian habitats under protected in the Emerald Network (IN MOD, IN MAJ for Black Sea region) would also be seriously impacted by changed hydrological and sedimentation regime and flooding. Changes on lower Rioni will also impact birds that would not be able to breed on or use during migration river islands and coastal habitats (including Rioni Delta) shrinking due to greatly reduced sediment transport. Sparsely vegetated river gravel banks (C3.55) and Riparian and gallery woodlands (G1.1) will be lost due to construction of the Lower Namakhvani dam and associated infrastructure.

Therefore, the Georgian Government violates Article 3, paragraph 1 and 2, Article 4, paragraphs 1, 2 and 3 of the Bern Convention by not protecting Rioni River and granting permits to build Namakhvani Hydropower Project.