22 November

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1 Advisory review of the Environmental and Social Impact Assessment Reports for the Baku-Tbilisi-Ceyhan Oil Pipeline and the South Caucasus Gas Pipeline in Georgia 22 November

2 ISBN Utrecht, Commissie voor de milieueffectrapportage

3 To the Minister of the Environment and Water Resources Nino Chkhobadze Ministry of Environment 68a, Kostava street Tbilisi Georgia your reference your letter of our reference subject direct dial Utrecht, Advisory Review of the Environmental and Social Impact Assessment Reports for the Baku-Tbilisi-Ceyhan Oil Pipeline and the South Caucasus Gas Pipeline in Georgia November 2002 Excellency, At your request the former Dutch Minister of the Environment Jan Pronk has asked the Dutch Commission for Environmental Impact Assessment to assist you with the review of the Environmental and Social Impact Assessment (ESIA) of the Baku-Tbilisi -Ceyhan oil pipeline project and the South Caucasus gas pipeline project in Georgia. A working group of the aforementioned Commission has been assigned to advise you on the quality of the ESIA reports for the two pipeline projects. The working group visited Tbilisi from 6 14 November I hereby send you the Advisory Review of the ESIA report on the Baku-Tbilisi -Ceyhan Oil Pipeline and the South Caucasian Gas Pipeline project in Georgia. I would like to ask your attention for the following: according to a strict approach, there should be a full description and comparative impact analysis of the three alternatives (Central corridor crossing Akhalkalaki district, Karakia route and Modified Central corridor) in order to facilitate decision making, which means that another addendum is required; however a more practical approach was followed by the Commission, taking into account that another addendum will hold up the procedure considerably. The three alternatives have been ranked on the basis of the information tat is provided in the ESIA reports, togethe r with expert judgement and site visits of the Commission. This approach requires anyhow strict permit conditions. Finally, I would like to emphasise the outcome of the advice of the Commission, indicating unambiguously that the Central corridor, crossing Akhalkalaki district, to be the environmentally most sound option. Therefore, from an environmentally point of view, there are no arguments to abandon this route as the preferred route. Postal address P.O. Box GH UTRECHT, THE NETHERLANDS Visiting address Arthur van Schendelstraat 800 Utrecht. The Netherlands Telephone Telefax Website mer@eia.nl

4 Pagina 2 I hope sincerely that our advice will help you to take a good decision. We are of course available for further advise. With warm regards, Dick de Zeeuw, Chairman of the working group Postadres Postbus GH UTRECHT Bezoekadres Arthur van Schendelstraat 800 Utrecht telefoon (030) telefax (030) website mer@eia.nl

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7 TABLE OF CONTENTS 1. INTRODUCTION General Setting of the projects... 1 Baku Tbilisi -Ceyhan Oil pipeline Request for advice Justification of the approach Outline of this advice MAIN FINDINGS AND RECOMMENDATIONS Route selection Route refinement for Lake Tsalka and Ktsia Tabatskuri Environmental management plan & monitoring plan ASSESSMENT OF THE ESIAS Selection of the 10 km corridor Assessment of the 10 km corridors... 6 The Commission recommends: Environment - The Borjomi / Bakuriani area Security risk Route alternatives for Ktsia Tabatskuri and Lake Tsalka Ktsia Tabatskuri area Tsalka reservoir Environmental management (plan) Project design Road plan Reinstatement plan Environmental requirements Social management plan Georgian resources Individual and land compensation Community investment programme Additional compensation and budget Monitoring Plan Operation and maintenance Monitoring

8 Appendices Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Appendix 6 Appendix 7 Appendix 8 Appendix 9 Letter of request Composition of the working group Legislative framework Risk assessment two examples Review of studies on vulnerability of the Borjomi ground water resources on oil spill pollution from BTC pipeline in Georgia Programme of the visit to Georgia 6-14 November Map 1: 10 km Corridors of Interest Map 2: Overview of the three selected routes crossing the Samtskhe -Javakheti region Map 3: Route alternatives for Ktsia Tabatskuria Area Appendix 10 Map 4: Route alternatives for Lake Tsalka -2-

9 1. INTRODUCTION 1.1 General On request of the Minister of Environment of Georgia, this advice is prepared by the Netherlands Commission for Environmental Impact Assessment (EIA)(hereafter called the Commission ) 1. Presented in this advice are the review findings of the final Environmental and Social Impact Assessment (hereafter called the ESIA report). The final ESIA report consist of the following three documents: Environmental and Social Impact Assessment report; Baku- Tbilisi Ceyhan Oil Pipeline: Georgia; draft for disclosure Report; April 2002; Environmental and Social Impact Assessment report; South Caucasus Pipeline: Georgia; draft for disclosure Report; April 2002; Addendum report; Environmental and Social Impact Assessment report Baku Tbilisi Ceyhan oil pipeline: Georgia; response to comments (from ESIA disclosure phase); September Setting of the projects The proponent for the project is a consortium of companies by British Petroleum (BP). The ESIA report is prepared by BP. Baku Tbilisi-Ceyhan Oil pipeline The Baku Tbilisi Ceyhan Main Export oil pipeline project (BTC-project) is intended to become a major system for transporting up to one million barrels per day (50 million tonnes per year) of crude oil from an expanded Sangachel terminal near Baku in Azerbaijan, through Georgia to a new marine terminal at Ceyhan in Turkey on the Mediterranean coast. Tankers will ship the oil to international markets. The total length of the pipeline is 1760 km. The length of pipeline running through Georgia as proposed in the ESIA report is 248 km. The 42 diameter BTC pipeline in Azerbaijan converts to 46 diameter as it enters Georgia and reverts back to 42 diameter in Turkey. In addition to the 248 km pipeline itself, permanent facilities in Georgia include: two pump stations, a pig launcher/receiver station along with two further pigging facilities integrated within the pump stations; one metering station, a number of valve stations, a cathodic protection system, an optical fibre communication system and a computer-based integrated control and safety system. According to the 1 The Netherlands Commission for Environmental Impact Assessment is an independent advisory body, has a legal basis and was established in For more information see the website: -1-

10 planning the construction is scheduled to start in the spring of The pipeline will become operational early An Inter-Governmental Agreement (IGA) between Georgia, the Azerba ijan Republic and the Republic of Turkey has been signed in which the transportation of petroleum via the territories of the Azerbaijan republic, Georgia and the Republic of Turkey through the Baku-Tbilisi -Ceyhan (BTC) Main Export pipeline has been agreed upon. On 28th April 2000 Georgia, Azerbaijan and Turkey initiated the Georgian Host Government Agreement (HGA) on the BTC-project. This Agreement has been ratified by the Parliament of Georgia on May 31, The HGA defines the environmental standards of this project. It has been stated that environmental standards of the Netherlands and Austria and the EC Directive 85/337/EEC will be applied. This advice focuses on that part of the BTC-project that crosses the territory of Georgia. South Caucasus Gas Pipeline The South Caucasus pipeline project (SC-project) is intended to become a pipeline system to transport up to 7.3 billion cubic metres of gas per year from an expanded Sangachal terminal near Baku in Azerbaijan, through Georgia to the Georgian/Turkish border for onward distribution to Turkish domestic customers via the national gas network. In addition to the pipeline itself, permanent facilities in Georgia include: one pressure reduction and metering station, a number of block valve stations, a natural gas off-take site, a cathodic protection system, an optical fibre communication system and a computer-based integrated control and safety system. The 42 diameter SCP will have a total length of 690 km, 248 km running parallel to the preferred route of the BTC pipeline between the Sangachal Terminal and the Georgian / Turkish border near Akhaltsikhe. The 690 km pipeline is planned to be operational in late The SC project is being implemented within the framework of Inter- Government Agreements between the two transit countries. Two Host Government Agreements (HGA) exist between the respective government of each transit country and the SC project owners. The HGA defines the environmental standards of this project. It has been stated that environmental standards of the Netherlands and Austria and the EC Directive 85/337/EEC will be applied. This advice focuses on that part of the SC project that crosses the territory of Georgia. 1.3 Request for advice According to the Georgian law an EIA must be executed prior to construction of a pipeline. Based upon an approved ESIA study, the Environmental license for both projects will be issued by the Ministry of Environment. -2-

11 This advice is the result of co-operation between the Government of Georgia and the Government of the Netherlands. The Georgian Minister of Environment has requested assistance from the Dutch Minister of Environment, with the implementation of EIA for the BTC-project and the SC-project. By letter dated 5 September 2000 the Dutch Minister of En vironment requested the Netherlands Commission for EIA to advise on the ESIA to be executed for the BTC-project, see Appendix 1 for the request. During the visit to Georgia in May 2001 the Minister of Environment requested the Commission also to advice on the ESIA for the SC-project. This advice is prepared by a joint Netherlands/Georgian working group of experts of the Netherlands Commission for EIA. The group represents the Commission and comprises expertise in the following disciplines: pipeline engineering, ecology, geo-hydrology, geography, sociology and public participation. For the composition of the working group and the Georgian group of resource persons who provided the working group with site specific information, see Appendix 2. The Dutch experts visited Georgia from 6 November until 14 November 2002 to draft this advice. Two site visit to respectively the Borjomi / Bakuriani area (June 2002) and the area crossed by the Central corridor (section from Tskhratskaro pass towards Aspindza town) was made on 10 November Justification of the approach The aim of this review is to check whether the ESIA reports contain sufficient information to guarantee the full integration of environmental and social considerations in decision-making. In the event, that essential shortcomings will be found, the seriousness of this lack of information for decision-making will be assessed and recommendations will be given for gathering supplementary information. An essential shortcoming is a shortcoming in the ESIA that, if not alleviated, will hamper the decision making because it leaves a serious gap in information or it leaves a major uncertainty or unacceptable risk untouched. For the final review of these ESIA reports the Commission made use of the following guidelines and directives which were mentioned in the respective HGAs for both projects: Environmental standards of the Netherlands and Austria; The Netherlands and Austria are members of the European Union and are obliged to follow the EC directives. Moreover, both countries are bound by the Conventions and Agreements of Ramsar, Bonn and Bern with respect to wildlife and Aarhus with respect to public participation. In addition, for the SC-project is stated that environmental standards with respect to natural gas pipeline projects shall in no event be less than those applicable in the United Kingdom; EC directive 85/337/EEC (as amended by EC directive 97/11/EC); Guidelines of the World Bank / International Finance Corporation group and the European Bank for Reconstruction and Development; -3-

12 Advisory guidelines for environmental impact assessment (first phase) of the Baku-Tbilisi -Ceyhan Main Export oil pipeline project in Georgia prepared by the Netherlands Commission for EIA (8 June 2001) and approved by the Minister of Environment of Georgia (16 May 2002). In the preparation of the final advisory review the Commission made exte n- sive use of the comments on the draft ESIA reports made by different parties during the disclosure period. Two comments were selected for a comparative study with the BP study because these reports 2 did not come to the same conclusions concerning an important issue of the project, the risks of oil spillage and the consequences for the water resources in the Borjomi / Bakuriani area. A comparative analysis was executed by two independent institutes in the Netherlands. The objectives of this study are: (i) to identify the differences and similarities of the conclusions and (ii) to compare the impact analysis in the different conclusions. The reviewers of one of these institutes joined the working group of the Commission for further analysis in Georgia. The conclusions of this comparative study are presented in Appendix 5. The Commission bases its judgement on the English version of the ESIA reports and Addendum report. The Commission has also reviewed the draft ESIA reports. These draft ESIA reports were submitted on 28 April 2002 for a disclosure period of 60 days. The Commission visited Georgia from 31 May 7 June 2002 (including a site visit to Bakuriyani on 1-2 June 2002 and prepared the following advice: Advisory review of the draft Environmental and Social Impact Assessment Reports for the Baku Tbilisi Ceyhan Oil Pipeline project and the South Caucasus Gas Pipeline in Georgia (19 July 2002). In this advice the Commission concluded that essential information for well informed decision making on both projects was missing. To alleviate these shortcomings in the final ESIA report, the Commission made some recommendations to provide more specific information. 2 - Lloyd, J.W., 2002, Review of Hydrogeology Pertinent to the River Borjomola Catachments and Gujaretis Tskali Catchments KP175 KP 192; Report is part of the Addendum report-appendix 1; - EMTS and CSD Azur, 2002, Reconnaissance Mission Concerning the Risks of Pollution to the Borjomi Groundwater Sources related to the Construction of the BTC pipeline; - Scientific Commission of the President of Georgia at Academic Sciences of Georgia, 2002, Assessments and Recommendations in Relation with the Project of Environmental Impact Assessment Documents of TBC Crude Oil Pipeline Project and South Caucasus Pipeline project. -4-

13 1.5 Outline of this advice In Chapter two, only the main findings and recommendations are listed. In Chapter three of this advice these are elaborated upon and explained in detail. 2. MAIN FINDINGS AND RECOMMENDATIONS 2.1 Route selection In the ESIA report the following four corridors have been assessed: the Eastern corridor, the Central corridor, the Modified Central corridor and the Western corridor. The Modified Central corridor is selected by BP as the preferred corridor. The other corridors have been rejected. This selection is the result of an assessment of main issues on: terrain and geo-hazards; environment; social aspects; security; constructability and reinstatement. The Commission is of the opinion that this assessment is partially incomplete and not transpa r- ent. These shortcomings are particularly related to the range of corridors on option and to deficiencies in essential information on security and environmental i nformation. With respect to the corridors, the Commission concludes that the rejection of the Western corridor and the Eastern corridor is sufficiently justified. However, the Commission concludes that the rejection of the Central corridor crossing the Akhalkalaki district is not sufficiently justified. Furthermore, the Commission concludes that another alternative which is developed by Georgian experts, the Karakia route (which is actually a corridor known as the Karakia route) should have been included in the assessment of the corridors. If essential but lacking information on security and environmental information on the Borjomi/Bakuriani area were included and valued in a proper way, according to the Commission, another ranking of corridors would have been the result. International standards urge to alleviate these shortcomings before decision making. However, the Commission learned that there is an urgent need for decision making in the short term. As a consequence there is limited time for further investigation. Furthermore, the Commission has come to the conclusion that ranking of the three corridors can be based on expert judgement, information in the ESIA report and field visits. Therefore, the Commission has decided that additional information is not necessary and a rectification of the ranking will suffice in this particular case. The suggested ranking is: 1. Central corridor (eastern section crossing the Akhalkalaki di s- trict) in combination with the western section of the Karakia route (first preference); 2. Karakia route (second preference); 3. Modified central corridor (third preference). Experts of BP and the Georgian resource persons of the Commission have not been able to come to an agreement on the technical feasibility of crossing the -5-

14 Karakia massif. A feasibility study of this section including all opportunities and constraints should therefore be executed in the not too distant future. The Commission is of the opinion that, in addition to the information in the ESIA report, the modified ranking in this advice together with the additional information to be provided on the feasibility of the Karakia route, should provide sufficient information for decision making on the routing of the pipelines. After selection of one of the corridors more detailed information for route refinement should be made available in order to set conditions in the license. 2.2 Route refinement for Lake Tsalka and Ktsia Tabatskuri The Commission is of the opinion that the justification given for ranking the different route alternatives crossing the sensitive areas of Lake Tsalka and Ktsia Tabatskuri is insufficient. The Commission has made an improved ranking of route alternatives for these two areas based upon expert judgement. 2.3 Environmental management plan & monitoring plan The Commission observed that the Environmental and Social Management Plan (EMP) and the Monitoring Plan (EP) are lacking. These plans should be elaborated upon and made available to set conditions in the license. The Commission recommends to split up the EMP in two parts; one part on environmental management and one part on social management. 3. ASSESSMENT OF THE ESIAS 3.1 Selection of the 10 km corridor Assessment of the 10 km corridors 3 Table 1 summarises the results of a comparative assessment of the four di s- tinguished 10 km corridors, see map Appendix 7. Based upon this comparison the Modified central corridor is assessed by BP as the preferred corridor. The Western corridor, Central corridor and Eastern corridor are assessed as unacceptable and rejected. The Commission observed that one possible feasible alternative, the Karakia corridor, has not been included in the assessment. Some background information on this corridor is provided in box 1. 3 BP informed the Commission that the Georgian authorities have instructed them that the area south of Borjomi district is a no go area for political reasons. Therefore, the Eastern and the Central corridor were rejected and BP did not invest anymore in a more detailled assessment of the Central corridor. The Modified Central corridor was therefore the starting point for BP to select the preferred 500 meter route. -6-

15 The Karakia corridor is known as Karakia route and hereafter called the Karakia route. The Commission noticed that the assessment of the four corridors is not clear. Information is lacking on the valueing and weighing of the selected criteria. Information on highly valued and environmentally sensitive areas is not included in this assessment. The security risk evaluation is not clear either. It appears that the (significance of) impacts in case of an oil spill has not been considered in this evaluation. Moreover, it is not clear if the attitude of the people in the Akhalkalaki district towards the pipeline has been considered in this evaluation. Shortcomings on environment and security risk are further explained respe ctively in section and Table 1: Summary of constraints and opportunities for the corridor options (Source: adapted table 3.9 from page 3-21 of the Addendum) Description Western Corridor Central Corridor Modified Central Corridor Eastern Corridor Karakia route ** Total length (km) Terrain, geo-hazards X O O PO O Environmental * X O O O O Social X O O O O Security * O X O X O Constructibility, reinstatement and long term integrity X O O PO? Overall assessment X X O X? Notes: PO = Preferred option (where one acceptable option is assessed to be significantly better than other acceptable options) O = Acceptable option X = Unacceptable option * The Commission noticed shortcomings in the assessment of the acceptability of the environmental issues and the security risk for the Modified Central corridor. This observation is explained in section and ** The Karakia route was added to this table by the Commission. An explanation is provided in this section. In table 1 only two options are being presented as a result of the assessment: an option is acceptable or unacceptable 4. This is rather a black and white presentation of the results and according to the Commission it does not re- 4 An acceptable option is assessed as a preferred option where one acceptable option is significant better than another acceptable option. -7-

16 flect the underlying results of the assessment ranging from significant negative impacts or high risks towards significantly positive impacts or low risks. This subtler distinction between the results should have been provided. As a consequence of these shortcomings, the selection of the Modified Central corridor as the preferred route and the rejection of the Central corridor BP has not been justified by BP. If the information on the valuable and sensitive Borjomi/Bakuriani area, the significance of the risks of (men induced) oil spills and the attitude of the population of Akhalkalaki had been was seriously considered, the Modified Central corridor could have been rejected as an unacceptable corridor and the Central corridor could have been assessed as an acceptable corridor. The Commission concludes that the rejection of the Eastern corridor and the Western corridor are sufficiently justified for security reasons respectively the crossing of a National Park. An adequate comparative assessment of the three potential corridors (Central corridor, Modified Central corridor and Karakia route) should be executed and the results should be presented in an Addendum to the ESIA report. This is the procedure that should be followed according to international standards. However, the Commission observed that as a result of the strict planning in the Host Governmental Agreement a decision on the routing should be taken in the short term. In order to facilitate the decision making process the Commission has made a ranking of the three corridors. This ranking is the result of expert judgement by the Commission and is based on: the information available in the ESIA report, comments of Georgian experts and the Academy of Science, expert meetings and field visits to the Borjomi / Bakuriani area and Akhalkalaki district and Aspindza district (the area crossed by the Central corri dor and the Karakia route (see map Appendix 8). The proposed ranking of the alternative corridors is: 1. Central corridor (east section crossing the Akhalkalaki di s- trict) in combination with the Karakia route (west section). 2. Karakia route (east secti on) in combination with the Central corridor (west section). It must be stated that it is assumed that the crossing of the Karakia massif is technically feasible; 3. Modified Central corridor. Suplemented with the necessary specific technical information on the Karakia route, a selection of one of these corridors can be made. If the Central corridor, the Karakia route or a combination will be selected, additional information will be neccessary for route refinement. The Commission recommends: An assessment of the constructability of the route crossing the Karakia massif should get the highest priority. All consequences / impacts of crossing this massif should be presented. A specified time frame should be made in case the application of special techniques such as tunneling is necessary. If the crossing of this massif is not constructable; it should be clearly justified. -8-

17 If the Central corridor or the Karakia route will be selected, additional information on route refinement needs to be gathered and assessed. This information can be made available as part of the license. Box 1: Information on the Karakia route Georgian experts co-ordinated by the US AID Contractor PA Consulting have developed an alternative route, the Karakia route (see map Appendi x 8). This route has been briefly described and assessed in the ESIA report. This route avoids the following two sensitive areas: - The Borjomi / Bakuriani area is almost completely avoided because this corridor follows a route south of the Modified Central corridor. - The Akhalkalaki district is avoided because this corridor follows a route north of this district. The Karakia route does not cross areas, which are highly valued from an environmental perspective. There are no areas to be crossed that are protected by Georgian law. The Tetrobi Managed Reserve as well as the proposed National Park of Erusheti will not be crossed. A preliminary technical assessment of this route showed that there is one section of the route which is undoubtedly difficult to cross. This is a section north of the Akhalkalaki district, the massif of Karakia. This is a so-called category V section ( no go ) limited to 7-8 km, because of (i) the complicated relief (ii) reinstatement constraints and (iii) safety of the labourers during construction. To cross this section there are two options: A tunnel (length approximately 3.5 km) through the southern slope of Triatleti range or; A detour to the north (Route along the northern slope of Trialeti range from the Eastern ridge of mountain Karakai to the western slope of mountain Sanislo). After this section the route proceeds to the village of Ota located in Aspindza district, passes Aspindza town, crosses the river Mtkvari and goes through the relatively simple area, from a technical point of view, until the boarder of Turkey. In the route from Ota towards the Turkish border two more category V sections have to be crossed: (i) the landslide complex located west of the river Mtkvari and (ii) the potential landslide complex located south of Akhaltsikhe. However, these problems can be solved technically. The Karakia route can be divided into two sections, a section east of Aspindza town and a section west of this town. Based upon expert judgement the Karakia route has been assessed. The findings of this assessment are presented in table

18 3.1.2 Environment - The Borjomi / Bakuriani area The Commission concludes that the assessment and the acceptability of the environmental impacts 5 are insufficiently justified for the Modified Central corridor, though however sufficient for the other corridors (see table1). The Commission is of the opinion that the value of flora and fauna, the landscape and the value and legal protection of (ground) water resources in the Borjomi / Bakuriani area are not adequately considered in the Modified Central corridor assessment. It is not clear how these values have been translated into the assessment of the four distinguished environmental criteria. Consequently, the evaluation of the acceptability of the Modified Central corridor is unclear. The value and the legal protection of the environmental issues and the consequences for the ranking of the corridors will be explained in the following se c- tions. Ecology and landscape The ecological and landscape value of this area is assessed as high and sensitive to the impacts of pipeline construction. The area has a protected status according to Georgian law but no IUCN equivalent categorisation (see Appe n- dix 3). The Borjomi / Bakuriani area is part of the Support zone of the Borjomi Kharagauli National Park and located in the southern part of the Borjomi district. In particular the following areas would be crossed: Tskhratskaro Pass, Tsikhisjvari and Kodiana Pass. Moreover, the nature and landscape is highly valued by people and tourists who visit the area in the summer and winter and therefore this is an important source of income for the population of this area. Geohydrology and water resources The area is well known through exploitation of groundwater resources by the Georgian Glass and Mineral Water Company (GGMW). The water they exploit and export is internationally known as Borjomi mineral spring water. These ground water resources are protected by law, see box 2 and Appendix 3. The Commissi on has made a review of the oil spill pollution risk of the water resources in this area and concluded that: The following resources are vulnerable to oil spill pollution: surface water rivers; groundwater in the river valley alluvium; groundwater in Volcano-clastic formation; Potential risk exists on the pollution of groundwater springs discharged from Quaternary lava. The hydrogeological information is not sufficient to make a proper assessment of the risks; The risk of pollution of Borjomi mineral groundwater could be avoided by maintaining the present production method of artesian flowing. For a more detailled assessment of the vulnerability of the water resources to oil spill pollution see Appendix 5. 5 The following four main criteria were distinguished to enable assessment of environmental impacts: nature conservation, hydrogeology, landscape and geomorphology. -10-

19 The Commission is of the opinion that the pre-cautionary principle should be applied to the Borjomi / Bakuriani area because: (i) these resources do have a considerable ecological as well as economic value; (ii) the ground water resources are protected; (iii) the surface water rivers, groundwater in the river valley alluviu, groundwater in Volcano-clastic formation are most vulnerable to oil spill pollution and (iii) for the ground water springs there is a potential risk of oil spill pollution. Application of the precautionary principle means that the following procedure should be followed 6 : first step: Feasible route alternatives should be elaborated to avoid the threat of pollution of these sensitive environmental resources; second step: If there are feasible route alternatives, the route alternative potentially affecting the sensitive environmental resources should be rejected. If there are no feasible route alternatives, this should be justified. Than a study should be executed towards effective mitigating measures. third step: It should become clear what mitigating measures will be applied. Application of these measures should be translated into the license. The Commission applied the first step of the precautionary principle and made a comparative assessment and ranking of the Central corridor, the Karakia corridor and the Modified Central corridor. Based upon the above mentioned values the Commission gave the Modified Central corridor the third prefere n- ce. Box 2: Protection of the ground water resources The ground water resources are protected under the Law on sanitary protection zones of resorts and resort areas. This legislation forms the basic framework. It states clearly that any activity is prohibited if the available mineral resources will be endangered. However, in cases of overriding interest, the government of Georgia is the dispensing authority, but only if the Government is fully compensated. In the case of the Borjomi groundwater resources, this means compensation of the total value of the resources and loss of income. This law is effectuated by way of amendments, in this case the Law regarding zones and resorts. The Borjomi area is protected under this law by a declaration entitled Resort Borjomi sanitary protection zones: project. Volume III; graphical annex (Tbilisi, 2000). The protection zones are indicated on a map, but the motivation is unclear. According to this declaration, the pipeline transect crosses Protection area 3 and the northern part of the10 km zone also crosses the even more stringent Protection area 2. Following the law, activities can only be permitted if damage to the mineral resource can be excluded (chapter 5, paragraph 38). In case no viable alternatives exist, dispensation is required from government under the conditions of a financial deposit in the order of the value of the resource and if an impact can be excluded (paragraph 39a-b). 6 This is the Dutch procedure, in case the precautionary principle is applied. -11-

20 3.1.3 Security risk In table 1 the results of the security risk assessment for the corridors is presented. In the Addendum it is concluded by BP that: the Western corridor and the Modified Central corridor are acceptable; the Central corridor and the Eastern corridor are unacceptable. In order to come to this conclusion the following methodology has been applied. The security risk is evaluated for each of the administrative districts that is crossed by the four corridors. Therefore eight criteria were put in place to assess the potential threats 7. These threats were assessed in terms of impact, probability, risk and manageability. This resulted is a security risk index for each of the four main corridors. On the basis of this index the Eastern and the Central corridor were rejected. The Commission would like to make the following comments with respect to the security risk: The evaluation of the potential threats is not clear because important information is lacking. Therefore the security risk can not be reviewed by the Commission. Moreover, it is not clear how the security risk for the di f- ferent districts has been translated to an overall security risk index for each corridor. The Commission applies the international agreed definition of risk: frequency multiplied by impact. As far as can be assessed the security risk index is related to the frequency and not to the impacts. Each threat is different, depending on the period, the type and the significance of the impacts. Risks of kidnapping and criminality are more probable during the phase of construction than during the phase of operation. Some of the threats, such as civil unrest and separatism, might have an impact on the (political / economic) control of the pipeline. Whilst sabotage and terrorism might cause oil spills. The Commission is not in the position to assess all potential threats. She focusses on the potential impacts related to oil spills. The Commission is aware that the (withdrawl of the) Russian Federation military bases, located in Akhalkalaki district, is considered a risk factor for a limited period of time. The Commission is not in the position and does not have the knowledge to judge this risk factor, neither related direct and indirect threats such as military riots, external influences or separatism and its consequences. This applies also to the risks and consequences of terrorism. The Commission is in the position to assess the significance of the impacts of oil spills caused by some of the potential threats. In general, oil spills are caused by: technical defecits, geo-hazards or men induced causes such as sabotage and terrorism. Concerning the men induced causes of 7 Potential threats: terrorism, sabotage, military riot, seperatism, civil unrest, external influence, kidnapping, criminality. -12-

21 oil spills it is known that sabotage (theft of oil by people along the pipeline) is the most important cause of oil spills in the world. The primary remedy is to raise ownership of the people along the pipeline by adequate compensation measures and development projects. The Commission raises the question if the significance of the impacts of oil spills due to sabotage or terrorism is determined for the different districts as part of the evaluation of the security risk. The significance of the effects of oil spills should be linked to the sensitivity of the area 8. If the above mentioned information on oil spills was taken into consideration in the assessment of the security risk, the security index for the Modified Central corridor would most likely be assessed higher than the present index (figure 5.1 in the ESIA) because there is a severe risk of pollution of the (ground) water resources of the Borjomi / Bakuriani area. The security index for the Central corridor will most likely not change because the area is less sensitive to the impacts of oil spills in comparison with the area crossed by the Modified Central corridor. For the Karakia route no security index figure has been presented in the ESIA report. However the Commission assessed the security risk of the Karakia lower than the risk of the Modified Central corridor and more or less equal to the risk of the Central corridor. In addition, the Commission gives an explanation of the potential threats and opportunities of the pipeline for one particular area, because it seems to play an important role in decision making on the routing; the Akhalkalaki district. It was stated by some Government officials that the inhabitants of the Akhalkalaki district are against the pi peline and therefore cause an additional threat to the security of the pipeline (oral communication). Other Government officials and Georgian experts stated the opposite; the pipeline could offer an opportunity to decrease the isolation and offer opportunities for development of the district (oral communication). To verify these statements the Commission has visited this district and interviewed men, women and youngsters in the following villages: Ura, Gado, Thurtskhi, Kotelia. All interviewed people were informed about the pipeline and stated that they would like to benefit from the pipeline as much as possible. They were aware of the fact that labour opportunities will only be temporary. The interviewed people did not express their opposition against the construction of the pipeline through Georgia in general or through the Akhalkalaki district in particular. Neither the attitude of the people in this district towards the pipeline nor the opportunities for development of the area have not been taken into consideration in the ESIA report. 3.2 Route alternatives for Ktsia Tabatskuri and Lake Tsalka In this section the Commission will focus on an assessment of those route alternatives crossing two sensitive areas along the Modified central corridor (the preferred route in the ESIA report): Ktsia Tabatskuri area and Lake Tsalka. 8 The Borjomi district is for example much more sensitive to oil spills than the Akhalkalaki district and moreover it is a national symbol of Georgia. -13-

22 3.2.1 Ktsia Tabatskuri area Ktsia Tabatskuri s sensitive area consists of the Tabatskuri Lake and its surroundings, the Narianis Veli Wetland and the Ktsia River Valley north of the lake. The area is highly valued for the presence of protected and endangered (migratory) birds. The area is protected as a Managed Reserve (equivalent to IUCN category IV). In the ESIA report a total of six route alternatives have been described which cross and / or avoid the sensitive areas of Ktsia Tabatskuri. Four route alte r- natives option A, B, C and D cross the Ktsia Tabaskuri Managed reserve (see map Appendix 9). These are described, assessed, valued and ranked in se c- tion Two other alternative routes which pass to the north of the Ktsia Tabatskuri Managed Reserve have been described and assessed briefly in se c- tion but were rejected (these routes are not shown on the map in Appendix 9). The Commission is of the opinion that the rejection is justified sufficiently (it crosses an existing ground water feeding zone). Due to the values and the legal status of the Ktsia Tabatskuri area the Commission is of the opinion that the precautionary principle should be applied (see section for an explanation). This means that a route south of the Ktsia Tabatskuri Managed Reserve should be assessed in order to avoid this sensitive area. It should be justified if this route is not feasible. It is stated in the ESIA report that this route has not been considered, because a significant part of this route passes through the Akhalkalaki district and was rejected for security re asons (route is not shown on the map). Out of the four options (A, B, C and D) option D is considered the preferred route. With regard to these four options the Commission agrees with the justification of the western part of option D (the section of option D which runs from the northern tip of the Lake Tabatskuri to the south west side of the lake). Concerning the eastern part of option D, this crosses an area free of infrastructure and it passes the edge of the wetland. An alternative option, the eastern part of option A runs parallel to an existing (dirt)road and does not cross the wetland. The eastern section of option D causes more negative ecological impacts than the eastern section of option A. Therefore the eastern section of A is preferred above the eastern section of D. Ranking of alternatives by the Commission from an ecological point of view: 1. A route south of the Ktsia Tabatskuri Managed Reserve because it does not cross highly valued areas. This route has not been selected and assessed in the ESIA report (first preference). This preference is made on basis of expert judgement. 2. A combination of option A s eastern pa rt until the northern tip of the lake followed by option D from the northern tip of the lake the south-west of the lake (second preference). 3. Option D is preferred by BP and is considered as the third preferred alternative from an ecological point of view. -14-

23 3.2.2 Tsalka reservoir Lake Tsalka is a man made reservoir. The water is of high quality and used for different purposes. From an ecological point of view the reservoir is mainly valued because it is used by migratory water birds, as stated in the ES IA report. The area north of the lake is an infiltration area and large amounts of ground water are stored in natural aquifers which occur relatively close to the surface. This ground water is assessed by the resource persons of the Commission as a valuable resource for future use 9. The reservoir and the groundwater resources in the areas to the north are protected by the Law on sanitary protection zones, see Appe ndix 3. In the ESIA report (section 3.5.6) three options A, B and C have been described and assessed (see map Appendix 10). The value and the legal protection of the ground water resources around the Tsalka reservoir have not been considered in the assessment of the constraints for these three options. This is an essential shortcoming. Other routes more to the north of the reservoir (not shown on the map) were rejected because of a number of river gorge crossings, the increased severity of rocky terrain and multiple crossings of streams feeding the Tsalka rese r- voir. The Commission is of the opi nion that the rejection of routes crossing this sensitive area is sufficiently justified. A route south of the lake avoids the sensitve ground water resources. However, it is stated in the ESIA report that this route is discounted because of a very severe gorge crossing of the Khrami river and the increased social impact, routing the pipeline in close proximity to the inhabitated area (route not shown on the map). Due to the value and the legal status of the (ground) water resources of the reservoir and its surrounding area the Commission is of the opinion that the precautionary principle should be applied (see section for an explanation). This means that a route south of the Tsalka reservoir should be assessed. If this route is not feasible, the reason why should be justified. The Commission does not see an unacceptable constraint in the pipeline crossing close to the settlements along the lake. The technical feasibility of crossing the Khrami river has not been assessed by the Commission. Recommendation: A route south of the Tsalka reservoir should be assessed and information should be provided with regard to the opportunities and constraints of the crossing of the Khrami River. 9 Use was made of hydrogeology maps prepared by GIOC. -15-

24 3.3 Environmental management (plan) Project design Road plan The project design document represents the conceptual design and forms a good basis for Front End Engineering and Design (FEED). This design should consist of two sections: mechanical engineering design and civil engineering design. The latter section is missing and therefore the project design document is incomplete. This is an important lack of information because civil e n- gineering design of the works together with mitigating measures determine for example how roads should be improved and the landscape restored. Recommendations: Civil engineering design of works and mitigating measures should be provided and translated in the license. In the ESIA report is stated that construction roads will be removed after reinstatement. However, during the visit of the Commission to Georgia in November 2002 the following new, but contradictory information was provided by oral communication. BP stated that they will consider to maintain a number of the construction roads in the Borjomi area, because these roads offer good opportunities for quick response in case of an oil spill. The National security council stated that permanent roads will be necessary along the pipeline in order to facilitate effective security control. These statements are in conflict with the information provided by the ESIA report. New roads might cause direct and indirect negative impacts such as: increase of illegal logging, poaching, fragmentation of habitats, soil- and water erosion. On the other hand new roads might have positive impacts as well. Information on these proposed roads is important because it will definitely have consequences for the route selection. Starting point for the main part of the pipeline is that the land will be reinstated as before construction. When the reinstatement will be executed properly, the consequences of the construction will not be visible anymore, all that will remain are the roads. Recommendation: A road plan should be made available and become part of the EMP. In case of maintenance of newly constructed roads during the postconstruction phase (not yet mentioned in the ESIA report) it should be justified whether a new evaluation and ranking of the assessed route alternatives is necessary or not. -16-

25 3.3.3 Reinstatement plan The reinstatement plan is incomplete; it only covers the mechanical design and engineering 10. A civil engineering plan with concrete measures is missing. As a consequence it is not clear which measures will be applied to avoid or mitigate negative environmental impacts during construction and operation. It is also unclear how it will be monitored. Recommendation: The reinstatement plan should contain concrete measures and should be part of the EMP. A section on civil engineering measures to mitigate the negative environmental impacts should be part of this plan Environmental requirements A number of key decisions and responsibilities have not been clearly addressed in the ESIAs and are shifted towards the execution phase and put in the hand of the regulating authorities or left to the responsibility of contractors and subcontractors. For instance, reinstatement and maintenance of the right of way (ROW) by two contractors for the SCP and BTC may result in conflicts, to be solved by BP. To the opinion of the Commission, the EMP should contain essential information for constructors and authorities to base their environmental requirements on and therefore should also include all the constructional environmental documentation produced by BP or its (sub)contractors as stated in the 10 Examples of issues to be addressed in a reinstatement plan. Topsoil removal and storage are common practice in Europe. In areas with natural and valuable vegetation, also the sedge is removed and replaced in order to facilitate re-growth of the natural vegetation. Also in agriculture land, it is important that the soil profile is restored. Tilling and seeding is needed where the corridor is crossing the public roads and places that are sensitive to erosion. It is mandatory that erosion prone transects are monitored until the vegetation is completely restored. It is common practice in Europe that the recovery of less common natural vegetation is monitored, especially where rare and endangered plant species are concerned. A monitoring plan for the recovery of vegetation (and fauna) is lacking in th e ESIA report. In agricultural fields, it is common practice to resume cropping and harvesting. It is remarked, however, that occasional crop damage is observed due to the higher temperature of the soil on top and around the pipeline (drought damage). This phenomenon has not been described in the ESIA report, nor the way this damage is assessed and will be compensated. The ESIA report does not describe how areas of natural importance will be restored. To the understanding of the Commission, activities will be planned for the summer season. This will leave only a limited period between the end of work and the winter. As a consequence, a band of highly erosive soils will be left uncovered during winter and spring. It is also not indicated how long it is expected that revegetation will take. -17-

26 tender documentation. In this way the BP corporate policies become clear and give regulators a solid and agreed basis for permit conditions. Recommendation: In the opinion of the Commission it is essential that all key decisions will be addressed in the EMP. This includes a clear description of the responsibilities and sound environmental conditions for civil engineering. The conceptional technical engineering report from BP can be taken as an example of a clear and well-defined measurable scope. 3.4 Social management plan The Commission is of the opinion that adequate communication and compe n- sation of the people living along the pipelines is of the utmost importance to raise ownership 11. This is the best guarantee to minimise threats for the pi peline, such as sabotage. Small scale sabotage is world wide the most important risk for oil spillage of on-shore pipelines. Guarantees for raising ownership are: maximum use of Georgian resources, adequate compensation for affected individuals and communities, and timely and proper communication with all affected people and organisations in the country Georgian resources The pipelines offer different kinds of opportunities for Georgia. Many people are looking forward to employment. However, the Commission warns for overexpectation. Constructing a pipeline is a temporary and specialised activity. It will require heavy equipment and skilled workers. With respect to Georgian personnel it is stated that in the BTC-project ESIA: (i) BTC Co is committed to maximize employment opportunities for local communities; (ii) it is estimated that in total 2,500 people will be employed during the peak construction period which will last approximately 12 months. Of this labour force % will be Georgian nationals. In the SC-project the same range of 50-80% is mentioned. The estimated number of 2,500 employed people during construction is in accordance with experiences of the Commission with other pipeline projects. However, the Commission is of the opinion that it would be realistic and feasible that during construction of the oil and gas pipeline 80% of the total labour will be provided by Georgian nationals. It will be possible to train people for a range of activities and limit the use of expatriates as specialist staff. Therefore, training programmes should be formulated and timely conducted in order to enhance the necessary skills. The process of labour recruitment should be monitored. The Commission also observed that most of the available local transport and road construction equipment can not be used because it does not meet the 11 Raising of ownership in this context means to increase the responsibility for the pipeline of the people living along the pipeline. As a consequence the chance for sabotage by these people is expected to decrease. -18-

27 standards mentioned in the ESIA (such as the 45 dba noise restrictions for transport vehicles) or seems not to be available. Recommendations: The Commission recommends that the policy statement of BP to make maximum use of local labour is elaborated and guaranteed for a contribution of 80% of the total labour force provided by Georgian nationals. Objectives and criteria for workers and equipment should be described and it should be explained in the villages along the pipeline how local people can benefit from the project. BP should play an important role in recruiting workers. BP and the Georgian government could jointly investigate the possibility to stimulate local investment in suitable equipment with the potential it could be used for future road maintenance and as part of the emergency response plan Individual and land compensation In the ESIA report it is stated that fair and transparent procedures for valuation and compensation for temporary use and permanent expropriation of land will be developed. The completed land parcel identification surveys will be of great help to identify the registered land owners and all registered land users. Owners or tenants have to be compensated for: loss of lands; crops and crop damages by extensive trench drainage; crop depression after construction; access on their lands by the construction crew; construction damages outside the regular ROW; road and fence repair; cut of lands by the construction activities; drinking water for cattle when construction activities cut off the source of water. Third parties have to be compensated when adjacent structures are impaired by lowering of the ground water table caused by the construction works 12. Recommendation: The Commission is of the opinion that the procedure for valuation and compensation of individuals and land should be available as part of the SMP. 12 In the Netherlands, compensation for land owners is regulated in the Mining Law (article 33 and 34). The land lease is determined in this law as 2 times the net result of the (agricultural) production. This rule applies to drilling and production locations, but not to pipelines. It is common practice to refund about 2,5 times the net income. Where pipelines are concerned, the energy production or transportation company becomes (co-)owner for a percentage of the land. Additionally, the original owner is compensated for the temporary loss of production (see the above rule) and land use is resumed by the farmer. In that case the farmer also will monitor the pipeline for leakage, since it is in his best interest. -19-

28 3.4.3 Community investment programme BP has provided an adequate and well designed community investment programme (CIP). One question remains: How does BP implement and achieve the (long term) objectives including a calender time framework? The Community Investment Programme offers good opportunities to meet needs of the communities. However, financial guarantees and sufficient information for long term projects do not yet exist (operation time of the pipeline is estimated to be about 40 years). This information however, should have been incuded in the ESIA report. Recommendation: Information on long term projects as part of the community investment programme and funding should be included in the SMP Additional compensation and budget Apart from individual and community compensation it is common practice that for example a (non-budgetary) environmental fund could be established. It would not be necessary to link activities paid by this fund directly to the project area. It is stated by BP that a Regional programme will be provided for the three host countries containing activities for this type of compensation 13. Instead of a fixed budget for individual compensation and for the CIP a flexible fund should be available according to the needs, respectively requirements of individuals and communities. Recommendations: An overview should be presented of compensatory measures and activities for communities along the pipeline and beneficiaries at regional and national level. The reports which were mentioned previously, including the CIP, should become part of the SMP. Information on individual and community compensation and the CIP needs to actively get explained in detail to the local population. Especially what is meant by the term community. 3.5 Monitoring Plan Operation and maintenance With respect to the operational phase BP has to initiate a formal training programme for maintenance and operation personnel. Necessary foreign special- 13 An example of community compensation; In Nigeria Sh ell provides free electricity to the local population in order to avoid sabotage by sharing resources. -20-

29 3.5.2 Monitoring ist staff shall have Georgian counterparts who will take over their duties in the course of time. Subcontractors for regular overhaul and repair work should be employed and trained. Permit conditions include specific monitoring demands to be fulfilled by the permit owner. Apart from these specific measurements, the authorities may make use of general monitoring results form national and local programmes. In this way the authority assures itself of the proper additional data to evaluate the predictions, made in the ESIA. It is common practice that an EIS contains a monitoring plan with clear objectives in order to facilitate the process. It also contains a paragraph in which the gaps in knowledge are addressed. Both are helpful to the authorities to set realistic targets and permit conditions. For some projects, an independent steering committee is appointed in order to direct the monitoring, qualify the results and guarantee independence. In several occasions the results were presented in the form of a national symposium. In order to ensure data becoming available, the regulating authority acts as follows: strict technical permit conditions and control by State supervision of the Mines (Ministry of Economic Affairs) and the State inspection Environmental Hygiene (Ministry of Environment); qualification according to international standards (for instance ISO14001) in combination with a directional permit; specific permit conditions for environmental monitoring (for instance recovery of flora; breeding success prior to and after construction). A general observation is that all studies have the nature of an inventory and contain extensive lists of potential hazards. BP invested heavily in scientific discipline. It is the experience of the Commission however, that most scientific disciplines have no knowledge of pipeline construction systems and operations and are therefore not capable in defining effective mitigation measures. The Commission therefore supports BP in investing in interdisciplinary capacity building in Georgia. In this way existing local scientific and social information can be directed to find the proper civil engineering solutions. Recommendation: A monitoring plan should be prepared shortly in order to set conditions in the license. The opportunity to utilize the local population in co-operation with non-governmental organisations in the monitoring phase should be described. -21-

30 APPENDICES With the Advisory review of the Environmental and Social Impact Assessment Reports for the Baku-Tbilisi-Ceyhan Oil Pipeline and South Caucasus Gas Pipeline in Georgia (appendices 1 to 10 )

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32 APPENDIX 2 Project information Proposed activity: To advise on the Environmental Impact assessment of the Baku-Tbilisi- Ceyhan Main Export Oil Pipeline and the South Caucasus Gas Pipeline in Georgia Categories: DAC/CRS code Project numbers: Ministerie van VROM DGM.B/BMB/ Commission for EIA 1120 Procedural information: Request for advice: 5 September 2000 Advisory review of draft ESIA report submitted: 19 July 2002 Advisory review of final ESIA report submitted: 22 November 2002 Information on the project: The Baku Tbilisi Ceyhan Main Export oil pipeline project is considered a major system for transporting up to one million barrels per day (50 million tonnes per year) crude oil from an expanded Sangachel terminal near Baku in Azerbaijan, through Georgia to a new marine terminal at Ceyhan in Turkey on the Mediterranean coast. Total length of the pipeline is 1760 km. The length in Georgia as proposed in the ESIA is 248 km. In addition to the 248 km pipeline itself, permanent facilities in Georgia i nclude: two pump stations, a pig launcher/receiver station along with two further pigging facilities integrated within the pump stations; one metering station, a number of valve stations, a cathodic protection system, an optical fibre communication system and a computer-based integrated control and safety system. The planning is that the construction will start in spring 2003, the pipeline will become operational in early This advice focuses on that part of the BTC-project that crosses the territory of Georgia. South Caucasus Pipeline The South Caucasus pipeline (SCP) is considered to be a pipeline system to transport up to 7.3 billion cubic metres per year of gas from an expanded Sangachal terminal near Baku in Azerbaijan, through Georgia to the Georgian/Turkish border for onward distribution to Turkish domestic customers via the national gas network. In addition to the pipeline itself, permanent facilities in Georgia include: one pressure reduction and metering station, a number of block valve stations, a natural gas off-take site, a cathodic protection system, an optical fibre communication system and a computer-based integrated control and safety system. The total length of 690 km, 248 km follows the preferred route and runs parallel to the BTC pipeline between the Sangachal Terminal and the Georgian / Turkish border near Akhaltsikhe. The planning is that the pipeline will become operational in late This advice focuses on that part of the SCP that crosses the territory of Georgia. The Georgian Minister of environment has requested assistance from the Dutch Minister of environment, with a thorough implementation of EIA for the BTC and SCP projects. The Dutch Minister of environment requested the Commission for EIA to advice on EIA. Composition of the working group of the Commission for EIA: 1 Appendix 2

33 Mr. J.M. Marquenie Mr. D. Steensma Mr. B. Burgess Mrs. I. Kurtskhalia Local expert Mr. D. de Zeeuw Chairman Mr. Y. Zhou Local experts (resource persons): Nodar Begalishvili - Risk Assessment and Analysis of Oil Spill Simulation Models Nugzar Buachidze - Assessment of Land Baseline Contamination Study Jemal Gabechava Hydrogeology Vakhtang Gvakharia - Land Baseline Contamination Study (Laboratory Analysis) Shalva Jaoshvili - Hydrology, Sedimentology Tengiz Lazarishvili Hydrogeology Temuri Mdinaradze - Geo-engineering; Hydro-engineering Merab Tvalchrelidze - Geo-morphology; Kote Zarandia Soils Andrei S. Kandaurov Ecology and Zoology Mr. Z Gurielidze acted as a resource person to the working group during the preparation of the guidelines. Technical secretary: Mr. A.J.Kolhoff Technical Secretary 2 Appendix 2

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37 Appendix 5 Review of Studies on Vulnerability of the Borjomi Groundwater Resources on Oil Spill Pollution from BTC Pipeline in Georgia Table of Contents 1. INTRODUCTION OBJECTIVES AND APPROACHES OF THE COMPARATIVE STUDY SUMMARY OF SIMILARITIES AND DIFFERENCES OF CONCLUSIONS COMPARISON OF IMPACT ANALYSIS ON THE BORJOMI MINERAL GROUNDWATER COMPARISON OF IMPACT ANALYSIS ON THE DABA SPRING WATER FINDINGS OF THE VISIT TO GEORGIA CONCLUSIONS AN RECOMMENDATIONS....8 Annexes Annex I Annex II Minutes of meeting of Georgian hydrogeologists.9 Data on Borjomi mineral water production wells Appendix 5

38 1. Introduction In Georgia, the Environmental and Social Impacts Assessment Study (ESIA) on the pipeline project was completed in September The draft ESIA report is made public for disclosure and consultation (ESIA, Georgia, draft for disclosure, 2002). The Georgia Glass and Mineral Water Company (GGMWC) raises serious concerns on the impacts on their Borjomi mineral groundwater resources from an oil spillage of the BTC pipeline. BP hired a consultant hydrogeologist to assess the vulnerability (Lloyd, 2002) and concluded that the Borjomi mineral groundwater is not vulnerable from an oil spillage of the BTC pipeline. However, reconnaissance study commissioned by GGMWC (EMTS and CSD Azur, 2002) concluded that there are risks of oil spill pollution of the mineral groundwater. Local hydrogeologists in Georgia (ASG, 2002) also voice various concerns. In view of the above conflict conclusions on the impact on the Borjomi mineral groundwater resource, the Commission invites two hydrogeologists (Dr Dick Hemker, Free University of Amsterdam and Dr Yangxiao Zhou, UNESCO-IHE Institute for Water Education, Delft) to assess the different studies with the aim to get a clear view of the differences and similarities between these studies. The results of this comparative study will be used to facilitate the discussion with the different stakeholders in Georgia. Secondly, the results of the comparative study will be used as input in the final advisory review to be prepared by the Commission. 2. Objectives and approaches of the comparative study Objectives of the comparative study are: to identify the differences and similarities of the conclusions to compare the impact analysis in the different conclusions A two-step approach was followed. In the first step a desk study was executed. The study concentrated on the review and analysis of the following reports: Lloyd, J.W., 2002, Review of Hydrogeology Pertinent to the River Borjomola Catachments and Gujaretis Tskali Catchments KP175 KP 192 EMTS and CSD Azur, 2002, Reconnaissance Mission Concerning the Risks of Pollution to the Borjomi Groundwater Sources related to the Construction of the BTC pipeline Scientific Commission of the President of Georgia at Academic Sciences of Georgia, 2002, Assessments and Recommendations in Relation with the Project of Environmental Impact Assessment Documents of TBC Crude Oil Pipeline Project and South Caucasian Pipeline project The relevant chapters of the ESIA report were also consulted for background information. In the second step Dr Zhou joined the working group of the Commission during the visit to Georgia in the period 5-14 November The objectives of the visit are to appreciate actual hydrogeological conditions of the area, to ascertain views and opinions expressed by different parties and to verify some important assumptions. The main activities are: Meeting of Georgian Hydrogeologists (Annex I) Meeting of GGMWC Hydrogeologists 2 Appendix 5

39 Discussion of findings with BP hydrogeologist through E-conferencing Collection of data of GGMWC production wells (Annex II) Field visit of production sites, river valley and Daba spring The results of the comparative review are presented in Section 3 to 5. Findings of the visit are described in Section 6. Finally in Section 7 conclusions are draw and recommendations are given. 3. Summary of similarities and differences of conclusions BP consultant (Lloyd, 2002) carried out an intensive review of hydrogeology of the area concerned and analysed vulnerability of different hydrogeological systems to possible oil spill pollution. Conclusions are based on the hydrogeological hypothesis, some measured data, field observations of hydrogeological phenomena, and discussions with some Georgian hydrogeologists. GGMWC consultant (EMTS and CSD Azur, 2002) carried out a reconnaissance mission. It reviewed the ESIA report and hold discussions with parties concerned (GGMWC, BP, and Georgia hydrogeologists). Their conclusions are based mainly on local knowledge of Georgian hydrogeologists, questioning of hypothesis made by BP consultant and similar experiences in France. Scientific Commission of the President of Georgia at Academy of Sciences of Georgia reviewed the ESIA report and report made by BP consultant. The following experts raised concerns of impacts on groundwater: Mr Vakhtang Gvakharia, head of department, Georgia Academy of Ecological Sciences Mr Tegiz Lazarishvili, Hydrogeologist, Georgian Department of Geology Mr Jemal Gabechava, Hydrogeologist, Director, Zenith Gamma Consulting Conclusions of these three parties are presented in Table 1. Table 1 Conclusions of impacts of an oil spill of BTC pipeline in the Borjomi- Bakuriani area Impacts of an oil BP consultant GGMWC consultant Experts at ASG spill on Water courses Not analysed Vulnerable Vulnerable beyond KP192 Gujaretis Tskali Not vulnerable No clear statement No clear statement River Borjomula River Vulnerable Vulnerable Vulnerable Mtkvari River No clear statement Vulnerable Vulnerable River valley Vulnerable Vulnerable Vulnerable alluvium Groundwater in Volcano-clastic formation No clear statement Mineral groundwater in Cretaceous limestone Vulnerable, but contaminant travel times would be sufficiently slow to permit effective remediation Not vulnerable, mineral groundwater is under artesian condition and discharges to rivers Vulnerable, difficult for effective remediation in fractured aquifer Vulnerable, polluted river water may mix mineral groundwater Vulnerable, polluted river water may mix mineral groundwater 3 Appendix 5

40 Groundwater in Quaternary lava Not vulnerable, groundwater discharges to rivers and springs Vulnerable, polluted river water may enter to Lava Vulnerable, polluted river water may enter to Lava In conclusions: All parties agree on potential impacts of oil spill on Borjomula River and river valley alluvium. Drink water supply using these river water and/or groundwater in river alluvium is vulnerable to oil spill pollution. Parties disagree on potential impacts of oil spill on Borjomi mineral groundwater. BP consultant concluded no vulnerability, GGMWC consultant stated polluted river water may mix deep mineral groundwater through cracks and faults and there is not enough hydrogeological information to determine its sensitivity. Georgian hydrogeologists stated that Cretaceous limestone is very near to surface at confluence of Borjomula and Mtkvari rivers and is sensitive to pollution, especially when GGWMC production wells switch to pumping. Parties also disagree on potential impacts of oil spill on Quaternary lava feeding Sadgeri and Daba springs. BP consultant concluded no vulnerability; GGMWC consultant stated that Daba spring is more vulnerable on oil spill pollution. Georgian hydrogeologists raised concerns on potential impacts and recommended further study. GGMWC consultant concerns that the Mtkvari River could be possibly polluted from the oil spill beyond KP192. BP consultant didn t analyse this possibility. 4. Comparison of impact analysis on the Borjomi mineral groundwater The Borjomi mineral groundwater is exploited from artesian wells intercepting groundwater from the Cretaceous limestone formation. The preferred BTC pipeline crosses the south of the area where this formation is buried underneath the Volcano-clastic and Flysch formations. In the confluence area of Borjomula and Mtkvari rivers, the Cretaceous limestone is only a few meters beneath Flysch. Therefore, there is no direct pathway of pollution from oil spill. The possible indirect pathways are: Spill into surface water courses and arrive at the confluence area of Borjomula and Mtkvari rivers and subsequently entry into mineral groundwater through cracks and faults Spill into Volcano-clastic formation and subsequently entry into mineral water source through faults and cracks Impact analysis by three parties is summarised in Table 2. Analysis of possible pathway of the confluence area of the Borjomula and Mtkvari Rivers: BP consultant considers the Mtkvari River as the regional groundwater drainage base so that groundwater discharges (upward flow) into the rivers. Therefore, polluted river water can t entry into Borjomi mineral groundwater. Regional distribution of the Cretaceous limestone formation, Spring waters in the vicinity of Borjomi and measured groundwater heads in the GGMWC wells were used to support this hypothesis. GGMWC consultant argues that the density difference between the shallow cold water and the deep hot water may cause the downward flow. In this case, the polluted shallow water could flow downward mixing with the mineral groundwater. Georgian hydrogeologists raise concerns that when GGMWC artesian wells switch to pumping, groundwater level may drop below the river level so that polluted Borjomula and Mtkvari river water may entry into mineral groundwater since 4 Appendix 5

41 Cretaceous limestone is very near to surface at the confluence area of the Borjomula and Mtkvari rivers. Analysis of possible pathway of the Volcano-clastic and Flysch formation: BP consultant assumes that mineral groundwater in the Cretaceous limestone formation leaks upward into Volcano-clastic formation in Tsikisjvari and Bakuriani area. On the other hand, contaminant travel times would be sufficiently slow to permit effective remediation. GGMWC consultant argues that the Bakuriani area also is a possible recharge area of Cretaceous limestone aquifer. The transport of pollutant in fractured rocks is very complex so that it is difficult for a remedy measure. Georgian hydrogeologists raise questions that the function of geological faults is not analysed. Table 2 Comparison of impact analysis on the Borjomi mineral groundwater Possible pathways BP consultant GGMWC consultant Experts at ASG Conclusion No pathway Pathway Pathway Confluenc e area of the Borjomula and Mtkvari Rivers Volcanoclastic and Flysch formation Arguments Evidences Cretaceous groundwater discharges (upward flow) to Mtkvari River at Borjomi, no possibility of polluted river water flows downward mixing with mineral water 1, Spring waters at Borjomi: high Temperature, high TDS and abnormal CO2 indicating deep groundwater discharge 2, GGMWC flowing wells have artesian condition, the deeper the well, the higher groundwater head, indicating upward groundwater flow 3, Groundwater heads in Cretaceous limestone are higher than Mtkvari river level 5 Appendix 5 Downward flow of shallow water or river water to mix with deep mineral water since 1, shallow cold water with higher density could flow downward to deep hotter water with lower density 2, groundwater head in wells could be lower than Borjomula river level 1, states no sufficient information to be sure that there is no deep mixing zone of deep mineral water with surface or shallow water 2, questions artesian conditions of the Cretaceous limestone aquifer 3, When Well No 41 is not restricted, water level in Well No 1 decreases When GGMWC artesian wells switch to pumping, groundwater level may drop so that polluted Mtkvari river may entry into mineral water 1, When Well No 41 is not restricted, water level in Well No 1 decreases 2, Outcrops of Cretaceous limestone are found at Mtkvari river gorge Conclusion No pathway Pathway Possible

42 Arguments Evidences Cretaceous groundwater leaks upward into Volcanoclastic formation. The contaminant travel times would be sufficiently slow to permit effective remediation. Higher heads of thermal springs in Tsikisjvari and in boreholes at Bakuriani Oil spill could reach the deep mineral water through cracks near the leak location. The transport of pollutant in fractured rocks is complex, difficult for effective remediation. Bakuriani area could be the recharge area of the deep mineral water Hydrogeologica l roles of faults are not analysed. Geological map 5. Comparison of impact analysis on the Daba spring water The Daba spring water discharges from the Quaternary lava unconfined system. The possible pathways are: Spill into lava formation and subsequently entry into spring water source through faults and cracks Spill into surface water courses (Gujaretis Tskali River and Borjomula River) and subsequently entry into spring water source Impact analysis by three parties is summarised in Table 3. Table 3 Comparison of impact analysis on the Daba spring water Possible pathways BP consultant GGMWC consultant Experts at ASG Direct Conclusion No pathway No clear Pathway pollution of oil spill Arguments Daba spring is in the Gujaretis Tskali River statement - Recharge area of Quaternary lava is catachment and the BTC pipeline doesn t cross this catchment located in the north of the pipeline. Groundwater flows towards Borjomi and discharges to Sadgeri spring and Daba spring Evidences Topographical map - Geological map Gujareti s Tskali River Conclusion No pathway No clear No clear statement statement Arguments BTC pipeline doesn t cross the catchment of Gujaretis Tskali River - - Evidences Topographical map Appendix 5

43 Borjomu la River Conclusion No pathway Pathway Pathway Arguments Evidences A groundwater divide exists forcing groundwater in Quaternary lava discharges to Borjomula River and Gujaretis Tskali River. Daba spring is in the Gujaretis Tskali River catachment, so Borjomula River can t flow to Daba spring Topographical map Estimate of groundwater recharge 1, In the upper area where rivers cross the lava, polluted river water transports through cracks of lava to Daba spring 2, In the lower river valley where river level is higher than the old valley basement Geophysical survey 1, Groundwater is concentrated in paleogorge stream 2, groundwater table in paleogorge stream may be lower than river level near village Sakochavi Geology and Geophysical survey In summary: BP consultant argues that the Daba spring is located in the Gujaretis Tskali River catachment and the BTC pipeline doesn t cross this catchment. A groundwater divide exists between the two river catchments, forcing groundwater in Quaternary lava discharges to Borjomula River and Gujaretis Tskali River. Therefore, Borjomula River water can t flow cross the water divide to Daba spring. GGMWC consultant argues that water level in rivers could be higher than Daba spring so that polluted river water can flow through cracks into Daba spring. Georgian hydrogeologists are critical to the simple hypothesis model used by BP consultant, which is based on assumptions of homogeneous and isotropic media and sufficient groundwater recharge. They argue that Quaternary lava is heterogeneous and anisotropic. Groundwater recharge may not be sufficient to maintain a water divide. Furthermore, geophysical survey reviewed that groundwater may be concentrated in paleogorge stream where water table may be lower than the river level. Therefore, polluted Borjomula river water may entry into groundwater and poses risks of springs. 6. Findings of visits to Georgia Meeting of Georgian hydrogeologists The detailed minutes of meeting are included in Annex I. Georgian hydrogeologists are not convinced by the report of BP consultant that there is no risk of oil spill pollution to groundwater in Quaternary lava and mineral groundwater in Cretaceous limestone. They believe there are high risks of pollution of lava groundwater and possible risk of pollution of mineral groundwater. They recommended that in the first place the pipeline should not cross the Borjomi area and should follow an alternative route south of the Borjomi area. In case of the pipeline crossing the Borjomi area, the engineering design should guarantee the zero risk of oil spill. 7 Appendix 5

44 Meeting of GGMWC Both the vice president of GGMWC and managing director of Borjomi mineral water stressed that the fact of the oil pipeline crossing the Borjomi area itself will pose problems of brand image, consumer confidence and promotion for exports of Borjomi mineral water. Irrespective to risks of potential pollution, any accident of oil spill in Borjomi area will be disastrous to consumer confidence, resulting in market claps which will be the end of Borjomi mineral water company. Field visit of Borjomi mineral water production site There are in total 9 mineral water production wells located in the Mtkvari River valley (Annex II). All production wells are artesian flowing and are not pumped. The total combined capacity is around 540 m 3 /day. The central wells (No. 1, 21, 21e and 41) are shallow (raging from 18 to 200 m) and wells in Likani (No. 59 and 54) and Vashlovani (No.25, 37 and 38) are very deep (ranging from 700 to 1500 m). Central wells are located on the axis of the anticline. Well No. 21 is located in the middle of Borjomula river. It is only 18 m deep and it reaches the Cretaceous limestone 5 m from the riverbed consisting of Flysch. The Total Dissolved Solids (TDS) is around 5.8 g/l and temperature is only 16 0 C Groundwater head is 1.2 m above the river level. Close to well No 21 is the Well No. 1 locating at right bank of the Borjomula river. It was originally a mineral water spring and in 1958 a well (194 m deep) was drilled at spring outlet to increase the production. The TDS is around 5.7 g/l and temperature is 31 0 C. Groundwater head is 3 m above the ground. Well 41 is 140 m deep and very productive (130 m 3 /day). The TDS is around 5.6 g/l and temperature is 37 0 C. Wells in Likani and Vashlovani are deep and probably located in synclines. The TDS is around 6 g/l and temperature is varies from 31 to 41 0 C. The Cretaceous limestone is highly heterogeneous and anisotropic. Groundwater flow is mainly controlled by geological structures (anticline, synclines and faults). Around 100 exploration wells were drilled in the area. Only 9 wells yield sufficient water becoming production wells, another 11 with low yield are used as observation wells, majority (80) wells were found dry. It is very interesting to notice that mineral groundwater is of type Na-HCO3 and combined Na and HCO3 concentrations account for 90% of TDS. Both Cl and Ca concentrations are very low. The TDS doesn t clearly decrease with the decrease of well depth and is fairly constant in time, indicating possibly no mixing of deep mineral groundwater with shallow fresh water. Isotope analysis in 1983 found almost no tritium in Well 1, 25, and 54 while water in Lomi mountain (recharge area) contains 60 TU, indicating also no mixing. The temperature decreases with decrease of well depth indicating that the deep hot groundwater is cooling down when flowing upward to the surface. Therefore, the measured temperature of water from wells doesn t represent actual temperature of groundwater in the aquifer. It is very important to maintain the current way of production with artesian flowing. When production wells switch to pumping in order to increase production rate, groundwater heads will decrease. Lowering groundwater heads than river level will definitely increase risks of river water infiltrating into mineral groundwater, especially for Well No Appendix 5

45 7. Conclusions and recommendations The following important water resources are present in the Borjomi area: Surface water rivers (Guraretis Tskali River, Borjomula River and Mtkvari River); Groundwater in the river valley alluvium which are used for drinking water supply by local villages; Groundwater springs (Sadgeri and Daba) discharged from the Quaternary lava are used both by Borjomi for drinking water supply and by the GGMWC for the bottled water; Groundwater in the Cretaceous limestone formation is used by the GGWMC for the bottled mineral water; Groundwater in the Volcano-clastic formation (the use of the water is not clear). Taking into considerations of views and arguments from all parties and preliminary analysis of collected data, conclusions are draw and recommendations are given as following: Surface water rivers (Borjomula River and Mtkvari River) are vulnerable to pollution; even with the clean-up measure, dissolved hydrocarbons could be transported into Borjomula river and eventually arrive at Mtkvari River, which will have impacts on riparian ecosystems. Recommendation An emergence clean-up plan should be stand-by. Groundwater in the river valley alluvium is vulnerable to the pollution once the river is polluted; even with the clean-up measure, dissolved hydrocarbons will be transported into groundwater. Recommendation Alternative water sources should be found for drinking water supply to local communities. There are no sufficient hydrogeological information to assess the vulnerability of groundwater springs (Sadgeri and Daba) discharged from the Quaternary lava. All parties hypothesised groundwater flow system and few data were used. Recommendation Further hydrogeological investigation is required to make better assessment; Under the present production method with artesian flowing, Borjomi mineral groundwater in the Cretaceous limestone is not vulnerable to pollution. A potential risk exists when production wells switch to pumping. Recommendation It is strongly recommended the present artesian flowing production method is maintained. 9 Appendix 5

46 Groundwater in the Volcano-clastic formation is vulnerable to pollution of oil spill. The transport of oil in fractured networks is very complex and it is very difficult to implement effective remedy measures. Recommendation The installation of a detection monitoring network is very important to monitoring the spreading of oil in groundwater. 10 Appendix 5

47 Annex I Minutes of meetings with Georgian Experts Group I: Geology, Geohazards and Hydrogeology (minutes are not approved) 13 November 2002: 15:00 18:00 hours Place: Georgian Ministry of Environment Georgian experts: - Mr Guram Buachidze, Hydrogeologist, Institute of Hydrogeology and Engineering Geology - Mr Tegiz Lazarishvili, Hydrogeologist, Georgian Department of Geology - Mr Jemal Gabechava, Hydrogeologist, Director, Zenith Gamma Consulting - Mr Temeuri Mdinaradze, Geological Engineer, Georgian Water Project Design Institute - Mr Merab Tralchrelidze, Geomorphology, Geological Institute Main issues of concerns by Georgian experts 1 Kumysi Lake area This is a saltwater lake. Geological deposits in the surrounding area are lake deposits with high content of salt. In geological history, salt in the deposits has being flushed by groundwater discharging into the Kumysi Lake. This process has caused surface collapses with depression hole of diameter of around 4-5 m. This geohazard may pose risk of oil pipeline. Special engineering measure is required to safeguard the pipeline. However, BP considers no risk. 2 Bendani mountain area Groundwater in Quaternary lava is wide present, is used by local people for drinking water and has potential for drinking water supply to Tbilisi. The risk of oil spill pollution of this groundwater resource is not assessed in the ESIA report. 3 Tsalka reservoir This is a large fresh water reservoir with good quality. The water is used for local drinking water supply and may also for Tbilisi in Future. The oil pipeline crosses the north bank of the reservoir posing high risk of oil spill pollution to the reservoir. To reduce the risk, the pipeline should keep distance of at least 2 km north of the reservoir. 4 Borjomi area The oil pipeline cross the Borjomi nature reserve. According to the existing Georgian Law, the oil pipeline is not allowed to cross this protected area. Furthermore, oil spill poses high risks of pollution of Borjomula river, Quaternary lava aquifer and possibly Borjomi mineral groundwater. Borjomi mineral water has important social and economical values. Experts disagree with conclusions of Prof. Lloyd that there are no risks of oil spill pollution of Daba Spring and deep mineral groundwater. They argue that hypothesis model of Quaternary lava aquifer is too simple and doesn t consider geological structures causing heterogeneity and anisotropy of lava flow and paleo river valley alluvium. Geophysical survey at village Sakochavi indicating possibility that Borjomula river can infiltrate to paleo river alluvium which flows possibly to Daba spring. They showed a east-west hydrogeological cross-section along the axis of the anticline through the Borjomi mineral groundwater production wells. The cretaceous limestone is 11 Appendix 5

48 very near to surface near observation well 128. From the contour maps of groundwater heads and TDS of Borjomi production wells they believe there is possible mixing of deep mineral water with shallow water. All experts suggest that in the first place the pipeline should not pass through the Borjomi area. In their opinion, an alternative route south of the Borjomi area is a better route. BP didn t choose this route due to security reason. Georgian experts found security is not a problem in the area. They have been working there many years and never had security problem. If the preferred route is chosen, the engineering design should guarantee the zero risk of oil spill. 5 Kodiana area (KP 189 to 192) The area is prone to landslides. Several old landslides are found along three kilometer long ROW. Mr Mdinaradze visited the site together with BP experts. BP has investigated one landslide by drilling borehole of 4 m deep. The experts think the sliding mass may be more than 20 m thick. The drilled borehole is too shallow. BP has not yet provided the engineering solution. 12 Appendix 5

49 Annex II Data on Borjomi mineral water production wells km Only approximately to scale FACTORY No 2 38 Vashlovani Kvibisi Deposit Likani Deposit 54 Mtkvari river Central Deposit FACTORY No 1 to Daba Key: Mineral water drillhole Bottling factory site Connecting pipeline (schematic) high ground 13 Appendix 5

50 14 Appendix 5

51 Georgian Glass Mineral Water Company Total production wells 9 Daily production 539 m3/day Observation wells 11 Well information Groundwater head Well No Location Production layer Production Production ratesurface elevation Depth of well Elevation of observation Measured presure method m3/day m m m Pa 54 likani Cretaceous limestone Flowing likani Cretaceous limestone Flowing Central Cretaceous limestone Flowing Central Cretaceous limestone Flowing Central Cretaceous limestone Flowing e Central Cretaceous limestone Flowing vashlovani Cretaceous limestone Flowing vashlovani Cretaceous limestone Flowing vashlovani Cretaceous limestone Flowing Well information Groundwater chemistry (13/03/2002) Well No Location TDS Cl Na Ca HCO3 Temperature g/l mg/l mg/l mg/l mg/l C 54 likani likani Central Central Central e Central vashlovani vashlovani vashlovani Isotope data 1983 Location Deutium Oxygen 18 Tritium Well /- 2 Well /- 2 Well /- 2 Sadgari spring /- 2 Lomi mountain / Appendix 5

52 Appendix 6 4 Programme of the visit to Georgia 6-14 November 2002 Wednesday 6 November hours Expert meeting on ecology: 1. Themur Kokosadze; biologist - Ministry of environment 2. Alexander Bukhnikashvili; biologist - Ministry of environment 3. Ramaz Gokhelashvili; biologist - Georgian Center for the Conservation of Wildlife hours Expert meeting on geology / geo-hydrology: 1. Themur Mdinaradze; geologist - USAID 2. Merab Tvalchrelidze; geologist - USAID 3. Gemal Gabechava; geologist - USAID 4. Thengiz Lazarashvili; geologist - USAID 5. Nino Basilashvili; Department of ecological expertise 6. Levan Bagdavadze; Borjomi Mineral Waters Company - Vice-President 7. Guram Buachidze; geologist GIOC 8. Dimitri Oniani; geologist - Ministry of environment 9. Patty Miller; IFC hours Expert meeting on social issues: 1. Guram Thevzadze; sociologist Academy of Science 2. Rezo Jorbenadze; psychologist - Tbilisi State University 3. Leo Chikava; Director of Institute of Demography 4. Nana Sumbadze; psychologist, Institute for policy studies 5. George Khutsishvili; Director of International Center on Conflict and Negotiation 6. Iago Kachkachishvili; sociologist - Tbilisi State University 7. Maya Batiashvili; Manager GIOC hours Visit to the Minister of Environment Thursday 7 November hours Expert meeting on soil and water: 1. Vakhtang Gvakharia; Zenith Gamma Consulting 2. Kothe Zarandia; Land department - soil protection division 3. Nodar Begalishvili; Director of Institute of Hydrometeorology 4. Nugzar Buachidze; Institute of Hydrometeorology Appendix 6 page 1

53 5. Jeffrey Jeter; EBRD hours Meeting with panel of experts of the Minister of Environment hours Meeting at National security council: 1. Tedo Japaridze; National security advisor 2. Giorgi Chanturia; President of GIOC 3. Nini Chkobadze; Minister of Environment hours Meeting at USA Embassy; Nicholas Dean first secretary Friday 8 November 10.oo hours NGO meeting: 1. Nino Gujaradze; CEE Bankwatch Network - national co-ordinator 2. Keti Dgebuardze; ECA NGO working group on the WB executive secretary 3. Kety Gujaridze; Association Green Alternative - social monitoring project co-ordinator 4. Manana Kochladze; CEE Bankwatch Network - regional co-ordinator for the Caucasus 5. Nana Jainashia; CENN Caucasus Environmental NGO Network 6. Nino Tevadze; CENN - country co-ordinator 7. Jeff Jeter; EBRD 8. Patty Miller; IFC 9. Nino Nadiradze; PA Consulting 10. Metgar Tchelidze; GIOC 11. Archil Magalashvili; GIOC 12. Zurab Shurgaia; GIOC 13. Maia Batiashvili; GIOC 14. Zaza Mebanidze; GIOC 15. Nino Basilashvili; Ministry of Environment 16. Khatuna Gogaladze; Ministry of Environment 17. Givi Kalandadze; Ministry of Environment hours Experts of the Academy of Science meeting at GIOC 1. Giorgi Chanturia; President of GIOC 2. Claudio Belingieri; Head Environmental advisor team 3. Ruud Platenburg; Member EA-team 4. Erekle Gamkrelidze, Academy of Science 5. Shota Adamia, Academy of Science 6. Guram Buachidze, GIOC 7. Gia Nakhutsrishvili, Academy of Science 8. Theimuraz Gocnbhitashvili, Academy of Science 9. Nana Sumbadze, Institute for policy studies 10. Iago Kachkachishvili, Tbilisi State University 11. Guram Thevzadze, Acad. of Science hours Meeting with Environmental Advisor team at GIOC Appendix 6 page 2

54 15.00 hours Meeting with Nicholas Dean first Secretary of the USA Embassy hours Meeting with Environmental advisor team and Minister of Environment hours Meeting with BP hours Meeting with Green Alternative Saturday 9 November hours Meeting with Environmental advisor team and Minister of Environment hours Meeting GIOC Sunday 10 November Monday 11 November Tuesday 12 November Field visit to Central corridor (Akhalkalaki district) and Karakia corridor Drafting of the advice hours Meeting with BP geo-hydrologists hours Meeting with PA consulting hours Meeting with Mr Molenaar Netherlands Ambassador hours Dinner with Country representative of the World Bank and Mr Molenaar Wednesday 13 November hours Meeting with deputy State Minister Mamuk Nikolaishvili hours Meeting at the Academy of Science: 1. Alexouder Tavkhelidze 2. Givi Sanadze 3. Leo Chikava 4. Guram Buachidze 5. Gurem Tevzadze 6. Guram Gamkrelidze 7. George Nakhutsrishvili 8. Mr. Mirtskhvlava 9. Nino Chkhobadze hours Meeting with BP staff hours Meeting at the ABRD 1. Nicolas Hadjinski 2. Mariam Mekvine-Tukhutsesi hours Meeting with chairman and members of the Parliament: 1. Nino Burjanadze (chairman) 2. Rosa Lortkiperidze 3. Givi Shugarov Appendix 6 page 3

55 4. Nino Chkhobadze 5. George Vashakmadze hours Visit Newspaper 24 hours Thursday 14 November hours Meeting with Nicholas Dean first Secretary of USA Embassy hours Departure from Tbilisi Appendix 6 page 4

56 APPENDIX 7 Map 1: 10 km Corridors of Interest Appendix 7 page -1-

57 Appendix 8 Map 2: Overview of the three selected routes crossing the Santskhe-Javakheti region Appendix 8 page -1-

58 APPENDIX 9 Map 3: Route Alternatives for Ktsia Tabatskuri Area Appendix 9 page -1-

59 APPENDIX 10 Map 4: Route alternatives for Lake Tsalka Appendix 10 page -1-

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