Comments on Draft ESIA Report for Baku-Tbilisi-Ceyhan Oil Pipeline

<strong>Comments</strong> on Draft 

ESIA Report for 

Baku-Tbilisi-Ceyhan 

Oil Pipeline 

(Georgia) 

August, 2002

<strong>Comments</strong> on Draft ESIA Report for BTC pipeline (Georgia) 

Introduction 

The Environmental and Social Assessment (ESIA) Draft Report for the Baku-Tbilisi-Ceyhan (BTC) Oil 

Pipeline: Georgian Part (further just ESIA) was prepared by ERM, URS and Dzelkva, for British 

Petroleum Amoco, operator company of BTC Co. These comments address the deficiencies of the 

different parts of the ESIA, and its compliance with national and International legislation and the 

requirements of International Financial Institutions. 

In accordance with the Georgian law on “Environmental Permissions and State Ecological Expertise”, 

the Association “Green Alternative” submitted a Georgian-language version of this document to the 

project sponsor in July 2002. 

Main Findings: 

Project Alternatives: 

The “no project” option and the options for routing or different pipeline component design are not very 

detailed and do not fully analyse possible implementation of these alternatives. 

Pipeline route selection 

• There is no clear estimate of the risks and socio-economic effects of alternative routes in the design 

of 10km, 500m or 100m zones. 

• While the eastern route has potential advantages for pipeline construction, it has been disregarded due 

to security concerns which are not fully presented nor proven in the ESIA. “When combined with the 

foregoing security concerns, these issues would have presented significant constraints to any efforts 

by Government and Project personnel to implement effective risk mitigation and emergency response 

efforts. On this basis, and supported by the Government, the administrative boundaries of the district 

were considered to present unacceptable HSE and other risks for the pipeline routing, and the Eastern 

Corridor was discounted.” More in-depth investigation of security concerns and/or a better 

presentation of research outcomes is necessary, rather than such general language. 

• The pipeline route 500m zone requires revision and design of the optimal alternative, taking into 

account the fact that the present route crosses very sensitive geodynamic areas as well as highly 

sensitive areas in the Borjomi and Trialeti Range, where the speed of underground waters is quite 

high (6-12m 3 /sec). 

The above information shows that it is necessary to determine several route alternatives (within 

the 10km and 500m zones), with full assessment of all potential risks (geological, hydrogeological, 

environmental) and a least-cost analysis for each alternative. 

ESIA Methodology 

The ESIA’s methodology lacks clarity, as it does not explain on what factors decisions were made. 

The ESIA for BTC lacks an economic evaluation for each project component and cost analyses for 

mitigation measures. 

While the document often states that particular decisions were based on cost/benefit analyses, it is not 

clear what the basis for these analyses is. For example, chapter 4 (4.7.8 “Operational power / fuel 

requirements for pump drivers”) concludes that, according to a cost/benefit analysis using BP’s 

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Environmental Performance Guidelines, “direct coupling of the drivers to the pumps was the best 

solution”. BP’s Environmental Performance guidelines are not given in the document. 

Another example, regarding route selection methodology: 

“Sakire: The route alignment was modified to avoid impacts on a summer village used by residents of 

Sakire. This village is used during the summer months when residents of Sakire take cows and sheep 

into the alpine meadows for grazing. Owing to the steep valley sides, the optimal route for construction 

passed through the village and would have required demolishing several of the wooden buildings. Given 

the severity of this social impact, an alternative route that passes to the north of the village, requiring 

removal of only a small animal shelter was identified. This alternative route requires felling of additional 

trees as it is in the tree line north of the village, but this was considered an acceptable trade-off in order 

to avoid the need to relocate structures”. 1 What kind of economic, environmental or social standards 

does the ESIA use to define the “relocation” of several wooden buildings as “severe” social impact and 

route elongation and cutting of additional trees as an acceptable compromise? 

Pipeline Construction Methodology 

While the project sponsor maintains that the pipeline and all facilities would be constructed according to 

international standards and regulations (chapter 5.5.3), the ESIA’s project description does not clarify the 

actual technologies and management standards for specific project details, such as the standards used for 

choosing the pipeline well thickness, protection from corrosion, and so on. 

It is actually quite important to assess the project’s compliance with IFI requirements. The EBRD, for 

example, requires “best technologies” and “good practice” in project implementation. 

It is absolutely unacceptable that several alternative locations for ancillary construction facilities were not 

studied during the ESIA preparations and that the project sponsor admits that “it is not possible to 

accurately estimate the degree of disturbance and its significance.” And while the document states that 

“the final location of these sites will require approval by BTC Co such that social and environmental 

factors will be taken into account”, it is in fact up to the Georgian State Agencies, rather than BTC Co, to 

issue permits for the “final location” and to guarantee “that social and environmental factors will be 

taken into account”. 

Environmental Monitoring methodology 

The project’s planned activities (at all implementation stages from preparation to operation) have a large 

impact on the environment, and it is therefore necessary to carry out environmental monitoring 

activities. It is vitally important to develop a monitoring program which would became an integral part 

of ESIA and should include a list of activities necessary for monitoring the project’s impacts. The 

specifics and intensity (frequency) of monitoring should be determined based on each activity’s 

duration, potential impact, and the value of the environmental factor. 

Furthermore, the project needs to specify a schedule of deadlines for mitigation measures (i.e. dates for 

beginning mitigation activities plus a timeline for their duration), taking into the consideration the 

type/specification of the relevant project activity and environmental factor. This point is important, as 

delayed implementation of mitigation measures could cause irreversible damage to nature (for example, 

delayed implementation may prove to have little or no mitigating effect). 

1 Chapter 4, 4.5.1.6. Stage III, Route Definition process (100 m) 

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Compliance with IFC Safeguard Policies 

Operational Policy 4.04 

International Financial Corporation Operational Policy 4.04 clearly states that the “IFC does not support 

projects involving the significant conversion of natural habitats unless there are no feasible alternatives 

for the project and its siting, and comprehensive analysis demonstrates that overall benefits from the 

project substantially outweigh the environmental costs”. This overall benefit 2 , according to the IFC, 

includes any kind of socio-economic and environmental benefits for the region. 

In light of the above, we may note that the document clearly avoids discussing the significance of the 

Borjomi region and, in particular, problems the pipeline may cause to Borjomi Mineral Waters. Neither 

the document nor chapter 13 – Cumulative Impact Assessment address this issue properly. 

The proposed route crosses surface water catchments of the Borjomi natural springs and boreholes 

between KP175.5 and 190. The ESIA states that the “potential impacts associated with the co-existence of 

the BTC project and the mineral water development taking place at Borjomi have been evaluated in the 

context of an hypothetical oil spill in this region and how this could affect the surface and groundwater 

regime and quality.” 

However, the document does not consider the impact of pipeline construction in the Borjomi region on 

potential tourism development and the development of future mineral water production. 

The Borjomi Region is one of the most well-known tourist destinations in the former Soviet Union and 

the most popular resort in Georgia, famous for its rich biodiversity and world-famous mineral waters 

that are recognised as a strategic resource for Georgian economy. 

The Georgian Glass and Mineral Waters Company (GG&MW) has two plants bottling Borjomi mineral 

waters and a glass and plastic bottle factory in nearby Khasuri. About 1200 people are directly employed 

in the bottling plants. In 1997, the EBRD and IFC provided USD 20 million for the rehabilitation of the 

two mineral water bottling facilities, the glass bottle factory, and a distribution network for the mineral 

water producer. In 1999-2000, the IFC supported the company's plans to acquire key strategic assets and 

strengthen control over the brand name Borjomi. 

Today’s annual turnover of GG&MW is about USD 60 million USD, with more than 60% of production 

exported to the former Soviet Union. According to marketing company “Comcon”, Georgian Glass & 

Mineral Water occupies 42% of the Russian mineral water market, selling 15 million bottles in Russia in 

2000 alone. Nowadays, GG&MW is expanding at 40% per year. 

At the same time, several relatively small factories are also bottling mineral water under the Borjomi 

name. The state-owned Big LTD company, for example, employs 250 people. About 25% of the 

population is employed in mineral water production. 

The following factors need to be considered: 1) total annual income from the pipeline for Georgia’s state 

budget is USD 64 million after the pipeline reaches full capacity, 2) construction would employ only 

2500 people, of whom only a projected 50-80% would be Georgian, 3) during operation, the pipeline 

would employ only 100-120 people in Georgia. 

2 The term "overall benefits" includes all benefits associated with the project, whether they are environmental, social, 

economic, or otherwise. Environmental services such as flood protection; aquifer protection, water purification and 

maintenance of biodiversity are all important benefits, which can be attributed to natural ecosystems. The loss of such 

benefits, along with any other environmental impacts of the development, must be compared to the social, economic 

and environmental benefits of any particular development, which is being considered. IFC would support the project 

only if the overall benefits substantially outweigh the environmental costs. (IFC Operational Policy 4.04. FAQ) 

3


Meanwhile, the project sponsor argues in the ESIA that “given the extremely low probability of a spill 

occurring in this region, or elsewhere along the pipeline, the potential impacts are highly theoretical and 

the discussion above needs to be viewed in its appropriate probabilistic context.” 3 

It is necessary once again to identify the route. In the Borjomi region we should consider not only the 

possibility of an oil spill and contamination of the underlying mineral water aquifer, but also any kind 

of possible incident that could result in the loss of mineral water markets outside the country. BP 

should take responsibility for such situations and develop a compensation plan. 

Compliance with IFC OP 4.01, 4.04 and IFC Safeguard Guidelines, EBRD 

Environmental Policy 

Environmental action plans and management plans 

Unfortunately, the Environmental Action Plans are for the most part not very detailed and do not comply 

with the International Financial Institutions’ requirements 4 which, according to the project sponsor, form 

the foundation for preparing the document. 5 

While the document argues that the Reinstatement Summary Plan, Landscape Assessment and 

Management and Cultural Heritage Management Plan have been fully prepared, no associated costs are 

listed, and there are no schedule or description of step-by-step required actions. In those cases where the 

step-by-step actions are prepared, the document states that they are not obligatory and that the contractor 

can alter them. 6 

Instead, what exists now is mainly a framework for the required plans (Community Safety Management 

Plan; Community Liaison Management Plan; Worker Camp Management Plan; Infrastructure and 

Services Management Plan; Procurement and Supply Management Plan; Employment and Training 

Management Plan; Resettlement Action Plan; Waste Management Plan; Pollution Prevention Management 

Plan; Transport Management Plan), and further elaboration in detail would be left up to the construction 

contractor. According to the project sponsor, this set-up complies with IFI rules. 

While international practice and World Bank OP 4.01 require that Environmental and Social Plans be 

elaborated before project development and be an essential part of the ESIA, these should be discussed 

publicly as well. 

Any delay in reinstating the pipeline corridor will result in the additional negative effects mentioned in 

Chapter 16, including: negative impact on fauna due to long-term disruption of habitat, impact on 

species diversity and population. The risk-factors of the Reinstatement Plan should be studied now, in 

order to minimise these factors. 

3 Chapter 13. 13.5.4 BTC and the Borjomi Mineral Water development 

4 The EAP will document the key issues, the actions that may be taken to address them adequately, the 

implementation schedule and an estimate of the associated costs. (EBRD Environmental policy & 

procedures) 

5 IFC Operational Policy 4.01, article 7: Depending on the project, a range of instruments can be used to 

satisfy IFC’s EA requirement: environmental impact assessment (EIA), environmental audit, hazard or 

risk assessment, and environmental action plan (EAP). EA applies one or more of these instruments, or 

elements of them, as appropriate.” And Annex C of OP 4.01 defines the- contents and issues that the 

EAP should cover. 

6 8.4. Procedures for Biorestoration, Annex 1, Reinstatement Summary Plan, BTC ESIA 

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Monitoring and Management 

According to the ESIA Document, the best tool for co-ordinating and monitoring the implementation of 

environmental and social activities is to introduce an Environmental Management System that includes 

social issues. This EMS should be elaborated on further – how it will be set up and how it will be 

implemented. 

The ESIA states that such a system should be an important tool for setting up all necessary 

environmental and social activities and responsible organisations, and for directing and monitoring the 

implementation of these activities. This means that all environmental and social issues will be 

implemented through the EMS. During operation, the EMS will effectively be based on the 

environmental and social plans; we already noted, however, that for the most part these plans have not 

yet been elaborated. What is more, the EMS itself and its framework have not been fully elaborated and 

from the ESIA’s general statements about the EMS it is difficult to judge its effectiveness. 

Mitigation measures during construction 

The Right of Way clearance and preparation of mitigation measures 

Mitigation measure 1 – The studies identified by this measure should already be done and there 

consequently should be an existing package of activities for the of maintenance and protection of rare 

and endangered wildlife species and for the mitigation of the negative impact of ROW clearance on local 

flora and fauna. It is quite clear, however, that the impacts on wildlife will be quite severe and more 

creative approaches for their mitigation are needed. 

Mitigation measure 2 – First of all, it should be clarified where the revenues from the sale of timber 

(from cutting the forest) will go. It should be mentioned that forest cutting does not only imply the loss 

of “stand-by” trees (timber resource), but also would lead to fragmented destruction of forest 

ecosystems. This means that the factor of sub-forests should be taken into account. In this situation, the 

planting of new trees (even at a 1:1,5 ratio) will not guarantee the restoration of forest ecosystems. 

To solve this issue, it is necessary to restore the complexity of the destroyed forest ecosystem, taking into 

account all local plant and animal species. While this is briefly mentioned in Measure 3, the concrete 

methodology for complex restoration should be elaborated in order to assess its effectiveness. Also, the 

functional value of the proposed cut forest should be assessed. 

Mitigation measure 5 – The Reinstatement Summary plan for temporary roads on temporary facilities 

should be developed to assess its efficiency. 

Mitigation measure 7 – Monitoring itself does not represent a mitigation measure, but it is the initial 

stage necessary for the mitigation measure’s elaboration and implementation. It is only logical that any 

kind of monitoring would have a negative impact in terms of habitat fragmentation and the disturbance 

of wildlife sanctuaries. The development of conservation measures for particular species and their 

immediate/timely implementation, in order to eliminate all negative impacts identified during the 

monitoring process, should therefore be compulsory. 

Mitigation measure 9 – This measure identifies the whole ecosystem as being affected by the Above 

Ground Installation construction, but lists fauna separately and doesn’t include appropriate mitigation 

measures. 

Mitigation measure 19 – The measure identifies local fauna as the project’s noise receptor during 

construction, but does not specify any appropriate mitigation measures. 

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Issue of pipeline decommissioning 

In order to elaborate the pipeline’s ROW Reinstatement Summary Plan, the issue of decommissioning 

the pipeline after it has finished operation should be discussed further. According to the ESIA (chapter 

1.4.5.) “it is generally preferable to leave the abandoned line in place as this avoids the environmental 

disturbance associated with removal. The option of using the pipeline for the local/national distribution 

of low-pressure gas, the transportation of water or as a conduit for services such as telecommunications 

cables, could also be considered.” This seems to us just a little preposterous. 

A decommissioning plan and financial mechanism for its financing should be an integral part of ESIA. 

Biodiversity protection strategy 

At first glance, a great deal of attention is devoted to the significance of biodiversity protection. The 

project sponsor is convinced that document fully complies with Georgian legislation as well as with 

international conventions, International Financial Institution operational policies and British Petroleum’s 

biodiversity strategy. 

The operational policy of International Financial Corporation clearly states, that “IFC does not support 

projects involving the significant conversion of natural habitats unless there are no feasible alternatives 

for the project and its siting, and comprehensive analysis demonstrates that overall benefits from the 

project substantially outweigh the environmental costs.” 

And British Petroleum’s biodiversity strategy aims to select a “pipeline construction corridor that avoids 

the most sensitive areas, including IUCN Category I to IV sites”. However, passing the route through the 

Ktsia-Tabatskuri Managed Reserve fully contradicts this principle, as this area is protected under IUCN 

category IV. 

At the same time, IFC Environmental, Health, Safety Guidelines for wild land management 7 require the 

implementation of a number of safety measures and plans for conserving habitat that exists only in 

project-effected areas. (Black Grouse on nearby Tavkvetili Mountain, Orchids on Bedeni Plateau) 

The construction phase has a special impact on protected sensitive ecosystems and their flora and fauna. 

The pipeline ROW will cross sensitive habitats, parts of which are located in the Ktsia-Tabatskuri 

Managed Reserve and the support zone of Borjom-Kharagauli National Park. 

The pipeline crosses wetlands near Tavkvetili Mountain that represent highly valuable conservation 

habitat in high mountainous zone due to their rarity and low self-restoration level. This requires 

conservation measure implementation during construction as well as during operation of the pipeline. 

The same applies to the Tskhratskaro-Kodiana zone (4.8 km). 

The pipeline construction will have a high residual impact on flora due to the clearance along the ROW 

of territories covered by thick primeval forests. This territory includes Tetritskaro and the villages 

between Tsikhisjvari and Sakire. As a result of this forest clearance, several species of national 

significance will be affected, including species listed in the Georgian Red Data Book (e.g. high mountain 

oak). 

7 World Bank wild land, forestry sector and biodiversity protection policies state that the World Bank Group will not 

support projects that might result in: disintegration of a habitat not elsewhere represented in the country and not under 

suitable protection: or the conversion of wild lands of special concern, including known sites of rare or endangered 

species, or important wildlife breeding, feeding and staging areas. 

IFC Environmental, Health, Safety Guidelines for wild land management 

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It is also stated here that, “no significant impacts are expected to occur with regard to forestry practice in 

Georgia, or to forestry management in general, as the forests affected by the proposed pipeline project 

are a small fraction of the overall forest heritage of the country”. This analysis should follow a different 

methodology, as the impact should be assessed not according to the amount of forest, but according to 

the biodiversity of territories affected by the project, the value of particular species in the ecosystem and 

the population status of individual species. 

This chapter also states that the impact of habitat fragmentation on mammal migration in the Tetritskaro 

region has not been assessed. International Financial Institution regulations require surveys and 

monitoring of migration to be undertaken now, and not be put off for the future, in order to clarify this 

issue. 

It should be noted that the presented ESIA document focuses all its attention on the conservation of 

particular species. Concerning their habitat, the ESIA states that complex reinstatement would be 

undertaken. After an assessment of the impact on particular ecosystem components, however, it will 

become clear that complex reinstatement will be in all cases almost impossible. Furthermore, the 

complex reinstatement plans are not developed at this stage, a step necessary for assessing their 

implementation and efficiency. It should also be noted that a separate reinstatement plan should be 

developed for each fragmented habitat. The complex reinstatement plans should be developed 

considering the degree of impact and the specific habitat’s biodiversity. 

Household and Hazardous Waste Management Plan 

There is no household and hazardous waste management plan for both the construction period as well as 

the operational period. The project sponsor claims that the construction contractor would develop a 

construction-specific waste management plan according to EU directives. 

It should be noted that, according to EU Directives 1994/67 and 89/369, British Petroleum agrees to 

dispose of part of the household and hazardous wastes in landfills and burn part in municipal 

incinerators. We wonder which municipal incinerator BP plans to use to burn the waste, taking into 

consideration that there is no incinerator at all in Georgia. 

Additionally, despite the fact that the World Bank and EU allow hazardous waste incineration, it should 

be noted that “successful incineration requires good design and careful operation. The key operational 

characteristics are temperature, residence time, and turbulence in the combustion chamber, all of which 

affect the efficiency of destruction. A poor installation can emit particulates, acidic gases, unburned 

wastes, and trace quantities of hazardous organic by-products. Some waste, such as PCBs, require 

careful control to ensure, for example, that minimum temperatures are maintained. Selected wastes can 

be incinerated in high-temperature process plants such as cement kilns. However, the waste stream must 

be limited to those wastes for which full destruction can be ensured and no unacceptable residues are 

emitted.” 8 

Again, we ask whether BP plans to construct a new state-of-the-art incinerator; (ignoring for a moment 

the negative impact which even the best incinerator brings – including heavy metals contamination, ash 

toxicity 9 , gas emission etc.) 

Even stranger is the fact that the ESIA does not include any hazardous substances management and 

operation plans, as required by the Management of Hazardous Wastes, World Bank Group Pollution 

Prevention and Abatement Handbook 10 . 

8 World Bank Pollution Prevention and Abatement Handbook 

9 According to the U.S. EPA, hazardous waste incinerators release ‘thousands’ of PICs (chemicals formed during the 

incineration process) in stack gas and deposit them in the residual ashes and liquids of all hazardous waste 

incinerators. 

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We also ask why, taking into consideration the experience of British Petroleum, the document does not 

specify the volume and kind of hazardous substances that will be allowed. Even if we consider this 

strange sentence stating that the contractor should satisfy the following requirement: “The physical and 

chemical properties of the materials should be studied”, just one issue remains to be clarified: Should 

this be carried out in Georgia (because it seems that there some new materials) or in the UK using 

materials which were already tested during other pipeline constructions. 

Health protection and security 

In order to identify and mitigate any negative environmental and social impacts during the construction 

and operation of the Baku-Tbilisi Ceyhan oil pipeline project, it is necessary to clearly assess all risks 

which the project would pose to the health of the population. 

Unfortunately, the document does not include any ways for identifying of negative impacts of pipeline 

construction and operation on the environment and public health; or the level of impact risk on public 

health. 

It is vital that the document explain how the sanitary standards requirements of Georgian law will be 

satisfied. 

For this reason, it is necessary for the environmental and social impact assessment to study the existing 

state of public health in order to be able to assess future changes in environment and public health 

caused by the project. The impacts of pipeline construction and operation could include more than the 

spread of AIDS and infectious diseases, and from our point of view it is necessary to add the risk of 

other diseases caused by oil and oil products (as very stable, toxic and carcinogenic substances) 

It is doubtful whether the AIDS mitigation measure (training) presented in the document will suffice, 

and the statement that “a rise in sexually transmitted diseases is more likely to occur in the large towns 

rather than the smaller communities along the route where prostitution is strongly discouraged because 

of more strict social norms” 11 really does not give much relief. Especially interesting is the question of 

what is meant by the “strict control” without which “the residual impact of an increase in diseases within 

communities could be highly significant in terms of human health”; and what basis exists for the “high 

expectation” that the impact would be of “medium significance”. 

The background information presented in section 7 includes quite scarce information – environmental 

baseline information – along with air quality assessment. It is necessary to assess water quality 

(including drinking water), soil quality and hygiene baseline. 

10 

• Define the scope. 

• Define the objectives and constraints. 

• Formulate the key questions to be addressed. 

• Collect the necessary information. 

• Prepare a technical assessment of appropriate available technologies. 

• Review the existing situation and develop a short list of critical problems and the technical options. 

• Prepare a number of alternative management plans, based on the preferred technical options. 

• Conduct review, discussion, and feedback. 

• Make decisions and carry out implementation and regular monitoring and adjustment. 

• Management of Hazardous Wastes, WORLD BANK GROUP Pollution Prevention and Abatement Handbook. 

11 Section 12, residual impact 12-9 pages. 

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It should be noted that a number of facts described in the baseline information do not comply with 

reality. For instance, the absence of healthcare facilities in Marneuli, Tetritskaro and Tsalka is not true 

and should be clarified 12 . 

The document completely ignores the existing water supply situation in communities along the pipeline 

route, specifically which kind of drinking-agricultural water supply systems are used: centralised or 

decentralised (water pipe, artesian well, mine well, rivers, water transportation). Furthermore, the water 

supply sources are not described (groundwater, open water reservoirs, rivers, reservoirs, lakes and etc.); 

neither is the state of the water supply facilities and network or the sanitary safety zones of water supply 

sources. 

Regarding the quality of water used by the population: are there any indirect or unintentional diseases 

related to water quality etc; is there any data on epidemiological situation and main water polluters 

(domestic, industrial or other wastes)? 

11.5.1.3. (page 11-45) Water needs for construction and operation – this is defined as the use of surface 

and ground waters for technical proposes, but the document fails to define used water 

purification/disinfecting measures and discharge locations, or the installation of water purification 

facilities. 

11.5.1.6. (page 11-46) Blasting – it should be considered that Georgian legislation forbids blasting in the 

safety zones of resorts and resort areas and in water reservoirs’ sanitary protection zones. 

Table 11-5, (page 11-66), 1.1.6. ROW and open trench – It should be mentioned that the Javakheti 

region contains epizootic zones and there are places of animal interment; excavation works in this area 

should take this epidemiological situation into consideration and consult with appropriate field experts 

and doctors (epidemiologists). 

Public Consultation Process 

Availability of information 

The Executive Summaries of BTC and the South Caucasus Gas pipeline distributed by the company 

included a questionnaire for comments. The company welcomed all comments regarding the ESIA and 

invited people to participate in public hearings, visit www.caspiandevelopmentandexport.com (the 

company website) or fill out the questionnaire form. 

On the web, the draft ESIA was available only in English, although it was promised that other languages 

would also be available. 

According to BP, the full ESIA with Executive Summaries and Community Information Brochure is 

available in local administration offices. However, because of the badly chosen timing for public 

disclosure (see below), the true availability of documentation becomes in most cases questionable. 

BP also announced that the document would be available at the offices of the Eurasia Foundation and 

Horizonti Foundation. Outside major cities, however, for instance at Horizonti Foundation Akhaltsikhe, 

office representatives said that they do not have the documents at the local office. 

Only after the local public hearings did BP leave the full set of documents in the local administration 

offices. It should be mentioned, however, that those documents were left only at certain local 

12 Table 9.9. (9-32 pages) 

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administration offices, for instance in Daget-Khachini, while the local hearings were set up for a wider 

range of settlements including Akhali Samgori, Kumisi and others. 

The announcement of public hearings was done differently in different regions. While there were public 

notices in Tetriskaro, in Akhaltsikhe there were complaints regarding the lack of information and there 

were no signs in the streets announcing the hearings. The same situation was observed in Daget- 

Khachini, where the people in the streets knew nothing about the hearing and we did not even see any 

posters in the local administration building. 

In rural areas of Georgia, where there is limited access to newspapers (because of a lack of money) and 

electronic forms of information (lack of electricity) other forms of advertisement were widely required. 

Public Hearings 

The company arranged three regional public hearings (in Rustavi, Tbilisi and Borjomi), plus ten local 

public hearings. All public hearings started at 11 a.m. or 2 p.m. on working days. This fact was one of 

the main obstacles keeping people from attending the meeting – in more urban areas (such as 

Akhalstsike, where many interested people such as university teachers were unable to participate because 

of work) as well as in rural areas (where many people at this time in June are still performing 

agricultural activities). 

Practice shows that important places such as Bakuriani, Tsalka, and other key places were missed. The 

frequency of the public meetings was not satisfactory. While the company can argue that the public 

hearings in Tsikisjvari and Borjomi 13 met the needs of Bakuriani district, we should underline that due to 

poor roads and poor timing, part of population was not able to participate in hearings. 

Timing for Public Disclosure 

Timing for public disclosure was chosen very badly. The local elections on June 2nd reduced local 

administrations’ ability to play an active and effective role. They could not adequately distribute project 

documentation to local communities prior to the consultation process, nor could they adequately explain 

the importance of the documents, the required procedures and public input. Communities often 

complained that they could not get answers from local governments regarding the documents. There are 

two reasons for this: 1) Election results were officially announced only on June 13th and most local 

governmental representatives avoided making any kind of statements; 2) local administrations have 

limited capacity and knowledge for helping people adequately prepare for local hearings. 

Comment period 

While the official public disclosure period lasted until July 31st (according to Georgian law), the 

questionnaire asked people to submit comments until the middle of July. 

Minutes from the Meetings 

Best Practices of Public Participation requires the preparation of minutes of the public hearing and for 

the minutes to be distributed among local authorities and interested parties. In fact, no minutes were ever 

sent to local administration offices although they repeatedly requested this to be done. 

13 or in a case of Tsalka in Beshtasheni and Kizil-Kilisa 

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Public Disclosure phone 

The public disclosure phone line (8 99 96 34 17) was not a toll-free number. The public therefore had 

limited possibilities for calling and discussing issues over the phone. 

Content of Public Hearings 

While BP attempted to follow the IFC’s Best Practices Manual for managing public consultations, and 

tried to build dialogue and trust among the people to manage expectations in order to “avoid unrealistic 

demands and expectations”, “be clear and firm”, “try not to overstate the benefits” or not to raise 

expectations, it seems that all of these measures were not adequate. 

It should be noted that, in the beginning, the BTC pipeline in Georgia raised very high expectations 

among the public and BP’s efforts to counter these high expectations through only the consultation 

process did not succeed. Although BP tried to clearly and firmly address the issue of expectations during 

the hearings, the company only provided information on what communities should not expect from BP, 

while leaving open the question of what they could expect from the company. 

According to the IFC Best Practices Manual, Guidance Note 6: “To be most effective public meetings 

should be employed to gain local acceptance for mitigation, compensation, and project benefits options 

that have already been agreed in principle through earlier consultation. Meetings are likely to be less 

effective when used as the sole means of information disclosure and public consultation.” Unfortunately, 

the public hearings in Georgia ignored this advice. 

Problems such as land compensation, energy supply, infrastructure development and 

employment, which represent the local population’s highest concerns, were not adequately 

addressed. At practically every meeting, the people expressed their dissatisfaction regarding the 

lack of information on the above mentioned issues. 

Land acquisition and compensation issue 

During the public hearings the question of land acquisition and compensation was one of the most 

burning issues. However, the company could not answer any specific question as the resettlement action 

plan had not yet been prepared and there was also no information on how different types of land would 

be compensated (the concern is not only about numbers for different-quality lands, but also concern on 

different types of land such as agricultural, pasture, non-urban and household). 

The explanation that all negotiations with landowners would be carried out on an individual basis did 

not solve the situation. 

Employment Opportunities 

During the public hearings, BP clearly stated that only 2500 people would be employed during 

construction, of whom only 50-80% would be Georgian. It was also underlined, however, that the 

contractor would define the final number of Georgian employees. 

At the same time, the company failed to make any clear statement denying promises to deliver 70 000 

jobs 14 . In fact, many recruitment offices (governmental and non-governmental) have already started the 

14 This type of promise is widely circled in Georgian society, and even was expressed by various parties during the 

public hearings. Similar claims could be seen in various newspapers e.g. newspaper, 24 saati, 15 July, 2002; 

11


registration process in the main towns. There was little warning that people should register only in 

offices established by the BP contractor. In Borjomi region alone, already 5000 people have registered 

with a job recruitment office, while in Akhaltsikhe and Tetriskaro there are about 2000 each. All of these 

people believe that they have been already registered for work 15 . 

Social Investment Programme 

While BP recognises corporate responsibility and talks about Social Investment Programs, local people 

have not received any information regarding the proposed amount of investment package. 

At the same time, people clearly require the energy supply (electricity and gas), all the public hearings. In 

the ESIA, the project sponsor recognises these expectations. 

During the public hearings, however, the project sponsor avoided discussing the above mentioned 

issues, something which only irritated the public. The discussion was often directed towards 

rehabilitation of schools and kindergarten. 

Conclusions: 

• The ESIA lacks baseline information in several areas (biodiversity, hygiene, health, socio-economic 

conditions), that require additional study; 

• There is a lack of consideration of alternative pipeline routing that might be preferable from an 

environmental point of view; 

• The ESIA lacks various Action Plans (including the Environmental Monitoring Plan, Resettlement 

Action Plan and Hazardous Risk Management) with clearly stated goals, implementation schedule and 

associated cost, as is required by the Netherlands legislation and IFC and EBRD policies. 

• The methodology of the ESIA and cost/benefit analyses (including the analyses of route selection, 

socio-economic parameters for choosing different project components and specific standards for 

each project component) is unclear. 

• Public participation was of little value to affected communities in terms of providing exact 

information on the project, land compensation and employment 

15 In some cases they have paid money for registration 

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