quality analysis of the esia draft report for the baku...

Quality Analysisof the ESIA Draft

Report for theBaku-Tbilisi-Ceyhan

Oil Pipeline:Georgian Part

August, 2002

Quality Analysis of the ESIA Draft Report for the Baku-Tbilisi-Ceyhan Oil Pipeline: Georgian Part

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Quality Analysisof the Environmental and Social Impact

Assessment Draft Reportfor the Baku-Tbilisi-Ceyhan Oil Pipeline: Georgian

Part

August 2002

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1. INTRODUCTION..............................................................................................................................2

2. GOALS AND OBJECTIVES..............................................................................................................2

3. METHODOLOGY.............................................................................................................................2

4. SUMMARY OF FINDINGS................................................................................................................3

5. DETAILED ANALYSIS .....................................................................................................................5

CHAPTER 1. EXECUTIVE SUMMARY ........................................................................................................5CHAPTER 3. INTRODUCTION...................................................................................................................8CHAPTER 4. PROJECT ALTERNATIVES .....................................................................................................9CHAPTER 5. PROJECT DESCRIPTION......................................................................................................10CHAPTER 9. SOCIO-ECONOMIC BASELINE ..............................................................................................11CHAPTER 10. POTENTIAL IMPACTS AND MITIGATION .................................................................................12CHAPTER 11. SOCIAL IMPACTS AND MITIGATION......................................................................................13CHAPTER 14. MANAGEMENT AND MONITORING .......................................................................................17CHAPTER 15. OVERALL PROJECT ASSESSMENT......................................................................................18

6. REFERENCES...............................................................................................................................19

7. GLOSSARY ..................................................................................................................................20

This analysis was prepared by Dusan Sevic (Central European University, Budapest) for CEEBankwatch Network.


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1. Introduction

The present Analysis examines the quality of the Environmental and Social Assessment (ESIA) DraftReport for the Baku-Tbilisi-Ceyhan (BTC) Oil Pipeline: Georgian Part (further just ESIA) prepared byERM, URS and Dzelkva, for the BTC Owners: BTC Co. BTC Co includes the State Oil Company of theAzerbaijan Republic (SOCAR), British Petrol (BP), Unocal, Statoil, TPAO, Itochu, Ramco, Delta Hessand ENI.

The BTC Pipeline will run through Azerbaijan, Georgia and Turkey. Another pipeline, the South CaucasusGas Pipeline (SCP), will run in parallel through the same corridor (at a distance of 32 m) through the Azeriand Georgian section. The two pipelines will be supplied with products from the Azeri-Chirag-Gunashli(ACG) Offshore Oil Field Development, and the Shah-Deniz Gas Development in the Caspian Sea, aswell as other regional crude oil and condensate streams.

BP has been nominated by the BTC Owners to lead the engineering design work for the project on behalfof the BTC Owners. As stated in the introduction section of the ESIA, BTC Co will be responsible forconstruction and operation of the proposed pipeline in both Georgia and Azerbaijan, with construction inTurkey falling under the control of the State Company BOTAS.

2. Goals and Objectives The goal of this Analysis is to assess the quality of the ESIA Draft Report and the respectiveEnvironmental Assessment (EA) Procedure, outline their main deficiencies, and give recommendations forimprovements. This goal is achieved by quality analysis of the report’s subcomponents describing thedifferent stages of the EA procedure, applying relevant methodologies of EA quality assessment.

3. Methodology

A choice of relevant and/or modified criteria from several EA quality assessment packages (Lee et al.1999, EU Environmental Assessment Quality Checklist, Bonde and Simpson 1999, Bonde and Cherp2000), good practice guides (Scott et al. 2000) was applied to assess the quality of the different aspects ofthe EA process/documentation.

Along with the use of the EA quality assessment criteria, the ESIA was compared to recommendationsfrom the BP Health, Safety and Environment (HSE) Policy, World Bank’s OP 4.01 and BP 4.01,International Financial Corporation’s Operational Policy 4.04 and European Union’s EIA and SEADirectives.

The main weak points of the ESIA process and report are outlined in the Summary of Findings, with moredetails provided in the Detailed Analysis. Due to time constraints, only the most important sections of theESIA report are covered in the Detailed Analysis, not all of them in equal depth.


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4. Summary of Findings

Report PresentationThe report is organised in a very logical and clear manner. It is divided into 17 sections and six appendices.There are a number of coloured maps, many of which provide adequate and easily accessible information.However, in some sections there are a number of maps which are not appropriate for their assigned use.In some cases the scale and level of detail is not appropriate. On some maps there are symbols provided inthe legend but not on the map or vice versa.

Even though the organisation of sections is logical, cross-references are often missing, making many of theclaims difficult to verify. Many sections provide either not enough or too much information, oftenunnecessarily repeated.

TimingFirst of all, separate project level ESIAs have been devised for the Azeri, Georgian and Turkish sectionsof the BTC, as well as for the different sections of the SCP and ACG. The best impact assessmentpractice today applies the “tiering” principle, in which Strategic-level (Environmental) Impact Assessment(SEA) is performed for a group of projects (within, for instance, an industrial sector or geographical area),after which individual project assessments are performed, using the findings and principles from the SEA.

Since BP is present in all those projects, and has the main responsibility for design of the projects anddevelopment of ESIAs, it should have performed a SEA first in order to improve the efficiency of theindividual project assessments. Supposedly, a SEA for the whole system is planned in the future, onceindividual ESIAs (and even projects) are completed. Such an approach is the opposite of the tieringprinciple, undermines the anticipatory principle and diminishes the efficiency of the impact assessmentprocess.

As to the Georgian part of the BTC oil pipeline, generally the ESIA procedure lags one step behind theproject design process. For example, the Environmental and Social Management Plan (ESMP) shouldhave been completed together with the draft ESIA report. Many missing subdocuments in the ESIA reportalso reflect numerous specific timing omissions within the environmental assessment process itself. Manyof the important and necessary activities have been completely omitted, performed too late, or postponedfor unspecified stages.

Project DescriptionTotal surface areas are given for AGIs, but not for the pipeline corridor and access roads. Maps (5-1a-e)are of inadequate scale and level of detail. AGI symbols are indicated in the legends but not inserted in themaps (5-1a-e) themselves. There are no separate maps for AGIs. There should have been schemes anddescriptions of AGIs, especially relating to pollution emission sources and treatment facilities, such asstacks, oil-water separators, spill tanks, and sewage treatment plants.

Waste ManagementThe amount of many types of wastes is either not known or only an approximate estimate. The ESIAreport does not include a Waste Management Plan (WMP). The ESIA should have included a full WMPat least for the operational phase and preferably for the construction phase as well. Design and applicationof waste management monitoring should be the responsibility of BTC Co, with the inclusion of staff fromthe Georgian Environmental Authorities. Oil-water separator characteristics should have been described.The problem of hazardous and toxic wastes has not been addressed at all. Incineration is proposed, butthere are no waste incinerators in Georgia, or in neighbouring countries. The air emissions subsection


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neglects the crude-topping plant and there are no estimations for Volatile Organic Compound (VOC)emissions.

AlternativesThe choice of alternatives was limited to the pipeline route. No alternatives were presented for thelocations and technologies for Above Ground Installations (AGIs).

Environmental and Social BaselineMeteorological data are mostly general, for all of Georgia, taken from existing figures. Exactmeteorological data, especially relating to wind and precipitation, should have been given for preciselocations of each AGI, including additional measurements if necessary. There is only one wind rosepresented for Tbilisi. For the noise baseline, there were 17 measuring sites; the sites were at the locationsof future AGIs i.e. future noise sources instead of the nearest potential receptors.

MethodologyBaseline information in many cases relies on secondary source review and not enough on additional fieldstudies. Impact significance assessment methodology is not appropriate. The impact consequence/severityRanking Categories (tables 7-2 to 7-12) are shifted towards diminishing impact significance, especially inthe cases of soil contamination, ground and surface waters, cultural heritage and landscape. The residualimpact-ranking matrix (Table 7-14) is also shifted towards diminishing impact significance.

Risk AssessmentRisk assessment was limited to oil spills resulting from pipeline damage. There was no risk assessment forAGIs, or for other types of accidents. The oil spill modelling assessment is presented in Appendix E,Annex IV.

Impact Prediction and EvaluationThe section on impacts lacks maps of appropriate scale and level of detail. Some impacts have not beenidentified at all. There is often not enough relevant data on sources, pathways and receptors. Impactmagnitudes are often predicted arbitrarily, without use of sound scientific methods. Due to the deficienciesdescribed for the methodology of impact significance assessment, impact significance has beenunderestimated in most of the cases.

Mitigation MeasuresMost of the proposed mitigation measures rely on the still non-existent Environmental and SocialManagement Plan (ESMP), i.e. specific management plans. As stated in Table 3-1 in Section 3, theconstruction phase management plans will be developed during the construction phase itself, which isgenerally too late. These plans should have been developed and included in the ESIA report. Withoutthese, most of the mitigation measures proposed are not substantiated in terms of timing, methodology,funding and responsibilities.

In a number of instances, mitigation measures were applied instead of identifying appropriate alternatives.Some of the proposed mitigation measures are not adequate to respective impact character and/ormagnitude.

Environmental and Social Management and MonitoringThere should have been an environmental and social management plan(s) devised in one or two separatedocument. Instead, there are plans to devise 14 partial plans without a central document that wouldencompass them all. So far, only four out of those 14 plans have been completed and included in the ESIAreport. In the absence of these plans, no adequate monitoring provisions are available.


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Consultation and Public ParticipationA number of irregularities were identified both in the C&PP process and the ESIA report, most of whichcan be found in the FFM Report (2002). The deficiencies are related to insufficient/inaccurate informationabout the project provided to the local populations, questionnaires’ contents and procedures etc.

5. Detailed Analysis

The numbering in the Detailed Analysis corresponds to the sections of the ESIA report that wereanalysed. As stated above, only the most important sections of the ESIA report are covered, and not all inequal depth.

Chapter 1. Executive Summary

1.1.Introduction

Subsection 1.1.2 outlines project Environmental and Social Goals and Objectives, some of which areimprecisely defined, which may create misleading conclusions, as follows:

• “No combustion emissions” This should be rephrased as “low” or “minimised combustion emissions”, since the project will createemissions related to power generation for certain above-ground installations (AGIs) such as pumpingstations (PSG1 and PSG2), the intermittent pigging station (IPSG) and transport of crude topped distillate(CTD) from PSG1 to PSG 2 and IPSG.

• “Zero discharge of oil chemicals to land and surface waters” Phrased in such a way, this objective neglects the evident risk of accidental spills. Should be rephrased as“minimised” instead of “zero”. • “No net damage to protected ecological areas or archaeological sites”.

This statement not only obscures the risk of accidental spills, but also neglects the impacts (which in somecases could even be irreversible) to ecosystems during the construction phase, and some of the impactsduring operation phase, such as noise and soil heating. Should be rephrased into “potential damagesminimised” instead of “no net damage”.

Section 1.1.1 The Need for the Project states that “the domestic demand for oil in the Caucuses andCentral Asia is low and unlikely to grow in the near future. Most of the expansion in production willtherefore be available for export, though this export potential is severely constrained owing to thelandlocked geography of the Caspian, and the limited pipeline and rail networks serving the region.” TheBTC pipeline will increase the ability to export oil more efficiently, but it will not address, or will onlypartially address the problems of the affected communities: access to energy, unemployment and badinfrastructure, particularly roads. Therefore, the aim of sustainable development and benefit for localcommunities will not be achieved.

1.3 Project Alternatives


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Subsection 1.3 on Project Alternatives does not mention the different route alternatives but merelycompares the “no-development” and “development” option, where the latter one is defended with“potential positive effects” (emphasis ours – in further text as well). Among these “positive effects” are“financial benefits to Georgia” without discussing the fairness of the distribution of those financial benefitsi.e. how much would be allocated to local affected communities in general, and specifically, in terms ofcompensation. Obviously, such estimation is impossible due to the fact the allocation of financial benefits tothe local and general population is not elaborated in further sections of the ESIA, since this task is left tothe discretion of the Georgian government.

The only other specified potential positive effect are the “increased employment opportunities” whichwould be minor because of the very small proportion of workers in the region that are skilled enough forthe BTC project, and the fact that these employment opportunities will exist only during the constructionphase, which is 30 times shorter than the exploitation phase.

It is also mentioned that “[in the case of the] no-development option…specific environmental and socialbenefits that may accrue as a result of the BTC project…would not occur”, without any elaboration onwhich those benefits might be.

1.4 Project Description

The South Caucasus (Gas) Pipeline (SCP) which will run parallel to the BTC Oil Pipeline is mentioned forthe first time in subsection 1.4 Project Description, instead of the earlier subsection 1.3.1 StrategicConsiderations where it should have been introduced and emphasised in order to reveal the fact ofincreased risk and magnitude of potential accidents of such a concept.

Subsection 1.4.3 Construction states that the Right of Way (ROW) – the 44m-wide corridor for the two(BTC oil and SCP gas) pipelines “…will be reinstated including planting of vegetation”, but fails to mentionthe fact that the vegetation types will be restricted to low vegetation, making it impossible to replantautochthonous vegetation in forests and ecologically sensitive/protected areas.

Subsection 1.4.5 Decommissioning specifies neither the techniques nor the responsibility for thedecommissioning of the BTC Oil Pipeline. This is explained by the fact that “…by the end of the proposedBTC export programme, best practice techniques for decommissioning may have changed. Anyabandonment plan would be supported by Best Practicable Environmental Option (BPEO) studies and anESIA”.

The present ESIA should have incorporated a decommissioning project and management plan based onpresent techniques with an obligation for modifications according to any new techniques at the time priorto decommissioning. BTC Co should be responsible for carrying out the final modifications of thedecommissioning project and management plan, the process of decommissioning. BTC Co (which consistsof International and Georgian companies) should also be responsible for the monitoring of thedecommissioning process, with guaranteed involvement of an independent expert team, includingrepresentatives from the Georgian Environmental Authorities. A special fund should be assigned for theneeds of the decommissioning phase. Only such an arrangement would ensure proper decommissioning ofthe pipeline.

As a matter of fact, as specified in 5.11.3 (Handover of Facilities), the BTC pipeline and AGIs will betransferred from BTC Co to the Georgian partner GIOC (Georgian International Oil Company) after 20years, which is around the time when ACG oil field productivity will fall below profitable rates. In this way,after deriving its initial economic benefits, the BTC Co leaves a deteriorating infrastructure with all itsincreasing economic and environmental risks and costs to GIOC.


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1.5 ESIA Methodology

Subsection 1.5 ESIA Methodology states that “…extensive local consultation with communities alongthe route” was carried out. The International Fact Finding Mission (IFFM) Report (2002) found that thoseconsultations were not performed up to the standards specified in the ESIA. These findings will be outlinedin detail in Section 7 on ESIA Methodology, together with comments on the methodology per se, as well asin sections 9 and 11 (social baseline, impacts and mitigation).

Later, subsection 1.6.3 Attitudes to the BTC Project claims that “people are generally optimistic thatthe construction and operation would bring both direct and indirect benefits. Employment wasoverwhelmingly the most important benefit perceived… repair of roads… improved access to energy, andimproved living conditions”. This subsection does not mention nor comment on the fact that this optimismof sampled local populations is unrealistic since none of these actions are planned, let alone guaranteed(except for short-term employment in limited numbers). This unrealistic optimism could be explained by thetentative way of information presentation in the BTC leaflet and questionnaires.

1.8 Cumulative Impacts

Subsection 1.8 Cumulative Impacts states that “at national level, no cumulative effects of significancewould result from routine operation of the BTC project”. At this point it should have been discussed whatpotential cumulative effects could arise in case of a major accident, at a national or regional level. Only onthe following page is it acknowledged that an explosion of gas in the SCP pipeline could cause a failure ofthe BTC oil pipeline, without discussing the magnitude and significance of impacts in such a case. Nor arethese impacts addressed in Section 10 Potential Impacts and Mitigation.

In the same subsection (1.8), the cumulative effects of the delayed reinstatement of the ROW are outlined(degraded landscape value, impoverishment of the seed bank and a reduction in the germination rate of thesurviving seeds, and erosive processes with associated negative impacts on the soils and natural habitats).This reinstatement delay is due to the installation of two pipelines (BTC and SCP) with a time delay of atleast one year. It should have been explained why it is not possible to install the two pipelinessimultaneously in order to avoid these cumulative impacts.

Potential long-term economic and social effect, supposedly positive, are discussed in the same subsection.It is stated that the “combined effect of the two pipeline projects will be to at least double the inflow ofcash into the local economies along the pipeline corridor”. This assumption is not supported by anyeconomic appraisal study or example case-study. It should be noted that the increased inflow of cashwould be of a limited duration, during the construction phase. Currently, there is no recruitment and/ortraining plan provided in the ESIA, and it is likely that the unskilled and semi-skilled working force will berecruited from one or two larger urban centres, rather than from the affected communities scattered alongthe pipeline route. Therefore, it is logical to suppose that only a minor fraction of the affected populationwill experience benefits from employment/training and the secondary cash inflow. The thesis that the BTCand SCP training programmes will increase the overall skills base for further use is of limited validity in theabsence of other future international quality construction projects in Georgia and until those trainingprogrammes are devised.

1.9 Management and Monitoring

Subsection 1.9 describes environmental and social Management and Monitoring. It is common practicethat such large-scale projects have incorporated Environmental Management Systems (EMS) and plans


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presented in their Environmental and Social Impact Assessment Reports. In this case the development ofan EMS is postponed towards the construction and operation phases, without any dates specified.

It is stated that there will be two EMSs for the Construction Phase. One EMS should be an “umbrella”EMS, to be developed by Ðquote the Project” (it is unclear whether this refers to the project team, ESIAteam, BTC Co, or someone else, and it leaves the responsibility as well as the date of completionunspecified) dealing with policies, plans, monitoring (the construction contractor’s performance), reviewand improvement. The other construction phase EMS is a more specific EMS related to environmental andsocial aspects of construction proper, to be developed by the construction contractor.

One EMS will, allegedly, be developed for the Operational Phase by “the Project” without completiondate specified.

In the same subsection (1.9) it is stated that the EMSs will be based on different environmental and socialplans. A list of 14 plans is given (see p. 1-31 in ESIA for full list). However, only four (Cultural HeritageManagement, Reinstatement, Landscape Management, and Oil Spill Response) of these were completedand made available before August 31, 2002, which is the deadline for submission of comments on the draftESIA. Even if the missing plans are to be developed, it is questionable whether they would be completedbefore the onset of construction (planned to start before the end of 2002).

All three EMS systems should have been developed (at least as draft versions) and outlined in this ESIA,with all relevant programmes completed, specifying activities, responsibilities, monitoring, timelines andfunding.

1.10 Overall Project Assessment

Subsection 1.10 Overall Project Assessment states that the “project design philosophy is based on…[seven] inherent mitigations”, some of which are unsubstantiated. For example “preventing the need forphysical resettlement” is questionable in the light of the Resettlement Action Plan (which is not yetdisclosed). The “intent to deliver a sustainable benefit to communities and the environment” is alsoquestionable since the only identified social benefit is short-term case studies in the past have shownnegative social impacts to communities in the long run, out-weighing the short-term positive effects.

Subsection 1.10.1 Environmental Project Assessment outlines seven unsubstantiated claims of“beneficial impacts” of the BTC project. For example, it is stated that biodiversity will be enhancedwherever possible, by means of an Environmental Investment Plan (EIP). First of all, no EIP has beendisclosed, and moreover, it is not even present on the list of plans on page 1-31. Secondly, enhancement ofbiodiversity is not necessarily a positive impact, especially if increasing the presence of non-autochthonousspecies after removal of autochthonous vegetation.

The “clean-up of identified areas of third-party pre-existing land contamination” is not backed up by a planeither. The same stands for “capacity building at national and local level…”.

Chapter 3. Introduction

Table 3-1 (p.3-7) shows the inter-relationship of the environmental and social assessment process with theengineering and construction processes. This table shows the origin of most timing problems identifiedthroughout the whole ESIA. The Environmental and Social Management Plan(s) (ESMP) should havebeen completed together with the Draft ESIA report, and the Environmental and Social Management


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System(s) (ESMS) should be initiated together with the construction phase. Instead, the ESMP and ESMSpreparation and onset have been shifted one step later.

Chapter 4. Project Alternatives

4.2 No-development option

Subsection 4.2 No-development option claims that “environmental and social benefits may accrue…such as increased employment opportunities, infrastructure upgrades and other community benefits” as aresult of the BTC project. The second part of the sentence does not elaborate on environmental benefitsannounced at the beginning, we have already commented on the short-term employment social effects insubsection 1.10 (see above).

4.5 Routing

Subsection 4.5.1.2 outlines the Principles of Pipeline Routing. Here, it is stated that “sensitiveenvironmental locations have been avoided to minimise potential effects…”. As we will see in the nextsubsection and elsewhere, the chosen corridor crosses several sensitive environmental locations that couldhave been avoided. It is also stated that, “main areas of population density have been avoided…” whichdoes not correspond to the facts. For example the pipeline route and the pumping station PSG1 aresituated within a settled area (near Lake Jandara).

In subsection 4.5.1.4 Corridor Selection Process (10km corridor) , three corridor options arepresented and compared: the Western Corridor, Central Corridor and Eastern Corridor. The EasternCorridor was discounted due to security concerns. It is also stated that the Eastern Corridor was rejected“owing to the length, the severe rugged terrain and environmental constraints associated with the Borjomi-Kharagauli National Park”. However it is not mentioned that the accepted “Modified Central Corridor”crosses the buffer zone of the very same Borjomi-Kharagauli National Park and the Ktsia-Tabatskurimanaged reserve, as well as other sensitive areas (Borjomi mineral water park, Tetritskaro outskirts andforest, Bedeni Plateau, Mt Taukvetili, Naranis Veli and Ktsia wetlands, Tskhratskaro and Kodiana, LakeTsalka area, Tsikhisjvari and Sakire forests, and Mtkvari and Potkhshkovi river crossings). Therefore,valid arguments in this subsection are only related to the length and severe rugged terrain considerations,which belong more to economic and technical, rather than environmental concerns. Furthermore, it is notexplained why the selected Modified Central Corridor did not avoid the Borjomi-Kharagauli National Parkbuffer zone and the Ktsia-Tabatskuri managed reserve.

Subsection 4.5.1.5 describes the Route Refinement Process (500m corridor) . The first stage of thisprocess consisted of detailed desktop studies, which considered a set of 11 criteria (list on p. 4-11), noneof which are directly related to environmental concerns. The second stage of the route refinement processwas a number of multidisciplinary fieldtrips, which again, applied mainly technical criteria (list on pp. 4-11and 4-12).

Only at the third stage, “following the initial identification of potential 500m corridors.”, wereenvironmental criteria applied, through environmental baseline literature review and identifying six keyareas which were subject to further field visits and environmental studies. The list of those six key areas ison pages 4-12 and 4-13. It can be concluded that not all ecologically sensitive areas intersected by thecorridor were included in the list, such as the Bedeni Plateau, Mt Taukvetili, Kodiana, and Sakire forests.

For each of the identified six key areas, several routing options were considered and the choice for thefinal 500m corridor is explained on pp. 4-13 to 4-22. All six cases show that extensive ecological studies


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have been performed. However, the impression is that technical and economic reasons for the finalchoices prevailed, and that suitable ecological/environmental data were used to justify the final choices.

4.7 Design Options

No alternatives for the location of Above Ground Installations are presented.

Chapter 5. Project Description

5.10 Operation, Control and Maintenance

Subsection 5.10.5 Wax Removal states that “It is intended that collected wax will be pumped back intothe BTC pipeline upstream of the mainline pumps. Alternatively, the oil may be warmed or pressurised tokeep the wax entrained in the crude oil as it passes through the receiver. As a result of these measures, itis not anticipated that significant off-site disposal of waste waxes will be required in Georgia.” It is notspecified which measure will be applied and to what extent, i.e. what amount of waste waxes will beproduced.

5.13 Wastes

The ESIA report does not include a Waste Management Plan (WMP). The ESIA should have included afull WMP at least for the operational phase and preferably for the construction phase as well, includingmonitoring provisions. Design and application of waste management monitoring should be the responsibilityof BTC Co, with an inclusion of staff from the Georgian Environmental Authorities. The problem ofhazardous and toxic wastes has not been addressed at all. Incineration is proposed, but there are no wasteincinerators in Georgia or in neighbouring countries. The air emissions subsection neglects the crude–topping plant and there are no estimations for Volatile Organic Compound (VOC) emissions.

Subsection 5.13.4 Construction and Commissioning Waste Management provides estimates of thetotal amount of such wastes in table 5-11 (p. 5-62). The construction and commissioning phase WMP isnot provided in the ESIA, having been left to the construction contractor to develop. It is stated that “thereare currently no waste disposal facilities in Georgia that meet the minimum technical requirements set bythe project”. It is the responsibility of BTC Co to choose locations and develop detailed design for facilitiesappropriate for construction and commissioning wastes and provide information in the ESIA report.Instead, it is written that “given the project schedule and the current availability of waste disposal facilitiesin Georgia… the contractors will choose to establish at least one landfill facility and to employ at least twomobile/semi-mobile waste incinerators. The ESIA fails to provide the characteristics of incineratorsdesigned for the stated types and amounts of waste.

Subsection 5.13.5.3 Hydrotest Water Disposal does not provide the chemical composition of hydrotestwater. It is therefore impossible to specify the amount of potential contaminants in advance. Instead, “theconcentration of iron and other potential contaminants in the discharged water will be determined and iffound to be above approved water quality parameters…the hydrotest water will be diluted prior todischarge,…[or] evaporation ponds will be used,… [or] chemicals (e.g. manganese dioxide) will be addedto neutralise the environmental effects of the iron”. None of the suggested mitigation measures areenvironmentally sound; they have the potential of creating additional environmental problems.

5.14 Waste Management during Pipeline Operation


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At the beginning of subsection 5.14 (p.5-66) it is specified that “upon completion of the commissioningphase, the project Waste Management Plan (WMP) will be re-formulated as an Operational WMP”. Asstated above, the examined ESIA document does not include a WMP. The ESIA should have included afull WMP for the operational phase. The application should be the responsibility of BTC Co, as well asmonitoring - with an inclusion of staff from the Georgian Environmental Authorities.

5.14.1 Solid and non-aqueous wastes.Estimates of the amount of solid and non-aqueous wastes are given only in approximate quantities (Table5-15), and there is no information on their further treatment/disposal. As mentioned above, there is no dataon oil-water separators.

5.14.2 Wastewater. There is no information on the chemical composition of Black Water and GreyWater. It is stated that potentially contaminated wastewater from, for example, equipment coolant systemsand from regular detergent washings of equipment will be “collected either in drums or a dedicated watersump tank for later removal by an approved waste contractor”. However, as admitted in further text, thereare no suitably equipped contractors in Georgia or in the neighbouring countries. The two suggestedalternative options (trickle feed to the STP and incineration) are not suitable either. The STPs are notdesigned for such wastes even for trickle-feed concentrations, and there are no waste incinerators inGeorgia and neighbouring countries that satisfy either national or international standards.

5.14.3 Atmospheric Emissions. Table 5-18 (p. 5-70) gives the estimates of total atmospheric emissionsassociated with operational activities. These were derived from the fuel requirements for the majorthermal plant. These data do not include volatile organic compound (VOC) estimates. Also, data shouldhave been given separately for each facility/emission source, not only the total numbers. The givennumbers relate only to power generation facilities. No estimations have been done for the crude toppingplant, since “such emissions are anticipated to be relatively insignificant compared to those associated withturbine operation”. However, the composition of emissions from the crude topping plant is significantlydifferent, especially in terms of VOCs. Therefore, estimates for the crude topping plant should have beengiven separately. The text is very imprecise.

Chapter 9. Socio-Economic Baseline

Analysis of the socio-economic baseline is based upon household interviews (708). In the text, there is areference to Appendix D, Socio-economic Baseline: Annex I - Community Survey Summary and Annex II- Table of Settlements to see a survey which was used to define the socio-economic baseline. However,Appendix D could not be downloaded from the web-site.

According to the FFM, “socio-economic baseline is based on a limited number of data and interviews andtherefore is incomplete and partial. No copy of the filled-in questionnaires has been given to the people,nor was a blank copy of the questionnaire filed at the local administration office. In some cases, severalquestions differed from one case to another and interviewers filled in questionnaires while askingquestions. In particular, figures about salaries and earnings from farming activities should be reviewed indepth in order to allow a fair compensation process for local communities. Therefore, additional surveyshave to be carried out with the aim of producing a reliable socio-economic baseline.”

As for the methodology, seven (sometimes the number five is mentioned) questionnaires were used togather data. However, only two are given in Appendix F, Annex I.


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Along the pipeline route, there are villages and towns where a majority of population belongs to differentethnic groups such as Russian, Greek, Armenian, and Ukrainian. It is not clear from the draft ESIAwhether these groups received questionnaires in their language, or not.

There is a contradiction between Table 9-8 and the text below. The table says: “Tsalka is also the districtwith the highest average household income” while the text below (9.5.2 Income and expenditure) says:“communities in Marneuli have the highest average levels of income…”

Chapter 10. Potential Impacts and Mitigation

Most of the proposed mitigation measures rely on the as yet non-existent Environmental and SocialManagement Plan (ESMP) i.e. specific management plans. As stated in Table 3-1 in Section 3, theconstruction phase management plans will be developed during the construction phase itself, which isgenerally, too late. These plans should have been developed and included in the ESIA report. Withoutthese, most of the mitigation measures proposed are not substantiated in terms of timing, methodology,monitoring, funding and responsibilities.

10.2 Construction Phase

Subsection 10.2 deals with impacts and mitigation measures during the construction phase. In subsection10.2.1 Identification of Project Activities, Table 10-2 (p. 10-4) gives a list of activities and associatedpotential impacts. The column for environmental significance (‘Ranking’) is missing.

In Subsection 10.2.2 General Mitigation Measures, Table 10-3 gives a list of proposed mitigationmeasures. Mitigation measure No. 1 suggests pre-clearance surveys in order to apply preservationmeasures through transplantation of trees and shrubs where possible. It is stated that “solitary individualsof rowan, high-mountain maple and birch are to be marked to avoid damage to them…”. Since the entiresurface of the ROW is to be cleared, all individuals on the ROW will be damaged. This measure is thusapplicable only to auxiliary construction facilities. Also, in the absence of an Environmental ManagementSystem (as discussed in subsection 1.9), it is not clear whose responsibility pre-clearance studies andpreservation measures will be. The same goes for mitigation measures No. 4 (pre-clearance bear survey)and No. 7 (wildlife monitoring programme).

Mitigation measure No. 8 “Avoid wetlands trough minor re-routes” should have been carried out duringthe project design phase, which was not always the case. The principles and criteria for re-routing duringthe construction phase are not described.

Mitigation measure No. 13 “Adopt strict fuelling and spill control procedures…” should be applied all alongthe pipeline route, and not only “…in areas where sensitive ground water resources occur”.

Mitigation measure No. 16 relates to situations where known archaeological sites would turn out to bemore extensive than anticipated, and are intersected by the actual pipeline track. On maps 8-10 a-f, it canbe seen that in many instances the pipeline passes through or very near to identified archaeological sites.Appropriate pipeline routing alternatives should have been identified and chosen in order to minimise “suchchance findings”, instead of applying “site evaluation and potential mitigation of impacts… if possible…between the time of discovery and the start of grading and pipe-trench excavation in the site area”.

Tables 10-4, 10-5, 10-6 and 10-7 outline impacts and mitigation at the port supply base, at pipe storageyards and working camps, at borrow pit and spoil disposal sites, and at waste disposal sites, respectively.


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Since these sites have not yet been determined, it is not surprising that there are no detailed explanations toaccompany these tables.

10.3 Operation Phase

Subsection 10.3 deals with impacts and mitigation measures during the operation phase. In subsection10.3.1 Definition of Activities, Table 10-8 (pp. 10-114 to 10-116) gives a list of facilities and associatedactivities, with their potential environmental impacts. The column for impact significance (‘Ranking’) ismissing.

Subsection 10.3.2 outlines General Operational Mitigation Measures in Table 10-9. As stated above,without appropriate management plans completed, most of the proposed mitigation measures are notsubstantiated in terms of timing, methodology, monitoring, funding and responsibilities.

Subsection 10.3.3 presents Assessment of Impacts and Mitigations for particular above groundinstallations (AGIs).

10.3.3.1 Pumping Station PSG1. As stated in section 4, there is no evidence of any alternative locationsassessment for PSG1. Furthermore, there is no appropriate description of the location nor is there anadequate map of appropriate scale which would include the nearest dwellings, the canal system and LakeJandara. Impacts on water resources are discussed only in terms of direct discharges, but not throughindirect pathways, such as atmospheric deposition. Noise impacts are arbitrarily assessed as insignificant,without noise propagation modelling being applied. Noise contours resulting from noise propagationmodelling should have been overlaid on an adequate map in order to substantiate claims on impactmagnitude/significance.

Table 10-11 gives results of air dispersion modelling for PSG1. It does not provide data for VOCs. Figure10-1 shows short-term NOx concentration contours laid over a satellite image. However, there is noindication of geographical directions. Also there is no clear indication of nearest settlements, and LakeJandari is not within the area of the image. It is not clear which wind direction was chosen for the modeland why (e.g. the most frequent wind direction or the direction of the nearest settlement).

Landscape impact simulations are presented in figures 10-2 to 10-4. The main stack is not included in thesimulation, even though its height is precisely determined (28m), making the whole exercise futile.

The residual impacts are limited to visual intrusion, thus neglecting impacts on air quality. The samecomments stand for PSG2 and IPSG1.

Chapter 11. Social Impacts and Mitigation

Five main issues were identified as a result of a field survey. A sample of the field survey could not bedownloaded from the Internet.

I. Access to energy – Project-affected communities expect better access to energy, one of the mainproblems in Georgia. However, the ESIA says that the responsibility for energy supply rests with thegovernment. According to the FFM, the government has told locally affected people that the BTC willbring cheaper gas supplies to Georgia. Moreover, “in the Naokherbi village, the local elected council hasbeen told by the project companies that theoretically it was possible to provide the village with gas supplyfrom the main gas pipeline.” (FFM, p.20)


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II. Local employment – Expectations are far higher than real job opportunities. According to theESIA, approximately 1 700 jobs will be offered during the peak construction period, and 50-80% might beavailable for Georgians. If that number is known and published in the ESIA, why do people still have suchhigh expectations? Information about available jobs should be disseminated, and estimated more preciselythan 50-80%, as there is a great difference between 50 and 80. III. In addition, the ESIA says: “unskilled workers may be employed with no prior constructionexperience, though preference will be given to applicants with experience.” Most of the people do nothave such experience; so how many jobs will be available for Georgians in the end?

I. According to the FFM, local people have not received any clear figures about jobs available forlocal communities, even though various state and private recruitment offices have already started theregistration process in towns close to the pipeline corridor. II. People who have registered in recruitment offices had to fill in a questionnaire written in Russianwith personal data and qualifications on the basis of their skills and past working experiences. Many ofthem confirmed that they have been registered as “unqualified” due to their low knowledge andexperience in the pipeline construction field. (FFM p.22)

Clear figures about employment opportunities should be given to the local population.

The draft ESIA states that the BTC Co will implement measures aimed at maximising the proportion ofGeorgian staff employed. These measures would be included in the Invitation to Tender for pipeline andAGI construction. What these measures would be is not specified in the document; neither is the mannerin which would the BTC Co would enforce them. Details will be in the Environmental and SocialManagement Plan, which is not ready yet. For a proper assessment of environmental and social impacts,this plan should have been prepared earlier, or at least a clear timeline should have been defined.

Suggestion: Application forms in BP’s recruitment offices should be available first of all in Georgian andthen in the other languages of particular communities. The Plan should be included into the ESIA andreleased to the public again.

Table 11-2 Impacts and mitigation measures: employment issues; general comment on the tables in Section11; third column, residual impacts: only negative residual impacts are assessed as low, medium and high;positive are assessed only as beneficial without significance.

It is not clear how BTC Co will enforce all the measures. For a lot of mitigation measures it is still notclear who is responsible and when detailed management plans or mitigation measures will be developed.As for implementation; is there a fund for mitigation purposes, and will it be enough to implementeverything written in the draft document?

Impact E5: Working conditions. The table says that “the terms of conditions of work (e.g. hours of work,overtime, wages etc.) that are specified in workers’ contracts will have an important effect on the qualityof life of local and foreign workers, (e.g. health and safety effects of long working hours).” Proposedmanagement and mitigation measure says, “construction contractors have been required (via ITT) to applythe BTC Co’s corporate policies on employees, relationships and ethics as well as the 8 core InternationalLabor Organization (ILO) Conventions on employees’ working conditions. Contractors will also berequired to abide by the BTC Co Statement of Social Objectives.” According to the ESIA, “there shouldbe no residual impacts if the mitigation measures are effectively implemented.” However, the documentdoes not say what will happen if these measures are effectively implemented and does not establish a


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compliance mechanism which could be used by workers if their rights are violated. This is of highimportance for the communities that have negative experiences with the Baku-Supsa pipeline in terms oflong working hours, low wages and very few employment opportunities of local people.

Impact E9: Local produce supply/neglect of farmland: the impact of the short-term economic benefit fromdirect employment has been overestimated compared with the longer-term harm of neglect of farmland,which is assessed as a low potential negative impact. For those communities that are highly dependent ontheir land, the consequences of livestock neglect will be higher than estimated in the document.

Impact E11: Enhanced local skills: although workers will gain experience, the impact of “a comprehensivetraining program” that is still to be developed is overestimated, since it is not likely that similar constructionworks will happen soon in the same area. Because of the peoples’ high dependence on the community life,it is not very likely that those workers will move to an area far from their land.

Table 11-4, Issue L1: Permanent acquisition of land (and any related income) for AGIs, block and checkvalve locations, access roads and other ancillary works. Management and mitigation measures are listed inthe table; however, it is not clear who is responsible for mitigation. In addition, measures are still to bedeveloped during the Land Acquisition and Resettlement Plan and it is not clear when that plan will befinalised. The information about land acquisition, with clear procedures on actual implementation, shouldhave been distributed to the affected communities and the plan included in the ESIA.

Companies should clearly define how they have designed and calculated their offers. Compensation shouldbe determined via a process of negotiation and consultation, using community involvement mechanisms.Local authorities should be aware of the negotiation process, so they could act as mediators in case ofdisputes.

It is important to define the form of payment for compensations. Money should be transferred directly tothe affected people, to avoid complicated procedures and possible corruption.

The draft ESIA does not define for which period will people receive compensation. For example, if theworks affect more than one harvest, loss should be included.

Also, land is used for different purposes, such agriculture or grazing land, and compensation should bedefined according to the different type of land use.

Issue L3 Severance of lots with associated temporary loss of productivity and income. Again, it is notspecified who is responsible for mitigation.

Issue L8 Temporary Impacts on Enterprises (including loss of productivity, downtime). Again, it is notdefined who is responsible for compensation. In addition, the draft ESIA fails to assess potential impactson the Borjomi Bottle Mineral Water Company. The quality of mineral springs within and outside of theBorjomi-Kharagauli Natural Park might be affected by the project. Therefore, potential impacts should beassessed and mitigation measures along with a plan for compensation clearly defined. Accordingly, L8issues/impact should be renamed ‘Impacts on Enterprises’ (without the word ‘Temporary’), since it is notyet known whether potential impacts on the above mentioned company will be temporary or not.

L9 Forest areas impacted by construction. The table says: “approximately 10-12 km of trees will becleared from the ROW in Georgia”. This figure is wrong, since the quantity of trees should be put in cubicmeters and the loss of trees should be assessed in accordance with the importance for that particular area.

L10 Restrictions on land use. Mitigation measure says: “the project will replace irrigation canals asappropriate”. It is not clear who is responsible and what “appropriate” means in this context.


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Impacts and mitigation measures: local infrastructure, services and natural resources issues.

I1 New roads/Improvements to roads. Roads should not be built in any ecologically sensitive areas.Therefore, alternative routes should be found in cases where new roads might cross sensitive areas. Notonly would the roads damage ecosystems, but better access to forests could have much higher, long-termenvironmental impacts.

It is not clear when the Transport Management Plan will be ready and how the findings will beincorporated into the ESIA. The level of use is not known and before the Transport Management Plan isready, it should have been estimated. No proper assessment can be done without an estimate of road use.

Residual Impact says only that roads and bridges will be improved. However, there is no assessment ofwhat will happen if the contractor fails to repair these roads, as happened on some routes during the Baku-Supsa pipeline construction. That issue should be put into the potential residual impact as well andappropriate assessment should be done.

I5 Increased rail traffic. It is known that rail traffic will be “substantially increased”. Therefore, anestimate of the magnitude and associated mitigation measures should be defined and included in the draftdocument.

I8 Water: increased pressure on water resources for construction activities, camps and AGIs. It is notclear who is responsible for mitigation and when the responsible party will identify “water sources forproject use that do not affect the amount of water required for local use.” Communities that use the samewater source as the project should have already been consulted, so that mitigation measures could bedefined.

I9 Water: damage to community water supplies. Again, the responsible party is not defined, nor themethod of getting “alternative source of supply.” Communities that will be affected should have beeninformed about possible water shortages and ways of getting water supply.

Construction personnel and community relations

C2 Siting of construction camps and pipe yards. The camp locations are still not identified; therefore, it isnot possible to assess potential impacts on local communities. Community Relations Plan should have beenfinalised and given for comments to affected communities together with the draft ESIA. Such sensitiveissues should have already been discussed with the local population, especially in a situation where peoplehope to get more job opportunities than needed. Potential tensions between the local population and“foreign” workers might be high, not medium as assessed in the draft document.

In addition, two districts affected by the project, Tsalka and Borjomi, contain a significant presence ofinternally displaced people (IDP). Competition between different groups for the new benefits expectedfrom the project might cause conflicts in these regions. Therefore, this issue needs to be assessed andproper mitigation measures defined.

Community Investment Plan

“The objective of the community investment plan is to have a positive impact on communities mostaffected by construction activities by providing direct benefits, engaging with, and adding value, to localcommunities in a sustainable way.”


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The draft ESIA contains no detailed description of the Community Investment Plan. Section 13 says thattwo types of community projects will be developed; longer term sustainable development projects andsmaller local community projects. “Potential projects will be developed through discussion with thecommunities, NGOs, international development agencies and government”.

The Community Investment Plan should have been developed during the ESIA preparation, together withlocal population. It would give the affected communities a rationale for this project and should focus ontwo main issues: access to energy and employment. The draft document should have at least given moredetails about the potential projects and an explanation of the expected benefits for the local communities.The plan should be defined at the local level and implemented by the local administration. Funding for suchprojects should be distributed at the local level.

Chapter 14. Management and Monitoring

Only four out of 13 different environmental and social management plans are ready, which makes itdifficult to assess potential impacts of the project on both the environment and on communities along thepipeline route. The information regarding the specific management plans is not detailed enough and doesnot give a clear picture how impacts will be mitigated.

Since the contractor company is accountable only to the BTC Co, such a biased approach limits thepossibilities for independent monitoring.

Reporting; It is not clear whether all these reports (the contractor’s, as well as BP’s) will be available tothe public, especially to the affected communities. A method for informing and including the localpopulation in monitoring activities should be developed.

Although the construction contractors are responsible for certain management plans, the timeline forcompletion, disclosure and public input should have been set in the draft ESIA.

1 Community safety management plan. The draft descriptions of the Infrastructure and ServicesManagement Plan; Employment and Training Management Plan; Procurement and Supply ManagementPlan; Transport Management Plan; Pollution Prevention Management Plan; and Waste Management Planare all missing a description of methods. Only targets/objectives are listed, but not how they are to beachieved.

2 Draft Community relations plans should have been completed and included in the ESIA. This planlists things that (theoretically) should be done, but not within the context of this particular project withcomplex relationships between communities, and between a particular community and worker camp. Thisis especially important, since the project will not meet peoples’ expectations.

3 Resettlement action plan. Only the resettlement action plan, which has to comply with the WorldBank Group OD 4.30, includes a clear time line and independent monitoring. Similar practice should beused for the other draft plans.

Monitoring in most cases be done by the BTC; there is a need to include the local population, experts,NGOs, etc. and to conduct an independent and non-biased monitoring plan.


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Chapter 15. Overall Project Assessment

Positive social impacts• There is very little information on the “Community Investment Programme, developed andimplemented in communities adjacent to the pipeline corridor and associated facilities”. Section 13 statesthat “potential projects will be developed through discussions with the communities, NGOs, internationaldevelopment agencies and government”. More detailed description about potential projects is needed andan explanation how will these projects address the most significant problems identified by the affectedcommunities. • “A limited number of direct employment opportunities on the project, primarily short term jobs duringconstruction, with fewer, longer term opportunities during operation”. The fact that the project will providea very limited number of jobs, mostly during the construction, contradicts with the ‘sustainabledevelopment’ that the project is to offer to the affected communities.

• “Skills development and training, increasing peoples’ employment chances after the pipelineconstruction”. These benefits are overestimated – it is not very likely that similar construction will happensoon in the same area and people along the route very much depend on the community life, agriculturalland, etc.

Access to energyAffected communities expect better access to energy as a result of the project implementation. However,BTC will not provide communities with energy. Some part of the compensation should be given in the formof energy, in order to achieve project success and acceptance by the local population.

Employment opportunitiesThere is a potential conflict over employment opportunities, since the expectations about the number ofjobs is much higher than they will be. It is important to address the issue of high unemployment throughsmall-scale projects along the route. People need to feel that the BTC made a difference to theirlivelihoods.

Community relationsThis is a delicate issue, since most of the people live in relatively closed communities, and management ofcommunity relations has been on the most important mitigation measures of the ESIA.However, detailed management plans are to be developed by the BTC Co and the contractor. In order toassess and develop adequate mitigation measures, management plans should have been completed and themethod of “ongoing consultations…with regulators, NGOs and other interested stakeholders” should havebeen defined.


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6. References

Bonde, J. and Cherp, A. 2000. Quality Review Package for Strategic Environmental Assessments ofLand-use Plans. In: Impact Assessment and Project Appraisal. Vol 18. No. 2., June 2000. pp 99-110.

Bonde J. and Simpson, J. 1999. Environmental Appraisal Review package for Development Plans.[Online] URL: http://matisse.ceu.hu/departs/envsci/eianetwork/publications/bonde99.html [cited 2. Feb.2002.]

BP Health, Safety and Environment (HSE) Policy

International Fact-Finding Mission (IFFM) 2002. "Preliminary report from an international and independentfact-finding mission: Azerbaijan, Georgia, Turkey Pipelines project - Georgian Section" [Online]URL: http://www.bankwatch.org/issues/moilclima.html [cited 30.Aug.2002]

Lee, N., Colley, R., Bonde , J. and Simpson, J. 1999. Reviewing the quality of environmental statementsand environmental appraisals. University of Manchester: EIA Centre.

Scott, P. et al. 2000. Strategic Environmental Assessment of Development Plans – Training Guide,Section 7. Draft Version. University of Manchester, EIA Centre, School of Planning and Landscape.

EU EIA Directive 85/337/EEC, as amended by 97/11/EC, EU – Guidance on EIA – (1996).

European Commission SEA Directive 2001/42/EC.

World Bank 1999 Operational Policies (OP) 4-01 Environmental Assessment

World Bank 1999 Bank Procedures (BP) 4-01 Environmental Assessment


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7. Glossary

BTC - Baku-Tbilisi-Ceyhan Oil PipelineSCP - South Caucasus Gas PipelineACG- Azeri-Chirag-Gunashli Offshore Oil Field DevelopmentEA - Environmental AssessmentESIA -Environmental and Social AssessmentSEA- Strategic Environmental AssessmentESMP - Environmental and Social Management PlanEMS- Environmental Management SystemsESMS- Draft ESIA report, and the Environmental and Social Management System(s)EIP- Environmental Investment PlanAGI- Above Ground InstallationROW- Right of WayPS - Pumping StationWMP - Waste Management Plan

quality analysis of the esia draft report for the baku...

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