“Gavigudet” Attended the Public Deliberation on the EIA Report of “Gia 2019” LLC

On August 19 the civil movement “Gavigudet” attended the Public Deliberation on the EIA Report of “Gia 2019” LLC, held in Rustavi City Hall.

The EIA report has been prepared upon changing the exploitation conditions of the enterprise; particularly, the company plans to install an additional separation mill with the performance of 15 tons per hour, which will be working 24 hours during 340 days in a year, and, consequently, 122, 400 tons of cement will be produced.

In addition to this, after the changes of the exploitation conditions, five additional silages will be arranged, each with the capacity of 120 tons.

Representatives of the company and National Environmental Agency attended the meeting.

Our group discussed the EIA report in order to prepare comments and notes. We submitted our remarks to the National Environmental Agency after voicing them on the public deliberation.

Traditionally, population was informed about the public deliberation by our team in advance (see the post).

Our comments regarded the following issues:

– Regarding the introduction of a continuous instrumental self-monitoring system in the enterprise, the EIA report provides a purchase agreement, according to which the enterprise had to receive the monitoring system by August 1. We would like to know, at what stage the installation process is for now?

The answer of company representative makes it clear, that the self-monitoring system has already arrived and is expected to be installed by the end of the month.

– The gen-plan of the factory does not include the noise sources sewerage scheme, required by the scoping decision. Also, the evaluation of the noise diffusion is general and it is not given specifically which devices induce noise.

– The zero alternative in the EIA report is oriented to justify the economic benefits of the project and does not provide the proper environmental explanation. Besides, it is not clear from the report whether appropriate forecasting studies, regarding emissions into the ambient air, were carried out before the decision to increase performance was made, which would reveal if the changes would or would not result into exceeding established emission norms. The method, used to discuss alternatives in the given EIA report, does not provide proper information.

– In the letter of agreement with the Rustavi City Hall, regarding the traffic rout, it is indicated, „that the load on the axle should not exceed 10 tons“, meanwhile it is mentioned in the paragraph 4.10 (impact during transportation of the raw materials/production), that the necessary amount for the production process is 480 tons per day, and 14-15 shipments will be made to receive materials. It is obvious, that mentioned amount of shipments does not meet the limit defined in the agreement letter.

As company representatives explained to us, 480 tons, indicated in the report represents the maximum amount for necessary raw materials, on top of that, axle load does not mean the load of the vehicle itself – the vehicle used for the transportation should have 3 axles with the 10 tons capacity for each.

– The intensity and conditions of removal of solid, hazardous waste, also companies, responsible for removal and further management conditions should be clarified.

– Paragraph 3.1 (technological scheme and regulation) of the EIA report states, that after increasing the capacity of the enterprise, only the intensity (quantity) of raw material import will be increased”, however the quantity is not specified, which should also be considered in the cumulative impact.

– Regarding the prevailing winds in the project area, we read in the EIA report, that “the prevailing winds from the project area are noticed from the north-west side, which does not represent the direction to the nearest settlement”, how ever it is unclear at what frequency and method the observations, on which this record is based, were made.

– “Mega Cement” LLC is not considered as a background polluter in this report. Besides, description of the cumulative impact is general needs to be detailed, based on specific indicators and data.

– It is mentioned in the 14^th chapter of the report, that “these measures revealed the interest of the population mainly in term of possible employment which indicates the fact that at the current stage of the socio-economic situation, the solution of employment problems for the population is of a higher priority than ensuring environmental measures” – it is not clear, what this record is based on, whether the company carried out a relevant survey with the population of Rustavi or has they met the residents of the nearest settlement, based on which this kind of attitude towards the project was revealed.

– Due to the fact, that “Gavigudet” actively follows the ongoing administrative proceeding in the Ministry, about existing/planned activities of plants in Rustavi, attends public delibarations and sends notes, it is desirable that the relevant decision or conclusion issued on a specific activity, be sent to us as well, together with the company and the municipality.

The project is implemented by Eco Centre in the framework of USAID Civil Society Engagement Program, funded by United States Agency for International Development (USAID).

This information material is made possible by the generous support of the American people through the United States Agency for International Development (USAID).

The contents of this information material are the sole responsibility of the Eco Centre and do not necessarily reflect the views of USAID, the United States Government, or EWMI.