How Did “Geo Enterprise” LLC Respond to Our Remarks and Comments?

“Geo Enterprise” LLC had planned to run a metallurgical plant on non-agricultural territory, in particular – melting the scrap metal (steel and cast iron) and preparing various castings.

On March 16, 2022 company addressed the ministry to get an environmental decision. “Gavigudet” attended the public deliberation of the project, which was held on May 3, 2022 and we sounded our remarks and comments. On May 23, 2022 National Environmental Agency made a decision to halt the administrative procedure until certain issues were not clarified.

On July 6, 2022 “Geo Enterprise” LLC submitted additional/clarified information, including:

– Answers to the Ministry questions;

– Answers to the questions of the civil movement “Gavigudet”;

– Extract from the public register (new one);

– License for extraction underground water;

– Letter of agreement with the City Hall of Rustavi about the route and schedule of transportation;

– The letter from the water supply company about the disposal of sewage waste water;

– Technical characteristics of the filters;

– Passport of the exhaust machine (translated).

We are pleased, that the company answered all questions, from us and the agency, within a reasonable time (our questions and comments can be seen here). We are also pleased, that the agency has taken into account and reflected the issues, raised by us, in their questions.

Agency’s and our questions were the same with regard of following issues:

– The EIA report should include justification of the production related technologies. In case of furnace justification is represented, however, the criteria for selecting the Russia-produced filter is unclear, so is its advantages over other alternatives.

– The issue of receiving raw materials needs to be clarified. The report does not provide the information about the scrap supply source and what share of it will be imported? Conditions of the agreement with the suppliers needs more detailing.

– The EIA chapter of justification of the project necessity does not provide clear picture, as it is limited to superficial assessments. The document does not include information about the preliminary research (methodology, research period, results, etc.) of local market, based on which the activity was planned.

– The section of ambient air impact mitigation means says – “In order to protect against atmospheric air pollution during adverse weather conditions, an appropriate action plan will be drawn up” – this recording needs to be clarified in terms of compliance with the current legislation. Beside, the issues to be specified are: based on which parameters the adverse weather conditions are defined? What exact steps are implied in the mitigation measures? Who will be responsible for drawing up the action plan?

Answers to Our Questions

Despite the fact, that all our questions have been responded, there still are some issues, we did not receive proper answer about. For example:

– The justification of the necessity of the project does not still provide the clear picture, as it should describe all the necessary information and data, that proves the need of the project implementation. Moreover, this description must be understandable for anybody.

– Technical characteristics of the selected filter and details, that proves its superiority are not still provided. The producer country is not the issue, but technical abilities, based on which the tool was selected, should be clear.

– One of our remark was about the fact, that the EIA report described the impact only during the exploitation process. But even after the response from the company, the problem remains the same – by the time of the preparation of the EIA report, the arrangement of the enterprise was completed, and given report assesses only impact during the exploitation process. The EIA report should also include the impact assessment during the arrangement process, otherwise it is a violation of the Environmental Assessment Code.

– Our question about mitigation measures in adverse meteorological conditions was only partially answered. Namely, they have explained what ‘adverse meteorological conditions’ are supposed to mean; but the technical regulation on “Ambient air protection during adverse meteorological conditions” makes it clear, that National Environmental Agency has the obligation to create the warning measures to stop the increase of pollution with harmful substances; and then the agency should send those measures to the companies. The Department of Environmental Supervision is responsible for monitoring the fulfillment of the abovementioned process.

In a letter we asked the agency whether the resolution about the environmental protection during the adverse meteorological conditions is enforced, but the agency respond, that for the time being, they are not able to predict adverse meteorological conditions, and therefore they are not able to create warning measures for avoiding the increase of harmful substances during adverse meteorological conditions. Aerological observations, that are necessary to identify meteorological conditions in the upper layers of atmosphere has not being conducted since 1990 years. In the agency, they hope this observation would be restored in 2023-2024 years.

Informational material is prepared within the framework of the project “Defending Our Right to Clean Air”, with the financial support of “European Endowment for Democracy”