Introduction

Construction of wind power plant is planned by JSC (Caucasian Wind Company), based on the agreement signed with the Government of Georgia. The installed capacity of the wind power plant is 54 MW and its project area is located in Kaspi Municipality, between Upper Rene, Igoeti and Kaspi – on the Kernak Range.

After reviewing the scoping report presented by JSC, a number of problematic issues have been identified that are important to consider in the decision-making process by the Ministry of Environmental protection and Agriculture of Georgia.

It should be emphasized that the bulk of the scoping report is copied from the scoping report of Tbilisi Wind Power Plant Project carried out by WEG ENVI consulting; Duplicated information is very important considering the potential environmental impacts.

The copied chapters are:

• 4.1„Key Specific Aspects of the Impact Expected for the Project’ (p.55);
• 4.2.1 “Potential Impacts on Surface and Groundwater” (p. 68);
• 4.2.2″Surface and Groundwater Mitigation Measures” (p. 69)
• 4.2.3 “Atmospheric Emissions and Noise Propagation” (p. 69);
• 4.2.4 „Mitigation measures”(p. 72);
• 4.2.5„Potential impacts on geomorphology, soils and geosciences”(p. 73);
• 4.2.6„Mitigation measures on geomorphology, soils and geosciences”(p. 74);
• 4.2.7 „Potential Impact on Landscape”(p. 75);
• 4.2.8 „Landscape mitigation measures ”(p. 76)
• 4.2.9 „Activities with potential impact on environment”(p. 76);
• 4.2.10 „Potential impacts on water habitats”(p. 78);
• 4.2.11 „Potential impact on the fauna”(p. 79); 3
• 4.2.12 „Ecosystems, flora and fauna mitigation measures” (P. 80);
• 4.2.13 “Deaths of birds and bats due to collisions with wind turbines and power lines” (p. 81);
• 4.2.14 “Bird and Bat Mitigation Measures” (p. 81)

The document also contains outdated surveys (biodiversity surveys conducted in 2017) as well as incorrect data. For example, the Ministry of Environment and Natural Resources is mentioned several times as the decision-making body – instead of the Ministry of Environmental Protection and Agriculture of Georgia. In addition, the document reads: ‘The Georgian Government plans to approve this nominee as an Emerald site in 2018 – GE0000046 Kvernaki, 12.98 ha’, while Kvernaki is already an approved site.

Power line issue

According to the scoping report, a 110 kV transmission line will be constructed, which will be connected to the Kaspi substation and Qsani substation 500/220/110,although the Scoping statement does not mention the 110 kV transmission line and substation project.

The report superficially reviews the impact of the transmission line on the environment. In this case, it is to be ascertained whether the operator has prepared a single scoping report on the transmission line and the wind power plant. If so, the transmission line should have provided the information required by the Environmental Assessment Code.

Project Area and Wind Turbines Coordinates

According to Article 8 (3) of the Environmental Assessment Code, the scoping report shall include information on the location of the planned activities, including GIS coordinates (together with the shp files). The Shape files, together with the Scoping announcement are displayed on the official website of the Ministry of Environmental Protection and Agriculture of Georgia, include only the transmission line and the Kaspi Road, the coordinates of the turbine location and the study area are presented in the scoping report only, as a table.

Coordinates are difficult to map because no coordinate system is specified (WGS 1984 UTM Zone 38N), and the location of the turbine must have been represented in Shape files. It is important to make coordinates available in the Google Maps or Google Earth program to make them more accessible to the public concerned.

The number of turbines

The document reads: “The total installed capacity of the Kaspi Wind Power Plant will be 54 MW. A total of 12 or 13 turbines will be installed, depending on the turbine power ”(p. 10), specifying the number of turbines after selecting their supplier. Table 2-3 presents “Project Wind Power Turbine Layout Coordinates” – lists 16 turbines. It is not clear how many turbines are planned.

Alternatives to Activity and Location

According to article 8 (3) of the Environmental Assessment Code, the scoping report should include alternatives to the planned activity and the place of its implementation.

Scoping report states: “Based on preliminary surveys of prospective areas for wind regimes and wind power plants conducted by the company, within the framework of the MoU signed between the Government of Georgia and JSC (Caucasian Wind Company) on March 15, 2017, a prospective project area was identified for further detailed research and project feasibility analysis. ”

There is no review of alternatives to planned activities and wind turbine deployment, and the reason for selecting the project site is wind modes and economic feasibility, while alternatives to environmental protection should be offered. It also indicates that special conservation areas, called the Emerald Site, have been selected for the location of the wind power plant, and there are no alternatives that would not cross the Kvernaki Range.

Emerald Network Site Selected as Project Area

The wind turbines are planned to be stretched for 7 km along the designated Emerald site „Kvernaki“ (GE0000046). The reason for the approval of the Kvernaki Range as an Emerald Network site is the conservation of species through the preservation of natural habitats. The area is important for species protected by the European Convention on the Conservation of Wildlife and Natural Habitats (the Bern Convention).

According to the map presented in the Scoping Report, the project area is fragmented in the middle of the Kvernaki Emerald Site (see below) , which may completely disrupt habitat integrity and adversely affect species.

In addition to being the site of the Emerald Network, it represents an area of special importance for birds – SPA 10 KVERNAKI (Special protection areas) and Important bird area (IBA). This information is not mentioned in the Scoping Report at all, while important bird sites are areas of international conservation importance.

In addition, with the signing of the Association Agreement between Georgia and the EU in 2014, the Government of Georgia undertook two important commitments within five years of the entry into force of the Association Agreement:

• Defining and establishing an area of particular importance to birds;
• Take special conservation measures to protect migratory species whose movements regularly cross-national borders.

Biodiversity Assessment

Despite the importance of the project area, the biodiversity survey was conducted only one day – on November 11, 2017, from 09:45 to 19:00, while the study area is 4200 hectares. The data is quite shallow, only birds and occasional mammals are mentioned.

According to the document, the field study goal was focused mainly on bird research and not on mammals or other organisms: “The fieldwork was mainly focused on birds; therefore, it was done at a time which coincides with the last period of migration season of birds and the beginning of the wintering season (p. 131).

It is a significant flaw that the document submitted in September 2019 relies only on one-day data for 2017, when it comes to the territory recognized as important for both Georgia and internationally biodiversity.

Egyptian Vulture and wind power plant

Egyptian Vulture (Neophron percnopterus) is a Red List species of Georgia (status – vulnerable), while in IUCN Red List it is endangered. According to Article 11 of the Law of Georgia on the “Red List” and “Red Book” of Georgia, any action that may result in the death of endangered wild animals, reduction of their number, their habitat, breeding grounds, disruption of survival stations, migration and water routes is restricted .

In addition, Egyptian Vulture is protected by the second annex of the Bern Convention – “Strictly protected fauna species”, and the Government of Georgia is obliged to provide emergency protection of the species of wild fauna listed in Annex II to the Convention.

According to various studies, the decline in the number of Eyptian Vulture may be due to poisoning, habitat loss and degradation, disturbance from human activity, and collisions with wind turbines. The number of its population is reduced in Georgia

In scoping report Egyptian vulture is mentioned several times:

• “Rare visitor” (or wandering species) – accounted for only a few times; its existence is not expected, as its area of distribution is quite remote from the project area”;
• “Passover migrants (birds) – birds are regularly encountered during seasonal flyovers, mainly in autumn and spring”;

Based on the information provided in the scoping report, Egyptian Vulture is a very rare species on the Kvernaki Ridge, accounting for less than 1% of field trips. It is unclear how the 1 % data was analyzed when the field “outings” were not conducted and only one day the bird was observed on Novembers 11, 2017.

Since 2018, Subuko has been monitoring populations on the Kvernaki Ridge and has identified 4 nests in the area, 2 directly in the vicinity of the project area.

Figure 1. Egyptian Vulture nest in the vicinity of the project area, on the Kvernaki Ridge. Photo by Shota Japarashvili

We believe that the construction of the wind turbines and the transmission lines, both will endanger the biodiversity on the Kvernaki Range, as evidenced by the report.

The report states: “The impacts on the landscape, natural habitat and ecosystem will be related to the construction and operation of wind power plant buildings, substations and access roads. Building and site areas and access corridors will change the natural characteristics for a long period (until the site is demolished). This may lead to the destruction of some local habitats and important ecosystems ”(p. 67);

“During the operation phase, wind turbines and power lines cause changes in the habitat of birds and bats, as electric towers and cables are barriers that hinder them in flight: birds / bats can collide and perish / get injured, or die if two cables are touched simultaneously“ (P. 79). “The placement of a significant migration corridor of the wind power plant will cause bird deaths due to collisions with it,” reads the scoping report. Also, during the construction and operation phase, noise, including explosions in certain areas, may scare birds off. Nowadays, there is a great number of scientific researches evaluating the negative impacts of wind turbines on fauna and other leech species. Since the Kvernaki is directly in the area of distribution of Egyptian Vulture, we will focus on the associated threats.

“During the operation phase, wind turbines and power lines cause changes in the habitat of birds and bats, as electric towers and cables are barriers that hinder them in flight: birds / bats can collide and perish / get injured, or die if two cables are touched simultaneously“ (P. 79). “The placement of a significant migration corridor of the wind power plant will cause bird deaths due to collisions with it,” reads the scoping report. Also, during the construction and operation phase, noise, including explosions in certain areas, may scare birds off.

Nowadays, there is a great number of scientific researches evaluating the negative impacts of wind turbines on fauna and other leech species. Since the Kvernaki is directly in the area of distribution of Egyptian Vulture, we will focus on the associated threats.

Vultures can fly for a maximum of 25 kilometers daily to feed. In our case, the maximum distance between the turbines and the nearest nest is 1.7 kilometers, and the farthest pairs are 10 kilometers. Studies suggest that the target distance between the pair of Egyptian vultures and the turbines should be at least 15 kilometers , which reduces the risk of collisions. The proposed location of the turbines does not meet this specific requirement (15 kilometers). As you may already know, Egyptian Vulture is one of the top monitoring species in the Kvernaki site, however, so far, we have not seen any studies on the distribution and habitat use of Egyptian Vulture at this particular site.

It should also be noted that, in the vicinity of the project area, Amperax Energy Georgia LLC plans to construct a wind power plant (see Figure 2), which increases the expected cumulative impact on Egyptian Vulture, as the distance between their nests and turbines does not meet the above safety requirements.

Figure 2. Shown with blue signs are wind turbines planned by JSC “Caucasus Wind Company” and in red by Amperax “Energy Georgia LTD

The installation of a wind power plant and transmission lines on the Emerald site, SPA and IBA will hinder the country’s commitment to biodiversity conservation and lead to degradation of the Kvernaki Ridge as a biodiversity site.

                  Figure 3. Egyptian vulture nests in the vicinity of the project area

According to the Scoping Report, a strategy to reduce bird impact involves selecting an area and removing an object from the most sensitive areas (p. 68). As the whole project area is fully located in a particularly important area for birds, we consider it necessary to find other alternative sites for the construction of the wind power plant and transmission line, taking into account environmental aspects. At the same time, the Ministry of Environment and Agriculture of Georgia shall take into consideration the obligations undertaken under the laws and international agreements of Georgia in the field of biodiversity conservation while making decision regarding another planned project.