measures connected to the diversion tunnel on the river Nakra that will transfer water to the Nenskra reservoir.
This neglect increases the safety hazards posed to 396 inhabitants of the Nakra community who have suffered of
damaging effects of landslides, mudflows and other geotechnical and geodynamic processes.
In light of the historic geological instability and natural hazards such as mudflows and landslides in the Nakra
community area, we deem the Nenskra HPP derivation channel as a structure that is aggravating
incommensurably risks to our safety. The investor’s failure to properly study and assess these risks and propose
adequate mitigation measures within the Environmental and Social Impact Assessment process has increased our
worries about the project implementation. We appeal to the EIB to withdraw from appraising the Nenskra HPP
project for financing so to avoid the impending threat to our safety.
Problem description
Located on the steep slopes of the Nakra river gorge and in the narrow valley along the river stream, the
community of Nakra has historically suffered of geological instability and natural risks. Heavy snow fall and snow
melting have triggered avalanches and caused ecological migration out of the villages. A part of the population
was resettled as a consequence of the January 1987 avalanches. Avalanches keep affecting the village and causing
outmigration till the day.
Two tributaries of the Nakra river – Lekverari and Laknashera – have affected the village with repeated mudflows
occurring during torrential rains and snow-melting. Strong mudflows torrents hit the village in 2006, 2010, 2011,
2012 and 2016 and they left damage on houses, bridges and other property. In 2010, the Laknashera river
covered the village cemetery and agricultural plots with debris. A year later, the Lekvereri river washed away a
plot of land of a household and caused material damage to the property.
Figure 1: The remains of the Lekverari river mudflow inside
Nakra village.
Figure 2: The remains of the Laknashera river mudflow
upstream from the Nakra village.
The latest mudflow on the Lekverari river occurred in the night of June 30, 2016 damaging several properties and
destroying two bridges.2 The mudflows have repeatedly brought large amounts of silt and stones close to the
village center and have been eventually washed away by the Nakra river.
2
Further photo and video documentation:
Landslides are observed at the area of the transfer tunnel as well as inside the village. A number of houses in
Nakra have been sliding off the slope. A number of agricultural and pasture plots inside the village have been
damaged by landslides and mudflows.
Next to the mudflows and landslides, geodynamic processes have likely posed additional threat to the property
and safety of the Nakra residents. As documented in the enclosed photographs, a number of houses located at a
varying distance from the Nakra river have suffered of cracks.
Figure 3: Lekverari river mudflow on July 1, 2016
Figure 5: Collapsing walls of a house in Nakra
Figure 4: Lekverari river mudflow on July 1, 2016
Figure 6: Cracking wall in a house in Nakra
We have observed that the frequency of mudflows and landslides has increased over the time. This trend is also
noted by the Upper Svaneti Climate Change Adaptation Strategy that warns against the intensification of the
hazardous geological processes in the region.3
The Nakra deputies and individual residents have raised their concern with natural hazards and the urgent need
for climate resilience measures with the regional and national authorities. The Upper Svaneti Climate Change
Adaptation Strategy4 has recognized the critical situation in Nakra and set up a goal of minimizing mudflow risks
in the river gorge through field studies and an appropriate action plan. We have no information about the
progress of the field examinations or the action plan.
Nakra river has effectively acted as a prevention to the lake formation and flooding during the mudflows. Its
current has transported sediments away from the village within hours or days from the moment the mudflow
occurred. The plan to build a transfer tunnel for the Nenskra dam upstream from the Nakra village increases our
fears is that if water is diverted from the Nakra river, the remaining volume in the river will have reduced capacity
to clean the debris brought by the potential mudflows on the Nakra tributaries. We worry that this could lead to
ponding and eventual flooding of the village.
Figure 7: Remains of a ponding caused by a mudflow in the Nakra village in
June 2016
Figure 8: Nakra resident at his land-sliding plot
Project assessment
Given the precarious situation and the safety concerns in Nakra, thorough geological and geomorphological
survey must have been conducted within the project Environmental and Social Impact Assessment (ESIA). Yet, the
geological and geomorphological baseline investigations and assessment along the Nakra river valley are absent
from the project ESIA study.
3
Specifically, the document notes cyclical nature of the geological risks observed in 1987, 1997-1998, 2004, 2011-2012.
4
Upper Svaneti Adaptation Strategy to the Climate Change. UNDP Georgia. 2014.
We believe that due to the highly unsatisfactory geological and geomorphological survey, the existing ESIA
underestimates the risks arising from the operation of the Nenskra HPP scheme and misclassifies them as
medium.5 The ESIA geotechnical risk assessment in Nakra is limited literally to a paragraph:
“During the operation phase, Lekvedari River, which is characterized by mudflows and which runs North to Naki
village, may pose some significant threat to the population of this village. Lekvedari River valley is located in the
North of Naki village and joins Nakra River from right side. The river valley is strongly eroded and during abundant
rainfall mudflows are generated with large amount of solid sediments. At present, solid sediment is regularly
washed by Nakra River water and therefore, the risk of spreading mudflow to the village is reduced. After Nakra
dam is being operated, only ecological flow will be released downstream of the dam and major part of water will
be discharged in Nenskra River valley through the tunnel. Therefore, the river will lose the capacity of
transporting solid sediment brought by Lekvedari River, due to which the riverbed may be blocked and
mudflow may spread towards the village. Although there is no a high risk of developing this scenario, appropriate
mitigation measures should be considered.” 6
We are informed that a supplementary package to the ESIA containing an additional geological assessment is
under the preparation by the investor. To our knowledge, geological investigations were conducted in the area of
the diversion tunnel thru June-September 2016. Since then, the works have been stopped. We remain worried
about the thoroughness of the survey and the quality of findings that such a short survey can render. We also
have doubts about whether the survey is extensive enough to cover all the geotechnical and geodynamic risks
and examine the downstream parts of the valley, including the Nakra community. Without a proper survey,
reliable predictions cannot be made as to future risks of the Nenskra hydropower scheme operation.
Importantly, the geotechnical investigations omit to include:
-
an inventory of landslides in the Nakra valley area (including their causes, scale, timing, frequency of
occurrence, stability, etc.)
-
an inventory of mudflows on the Lekverari, Laknashera and possible other tributaries of the Nakra river
(including their causes, scale, timing, frequency of occurrence, stability, etc.)
-
a study of slope instability along the entire length of the Nakra river valley
The geodynamic investigations are missing altogether. In particular, investigations of geodynamic or geotechnical
processes that have caused damage to the houses, plots and other property in Nakra are pending.
Project mitigation
Detailed prevention, mitigation and remedial measures are missing from the current ESIA. The mitigation outlined
in the ESIA concentrates on the eventual lake formation as a result of a mudflow.
“The most important mitigation measure is that during the flood a full flow of Nakra River should be released
downstream of the dam in order to ensure downstream transportation of solid sediment from Lekvedari River. It
should be noted that protection of Naki village area is still relevant matter, as mudflow hazard is also expected
from upper part of Lekvedari River and activation of such processes will not be related to the operation of Nakra
dam.”7
5
Environmental and Social Impact Assessment Report. Project on the Construction and Operation of Nenskra HPP. „Nenskra”
JSC. Executor: Gamma Consulting Ltd. Tbilisi 2015. p. 356.
6
Ibid., p. 353.
7
Ibid. p. 353.
“During the flood periods, the total volume of the river flow should be released downstream of Nakra dam in
order to minimize the risk of solid sediment (brought from Lekvedari River) accumulation in Nakra riverbed
and to minimize negative impact on Nakra village.”8
This is highly unsatisfactory presentation of the mitigation efforts. The ESIA fails to present a detailed
management plant that would describe the individual steps to be taken in the risks monitoring, equipment
readiness, flooding response plan, etc.
Given the unsatisfactory character of the investigations so far, we are concerned that inappropriate mitigation
measures would be proposed by the investor within the additional ESIA study and result in heightened risks to the
affected community.
Conclusions
Geological instability and natural hazards have caused destruction of farming and forest lands and disturbance of
human lives, houses and other property in the community of Nakra. Detailed geomorphological and geodynamic
investigations within the entire Nakra river valley area have not been undertaken as a part of the Nenskra HPP
project ESIA. Thorough assessment of related hazards and the preventive and mitigation measures have not been
outlined either. This has undermined our trust in the proper assessment and implementation of the project.
Given the general geological instability of the Nakra area, we remain convinced the project will increase the
existing safety risks. We see this as serious enough reason for the EIB to stop the appraisal of the project.
Good faith efforts to address the issues
1. Participated in Number of individual meetings with Investor including in Nakra and in Chuberi raising this
concerns;
2. Meeting with representatives of the International Financial Institutions (ADB, EBRD) together with Investor in
Nakra;
3. Regular contacts with the Investor;
4. Number of protest actions in Chuberi, in Nakra as well as in Tbilisi in front of EIB and ADB offices – More than
10 protest rallies including blockade of the road in Chuberi in May 2016;
5 Collective approach to the Minister of Environment; September 25, 2015: http://greenalt.org/wpcontent/uploads/2015/09/Nenskra_-collective.pdf
6. Collective approach to the IFIs on Nenskra; April 18, 2016: http://greenalt.org/wpcontent/uploads/2016/04/mimarTva_chuberidan_2016.pdf
7. Response of the EBRD; May 6, 2016: http://greenalt.org/wpcontent/uploads/2016/05/%E1%83%9E%E1%83%90%E1%83%A1%E1%83%A3%E1%83%AE%E1%83%98_%E1%83
%AD%E1%83%A3%E1%83%91%E1%83%94%E1%83%A0%E1%83%98%E1%83%A1_%E1%83%97%E1%83%94%E1
%83%9B%E1%83%A1.pdf
8. Response approach to EBRD; May 23, 2016: http://greenalt.org/wpcontent/uploads/2016/05/EBRD_response_of_chuberi.pdf
9. Participation in Roundtable meetings orginised by different organisations including NGOs.
8
Ibid. p. 354.