Today, on June 21st, a public deliberation of the Environmental Impact Assessment (EIA) report was held at Rustavi City Hall regarding the project for the establishment and operation of LLC ‘Standard’s’ waste recovery (waste oil processing) production facility and temporary storage facility for hazardous waste (waste oils).
Our team and members of the ‘Eco Centre Academy’ (12 members), attended the public deliberation. The young people learned about the essence of public deliberation and gained experience in participating in official meetings and expressing their opinions. Additionally, we are pleased that citizens, who got information about the public deliberation from us, also joined the meeting, and expressed their interest in the ongoing processes in the city through their attendance.
Traditionally, representatives from the company, the consulting firm, the National Environmental Agency (Environmental Assessment Department), the Environmental Information and Education Center, and Rustavi City Hall attended the meeting.
LLC ‘Standard’ plans to set up and operate a temporary storage facility for waste oils and a technological line for waste (waste oil) recovery. The project involves receiving hazardous waste – waste oils at the production facility, temporary storage, and their recovery.
Regarding this activity, our team, along with academy members, discussed and prepared comments at the EIA working meeting, which were voiced by the academy members during the deliberation. We offer you their comments/questions and feedback:
– In the alternatives discussion chapter of the EIA document, it is stated that site alternatives were not considered because LLC ‘Standard’ has a lease agreement for the project site. Despite the pre-selection of the site, it would have been more appropriate to highlight the advantages of the chosen site in this section of the document.
As explained by the consulting company representative, at the scoping stage, the scoping conclusion was issued for one specific alternative out of two alternatives, so the consulting company did not consider it necessary to consider another alternative at the EIA stage. Consequently, the EIA directly introduced the alternative for which the scoping conclusion was issued.
In this regard, the representative of the National Environmental Agency also noted that issuing a scoping conclusion for any alternative does not exempt the activity from considering other alternatives at the EIA stage.
In the technological alternatives chapter, several methods for recovering used oils are described, with their characteristics and advantages. In the same chapter, it’s noted that the project plant plans to use a method where the planned technological process involves heating the oil to be processed at a certain temperature, during which bentonite is added. The alternatives chapter doesn’t clearly show the advantage of the chosen method and why it’s more acceptable than all the others listed above. According to the plant representative’s explanation, this specific method was chosen from several options due to various factors, including budgetary advantages, and also because the company received this equipment as a dividend.
– About 370 m from the project area is LLC ‘G Trans’ (02.05.03.747), 470 m away is LLC ‘Ferro Alloys Production’ (02.05.03.372), and about 500 m away is LTD ‘Poladkonstruktsia’ (02.05.03.098). These enterprises are not reflected in the EIA. It’s also interesting to know the profile of these enterprises.
As we were told, emission sources will be indicated in detail at the stage of preparing the MPE (Maximum Permissible Emission) document.
– According to the EIA document, the equipment used in the plant’s technological cycle is custom-made, so their passport data doesn’t exist. Will the equipment be made according to any standard and how safe will their operation be?
According to plant representatives, the equipment doesn’t have a passport because it’s not factory-made. They were checked by expertise and visual inspection (by a technologist).
– According to the technological cycle, finally, the sale of the obtained product is envisaged from the clean oil storage. Does the planned technology allow the use of oil in its primary form?
According to the plant representative, this is possible. It will have the same quality, but the cost will be much lower than imported oil.
– In Chapter 6.1 of the EIA report, it’s noted that ‘By implementing the project, some kind of irreversible impact is expected’, but in the following chapters, we don’t find a discussion of irreversible impacts. This issue needs clarification.
Answer: It’s a mechanical error and simply the particle ‘not’ is missing in this sentence.
The academy members raised the issue of conducting public deliberations in a hybrid format to allow more citizens to participate in such meetings.
Ministry representatives explained that although this is not provided for by law, the agency tries to schedule meetings in a hybrid format where possible. However, they said that the online format is a much more difficult process to manage and record citizens’ opinions, so preference is given to the face-to-face format.
In addition, we are pleased that besides the members of the academy, a citizen also asked questions about the potentially harmful effects of the activity and what standards are in place for preventing occupational safety risks.
Comments for the Ministry:
– If there are any remarks, it would be desirable for the letters we send to the Ministry to also be sent to the company, so that the same flaws in the previous document are not duplicated in future administrative proceedings for the same activity. In case the documentation is flawed and our remarks are taken into account in the letter, it would be desirable for this letter to be sent to us as well or for us to be notified. If the remarks are not taken into account, we would like to be informed of the reason.
– Given that the civic movement ‘We Are Suffocating’ actively monitors the administrative proceedings in the Ministry regarding existing/planned enterprises in Rustavi, attends public deliberations, and sends remarks, it would be desirable that the relevant decision or conclusion issued for a specific activity be sent to us as well, along with the company and municipality.
We also sent these comments to the Ministry in written form. After the public discussion, we also visited the plant site and inspected the situation on the spot.
The informational material is prepared within the project that is implemented with the support of the USAID National Governance Program