AMMONIA MARINE TERMINAL TAMAN KRASNODAR REGION, RUSSIA PUBLIC CONSULTATION AND DISCLOSURE PLAN Prepared for TOGLIATTIAZOT by IT Russia Services, Inc. Moscow June, 2003
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AMMONIA MARINE TERMINAL
TAMAN
KRASNODAR REGION, RUSSIA
PUBLIC CONSULTATION AND DISCLOSURE
PLAN
Prepared for TOGLIATTIAZOT
by
IT Russia Services, Inc.
Moscow
June, 2003
TABLE OF CONTENTS
1.0 INTRODUCTION .................................................................................................................................................3 1.1 Objectives...........................................................................................................................................................3 1.2 Scope of Work ...................................................................................................................................................3
2.0 BRIEF DESCRIPTION OF THE PROJECT.....................................................................................................4 3.0 REVIEW OF PUBLIC INFORMATION POLICY REQUIREMENTS .........................................................5
3.1 Requirements of the National Legislation ..........................................................................................................5 3.2 Principles and Procedures Established by International Organizations ..............................................................8 3.3 Corporate Requirements to Environmental Policy, Public Relations and Information Disclosure.....................9
4.0 REVIEW OF PUBLIC CONSULTATIONS AND DISCLOSURE OF PROJECT INFORMATION ACTIVITY PERFORMED BY TOAZ....................................................................................................................10
4.1 Determination of Major Stakeholders...............................................................................................................10 4.2 Establishing the Interaction with the Interested Parties and Implementation of Preliminary Consultations ...11 4.3 Major Comments, Concerns, and Recommendations Expressed by the Public...............................................15 4.4 Consideration of the Concerns and Critical Comments from the Stakeholders during the Development of
Design and Preliminary Stage of Construction ................................................................................................17 5.0 PUBLIC CONSULTATIONS ON TEOC ENVIRONMENTAL PROTECTION SECTION (EIA)...........22
5.1 Disclosure of Information about the Project .....................................................................................................22 5.2 Consultations with the Public ...........................................................................................................................23 5.3 Schedule ...........................................................................................................................................................24 5.4 Collection, Consideration, and Generalization of Concerns ............................................................................26 5.5. Resources and the Responsible Persons...........................................................................................................28
6.0 CONSULTATIONS DURING THE CONSTRUCTION, OPERATION, AND TERMINATION OF OPERATION.............................................................................................................................................................28
6.1 Interaction with the Stakeholders during the Construction...............................................................................28 6.2 Tasks of the Program and the Allocation of Responsibility .............................................................................28 6.3 Responsibilities of Togliattiazot .......................................................................................................................29 6.4 Responsibilities of Subcontractors....................................................................................................................29 6.5 The Resources and Elements of the Organizational Structure Required for the Interaction with the Interested
Parties during Construction..............................................................................................................................29 6.6 Relations with the Interested Parties during Operation.....................................................................................30 6.7 The Resources and Elements of the Organizational Structure Required for the Interaction with the Interested
Parties during Operation ..................................................................................................................................30 6.8 Interaction with the Interested Parties in the Period of Termination of Operation ...........................................31
7.0 THE GRIEVANCE MECHANISM...................................................................................................................31
7.1 Procedure of Grievance Consideration .............................................................................................................31 7.2 Response to Complaints ...................................................................................................................................32 7.3 Monitoring ........................................................................................................................................................32 7.4 Archiving..........................................................................................................................................................32
Attachment 1 ...............................................................................................................................................................34 Attachment 2 ...............................................................................................................................................................47 Attachment 3 ...............................................................................................................................................................50
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1.0 Introduction
This document contains a Draft of Public Consultation and Disclosure Plan (PCDP) for the Ammonia Marine Terminal Project (AMT) planned to be constructed by OAO Togliattyazot (ToAz) in Taman Peninsula, Krasnodar Region (Krai), Russian Federation (RF).
The document was prepared by the IT Russia Services Inc. in line with the EBRD’s Public Information Policy and IFC’s OP 4.01, based on the analysis of TEOC documents presented by Togliattyazot, information from mass media, consultation with representatives of interested parties, and interviews during our visits to the construction site in Taman Peninsula and to Krasnodar on April 10–14, 2003.
1.1 Objectives
The document presents the analysis of measures already taken by OAO Togliattyazot during preparatory work on AMT and the outline of the plan for future actions aimed at timely informing all the interested parties about the project and its possible impacts. The document also contains the analysis of concerns, complaints and recommendations of different stakeholder groups, and suggestions on creation of a mechanism for taking this information into consideration when updating the design documentation and implementing the project.
The PCDP could to be updated during its realization according to suggestions of the Project sponsor.
The objectives of this document include:
Determination of the major stakeholder groups and discussion of the mechanism of interaction with them
Development of the schedule of consultations with the stakeholders at different levels (local, regional, international), as well as at different stages of the project development and implementation
Development of the mechanism allowing the stakeholders critical comments and recommendations to be taken into account in the process of project update and implementation
Evaluation of the resources required for the PCDP implementation.
This plan is a “living” document, since it will be reconsidered and amended when additional data arrives in the course of the project development and consultations with the public and other stakeholders.
1.2 Scope of Work
The PCDP considers the following issues:
Brief description of the AMT Project
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Review of the requirements on public consultations and disclosure of information contained in the national legislation, documents of international organizations, and corporate standards
Review of the consultations with the public and other stakeholders already implemented by ToAz and steps having been made for the disclosure of information about the Project.
Draft Program of consultations for the construction and operation phases
Assessment of the resources and organizational structure required for the implementation of PCDP
Development of an effective grievance mechanism.
This document will be amended with:
1. The list of major project stakeholders
2. The list of major publications about the Project
3. Extracts from the public consultations minutes.
2.0 Brief Description of the Project
The Project to be implemented by ToAz in Taman District of Krasnodar Region (Krai) (Russian Federation) is aimed to the construction of the marine ammonium terminal on the Black Sea shore of Taman peninsula. The planned terminal is a complex engineering facility with ramified main and auxiliary process streams. All integral parts of the liquid ammonia terminal project and their basic elements, which are potential sources of environmental impacts, are listed in Table below.
Ser. Nos.
Description of main project parts Objective Basic elements
Transportation Facilities 1 Railroad line between
Vyshestebliyevskaya Station and TogliattyAzot Station
Liquid ammonia transportation in railroad tank cars from the main railroad line to the ammonia storage facilities. Length: approximately 40km
Railroad sidetracks Bridges and embankments with culverts Railroad crossings Togliattiazot railroad station
2 Ammonia pipeline Liquid ammonia transportation from the storage facilities to the tanker loading system. Length: approximately 4 km
System of Insulated Steel Pipelines of the Onshore and Tanker Loading Facilities
Onshore Terminal 3 Onshore ammonia
storage facilities of the terminal
Transfer and storage of liquid ammonia
1. Unloading facility (two double-sided unloading racks for 14 unloading points at each side, i.e. the total of 56 points; one additional unloading rack for 14 unloading points. Thus, the total number of unloading points is 70)
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Ser. Nos.
Description of main project parts Objective Basic elements
2. Isothermal storage facilities for liquid ammonia (two vertical double-wall steel cylinders each with a capacity of 30,000 tonnes of ammonia)
3. Support system for the ammonia storage (including compressor and condensate station, gas-piston electric power plant, flare facility, etc.)
4 Technological facilities within the coastal zone
Provision of support services for the onshore terminal
Support facilities, including ammonia circulation pump, drainage tank, seawater pump station
Sea Terminal 5 Hydroengineering and
onshore facilities of the sea terminal
Engineering support for vessel handling, safe mooring at the berth and integrated services of vessels
1. Shore protection structures (total length of approximately 3 km)
2. Approach pier (total length of over 2 km)
3. Loading jetties
4. Protection against waves (total length of over 1 km)
5. Fairway and operational sea area
6. Gas tankers and support vessels
Auxiliary and Office Facilities 6 Auxiliary facilities for
support to the terminal operations
Wastewater treatment facilities, fire safety systems, storage of materials and supplies, equipment maintenance facilities
1. Biological wastewater treatment plant
2. Accumulating and evaporation pond
3. Fire department
7 Office building and general auxiliary services of the terminal
Day-to-day management of the operations
Office and general facilities buildings, entrance building, boiler house, pump station, Togliattiazot industrial site, etc.
3.0 Review of Public Information Policy Requirements
Suggested measures aimed at public consultation and disclosure of information comply with the following legal requirements:
Legislation of the Russian Federation
Principles and procedures established by international organizations, including the World Bank, IFC, and European Bank for Reconstruction and Development, International Conventions for Public Involvement
Internal corporate standards of Togliattiazot.
These requirements will be briefly outlined in the following sections:
3.1 Requirements of the National Legislation
Effectively, all the stages of the preparation for the implementation of the proposed economic activity are supposed to involve participation of the public in making environmentally
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important decisions. The mechanisms of this participation are incorporated in the legal and other regulatory acts to ensure the implementation of the constitutional provision which reads as follows – Everyone has the right for good environment, adequate information on its state and damage compensation caused by the environmental violation.
1. According to Article 11 of the Federal Law dated January 10, 2002 No.7-ФЗ On Environmental Protection the citizens enjoy the right to:
Participate in meetings, public rallies, demonstrations, marches and picketing, collection of signatures under petitions, referendums related to environmental protection and other action consistent with the legislation of the Russian Federation;
Put forward proposals for the Public Environmental Expert Review and participate in it as proper;
Submit to the Government of the Russian Federation, constituent entities of the Russian Federation and local governments complaints, requests and proposals concerning environmental protection, adverse environmental impacts and to receive timely and well justified response;
Sue for environmental damage.
In addition to the above, non-governmental associations have the right to:
Organize and conduct as proper hearings concerning the design process and siting of the projects whose economic and other activity may cause damage to the environment and risk to the life, health and property of the citizens;
Organize and conduct as proper the public environmental expert review;
Recommend their representatives for the participation in the State Environmental Expert Review;
Submit to the government of the Russian Federation, constituent entities of the Russian Federation and local governments petitions for the cancellation of decisions concerning the design, sitting, construction, reconstruction, and operation of the projects whose economic or other activity may have a detrimental environmental impact, as well as for the containment, suspension or cancellation of the economic or other activity with an adverse environmental impact.
Article 35 of the Law provides that if the sitting of structures has an impact on the legal interests of the citizens, the relevant decision shall be made with due regard to the results of the referendum to be carried out in the respective territories.
2. During the pre-investment preparation of the project, public participation takes the form of participation in the process of Environmental Impact Assessment (EIA). The Regulation on the Assessment of the Environmental Impact of the Proposed Economic and Other Activity in the Russian Federation was approved by the 372 Order of the State Environmental Committee of Russia dated May, 16, 2000. Section IV of the said Regulation addresses the public awareness and participation in EIA.
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Public awareness campaign and public participation shall take place at all the stages of the environmental impact assessment.
Public participation in the preparation and discussion of the EIA materials shall be provided for by the Developers as an integral part of the EIA process and shall be arranged by the local governments or the respective state authorities in cooperation with the Developer and in accordance with the legislation of the Russian Federation;
Provision of information to the public and other participants of the EIA process during notification, preliminary assessment and preparation of TOR for EIA shall be the responsibility of the Developer. An update on the federal level proposed activities shall be published in the official publications of the federal authorities;
The Developer shall provide access to the TOR for EIA to the public involved and other participants of the EIA process as of the date of approval and till the date of completion of EIA;
The EIA also updates the plan of action for the public discussion of the proposed economic activity including the need for the public hearings concerning the EIA materials;
The decision on the format of the public discussions including public hearings shall be based on the extent of environmental risk from the proposed economic and other activity, the factor of uncertainty, the degree of interest of the public;
The procedure for public hearings shall be determined by the local governments in coordination with the Developer and the public concerned. All the decisions concerning public participation shall be documented.
The Developer shall arrange public hearings concerning the proposed activity and minutes of the hearings clearly reflecting the main items of the discussions, differences between the public and Developer if any. The minutes shall be signed by the representatives of the state authorities and local government, citizens, non-governmental organizations (associations), the Developer. The minutes of the public hearings are part of one of the attachments to the final version of the EIA materials for the proposed economic and other activity.
For 30 days following the public hearing and up to the decision concerning the implementation of the proposed economic and other activity, the Developer is obliged to receive from citizens and non-governmental organizations comments and proposals in writing and document them as attachments to the EIA materials.
According to the provisions of Article 14 of the Federal Law No. 174-ФЗ On Environmental Expert Review, dated November 23, 1995, the state environmental expert review shall only be carried out only subject to the availability of the materials of the discussion of the proposed activity with citizens and non-governmental organizations, with the discussion arranged by local authorities.
3. At the stage of the State Environmental Expert Review, the citizens implement their rights through the public environmental expert review. The rights of citizens and non-governmental organizations are addressed by Chapter IV of the Law on Environmental Expert Review.
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The public environmental expert review will be initiated by citizens and non-governmental organizations/associations whose main area of activity, as prescribed in their charters, is environmental protection including the arrangement and carrying out of the environmental expert review, and which have been registered in accordance with the legislation of the Russian Federation. The public environmental expert review could also be initiated by the local governments.
The public environmental expert review shall be carried out prior to the state environmental expert review or in parallel with it.
Within seven days of the date of application for the public environmental expert review, the local government must register the application or refuse its registration. The Application for the public environmental expert review, which has not been turned down within the established period, shall be considered as registered.
The conclusion of the public environmental expert review shall be valid after its approval by the competent state body in the area of state environmental expert review.
4. Environmental referendums are regulated by the Federal Law on the Basic Guarantees of Universal Suffrage and the Right to the Participation in a Referendum of the citizens of the Russian Federation, as well as by the Law of Krasnodar Krai No. 109-КЗ dated December 1997 on Local Referendum.
A local referendum may address local issues as referred to in the Charter of the municipal formation;
To approve a local referendum the representative body of the local government shall receive signatures of not less than 5 percent of the citizens, who enjoy the right to participate in the referendum, for the support of the referendum initiative.
The referendum decision is binding for everybody and does not need to be approved by any of the state authorities (officials) or local government.
If the implementation of the decision of the local referendum requires the adoption of a regulatory legal act, the local government, which is responsible for this issue, must set the deadline for the preparation of the said act within 15 days of the date of effectiveness of the decision.
It is known that Krasnodar Krai has certain experience in the arrangement of local environmental referendums. In 1998 and 2000, the resort city Gelendjik held two referendums concerning a cargo port project.
3.2 Principles and Procedures Established by International Organizations
International organizations pay considerable attention to involving the public in the decision making process concerning major development issues and individual projects being implemented with the support of these organizations. International Bank for Reconstruction and Development – World Bank (and other organizations belonging to this group, such as International Financial Corporation), European Bank for Reconstruction and Development and other organizations contribute significantly to the adoption of internationally recognized standards in this area.
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International Financial Corporation (IFC)
As early as 1993, IFC, a member of the World Bank Group, introduced the requirement of public consultations and information dissemination as a prerequisite to granting its support. Since then, IFC has developed a number of additional guides and procedures to specify this requirement. A special document – IFC Policy Toward the Dissemination of Information, which was approved in September 1998, determines the guidelines the Corporation follows in its activity and describes the materials to be made available for the public. For details see www.ifc.org
European Bank for Reconstruction and Development (EBRD)
EBRD recognizes the growing public interest to its projects and the principles of activity and proceeds from the need to disseminate this information among the general public. The document of the European Bank for Reconstruction and Development “The Principles of Public Information” issued in 2000 envisages extending the volume of information EBRD will make available for the public. This document is based on the following fundamental principles:
Transparency
Willingness to listen to criticism and to take it into account
Reservation of the commercial approach to the implementation of the mandate.
Considering this, EBRD procedures envisage the observance of the national environmental protection standards and the working rules of EU, or, where no EU rules are available, the national standards and the rules of World Bank. Therefore, the projects that may have transboundary effects must be implemented with due regard to the requirements of the Convention for Environmental Impact Assessment in Transboundary Context (Espoo Convention) – see also: www.ebrd.org.
3.3 Corporate Requirements to Environmental Policy, Public Relations and Information Disclosure
In cooperation with EBRD, the Company has developed and started implementing "The Plan of Actions Aimed at Environmental Protection for 2000–2005"; reports on its implementation are sent to the Bank environmental division on a regular basis.
The management of OAO Togliattiazot pays considerable attention to the interaction with the interested parties and disclosure of information about the Project through appropriate steps taken at the local, district, and regional levels.
The ToAz organizational chart includes special positions for managing these issues. At the level of the Corporation senior management, these issues are controlled by Vice-President and the Head of International Relations Department (though the President of Corporation also takes active part in the interaction with the major stakeholders and public relations). On the construction site, these are the duties of a special Manager for public relations.
During the construction preparation period the ToAz Corporation have conducted substantial work in Krasnodar krai, Temryuk District, and in Volna Settlement to establish the circle of interested parties, determine the ways and means for communication with them, disclose
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information about the project, register and consider commentaries of project stakeholders. The major forms of interaction in such cases were discussions about the Project in local and regional mass media; interviews; consultations; panel discussions; public hearings, with the participation of Corporation managers and representatives, representatives of administration, deputies, public, and invited experts.
More detailed information about this activity is presented in the next section.
4.0 Review of Public Consultations and Disclosure of Project Information Activity Performed by TOAZ
Analysis of documentation provided by ToAz Corporation, materials of mass media, and consultations with the representatives of stakeholder groups and individual stakeholders allows the conclusion that during design, coordination, and preparation of individual Project components construction phases, Togliattiazot was taking measures for public relations and consultations, as well as for disclosure of information about the Ammonia Marine Terminal Project.
The major efforts at this stage were focused on:
Determination of the project major stakeholders
Establishing interaction and conducting preliminary consultations with them for formulation of the their positions
Dissemination of information about the Project and its potential impacts, with allowance made for the principal critical remarks, development of the mitigation measures
Development of public consultation and interaction mechanisms and for obtaining necessary approvals.
4.1 Determination of Major Stakeholders
At the initial stage of preparation and implementation of AMT Project, Togliattiazot has revealed the major interested parties and stakeholders at the local, district, and regional levels. The list stakeholders included the persons, organized groups, and organizations that may be affected by the Project implementation, either directly or indirectly, either favorably or adversely, or can exert some effect on the success or failure of AMT Project.
All identified stakeholders were divided into the following groups:
Authorities (including legislative and executive bodies at local and regional levels, as well as representatives of federal regulatory authorities) for example, Head of Temryuk District, Vasilevskii Ivan Nikolaevich; Head of Administration of Tamanskii Okrug, Ostapenko Rodion Mikhailovich; Chairman of the Standing Commission of the Temryuk District Council of Deputies for the Issues of the Agro-Industrial Complex and Land Use, Rydin Aleksei Ivanovich; Head of the Committee for Health Resorts and Tourism of the Territorial Administration, Fursova Elena Borisovna; Head of the
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Central Directorate of the Ministry of Natural Resources for Krasnodar Territory, Velichko Sergei Vasil’evich, and others.
Local residents (inhabitants of the nearby settlements; land owners whose land lots are situated in the area of potential Project influence; local fishermen; people who use the coastal area for recreation), such as the leader of Taman’ Cossacks, Glin’ko Nikolai Arsent’evich; Head of the War Veteran Council of Taman’ Stanitsa, Obido S.I.; Stanishevskii Sergei Grigor’evich, a businessman, influential and active local figure; and others.
Groups of influence (business structures, nongovernmental organizations (NGOs), research institutions, mass media) – Director of “Ogonek”, a recreation center in Volna, Anatolii Goryainov; a representative of the Khvalyun fishery collective farm, Demchenko Aleksandr Ivanovich; Chairman of the West Caucasian Social-Environmental Union, Andrei Rudomakha; Environmental movement “Rainbow Warriors”; Vol’naya Kuban’” newspaper; Director of “Kubangiprozem” Institute, Seredin Aleksei Mikhailovich; and others.
A separate stakeholder group incorporates international financial institutions, to whom the ToAz corporation has applied for a loan, required for the implementation of the AT Project.
In the process of major stakeholders determination ToAz proceeded from the assumption that the circle of stakeholders can enlarge and may change in the course of project implementation, which will require appropriate amendment of their list and interaction schedule (the stakeholders will be listed in Attachment 1).
4.2 Establishing the Interaction with the Interested Parties and Implementation of Preliminary Consultations
Preliminary consultations in Krasnodar Administrative Krai have been conducted since 1998 with the aim to inform the regional authorities, population, and the groups of influence about the project, establish the major limitations that the Corporation can face in the course of project implementation, and find the ways for their negotiation.
Special offices for interaction with the interested parties were introduced within the administrative structure of Togliattiazot Corporation both at the level of Directorate in Togliatti and at the site of project implementation in Volna Settlement, Temryuk district.
At the corporation level, the office is managed by S.N. Titov, Head of External Relations Department (Togliattiazot, Povolzhskoe shosse 32, Togliatti; telephone: (8482) 24-5945, fax: (8482) 24-0110, e-mail: [email protected]). At the construction site, the responsibility for public relations rests upon a special Service headed by A.I. Ponomarev (Volna settlement, Temryuk District, Krasnodar Krai; phone/fax 8 (901) 491-1715; 8 (861) 485-8141).
In 2002, a joint meeting of the Administration of Temryuk district, Krasnodar Krai, and the managers of Togliattiazot Corporation adopted a resolution on the creation of a joint Working Group for Public Relations and Information Disclosure about the Project (Minutes dated July 24, 2002). The administration is represented in this group by A.P. Grishchenko, Deputy Head of the District; M.S. Isaenko, Deputy Head of the District for Organization and Personnel; and I.G. Mironenko, Head of the Administration Staff and Head of the Press Service at the District Administration. On behalf of Togliattiazot, the group activity is coordinated by S.N.
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Titov, Head of External Relations Department, and A.I. Ponomarev, Head of the Project Service for Public Relations.
Representatives of the Corporation have established working contacts with representatives of the regional administration of Krasnodar Krai, Temryuk District, and municipal authorities in the area of project implementation, and started interaction with the major stakeholders.
As for the authorities, preliminary consultations with them were intended to determine the possible serious obstacles for and limitations to the project and to receive initial permissions. A specific task included consultations with land owners and land users in the area of project implementation (public structures, corporations, or private persons) in order to come to agreement and obtain necessary and sufficient land allocations.
The procedure of land allocation for the construction has been conducted in parallel with the process of the construction project approval. For this purpose, Togliattiazot Corporation has held consultations and negotiations with the local power authorities, juridical and natural persons, who owned the lands required for the project implementation, that is, agro-industrial enterprises and farmers, who had received their allotments during the reformation of the local collective farms. As a result, ToAz has received the lands, required for the project, in a long lease (for 49 years).
The lands allocated were mostly of little use for agricultural production, i.e., salinized, low-fertility, located on the sea coast, in lowlands, and so on. All land agreements were made willingly between the company and land users, and when agreement could not be reached (i.e. people did not want their land used) the company choose other alternatives so as to avoid impacting those properties. For instance, the configuration of the AMT main land plot was changed after it had been found impossible to gain understanding with local farmers.
The decisions regarding the land allocation were legalized by the appropriate resolutions of the Head of Temryuk District, Krasnodar Krai (of September 28, 2001, no. 2492 “On the Allotment of Land in Long Lease to OAO Tol’yattiazot in Temryuk District”) and the Head of Krasnodar Krai Administration (of October 24, 2001, no. 1013 “On the Allotment of Land to Togliattiazot Public Corporation (OAO) in Temryuk District).
Serious efforts were made to establish contacts with public. It is worth mentioning that by the moment when Taman Peninsula was chosen as the place for AMT construction, a socially active environmental opposition has evolved and several public groups were created to oppose a similar project for transfer of liquefied hydrocarbon gases (LHG). The LHG terminal construction was started near the present AMT construction site about 2.5 km from Volna Settlement. Thus, starting its work in Taman, Togliattiazot Corporation faced an already existing active environmental opposition represented by Social–Ecological Union and Green movement, local Cossacks and organized local residents (mainly from Volna Settlement and Taman Stanitsa, which lie within the area of potential project impact), as well as representatives of environmentalists based beyond the Krasnodar Krai territory, such as activists of environmental movement – “Rainbow Warriors”. One of the first meetings was held on 1998 Temryuk with the participation of representatives of authorities, local MPs, heads of enterprises in the region, representatives of technical services, nature-protection authorities, Committee for Protection of Historical and Cultural Heritage, mass media (“Taman’” newspaper, “Master” TV), and others. One of the recent hearings was held in Taman on February 10, 2003 (see Minutes in the Attachments).
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To establish contacts with the stakeholders and disclose information about the Project and the ToAz Corporation in general (including the environmental aspects of its activity), Togliattiazot organized in 1999 a visit of 25 representatives of Taman public to Togliatti, where the major facilities for ammonia production are based, and to the Yuzhny port in Ukraine, with a liquid ammonia terminal, largest in CIS. “Round table” discussions involving representatives of public were conducted after these visits in Temryuk, Taman, and Volna Settlements. The Togliattiazot staff members who took part in these discussions used this opportunity to take a closer look at the position of Taman public and its anxieties and criticism related to the implementation of the AMT Project. One more visit to Togliatti was organized in July 2001 for representatives of power structures, NGOs, and local population.).
Consultations with the public at local and district levels were also conducted in the form of public hearings (held in Taman’ Stanitsa and Volna Settlement); and public discussions with participation of district authorities, ecologists, and various experts. For instance, in the “round table” discussions and public hearings carried out in Temryuk District in late March - early April, 2001, side by side with corporation managers and local authorities local environmentalists - M. Osicheva, the President of the Black Sea Regional Social and Economic Center; V. Ponomareva, Coordinator of the Social and Environmental Union; A. Rudomakha, representative of the Independent Ecological Service for the Western Caucasus; V. Drozdov, Deputy Ataman of Taman’ division for Ecology - were participating, as well as bunch of local experts - V. Kirillov, Director of “Krasnodarberegozashchita” (Shore Protecting Institute); A. Nikitenko, Head of “Kuban’rybvod” (Agency responsible for the protection of fishery); N. Esin, Director of the Southern Division of the Institute of Oceanology, Russian Academy of Sciences, and others (see “Vol’naya Kuban’”, April 4, 2001).
Special meetings were organized individually with “groups of influence” – Cossacks, NGOs, organized groups of local residents, mass media. For example, a meeting with representatives of Cossacks of Taman okrug, Temryuk district, and Anapa okrug was held on July 7, 2002, where the corporation was represented by S.P. Matyunin, Vice-President, S.N. Titiov, Head of External Relations Department, and A.I. Ponomarev, Head of the Public Relations Service; on September 8, 2002 a meeting of S. Matyunin, Vice-President of Tol'yattiazot, with representatives of the Social-Environmental Union of the Western Caucasus (A.Rudomakha, Co-Chairman) and Independent Environmental Service for the Northern Caucasus (T.Lvova); as well M. Kryzhanovsky, representative of a group of local residents took place in ToAz office in Volna settlement; and on September 17, the same year, a "round table" was held in Volna Settlement for representatives of the federal, territorial, and district mass media (which included correspondents of "Tribuna," "Trud," "Kuban Segodnya," Versty," "Sel'skaya Zhizn'," "Pravda," "Parlamentskaya Gazeta," Kubanskie Novosti," "Krasnodarskie Izvestiya," "Taman'," "Chelovek Truda," "MPK Gazeta," newspapers and "TMT" TV company, "Kuban'" TV and radio broadcasting company, and "Krasnodar" TV and radio broadcasting company).
At these meetings, Togliattiazot representatives informed the participants about the progress in the project approval and measures taken to ensure the safety of the terminal facilities, answered questions of the participants, and demonstrated numerous documents relating to the project. As A.Rudomakha, representative of the Independent Ecological Service for the Western Caucasus noted, the meeting with NPO representatives was constructive and “broke the total confrontation of the independent environmentalists with Tol’yattiazot… Some disagreements were eliminated immediately in the course of the meeting.” (A. Rudomakha. “Independent Environmentalists and Tol’yattiazot: the Dialogue Begins” “Kavkaz,” September 11, 2002).
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In 2000 – 2001 two scientific seminars were organized in Taman and Temruk with a focus on environmental aspects of ammonium production and transportation in Russia and other countries. Technical experts from Krasnodar, Togliatti and Moscow participated in these seminars.
Consultations with the stakeholders at the higher, regional level, Togliattiazot were held mainly in a format of consultations with the Krasnodarsky Krai authorities (and subdivisions of federal supervision authorities in Krasnodar), as well as in a format of public discussions of the Project perspectives in the sub-regional mass media with active involvement of well known local experts.
Public discussions were organized by and Project related information was disseminated through the following local newspapers: “Vol’naya Kuban’,” which is published in Krasnodar and spread over the entire Territory; the circulation is 35 000
“Orbita,” which is published in Anapa and widely spread over the entire Krasnodar Territory; the circulation is 16 250
“Taman’ Vpered!” is published in district center Temryuk with a circulation of 40 000 and is spread free of charge
“Taman” is published in Temryuk with a circulation of 5 000.
“Kubanskie novosti”, daily newspaper (Krasnodar).
Agreement on information dissemination has been signed with local TV station (of Temryuk district) and an appropriate plan for coverage of the Corporation activity in the region and AMT Project implementation has been approved by both parties to the Agreement. Reporters from other channels popular in Kuban, such as “33rd Channel” from Novorossiisk, are also invited to cover panel discussions and public hearings.
Cooperation with local radio stations is not considered important for the Corporation, since according to the estimates of Togliattiazot personnel, responsible for public relations, only a handful of people listen radio in the territory, so its role is insignificant.
More than 20 publications in mass media have been devoted to the Project. In these publications:
The investor – ToAz – was introduced to the general public and told about its production activity and social programs being implemented in Temryuk district and other regions of Russia
The AMT Project was presented and its environmental, social, and economic effects were discussed
The progress in approvals and expert examinations was considered; the conclusion of experts regarding the project of an approach railroad was presented separately
Special attention was paid to the interpretation of the requirements of RF legislation to the involvement of public representatives to the discussion of projects. The right and procedure of establishing public expertise were explained.
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The major publications in newspapers and TV broadcasts are listed in the Attachments.
4.3 Major Comments, Concerns, and Recommendations Expressed by the Public
Analysis of materials of public consultations and publications in mass media allows to highlight the main issues associated with the AMT Project implementation that have become of greatest public concern.
The variety of concerns brought up by the interested parties during consultations can be grouped as follows:
1. Socio-economic consequences of the Project implementation for local population
2. Safety of the facility and railroad link operation (in terms of the population life and health hazards)
3. Possible damage to agriculture, first of all, to viticulture and fishery
4. Possible damage to the recreation potential of the region and tourism, an important branch of regional economy
5. Damage to the cultural and historical heritage of the territory
These critical issues are discussed in details below.
1. Socio-economic consequences of the Project implementation for local population
The question of what the region and its population will gain from the activity of Togliattiazot Corporation was repeatedly asked by a wide circle of interested parties mainly in the area where the terminal will be constructed. The population hopes are that additional working places will be created and the Corporation will contribute to the development of the social infrastructure in Temryuk district, Taman’ Stanitsa, and Volna Settlement, including the development of local transport, health care, education, gas supply, and the like.
2. Safety of the facility and railroad link operation (in terms of the population life and health hazards)
The issues of industrial safety of the facility and the approach railroad are of concern for a wide circle of stakeholders from authorities to local population. The arguments that the project has been thoroughly designed and that there were no accidents either at the plant in Togliatti or in the ammonia terminal in Yuzhnyi fail to convince some of the opponents of AMT construction in Volna Settlement. Their most common arguments are as follows:
It is impossible to exclude ammonium leaks during loading tankers not in a harbor but in the open sea two kilometers off-shore
Active geological processes are common in Taman, including possible earthquakes, volcanic activity, erosion and landslide processes
Unfavorable navigation conditions near the AMT facility (active currents; sediment transport, which causes migration of shallows and banks)
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Unfavorable weather and climate conditions (frequent strong winds, storms, fogs)
Risk of delivering large volumes of liquid ammonium by railroad passing through populated areas
Terrorism and diversion hazard because of the regional conflicts in the nearby Caucasus area.
The argument that Taman’ Peninsula is the area of higher geological hazard was presented by the interested parties at different levels, in particular, it was mentioned in federal mass media, such as Literaturnaya Gazeta, Novaya Gazeta, Nash Sovremennik, it can also be frequently met on environmental sites in the Internet.
The advocates of these approaches suggest that AMT should be either constructed on the shore in some closed bay or the project should be declined.
4. Potential damage to local agriculture.
Discussions of the possible adverse impact of the project on Taman’s agriculture are commonly narrowed to the damage to wine-making in the area (without any serious arguments) and to fishery. In the latter case, the opponents mention the disturbance of fish migration near the facility, withdrawal of the areas used for fishing by fishermen of Khvalyun cooperative, and the fact that the facility construction will impede the development of marine culture along the coast between Panageya Cape and Zheleznyi Cape.
Recommendations of stakeholders for mitigating the adverse effect are focused mostly on the development of additional compensational measures.
5. Potential damage to recreation and tourism.
Potential damage to the recreation potential of the region and tourism, an important branch of economy of the region is also widely discussed by the interested parties at different levels. The major concern of Temryuk District inhabitant is whether the construction of AMT can scare away health-resort visitors who allow the local population to earn money, whereas the representatives of environmental organizations and territorial authorities raise the issue that the interference in the coastal zone may have unpredictable consequences. In their opinion, the construction of AMT may disturb the transport of geological material with the result that the Tuzlinskaya scour will notably increase, Bugazskaya Spit will disappear, Kiziltashskii Firth will become a sea bay, and the Anapa beaches will suffer from sand deficiency and gradually disappear.
As an alternative to the facility construction, the opponents of AMT suggest attraction of investments for the development of resort and tourist potential of Taman.
6. Impact on historical heritage.
Comments on the adverse impact of the Project on the places of cultural and historic importance are a common argument adduced by the opponents of the Project as a factor that impedes the implementation of AMT Project in Taman. This argument is used by many activists of environmental movements and some Russian cultural authorities. However, experts–archeologists from the archeological expeditions of the Institute of Archeology, Russian Academy of Sciences, Pushkin Museum of Fine Arts (Moscow), the State Hermitage
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(St. Petersburg), who have conducted archeological dig in Taman’ for many years, as well as the management of Taman’ Archeological Museum have never opposed the facility construction at Volna Settlement, arguing that the land area allotted for facility construction near Volna Settlement have been always peripheral with respect to the populated locations that existed in the area.
At the same time, the Territorial Committee for Protection, Restoration, and Use of Historical and Cultural Values (Heritage) controls the organization and implementation of construction operations at the AMT facilities and approves the allotment of land only provided the necessary archeological studies have been made and measures for protection of the objects of historical and cultural values are provided in the plans for actions in emergencies.
4.4 Consideration of the Concerns and Critical Comments from the Stakeholders during the Development of Design and Preliminary Stage of Construction
The management of Togliattiazot and of the AMT Project takes into due consideration stakeholder’s critical comments, made during the public hearings.
4.4.1 Social Development Issues.
Considering the importance attached by the local interested parties to the social development issues and responding to their requests, Togliattiazot Corporation made steps for the development of the social infrastructure and improvement of the social situation in Temryuk District. First, the corporation decided to preferably employ (at the stages of design development and construction preparation) the residents of Temryuk District. As a the result of this policy residents of 12 nearby populated localities are now involved in construction activity. Some local employees have received aid in the form of means for housing; the corporation paid for the higher education of some employees; some other employees were supported in occupational training and passed probation at the corporation facilities located beyond Krasnodar krai.
ToAz Corporation acquired and passed to the local administration 8 “Ikarus” buses in order to replenish the transport fleet of Temryuk; constructed a retrodirective antenna to provide the residents of the western part of Taman’ Peninsula with stable TV broadcast, thus enabling them to watch previously inaccessible federal TV channels; financed the repair of the hospital in Taman’ village, reconstruction and equipment of a school, kindergarten, a club-house in Volna Settlement, and so on.
ToAz Corporation also gave support to the administration and population during emergencies, such as a flood in 2002, when transport, building materials, electrical equipment, clothes, footwear, and workers for eliminating the consequences of the disaster were sent to the affected areas.
By and large, the investments of ToAz Corporation to the social and economic development of Temryuk District for the period up to April 2001 totaled about 30 million rubbles (circa $ 1 million).
4.4.2 Safety of the Facility and the Approach Railroad.
In response to the critical comments about the high potential risk of the project, Togliattiazot Corporation:
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considers the unfavorable natural factors when selecting the engineering design solutions;
engages necessary experts in the development of design solutions and disclosure of information about the project;
elucidates its approaches to the safety issues and explains the efficiency of adopted design solutions to a wide circle of interested parties.
The process engineering solutions were developed with allowance made for the Russian safety guidelines and regulations currently in force. The criticism and proposals of the Commission of experts that conducted examination of “Substantiation of Investments in the Construction of Ammonium Terminal in Temryuk District, Krasnodar Krai” were taken into account at the next phases of design.
The AMT design was developed with the allowance made for the 9-point seismic scale and the complex geological conditions of the proposed construction site. Shore protection works are planned in accordance with recommendations of Interdepartmental Commission. The necessary fire safety measures are taken, cathodic electric protection of the structures was ensured. International experience in designing facilities of this type was used in the design.
As a reaction to stakeholders concerns, additional measures should be taken to improve the safety of traffic on the approach railroad (for example, construction of its crossings with motor roads, creation of sanitary protection zones in populated localities). Additional measures are also planned to ensure navigation safety within the operational water area of the port and the approach fairway (because of the unfavorable natural and climatic conditions), which is scheduled to implement before the construction is started.
Additional measures will be taken by ToAz to further disclosure the information about the efficiency of the suggested engineering solutions. ToAz is planning to carry out in June – October 2003 an additional evaluation of industrial risks and safety of design and equipment to be supplied (with participation of Russian and international experts) and to disclose the conclusions to the stakeholders.
4.4.3 Measures for Preventing or Minimizing the Damage to Agricultural Production.
Measures in this area are aimed primarily at minimizing the adverse effect of project implementation on the local economics, mainly, viticulture and fishery. The corporation has focused its efforts on the rational approach to the withdrawal of agricultural lands and areas used for fishery, as well as to the development of efficient compensation mechanisms and their coordination with the affected parties.
Viticulture
The agricultural enterprises in the area of project implementation are engaged mainly in vine growing and processing. The effective functioning of this branch is the focus of particular attention of stakeholders not only at the district level, but also at the higher levels of the region and Krai.
Considering the anxiety and criticism of the stakeholders, ToAz Corporation has established constructive interaction with the regional authorities and the agricultural enterprises of the western Taman’.
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Land withdrawal and allocation for the needs of AMT and approach railroad was made with the consideration of the fertility and the current use of the land. The lands allotted for construction were mainly inconvenient for use, low-fertility, salinitized, and the like. In the cases where fertile lands were withdrawn, lands with similar quality from the district reserve were allotted and pecuniary compensation was made (covered in part by the supply of fertilizers, pesticides, motor fuel and oil). Thus, the compensations for land use for railroad construction amounted to about 35 million rubles (circa $1.5 million). This sum was covered by diesel fuel, mineral fertilizers, plant protection means, gasoline, and the like).
Fishery
To prevent the adverse impact on fishery, ToAz Corporation has chosen the engineering solution that minimized the impact on fish migration along the Taman’ coast, i.e., the construction of a pile jetty with long spans (24 m). In terms of fishery, the construction of a sea wall is similar to the construction of an artificial reef, which creates conditions for spawning of some fish species and results in the formation of additional food reserves.
Withdrawal of a part of water areas from the use for fishing (in the port protection zone) should be compensated to the Khvalyun cooperative, which fishes in this area, in accordance with calculations made by experts from the authorized institute and approved by the supervision authority (Kuban’rybvod). In addition, ToAz is currently negotiating with local fishery cooperative a supply of modern fishery boats.
4.4.4 Consideration of the Criticism Regarding the Damage to Recreational Potential.
The possible damage to the recreational potential and tourism is the focus of attention of the stakeholders at different levels. This issue is widely discussed at public hearings, in local papers, in statements of territorial leaders, in appearances of project opponents at the federal level. This issue is of particular attention because of the intention of the Krasnodar Krai Administration to make tourism and recreation a leading branch of local economy.
The project managers work for taking these concerns into account when developing the design solutions and disseminating information about the project.
The steps having been made so far by the Corporation in this direction were reduced to the engagement of authority experts for proving to the public in direct contacts and through mass media that the terminal is environmentally safe and the ammonia terminal operation can blend together with regional development.
In addition to that, the corporation plans to take measures at the local level for the development of the social and cultural infrastructure, protection of the coast, and creation of organized beaches, which should increase the recreation appeal of the coast.
At the same time, the issue of the after-effects of the project implementation, in particular, coast protection in the Anapa beaches and the Anapa resort as a whole are still poorly known. The development of substantiation and the preparation of measures for minimizing the adverse impact of the project implementation on the recreation and tourism remain among the priority issues of ToAz activity. The Company realizes the importance of this issue and plans to consider it before starting the large-scale construction at the site.
4.4.5 The Cultural and Historical Heritage.
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As for now, the Project management has established working interaction with the Territorial Committee for Protection, Restoration, and Use of Historical and Cultural Values (Heritage). The Corporation and Committee have signed "The Agreement on Comprehensive Archeological Survey of the Burial Mound of the Antique Age and Destroyed Parts of Settlements of the Antique and Medieval Ages" (no. 15/2001, dated October 1, 2001). Togliattiazot has also prepared an order regulating the interaction with the Committee during construction works at the transfer complex site foreseeing actions to be taked in case of any accidential discoveries.
The company financed the necessary archeological surveys in the area intended for economic development. The order of implementation of design, survey, and construction works was determined in accordance with the recommendation of the Committee. The Committee approves the land allocation for the Project only provided that the necessary archeological surveys have been performed. In pursuance of recommendations of the Committee and for the sake of preservation of the cultural and historical heritage of the Russian Federation, ToAz envisages at the stage of construction:
Completion of rescue archeological digs in the construction area;
Organization and implementation of monitoring of archeological sites in the zone of influence of the facility;
Obligatory participation of an archeologist (with an open list for implementation of prospecting) as an inspector (authorized representative of the office for protection of cultural heritage) in any excavation work;
Extraordinary organization of protection (rescue) digging once archeological objects are found;
Reclamation of the surface of the areas of historical value, disturbed during construction works, in order to prevent the development of exogenous processes.
In the period of operation, the Company will ensure:
Organization and implementation of monitoring of archeological sites in the zone of influence of the facility;
Conditions for the organization and implementation of regular archeological digs in the zone of influence of the facility;
Immediate organization of protective (rescue) archeological digs and other rescue operations in the case of emergency at the facility that may cause damage to the cultural heritage articles;
Assistance in studying the cultural heritage in the zone of influence of the facility and support of its protection, including establishment of museums.
The efforts of ToAz in this direction will receive a wider coverage in order to facilitate the approval of project at different levels and its implementation.
The major stakeholders’ concerns expressed in the course of public consultations and the measures taken by ToAz as a response are summarized in the table below:
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The area of concern of the stakeholders
Response of ToAz Corporation Priority measures to be taken
Social and economic effects of the project implementation for the residents
Agreement for cooperation with the district authorities has been signed Temryuk District residents have a priority as employees Allocation of means for local employees for housing Establishment and support of the occupational training of local employees Support of the transport fleet development in Temryuk Construction of a retransmitter antenna to provide the residents of the western part of Taman’ Peninsula with stable TV broadcast Aid in the repair and equipment of social facilities (hospital in Taman’ Stanitsa, school, kindergarten, club-house in Volna Settlement) On request of Taman’ Rural District Administration, ToAz rendered assistance in delivering 240 tons coal from Temryuk for the persons who have privileges Rendering help during natural disasters By and large, the investments of ToAz Corporation to the social and economic development of Temryuk District for the period up to April 2001 totaled about 30 million rubbles ($ 1 million).
Preparation and publication of the plan and budget of measures Keeping the interested parties informed about the results of plan implementation
Safety of the facility and the approach railroad (in terms of life and health hazard for population)
The design solutions are chosen with allowance made for the unfavorable natural factors (9-point seismic hazard and the complex geological conditions) Experts are engaged as required Shore protection operations are planned. Togliattiazot elucidates its approaches to the safety problems and proofs the efficiency of the accepted design solutions to the wide circle of interested parties.
According to the criticism of interested parties, additional measures are to be taken at this stage for improving the safety of traffic on the approach railroad (for example, construction of its crossings with motor roads, creation of sanitary protection zones in populated localities) Additional measures should be taken to ensure navigation safety within the operational water area of the port and the approach fairway Additional measures are planned for further dissemination of the information about the efficiency of the used engineering solutions (at all levels of interaction with the interested parties); the evaluation of technological risks and design safety will be carry out in June-October 2003.
Possible damage to agriculture, primarily to viticulture and fishery
The Corporation uses a rational approach to the withdrawal of agricultural lands and areas used for fishery Compensation mechanisms have been developed; their coordination with the interested parties is in progress Compensation for the use of lands of railroad construction amounted to about 35 million rubles During field works, when fuel and lubricants are commonly in short supply in agricultural regions, ToAz provided a considerable amount of fuel for the agricultural enterprises in the region To prevent the adverse impact on fishery in the district, ToAz Corporation has chosen the engineering solution that minimized the impact on fish migration along the Taman’ coast The construction of a sea wall will create conditions for spawning of some fish species and result in the formation of additional food reserves
ToAz is currently negotiating compensational measures with local fishery cooperative including purchase of modern boats. Keeping the interested parties informed about the activity in this field
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The possible damage to the recreational potential and tourism – an important economic branch in the region
Engagement of experts of authority in the territory for proving to the public that the terminal is environmentally safe and the facility operation can be combined with the development of tourism Corporation plans to take measures at the local level for the development of the social and cultural infrastructure, protection of the coast, and creation of organized beaches, which should increase the recreation appeal of the coast
The issue of the after-effects of the project implementation, in particular, coast protection to the Anapa beaches and the Anapa resort as a whole is planned to be investigated The development of substantiation and the preparation of measures for minimizing the adverse impact of the project implementation on the recreation and tourism are still among the priority directions of Togliattiazot activity aimed at the interaction with interested parties and dissemination of information about the project.
Damage to the cultural and historical heritage of the territory
Working interaction have been established with the Territorial Committee for Protection, Restoration, and Use of Historical and Cultural Values (Heritage). The Committee approves the allotment of land for the project only provided that the necessary archeological surveys have been performed.
The efforts of Togliattiazot in this direction will receive a wider coverage in order to facilitate the approval of project at different levels and its implementation.
5.0 Public Consultations on TEOC Environmental Protection Section (EIA)
5.1 Disclosure of Information about the Project
In accordance with the international requirements, public consultations should be conducted at the stage when a draft of the environmental impact assessment document (EIA) is available.
The appropriate stage of public consultations should start in the course of Russian TEOC EIA materials examination by the State Environmental Expert Commission (since June 2003).
The disclosure of information is based on the requirements of the RF legislation regarding the involvement of the public in the discussion of environmentally significant projects, as well as on the relevant documents of the, IFC, and EBRD.
EIA materials (including EIA executive summary and PCDP - both in Russian) and a brief description of the project (without technical details, also in Russian) will be made available in
Krasnodar Krai Administration
Municipal Administration of Temryuk District
Administration of Taman’ Agricultural District
Club-house in Volna Settlement
Additionally, a brief description of the Project, its possible effect, and measures for prevention and/or mitigation of its adverse consequences in Russian and in English should be placed on the web-sites of IFC, EBRD, and ToAz Corporation at least 60 days prior to the adoption of decision on the project financing. This time will be used for the collection and collation of critical remarks made by a wide groups of stakeholders.
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The Company also plans to present EIA materials and the conclusions of the State Expert Commission in local, district, and territorial mass media and conduct a series of public hearings (in Krasnodar, Temryuk, and Taman’) in order to provide access to the discussion of the Project for the widest possible circles of the interested parties. EIA materials with commentaries of experts recognized in Kuban’ will be published in “Vol’naya Kuban’”, “Orbita”, “Taman’ – Vpered!” newspapers and on local TV of Temryuk District. Public hearings with the participation of experts and the major stakeholders are planned to conduct in Temryuk and Taman two weeks after the reception of the conclusion of state environmental expertise, and in Krasnodar, three weeks after its reception.
5.2 Consultations with the Public
The objectives of public consultations at this stage are to inform the stakeholders about the potential environmental impacts and proposed measures for the prevention and mitigation of the adverse consequences of the project implementation, collecting and generalizing the critical remarks and their implementation in the project development.
The types of consultations planned to use to implement these tasks are as follows:
Meetings, hearings, and seminars (including systematic interaction with the representatives of authorities, public meetings, public hearings, special seminars) aimed both at wide public circles and groups of interested parties.
Discussions in mass media
The preferential use of different types of consultations in the interaction with the stakeholders at different levels is shown in the following table:
Meetings, hearings, seminars
Discussions in mass media
Information centers and exhibitions
Information materials
Authorities X Krai level (June-July)
X Information package
Population in the project area of impact
X Local and district level (June)
X Krai level (June – July)
X Local level (June – July)
Groups of influence, including:
Nongovernmental organizations
X All levels (June – July)
X All levels (June – July)
X All levels (June – July)
X Information package
Business structures X Local and district level (May-June)
Research organizations X Territorial level (June-July)
X Information package
Mass media X All levels (June – July)
X Information package Press-releases
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Parties to the Trans-boundary Effects
To clarify procedures with the Russian Ministry of Natural Resources (June)
The consultations should be based on the conclusions of EIA sections with maximum possible involvement of recognized experts in order to avoid possible accusations of the project poor quality and to make the problem discussions constructive and meaningful. During the meetings, hearings, and seminars, the Company is planning to use mobile information centers and exhibitions, and disseminate information packages. The information package includes:
The decision of the State Environmental Expert Commission
Brief information about the project and its impacts on environment and historical heritage
Information about the company response to the stakeholders’ concerns.
When a confrontation appears in the course of public consultations, the assessment of the actual significance of the raised problems for the project development may require additional interviews with the key persons and groups and/or public opinion polls.
5.3 Schedule
The preparation of actions intended for the presentation of conclusions of the State Environmental Expert Commission to the parties that may be affected by the project implementation will begin in June 2003.
Target audience
Action Implementation date
Krasnodar Krai Committee for Protection of Cultural Heritage, wide public
Approval by the Board of Directors of the ToAz Policy on Protection of Cultural and Historical Heritage
June
Wide public Approval by the Board of Directors of Addenda to the AMT Project’s Plan of Public Consultations and Information Disclosure
June
The parties of potential transboundary impact
Putting an application to the RF Ministry of Natural Resources (official authorized body) for official elucidation of the applicability of the regulations in the Convention on EIA in the transboundary context to AMT Project (in accordance with the World Bank Directive on International Water Ways and the requirement of EBRD on the observance of Espoo Convention)
June
Krasnodar Krai authorities, including the Committee for Natural Resources and
Preliminary consultations for the preparation of public hearings
June
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Environmental Safety of the Krasnodar Krai Legislative Assembly; Committee for Health Resorts and Tourism of Territorial Administration; Division of Infrastructure Development in the Azov and Black Sea Coast, Department of Complex Development of the Azov and Black Sea Coast, Territorial Administration, and others. Supervision authorities of RF in Krasnodar Krai, including Department of Ministry of Natural Resources for Krasndar Krai; Department of Environmental Expertise for Krasnodar Krai and so on.
Preliminary consultations for the preparation of public hearings
June
Research institutions Concluding agreements on additional studies of possible consequences of the project implementation, including modeling the impact on Anapa beaches; assessment of the project safety
June
Representatives of the territorial scientific community, including Eletsky B.D, Deputy Director of the Department of Education and Science; Seredin A.M., Director of “Kuban’giprozem” Institute; Peshkov V.M., Professor in “Kubanvodproekt” Institute; and others.
Preliminary consultations, presentation of materials on environmental impact assessment
June
Mass media Presentation of materials on environmental impact assessment, cooperation agreements
June
More active consultations with the public and public hearings are planned for June-July 2003:
Target audience Action Participants Implementation date Public in the project implementation site
Discussion in mass media
Local population, NGOs, administration officials, experts
June - July
Information center Local population, NGOs July Public hearings Local population,
NGOs, administration officials, experts
July
Temryuk District public, including NGOs
Discussion in mass media
Local population, NGOs, administration officials, experts
July
Information center Local population, NGOs July Public hearings Local population,
NGOs, administration officials, experts
July
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Presentation of materials in the Internet
Public, experts June
Krasnodar Krai public, including NGOs
Discussion in mass media
Local population, NGOs, administration officials, experts
June–July
Information center and exhibition
Local population, NGOs, experts
July
Public hearings July Presentation of
materials in the Internet Public, experts June
International public, including Civil Society Institutions
Presentation of materials in the Internet
Public, experts June
Business structures Consultations Experts, administration officials
June
Public hearings Local public, NGOs, administration officials, experts
July
Research organizations Consultations Experts, administration officials
June
Holding a symposium in Krasnodar Krai (in the project implementation site) with the involvement of experts recognized in Krasnodar Krai
Experts, administration officials
June
Holding a panel discussion in Krasnodar with the involvement of experts, representatives of power structures, NGOs
Experts, administration officials, NGOs
June
Power structures Holding work consultations and coordination
Experts June
Participation in a panel discussion with scientific experts
Experts, administration officials, NGOs
June
Mass media Providing information materials and press-releases, invitation to other actions included in this schedule
Experts, administration representatives, NGOs
Starting from June 15
5.4 Collection, Consideration, and Generalization of Concerns
Special efforts of the project managers are focused on the organization of collection and analysis of stakeholders’ concerns in order to
Determine and record all major questions raised in the discussion
Make a proper analysis of these questions
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Discuss and coordinate the measures aimed at the prevention and mitigation of possible adverse consequences of the project implementation.
The responsibility for this activity rests upon the Public Relations Service of the Project (the responsible person is A.I. Ponomarev, Head of the Service, Volna settlement, Temryuk district, Krasnodar Krai; phone/fax 8 (901) 491-1715; 8 (861) 485-8141).
The Service keeps records of the critical remarks, coordinates the work for their analysis, and controls the response to the criticism. For this purpose the Service representatives:
Monitor publications in press
Collect critical remarks sent through the Internet
Keep records of critical remarks sent to the Company in writing (applications, statements, letters)
Take part in consultations with the public and keep minutes.
All concerns are recorded in a numbered Record Log (started in November 2001). Each critical remark is assigned an account number. The record contains the date of reception, the author (with the name, affiliation, and post), the essence of the remark, the person responsible for the analysis and response, and the steps taken. For processing the remarks, an account card with a number and contents similar to that in the Record Log will be made for each remark. If necessary, the card is passed to the appropriate divisions of the Company for its treatment, after which the card is returned to the Public Relations Service and the new records having been made on the card is reflected in the Record Log.
The Public Relations Service prepares a weekly summary list of received critical remarks, which will be rendered to the Project Managers.
Project Managers control the treatment and response to the critical remarks received.
After the necessary analysis (upon the completion of the period assigned for the public discussion of the Project), the EP materials will be properly amended; in the case of significant drawbacks, the LAT Project will be amended to eliminate them.
Information about the consideration of the critical remarks of interested parties will be supplemented as an appendix to the Plan of Public Relations and Dissemination of Information about the Project and to the amended version of EP materials.
Records should be made of all the critical remarks advanced in the course of public consultations (in the minutes of public hearings) and received by the project managers in writing, including those received through the Internet, within the 60-day period assigned for public discussion of EP materials (appeals, statements, letters).
A detailed scheme of organizing the collection and consideration of critical remarks, as well as the forms of reports will be developed in cooperation with the representatives of Togliattiazot Corporation in the course of reconsideration of the Public Relations Plan.
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After the necessary analysis (upon the completion of the period assigned for the public discussion of the Project), the EP materials will be properly amended; in the case of significant drawbacks, the LAT Project will be amended to eliminate them.
Information about the consideration of the critical remarks of interested parties will be supplemented as an appendix to the Plan of Public Relations and Dissemination of Information about the Project and to the amended version of EP materials.
5.5. Resources and the Responsible Persons
In the period when consultations with the public on the results of EIA consideration are in progress, the Public Relations Service is based in Volna settlement, Krasnodar Krai, it is subordinated to the Project Manager in the person A.Vinogradov and its activities are coordinated by S.Titov, responsible for public relations of “Togliattiazot”.
The Service incorporates:
Head of the Service responsible for the general direction of its activity, the organization of record of arriving critical remarks, preparation of summary lists, monitoring, and coordination of activity with the Project Managers
Service Engineer responsible for collection of critical remarks, control of the circulation of critical remarks within the Service, collection and registration of decisions regarding the critical remarks.
6.0 Consultations during the Construction, Operation, and Termination of Operation
6.1 Interaction with the Stakeholders during the Construction
Consultations with the interested parties and dissemination of information in the period of construction are complicated by the involvement in the project of subcontract organizations with their organizational structures and zones of responsibility. Therefore, in this period, the responsibility for public relations and dissemination of information should be clearly distributed between the Customer – Project Managers, and the subcontract organizations. This goal can be achieved through the acceptance of a special document – the Program for Interaction with Interested Parties at the Phase of Construction.
6.2 Tasks of the Program and the Allocation of Responsibility
The tasks of this Program take into account:
Keeping the interested parties informed about the course of Project implementation and its consequences for the environment and the social medium
Notifying the Project managers and subcontractors about the problems that can affect the Project implementation
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Monitor the efficiency of measures aimed at the prevention/mitigation of adverse consequences
Efficient treatment of complaints and critical remarks of interested parties.
The responsibility for the Program development rests upon the Project managers; the responsibility for its implementation (including the allocation of necessary resources) is distributed between the Project and subcontract organizations.
6.3 Responsibilities of Togliattiazot
Measures aimed at the implementation of design solutions that may affect the Project as a whole, as well as steps for the fulfillment of obligations in social programs (including the organization of occupational training) are the responsibility of the Project managers.
The Project managers prepare the Program of Interaction with the Interested Parties, ensure the inclusion of the relevant obligations in the contracts with subcontract construction organizations, coordinate the activity in this field, and control the subcontractors fulfilling their functions in public relations.
The Project managers assist the subcontract organizations in the development of their programs for public consultations and implement the necessary monitoring and control of their fulfillment.
Togliattiazot uses the Public Relations Service to control this activity. The Service, provided with the necessary resources, is headed by a public relations manager and incorporates a public relations engineer, and a secretary.
6.4 Responsibilities of Subcontractors
Subcontractors are obliged to supplement their contract responsibilities by measures for interaction with the public, including the following:
• Development of plans of interaction with interested parties in the course of preparation and implementation of construction works, transport of freights for the construction, and so on.
• Allocation and training of personnel responsible for this activity
• Organizing the necessary training for the personnel of subcontractors.
All subcontract organizations are obliged to keep record of the received complaints and pass a copy of each complaint to the ToAz Manager for Public Relations within two weeks after the complaint reception. Notes will be made on the copy to indicate the measures taken and the person responsible, and a copy of response to the author will be attached. The originals of these documents will be kept in the subcontract organization until the completion of construction, after which they will be passed to the LAT administration for storing in archive for five years.
6.5 The Resources and Elements of the Organizational Structure Required for the Interaction with the Interested Parties during Construction
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During the construction period, Public Relations Service will be used at the construction site. This Service is directly subordinate to the Construction Manager. It shall inform the Committee of Directors, in accordance with the established order (no less than twice a month), about the situation in the interaction with stakeholders.
At the construction stage, the Service incorporates three employees:
• Public Relations Manager is responsible for the interaction between the Project and third parties; he coordinates and controls the treatment of complaints received during Project implementation.
• Public Relations Engineer works in close cooperation with the Public Relations Manager and is responsible, primarily, for the record of arriving complaints and for the responsible persons in the Company and subcontractors responding to these complaints. Public Relations Engineer prepares weekly summary lists of received complaints, which are sent to the Project Manager and to the relevant subcontractors.
• Secretary records and archives the materials relating to the receipt and treatment of complaints in the Company.
The Construction Manager monitors the activity of the Service and the treatment of arriving critical remarks.
6.6 Relations with the Interested Parties during Operation
The tasks of public relations at this stage are
• To maintain constructive relations with local population; agricultural producers; persons working in science, art, etc.; representatives of local authorities for effective functioning of the facility
• To ensure continuing dissemination of information related to the safety of the facility
• To implement monitoring of the environmental and social situation in the area of the facility functioning and inform the managers of Togliattiazot about such situations and the measures taken.
6.7 The Resources and Elements of the Organizational Structure Required for the Interaction with the Interested Parties during Operation
During the operations stage, the Public Relations Service will be operating at Volna settlement. This Service will be directly subordinate to the AMT Manager and will inform him/her about the relations with and concerns of stakeholders (in accordance with the established order but no less than twice a month).
At the operations stage, the Service consists of two employees:
• Public Relations Manager is responsible for the interaction between the Project and third parties; he/she coordinates and controls the treatment of complaints received.
30
• Secretary records and archives the materials relating to the receipt and treatment of complaints in the Company.
The AMT CEO monitors the activity of the Service and the treatment of arriving critical remarks.
6.8 Interaction with the Interested Parties in the Period of Termination of Operation
In the case of termination of AMT operation, the issues of public relations will be a focus of attention of the project managers; the decision about the termination, the procedure, and the possible effects will be discussed with the interested parties; the necessary measures for the prevention or minimization of the possible adverse impact of the termination on the environment and social medium will be taken.
7.0 The Grievance Mechanism
The aim of creating such a mechanism is the registration and adequate response to the complaints of interested parties, including local residents, affected by the Project implementation.
The responsibility for this work rests upon a special service for the interaction with the public, the office of which is located in the administrative center in Volna settlement. The responsible manager of this service coordinates and controls the treatment of complaints of the interested parties.
7.1 Procedure of Grievance Consideration
All complaints received by the Project managers, including the complaints received by the environmental protection department, the department of labor protection and accident prevention, and others, are passed to the Public Relations Service (supplemented by commentaries and resolutions of the relevant departments).
This Service (headed by A.I. Ponomarev, Service Engineer is V.P. Ponomareva) is situated in Volna settlement, Temryuk district, Krasnodar Territory; phone/fax (861) 485-8141.
Service Engineer assigns the complaint a sequence number and makes the necessary record in the complaint log. The log record format is to be discussed with Tol’yattiazot Corporation; however, the following items can be recommended:
• Date received
• Incoming number
• Information about complainant (Name, address)
• Complaint subject
• Response of the company (when the complaint is valid)
31
• The department and person responsible for the verification and implementation as may be required
• Outgoing number and answer date.
7.2 Response to Complaints
Public Relations Manager controls and coordinates the work with complaints, prepares answers with engaging employees from other departments as may be required.
All complaints received from interested parties should be answered in writing within two weeks, which does not exclude oral answers and commentaries as may be required.
7.3 Monitoring
Reports about the work with received complaints are regularly sent to the Project management (no less than once a month), including the subject of the complaint, its validity and the importance of the issue, measures taken.
If necessary, the most acute and important issues are immediately reported to the project management.
7.4 Archiving
All documents relating to the work with complaints of interested parties are to be stored in the office of Public Relations Service for one year, after which they are to be passed to archive for long-term storage (up to 10 years).
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ATTACHMENTS
33
Attachment 1
List of Stakeholders
Stakeholder Reasons for involvement in Project
Comments
Krasnodar Krai Authorities Mr. V. Tkachev – Head of the Krasnodar Krai Administration
Mr. V. Tkachev is at the head of the Krasnodar Krai Executive Authorities
Krasnodar Krai Main Department of Natural Resources and Environmental Protection of the RF Ministry of Natural Resources (KMD MNR) Mr. Sergei Velichko – Head of KMD MNR Mr. Leonid Yarmak – Deputy Head of KMD MNR
Responsible for environmental protection activity. The Project should be approved of by this Agency.
State Environmental Review Department of KMD MNR Ms. Svetlana Burakova – Head
Ms. S. Burakova is in charge of the environmental review.
Azov-Kuban Supervisory Inspection Department of KMD MNR Mr. Konstantin Larionov – Head
Mr. Larionov supervises environmental protection activity.
Krasnodar Krai Department of Natural Resources, Environmental Protection and Water Management
This Department is the Krasnodar Krai Executive Authorities’ Agency authorized to coordinate activities of all other agencies in the field of i) environmental protection; ii) protection, reproduction and use of biological resources; iii) protection, reproduction and use of mineral resources; and iv) water resources management.
Krasnodar Krai Centre of the State Sanitary & Epidemiologic Surveillance
The Project design documentation should be approved of by this Agency.
Krasnodar Krai State Fire Fighting Service
The Project design documentation should be approved of by this Agency.
Krasnodar Krai Committee for Historical & Cultural Values (Heritage) Conservation, Restoration and Management
The Project design documentation should be approved of by this Agency.
Federal State Institution “The Krasnodar Territorial Fund of Geological Data”
The Project design documentation should be approved of by this institution in the process of land plot allocation.
Krasnodar Krai Committee for Land Resources and Land Management
The Project design documentation should be approved of by this Committee
34
Stakeholder Reasons for involvement in Project
Comments
Mr. Valery Nelyubov, First Deputy Head of the Committee
in the process of land plot allocation.
Kuban Basin Water Management Department Mr. Vasily Get’manov – Head
The Project design documentation should be approved of by this Department in the process of land plot allocation.
Krasnodar Krai Department of Architecture and Construction Operations
The Department exercises control over construction operations activity and is one of the key agencies issuing required approvals.
As applied to the present Project, this Department is responsible for the following issues: - approval of design
documentation relevant to construction of facilities affecting coastal zone conditions;
- approval of draft resolutions of the Head of the Krasnodar Krai Administration as to land allocation;
- coordination of liaison among investors, clients, contractors, design documentation developers, construction materials/equipment suppliers, who are involved in implementation of investment programs;
- development and implementation of programs on multipurpose use and protection of coastal zones, development of engineering infrastructure of coastal zones beyond the bounds of residential areas;
- architectural control/construction operations supervision; methodological organizing management and coordination of activities carried out by Gosarkhstroinadzor bodies on the Krasnodar Krai territory;
- issuing of permits for carrying out of construction-and-assembling operations at
35
Stakeholder Reasons for involvement in Project
Comments
construction sites of particular importance (comment – None of the legislative documents explains the notion of “construction sites of particular importance);
- inspections of facilities under construction as well as of companies and enterprises engaged in construction operations, without regard to their departmental subordination and property forms;
- suspension of construction operations if major violation of regulations are revealed.
Department of Comprehensive Development of the Azov – Black Seas Coastal Zone (Krasnodar Krai)
The Department is authorized to approve of pre-design and design documentation for construction/upgrading of facilities affecting the natural environment in coastal zones of the Sea of Azov and the Black Sea.
Krasnodar Krai Department of Health Resorts and Tourist Industry
The Project design documentation should be approved of by this Department.
Krasnodar Krai Committee for Emergency Situations and Water Resources Management
The Project design documentation should be approved of by this Department.
Inter-Departmental Commission on Arrangement of Productive Forces on the Krasnodar Krai Territory
The Commission is authorized to consider issues concerning location of new facilities or expanding/upgrading of operational facilities. In particular, the Commissions takes decisions whether to approve or not to approve of a project on locations of industrial facilities or social infrastructural facilities in the Kranodar Krai. The Commission considers pre-design/design documentation elaborated by individuals or legal entities to assess the expedience of location of a facility, its impact on both the environment and demography, and other aspects of regional
36
Stakeholder Reasons for involvement in Project
Comments
activity. Inter-Departmental Commission on Seismic Safe Construction Operations and Thermal Protection of Buildings/Facilities
The Commissions is an advisory organ responsible for preparation of decisions to be made by the Department. The Commission also participates in the approval process relating to measures on provision of the required seismic safety and thermal protection of buildings/facilities under construction.
Central Inspection of the Krasnodar Krai State Architectural/Construction Supervision under the Krasnodar Krai Administration Department of Architecture and Construction Operations
The Inspection is responsible for issuing the following permits for carrying out of construction & installation operations: - permit for carrying out of
the whole scope of construction & installation operations;
- permit for carrying out of specific kinds of construction & installation operations, such as site engineering preparation, soil excavation for foundations, laying of service lines, construction of foundations.
Department of Economics and Forecasting Mr. Sergei Gordienko – Director (Deputy Chairman of the Krasnodar Krai Local Government
Responsible for attraction of investments to Kranodar Krai economics.
Krasnodar Krai Main Department of Civil Defense and Emergency situations Major-General P. Efremov- Head
Responsible for emergency situations issues.
According to expert conclusions, there are plenty of UXOs at the construction site, and they are still dangerous. The Work Safety Act is required, otherwise construction operations may be suspended.
Department of Health Resorts and Tourist Industry of the Krasnodar Krai Administration Ms. Elena Fursova - Chairman
Responsible for development of the tourist industry.
Committee for Natural Resources and Ecological Safety of the Krasnodar Krai Legislative Assembly Mr. Alexei Tkachev - Chairman
Responsible for environmental protection activity.
Division of Infrastructure Development in the Azov-Black Seas Coastal Zones of the Department of Comprehensive
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Stakeholder Reasons for involvement in Project
Comments
Development of the Azov – Black Seas Coastal Zone (Krasnodar Krai Administration) Mr. Sergei Netrebko - Chief Mr. Alexander Ermolenko – Governor Representative on the Azov Coastal Zone Territory Mr. Alexander Kulikov – Deputy Governor Representative on the Azov Coastal Zone Territory
Former Head of the Temryuk District Administration.
Mr. Boris Kibirev – State Duma Deputy, Deputy Chairman of the State Duma Committee for Health Resorts and Tourist Industry
One of the leaders of the regional movement “Otechestvo” (“Motherland”) (Leader – Mr. Kondratenko)
Temryuk District Local Authorities Mr. Ivan Vasilevsky - Head
Pursuant to Article 27 of the Charter of the municipal formation “The Temryuk District of the Krasnodar Krai”, the Temryuk District Administration, as local authorities, is involved in the following environmental protection and land management activities: - participates in
environmental protection activities; provides for implementation of environmental protection actions;
- organizes environmental review of construction projects as well as of facilities and enterprises which are sources of air and water pollution and do not have adequate treatment facilities;
- performs water resources management at the local level;
- exercises control over operation of water supply facilities;
- organizes implementation of sanitary, hygienic and epidemiological measures.
Head of the local Administration holds an interest in attraction of investments and in participation of investors in solving local social issues. Previously, he objected to construction of the Terminal, but currently he realizes that this Project is the only actual investment source for implementation of social programs (from an interview published the “Krasnodar News” newspaper, December 12, 2001).
Temryuk District Main Department of Natural Resources, Environmental Protection and Health Resort/Tourist Industry Ms. Svetlana Mikheeva, Deputy Head of the District Administration
Participates in the approval process (environmental issues) at the local level.
Department of Environmental Participates in the approval
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Stakeholder Reasons for involvement in Project
Comments
Protection and Tourism of the Temryuk District Administration Mr. Sergei Rak – Chief
process (environmental issues) at the local level (Ms. Mikheeva’s assistant).
Inter-Departmental Engineering Board of the Temryuk District. The Engineering Board is headed by the Deputy Head of the District Administration who is in charge of construction operations in the district. The Board consists of Head of the Gosarkhstroinadzor District Inspection, Head of the District Envvironmental Protection Committee, Chief Sanitary Inspector, and Chief of the District Fire Supervision department.
The objectives of the Engineering Board are to coordinate activity of local structural divisions and municipal services of the town (district) in the field of design, construction and commissioning of facilities. In particular, the Board’s round of duties includes: - consideration of applications
for land plot allocation for construction needs;
- consideration of town-planning statements regarding compliance of future facilities locations with town-planning master plans;
- organization of meetings of the Commission on Land Plot Allocation;
- preparation of initial permits for land allocation;
- consideration of substantiation of Terms of Reference for designing of facilities to be constructed;
- control over work schedule for issuing Terms of Reference for designing of facilities to be constructed.
Permanent Commission on Environmental Protection, Fishery, Health Resorts Services and Tourist Industry of the Temryuk District Deputy Council Mr. Nikolai Kondratiev – Chairman
The Project is to be implemented on the territory supervised by this Commission.
Permanent Commission on Agriculture and Land Use Mr. Alexei Rydin - Chairman
The Project is to be implemented on the territory supervised by this Commission
Permanent Commission on Housing & Communal Services, Industry, Construction Operations, Communications, Transport and Municipal Services of the Temryuk District Deputy Council Dmitry Tsvetenko - Chairman
The Project is to be implemented on the territory supervised by this Commission
Permanent Commission on Social Protection of Population, Public Health, Education, Culture, Sports
The Project is to be implemented on the territory supervised by this Commission
39
Stakeholder Reasons for involvement in Project
Comments
and Youth Affairs of the Temryuk District Deputy Council Ms. Irina Konograeva – Chairman Taman Okrug Administration Mr. Rodion Ostapenko – Head Mr. Eugene Bondar – Deputy Head
The Project is to be implemented on the territory supervised by this Administration
Vyshesteblievsky Okrug Administration Ms. Larissa Bedakova – Head Mr. Vladimir Mazurin – Deputy Head
This Okrug borders upon the Taman rural okrug. The Administration expresses concern over potential negative consequences which may be caused by Project implementation.
“The following cynical phrase can be read in the Tolliattiazot official documents: ”In the event of emergency the island mooring jetty, the “Fakel” Holiday Home, the Volna Settlement, the Taman Cossack Village, the Vinogradny Settlement and the Vyshesteblievskaya Cossack Village may be affected” …… (from the “Novaya Gazeta_ newspaper)
Novoatamansky Okrug Administration Mr. Vladimir Drosdov – Head Mr. Vyacheslav Bychkov – Deputy Head
The Project is to be implemented on the territory supervised by this Administration
Mr. A. Dobrynin – Temryuk Council Deputy
Actively participates in discussions on future Project aspects.
Representatives of local enterprises, farms and business companies
Khvalyun fishery collective farm Mr. Alexander Demchenko – Head
The fishery collective farm area will be affected by Project implementation. Mr. Demchenko expresses concern over potential damage to the farm.
The Khvalyun fishery collective farm may cease its activity because of the construction of a 2,5 km off-shore pier in the main fishery areas. 250 fishes and their family will be deprived of means of subsistence (from News Release of the “Ecoport” Social Ecological Union)
Temryuk District Chief Wine Maker Mr. Victor Zadorozhko
Responsible for this important branch of district economy
“Mirny” Agricultural Farm Mr. Pavel Yablonko – Head
This agricultural farm is located within the Project area
“Yuzhnaya” Agricultural Farm (Taman Cossack Village) Mr. Pavel Tychina – Director (former Director – Mr. Alexei Peredisty)
This agricultural farm is located within the Project area
“Taman” Agricultural Farm (Novotamanskaya Cossack Village) Mr. Ivan Filatov - Director
This agricultural farm is located within the Project area
40
Stakeholder Reasons for involvement in Project
Comments
JSC “Pobeda” (Vyshesteblievskaya Cossack Village) Mr. Valery Volkov - Director
This agricultural farm is located within the Project area
JSC “Taman Molding Materials Plant” Mr. Valery Burakov – Director
Representative of the District Business Society
Mr. Sergei Stanishevsky Representative of the District Business Society; Tradesman in the town of Taman; an authoritative and active local person
Mr. Vladimir Bryntsalov – State Duma Deputy, President of “Ferein” Concern; Vineyards Landlord in Taman
His position will be important for local residents, since Cossacks consider his opinion.
“Fakel” Rest Home This recreation object is located within the Project area
“Ogonyek” Rest Home Mr. Anatoly Goriainov – Director
This recreation object is adjacent to the Terminal site.
Mr. Goriainov objects to construction of the Terminal (damage to tourism, land disturbance) (from the “Novaya Gazeta” newspaper)
NGOs and Public Organizations Social Ecological Union of West Caucasus Mr. Andrei Rudomakha – Chairman
This NGO is involved in Project discussions
Threat of environmental calamity in the Taman area; strong requirement to comply with the established procedure of obtaining permits for construction operations
Social Ecological Union of West Caucasus Mr. Yu. Tertychny – Board Member
This NGO is involved in Project discussions
Historical and cultural landmarks were destroyed in the course of construction of an access railroad. Construction operations are being performed by OAO “Tolliattiazot” within the framework of the Ammonia Terminal Project (from the Open Letter to S Yasnev - Temryuk District Public Prosecutor)
“Rainbow Custodians - Radical Ecological Movement” (the town of Kasimov, Ryazan Oblast) (note- is this part of their official name – radical – Yes, it’s their official name; in other cases I deleted “radical”)
Organization of mass-meetings against construction operations
“Rainbow Custodians” -Radical Ecological Movement was formed after mass-meetings against construction of environmentally hazardous facilities in the Volga Region held in 1980s. Since that time, every summer the “Custodians” have been organizing “protest camps” and other ecological, antiwar, and anti-fascist actions in different cities of Russia,
41
Stakeholder Reasons for involvement in Project
Comments
Ukraine, Byelorussia and Czech. “Rainbow Custodians” Radical Ecological Movement is de-centralized – all issues are solved collectively (no chiefs and subordinate members). (from web-site information).
Movement Against Violence (Ekaterinburg) Mr. Gleb Edelev – Coordinator
Organization of mass-meetings against construction operations
“…. People united by ideas of solidarity and mutual assistance oppose to state power and violence. We are not politicized, we protect ourselves against policy and politicians….. “. (from web-site information) “We ….. demand: - stop constructing the
Ammonia Terminal; - provide complete public
awareness in respect of design documents substantiating safety and legitimacy of construction operations;
- establish an inter-departmental commission authorized to verify legitimacy of construction operations; representatives of NGOs must be among commission members”… (from Resolution of the meeting held on September 9, 2002)
“Autonomous Action” Anarchist Movement
Organization of meetings against construction operations
Regional Black Sea Social Ecological Centre Ms. Maiya Osicheva – President
This NGO objects to Project implementation
NGO rises in opposition to construction of terminals in the Black Sea coastal zone.
Independent Environmental Protection Agency I. Romanova, T. L’vova – Agency Representatives
This NGO objects to Project implementation
[Construction operations] is being performed without approval of the State Environmental Review, to say nothing of the independent review…. This Project is hazardous with relation to geological characteristics of the territory… (from interview to “Liberty” Radio on August 16, 2002)
42
Stakeholder Reasons for involvement in Project
Comments
“For Chemical Safety” Union (Moscow) Professor Fedorov – President
Supports NGOs in their protests against Project implementation
The union objective is … “to provide self-protection of Russian people against intrusion of hazardous toxicants….. The need in establishment of a powerful public anti-chemical movement (like numerous anti-nuclear movements) is dictated by evident inhuman activity of many industrial facilities and industries, which for many years have been emitting toxic substances to the environment and poison both the natural environment and people”… (from web-site information). TEOC documentation is very rough. This documentation was approved of by the state environmental review three years ago. No adjustments have been made since that time. Construction operations are underway, so appropriate design documentation must have been developed. But environmental review approvals and Minpriroda’s permits are not available. Numerous construction norms have been violated. (from interview to “Liberty” Radio on August 16, 2002).
IPF “For Survival and Human Development” (Moscow) Mr. R. Khairov – Executive Director
Mr. Khairov applied to the RF Ministry of Natural Resources (Department of State Control over Natural Resources Use and Environmental Protection) concerning Project implementation.
Temruk District Cossack Okrug Victor Aleshchenko – Ataman
Local Cossack leader The Cossacks attitude to construction of the Ammonia Terminal on the Taman Peninsula territory is as follows: …. It is our belief that construction of the Zhelezny Rog port in the open water area of the Black sea for loading of ships with environmentally hazardous cargoes is crime. (from Appeal of the Taman
43
Stakeholder Reasons for involvement in Project
Comments
Cossack Ataman Board to Heads of the Krasnodar Krai Administration, Temryuk Administration and environmental protection agencies).
Taman District Cossack Society Nikolai Glinko – Ataman
Local Cossack leader. Ataman Glinko believes that project realization will result in environmental calamity, destruction of historical landmarks, and nature disturbance in the Taman district.
Temryuk District Cossack Society Esaul Victor Drozdov – Ataman Advisor in environmental protection issues
Esaul Drozdov believes that project realization will result in environmental calamity, destruction of historical landmarks, and nature disturbance. He insists on participation of Cossacks in project review. He objects to construction of the Terminal on the basis of currently approved design specifications.
Former Head of Taman District Administration Gennady Maikov – active leader of Cossack movement
Appeals for environmental and public health protection in the Taman District
‘…… “Tolliattiazot” design documentation was neither properly reviewed by the State Committee for Environmental Protection nor approved of by certain Krasnodar Krai supervisory agencies. Up to this date, only TEOC is available… Without doubt, construction operations are illegal……”. (from interview to “Liberty” Radioof August 16, 2002).
Taman Village Veteran Society Mr. S. Obido – Chairman
Appeals for environmental and public health protection in the Taman District
Mr. Obido demands to stop “illegal” construction operations. In case of emergency, the Taman District population as well as adjacent residential areas may be affected. (from the Letter to L. Putina).
Local Residents Initiating Group Mr. M. Kryzhanovsky – leader
Appeals for environmental and public health protection in the Taman District
School # 32 (Volna Settlement) Ms. Tatiana Krivenko – Director
Scientific research and design institutions, experts
SUE “Krasnodarberegozashchita” Mr. Kirillov – General Director
Develops and implements design specifications for
44
Stakeholder Reasons for involvement in Project
Comments
construction of shore protection facilities.
JSC “Spetsmorstroi” Mr. V. Lamin – Chief Engineer
Responsible for construction of mooring facilities.
Russian Marine Biological Centre (Novorossiisk) Ms. Lidia Bolgova – Director
Fishery Review
“Kubangeologia”, Azov Subsidiary Mr. Josef Gusakov – Director
Engineering Geology and Seismic Safety Review
SUE “Kubangeologia” Mr. Vladimir Sheremetiev – Deputy General Director
Engineering Geology and Seismic Safety Review
Temryuk Estuary Observational Station Dr. Alexei Ivanov – Chief
Environmental Consequences Review
JSC “SevkasTISIZ” (Krasnodar) Conclusions on Engineering Geology
Institute of Oceanology, the Russian Academy of Sciences, South Branch Mr. Nikolai Esin - Director
Environmental Consequences Review
Department of Education and Science of the Krasnodar Krai Administration Mr. Boris Eletsky – Deputy General Director (is in charge of science)
Leading scientist focused on the of development of local marine biota (mussels, oysters)
Mr. Eletsky objects to construction operations since they may pollute the natural environment. He is an active speaker at different scientific and public meetings.
“Kubangiprozem” Institute Mr. Alexei Seredin - Director
Mr. Seredin has developed a “Pattern of the Temryuk District Territory Under Special Protection” document, which hinders Project implementation
According to the “Pattern …” document, all lands in the Taman area should be occupied by vineyards and rice fields.
“Kubanvodoproekt” Institute Professor Vladimir Peshkov
Expert in coastal zone studies; prognosticator of sea level fluctuations
According to Professor Peshkov forecast, the most Taman area will be flooded in 70 years due to rising of the sea level.
Local Mass Media “Volnaya Kuban” (daily newspaper), Krasnodar; “Kuban News” (daily newspaper), Kranodar Ms. T. Vasilevskaya – Deputy Chief Editor “Orbita” (newspaper), Anapa; “Taman – Vpered! (Advance)” (newspaper), Temryuk; “Taman” (newspaper), Temryuk; Temryuk Municipal TV Mr. G. Ishchenko - Director
Discussions relative to future prospects and consequences of Project implementation; public awareness; public relations.
Temryuk District Local Party Organizations
RF Communist Party Victor Kulga – leader (125 members)
Public relations
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Stakeholder Reasons for involvement in Project
Comments
“Otechestvo (Motherland” Kondratenko – leader Victor Ryabysh – Chairman, Coordinating Board (10200 members) LDPR Nickolai Golovnya – leader (53 members)
46
Attachment 2
Main Publications on AMT Project in Newspapers (2000 – 2002 yy., in Russian) № п/п Издание
Статья Дата
1. «Вольная Кубань» «Берег тревоги и надежды» 04.04.2001 г. 2. «Вольная Кубань» «Тамань-Тольятти: ключ к терминалу» 15.02.2001 г. 3. «Вольная Кубань» «Морские ворота с видом на Тамань» 12.01.2001 г. 4. «Вольная Кубань» «Горицвет вдали от рельсов
(экологическая экспертиза)» 12.01.2001 г.
5. «Вольная Кубань» «Вода под защитой» 12.01.2001 г. 6. «Вольная Кубань» «Берег надежды и опоры» 12.01.2001 г. 7. «Вольная Кубань» «Тамань-Тольятти: диалог партнеров» 16.11.2000 г. 8. «Вольная Кубань» «Тамань-Тольятти: путь к причалу» 28.09.2000 г. 9. «Вольная Кубань» «Семь раз отмерь» 08.09.2000 г. 10. «Вольная Кубань» «Дело связало Тамань и Тольятти» 21.06.2000 г. 11. «Вольная Кубань» «Тамань доверяет, но проверяет…» 19.04.2000 г. 12. Газета «1 сентября» «Будет ли завершено строительство
терминала по перевалке аммиака на таманском полуострове?»
№ 34, 2001 г.
13. «Краснодарские известия» «Долгая дорога к причалу» 17.09.2002 г.
14. «Кубань сегодня» «Объект государственного значения» 20.08.2002 г. 15. «Кубань сегодня» «Как построить порт в Тамани» 16.08.2002 г. 16. «Литературная газета» «В защиту Тамани и нового Крыма» 14-20 марта
2001 г. 17. «Новая газета» «В зону поражения могут попасть…» 19-22 декабря
2002 г. 18. «Российская газета» «Аммиак конвертируют в доллары» 23.01.2001 г. 19. «Российская газета» «Мечты и печали по дороге к причалу» 15.08.2002 г. 20. «Тамань» «Международные эксперты изучают
инвестиционный климат Тамани» 13.02.2003 г.
21. «Тамань» «В. Махлай: «Через два года вы не узнаете Тамани»»
03.12.2002 г.
22. «Тамань» «Быть ли терминалу на Тамани» 13.07.2000 г. 23. «Трибуна» «Как построить порт в Тамани» 13.08.2002 г. 24. «Трибуна» «Начинать с собственного дома» 06.06.2002 г. 25. «Трибуна» «Большие надежды на «Надежду» 26. «Трибуна» «Владимир Махлай – человек
государственный» 06.06.2002 г.
27. «Трибуна» «Здесь варят солнце сталевары» 28. «Трибуна» «Королевский набор» 29. «Трибуна» «Волна на волне будущего» 28.03.2002 г.
47
Information on AMT Project and ToAz Activities on Local TV (second half of year 2002, in Russian)
№ п/п 1. Интервью В.Н. Махлая о работе корпорации на территории
района с 1997 г. 24.07.2002
2. Интервью В.Н. Махлая об участии корпорации в социальном развитии п. Волна
26.07.2002
3. Интервью В.Н. Махлая о планах работы подразделений корпорации в Темрюкском районе в третьем квартале 2002 г.
29.07.2002
4. Комментарий главы района И. Василевского о встрече с президентом и рабочей группой корпорации «Тольяттиазот»
26.07.2002
5. Интервью и.о. главы Таманского сельского округа Е.П. Бондаря об участии «Тольяттиазот» в благоустройстве ст. Тамань и п. Волна
18.07.2002
6. Телеочерк о В.Н. Махлае 12.08.2002 7. Интервью главы района И. Василевского о федеральной
программе и необходимости строительства порта на м. Железный Рог
02.08.2002
8. Интервью с начальником порта АМОТОАЗ Л.И. Киселевым 15.08.2002 9. Репортаж о вкладе «Тольяттиазот» в подготовку учреждений
образования п. Волна к новому учебному году 21.08.2002
10. День строителя. Репортаж с объектов корпорации 09.08.2002 11. Репортаж о реконструкции центральной площади ст. Тамань и
строительстве торгового комплекса 29.08.2002
12. Репортаж о ремонте дорог в п. Волна 23.08.2002 13. Репортаж о финансировании горячего питания в школах
Таманского округа 03.09.2002
14. Блиц-опрос населения Тамани с комментарием специалистов «Тольяттиазот»
05.09.2002
15. Репортаж о газификации п. Волна и ст. Тамань 09.09.2002 16. Репортаж из агрофирм, получающих азот от корпорации 13.09.2002 17. О вкладе корпорации в финансирование мероприятий по случаю
65-летия Краснодарского края и Дня города 16.09.2002
18. Дискуссионный клуб специалистов корпорации с экологами 23.09.2002 19. Репортаж со строящихся объектов корпорации в Темрюкском
районе 25.09.2002
20. Интервью Л.И. Киселева, руководителя строительства 27.09.2002 21. Интервью заместителя полномочного представителя президента
РФ в Южном федеральном округе В.В, Крохмаля о необходимости выполнения федеральной программы по строительству порта на м. Железный Рог
01.10-07.10.2002
22. Дискуссионный клуб специалистов корпорации с медиками 02.10.2002 23. Репортаж о материальной поддержке Таманской участковой
больницы и станции «Скорой помощи» 09.10.2002
24. Об использовании инвестиций «Тольяттиазот» в экономике и социальном развитии района
15.10.2002
25. Комментарий специалистов управления сельского хозяйства о благоприятном влиянии азота на плодородие земель
17.10.2002
26. Репортаж о строящихся объектах корпорации 24.10.2002 27. О строительстве жилья для молодых семей 29.10.2002 28. Размещение телеочерка о корпорации «Тольяттиазот» 01.11-05.11.2002 29. Репортаж о реконструкции автовокзала в ст. Тамань 02.11.2002 30. Интервью заместителя главы района А.П. Грищенко об участии
корпорации в развитии промышленности района 12.11.2002
31. Пресс-конференция выпускников Таманских школ №9 и №28 со 15.11.2002
48
специалистами корпорации о возможностях обучения в ВУЗах и дальнейшего трудоустройства на объектах корпорации
32. Репортаж об автобусном маршруте Волна-Тамань 18.11.2002 33. Репортаж со строящихся объектов корпорации 25.11.2002 34. Блиц-опрос населения Таманского округа о нуждах, участие
корпорации в решении этих проблем 26.11.2002
35. О предполагаемом вкладе корпорации в бюджет района на 2003 г.
28.11.2003
36. О поддержке молодых семей п. Волна и ст. Тамань при рождении ребенка
29.11.2002
37. Интервью заместителя главы края по вопросам промышленности о деятельности корпорации в Темрюкском районе, о выполнении совместного договора, подписанного в 2001 г.
03.12.2002
38. Репортаж со строящихся объектов корпорации 06.12.2002 39. Дискуссионный клуб с участием специалистов Центра занятости
населения и корпорации о возможном трудоустройстве населения района на объектах «Тольяттиазот»
10.12.2002
40. Репортаж об уличном освещении Таманского округа 13.12.2002 41. Репортаж о ремонте дорог 16.12.2002 42. Репортаж о реально оказанной поддержке Таманскому
сельскому округу корпорацией 20.12.2002
43. Комментарии главы района И. Василевского о взаимоотношениях и реально предпринятых совместных мерах по снятию ажиотажа вокруг строительства терминала
23.12.2002
44. Поздравление В.Н. Махлай труженикам района с Новым годом 30.12.2002 45. О планах корпорации на 2003 г. 30.12.2002
49
Attachment 3
Selected Minutes of Public Meetings (full versions are available in Russian). Are there minutes of any public meetings?
1. Minutes of Public Hearing Held in Temruk, Temruk District, Krasnodar Krai (March 26, 1998) Is it 1998 0r 1996?
Participated 45 persons representing local administration, business, local agricultural producers, technical experts, residents, mass media
The issue under discussion: TEOC of AMT Project
Presentations made by:
1. V.Alborov, ToAz vice president
2. R.Zargarian, Lead Engineer of “GIPROGOR” Design Institute
3. V.Paschenko and D.Khromov, Project Design Managers, Design Institute of Ammonium Industry
The following persons participated in discussions:
1. A.Ermolenko, Head of Temruk District Administration
2. S. Artyliakova, Head of Kuban-Azov Environmental Department
3. V.Serenko, Head of Sanitary Inspection
4. M.Lut, Expert of Commission on Cultural Heritage Preservation
5. S.Petrov, Head of Department of Architecture and Construction
6. V.Riabysh, Expert of Control Department for Ammonia Production.
Participants have expressed support for the project under conditions of observance of environmental legislation requirements, requirements for protection of archeological sites, and taking into consideration concerns of local stakeholders.
2. Meeting with Representatives of Local Cossack Organizations, Volna Settlement (July 7, 2002)
Participated: ToAz representatives – S. Matunin, Vice-President; S.Titov, Head of Public Relations Department; A.Ponomarev, Head of Public Relation Service of AMT Project; Cossacks from Taman, Temruk, Anapa.
3. Round Table Discussion for Mass Media Representative, Volna Settlement (september 17, 2002)
Participated: correspondents of "Tribuna," "Trud," "Kuban Segodnya," Versty," "Sel'skaya Zhizn'," "Pravda," "Parlamentskaya Gazeta," Kubanskie Novosti," "Krasnodarskie Izvestiya," "Taman'," "Chelovek Truda," "MPK Gazeta," newspapers and "TMT" TV company, "Kuban'" TV and radio broadcasting company, and "Krasnodar" TV and radio broadcasting company; ToAz representatives – S. Matunin, Vice-President; S.Titov, Head of Public Relations Department.
4. Minutes of Public Hearing Held in Taman, Temruk District, Krasnodar Krai (February 10, 2003)
Participated 29 persons representing local administration, business, local agricultural producers, technical experts, residents, mass media, IFC and EBRD
50
51
The issue under discussion: TEOC of AMT Project
Presentations made by:
1. I.Vasilevsky, Head of Temruk District Administration
2. V.Makhlay, ToAz President
The present status of AMT Project and its impact on economy, social issues and environment were discussed (seven local residents and media representatives have participated in discussion).
The participants have supported the ToAz activities aimed to the AMT construction; they also addressed Krasnodar Krai Administration with a request to allow further AMT construction works, and recommended to develop a general plan for Volna settlement socio-economic development.
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