Presidential Council on Development of Sports and Preparation for the Olympic Games Established

WWF-Russia Tel: +7 495 727 09 39 Fax: +7 495 727 09 38 19, Nikoloyamskaya [email protected] Street, bd. 3 109240 Moscow Russia

There was a very significant progress made in the course of 2009 in the level of public participation. By the initiative of myself and former president of the state corporation Olympstroy, which manages most of construction, Coordination Council has been established in December 2008. There were 10 physical meeting of this Council in 2009, all in Sochi. All meetings were open for media, NGOs, contractors and sub-contractors. Presidential Council on development of sports and preparation for the Olympic Games established several thematic working groups, including one on environment chaired by the Minister of natural Resources and Ecology Yuri Trutnev. WWF and Greenpeace representatives are members. This working group met 4 times in 2009. In September 2009 Deputy Prime Minister Dmitry Kozak convened a meeting on environment with NGOs taking part. Finally, WWF project on reintroduction of leopard in the Western Caucasus was included in the programme of environmental support of the Olympic Games and received substantial governmental funding. However, despite frank and constructive discussions, decisions jointly taken at all those venues are far from being implemented. This is the greatest deficiency of those consultation mechanisms questioning their real purpose. All points below were reflected in the minutes of aforementioned meetings, which can be found in Russian on our web site http://www.wwf.ru/about/what_we_do/reserves/sochi2014/discuss/. Below are major points of concern with more detailed explanation:

1. Poor quality of project documentation. This is definitely true for environmental impact assessment sections (I personally reviewed about 10 projects as a formal expert of state environmental expertise commissions) and is likely to be true for geological data and technological solutions. For biological data, the major reason is lack or poor quality of field data – preliminary field surveys simply were not done or done at an inadequate level. To give one example, EIA for the combined railway and highway, by far the largest project related to the Olympics (estimated cost 8 billion USD) is based on couple weeks of zoological and botanical research done by less then 10 people. As a result, projects do not have any reasonable mitigation plans, nor technological solutions allowing for minimizing the impact. This poor quality and urgent need for supplementary field research was confirmed by the protocol of the meeting of Coordination Council under Olympstroy on 25 January 2009 and then reconfirmed at the following meetings. We suggested that project designers pull their funds to carry out one joint field survey in spring-summer 2009 and then adjust their projects accordingly. Our proposal was supported by the Council, several companies specializing on EIAs for big projects presented their proposal and one was recommended to carry this survey out. However, Olympstroy failed to pursue project designers to allocate funding and field data is still lacking. Recent events, when on 14th December 2009 cargo port under construction was fully destroyed by the storm and then Mzymta river flooded on-going construction sites along the river on the 29th

President: HE Chief Emeka Anyaoku Registered as: Director General: James P. Leape WWF-World Wide Fund For Nature President Emeritus: WWF-Fondo Mondiale per la Natura HRH The Duke of Edinburgh WWF-Fondo Mundial para la Naturaleza Founder President: WWF-Fonds Mondial pour la Nature HRH Prince Bernhard of the Netherlands WWF-Welt Natur Fonds Also known as World Wildlife Fund

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December 2009, gave clear signals that not only environmental but also technological risks were not properly assessed (video on the storm at http://www.youtube.com/watch?v=E1ZoGvRp_ck, pictures form the flood in Attachment 1). It is important to mention that both weather events were not abnormal, such storms and floods take place in the area several times a year. According to official sources, destruction of the port brought 60 million USD in losses. Doctor of geological sciences Sergei Volkov, who has been working for the Olympic construction until last summer described in details the problem of lack of baseline data and possible consequences for the safety in his open letter to President Dmitry Medvedev (http://www.privetsochi.ru/blog/sochi2014/2055.html in Russian).

2. Lack of monitoring Despite construction is on-going at least since 2008, there is no comprehensive monitoring programme of the impact of the construction. Some private investors contracted Sochi national park scientific staff for this purpose, but scope of their work is limited to specific investor’s objects. Methodology of this monitoring was not approved by any independent scientific body and data cannot be fully trusted because of conflict of interests – the same park staff previously was giving green light for the construction. Monitoring was specially discussed at the meeting of the Working group under the chairmanship of Minister Trutnev on 16 October 2009. Roshydromet, responsible for monitoring reported that it will fully start as from 2012, which does not make any sense as all facilities will be already in place. My objection to such lag was supported by the Minister, who then asked WWF to propose monitoring scheme which we submitted in 2 weeks to the Ministry, but nothing happened since then.

3. Time lag and weakness of compensation measures Compensation measures within the preparation for the Olympics can be divided into general ones and project specific ones. General compensation measures include expansion of existing and establishment of new protected areas as well as recently included reintroduction of leopards. Of those, only leopard reintroduction programme is fully up and running. Regarding protected areas, none has yet been expanded or established and those which are in the pipeline are either questioned by regional authorities or are going to be established in smaller size or with different borders than originally designed. These are the following: i. Transfer of the Sochi republican refuge (zakaznik) to the Ministry of natural resources and ecology from the Ministry of agriculture with following division of its territory between Sochi national park and Caucasian biosphere reserve – done. ii. Expansion of Sochi national park – documents still being agreed between the authorities. In the meantime some areas originally planned for inclusion are already being leased to private companies. Moreover, in July 2009 the City of Sochi adopted General land use plan where 3

approximately 8,000 ha of Sochi national park are shown as city rather than park territory, conflict still not resolved. iii. Establishment of natural park in Imeretinskaya lowland to protect migrating birds (this site is in Ramsar shadow list), endemic plants, amphibians and reptiles. This park was designed in 2008 when scientists did a thorough survey of the area published by WWF in 2009. However, field visit by the Working group in March 2009 showed that most of plots suggested for inclusion in the park were already developed or leased for construction. Current design will not serve any conservation purposes according to the judgment of experts. iv. Establishment of the biosphere polygon of Teberda biosphere reserve to ensure its connection with the Caucasian biosphere reserve. This polygon was designed by WWF in 2007 totalling 105,000 ha but then shrunk by the regional authorities to 28,000 ha. v. Establishment of Utrish reserve1. In 2008 Ministry of Natural Resources and Ecology gave contract to WWF to design this protected area. WWF submitted proposal for 15,000 ha and the Ministry accepted this proposal. However, at the end of 2008 local activists noticed illegal construction of the road within the territory of proposed reserve and organized public protests. Construction was terminated, but then it came out that Administration of the President was planning to construct a guest house right in the core of proposed reserve and this was the reason for road construction. Later on the regional authorities insisted on cutting original design further and Ministry agreed to exclude both future guest house and areas suggested by the region from the original design. As a result, proposal shrank to 9,000 ha and most valuable coastal stands of juniper and pistachio were excluded from the reserve territory while this is the largest relict dry subtropical Mediterranean ecosystem in Russia. Public protests are already carried out in various Russian cities, but many more actions are expected when construction really starts. vi. At the end of December we were informed that Russian registration service changed the borders of Caucasian biosphere reserve to allow building public road to Gazprom resort. This was not done by any governmental decree, there was no discussion of this at all. The Service simply changed the land use documents cutting the reserve’s territory. Caucasian reserve is a World Heritage site and surely there will be a reaction from the World Heritage Committee on this. Project specific compensation measures are often inadequate which probably results from lack of proper research. One striking example is establishment of box tree plantations as a compensation measure for cutting primary forests with dominance of box tree during construction of a combined railway and highway. Not mentioning that monospecies plantations cannot compensate for destruction of complex primary forests, but the source of seedlings is very dubious. Although it is claimed that seedlings were coming from some breeding centres, there are many witnesses that they

1 Formally establishment of Utrish reserve is not included in the Olympic programme, but it was specifically mentioned in the Minutes of the meeting with the Minister of Natural Resources and Envrionment from 02 July 2008 4

were simply dug out in nature within Sochi national park and taken to plantations. In fact there are no breeding centres for box tree in Russia.

4. Combined railway and second highway from Adler to Krasnaya Polyana This road has been being built with neither permissions nor project documentation for more than a year since autumn 2008 and resulted in destruction of unique forests. In November 2009 project documentation was finally submitted for state ecological expertise. Expert panel consisted of more than 20 experts of which 3 looked at biological components (one on animals, one on plants, one on water biological objects). Other experts were assessing waste management, air and water pollution, geology, emergency situations etc. At the end of December panel approved the project by majority vote, but 3 experts (on fauna, flora and protected areas) submitted special opinions with negative estimation of the project, which means that from biodiversity conservation point of view the project is unacceptable.

5. Weakening environmental legislation Whole process of preparation for the Olympics was accompanied by amending environmental legislation lifting former restrictions and bans. For example, in 2006 the Law On Protected Areas has been changed, allowing mass sports events in the national parks (previously directly banned). In late December 2009 Parliament approved another amendment to the Forest Code, allowing cutting endangered species of trees and shrubs for construction of Olympic facilities.

6. Access to the area of construction and abuse of NGOs We have previously reported on the detention of 2 activists from Environmental Watch on the North Caucasus in August and this situation repeated in October. A group of NGO activists and WWF expert visited ceremony on opening the box tree plantation on 12 October 2009. This plantation was part of compensation programme within the project of combined railway and highway. There were around 100 people, mostly journalists on site. Just before the start of the ceremony border guard patrol came in and detained 3 activists from Environmental Watch on the North Caucasus, one German journalist and professor V. Akatov who took part in the examination of the construction site as WWF invited expert the day before. They were all taken at the border guard station, one of them with the use of force. At the station they were accused of violating the border zone regime requiring obtaining special permit for visits. Few days after the court in Adler ruled fines for A. Rudomakha and S. Gazaryan from Environmental Watch on the North Caucasus. Appeals to the higher court brought no change. Thus it came out that all Olympic facilities are being constructed in the border zone with special regime requiring permits for visits but this regime is implemented selectively against NGOs as apparently no tourists or visitors ever obtain any permits and probably do not even know about this regime. Selective justice when obvious crime like illegal construction destroying endangered species is allowed to continue while NGO activists are prosecuted for just being there is absolutely unacceptable and led to termination of our participation 5

in the Coordination Council of Olympstroi. We cannot continue our work if it poses risks for the dignity and health for our staff and more importantly invited experts. Summing up, we believe that for the time being preparation for the Olympics is not under control, construction is of poor quality, vast damage to the environment has already been made and more is expected and NGOs are deprived from the ability to provide independent advice. WWF believes that the following measures are necessary to prevent more damage to the environment: 1. Making developed ‘Green standards’ legally mandatory for all contractors. 2. Introduction of control mechanisms over contractors with the right of cancellation of contracts and claiming funds back in case a contractor does not follow environmental requirements. 3. Significantly expand and empower governmental environmental control in the area of construction with the right to terminate construction with immediate effect. 4. Reconsideration of transportation, including cancellation of the combined road. 5. Immediate allocation of funds for baseline research and following monitoring. 6. Creation of mechanisms, including legal changes, in order to fully implement compensation scheme on expansions and establishment of protected areas within scientifically justified borders. 7. Cancellation of the border zone regime in the area where Olympic facilities are being constructed. Some of these decisions can be taken only at the level of the Prime Minister with following approval by the Parliament as they do require changes in laws. These Olympic Games have no chance to be ‘green’ any more as serious irreversible damage to unique ecosystems has already been made but there is still a chance to minimise further damage and implement territorial compensation (expansion and establishment of protected areas) in full. Same applies to safety of the Olympics which is dramatically undermined by poor quality of projects and death Olympic count has already started and unless all projects are carefully scrutinised more catastrophes can be foreseen in this area of 9 point earthquake potential with active seismic fault, massive landslides and karst formations.