Letter to President of the International Olympic Committee

December 12, 2014

Thomas Bach
President of the International Olympic Committee
Château de Vidy
Case postale 356
1001 Lausanne, Switzerland
Phone +41 21 621 61 11
Fax +41 21 621 62 16

Dear President, dear members of the IOC,

We appeal to you on behalf of the movement “Protect Kok-Zhaylau”, Ecological Society “Green Salvation”, and ten thousand citizens of Kazakhstan and other countries who oppose construction of a mountain ski resort on the territory of Ile-Alatau National Park.

We share and fully support the principles of the Olympic Charter. As people who are actively involved in protection of natural environment for the current and future generations, we especially welcome the IOC’s aspiration “to encourage and support a responsible concern for environmental issues, to promote sustainable development in sport… and to promote a positive legacy from the Olympic Games to the host cities and host countries”[1].

We are addressing to you because the Republic of Kazakhstan submitted a proposal to host the Olympic Winter Games 2022 in the city of Almaty, and the proposal contains serious violations of the above mentioned principles of the Olympic Charter.

  1. Some of the sites which are intended to be used to conduct the Olympic Games will be placed on the territory of Ile-Alatau National Park. For example, the proposal names existing mountain ski resorts “Chymbulak”, “Tabagan”, “Akbulak” and the planned mountain ski resort “Kok-Zhaylau”. The 2022 Working Group Report indicates: “The proposed development at Kok-Zhaylau is situated in a potentially sensitive natural area within the National Park of Ile-Alatau.”[2]

But the 2022 Working Group Report does not specify that Ile-Alatau National Park is one of the sites of the Republic of Kazakhstan submitted for the Tentative List to be included into the World Heritage List of the Convention concerning the Protection of the World Cultural and Natural Heritage[3]. This fact, probably, was also omitted in the proposal submitted by the National Olympic Committee (NOC) of Kazakhstan. Construction of the mountain ski resort Kok-Zhaylau will significantly decrease chances of Ile-Alatau National Park of being included into the World Heritage List.

Further on, the 2022 Working Group Report states: “Environmental feasibility studies are currently in progress.”[4] Despite of the fact that the process of approval of the project by the state officials is not completed yet, in July 2014, construction was started on the territory of the national park. As a result, significant damage was brought to the ecological systems of the park.[5] Official organs responsible for parks management do not undertake any measures to stop the construction, at least, until completion of the official project approval procedure.

The started construction opposed the statement that: “The bid stated that alternative sites for the venues proposed are available within the existing proposed Olympic zone.”[6] Alternative sites were indeed considered, but all of the reviewed sites were located within Ile-Alatau National Park.

  1. The 2022 Working Group Report lists atmospheric air pollution, poor quality of auto fuel, and poor waste management to be the main ecological problems to be solved in Almaty.[7] But nothing is mentioned about a whole spectrum of other factors seriously influencing environmental conditions of the city. These are: increasing deficit of water resources[8], shrinking glaciers of the mountainous area where Ile-Alatau National Park and Almaty Nature Reserve are located, destruction of wild fruit forests with valuable tree species, construction development in fertile lands, including construction of sport facilities, destruction of habitats of rare species of plants and animals.
  1. The 2022 Working Group Report says nothing about influence of the construction of the mountain ski resort Kok-Zhaylau over the territory of Kyrgyz Republic, and that the proposed activity is subjected to the Convention on Environmental Impact Assessment in a Trans-boundary context. The Ministry of the Republic of Kazakhstan in its reply (No.03-20/13829 dated on 19.12.2012) to the request of the Ecological Society “Green Salvation” admitted that the construction is planned “in a very sensitive ecological region bordering with Kyrgyz Republic”. Therefore, “in accordance with the Appendices I and III of the Convention, provisions of the Convention must be applied during preparation of the project of EIA”.

Apart from the indicated convention, the proposed activity can lead to violation of the Convention on Biological Diversity, Convention on the Conservation of Migratory Species of Wild Animals, Convention on Long-Range Transboundary Air Pollution. Unfortunately, the state officials are not interested in conducting of a comprehensive environmental impact assessment of the proposed activity in the national park – that is why it is made in a hurry.

This is confirmed by official documents published by the project developers. They admit that “the works over the project indicated that there is not enough of reliable data for a well-reasoned justification or adoption of correct decisions. This is due to the fact that during the post-soviet period…, practically no task-oriented scientific research or survey was performed. A lot of the data became outdated, and some wrong decisions are needed to be reviewed from the point of the current methods and technologies. Without solving this question, it is impossible to predict potential negative processes and effects.”[9]

  1. Paragraph 13 of the 2022 Working Group Report, devoted to legal situation in Kazakhstan, states: “Bid documents indicate that there should be no legal obstacle to the organisation of an Almaty 2022 Olympic Winter Games. Mention is made of the State’s willingness to adopt sports-related legislation to support the organisation of the Games. The “Law on Physical Culture and Sport” is currently being revised and the draft law should include certain provisions of the Olympic Charter.”[10]

We have no doubts that Kazakhstan would allow any legislative amendments despite of their consequences, in order to seek organization of the Olympic Games in Almaty.

Practice shows that the legislation of Kazakhstan is poorly correlated with the international law, has a lot of contradictions, is subjected to endless changes depending on the interests of various influential economic groups. As result of the numerous amendments and additions introduced into the law “About specially protected natural territories” (2006), this normative legal act already cannot secure normal functioning of national parks and nature reserves. Specifically, that is why Almaty city authorities declare with such confidence that there are no legislative obstacles to conduct the Olympiad. But in fact, the legal situation continues to deteriorate. In 2010, the National Report about environmental situation in the country indicated: “Inaction in the area of conservation of biodiversity of Kazakhstan threatens to lead to full extinction of some of the species of animals and plants, degradation of ecosystem.”[11]

In 2013-2014, in order to protect integrity of Ile-Alatau National Park, the public filed five lawsuits to courts demanding to stop the illegal construction.[12] To appeal in courts actions or inaction of the state organs is highly difficult, as “the independence of the judiciary is constrained by the influence of the executive, and corruption is evident throughout the judicial system.”[13] Apparently, this fact was also missed in the NOC’s proposal.

  1. Paragraph 14 of the 2022 Working Group Report states: “Almaty’s bid has the full support of all levels of government. … An opinion poll commissioned by the bid committee shows 65% support in Kazakhstan. The IOC poll in Almaty and the surrounding municipal areas shows 66% support for Almaty hosting the Games, with 13% against.”[14]

It is very difficult to talk about the level of support of the games among the population, because there are no legal mechanisms of accounting of public opinion in Kazakhstan. Public right to participate in a decision-making process is proclaimed in the Articles 13 and 14 of the Environmental Code, but practice shows that the state officials, basically, hamper its realization.

This is reflected in the Decisions II/5а (2005) and V/9i (2014) of the Meeting of the Parties of the Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters. In particular, the Decision V/9i states that the Meeting of the Parties “Regrets that the Party… remains in non-compliance with article 6, paragraphs 2, 6, 7, and 9, of the Convention on public participation in decision-making.”[15] State officials do not undertake effective measures to provide efficient public participation in the decision-making process. On the contrary, they are eager to remove the public from this process.

Also it is necessary to account extremely high level of corruption in the country which creates favorable conditions for manipulation of the public opinion. According to the research conducted by Transparency International in 2012, among 174 countries studied for the Corruption Perception Index Kazakhstan was ranked 133. In 2013, it was ranked 140 out of 177[16] countries. Corruption in Kazakhstan has a systematic nature and exists in all branches of power.

The 2022 Working Group Report states: “The Bid Committee also includes representatives of the NOC, national and local governments, athletes and the private sector, as well as representatives of the state controlled Wealth Fund “Samruk-Kazyna”, which owns 583 companies contributing 56% of the GDP of Kazakhstan. There is a good representation of all stakeholders.”[17] The proposal, probably, does not indicate that “according to operative data of the Agency of the Republic of Kazakhstan on Statistics, by the end of 2011, unobserved economy constituted 19.5% of GDP, during the past years, it varied between 19.5% and 20.1%.” “According to the World Bank data, average volume of shade economy in Kazakhstan for the period of 1999-2007 was 41.1%.”[18]

  1. Besides, in Kazakhstan there are acute social problems which require budget investments:

unemployment: 35.43% of capable to work population do not have a permanent job (according to the data of the Agency of Statistics of the RK), 43-45% – according to unofficial estimating data.

- housing deficit, which in 2013 was 23 million m² or 383 333 apartments;

- 60% of children do not have an access to daycare and preschool education;

- according to the information of the Ministry of Education and Science of the RK, there is a deficit of 70 000 of student spaces in Kazakhstan. 103 schools operate in three sessions, and besides, 176 schools are in emergency situation. Overall, in order to cover the current deficit it is necessary to build 328 schools (even without accounting the population growth). The biggest problem of education is insufficient funding, despite of the official increase of the state expenses on education which in 2013 comprised of about 4.2% of GDP. This is absolutely not enough, as the minimal standard for the countries of the Organization for Economic Co-operation and Development (OECD) is about 6%.

  1. The public campaign was supported by the Nature and Biodiversity Conservation Union of Germany (NABU), (Deutscher Alpenverein e.V.)[19], and European Ecoforum[20].

Information about negative consequences of realization of the project on ecological systems of the national park was submitted to the UNESCO World Heritage Center[21], Convention on Biological Diversity[22], and World Commission on Protected Areas of the International Union for Conservation of Nature[23].

Aarhus Convention Compliance Committee began reviewing a statement from Almaty residents about violation of the rights of the city residents on participation in decision-making process concerning the project “Kok-Zhaylau” and about general failure of the state authorities to secure public participation in decision-making process on the matters related to plans, programs, and policies, in accordance with the Article 7 of the Convention (АССС/С/2013/88[24]).

  1. Based on the aforementioned facts, it can be concluded that the actions of the state authorities of the Republic of Kazakhstan contradict to the Olympic Charter. In particular, the state authorities neither encourage, nor support “responsible concern for environmental issues”, nor promote “sustainable development in sport”, nor contribute to “a positive legacy from the Olympic Games” by the city of Almaty and the country in general. Based of the above stated, the public of Kazakhstan appeals to you to decline the proposal about conducting the Olympic Games in Almaty. 

To discuss the problems described, we suggest a meeting of the IOC Working Group with the participants of the movement during the planned visit of the working group to Almaty in the beginning of 2015.


  1. Belkhojayev Nursultan (Almaty),
  2. Zhukenova Zhamilya (Almaty),
  3. Berkova Nadezhda – Ecological Society “Green Salvation” (Almaty),
  4. Kuratov Sergey – Ecological Society “Green Salvation” (Almaty),
  5. Medvedeva Nataliya – Ecological Society “Green Salvation” (Almaty),
  6. Spatar Svetlana – Ecological Society “Green Salvation” (Almaty),
  7. Solyanik Sergey (Almaty),
  8. Krassovitskiy Pavel, candidate of physical-mathematical sciences, senior researcher of Institute of nuclear physics (Almaty),
  9. Ibraeva Yelena, professor, doctor of physical-mathematical sciences, leader researcher of Institute of nuclear physics,
  10. Nurmakov Adil, C.Sc. in Political Science (Almaty),
  11. Chechulin Alexandr (Almaty),
  12. Vashchenko Nadezhda (Almaty),
  13. Baranov Igor (Almaty),
  14. Tlegenov Nurzhan (Almaty),
  15. Karpova Mariya (Almaty),
  16. Kvashnina Alexandra (Almaty),
  17. Tashimova Saltanat (Almaty),
  18. Nazarov Alois (Almaty),
  19. Zhukov Dmitriy (Almaty),
  20. Kartun Valeryi (Almaty),
  21. Zhitnik Alexey (Almaty),
  22. Ibrayev Tair (Almaty),
  23. Araslanova Rimma (Almaty),
  24. Iglikov Marat (Almaty),
  25. Iglikov Serjan (Almaty),
  26. Iglikova Malika (Almaty),
  27. Baikadamova Baldurgan (Almaty),
  28. Gazke Yevgenia (Almaty),
  29. Yakubova Gulzia (Almaty),
  30. Yakubova Dana (Almaty),
  31. Andreeva Larisa (Almaty),
  32. Abdumanapova Adalyat (Almaty),
  33. Popov Ivan (Almaty),
  34. Buzykin Andrey (Almaty),
  35. Gumirova Olga (Almaty),
  36. Zhanuzakova Madina (Almaty),
  37. Shuptar Vitaliy, Avalon Historico-Geographical Society PA (Karaganda),
  38. Yerekenov Abay (Almaty),
  39. Kim Aliya (Almaty),
  40. Yerekenov Bekjan (Almaty),
  41. Yerekenov Aidar (Almaty),
  42. Shormanbayev Amangeldy (Almaty),
  43. Damelya Aitkhozhina (Almaty),
  44. Jandossova Azhar (Almaty),
  45. Dagmar Schreiber (Berlin, Germany).


[1] Olympic Charter. Mission and Role of the IOC, paragraph 13 and 14; http://www.olympic.org/Documents/olympic_charter_en.pdf
[2] XXIV Olympic Winter Games 2022 Working Group Report. – Lausanne, 9 May 2014, p.38;
[3] http://whc.unesco.org/en/statesparties/KZ/.
[4] XXIV Olympic Winter Games 2022 Working Group Report, p.38.
[5] In August 2014, the Department of Ecology of the city of Almaty made a complaint to the developer for the damage brought to the environment and filed the case to a court for suspension of the construction works (Letter of the Department of Ecology of the city of Almaty No.04-11/921 dated on August 19, 2014).
[6] XXIV Olympic Winter Games 2022 Working Group Report, p.38.
[7] Same as above.
[8]  “Accroding to expert estimations, degradation of mountainous glaciation will decrease the flow rate of the rivers of the northern slope of Zailiisky Alatau on approximately 16 percent… All of these three directions of negative consequences of degradation of glaciation on water resoruces and water patterns of mountain rivers require a comprehensive study and quantitative evaluation.” National Report about human development. 2008, p.62-63.
[9] Feasibility study of allocating lands of specially protected natural territories of Ile-Alatau State National Natural Park into lands of reserve for mountain ski resort “ Kok-Zhaylau ”, Almaty 2014, p.91.
[10] XXIV Olympic Winter Games 2022 Working Group Report, p.45.
[11] National report on environmental situation in the Republic of Kazakhstan in 2010. – Almaty, 2011, p.115.
[12] For example, see: http://www.greensalvation.org/index.php?page=KokZhaylyau_campaign.
[13] Strategy for Kazakhstan. European Bank for Reconstruction and Development: http://www.ebrd.com/documents/strategy-and-policy-coordination/strategy-in-kazakhstan.pdf, December 17, 2013, p.34.
[14] XXIV Olympic Winter Games 2022 Working Group Report, p.47.
[15] http://www.unece.org/env/pp/aarhus/mop5_docs.html.
[16] Corruption Perceptions Index 2012; http://cpi.transparency.org/cpi2012/results. Corruption Perceptions Index 2013; http://www.transparency.org/cpi2013/results.
[17] Same as above.
[18] Comprehensive plan against shade economy in the Republic of Kazakhstan for 2013-2015. Adopted by the Government of the Republic of Kazakhstan dated on February 27, 2013, No.190:  http://adilet.zan.kz/rus/docs/P1300000190.
[19] http://www.alpenverein.de/natur-umwelt/online-petition-gegen-skierschliessungsplaene-in-kasachstan-kasachstan-skigebiet-im-nationalpark_aid_12332.html.
[20] http://panoramakz.com/index.php/component/k2/item/35170-predstaviteli-obshchestvennosti-v-znak-protesta-pokinuli-slushaniya-po-proektu-gornolyzhnogo-kurorta.
[21] http://www.greensalvation.org/index.php?mact=News,cntnt01,detail,0&cntnt01articleid=474&cntnt01returnid=51.
[22] http://www.greensalvation.org/index.php?mact=News,cntnt01,detail,0&cntnt01articleid=480&cntnt01detailtemplate=news01detail.tpl&cntnt01returnid=51.
[23] http://media.wix.com/ugd/40939f_4ae578e88b1245b0bd64cfb626945c5b.pdf.
[24] http://www.unece.org/env/pp/compliance/compliancecommittee/88tablekaz.html.