Almaty’s Green City Action Plan: a plan for destructive creation?

The Kazakh city of Almaty joined the European Bank for Reconstruction and Development (EBRD)’s Green Cities initiative in 2019. How does the first Green City Action Plan in Central Asia reflect public participation?

The Kazakh city of Almaty joined the European Bank for Reconstruction and Development (EBRD)’s Green Cities initiative in 2019. In November 2022, Almaty became the first city in Central Asia to approve its Green City Action Plan (GCAP). Bankwatch and Green Salvation have called on the EBRD and local authorities to ensure public participation during the implementation of both the GCAP and some of the more controversial urban development projects in the city. So far, this call has fallen on deaf ears.

This article was written by Green Salvation, Bankwatch’s partner organisation based in Almaty.

On 4 November 2022, the supposed relocation of Almaty’s airport building, built in 1947, began. But instead of being moved 420 metres to the southeast, as stipulated by a decree from the head of the local government – the Akim of Almaty – dated 11 November 2020, the building was moved to the scrapheap. Excavators and bulldozers paid little heed to the ‘integrity and safety of the monument’ as it was cleared to make way for the construction of a new airport terminal, which proponents say the city badly needs.

The participants and investors involved in the old airport’s demolition were the local government, the Akimat and several other stakeholders. This is despite the fact that the building is still included in the current state list of historical and cultural monuments of local importance in Almaty, a list approved by the very same Akim.

This is not the first time the city authorities have taken such a destructive approach to creation. Locals recall the demolition of the Palace of Pioneers and the Alatau cinema, several kindergartens being destroyed, the foothills around the city built up with villas and cottages, and thousands of hectares of apple orchards being cut down. Writing down a complete list of ‘reconstruction projects’ like this would take more than a dozen pages. And then there’s the destruction cause by developers within the Ile-Alatau National Park and the Medeu Regional Nature Park.

Behind the smokescreen of public hearings

How can these projects possibly comply with the law that ‘recognizes and guarantees’ public participation in the decision-making process, consideration of ‘public interests’ and respect for human rights? After all, many citizens publicly opposed the demolition of the old airport building; even the Akim of Almaty had made a resolution to protect it. If this can still happen, what do the dozens of agencies responsible for keeping order and ensuring the rule of law actually look out for?

According to ‘highbrow’ scientists, experts and bureaucrats within the city, members of the public don’t understand enough to participate in these processes. One has to wonder what special knowledge is needed to understand that in a state governed by the rule of law, the law must be strictly observed. Still, the city’s experts seem to believe that public opinion can be ignored at the earliest stage of decision-making.

It seems that their approach is to create a smokescreen of public hearings while never actually making any obligations to the opinion of the people. And from there it is a very simple algorithm: we tear it down, build it, grow it or cut it down, depending on what the investment requires. But the investment’s needs always come first.

Only in very rare cases does the public manage to preserve natural landscapes, individual city streets, houses and trees. But this is only a drop in the sea of destructive creation that has engulfed the country.

All of this is already known. What is new in the case described above is that the airport’s destruction was financed by the EBRD. And the bank, together with the city’s leadership, has grand plans.

On 12 October 2022, the fourth consultation workshop with the interested parties was held in Almaty. The local government gave an advance presentation of Almaty’s GCAP. The initiative is part of the Green Cities programme implemented by the EBRD and funded by the Federal Ministry of Finance of the Republic of Austria.

After reading the GCAP, Green Salvation has come to the following conclusions, which we have sent to the authors of the document. No response has yet been received.

The document does not clearly explain how public opinion was taken into account in its preparation. There is no quantitative and qualitative data that could confirm the public’s participation of the public and its effectiveness.
It talks about the need to involve citizens, consumers and the public early in the processes (pp. 24, 41, 101, 109, 118, 126, 133, 134, 137, 144, 155), but there is no clear statement of how this was achieved. This once again confirms that public participation in the preparation of the plan was and apparently will continue to be reduced to formal participation in workshops and conferences during the project’s implementation.

The document lacks a detailed analysis of the legal framework for the implementation of the GCAP and specific analysis of the obstacles that may arise. These potential roadblocks could include the high degree of corruption in the country, legal chaos, limited access to information and poor work by government agencies.

One gets the impression that in developing the document, its authors did not use all available sources and data. This indicates that the GCAP was poorly prepared (see appendix for specific comments).

What can we expect from the EBRD’s activities after such a tumultuous start and a long-awaited but poorly prepared action plan? The question is rhetorical, but apparently both officials and bankers are satisfied with everything they’ve done so far.

Comments about the GCAP, Almaty 2022

Green Salvation submitted the following comments regarding selected actions within the GCAP:

Action 10: Transit-oriented design – application of transit-oriented design in the development of satellite cities.

The plan does not indicate whether new expansion of the city’s boundaries is anticipated.

It does not address the need to move industrial facilities beyond the city limits or to move motor vehicle depots away from residential areas.

Action 16: Develop a citywide blue-green strategy and implementation plan.

The plan does not indicate when the 2030 Green Space Strategy was adopted or where the public can read it.

It does not analyse the condition of the city’s green fund (it does not indicate the percentage of trees that have taken root, diseased trees and the financial costs of replanting).

It is not clear what is meant by ‘withdrawal of lands due to their location in specially protected natural areas of the region’.

It does not take into account that Ile-Alatau National Park is included on Kazakhstan’s preliminary list for nomination to the List of the Convention for the Protection of the World Cultural and Natural Heritage.

It does not mention the creation of a structure for the unified management of the city’s green fund.

Action 18: Increase the water permeability of the city of Almaty.

The plan does not mention the need to upgrade the ‘aryk’ system of irrigation ditches, which prevents soil from absorbing moisture.

It does not consider what measures need to be taken against spot and compressive development that reduces the amount of open space.

Action 19: Prevent and address landslide emergencies.

The plan does not analyse the legal causes of landslide hazards.

Existing landslide hazard maps and studies have not been taken into account in the development of the plan.

It does not take into account that the violation of architectural and urban planning laws is one of the most serious legal problems in Kazakhstan.

Action 21: Develop a comprehensive waste management strategy.

Local governments do not have sufficient authority to develop their own waste management strategies.

Action 22: Establish a construction and demolition waste recycling facility.

The plan does not address the issue of reducing waste production by reducing the destruction and demolition of existing facilities, including those already built during independence and illegally built facilities.

It does not consider the possibility of reconstructing exploitable facilities instead of demolishing them.

It does not take into account that the inexpedient ‘relocation’ (and in fact demolition) of the old airport building (which is a GCAP project) will be a source of construction and demolition waste.

It fails to consider that one source of construction and demolition waste is substandard construction and outdated technology.

Action 27: Develop a water conservation plan.

The plan does not take into account that water loss occurs in large part due to the destruction of watersheds, forests and air pollution over mountain ranges.