Bank for Development and Reconstruction… and Reproduction!

Аэропорт123Good intentions

In November 2020, the European Bank for Reconstruction and Development (hereafter—EBRD) approved a “syndicated loan of up to $229.4 million” to finance the development of infrastructure at Almaty International Airport (hereinafter—ALA) and improve the level of services on its territory, including the construction of a new passenger terminal.[1]

“With the construction of a new international terminal, the modernisation of the domestic terminal, and the adoption of IATA’s [The International Air Transport Association] Optimum Level of Service standards, the airport will be able to provide better quality aeronautical services and expand its commercial space to offer a wider scope of non-aeronautical services. The involvement of TAV Airports, a global and experienced airport operator, will improve the connectivity, service quality and will help develop ALA’s potential as a major regional transit hub. This Project will be the first large-scale foreign direct investment in the airport infrastructure sector in Kazakhstan and the largest across the Central Asia region.”

Аэропорт1234They wanted to do it according to the law.  It turned out as always

Everything would be fine, but there was one problem. The airport’s VIP terminal building, built in 1947, stood in the way of the implementation of the largest transaction of its kind in Central Asia. And the trouble is, it turned out to be a historical and cultural monument of local significance in accordance with Kazakh legislation.[2]

There is nothing to be done; the issue must be resolved in accordance with the requirements of national legislation. And the following explanation appeared in the EBRD project: “As part of the terminal expansion, the existing building of VIP terminal will need to be relocated. This building has both historical and cultural significance and protected under the national legislation.” This formulation was fully consistent with the spirit of the bank’s Environmental and Social Policy. “EBRD will not knowingly finance, directly or indirectly, projects involving the following: … (c) Activities prohibited by host country legislation or international conventions relating to the protection of biodiversity resources or cultural heritage.”[3]

Then “legal” improvisation began, if not casuistry. “A Cultural Heritage study, conducted by an international specialist firm, confirmed that: (a) VIP terminal is not critical cultural heritage; (b) the building relates to a replicable cultural heritage, and its main structural elements can be salvaged for subsequent preservation; (c) types of expertise required to preserve the replicable elements of the building ex situ or reintegrate them into the building of a new terminal. The government supported key recommendations of PR8 [cultural heritage] study, and the client re-confirmed its commitment with regards to the preservation of the key structural elements of the VIP building.” [4]

Firstly, the project developers obviously got something wrong. There is a concept of reproducible resources. However, what is “reproducible cultural heritage”? This is an “invention” of the International Finance Corporation, which is used in the manual on cultural heritage sites. In any case, there is no such definition in the legislation of Kazakhstan. Secondly, it seems that the creators of the project are deliberately juggling various terms. Either move, then dismantle, then reproduce! As a result, the building was simply demolished, retaining key structural elements. Third, the claim that the government “supported the key recommendations of the study” is highly questionable. In the resolution of the Akimat[5] of the city of Almaty dated November 11, 2020 No. 4/492 “On the relocation (перемещение) of the historical and cultural monument of local significance Airport (International Lines Airport),” paragraph 2 states: “To the municipal state institution Department of Culture of the City of Almaty:

1) When transferring, ensure the integrity and safety of the monument;

2) Take other measures arising from this resolution.”

No dismantling, much less demolition, was even planned. What a disobedient Akimat!

Fourthly, Article 29 of the Law “On the Protection and Use of Objects of Historical and Cultural Heritage” [6] states:

“1. Relocation and changing a historical and cultural monument is a change in the position of the historical and cultural monument in space, its appearance, space-planning and design solutions and structures, interior and other physical characteristics reflected in the passport of the historical and cultural monument.

  1. Relocation or changing a historical and cultural monument is prohibited.

An exception is allowed only in cases of destruction of more than seventy percent of a historical and cultural monument or loss of historical and cultural significance, or if its movement and change will lead to an improvement in the conditions for its preservation …

  1. Individuals and legal entities that received the decision, when relocating or changing a historical and cultural monument, are obliged to ensure the conditions for its preservation!”

What national law was the EBRD guided by when deciding to dismantle “not critical” cultural heritage? By the way, there is no such concept in the legislation of Kazakhstan either.

Everyone knows where the road paved with good intentions leads. The case with the airport VIP terminal building was no exception. 

Аэропорт новый 6How can we understand you now?

The public of the city of Almaty was extremely concerned about the plans to relocate the historical and cultural monument. There was and is no such experience in Kazakhstan. According to independent experts, as a result of the “transfer” (relocation), the historical building could have been completely lost.

On December 28, 2020, public hearings were held on the project “Assessment of the environmental impact for the period of operation and reconstruction, expansion and development of the passenger terminal building and platform, and associated infrastructure facilities at the Almaty International Airport.”

At the hearings, representatives of the public put forward a demand to make changes to the Almaty airport reconstruction project to preserve the old building.

In November 2022, unfortunately, as part of a project financed by the EBRD, a cultural heritage site of local importance in Almaty— the airport VIP terminal building—was demolished. In 2023, its copy was erected on Akhmetov Street.

We believe that the EBRD violated its own Environmental and Social Policy, which does not allow financing activities prohibited by the laws of the host country!

On October 16, 2023, the Eсоlogical Society Green Salvation sent a letter to the Director of the European Bank for Reconstruction and Development for Kazakhstan with a request to inform what measures the bank plans to take in connection with violation of the requirements of its Environmental and Social Policy. There was no response until early December.

This is a violation of another policy point, namely EBRD Project Implementation Requirement 10: Information Disclosure and Stakeholder Engagement. The first paragraph of the introduction of Requirement 10 states: “In particular, effective community engagement, appropriate to the nature and scale of the project, promotes sound and sustainable environmental and social performance, and can lead to improved financial, social and environmental outcomes, together with enhanced community benefits.” What benefits did the population receive from the demolition of the airport’s VIP terminal?

On December 5, 2023, the Ecological Society sent a new appeal to the EBRD. On December 20, the long-awaited answer arrived.

Of course, the EBRD considers that the Environmental and Social Policy has not been violated. “All concerns and requests from the public, activists, and CSOs [Civil Society Organizations] were given careful consideration, and detailed responses had been provided throughout the consultation process.”

“Furthermore, to address your concern regarding the lack of in-country expertise in Kazakhstan to relocate the historic buildings, the sponsors hired one international heritage consultancy to carry out the heritage assessment and an another international heritage firm to guide the preparation and implementation of the VIPT [VIP terminal] relocation process (Mott McDonald).”

The sponsors considered three options.

Option 1. Keep the historic VIPT building in its original location and build a new terminal adjacent to it (proposed by the Project);

Option 2. Replace the existing VIPT building with a new International Passenger Terminal to the south, with the new terminal taking its place (proposed by the Project);

Option 3. Use the design features of the historic VIPT and integrate them with new features as part of the new passenger terminal (proposed by the stakeholders).”

“Following an in-depth analysis of each alternative and a series of public consultation meetings, the option 2 was selected as the most viable and realistic alternative.” The terminal was demolished. The EBRD does not deny this fact, but provides the following arguments to justify it.

“It needs to be borne in mind that the historic VIPT building was an element within a much larger culturally significant landscape, i.e. extending along Mailin Street and terminating at the airport garden forecourt and historic VIPT. This culturally significant resource had lost much of its landmark status over the years through subsequent development. Mitigation to offset the loss of the historic VIPT has consequently devoted a lot of attention to recovering as much of the eroded significance of the larger cultural landscape as possible.” Not a monument, but a cultural landscape!

Expert opinion is, of course, a significant argument, but not final and not binding. According to paragraph 12 of the Normative Resolution of the Supreme Court of the Republic of Kazakhstan dated July 11, 2003 No. 5 “On court decisions in civil cases”: “The expert’s opinion does not have an advantage over other evidence and is not binding on the court. It must be assessed in conjunction with other evidence.”

The letter does not contain one, apparently, in the EBRD’s opinion, insignificant detail. There is no reference to the law, according to which the demolition of the monument was recognized as “the most viable and realistic alternative.” As mentioned above, in Article 29 of the Law “On the Protection and Use of Objects of Historical and Cultural Heritage,” the movement of historical and cultural monuments does not imply their demolition. Moreover, paragraph three of this article states that “individuals and legal entities who have received the decision, when relocating or changing a historical and cultural monument, are obliged to ensure the conditions for its preservation!” The conditions for the preservation of the monument have been met, but what about the preservation of the monument? How can we understand you now, gentlemen?


“3.702 Moving buildings (передвижка зданий): a complex of construction works, including the installation of foundations in a new location, preparing a rail track, separating the building from the foundation, placing a rigid metal structure under the walls and columns of the building, installing devices that provide normal conditions for people in the building, moving the building along the rail track using electric winches.”[7]

“3.972 Building demolition (снос зданий): Purposeful, often forced, activity to liquidate a construction site, due to a number of reasons or physical and moral deterioration of the construction site.”[8]


© Ecological Society Green Salvation, 2024.

[1] Almaty International Airport expansion:

[2] Resolution of the Akimat of the city of Almaty dated November 10, 2010 No. 4/840 “On approval of the State List of Historical and Cultural Monuments of Local Significance of the City of Almaty,” paragraph 73:

[3] Environmental and social policy. As approved by the Board of Directors at its Meeting on 7 May 2014,  Appendix 1:

[4] Almaty International Airport expansion.

[5] Akimat is a local executive body.

[6] Law of the Republic of Kazakhstan dated December 26, 2019 No. 288-VI “On the Protection and Use of Historical and Cultural Heritage Objects” (as amended on May 1, 2023).

[7] Construction terminology. Technology and organization of construction. SP RK 1.01-102-2014. Astana, 2015, p.61.

[8] Ibid., p.82.