Statement on the project of a multi-purpose center near Heroes’ Square
The process of spontaneous urban development is not a new phenomenon for Tbilisi City, although in recent times it has acquired new dimensions.
The number of such projects involving the development of urban areas with an unusually high intensity for Tbilisi has increased considerably.
Often, construction is planned in areas that are unfavorable for construction and that have not been developed previously or only with low intensity.
At the same time, the functional characteristics of the areas also change considerably.
Such spontaneous and unplanned use of urban areas further reduces the chances of sustainable, stable, and rational development of the capital city.
One of the most vivid examples of this approach is the project of a multi-story and multi-functional center on Heroes’ Square, the development regulation plan for which, despite the sharp criticism from specialists and the general public, was approved by the City Council by Decree N 388 on August 25, 2023.
We believe that the planned development is in conflict with the principles of sustainable and stable development, the Law of Georgia on Cultural Heritage, and the principles and objectives of the master plan for land use and transport policy of the capital city.
The planned development will substantially alter the spatial-planning structure of the historical part of Tbilisi, destroy the potential connection of the open and recreational spaces of the Vere Gorge and the Mtkvari bank, and will have a negative impact on the traffic situation, due to the following arguments:
1. The large-scale risks associated with the project have not been properly examined.
When taking the decision, the municipality improperly examined and assessed the natural hazards relating to that decision and ignored the study data presented as part of the planning assignment.
It did not juxtapose private and public interests and made an asymmetric decision in favor of private interest in violation of the minimum standard of publicity.
As the decision-making process took place in an accelerated manner behind closed doors, representatives of the public were not given the opportunity to attend the meeting and present their arguments concerning the risks related to the project. In addition, the opinions of the experts present with respect to the decision were completely unjustifiably ignored.
Against this background, the superficial and indifferent attitude demonstrated towards natural hazards is alarming.
As known, the area of the former silk factory and swimming pool Laguna Vere was flooded in 2015 during the flood of the River Vere.
The pre-design study does not include proper information on the flood and potential risks.
In the preliminary engineering-geological study, no attention has been paid to this issue,
while in the section of the pre-design study where the ecological data of the project area are provided, extremely outdated and non-scientific information is given concerning the Vere River.
In particular, the article published in the newspaper Netgazeti (https://netgazeti.ge/life/5950/) in 2010 has been reproduced unaltered.
The document makes a general reference to the fact that the underground collector of the Vere River passes along the northern border of the area, and the protection areas will be determined at the next stage, in the framework of the development regulation plan.
The fact that the issue was not properly examined at the stage of the planning assignment of the development regulation plan is clear from the government’s resolution N 23.1252.1386 of August 22.
The municipality requires the applicant to protect the drainage and collector restriction areas and, if necessary, determine the appropriate measures at the next stage.
In the future, the provision of the position of the National Environment Agency and the master plan agreed with it that indicates the overall dimensions of the collector and the limitation areas is required.
The fact that the municipality considered it permissible to undertake one of the most large-scale constructions in the capital city in one of the most sensitive places in terms of the risk of geological processes, without properly examining and assessing the risks (including in the context of climate change) at the initial stage, is against the legislative principles of stable and sustainable planning as well as the decision-making by the administrative body.
2. Under the project, it is planned to cancel 3 hectares of the recreation area, which harshly violates the principles of the greening of the city.
The project area is located in the center of Tbilisi, in the immediate vicinity of Heroes’ Square, at the confluence of Mtkvari River and Vere Gorge.
It falls within the zone of regulation of the development of the historical part of Tbilisi, and according to the land use plan of the capital, it was given the status of recreation area 2.
The planned project envisages the change of the status of recreational area 2 for 3.3 hectares (33147 m2) to high-intensity public-business area 2.
In addition, only 25% of the buildings will be used for public and business purposes.
The remaining 75% is intended for residential use.
It is planned to partially preserve the existing former industrial buildings and construct two 40-story (170 m.) and 52-story (215 m.) buildings.
The project maximizes the use of open spaces.
Taking into consideration the specifics of the location and the large-scale nature of the planned development, the project area cannot be considered in an isolated manner.
It should be assessed in the overall context of Vere Valley and Mtkvari Bank.
Despite the infrastructural projects carried out at different times in the area of Heroes’ Square, the potential for connecting the open and recreational spaces of Vere Valley and Mtkvari Bank still exists.
The planned development will eliminate the possibility of creating a green corridor, which is especially alarming in light of the shortage of green spaces in the capital and the climate crisis.
This also contradicts the “green city” principles of the master plan for land use of the capital.
In addition, under the project documentation, the change in the status of the recreation area was presented as inevitable “due to the location on the edge of the active roadway” (pre-design study, feasibility study, development goal, pp. 96 and 98.
3. Such reasoning is cynical and only serves the private interests of the owner.
The municipality, on its part, considered this reasoning acceptable, ignored the public interest and unconditionally gave the green light to the change of the recreational function.
The planned development will eventually destroy the historical part of Tbilisi.
The planned construction will be the second and even more serious precedent of large-scale vertical and gross intervention in the historical part of Tbilisi after the Biltmore Hotel.
It will completely change the spatial-planning structure and panoramic views not only of Heroes’ Square but also of the historical part of Tbilisi as a whole, which directly contradicts the Law of Georgia on Cultural Heritage (Article 38).
It is also worth mentioning that the authors of the project ignore the recommendations of the historical-architectural study presented in their project documents, according to which such vertical development is not recommended and the choice of such a scale for the new development is emphasized, which does not suppress the neighboring objects (the circus building, Heroes’ Memorial, etc.)
(historical-architectural study, p. 15)
4. The planned construction is also problematic in terms of traffic.
Residential and office functions are one of the most passenger-intensive functions in relation to the development area, which are carried out simultaneously mainly during peak hours.
Such a development must be served by public transport of appropriate intensity. It must have good pedestrian connections for both public transport and other functions.
Otherwise, it is expected that a large share of the travel attracted and generated by the development will be carried out by individual vehicles, which not only is in conflict with the declared transportation policy of the City Hall but will also objectively create a whole range of problems for the city.
It is alarming that within the framework of the previous project documents, a high-quality study that uses more accurate calculations and appropriate simulation programs and that would comprehensively assess the risks of projects of similar intensity and location is not only unavailable,
even more, the presented assessment of the impact on transport is fragmentary and does not comply with the methodology and standard established in practice so far.
In addition, even the fairly conservative calculations of the presented deficient study clearly show the magnitude of the new traffic expected as a result of the planned, over-intensive development.
On the other hand, the Transport and Urban Development Agency tends to ignore these data and considers the planned development to be permissible with generic and formulaic text inappropriate for the project area in the letter/deed N 01232262998.
Due to the location of the project area, the high car traffic is a problem not only in terms of increasing the use of car in general, or of local congestion.
Hero’s Square and the right bank are important arteries of the city.
The right bank is a major and uncontested end-to-end link between the north and south directions of the city. Therefore, the overloading effect of the mentioned traffic nodes and arteries will apply to the entire city.
The presented argumentation clarifies the scale of risks and dangers, the path to which is opened by the decision of the Tbilisi City Council.
We believe that the public should resort to all possible legal means to have the said decision annulled in order to avoid the final destruction of the already heavily damaged urban and cultural system of Tbilisi.
Center for Urban Studies