Drainage Without Environmental Review: Who Authorised the Discharge of Water from Buzovna into the Caspian Sea?

The Ecology Ministry has confirmed that it did not receive the drainage-line project. However, the ministry has yet to disclose who allowed construction to begin without an environmental opinion or how the administrative investigation ended

A drainage line intended to carry groundwater and rainwater from Buzovna into the Caspian Sea was built without the project being submitted to Azerbaijan’s Ministry of Ecology and Natural Resources. This follows from an official response issued by the State Environmental Expertise Agency on August 17, 2026.

Mirsalam Ganbarov, chairman of the Agency’s Management Board, stated in response to an information request from the director of the Turan Analytical Service:

No application or project documentation concerning the matter has been submitted to the Ministry.

The response raises questions about whether mandatory environmental procedures were followed during the design and construction of the facility. This is not merely a pipe laid beneath a road, but an infrastructure line ending in the direct discharge of water into the Caspian Sea.

Ministry acknowledged signs of a violation

This is the environmental authority’s second response concerning the Buzovna project.

A July 2 letter from the State Environmental Security Service said that the May 25 appeal from the director of the Turan Analytical Service had been examined by officials of Regional Department of Ecology and Natural Resources No. 11 and the State Environmental Expertise Agency.

The ministry initially said that water-control issues fell within the powers of the Azerbaijan State Water Resources Agency and forwarded the appeal to the State Service for Supervision over the Use and Protection of Water.

However, the same letter contained a more significant acknowledgement: the necessary steps had not been taken to obtain an environmental-expertise opinion for the construction of the line.

Regional Department No. 11 consequently sent an official request to the United Water Supply Service of Large Cities. It sought supporting information and documents and raised the question of opening administrative proceedings against the responsible officials and legal entities.

The Ecology Ministry therefore effectively acknowledged signs of a violation as early as July. Its August response confirmed that the project had not been submitted for environmental review at all.

Neither response, however, identifies the project’s client, explains who authorised the start of construction or discloses the outcome of the administrative investigation.

Pipe first, documents later?

The lawful sequence should have been the reverse.

Before excavation and construction began, the client should have conducted engineering-geological and hydrogeological studies, identified the causes of flooding, determined the volume of groundwater and rainwater, prepared a project and assessed the consequences of discharging the water into the Caspian Sea.

The project should have specified the route and parameters of the pipeline, the location of inspection chambers, all connections, hydraulic calculations, the technical design of the sea outlet, measures against accidents, blockages and seawater backflow, and procedures for operation and laboratory monitoring.

The origin of the discharged water is particularly important. Describing it as “drainage water” does not in itself prove that it is safe.

In an urban environment, rainwater and groundwater may contain petroleum products, suspended solids, heavy metals, household waste and microbiological pollutants. The possibility of connections from private homes, sewer lines, commercial properties and other sources of polluted wastewater must be excluded.

Without answers to these questions, it is impossible to determine whether direct discharge into the sea is acceptable or whether preliminary treatment and continuous environmental monitoring are required.

The project should have undergone environmental review

Article 54 of Azerbaijan’s Law on Environmental Protection includes infrastructure projects among the objects subject to state environmental expertise.

The Rules for Conducting State and Public Environmental Expertise, approved by Cabinet of Ministers Resolution No. 184 of May 21, 2020, provide for the review of infrastructure projects, their feasibility studies and environmental impact assessment documents.

A drainage line crossing a populated area and discharging water directly into the Caspian Sea affects land, groundwater, the coastal zone and the marine environment. The project should therefore, at a minimum, have been submitted to the State Environmental Expertise Agency.

Whether a full environmental impact assessment document was required depends on the facility’s characteristics and scale. But that decision should have been made by the environmental authority after reviewing the project, not unilaterally by the client or after construction had been completed.

Because the ministry did not receive the project, it could not assess environmental risks in advance, require changes to the technical design or impose operating conditions.

One sample does not replace an environmental review

The Khazar District Executive Authority previously reported that a water sample had been collected from the inspection chamber closest to the sea. According to the Central Laboratory of the United Water Supply Service of Large Cities, no pollutants were detected.

However, analysis of a single sample cannot replace an environmental review.

Such a sample reflects the composition of the water only at a particular place and time. It does not show conditions after heavy rainfall, seasonal changes in groundwater or possible intermittent polluted discharges. Nor does the analysis prove that there are no other connections to the line.

For an objective assessment, samples should be collected repeatedly:

• from several inspection chambers;
• before the sea outlet;
• directly at the discharge point;
• from seawater on both sides of the outlet;
• during dry weather and after rainfall.

Testing should cover not only general indicators but also petroleum products, suspended solids, nitrogen and phosphorus compounds, heavy metals, surfactants and microbiological indicators.

The results of this monitoring should be publicly available to Buzovna residents.

Who commissioned the project?

The central question is who made the decision to build the line.

The replies from government agencies still do not identify:

• the project’s client;
• the design organisation;
• the contractor;
• the source of financing;
• the owner of the drainage line;
• its future operator;
• the authority that permitted excavation and construction;
• the organisation responsible for restoring the road.

There was no information board at the construction site. Residents could not obtain information about the client, contractor, work schedule or technical supervision.

Construction continued for approximately three months. A plastic pipe about 30 centimetres in diameter and around 300 metres long was laid through central Buzovna. The line was installed at a depth of approximately 1.3 metres and was equipped with four inspection chambers and five connections.

Although hydraulic testing was completed, the road surface remained unrestored for an extended period. The work obstructed cars, buses and pedestrians.

These circumstances require answers not only from environmental and water agencies but also from the State Committee for Urban Planning and Architecture, the Ministry of Emergency Situations, the Khazar District Executive Authority and the organisation that commissioned the project.

What should the Ecology Ministry do now?

The Ecology Ministry should not limit itself to stating that it did not receive the project. The absence of the project is precisely what creates grounds for a comprehensive investigation.

First, the ministry should identify the client, contractor, designer, owner and future operator. It should request documents from the State Water Resources Agency, the United Water Supply Service of Large Cities, the Khazar District Executive Authority and the State Committee for Urban Planning and Architecture.

It should then obtain:

• the construction project;
• hydrogeological studies;
• hydraulic calculations;
• the construction permit or notification-procedure documents;
• technical specifications;
• the discharge permit;
• certificates for concealed works;
• test reports;
• technical-supervision documents;
• all laboratory results.

Regional Department of Ecology and Natural Resources No. 11 should conduct an on-site inspection with the participation of the State Environmental Expertise Agency and water-control bodies.

The inspection should verify the pipeline’s actual route, all chambers and connections, the true source of the water, the sea outlet and the condition of the coastal area.

The results should be recorded in an official inspection report rather than remaining limited to correspondence between agencies.

Can the line be operated?

Until the required procedures have been completed, the competent authorities should consider suspending unfinished construction, prohibiting commissioning or temporarily halting discharge into the sea.

If state environmental expertise was mandatory, the line should not be operated without a positive environmental opinion.

Submission of the project after construction has been completed should not become a formality used to approve an existing facility. Experts should examine several alternatives, including preliminary water treatment, relocation of the outlet, reuse of the water or abandonment of direct discharge into the sea.

If the project’s safety cannot be demonstrated, the line should not operate in its present form.

What happened to the administrative investigation?

In its July letter, the Ecology Ministry said an official request had been sent to initiate administrative proceedings. The August response says nothing about the results.

The ministry should disclose:

• whether administrative proceedings were opened;
• which documents were obtained;
• who was identified as responsible;
• whether an administrative offence report was drawn up;
• whether binding instructions were issued;
• whether the work was suspended;
• whether the violations were remedied;
• whether anyone was held accountable.

If no proceedings were opened, the ministry should explain why the action officially announced in July was not completed.

The absence of a project is not a final answer

The State Environmental Expertise Agency’s statement that the project was not submitted to the Ecology Ministry should be the beginning of an investigation, not its conclusion.

The state authority has effectively confirmed that infrastructure with a direct outlet into the Caspian Sea was built without prior environmental review.

The authorities must now establish who decided that the project could proceed without environmental expertise, on what basis the work began and who is responsible for any potential consequences.

The government agencies’ responses still do not provide a complete picture. One institution refers to another, while the project’s client and legal basis remain unknown.

But the pipe has already been laid and its outlet is directed toward the Caspian Sea. The issue is therefore no longer limited to which documents were missing. The central question is whether the state will enforce environmental law after the violation has been officially identified.

Official sources: Law on Environmental Protection, Rules for Conducting State and Public Environmental Expertise, Law on Water Supply and Wastewater, and the Code of Administrative Offences.