The True Cost of Green Energy: How the Hyrasia One Project Could Impact Mangistau’s Nature

Text by Aliya Wedelich

The Hyrasia One project, which the Swedish-German firm Svevind Energy Group is planning in the Mangistau region of Kazakhstan, is set to become one of the world’s largest green hydrogen producers. By harnessing solar and wind power, it aims to generate up to 40 gigawatts of renewable electricity, which will produce up to 2 million tons of “green” hydrogen or up to 11 million tons of green ammonia per year. However, biologists and environmental activists warn that this green vision conceals serious environmental risks and threats.

Scale and location of implementation

The project includes building five renewable energy clusters on an area of about 5,500 km² and an industrial complex of about 70 km² near the port village of Kuryk on the Caspian Sea coast.

Since the project initiators did not present a scheme of the location of the planned clusters in relation to existing protected areas, activists tried to recreate it themselves - based on scattered data from the developers' speeches. The scheme presented above is not an official document.

Each cluster will consist of wind turbines and solar panels that capture wind and sunlight to generate electricity. According to the project website, the wind farms and solar farms will provide 27 gigawatts and 13 gigawatts of electricity, respectively. The wind farms will consist of more than 5,000 wind turbines with a hub height of 150 meters, for a total height of 225 meters. The solar plants will cover a total area of 150 km².

This area is a unique landscape of cold winter deserts, with rich biodiversity and historical and cultural heritage. Here are the most important habitats and migration routes of gazelles, kulans, honeyeater and Persian leopard, as well as the flight paths of the Steppe Eagle and other rare birds.

Threats to wildlife

HYRASIA ONE LLP's Statement of Proposed Activities dated September 2, 2024 states that “areas of high natural value were excluded from planning at the earliest stage of pre-project works”.

However, according to environmentalists, this cannot be said for the two planned clusters “Rakhym” and “Kanaghat”, the plans for the creation of which are of particular concern to them. The fact is that, according to the project, they will be located between specially protected natural territories: Ustyurt State Nature Reserve, the projected cluster of this reserve “Southern Ustyurt” (Kazakhstan) and the national park “Southern Ustyurt” (Uzbekistan).

According to experts and eco-activists, the construction of these clusters could lead to:
- destruction of ecological corridors and habitats of rare species,
- disruption of migration routes,
- increased disturbance and poaching activity,
- bird mortality from collisions with wind turbines and overhead power lines (OPL).

The project is already in conflict with wildlife interests before it has even moved to the construction stage. The area reserved for the Kanaghat cluster overlaps with the area where the South Ustyurt cluster is planned. These plans to expand the Ustyurt reserve have been developed over many years with the participation of the reserve itself, the Ministry of Ecology and Natural Resources of Kazakhstan and environmental organizations. According to unofficial information, now this territory may not be transferred to the reserve. Aliya Wedelich, editor of Ecostan News, sent official inquiries to the Committee of Forestry and Wildlife and the Akimat of Mangistau Oblast to clarify the situation.

Ecologists have expressed all these concerns in written appeals both to the top officials of the Federal Republic of Germany, the country that provided investment guarantees for the project, and to the project management in Kazakhstan, as well as to the Ministry of Ecology and Natural Resources of the Republic of Kazakhstan.

Already now, according to BRCC and ACBK, tens of thousands of birds die on power lines in Kazakhstan every year. Installation of wind turbines and construction of infrastructure without an environmentally sound approach may exacerbate the situation.

The public has not been heard

Three Kazakhstani non-governmental organizations - EcoMangistau, EcoMuseum and BRCC - with the support of international experts sent an appeal to Bundestag deputies, German President Frank-Walter Steinmeier and three key ministers - Foreign Affairs, Economy and Climate Protection, and Environmental Protection - on February 10, 2025. The letter expresses serious concerns about the environmental risks associated with the Hyrasia One project and emphasizes the need for a transparent, science-based and inclusive approach to the selection of sites for wind and solar installations in Kazakhstan.

According to the authors, the selection of sites for construction was done without full discussion with local residents, environmentalists and the scientific community. The sites presented on the company's website are presented as already approved, without explaining the logic behind the selection or consideration of alternatives. Environmentalists insist: priority should be given to the complete elimination of damage to nature rather than its compensation - this principle is enshrined both in Kazakhstan's international obligations (including the Paris Agreement) and in the provisions of the country's Environmental Code.

German ecologist Til Dieterich is among those who signed the appeal to the first persons of the Federal Republic of Germany. Til represents the German Nature Conservation Union (NABU), being the chairman of its expert group on Eastern Europe, Caucasus and Central Asia, and is also the director of biodiversity at the Karaganda EcoMuseum. He learned about the project when, in June 2023, the German president traveled not to Astana but unexpectedly to Aktau:

“Then it became clear that the matter was serious. My colleagues and I immediately sounded the alarm, because it turned out that they wanted to locate green hydrogen production near the Ustyurt reserve, in an almost untouched desert zone, where there are still no roads, power lines or lighting. We know these areas well - we have been working there for more than 10 years, seeking the nomination of the reserve for inclusion in the UNESCO World Heritage List.

Why choose particularly vulnerable ecosystems instead of using existing industrial zones? There is still no clear answer to this question. The public and independent scientists were not involved in the selection of sites, public hearings were either not held or became a formality. And now, significant investments have been made in pre-project studies in locations that have raised serious environmental concerns from the outset.

In addition, this represents a major economic risk to the success of the Hyrasia project: if the German public realizes that 'green' hydrogen from Kazakhstan is not really green, exports may simply not take place.”

Meanwhile, the Hyrasia One project website reports that the environmental impact assessment (EIA) and environmental and social management plan (ESMP) will not be published until the end of 2025. In a previously published statement on the proposed activity, the company has already rated potential impacts on bird and bat populations and migration routes as “moderate in magnitude” and “long term”.

Another author of the appeal, Nurlan Ongarbayev, head of BRCC and member of the Public Council under the Ministry of Ecology and Natural Resources of the Republic of Kazakhstan, notes:

“To date, representatives of the Ministry of Ecology in assessing the consequences of the project are focused mainly on water use and air quality issues. At the same time, the current system of environmental control does not fully cover the risks to biodiversity. This creates vulnerabilities in the protection of national interests and opens the way to obtaining permits even in the case of serious threats to unique flora and fauna - or for violation of the Ecocode in the formal presence of all necessary documents.

All this is happening against the backdrop of the fact that the President of Kazakhstan has twice this year emphasized in his speeches the priority of biodiversity conservation as a key direction of the state environmental policy”.

What else is troubling activists?

The answers to the activists' concerns will probably be in the EIA, which the company promises to publish by the end of the year. Hyrasia One promises that this assessment will be “the largest in the history of the Republic of Kazakhstan” and that “both national requirements and international EIA standards” will be taken into account. The EIA is being conducted by the German company FICHTNER.

To better understand the environmental risks of the project, the eco-activists asked the company's management:
- Information on the boundaries of all proposed production sites;
- A report on the results of the assessment conducted for the selection of seven production sites;
- Results of environmental and social studies conducted by the hired contracting organization;
- Detailed characteristics of the transmission lines;
- Planned detailed projected technical solutions for biodiversity conservation;
- Annual Report or Sustainability Report by the project shareholder/s for 2023.

In their response, the company representatives promised that stakeholders will find most of the answers in two documents: the Pre-EIA, which should be published on the company's website in the first half of 2025, and the EIA by the end of the year.

Kirill Osin, Head of EcoMangistau, says that the company's response was in a friendly tone:

“The company's management, represented by the regional director and a member of the Management Board of Hyrasia Energy LLP, has stated its readiness for any interaction with the interested public and expressed its intention to share information. But so far, nothing is happening. The company said it is conducting studies and has promised to provide all information on the results.”

In the September 2, 2024 proposed activity statement No. KZ44RYS00756082, the company acknowledges potential impacts on biodiversity but does not provide transboundary impact assessments despite its proximity to the borders with Uzbekistan and Turkmenistan. The volumes of water intake from the Caspian Sea (up to 93 million m³ per year) and discharge of treated wastewater (up to 43 million m³ per year) also raise questions about long-term impacts on marine ecosystems.

In addition, the project plans to:
- transformation of large natural areas for roads and infrastructure,
- construction of hundreds of kilometers of overhead power lines,
- possible groundwater abstraction and utilization, especially in such an arid region as Mangistau.

Are there any alternatives?

Environmentalists propose to relocate the most problematic clusters “Rakhym” and “Kanaghat” to already disturbed - anthropogenically modified - lands - for example, industrial areas near Aktau and Zhanaozen or former territories of oil and gas development. This would allow to:
- preserve wildlife,
- utilize already existing infrastructure (roads, power lines),
- attract local specialists and simplify logistics.

“We do not understand why the German project seeks to locate hydrogen production in pristine wilderness when there are extensive industrial areas in the region that have been used by the oil and gas industry. Utilizing such areas in combination with alternative energy sources would avoid the destruction of natural ecosystems. Moreover, these areas already have developed infrastructure (roads, power lines) and are closer to settlements where future workers can live,” the Kazakhstani eco-activists said in their appeal to the first persons of the Federal Republic of Germany.

In the meantime, Svevind and its Kazakh partners continue to move forward, only partially publicizing information about the project.

What to do?

The Hyrasia One project has the potential to be a breakthrough - or failure - in the history of green energy in the region. For it to become a true example of sustainable development, it needs to:
- Conduct an independent and open environmental assessment involving all stakeholders,
- Revise the location of a number of clusters, especially Rakhym and Kanaghat,
- Ensure access to full biodiversity data and the results of environmental studies for the public and specialists,
- ensure access of representatives of local communities and NGOs to the decision-making process.

“We are ready for an open dialog to find equitable and sustainable solutions for the production of truly green hydrogen in Kazakhstan - including on the Caspian Sea coast. This process must take place with the mandatory participation of local communities and civil society. This requires public access to complete and reliable information about the project to be able to influence key environmentally significant decisions,” the Kazakhstani activists say. They add that they count on “the rich experience of democratic governance in Germany to make this project an example of a just energy transition in Kazakhstan - for the benefit of our countries and the entire region.

The authors of the appeal are still waiting for a response from the German leadership. Til Dieterich explains what mechanisms for participation are available within the country and why it is necessary to act now:

“Theoretically, there are mechanisms in Germany - you can initiate official petitions, or through opposition parties submit a so-called “small parliamentary inquiry” (Kleine Anfrage) to the Bundestag. This requires effort, but it can move the situation.

The problem is that the project has been formalized as a private one - through the German company Svevind. Where they will get the money and who will invest it is still unclear. We suspect that the information is deliberately withheld until the last minute so that public control mechanisms are not activated. Therefore, the sooner we start making noise, the more chances there are that the situation will change.”