Georgia’s Ministry of Environmental Protection has effectively confirmed to Batumelebi that the project planned by the Arab company Eagle Hills in Gonio will affect a protected area in the Chorokhi River delta.
According to the ministry, if necessary, “the issue of implementing compensatory measures for a small part of the Emerald Network territory [where development is planned] will be determined.”
To facilitate Eagle Hills’ investment projects in Krtsanisi Park and the areas adjacent to Gonio, the Georgian government, by a decree issued in March 2025, instructed the Ministry of Environmental Protection and Agriculture to “carry out appropriate measures, as needed, to adjust the boundaries of protected areas within the Emerald Network framework.”
Batumelebi requested written information from the ministry on what specific measures have been taken or are being taken to adjust the boundaries of protected areas within the Emerald Network.
In its written response, the Ministry stated:
“Development projects require a Strategic Environmental Assessment (SEA) procedure. Taking into account the state policy on the sustainable management and protection of biodiversity, the Ministry of Environmental Protection and Agriculture, in compliance with national and international legislation, will ensure the implementation of SEA procedures in relation to projects planned for the Gonio and Krtsanisi areas.
The purpose of the SEA is to minimize negative impacts on the environment and human health,” the Ministry wrote to Batumelebi.
As for the Chorokhi Delta, which is part of the Emerald Network protected area, the Ministry says that during the project review process it will assess the expected impact and take into account the international agreements to which Georgia is a party.
“An assessment will be conducted of the anticipated impact of the project planned in the Gonio area on the Chorokhi Delta Emerald site [GE0000054]. If necessary, the issue of implementing compensatory measures for a small part of the Emerald Network territory [where development is planned] will be determined.
In reviewing the projects, the Ministry will be guided by the requirements of national legislation and the international environmental agreements to which Georgia is a party. All necessary assessments and decision-making related to the major investment projects planned in the Gonio and Krtsanisi areas will be carried out in full compliance with these requirements,” the Ministry of Environmental Protection and Agriculture wrote.
The Ministry does not specify what exactly is meant by “compensatory measures.”
Batumelebi also requested the Ministry to provide information on the boundaries of the Emerald Network protected area in the Chorokhi Delta as of March 17, 2025, and the same boundaries after any adjustments reflecting the current situation (including relevant maps and the size of the protected area before and after the adjustment).
“If the boundaries have not yet been adjusted, please indicate approximately how many square meters the Emerald Network protected area in the Chorokhi Delta is expected to be reduced by,” Batumelebi wrote.
The Ministry did not provide this information to Batumelebi.
Eagle Hills Projects in Gonio and Krtsanisi
The investment agreement signed with Eagle Hills, under which USD 6.6 billion worth of development projects are to be implemented in Tbilisi and Adjara creating new residential and tourism infrastructure has been classified as a commercial secret.
The ruling party Georgian Dream claims that the project has no flaws and that the confidentiality of the agreement is a standard practice.
However, political scientist Lela Jejelava argues that the deal represents yet another “trick and scheme” by Ivanishvili. She does not believe that Arab-style cities will actually be built in Georgia.
Georgia Is Not the Only European Country Where Eagle Hills Plans, Implements, or Negotiates Investment Projects
Georgia is not the only country in Europe where Eagle Hills is planning, implementing, or negotiating investment projects. As it turns out, questions surrounding the company’s investments have been raised in other countries as well.
Any potential dispute arising under the investment contract signed with Eagle Hills will be reviewed under British law, Prime Minister Irakli Kobakhidze has stated.
The company Eagle Hills Georgia LLC was registered in Tbilisi on April 28, 2025. Its director is Hisham Mohamed Ibrahim Soliman, a dual citizen of Egypt and the United Arab Emirates. At the time of registration, 100% of the company’s shares were owned by Jaona Investment LLC (United Arab Emirates).
For several years, the ruling Georgian Dream party has been discussing plans to develop the territory of the former military training ground (polygon) in Gonio. Concept plans were prepared, yet to this day the area has not even been fully demined.
Despite this, in 2016, Georgian Dream brought other Arab investors to the site. In 2017, the government developed an investment concept for the former Gonio polygon, though that concept differs significantly from the renderings recently presented by Eagle Hills Georgia.
In 2019, the Ministry of Defense told Batumelebi that “almost half of the territory has already been demined; due to climatic conditions, the work is difficult and therefore the demining process is ongoing.”
The Russian army left the former Gonio military polygon in 2005 without clearing it of mines. In February 2010, three members of the Bilvanidze family were killed by an anti-tank mine collected as scrap metal on the site. At the time, the Ministry of Defense stated that demining would likely be completed by the end of 2010.
Ahead of the 2021 local self-government elections, Georgian Dream once again announced plans to develop the former Gonio polygon, but after the elections, the project was once again forgotten.
Five months after the company’s founding, in September 2025, the shareholder structure of Eagle Hills Georgia changed. This time, 100% of the shares were transferred to Eagle Hills Development Holding Limited (United Arab Emirates).
On November 18, 2025, Eagle Hills Georgia again applied to the Public Registry; however, the registry rejected the request to register changes to the company’s charter and legal address due to deficiencies. The company corrected these deficiencies on November 20, after which the changes were registered.
According to the Georgian government, the State of Georgia will acquire a 33% stake in Eagle Hills Georgia, and the company will receive for investment purposes the territory of the former Gonio military polygon (260 hectares) and the Krtsanisi forest park (590 hectares). According to the latest Public Registry records, both territories remain state-owned.
Update: According to a Public Registry extract dated December 2, 2025, 66.67% of Eagle Hills Georgia is owned by Eagle Hills Development Holding Limited (UAE), while 33.33% is owned by the State of Georgia, with the Ministry of Economy and Sustainable Development registered as the managing authority of the state share.
Following the announcement of the new Arab investment, the continuation of demining works at the former Gonio polygon was once again placed on the agenda. Alongside the Ministry of Defense, the Delta Scientific-Technical Center was also involved in the process.
The Chorokhi Delta and the Emerald Network
According to the Ministry of Environmental Protection and Agriculture, the Emerald Network is a pan-European ecological network aimed at ensuring the long-term survival of internationally important species of wild fauna and flora and their habitats, based on shared principles among participating countries.
The establishment of the Emerald Network is a mandatory requirement under the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention, 1979) and serves as one of its key mechanisms.
Emerald sites ensure the protection and long-term survival of endangered species protected under the Bern Convention, including migratory species.
Under Annex XXVI of the EU–Georgia Association Agreement, and in accordance with Article 6 of the Habitats Directive (92/43/EEC), any project requiring a license must undergo an Appropriate Assessment, meaning an assessment of its impact on the Emerald Network.
Chorokhi Delta: A Critical Ecological Zone
The Chorokhi Delta (shown in standard boundaries in purple on official maps), with the Eagle Hills investment area (the former military polygon) marked in red, is entirely located within the boundaries of the Emerald Network site “Chorokhi Delta” (GE0000054). The map is taken from the Chorokhi Delta Emerald Site Management Plan, which, according to the Ministry, remains a draft working document.
Batumi is also part of a 10-kilometer-wide bird migration bottleneck, ranked third in the world after Mexico and Israel in terms of the number of migratory birds. Each year, more than one million birds of prey migrating from Eurasia to Africa pass through Adjara’s skies. The Chorokhi Delta forms a key part of this migration corridor and is itself included in the Emerald Network.
Despite its importance, the Chorokhi Delta is effectively left without state management.
In 2021, 36,000 GEL from the state budget was allocated to develop the Chorokhi Delta Emerald Network Management Plan (GE0000054). However, as Batumelebi has learned, this management plan has not been implemented for four years.