The Audit project has been realized with financial support of OSI-AF
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▪The audit of Contractor by the BTC;
▪External audits. (ЕISA. Section 6.4.4.1.)
Observation:
The contractor was not audited by BTC/SCP. Representatives of BTC/SCP state that
cultural heritage management is out of Contractor’s responsibility, they have control
over it. Therefore there is no need to conduct an audit of CCIC on cultural heritage.
They did not show any document proving this argument. Only external audit and audit
by “Oxford Archaeology ” was conducted. But there were no self provision documents
of Contractor.
Non-conformance:
According to commitments it was intended that contractor would provide self-provision
(point 6.4.4). But this activity was not implemented.
Recommendation:
Cultural Heritage Protection is very sensitive field. Therefore, self-provision is very
necessary. Contractor has to discuss this issue and take into consideration in its
activities.
3.1.4. Commitment:
According to ESIA documents the strategy plan on the Cultural Heritage Protection
should be developed with the Gobustan State Historical Artistic Reservation.
Observation:
The development of documents has not completed yet. During the trip a head of the
Gobustan State Historical Artistic Reservation expressed her discontent about that.
Analysis:
It was intended in ESIA to develop Strategic Plan on Cultural Heritage Protection along
with Gobustan State Historical Artistic Reservation. This plan has not been developed
yet.
Recommendation:
It is recommended to accelerate preparation of the Strategic Plan for Protection of
Cultural Heritage along with the Gobustan State Historical Artistic Reservation
3.2. The Audit Performance of SCP in Meeting Commitments
Group members visited Gobustan State Artistic Reservation to conduct an audit of
commitments.
It is known that a pipeline is very close to one of the worldwide important monuments –
The Gobustan State Historical Artistic Reservation (900 meters of the pipeline passes
through 400 meters depth of territory of the reservation). The BTC/SCP tried to
minimize influence on reservation according to the commitment concerning this issue.
3.2.1. Commitment:
According to the SCP commitments 647 (650) on the Cultural Heritage Protection: «The
pipeline has been routed as close to the boundary of the Gobustan Cultural Reserve as
possible, through a relatively disturbed area and away from known locations of
archaeological significance. Trial trenching will be conducted in this area to determine if
there are any archaeological features present and a mitigation strategy will be
The Audit project has been realized with financial support of OSI-AF
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developed in accordance with the Cultural Heritage Management Plan (Part 2a,
Baseline Appendix)».
Observation:
The archeologists of the company held trainings for the contractor staff. Important
measures were taken in educating archeologists, as well as slideshows prepared on the
base of archeological findings were presented to the staff members. We would like to
outline the role of archeologist of the company in this issue.
Analysis:
The audit group evaluates this issue as positive.
3.2.2. Commitment:
According to the SCP commitments 206 (156) on the Cultural Heritage Protection: ”The
pipeline has been routed to avoid known or potential archaeological sites where
practical”; According to the ESIA and Cultural Heritage Protection Plan SCP should
minimize negative impacts to the cultural heritage and must strengthen positive
impacts.
Observation:
According to commitments BTC should minimize the influence to the Gobustan State
Historical Artistical Reservation. But it wasn’t achieved properly. The pipeline has
separated one part of the Gobustan State Historical Artistical Reservation. State
Special Security Service is causing some difficulties for the experts to enter the
reservation. As a result of this that area is out of reservation’s control. We could not
check it because the weather was rainy and there was no transport-“Land Cruiser”. The
employees of the reservation caused us obstacles to conduct an audit. So we have
taken the opinion of the director as a ground.
There is no plan for emergency event case. This problem might even extend if we
consider the growth of the reservation.
Analysis:
As a result of wrong planning the part of the reservation area was separated into two
parts and one of the separated parts was left uncontrolled after the pipeline was built.
The commitment was not fully implemented. This is considered as a negative case.
Recommendation
Immediate measures must be taken to have a control over reservation area, which was
left uncontrolled as a separation of the reservation area into 2 parts. Taking into
account the world-wide importance of the Gobustan state artistic reservation the risks to
reservation must be assessed, insurance issues must be clarified and strategies for
emergency cases must be developed.
3.2.3. Commitment:
According to the SCP commitments 214 (164) on the Cultural Heritage Protection: “The
BTC Owners are currently discussing the possibility of working in conjunction with the
Azerbaijan Ministry of Culture to develop a management plan for the Gobustan Cultural
Reserve.”
Observation:
The SCP is providing a fruitful work together with Ministry of Culture of the Azerbaijan
Republic department of “ Exploration and Protection of Monuments”; Special committee