The Krtsanisi scoping opinion decides what 633 hectares gets assessed for

On 27 August the Spatial and Urban Development Agency filed Eagle Hills' development concept for Krtsanisi with the National Environmental Agency. The site is 633 hectares of state land on both banks of the Mtkvari, held by Eagle Hills Georgia under a two-year usufruct granted without charge. Gardabani municipality had announced in July that planning had begun; the area measures 6,335,813.3 square metres and was given special regulation territory status by a 2026 government resolution. The public comment period closed on 21 September. The next step is a scoping opinion from the National Environmental Agency and the National Center for Disease Control, which sets what the environmental impact assessment must examine.

The Organising Group for the Protection of Gonio-Krtsanisi submitted 18 pages of comments. Its central procedural claim is that the assessment asks how to build rather than whether or where, because the site was fixed before the review started — in a January 2025 memorandum, with a February 2026 decree transferring the land free of charge and the public learning of that decree only in August. The group says no alternative sites were assessed and asks for the restoration of Krtsanisi forest park to be evaluated properly as the zero option, alongside former industrial land in Tbilisi, Rustavi or Gardabani. It also says the fauna survey used no camera traps or bat detectors and that the stakeholder list omitted a petition of roughly 13,000 signatures. These are the group's submissions, not findings of the agency; the scoping opinion is where the regulator responds.

The government has announced Eagle Hills investment across Krtsanisi and Gonio at $6.6 billion, with roughly $3.4 billion attributed to Krtsanisi alone. The contracts are classified. The campaign group's financial objection is scale: it points out that UAE direct investment into Georgia across 2025 and 2026 runs under 3% of the Krtsanisi figure, and that a first-day sale of around 300 units would cover a small fraction of the stated investment. A separate Caucasus Business Journal report in April put the combined Krtsanisi and Batumi-area commitment at $6 billion with construction expected to start in early 2026. For anyone holding property nearby, the practical question is not which headline figure is right but how much of it is contractually committed — and that is the part nobody outside the contracting parties can currently see.

The second site lies entirely within the Emerald Network, the European network of areas of special conservation interest. No development concept for Gonio has been published. A March 2025 government decree already instructs the environment ministry to alter Emerald Network boundaries where required. That sequence — boundaries adjustable by decree, concept not yet public — is the reason the Gonio half of the project carries more regulatory uncertainty than the Krtsanisi half, and why anyone evaluating coastal land in that stretch should treat the current zoning as provisional rather than settled.