Uzbek Resort in UNESCO Site Sparks Environmental, Legal Concerns

Public hearings in Gazalkent, in Uzbekistan’s Tashkent region, have revealed significant controversies surrounding the Sea Breeze Uzbekistan investment project. The project involves constructing an all-season resort complex–effectively a new town for 10,000 residents–on 577 hectares within the Ugam-Chatkal National Natural Park on the shores of the Charvak Reservoir. The event, attended by officials including the Bostanlyk district khokim and the Tashkent region deputy khokim, as well as local residents, experts, journalists, and bloggers, raised numerous questions about the ecological safety of a region that serves as the primary source of drinking water for the capital.
The project’s regulatory framework is centered on Cabinet of Ministers Decree No. 490, dated August 1, 2025. This decree permits the investor, Sea Breeze Uzbekistan LLC, to conduct construction and installation work concurrently with the development of project design and cost estimates until the end of 2029. This provision directly conflicts with Uzbekistan’s Urban Planning Code and the Law on Ecological Expertise, both of which prohibit construction from starting without an approved project and a positive state environmental review. Despite the absence of an Environmental Impact Assessment (EIA), preliminary work–including soil removal and foundation site leveling–has already commenced on the mountain slopes. The project’s “exception” status, as defined in the decree, effectively removes it from the legal framework governing nature protection, which explicitly forbids any activity that threatens the preservation of natural complexes in protected areas.
The resort’s proposed location is a source of particular concern. The Ugam-Chatkal National Park is part of the Western Tien-Shan, a designated UNESCO World Heritage Site. Under international conventions ratified by Uzbekistan, the state is obligated to ensure the integrity of these territories. A mission from UNESCO and the International Union for Conservation of Nature (IUCN) that visited the region has already identified serious threats. The construction of large-scale infrastructure, landscape alteration, and potential water pollution contradict the site’s status as a unique natural area. Furthermore, the developer’s plans to introduce non-native species such as palm trees for landscaping violate the Law on Protected Natural Areas, which prohibits the introduction of alien species that could disrupt the local ecosystem.
Water supply and wastewater management remain the central environmental challenges of the project. The Charvak Reservoir supplies drinking water to Tashkent and the surrounding region. The Sea Breeze project includes a proposal to lay a 1400 mm diameter sewer main at a cost of $10 million. The technical viability of this solution is questionable, as similar schemes have previously resulted in sewage leaking directly into the water. At the hearings, representatives from the water utility, Suvtaminot, confirmed plans to lay the pipes but could not guarantee a complete seal or the absence of emergency discharges within the water protection zone. The increased load on the treatment facilities in the city of Chirchik, where the sewage is to be directed, is also a major concern. Uzbekistan’s Water Code establishes the unconditional priority of using water resources for the population’s drinking needs and prohibits the discharge of any wastewater into drinking water sources.
The situation is compounded by climatic factors. Observations in recent years, including the low-water year of 2025, show a consistent trend of shrinking glaciers in the Pskem and other rivers that feed the Charvak Reservoir. Amid climate change and periodic droughts, the reservoir often fails to fill to its design capacity. The construction of a resort city with high water consumption will place additional strain on the region’s water balance. Hydrological modeling predicts further shifts in flood periods and reduced river flow, threatening not only the resort’s viability but also the water security of millions of people dependent on the Chirchik river basin.
During the hearings in Gazalkent, local residents, farmers, journalists, and bloggers sought answers regarding the project’s compliance with environmental regulations but received no specific clarification from investors or officials. While Uzbekistan participates in international climate conferences and receives grants for biodiversity conservation, the implementation of large commercial projects often conflicts with its declared goals of “green” development. Experts warn that ignoring the environmental risks associated with the Sea Breeze project could lead to the irreversible degradation of the unique Western Tien-Shan ecosystem and a decline in drinking water quality for the capital region.
