<!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.0 Transitional//EN">
<HTML><HEAD>
<META content="text/html; charset=utf-8" http-equiv=Content-Type>
<META name=GENERATOR content="MSHTML 8.00.6001.23588">
<STYLE></STYLE>
</HEAD>
<BODY bgColor=#ffffff>
<DIV><FONT size=2 face=Arial></FONT><BR> </DIV>
<DIV dir=ltr>
<DIV dir=ltr>
<DIV class=gmail_quote>
<DIV dir=ltr>
<DIV><BR></DIV>
<DIV>
<DIV class=gmail_quote>
<DIV dir=ltr class=gmail_attr>From: <B dir=auto class=gmail_sendername>eugene
simonov</B> <SPAN dir=auto><<A
href="mailto:coalition@riverswithoutboundaries.org"
target=_blank>coalition@riverswithoutboundaries.org</A>></SPAN><BR>Date: пт,
8 нояб. 2024 г. в 05:20<BR>Subject: Rogun HPP Project Consultations in Tashkent
and future consultations in absence of valid Environmental and Social
Instruments<BR></DIV><BR>
<DIV dir=ltr>Dear President Banga:<BR><BR>We are surprised that after 10 months
of inaction, the World Bank and Rogun HPP PMG have all of a sudden announced a
series of consultations with very little notice. We feel that those are not
meaningful consultations conducted in a good faith, but rather a chaotic
box-checking exercise designed to help pave the way for the imminent Board
approval of the Rogun HPP in the absence of valid environmental and social
instruments.<BR><BR>We were also informed by Mme Proskuryakova that the Rogun
HPP ESIA has expanded the Area of Influence (AOI) to include the downstream
sections of the Vakhsh and Amu Darya rivers and assessments have been already
performed. However, no new assessments reports on downstream impacts have been
disclosed for comment.<BR><BR>Several representatives of the Rogun Alert
Coalition participated in the meeting organized by the World Bank and Rogun HPP
Project on October 28 in Tashkent and concluded that those consultations fell
short of any basic requirements for meaningful consultation, including those
prescribed in the World Bank’s ESS 10.<BR><BR>Consultations were announced only
a week in advance without much effort to inform potentially affected communities
in riparian countries. <BR><BR>No agenda was provided at the time of invitation,
and when it arrived a day later the items it included were not accompanied by
corresponding draft assessment studies, leaving participants without documents
they could meaningfully comment on. <BR><BR>No comment period was indicated
despite specific requests from CSOs to disclose for consultation key documents
relevant to the topic of consultations. We were told that those reports are not
ready yet and invited instead to comment on the “ESIA/ESMP which has been
disclosed since last December” and the “updated Non-Technical
Summary.<BR><BR>The meeting was not supported by any disclosed assessment of
impacts on riparian countries, and no up to date assessment of downstream
impacts in riparian countries were included in the 2023 ESIA materials.
Meanwhile, the previous 2014 ESIA included an extensive chapter solely dedicated
to impacts on riparian countries downstream of Vakhsh hydropower cascade.
<BR><BR>We were also made to believe that an updated assessment cannot be
commissioned any time soon as it should be based on updated current information
on climate change, hydrology, sedimentation processes, socio-economic situation
and water use in riparian countries as well as analysis of changing policies,
legislation and treaties. Some of these baseline studies were only recently
commissioned by the Rogun HPP project, while other studies were completely
omitted. All in all, the current ESIA is not based on up-to-date information and
therefore cannot be treated as a credible assessment from which to draw
conclusions and plan mitigation measures. <BR><BR>The presentations shown on
October 28 did not fully correspond with the announced agenda, were selective in
covering only favorable aspects, and contained contradictory statements.
Although the agenda featured “findings of the ESIA” and “biodiversity
management”, the first presentation titled “Introduction the Rogun Hydropower
Project” did not present ESIA findings on impacts in any credible form. The
presentation included only one slide on negative impacts, while these would
typically be the focus of any ESIA. Speaking of absence of any alternatives to
Rogun HPP, the presenter lamented “in future solar and wind could
contribute, but now it is not advanced enough technology and too expensive”
when, in fact, in 2023 the cost of solar PV installation was on average 4 times
less expensive than for hydro, while 50% of newly capacity installed globally in
2023 was for solar and wind versus only 2% for hydropower.<BR><BR>Dr. Zwahlen,
who was supposed to present about cumulative impacts demonstrated deep disregard
for on-going efforts and agreements presently implemented by governments and UN
agencies to sustain what is left of the Southern Aral Sea– Amu Darya River
delta, stating that measures implemented for saving Aral Sea “did not keep it
from shrinking further” anyway. Based on that derogatory statement, he insisted
that the fact that Rogun reservoir filling will decrease the volume of water
delivered to the Aral by at least 25% is “insignificant” and does not require
further impact assessment. He then suggested that a dedicated part of the 2014
ESIA on impacts on riparian countries was excluded from the 2023 ESIA
documentation “because we already discussed that ten years ago”. It was
extremely disturbing to learn that this person single-handedly prepared the
cumulative impact assessment (CIA), which will be the only section of the ESIA
dealing with the assessment of downstream impacts. We were also concerned to
learn that two drafts of the CIA report prepared by July and October have not
been disclosed for public consultation.<BR><BR>The ESIA team largely failed to
answer any substantive questions from the audience, including those on the
mandatory World Heritage impact assessment, cumulative assessment for extreme
circumstances (such as dam malfunction or failure), climate risk assessment,
etc. Finally, when a local participant asked to describe the main findings of
the ESIA, there was no answer at all. The project representatives repeatedly
minimized the impacts of Rogun, yet were forced to concede that assessments
supporting that claim are not ready yet.<BR><BR>The experience of the
consultations in Tashkent clearly showed that in the absence of good faith on
the side of the World Bank and PMG and intentional non-disclosure of documents
relevant to consultations, there is no room left for meaningful dialogue, nor
for getting credible answers to questions asked by CSOs. <BR><BR>We were further
informed by World Bank staff that the updated ESIA/ESMP and the other
environmental and social instruments will not likely be disclosed for
consultation prior to the World Bank’s expected Board meeting, and would only be
disclosed after Board approval. <BR><BR>We request that the ESIA Report
(including Volume II which contains actual technical data on ESIA findings
demonstrating its credibility), the Cumulative Impact Assessment, Biodiversity
Management Plan, Resettlement Action Plan 2, and Emergency Response Plan for
Vakhsh Cascade undergo consultations before the project financing decision, and
that they be disclosed for comment at least 2-4 weeks prior to consultation.
<BR><BR>We are also surprised that the Stakeholder Engagement Plan (SEP) mainly
consists of reports on stakeholder engagement that happened 10-15 years ago and
contains little information on ESIA consultation after official disclosure of
the draft report in December 2023. The SEP must contain a coherent plan for the
sequence of pre-appraisal public consultations on essential assessment studies
listed above. Instead, we heard vague promises of “several meetings to be held
in riparian countries” without dates, names of countries, or a clear agenda. We
are also surprised that at least 9 letters with substantive questions sent by
CSOs to the World Bank in 2024 are omitted in the SEP and request that those be
included with a matrix of responses in standard table format.<BR><BR>On November
4, we received from the World Bank an invitation to new international
consultations with CSOs, hastily scheduled for November 14. While we welcome the
World Bank’s willingness to consult with us, we would like to point to multiple
discrepancies with good practice and the World Bank’s ESS 10:<BR><BR>1.
Announcement arrived only 10 days before the consultation date, which makes it
difficult to fit in already busy schedules,<BR>2. Invitation is addressed to a
dozen of international groups, thus ignoring other potentially interested
stakeholders,<BR>3. As of November 5, there was no announcement even on the
dedicated project website, which makes us doubt that any genuine effort is made
to inform the public,<BR>4. Topic and arrangements for the consultations are
vague, e.g. to “Address concerns on E&S and technical issues in more
detail”, “Further explore stakeholder engagement”, etc. If the plan was to give
us oral answers to our previous letters, we insist on receiving these responses
in writing,<BR>5. No disclosed documents are listed as the subject of upcoming
consultations. Again, as in the earlier meeting, the proposed consultation is
not “based on the prior disclosure and dissemination of relevant, transparent,
objective, meaningful, and easily accessible information in a time frame that
enables meaningful consultations ” (ESS 10, para 22),<BR>6. No commenting period
was indicated nor any information given on the reporting process by which
outcomes of the consultation meetings and subsequent commenting will
be summarized and incorporated in the ESIA report.<BR><BR>We believe that
further “in-depth exchange” that you asked for is impossible without the proper
inclusion of interested stakeholders, advanced disclosure of essential
assessment studies for comment, and setting a clear and equitable procedure that
ensures that consultations are meaningful.<BR><BR>We kindly ask you to
reschedule consultations from November 14 to a time by which you can provide us
with a coherent set of disclosed reports, reflecting new ESIA assessments, and
which would form the subject of the
consultations.<BR><BR>Sincerely,<BR><BR>Rivers without
Boundaries<BR><BR>CounterCurrent<BR><BR>International
Rivers<BR><BR>Socio-ecological union international<BR><BR>World Heritage
Watch<BR></DIV></DIV></DIV></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV style="FONT: 10pt arial">
<DIV style="BACKGROUND: #e4e4e4; font-color: black"><B></B> </DIV>
<DIV style="BACKGROUND: #e4e4e4; font-color: black"><B></B> </DIV>
<DIV style="BACKGROUND: #e4e4e4; font-color: black"><B>From:</B> <A
title=bulat.yessekin@gmail.com href="mailto:bulat.yessekin@gmail.com">Bulat
Yessekin</A> </DIV>
<DIV><B>Sent:</B> Friday, November 08, 2024 2:34 PM</DIV>
<DIV><B>Subject:</B> Обращение к президенту Всемирного банка</DIV>
<DIV> </DIV></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV></DIV></DIV></DIV></BODY></HTML>