83360 Report on 2nd Riparian Information-Sharing and Consultation Meetings on the Assessment Studies of the Proposed Rogun Hydropower Project November 6-7, 2012 World Bank Regional Office, Almaty, KZ Prepared by Europe and Central Asia Region World Bank In partnership with the Independent Engineering and Dam Safety and Environment/Social Panels of Experts for the Rogun Assessment Studies 2nd Riparian Information-Sharing and Consultation Meetings on the Assessment Studies of the Proposed Rogun HPP November 6-7, 2012 EXECUTIVE SUMMARY This report describes Riparian Information-Sharing and Consultation Meetings held on November 6-7 for the Assessment Studies of the proposed Rogun Hydropower Project (HPP). This report provides the context for this assessment and riparian process, the main findings presented and topics discussed at the meetings. The report also documents comments received from participants both at the meetings and as received separately, along with responses provided by the technical experts. Context: The Government of Tajikistan (GoT) is studying the potential benefits and risks of the proposed Rogun Hydropower Project (HPP) to comprehensively evaluate its technical, economic, social, and environmental viability. Two assessment reports are being undertaken: a Techno-Economic Assessment Study (TEAS) and an Environmental and Social Impact Assessment (ESIA). In response to a request by the Government of Tajikistan and several riparian governments, the World Bank is providing support to ensure the studies are completed in accordance with the World Bank’s policies and procedures, meet international standards, and are objective and transparent. As part of its engagement, the World Bank coordinates two independent Panels of Experts (PoEs) that scrutinize the technical quality of the Assessment Studies. In order to share intermediate findings and ensure that the diverse perspectives of the potentially affected stakeholders in the riparian countries are heard and understood, the Bank also supports a riparian consultation and information sharing process. The riparian process began with consultations on the Assessment Studies’ Terms of Reference (2008/9) followed by a first set of information sharing and discussion meetings in May 2011. On November 6th and 7th, 2012, the World Bank hosted the 2 nd Riparian Information-Sharing and Consultation Meeting. Representatives from five governments (Afghanistan, Kazakhstan, Kyrgyz Republic, Tajikistan, and Turkmenistan) and 45 CSOs (from the aforementioned countries and Uzbekistan) participated along with 38 members of development partner community. Consultants’ presentations were followed by comments from the PoEs and discussion among the participants and technical experts. Materials were posted online and comments were accepted by e-mail or mail to the World Bank over a six-week period ending November 25, 2012. Environmental and Social Screening Report: One of the key objectives of the meeting and review period was to share the Screening Report of the ESIA (ESSR). The ESSR prepares the scope of work for the ESIA by identifying potential physical, biological and human impacts that may require focused research and analysis. The ESSR led to discussion on several issues, including relocation of cultural and religious sites, legal and administrative platforms, information on upstream flows, and natural habitats. Stakeholders viewed three issues as most important for deeper examination: resettlement, potential impact on downstream flows and climate change:  The meeting clarified that resettlement has ceased except for already occurring resettlement due to safety- related maintenance in and around the construction site. This maintenance and safety-related resettlement will be subject to a Resettlement Audit and monitored against the national laws of Tajikistan, t he Bank’s operational policy on resettlement (OP 4.12) and international standards. The Assessment Studies will examine potential future resettlement associated with filling of the proposed Rogun HPP reservoir which will include a Resettlement Policy Framework and a Resettlement Action Plan that will be disclosed and satisfactory to international standards. Participants raised concerns on livelihoods, the grievance mechanism and the capacity to access it, and impact on historical sites (particularly cemeteries). While it appears communities are well informed, the need to address these issues in the studies was emphasized.  Several participants questioned the potential changes in downstream flows. The Government of Tajikistan has committed to staying within the obligations of the Nukus Declaration. Nonetheless, potential changes in flows at the border with Uzbekistan will be assessed under a variety of scenarios (for both filling and operational modes of the entire Vakhsh cascade), and using various hydrologic conditions. Transboundary assessments of the middle and lower reaches of the Amu Darya will be undertaken should potential changes at the border in either volume of flow or flow patterns in the agricultural seasons indicate impact.  Participants in the meetings repeatedly raised the issue of climate change. The PoEs recommended that the consultants first analyze relevant available information and models on climate change in the Amu Darya Basin but emphasized that it be integrated into the study. Additionally, riparians raised concern that the ESSR mentions that “construction is ongoing at the site”. The Government confirms, and the World Bank has verified, that all non-maintenance-related work at the site has ceased in accordance with the Bank’s conditions for continua tion of the assessment process. The reason for the discrepancy is that the ESSR was prepared prior to the implementation of this agreed cessation of non-maintenance work. Until the assessment process concludes, no water will be diverted and works on site will be limited to maintenance and safety-related works, as agreed by the Government of Tajikistan and publically affirmed by both Tajikistan and the World Bank. The World Bank will continue to monitor site conditions on a bimonthly basis. Techno-Economic Assessment Study: The agenda for the TEAS focused on Design Criteria and interim findings on hydrology and geology.  The Design Criteria define safety standards consistent with international guidelines. The Government of Tajikistan has adopted the internationally recognized highest level of safety for the most significant types of risks, adhering to the guidelines of ICOLD (International Commission on Large Dams). ICOLD requires that hydrological safety adopts the Probable Maximum Flood (PMF) in the design of the structures, and seismic safety adopts the Maximum Credible Earthquake (MCE) in the structural design of dam and appurtenant works. Design criteria apply to all aspects of the proposed project -- existing and potential works.  The ongoing Hydrology Study considers characteristics of the Vakhsh river basin, inflows at the site of the proposed project, floods, and potential impacts of climate change. The consultants affirmed that existing hydrology data are adequate to complete the study, which was corroborated by the PoEs.  The Engineering Geology studies reported on site investigations such as drilling, geophysics, rehabilitation of exploratory audits, and hydrogeology. Based on preliminary results and numerous site visits, the initial opinion of the Panel is that the: o Suitability of the dam site and type of dam can be confirmed o Salt structure below the dam site can be appropriately managed to ensure operational safety Other issues of discussion included sedimentation impacts, possibility of increased mudflows, catastrophic dam failure, the Ionaksh fault and springs in the right upstream side, and the permeability conditions of dam abutments. The findings on geology are preliminary and will be updated at the conclusion of the site investigations. Next Steps: Based on their expert opinions and the verbal and written feedback from participants in the Riparian Program, the PoEs made several recommendations to the Government of Tajikistan. Integration of these recommendations into the Assessment Studies will be monitored by the World Bank. A third set of information-sharing and consultation meetings is planned for February 2013 to review the status of consultants’ assessments and share findings. Possible topics include: resettlement and infrastructure replacement costs for different dam alternatives, geology and site investigations, and hydrology and cascade modeling. A fourth set of information-sharing and consultation meetings is planned to discuss the draft TEAS report regarding economic, social, environmental and technical viability and optimized project configuration, and the associated draft ESIA report. Dialogue with stakeholders on the assessment process is critical to ensuring that their relevant perspectives and comments are heard and understood. This dialogue is also an important opportunity for progress on regional water and energy resource management issues more broadly. The World Bank welcomes the continued participation of riparian governments, civil society and other stakeholders. Table of Contents 1. Introduction ............................................................................................................................... 1 2. Proposed Rogun Hydropower Project Assessment Studies and Riparian Information Program 2 a. Assessment Studies for Proposed Rogun Project ............................................................................... 2 b. Rogun Riparian Information Program ............................................................................................... 2 c. Broader Role of the Bank in the Assessment Studies ........................................................................ 3 3. Previous Information Sharing ............................................................................................................. 5 a. Rogun Assessment Studies Terms of Reference (2008/2009) .......................................................... 5 b. May 2011: Information Sharing and Discussion Sessions on the Inception Reports ......................... 6 4. 2nd Riparian Information-Sharing and Consultation Meetings on the Assessment Studies of the Proposed Rogun HPP (November 6-7, 2012) ..................................................................................... 7 5. ESIA Screening Report (ESSR) .......................................................................................................... 9 a. Purpose of ESSR ................................................................................................................................ 9 b. Summary of Presentations .................................................................................................................. 9 c. Highlights of Comments and Responses .......................................................................................... 11 6. Interim studies for Techno-Economic Assessment Studies (TEAS) ............................................. 14 a. Overview of TEAS Progress ............................................................................................................ 14 b. Summary of Presentations ................................................................................................................ 14 c. Highlights of Comments and Responses .......................................................................................... 15 7. Cross-Cutting Issues .......................................................................................................................... 17 8. Recommendations by the Panels of Experts to the Government of Tajikistan ........................... 18 9. Next Steps ........................................................................................................................................... 20 10. Annexes ............................................................................................................................................... 21 a. Agenda ........................................................................................................................................... 21 b. Participants at CSO 2nd Information-Sharing and Consultation Meetings (November 7, 2012) ... 22 c. Matrix of Comments on Rogun Assessment Studies with Responses ........................................... 29 d. List of November 2012 Information-Sharing and Consultation Materials available on www.worldbank.org/ECA/Rogun ................................................................................................. 59 Report on 2nd Riparian Information-Sharing and Consultation Meeting on the Assessment Studies of the proposed Rogun HHP November 6-7, 2012 World Bank Regional Office, Almaty, Kazakhstan 1. Introduction On November 6th and 7th, the World Bank hosted the 2nd Riparian Information-Sharing and Consultation Meetings on the Assessment Studies of the proposed Rogun Hydropower Project (Rogun HPP). The sessions were held at the Bank’s regional office in Almaty, Kazakhstan. Government and CSO representatives participated on their respective days and development partners joined the CSO sessions as observers. These meetings were the latest in a series of engagements with riparian1 stakeholders on the proposed project. The purpose of the meetings is to enable the incorporation of stakeholder concerns and opinions into the ongoing Rogun HPP Assessment Studies process. This report describes the Bank’s engagement in the Assessment Studies, the milestones in the riparian program, the key documents presented and discussed during the meetings, the recommendations to the Government of Tajikistan (GoT) based on the meetings, and the next steps in the process. It details the meetings held on November 6-7, 2012 in Almaty, Kazakhstan and subsequent written feedback. More details about the World Bank’s engagement in the Assessment Studies of the proposed Rogun HPP can be found at: http://worldbank.org/eca/rogun More details on the 2nd Riparian Information-Sharing and Consultation Meetings specifically can be found at: http://go.worldbank.org/2TFMJZIRY0 Rogun Riparian Information Sharing Program Terms of 1st Riparian 2nd Riparian 3rd Riparian 4th Riparian Reference Meetings Meetings Meetings Meetings (2008/09) (May 2011) (November 2012) (early 2013) (2013) Explanation of Inception reports E/S Screening Report proposed project Riparian program Hydrology (Presentation) and World Bank Introduction to Design criteria policies Panels of Experts Geology (Presentation) Draft ToRs 1 The six riparian countries are Afghanistan, Kazakhstan, the Kyrgyz Republic, Tajikistan, Turkmenistan, and Uzbekistan. 1 2. Proposed Rogun Hydropower Project Assessment Studies and Riparian Information Program a. Assessment Studies for Proposed Rogun Project In response to a request by the Government of Tajikistan and several riparians, the World Bank is supporting two studies to evaluate the viability of the proposed Rogun Hydropower Project (HPP) according to international standards:  Techno-Economic Assessment Study (TEAS)  Environmental and Social Impact Assessment (ESIA) The Assessment Studies examine the potential benefits and risks of the proposed Rogun HPP and comprehensively evaluate its technical, economic, social, and environmental viability based on international standards and practices, and in accordance with the World Bank’s policies and procedures. The studies will provide the Government of Tajikistan, the World Bank, the other Central Asian countries and the international community with information about key elements associated with the proposed Rogun HPP, such as the proposed project’s technical soundness, safety, economic viability, and environmental and social impacts, including potential changes in water flows in downstream countries. These Assessment Studies are being conducted by international consultant firms contracted on a competitive basis by the Government of Tajikistan and financed through an IDA project with assistance of World Bank experts. The procurement process was overseen by the World Bank. A consortium led by Coyne & Bellier is undertaking the TEAS (contract signed on February 8, 2011) while Poyry is undertaking the ESIA (contract signed on March 25, 2011). These studies are one factor in informing the decision on the proposed project. The studies will not provide a conclusion on whether the Project should be built. That will be the ultimate decision of the Government of Tajikistan, informed by discussions among the Governments of Kazakhstan, the Kyrgyz Republic, Tajikistan, Turkmenistan, Uzbekistan, and Afghanistan (hereafter referred to as “riparians”) and with other stakeholders, development partners, and financiers. b. Rogun Riparian Information Program A key element in the World Bank’s involvement in the Rogun Assessment Studies is to ensure communication and openness, given the significance of the proposed project to all six riparian countries. This began a process to engage each country and to bring countries and civil society together to share knowledge, information and expertise. The Rogun Riparian Program consists of a series of information sharing and discussion sessions to be held over the study period, complementing regular channels of dialogue with stakeholders (e.g. press releases, consultations by the ESIA consultants, web updates, etc). This program is essential to share interim findings and ensure that the diverse perspectives and points of view of the affected stakeholders in the riparian countries are heard and understood. The purposes of the Riparian engagement are:  To ensure credible, transparent assessments that benefit from international scrutiny  To encourage dialogue among riparians 2  To respond to the request of riparian governments with the support of international financial and donor communities  To ensure the highest quality of the assessment studies and a process that considers stakeholder concerns. The Riparian Program involves the participation of the following riparian governments: Afghanistan, Kazakhstan, the Kyrgyz Republic, Tajikistan, Turkmenistan, and Uzbekistan, as well as Central Asian Civil Society Organizations (CSOs). The involvement of the International Panels of Experts, the World Bank, and the ESIA and TEAS consultants helps to inform the discussion among riparians. The approach involves three channels for exchange: face-to-face meetings (such as the May 2011 and November 2012 Riparian Information-Sharing and Consultation Meetings), video-conferences, and web outreach and information sharing (http://worldbank.org/eca/rogun). While continuous dialogue is essential to the process, the Riparian Program is most active during key stages of the study process such as consultation on ToRs (2008/2009), when discussing inception reports and the structure of the study process (May 2011); the design criteria and ESIA screening report (November 2012); and project options, site investigations, water management and the draft ESIA and TEAS reports (2013). c. Broader Role of the Bank in the Assessment Studies In addition to the riparian information program, the Bank also convened and is coordinating two independent Panels of Experts (PoEs) to perform due diligence and ensure that the studies conform to international quality standards. The PoEs are composed of internationally-recognized professionals; their role is to review the results of the assessment studies, help facilitate communication of concerns raised by stakeholders, and convey their views to all interested parties. They formally communicate their recommendations and assessment, drawn in part from riparian dialogue, to the Government of Tajikistan and the World Bank. The Panels were also available for detailed discussions with riparians, and, at the end of the assessment, each Panel will furnish their independent reports on the overall assessment incorporating riparian input. In addition, the World Bank has a team of multi-disciplinary specialists who have direct access to work of both consultants; this team is closely reviewing the interim documents of the consultants. During the summer of 2012, the World Bank reached agreement with the Government of Tajikistan to align work at the site with the studies. This has led to the cessation of all non-maintenance-related work at the site and resulted in a monitored decrease in public spending. Until such time as the assessment process concludes, no water will be diverted and works on site will be limited to a maintenance schedule (as agreed by the Government of Tajikistan earlier this year). These commitments have been publically affirmed by both Tajikistan and the World Bank. The World Bank has committed to supporting the Assessment Studies and riparian engagement only. This does not imply that the Bank will financially support the proposed project itself. For more information on the Bank’s engagement on the Assessment Studies of the proposed Rogun HPP, please visit: http://worldbank.org/eca/rogun. 3 The World Bank’s Engagement on Water and Energy in Tajikistan and in Central Asia The World Bank’s involvement in the Assessment Studies is supported by the Bank’s energy engagement in Tajikistan and the Bank’s broader efforts to support sustainable energy and water resource management across Central Asia. The World Bank’s engagement in the Tajik energy sector addresses the immediate problems of Tajikistan’s winter electricity shortages as well as the long term sustainability of the energy sector. The Assessment Studies of the Rogun HPP are one aspect of the Bank’s support to Tajikistan, but the Bank is also engaging with Tajikistan on a study of electricity supply options, hydrometeorology services modernization, and the proposed CASA-1000 regional electricity transmission system. The Bank’s overarching goal is to help the Tajik people receive reliable, affordable electricity all year round. The World Bank recognizes that the sound management of water resources for both irrigation and power generation is critical for the sustainable development and growth of all the countries in Central Asia, as is sound energy resource management. Through the Central Asia Energy and Water Development Program (CAEWDP), the World Bank supports efforts to increase energy and/or water security through national level efforts (such as in Tajikistan) as well as by promoting relevant, mutually beneficial regional cooperation and dialogue. For more information on the Bank’s engagement on energy and water issues across Central Asia, please visit: http://worldbank.org/eca/caewdp. 4 3. Previous Information Sharing In addition to the World Bank and Government of Tajikistan’s websites2, information has been shared and input received on two separate, formal occasions, as summarized below.3 a. Rogun Assessment Studies Terms of Reference (2008/2009) The World Bank held initial consultations with the riparians on the Terms of References (ToRs) for the Assessment Studies (ESIA and TEAS) in 2008-2009. The consultations had the following objectives: (i) Understand the riparian country’s views on the potential construction of the proposed Rogun HPP in particular and the development of Vakhsh River basin in general; (ii) Obtain comments and inputs on the draft ToRs to ensure that the ESIA adequately addresses all possible impacts that the proposed Rogun HPP individually or in connection with other proposed developments in the Vakhsh cascade may have on riparian countries; (iii) Explain the Bank’s rules, procedures and safeguard policies applicable to such large projects with cross border implications, and (iv) Discuss broader regional issues of energy and water resources development in Central Asia. The chronology of events is as follows: Date Event 27-06-08 Meeting in Tashkent between the First Deputy Prime Minister and the World Bank Country Manager for Uzbekistan (as part of the new Conference on the Aral Sea discussions). 30-09-08 Consultations in Ashgabat, Turkmenistan. 01-10-08 Consultations in Astana, Kazakhstan. 03-10-08 Consultations in Bishkek, the Kyrgyz Republic. 05-10-08 Consultations in Kabul, Afghanistan. 20-01-09 Consultations in Tashkent, Uzbekistan. 11-03-09 World Bank Group Statement on Water/Energy Developments in Central Asia. 14-09-09 Follow up consultations in Ashgabat, Turkmenistan 15-09-09 Follow up consultations in Tashkent, Uzbekistan 08-03-10 World Bank provides no objection to the ToR 03-05-10 Requests for Proposals sent to short-listed candidates 10-06-10 Three proposals were received for TEAS and one for ESIA As a result of the consultations, the ToRs were revised, including:  specification of both local and riparian impacts in the objectives of the ESIA,  detailing of the impact on river flow regime,  addition of a set of tasks in the ESIA ToR dealing explicitly with impact assessment in riparian countries, 2 http://www.barkitojik.tj/eng/index.php?option=com_content&task=view&id=66&Itemid=49 3 The World Bank and Government of Tajikistan have, additionally, shared information with riparians separately through bilateral channels, such has correspondence. 5  an additional paragraph on upstream and downstream water regulation,  additional references to safety related to seismic and tectonic conditions,  provisions for an instrumentation plan for monitoring the behavior of the dam through its lifetime and an emergency preparedness plan have been added to the risk evaluation and assessment report, and  linkages between the TEAS and ESIA studies to ensure consistency. For more information on the ToRs and on the consultation process for them, see: http://siteresources.worldbank.org/INTECA/Resources/VakhshConsultations.pdf. b. May 2011: Information-Sharing and Discussion Meetings on the Inception Reports The first information-sharing and discussion meetings on the Assessment Studies for the proposed Rogun HPP took place on May 17-19, 2011 in Almaty, Kazakhstan. The purpose of the meetings was: 1) to introduce the international independent Panels of Experts convened to review the two Assessment Studies, 2) to provide information to the riparian countries about the current status of the Assessment Studies and the work program, and to review the draft inception reports on the two studies; and 3) to seek feedback and input from the participants on the program of information sharing and discussions with governments and civil society organizations in the region. Government representatives from four countries (Kazakhstan, the Kyrgyz Republic 4 , Tajikistan, and Turkmenistan) welcomed the opportunity to have an open and constructive discussion at the regional level. The concerns they raised included the issues of dam safety, availability of water flow downstream, and the transparency of the study process. Similarly, representatives from 80 civil society organizations – from Kazakhstan, Kyrgyz Republic, Tajikistan, and Uzbekistan, as well as some international nongovernmental organizations – focused on issues such as scope of the Assessment Studies, importance to take into account both irrigation and energy needs, seismic safety of the proposed dam, potential impact on the downstream countries, impact of climate change, resettlement of population in the potential reservoir area, and greater engagement of the civil society and local population in the study process. Participants agreed that information-sharing and involvement of all riparian countries are critical for the openness, transparency, and credibility of the study process. For more information and documents related to the first meetings, visit http://go.worldbank.org/UVHOMD76O0 4 Participation as observer 6 4. 2nd Riparian Information-Sharing and Consultation Meetings on the Assessment Studies of the Proposed Rogun HPP (November 6-7, 2012) The second information-sharing and consultation meetings took place on November 6-7, 2012, in Almaty, Kazakhstan with Government and CSO representatives. The purpose of the meetings was to discuss the draft Screening Report (ESSR) which is a precursor to the ESIA, and the draft Design Criteria of the Techno-Economic Assessment Study (TEAS). These documents do not provide final results but will guide future work on both studies. The agenda is included as Annex A. The meetings provided an opportunity for riparian governments and civil society representatives to review the building blocks of the Assessment Studies and members of two independent Panels of Experts to present their perspectives on the work to date and discuss their technical reviews. After presentations on the draft Screening Report and draft Design Criteria, participants interacted directly with the consultants, experts, and World Bank staff to provide feedback and share their concerns. The Government of Tajikistan and World Bank disclosed draft documents (ESSR and Design Criteria) in English and Russian approximately three weeks before the meetings. On November 6, riparian government representatives from Afghanistan, Kazakhstan, Kyrgyz Republic, Tajikistan, and Turkmenistan appreciated the opportunity to have an open and productive discussion at the regional level. In Almaty/by VC, questions focused on potential environmental and downstream impacts, dam safety and the allocation of water resources. During the meeting, the issues of climate change, sediment management, evaporation, and data-sharing were also discussed. Written comments were received from the Government of Uzbekistan dated November 7, 2012. On November 7, more than 45 civil society organizations were connected by a video-conference between Almaty (host site), Astana, Bishkek, Dushanbe, Kabul, and Tashkent and by audio connection with Ashgabat. Approximately 60 individuals participated, with an additional 54 attending as observers (including 38 representatives from development partners and 16 from the Government of Tajikistan). The list of attendees is included in Annex B. On both days, participants’ comments and questions focused on the seismic risks of the proposed Rogun project site, the potential effects of climate change on hydrology, the Government of Tajikistan’s plans for future resettlement and related grievance mechanisms, as well as cultural heritage sites. The Government of Tajikistan repeated the commitment made the previous day, namely that they intend to abide by the inter-governmental agreement on the Amu Darya river basin (Protocol 566 under the Nukus Declaration). The meeting emphasized that impacts of any potential changes in current water flows on downstream countries will be an ongoing focus for discussions, even if the changed flows remain within the scope of the Nukus Declaration. An in-depth economic analysis of the proposed project is underway to examine the role of the proposed project in meeting domestic demand and export opportunities. Participants called for an initial, preliminary economic analysis to give an early indication of the economic viability. Comments on the draft Screening Report for the ESIA, draft Design Criteria and other materials shared at the meeting were accepted until November 25, 2012, via email or mailed to the World Bank Country Offices. The remainder of this report documents the presentations and comments. A complete set of comments, from both meetings and those received online, and with responses offered from the Panels of 7 Experts, is included in Annex C. Information on these meetings, documents and presentations made in Almaty and a transcript of comments from the November 7 meeting are publically available on the Bank’s website at http://go.worldbank.org/2TFMJZIRY0. Highlights are summarized below. 8 5. ESIA Screening Report a. Purpose of ESSR The ESIA Screening Report (ESSR), available on the Bank’s5 and the Government of Tajikistan’s6 websites:  provides an overview of the prevailing physical, biological and social conditions in the proposed project area  identifies environmental and social issues which will be significantly affected by the proposed project  determines what information and data are already available on relevant issues, and  refines a work plan for going forward with the Environmental and Social Impact Assessment. The work was carried out using available documents, site visits, and discussions with stakeholders. The ESSR refines the scope of work (preliminarily formulated in the ToR and through earlier consultations with riparians) for the ESIA by identifying which aspects have potentially relevant impacts and require additional work and which aspects do not require additional work. The ESSR is not the final result of the environmental and social analysis of the proposed project; rather it helps focus the subsequent analysis on key issues. Comments from stakeholders help define the scope of the ESIA. Subsequent reports will provide more detailed analysis on impacts, benefits, and risks. b. Summary of Presentations Two presentations during the November meetings focused on the ESSR: one by the consultants and the other by the ESIA Panel of Experts. The presentation by the consultant outlined the purpose and coverage of the ESSR and examined the environmental impact through three components: physical, biological, and human. The following table from the ESSR breaks down the importance of potential impacts: Physical Climate •No impact of project on local climate: No importance •Potential effect of climate change on project: Intermediate importance Geology •Local project impacts: risk of increased landslides and erosion: Intermediate importance (local) •Project risks due to earthquakes ( located in seismically active zone): Very high importance (local, national and international level) Water •Water quality: risk of contamination during construction; small risk during operation: Intermediate importance •Hydrology: seasonal distribution of river flows d/s of the dam: Very high importance (local, national and international level) Biological Vegetation Affected area is heavily influenced by human activities; no important 5 http://siteresources.worldbank.org/ECAEXT/Resources/Rogun_ESIA_E&S_Screening.pdf 6 http://www.barkitojik.tj/eng/index.php?option=com_content&task=view&id=66&Itemid=49 9 and flora natural habitats. Minor importance (local level) Fauna (aquatic Affected area is heavily influenced by human activities; no important and terrestrial) natural habitats; no confirmed presence of rare or endangered species. Fish migrations already interrupted by Nurek dam. Minor importance (local level) Protected One protected area d/s of the dam indirectly affected (change in water areas regime). Intermediate importance (local / national level) (biodiversity) Human Affected About 78 villages and 42,400 persons would be resettled from the population construction and reservoir area. High importance (local and national level) Construction Environment, Health and Safety issues during construction. Intermediate related importance (local level) activities The presentation by the consultants highlighted several issues of particular interest:  Resettlement. As a large area would be submerged by the proposed project's future reservoir area, some villages would need to be resettled. Including the construction stage and the full development (reservoir) stage, 78 villages with approximately 42,400 persons would need to be resettled. The consultants observed that the organization in charge of resettlement is in place and actively working with local communities and resettlees. Some villages located in the area affected by maintenance and safety related construction are currently in the process of resettlement (Stage 1 resettlement). According to the Financing Agreement between the Government of Tajikistan and the World Bank, no resettlement of the population living in the area of the proposed project's future reservoir area (Stage 2 resettlement) would proceed until after (1) a decision on the proposed project is taken by the Government of Tajikistan and (2) a Resettlement Policy Framework, Resettlement Action Plan, and Resettlement Audit Report have been prepared, disclosed, and published as required under the ESIA.  Hydrology. This is one of the “most important [topics] of the ESIA [given that] water resources are shared between the countries of the river basin”. The ESIA is to consider the potential impacts on the Aral Sea Basin of the proposed project on the flow volume and pattern. Using a model of the entire Vakhsh cascade, which is a work in progress, the analysis of downstream impacts will be done in two stages: (i) Assess the potential impact at the border with Uzbekistan; and (ii) Assess middle and lower reaches of the Amu Darya in downstream countries where changes in flows at the border indicate potential impact. The Panel of Experts presented their assessment of the ESSR, identifying:  Issues covered sufficiently, with little additional work required: vegetation, fauna, and archaeology 10  Issues covered to some extent, some additional work required (i.e., the ESSR addresses the issue but not yet in the necessary depth and so needs further research and analysis in the ESIA): geology, protected areas, construction site management; and social impacts/resettlement  Issues requiring immediate and considerable attention (i.e., where gaps exist in the ESSR): hydrology/sediments/climate change; downstream impacts; environmental/social aspects of economic analysis The PoE provided extensive comments on the areas requiring some additional work and those requiring immediate and considerable attention. Their overall recommendations to the ESIA consultants included:  Strengthen and finalize Resettlement Audit, Framework and Plan  Address non-resettlement social impacts in addition to resettlement  Prepare the Public Consultation and Disclosure Plan  Follow-up on previous Panel recommendations  Recognize the critical importance of sediment issues  Systematically engage with GoT and TEAS on Vakhsh cascade modeling and modeling of the Amu Darya, based on a common and updated data set  Accelerate activity on analysis of downstream impacts  Analyze relevant available information and models on climate change in the Amu Darya basin  Estimate environmental and social benefits and costs for alternative designs  Continue to improve cooperation with TEAS consultants c. Highlights of Comments and Responses A complete set of comments, from both the meetings on November 6 and 7, 2012, as well as comments received online, and with responses offered from the Panels of Experts, is included in Annex C. A transcript of the November 7 meeting is available on the web site. Highlights are summarized below. During the meetings, participants raised comments on five key issues: impacts on downstream flows, resettlement, biodiversity, scope of engineering issues covered, and geological creep. Downstream flows are a critical issue that was discussed thoroughly during the riparian governments’ meeting and civil society information-sharing and consultation sessions. Downstream riparians are particularly concerned that the assessments cover the whole Amu Darya basin, referring to a UN-ECE convention on transboundary waters and Protocol 566 under the Nukus Declaration. This includes risk of simultaneous filling of Rogun and operation of Nurek during growing season, and the possible negative and positive influence of the proposed Rogun HPP on the flow to downstream countries, and possible future developments on the Pyanj River. The ToR for the ESIA consultants specifically state: “The consultant will assess the impacts of the construction and operation of Rogun HPP on the downstream countries. The specific assessment should be done in concert with the consultants conducting the TEAS, who would be responsible for proposing any technical and economic solutions.” These instructions, which reflect the 2008/2009 consul tations on the ToRs with all riparian governments, are followed by a description of the topics to be addressed. However, participants expressed concern about the coverage of this issue in the ESSR and the scope of analysis for assessing the potential changes in flow. Both the Panels of Experts and the World Bank 11 agreed that this critical riparian issue must be covered adequately. These recommendations have been formally shared with the Government of Tajikistan. The Government of Tajikistan has committed to staying within the obligations of the Protocol 566 under the Nukus Declaration. However, a careful analysis of potential changes in current flows at the border with Uzbekistan will be conducted under a variety of scenarios for both filling and operational modes of the entire Vakhsh cascade, and using various hydrologic conditions (including potential impacts of climate change). This modeling will be introduced in the next set of riparian meetings. Transboundary assessments of the middle and lower reaches of the Amu Darya will be undertaken should potential changes in flows at the border indicate impact. On resettlement, the ESSR and accompanying presentation provided some clarification on the process and organizational framework for resettlement. Relocation processes have ceased, except for already occurring resettlement related to ongoing maintenance and safety-related work. The Government of Tajikistan has committed to ensure that the limited ongoing resettlement is carried out in full compliance with Tajik laws. There is also agreement that a Resettlement Audit will be carried out to indicate any actions that may be needed to make the current resettlement comply with Bank OP 4.12 and International Standards. Participants, however, raised concerns on livelihoods, the grievance mechanism and the capacity to access it. The impact on historical and cultural/social sites (particularly cemeteries) was also raised in the context of resettlement of communities. An NGO participant from Tajikistan noted that the Bureau of Human Rights in Dushanbe has followed the resettlement and completed a survey of those being resettled which indicated that the local population was well informed of the proposed project and implications for resettlement, and that the national laws of Tajikistan on resettlement were being upheld.7 Additionally, riparians raised concern that the ESSR mentions that “construction is ongoing at the site”. The Government confirms and the World Bank has verified that all non-maintenance-related work at the site has ceased in accordance with the Bank’s conditions for continuation of the assessment process. The reason for the discrepancy is that the ESSR was prepared prior to the implementation of this agreement for cessation of non-maintenance work. Until the assessment process concludes, no water will be diverted and works on site will be limited to maintenance and safety-related works, as agreed by the Government of Tajikistan and publically affirmed by both Tajikistan and the World Bank. The World Bank will continue to monitor site conditions on a bimonthly basis. Participants noted that biodiversity and natural habitats, particularly forests and seasonally flooded wetlands, should be fully covered by the studies. This is related, for example, to potential impacts on ongoing efforts to restore the special floodplain ecosystem of the Tigrovaya Balka Nature Reserve. In addition, potential hydrological linkages between the Vakhsh River and nearby groundwater resources should be explored. The third area was related to the engineering scope, and particularly the key areas of dam safety, hydrology, design criteria, and geology. Some of the comments recognized the importance of including the extensive hydrologic assessment that has already been completed and the statement of the estimated probable maximum floods in the ESIA. Finally, on the geological creep on the faults at the dam site, there are ongoing measurements being made and there was a recommendation by the Panel to continue to collect data on this. However, it was 7 Rogun Relocation Report (2012), available: http://www.bicusa.org/en/Document.102958.aspx 12 indicated that this would not affect the feasibility of the proposed project because the creep is not expected to be significant. Furthermore, there are a number of design solutions that would completely mitigate the creep. A detailed presentation on geology was given in the session on the TEAS. 13 6. Interim studies for Techno-Economic Assessment Studies (TEAS) a. Overview of TEAS Progress The documents reviewed in the meeting are interim reports and do not represent the final Techno- Economic analysis of the proposed project. Comments from stakeholders will help to refine these studies. Subsequent reports will provide full assessments of the proposed project’s Techno-Economic elements. The TEAS has made considerable progress in each of the phases since the Inception Reports were reviewed at the 1st Riparian Information-Sharing sessions in May 2011. Progress is summarized below; topics covered and information shared at the November 6/7 sessions are in bold: Phase 0: Salt Dome Assessment: Additional geotechnical site investigations are well advanced, preliminary results of which are included in the geology presentation made at the information session. Phase I: Assessment of Existing Works: Meetings in June 2012 with HydroProject Moscow indicated that the Finite Elemental Analysis (FEA) models of power house and transformer caverns are being re- elaborated by HydroProject Moscow; Tests are ongoing. Phase II: Proposed Rogun Hydropower Project Definition of Options8:  Engineering design criteria presented at the information session (distributed in advance of session), covering seismicity, sediment management;  Hydrology analysis in draft as presented at the information session, for review by PoE;  Reservoir operation simulation model and study under preparation  Geological and geotechnical investigations well advanced;  Detailed methodology for seismic hazard assessment under preparation;  Economic methodology under revision based on World Bank comments. b. Summary of presentations Three separate presentations were made by the consultants and PoE on the interim studies for TEAS: design criteria, hydrology, and engineering geology. The Design Criteria presentation noted that such criteria are necessary to (i) apply consistent criteria and safety standards to existing and future works; and (ii) to demonstrate that current international guidelines for the design and construction of high dams are followed. The Design Criteria covers:  design parameters,  design criteria for the dam,  design criteria for hydraulic works,  design criteria for underground works,  scheme operation criteria, 8 Phase III: Assessment Report for the Selected Option, will proceed only after a decision regarding viability from Phase II. 14  sedimentation management, and  the downstream right side zone of the valley. The Engineering and Dam Safety PoE recommends that the design criteria should also cover mechanical and electrical aspects. The Techno-Economic Assessment of the proposed Rogun HPP will be based on design criteria that follow the recommendations of ICOLD (International Commission on Large Dams). ICOLD leads the profession in setting standards and guidelines to ensure that dams are built and operated safely, efficiently, and economically, and are environmentally sustainable and socially equitable. The Government of Tajikistan has adopted the internationally recognized highest level of safety for the two most significant types of risks for a structure of the same category as the proposed Rogun HPP. Specifically, dam risk classification will be performed in accordance with ICOLD Bulletins 72 and 82 to guide the choice of flood design and earthquake design as follows: (i) Hydrological safety adopts the Probable Maximum Flood (PMF) in the design of the spillways, and (ii) Seismic safety adopts the Maximum Credible Earthquake (MCE) in the structural design of dam and appurtenant works. The ongoing Hydrology Study, the second presentation, considered characteristics of the Vakhsh river basin, inflows at the site of the proposed project, floods and the PMF measure, and potential impacts of climate change. The PMF peak has been estimated at 8160 m3/s which is higher than an earlier estimate by HydroProject Institute (Moscow) and significantly higher than the value for the 1/10,000 year flood. A full Hydrological Report will be disclosed in early 2013, prior to the 3rd riparian meetings. The final presentation, Engineering Geology, presented preliminary results from additional site investigations such as drilling, geophysics, rehabilitation of exploratory audits, and hydrogeology (all in advanced stages of execution). These preliminary results illustrated the stability conditions of the downstream right side zone of the valley; the salt wedge; the Ionaksh fault and springs in the right upstream side; and the permeability conditions of dam abutments. Evidence from site investigations to- date indicates that geological conditions seem acceptable for the feasibility of the proposed project. However some potential risks have been identified and require further consideration: the activity of faults in the foundation and abutment areas; the Gulizindan fault as a potential axis of leakages; and the possibility of large scale landslides upstream, along the reservoir rim. A geological report on the stability of the right bank will be disclosed in early 2013, prior to the 3rd riparian meetings. c. Highlights of Comments and Responses Discussion on the Techno-Economic studies focused on dam safety, and related issues such as seismic hazard, geologic stability and design floods. These concerns were raised in all sessions, and in subsequent comments received by mail. There was an extensive discussion of seismicity and the application of the maximum credible earthquake (MCE), defined as the maximum seismic event that can be generated by the given seismo-tectonic setting, typically with a return period exceeding 1 in 10,000 years. It was clarified that, having established the MCE as the design criteria, ground accelerations need to be estimated, based on site-specific 15 characteristics and seismo-tectonic modeling. This is under-way and is currently being subjected to a detailed review by a specialized European seismic institute (BRGM from France). Discussion on the salt dome, associated with the Ionaksh fault, further clarified that, technically, it could be appropriately managed to ensure operational safety as extensive studies have shown impermeable conditions of the salt at depth, on both valley sides. It was noted that assessment of the salt dome effects on the feasibility of the proposed Rogun HPP will be included in a special report (Phase 0) of the Techno- Economic Assessment Study. The quality of existing works was identified as a risk, given their age, basis of design, and quality of data. Phase 1 of the TEAS is addressing these issues in depth. It was clarified that the agreed design criteria are applicable to any part of the works, including already built structures. If necessary, these existing works would be modified to meet the design criteria and the costs taken into consideration in the economic assessment. The discussion underscored the need for a continued commitment to rigorous dam safety standards. Other issues regarding design and dam safety were:  Sedimentation impacts on reservoir life (to be captured in the economic studies and long term sediment management strategy) and potential damage to tunnels (to be taken into consideration in tunnel design and lining, and in simulation studies of the Vakhsh cascade).  Possibility of increased mudflows and landslides along the reservoir rim (to be addressed in the geology report based on site investigations)  Combined risks, in particular probable maximum flood (PMF) and maximum credible earthquake (MCE); (international practice does not combine these extreme events because the combined probabilities are extremely low).  Catastrophic failure of the dam, the possible consequence of high floods or seismic instability or displacements (addressed in the Phase 2 studies). The necessary shift in standard for flood management to a PMF was discussed more fully as was the quality and quantity of basic hydrologic data (likely sufficient but requiring further verification). A question was raised about the availability and use of Kyrgyz data from the upper watershed. One participant questioned the Government of Tajikistan’s long-term policy strategy regarding the energy generated by Rogun. Although this issue is beyond the scope of the technical Assessment Studies, it was clarified that alternatives to the project will be addressed, and the role of exports and domestic demand explored as part of the economic analysis. The economic assessment, including an estimate of net return or “payback”, is underway. Economics will inform on the feasibility of various proposed dam heights and installed capacities. 16 7. Cross-Cutting Issues In addition to comments received regarding the draft ESSR and the draft TEAS reports, participants commented on several cross-cutting issues which were relevant to the assessment and/or riparian process. Several participants requested that the Assessment Studies more comprehensively consider the potential positives of the proposed project including the production of affordable and clean energy and potentially improving water security in dry years. Participants in the meetings raised the issue of climate change numerous times. Climate change will be integrated into the studies and is an important consideration in the overall hydrological work and in sediment management. Although the consultants’ preliminary sense is that climate change is unlikely to make a large difference in design criteria, such as a probable maximum flood, it was noted that reservoir operations will need to adapt over time as conditions change. Participants also commented on the study and riparian process itself, reiterating the importance of engaging riparians and individuals across the region. Participants reaffirmed the importance of continuing to meet international standards in terms of consultation and information sharing and the need to ensure clarity in how comments are incorporated. It was suggested that HydroProject Moscow and the Interstate Commission for Sustainable Development of the International Fund for Saving the Aral Sea (IFAS), in addition to the Executive Committee of IFAS, also be invited. Concern regarding the voice of local populations was noted. All of the materials, presentations, and comments related to the 2nd Riparian meetings are available on the World Bank’s external website at: http://go.worldbank.org/2TFMJZIRY0 17 8. Recommendations by the Panels of Experts to the Government of Tajikistan This section is taken directly from the Panels’ recommendations based on the discussions. These have been formally transmitted to the Government of Tajikistan in November 2012 and shared with the consultants by the World Bank. ESIA: a) New Regional Opportunities and Need for Positive Focus: Studies should consider possible future development that may influence flow patterns and needs in the Amu Darya basin, and consider positive regional impacts. b) Environmental Impacts of Climate Change (CC): The Draft ESIA should present and discuss available information, models and analyses from which decisions can be made on what additional analysis is needed on climate change and how the findings shall be incorporated in the project, noting possible resulting flooding and low-flow and run-off changes. c) Actively Accounting for Public Opinion on Resettlement: The Resettlement Program for Rogun has been commended, but it must also address the important objective of ensuring that displaced people can improve or at least restore their livelihood in their new location. d) Cultural Monuments, Resettlement Principles and Plans and Inundation of Cemeteries: The draft ESIA will address impacts on cultural assets in accordance with World Bank policy on cultural heritage. World Bank safeguard policy on resettlement handles the intent of informed consent through its thorough public consultation, disclosure and grievance procedures.9 e) Regional Benefits and Clean Generation Capacity: While replacing fossil fuels with power from Rogun is, environmentally, a win-win situation for both buyer and seller the role of trade is outside the realm of the ESIA process. f) Report by Human Rights & Rule of Law NGO: The organization’s report should be made available to interested parties. g) Downstream flow impacts and CC effects on Irrigation in Turkmenistan and Uzbekistan with follow-on Desertification Problems: The GoT’s commitment to remain within the Protocol 566 under the Nukus Declaration is recognized and strongly supported by participants. Furthermore, it should be noted that, should GoT increase withdrawals to the full Nukus allocation as part of the proposed Rogun project, effects will be imposed on downstream water users and the Aral Sea. Using the cascade model being produced by the consultants, the GoT is advised to actively explore possibilities of implementing the proposed Rogun project without having to change current flow conditions across the border. If flows vary significantly downstream, environmental and social impacts must be investigated as part of this feasibility study (e.g., analysis all the way down to the Aral Sea) to inform on risks to the lower basin. TEAS: 9 For a further clarification on the World Bank’s policies, the World Bank's indigenous peoples policy, which is not applicable here, provides for free prior and informed consultations leading to broad community support for a project. The World Bank's policy for involuntary resettlement which does apply to the proposed Rogun hydropower project provides for broad consultations, disclosure and grievance redress for the people affected by resettlement. 18 a) Economic analysis: The economic analysis which is being undertaken will take into account domestic demand and export market opportunities, as well as social and environmental costs and benefits. This analysis will also be used for the scheme optimization. b) Cascade modeling- Modeling of the impoundment: the cascade operation model that is being developed will be able to assess impact of reservoir impoundment which would be taken over an extended period to minimize impact – in both filling and operational periods – on the downstream riparian countries. c) Seismic design of the dam: The dam would be designed not to fail under a Maximum Credible earthquake. This earthquake acceleration level will be determined by undertaking a site specific Probabilistic Seismic Hazards Assessment study which will take into account the following:  Historical and instrumental records in the area  Reservoir-triggered seismicity  Regional tectonics. d) Hydrology: Assessment of the hydrology has been done using data on the available gauging stations. Information on data sources will be available in the TEAS Consultant’s finalized report on Hydrology. e) Floods: Hydrological and meteorological data have been used to establish relevant design flood (1 in 10,000y flood and the PMF). PMF is the appropriate international standard to apply. Design Criteria for the projects specify that Glacial Lake Outburst Floods (GLOFs) should be taken into account in the PMF derivation. f) Dam safety: Assessment of dam safety to a combined impact of MCE and PMF on the dam would not be used as a design criteria for the dam design as the combine probability of these two extreme events occurring simultaneously is negligible (less than once in 100 million years). g) Sedimentation: Studies to assess long term sedimentation impacts on the dam options are being undertaken. They will clarify the useful life of the proposed project. h) Geology/ Faults: The faults that cross the dam site are subjected to creep movement of a few millimeters per year and the design options are being developed for the structures to accommodate this movement. 19 9. Next Steps The ESIA and TEAS consultants will continue their analyses for their respective Assessments. A third set of information sharing meetings is planned for February 2013 and is expected to cover: seismicity methodology, right bank stability, costs of resettlement and community infrastructure) and cascade model. A fourth set of information-sharing and consultation meetings is planned for mid 2013 to discuss the draft TEAS report and the draft ESIA report on the most viable options. Rogun Riparian Information-Sharing Program 2nd Riparian 3rd Riparian Terms of 1st Riparian Meetings Meetings 4th Riparian Reference Meetings (May (November Meetings (2013) (2008/09) 2011) (February 2013) 2012) Explanation of Inception reports E/S Screening Report Hydrology proposed project Riparian program Hydrology Geology: Right Bank and World Bank Introduction to Design criteria Flood management policies Panels of Experts Geology Seismic methodology Draft ToRs Reservoir operations Social costs of alternatives 20 Annexes a. Agenda With video or audio connections to World Bank offices in Ashgabat, Astana, Bishkek, Dushanbe, Kabul, and Tashkent Purpose: To share new information from the assessment studies on the proposed Rogun Hydropower project 08:30 – Registration 09:00 09:00 – 09:30 Welcome  Opening comments World Bank  Review of agenda 09:30 – 10:00 Purpose and structure of assessment studies World Bank 10:00 – 10:30 Update on study process  Review of May 2011 information session World Bank  Study schedule  Schedule of information sharing sessions 10:30 – Coffee and tea 11:00 11:00 – 13:00 Environmental and Social Screening report Poyry Consultants  Presentation on purpose, findings, links to other World Bank studies Panels of Experts  Comments from Panels of Experts All participants Moderated discussion 13:00 – Catered lunch 13:30 13:30 – 15:30 Engineering studies Coyne & Bellier  Presentation of findings World Bank  Comments from Panels of Experts Panel of Experts Moderated discussion All participants 15:30 – Coffee and tea 16:00 16:00 – 17:00 Summary  Recap of findings and comments World Bank  Next steps 21 b. Participants at CSO 2nd Information-Sharing and Consultation Meetings (November 7, 2012) AFGHANISTAN 1. Zabihullah Zabihullah Program Director of Coordination of Afghan Relief- CoAR Kabul 2. Hayatullah Wahdat Policy and Fund raising Senior Advisor to CoAR Networks Kabul 3. Mohammed Sharif Agriculture Program Manager, CoAR Kabul 4. Nasir Ahmad Sakhi Afghanistan Bayat Ethnic Council (ABEC) Kabul 5. Marie Huber Researcher IWA Kabul 6. Hayatullah Hayat Speaker, Civil Society Coordination Center (CSCC) Kabul Executive Director, Social Development & Legal Rights (SDLR) 7. Freshta Dost Communication officer IWA Kabul 8. Obaidullah Hidayat Safeguard Consultant Kabul KAZAKHSTAN 1. Mr. Marat Aitmagambetov Moderator, Director, Counterpart International Almaty 2. Ms. Nuria Bikineeva Regional Coordinator “Echo” NGO Almaty 3. Ms. Fayma Urazaeva Head of Sustainable Consumption Department, NGO “Center of Sustainable Production and Almaty Consumption ” 22 4. Mr. Nikolay Chmelevskiy “Cooperation for Sustainable Development” Center, Energy Efficiency Expert Almaty 5. Mr. Sergey Solyanik Crude Accountability, Consultant Almaty 6. Andrey Komov Research Institute for Transport and Communications Almaty 7. Saodat Olimova Carnegie-Farabi Research Center Almaty KYRGYZ REPUBLIC 1. Ms. Irina Mukambaeva Chairperson of Public Supervision Council, Department of Water Resources Bishkek 2. Deputy Chairman of Public Supervision Council at the State Agency for Environment and Bishkek Ms. Kaliya Moldogazieva Forestry, Human Development Centre “Tree of Life” 3. Chairman of Public Supervision Council at the State Agency for Environment and Forestry, Bishkek Mr.Kairat Moldoshev Tabiyat Life Public Association 4. Chairman of Public Supervision Council at the Ministry of Energy and Industry, UNISON Public Bishkek Ms. Nurzat Abdyrasulova Association 5. Ms. Zulfia Marat Human Rights Bureau Bishkek 6. Ms. Anara Dautalieva Taza Tabigat Bishkek TAJIKISTAN Participants in Almaty 1. Mr. Ali Boboyev PMP International Almaty 2. Ms. Bakhrom Sirojev Honorary Head of the “Association of energy experts”, member of the Academy of international Almaty engineers 3. Mr. Sobit Negmatullaev - Academician on geology and seismology of the “Seismology Institute of the Academy of Sciences Almaty of Tajikistan” 4. Mr. Khamidjon Arifov “Tajik National Committee on Large Dams” Almaty 5. Ms. Rafika Musaeva Chairman of the “Association of energy experts” Almaty 6. Mr. M. Khokhmirzoyev Specialist, Projects Implementation Group Almaty Participants in Dushanbe 1. Mr. Anvar Khamidov NGO Climate Change Dushanbe 2. Mr. Daler Shodiev NGO “Strategy” Dushanbe 3. Mr. Furkat Kadyrov Tajik-Norwegian Small Hydro Power Development Center Dushanbe 4. Ms. Gulchehra Murodova Shahrvand Civil Society Support Center (Kulyab) Kulyab 5. Mr. Kamolidin Sirojidinov Independent expert Dushanbe 6. Mr. Khurshed Abdulloev Association of Renewable Energy of Tajikistan Dushanbe 23 7. Ms. Makhbuba Sharipova NGO Mayram (Kulyab) Kulyab 8. Ms. Malika Boymuradova NGO ASTI (Khujand) Khujand 9. Ms. Malika Babadjanova Tajik Branch of the Regional Environmental Center for Central Asia Dushanbe 10. Ms. Nargiz Zokirova Bureau of Human Rights and Rule of Law Dushanbe 11. Mr. Rakhimjon Djuraev Human and Nature NGO Dushanbe 12. Mr. Shuhrat Abdullaev National Association of Small and Medium Businesses Dushanbe 13. Ms. Shahlo Akobirova Khoma NGO Dushanbe 14. Mr. Umed Ulugov Youth of the 21 Century NGO, Head of the Club of the Environmental NGOs Dushanbe 15. Mr. Yasunov Pulat Association of Builders Dushanbe 16. Mr. Blagoveshenskaya Svetlana NGO “Fund Kuhiston” Dushanbe 17. Ms. Alikhanova Takhmina Independent Expert Dushanbe 18. Ms. Muazama Burkhanova Center “Dastrgiri” (Fund for Support of Civil Initiatives) Dushanbe 19. Ms. Yakubova Muhiba Association of Women Scientists of Tajikistan under the Sciences Academy of RT Dushanbe 20. Mr. Amindjanov M. Energy Experts Society Dushanbe 21. Mr. Georgiy Koshlakov War Veterans Council of Tajikistan / Russian Tajik Slavonic University Dushanbe 22. Ms. Savridinova Qulafso “Soyuz Parlament” (Union of Parliamentarians) Dushanbe 23. Mr. Aminov Firuz Youth Ecological Center Dushanbe 24. Mr. Kamollidinov A. Public Organization “DEPAS” Dushanbe 25. Mr. Usmanov S. Association of Energy Experts of Tajikistan Dushanbe 26. Mr. Olimov M. Research Center “Sharq” Dushanbe 27. Mr. Saidov F. Independent Expert Dushanbe TURKMENISTAN 1. Oleg T. Guchgeldiyev Independent consultant, Environment and community development Ashgabat 2. Guljamal Nurmuhamedova Consultant, Director of Analytical agency Ashgabat UZBEKISTAN 1. Sultanov Ruzimukhamad NGO “Ecoschool” 2. Kobzev Aleksey NGO “ECOFORUM OF UZBEKISTAN” 3. Majitov Tokhir NGO “Suvchi” 4. Rafikov A. L. NGO “Suvchi” WORLD BANK 24 1. Mr. Saroj Kumar Jha Regional Director, Central Asia 2. Mr. Roland Kyle Peters Director, Strategy and Operations 3. Mr. Ranjit Lamech Energy Sector Manager 4. Ms. Marsha Olive Country Manager for Tajikistan 5. Mr. Takuya Kamata Country Manager for Uzbekistan 6. Mrs. Agnes Kiss Regional Environmental and Safeguards Advisor 7. Ms. Daryl Fields Senior Water Resources Specialist 8. Mr. Imtiaz Hizkil Senior Power Engineer 9. Mr. Alessandro Palmieri Lead Dam Specialist 10. Ms. Elena Karaban Communications Officer 11. Ms. Lola Ibragimova Social Scientist PANELS OF EXPERTS 1. Mr. Torkil Clausen Water Resources Expert, Denmark 2. Ms. Ljiljana Spasic Gril Dam Engineering/Safety Expert 3. Mr. Roger Gill Hydro Focus Pty Ltd, Australia Emeritus Professor at NTU Athens 4. Mr. Paul Marinos Independent Consulting Engineer, Greece 5. Mr. Eric Helland-Hansen Hydropower and Environment Expert, Norway CONSULTANTS 1. Mr. Nicolas Sans Project Engineer, Dams and Hydroelectric Schemes, Coyne & Bellier 2. Mr. Ascensio Lara Senior Expert Consultant, Tractebel Engineering, Coyne & Bellier 3. Mr. Silviu Ianos Poyry 4. Mr. Robert Zwahlen Poyry 5. Mr. Pierre Beiderman Poyry, Water resources specialist OBSERVERS (TJ Gov) 1. Mr. Farrukh Khamraliev State Advisor to the President on Economic Policy Almaty 2. Mr. Pulod Mukhiddinov First Deputy Minister of Energy and Industry of the Republic of Tajikistan Almaty 3. Mr. Sulton Rakhimov First Deputy Minister of Irrigation and Water Resources of the Republic of Tajikistan Almaty 4. Mr. Bakhrom Kholnazarov Ambassador extraordinary and plenipotentiary of the Republic of Tajikistan in Kazakhstan Almaty 5. Mr. Khairullov Ibodzoda Head, Ecology and Emergency Situations Unit of the Executive Office of the President RT Almaty 6. Mr. Asadullo Khakimov Head, International Relations department of the Ministry of Justice of the Republic of Tajikistan Almaty 7. Mr. Nurali Saidov Deputy Director of the Agency for construction and architecture under the Government of Almaty 25 Tajikistan 8. Mr. Azim Ibrahim Chairman, General Geology Directorate under the Government of Tajikistan Almaty 9. Ms. Oyhon Sharipova Deputy Chairman, Committee for environment protection under the Government of Tajikistan Almaty 10. Mr. Isroil Nasyrov Director, Project Management Group for construction of hydropower facilities Almaty 11. Mr. Khairullo Safarov Director of OJSC Rogun HPP Almaty 12. Mr. Ramazan Mirzoev Director, SUE "Rogun HPP flooding aread directorate" Almaty 13. Ms. Elena Lashkarbekova Deputy Chairman of OJSC Barki Tajik Almaty 14. Mr. Mahmadsaid Technical Director, OJSC Rogun HPP Almaty Shamsulloev 15. Mr. Mehreddin Tohirov General Director Secretary, OJSC Rogun HPP Almaty 16. Mr. Sarim Safin First secretary of the Tajik Embassy in Kazakhstan Almaty 26 OBSERVERS (DONORS) KAZAKHSTAN 1. Mr. Sagit Ibatullin Director, The Executive Committee of Almaty International Fund for saving Aral Sea (IFAS) 2. Mr. Frank Schrader Regional Consultant, GIZ Transboundary Water Management in Central Asia Almaty +49-461-9402962, +49-461-31557721 (Schrader_frank@t-online.de) 3. Mr. Bakhtiyor Faiziev Principal Banker, Municipal and Environmental Infrastructure, European Bank for Reconstruction Almaty and Development (EBRD) 4. Mr. Tulegen Sarsembekov Assistant to the general director, Eurasian Development Bank Almaty 5. Mr. Alexander Mironenkov Head of Technical Assistance Division of Eurasian Development Bank (EADB) Almaty 6. Mr. Lorenzo Rilasciati Environmental Affairs Adviser Almaty Office of the Coordinator of OSCE Economic and Environmental Activities, OSCE Secretariat 7. Mr. Tamerlan Munchayev Member of CICA Secretariat, Secretariat of the Conference on Interaction and Confidence Almaty Building in Asia (CICA) 8. Ms. Alia Baidebekova Project Manager, European Commission (After 6:30PM) Almaty 9. Mr. Svetlin Sergeenkov Regional Planning Officer Almaty Central Asia, South Caucasus, Eastern Europe, Service for Foreign Policy Instruments, European Commission 10. Bakhit Abdildina UNRCCA Representative in Kazakhstan, Almaty National Programme Coordinator UNRCCA 11. Mr. Valeriy Zhiltsov International consultant for renewable energy, UNDP/GEF, WB and ADB Almaty 12. Ms. Ashley King Environment Officer, USAID/Central Asia Almaty 13. Mr. Michael Trainor Senior Energy Policy Specialist , Office of Economic Growth, USAID/Central Asia Almaty 14. Mr. Daniyar Abylkhanov Energy specialist, Islamic Development Bank Almaty 15. Mr. Kamen Velichkov Head of Politics, Press and Information Unit, EU Astana 16. Mr. Thomas van Eeckhout EU Astana 17. Mrs. Peta Bacova Deputy Head of Mission, Embassy of the Czech Republic in Astana Astana 18. Ms Anne Marte Amble Norwegian embassy, (DHM) Astana 19. Ms Hanna Kosonen Finnish embassy, Deputy Ambassador Astana 27 KYRGYZSTAN 1. Mr. Mishima Kenji Representative, JICA Kyrgyz Republic Office Bishkek 2. Mr. Rafaelo Muller Deputy Head of Delegation, Red Cross in the Kyrgyz Republic Bishkek TAJIKISTAN 1. Mr. Chantal Felder Swiss Agency for Development and Cooperation Dushanbe 2. Mr. Christian Melis OSCE Dushanbe 3. Mr. Michael Bradow United State Agency for International Development Dushanbe 4. Mr. Daler Asrorov United State Agency for International Development Dushanbe 5. Mrs. Aliona Niculita United Nations Development Program Dushanbe 6. Mr. Boris Filipov European Commission Dushanbe 7. Mr. Iida Jiro Japan International Cooperation Agency Dushanbe 8. Mr. Tojiddin Najmedinov Japan International Cooperation Agency Dushanbe 9. Mr. Smagulov Agibai Embassy of Republic of Kazakhstan in Tajikistan Dushanbe 10. Sitora Shokamolova Secretariat of the Development Coordination Council Dushanbe UZBEKISTAN 11. Mr. Daniyar Nuralginov Representative, Embassy of Kazakhstan 12. Mr. William Lieutenant Representative of the Embassy of United States of America Tashkent 13. Mr. Asamura Takao Tashkent 14. Mr. Yens Rasmussen OBSE Representative Tashkent 15. Mr. Karl Kulessa Acting UN Resident, UNFPA Tashkent 16. Mr. Yukihiko Ejiri Head of office, JICA Tashkent 17. Mr. Fukumori Representative, JICA Tashkent 28 c. Matrix of Comments on Rogun Assessment Studies with Responses Country Comment Response10 Information-sharing and discussion process Afghanistan The level of sharing of information on this important issue with We thank the Government of Afghanistan and Afghan CSOs the civil society of Afghanistan is not sufficient. Request the for their participation and contributions. We will make every World Bank to have another session, a special session with effort to disclose materials four weeks prior to meeting, and broader representative of the civil society of Afghanistan, and have them available for comment for six weeks. then the comments will be summarized and sent to the central management of this project. This is the first time that we were The World Bank will explore opportunities there are for informed about this process, so we are not that much ready and additional engagement. The website also provides we haven’t went through the information, and there is a broad considerable material, including all presentations and civil society in Afghanistan, we have a lot of organizations. So I documents from the first session in May 2011, a report on will request the World Bank that they will organize another consultation on the Terms of reference, and of the interim session directly with civil society of Afghanistan, and they documents relevant to the Assessment Studies. should get their comments. Kazakhstan I have a comment and would like to thank the World Bank for We thank the Government and civil societies of Kazakhstan providing the opportunity for a dialogue between countries. Our for their useful participation. organization has monitored this process for three years now; and we are interested in management of the water resources between countries as all the rivers of Kazakhstan are transboundary rivers, and we are also very concerned about the issue. Thank you Kyrgyz Thank you for organizing such an outstanding event to discuss The comments received on the inception reports in May 2011 Republic the Rogun hydropower plant. In May 2011, the consultations were shared both directly with the Government and also with civil society were held. Were the comments and through the Panels of Experts in their recommendations. suggestions, which were announced in May 2011 in the consultations with civil society, taken into account in the existing environmental and social screening instruments as well as feasibility studies? Kyrgyz First of all I would like to reproach the World Bank. The fact is We thank the Government and civil societies of the Kyrgyz Republic that it is a holiday in Kyrgyzstan today, the Memorial Day to Republic for their useful participation, especially on commemorate people killed during the revolution. Today we Memorial Day. have the Memorial Day, and we were going to commemorate 10 Prepared by the World Bank with the Engineering and Dams Safety and Environmental/Social Panels of Experts and input from consultants Coyne & Bellier and Poyry. 29 those repressed during and after the revolution. We understand very well what a loss it is. We also lost some of the cultural heritage during the construction of the Kyrgyz hydropower cascades. We know everything, we remember all the good and bad, so first I would like the World Bank to take into account next time that these countries have memorial days and not to set up meetings on such days. Kazakhstan There is such an organization, ‘Interstate Commission for The Executive Committee of the International Fund for Sustainable Development’ (ISDC) in Central Asia. Does the Saving the Aral Sea (EC_IFAS) participates in the riparian Project interact with them in that direction? program. An invitation to the ISDC will be extended. Tajikistan On 19 May 2011 we agreed that the Moscow Design Institute ‘Hydroproject’ would surely be included in the list of Hydropower Moscow is a consultant to the GoT. An participants that was approved by all the participants. invitation to include them will be reiterated to the GoT. Unexpectedly, and unfortunately, there is no ‘Hydroproject’ on Slide 4 ‘Participants’ in the presentation of Daryl Fields. Could you please explain the reasons for removing ‘Hydroproject’ from the list of participants and tell us if any of them are at the meeting today? On 19 May last year, they took part, the chief engineer did. I think that the involvement of ‘Hydroproject’ is very important because the screening report refers to their 2009 project. Kazakhstan What is the opinion of the population about the construction? The views of the population are captured through two mechanisms in the Assessment Studies. First: consultations with the local (i.e. directly affected) population as part of the Environmental/Social Impact Assessment Study. There is no opposition against the project, but the population is suffering from the "on and off" process, which causes a great deal of uncertainty. The population outside the directly affected area waits for the project since they suffer from insufficient power supply.. Second, through the World Bank riparian program, which has engaged over 50 civil society organizations in six countries. Comments are posted publicly. The GoT attends all meetings and the PoEs are responsible to incorporate stakeholder comments as appropriate in their recommendation to GoT. Kazakhstan I would like to call your attention to the observance of the Neither the World Bank nor a majority of its shareholders are 30 provisions of the Aarhus Convention in the discussion and parties to this specific convention, nor does the Bank have the implementation of project of the Rogun HPP, which I raised power to compel shareholders to comply with individual during the meeting in Almaty on November 7. conventions which they may be a party to. In particular, public participation in decision-making process (Article 6) at ALL stages of the project and at an early stage, However, the Bank has committed to ensuring that Bank including design, research and construction of the facility. This safeguard policies and international safeguards are adhered to means not only informing the public and holding public in the Assessment process and that riparians and other hearings, which have often a formal nature in our countries, but stakeholders are engaged throughout, to put objective also having a mechanism to consider the opinion of the people information on the table and to foster open and informed in decision-making and feedback from them. Otherwise it will dialogue. The process has been supported by international be the violation of rights of citizens. partners including the UN and the EC As you know, Tajikistan is a party to the Aarhus Convention, as well as Turkmenistan and Kazakhstan, whose interests will also The Bank’s objective is a transparent and accountable process be addressed during the implementation of such a large-scale that enables a wide range of stakeholders to have their voices cross-border project. heard and accounted for. With that objective in mind we http://www.unece.org/env/pp/ratification.html have consistently made public key information and updates Unfortunately, during presentations November 7 (session 2) on regarding the process in a timely manner, have invited the social and environmental assessment, there was no riparian Governments and regional CSOs to participate in information on the opinion of the population of Tajikistan, as information sharing discussions (e.g. our recent meetings in well as Kazakhstan, Turkmenistan, Uzbekistan, and how Almaty which you participated in), and have opened people's opinions were taken into account in decision-making on commenting to the general public on the draft documents Rogun. Moreover there is clear from the presentation 5 - no plan being discussed at key milestones in the process. In turn, the consultation (slide 13) and the analysis of international assessment process and the broader objective of stronger agreements (slide 23). From this we may conclude that in the regional dialogue on water and energy resource management present there are violations of the rights of the citizens of have benefited – reflecting the concerns of various parties and Tajikistan and other countries to participate in the decision- enabling improved participation and voice. making process on Rogun. Therefore the World Bank staff in the further work on the The World Bank has not committed to finance the project should pay attention on implementation of the Aarhus construction of the proposed project itself. Convention provisions by the authorities of Tajikistan, as well as the bank team in its activities. Otherwise, the bank may be In addition to the World Bank hosted information sharing, the accused in assistance of violation of the international agreement. ESIA consultants are present in the local communities as part The World Bank Group already has had such a bad experience of information collection and also to fulfill the consultation in the region, when the public filed charges against the requirements of the World Bank for the ESIA. The Bureau of International Financial Corporation for violation of the Human Rights who is actively supporting resettles has provisions of the Aarhus Convention in connection with the indicated that the local populations are well informed and 31 Karachaganak project, Kazakhstan. For more information: engaged. http://www.crudeaccountability.org/en/index.php?page=campai gn With respect to slide 23, the ESIA takes into account relevant http://www.cao-ombudsman.org/cases/case_detail.aspx?id=105 international agreements. http://www.cao-ombudsman.org/cases/case_detail.aspx?id=74 http://www.greensalvation.org/en/index.php?page=berezovka-en We hope that these comments will be considered in future work of the bank on the Rogun HPP. Tajikistan First of all, let me express my gratitude to the World Bank, as We thank the civil societies of Tajikistan for their useful well as all the experts here for providing a second chance to participation. participate in the discussion of the Assessment Studies on the Rogun hydropower plant project. In this case, we, the region’s civil society, perhaps for the first time, were given a unique opportunity for all of us to gather and discuss a very large regional project. I think this will not only enable us to facilitate mutual understanding but also overcome mistrust and excessive politicization of the project which are caused by the most significant socio-economic component. Thereby, once again I would like to stress the really key role of the World Bank in promoting such a discussion in Central Asia in order to reach coordinated solutions with regard to the major water and energy problems. Tajikistan Where will the next meeting for the exchange of information It will again be held at the World Bank’s regional office in take place? Almaty. The offer to host a meeting in Tajikistan is appreciated and will be considered in the future. Tajikistan Proposal: To more regularly cover all subsequent steps by the The Assessment Studies will continually draw upon the latest next discussion in order for the civil society to be better relevant information both within Tajikistan and from the informed about the project progress and assessments conducted. broader region and beyond to expand the quality. Information To organize within these stages an international conference or a from experts and Governments is welcome. We will continue meeting at which to make submissions on international to make Assessment information available via our website as experiences in operating high dams in the context of the Rogun it becomes available (http://worldbank.org/eca/rogun). HPP, if possible. Also use the unique material gained in Tajikistan by researchers, experts, NGOs that are willing to provide additional information. This will make the process more transparent. Tajikistan The feasibility study consultants presented a separate project Yes. Assuming the current schedule is maintained, final draft 32 report on the stages zero one and two. The screening report reports covering all aspects of the ToRs for both the TEAS provides information about the expected time of reporting. and ESIA will be available in the first six months of 2013. What is the expected timing of reports for phases zero, one and two? Will all the three most important reports presented by the end of 2013? General comments on the assessment studies Afghanistan Good morning to all the representatives from all countries, and The Assessment Studies are intended to assess, first, if the on behalf of civil society from Afghanistan, I will congratulate proposed project is viable technically, economically, socially, the people of Tajikistan for this great initiative. Definitely internationally, and environmentally, and, second, to identify Afghanistan as a neighboring country will benefit from it, yet measures to mitigate and offset potential negative impacts. we have concerns on whether the project is handled right. That is our concern and that concern is equally shared, I think, by the people of Tajikistan. Afghanistan … this project will also bring a lot of new opportunities, social Several positive aspects of the proposed project were and economical and many other opportunities to the region, not identified by stakeholders. The PoE recommends that new just to the people of Tajikistan, but to the whole region. I would regional opportunities and positive regional impacts like to ask the team that they should also focus on the (including contributions to climate change adaptation opportunities during the assessment and during the study measures) be considered in the Assessment Studies. The because we should not just focus on the negative, we should also PoEs encourage riparian countries to cooperate in studies of focus on the positive as well. I think this will complement the possible downstream impacts. study. So this is my particular request to the World Bank team. Tajikistan The Rogun HPP and reservoir are regional but we assess the negative impact of the hydropower installation on the downstream countries. However the project brings a lot of benefits to the region as a whole. That includes ensuring water security in dry years (2000 or 2006), were major flow augmentations from the Nurek reservoir. The Rogun HPP produces clean and cheap energy. The fuel resources, i.e. coal, oil and natural gas are saved to generate electricity and reduce emissions of carbon dioxide into the atmosphere. The Rogun HPP also has a positive effect on reducing the risk of floods, landslides and droughts. Are these aspects taken into account in any research, which has been already conducted or is being conducted, or will they be taken into account at a later stage? ESIA Screening Report – Overall comments Afghanistan Afghanistan is missing from the water allocation tables. The water allocations under Nukus do not take Afghanistan 33 into consideration; however Afghanistan will be factored into the analysis of downstream flow impacts. Tajikistan Has an assessment of the effectiveness of different power An assessment of different power production alternatives is production alternatives been carried out? This would show the underway as part of the TEAS. It will explore the options effectiveness of hydropower generation in the context of clean available. electricity. Due to the increase in fossil fuels e.g. in a CHP plant, the chemical composition of the atmosphere changes. Given the The incremental benefit of reduced greenhouse gas emissions fact that the hydropower surplus produced can be sold to the will be taken into account. neighboring states and used in the country itself, this will give an option of not building additional CHP plants and thus reducing the impact on the environment because CHP emissions lead to a lot of environmental adverse effects. Have such calculations of efficiency of a HPP been carried out to compare with other sources of energy generation? Kazakhstan I could try to answer one of the questions of our colleagues, Thank you which had previously been posed, regarding the greenhouse gas emissions; we can roughly estimate the capacity of a coal plant with an installed capacity or similar capacity; that is about 3.5 GW. Such a plant fueled by coal would emit about 5-7 million tons of CO2 per year or even more. Thus the construction of a hydroelectric power plant will make it possible not to emit this amount of the greenhouse gases, and this figure is perhaps even higher. Kazakhstan One of the criteria is the availability of alternatives of A “Least Cost Generation Plan”, which explores alternatives, comparable value. In this regard, I have a question: does the will be completed as part of the TEAS. World Bank have the methodology for the evaluation of such alternatives? If so, it would be quite useful to use it in this project. Then it will eliminate a lot of questions and unnecessary stress Turkmenistan The Screening Report mentions that “construction is ongoing at Since the writing of the Screening Report, conditions have the site” changed. The World Bank can confirm that all non- maintenance-related work at the site has ceased in accordance with the Bank’s conditions for continuation of the assessment process. Until such time as the Assessment process concludes, no water will be diverted, and works on site will be limited to maintenance, as agreed by the Government of 34 Tajikistan at the highest level and as publically affirmed by both Tajikistan and the World Bank. ESIA Screening Report – Legal and Administrative Platform Tajikistan Comments on Chapter 2. ‘Legal and administrative platform’. This will be noted to the GoT for advice to the consultants. Paragraph 2.1 Environmental protection. Appendix 2.1 of the The Bureau of Human Rights has been active in the area, Report provides a simple list of the environmental laws of the monitoring compliance with Tajik laws. A representative of Republic of Tajikistan without any appropriate comments. This the Bureau reported at the November 7 meeting that all laws list lacks an important law, the ‘Land Code of the Republic of were being respected. Their report can be found at: Tajikistan’ . A key requirement of the international standards http://www.bicusa.org/en/Document.102958.aspx including those of the World Bank is to ensure compliance with the national legislation of the country in which a project is implemented. The key legal requirements concerning the Rogun hydroelectric power project have not been considered. Tajikistan A schematic illustration of the standard procedure for EIA is This will be noted to the GoT for advice to the consultants. shown in Figure 2.1 of the Report. The diagram has not been translated into the Russian. The diagram should be related to the existing situation at the Rogun HPP; in other words, based on this standard scheme and ToR, a new EIA diagram in relation to the Rogun HPP should be made. The Report does not contain such an important diagram. ESIA Screening Report – Project Design and Cascade Tajikistan Paragraph 3.3 ‘Brief History of the Project’. At the very end it This will be noted to the GoT for advice to the consultants, says that ‘the subsequent damage was caused by the earthquake who will update the details to include the magnitude of the in 1995’. Would you please comment on this statement in the earthquake and the type of damage. ESIA report. ESIA Screening Report – Environment Are there likely to be reservoir-related health impacts and There are health risks, mainly for the work force, related to disease? the construction period. However, unlike for projects in tropical areas, under the given climatic conditions there is no risk of spreading of waterborne diseases due to the reservoir. ESIA Screening Report – Resettlement Kyrgyz Concerning the resettlement program, how are the sources of World Bank policies require that livelihoods, beyond strict Republic subsistence going to be restored or assisted in restoration? resettlement, are to be considered. This issue has been raised with the consultants by the PoE. Livelihoods are to be incorporated into the resettlement plan. 35 Kyrgyz The resettlement program is very ambitious. Does the World The World Bank’s Safeguard policy on Resettlement handles Republic Bank follow the Free And Prior Informed Consent of the the issue of informed consent through its thorough public population? Proposed was a mechanism of making complaints information sharing and consultation, disclosure and but the experience of working on the World Bank projects shows grievance procedures. Free prior and informed consent is a that quite often people are simply not trained in how to deal with complaints. Do you plan to provide any complaint handling principle applied to indigenous peoples, and hence is not training, and will all the documents be translated into the national relevant in the Rogun context. Nevertheless the ESIA and languages of all the riparian countries (Tajik, Uzbek, Afghan RAPs will provide for broad and meaningful consultations etc.)? with the populations affected by Rogun. There is a grievance mechanism at 3 levels, timely consultation with affected peoples, measures to address local populations, and final documents (but not drafts) are translated into local languages. On the capacity of local populations to access these mechanisms, this has not been an issue thus far, however we will continue to take this point into account going forward. Kyrgyz A proposal concerning resettlement in connection with the Thank you for this reference. Livelihoods is a core element Republic construction of the Rogun HPP. In the presentation, which in a resettlement plan under World Bank policies and has explains the resettlement issues in the context of six villages been noted by the PoEs (see above). (about 42,000 people), the speaker has noted that the HPP itself will provide jobs for the people and thereby improve the well- These are issues that are being dealt with in the RAP. being of the population. What will be with the living standards of The villages mentioned are only those located in the the migrants themselves? According to the information received, construction area, which are in the process of being relocated they will be relocated upstream, how far will it be from the HPP (Stage 1 resettlement). The number of 42,400 people refers to itself? Will the immigrants find any work there? In this case, if the entire reservoir (with a total of about 78 affected villages they it is not for them to get every day/shift to work at Rogun, – Stage 2). some related training should be organized as the settlers have Affected people have a choice between different relocation been mainly engaged in agriculture. sites. Most of the households relocated so far chose a site in The GEF project on Sustainable Land Management in the High downstream areas, where living conditions, including the Pamir and Pamir-Alai could be an example of how you can potential for finding jobs, are generally better. contribute to local communities through grants co-financing by the zhamaats (selected groups of households which tend to be 36 poorer families combining 8-10 families from one ail (village)). This experience (proven in Tajikistan) is more than adequate for working with immigrants from Rogun, which for the most part are rather poor households, in order to provide them with decent living conditions. (Appendix: a PALM medium-term report in English) Kyrgyz The issues of ethnic relations should be approached very sensibly Potential ethnic issues must be treated with care. Republic as the Jirgatol District is predominantly populated by the Kyrgyz. Rogun dam site is located in the Rasht region, which is divided in seven districts (rayons), namely, Fayzabad, Rogun, Nurobod, Rasht, Tavildara, Tojikobod and Jirgital. The Construction site and the future reservoir will directly affect Rogun, Nurobod, and Rasht. Jirgital (Jirgatol) district,. There is no Kyrgyz population in the affected districts. Tajikistan I would like to express my opinion concerning resettlement The work of this CSO is appreciated. The Rogun Relocation because since 2010 our organization has been working on Report (2012) as available protection of the rights of the affected people who would be at:www.bicusa.org%2Fen%2FDocument.102958.aspx&ei=eS resettled in the context of the Rogun hydropower project, and PGUKbLEeSn0AGh- there were many issues directly related to the relocated people. YDQDA&usg=AFQjCNFn6PD57j2EHMlxpjkZIL6byo5Nsg As for people affected by resettlement, I would like to say that we have worked quite closely with the management of the Rogun The Environmental and Social Consultant is aware of this hydropower plant flood zone. In cooperation with this work, and the recommendations are included in the RAP. organization we held a public hearing to clarify the Rogun hydropower plant issue and possible future consequences. Our organization provided legal advice directly to the affected population. Also in 2011, we conducted a study with respect to the rights of people in connection with their resettlement. I would also like to say that the migrants are satisfied with the process of resettlement in general. As a result of our study, we have not identified any serious violations in terms of human rights. Of course, there were some issues we disagreed with; those issues concerned compensation, infrastructure construction and property evaluation. Based on our research, we developed recommendations. All of our recommendations were sent to the Government, the Flood Zone Directorate. I would like to note that almost all of our recommendations have been taken into 37 account; and today there are no serious problems with regard to resettlement. Kyrgyz I would like to ask our Tajik colleagues to send us their report on See note above Republic resettlement in order to make sure we understand what you have said. I have serious doubts about what you have said. The thing is that 40,000 people are affected by resettlement, and you have no complaints. In fact we have 100 people to resettle, and a lot of claims are being made; it is a whole city to build with all the infrastructure and utilities. Therefore I would ask you to be more responsible for your words. I would like to call for this competence, and maybe you are right, but could you please send us your entire report, the final study? Tajikistan Comments on Chapter 5. ‘Environment: General’. These contradictions have different reasons: Paragraph 5.2 The case of the Rogun HPP. In paragraph 5.2(6) it  Rogun is a rather old project, which originated in the is stated that ‘major social consequences are represented by the 1970ies, with a start in construction in the 1980ies; fact that about 63 kishlaks (villages) with a population of about  during the social unrests after independence there 30,000 people are subject to resettlement’. However, according to was a great deal of population movement, also in this Table 18.6 ‘Kishlaks in the project area’ (CECN Volume 2. part of the country: Appendices), the exposed population is 41,900, and the number  the final decision on reservoir elevation still needs to of villages is 72, and according to the presentation of the be taken; Consultant (Rougu) as of 7 November 2012 the number of the  there is as yet no detailed final resettlement planning, resettled population is just 44,700 including: 2200 people at the which means that for some villages it is still not clear first stage and 42,500 people at the second stage (consequently whether they will have to move or not. seven villages at the first stage and 63 villages at the second For these reasons there are reports from different project stage). All the three places show different numbers of population stages, all with some uncertainties. It is part of the ongoing and settlements without specifying the date of fixing population work to come closer to a realistic description of the actual and without specifying the source of information. What can the situation. reader derive from a comparison of conflicting data of the same consulting company on the same issue? ESIA Screening Report – Archaeology, cultural heritage Kyrgyz What archaeological or cultural sites will be in the area of The ESIA consultants have made an assessment of the Republic construction of the Nurek hydropower plant, if any? situation. About 10 sites were identified; however, most of them have largely been destroyed by past construction activities, road construction and so on. There is one in the upper part of the reservoir which is largely intact; a program for excavation and analysis of this site is being proposed as a 38 mitigation measure that should be carried out before impoundment. Turkmenistan Perhaps every village has a cemetery. Cemeteries may not be in Cemeteries are an important cultural issue. The Tajik the bed of the reservoir, as the downstream water will be used for government has a process in place that determines how the various purposes including drinking water. Have the reburial relocation of cemeteries has to be done. Actual relocation of issues been addressed? graves is being done with the local authorities (including Tajikistan Mosques should be included in the list of community religious authorities and the people of the affected villages). infrastructure items. Almost every kishlak (village) has a mosque subject to relocation. In the region almost all of the male adult Resettlement includes relocation, reconstruction and in many population of villages goes to a mosque each day. In the new cases improvement of public and social infrastructure. This areas of compact settlement provisions should be made for includes mosques and public meeting places (which in many allocating a small size of land for the construction of a of the affected villages are actually the same). community mosque. Tajikistan Comment to Paragraph 15 ‘Archaeology’. Almost every village has a mosque, and almost every village has its own cemetery. The zone impacted by the reservoir also has holy places for the local residents. The CECN report says nothing about that (does not take into account). Tajikistan Paragraph 37 says as follows. The Consultant will focus on the physical cultural properties, such as any cultural, religious, historical or archaeological sites including: cemeteries, - burial places, which may be flooded or damaged due to the construction of the dam, the shallowing of the reservoir, open design, construction camps as well as access and transport roads. -- The religious sites and holy places of the local value have not been studied. Availability of animal burial sites have not been assessed. ESIA Screening Report – Water resources/Transboundary issues/ Riparian impacts / Climate Change How much will be evaporated from the reservoir? Evaporation occurs in proportion to the area of the lake surface, whereas precipitation is proportional to the surface of the river basin. In the case of the proposed Rogun reservoir, although minor compared to inflows, reservoir evaporation will be included in the models. The hydraulic cascade model will include losses due to evaporation. Afghanistan There is not much coordinated focus on the downstream impact Downstream flows are a critical issue that was discussed 39 on the riparian countries. I would like for the team to pay close thoroughly during the riparian governments’ meeting and attention to that and then properly share with the riparian civil society information-sharing sessions in November. The countries and especially when Afghanistan has a plan to launch Government of Tajikistan has committed to staying within a big project of utilization of Amu Darya water and Kundus, and the obligations of the Nukus Declaration and Protocol #566. that will affect all these assessment, that is a plan in the future. Notwithstanding, a careful analysis of potential changes in flows across borders will be assessed under a variety of scenarios for both filling and operational modes of the entire Vakhsh cascade, and using various hydrologic conditions. This modeling effort will be introduced in the next set of riparian meetings. Transboundary assessments of the middle and lower reaches of the Amudarya will be undertaken should potential changes in flows at the border indicate impact. Kyrgyz Several times it was mentioned that in the simulation the climate The consultants will first undertake a full review of existing Republic change impact and changes of water regime on the Vakhsh and climate change studies, data and analysis of climate change in Amu Darya river basins would be considered. What models will Central Asia, after which an approach (including choice of be used? How close will these models be to reality to predict the estimates) will be determined. future development of these issues? Kazakhstan Are there any data or peer review of the project on the territory The government of Kazakhstan is participating in the riparian of Kazakhstan? This concerns the environmental impact, maybe sessions and receiving interim documents. climatic change, it would be interesting to see such information. Located on the Amu Darya, the proposed project will not affect flows in the Syr darya that runs through Kazakhstan. Further, the proposed project will not likely create or affect micro-climates; therefore, not climate effects in Kazakhstan are expected. The project is not expected to have an impact o climate change but the effect of climate change on the project will be considered (see note above). Kyrgyz • The climate change will have a negative impact on mountain Climate change will be examined as part of the Assessment Republic ecosystems by affecting the living standards of the population in Studies. The role of a reservoir such as Rogun in the upstream regions, as well as the city and downstream contributing to adaptation has been identified as a potential environment depending on the mountain goods and services. benefit. Assessment of this benefit will be partially captured First of all it concerns the degradation of glaciers, which will in the examination of flood routing. The PoE recommends affect water availability with a high proportion of glacial runoff; that the Assessment Studies consider potential positive but upon further warming you should expect negative regional impacts. consequences for many other rivers in Tajikistan too. By 2050 thousands of small glaciers will completely disappear in 40 Tajikistan. The glaciation area of the country will be reduced by 20%, the amount of ice will decrease by 25%. Therefore, researchers recommend the construction of reservoirs in addition to dams, which feed HPPs, in order to better control the water flow given the outlook for glaciers melting in the context of global warming. In the presentation and paragraph 7.4.2.2 of the ESIA there is a mention of the ‘climate change impacts in the Amu Darya basin, which will have a far more decisive effect on the amount and distribution of flows in the future’. Will the future assessment take into account the positive impact of the Rogun HPP water reservoir on water storage to compensate for the loss of moisture in glaciers due to the climate change? Kyrgyz • As a mountainous country, with a similar climate and natural Glaciers are considered in assessing hydrology. There are no Republic conditions, I have not heard from the presentation whether there glaciers in the proposed construction zone. any glaciers in the proposed planned development area and whether they fall under the area of construction. Which are those glaciers in Tajikistan? Kyrgyz What will happen in the upstream in the context of filling the The proposed reservoir will have no or negligible impact on Republic reservoir? What is the volume of the reservoir, and how will the microclimate of the area, let alone on regional climatic water reservoir influence the change of the climate layer at the conditions in the upstream or downstream areas. upper part of the basin? The Vakhsh River that will fill the Rogun HPP is formed by the rivers Mussu and Kyzylsu. The river Kyzylsu is formed in Kyrgyzstan in the Alai Valley. Filling the reservoir will be expected to affect the upper part of the valley. Due to global climate change may influence changes in the landscape in the upper parts. World Bank need to examine not only the processes that occur in the lower reaches, but also the processes that may occur in the upper reaches of the reservoir. Does the authors of the project the changes that may occur. I propose to put several hydrometeorological in Kyrgyz Republic in the Alay Valley to track the changes that will occur after the filling of the reservoir. Turkmenistan • Concerning the presentation of Robert Zvallen: it was pointed Downstream flows are a critical issue that was discussed out that a medium change in the water regime has an impact at thoroughly during the riparian governments’ meeting and the local and national levels. To what extent has the impact of civil society information-sharing sessions in November. The changes in the water regime at the international level for the Government of Tajikistan has committed to staying within 41 downstream countries been studied? the obligations of the Nukus Declaration and the PoE advises the GoT to actively explore possibilities of implementing the • Concerning presentation 5 on climate change. We agree with Rogun project without having to change current flow the Kabul delegation that the impact on the downstream conditions across the border. Notwithstanding, a careful countries should be seriously explored. It has been said that the analysis of potential changes in flows across borders will be climate change has a very high level of ‘uncertainty’. It is very assessed under a variety of scenarios for both filling and important for Turkmenistan, according to the recent information, operational modes of the entire Vakhsh cascade, and using for the last 10 years our rainfall amount has decreased by 33% various hydrologic conditions (including potential impacts on compared to 5% predicted for the next 50 years. Therefore the flows from climate change). This modeling effort with study of changes in the water regime for the downstream scenarios will be presented in Phase 3. Transboundary countries and especially the effect of changing the regime, plus assessments of the middle and lower reaches of the the change in climate are very important to us in terms of the Amudarya (e.g., analysis all the way down to the Aral Sea) socio-economic impact assessment and from the standpoint of will be undertaken should potential changes in flows at the environmental impact. There is an important nature reserve with border be identified to inform on risks to accelerated unique riparian forests downstream the middle course of the desertification and livelihoods in the lower basin. Assessing Amu Darya. How will these issues be addressed and included in potential downstream impact would benefit from full riparian the assessment? cooperation. Turkmenistan Slide 13, ‘Rates of Filling and Draining of the Water Reservoir’. Will the downstream demand for water be taken into account, will the demand be considered only at the level of Tajikistan or all the downstream countries, and how is it all going to happen? Uzbekistan Intensive desertification begins with the reduced flow of the Amu Darya. How and who in the project has studied the desertification-related changes in the Amu Darya downstream countries? Tajikistan • Comments on Chapter 8 ‘Water Resources’. The potential effect of the proposed Rogun project on river Paragraph 8.3.4 Combined effect of the Nurek dam and flows (volume and pattern) will be examined in detail, irrigation It is practically important to determine the impact of coordinated with updated hydrologic data (see presentation changes in the regime of the Vakhsh River due to the Nurek on Hydrology) and cascade modeling. The modeling work hydropower installation, on the regime of the water table and the will be outlined at the next riparian meeting. irrigated lands in the Vakhsh valley. All researchers note a ground water table rise and the intensification of resalinization Downstream flows are a critical element in understanding the of irrigated land in the Vakhsh valley in Tajikistan. Whether this potential risks and benefits of the proposed project. The is also related to the seasonal changes in the water flow and modeling will, first, determine the potential impact on flows water level in the river Vakhsh as a consequence of operation of at the border with Uzbekistan; if, under a variety of scenarios, the Nurek hydroelectric installation. If it is related, then to what an impact could occur, then implications in downstream 42 extent? countries will be assessed. Tajikistan • Paragraph 8.5 Residual flow (sub-paragraph 8.5.4 Recommendations). The Consultant recommends to use the residual flux (ecological minimum) at a rate of 150 m³/s or 10 m³/s or zero flow for hydraulic modeling. I think that none of the options can be acceptable for the following reason. According to the regulations and well- established rules, a sanitary flow minimum of 100 m³/s is maintained at any time during the year along the whole length of the river Vakhsh and Amu Darya. That is the residual flow. This figure is confirmed by the Consultant itself in all its charts and diagrams (the minimal actual flow exceeds 100 m³/s in any case). To ensure operation of the HPP of the Vakhsh cascade in normal conditions during the year, the flow downstream of the Nurek hydroelectric installation may not be less than 400 cubic m³/s. This passage referred to as ‘energy’ one is needed to fill the valley reservoirs for irrigation, as well as to ensure the planned flows in the irrigation systems of the Vakhsh River basin. This standard is also met. Under the project, the regimes of the Nurek and Rogun water reservoirs are determined by the requirements of the Amu Darya river basin including the hydropower operation. The passages from them are set at no more than the minimum required to ensure a given water use in the downstream area, and all the excess flow is accumulated within the useful volume of the Nurek and Rogun reservoirs. Discharges are allowed only after filling up to the normal water level. Consequently, operation of the Rogun and Nurek reservoirs is subject to the rules of compensating flow augmentations for irrigation consumers of the middle and lower reaches first. However, given the importance of those hydropower installations, they cannot reach the dead-storage level at once but sequentially from the Nurek one by setting up several levels of dispatch. We should not neglect it as an ‘obsolete hypothesis’ but take into account all of the above and the residual flow in the 43 downstream of Rogun HPP for hydraulic modeling taking not less than 100 m³/s, down the Nurek hydroelectric installation at least 400 m³/s. • Paragraph 8.7.2.1 Contribution of the EIA Consultant (current situation). The Protocol # 556 for Tajikistan in the Amudarya river basin there established a water intake limit of 9.5 billion cubic meters of water per year. This parameter includes the intakes of the basin of the rivers Panj, Vakhsh, Kofarnihon and Surxondaryo. However further in the report the possible limited amount of water intake of the Vakhsh river basin itself is not provided. But the hydraulic modeling should consider only the water intake for the Vakhsh river basin. The actual intake of the Vakhsh river basin over the last years of the USSR (1988-1991) was 4.0 - 4.7 billion m3 of water per year. • Comments on Chapter 8 ‘Water Resources’. Paragraph 8.3.4 Combined effect of the Nurek dam and irrigation It is practically important to determine the impact of changes in the regime of the Vakhsh River due to the Nurek hydropower installation, on the regime of the water table and the irrigated lands in the Vakhsh valley. All researchers note a ground water table rise and the intensification of resalinization of irrigated land in the Vakhsh valley in Tajikistan. Whether this is also related to the seasonal changes in the water flow and water level in the river Vakhsh as a consequence of operation of the Nurek hydroelectric installation. If it is related, then to what extent? Tajikistan The environmental screening report provides the effects of The role of a reservoir such as Rogun in assisting with changes, or indicates that the effects of climate change in the climate change impacts and adaptation has been identified as Amudarya basin will have a much more crucial importance. a potential benefit. Assessment of this benefit will be According to the report and geologic information it can be partially captured in the examination of flood routing. The observed that a reduction in the volume of glaciers up to 70% PoE recommends that the Assessment Studies consider leads to the earlier shift of the floods. Question: How do you potential positive regional impacts. 44 assess the impact of the Rogun reservoir on mitigation of the negative climatic impacts in the regulated source of the river Vakhsh? Tajikistan Comments to Chapter 17 ‘Cross-border issues’. This does not relate to the situation in natural rivers, but to Paragraph 17.4 Open issues. I do not agree with the conclusions the case when dams are being built. There is no binding of the Consultant that ‘the existing rules do not ensure regulation (law) which defines a minimum ecological flow to preservation of the ecological flow of the Vakhsh and be released from dams in order to maintain ecosystems Amudarya’. As for the Vakhsh river, the sanitary depending on these rivers. In the case of run-of-river power (environmental) flow augmentations with a flow rate of 100 plants, as those along the Vakhsh downstream of Nurek, this m3/sec are continuously maintained year-round. The is not of much concern. consumption has never been less than 100 m3/sec at the mouth of the river Vakhsh. Tajikistan The Consultant said that ‘the water/power interdependence This will be noted to the GoT for advice to the consultants. could be observed in the Soviet period whereby water and energy could be freely exchanged on mutually beneficial terms, and it no longer existed’. This statement of the Consultant is not true. In the Soviet period a united energy system of Central Asia was effectively in pace. Like the Nurek HPP, it was run by Moscow. By seasons of the year there were energy cross-flows from one union republic to another. But this was not, under any circumstances, associated with the water exchange. Water was managed by the USSR Ministry of Water Administration, and energy was managed by the USSR Ministry of Energy. There had never been any swap transactions between them, e.g. ‘water in exchange for energy’ or vice versa. In summer the Ministry of Water Administration might not ask to let water running idle and by-passing turbines in exchange for supplying under-supplied energy as they did not have any HPPs. TEAS – General comments Afghanistan We would like to hear from the team the future policy of the The expected utilization of the energy will be analyzed as Tajik government on the utilization of the energy of this part of the economic assessment. The consultants will hydropower station. How they will utilize internally and also examine exports markets as well as domestic demand. internationally the energy? What will be their policies and how do you allocate that? What will be their policy to transfer the energy to Southeast Asia and to neighboring countries, and we 45 would also like that this part should be included in that assessment. There is nothing mentioned about the after-dam construction on the utilization policy of the energy of this dam. Kyrgyz Are there any payback estimates for the project, in how many The economic analysis is a critical part of the assessment Republic years will it reach the payback level? studies. Work is currently underway (see comment above) and will need input on the optimization of dam heights and installed capacities. Tajikistan According to recommendations of the Experts Panel, the design Hydroproject is contracted by the Government of Tajikistan; criteria had to be developed jointly with the Moscow Design publishing of its comments will be requested of the Institute ‘Hydroproject’. In the Report contribution of Government. ‘Hydroproject’ to the criteria development is not specified. Could you please publish the comments of ‘Hydroproject’ on the design criteria. Kyrgyz Could the ICOLD standards could be made available? ICOLD members may download bulletins from Republic http://www.icold-cigb.org/GB/Publications/bulletin.asp TEAS – Hydrology Uzbekistan The hydrological outcomes and solutions cause concern. The Hydropower operations do not consume water (although presentation author spoke of a hydrograph and gave the results, reservoir evaporation is in fact a “water consumption”), but There will be problems for the hydropower sector even with the use it as it passes through the turbines. The water will hydrograph. Let us consider that without this hydrological flow, continue on its course, with the exception of abstractions for there will be needed passages, around 40-50% for the supply of (for example) irrigation unrelated to electricity generation. the downstream regions, Turkmenistan, Uzbekistan and However, the pattern and timing of flow may be affected Afghanistan. which will be the subject of thorough assessment; the What will be left of the hydrograph for the operation of the modeling work will explore the use of water from the reservoir and other processes? proposed reservoir, through the Vakhsh se hydropower cascade, to the border with Uzbekistan, and beyond should possible impacts warrant. Kyrgyz Concerning the speech of Alexander Palmieri on water This comment will be passed along to the consultants. Republic resources. It is said that the flow of the Vakhsh river has been measured since the early 1930's and there are many gauging stations. At the moment, we are interested in filling this reservoir in Kyrgyzstan. The reservoir will be on the border of Tajikistan and Kyrgyzstan. The report says almost nothing about the flows that come from Kyrgyzstan and are formed in the Pamir Mountains, i.e. Kyzylsu and Mukhsu. The given data concerning the basin of Vakhsh, the rivers Indush, Chinar, 46 Biknazar, Sardaryad and Tyuminar, on the downstream flows. Why does it not provide any data on the upstream flows Kyzylsu and Mukhsu? Please let us make predictions and modeling on the upstream threats; we have the weather information for hydrometeoinformation on the upstream river flows that will shape and fill the reservoir. 86 hydrometeostations out of 32 are left in Kyrgyzstan. In the upstream, at Mukhsu only one is left, and that does not give full information. Tajikistan We are pleased with the report on hydraulics, and not because This will be noted to the GoT for advice to the consultants. there are results, but simply due to the approach and results. Turkmenistan • A question to presentation # 7, Slide 13, the parameter ‘Fill Impact on flows will extend to the full area of potential and run down rates of the reservoir’. This will take into accountimpact. As a first step, a number of scenarios will be the demand for water downstream. Will it take account of explored to understand the potential changes in flow volume and pattern at the border with Uzbekistan. The PoEs have demand only in Tajikistan or all countries, and how is it going to happen? repeatedly expressed the importance of these analyses to understand potential transboundary implications. TEAS – Geology / Seismicity / Dam Safety / Mudflows / Floods / Underground waters Uzbekistan There is a need to study the tectonic faults and other processes. Information from past studies provides answers to many First of all, it may be due to the limestone, salt layers and other geological issues. However, additional site investigations things but the tectonic faults are mainly important for geological were deemed necessary to: i) update old information, and ii) surveys. What was the basis of the research? Obviously the used to address particular aspects in the complex geological data on faults were obtained sometime in the 1960-1970s. context of the site. They are completed except hydro- Recently, no such studies have been conducted. If you make geological tests. Results of the investigations will be used in observations in recent years, it will be possible to detect the final geological assessment and calculation of seismic problems with respect to the seismic influence. risk. Based on preliminary results and numerous site visits, the opinion of the Engineering and Dam Safety Panel of Experts is that suitability of dam site and type of dam can be confirmed. These conclusions are preliminary and the final draft assessments will be shared as part of the upcoming riparian consultation and information sharing meetings. Tajikistan • When the reservoir is filled, the groundwater, fissure-ground Stability of slopes are currently being examined, aided by site water, partially fissure-stratal water and fissure-karst water are investigations. dammed and their level rises to such marks, which allow them flowing into the reservoir again. This may lead to a breach of 47 stability of the slopes and soils. This has not been reviewed. • The Nurek HPP has greatly changed the natural mode of the This comment will be passed to the Government of Tajikistan river Vakhsh highly adapted to the irrigation. This fact has been to share with the consultants. known since long ago. This is clearly illustrated in the chart 8-13 on page 42 of the Report. In summer the water flow decreased by 400 cubic meters per second, and in winter it increased by 200 cubic meters per second, contrary to the natural mode. As a consequence, the water levels of the river Vakhsh within the Vakhsh irrigated valley have changed. The impact of these changes on the mode of the ground water table within the Vakhsh valley has not been considered. Was the increased ground water table and resalinization of the irrigated land due to the Nurek HPP? Tajikistan In the ‘Summary’ the issue of mudflows specific to the area was Mudflows are being examined as part of the geological left aside by the Consultant. The Consultant should take into studies. account and develop measures to prevent the formation of mudflows and control the mudflows already formed. This is necessary to ensure engineering protection of the reservoir of the Rogun HPP from mudflows and heavy siltation. It is necessary to create a number of small dams in the upstream of the side rivers in order to combat stormwater flows, retard flood runoffs in some tributaries of the rivers and thus prevent their simultaneous entry into the main artery of the river, the Vakhsh River above the dam. Kyrgyz A question concerning the calculations of the floods, one flood A “1 in a 10,000 year flood” (i.e. 0.01% chance of the flood Republic in ten thousand years, theoretically or practically, can they occur occurring in any given year) is a statistically determined flood more frequently? but it can, theoretically, occur at any time as the measure is probabilistic. With climate change, the return period may become more uncertain. Kyrgyz A question concerning the seismic magnitude of the induced The design MCE (maximum credible earthquake) is yet to be Republic earthquake, the figure was not mentioned. calculated. Tajikistan The recorded reservoir-triggered seismic intensity associated Data on reservoir-triggered seismicity collected on Nurek with the Nurek HPP activities requires a detailed study with the dam will be used when assessing the design for earthquakes help of local seismic networks capable of detecting low-energy for Rogun. 48 seismic events including those caused by the natural and man- induced processes. Kazakhstan Has any assessment of the possible mountain lakes upstream the GLOFs (Glacier Lake Outburst Flows) will be addressed. proposed site of the dam due to potential mudflows been made? Turkmenistan Has any assessment been made to take into account a negative The dam would be designed to accommodate extreme flood scenario or even a catastrophic one? For example, an and seismic events. It will also include measures that will be unfavorable seismic situation which may lead to the worst put in place to ensure that in the case of an emergency the scenario, e.g. the dam burst? reservoir level could be safely lowered. Uzbekistan What are the possibilities to effectively protect the salt dome at The salt formation is associated with the Ionakhsh fault which the base of the dam. It is surprising that it is proposed to passes under the upstream shell of the dam. Locating the dam monitor the salt dome at the base of the dam in the course of core downstream of the salt dome ensures essentially filling and operation of water reservoir, i.e. after the dam is hydrostatic conditions around the salt formation; this is of built. At the same time salt dome protection from the washing is fundamental importance for satisfactory long term behavior. one of the highest risks of the Project and all the needed Extensive studies have shown impermeable conditions of the protective solutions shall be elaborated and reflected in the salt at depth, on both valley sides. Grouting of the upper TEAS and undergo an expertise before the start of the Project zone, where dissolution has occurred, will be implemented should it be necessary according to specifications determined with a dedicated salt dissolution model. In addition to treatment of the upper, weathered part of the wedge, the following measures would be recommended to be defined in the operation and maintenance plan: - installation of a monitoring system to follow up performance of the treatment works during reservoir filling and operation; - definition of a contingency plan to identify remedial measures to be implemented in case the monitoring system triggers pre-defined indicators. Assessment of the salt dome effects on Rogun feasibility will be included in a special report (Phase 0) of the Techno- Economic Assessment study. Uzbekistan What approaches are being applied to the tunnels which pass Pressure tunnel alignments are being studied to avoid or through the tectonic faults? minimize the crossing of active faults; special structures (intakes, gates rooms, transitions, etc.) would be located as far as practicable from faults. In correspondence with faults crossing, provisions would be made to allow relative 49 movements of tunnel short sections and linings designed to support large external loads. The need for pre-planned maintenance interventions will be specified in the operation and maintenance plan of the works which will be part of Phase II report. Uzbekistan • Despite the long-term study, the consultants do not confirm the The original design of Rogun HPP adopted a central core dam safety issues in terms of seismic activity and the height of rockfill dam. The Consultant has evaluated the existing the dam of 350 meters. What additional criteria are used to design of the dam and compared it with other dam types determine the safety in the context of seismic activity? feasible for the site. A concrete dam was not considered suitable due to high rock mass heterogeneity and presence of • The Rogun HPP site is located at the Vakhsh fault, which is a active, creeping faults. An embankment dam can seismically dangerous area and the highest one in Central Asia. accommodate fault movements, for both earthquake- The area also poses a great risk of stress in the crust. Has the associated displacement and continuous creep. expert group made a hydrodynamic assessment of the area? Installation of instrumentation (extensometers) for monitoring • What is the stress condition of the mountain massif at the site cavern deformations has been in progress since late of the underground construction? September; completion is expected by mid-January 2013. This activity is followed very carefully because of its critical • What is the potential of the spreading of the Ionakhsh fault to importance for safety. Excavations have been suspended until the water inlet of the Project? convergence measurements confirm stable rock mass conditions; this will be monitored by the World Bank. The right abutment forms a rather narrow saddle which, if permeable in depth, could cause leakages. Data so far indicate a low permeability of the fault zone in the higher parts of the abutments (gallery 1034, new borehole IF1), therefore connection appears difficult. Results from two boreholes have shown rock mass permeability which suggests extending the grout curtain inside the saddle area. The length of the extension will depend on the position of the water table inside the saddle area. Tajikistan I would really like you to get all the materials that we have Thank you. collected. We have studied the area and history of earthquakes since 1490 to the present day. The earthquakes over the past 120 All of the seismic data collected in Tajikistan will be assessed years have been described in detail; I think it will soon be and used in the Phase 2 design. translated into English and passed to you. We have studied all 50 earthquakes that occurred in Tajikistan and neighboring Afghan earthquakes with a high scale. None of those earthquakes created the strength and intensity of more than 6 points. But despite this, all the estimations for Rogun HPP consider 9 points. But I would like you to use our materials, and more than that, we would then show the world along with the American colleagues that seismicity cannot be homogeneous. Moreover, we have very detailed recent seismic data. These earthquakes have low magnitude. We would like the materials to be used and interpreted by you, not just by us. We hope that by getting all this information, you will be able to also evaluate the area. I am happy to have this opportunity, and I would like to say that in the near future we will make sure the materials are translated into English and made available to all the experts who would like to engage in the issue. Thank you very much. Tajikistan We hear the same questions from year to year, from month to Thank you. The geologic assessment, supported by month, in the same interpretation, with the same epithets - the additional site investigations, will further establish the status Ionakhsh fault, long-lived fault, active fault, the faults are called of faults and associated risks. The seismic stability of Nurek 35, 48 and so on. These faults do exist, and they are constantly Dam is recognized and lessons learned from Nurek will be being monitored, and now nobody will dare to call them “living” taken into account in Phase 2 works for Rogun. faults. Some of them have long been healed, e.g. the 35th fault has long been dead, and it will never recover. The others do not pose any risk. The member of the Academy of Sciences has just showed you some maps to demonstrate that surveys around those tectonic deformations had been made for decades and even centuries, and there was not any earthquake with a magnitude higher than 6 points. The seismic hazard is not much expected, but the project is designed for 9 points. Similar to the rockfill dam to be built at Rogun is Nurek, the first man-made dam which has shown its absolute stability for four decades. The parameters (filtration, density, stability) of the Sarez rockfill dam, which was formed as a result of a powerful landslide during an earthquake, have not changed for 111 years. There have not been any collapses for that period either. That is a natural modeling which cannot be compared with either physical or mathematical modeling in terms of reliability. Overall the 51 issues of seismic hazard and seismic resistance have been probably developed in Tajikistan at a level much higher than anywhere else, and it is due to the fact that we have a very intense tectonic area. Turkmenistan In the design of safety, control and so on, we should also Both events have extremely small probability. Probable consider a combined approach, that means not only separately maximum flood (PMF) has a probability of occurring which calculate floods but also combine with earthquakes. Will there is lower than once in 10,000 years. Maximum credible be a review of combined safety in the event of simultaneous earthquake also has a very small probability of occurring, maximum floods and earthquakes? What might be the outcome? which is again at least less than once in 10,000 years. The combined probability of those two events is an extremely low once in 100 million years. The international standard approach to designing dams is to use the more demanding risk level of one or the other. So maximum credible earthquake is normally combined with normal full supply level (not probable maximum flood) Some lower level earthquake can be combined with the probable maximum flood. Tajikistan • To paragraph 1.1 The applicability of the design criteria. The The design criteria are applicable to all segments and consortium says that ‘these design criteria will be used for the components of the proposed project, including existing stages 0, 1 and 2’ without mentioning that the criteria are works. designed for the full project and/or the first phase. Existing works would need to be upgraded where they do not • Paragraph 1.2 Existing structures. The Consortium stresses that meet design criteria. ‘these criteria are applicable to all components of the Rogun project designed for long term operation’. For us this means that the existing structures now being restored should also meet these criteria (safety, proper functioning etc.). Therefore, after identification and assessment of conformity of the constructed facilities to international standards, it will be necessary to properly develop new engineering design (design specifications and estimates) brining the built structures in compliance with international requirements. Obviously, a lot of time is going to be spent on that. • Paragraph 2.2.2 The probable maximum flood. The criteria of Flood management will be explored in depth, including in the the probable maximum flood flow are presented. But further in comparison of dam heights. 52 the report, the criteria for the safe passage of flood (estimated and maximum possible) are stated vaguely. It is advisable to cover this topic in a separate section. The fourth upper tunnel of the downstream Nurek hydroelectric installation is designed for flood discharge at a little over 5,000 cubic meters of water per second. TEAS – Sedimentation Uzbekistan Can you comment on the damaging effect of sediments on the Sediment loads and the way that the sediment travels through construction tunnels? the system and through the reservoirs is a very critical issue. Studies must not only look at the total sediment amount but The presentations provide no exact calculations of the alluvial the composition. It is a key issue for many major dams in the regime of tributaries of the Vakhsh and the Vakhsh itself. It world. Also the PoE has emphasized that sediment is depends on for how many years the Rogun HPP will be produced in natural processes that are affected by climate, effectively operated. 80% of the water reservoirs in the world and climate change can in fact affect the way sediment is are silted. Thus the issue should be carefully addressed and generated and deposited and so forth, and that needs to be calculations made. Then we will know for how many years the factored in. Rogun HPP will be effectively operated. This project has a very large inflow of sediments; the lowest estimates are of the order of 60 million cubic meters per year. There’ll be a dedicated study necessary to have a very good look at the long-term implications of sediment management strategy in this project, including sediment estimation and sediment mitigation measures. The sedimentation management issue is also addressed by the design criteria. For example, design of the river diversion tunnels will take into account the erosive nature of the Vakhsh River. The design will specify measures to provide adequate erosion resistance to the lining during operation period of the waterways. Such measures will be included in Phase II report of the techno-economic assessment. Turkmenistan • Although due to the potential rapid siltation of the-first-stage Construction at the site has stopped (except for necessary reservoir (for less than 10 years), the construction of the first maintenance to protect existing structures). stage of the dam to reach the level of 1110 meters above sea 53 level is technically not appropriate, the item has not yet been removed from the agenda, and construction of the first stage enjoys the active support of the local community. Editorial and Clarifications on Scope Tajikistan Environmental/Social Screening Report: • The sentence ‘the discussions which were held in August 2012’ (page B, last paragraph) should be corrected to: ‘the discussions held in August 2011’, further as the text goes. A similar amendment is necessary on page 10 of the Report. • The Report in Russian has been poorly edited or not edited at all. There are mistakes in the names, units and so on. Since the ‘Summaries’ of reports in Tajik are usually prepared from the Russian version, the reports in Russian need to be more carefully edited so that mistakes are not automatically transferred in the Tajik-language version. • Proposals for the structure of the report: the structure should be slightly modified and expanded to add separate chapters, ‘Key methods and methodological approaches’, ‘Legal requirements of the Republic of Tajikistan’, ‘The World Bank Requirements’, ‘Safety and Health’ and ‘ESIA Activity Plan’. For the reader’s convenience, all the covered issues on the environmental and social situation should be grouped and added to separate chapters, ‘The current environmental situation’ and ‘The current soc ial situation’. It would be advisable to make all the aspects identified as a separate chapter under the title ‘The significance of the environmental and social aspects’. All the environmental issues addressed should be presented in the first section under the title ‘Environmental screening’ whi ch will include all the chapters on environment. In the same way all the social aspects should be incorporated in the second section called ‘Social screening’. Such a structure would be more understandable to readers and match the name of the Report better. Paragraph 3.1 Location of the Project. Figure 3-2 on page 6 of the Report gives a diagram (an outline map) of the Rogun reservoir with the affected areas. According to the link, the Diagram was taken from the 1983 Atlas of Tajikistan. It has been 29 years since the publication of the Atlas. For the period there have been great changes in the populated areas, e.g. new settlements, extensive additions, newly built utilities (bridges, power lines etc.). Although the diagram shows the new names of districts and villages, the Diagram still needs more adjustment, updating and bringing to the level of early 2012. It is necessary to clarify the outline of the future reservoir and lines of the future water’s edge. Paragraph 3.5 ‘Cascade on the River Vakhsh’. Figure 3-3 has long gone out of date, nor it reflects the reality. For example, in the Figure the Shurob HPP and Sangtuda-1 HPP are marked with a red number as projects under construction. In fact the Shurob HPP is not yet built, and the construction of Sangtuda-1 was completed two years ago. The Perepadnaya HPP and Central HPP on the Vakhsh main canal are not functioning but the Figure shows them as operated. 54 Earlier this figure was several times demonstrated/presented by the OJS Holding Company ‘Barki Tojik’ and others at va rious conferences/events. Personally I have seen the diagram five times at various forums. I did not expect that after a few years I would see this pattern in the screening report of the Rogun HPP for the sixth time without a single change. Opinion on Chapter 13: Neither the Report, nor its Appendices give any data sources or population dates. The figures are different in different sources. We strongly recommend that the final ESIA report specifies the date and the population as of the beginning of 2012, or possibly the beginning of 2013 (or uses the data from the last national 2010 census). Due care should be taken that each settlement (in the text, tables and the Appendix) has the same census date and the same number of population. In general, the chapter ‘Settlements and Population’ is poorly developed. Tajikistan The purpose of the ESSR is to identify issues that are to be addressed and require study over the course of the Assessment Studies. As such, it is an interim report. These issues will addressed in the actual ESIA report. • A key requirement of the international standards is to ensure compliance with the national law of the country in which the project is implemented. The report simply lists the current laws of the Republic of Tajikistan without any appropriate comments. The key legal requirements in the context of the Rogun HP project are not considered. • Any feedback on the expectations, preferences and concerns? There is no analysis of alternatives. Inaccurate data lead to incorrect conclusions. • ‘Summary’ (page A) says ‘Prepare a work plan for further actions’ however a single consolidated work plan is not prepared. 4.2.2 Initial environmental screening and social screening (Objectives and performance assessment): Paragraph 26 ТЗ: To review the previous research at different stages carried out in the initial assessment/development; to study/summarize what has been done in the past in terms of environmental/social, legal and financial examinations, the current situation and actions planned for the future.– the legal and financial examinations, if any, have not been studied and summarized. Paragraph 27. To make a list, prioritize and explain the major environmental and social issues of the project; to assess whether they are were adequately addressed in the last stages of the Project. – a summary list is not compiled. Paragraph 28. It should carry out an integrated initial assessment of the environmental and social impact in accordance with the requirements of Tajikistan and the World Bank’s Operational Policies. -- The requirements of Tajikistan and the World Bank are not described. Assessment was made without regard to these requirements. In Paragraph 29: It will review the legal and institutional framework of Tajikistan for: - acquisition of land (and probably the disposal of land), - compensation and resettlement, 55 and - Make comparison with the safeguards of the World Bank and identify gaps and deviations. -- Not done. Comparisons have not been made; deviations and gaps have not been identified. In Paragraph 34. The environmental screening will cover the direct and indirect impacts of the Project. The screening range will be extended beyond the Project’s site prior to the assessment of impacts in the upstream and downstream. -- Assessment of the impact on the upstream was not carried out (above the impounded water level of the reservoir) In Paragraph 35. The social screening will review: - the land policies, - the land register and other official documents, - check the census - secure land tenure, - discuss with local authorities and community leaders the possible scope of the resettlement and socio-economic impacts for communities from the Project including the communities which will be hosting immigrants. -- Review of the land policies has not been carried out. The population census has not been checked. In Paragraph 35 – (continuation). It will provide an overview of the Tajikistan law on issuing permits and the role of the Department of Energy/Environment as well as land acquisition and resettlement; and make a comparison with the safeguards of the World Bank. Any significant deviations and gaps should be identified. – Not performed. Paragraph 38 (continuation). The consultant is recommended to study Appendix 4 of the ToR on ESIA for a more detailed explanation of the issues that should be considered when conducting a social assessment for the Project. -- Only the comments to Table 4 are given, the table has not been taken as a guide. The medical and biological analysis of the flood zone has not been executed. In Paragraph 38. Social screening should be conducted to understand the socio-economic profile of the impacted communities and in order to develop activities to meet their development needs and mitigate any possible negative effects. – It was carried out only for the first stage. Comments on Chapter 3. ‘Project’. Paragraph 3.2 Rogun HHP. Table 3-1, ‘Key Parameters of the Rogun HHP’ does not specify the designed average annual electricity production (billion kWh) for the the first stage and for the project as a whole. The annual electricity production is a 56 key parameter of a hydropower plant. Comment to Paragraph 2.2 Relocation. This paragraph contains 2 decrees of the Government of the Republic of Tajikistan (# 467 of October 1, 2008 and # 47 of January 20, 2009) concerning the procedures for internal migration in Tajikistan and concerning the Plan of Resettlement of the Rogun and Nurabad areas from the Rogun flooded area. In this paragraph the Consultant was required in the form of a table to compare the relocation requirements of the World Bank and corresponding legal provisions of the Republic of Tajikistan. When making a comparison the Consultant would have discovered the main difference, there is no resettlement procedure well-defined and circumscribed in law in Tajikistan; there is no directly applicable law to ensure the order and procedures in the case of involuntary resettlement; the Consultant would have revealed some other deviations from the World Bank requirements. For example, the terms ‘relocation’, ‘involuntary resettlement’, ‘forced migration’ cannot be found in the legislation of the Republic of Tajikistan. In thi s regard, there is a potential for the implementation of any resettlement strategy including the ones not fully beneficial to the population. It is needed to review the norms of civil, land, housing and budget legislation applicable to relocation of people from the flood zone of the Rogun HPP (applicability of the budget legislation is determined by the state responsibility for relocation and by the use of budget funds for such purposes). The review should be carried out in 2 ways: the right to housing and property rights of citizens. • Comment to Paragraph 13. ‘Relocation and Population’. Paragraph 13.2 Special conditions of relocation of the Rogun HPP. (Note: the name of paragraph 13.2 is worded wrongly, editing is required). From paragraph 13.2 to paragraph 13.4.2 ‘Approach’, outlined is the explored current resettlement program that does not meet the ToR requirements particularly those of the second part of paragraph 29 of the ToR. The main description requirement is the complete coverage of the potential social problems but not the complete information about them. The ToR required making an overview of the Tajikistan’s legal and institutional framework in the context of land acquisition compensation and resettleme nt, and making a comparison with the World Bank safeguards as well as identifying gaps and deviations. For that purpose it was necessary to set out in detail the ‘Legal framework of relocation in Tajikistan’ (the citizens’ right s, the rights of citizens to housing, provision of housing to owners, enforcement of the citizens’ rights to compensation for property and land lost). Then it would be necessary to set out the WB requirements in respect of resettlement, compare the basic requirements of the legislation of Tajikistan and the World Bank, identify gaps and deviations. Then a review of compliance of the implemented, ongoing and planned relocation with the World Bank requirements. The Consultant is also required to develop mechanisms and procedures necessary to achieve compliance with the WB requirements. The above paragraphs have nothing like that. These items should be copied to the Appendices. Paragraph 13.5.3 Compensation principles. Paragraph 7 of the Decree of the Government of the Republic of Tajikistan #47 ‘On the relocation from the fl ooded Rogun HPP 57 area of the population of the city to Rogun and the Nurabad district’ says as follows, ‘... to provide funding to migrant families after the actual resettlement of migrant families to new places for the construction of housing in the amount of 3000 somoni as a soft loan, 100 somoni to the head of the family and 50 somoni to each family member as a lump sum’. Following the idea of the Decree migrants should live in tents prior to building a new home (5 points Resolution fixed allocation of tents). The Decree requires secure funding after the actual relocation but the Consultant says that within 10 days of the decision to resettle. That means the Report provides no reliable legal analysis. Paragraph 13.6.2 The outcomes of household surveys. Identifying vulnerable groups of the resettled population including the following categories: retirement pensioners, the disabled people, families with children, single mothers, families with disabled children and dysfunctional families should have become one of the main outcomes of the household survey. The current demographic trends such as population growth, life expectancy, the fertility and mortality rates have not been assessed either. These aspects have not been studied at this stage of the assessment studies. 58 d. List of November 2012 Information-Sharing and Consultation materials available on www.worldbank.org/eca/rogun  Meeting Agenda  List of Participants (for November 7th)  Draft ESIA Screening Report o Volume 1: Main Text o Volume 2: Annexes  Draft Design Criteria (TEAS)  Presentations o Presentation 1: Overview of the Study Process o Presentation 2: Information Sharing and Riparian Discussions o Presentation 3: Information Sharing Program: Ensuring Transparency and Quality o Presentation 4: Environmental and Social Screening Report o Presentation 5: Presentation by Panel of Experts based on the ESSR o Presentation 6: Overview of TEAS Progress o Presentation 7: Design Criteria o Presentation 8: Ongoing Hydrological Study o Presentation 9: Engineering Geology o Presentation 10: Next Steps  Documentation o Consultation report o Matrix of comments and responses o Transcript of November 7, 2012 session with civil society o Government of Uzbekistan comments (letter to World Bank, with permission) 59