Tajikistan – a small, landlocked, mountainous country in Central Asia – is at the crossroads of major geopolitical interests. Tajikistan borders Afghanistan and China. Russia considers this ex-USSR country to be in its sphere of interest, and Europe has declared its readiness to reduce the Central Asian countries’ dependence on Russia, and counter China’s Belt and Road Initiative.Meanwhile the key Chinese, Iranian and Russian financiers are eager to join the World Bank and EU in the Rogun dam financing.
The Tajik authorities expect their foreign partners to support the country’s largest project to date – the 3780 MW Rogun hydropower plant. Conceived in the 1970s, as a 335-meter-high dam with 13 cubic kilometres storage reservoir, the project was supposed to become the tallest structure of its kind in the world.
Since the project relaunch in 2006, Tajikistan has already spent USD 3.3 billion on it and still lacks at least USD 6.4 billion to complete this project. Less than 25% of all construction works have been completed by the end of 2023. All the major international financial institutions (IFIs) – the World Bank (WB), European Investment Bank (EIB), Islamic Development Bank (IDB), Eurasian Development Bank (EDB), Asian Infrastructure Investment Bank (AIIB), Asian Development Bank and eight more are under pressure to get involved in the “Rogun sustainable finance” scheme orchestrated by the WB. The same and other IFIs, such as the ADB and EBRD, finance associated projects: roads and transmission lines enabling construction and functioning of the Rogun dam.
Obstacles and problems
The Rogun dam was part of the Soviet water infrastructure plans for Central Asia that eliminated the Aral Sea. Its construction would have a huge impact on downstream countries: Afghanistan, Turkmenistan and Uzbekistan. Reduced and seasonally redistributed water flows in the Amu Darya (the river that gets 40 per cent of its water from the Vakhsh, where the Rogun dam is being built) is likely to have a huge impact both on ecosystems and agriculture, which relies heavily on the inefficient irrigation system introduced in Soviet times. The World Bank has been for years adamantly insisting that the pattern of river flow below the Vakhsh hydropower cascade will not change after the Rogun HPP is built but has failed to present any scientific proof for this counterintuitive statement or actual assessment of needed environmental flows into Amu Darya.
Furthermore, the “updated” Environmental and Social Impact Assessment (ESIA), published in December 2023 by the World Bank, omits consequences of several risks, which have previously been the focus of public attention. Instead of addressing the possible functions of the Rogun reservoir in confronting the basin-wide water crisis unfurling in the Amu-Darya River, the ESIA limits its assessment area to the Rogun reservoir footprint and a 17-kilometer downstream river section all the way to the next Nurek reservoir. There is no credible answer to a crucial question, whether there is sufficient water resource available for filling the giant reservoir without compromising needs of other sectors and riparian countries. Eight million people downstream may suffer if the giant reservoir redistributes the flows in Amu Darya River, which must be properly assessed and mitigated.
According to the 2024 World Heritage Watch Report, the ESIA fails to develop measures mitigating major negative impacts, including the reduction of the river flow to the Aral Sea, impacts on the “Tugay Forests of the Tigrovaya Balka” World Heritage site in the Vakhsh River floodplain, degradation of habitat of critically endangered endemic sturgeons, whose survival is fully dependent on flow regime of Vakhsh and Amu Darya rivers.
According to 2023 report by the International Monetary Fund (IMF), Tajikistan’s ‘fiscal space remains limited due to debt sustainability concerns’ and Rogun investment has been a major problem for country’s fiscal health, while both the project costs and delays are on increase. ‘Finding a solution to the construction of Rogun that does not crowd out government spending on health, education, social welfare and other infrastructure must be one of the government’s top priorities,’ reads the 2022 World Bank’s own report Public Expenditure Review of Tajikistan. However, when political decision to support Rogun became ripe the IMF and the World Bank made an unprecedented U-turn and now they preach that taking on multi-billion non-concessional loans is perfectly safe for Tajikistan.
In 2014 the Human Rights Watch reviewed early resettlement from Rogun reservoir bottom and highlighted issues such as lack of access to land for farming and raising livestock, reduced access to and variety of food, loss of income-generating activities, unreliable and inadequate access to basic services, and lack of fair or adequate compensation.
In 2024 the dam project documentation downplays and neglects diverse and problematic consequences of resettling 60.000 people, which will inevitably have massive environmental and social impacts. All the more so in a society with few political and individual freedoms, low levels of transparency, the highest level of corruption, and exacerbating human rights violations.
In such circumstances, the fact that at least 7297 people have been already displaced and 52,000 are still expected to be resettled should be a red flag for IFIs.
The ESIA also proves that the Rogun project is not climate friendly. According to EU standards, with more than 102 g CO2 e/KWH it does not meet the criteria for a “substantial contribution” to climate change mitigation. Nor will Rogun hydropower contribute to the decarbonisation of the Tajik energy system, which has a similar emission intensity (106g CO2 e/KWH). If Uzbekistan and Kazakhstan decide to rely on energy imports from this source, the project could delay Central Asia’s green transition by 15 years. Meanwhile the exorbitant cost of the Rogun Dam project will make the electricity produced by it no affordable to poor populations of Tajikistan and other countries of the region.
Hydropower plans generate about 90 per cent of Tajikistan’s electricity; the Rogun HPP alone will cover 30 per cent of its needs. The risk of over-dependence on a single source has not been considered in the ESIA. Officials often wrongly claim that “we passed the point of no return, there are no viable alternatives to the 330-meter Rogun dam”. This gives them excuse not to consider any modern alternatives. Instead of an up-to-date analysis of alternative energy sources, the ESIA refers to a 2014 (!) report saying, “it was noted that wind and solar power generation cannot make up the shortfall in electricity supply and remains more expensive than other sources, although costs have been steadily declining in recent years.” The use of 2014 data is a deliberate falsification that does not reflect the current opportunities.
Likely, alternative renewable schemes based on solar and wind could be built five times faster and three times cheaper than the giant Rogun HPP, whose price tag has been rising at a rate of 15 per cent a year since 2008. Even the World Bank “project information document” recognizes the acute need to diversify the energy sources of the extremely hydropower-dependent energy system of Tajikistan
Rogun Dam safety has always been a concern, as the location selected for construction sits atop of a seismic fault and a salt dome. The lengthy construction process was several times arrested and reverted by floods and earthquakes. At present experts raise concerns about poorly explored landslide-prone slopes, with one of those threatening to block Vakhsh immediately below the Rogun Dam.
Despite all those risks no transboundary emergency plan has been presented to downstream population, neither any mitigation and compensation mechanism has been discussed for not an unlikely case of dam failure or other major accident.
Public Participation Nullified
In 2008-2014, the previous attempt of the WB to initiate international financing of Rogun HPP included series of five regional consultations and many other stakeholder engagement events. All project documents were in advance presented for public comment.
In sharp contrast, in 2023-24 no meaningful regional consultations were announced, only a summary of the updated ESIA has been disclosed, while the biodiversity management plan and current resettlement action plan are not publicly available at all. The WB itself has already recognised that “Although it has been disclosed for public review, the ESIA will require significant improvements before it can be made final and considered for approval by the World Bank”, as written in the Terms of Reference issued on 18 January in order to hire a consultant to redo a substandard cumulative impact assessment.
On November 9, 2023, a meeting with many riparian officials and several NGOs was held behind closed doors in Almaty. Most participants had no chance to examine the ESIA documentation prior to the meeting, as it was officially disclosed only in December. The first public information about these “riparian consultations” appeared on February 2, 2024. None of new project materials have been available in Tajik language on websites till June 2024, which makes us doubt that any free prior and meaningful consultations were held locally, as claimed on the website of the Rogun project proponents.
In January 2024, Rivers without Boundaries Coalition (RwB), NGO Forum on Asian Development Banks and the international organisation such as Bankwatch Network have appealed to the World Bank and other IFIs, requesting to hold public consultations on the updated environmental assessment of the project not only in Tajikistan but also in Uzbekistan, Turkmenistan, Kyrgyzstan and Kazakhstan with the participation of all interested public and scientific organizations to ensure that all suggestions and comments are fully taken into account. During first half of the 2024 a coalition of 20 local, regional and international civil society groups has been sending questions and requests to the World Bank and project implementation group and getting vague promises and unsatisfactory answers.
For the civil society, the Rogun Dam has become a symbol of extremely dangerous, poorly designed megaproject, which is being pursued by many international finance institutions driven by geopolitical consideration with massive violations of their own environmental and social standards.
Newest developments: banks opt for half-a-dam and partial ESIA
In 2023, a new Project Information Document raised several new issues about the project:
- Reservoir filling will take another 6 years after the completion of construction works, extending full project completion beyond 2040.
- IFIs have not committed to finance the completion of the whole project, but only the USD 2.44 billion “Phase I”, adding 1/3 of intended capacity and leaving the dam100 meters short of its intended height by 2029.
In early July 2024, the Rogun HPP Project page at the World Bank website announced that final decision by the Board should be made on July 31st , then it was moved to September 30th, then to October 31st, and by early October estimated Board meeting date is December 17th.
- The World Bank, EIB, IDB, ADB and AIIB are listed as the main IFIs involved in the project, with further contributions of the Government of Italy and 4 funds from Arab countries totalling USD 1535 million, of which the World Bank pledged 350 million.
- As of July 2024, more than half of crucial safeguard documentation has not been presented for consultations, including actual detailed ESIA (Volume II).
Financiers will be responsible for the consequences
It is difficult to see how banks such as the EIB, EBRD, World Bank, AIIB and ADB can justify their involvement in this project. Whether and how they would improve standards and reduce negative impacts if they became involved now, remains a question, but once involved, they would clearly be responsible for the significant environmental and social damage to come.While environmental and social policies and procedures may be useful for improving business practices and implementing processes to mitigate individual impacts, they will not have a significant impact on such a massive already significantly flawed project. Better procedures may help prevent some misconduct, but they can’t make the resettlement of 50,000 people acceptable, neither can they guarantee water security and ecological balance in already struggling Amu Darya Basin. The purpose of environmental and social due diligence is to prevent such projects from happening and help governments find more sustainable alternatives that better serve the needs of the population.