The EBRD is facilitating the introduction of green technologies, waste recovery and recycling systems in both countries, but more information is needed on progress and impacts.
The role of international aid institutions and development banks in the economically distressed Central Asian region has been undeniably positive for decades despite challenges. Donors have invested significant amounts of capital in infrastructure projects and development initiatives in the region since the 1990s. The European Bank for Reconstruction and Development (EBRD) remains one of the more active banks providing funds for environmental projects to the governments and municipalities in the region. The EBRD is currently upgrading local waste management facilities in Kyrgyzstan and Uzbekistan, which is in line with the bank’s Green Cities policy tool. Essentially, the EBRD is facilitating the introduction of green technologies, waste recovery and recycling systems in both countries.
A Landfill Project in Bishkek
The bank provided a sovereign loan of 11 million euro and another grant in the sum of 3 million euro to the Kyrgyz Republic for a solid waste management project in Bishkek, a new landfill. The EBRD’s project documentation mentions an additional 8 million euro grant from an international donor for the project, bringing the project’s price tag to 22 million euro. The solid waste management project in Bishkek has yet to be finalized after its initial approval in 2013, when the loan agreement was signed.
The existing city landfill remains a source of ongoing air pollution in the vicinity. The existing dumpsite is the scene of a recurring landfill fire that increasingly takes place on the premises due to the decomposition of organic material producing easily ignited landfill gas. These fires are becoming more frequent during warm seasons as temperatures rise, peaking during the summer.
Bishkek’s dumpsite has been in operation since 1978 with the original plan built around collecting and utilizing waste for a city with a population of 400,000. Today, the Kyrgyz capital has 1.2 million residents, and the size of its Soviet-built landfill has dramatically expanded, reaching nearly 50 hectares of land. Thus the EBRD project aimed at establishing a new landfill. The city’s public, civil society organizations and media remain vigilant regarding the project’s progress, but the city authorities have yet to explain the delay after the disbursement of 22 million euro to complete the new landfill project.
Environmental activists blame the city administration and the country’s government agencies for failing to provide necessary permits and documents in a timely manner to the contractor company working on the landfill project implementation. “Such documents, according to the laws of the Kyrgyz Republic, are issued after approval of the project and the conclusion of the examination. Now the project has not been completed, and the initial version has not passed ecological expertise in the State Agency for Environmental Protection and Forestry,” said activist Bermet Borubayeva.
Project Implementation Progress
The main reasons for such prolonged project implementation are seemingly the COVID-19 pandemic, the political impact of the overthrow of the country’s government in October 2020, alleged corruption involving city officials and endless red tape. Political instability in the Kyrgyz Republic has been a prevalent factor that continues to have a prolonged negative impact on the Central Asian nation’s governments. The country has seen the overthrow of governments on multiple occasions since 2005, while Cabinet changes are even more frequent. More than 30 prime ministers have served in office since 1991, when the nation gained its independence.
The COVID-19 pandemic, and the quarantine restrictions put in place in 2020, have not necessarily delayed the project’s progress, but have contributed to an increase in the costs for the contractor. Moreover, excessive bureaucracy remains a critical issue due to delays after “data obtained as a result of additional research and modeling” by the contractor revealed that the official landfill area and actual landfill area proposed for reclamation differ in size. This required re-approval of the project documentation. Environmental activist Borubayeva wrote via email for this article that the “EBRD should have properly monitored the implementation of the waste management project and violations [in Bishkek].”
Environmental and Social Objectives of the Project
The existing landfill in Bishkek generates leachate with “high chain hydrocarbons, high chloride levels and relatively high biological oxygen demand” while there are “occasions of leachate overflow to the [Ala-Archa] river basin to the East of the site.” Activists and environmentalists argue that a lack of leachate treatment on the landfill premises is resulting in the “increased concentrations of phosphates entering surface waters and leading to eutrophication of the Ala-Archa reservoir water.” An EBRD assessment stated that recultivation of the existing dumpsite will “reduce potential groundwater and surface water pollution from the existing dump by reducing infiltration of water into the waste through recontouring, cover layers and restoration planting. Any remaining leachate produced will be intercepted and stored in a leachate lagoon where it will partly evaporate with any excess pumped to the leachate lagoon in the new extension landfill.”
However, these projections remain unattainable as the landfill project has yet to be completed and environmental analysis conducted upon collecting data on location. Worsening air quality in the city of Bishkek has become a critical matter for city residents as the country’s capital was listed in the “hazardous” group globally, with very unhealthy air quality in recent years. The latest United Nations Environment Program (UNEP) study on air quality in Bishkek noted that emission estimates for the landfill fires were not included in the report because of the landfill’s location outside the city. “Nevertheless, the landfill fire is reported to have a significant impact on the air quality near the landfill and is something that should be addressed as a priority.” Therefore, more research into air quality at the landfill project location and surroundings is recommended and the installation of air quality monitoring sensors in the area for better data analysis.
It is expected that the EBRD project will have a positive environmental and social impact on resolution of the longstanding issue involving the existing landfill dumpsite. However, it cannot be quantified now until the reclamation of the existing dumpsite and launch of the new landfill site take place in 2023 and a post-project impact study is conducted to understand the project results. The EBRD’s contribution to the project’s implementation progress is considerably significant as the bank has been invested in the project since 2013 and it’s plausible that without EBRD’s consultancy and funding, the city of Bishkek and the Kyrgyz authorities wouldn’t have the capacity nor expertise to manage such a complexity-ridden undertaking.
Landfill Projects in Khorezm and Karakalpakstan regions of Uzbekistan
The government of Uzbekistan approached the EBRD for assistance with funding and implementation of waste management projects in the country’s Khorezm and Karakalpakstan regions. The bank allocated a sovereign loan to Uzbekistan of up to $120 million for the implementation of both projects. An EBRD environmental and social audit assessment revealed that the “project would not trigger physical displacement, however, could cause economic displacement impacts.” The report indicated that a Livelihood Restoration Framework (LRF) was prepared due to projected impacts to regulate and provide guidance for “land acquisition, compensation and livelihood restoration activities” in the future.
The LRF stated that the EBRD consultants met with residents and have learned that farmers are “concerned with the possibility of terminating their leases and life-long inheritable possession rights or imposing land use restrictions, especially a prohibition of food crop cultivation.” For instance, about 63 hectares within the sanitary zone are “arable lands used for cultivation of rice, wheat, and corn” in the Bagat district of Khorezm region. Local households earn their income by growing crops while unemployment numbers are high in the project area. Therefore, the bank’s goal to resolve any potential grievances due to loss of income and access to farmland during project implementation in Uzbekistan is certainly a positive step toward the resolution of disputes.
The country was featured in the global media in recent years after a rampant wave of forced evictions and questionable demolitions of private properties taking place in the nation’s major cities. The Uzbek authorities were criticized by global rights organizations for mass demolitions across the nation. “International human rights law requires that any process of expropriation or government acquiring of an individual’s property be subject to due process and appropriate and adequate compensation. Expropriation should never be arbitrary nor place an undue burden upon individuals,” stated Human Rights Watch in a report on events in Uzbekistan. The EBRD must ensure that preventative measures and conflict-resolution mechanisms are in place if property or land disputes arise.
CEE Bankwatch representatives learned upon making a trip to Nukus, and the Turtkul and Karauzyak districts in the Karakalpakstan region, and meeting with community members that many residents in both districts outside the city of Nukus were unaware of the EBRD’s public consultation process and grievance resolution mechanism. Moreover, several locals expressed their concerns regarding possible ramifications for their well-being out of repercussions for voicing their complaints or critical views about the project. Community members indicated to the team of activists that neither the EBRD nor the project representatives have consulted with locals regarding the reconstruction and expansion of the existing dumpsites in the area.
Activists took notice of the EBRD’s failure to uphold grievance mechanism compliance in the Turtkul and Karauzyak districts. For instance, contact details for the public grievance mechanism weren’t valid. And while some grievances were raised with local authorities, they remain unanswered. Respectively, such discrepancies regarding dysfunctional grievance mechanisms on the ground and at the project level may lead to unresolved social traction in the long run, especially in the reprisal-prone environment as the CEE Bankwatch team witnessed in the project locations of Karakalpakstan region.
The team was unable to visit sites in the Khorezm region due to time and travel constraints. Therefore, the project progress in the Khorezm region couldn’t be independently verified. However, previous analysis of the EBRD’s environmental and social impact assessment by the Uzbekistan-based activists in 2021 revealedmultiple concerns regarding the projects in Khorezm’s Kushkupyrsky and Bogdatskiy districts. Specifically, activists highlighted that the project design didn’t include “waste segregation for excluding toxic substances, decreasing the volume of disposable waste” and a lack of “proposals for incentivizing recycling and capturing biogas”. Concerns were also expressed regarding potential air pollution and the lack of “data for greenhouse gas emissions and their cumulative impact.”
Subsequently, it is unlikely that the Uzbek authorities would provide more transparency regarding the projects’ implementation progress. In such a case, EBRD could step in to ensure that the information on the waste management projects in both regions of Uzbekistan can be accessible for local and international groups.
