Review of EIAR for the Ilisu Dam and HEPP

Summary

Submission

by

Corner House Research

Ilisu Dam Campaign

Kurdish Human Rights Project

Friends of the Earth

Berne Declaration

Campaign An Eye on SACE

Pacific Environment

World Economy, Ecology and Development (WEED)

September 2001

Review of EIAR for the Ilisu Dam and HEPP

Summary

Introduction

On July 3rd 2001, the Export Credit Agencies considering support for the proposed Ilisu Dam in the Kurdish region of Southeast Turkey released the Ilisu Consortium’s Environmental Impact Assessment Report for the project and invited public comment.

This Summary, together with the enclosed reports and accompanying documents, constitutes a joint submission in response to the consultation on the EIAR from eight non-governmental organisations: Corner House Research (UK), the Ilisu Dam Campaign (UK), the Kurdish Human Rights Project (UK), Friends of the Earth (England, Wales and Northern Ireland), Berne Declaration (Switzerland), Campaign An Eye on SACE (Italy), Pacific Environment (US) and World Economy Ecology and Development (Germany).

In addition to this Summary, the submission consists of:

Summary of Submissions

In our submission, the information contained in the EIAR demonstrates a clearly sufficient and defensible basis for export credit assistance to be denied for the Ilisu project. Moreover:

  1. The EIAR consideration of resettlement, hydrologic and geomorphic impacts, alternatives and cultural heritage is inadequate and, in many respects, seriously flawed and in breach of internationally accepted practice.

  2. The EIAR does not meet its stated reference guidelines:

  1. The EIAR does not comply with relevant World Bank, OECD and World Commission on Dams’ guidelines.

  2. The recommendations of the December 1999 Environmental Review of the Ilisu Dam Project, commissioned by the UK government and conducted by Environmental Resources Management, have not been complied with.

  3. The pre-conditions set by the Export Credit Agencies and their governments for granting export credit have not been fulfilled.

Consideration of resettlement, hydrologic and geomorphic impacts, alternatives and cultural heritage

Resettlement

Hydrologic and Geomorphic Impacts

Cultural Heritage

Alternatives

Violations of US Export-Import Bank guidelines

The US Export Credit Agency, Export-Import Bank’s ‘Environmental Guidelines’ and ‘Environmental Guidelines - Table 9: Hydropower and Water Resources Management’ have not been complied with in that:

Violations of Internationally Accepted Practice

In addition, it should be noted that the project fails to comply with the following internationally accepted standards for best practice:

World Bank

OECD

World Commission on Dams

The specific breaches are tabulated in Annex 1 of this Summary and cross referenced to the materials provided.

On resettlement alone, the project breaches 7 World Bank guidelines on 30 counts; OECD DAC, 2 guidelines on 14 counts; and WCD six guidelines on 31 counts.

Failure to address concerns raised by ECAs

The recommendations of the December 1999 Environmental Review of the Ilisu Dam Project, commissioned by the UK government and conducted by Environmental Resources Management (ERM), have not been complied with. Specifically:

Details are provided in Annex 2 of this Summary.

Failure to comply with ECA Pre- conditions

The five pre-conditions set by the ECAs and their governments have not been met. In particular:

Draw up a resettlement programme which reflects internationally accepted practice and includes independent monitoring.

Make provision for upstream water treatment plants capable of ensuring that water quality is maintained.

Give an assurance that adequate downstream water flows will be maintained at all times.

Produce a detailed plan to preserve as much of the archaeological heritage of Hasankeyf as possible.

Overall Conclusion

Proceeding with the Ilisu Dam would involve adverse social, environmental and cultural effects of such a magnitude that a decision to deny export credit assistance would be patently defensible.

Moreover, given the matters itemised above and contained in this submission, it can fairly be said that (i) international best practice has not been complied with in assessing and addressing such effects; and (ii) in all the circumstances, it would be both inappropriate and of questionable legality to approve applications for export credit assistance.