Environmentalists demand that the hearings on the Rogun Dam be declared invalid
The international ecological coalition “Rivers without Borders” expressed serious concern about the organization of public consultations on the Rogun Dam project, which took place on September 11, 2025 in Dushanbe. In their appeal to the World Bank and the Group for the Implementation of Projects for the Construction of Energy Facilities in Tajikistan (GRPP), environmentalists stated numerous procedural violations and the low quality of the documentation submitted, which, in their opinion, undermines the credibility of the entire environmental and social assessment of the project.
The process of informing the public about the hearings on the updated Environmental and Social Impact Assessment (ESIA) was most severely criticized. Public activists point out that the notification of the publication of documents on August 22 was posted only in the “Tenders” section on the GRPES website, while civil society organizations that had previously criticized the project did not receive direct notifications. The invitation to the “final consultations” itself was sent to them on Saturday, September 6, which left the interested parties not enough time to prepare for the September 11 event. As a result, representatives of only two non-governmental organizations from outside Tajikistan attended the meeting, however, the organizers of the event refused to recognize the haste and illegitimacy of the hearings. It is also surprising that the deadline for submitting comments and suggestions was set for September 12, that is, the day after the hearing. Such a short period directly violates international standards that require reasonable time to analyze project materials.
The format of the consultations themselves also caused complaints from environmentalists. The discussion of the project documentation, numbering more than two thousand pages of technical information, was reduced to one event with an hour-long question and answer session. Such an approach, according to the coalition, turns a constructive dialogue into a formality and contradicts the assurances previously received from representatives of the World Bank about holding separate in-depth consultations on key documents.
The preliminary analysis carried out by the specialists of the Rivers Without Borders coalition revealed significant gaps in the documentation itself. In particular, the main volume of the EIA lacks a key chapter on transboundary cumulative impact assessment, as well as the declared “Biodiversity Action Plan”. The chapter on the initial data contains only 3.5 pages with irrelevant sources, and the section on climate change is not supported by data from new hydrological and climate studies, although they were commissioned by the project. Representatives of the Tajik civil society also pointed out the shortage of qualified personnel in the country – more than 300 inspectors – for the implementation of the “Environmental Management Plan”.
During the hearings, rather contradictory information was voiced. Statements about the impact zone of the Rogun Dam project, extending “to the Aral Sea”, differed from statements that the impact below the Nurek Dam would not be considered. The head of the Association of Power Engineers of Tajikistan said that the official indicator of electricity generation of the Rogun Dam in all the documents discussed is overestimated by 15-20%, which makes the calculations of the specific impact unreliable. Also, different deadlines for the completion of the Dam construction were named – from 2032 to 2036 – which casts doubt on the existence of a single work schedule.
In light of the violations identified, the Rivers Without Borders Coalition called on the Tajikistan Energy Construction Project Implementation Group and the World Bank to invalidate the September 11 consultations. Environmentalists demand to publish all finalized project documents in the appropriate languages, announce a new schedule of in–depth consultations on each key document and set a new deadline for submitting comments and suggestions – at least 30 days. The coalition also insists on strengthening the supervisory function of the World Bank to ensure that the project complies with international standards.
Original (in Russian): Экологи требуют признать слушания по Рогунской ГЭС недействительными
