Rogun Dam Assessment Criticized Over Transboundary Impact

A report from the international environmental coalition Rivers without Boundaries, titled “With Eyes Wide Shut: Ignoring the Transboundary and Cumulative Impacts of the Rogun HPP,” concludes that the project’s transboundary impact assessment does not fully meet the environmental and social standards of the World Bank and contains fundamental shortcomings. The coalition’s report highlights that the current impact assessment is based on outdated 2014 data and static scenarios that fail to account for the dynamics of climate change and the actual hydrological situation in the Amu Darya basin.
The analysis points to the project developers’ failure to assess key external factors, such as the construction of the Qosh Tepa canal in Afghanistan, which will significantly influence the region’s water balance. Instead of a comprehensive study, the HPP project developers propose viewing the giant dam’s impact as “neutral”–a position the coalition considers misleading. The operation of the Rogun reservoir is expected to extend the life of the Vakhsh cascade of hydropower plants by 60–100 years, thereby reinforcing an existing flow regime detrimental to downstream ecosystems, including the Tigrovaya Balka Nature Reserve, a UNESCO World Heritage site.
The assessors are accused of excluding the most acute and inconvenient scenarios from the analysis. The claim that the world’s tallest dam would have a neutral impact contradicts the logic of cumulative effect assessment. Without implementing strict commitments for environmental flows and artificial floods, the project would prolong the degradation of unique natural complexes for another century, in direct violation of the conservation principles of international financial institutions.
Particular attention is given to the risks facing biodiversity and the Ramsar Convention-protected wetlands of the Amu Darya delta. The Rogun HPP impact assessment lacks clear mechanisms to guarantee water delivery to these critically important zones during dry periods. Furthermore, the coalition notes serious gaps in the public and stakeholder consultation process in downstream countries, which challenges the legitimacy of conclusions about the project’s social acceptability.
There is a noted trend of disregarding the interests of downstream populations and ecosystems. No consultations were conducted in the project’s impact zone in Uzbekistan and Turkmenistan, and risks related to the seasonal redistribution of flow and the commissioning of the Qosh Tepa canal were omitted entirely. This sets a dangerous precedent for a major regional infrastructure project advancing without a solid foundation of transboundary cooperation and consideration of neighboring opinions.
To address this situation, the Rivers without Boundaries coalition recommends a full-scale Strategic Environmental Assessment (SEA) for the entire Amu Darya basin. The coalition insists on the need to develop legally binding flow management plans that include measures for climate change adaptation and biodiversity conservation. Without a radical revision of the assessment approach and the implementation of mechanisms to mitigate and compensate for damages, the Rogun HPP project risks becoming a source of long-term environmental and social tension in Central Asia.
