In April 2022, CLEAN and NGO Forum on ADB filed 6 complaints regarding the destructive impacts of the Bangladesh Bhola IPP.
 

Key concerns include the following –

1. Lack of Information Disclosure and Meaningful Consultation

• An overall lack of timely information disclosure by both AIIB and NBBL on project information

• Poor and misleading translation of key documents, especially the Environmental and Social Impact Assessment (ESIA), E&S Summary, Environmental Management Plan (EMP), and Grievance Redress Mechanism (GRM) have been classified by CLEAN. The translated documents are in some instances incomprehensible and do not make sense.

• Lender has not provided any documentation or output from the consultation reports and has misrepresented accounts of consultations that could not be validated.

 

2. Coercion, Fraud, and Intimidation on Land Acquisition

• Coercion and intimidation faced by local communities especially Hindu from ‘middlemen’ appointed by NBBL to forcibly acquire land at the lowest rates.

• Hindu communities fearing retaliation in case they are identified as stakeholders raising concern.

• No records of sale or transaction on first phase land acquisition by NBBL

• Land acquisition practice was in violation of the “Bangladesh Acquisition and Requisition of Immovable Property Ordinance, 1982 and the amended ordinance of 2017”, which stipulates land owners be entitled to thrice the market price from private companies (in this case NBBL)

• Ineffective and non-functional local grievance redress mechanisms GRM.

 

3. Environmental Impact and Livelihood Loss

• Construction and Sand waste deposited by NBBL has led to Mandartoli Shakha Khal/River Channel river bed over siltation. Further, the NBBL embanked its northern part with sand sacks and has taken over half of the canal. The sand from the sacks has spilled out into the canal bed causing siltation and the canal to gradually dry up. Now the canal is only 1-2 feet deep and has lost its water-carrying capacity.

• Destruction of Betel Leaf farms: Due to Mandartoli Shakha Khal clogging, monsoon water overflows during high tide and directly floods the Dakshin Kutba village. Estimated 400 Betel leaf farms have been destroyed; displacing over 2000 families dependent on agriculture. Over 100 households are approximated to be directly waterlogged and left completely disconnected from public services, communication, health care, and other necessary services.

• Project site has taken over half of all grazing land in the area, leading to a direct impact on goat herders who are mainly women.

• Labor Colony has discharged large amounts of effluent, sewage, and waste to surrounding villages, leading to uninhabitable living conditions.

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Surkhandarya 1,560MW CCGT Power Plant [PROPOSED]

 

The AIIB is proposing to provide a loan of 225million EUR to support the design, construction, and operation of a new 1560MW Combined Cycle Gas Turbine Power Plant in the Surkhandarya region of Uzbekistan. According to the Bank's own ranking, the project is identified as a safeguards Category A project (highest risk).  The project consortium is made up of the Dutch conglomerate, Stone City Energy, France's EDF, Germany's Siemens Energy, and Qatar's Nebras Power.

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Dubious GHG Accounting

Although CO2 emissions have been estimated in AIIB project documents, there is no reference for how the calculations were derived and what scopes of emission are being considered. No estimated calculations of other emissions, including most critically, methane, are evident.

 

Climate and Biodiversity Concerns

The project site will occupy 70 hectares of land beside the Uchkizil irrigation reservoir, which it will use for water intake and for discharging treated wastewater. The reservoir is also relied on for irrigating agricultural fields in the area. No specific measures are listed for avoiding and responding to incidences of contamination from the effluent discharges or accidental leaks on-site during project construction or operation.

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Community Concerns Undisclosed

Details on community consultations, specifically on how those living and working around the reservoir have been informed, what project concerns they raised, and how/if these issues are being addressed remain absent from AIIB's documentation. Although plans for future consultations are mentioned, it's not clear how these discussions will be carried out and what - if any - precautions would be taken to avoid risks of reprisals to local people raising questions.

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Mis-Aligned with the Imperatives of Climate Science

Although the AIIB suggests the design of the project is "climate resilient" there is no published information to explain what this means. The reality is that in fact the project, which is expected to only become operational in 2026, would undermine the AIIB’s own stated pursuit of Paris alignment and joint MDB climate commitments. The climate science is clear: ramping up construction for new fossil gas infrastructure is unequivocally incompatible with the action required to meet the Paris Agreement goals of limiting global heating to 1.5C (IPCC Assessment Report 6; “Net Zero by 2050 Roadmap”) As outlined by the IEA,  to have a chance to keep global heating below catastrophic levels, large scale gas‐fired generation to peak globally by 2030, and the electricity sector would need to be completely decarbonized by 2040 worldwide. 

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Project Location: Surkhandarya region, Uzbekistan

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