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Review of project Environmental Impact Assessment

October 2003

OUT NOW!! - See IFC generic reply to EIA comments

The Baku Ceyhan Campaign has, along with its partner groups, carried out a detailed study of the Environmental Impact Assessment (EIA) for the Turkish section of the Baku-Tbilisi-Ceyhan (BTC) pipeline. Astoundingly, it found 173 violations of international standards, including the World Bank's own lending policies. Its findings included:

  • The BTC project violates every relevant World Bank safeguard policy on multiple counts. On consultation alone, the project breaks 6 key World Bank guidelines on 83 separate counts.
  • Many of the claims made in the EIA are misleading and unsupportable. For example, BTC claims to have conducted comprehensive consultation exercises, yet those exercises lasted little more than two months in total and fewer than 2% of people were consulted face to face.
  • Since World Bank standards form part of the legal regime for the project as mandated by the Host Government Agreement (HGA) and the Lump Sum Turnkey Agreement, such breaches potentially constitute violations of host country law.
  • In order to keep to the project's construction timetable, Emergency Powers have been invoked to carry out the land acquisition process more quickly, in violation of World Bank policy OD 4.30 (Involuntary Resettlement). For poorer people, the likely outcome is that they will be worse off than before the project. Some are already talking of having to leave their lands.
  • BTC has declined to apply the World Bank's Operational Directive 4.20, Indigenous Peoples, the only directive specifically aimed at safeguarding the interests of minority groups. Closer investigation, however, reveals that the Kurds in particular meet every one of the criteria for applying OD 4.20, and that the rationale for not doing so is fatally flawed. The decision not to apply the policy leaves ethnic minority groups unnecessarily and unjustifiably vulnerable to socio-political difficulties connected to the BTC project.
  • The legal framework for the project is in potential breach of Turkey's obligations under international human rights and environmental law. The HGAs also conflict with Turkey's accession agreements with the European Commission, and with with the OECD's Guidelines on Multinational Enterprises. Funding for the project may therefore breach the World Bank's Memorandum of Understanding with the EC on finance for accession countries.

Download the EIA Review:

Executive summary

Cover page + contents

Chapter 1 - Introduction
Chapter 2 - Issues arising from legal regime for BTC project
Chapter 3 - Consultation
Chapter 4 - Land expropriation, compensation and resettlement
Chapter 5 - Cultural Heritage
Chapter 6 - Environmental assessment
Chapter 7 - Lack of assessment of alternatives to the BTC project
Chapter 8 - Ethnic minorities and disadvantaged groups

APPENDICES

SUPPLEMENTARY APPENDIX

Evaluation of project compliance with Equator Principles

See also correspondence:

Letter to Hilary Benn (DfID) re project breaches of World Bank standards, October 2003
Letter to IFC re project breaches of World Bank standards, October 2003
Letter to EBRD re project breaches of World Bank standards, October 2003
Letter to ECGD re project breaches of World Bank standards, October 2003

IFC generic reply to EIA comments, October 2003