Kambarata hydropower project: greater scrutiny from international banks is needed 

However, recent public consultations on the project’s Environmental and Social Impact Assessment (ESIA) have revealed critical, unaddressed risks. The project is being presented as a national priority, but its current plan fails to adequately address serious seismic, social and environmental dangers.  

Kambarata HPP-1 is projected to have an average production of 5.6 TWh of electricity annually. Kyrgyzstan has a 34 per cent share of the project while Uzbekistan and Kazakhstan have 33 per cent each. To complete the project, around EUR 4-6 billion will be required. The EBRD is considering lending EUR 1.3 billion to support the project and the EIB another EUR 900 million.  

Experts from ‘Rivers without Boundaries’ made a detailed Cumulative Impact Assessment where they concluded that the project would result in unmitigated transboundary hydrological risks and would violate biodiversity safeguards. They’ve concluded that the project suffers from a severe deficit of good governance and public accountability and that the project will adversely affect thousands of locals in nine nearby villages.  

These risks and challenges were discussed during the second round of national consultations over the ESIA for the project, which was organised by the Ministry of Energy of the Kyrgyz Republic in Bishkek on 16 October 2025. Around 100 people – including locals, experts and NGO representatives – attended the meetings, and around 30 participated online.

The social concerns from local communities, who are dependent on cattle breeding, were mainly about the loss of their ability to continue this work if construction starts. They also expressed a need for the project to hire more locals.

The ESIA claims ‘only three households’ will be physically displaced. But it also indicates the reservoir will flood over 3,500 hectares of irreplaceable winter pasture land, threatening the livelihoods of over 1,000 households that depend on cattle breeding. Experts from ‘Rivers without Boundaries’ highlight that in the Cumulative Impact Assessment  (CIA) 50 km²  of ‘natural grasslands’ are currently left without biodiversity mitigation. Though the project’s management claims that the ‘aquatic river habitat’ and associated lands are not technically ‘lost’ but are simply being ‘converted into reservoir habitat’ and therefore do not require mitigation, experts from ‘Rivers without Boundaries’ call this a ‘blatant violation’ of the World Bank’s ‘no net loss’ requirements.  

The project will result in the destruction of over 80 kilometres of trails and 11 bridges, thereby severing access to remaining pastures. Authorities have announced plans to build an additional bridge and new roads for shepherds as well as to employ locals in the construction works, but locals did not seem convinced that these plans will actually happen. The ESIA states that construction is expected to create 600 to 3,000 new jobs  and that during the peak construction phase there will be about 7,000 workers onsite. The construction timeframe is estimated at 8.5 years.  

Another important concern comes from the Kyrgyz Republic’s National Academy of Sciences which has issued a serious warning. An active seismic fault is located directly under the proposed dam site. The institute insists that crucial seismic micro-zoning is necessary, but its experts report their warnings have been ignored by project consultants. 

Meanwhile, ecology experts from ‘Rivers without Boundaries’ have labeled the ESIA’s biodiversity section a ‘black box’. It lacks specific data about the project’s impact on the various potentially affected species. Most alarmingly, the ESIA proposes to determine if the area is a ‘critical habitat’ only after a decision has been made to implement the project.   

‘Rivers without Boundaries’ believe that this is a fundamental breach of international best practices, which require such assessments to be made prior to an implementation decision in order to determine if a project should be radically revised or abandoned. They state:

‘The ESIA does not provide a complete picture of the consequences of the hydropower plant construction for the most valuable natural aquatic habitats of the Naryn River. Consequently, the project has no mitigation plans to protect or restore habitat to compensate for degradation of a long stretch of natural river or 50 square kilometers of grasslands, and therefore fails to ensure that there is no net loss of biodiversity as required by the World Bank standards. Instead of habitat protection the largest budget item in the biodiversity management plan is devoted to building a fish farm for artificial breeding of native catfish and invasive trout’.  

In addition, the most well known impacts of the new dam are expected to occur in Uzbekistan, Tajikistan and Kazakhstan downstream of the Naryn Hydropower Cascade and reinforced by the new large Kambarata–1 reservoir.   

The Cumulative Impact Assessment attached to the ESIA explains that seasonal redistribution of flows may affect the whole Syrdarya River down to the Lesser Aral, degrade three Ramsar wetlands and affect irrigation systems important for millions of people. Specific impacts will depend on the flow management regime of the Toktogul and Kambarata-1 reservoirs, but this regime has not yet been agreed upon or designed.

‘Rivers without Boundaries’ also criticizes the ESIA for the absence of a sufficient environmental plan. ‘[The] CIA vaguely recommends designing such transboundary environmental flow management plan as the top priority. However, the whole ESIA does not include such a plan, or any further solid mitigation measures to avoid those negative impacts downstream, while its “environmental flow assessment” does not cover transboundary impacts and cascade regulation effects’.

What should potential financiers do now?  

Given these challenges, the World Bank, EBRD, EIB, Asian Development Bank and other potential financiers have a responsibility to stop overly relying on the developer’s ESIA. Before committing any funds, these institutions must conduct a rigorous gap assessment and ensure the ESIA process is sufficiently comprehensive and participatory to effectively assess all risks and impacts. These steps are vital to ensure the project aligns with their own policies and to avoid financing a social, environmental and economic disaster.  

International financial institutions must acknowledge the political climate. In these countries civil society organisations face reprisals and independent media is banned. Given this environment, international lenders must assess the risks and introduce mitigation measures to ensure transparency and meaningful stakeholder engagement. The international financial institutions must require the government to demonstrate cooperation with local activists and experts and to not threaten the activists. An independent, secure and anonymous grievance mechanism to protect stakeholder voices should be established to address these challenges.   

It is important for the banks to demand a realistic livelihood restoration plan. This should focus on the thousands of locals who are losing their pasture-based incomes. It must also provide specific, verifiable and fully-funded strategies for replacing lost winter pastures and access routes.     

All action points regarding offsets, transboundary monitoring and public safety must not merely be ‘recommendations’ in a plan but must be included as legally binding requirements in the Environmental and Social Action Plan (ESAP) linked to the loan agreement.  

The financiers should ensure that impact on all natural habitats degraded or modified by the hydropower project are dealt with in strict accordance with mitigation hierarchy and that ‘no net loss’ of biodiversity is truly achieved (e.g. by permanent protection of other similar rivers, where additional dams are now planned).   

Before the financing decision is made, potential critical habitats should be explored both upstream from the Kambarata-1 dam and downstream of the Naryn Cascade where the CIA highlights at least three wetlands of international importance dependent on the downstream water regime.   

To prevent conflict and environmental degradation, financial institutions must assert control over the project’s operational framework. They must mandate that the transboundary environmental flow regime downstream of the Naryn Cascade be designed during ESIA finalisation, not afterwards. This regime must be agreed upon and operationalised in binding reservoir cascade management rules, subject to full consultation with local communities in the three downstream countries. Without these binding guarantees, the lenders cannot claim to have mitigated the project’s transboundary risks.  

International banks now have a choice, either enforce their own standards to mitigate these risks or become complicit in funding a project with flawed foundations.