People living in the settlements adjacent to landfills slated for expansion under a waste management project financed by the European Bank for Reconstruction and Development were not adequately consulted. 

This article was originally published in The Diplomat.

In 2022, the European Bank for Reconstruction and Development (EBRD) approved a waste management project in the Karakalpakstan region of Uzbekistan. As part of this project, there are plans for three existing landfills to be expanded in the Turtkul, Kungrad and Karauzyak districts, with one new landfill to be constructed in Nukus. Although a generous budget of EUR 440 000 has been earmarked for environmental and social due diligence, people living in the adjacent settlements were not consulted and see no benefits of expanding a landfill next to their homes. 

Investors keep ignoring the extremely high social risks of waste projects

The EBRD categorises these waste management projects as having low environmental risks, which means that less due diligence and transparency is required. But the social risks of such projects and the need to engage with affected communities remain high and should not be ignored.

‘In summer, it stinks so much you cannot breathe. There are diseases because of the flies’, said a man who lives with his family in a house located about 500 metres from the Turtkul landfill. Others also complained about dogs bringing medical trash into the village, smells and fumes from burning trash, and garbage trucks running through the settlement several times per day. 

Moreover, almost everyone we interviewed told us that nobody informed them about the plans or asked for their opinion. ‘Everyone here knows about the bad smell, and it will be much worse if the landfill is extended. But no one told us about those plans’, said a woman who lives near the Karauzyak landfill.  

Many people living nearby are farmers and are concerned with coyotes attracted by the trash and the threat they pose to the cattle. Moreover, landfills in close proximity may pollute underground water, which is the main source of drinking water for most residents. 

‘We are against the landfill expansion because we live very close to it – it is very harmful for us and our children. But no one asked me’.

– one of the nearby residents that Bankwatch interviewed in November 2022

When asked about public consultations, both the Turtkul landfill manager and the mayor of Karauzyak replied that ‘no one complained’. However, in every district there are some active residents who have been raising concerns for a long time with no success. 

In Uzbekistan, a democratic deficit, limited space for freedom of expression and weak protection of human rights go hand-in-hand to make local communities fearful of speaking up against bad projects supported by the government. In this reality, it is up to development banks to ensure that their activities do not cause harm or contribute to human rights violations. As such, the banks must take necessary measures to guarantee meaningful public participation and identify, address and mitigate reprisal risks for people opposing the projects. 

To mitigate such risks, international development banks like the EBRD need to consider the specific contexts in the countries they invest in. For this reason, public consultations with project-affected people and engagement with civil society stakeholders in such contexts require much more effort to create a safe space for dialogue. Early consultations and designing projects based on community feedback – in this case, locating project facilities further away from communities – can prevent community grievances and possible attempts by the EBRD’s clients and authorities to silence critical voices.

‘Within the pre-approval environmental and social due diligence, the EBRD’s consultant visited the project sites and conducted interviews with representatives from the project company, but not the people living nearby. As a result, the EBRD failed to identify and address human rights and community health risks’, said Nina Lesikhina, Bankwatch’s community support coordinator.

In 2021, Bankwatch notified the EBRD’s project team about the local communities in Karakalpakstan, raising concerns about the close proximity of the landfills to people’s houses. However, the project was approved in 2022 with no visible consideration for these concerns.

The bank is also responsible for identifying alternative project sites for its investments, as site selection should be based on a proper environmental and social risk assessment. ‘There is plenty of space between Bukhara and Kazakhstan; no need to have a landfill so close to people’s homes’, commented several locals on the waste project’s location.  

The EBRD’s rationale behind the extension of the existing landfills is to minimise the acquisition of new land. This could be a valid point, but not in a country where land is usually allocated without much consideration of environmental and social risks. Therefore, the current landfills happened to be constructed just hundreds of metres from people’s houses, despite the legal requirement to ensure a 500-metre sanitary zone. Further extension of the existing landfills will contribute to the environmental marginalisation of the communities.