LETTER FROM MR. RASHAD KALDANY TO THE BEREZOVKA INITIATIVE GROUP AND CRUDE ACCOUNTABILITY
International Finance Corporation
World Bank Group
Oil, Gas, Mining and Chemicals Department
Rashad-Rudolf Kaldany
Director
2121 Pennsylvania Ave., N.W.
Washington, DC 20433 USA
Telephone; (202) 473-6787•Facsimile (202) 522-3743
January 30, 2006
Ms. Svetlana Y. Anosova
Initiative Group of the Residents of Berezovka
Berezovka, Burlin Region
West Kazakhstan Oblast 090300
REPUBLIC OF KAZAKHSTAN
Ms. Kate Watters
Executive Director
Crude Accountability
PO Box 2345
Alexandria, VA 22301
Dear Ms. Anosova and Ms. Waters [sic],
Re: Your letter to Mr. Paul Wolfowitz of December 9, 2005
Thank you for your letter to Mr. Wolfowitz regarding the environmental situation around the IFC-financed Karachaganak project in Kazakhstan, which we received in late December 2005.
We noted your continued concerns, centering on the atmospheric and water resource pollution that you believe to be originating from the project, and its associated potential for adverse health effects on the local population. Accordingly, IFC engaged with its client (Lukoil) and the project company (KPO B.V.) to examine the issues contained in your letter and has obtained from them the following information:
1. KPO’s ambient air quality monitoring program is in compliance with the relevant environmental legislation and regulations in the Republic of Kazakhstan. Routine monitoring for the toxins listed in your letter as being present in above maximum permissible concentrations around the Karachaganak field is not required by law in Kazakhstan, nor is it representative of normal global oil industry practice elsewhere in the world.
2. Notwithstanding the above, in acknowledgement of the importance of the issue of ambient air quality to various stakeholders (including employees, neighbouring communities, local government, and shareholders), KPO commissioned an independent air quality study by a scientific organisation with extensive international experience ( the non-profit Batelle Memorial Institute), as a complement to its own monitoring program. The results of the Batelle study, which was performed in accordance with the highest internationally accepted scientific standards (for both data collection and analysis), have recently become available. They do not find evidence of the alleged excessive concentrations of toxic substances in the ambient air surrounding the Karachaganak field. (KPO is now in the process of preparing and providing translations of the Batelle study to all the villages neighboring the field.)
3. However, recognising the divergence of the findings of past analyses by different parties, KPO has now offered to collaborate with local communities and other stakeholders on the joint design and implementation of an ongoing additional program of scientifically sound ambient air quality monitoring, whose accuracy, reliability and independence can be accepted by all parties. As part of this stakeholder partnership initiative, KPO has specifically stated its interest in an active contribution from members of civil society, including the Initiative Group of the Residents of Berezovka and Crude Accountability.
4. KPO has informed IFC that it is prepared to provide the necessary funding for the above program but—in order to ensure maximum impartiality—has proposed that all monitoring be conducted by independent third parties who are commissioned by, and therefore owe their duty of care to, the Village Councils, which represent the eight communities neighboring the Karachaganak field and which are supported by the local legislature and government.
5. As no water quality data for the water supply system of Berezovka was provided with your letter, it has not been possible for IFC to review this issue in detail. However, we understand from KPO that Berezovka is located upstream of all surface and ground water flows running in the vicinity of the Karachaganak field. Hence, in order to be able to examine this issue more fully, we would first need to receive the data which you believe demonstrates the impact of the KPO operations on the quality of the water supply in Berezovka.
IFC remains committed to safeguarding the continued compliance of the Karachaganak project with the World Bank Group environmental and social standards. Accordingly, we will continue to monitor closely the project’s performance and the progress of the above initiatives, and will support these as appropriate.
At the same time, we would encourage strongly both the Initiative Group and Crude Accountability to respond to KPO’s offer of partnership, which is directly aligned with your recommendation in your letter to Mr. Wolfowitz for “further serious research into the problem of environmental pollution.” In our view, as already stated on several previous occasions, such direct collaboration would present the best opportunity for achieving a durable resolution to all environmental discussions at Karachaganak.
Sincerely,
Rashad Kaldany
Director
Oil, Gas, Mining and Chemicals Department
Cc: H.E.E. Dosaev, Minister of Health, Republic of Kazakhstan
H.E. K. Mukhamedzhanov, Minister for Environmental Protection, Republic of Kazakhstan
Mr. R.S. Akhmetov, Deputy to the Senate of the Parliament, Republic of Kazakhstan
Mr. R. Kh. Suerbaev, Oblast Ecology, Western Kazakhstan Oblast
Head of Oblast Department of Health, Western Kazakhstan Oblast
Mr. E.K. Imashev, Akim, Burlinsky Raion
Mr. R Uteshev, Deputy Akim, Burlinsky Raion
Mr. R.K. Narmaukhamedov, Akim, Berezovka Okrug
Mr. P. Campelli, General Director, KPO, B.V.
Ms. Kate Kopishke, Specialist Ombudsman, Office of the Compliance Advisor Ombudsman (CAO), IFC
Bureau for Human Rights, Uralsk