correspondence Turkmenistan Turkmenistan Advocacy

Correspondence: Civil Society Response to EBRD regarding CMI Offshore project in Turkmenistan

In January 2017,  Crude Accountability initiated the open letter addressed to the European Bank Bank for Reconstruction and Development regarding the CMI Offshore Project and the Bank’s operations in Turkmenistan. The letter was signed by 37 civil society organizations.  In March 2017, we got a response from EBRD. However, we still have serious concerns with regards to implementation of the EBRD Social and Environmental Policy and Performance Standards in Turkmenistan. The letter below is the continuation of our correspondence with the Bank regarding the matter. 

To: Mr. Neil McKain

CC: EBRD Board of Directors
Director, Central Asia
European Bank for Reconstruction and Development

20 March 2017 Dear Mr. McKain:

Dear Mr. McKain:

Thank you for your letter dated 1 March 2017 concerning our questions with regard to the CMI Offshore project in Turkmenistan pending final review. It is particularly informative and we appreciate your attention to this matter. The information you have provided, however, along with further descriptions we receive from inside the country, continue to pose serious concerns with regard to implementation of the EBRD Social and Environmental Policy and Performance Standards. We therefore request that the Board date for this project be postponed until a proper impact assessment is carried out and disclosed to the public.

In your letter you explained that the loan would be used to purchase an AHTS vessel. These vessels are mainly used to handle and tow anchors for oil rigs, and are therefore considered associated facilities for the oil and gas sector. This necessitates that the project be considered under Category A guidelines for impact assessment and management. In addition, this loan would violate the Turkmenistan Country Strategy which explicitly states that “[t]he Bank will provide financing to privately-owned companies outside the oil and gas sectors…”

The fact that the Head of the Administration of the State Nature Reserve of Hazar stated that operations of the Company’s vessels do not represent a threat to the Reserve’s flora and fauna poses some serious conflicts.

  • First, our sources on the ground tell us that all maritime transport routes in the area go through the Hazar Nature Reserve, which is a Wetland of International Importance under the RAMSAR Convention. The Head of the Administration does not seem to deny this. For maritime transportation purposes, certain areas of the Hazar seabed have been excavated further to allow greater depth, and thus have disrupted the entire ecosystem. Our sources tell us that the maritime routes are just as bad for the nature reserve as construction of the Turkmenbashi port, because of the excavation of the sea-bed, which contains half of the feeder biomass for the wetlands ecosystem.
  • The Head of the Administration also insists that there are no spawning sites of endangered fish in the area of operations. This also seems to underscore our research that the area of operations will be inside the protected area thus necessitating the categorization of the project as Category A.

Mr. McKain, you stated, “the project would not result in any additional environmental or social impacts compared with the current situation.” As you know, the governance and human rights record in Turkmenistan is one of the worst in the world, and environmental management is virtually nonexistent following the liquidation of the Ministry of the Environment in 2016. Therefore, as the EBRD Turkmenistan Country Strategy stipulates, international financial institutions like the EBRD cannot invest in the status quo of the country. This investment will violate international standards.

We request that the Board delays consideration of this project until it is re- categorized as Category A, and associated facilities of the oil and gas sector are considered in accordance with the provisions of the current Turkmenistan Country Strategy.


1.Erida Skendaj, Albanian Helsinki Committee (Albania)
2.Katie Morris, ARTICLE 19 (International)
3.Alexander Fyodorov, Association of Journalists-environmentalist of the Russian Journalist Union ( Russia)
4.Olexandra Matviichuk, Center for Civil Liberties (Ukraine)
5.Yuri Dzhibladze, Center for the Development of Democracy and Human Rights (Russia)
6.Sonia Zilberman, Crude Accountability (USA)
7.Igor Trombitsky, Eco-TIRAS Intl. Assn. of River Keepers (International)
8.Andrey Laletin, Friends of the Siberian Forests (Russia)
9.Eldar Zeynalov, Human Rights Center of Azerbaijan (Azerbaijan)
10.Matthias Hui, (International)
11.Erika Leonaitė,Human Rights Monitoring Institute (Lithuania)
12.Tolekan Ismailova, Human Rights Movement “Bir Duino-Kyrgyzstan” (Kyrgyzstan)
13.Tinatin Tsertsvadze, International Partnership for Human Rights (International) 14.Yevgeniy Zhovtis, Kazakhstan International Bureau for Human Rights and the Rule of Law (Kazakhstan)
15.Alban Muriqi, The Kosova Rehabilitation Centre for Torture Victims (KRCT), (Kosovo)
16.Pepijn Gerrits, Netherlands Helsinki Committee (Netherlands)
17.Ivar Dale, Norwegian Helsinki Committee (Norway)
18. Alex Postica, Promo LEX Association (Moldova)
19.Haykuhi Harutyunyan, “Protection of Rights without Borders” NGO (Armenia) 20.Anara Ibrayeva, Public Association “Dignity” (Kazakhstan)
21.Natalia Taubina, Public Verdict Foundation (Russia)
22.Leila Alieva, Regional Center for Strategic Studies (Azerbaijan/Georgia) 23.Eugene Simonov, Rivers without Boundaries International Coalition (Russia) 24.Nikolay Krayev, Russian Scientific Research Institute of Hunting (Russia) Sviatoslav Zabelin, Socio-ecological union (International)