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サハリンU開発に関する融資機関宛NGO要請書
2005年2月7日


サハリンU開発に関する融資機関宛NGO要請書


サハリンII第二期工事への融資を検討している融資機関(欧州復興開発銀行、国際協力銀行、米国輸出入銀行、英国輸出信用保証局)に対して、各国のNGOが要請書を提出しました。

この要請書は、サハリン先住民族からの独立「民族学的アセスメント(文化影響調査)」の要求、ニシコククジラの独立レビュー、そして南部コルサコフの住民の生活環境において生じている様々な問題について、各融資機関の対応を求めるものです。

以下、レターの全文です。

___________________


Friends of the Earth Japan ● Friends of the Earth Netherlands/Milieudefensie
CEE Bankwatch Network ● Friends of the Earth EWNI
Pacific Environment ● PLATFORM
Sakhalin Environment Watch
Urgewald ● WWF Russia



February 1, 2005

Jean Lemierre
President
European Bank for Reconstruction and Development
London, England
(via email)

Patrick Crawford
Chief Executive Officer
Export Credit Guarantee Department
London, England
(via email)

Kyosuke Shinozawa
Governor
Japan Bank for International Cooperation
Tokyo, Japan
(via email)

Philip Merrill
President and Chairman
Export-Import Bank of the U.S.
Washington, DC
(via email)


Dear sirs,

Thank you again for your due diligence on the Sakhalin II project. We write concerning three issues that deserve your immediate attention:

    ・ Sakhalin indigenous organizations' demand for an independent cultural impact assessment (ethnological ekspertiza) and compensation fund;

    ・ Royal Dutch/Shell's refusal to consider alternative designs to protect the critically endangered Western Gray Whale;

    ・ Ongoing project impacts on the city of Korsakov.


INDIGENOUS CULTURAL IMPACT ASSESSMENT AND COMPENSATION FUND

On January 21, 2005, we received a copy of a letter to you from Pavel Sulyandziga, Vice President of the Russian Association of Indigenous Peoples of the North, Siberia, and Far East (RAIPON). Mr. Sulyandziga's letter urges you to exercise your authority to require that the Sakhalin II project provide for an independent cultural impact assessment, and support compensation in the form of a development fund for indigenous people that are negatively affected by Sakhalin II. We join the call of RAIPON and the Sakhalin indigenous peoples for this independent assessment and development fund. We urge you to intervene and to enforce your policies by requiring the completion of the cultural impact assessment and development fund as a prerequisite for further consideration of financing for Sakhalin II.

Russian indigenous leaders--with members of the Nivkh, Uilta, Nanai, and Evenk peoples--have been driven to protest by blockading oil and gas development activities on Sakhalin Island. From January 20-24, 2005, hundreds of Sakhalin indigenous peoples endured minus 30 degree Celsius temperatures to stand in defense of their rights and against the negative impact of oil and gas projects (see links to news stories below). Indigenous leaders are justifiably concerned about the impacts of these projects including, inter alia, harm to fisheries, reindeer pastures, and forest animal populations. Indigenous leaders indicate that compensation provided so far by oil companies is insufficient, and that they do not trust the oil companies' environmental, social and health impact assessments. They report that some companies, including Sakhalin Energy, have rebuffed their attempts to create a meaningful dialogue, sending public relations staff to meetings rather than company officials with any authority to remedy their concerns. This has also been the long-standing experience of other NGOs and community groups with Sakhalin Energy.

The protests undertaken by the indigenous leaders represent a very serious escalation of conflict, and it is another indication that the Sakhalin II project has failed to provide minimal environmental and social safeguards necessary to comply with the policies of your institution. We stand in solidarity behind these indigenous leaders and echo their call for you to enforce your policies and to require Sakhalin II project sponsors to provide for an independent cultural impact assessment and indigenous peoples development fund.


PA-B PLATFORM ALTERNATIVES

Our organizations applaud your institutional support for the convening of the Independent Scientific Review Panel (ISRP) to assess Sakhalin II project impacts on the critically endangered Western Pacific Gray Whale. The success of the ISRP rests in part on Royal Dutch/Shell's fulfillment of commitments to provide the Panel with information it needs to perform its assessment. The ISRP Terms of Reference include a directive to assess project design alternatives and additional mitigation measures. Royal Dutch/Shell has recently provided the ISRP with a Comparative Environmental Assessment (CEA), which we had hoped would provide the Panel with some of the information it needs to meet this directive, including assessment of alternative subsea pipeline routes and platform locations.

The CEA is also supposed to be part of larger Environmental Impact Assessment (EIA) addenda that your institutions require and have committed to make publicly available. However, Royal Dutch/Shell has decided to conceal the CEA until sometime after the ISRP concludes its review. Royal Dutch/Shell has stated that it is withholding the CEA so the ISRP can review it without it being "subject to external pressures that might arise from a public debate on the CEA's content and conclusions." This is curious, given that the scientists involved are quite used to conducting independent scientific work concurrent with parallel discussions between citizens and governments, including long-standing dialogue between non-governmental organizations and your institution.

Meanwhile, we are more deeply concerned about what is apparently not in the CEA. According to Jamie Walls of Sakhalin Energy, the CEA does not include any comparative assessment of alternative locations of the PA-B platform, which is currently planned to be located adjacent to Western Pacific Gray Whale feeding grounds. As a consequence, the CEA does not present alternatives and mitigation measures that the ISRP needs to fulfill its TOR, and that your institution's environmental policies require.

This highlights the longer-term unwillingness of Sakhalin II project sponsors to consider project design alternatives to protect the critically endangered Western Pacific Gray Whale. For example, Sakhalin Energy's Environmental Impact Assessment states that the proposal to move the PA-B platform a sufficient distance east (away from the whale feeding area) has been "declined as a technically viable option," and that extended reach drilling is only possible up to 6 kilometers. Yet, great strides have been made in extended reach drilling to reach distances in excess of 10 kilometers. Extended reach drilling up to 11 kilometers is being conducted by ExxonMobil's Sakhalin I project due in part to environmental concerns. Concurrently, conservation organizations have suggested an alternative PA-B platform placement at a safe distance to the east of the currently proposed location. Yet, Sakhalin Energy states it cannot possibly consider alternative locations for the PA-B platform. Sakhalin Energy's CEA apparently presents no data to justify this position.

We are as yet unaware of the extent to which Royal Dutch/Shell has provided other information that the ISRP needs and that your institution requires, such as assessment of cumulative impacts associated with Sakhalin II. Requests over several years to Royal Dutch/Shell to present this information have been rebuffed. Given that the ISRP is scheduled to conclude its work by mid-February, Royal Dutch/Shell's willingness to provide the Panel and your institutions with the information that they need to meet your mandates is in serious question. Swift intervention by your institution is necessary in order to persuade Royal Dutch/Shell to seriously consider design alternatives to protect the Western Pacific Gray Whale, including relocation of the PA-B platform.


KORSAKOV

We appreciate the attention that you have paid to social impacts of the Sakhalin II project, including the negative impacts of the construction of the Liquid Natural Gas plant on the city of Korsakov. We were recently provided with a copy of a paper on these impacts by Lina Lazebnik, of the Korsakov-based community organization "Knowledge is Strength." Lazebnik's paper was written in response to queries from U.S. Congressional staffers following meetings in October 2004 with committees with oversight of public finance institutions, including EBRD and U.S. ExIm Bank.

Lazebnik's paper documents a number of very serious negative impacts on Korsakov, including the overwhelming of the water, waste, housing, medical and transportation infrastructure. Local authorities worry that Korsakov might be without water during parts of the winter, and along with it, electricity. Korsakov has suffered the brunt of 1,500 imported workers that have descended on the area, overburdening its social services and increasing communicable diseases including AIDs, tuberculosis and pediculosis.

Lazebnik demonstrates that much of these impacts are due to rampant cost-cutting tactics by Sakhalin II contractors, harming the city of Korsakov and project workers alike. She reveals that the promise of employment for Sakhalin residents has fallen far short. She notes that plans to compensate Korsakov are grossly insufficient to prevent a worsening community crisis. By Fall 2004, another 1,500 workers arrived, raising the total additional load on the infrastructure to 3,000 people. As a result, a local population that originally welcomed Sakhalin II now looks at it with increasing aggression.

The damage to Korsakov and the socio-economic costs that the Sakhalin II project have inflicted represent an obvious violation of your banks' environmental and social policies, as well as the violation of the human rights of Sakhalin residents. We urge your institution to intervene to ensure that the Sakhalin II project acts quickly to mitigate the financial and social toll it is exacting upon the city of Korsakov, on indigenous people, and on the Island of Sakhalin as a whole.

Sincerely,


Doug Norlen
Pacific Environment
San Francisco, California
United States

Shoko Murakami
Friends of the Earth Japan
Tokyo
Japan

Dmitry Lisitsyn
Sakhalin Environment Watch
Sakhalin Island, Russia

Regine Richter
Urgewald
Berlin, Germany

Igor Chestin
WWF Russia
Moscow, Russia

Petr Hlobil
CEE Bankwatch Network
Prague, Czech Republic

Nick Rau
Friends of the Earth
England, Wales, Northern Ireland
London, England

Donald Pols
Friends of the Earth Netherlands/
Milieudefensie
Amsterdam, The Netherlands

Greg Muttitt
PLATFORM
London, England




Press Coverage of Indigenous Peoples' Protest


For more information including pictures of the protest see:
https://www.pacificenvironment.org/russia/sakhalin_protest/index.html





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