Report No. 13990-KG Kyrgyz Republic National EnvironmentalAction Plan

Public Disclosure Authorized May 2. 1995

Infrastructure, Energy and Environment Division Country Department III Europeand Region

Environment Division Technical Department Europeand Central Asia, Middle Eastand North Africa Region Public Disclosure Authorized

Public Disclosure Authorized 2= _-X:X Xn C:,e, , =_ - . -

Documentof dieWoas= _____ Public Disclosure Authorized CURRENCY EQUIVALENTS

Currency Units = Som

MEASURES AND EQUIVALENTS

I cubic meter (m2 ) 35.310 cubic feet I hectare (ha) = 2.470 acres I ton = 1,000 kilogrammes

GLOSSARY OF ABBREVIATIONS AND ACRONYMS

ADB Asian Development Bank CIS Commonwealth of Independent States EBRD European Bank for Reconstruction and Development EIA Environmental Impact Assessment EU European Union FSU Former Soviet Union GDP Gross Domestic Product GEF Global Environment Facility Geprozem Institute of Land Use and Utilization GNP Gross National Product GOKR Government of the Kyrgyz Republic Goskomekonomika (SCE) State Committee on the Economy Goskomgeol (SCG) State Committee on Geology Goskominvest State Committee on Foreign Investments and Economic Assistance Goskompriroda (SCEP) State Committee on Environmental Protection Goskomstat State Committee on Statistics Hydromet State Hydrometeorological Agency IAEA International Atomic Energy Agency IDA International Development Association IFC Intenational Finance Corporation KJKS Kyrgyzjikommunsoyuz (Urban Municipal Services) KSRS Kyrgyzselremstryoy (Rural Municipal Services) Kygyszaltin State holding company for all mining and metallurgical enterprises Kyrgyzokhotrybolovsouz Kyrgyz Hunting and Fishing Union Leskhoz State Forestry Farm mkrR Microroentgen MOA Ministry of Agriculture MOE Ministry of Energy MOF Ministry of Finance MOH Ministry of Health MOI Ministry of Industry MOT Ministry of Trade M&M Mining and Metallurgy MOWE Ministry of Water Economy PDK Maximum allowable concentration TOE Millions of tons of oil equivalent NAS National Academy of Sciences NBK National Bank of NEAP National Environmental Program Action Plan NMP Net Material Product Sanepid Sanitary-Epidemiological Service UNDP United Nations Development Programme USAID United States Agency for International Development Vodokanal Water Supply and Sanitation Utility

FISCAL YEAR

January I - December 31 TABLE OF CONTENTS

EXECUTIVE SUMMARY ......

PART ONE

NATIONAL ENVIRONMENTAL ACTION PLAN: PRIORITIES FOR ACTION 1995-97

1. WHY DOES THE KYZGYZ REPUBLIC NEED A NATIONAL ENVIRONMENTAL ACTION PLAN? ...... 1

2. SETTING GOALS AND PRIORITIES ...... 5

A. Key Environmental Problems ...... 5 B. Priority Actions ...... 7 C. Critical Constraints ...... 8

3. MAJOR ENVIRONMENTAL CONCERNS: DEFINITION AND UNDERLYING CAUSES ...... 9

A. Water ...... 9 B. Land ...... 11 C. Environmental Concerns Related to the Mining and Metallurgy Industry . 14 D. Air ...... 15

4. FRAMEWORK FOR ACTION ...... 17

A. Addressing Priority Problems ...... 17 B. The NEAP Process ...... 26

PART TWO

BACKGROUND PAPERS

1. SETTING ENVIRONMENTAL PRIORITIES USING HEALTH INFORMATION .37

A. Background .. 37 B. Exposures to Toxics .. 39 C. Information Management .. 43 D. Capacity Building and Institutional Strengthening ...... 44 2. WATER RESOURCE MANAGEMENT IN THE KYRGYZ REPUBLIC ..... 45

A. General Overview ...... 45 B. Occurence and Characteristics of Groundwater ...... 51 C. Water Resources Development and Use ...... 52 D. Domestic, Industrial, and Agricultural Water Use ...... 58 E. Threats to the Quality of Raw Water Supplies ...... 65 F. Drinking Water Quality ...... 68 G. Conclusions and Recommendations ...... 69

3. NATURAL RESOURCES ...... 73

A. Agriculture ...... 73 B. Forestry ...... 79 C. Watershed Protection ...... 84 D. Biodiversity Conservation ...... 86 E. Tourism ...... 91

4. THE MINING AND METALLURGICAL SECTOR ...... 95

Hot-spot in the Mining and Metallurgical Sector ...... 98

5. THE INDUSTRIAL SECTOR ...... 111 A. General Overview ...... 112 B. Toxic Industrial Waste Disposal ...... 113

6. THE ENERGY SECTOR ...... 118

7. LEGISLATION, STANDARDS AND ENFORCEMENT ...... 126 ACKNOWLEDGEMENTS

This report is the result of a cooperativeeffort between the Governmentof the Kyrgyz Republic and the World Bank. The idea of preparing a NationalEnvironmental Action Plan (NEAP)was discussed and agreed with the governmentagencies responsible for enviromnentalprotection in March 1994. The report is expectedto help the Governmentin developingits environmentalpolicies and the donor agencies in targeting assistanceand avoiding duplicationof effort.

The preparation of the National EnvironmentalAction Plan on the Kyrgyz Republic side was overseen by a high level Steering Committee,coordinated by Mr. I. S. Muratalin,Chairman of the State Committee on Environmental Protection. Members of the Committee included the Minister of Agriculture Mr. Z. A. Asanov, the Minister of Water Economy Mr. M. Z. Zulpuev, the Minister of Health Mr. N. K. Kassiev, the Chairmanof the State Committeeon the EconomyMr. A. M. Muraliev, the Chairmanof the State Committeeon StatisticsZ. A. Akeneev,the Chairmanof the State Committee on Geology Mr. Sh. T. Tekenov, the President of the National Academy of Science Mr. T. K. Koitchuev, the Director of the State Agencyfor TechnicalControl in Mining Mr. A. M. Masaliev, the Director of the State HydrometeorologyAgency Mr. 0. N. Tokoev and the chief of the Department of Scienceand InternationalCooperation in the State Committeeon EnvironmentalProtection Mr. M. S. Sulaimanov. The Deputy Chairmen of the State Committee on EnvironmentalProtection, Mr. T. A. Kulumbaevand Mr. T. S. Musuralievprovided valuable assistancein the preparation of the report.

The Kyrgyz Government formed an expert Working Group to prepare the NEAP with representativesfrom governmentagencies and non-governmentalorganizations (NGOs), coordinatedby Mr. K. D. Bozov, Chief Ecologist of the Kyrgyz Republic, and Mr. E. D. Shukurov, Director of the Institute of Biology at the National Academy of Scienceand Chairman of "Aleine" (an environmental NGO). The Working Group includedL. M. Kiashkina, T. G. Korneeva, L. A. Epstein, T. Klimakova, S. T. Malishev, A. A. Ishmuhamedov,A. Sidikov, N. G. Mudratchenko,A. M. Isaev, G. Osmonalieva, F. S. Kovaltchuk,V. D. Zamoshnikov, N. I. Kabanova, E. A. Suerkulov, V. M. Shaposhnikova,A. A. Imanaliev, C. 0. Sadabaeva, M. C. Sulaimanov,S. A. Mambetzhanova,K. M. Noruzbaev, I. K. Kenzghetaev,I. A. Dairov and E. A. Omurbekov. The Kyrgyz experts wrote basic reports on current environmentalissues and participated in series of discussions with the World Bank NEAP team.

The Bank's National EnvironmentalAction Plan team was led by K. Georgieva, Environmental Economist, and included R. Batstone, Principal EnvironmnentalEngineer, R. Ackermann, Principal EnvironmentalPolicy Analyst,T. Garvey, SeniorWater Quality Specialist,and E. Ibraimova, J. Moore, L. Talbot, H. Mishra, K. Shankar, N. Bech, K. de Wijs and D. Everett (Consultants). V. Tsirkunov, K. Lvovsky and D. Onoprishvilicontributed to the preparation of sections of the report. J. Djaky, with support from E. Marinovaand J. Kouame,was responsiblefor the productionof the report. Two NEAP preparation missionsto the Kyrgyz Republicwere carried out in June 29-July 15, 1994 and October 25- November 10, 1994, to support the Kyrgyz Governmentin finalizingthe NEAPand settingenvironmental priorities for the Kyrgyz Republic. Peer reviewers were A. Bond and M. Kosmo. The World Bank Resident RepresentativeMr. Michael Rathnam and Mr. Valeri Tian, Project Officer in the Resident Mission, provided valuable contributionto the NEAP process and to the report.

Work on the NEAP utilized a document on the status of the environment prepared by the Government of the Kyrgyz Republic for the UNCED meeting in 1992. It also drew upon World Bank sectoral studiesfor the Kyrgyz Republic(on agriculture, miningand energy), as well as reports on health and poverty assessment. We wish to thank the authors of these reports for allowing us to use some of their findings. The Kyrgyz Republic: an Overview

Background. The Kyrgyz Republicis a landlockedCentral Asian counry with a populationof 4.3 million (1994). It is among the smallest and poorest of the republics of the Former Soviet Union (FSU), covering 198,000Km 2 or less than I percent of the FSU, with a per capita income in 1993 of US$830. The Republic is divided into 6 states or oblasts, arid a capital district, . Although the country is a democratic republicand relies on the former Sovietadministrative structure, the indigenoustribal social and political structure is still strong.

Demography. The Kyrgyzmake up 52 percent of Kyrgyzstan's population. Tle other major ethnic groups includeRussians, Uzbeks, Ukrainians,Germans, Tatars, Dungan,Kazaths, Uighurand Tajiks. Since independence,many of the Russians, Germansand Ukrainianshave migrated to other republics, creating managerialand technicalvoids in institutionsthroughout the country. Prior to 1990. the country had one of the lowest rates of emigrationin the Soviet Union. Approximately64 percent of the populationlives in rural areas -around Lake Issyk-Kul,the Pergana Valley, the Valley, and the lower slopes of the Tien Shan and Pamir Mountains. The remaining 36 percent live in urban areas, particularly Bishkek and Osh.

Topography. Kyrgyzstanis dominatedby the Tien Shan mountainrange, which divides the country into 2 zones, the northern region includingthe , Chui, Issyk-Kyuland Bishkek, and the catchment in the south. The country is very mountainous,with 94 percent of the territory over 1,000 m abovesea level, of which 40 percent is above 3,000 m as], with large glaciers and snowfields(Map 1, IBRD #26876). Pobeda, the highest peak, is 7,439 m. The region is seisrically very active, with frequent earthquakes and landslides.

Climate. The climate is continental: cold winters and hot summers, with high local variations depending on altitude. In July, average temperatures in the lower areas range from 17°C to 270C (high temperatures can exceed 40°C), while temperatures may reach only I0°C at 3,000m. In the winter, frost occurs in all regions. Precipitationis the highest in the mountains, mostly as snow, with a maximumof 1,000mmnon the slopes of the Fergana Valley. Precipitationin the Talas region varies from 250mm to 500mm. Issyk-Kulreceives from 200mm in the west, up to 600mm in the east. Rain and snow mostly occur in the fall, winter and spring, with snowfallpossible until May. Summersare generally dry. Map 2 (IBRD #26620)illustrates the water resources of the country, includingannual rainfall, major rivers, lakes and snowfields. Potential annual evaporationvaries between 200mnmin high altitudes(above 3,500m) and 1600mmin low areas (below 500m). Evaporation in key irrigated areas can vary between 1,200mm and 1,600mm, far exceeding the average precipitation (400mm).

Vegetation. Vegetationis classified vertically into three belts. Pastures and steppes dominate regions below 1,500m; this area is used for agriculture although parts of this lower belt are consideredas semi-arid. In the southwest where there is more precipitation, there are relic fruit and nut forests. The second belt, between 1,500m and 3,000m, contains grasslandsand broadleaf and conifer forest up to the treeline (3,000m). The highest belt (above3,000m) containsalpine grasslandand sub-alpinemeadows, with a high variety of flowers, intercalated with pernmaent snowfields, glaciers and rocks. OnlY about 7 percent of the land is desert, steppe, or arable river valleys, thus readily manageablefor human use.

Fauna. Wildlife in Kyrgyzstanconsists of some 80 species of mammals, includingvaluable game species such as the Marco Polo sheep and the Siberian wild mountaingoat. Endangeredsnow leopardsalso inhabit the mountains, as well as different species of bear, wolf, lynx, fox, deer, marten, weasel and marmots. About368 bird species can be encountered,the majorityof which are migratoryspecies, and there are approximately30 reptiles and 65 fish, includingthree types of tout. National Environmental Action Plan: i Executive Summary

EXECUTIVE SUMMARY

BACKGROUND

1. The Kyrgyz Republic is a small, mountainous Central Asian country with a population of 4.3 million people. Independent from the former Soviet Union (FSU) since 1991, the country is reshaping itself socially, politically and economically, moving from the former Soviet socialist system to democracy and a market economy. Consequently, environmental policy reform is being carried out within the context of profound economic and structural change.

2. The majority of the people live in rural areas (more than 64 percent). They are mainly farmers (although only seven percent of the land is arable) and shepherds who seasonally graze their livestock over much of the mountainous countryside. Primary agricultural production accounts for about 40 percent of GDP; industry, including mining, comprises about 30 percent. The Kyrgyz economy has been very seriously affected by the loss of fiscal transfers from Moscow (accounting for about 11 percent of GDP before independence) and by the loss the assured markets of the FSU. One result has been severe economic recession --since 1990, real output has declined by 45 percent in agriculture and by more than 60 percent in industry. With $830 per capita income in 1993, the Kyrgyz Republic is among the poorest republics of the FSU.

3. Many environmental problems have temporarily abated as a result of the economic downturn. Once the economy recovers, these improvements may not be sustained unless they are complemented by appropriate policy changes, encouraging resource conservation and better environmental performance. Generally, pollution emissions and agricultural chemical contamination decreased as a result of production decreases or cutbacks in the uses of polluting inputs. Other problems have intensified, due to changing household and industrial economies. For example, although the economic downtown has resulted in a reduction of industrial pollution, deforestation and soil erosion may have increased. Overall, pollution monitoring and regulatory enforcement have been halted because of lack of funds to support staff travel and equipment.

4. Country development objectives and policies. Since independence, the Kyrgyz Republic has shown a strong political commitment to move toward a market economy. The Government has been focussing its efforts on eliminating the distortions of the command economy, and reducing the role of the state. A complex stabilization and structural transformation program is being implemented, with assistance from the IMF, the World Bank and other bilateral and multilateral donors. In May, 1993, the Government introduced its own currency, the som, and, despite external and internal economic difficulties, has considerably advanced the implementation of the reform program.

* In the short and medium term, macroeconomic stabilization efforts have been focussing on tight monetary policy, fiscal revenue enhancement, and imposing financial discipline on the enterprise sector. Prices, interest rates, external trade and the foreign exchange regime have been liberalized, inflation has been curbed, and the currency strengthened.

* Structural reforms underway include privatization, already almost completed for small- scale service and retail operations; enterprise reform, including restructuring medium and large scale enterprises and removing subsidies; and private sector development, with legislation to expand private ownership, clarify property rights, and encourage competition. Sectoral reform is currently focussed on the agriculture sector. NationalEnvironmental Action Plan: ii ExecutiveSummary

* Social stability. Increasing poverty is a major concern--about 50 percent of the population is already below the nominal poverty line, and with rising energy and food prices, may becomefurther impoverished. Republic, oblast and rayon governmentswill be assuming responsibility for primary social services (including water supply and sanitation)from the monolithicsector enterprises, which will further burden constrained governmentbudgets.

5. The country's developmentstrategies in agriculture, energy and mining depend on improved managementof the nation's natural resources. These sectors carry considerableenvironmental liabilities from past managementpractices, however, and the potential for environmentalproblems in the future is high if they are not managed well. Therefore, environmental management and natural resource conservationare becomingincreasingly important to the country's economicdevelopment. Environmental policy changes must support and be supported by the country's broader policy objectivesof social and macroeconomicstability, and economicgrowth.

6. Many of the policy steps from the Government reform program (macroeconomicstabilization, price liberalization,privatization, impositionof hard budget constraints) are expected to contribute to environmentalimprovements. For example, increased prices of natural resources should encourage resourceconservation and reduce the levelof air and water pollution, and wastegeneration. Conversely, there is evidencethat privatizationof some industrialactivities is resulting in a decline in environmental controls, at least for the short term, as existingstate oversight is removed, and enforcementcapabilities weaken.

7. Exactly how sectors, enterprises and individualswill react to liberalizationmay not always be possibleto predict. For example,strict and fully enforced regulationsshould encourage both state-owned enterprises and the newly emergingprivate sector to comply with standardsand to maintain the existing environmentalinfrastructure. Rational fees and tariffs for resources, which have been proposed by the government, can help encourage more efficient resource use; and more clearly defined property rights structures should encourageinvestments in resources for long-termreturns.

8. Preparing the National Environmental Action Plan (NEAP) has been and will continue to be a complexprocess, which includes:(i) identifyingthe most critical environmentalissues that affect the economy and the social welfare of a country, and proposing a set of priority actions in a NEAP report; (ii) endorsementof the Action Plan by the Governmentand the public; (iii) mobilizingexternal assistance to implementthe NEAP; and (iv) periodicupdate to reflect changingenvironmental conditions, priorities and implementingcapacity.

9. The Governmentof the Kyrgyz Republic,assisted by the World Bank, initiated the preparation of the NEAP in March, 1994. A high level Steering Committeewas establishedto guide the activity, under the leadershipof the State Committeeon EnvironmentalProtection (Goskompriroda). An expert Working Group with representatives from government agencies, academia, and environmentalnon- government organizations (NGOs) was formed to develop the plan. This group worked in close collaborationwith a World Bank environmentalteam.

10. Publicparticipaticn is essentialfor the NEAP process. The Kyrgyz NEAP involvesNGOs and the general public in three types of activities:(i) expert contributionsto the drafting of the NEAP report; (ii) local discussionson environmentalpriorities; and (iii) broad public informationon the objectivesand expected outcomes from the NEAP. A Public ParticipationProgram has been developed, financedby the Fund for Innovative Approaches in Human and Social Development (FIAHS), and launched in National EnvironmentalAction Plan: iii Executive Summary

October 1994 by a Bishkek-based environmental NGO ("Aleine"). The program will provide a vehicle for consultations with the oblast administrations and local NGOs during the final stage of NEAP preparation and during the NEAP implementation.

Ii. The first phase of the NEAP, recorded in this report, focusses on critical environmental issues that threaten public health, economic and ecological stability and biodiversity, and on the options available to resolve these problems. Five main criteria were applied to this process: (i) threat to human health and welfare; (ii) significance for economic recovery; (iii) efficient utilization and maintenance of existing fixed capital, particularly environmental infrastructure; (iv) environmental policy and institutional changes allowing for the adjustment to structural transition and a market economy; and (v) full use and development of human resource capabilities.

12. The Republic cannot address all issues at once. NEAP findings affirm that environmental protection and economic development are inextricably intertwined in the Republic Knowledge and public priorities determine what actions should be taken; as both of these change over time, the NEAP will be periodically updated. The long-term social and economic development goals of the Republic should guide the setting of priorities for action. These long-term goals currently focus on increasing the productivity of renewable and non-renewable natural resources, as well as on ensuring good public health. Therefore, the key areas of concern which unite the problems identified by the NEAP team are the unsustainable use of naturalresources and the impact of pollutionon publichealth.

13. In this report, the findings of the NEAP Working Group are presented in two parts. Part One of the report explains the rationale for a National Environmental Action Plan, sets goals and priorities, and prescribes specific steps that can be taken over the next three years. Part Two contains the background papers on health, water resources, natural resources, mining, industry and energy on which these conclusions are based.

KEY ENVIRONMENTALPROBLEMS AND ACTIONPRIORITIES

Unsustainableuse of naturalresources

14. Kyrgyzstan's economic performance and social welfare are critically dependent on its natural capital. The NEAP identified five major areas of concern:

* inefficient water resource management;

* land degradation, mainly due to overgrazing;

* overexploitation of fragile forest resources;

* threat of irreversible loss of biodiversity; and

* inefficient mining and refining practices.

15. Ineffective water resource management. The Republic's water resources, which are critical for all five Central Asian Countries, suffer from inefficient distribution, and are not adequately protected from chemical and biological contaminants. Elements of the problem include inappropriately designed and aging infrastructure, lack of funds for operations and maintenance, a tariff structure which captures NationalEnvironmental Action Plan: iv ExecutiveSummary

only part of the operatingcosts, and insufficientregulation and enforcementof waste emissionsnear water sources.

16. To improve the managementof water resources and efficiency of water use, small targeted programs should be developedfor repairing and upgrading the physical infrastructure. Expenditures should be directed toward rectifying the highest priority problems of water supply contamination, supportingthe distributionof low-costsanitation technologies, and rehabilitatingand repairingirrigation networksthrough modestinvestments at the local level. Projects shouldbe based on a least-costapproach with respect to investment,operation and maintenance,and implementedquickly withexisting technology and locally-availablematerials.

17. Low productivityof the land. Rural poverty is both a direct outcome and a cause of increasing land degradation. Land degradation in the form of soil erosion, soil compaction, and deforestationis reducing the productivity of virtually all croplands, pastures, and forests -- resources on which at least 30 percent of the nation's economy is based. Natural regulation of waterflowsis hindered, reservoirs and irrigation networks are vulnerable to silting-in, and land slides and mudflows are destroying communitiesand productivelands. Extensiveovergrazing by livestock(particularly sheep and goats), inappropriatefarming practices, and poorly designed and maintainedirrigation systemsare the primary causes of degradation.

18. Farmer training in specificconservation techniques such as contour ploughing, reduced tillage, integratedcrop management,and intensivegrazing techniquesmay rectify some of the worst practices, and increase farm income. A rural credit program would also facilitate short-term investment in agriculturalinputs. Althoughauthority structures are changing, and land managementresponsibility is returning to local communities, resource rights are still unclear. There will be few incentives for investmentin the land's long-termproductivity and further degradationmay result if tenure rights remain uncertain.

19. Fragileforests. The conditionof the forest resourcesin the Republicis the result of past forest and rangelandmanagement practices. Since the beginningof the 40s almosthalf of the forestry cover has been lost, mostly during the Second World War. Now forests cover only 4 percent of the country's territory. Unofficial harvesting of wood is wreaking an unknown amount of damage on the already fragile forest resources. Illegal exploitationof wood for fuel and constructionby rural communitiesis viewed as a necessary responseto sky-rocketingprices and the cessation of fuel and incomesubsidies. The extensive grazing practices of herders dramatically reduces natural regeneration, and compounds forest managementproblems.

20. An integratedprogram for joint productionand conservationactivities in forests and grasslands must be developed, and forest policy should be revised to harmonize forest and grassland production objectives. Local communities(particularly the forest farms) should be able to capture the value of alternative activities, ecotourism, on the land. In particular, short-term credit needs to be availableto develop collection,processing and marketing of non-wood forest products such as fruits and nuts.

21. Threatenedbiodiversity. The Kyrgyz Republic has an outstanding natural heritage, of great beauty and diversity. The erosion of genetic diversity throughoutthe country is evident and profound, however. Biological impoverishmentaffects regional water regimes, quality of life, and economic options. It also is a significantglobal resource lost.

22. Future development depends on reversing the current decline in biodiversity--throughbetter managementand protection of watershedsand expansionof non-extractiveactivities such as ecotourism National Environmental Action Plan: v Executive Summary

and other biodiversity-conserving enterprises. A National Biodiversity Conservation strategy should be developed. It should encourage management of human activities to reduce habitat encroachment, and support economic activities which rely on biologically diverse resources. In addition, the protected area system should be reviewed and strengthened, with the active participation of the communities residing within it.

23. Wasteful mining and refining industries. A significant percentage of the Kyrgyz economy depends on the sound management of its nonrenewable mineral resources. Inefficient mine operations and processing plants have created dumps rich in materials, but badly maintained. Heavy metals and other toxins are now leaching into the environment. The economic costs of these practices are measured in terms of lost revenues from wasted resources, and potential health damages from exposure to toxins. Unfortunately, many of the minerals the Republic has relied on in the past, such as mercury and uranium, are facing very weak markets now and in the future, and it is unlikely the industry will be able to fund clean-up from its own revenues.

24. More information on mining wastes needs to be gathered through a specific data-sharing and monitoring program jointly established by the three key agencies, Sanepid, Hydromet and Goskompriroda. Documented health damages from water contamination and assessed risk of major environmental disaster should be main criteria by which mitigation measures for dealing with mine wastes are chosen. Environmental staff should be trained in environmental impact assessment to carry out a systematic assessment of mining waste dump and dam safety, and environmental surveillance of mining industries must be restored.

The impact of pollution on human health

25. Under the current budgetary constraints the Kyrgyz Republic can afford to address only those pollution problems which have direct impact on public health. These areas are:

* protection and decontamination of drinking water, and assistance for improved sanitation and personal hygiene;

* reducing dust emissions from district heating and power plants; and

* assessing the extent of soil and water contamination with uranium, mercury and other heavy metals, and agrochenuical wastes.

26. Contamination of public water supplies lie behind the most serious threats to public health in the Republic -- human exposure to water-borne diseases and toxic levels of heavy metals and radioactive wastes. Water-borne diseases may be reduced by repairing the existing water supply systems, installing low-cost but effective latrines, and enforcing land-use controls around surface water sources. Distributing simple teaching materials on personal hygiene, and supporting a low-cost rural sanitation program for latrine construction are also essential.

27. Exposure to airpollution in the largest cities is blamed for higher levels of respiratory diseases and morbidity in vulnerable urban populations, although air pollution is generally not a significant problem in the Republic. Particulates and other pollutants can be dramatically reduced by properly maintaining and operating existing equipment. For example, repairing and using existing dust filters (electro-static precipitators) in the major central heating and power plants in Bishkek and Osh, and regularly maintaining the existing bus fleets would dramatically reduce particulate levels in those areas. NationalEnvironmental Action Plan: vi ExecutiveSummary

28. The extent of health risk from exposure to heavy metals and radioactive elements which have been mobilized from mines, tailings deposits, dumps, and processing plants is a great unknown -- existing data are inconsistent and incomplete. More information must be gathered quickly before clean-up priorities can be assigned. The clean-up costs may be very high, and tbr this reason it is important that decisions to act are based on solid information about the relative hazards at each site. The wide-spread environmental and human health costs may could be incalculable, however, if clean-up at certain sites does not occur.

CONSTRAINTS TO BETTER ENVIRONMENTALMANAGEMENT

29. Policy constraints. Moving from problems to solutions will not be easy. The Kyrgyz Republic inherited its basic institutional and policy framework for environmental management from the FSU. In particular, resources were centrally allocated, physical performance targets were pre-eminent in importance, and the administered price system and soft budget policy placed little value on natural resources. Although the Republic has taken steps to adjust this structure, the main components of the previous institutional and management system remain intact at both the local and national levels. This hinders the progress of structural change. Economic reform can facilitate environmental management. For example, the removal of energy subsidies would encourage energy efficiency, and the progress of privatization would bring managerial improvements, improve resource utilization and encourage technological changes. However, managerial resistance to reforms and lack of experience slow the process of changes and constrain the potential environmental benefits of the economic reform.

30. Institutional and human constraints. The positive effects of economic restructuring will be sustained and deepened only if they are accompanied by the development of an integrated, decentralized environmental management system. An integrated system means air, water and soil pollution problems must be considered simultaneouslyduring the setting of environmental priorities. Decentralizationmeans that successful environmental management will require strengthening of the environmental authorities at all levels. Both of these require general public access to comprehensive, accurate and timely information about ecological, economic and human health parameters. Both require resources at all levels to facilitate monitoring, data analysis and communication, and to provide training. Retraining will assist environmental staff in their efforts to modernize procedures and develop problem analysis and project management skills appropriate to a free market economy.

PRIORITY ACTIONS

31. Acknowledgingthese constraints, three types of environmentalactions are identified as priorities in the short term: (i) a limited amount of expenditure for the rehabilitation, operation and maintenance of rapidly deteriorating and costly to restore institutional and physical infrastructure (in particular, water and sanitation infrastructure) and small investments targeted to rural natural resource-based enterprise development; (ii) a significant effort to collect well-definedinformation needed to make soundjudgments in the future regarding priorities for environmental action, and to ensure that the most urgent issues are tackled first; and (iii) enhancementof the environmentalregulatory framework, including training and support for staff in the environmental institutions.

32. As more and better information on the precise nature and urgency of environmental problems become available, the recommendations of the NEAP will be revised and refined. The tools available to the Kyrgyz Government to integrate environmental considerations into the overall economic and social development priorities will remain the same. They include: (i) changes in policies and regulations, (ii) improvements in the institutional framework for environmental management; and (iii) expenditures on projects with environmental benefits. NationalEnvironmental Action Plan: vii Executive Summary

33. There is a need to revisit environmental laws and regulations inherited from the FSU, in order to develop a coherent legislative system which corresponds to the requirements of economic transition and to the implementation capacity of the environmental authorities. Within this revision, issues of environmental liability must be addressed. Although the concept of liability is included in the existing environmental statutes, it does not define responsibility for past pollution, which is necessary for the on- going privatization process.

34. To support more efficient environmental institutions and effective environmental policy, several activities have been identified as high priority. Training environmental staff of government and quasi-governmental organizations is emphasized, particularly in international standards for environmental impact assessments (ElAs). This will promote harmonization with international environmental standards, and help ensure that new economic activities will meet all necessary environmental requirements. On-the- job training combined with international exchanges, are recommended with an immediate focus on the evaluation of the new gold mines, and a systematic assessment of mining waste dump and dam safety.

35. Environmental personnel should also be trained and funded to carry out efficiency and environment audits in selected municipalities, industries and mining industries. This activity will create local capacity to identify low-cost efficiency improvements in the polluting enterprises and form a basis through which the public can be educated and environmental standards can be monitored and enforced.

36. Enforcement. Assuring enforcement of standards and regulations is a key objective of the NEAP, which requires (i) properly set standards, to protect public health and productivity, and (ii) an effective monitoring system. Kyrgyzstan has a system of pollution charges, user fees and fines, for both water and air, which was developed under the Soviet Union. Charges are well below the level needed--fines (when they are collected) are a small fraction of the damage or abatement costs, and user fees usually do not cover even routine maintenance costs. Like most other countries, Kyrgyzstan needs to find a balanced approach between market and regulatory instruments. To be successful in environmental reform, however, central and local administrators must first be committed to enforcing regulations, and funding routine maintenance and operation of their environmental infrastructure from user fees.

NEXT STPS

37. The NEAP is an on-going process. Next steps include: (i) public review and Government endorsement of the NEAP; (ii) NEAP presentaton to the donor community; and (iii) implementation of high priority policy, institutional and investment actions. The high level Steering Committee is expected to further guide the implementation of the NEAP.

38. A small NEAP office will expedite the agreed upon framework for action. This office will facilitate collaboration among the many institutions within and outside the Government which must be involved in the environmental policy reform process, provide status reports on the implementation of projects, maintain an environmental library and information center, and update commnunicationson the changing inventory of key enviromnental concerns.

39. To initiate the NEAP, Goskompriroda will focus on a limited number of high priority actions during 1995. These will include:

* Defining environmental liability for past pollution to complement the on-going privatization process, and establishing legal guidelines for settling liability conflicts; National EnvironmentalAction Plan: viii ExecutiveSummary

* Developing the capacity to carry out Environmental Impact Assessment (EIA) according to intemational standards, including training technical staff in international procedures, and establishing compatible national guidelines;

* Establishing the capacity to perform efficiency and environmental audits in selected pilot enterprises--in particular the Kara-Balta mine--to identify options for an economically viable mine waste re-utilization and cleanup;

* Reviewing (with international assistance) the existing legal and regulatoryframework for the protection of environmental resources, including the appropriateness and enforceability of existing standards, permit systems, fees, and fines;

* Reviewing the international environmental conventions signed and ratified by the FSU, as well as new international initiatives which affect the Kyrgyz Republic; initiating a program for government ratification of the appropriate conventions and legal or regulatory reform required to be in compliance with the agreements; and

* Developing a National Biodiversity Strategy which integrates ecosystem preservation with local land-based economic activities.

40. In addition to the above actions, work should be initiated by the relevant authorities and Ministries to address the most urgent needs of the water supply and sanitation sector. In particular, short- and long-term technical assistance needs should be assessed within the next year, focussing on the rehabilitation, repair and replacement of facilities with the highest immediate health and economic impact, modernizing municipal and irrigation water distribution systems, and retaining and training local technicians. In the mining and metallurgical sector, interventions should focus on collecting the data needed to make hazard assessments and determine least cost remedial actions in the most critical areas. Environmental monitoring programs and regulatory enforcement must be reinstituted before far greater economic costs are incurred. PART ONE

NationalEnvironment Action Plan: I Priorities for Action 1995-97

1. WHY DOES THE KYRGYZ REPUBLIC NEED A NATIONAL ENVIRONMENTAL ACTION PLAN?

The Opportunities and Constraints of Economic Transformation

.1 The Kyrgyz Republic declared independence from the former Soviet Union (FSU) in August 1991, and joined the Commonwealth of Independent States (CIS) in December 1991. A new constitution was enacted on May 5, 1993, and the country introduced its own currency, the som, leaving the ruble zone. The Republic is determined to move toward a market economy, reaffirmed by the Kyrgyz people in a referendum held in 1994.

1.2 With an income of $830 per capita, the Kyrgyz Republic is one of the poorest in the FSU. Economic development relies on natural capital in agriculture, mining (gold mining in particular) and hydropower production. Rich in water resources, the Kyrgyz Republic plays a key role for the water balance in the basin. Reliance on natural resources for return to growth and income generation makes proper environmental management and natural resources conservation increasingly important to the country's economic development. Environmental policy, therefore, must support and be supported by the country's broader policy objectives of social and macroeconomic stability and economic growth.

1.3 The Kyrgyz Republic is one of the least industrialized countries of the Former Soviet Union. Industry, including mining, makes up about 30 percent of the GDP. Primary agricultural production comprises about 40 percent of the GDP, although only seven percent of the land in the Republic is arable. The remaining 30 percent of the GDP is comprised of primarily state service sectors such as state administration, health care, and scientific and educational institutions. During the Soviet period state social services (such as education and health care), now in decline, were relatively well-developed, while the commercial service sector was almost non-existent.

1.4 The Republic has an industrial base designed as part of a Union-wide plan for industrialization emphasizing FSU interdependence. Imposed by the central authorities of the FSU, the country's industrial structure did not correspond well to the resource potential of the Republic. As a consequence, many enterprises are entirely dependant on imported raw materials and FSU markets for their products. With a relatively small internal market, the Kyrgyz Republic is particularly vulnerable to breakdowns in inter-republic trade. Its geographical location handicaps interaction with more distant markets. In addition, industrial development under the FSU was focused on defense-related resources such as uranium and rare earths. These markets are very weak now world-wide, and the sector must be restructured if it is to survive.

1.5 Physical infrastructure, such as electricity and roads, is relatively well-developed. Electrical power reaches virtually every mountain village. The quality of many roads is worsening, however, making transport of heavy loads difficult. Rail transport within the country and to neighboring republics is very limited. Although there are a number of airports, none meets international standards at this time. These limitations in physical infrastructure make inter-republican trade very costly.

1.6 Under the FSU, the Kyrgyz Republic received highly subsidized fuel supplies. The country has considerable hydroelectric potential and exports electric power to neighboring republics; and it has sizeable resources of good quality lignite--estimated at over 50 percent of Central Asia's proven reserves. Nevertheless, the Kyrgyz economy is dependent on imported gas and oil for energy. The Republic now pays world prices for petroleum imports from Russia and Kazakhstan. In addition, Kyrgyzstan is forced to pay 60 to 80 percent of the European market price for natural gas, although the gas comes from and transportation costs between the two republics are minimal. The swift rise in imported NationalEnvironment Action Plan: 2 Prioritiesfor Action1995-97 energy prices toward world market levels has led to large terms of trade losses for the Kyrgyz economy, especiallysince it has not been able to obtain favorableterms for its electricity exports. Total industrial output declinedby 65 percentduring the past three years, particularlyin mineral beneficiation,which is a high energy consumer, and in the machinery,electro-technical and electronicssubsectors. The decline in the agricultural sector has been less severe, falling by 45 percent.

1.7 The Kyrgyz Republic is strongly affectedby developmentsin the CIS, particularlyRussia. As an integral part of the USSR, the country was subject to directions from the "center" on production, investment,trade, and virtually all other aspectsof economicactivity. Officialtransfers from the USSR budget accountedfor 10 to 15 percent of budget expendituresduring 1989-1991. Large implicitsubsidies from other republics also existed in the form of subsidized industrial and agricultural inputs and guaranteedmarkets.

1.8 Many environmental problems appear Figure 1.1: Air Pollution from Point Sources and to have improved as a result of the economic Industrial Productionin 1987 downturn. Generally, pollution emissions and ConstantRubles (x Million) agricultural chemical contamination have (1980 -1983) declined as a result of production declines or cutbacksin the applicationof pollutinginputs. Figure 1.1 relates declines in pollution 20 7000 emissions with the changes in industrial 6000 production. Other problems may have E intensified, however, due to changes in P 150- *2 household and industrial consumption or * 100 ~~~~~~~~~~~~3000 patterns. For example, deforestationmay be - . increasing as rural households are turning ILa - * x increasingly to wood for fuel. Pollution* mnonitoringand regulatory enforcement have 1907 1990 M 1992 i9m virtually ceased because of the lack of funds mAir pollutionfrom point sources to support staff travel and equipment, or the --- Industrial Production lack of will to close facilities on which hundreds or thousands of people depend either directly or indirectly for their livelihood.

1.9 Social and economic concerns. Althoughincome levels are low, the populationis well-educated and in the past enjoyed social support in the form of education, health services, and guaranteedincome and pensions. Unfortunately,provision of social services, previouslysecured by the central government and the enterprises, is severely limited by restricted budgetary policy and collapse of the state sector. Future levels of these services are uncertain. Increasingpoverty is a major concern -- about 50 percent of the populationis already below the nominal poverty line, and with rising energy and food prices may become further impoverished. Republic, oblast and rayon governmentswill be assumingresponsibility for primary social services from the monolithicsector enterprises -- further burdeningconstrained local budgets. Amongthose responsibilitieswill be maintenanceof publicinfrastructure and municipalservices (e.g., safe water supply and sanitation).

1.10 Economic stabilization and adjustment. In the short and medium term, macroeconomic stabilizationefforts have been focusingon fiscal revenueenhancement, and imposingfinancial discipline on the enterprisesector; Prices, interest rates, external trade and the foreign exchangeregime have been liberalized,while succeedingin curbing inflationand strengtheningthe currency. National Environment Action Plan: 3 Priorities for Action 1995-97

1.11 Structural reforms underway include privatization, already almost completed for small-scale service and retail operations and advancing for medium and large enterprises, enterprise reform, including restructuring large scale enterprises and removing subsidies, and private sector development, with legislation to expand private ownership, clarify property rights, and build an incentive framework encouraging investment and breaking up dominant structures. Sectoral reforms are designed to promote a rapid response in key sectors of the economy, particularly in agriculture and in the financial sector.

1.12 Many of the policy steps of the Figure 1.2: Share of EnvironmentalInvestment Government reform program (price of Total National Icome liberalization, removal of imports and export quotas, privatization, imposition of hard budget constraint) are expected to contribute 05 to environmental improvements. For example, increased prices for natural 0 4 resources should encourage resource ~0303 conservation and reduce the level of air and water pollution, and waste generation. On 022 the other hand, economic downturn and 01 budgetary restrictions have severely constrained environmental spending. The 0 _ l _ l _9*3_ share of environmental investments in the 1985 1990 Year 1992 1993 country's national income dropped to a record *efnbgesh] low level of 0.05 percent in 1992, going up in 1993, yet to still very low level--0. 12 percent (Figure 1.2).

1.13 In the short term some policy measures may also have an adverse environmental impact. Price increases force individuals and organizations to shift to alternative fuels, some of which are more polluting, such as coal, or more ecologically damaging, such as wood stripped from erosion-prone slopes. For example, up to 95 percent of rural households are using wood fuel (in combination with other energy sources). Most of it is freely collected along roads and in forests--only about 17 percent of the firewood used is purchased'. Accelerating deforestation is the result. Similarly, privatization, not combined with proper enforcement of environmental regulations, may lead to neglecting necessary environmental costs and worsening the environmental performance of the privatized enterprises.

1.14 Selection of sources of energy supply should be based on cost considerations, including environmental externalities, and should be combined with conservation measures which can be quickly and inexpensively implemented. Changes in the power market from 1990 to 1994 are illustrated in Figure 1.3. Although the overall energy consumption has decreased, mostly as a result of dramatic output decline, the shares of electricity, and firewood and dung cakes have increased. For electricity, the increasing share is due to raising residential electricity consumption (tripling in rural households and doubling in urban households between 1990 and 1993)2. This probably reflects state policy encouraging the consumption of nationally-produced electricity, including lax collection of electric fees, and the reduced availability of other fuels. Raising share of firewood is particularly alarming in light of the fragile condition of the national forests. Energy consumption per capita is well below the average for the FSU, mostly because of a low share of energy intensive industries in the economy.

I/ Kyrgyzstan Energy Sector Review.

_/I KyrgyzstanEnergy Sector Review. National Environment Action Plan: 4 Priorities for Action 1995-97

1.15 Many industrial enterprises use old Figure 1.3: Breakdown of Total Primary Energy Supply techinologies and equipment is poorly mlainitained due to lack of funds for maintenanceand spare parts. With the break tip of the FSUJ,the financial position of these 7OM enterprises has further deteriorated. 6__ Industrial restructuring will influence the iricdustrymix--the most significant short-term soa _l ICm environmental benefits may be gained through s _ CCU ma.rlrket-inducedshifts away from industries _ NahJrHI,"s whlich are no longer viable, to processes _Prd a Pructs whichl pollute less. Non-ferrous mining (such 200D _ E -Wnoty as gold) and hydroelectric power generation applzearto) he promiiising sectors -- both of o whilch can have negative environmental 199. 1994 impacts if not welli-managed. Environmental regulationis will need to be responsive to poteunial development in these areas.

.16 Agriculture has considerable potential for development and is a key sector targeted for support and refornm. Foreign investors are interested in the development of gold mining. Both agriculture and miiiing also bring with them severe environmental liabilities from past management practices. The reform prograni must be balanced to avoid incurring further social and environmental costs, and economic ;lialysis of rcforin options must integrate these costs.

I 17 This period of economic change is a unique opportunity to introduce sound environmental policies whichi reinforce the economic signals. If environmental policies are integrated with economic change as they should be, then they will be more easily and effectively adopted. For example, environmental charges and fees should be introduced as part of an overall tax reform package. Actions which disCoLurage "bad behavior" (such as pollution fees) can be balanced with rewards (reduced income taxes, or tax rehates for investing in clean technologies). Likewise, actions which regulate landuse or assign pollution liability should be made clear at the beginning of the privatization process, rather than later when owners have a vested interest in resisting regulatory control. Rational fees, tariffs and standards for resource use, such as those proposed by the government, will help encourage more efficient resource use In addition, miore clearly defined rights structures will encourage investments in resources which pro. idle long-term returns. NationalEnvironment Action Plan: 5 Prioritiesfor Action1995-97

2. SETTINGGOALS AND PRIORITIES

2.1 Why is it important to be concerned about environmentalissues? Kyrgyzstan faces difficult economic and social dilemmas. Why not defer environmentalissues until other problems have been addressed? The simple answer is that some environmentalissues can not wait because they are critical for the economicdevelopment of the Republic,the protection of public health, or because their neglect may lead to irreversibledamage. Other environmentalissues may have a relativelyminor impact on the economy or on the public--theycan and shouldbe postponed.

2.2 Choosingwhat is importanttoday and what can be deferred is not easy. It requiresboth scientific knowledgeand public consensus. Knowledgeand public priorities will change over time. As a result, the NationalEnvironmental Action Plan (NEAP) will be updated. The NEAP focuses on a small number of crucialproblems whichdeserve priority attentionnow and emphasizesthe collectionand dissemination of sound information. Other issues will be raised in the future, as the success of this Action Plan is assessed, conditionschange, and new informationis available.

2.3 The NEAP distinguishesbetween priorities and goals. Prioritiesare the actions that need to be taken in a two or three year period, carefully allocatingavailable resources. Priorities will need to be adjusted and new ones introducedfrom time to time in order to reach long-termgoals. The long-term goals for the Kyrgyz Republicaddress two priority areas: (i) increasingthe productivityof renewableand non-renewablenatural resources; and (ii) ensuringgood public health. Both are of critical importance for the economicdevelopment and public welfare.

A. KEY ENVIRONMENTALPROBLEMS

2.4 The key areas of envirorunentalconcern identifiedby the NEAP team are the unsustainableuse of natural resources and the impact of pollution on public health. The nature of the concerns is summarizedbelow. Greater detail on each of the issues can be found in the attachedbackground papers.

Unsustainableuse of naturalresources

2.5 Inefficient use of water. The Kyrgyz Republicis rich in water resources, although the amount of available water varies greatly throughout the country. Watersheds and catchments must be actively managed to protect and maintain these supplies. The irrigation, rural and urban water supply and sanitation infrastructurein the Kyrgyz Republicis well developed,but it is falling into disrepair due to financial and personnel shortages. Its continuedfunctioning is also essential. The economic and social costs of inadequatemaintenance could be very large, especially if new capital investmentsare required to replace facilities that are no longer usable.

2.6 Land degradationdue to overgrazing,and inappropriatefarming and irrigationpractices. The majority of the Kyrgyz people live in rural areas (Figure 1.4) and depend directly or indirectly on the productivityof the land. For rural populationsto have an acceptablestandard of living, soil productivity must be maintained and enhanced, and the production of renewable resources (livestock, crops and forests) managedin a sustainablemanner. If steps to reduce erosion are not taken, there will be growing economic,political and social costs from lost productivityand from sedimentation-causedcapacity loss in reservoirs. National .iivironment Action Plan: 6 Priorities for Action 1995-97

2.7 Overexploitation of fragile forest Figure 1.4: Populationof the Kyrgyz Republic resources. The State Forest Fund includes (ThousandPeople) fifteen percent of the the land area in the Republic. Deforestation in Kyrgyzstan is very serious, however, and most of the land in the Fund is used as rangeland. The loss of forests is due to high levels of tree harvesting in the past, the enormous pressure of - extensive grazing by large numbers of 2 | _ _ livestock, and the increased demand for _ _ wood, as a result of reduced imports of wood ______.P - from FSU republics and reduced availability * R.Pp of other fuels. The official timber harvest is Iwo about 40,000 m3 . The estimated illegal *_ fuelwood and timber extraction is about o 500,000 m3 or higher. Unfortunately, there g i E ; are no accurate figures on the existing standing stock, annual growth, or rate of deforestation. Uncontrolled cutting, however, will increase hardship in the future for rural people dependent on wood and non-wood products; it will accelerate deterioration of the upper watersheds and reduce biodiversity.

2.8 Loss of biodiversity. The ecosystem and species diversity of Kyrgyzstan is naturally high because of the dramatic relief, numerous microclimates, and diverse landscapes. A relatively large number of animals are endangered, however, and are listed in the Red Data Book of Kyrgyzstan. While hunting is officially regulated, enforcement of hunting control is very limited and licensing is very liberal (particularly for foreigners). Protected areas cover only 2.7 percent of the territory, and capture remnants of several ecosystems--most of them too small to maintain viable populations. There is a real threat for irreversible habitat loss, with negative global and local impacts. In the Kyrgyz Republic biodiversity protection is critical for potential development of tourism and therefore has a significant economic value.

2.9 Wasteful mining and refining practices. The Kyrgyz economy depends on the sound management of its nonrenewable mineral resources as well. Some of these will grow in importance in the future; others will no longer be in demand. Inefficient mining and refining industries created dumps rich in materials, but so badly maintained that heavy metals and other toxins are leaching into the environment. The economic costs of these practices are measured in terms of lost revenues from wasted resources, and potential health damages from exposure to toxic mine wastes.

Impact of pollution on public health

2. 10 Current data suggest that the most serious human health concerns in Kyrgyzstan -- childhood nutrition, hepatitis A, tuberculosis, maternal and infant morbidity and mortality -- are generally related to environmental exposures against which low-income populations have few defenses. These include such as unsanitary living conditions, use of contaminated food, poor water supply, inadequate nutrition, and exposure to toxins or biological contaminants. In addition, public health is expected to worsen as public infrastructure deteriorates. Infant and child morbidity are also increasing, caused largely by respiratory diseases in the winter from insufficient heat and more polluting fuels in homes and schools, and diarrheal diseases in the sunmmerfrom poor sanitation and contaminated water supplies. National EnvironmentAction Plan: 7 Priorities for Action 1995-97

2.11 Water pollution. In general, Kyrgyz water supplies are of excellent quality at their source. Water contamination occurs as the result of the deteriorated condition of the piped distribution systems, including treatment plants, and the lack of protection of the surface water sources from residential, industrial and agricultural wastes. Simple steps, such as funding regular maintenance and operations of the systems, enforcing land-use controls near water sources, and instituting low-technology, local solutions to sanitation would reduce many of the social costs associated with poor public health, and avoid irreversible damage to aquifers.

2.12 Air pollution. Although there are localized air pollution problems of an unquantified extent around smelters and mining waste dumps, the primary air pollution-related health problems are due to low quality fuels and non-operating pollution control devices associated with energy plants and transportation. These problems can be dramatically reduced by properly maintaining and operating existing dust collectors in the major industries and in district heating and power plants, and by regularly maintaining the city bus fleets.

2.13 Mining wastes (uranium, mercury, and heavy metals). Waste management in general is not well-developed, but in the mining industry, where the presence of toxics in the wastes makes good management of grave importance, the quality of environmental controls has been at best inconsistent and at worst critically negligent. Environmental monitoring has ceased for funding reasons at virtually all sites, the extent of health risk is unknown at the nearly 50 uranium tailings sites inherited from the Soviet Union, at the Haidarkan mercury combinat, or at the Kyrgyz Mining and Metallurgical Combinat (heavy metals). Experience in other countries shows, however, the localized risks to human health from exposure to these toxics can be severe.

B. PRIORITYACTIONS

2.14 There are many important problems in Kyrgyzstan -- how do we judge which environmental issues should receive priority attention? The Kyrgyz Republic's overriding objectives are to ensure sustained economic growth and to reduce poverty. Economic transfornation and the creation of new employment opportunities are key to attaining these objectives. Funds for environmental investments are limited and should go to actions which will support positive economic changes, or to problems which may be aggravated by the economic changes.

2.15 Three types of environmental actions are identified as priorities in the short term:

(i) Well-targeted expenditures are required to strengthen institutions and to rehabilitate, operate and maintain physical infrastructure that is rapidly deteriorating. Both will become increasingly costly to repair or replace. Timely investment in water and sanitation infrastructure will yield high benefits relative to the cost, just as small investments targeted to rural natural resource-based enterprise development can build strong links between economic development and natural resource conservation.

(ii) A significant effort to collect well-defined information for pollution loads, environmental degradation, resource use, status of waste sites and impacts on both population and ecosystems is required in order to make sound judgments in the future regarding priorities for environmental action. The ratio of economic benefits to costs is again likely to be high. Better information will help ensure that the most urgent issues are tackled first. National EnvironmentAction Plan: 8 Priorities for Action 1995-97

(iii) The environmental regulatory framework should be enhanced and the ability of staff in environmental institutions to operate effectively in the changing economic structures should be supported and strengthened. International assistance should be well coordinated and applied to the most important economic and environmental issues will facilitate this process.

2.16 Section 3 of Part I presents a summary of the major current environmental concerns. Recommended actions are described in the following Section 4. Part II provides a more detailed description of those concerns in the form of background papers on environmental health, water management, natural resource management, mining and metallurgy sector, industry, and energy.

C. CRITICALCONSTRAINTS

2.17 Financial constraints. In the current economic climate competition for funding both on national and on local levels is severe, and spending for environmental activities is harshly restricted. In order to prevent irreversible deterioration of public utilities and ecosystems, at least minimal resources should be secured for continued operation, maintenance and repair of vital infrastructure, as well as for important inputs in agriculture and forestry. Currently, only a negligible amount is available in the national budget, which imposes the need for raising funds through international assistance. Over time, a growing proportion of the money must come from the users of municipal and agricultural or forestry services.

2.18 Policy and institutional limitations. Money is not the only constraint. Under the former soviet system, generous financing for large capital investments was easily available, and proved to be the most inefficient way to improve resource productivity or environmental performance. In fact, broad economic policy reform and market accountability will address many of the causes of wasteful resource use and environmental degradation without the need for costly environmental expenditures. Efficient policy combined with small- and medium-scale targeted interventions tailored to the local economic and ecological structure have proven to be far more effective. No amount of investment will make up for policies that are misplaced or that encourage inappropriate practices.

2.19 Human resources. Successful policies and effective institutions are only possible if well-trained staff is available. While there are many highly skilled technical specialists in the country, locating appropriately trained and committed local managers to implement projects, devise low-cost innovative solutions to problems, and direct efficient and competitive enterprises is difficult. This Action Plan stresses actions to ensure that the human resources are available and sound incentives are in place to build a sustainable future for Kyrgyzstan. NationalEnvironment Action Plan: 9 Priorities for Action 1995-97

3. MAJOR ENVIRONMENTAL CONCERNS: DEFINITION AND UNDERLYING CAUSES

A. WATER

3.1 Limited water supply. Although Figure 1.5: Actual Water Use by Sector (1992 - 1993) Kyrgyzstan is water rich, available water (Million m3) supply is determninedby agreement among the five Central Asian States on the sharing of surface and ground water3. Kyrgyzstan uses all of its allotted share. Map 2 (IBRD #26620), attached at the end of this report, indicates the distribution of rivers, rainfall, permanent snowfields and glaciers throughout the country.) Water availability is therefore very limited. There are numerous opportunities for low-cost improvements in ,p (414) efficiency and water conservation, not utilized 8e/6 at this stage. This is evident in the water distributionsystems in the larger cities, and in the major irrigated areas of the and _ Industry (860) Naryn River basins. In these areas, irrigated DOMunCpa 414) agriculture alone uses about 88 percent of the total water consumed. Basic improvements in the water distribution infrastructure and Agncuture water-use practices could result in major 88lb water conservation benefits. The water surpluses gained could in turn provide opportunities for new development in either agriculture or industry. Figure 1.5 illustrates the water consumption imbalance among the three primary sectors of the economy.

3.2 Inadequate operation and maintenance of irrigation systems. Key elements of the irrigation infrastructure of the Republic are aged, including pump stations, diversion works, and reservoir facilities. In addition, regular canal cleaning has declined, and water control structures are not repaired. As a result of the lack of maintenance, repair, and replacement, irrigation capacity and the volume of water delivered have declined. Out of the budget of 285 million soms which was agreed upon in 1993 with the Ministry of Finance, only 60 million soms were officially allocated, and 30 million soms actually provided (an amount only sufficient to pay minimal salaries). Expenditures on maintenance and repairs have declined from 56 percent of the estimated requirements in 1991, to 9 percent in 1992, and 5 percent in 1993. While increased efficiencies and restructuring of sector institutions, infrastructure, and modes of operation are needed, failure to adequately fund general operations and maintenance will have costly consequences in such an economically vital sector. Agriculture contributes 28 percent of the GDP (constant 1992 prices). Agricultural production is highest on irrigated lands.

31 Under the forner Soviet Union, Kyrgyzstanwas required to allow over 75 percent of the water in rivers that originated in the Republicbut flowedinto neighboringrepublics to pass on to them for their use. Current inter- republic agreements continue this division of water-rights, with no compensationfrom the other republics to Kyrgyzstanfor this valuable resource. National EnvironmentAction Plan: 10 Prioritiesfor Action1995-97

3.3 Shortage offunds and personnel. An estimated 70 percent of the current water supply network is in poor condition and needs rehabilitation, repair, and replacement. About 97 percent of the piped water supply systems for rural people is provided by wells that supply water mains, hydrants and standpipes. Much of this system was built prior to 1970. There are no funds to install additional disinfection equipment where it is needed or to buy chemicals for existing units. Funds are only available for emergency repairs. Barely 10 percent of the previous number of staff are available to monitor drinking water quality in this highly dispersed system of water supply in rural areas. The lack of staff and budget has resulted in about a 75 percent reduction in the rate of expansion of coverage and in untrained personnel operating and maintaining many systems.

3.4 Exposure to contaminated water. Ground water supplies 90 percent of all drinking water provided by centralized pipe systems, and a high proportion of industrial water. The observed quality of freshwater from underground sources fed into the centralized distribution systems in urban and rural areas meets the present state standard for drinking water with respect to physical, chemical, and bacteriological parameters and generally does not require treatment before distribution. The deteriorated condition of piped distribution systems and the exposure of some of the surface water sources, however, create vulnerabilities to contamination and associated health risks. Some towns must still rely on surface water that is locally vulnerable to contamination from agro-chemicals, livestock manures, and sanitary wastes. Areas of low water quality are located in the most populated regions of the Chu river basin, in Osh and Djalal-Abad Oblasts, and in rivers flowing into Issyk-Kul Lake.

3.5 Contamination of the upper part of many aquifers with substances such as heavy metals, oils, and sanitary wastes is extensive in areas near industrial and mining sites and cities. The effect of these pollution sources is to create a layer of contaminated water overlying the deeper zones of good quality water that is being withdrawn by water supply wells. Unlike immiscible fluids such as oils which would tend to float above the good quality water, soluble substances such as heavy metals and nitrates gradually diffuse throughout the aquifer--eventually contaminating it to dangerous concentration levels if the infiltration of pollution from the surface continues. Hence, further pollution should be prevented even in those cases where pollution already exists. The intrusion of saline ground water into the aquifers due to over-pumping municipal water supplies and irrigation wells is another example of unsafe exploitation of groundwater. This has been observed particularly in Osh and Djalal-Abad Oblasts.

3.6 Unprotected surface water sources. Efforts to enforce sanitary protection zones in areas near surface water intakes or where water infiltrates into the aquifer have proven ineffective. Uncontrolled construction of homes without sanitary facilities or connection to sewers, expansion of livestock operations, laundries, storehouses for agro-chemicals and fertilizers, and unsafe disposal of liquid and solid municipal and industrial waste have continued to expand in an unregulated manner. They are all sources of surface water contamination. Osh provides an important example of the consequences of ineffectivecontrol of land use near raw water sources and the resulting vulnerability of the water supply. One of the principal water sources for Osh is the Ak-Buura River which is prone to sudden and damaging floods. This basin has numerous large livestock and farming operations, and dachas without adequate sanitation facilities, from which wastes are washed into the water supply system during these floods, resulting in disruption of service and dangerous contamination of the raw water supply.

3.7 Waste water collection capacity in the towns equals about 70 percent of the volume of water supply capacity. All the towns served with waste water collection systems are provided with biological treatment facilities. However, no systematic assessment is available of the current performance and effectiveness of these treatment facilities, and anecdotal reports from the sanitary inspection service indicate that over half are ineffective or inoperable. Sanepid inspections also show that municipal solid waste is not collected in a timely manner, and over 90 percent of all municipal solid waste disposal sites do not meet sanitary standards. These conditions contribute to the steady increase in untreated pollution entering the environment and infiltrating into underground aquifers and surface water channels. National Environment Action Plan: 11 Priorities for Action 1995-97

3.8 Health damages from poor personal hygiene. Hepatitis-A and OKZ4 both increased in 1993. The most infected areas are Osh and Djalal-Abad oblasts. These oblasts have large irrigated areas where canals and other open water supplies are contaminated by free-ranging livestock and incorrect disposal of human excreta. Drinking water is probably not the main source of waterborne diseases in adults, as the Kyrgyz people traditionally drink boiled water in the form of tea. Children, however, often inadvertently drink untreated water. Infection also takes place by eating contaminated food and through poor personal hygiene. These are largely cultural factors, and individuals need to be educated about how they can limit their exposure by altering their behavior.

3.9 Conclusions. There are sufficient quantities of raw water of excellent quality available for domestic and industrial use for the foreseeable future, provided water resources aie properly managed. Without significant renovation of the urban and rural distribution networks, improvement in the efficiency of on-farm use of water, and initiation of a major effort to increase water conservation in all sectors, water availability will be a constraint to future development.

3.10 The regulation of land use and enforcement of pollution prevention has been seriously inadequate in areas around water sources. This has led to negative health consequences in the form of increased morbidity and mortality among populations with vulnerable raw water supplies--particularly those using rivers, canals, and open reservoirs.

3.11 The present system of financing the maintenance, rehabilitation, repair, replacement, and modernization of drinking water and irrigation water supply infrastructure is insufficient. As a result, major health and economic costs are already evident. These problems will inevitably grow as the present infrastructure ages, and functions deteriorate further, including intakes, pumps, disinfection equipment. canals, gates, and distribution pipe systems which in most areas are over 30 years old.

3.12 The key water management organizations have been seriously weakened during the past few years. The Republic depends on these organizations and their staff for protection and management of this vital resource. Decreased size and improved efficiency of public sector organizations are legitimate aims during this stage of the transition, but the loss of highly trained staff and inoperable and out-of-date equipment may leave these organizations permanently crippled, with direct health and economic consequences as water management and water supply deteriorates.

B. LAND

3.13 This section looks at some of the causes for the low productivity of land in the context of crop production, livestock management, and forestry, and describes briefly the high potential benefits from biodiversity conservation in Kyrgyzstan.

3.14 Low crop yields. Kyrgyzstan's principal crops are cereals, maize, and cotton. The main crop production regions are the Fergana Valley in Osh and Djalal-Abad Oblasts, in the Chu and Talas valleys, and in the Issyk-Kul basin. Crop production contributes 40 percent of the gross value of agricultural output (livestock contributes 60 percent), and in 1990, about half of the total value of exports came from the agricultural sector. Agricultural policy has been directed towards self-sufficiency in cereals for food security, with a number of supporting regulations, such as compulsory marketing, and centralized farm management.

4/ IdentifiedOKZ is defined as acute enteritis, colitis, gastro-enteritisand rotavirus infectionscaused by identifiedfactors. UnidentifiedOKZ is defined by unidentifiedgastro-intestinal infections and unidentifiedtoxic food infections. National Environment Action Plan: 12 Priorities for Action 1995-97

3.15 The ovenvhelming problem with regard to crop production in Kyrgyzstan is one of economics. Inappropriate policies and regulations, bureaucratic hindrances and slow structural reforms (particularly land redistribution), in combination with inflation, delayed payments to crop producers, and absence of credit facilities, are the main reasons for the problems in the agricultural sector. As a result, many farmers turn away from commercial production to food crops for subsistence. This is evident from the decline in marketed and processed output, which is much greater than the fall in primary agricultural production.

3.16 Agriculture productivity is presently Figure 1.6: Use of Agro-chemicals per year constrainied primarily by the lack of an in the Kyrgyz Republic adequate water supply to the irrigated lands (tons) and sufficient nutrients to achieve reasonable harvests. Compared to Western countries, use of agro-chemicals is low and has declined 733 significantly over the last decade (Figure 700 6139 1.6). The application rates of fertilizers are 10 s to 20 percent of the rates in Western 5x 43* 4530 countries. Average use of pesticides is less than 50% of application rates in the West. 4000 3479 Increased agricultural inputs would enhance 300 23 the productivity of crop production. 20 Increased use of inputs must proceed with l iii caution, however, to avoid water pollution low associated with the improper handling and o storage of agro-chemicals--which is already a 1980 1981 1985 199 1991 1992 1993 problem in some areas.

3.17 On-site soil erosion and salinization of improperly irrigated lands are the key long-term environrmentalconcerns related to landuse. About 60 percent of the arable lands are affected by topsoil loss and 6 percent by salinization. Compared to the lack of adequate water and nutrients, soil erosion and salinization have less immediate impact on production levels. They are the product of improper water supply management and cropping practices, however, and if not addressed these problems will have profound long-term effects on the productivity of the land.

3.18 It is important to emphasize that sound economic policies in agriculture will initially have a greater impact in addressing rural environmental problems than specific environmental measures. This is because environmental problems in rural areas stem to a large extent from a reaction of farmers and livestock holders to the prevailing economic insecurity and to poverty.

3.19 Decreasing productivity of rangelands. The size of Kyrgyzstan's herds have dropped dramatically since independence. Nevertheless, they are still at levels which are twice the estimated carrying capacity of Kyrgyzstan's grasslands, and soil erosion and reduced productivity affects 60 percent of the pastures. Most of the livestock has been moved from collective and state ownership to the private sector and grazing pressure has increased on lands around settlements. With land tenure uncertain and monetary instruments weak, many people are keeping their assets in their herds--a traditional source of wealth and security.

3.20 The implementation of economic reform policies, such as price liberalization and land tenure assignment, should encourage more sustainable livestock management. Overall herd size is already shrinking as a result of the changing economic situation. Flock structure is changing, and more seasonal lambs are being sold for meat export. In addition, livestock grazing patterns can be more carefully NationalEnvironment Action Plan: 13 Prioritiesfor Action1995-97 managed. For example, depending on the life cycle of the particular fodder species, animals can be concentratedon smallplots of land for short periods and frequentlyrotated--resulting in a less destructive feeding pattern.

3.21 Disappearingforests. Forests cover Figure 1.7: Land Use Categoriesin the Kyrgyz Republic about 4 percent of the country, or 7 percent of the manageable land area (Figure 1.7). The Forest Department, under the State Committee for EnvironmentalProtection, is responsiblefor the managementof 15 percent FoeSt (0 8) of the territory. Map 3 (IBRD #26688) illustrates the lands under the administration of the Forest Department. At the local level, _ 9 the Forest Department is represented by 32 Z., 45% Leskhozes ("forestry farms''), managing 95 percent of the state forest land. These lands are not subject to privatization. Leskhozes are productive entities and are involved in CsnM (14) collecting, processing, and marketing fruit, 7% honey, lumber, furniture, firewood, livestock and crops. About 55 percent of their land is leased out by regional and national authorities as rangelands to herding groups from both Kyrgyzstanand neighboringrepublics. These leases are currently being restructured or reclaimed. The leskhoz budgets are channelled through the Oblast and local authorities. These authoritiesmay reallocatefunds at their discretion,which has resulted in budget cuts of up to 70 percent for some of the leskhozes, as local government priorities are often not focussed on forestry. Curtailed funds mean that forest management activities are minimized, and enforcement capability against illegal cutting and grazing is very weak. In addition, processing and marketing forest products are hamperedby the lack of short term credit facilities.

3.22 Biodiversityat risk. Map 4 (IBRD#26687) shows the major categoriesof protectedareas. They are widely dispersed, with no connecting corridors. Wildlife numbers are decreasing rapidly from intensive hunting, and habitat fragmentationand destruction.

3.23 Kyrgyzstan has good prospects for tourism development, due to its great scenic beauty. Adventure tourism such as mountaineering,trekking, and horsebackriding have the greatest immediate potential. Wildlife resources are key elements of these attractions and tourism revenues may be used in part to support conservation goals. Map 4 also includes cultural heritage sites which may be of interest to tourists. These sites are frequently adjacent to protected areas or leskhoz lands. Infrastructure, facilities and services are currently lacking, however, and widespreadhunting and poaching have made wildlife very wary and difficult to observe and enjoy. Lack of finances for the protected areas and pressure from grazing, hunting and firewood collection contribute to the management problems. There is a need to prepare a National BiodiversityConservation Strategy which integrates conservationwith developmentand other institutionalgoals in a cost-effectivemanner. Internationalresources should be coordinatedto assist in this effort. Ratifyinginternational conventions would facilitatethis process. The long-termbenefits will be substantial.

3.24 Degradedwatersheds. Due to the seismic activity of the country, steep slopes, and unstructured fragile soils, the land is naturallyvery susceptibleto soil erosion. The situation is aggravatedby human activities, mainly through inappropriate livestock managementand the loss of a protective vegetative National EnvironmentAction Plan: 14 Priorities for Action 1995-97 cover. Land slides, mud flows and gullies are ubiquitous in the landscape, causing damage to infrastructure and endangering human life. There is clear evidence that irrigation systems and reservoirs are silting up, causing drainage problems and loss of storage capacity. The extent to which hydropower reservoirs are silting-in and losing storage capacity is unknown, but judging by the amount of soil erosion in the upper catchments, downstream sedimentation must be high. In addition, the water storage capacity of the soils is low, and streams and rivers have extreme seasonal variations in flow, resulting in destructive floods and water shortages.

3.25 Conclusions. Improving the productivity of land in the broadest sense will depend on sound economic policies, and well defined land use management. These, and other measures to improve the income of rural populations will go a long way toward addressing some of the most pressing environmental problems in rural areas. At the same time, a forward looking strategy will include modest measures to ensure a sound biodiversity strategy.

C. ENVIRONMENTAL CONCERNS RELATED TO THE MINING AND METALLURGY INDUSTRY

3.26 The mining and metallurgy (M&M) sector is commonly associated with significant environmental problems. Inadequate information is available, however, to proceed with measures other than information collection and establishing a sound regulatory and enforcement framework. Environmental investments in the sector risk being very expensive, and the country cannot afford to make inefficient investments which do not achieve tangible environmental improvements at least cost.

3.27 The mining and metallurgical sector is facing serious financial and market-related problems, not least because of the rapid increase in energy prices (the cost of energy is often more than 50% of the cost of production). Many skilled technicians and managers departed after independence.

3.28 The mining and metallurgy sector accounted for 10 percent of industrial production and 11 percent of the workforce in 1992. The minerals produced include antimony and antimony oxides, mercury, gold, uranium oxide, minor rare earths (lanthanum, cerium, dysprosium, erbium, gadolium, holmium, etc.), molybdenum and calcium fluoride. A mine and processing plant for tin and tungsten is currently under construction. In the past the sector was oriented primarily toward the traditional markets of the FSU and thus is now heavily affected by the collapse of these markets. The future world markets for the Republic's mineral resources are either modest (gold, antimony and mercury) or not promising (uranium, rare earths, tin/tungsten and molybdenum).

3.29 Gold production is the only sector which is attracting notable interest on the part of foreign investors. The development of two commercial gold deposits in joint venture with foreign companies is being in progress (one of them, in Kutmur, is co-financed by the IFC), and further exploration for bulk deposits is likely. It will be critical that the development of these gold deposits be carried out in the context of sound environmental policies, including environmental impact assessments which meet international standards.

Exposureto toxics

3.30 There are a number of areas, usually associatedwith active or closed mines or processingplants, which are identified by Kyrgyzaltinas sites of particular environmentalsignificance due to abandoned mine workings, tailings deposits, waste dumps or impoundments. Map 5 (IBRD #26619) (Mining Hot Spots and Mining Areas) identifiesthe major locations of concern. Monitoring at all of these sites has been limited due to lack of resources, and the state of containmentof potential toxins is unclear in a number of instances. National EnvironmentAction Plan: 15 Priorities for Action 1995-97

3.31 Mercury and antimony. The surface antimony mine in Kadamzhay and the deep shaft mercury mine in Haidarkan are both located in the middle of settlements of approximately 12,000 inhabitants each. There are no sanitary or safety zones separating housing from the mines and tests in housing areas indicates residents are exposed to antimony and mercury vapors. Although the reliability of the data is unclear, the morbidity rates in the exposed settlements appear to be very high, and it is thought that the non-mining population is exposed to unacceptable health risks.

3.32 The mercury mine in Haidarkan is scheduled to be closed and production shifted from mercury to other heavy metals. Soil pollution will remain, however. Consequently, a monitoring program is urgently needed to determine the extent and impact of residents' exposure to on- and off-site pollution. The need for major measures cannot be ruled out, such as relocating inhabitants from the contaminated area.

3.33 Radiation. Under the Soviet Union, uranium was a critical strategic asset and in high demand. Since independence, uranium mining operations have ceased, while uranium oxides processing at Kara- Balta continues using imported concentrates. Sites such as the facilities at Kara-Balta and some former uranium tailings dumps have been called by local experts "clear and present dangers to the health and safety of numbers of people". For many combinats, mines and waste dumps, however, information is not available on the environmental conditions within and around the sites. The lack of data makes any statement about conditions at the sites controversial. The absence of environmental oversight, however, also makes the existence of hazardous conditions likely. In addition, there is concern for exposure to radiation from nuclear testing in China.

3.34 Due to the lack of monitoring, there is no conclusive evidence of radon pollution from natural sources, although the nature of the substrate makes the existence of radon emissions a possibility. There is sufficient evidence, however, of the need for general health-oriented monitoring of radiation, particularly in areas surrounding dumps related to uranium mining and processing, at the sites of former accidents, and from contaminated materials, such as old equipment and uranium-containing coal used for fuel.

D. Ait

3.35 Increased pollutionfrom coal. Air pollution problems are dominated by the growing shift from gas to coal for power and heat, especially in the major urban areas. The shift is a consequence of the rapidly rising prices for natural gas which has to be imported at close to market rates. The Kyrgyz Republic has abundant supplies of coal that is low in sulfur but causes harmful emissions of particulates and coal ash, which are a problem in the largest cities. Like other fuels, the price of coal is also rising, due to increases in the cost of freight and the physical difficulty of transporting coal within the country. Because of these difficulties, coal burned in the north is primarily imported from Kazakhstan. Industrial air pollution has significantly declined because of the rise in fuel prices and the large contractions in the economy. Until industrial restructuring has progressed further, however, it is difficult to predict future trends.

3.36 In rural areas without central heating and power plants, heating is provided by coal, wood, and manure/straw fuels. Rural communities are gradually installing additional transformer capacity (both with and without government financial assistance) to enable conversion to electric space and water heating and electric cooking. Electricity consumption in the rural households is increasing; however, most of the poor rely on wood and nanure/strawfuels. The shift in fuel supply toward more reliance on fuel wood creates even greater environmental pressure on the few remaining forests. NationalEnvironment Action Plan: 16 Prioritiesfor Action1995-97

3.37 Air pollution in Bishkek. Air pollutants accumulatein the lower levels of the atmosphereover the city of Bishkekdue to its climate,geographical position and meteorologicalconditions. Seventy-eight percent of the pollutants are emitted by the municipalpower plants. In addition, there are also over 270 relativelysmall industrial, municipaland transport enterprises within the municipalarea whichhave both routine and sporadic atmosphericemissions. There are no large industrialpolluters such as oil refineries or metallurgicalplants, however. Private transport contributesto air pollution, as well, but its share is probably declining due to the sharply rising price of fuel.

3.38 Conclusions. The largest air pollutionreduction benefits can be achievedthrough the installation and/or correctuse of dust filters (electro-staticprecipitators) in the major power and central heatingplants in Bishkek and Osh. This is a relatively inexpensivemeasure that can bring about significant benefits to human health. In addition, systematic maintenanceof the large public bus fleet will go a long way toward reducing the most harmful emissionsfrom vehicles. National Environment Action Plan: 17 Priorities for Action 1995-97

4. FRAMEWORK FOR ACTION

A. ADDRESSINGPRIORITY PROBLEMS

Water supply systems at risk

4.1 The health and economic well-being of the Kyrgyz population depends critically on a well functioning water supply and water management infrastructure. Failure to ensure sound maintenance of the already deteriorating system will cause significant long-term costs both to individuals and to the economy as a whole. There is no need for massive investments in sophisticated technology to reverse the process of deterioration -- rather, the emphasis should be placed on the gradual introduction of new institutional arrangements, on halting the exodus of skilled people from public sector organizations, and on simple, well known, and low cost investments in the impressive water management and sanitation infrastructure that already exists in the country. In addition, a modest program is justified to expand these services to vulnerable groups.

4.2 Policy response. Water supply and waste water operations by the Urban Municipal Services (KJKS) are financed through water tariffs and fees paid by its clients for services. In the case of households, water charges are paid as part of a lump sum charge paid to the local communal department for municipal services. Domestic tariffs for water and sewer services are established by local authorities based on the accounts of the local unit of KJKS which are regulated by the State Committee on Prices, which unfortunately do not allow the cost of maintenance of existing facilities to be included in the rate base. At present tariffs cover between 50 and 100 percent of real operating expenses.

4.3 Tariffs negotiated with industrial enterprises include the underpayment by domestic and municipal consumers which results in a significant cross subsidy by industry to these other consumers. The central government, which formerly subsidized services and construction of new facilities, provided 1 million soms in 1994 for construction, but no operating subsidies. Arrears are currently very large--(more than 12,000,000 soms) and growing. It is estimated, however, that if current tariffs reflected the full cost of operation and maintenance, few household could afford to pay the water charges.

4.4 A new water law was passed by the Supreme Soviet in the fall of 1994. The new law strengthens the legal basis for water management and the regulation of both water quality and water use, but the provision to begin the gradual recovery of state costs for infrastructure construction, operation, and maintenance costs was eliminated for agriculture and forestry water uses. At present therefore, the Ministry of Water Economy (MOWE) has no means to assess water charges to recover even part of its costs, and no means to reorganize irrigation to decentralize responsibility for routine maintenance activities to the farmers or other local irrigation organizations such as water use associations or farmer- owned irrigation districts.

4.5 In order to ensure the long-term financial sustainability of the country's water management program, the overriding policy issue is therefore to establish sound mechanisms for mobilizing local funds to finance essential infrastructure operation and maintenance services for domestic, industrial, and irrigation water supply. Even before it is possible to resolve the many difficult questions regarding local government organization and finance, immediate measures need to be identified to mobilize funds for rehabilitation and essential maintenance and operations including the purchase of chemicals. Essential steps in municipal water supply and in irrigation will be (i) gradual increase in domestic and industrial tariffs, and (ii) introduction of water charges for irrigation water users. National Environment Action Plan: 18 Priorities for Action 1995-97

4.6 Technical assistance needs. Donor financing could be sought for essential technical assistance needs which might include:

(i) Assistance in developing municipal and Oblast governance and financial reforms;

(ii) Assistance in strengthening health assessments at the Oblast and Rayon levels, including strengthening local units of Sanepid, Goskompriroda, Goskomgeol, and MOWE monitoring capability and related joint information systems;

(iii) Assessment of rehabilitation and modernization needs for irrigation water distribution, and preparation of studies and proposals to gradually reform irrigation water pricing and increase cost recovery;

(iv) Development of cost management programs for the maintenance of municipal and irrigation services; and

(v) A wide range of training and capacity building activities at the Oblast, Rayon, and municipal levels including, for example, introduction of modern financial management systems such as accounting procedures at the municipal level.

4.7 Financing. Modest amounts of expenditures are recommended to address the highest priority problems of water supply contamination, the most vulnerable water sources, and those population groups most affected in terms of health risks and/or poverty. Interventions could include completion of projects; rehabilitation, repair or replacement of facilities that are not working properly, including pump stations, wells, pipe networks and mains, intakes, reservoirs and storage tanks; treatment works including disinfection equipment, sewers and private sanitation facilities; and purchase of spares and chemicals. Priorities should be based on an assessment of the following factors:

(i) Health. The extent to which the proposed project reduces health risks, based on direct measurement of the incidence of water borne diseases, child morbidity and mortality. Decisions can also be based on consistent detection of high risk factors including contamination with bacteria, nitrates, or other factors which can be shown to represent a high health risk under current conditions at the specific location.

(ii) Productivity. The economic impact of the problem or the intervention in terms of its impact on agricultural income, reductions in the cost of water, and the effects on local employment (particularly the potential intensive use of local labor).

(iii) Equity. The use of low-cost measures using local materials and private businesses and contractors, and the impact on areas with especially low income.

(iv) Technical and Financial Factors. Proposed projects should demonstrate that they are based on a least-cost approach with respect to investment, operation, and maintenance; can be implemented quickly with existing technology and available materials; and are capable of being phased over time.

4.8 An inter-ministerial or multi-agency team should form an emergency working committee to evaluate and select proposals from the concerned agencies and local units of government. The Working Committee, possibly with foreign technical assistance, could issue guidelines for identification and preparation of project proposals, develop, describe, and issue criteria for project evaluation and selection, visit project sites, and compile and possibly collect data on which to base the evaluation of sub-projects. National EnvironmentAction Plan: 19 Priorities for Action 1995-97

The guidelines would include well defined procedures for the preparation of feasibility studies, including a standardized, and simplified report format.

4.9 Pilot and demonstration projects. To deal with the most urgent problems, and to demonstrate immediate action at the local level, a number of pilot and demonstration projects should be considered which demonstrate new approaches, materials, and techniques, and have immediate local benefits.

(i) Low cost sanitation demonstration projects, such as the introduction of new latrine and septic tank design and construction methods, which emphasize opportunities for income generation (construction of slabs, latrine construction, etc.) and community participation.

(ii) Improved operation and performance of existing waste water treatment plants; introduction and pilot testing of lower cost (investment, operation, and maintenance) treatment systems for small towns and villages with piped water and sewer service.

4.10 Consideration should also be given to supporting a village grant and/or credit program to support essential works and income generating activities.

4.11 Longer-termn water supply requirements. At this time, additional water resources should be sought through savings and efficiency improvements in irrigation water use, since industrial and domestic water use is only 10 percent of total water use in the Republic. Investment in additional and new sources of water supply for these latter water uses should be made only after water wastage and inefficiencies are eliminated. This approach is likely to prove far less costly.5 For example, for Bishkek there are plans to expand or supplement the existing sources over the next 10-20 years. A major new field has been identified -- Issik-Atainskoe -- with a capacity nearly equal to the two existing fields. Development of this new field would avoid the growing problems of managing the pollution of the existing aquifers, but at considerable expense. The intrusion of contaminated water into the deeper portions of the existing aquifers should be prevented, and greater efforts made to prevent pollution from industrial, municipal, irrigation, and livestock sources.

4.12 Greater use of the shallower, sometimes polluted ground water for so-called technical or non- potable uses for which it is suitable would also ease the pressure on aquifers and conserve the high quality water for drinking purposes (about 130,000 m3/day are already withdrawn for these uses in Bishkek).

4.13 Institutional strengthening. The capability of government agencies and other institutions to systematically assess priorities is crucial to ensure effective actions with very limited resources. The process for priority setting, planning and capital budgeting can be improved by strengthening the processes and linkages among different agencies to ensure the flow of timely health and economic impact data. The extreme limitations on financing needed for rehabilitation, repairs, and particularly extensions of service into new areas, requires rigorous attention to priority-setting based on the relative impact of improvements on health and the local economy. This type of benefit-cost-analysis requires good quality and timely data on such things as the results of sanitary inspections, tap and water quality data, health statistics, flow distribution data, water shortages and outages, and economic data on production in irrigated areas.

5/ In areas where street and yard standpipesare the predominantmode of water service, water use will tend to be quite low in per capita terms, but there could still be substantialwaste where fittings and fixtures are in poor condition. NationalEnvironment Action Plan: 20 Prioritiesfor Action 1995-97

4.14 Furthermore, the government must make every effort to ensure that the key water management organizations in the public sector are fully functional and that key technical people remain with these organizations. The tremendous restructuring that these organization have already undergone was necessary in part, but the government should take urgent steps to ensure that these economically vital organizations are not crippled.

4.15 Data and monitoring requirements. There have been reports of significant loss of reservoir storage capacity due to sedimentation in the 15 major and 24 smaller reservoirs. While the detrimental effects of deforestation and erosion caused by inappropriate grazing practices and construction of roads and other infrastructure are evident in many watersheds of the Republic, there appears to be little or no systematic data on sediment transport in the streams and rivers where this might be a significant problem, and no data on rates of reservoir sedimentation and its economic consequences. Since the effects of stream and reservoir siltation are long-term and costly problems to rectify, more systematic monitoring and diagnostic analysis of this problem, and implementation of low-cost preventive measures, should receive priority attention. Maintaining water storage capacity is vital for Kyrgyzstan not only as a source of hydro-power but especially to guarantee adequate water supplies for irrigation during the summer months when water flows are often low and unreliable.

4.16 During the last few years, monitoring capacity has dramatically deteriorated due to a sharp decrease in financing. Lack of basic chemicals, spare parts, glassware, supplies, lack of cars and gasoline, etc. have also contributed to the deterioration of the quality of results. As described above, the types and amounts of future investment depend critically on sound information on water quantity and quality in selected parts of the country. In this regard, the capabilities of the major institution active in this area -- Hydromet -- should not be left to deteriorate any further. Small expenditures on reliable monitoring can prevent wrong and potentially very costly investment decisions.

Low productivity of land and forest resources

4.17 Agricultural policy reform. During the privatization and transformation process in agriculture, efforts should focus on changes in policies including land tenure, payments to producers, and agricultural credit. These will contribute most toward increasing crop yields in the longer term. In the longer run, farmers should be given information and supported in their efforts to reduce soil erosion through reduced tillage, mulching, contour ploughing, strip cropping, improved irrigation and better storage and handling of agro-chemicals.

4.18 Support to the forestry farms (leskhozes). Modest investments in leskhozes are warranted at this time, however, as the leskhozes are not undergoing restructuring or privatization and could contribute significantly toward environmental improvements in rural areas. At present, the leskhozes are suffering radical budget cuts of up to 70 percent. A program to support tree planting would be sensible, given the multiple benefits of such a program: there is an urgent need for local construction wood (tree poles) and for firewood in rural areas. Increasing the tree cover would also reduce soil erosion, land slides and mud flows in the fragile upper catchments, moderate streamflows and provide habitat for wildlife.

4.19 In addition, support to forest-related activities provides employment opportunities in rural areas which are particularly important at this time when the job situation in agriculture and industry is very uncertain. Tree-planting is labor intensive, as are the collection, processing and marketing of non-wood forest products, particularly fruits, nuts and honey. It is highly desirable to provide short-term financial credit for these kinds of activities, which encourage a sustainable rural economy.

4.20 In the longer run, the Forest Department (which has recently been integrated in the State Commnitteefor Environmental Protection) needs to develop a consistent forest policy, combining production withprotection objectives. The present forest policy emphasizes the protective role of forests, National Environment Action Plan: 21 Priorities for Action 1995-97 and most activities -- including the afforestation program -- are focused on this issue. On the other hand, there is an urgent need to meet the growing demand for wood. If this demand is not at least partially met, illegal cutting of trees for firewood and construction will accelerate and further increase the pressure on natural forests. A first step in developing new directions in forestry would be to set up a good data base, providing information on standing stock, growth rates, production and consumption.

4.21 Improved livestock management. To reduce the degradation of pasture land, the numbers of livestock will need to be reduced over the next five years, and an effective landuse planning system based on land capability needs to be developed. Because semi-nomadic grazing is an important part of Kyrgyz history and culture, such a change will be met initially with considerable resistance. Appropriate land tenure is essential: secure grazing rights encourage local enforcement of stocking limits and sustainable management of the grasslands. The information needed to determine carrying capacity is readily available from the Institute of Land Use and Utilization (Geprozem). Introduction of grazing management practices such as no-grazing zones and rotational grazing could be part of such a plan.

4.22 Part of the solution to reduce the number of livestock also lies in changing the flock structure from meat and wool production using ewes and wethers, to a flock oriented toward seasonal prime lamb and higher quality wool production. A growing market for lamb exists in the Middle East and could be further developed. Currently, lamb is being sold to Iranian buyers. Meat products can only be sold on hard currency export markets, however, if industry standards are thoroughly upgraded and enforced. At present, no Kyrgyz enterprise could meet the standards of the European Union or the United States Department of Agriculture. The removal of export taxes and barriers provides one incentive to achieve such standards. Provision of credit to private enterprises for purchase of self-contained mobile abattoirs would further promote industry competitiveness.

4.23 Biodiversity conservation. The country has a high diversity in habitats and species and is of outstanding scenic beauty, particularly the Tien Shan mountains which are second only to the Himalayas. Adventure tourism has great potential, but services and infrastructure are inadequate. Biodiversity conservation is severely constrained by a small and fragmented protected areas network, hunting, poaching and by a general lack of public awareness.

4.24 Low-cost efforts in biodiversity conservation could have important payoffs in the future. This is a good time to prepare a longer-term national biodiversity strategy and secure an enlarged protected area network not only to stop the major loss of habitat and reduction in the number of (endangered) species, but also to improve catchment protection and to attract international tourism which can be an important source of foreign exchange earnings. This is an area suitable for international donor support.

4.25 As part of developing a national biodiversity strategy, the hunting licensing system should be reviewed and hunting areas reduced. The species that are hunted should be re-assessed on the basis of an inventory of hunted species. Over time, a reduction in hunting activity will make rare animals less shy and therefore more accessible to tourists who visit Kyrgyzstan to see its natural beauty. This change will take time, however, as local livestock holders view wild animals such as wild goats or wolves as competing with, or endangering, their herds. If national parks or reserves are to serve their intended purpose, much greater effort will be required to involve local people in park management and decisions affecting their livelihoods.

4.26 Information forfuture decision making. Information on soil erosion and its effects is scattered in different agencies and not readily available for making informed decisions. A coherent policy to deal with land degradation would benefit greatly from a country-wide assessment of the status of watersheds, including the degree of soil erosion and the occurrence of, and susceptibility to, mud flows and land slides. At the same time, a program to monitor river siltation and sedimentation of reservoirs will provide a basis for deciding how to prioritize the erosion problems among different watersheds. National EnvironmentAction Plan: 22 Priorities for Action 1995-97

Health damages

4.27 Low-cost sanitation measures. The major public health problems are indirectly related to environmental causes. The main concerns are waterborne diseases such as Hepatitis A and diarrheal diseases. The main causes in rural areas are related to poor sanitationand open water supplies. There are virtually no public funds budgeted for sanitation, althoughsanitation is a major public concern.

4.28 Government officials often think of improved sanitation in terms of sewer connections and biological wastewater treatment which are very expensive for individualhouseholds and communities. Low-cost alternativescould significantlyreduce health risks. Both international and local resources shouldbe appliedto install low-costbut effectivelatrine technologies. In addition, poverty plays a large role in rural health status. Projects which promote the constructionof improved latrines with local buildingmaterials and local labor will have a three-foldeffect -- improvingthe environment,the health status of the populationand the economiccondition of the poorest members of society.

4.29 Publicawareness campaign. A well-targetedpublic informationcampaign and appropriateschool curriculaemphasizing the virtues of basic sanitationprinciples and food hygieneare likely to bring about significanthuman health improvements,especially in rural areas.

4.30 Land use controls. Public health will also be enhancedby ensuringthat water supply sources are strictlyprotected. Land-use restrictionsmust be strictly enforced around water sources.

4.31 Reducing dust emissions. Air pollution(other than inside homes and factories)affects the health of urban populationsin Bishkek and to a smaller extent in Osh, especiallyduring the winter when dust emissions from the major power and heating plants may be trapped near to the ground as a result of atmosphericconditions. The highestpriority is to maintainand properly operate existingdust collectors as well as to upgrade equipmentwhere it is needed. Experiencein many countriesshows that the benefits of controllingdust emissions tend to significantlyexceed the costs.

4.32 How criticalis the health damagefrom mine wastesat the three largestcombinats? Information on priority areas for cleanup of mine wastes is still inconsistentand incomplete. A number of studies of potential health hazards from mine wastes at Haidarkan, Kadamjaiand Orlovsky are underway and should be completed. Until there are reliable health analyses of the rminewaste areas, significant expendituresshould be avoided on cleanup or even on (pre)feasibilitystudies because of the risk of wasting large amounts of money on unnecessarywork.

Using donor resourcesmore effectively and mobilizingadditional extemal resources

4.33 Coordinatingactvities. One of the objectivesof the NEAP Office is to help coordinatedemand and supply of donor assistance. The interests of the various actors are not always congruent, and it is importantthat the Kyrgyz Governmentretain oversightand control over the many differentactivities, and avoid overlap (both in internal requests, and in external commitments). A first step is to prepare a detailed list of donor activitieswith a particular emphasis on environment-relatedwork (the Box below provides an initial and incomplete listing). This list will only retain its value, however, if it is continuously updated. Over time, the goal is to efficiently extract the maximum benefit from internationalassistance, to ensure that it dovetails with national programs, and to avoid overlaps and duplication. This is also an opportunityto identifynew potentialsources of funds, and to prevent scarce grant resources from being used for low-priority activitiesthat are not part of the Action Plan. National Enviromment Action Plan: 23 Priorities for Action 1995-97

Initial Survey of International Assistance Activities for Environment

Gennany (German Association for Technical Cooperation, GTZ, and NABU, a Gennan NGO): Proposed the establishment of a Man And Biosphere (MAB) reserve (UNESCO) for the entire catchment of Lake Issyk Kul and the Eastern Tien Shan mountains. NABU is conducting research in the area, financed by GTZ. GTZ is also supporting a pilot program in water quality monitoring in the Chu valley.

Japan: Supply of agro-chemicals.

The Netherlands: Supply of agro-chemicals and technical assistance for environmental improvements in Bishkek public transport, a coordinated monitoring system, industrial waste minimization, and NG0s.

Switzerland: Funds and technical assistance for forestry projects, beginning in 1995. Five projects have been proposed: development of a forest information system; forest management in the (northern) spruce area; forest managementand silviculture in the (southern)walnut area; afforestation; and training of technical fotest staff. Switzerland is also providing support for the NEAP Office.

United States Agency for International Development (US-AID): Technical assistance support for water resource management.

European Union (EU): The EU intends to support environmental institution building. At present, the Union is supporting a pre-feasibility study to review options for cleaning up the Minkush mine site.

Asian Development Bank (ADB): ADB is planning to provide assistance for environmental regulatory reform and for setting environmental standards. Additional support would also be provided for capacity developmnent in Goskon;pfiroda.

European Bank forReconstruction andDevelopment (EBRD): The EBRD ispreparing aproject tosupport the public and emerging private sectors in developing tourism. The EBRD tourism project has two objectives: (i) to promote the Kyrgyz Republic as an ecotourism destination while assuring their protection; and (ii) to promote local culture and protect the national heritage by reviving and marketing handicrafts. The project will support private enterprise development such as small hotels, rest camps, tour operators, travel agencies, guides, park wardens, and vendors.

Global Environment Facility (GEF): Likely to support a regional biodiversity project involving Kyrgyzstan, Kazakhstan, and Uzbekistan.

International Atomic Energy Agency IAEA): Interested in supporting monitoring of Uranium tailings.

United Nations Development Prgramme (UNDP): UNDP Is likely to help organize a seminar on institutional capacity building for envirommentalmanagement.

World Bank/IDA: Through its policy lending operations, the World Bank and IDA have been supporting proper pricing of exhaustible resources to promote conservation and reduce environmental degradation. Assistance for the agriculturalsector also addresses the issueofland degradation. Sectoral reviews in Mining and Energy have identified environmental concerns and proposed steps to deal with them. The Bank is supporting the preparation of the Kyrgyz NEAP and will work with the Government to determine specific areas of assistance. National Environment Action Plan: 24 Priorities for Action 1995-97

The Aral Sea Program: a Case of Successful Coordination

Five riparian states share the Aral Sea Basin, an area of 690O kekm 2 . They are the Kyrgyz Republic, Kazakhstan,Tajikistan, Turkmenistan,and Uzbekistan. The Aral Sea itself lies between szakbstanand Uzbekistan. Twokey riversdrain into the sea: the and AmuDarya Rivers;the moFuntains of Kyrgyzstanare the sourceof headwatersfor both rivers. In 1960, the Aral Sea wasthe fourth largest lakecinthe World. Sincethen, it has shrunkto half its size becauseof the near tota}ldiversionof in- flowingwater for irrigation.iLavish use of agriculturalchemicals has degradedwater qWity, and industrial and municipalpollution further aggravates the situation.The fishingindustry is destroyed;wetlands are now desert; biodiversityis decimated;and wind blowssalts and pesticidesfrom the exposedsea bed over crops and people. According.to a 1992UNDP study, the destructionof the AralSea is one of the moststaggering disastersof the twentiethcentury.

In rresponseto the severeenvironmental crisis in the Aral Sea Basin,the five riparianstates are jointly developinga regionalstrategy to savethe Sea. TheWorld Bank, UNDPand UNEP,:inacollaWration with bilateraldonors, have respondedto requestsfor assistancewith the Aral Sea Program,which has four majorobjectives: (i) stabilizethe environmentof the Sea; (ii) rehabilitatethe lands around the Sea; (iii) developjoint managementof transboundarywaters; and (iv)build regional institutions to realizethese goals. Thefirst phase of theProgram, which is jointly funded by thecountries and externaldonors, focuses on mneetingthe inrmediateneeds of the regionand developingprojects which advancethe four objectives. In addition,the programwill assist the riparianistates in adoptingnational macroeconomicand sectoral policieswhich support sustainable land, waterand other naturalresource development. Phase One has seven programsor areas of focus:

1. Preparationof a regionalwater resourcemanagement strategy; 2. Developmentof a regionalenvironmental monitoring system4which tracks water availability anidconsumption; 3. Reductionof agricultural,industrial and municipalwater pollution; 4. Researchand selectionof engineeringoptions for environmentalrestoration projects; 5. iDesignand implementationof regionalpublic educatio programson environmentand health; 6. Integratedland and water managementin the upperwatersheds;; and 7. Institutionalcapacity building for regionalenvironmental management.

... Program 6 (integratedupper watershedmanagement) is particularlyimportant to the Kyrgyz Republic, Improvedwatershed managemnent is a governmentalpriorty, and specific ns to this end are identifiedin the NationalEnvironmental Action Plan (NEAP). It istinportant to note that Athecountry is neithera major drainnor majorpolluter of the Mal Sea. In compliancewith inter-republic water allocion agreements,Kyrgyzstan uses only about4 % of the total flowof the and Syr Darya Rivers. It o produc lessthan onepercent of the.cotton and alfalfa(major water consumers) grown in theregion. Nevertheless,upstreami activities in the Republicsignificantly impact environmental conditions and activities downstream.Eroslonrdue to deforestationand overgrazingis severe,altering waterregines and degrading waterquality. Poorlyplanned and managedirrigation systems loseIor contaminate many thusands of cuic imetersof water. Mining,industrial and municipalpollution also flows.intothe Basin. Theintiative taken by the Government:to addremthese problemsthrough the preparationof the NEAPcomplements the Aral Sea Program andprovides leadeship in the regionon environmental policy.

ii.0;. 0A numberof other programsand projectsdeal withissues identifid in thWeNEAP, such as programs 1l. and 3f.1on Water ManagementandVWater Quality Strategies;programs 1.2 aIdS1.3 on Iprvn Efficiencyandi Operation of Dams and on SustWinabilityof Dams and Reservoirs;and program2.1 on flydrometServices. NationalEnvironment Action Plan: 25 Prioritiesfor Action1995-97

Strengthening the environmental institutions

4.34 The success of the NEAP will dependon the capacity of the environmentalinstitutions to develop and enforce proper environmentalregulations. Under the overall responsibility of Goskomprirodaa formal coordinationmechanism amongthe agencieswith environmentalmonitoring and control functions should be establishedat national and at oblast levels. Goskomprirodashould develop a realistic and enforceablesystem of standards and regulations. Since the most important environmentalproblems are local in nature and environmentalpriorities vary from oblast to oblast, gradual decentralizationof the environmentalmanagement should be carried out. In the shot term this process shouldbe initiated with strengtheningthe oblast branches of Goskompriroda. Over time they should be authorized to develop regional environmnentalstrategies, set specific targets for environmental improvements and develop complianceschedules for the main polluters.

4.35 A number of activities have been identified as being of high priority to establish a basis for making sound environmentalmanagement decisions in the future. These include the following:

4.36 Developingthe capability to carry out EnvironmentalImpact Assessment (EIA) according to internationalstandards. InternationalETA training in combinationwith a full EIA of the two new gold mines accordingto internationalstandards should help ensure that new mining activitiesin particular will meet all necessary environmentalrequirements. On-the-jobtraining could be carried out in addition to internationalexchanges. A similar approachcould also be appliedtoward a systematicevaluation of dam safety. In the long run, the capabilityto carry out sound EnvironmentalImpact Assessmentsshould help prepare for eventual constructionof new industries and possible expansion of hydroelectric facilities. These are inexpensiveactivities which can avoid significant future environmentaldamage and related economic costs. Training should start now before economic activity picks up.

4.37 Developingthe capabilityto carry out efficiencyand environmentaudits in selected industries and mining enterprises. Again, the most effectiveapproach involves on-the-jobtraining in the highest priority industries that are likely to be restructured, e.g., cement, electroplating, slaughter houses, textiles. This work shouldhelp identifylow-cost efficiency improvements in the most polluting industries that are likely to continue operatingduring the next 3-5 years.

4.38 An environmentalaudit should also be carried out of the Kara-Baltamine to identify options for economicallyviable mine waste re-utilizationand cleanup of mine wastes.

4.39 Reviewing appropriate regulations and proposed measures for dealing with treatment and disposal of hazardousmaterials from enterprises, includingstored banned pesticides. A review of internationalapproaches to setting appropriate and enforceable regulations will help avoid long-term health damages and avoid liability problems in connection with restructuring and privatization of enterprises.

4.40 Strengtheningthe monitoringsystem. To assure enforcementof environmentalstandards and regulations,the monitoringsystem shouldbe significantlyupgraded. Currently existingoverlap between in monitoring responsibilitiesof Goskompriroda,Hydromet, Sanepid and Goskomgeologiashould be assessed and steps should be taken to integrate the monitoring system. The Central and five oblast laboratories of Goskompriroda should be sustained and upgraded through provision of analytical chemicals, glassware, spare parts, modem analytical and computer equipment, and vehicles. Retrain laboratory staff in modem analytical and computingtechniques. NationalEnvironment Action Plan: 26 Prioritiesfor Action1995-97

4.41 Privatizationand the need to clarify environmentalliability. The concept of liability is included in all the environmentalstatutes, includingthe Law on EnvironmentalProtection, Law on Enterprises, and Lawon PeasantEnterprises. The governmentmay sue for monetarycompensation for both economic and environmental harm, which occurs on state property, and the revenues used to restore the environment to its original condition. Individuals and enterprises may bear both civil and criminal liabilityin accordancewith the laws on EnvironmentalProtection, Land Reform, Enterprises, Land and Forestry Codes of the Kyrgyz Republic. There is no clarification, however, of how to deal with environmentalliability in the process of privatization.

4.42 The success of the government's privatization program imposes a serious burden on the environmentalauthorities, who have limitedexperience in dealingwith privatebusinesses and are severely constrained in their ability to monitor and control environmental performance. A new system of standardsand regulationsresponsive to a market economyneeds to be designed. Experiencefrom other FSU republics shows that new standardsare often set at levels that are too high, with little consideration for enforcementcapability--this practice should be avoided in the Kyrgyz Republic. The standardsand pollution limits shouldbe revised based on projected enforcementcosts and benefits, and implemented within a realistic timetable.

4.43 In additionto dealing with present liability, the issue of environmentalliability for past pollution needsto be urgently addressed,particularly with the objectiveof attractingforeign investors. The Kyrgyz Government should select one of the existing options: (i) sell assets at a lower price and transfer full liability to the new owner; (ii) sell assets for a full price and assume liability(setting aside some of the purchasefunds for cleanup); or (iii) design a combinationof the above options with clear decision rules.

B. THE NEAP PROCESS

4.44 The purpose of the Kyrgyz National Environmental Action Plan is to help policy-makers strategically integrate the formulation of environmentalpolicies and regulations with the process of economictransformation -- making environmentalconsideration an integral part of the overall economic and social developmentstrategy. The tools availableto the Kyrgyz Government include: (i) changes in policies and regulations;(ii) improvementsin the institutionalframeworkfor environmentalmanagement; and (iii) expenditureson projects with environmentalbenefits.

4.45 There are a number of possible sources of project funding -- both domestic and external. Domestic sources include user fees and fines, public expendituresfrom the general budget, and private investment;international sources include internationalfinancial institutionssuch as the World Bank, the Asian DevelopmentBank and the EuropeanBank for Reconstructionand Development,bilateral agencies or non-governmentalorganizations which provide grants, and private direct investmentin areas such as biodiversity-basedenterprises or environmentaltechnologies. During the economictransformation and in the context of the severe budgetary constraints, much of the funding for environmentmay have to come from external sources. Over time, the majority of funding must come from domestic sources.

4.46 The principal objectives of the NEAP process in the Kyrgyz Republic are:

* to carry out an assessmentof the environmentalresources and problems of the Kyrgyz Republic and their potential impacts on the country's economicdevelopment;

* to discuss the emergingdevelopment trends in various sectors of the economy and their environmentalconsequences; National EnvironmentAction Plan: 27 Priorities for Action 1995-97

* to reach a consensus on the priority areas for funding environmental activities within the budgetary and financial constraints that the Kyrgyz Republic economy is experiencing now and will experience in the near future;

* to initiate an evaluation of the institutional capacity for environmental management within the present constraints, and of the policies which affect the use of natural resources; and

* to recommend specific macroeconomic, sectoral and project investment actions which address the critical environmental issues identified, and which complement the national development strategy.

4.47 Kyrgyz Government actions. To this end, the Government -- under the leadership of Goskompriroda -- has taken the following steps:

(a) A High Level State Committee has been established by means of an Ordinance of the Prime Minister dated May 19, 1994, with the objective of guiding the preparation and implementation of a National Environmental Action Plan (both to be carried out in collaboration with the World Bank). The State Committee is chaired by the Chairman of Goskompriroda and includes the Ministers/Chairmen of the Ministry of Agriculture, Ministry of Water Resources, Ministry of Health, State Committee on Economy, State Committee on Geology, Academy of Science and the Agency of Hydrometereology.

(b) A NEAP Expert Working Group has been organized through a special order of the Chairman of the State Committee on Environmental Protection dated June 16, 1994. The Expert Working Group is co-chaired by an official from the State Committee on Environmental Protection and an expert from academia. The Government will expand the Expert Working Group as necessary to carry out the work on the implementation of the NEAP.

4.48 NEAP office. Implementation of the NEAP requires collaboration among many institutions within and outside the Government. In order to facilitate this process, a small NEAP Implementation Office is being established with initial funding from Switzerland and with assistance from the World Bank. Office space is provided by the State Committee for Environmental Protection (Goskompriroda). The NEAP office is responsible for maintaining a library and documentation system, facilitating coordination among the different institutions participating in the implementation of the NEAP, providing status reports on the implementation of the NEAP, updating the inventory of key environmental concerns to ensure that action focuses on current priorities, and disseminating information. Over time the office is expected to assume the functions of a Public Information Center.

4.49 Wide ranging discussions throughout the Government, have led to the following recommendations for action within the next 2-3 years (Tables 1-3). As more and better information on the precise nature and urgency of environmental problems becomes available, these recommendations will be continually updated and/or altered. Table 4 presents technical assistance needs identified by the Bank and the Kyrgyz authorities during the preparation of the NEAP. 28

KYRGYZ REPUBLIC NATIONAL ENVIRONMENTAL ACTION PLAN: PRIORITIES 195-1997 Table 1: Powy Reforms

AREA OF CONCERNAND OBJECTIVE OR OUTCOME ACTONS TO BE TAK :EN: RESPONSIBLE INSTIIlJTIONS TlM{NG. RECOMKMEDATION :_::______::_a:_:__j:: _:_ :_ ::_ :

Water resources management

Gradually develop effective local Prevent loss of performance or function of facilities Develop and implement a pilot system of MOF with MOWE, State By end 1996 mechanism to mobilize funds for full such as canals, diversion works, water pipes, pumps, local government financing in a selected Committee on Prices and the pilot funancing of operation and maintenance and drinking water treatment works through oblast (Issyk Kul or Osh). oblast authorities (including provision of chemicals) for improved operation and maintenance, water supply, sanitation, and irrigation Gradually introduce user charges for water KJKSNodokanal in the pilot 1996 + facilities. Prevent health damages from dirty drinking water; and municipal services as part of the piloL oblast

Increase agricultural productivity; Analyze experience, set up a local MOWE, Oblast authorities, By mid-1997 government ftnancing policy group and KJKSNodokanal Avoid the need for costly repairs in the future; propose a national refonn program.

Prevent 'brain drain' from the sector. Reorganize and streamline municipal MOF, MOWE, By end of 1997 infrastructure operation and maintenance Goskomekonomika, oblasts services in the oblast water utilities, authorities

Provision of safe drinking water

Improve enforcement of land use controls Reduce vulnerability of surface and ground water Develop improved, enforceable standards for GoskomGeol, SANEPID, By end of 1995 in sanitary protection zones for drinking intakes to pollution. drinking water intakes. Goskompriroda, MOWE. water supplies.

Promote policies focused on rural Avoid health damages, especially among small Encourage the implementation of pollution MOWE, Goskompriroda, Oblast By end of 1996 development, including on provision of children. prevention incentives, including fees and environmental institutions. safe drinking water and proper sanitation. fines; update the existing fees and fines.

Develop a small-scale effective awareness Clearly define sanitary protection zones and Ministry of Agriculture, KSRS, In 1995, 1996 campaign to promote hygiene and the train local authorities in low cost water and Oblast authorities. importance and use of clean water. sanitation measures.

Prepare simple teaching material and Sanepid, Goskompriroda, Ministry By end of 1995 encourage schools to promote hygiene. of Education, NGOs

Land degradation

Promote soil conservation techniques Enhance soil fertility and increase production Provide farner training on specific Ministry of Agriculture, Oblast 1995-1997 + conservation techniques such as mulching, authorities, local farmer Reduce point source pollution by agro- Reduce downstream ecosystem degradation and contour ploughing, strip cropping, reduced associations, leskhozes chemicals and livestock wastes human health hazards tillage, and integrated pest management. 29

AREA OF CONCERNAND OBJECTIVEOR OUTCOME ACllONS TO BE TAKEN RESPONSIBLEINSTITUlTONS TIMING RECOMMENDATION l

Land degradation (cont'd)

Updatelegislation and standardsgoveming Strengtheninstitutional tools to govern andsanction Providetraining to local agro-chemical MOA, Institutesof the National 1995-1997+ the sector agriculturalpractices distributorsor handlerson substitute Academyof Sciences,local technologiessuch as integratedpest farmerassociations. management,and provide education on propercontainment and handling of toxics. Supporton-going efforts to use composting and vermicultureto recycieexisting agriculturalwastes into fertilizers.

Forestry

Lack of managementof the Recognizerangeland ecosystems as a major part of Reviewand reviseforest policy and Goskompriroda(the Forest By the end of 1997 forest/rangelandareas as integrated the productivesystems under the managementof the harmonizeforest/grassland production and Department),Biological and productivesystems resulting in a conflict ForestDepartment Developan integratedprogram protectionobjectives ForestryInstitutes of the NAS, the of interestbetween short-term and long- for joint productionand conservationactivities in NEAP office term needs,and herdingversus forestry forestsand grasslands. needs. Re-evaluatethe local and international rangelandleases, basing future fee-based Goskompriroda,MOA Oblastand By the end of 1995 Conflicting authority over the land Greaterleskhoz control over the managementof leaseson the valueof the landto the local local authorities,including compromisethe ability maximizeeither their land, includinglocal captureof the valueof the leskhozfor supportingforest and grassland Leskhozauthorities. protectionor productionfunctions land for alternativeactivities. restorationand productionactivities.

Tailor productiveuses of the land By the end of 1996 accordingto the capabilityof the particular Reversalof landdegradation through appropriate Zone fragile lands(particularly Leskhoz Goskompriroda,Geprozem sites to support thoseuses, including site specificconservation practices lands)according to their capabilityto Institute,NAS, and Leskhoz managingthe numbersand timing of supportvarious activities. authorities. grazing livestock.

Legrslation and standards

Developa realisticpolicy frameworkfor Providesustainable and enforceablelegal framework, Reviewthe existinglegal and regulatory AppropriateParliamentary By end 1995 legislativechanges in line with economic adjustedfor the Kyrgyz socialand political framework(including emission and Commissions;Goskompriroda; reform;set objectivesfor gradual environment. concentrationstandards); obtain international NEAP office. replacementof the Sovietlaws, standards assistanceto reviewthe draft new laws on and regulations. protectionof air, water,underground resources,protected areas and biodiversity.

Revisethe systemof pollution standardsto Reviewcurrent practice in FSU countries; Goskompriroda,NEAP office. By end 1995 reflect (i) healthrisk and assessprogress-to-date and lessonslearned. (ii) enforceability.

Securetechnical assistance for the revision Preparea mediumterm programfor AppropriateParliamentary By the endof 1995 of laws and standards. legislativechanges with emphasison Commissions,Central enforcement Govemment. 30

AREA OF CONCEN AND OBJECTIVEOR OUTCOME ACTIONS TO BE TAKEN RESPONSIBLE INSTITIMONS TInMIG RECOMMENDATION

Legislation and standards (cont'd)

Prepare realistic compliance schedules for Review all intemational conventions, signed Ministry of Foreign Affairs, By the end of 1995 all major polluters. and ratified by the FSU, and new Goskompriroda, Office of the intemational initiatives, affecting the Kyrgyz President Republic, and propose program for Kyrgyz action.

Develop and implement a pilot program for Goskompriroda, MOWE, MOI, By the end of 1996 enforceable and effective pollution charges MOF. and fees.

Establish transparent procedures to assure Goskompriroda, MOWE, MOI, By the end of 1996 proper implementation of licensing MOF procedures, including the involvement of independent auditors and NGOs.

Develop an inventory of enterprise Goskompriroda, NEAP office. By end of 1997 environmental passports and permits.

Nature Protection and Biodiversity Conservation

Review and expand the protected areas Enhance biodiversity conservation (for its own sake Review and expand the protected areas Goskompriroda, Academy of By the end of 1996 network, and coordinate management of and to promote eco-tourism and adventure tourism) network. Science, Oblast authorities. transboundary reserves with neighboring by consolidating the fragmented protected areas republics. network and improving habitat. Participate in the planning and implementation of a regional biodiversity Goskompriroda. 1995 conservation strategy with Kazakhstan and Uzbekistan.

Review adequacy of hunting regulations. Goskompriroda By the end of 1995

Initiate a program to raise public awareness. Goskompriroda, Ministry of In 1996-1997 Education, NGOs, Oblast authorities.

Hazardous waste management

Review appropriate regulations and Avoid long-term health damages; avoid liability Review intemational approaches to setting Goskompriroda, SANEPID, By the end of 1995 proposed measures for dealing with problems in connection with restructuring and appropriate and enforceable regulations. Ministry of Industry, Kyrgyzaltin, treatment and disposal of hazardous privatization of enterprises. enterprises and mines. materials from enterprises, including stored banned pesticides. 31 Table 2: Insttutionsand Information

AREA OF CONCERNAND OBJECTIVE OR OUTCOME ACTIONS TO BE TAKEN RESPONSIBLE TIMING RECOMMENDATtON INSTITullONS Cross-sectoralcoordination of environmental actvities

Develop, formalizeand strengthenthe inter- institutionallinks amongministries and other Advancementof theenvironmental Establishan EnvironmentalPolicy Council underthe NationalGovernment, By mid-1995 govemmentagencies. managementsystem. Deputy PrimeMinister in chargeof environment. Goskompriroda.

Continuethe operationof the NEAP Working Group Goskompriroda;agencies 1995-1997 (with new mandaterelated to NEAP representedin the Working implementation). Group.

Fragmented,overlapping and deterioratingmonitoring system

Establishan integratedmonitoring network, Provideefficient and cost-effective Sustainand upgradethe Central and five oblast Goskompriroda Mid-1996 serving environmentalpolicy andenforcement of monitoringservices for decisionmakers laboratoriesof Goskomprirodathrough provision of standardsand regulations. and environmentalregulators. analyticalchemicals, glassware, spare parts, modem analyticaland computerequipment, and vehicles. Drinking water: monitorwater supply quality at Assuresound data for planningappropriate the tap and in waterbodies where there is direct expansionof water supplyto vulnerable Retrain laboratorystaff in modemanalytical and Goskompriroda,Sanepid, 1995-1997 abstractionof drinkingwater in rural areas. groups(based on informationfor health computingtechniques. Hydromet impacts- incidenceof water-bome diseases,increased child morbidityand Collaborateto designcost-effective monitoring Goskompriroda End of 1996 mortality, consistentcontamination with systemto respondto the particularquestions that Hydromet bacteria,nitrates, etc.; flow distribution; need to be answeredin order to maintainand/or GoskomGeol water shortagesand outages; and upgradesound water supply systems. Sanepid productionin irrigatedareas. MOWE Uraniummining: monitorthe statusof closed uraniummincs andtailings. Avoid risk of major environmentaldisaster Assessthe monitoringneeds in different locations Goskompriroda, Endof 1995 and minimize healthrisk. accordingto the seriousnessof the existingand Kyrgyzaltin potentialenvironmental problems and propose GoskomGeol rationalmonitoring set andsampling.

Commissionan independenttechnical appraisal of GOK, 1995- the integrityof uraniumsites on waterways; assure Goskompriroda 1997+ propermonitoring of all tailings and closedmines. Kyrgyzaltin 32

0AREA OF:CONCERN :AND ::: : O IVEEOROUTCOM E AC NS.TO TO BEATAKENBEh RES SIBLE l;E ::OLEN REO : ON INSTTrUlIONS

Inadequate ecological appraisal procedures

Developcapability to carry out Environmental ImpactAssessment according to intemational Ensurethat new mining activities, Arrange an intemationalELA training programin Kyrgyzaltin, Mid 1995 standards. especiallyGold mining, meetall necessary combinationwith full EIA of two new gold mines Goskompriroda(central and environmentalrequirements. Prepare EL4s accordingto intemationalstandards (provide on-the- oblastadministrations) for plannedconstruction of new industries job training in additionto intemationalexchanges). and possibleexpansion of hydroelectric facilities. Theseare inexpensiveactivities Carry out ELI involving systematicevaluation of Goskompriroda, Institutions which can avoid significantfuture dam safety(provide on-the-jobtraining in addition responsiblefor hydropower Early 1996 environmentaldamagc and related to intemationalexchanges). development, Oblast economiccosts. Training should startnow administrations) beforeeconomic activity picks up.

Low efficiency of Resource Use in Industry

Developthe capabilityto carry out efficiency Identify low-cost efficiency improvements Carry out combinedaudit training andactual Ministry of Industry, End of 1995 and environmentaudits in selectedindustries and in the mostpolluting industriesthat are environmentalaudits in the highestpriority industries Goskomprirodaand mining enterprises. likely to continueoperating during the next that are likely to be restructured,e.g., cement, individual industrialplants. 3-5 years. electroplating,slaughter houses, textiles. Identify opportunity for economically viable mine wastere-utilization. Carry out studyto identify utilization and cleanupof KyTgyzaltinand Mid 1996 mine wastesat Kara-Balta. Goskompriroda.

Hazardous Waste

Assesshow critical is the potentialdamage to Cost-effectiveapproach to reducing Completeand extendongoing studiesof potential NAS, Kyrgyzaltin, Sanepid, 1995-1997 health from mine wastesat the threelargest potentialhealth damage. health hazardsfrom mine wastesat Haidarkan, Goskomgeol,Hydromet, combinats. Kadamzhai,and Orlovsky Combinats. Goskompriroda

Water management and supply

Strengthencoordination and information Healthand economicimpacts used as Test integratedapproach to health assessmentand MOWE, Goskompriroda, 1995-1997 exchangeto improvepriority setting, planning primary criteria in planningand priority economicevaluation in planningpriority water SANEPID, Goskomgeol, and capitalbudgeting. settingfor water management supplyand irrigation infrastructurerehabilitation KJKS, KSRS, programs;introduce modem information Rayonand Oblastauthorities managementtools to encouragethe timely exchange of information.

Strengthenwater managementorganizations and More cost-effectivepublic sector Improve the pay and working conditionsof public MOF, MOWE, 1995-1997 enhancethe technicalexpertise and effectiveness organizations. sectortechnical and managerialstaff; provide Goskompriroda,SANEPID, of staff. training; introducemodem equipment and tools in Goskomgeol,KJKS, KSRS. offices, laboratories,and field stations. . 33

AREA OF CONCERNAND OBIECTIVEOR OUTCOME ACrIONS TO BE TAKEN RESPONSIBLE TIMING RECOMMENDATION tNSTITUTIONS

Prepareguidelines for identificationand Both the nationalgovemment and donors Develop,describe, and issue criteria for project Working party from multi- End of 1995 preparationof projectproposals for watersupply could rapidly supporthigh-priority evaluationand selection, visit projectsites, and agencyteam and sanitation. investmentsin watersupply and sanitation. compileand possiblycollect dataon which to base the evaluationof subprojects.Develop a standardizedand simplified reportformat for preparationof projectfeasibility studies. Develop transparentcost-sharing arrangements.

Forest Management

Strengthenupper catchment land managementby Developmentof sustainableeconomic Developa rural credit programdesigned to Goskompriroda,MOF, 1995-1997+ strengtheningthe economicbase of the activities in fragile watersheds. encouragesmall naturalresource-based enterprises MOA Leskhozes. which promotethe resourceconservation.

Establishan on-goinginformation gathering Providepolicy -makerswith sufficient Train forestrypersonnel in torestinventories which Goskompriroda,NAS 1995-1997+ systemon forestinventories and health.Expand informationto establishlong-term forest provideinformation, standing stock, annualgrowth, Institutes, this systemto includeForest Department managementgoals and short-term regeneration,and health. Supportcomprehensive Leskhozofficials rangelandassessments. regulationsand permitting parameters. inventorieson ForestDepartment lands. Expand processto includerangeland inventories for the purposesof livestockmanagement and restoration programs.

Blodiversity Conservation

Initiate a nation-widebiodiversity protection Halt the catastrophicerosion of biological Developa NationalBiodiversity Strategy which Goskompriroda, Mid-1996 program. diversity throughoutthe countryby integratesecosystem preservation with local forestry, NEAP office, developinga programwhich integrates herdingand agricultural activities. Join the Oblastand rayonauthorities. biodiversityconservation with economic intemationalBiodiversity Convention, and focus activitieson the local level. intemationalefforts for biodiversityconservation on the local solutionsidentified in the Kyrgyz Strategy.

Environmental Oversight

Preparedetailed list of donor activitieswith Efficiently extractmaximum benefit from Establishwell-designed computerized data base and Goskomprirodawith 1995-1997+ particularemphasis on environment-relatedwork. donor assistanceand avoid overlaps, ensurecontinuous updating. Ministry for ExtemalAffairs duplication,and donorsupport to low- and Ministry of Finance pfiofity activitics.

Carry out long-termreview of environmental Ensurerational implementation of a long- Preparelist of functionsof all thedifferent Goskomprirodawith all 1995-1997+ managementfunctions in the Kyrgyz Republic. term sustainabledevelopment strategy. environmentalinstitutions in Kyrgyzstan;discuss and affectedinstitutions, clearlydefine respective responsibilities; restructure especiallyOblast Goskomprirodain order to betterliaise with other environmentalinstitutions agenciesand efficiently carry out high priority tasks of NationalEnvironmental Action Plan. Note that this activity doesnot imply changingthe lines of authorityin different ministriesor committees,nor reductionsin staff. Theseshould be longer-termobjectives to be implementedgradually afterthe currentNEAP and aftera full assessmentof the responsibilitiesof different institutions. 34

Table 3: Targeted Inveshnents

PROBLEM LOCAT/ON SOURCE j POSSIBLEACTIONS

Exposureto contaminated Pipedistribution systemsin urban Deteriorateddistribution MOWE with KJKS/Vodokanal, KSRS; SANEPIDl drinking water and consequent and rural areas;open reservoirs systemsand pumpstations; Developprioritized action programand rehabilitate,repair, and replacefacilities with highest health damagesaffecting and other surfacewater sources in non-functioningand immediatehealth and economicimpact, installmodem control andmanagement systems in larger especiallypoor people. Osh, Dzhalal-Abad,Talas. and unavailabledisinfection networks;concurrently train new cadreof local techniciansto operateand maintainfacilities in rural Chu Oblasts. equipment;ineffective waste areas;update training of local techniciansin urban areas. water collectionand treatment Proposedprojects should demonstratethat they are basedon a least cost approachwith respectto systems. investment,operation, and maintenance;can be implementedquickly with existing technologyand availablematerials; and are capableof being stagedor phased. The sizeof individual projectswould be restrictedin order to utilize the limited availablefunds on the highestpriority problemsin all Oblasts. Proposedprojects should demonstrate that local authoritiesare committedto a plan and have or are developingthe necessaryfinancial mechanismsfor graduallymoving towardfull costsrecovery tariffs within a reasonableperiod of time.

Contaminationof unprotected Rural settlementsin Osh, Dzhalal- Livestockoperations; mine MOWE with KSRS, KIKS/Vodokanal: surfacewater sourcesand Abad. and industrialtailings; Reconstructintake works: substitute ground water; extendand repair pipe networks. consequenthealth damages untreateddomestic and affecting especiallypoor people. industrialliquid wastes.

Rural poverty, relatedin part to Osh, Dzhalal-Abad;Narvn Oblast Scarcityof wood and non- National Government in collaboration with Oblast Governments and Leskhozes: natural resourcemanagement wood products(firewood and Provideshort-term credit to developcollection, processing and marketingof non-woodforest products, (deforestationand soil erosionin poles);land slides and mud particularly fruits and nuts. uppercatchments) flows; siltationof irrigation and hydro power reservoirs.

Air pollution Bishkek. District heatingand power Power plant, Goskompriroda: plant, primarily usingcoal Ensurethe correctand continuoususe of Electro-StaticPrecipitators to reduceparticulate pollution. and mazut.

Abbreviations: KJKS: Kyrgyzjilkommunsoyuz MOWE: Ministry of Water Economy KSRS: Kyrgyzselremstroy(responsible for rural piped water supply) SCP: State Committeeon Prices 35 Table 4: Proposals for Technical Assistance

PROJECT DESCRIPTION COST ESTIMATE

I Decentralizationof water supply Identify institutional changes required to decentralize decision-making,operations and maintenance to local $150,000 and sanitation services municipalities. Assess various low-cost sewerage schemes. Evaluate the feasibility of private sector involvement in the providing low-cost services in the water supply and sanitation sector. 2 Prefeasibility Study for a Rural Estimate future water needs in rural areas, including social assessment, cost recovery potential, health and $500,000 Water Supply and Sanitation economic analysis. Estimate sanitation needs and develop a joint water supply and sanitation action Project programnwith a set of targeted interventions. In addition, sponsor pilot projects to demonstrate appropriate technologies which will be used as a model to develop a rural water supply and sanitation project.

3 Prefeasibility Study for an Urban Conduct water audits and estimate future needs of the water supply and sanitation systems in major urban $280,000 Water Supply and Sanitation centers to establish priority areas of intervention. The study will include the following: estimate Rehabilitation Project unaccounted-for water (UFWs), evaluate existing treatment and distribution facilities, review extent and accuracy of metering, audit financial revenues including collection and billing. The study would result in a priority action program to rehabilitate, repair and replace facilities with the highest immediate health and economic impacts. 4 Environmental Standards and Review the existing legal and regulatory framework to protect air, water and undergroundresources. $1,000,000 Monitoring Systems Review environmental standards to harmonize them with international standards. Strengthen the monitoring system through support for the Central and oblast laboratories of Goskompriroda. Focus on basic equipment such as analytical chemicals, glassware, spare parts, computers and other instruments, and vehicles. Retrain laboratorystaff in modern analytical and computing techniques.

5 Monitoring the interaction of Establish a monitoring system through the local Sanepid stations for combining health parameters with $350,000 public health and water environmental monitoring, and provide analytical equipment to the joint laboratory of Goskompriroda and contamination, particularly in Chui Sanepid Station.. Monitoring should provide data for (i) estimating exposures to chemical and rural areas biological pollution, (ii) providing early prophylactic warning, and (iii) developing protective measures such as sanitary zones around mines. Assistance should fund training, equipment, and information dissemination costs.

6 Risk assessment of mining Conduct an environmental risk assessment of radioactive materials, mercury, antimony and rare earths $400,000 residuals and hazardous waste mobility in mines, tailings and residue dumps. 7 Environmental Audits Train Kyrgyz experts in environmental audit procedures. Carry out comprehensiveindependent $300,000 environmental audits of five of the most polluting industrial enterprises eligible for funding under the Bank's private enterprise development project. Prepare environmental management action plans for regulatory compliance. 8 Hazardous Waste Management Review appropriate regulations and proposed measures for dealing with treatment and disposal of hazardous $300,000 materials from enterprises, including stored banned pesticides. Review current practice. Prepare an industrial hazardous waste management action plan for the Republic. 36

[ | PROJECT | DESCRIPTION | COST I I | ESTIMATE 9 Pollution Permitting System Develop an improved pollution permitting process to control air and water pollution and hazardous $200,000 industrial waste generated by industrial enterprises. 10 Environmental Impact Develop an improved EIA regulatory and enforcement process for newly proposed operations which is in $200,000 Assessment harmony with international EIA standards. Focus on training environmental agency staff, including on-the- job training assessing existing and proposed gold-mining operations. 11 National Biodiversity Strategy Develop a nation-wide strategy for protecting diverse ecosystems, focussing on reducing habitat S 75,000 encroachment and supporting economic activities that rely on biologically diverse resources. Coordinate with related on-going studies under the Aral Sea Program and in connection with efforts to develop a transboundarybiodiversity conservation program. 12 Environmental Education Develop curricula and textbooks for environmental education of children in primary and secondary schools. $100,000 Print and distribute new teaching materials. Train the teachers in subject delivery. PART TWO

BackgroundPapers: Setting Prioritiesin 37 The EnvironmentalPolicy Using HealthInformation

1. SETTING PRIORITIES IN ENVIRONMENTAL POLICY USING HEALTH INFORMATION

Kyrgyz Republic - Vital Statistics

Total Population(1994): 4,429,905 Urban (approximate): 1,572,056 Suburbanand Rural: 2,857,849

Birth Rate: (1992) 29/1000 Death Rate:(1992) 7/1000

Life Expectancy(female) (1992): 72.2 years Life Expectancy(male): (1992) 64.2 years

Note: 37% of the populationis youngerthan 15 years old.

Sources: EnvironmentalHealth Services in Europe, Kyrgyzstan,28 June - 10 July, 1993; Duchemin,WHOOMS Bureau for Europe, Copenhagen;and Goskomstat.

A. BACKGROUND

1.1 Primary health problems. Although current knowledge suggests that the primary human health concerns in the Republic are poverty-related, poverty and the state of the environment are often inseparable. For example, the causal factors of poverty, poor water supply and land degradation are commonly intertwined. Childhood nutrition, hepatitis A (a problem particularly in the south), tuberculosis, maternal and infant morbidity and mortality are the main problems. Inadequate childhood nutrition is poverty-induced, and Hepatitis A and poor maternal and infant health are often related to environmental contaminants to which low-income populations are more likely to be exposed. Table 1-1 illustrates the trends in infant mortality per general disease category.

Table 1-1: Infant Mortality Rate per Disease Category 1988 to 1993

_ 1988 1989 1990 1991 19921 1993

InfantMortality Rate r 36.8 J 32.2 30.0 29.7 31.5 31.9 Disease Category

Respiratory 17.9 14.9 13.6 12.3 13.6 14.9

Perinatal 6.2 7.1 7.1 8.0 7.7 8.0

Acute Diarrheal 5.4 3.4 NA 3.0 5.1 4.3

Source: Childrenand Women in Kyrgystan, Draft Report, UNICEF, 1994. BackgroundPapers: SettingPriorities in 38 The EnvironmentalPolicy Using HealthInformation

1.2 The breakdown of the health care system. The ul infant morbidity went up from 36/1000 in 1991 to 88,1/1000 in 1992. The u14 (children under 14 years) morbidity was 529/1000 in 1993. As a result of UNESCO-led efforts, infant mortality is expected to decrease for children under 1 year (ul) in 1994. The main causes for children's morbility and rnortality are respiratory diseases aggravated by insufficient heat in homes and schools in the winter, and diarrheal diseases caused by poor sanitation and contaminated water supplies. Sanitation is deteriorating in many places: schools which used to have flush toilets (60 students per toilet) have changed to unlined pit latrines (500 students per latrine). Table 1-2 records this decline by infant mortality rate. Infant mortality and morbidity rates are the considered the most sensitive indicators of public health.

Table 1-2: Infant Mortality Rate (IMR) by Region (Number of children per 10,000)

Regions [ 1983 1984 1985 1986 1987 1988 1989 1990 1991I 1992 I193

Republic 40.1 40.9 41.9 38.2 37.8 36.8 32.2 30.0 29.7 31.5 31.9

City 29.3 29.0 30.0 28.6 31.4 30.5 28.3 27.4 26.8 30.5 35.4

Rural 44.8 46.2 47.2 42.4 40.6 39.6 33.9 31.1 31.0 32.0 30.6

Bishkek 24.8 23.2 27.1 24.2 27.7 28.7 30.8 28.0 27.9 36.5 50.0

Chu 37.4 35.7 34.9 29.1 29.2 25.9 27.0 26.0 25.5 23.0 20.8

Issyk-Kult 38.1 36.2 35.9 30.1 36.3 32.6 28.2 30.5 28.3 28.4 34.3

Naryn 46.6 38.1 42.8 47.5 40 .4 39.2 34.9 28.0 31.2 33.1 38.9

Talas 36.5 45.7 51.0 43.4 37.5 37.7 35.5 29.2 33.2 29.3 33.6

Osh 43.5 48.6 48.4 45.0 44.3 44.1 36.9 34.7 32.3 33.6 31.7

Djala-Abad 42.5 41.3 42.5 38.4 36.9 36.4 28.6 26.2 28.2 32.9 29.0

Source: Childrenand Womenin Kyrgyzstan,Draft Report, UNICEF, 1994, and the NEAP WorkingGroup on EnviromnentalHealth.

1.3 What is environmental health? Current health policy in the Kyrgyz Republic makes little distinction among different health categories, such as public health, occupational health and environmental health. The organizational and legal system distinguishes between curative and preventive health care only, which are theoretically administered separately at the oblast and rayon level. In fact, they are implementedjointly. In addition, previously existing environmental health departments have been closed due to insufficient funding, and their responsibilities either taken over by other health services, or abandoned. This confusing situation complicates efforts to clarify either public health or environmental policy. It is important to define the differences, however, for both regulatory and organizational reasons. For example, the exposure of workers (including women and children) to occupationalhazards associated BackgroundPapers: Setting Prioritiesin 39 The EnvironmentalPolicy Using HealthInformation

with tobacco-growing or mining, or to glues and dyes used in factories, is not an environmental exposure per se but an occupational one--and is better treated as such. Exposure of the general population to hazardous factors in the environment such urban air pollution, contaminated drinking water, or heavy metals mobile beyond industrial sites is an environmental exposure requiring an environmental policy response. Similarly, a separation between public health and environmental health may be made. Outbreaks of measles or tuberculosis, and vaccination programs are typical public health issues, while sanitation (in terms of the proper disposal of human excreta) is both a public health and an environmental health problem. For these reasons, several "environmental health problems" identified by Kyrgyz experts are not included within the NEAP, although they may be of critical significance from a public health perspective.

1.4 One National Environmental Health Plan. Three concurrent initiatives to develop an environmental hea]th policy are presently underway: (1) under the Ministry of Health, an environmental section is being prepared for the joint program called "Healthy Nation" with Emil Shukurov as chairman, (2) a national environmental health program is being prepared as part of the Manas national health policy project, and (3) under the State Committee for the Environment, environmental health policy recommendations will be made as part of the NEAP. Three concurrent but independent efforts are neither efficient nor desirable. There should be only one national environmental health plan. It should combine the specifically environmental health-related recommendations of the "Healthy Nation" and MANAS projects with local Government and NGO initiatives, and be incorporated into the implementation structure of the NEAP.

B. ExPosuREs TO Toxics

1.5 Exposure to bacteriologically and virologically contaminated water. The Kyrgyz Republic has an abundant supply of good quality fresh water. Ironically, it is pestered by waterborne diseases, however. Traditionally, the Kyrgyz people drink boiled water in the form of tea. Therefore, drinking water may not be the main source of waterborne diseases. The most areas most infected with OKZ' and Hepatitis-A are the Osh and Djalal-abad oblasts. These oblasts have large irrigated areas. Canals and other open water supplies are contaminated by free-ranging livestock (even in areas around main drinking water supply systems) and incorrect disposal of human excreta. The infection of humans probably takes place predominantly by eating contaminated food, using surface water such as irrigation ditches, for washing and cooking, and by generally poor personal hygiene. Such factors are largely cultural factors. In addition, because of the breakdown of structured institutions, it has become increasingly unclear what the behavioral "do's" and "don't's" are. In areas served by piped water supply, these cultural factors are aggravated by deteriorating conditions in the water treatment plants, including lack of purifying chemicals and spare parts. This lack of decline in standards (particularly since 1992) has reversed a previously observed downward trend in the occurrence of waterborne diseases. The reported occupance in the whole population of Hepatitis-A increased in 1993 from 36/1000 to 44/1000 and of OKZ from 35.7/1000 to 36.9/1000. If these numbers are correct, infant morbidity (ul) must be very high. The data necessary to confirm these figures and conclusions probably exist, but they are not readily available to health and environmental policy-makers. Existing water monitoring programs by Saniped and Kyrgyzjylcommunsoyuz should be upgraded and combined or standardized to obtain better information on the health status of the people.

1/ IdentifiedOKZ is defined as acuteenteritis, colitis, gastro-enteritiscaused by identifiedfactors (ICD-IX 008;005.0and 2-4,8). Includedare also rotavirusinfections belonging to ICD-IX008. UnidentifiedOKZ is defined by unidentifiedgastro intestinalinfections and unidentifiedtoxical food infections(ICD-IX 009 and 005.9). BackgroundPapers: Setting Priorities In 40 The Environmental Policy Using Health Information

...... 0100 Basicg:RecomntIon: Saitatin in Csentral.Asa Onoof thentsin environmental health problems in theCentral Aian republicsis e occurrnce of wa6to disease:6 uc At HepiadtisA and OKZ. (0K:Zis an m for varous acte identifiedand - d tdiaril diases.)The main caus¢s in rural areasare poor uiion andopen water Supply. Rura;sanittio d- isvetyi poorftrough the.Cetral AsianReublics, and the Kyrgyz Republic is no aee0lon, nlWinedpit latrineare stad inlrurlarea andthere ar no govenmntor community bqdVbJorahitatln tihelhough saniaion is widelystald 4as a a concern.Public officias are evI;4-t:4ytaaware 4d:ow-costbut CWbeffe inetehn e causethe definition of improved sanitao isgenerally a-sewer connection which is prhibitively xpensive for ithet individual households r0X; tes. i :ltio, soap-is esive ndbasic ysaniaon is appa y not a very highpriority amongrura households.Because poverty plays large roleit rrahealth status,projects which promote the;conatt_ctlonof iimproved latrineswitlocal buildingmateis and ocal laborwill have a dre-fold E ect-povng the environment,the halth statusof thepopulation and the economiccondition of the pooswts of :siocity.0Ibis:Th-0 t is applicableto nrualareas toughout CentralAsia...... :: : : : ::

1.6 Exposure to mercury and antimony. There is an undergroundantimony mine in Kadamzaiand a deep shaft mercury mine in Haidarkan, Haidarkandistrict, Osh Oblast. Both mines are located in the middle of settlements of approximately12,000 inhabitants,each. There are no sanitary or safety zones separatingresidential areas from the mines, and monitoringin the housing areas in Haidarkan indicate residents are exposed to mercury vapors in the air. Tables 1-3, 1-4 and 1-5 illustrate air and water contamination in the region. Table 1-6 compares the morbidity rates of the non-miningbut exposed populationwith a control settlement. The morbidityrates in the exposedsettlements are extremelyhigh.

Table 1-3: Ranges of Mercury Vapor (mg/m3) in the Open Air in Haidarkan With the Number of Times the MAC* Value was Exceeded 1987-1994

Location 1987 j 1988 | 1989 1990 1991 1992-94

Dormitory .017-.056 .01-.023 .0048 .00011 .00035 .00034- (186) (76) (16) (4) .00022 Hotel .017-.032 .018 .03 .0014 .00034 .00032-.0002 (106) (60) (10) (4.6) Kindergarten .016-.034 .015 .0032 .0016 .0016 .00035- (113) (50) (10) (5) .00024

Garage .021 .018 .0038 .0014 .0014 .00034- (70) (60) (12) (4.6) .00023

*MaximalAllowable Concentration:.0003 mg/m3 . Source: Sanitaryand Epidemniological Station (Sanepid), Kadamzai Laboratory. Background Papers: Setting Priorities in 41 The Envirommental Policy Using Health Information

Table 1-4: Antimony concentrations in the Sbaldmardan-Sai River Sampled September 7, 1994

Sample Site |_Antimony (mg/mr3 )

Bridge at Dzydalik (Karabisky GPR) 0.000

Bridge at Kadamzai (KSK) 0.025

Bridge at (CRB) 0.035

Source: Sanitary and Epidemiological Service, Kadamzai Laboratory

Table 1-5: Ambient Air Quality in Kadamzai Sampled September 15, 1994 (mg/m3)

Site Antimony Sulphur Nitrogen dioxide oxides

Workers dormitory .053 .44 .037

Drugstore .074 .48 .035

| Kindergarten .028 .12 .026

Note: MAC values for antimony in the mine interior are 0.5 mg/m3 (peak value) and 0.2 mg/m3 (average value); for sulphur dioxide 0.5 mg/m3 (peak), 0.05 mg/m3 (average); and for nitrogen dioxide 0.085 mg/m3 (peak) and 0.04 mg/m3 (average).

Source: Sanitary and Epidemiological Station (Sanepid), Kadamzai Laboratory BackgroundPapers: SettingPriorities In 42 The EnvironmentalPolicy Using Health Information

Table 1-6: Morbidity Rates in the Haidarkan District (Rates per thousand)

Disease ControlSettlement ExposedSettlement ExposedSettlement (Utch-Kurgon) (Kadamzai) (Haidarkan)

1992 1993 1992 1993 1992 1993

Respiratory 19.5 17.7 170.5 200.7 130.5 98.6

Bronchial Asthma 1.06 1.37 1.09 1.52 1.38 1.23

Gastro-Intestinal 18.1 23.2 39.9 51.9 39.1 36.7

Urinal and Genital 11.1 7.3 25.5 29.6 13.1 18.8

Skin 13.9 14.0 50.5 41.8 15.6 20.2

Skeletaland Muscles 3.1 2.3 41.4 49.9 40.4 44.6

Congenital 0.35 0.28 1.04 1.16 0.64 0.35 Malformnations

Source: Sanitaryand EpidemniologicalService, Osh Oblast.

1.7 Overall, health experts believe that the non-mining population is exposed to unacceptable risks. It is not clear how reliable the data are, however. If they reflect accurate trends, the ul morbidity rates in these areas can be expected to be much higher than in areas with no exposure. Unfortunately, the intensity of monitoring is unclear. There do not appear to be many sampling points, although Goskompriroda and Sanepid have joint sampling schemes. Furthermore, any hard evidence on dose- response relationships is not available because the actual exposure mechanism is not fully understood. The main exposures appear to be (i) through the soil in the settlement and thus through the crops harvested, (ii) emissions within and from the mining plant itself, and (iii) through mine tailings and other wastes.

1.8 The mercury mining enterprise at Haidarkan mine is expected to close sometime in the future, as one of 29 industrial operations scheduled to be shut down because they are not considered economically viable. The mercury enterprise is already reducing the size of its operation, and the number of miners employed are expected to fall by almost 50 percent within the next few years. The mining company estimates that air and water pollution has decreased accordingly by two thirds, although it is not clear on what basis this conclusion is reached. A production shift from mercury to other heavy metals is planned, however. Soil pollution will remain after mercury mining has stopped. Consequently, a monitoring program is badly needed to determine what practical measures are needed to reduce residents' exposure. It is very possible such a monitoring program may indicate that major measures are needed, such as closing the mine completely, or relocating inhabitants from the contaminated area.

1.9 Exposure to radiation. The nature of the rock substrate in Kyrgystan makes it likely that radon emissions exist in some areas. They may not occur under conditions that would lead to unsafe build-up of particles, however. Tests were performed for radon contamination on 43 samples of water from BackgroundPapers: SentingPriorities in 43 The EnvironmentalPolicy Using HealthInformation

artesian wells and from the water supply system in the city of Bishkek. The average Radon concentration was 47/1. The EPA standard is 74/1. Radon levels in the populated areas around the and gold combinat were also estimated. There are no negative findings reported, but the data are not available. Other forms of radiation hazards do exist, however. For example, the Kichi-Kemin area was flooded in 1964 by waters containing radioactive wastes. Radiation levels in populated areas in the Kichi-Kemin area reportedly do not exceed concentration standards, at this time, although again, there are no data available to document this conclusion. Excessive radiation was found, however, in areas where the soil was not properly recultivated and where building materials were used from the former submerged area. Mortality has reportedly risen since the flood, but there are no figures available. Generally, due to the lack of monitoring, there is no conclusive evidence of health damage from radiation. There is sufficient evidence, however, of the need for a general health-oriented monitoring program for radiation.

C. INFORMATIONMANAGEMENT

1.10 Data quality and availability. Reliable data on infant morbidity and mortality are assembled in a computerized database called ASU (Avtomaticheskaya Systema Upravleniya) by the Institute of Obstetrics and Pediatrics. This database does not contain environmental parameters. The main source of health information is the yearly report compiled by the Republican medical information center (200 copies/year). These data are partly computerized and their reliability is assumed. The computer information center of the Ministry of Health has developed a program for computerizing the public health care system primarily for purposes of the medical insurance system, which is implemented in Karakol, Issyk-Kul Oblast. This database covers all aspects of national health care--only part is relevant for environmental health, and only a very small part is devoted to water quality monitoring.

1.11 Necessary health data for a NEAP. Ideally, a NEAP database would be able to relate health data with environmental data on a national basis. Such a database does not exist anywhere in the world, however. Existing initiatives could be combined, however, focussing on groups most at risk, and relating environmental exposures and pertinent diseases. Examples of this kind of database are:

* A database that can relate rural water quality/supply, child health, and the occurrence of waterborne diseases and provide information for setting priorities for rural water supply and santitation;

* A database which can relate exposure to contaminants with population morbidity, mortality and related parameters such as the birthweight of infants and the health of young women in mining areas such as the Haidarkan district; and/or

* A database that can relate exposure to pollutants with population morbidity and mortality and related parameters in rural pesticide-intensive cultivated areas, such as the Suzak rayon in Osh oblast or the Chu valley.

Studies have been ongoing on all of these issues; however, research efforts are virtually halted due to lack of funds. A follow-up study on any of these subjects by the Institute of Ecology, for instance, would be very cost-effective, and yield invaluable information.

1.12 Data generation. The existing mechanisms for monitoring of health and environmental quality and data generation roughly follow the standards of the old Soviet sanitary surveillance system. This system, although ostensibly complete, is very difficult to implement. Data generation in the Krygyz Background Papers: Setting Priorities in 44 The Environmental Policy Using Health Information

Republic is therefore incomplete and inconsistent. For example, sampling schemes are not kept, registration is not uniform, data are on handwritten forms and not computerized, data are not verified either in content or form, and there exist large differences in implementation between rural areas and the cities. Compounding the problem, laboratory testing equipment (for blood and urine, or water quality) is old, or out-of-date, and frequently has not been maintained. There are no datacommunication procedures to speak of apart from the handwritten forms.

D. CAPACITY BUILDING AND INSTTrUTIONAL STRENGTHENING

1.13 Information sharing. The Ministry of Health shares information and data with Goskompriroda on an informal and irregular basis. The rayon Sanepid stations do not formally share information with the various rayon water authorities, the oblast Sanepid stations do not formally share information to the oblast water authorities, and so on up to the national level. The reasons are various: sheer lack of paper and bad telephone lines; the lack of opportunities in the past to experience the usefulness of information- sharing; and--most importantly--the vertical organization of information flow which results in the dilution of data which must travel from settlements upwards through rayon and oblast to the national level. At each level, data selection and aggregation introduce distortions and make it increasingly difficult to match one environmental data source with other sources from other regions or agencies.

1.14 Epidemiological Monitoring. Epidemiological monitoring efforts nationwide are not uniform, not computerized, and not directed toward extracting environmentally-related epidemiological data. There is a great need for environmental epidemiological training on oblast and rayon level. Monitoring equipment, computer equipment and communications equipment are needed on all levels. The monitoring schemes of Sanepid, Goskompriroda and Kyrgyzjylcommunsoyuz should be revised and coordinated, so that their databases complement each other and may be compared and combined. Simple, up-to-date monitoring protocols are needed. BackgroundPapers: WaterResource 45 Managementin the KyrgyzRepublic

2. WATER RESOURCE MANAGEMENT IN THE KYRGYZ REPUBLIC'

A. GENERAL OvERVIEW

2.1 The water resources of the Kyrgyz Republic are key to the economies of the four other states in Central Asia. The Republic is endowed with abundant surface water and groundwater resources-it has extensive reserves held in lakes, permanent snowfields and glaciers. There are more than 3500 rivers in the Republic itself, flowing into basins within the country or downstream through Kazakhstan, Uzbekistan, Tadzhikistan, Turkmenistan, and the Xinjiang province of China. The largest river is the Naryn. Other rivers longer than 200 km include the Kara-Darya, Chu, Talas, Sary-Dzahz and Kyzyl Suu. The headwaters of the Syr-Darya and Amu-Darya Rivers, which flow into the Aral Sea, are generated in the mountains of the Republic, as well.

2.2 River flows originate in 85 percent of the Republic's area. The remaining 15 percent of the area does not generate flows; on the contrary, rivers lose water in these areas, either through recharging natural aquifers, or being diverted for irrigation. Areas with a net river water loss include the foothills and alluvial areas of the Chu Valley, the periphery of the Fergana Valley, plains around lakes--especially Lake Issyk-Kul, and the foothills and alluvial plains of other mountain valleys.

2.3 Of the 44.5 km3 average annual flow, 11.6 km3 were endowed to the Kyrgyz Republic for its own use by the former Soviet Union. Current inter-republic agreements continue the division of water- rights, with the Kyrgyz Republic permitted to use about 24 percent of the flow. Irrigation uses both surface water and groundwater, while domestic and industrial water supply is largely based on groundwater.

The Principal River Basins of Kyrgyzstan

2.4 The largest river basins in the Kyrgyz Republic are the Amu-Darya, Syr Darya, Chu, Talas, and the Sary-Djaz. Table 2-1 summarizes the basic features of the main river basins of the country and their estimated total water resources. The distribution of water resources unfortunately does not correspond to the distribution of major water users--population, agriculture and industry--especially in the basins of such rivers as Sary-Djaz, Aksai, Naryn and its tributaries.

2.5 The two major tributaries of the Syr Darya River in Kyrgyzstan are the Naryn and the Rivers, which are the largest rivers in the Republic. The Naryn watershed area is 59.11 thousand km2 or about 30 percent of the area of the Republic. The average annual flow of the river is 13.7 kIn3, about 31 percent of the total water volume of the country. Flow is regulated by the cascade of reservoirs (of which the largest is the Toktogul reservoir with a capacity of 19.5 kma3 ) that are the country's most important source of hydro-electric power. The second largest river in Kyrgyzstan is the river Kara Darya. The watershed area is 31.65 thousand km2 and the average annual flow is 4.35 km3. The river is regulated by the reservoir with a volume of 1.75 kmn3.

I/ Thisbackground paper was prepared by TonyGarvey and VladimirTsirkunov of the WorldBank on behalf of the followingagencies who wrotebasis reportson water managementand water supplyfor the NEAPWorking Group: Ministry of Water Economy; Sanepid; State Committee on Geology - HydrogeologicalExpedition; Hydromet;Bishkek vodokanal; Kyrgyzjilkommunsoyuz; Kyrgyzselremstroy; Goskomstat; Goskompriroda; and EnvironmentCommittees in Issyk-Kul,Talas, and Chu Oblasts. Background Papers: Water Resource 46 Management In the Kyrgyz Republic

2.6 The basin of the Chu river occupies the largest part of the northern section of the Republic. Major urban and industrial centers are located in this basin, and it is one of the most important irrigated areas. The Chu also forms the border between Kyrgyzstan and Republic of Kazakhstan for 221 km of its 336 km length in Kyrgyzstan. The watershed of the Chu River is 38.4 thousand km2 half of which is located in Kazakhstan. The upper part of the river is regulated by the Orto-Tokoy reservoir with a volume of 0.47 km3. The Talas River watershed is much smaller than the Chu, 7,640 km2, but its higher water yield has allowed significant irrigation development. The river is impounded by the Kirov reservoir with a volume of 0.55 kn3.

Table 2-1: The Annual Pattern of Surface Water Availability

River Flow (kn3 /yr) River Basin Oblast(s) Watershed area Average Estimated Low Flows (1031km) Year 75 percent j 95 percent

Chu Chuisk 14.154 3.729 3.397 2.99 Talas Talas 7.64 1.35 1.184 1.0 Assy Issyk-Kul 0.454 0.188 0.168 0.143 Syr Darya Osh, Dzhalal-Abad,Naryn 99.458 27.424 22.818 18.454 Amu Darya Osh 7.7 1.252 1.1 0.927 Issyk-KulLake Issyk-Kul 15.738 3.332 3.002 2.617 Ili Issyk-kul 0.997 0.363 0.306 0.243 Tarim Issyk-Kul 22.65 6.15 4.865 3.554 TOTAL 168.791 44.463 37.53 30.621

2.7 The basin of Issyk-Kul Lake, the largest in Kyrgyzstan and notable for its high recreational value and its exceptional clarity, has no outlet and lies in the north-eastern part of the Republic. More than 80 small rivers from the slopes of the Terskey and Kungey-Alatoo ranges flow into the lake. The total watershed area of the lake basin is 15,738 km2.

2.8 Surface water availability in the major river and lake basins of Kyrgyzstan is sununarized in the Table below. In addition to the average annual volume, estimates of the reliability of different levels of annual flow are also given, including the flow expected to be equaled or exceeded in 3 out of 4 years (75 percent), and the flow that is expected to be equaled or exceeded in 95 percent of the time over a long period of years. BackgroundPapers: Water Resource 47 Management in the Kyrgyz Republic

The Distinctive Seasonal Patterns of Streamflow

2.9 The primary source of moisture in Kyryzstan is snowfall on the high mountain slopes which are covered in part by permanent snowfields and glaciers. Streamflow and ground water recharge originates mainly from melting snow and glacial ice. This results in three major periods of streamflow depending on elevation, the local dynamics of snow and glacier melting, and the varying rate of ground water discharge over time:

(i) A period of high flow due to seasonal snow melting from mountain slopes of low and average elevations.

(ii) A period of high flow due to snow and glacier melting at higher elevations.

(iii) A low flow period when rivers are fed by ground waters.

2.10 This regime is typical of Central Asian watersheds, and has been classified into four distinct types by Schultz as outlined in Table 2-2 below according to the ratio of the summer and spring flows, the proportion of annual flow that occurs the summer, and the length of the peak flow period.

Table 2-2: Seasonal Patterns of Streamflow

Type of River July to Septembervs. Flow July to September | Monthswith the I March to June Flow Ratio (percent of annual) maximum flow

Rivers fed by glaciers 10 38 July - August and snow Rivers fed by snow and 0.99 - 0.27 40 - 17 June - July glaciers l Rivers fed by snow 0.27 - 0.18 16 - 12 April - May

Rivers fed by snow and 0.17 - 0.00 13 - 00 March - April - rains May

2.11 Riversfed by glaciersand snow where the primary source is from melting glacial ice. These rivers drain the highest elevations (including the upper watersheds of the Naryn, Kyzul-Su, and Tarim Rivers, and a number of small rivers or streams, such as the Almedin, Alaarcha, Dzhuuky, Ton, Dzheti- Oguz, and others). Floods in these rivers usually begin in the second half of April, sometimes in May, and end in October. The peak of flooding and highest water discharges are observed mostly in July and August. The duration of the high flow is 170-180 days. The water flow during this period accounts for 80-90 percent of the annual volume.

2.12 Riversfed by snow and glaciers also drain high altitude sections of watersheds, but the ratio of glacier waters is considerably less than for the previous group. The high water period for these rivers lasts from March or April until September, rarely to October, and varies from 140 to 200 days. The maximum discharges are observed in June. Rivers of this type are located in the basins of Naryn, Chu, and Talas. BackgroundPapers: Water Resource 48 Managementin the KyrgyzRepublic

2.13 Rivers fed only by snow have limited distribution in Kyrgyzstan. The average estimated height of their watersheds is 1600-2800meters (Kugart, Zarger, Donguztau, and Yassy Rivers). The high water period for these rivers begins in March and usually ends in August, while the maximum discharges are observed in May. The total duration of the high water period is from 140-180 days, with the flow for this period comprising 60-85 percent of the annual volume.

2.14 Rivers fed by snow and rain are very uncommon in Kyrgyzstan, the River being the only significant example. The high flow period starts in February or March and ends in July or August, or sometimes as early as May.

Lakes and wetlands

2.15 There are approximately 2000 lakes with a total surface area of about 7000 km2. The lakes are primarily located in basins of tectonic origin, in the highland area between 3,000 and 4,000 meters. The largest are Issyk-Kul, Son-Kul and Chatyr-Kul. Characteristics of the most important lakes and reservoirs are presented in Tables 2-3a and 2-3b. Note that the total storage, excluding Lake Issyk-Kul, is only 10 percent of the total runoff, which means that lakes have only a slight influence on redistributing flows over the year. Wetlands occur in alluvial valleys of many rivers and along the borders of Lake Issyk- Kul. The total area, however, is only 0.5 percent of the territory of the Republic.

Monitoring Surface Water

2.16 Routine monitoring of ambient surface water quality and quantity is carried out by the Kyrgyz Hydrometeorological Agency (Hydromet). The Agency runs a network of fixed monitoring sites located in all major river basins. In 1991, Hydromet made regular water quality observations at 83 cross-sections on 47 rivers, 49 locations on 4 reservoirs, and 45 locations on Issyk-Kul Lake. Samples taken from the water bodies were delivered by cars or by regular mail to two Hydromet chemical laboratories located in Bishkek and Osh. Laboratories are equipped with outdated wet chemistry analysis apparatus and apply techniques that were standard for the whole FSU. This network provides data on basic parameters (oxygen, pH, odor, color, turbidity, etc.), major ions, organic substances (COD, BOD5), nutrients, some heavy metals (Cu, Zn) and pollutants (oil and grease, surfactants, phenols, DDT, lindane, etc.). The results of monitoring are published in an annual Hydromet Report on water quality conditions where concentrations of measured substances are compared with existing maximum allowable concentrations (MACs) and data for the previous year.

2.17 Surface water quality monitoring in the zones of direct impact from pollution discharges (usually 500 m downstream of the discharge) is the responsibility of the water discharger or polluter. Usually the number of monitored parameters is limited. No quality assurance/quality control procedures are applied to check their monitoring performance. The results of self-monitoring are periodically (e.g. once in a quarter or year) checked by the central inspection laboratories of the State Committee for Environment Protection.

2.18 At present Hydromet monitoring is still in relative good order, however, that is not expected to last very long. During the last few years, monitoring capacity has dramatically deteriorated due to a sharp decrease in financing (comparative financing figures). Seven stations have been closed, and in 1994, 20 stations were partially destroyed. Regular station inspection has also been stopped because of transport problems (the seven available cars are very old). Lack of basic chemicals, spare parts, glassware, supplies, lack of cars and gasoline, etc. also contributed to the deteriorating quality of results. Background Papers: Water Resource 49 Management in the Kyrgyz Republic

Table 2-3a: Major Lakes and Other Natural Water Bodies1

No. | Name | Altitude River Basin I CA Area, Lake Area | Volue Comment I I (m) || (I.10) | (n') I

I Issyk-Kul 1606 Issyk-Kul 22080 6236 1738000 Saline

2 Sonk Kul 3013 Naryn 1120 270 2640

3 Chatyr Kul 3530 Naryn 1050 154 610 Saline

4 Aj-Kul 2937 Aksuu 30 1 57

5 Kara-Toko 2876 42 1.1 49

6 Sary Chelek 1873 Naryn 91 4.9 483

7 Kara-Suu 2022 Naryn 171 4.2 223 Saline

8 Kalkatach 2303 Naryn 99 1 21

9 Kullun 2856 Kara Darya 144 3.3 118

10 Tash-Bulak* 3540 Naryn 10 2.5 13

II Cheul-Ukuk 3048 Chui 66 1.6 34

12 Cheul-Suu* 3514 Ak Sail 488 4.5 338

13 Sarie-Chul* 3477 Naiyn 12 1.2 20

14 Okoaju-Chul* 3628 Naryn 54 1.2 6

15 Kask-Suu* 3882 Naryn 20 1 48

16 Djaul-Chul* 3770 Naryn 20 1 5

17 Suungkorchuck* 3766 Naryn 31 1.5 8

18 Ala-Chul 3532 Issyk-Kul 12 1.3 43

19 Mertbachir 3304 Sary Dzhaz 318 4.5 129

20 Besh-Tash 2994 Talas 54 0.54 6

21 Kalaa-Chul 1847 Naryn 90 0.3 2.7

22 Chul-Tur 2725 Chui 256 0.2 1.8

Total volume without Issyk-Kul 4855.5 = 4.8 km'

1/ Data from ATLAS, Kyrgyzstan (Moscow, 1987) and local expert. Background Papers: Water Resource 50 Management in the Kyrgyz Republic

Table 2-3b: Reservoirs'

No. Name | Year Built | River Basin | Vol. Area Dam He4bt

I I I I _ _ _ I 103__ (11mn) (m)

I Tjurtkul 1971 Isafa 90 6.6 34

2 Naifnan 1966 Charsai 40 3.2 40.5

3 Basar Korgon 1962 Kara-Unkyur 30 2.8 25

4 Sokulluk 1968 Sokulluk 11.5 1.8 28

S Ala-Archa 1966 Ala-Archa 39 5.2 22

6 Orto Tokoi 1956 Chui 470 25 52

7 Toktogul 1974 Naryn 19500 284 215

|8 Kirov 1975 Talas 550 26.5 83.7

| 9 Kocksai 1981 Naryn 370 12.0 110

10 Papan 1981 Ak-Buura 260 7.1 120

II Andizhan 1978 Kara-Darya 1750 - -

12 Uch-Kurgon 1964 Naryn 52.5 4.0 31

12 a Tashkumyr Naryn 250

Planned or under construction in 19852

13 Kambar-Ata - Naryn 8500 89.5 295

14 | Sokh 250 | |

15 Churjart - Chuijart 95 5.0 20

16 Arawan - Arawan 100 4.0 90

17 Chat-Barn - Talas 100 5.3 45

Total capacity (present and planned) 32,458 = 32.46 kmn

I/ Data from ATLAS,Kyrgyzstan (Moscow, 1987)and local expert.

2/ Latest year of available data. BackgroundPapers: Water Resource 51 ManagementIn the Kyrgyz Republic

B. OCCURRENCEAND CHARACTERISTICSOF GROUNDWATER

Ground Water Availability

2.19 Groundwateraquifers occur in tertiary and older sedimentaryrocks and in quaternary alluvial areas. Aquifers are recharged both by precipitation and river water infiltration. Infiltration from irrigation canals and irrigated areas also occurs. The main source of water is, however, river water. This means that groundwater cannot be considered an independentsource of water. The alluvial and piedmontareas of inter-mountainvalleys are where most of the exploitablegroundwater is found--inthe Chu, Issyk-Kuland Talas valleys. Of practical interest are also the Naryn and Fergana valleys. The latter border Uzbekistan.

2.20 Ground water is widespreadin Kyrgyzstanand is generally of high quality and suitable for all uses. The most important and abundant ground water resources occur mainly in the inter-mountain valleys in alluvial and glacio-fluvialdeposits, sedimentaryrocks of quaternaryage, and in the piedmont and alluvial cones that form the lower slopes of the mountains. Water bearing aquifers can reach depths of 300 meters or more in thickness with transmissivitiesranging from 5 to 50 m/day. The Table below summarizescurrent estimates of ground water availabilityand proven reserves.

2.21 While the total estimated fresh ground water resources are about 30 million m3/day, proven reserves in the 42 deposits that have been explored in detail total about 10 million m3/day (Table 24). As of mid-1994, about 5,900 wells have been developedin these aquifers for domestic, industrial, and agricultural water supply. The average depth of these wells is about 150 meters and the average discharge is about 15 per second or 2.8 km3. This means that only a quarter of the groundwateris used. Half of this water is used for irrigation and the other half for domestic and industrial purposes. The Vodokanals organize the exploitation and observation for quality of groundwater, as well as the AgriculturalWater Supply Service, the Kyrgyz HydrogeologicalExpedition, and separate enterprises.

Table 24: Ground Water Reserves

Nameof Oblast EstimatedReserves No. of deposits with Confirmed No. Of (m3/day) estimated reserves reserves (m3/day) existing wells Chuisk 7648 13 5553 2207 Talas 2250 4 306 245 Issyk-Kul 5803 7 2083 1078 Naryn 9154 3 41 459 Osh 2595 13 1131 1105 Djalal-Abad 1898 2 1175 806 TOTAL 29348 10289 5900

Monitoring and Management of Ground Water Resources

2.22 Systematicexploration, investigation,and monitoringof ground water in Kyrgyzstanis carried out by the State Committeefor Geology,Hydro-geological Expedition. This organizationis instrumental BackgroundPapers: Water Resource 52 Managementin the Kyrgyz Republic

in issuing water permits and advises other state institutions on aquifer protection. Applications to utilize ground water must first be approved by the Expedition and applicants will receive a "water well passport" before the Ministry of Water Economy will grant a permit. In addition to exploration, mapping, and testing of aquifers, the Expedition operates a network of 800 observation points (wells, springs, holes) of which only about 75 percent are presently operating because of loss of staff, lack of budget, and lack of spare parts. The Ministry of Water Economy also operates a network of observation wells, concentrated in irrigated areas. A number of these wells are no longer operable or active.

2.23 Ground water pollution is generally the result of worsening environmental conditions on the land caused by economic and other human activities, although some hydro-chemical changes such as increased salinity can be caused by geologic deposits along the flow path of ground water (highly mineralized water may also exist in the deeper, older parts of an aquifer). With the possible exception of the aquifers presently serving Bishkek, the volume of ground water available to meet current and future needs is adequate. Similarly, the quality of the water for all purposes including drinking is excellent, but monitoring of ground water quality is showing some disturbing trends. Long term observations of ground water quality in Kyrgyzstan shows an increasing nitrate content, mineralization, and hardness.

C. WATER RESOURCESDEVELOPMENT AND USE

Water Use

2.24 Inter-governmentalagreements among the five Central Asian Stateson the sharing of surface and ground waters restrict the volume of river flow available to the Republic to 24 percent of the average annual flow of 46.8 kin3, or 11.6 Ian3 . Water is divided in the Republicamong domestic, industrialand agriculture uses. Crop irrigation consumes the bulk of the water. Table 2-5 below summarizestotal estimatedwater requirementsbased on commonlyused norms appliedto current conditionsin each major sector in Kyrgyzstan in an average water year. Actual water use in 1992 and 1993 in each of the major river basins is summarized in Table 2-6. Actual use is about I kmn3 below the estimated total requirement, but within the allotted volume of 11.6 kM3. The largest proportion (45 percent) of the allotted 11.6 km3 , is consumed in areas draining into the Aral sea basin: the Naryn, Chatkal and Kara- Darya and Kyzyl Suu. Other drainage basins are the Chu (4.5 percent), Lake Issyk-Kul(11.3 percent), Talas and Assa (3.2 percent). The remaining six percent drains into Kazakhstanand China.

Table 2-5: Estimated Water Requirements by Sector

Use EstimatedVolume of WaterUse Percentof (million in3) Total

Agriculture, including 11,332 90 Irrigation 11.239 89 Domesticand Communal 413 3 Industry 857 7 Others 52 <1 TOTAL 12,654 100 53

Table 2-6: Actual water use by major water users in 1992-93 (millions of m3 ))

Municipal services Industry Agriculture Other Total Including River basin Years including including total including sectors ground total total energy irrigation waters urban j rural production I

Amudaria 1992 0.4 0.4 80.5 74.0 80.9 0.1 1993 - - - - - 87 85 - 87 2

|Syrdaria 1992 83.3 20.3 63 252.6 41.2 4,739.7 4,670.9 56.6 5,132.2 514.2 1993 98 33 65 236 38 4,684 4,570 53 5,071 454

Talas 1992 10.1 2.1 8.0 10.9 - 859.9 852 16.1 897.0 22.6 1993 10.0 2.0 8.0 11 - 933 915 5 959 15

Assa 1992 - - - - - 113.7 112.2 0.2 113.9 1.5 1993 1 - 1 - - 98 97 - 99 1

Chu 1992 224.4 171.42 253 818.2 477.7 2,987.1 2,925.7 18.7 4,048.4 319.0 1993 274 21 53 601 320 2,781 3,072 17 3,964 325

|Issyk-Kul 1992 36.5 24.8 11.7 14.3 - 1,346.3 1,315 8.5 1,405.6 76.8 Lake 1993 31 21 10 14 - 1,245 1,224 9 1,299 62

Kyrgyz 1992 354.7 218.6 135.7 1,098 518.9' 10,127.2 9,886.8 100.1 11,678 934.2 Republic: total 1993 414 277 137 62 358' 10,119 9,671 84 11,479 859

Comment: Volume of consumptive use in energy production accounts for 5.2%. BackgroundPapers: Water Resource 54 Managementin the Kyrgyz Republic

2.25 Irrigated agricultureconsumes about 89 percent of the total water used. (Domesticand industrial consumersuse only about 10 percent of the water). Table 2-7 summarizesland use in each of the major river basins. When these data are combined with the corresponding water-use data in Table 8, it is apparent that there is a wide variation in water use for irrigation, ranging from a low of 3,805 m3/ha in the Chu River basin to a high of 11,212 m3/ha in the Syr Darya River basin. For the country as a whole, average water use in irrigation on the 1,077,000 ha of irrigated land is 8,978 m3/ha.

Water Balance on the Major Rivers

2.26 Table 2-8 outlines the estimated water balance on each of the major rivers. Available water supply appears to be completelyutilized except in the Amu Darya River Basin. The Chu basin is the only basin for which measured outflow data is availableto check the water balance, however. For the four major river basins shared with the neighboringcentral Asian Republics (whichexcludes Issyk-Kul), the total net water use in Kyrgyzstanis estimated to be 12,720 million m3 out of a total water availability of 43,046 million i 3 . This is just under 30 percent of the total water resourcesavailable and a little more than the amount allowed under the current water-sharingagreements.

2.27 Table 2-8 on water balances shows that under the existing agreementson water-sharing, there are very limited additional water resources in the Republicfor new uses such as expanding irrigation. Water availability may be below existing estimated requirementsin some sub-basinswhere storage and regulating capacity is also limited, particularly near the end of the irrigation season. These water balances, together with the figureson estimatedand actual water use, deserve careful scrutiny, however. There may be numerous opportunitiesfor low- or modest-cost improvementsin efficiency and water conservation. This potential is evident from a cursory inspectionof water distributionin the larger cities, and in the major irrigated areas of the Chu and Syr Darya River basin. In these areas, basic improvementsin irrigation and potable water distribution infrastructure, water control, and water-use practices may result in major water conservationbenefits.

2.28 The developmentof additionalwater resourcesthrough savingsor greaterefficiency should focus on improvementsin irrigationwater use, as domestic, communal, and industrial usages combinedare only 10 percentof the total water use in the Republic. Investmentin additionaland new sources of water supply for these latter uses should be made only after water wastage and inefficienciesin these sectors are eliminated as well, however. This conservation approach will quickly prove less costly than developing additional sources which appear not to be available. It should be noted that although per capita water use may be quite low in areas where street and yard standpipes are the predominantmode of water service, there could still be substantialwaste where fittings and fixtures are in poor condition, and water leaks or is allowed to run continuously. Background Papers: Water Resource 55 Management In the Kyrgyz Republic

Table 2-7: Land categories in the Kyrgyz niver basins (thousand hectares)

Including _ _ __ River Basin Total land area Agri- Including Forests Other cultuaral aMd lands Larnds Arable Multi Hay Rangelarnd Backyards bushes year Growing vegetation

Amudaria total land 775.0 360.9 23.5 17.2 319.2 1.0 1.5 412.6 irrigated 22.6 22.3 19.2 - 0.8 1.3 1.0 0.3 -

Syrdaria total land 11,184.6 6,101.6 536.4 24.1 133.7 5,341.3 64.1 875.5 4,207.5 irrigated 407.6 402.0 297.3 23.9 3.6 28.2 49.0 5.6 -

Chu total land 3,161.9 2,269.9 454.4 13.1 24.4 1,746.3 31.7 105.0 787.0 irrigated 371.0 356.7 308.7 12.7 - 7.9 27.4 14.3 -

Talu and Assa total land 1,444.4 868.8 121.7 2.1 2.6 730.7 11.7 69.3 506.3 irrigated 115.0 108.6 90.3 2.1 1.0 4.9 10.3 6.4 -

Issyk-Kul Lake total lnd 3,700.3 1,330.5 185.4 4.9 10.4 1,113.3 16.S 124.7 2,245.1 irrigated 161.0 158.1 133.9 4.6 0.9 5.0 13.7 2.9 -

Kyrgyz Republic: total total land 20,266.2 10,931.7 1,323.4 44.2 188.3 9,250.8 125.0 1,176.0 8,158.5 irrigated 1,077.2 1,647.7 649.4 43.4 6.3 47.3 101.4 29.5 -

=. ~ = = . = = Background Papers: Water Resource 56 Management In the Kyrgyz Republic

Table 2-8: Water management balance for major basins in Kyrgyz Republic (for a normal hydrological year)

3 l ______Actual balance for 1992 (million/m ) Item I Amudaria T Talas and Issyk-Kul Syrdaria Chu Assa Lake

1. Availability

1.1 Natural river flow' 1,929 1,626.3 3,559 30,918.4 3,708.3 (long-term average) (1,930) (1,551) (3,740) (27,425) (3,525)

1.2 Water diversion (discharge to water 236.6 791 533.1 935.0 bodies), return flow

1.3 Release from reservoirs - - 2,722.0 430.2

1.4 Precipitation to lake or reservoir surface 3.9 2,090 - 3.5

1.5 Ground water inflow - 130 -

Total 1,929 1,866.8 6,570 34,173.5 5,077.0

H. Withdrawal

2.1 Ground water extraction decreasing river 0.1 12 39 229.2 133.4 flow

2.2 Water withdrawal from surface bodies (to 80.4 974.9 1,315 4,459.2 3,390.5 be used in Kyrghyzstan) (4202) (9502) (1,5002) (4,3802) (3,850)

2.3 Filling of reservoirs - - 2,567.0 445.7

2.4 Evaporation from lake or reservoirs surface - - 4,420

2.5 'Sanitary' discharge 428.9 268.1 - 4,110 920.0

2.6 Water trnsfer to other Republics - - - 274.8 152.4

Total 509.4 1,255 5,774 11,640.2 5,042.0

111. Balance

3.1 Calculated net outflow 1,848.5 879.9 - 26,643.3 955.0 (measured net outflow) - - - - (1,130)

3.2 Ground water withdrawal 77 540.7 319.0 (500)

Comments: 1. Volume of 'sanitary' discharge is considered to be equal to 75% of minimum daily discharge for the year of 95% probability of occurrence 2. ' - reconstructed 3. 2 - limit of water withdrawal BackgroundPapers: Water Resource 57 ManagementIn the Kyrgyz Republic

Development of Reservoir Storage to Regulate Water Availability

2.29 As discussed earlier, peak flows occur in April to July, with 80-90 percent of the flow occurring in the period of 140 to about 180 days extendingto Augustor September. While this correspondsto the most important season in Kyrgyzstan,low and unreliable flows are often the rule in the summer months particularlyin the latter part of the growing season. Hence, regulationof these flows is needed to ensure adequate water supplies are available over the full period needed--includingfor other purposes such as power generation. Fifteen major reservoirshave been built with a total active storage capacity of 15.6 knm3 to regulate these flows. Two of these reservoirs were built for power generationand are operated only for that purpose. Ten reservoirs have been built primarily for irrigation but also provide some municipal and industrialwater supply as well. In addition, there are 24 smaller reservoirs with storage capacitiesranging from 1-10 million m3 .

2.30 There have been reports of significantloss of reservoir storagecapacity due to sedimentation. The detrimentaleffects of deforestationand erosioncaused by overgrazing,and constructionof roads or other infrastructure,are evident while travelingin many watershedsof the Republic. There appears to be little or no systematicdata on sediment transport in the streams and rivers where this might be a significant problem, however, and no data on rates of reservoir sedimentationand its economicconsequences. The effects of stream and reservoir siltation are long-termand costly problems to rectify. More systematic monitoringand diagnosticanalysis of this problem are needed, and low-costpreventive measures should receive priority attention.

Institutional Arrangements for Water Management

2.31 As is common in many countries, the responsibilityfor developing, managing, and monitoring water resources for various purposes is divided among a large number of technical agencies. In Kyrgyzstan, the Ministry of Water Economy (MOWE) is at the apex of this group of agencies. It has no direct authority over the other agencies, but it is responsiblefor water allocation, water accounting, and for regulatingand issuingpermits for water use. The State Committeefor EnvironmentalProtection is responsiblefor regulatingthe dischargeof pollutants into the Republic'swaters, and for the collection of fees and fines for such discharges. The MOWE, togetherwith the Oblasts and Rayons, is responsible for the construction and maintenanceof irrigation infrastructure and the delivery of irrigation water. Hydromet, the State Committee for Geology - Hydrogeological Expedition, and the MOWE are responsiblefor aspects of municipaland industrialwater supply. Routine monitoringof the quantity and qualityof water is the responsibilityof Hydrometand the StateCommittee for Geology- Hydrogeological Expedition. The MOWE monitors ground and surface water quantity and quality in irrigated areas. Dischargers of pollutants are responsible for monitoring water quality within 500 m of the point of discharge. Goskompriroda,The State Committeeon EnvironmentalProtection, supervises and checks this self-monitoringsystem. The Sanitaryand EpidemiologicalService of the Ministryof Healthmonitors the quality of tap water and sanitary facilities.

Protected Watersheds

2.32 A number of areas and watershedshave been designatedin Kyrgyzstanwhere access and land use are restricted. These areas are regulated to protect water supply sources and sensitive environmental resources. The areas and their location are summarizedin the following Table 2-9. BackgroundPapers: Water Resource 58 ManagementIn the Kyrgyz Republic

Table 2-9: Protected Watersheds

RiverBasin: Reserve Oblast | TotalArea .______;(ha) Syr Darya Besh-Aral Dzhalal-Abad 63,200 Sary-Chelek Dzhalal-Abad 23,800 Naryn Naryn 59,860 Karatal-Japyryk Naryn 6,500

Issyk-Kul Issyk-Kul Issyk-Kul 18,900

TOTAL 172,260

2.33 The vulnerable character of Lake Issyk Kul must be particularlystressed. The threats to the lake include:

* pollution of the rivers flowing into the lake;

* diversion and use of the waters draining into the lake, which can negatively affect the equilibriumbetween water inflow and lake evaporation; and

* the increasedlevels of salts washing into the lake from agriculturalactivities may influence the mineral balance of the lake.

The lake has no flushing capacity, as it has no outlet, compoundingthe impact of any human-induced changesto waters flowing into it. The saline character of the water is already evident.

D. DoMESTIc, INDusTRIAL,AND AGRICULTURAL WATER USE

Water Supply

2.34 Three organizations are responsible for supplyingdomestic, communal, and industrial water to people and industriesin urban and rural areas. About64.5 percentof the total population*of Kyrgyzstan live in rural areas. Of the urban population,over one third, 38 percent, lives in Bishkek, and the balance in oblast and rayon centers. In Bishkek, a vodokanalunder the Bishkekcity council is responsible for water supply, and wastewatercollection and treatment. In the smallercities, towns and villagesthat form the oblast and rayon centers, the organization Krygyzjylkommunsoyuzdevelops, operates, and maintains water supplies and sanitation facilities. Finally, Kyrgyzselremstroyis responsible for developingpiped water supplies in rural areas.

2/ About4,430,000 in 1994. BackgroundPapers: WaterResource 59 ManagementIn the KyrgyzRepublic

Water Supplyfor Oblast and Rayon Centers, and Small Towns

2.35 KygyjylJkommunsoyuz:The State organization Krygyzjylkommunsoyuz(KJKS) develops water supplyand sanitation systemsfor oblast and rayon centers, and small towns in Kyrgyzstan. It currently provides service to 613,300 people in 45 municipalities and small towns, about 60 percent of the estimated 1,048,000 people living in urban areas outside of Bishkek. Tables 2-10 and 2-11 summarize the current extent of water supplyservice and waste water collectionand treatment service in these areas. The principle type of water service in these urban areas is household connections and hydrants or standpipeslocated in the street or yard. As indicatedin Table 2-10, about 39 percent are served through street and yard taps, and the remaining by household connections.

2.36 KJKS is responsible for the operation and maintenance of all urban and municipal infrastructurein Kyrgyzstanexcept in the city of Bishkekwhich is responsible for its own services. KJKSservices range from water supplyand wastewatercollection and treatmentto housingmaintenance, solid waste collectionand disposal, street cleaning, heat, maintenanceof trees and green spaces, road maintenance,etc. Its clients includehouseholds, industries, institutes and other state organizations, and oblast, rayon, and other local authorities. KJKS operates through two types of oblast and rayon organizations:vodokanals who are responsiblefor water supply, sewers, and waste water treatment; and combinatswho are responsiblefor all other municipal infrastructureoperation and maintenanceservices. These local units carry out all project work as well as the operation and maintenanceof facilities.

2.37 The primarysource of water supply for KJKS systems is ground water which is generally of excellentquality. The two primary sources of risk for drinking water are the deteriorated condition of the distributionsystems and the vulnerabilityof surface water sources to contaminantsin some areas. Sometowns must still rely on surfacewater that is locally vulnerableto contaminationfrom agro- chemicals, livestockmanures, and sanitary wastes. An importantexarnple of the negativeconsequences of ineffectivecontrol of landuse near raw water sources can be found in Osh. One of the principal water sources for Osh is the Ak-Buura River which is prone to sudden and damaging floods. This basin has numerouslarge livestockand farming operations, and many dachas without adequatesanitation facilities located within the flood zone. Wastes are washed into the water supply system during high waters resulting in disruption of services and dangerous contaminationof the raw water supply. In another example reported by the sanitary inspectionauthorities, 60 percent of the populationof Kala-Kulrely on unfiltered and non-disinfectedsurface water from the Kala-Kuland Kashka-Surivers, which is piped through the municipal network.

2.38 As indicated in Table 2-11, waste water collectioncapacity in the towns equals about 70 percent of the volume of water supply capacity. All the towns served with wastewater collection systems are provided with biological treatment facilities. No systematic assessment is available of the current performance and effectivenessof these treatment facilities, however, and anecdotal reports from the sanitary inspectionservice indicate that more than 50% are ineffectiveand are sources of health risks. BackgroundPapers: Water Resource 60 ManagementIn the Kyrgyz Republic

Table 2-10: Water-supply by Kyrgyzgylkommunsoyuz

Total Quantity of water intakes Quantity of Length The number the number of Name (denomination)of the capacity hydrant of water of people people using populated areas thousand (street etc. mains using water- water-pipes inside m'/day iUndergroundOpen Total water pipes) (km) pipes in the the yard and street house

Towns

Osh 132.71 8 2 10 581 260 1,180 43,347 Karakol 29.8 4 2 6 200 156 8,300 33,070 Cholpon-Ata 11.5 2 - 2 14 79.15 400 5,300 Balykchi 43.9 12 12 97 174.4 12,600 20,000 Kyzyl-Kiya 36.9 14 14 306 276.6 2,340 11,540 4.9 4 4 71 56.8 1,840 4,145 Kara-Suu 3.02 3 3 145 35.8 2,120 3,200 Jalal-Abad 4 9 9 24 176 2,723 17,633 Tokmok 24.7 3 3 454 18.6 2,120 4,250 Kant 108.7 2 2 49 35.7 320 700 Kara-Balta 7.8 5 5 260 125.8 1,210 18,430 Talas 26.0 - 1 71 71.0 200 1.234 Naryn 9.92 1 1 2 55 62.3 33,000 2,000 15.6

Total on towns 455.45 68 5 73 2327 1,668.15 68,353 164,849

VillaRtes

Gulcha 2.57 1 - 1 78 21.5 1,230 2,100 Isphana 7.1 5 5 47 35.0 848 1,940 Batken 9.2 5 5 190 64.9 1,340 2,420 Knowkat 8.64 1 2 3 180 53.0 2,120 4,130 Kara-Kuldga 1.66 5 - 5 102 42.4 1,180 3,244 Pokrovka (Jety-Oguz Region) 4.8 2 2 190 51.4 6,540 4,700 Typ 7.5 1 1 20 89.5 5,390 6,100 Teplokluchenka 2.7 - I I 110 75.3 5,000 4,920 Bokonbaevo 2.8 3 - 3 80 30.3 5,700 Ala-Buka 7.5 1 1 2 6 11.6 585 1,382 Suzak 6.55 3 - 3 16 15.0 370 3,900 Karavan 7.3 4 4 231 83.5 1,120 2,200 Lenin-Jol 7.68 2 2 106 44.4 800 1,600 Chatkal 1.6 - 1 23 13.2 2,940 Kazarman 4.0 1 1 74 20.2 3,234 Chui 9.1 1 1 68 27.6 1,100 2,400 Lebedinovka 3.8 1 1 94 47.8 1,200 2,300 Sokuluk 7.7 1 1 86 67.3 270 6,580 Belovodskoe 11.2 2 2 288 83.8 3,110 7,140 At-Bashi 1.7 - I 1 54 18.0 5,200 500 Chack 2.3 - 2 2 53 14.4 2,400 1,200 Kochkorka 2.4 1 1 54 36.0 3,200 2,000 Baetovo 3.0 1 1 45 22.7 2,440 1,150 Kok-Oy 2.9 1 I 64 25.0 150 503 Kyzyl-Adyr 10.0 2 2 45 49.95 180 900 Pokrovka (Mains region) 4.5 1 - 62 33.0 195 322 Shekhphtar 1.56 - 1 4 10.2 52 596

Total on villages 141.76 54 2370 1,086.95 578,994 64,227 Background Papers: Water Resource 61 Management In the Kyrgyz Republic

Total Quantity of water intakes Quantity of Length The number the number of Name (denomination) of the capacity hydrant of water of people people using populated areas thousand (street etc. mains using water- water-pipes inside m'/day Underground Open Total water pipes) (km) pipes in the the yard and street house

Settlements (kind of a very small town)

Kyzyl-Gar 2.3 I 1 13 41.7 2,200 Shamaldy-Sai 6.0 I 1 4 29.0 - 2,769 Toktogul 1.89 I 1 82 52.64 216 3,923 Bystrovka 11.5 1 1 127 138.6 1,960 2,310 Ivanovka 3.8 1 1 140 30.8 1,310 2,790

Total on settlements 25.49 5 366 292.74 5.686 11,792

Total on Kyrgyzjilkommunsoyuz 622.7 132 5.063 3,047.84 131,933 240,868

Table 2-11: Sewerage Provision by Kyrgy7jilkommunsoyuz

Name of populated areas | thousand m/24 hours (krn) Treatment

Towns

Jalal-Abad 36.65 62.75 Mechanical and biological treatment

Tokmok 36.5 36.4 - -

Kant 3.0 9.0 - | Kara-Balta 24.5 12.7 - | Osh 100.0 133.1 - | Kyzyl-Kiya 25.0 12.0 - - Naryn 6.0 18.8 - | Karakol 22.0 30.3 - | Cholpon-Ata 36.0 21.1 - | Balykchi 34.0 42.1 - | Talas 6.0

Total 323.65 384.25

Settlements (kind of a very small town)

Shamaldy-Sai 1.728 11.0 - | Toktogul 5.6 12.0 - |

Total 7.328 23.0

Villages

Shekaphtar 0.2 5.22 Belovodskoe 0.4 5.1 Karavan 3.98 Batken 0.4 9.0 Teplokluchenka 0.2 2.2

Total 1.2 25.5

Total on Kyrgyz-Jilkommunsoyuz 332.178 432.75 BackgroundPapers: Water Resource 62 ManagementIn the Kyrgyz Republic

2.39 KJKS water supply and waste water operations are rinanced through water tariffs and fees paid by its clients for services. In the case of households, water charges are paid as part of a lump sun charge paid to the local communal departmentfor municipal services. Domestic tariffs for water and sewer services are establishedby local authoritiesbased on the accounts of the local unit of KIKS which are regulatedby the State Committeeon Prices who unfortunatelydo not allow the cost of maintenance of existingfacilities to be includedin the rate base. Only emergencyrepairs are includedin KJKS's rate base. Tariffs negotiatedwith industrialenterprises take into accountthe underpaymentby domesticand municipal consumers, which results in a significantcross-subsidy by industry to these other consumers. At present, however, tariffs cover between 50 and 100 percent of real expenses. Financial deficits are currently very large--32,000,000soms and growing.

2.40 An estimated 70 percent of KJKS's service network is in poor condition and needs rehabilitation, repair, or replacement. There are no funds to install additionaldisinfection equipment where it is needed or to buy necessarychemicals for existingunits. If current tariffs reflected the full cost of operationand maintenance, it is believed that few householdscould afford to pay the water charges.

2.41 Water Supply in Rural Areas. The State organizationKyrgyzselremstroy develops piped water supply systems for rural people in Kyrgyzstan. The extent of the current piped water service in rural areas is summarizedin Tables2-12 and 2-13. The countryhas been implementinga program to expand piped water supply for many years achievingthe present estimated coverageof about 47-50 percent of the rural population. The remaining villages, totaling about 634, still depend on open reservoirs and irrigation canals for water supply. About 72 percent of the 2.5 million rural populationare presently served by smallpiped water supplysystems. About 97 percent of the rural piped service is provided by 770 ground water wells supplying 662 water mains averaging 14 km in length. These mains supply 26,814 street hydrants or standpipes. About half of this system was built prior to 1970. It is reported that barely 10 percent of the previous number of staff are availableto monitordrinking water quality in this highly dispersed system. The lack of budget at Kyrgyzselremstroyhas resulted in major reductions in the expansion of coverage to about 25 percent of its former rate. In addition, untrained personnel operate and maintain many systems.

2.42 Industrial Water Use. Industriesuse about sevenpercent of total water used in the country. The total water used was 862 million m3 in 1993, including601 million m3 in the Chu River basin, and 236 million m3 in the Syr Darya River basin, mainly in the Osh and Djalal-Abadregions.

AgriculturalWater Use

2.43 As with many parts of the domestic water supply distribution system, key elements of the irrigation infrastructureof the Republicare old, includingpump stations, diversion works, and reservoir facilities. Performanceand function of the water supply system are deterioratingbecause of the lack of maintenance,repair, and replacement. Agriculturalproductivity is much higher on irrigated lands, and agriculture contributes about 30 percent of the GDP. Therefore there are considerableeconomic costs for the Republic when the water distribution system functions inefficientlyand below capacity. 63

Table 2-12: Rural water supply in the Kyrgyz Republic (excluding regional centers)

Name of Oblast Total number of Length of The head-work Including surface Water-supply The years when water-mains were buildd Street water niral water mains water-supply water-supply water number wells 19Hydrants km intake Before 1960 1961-1970 1971-1994l

Chui 192 3,061.5 246 5 230 303.7 1,610.2 1147.6 8,884

Issyk-Kul 104 1,250.0 120 3 119 97.7 559.2 593.1 4,380

Nalyn 70 735.7 69 - 42 48.2 252.0 435.5 2,206

Osha 138 2,353.5 225 8 209 169.5 886.8 1,297.2 5,982

Dhalal-Abad 106 1,519.4 117 7 110 63.0 468.4 988.0 3,083

Talas 52 683.3 53 60 88.9 239.2 355.2 2,279

Source: Appendix No.2 to letter 'Kyrgyzselremstroy' from 12.08.94. 64

Table 2-13: Central water supply in rural areas in the Kyrgyz Republic

Number of rural populated areas Number of constant rural population Funds necessary to maintin technical Total number of rural (thousand people) service of existing water mains in a year Oblast water mains (in thousand soms) Total No central water-supply Total Not providedby cental

I ______I ______I ______I__ w ater-supply In all the republic 9,603.4 1,736 737 2,427.0 672.8 16,737.0

Chui 3,061.5 318 22 497.0 9.5 5,333.7

Issyk-Kul 1,250.0 183 50 241.5 42.8 2,177.8

Naryn 735.7 132 52 168.3 45.3 1,281.7

Osh 2,353.5 611 359 887.4 342.3 4,078.7

Jalal-Abad 1,519.4 404 227 483.5 196.0 2,674.6

Talas 683.3 88 27 149.3 36.9 1,190.5

Total 19,206.8 3,472 1,474 4,854 1,345.6 33,474.0

Source: Appendix No.1 to letter "Kyrgyzselremstroy" from 12.08.94. N 01-65

Note: Regional centers where Vodokanals provide services to maintain water supply are not included in the data on providing the rural people by drinking water. All the rural water-mains are included, including water-mains built before 1970 (45% of all rural water-mains). All of them are old and need reconstruction, but they are still working. BackgroundPapers: Water Resource 65 Management in the Kyrgyz Republic

2.44 Expenditures on maintenance and repairs to the irrigation system have declined from 56 percent of the estimated expenditure requirements in 1991, to 9 percent in 1992, and 5 percent in 1993. Canals are cleaned less often, water control structures are not repaired, and canal capacities and the volume of water delivered have declined. The budget for new construction in the irrigation system was 512.9 million rubles in 1992, divided among the oblasts (77 percent) and MoWE (23 percent); the corresponding budget for operation was 444.9 million rubles including 133 million rubles for capital repairs. In 1993, a budget of 285 million soms was agreed upon with the State Committee for the Economy, but only 60 million soms were allocated, and 30 million soms actually provided--only enough to pay salaries. Expenditures on maintenance and repairs have declined from 56 percent of the estimated requirements in 1991 to 9 percent in 1992, and 5 percent in 1993. While increased efficiency and restructuring of water sector institutions, infrastructure, and mode of operation are needed, failure to adequately fund operation and maintenance is a costly and short-sighted policy in such an economically vital sector.

2.45 A new water law was passed by the Jogorku Kenesh in the fall of 1994. The new law strengthens the legal basis for water management and the regulation of both water quality and water use. A provision to begin the gradual recovery of state costs for infrastructure construction, operation, and maintenance costs was eliminated, however, for agriculture and forestry water uses. Therefore, the MOWE has no means to assess water charges to recover even a part of its costs at present. It also cannot reorganize irrigation to decentralize responsibility for routine maintenance to the farmers or local irrigation organizations, such as water-user associations or farmer-owned irrigation districts.

E. THREATS TO THE QUALrrY OF RAW WATER SUPPLEES

2.46 Nearly 90 percent of all drinking water provided by centralized pipe systems, and a high proportion of industrial water, is supplied from groundwater. The observed quality of freshwater from underground sources used in centralized distribution systems in urban and rural areas meets the present state standard for drinking water with respect to physical, chemical, and bacteriological parameters. The water is usually not treated before distribution. Long term records reportedly indicate disturbing trends, however, including worsening ground water quality near major cities such as Bishkek and Kara-Balta. Nitrate concentrations have risen steadily, exceeding the maximum of 45 mg/l in several observation wells. Bacterial pollution of open reservoirs and water channels exceed the standards by 10-300 times in some areas.

2.47 The unsatisfactory sanitary and technical condition of many raw water intakes is also contributing to the deterioration of raw drinking water quality. Efforts to enforce sanitary protection zones in areas near surface water intakes or where water infiltrates into the aquifer have proven ineffective--uncontrolled construction of homes without sanitary facilities or connection to sewers, expansion of livestock operations, laundries, storehouses for agro-chemicals and fertilizers, and unsafe disposal of liquid and solid municipal and industrial waste continues to expand in an unregulated manner. Sanepid data indicates that more than half of all waste water collection and treatment systems are ineffective or inoperable. Their inspections also show that municipal solid waste is not collected in a timely manner, and over 90 percent of all municipal solid waste disposal sites do not meet sanitary standards. These conditions contribute to the steady increase in untreated pollution entering the environment and infiltrating into underground aquifers and surface water channels. BackgroundPapers: WaterResource 66 Managementin the KyrgyzRepublic

Threats to GroundWater Quality

2.48 Contaminationof the upper part of many aquifers with substancessuch as heavy metals, oils, and sanitary wastes is extensivein areas near industrialsites and cities. The effect of these pollution sources is to create a plume, or layer of low quality, contaminatedwater overlying the deeper zones of good quality water that is being withdrawnby water supplywells. Unlike immnisciblefluids such as oils, which would tend to remain in this shallow zone floatingabove the good quality water, soluble substancessuch as heavy metals and nitrates gradually diffuse throughout the aquifer eventually contaminating it to dangerousconcentration levels if the infiltrationof pollutionfrom the surfacecontinues. Hence, the long term importanceof pollutionprevention even in those cases where pollution already exists.

2.49 Agriculture, including intensive irrigation and concentratedlivestock farming, is also been an important source of pollution. An example of the consequences of uncontrolled exploitation of groundwaterhas been observed in Osh and Dzhalal-AbadOblasts, where over-pumped irrigation wells combinedwith heavy municipalwater demand have caused the intrusion of saline ground water into the aquifers. In the Bishkekarea, nitratescontaminate the Alaarchi aquifer, which suppliesabout 60 percent of the city's water supply,down to depths of 100-150m. Concentrationsexceeding the present maximum allowableconcentration (MAC) (45 mg/l) extend over about 25 km2 of the aquifer, and concentrations ranging from 22 to 45 mg/I have been observedover about 80 km2. In the other aquifer servingBishkek, Orto Alysh, a steady trend of increasing nitrate concentration has been observed. The Bishkek Vodokanal, for example, observed an increase from 21.6 mg/l to 26.5 mg/l, about 20 percent, in the Orto-Alyshaquifer between 1992 and 1993. Elevated concentrationsof Cr6 ' are also being observed near large industrialsites locatedover the Alaarchi aquifer.

2.50 The principle sources of groundwaterpollution threats include:

3 unsafe storage and disposalof toxic and other industrial wastes, includingwaste oils, other organic substances,and sanitary wastes by industries;

3 the poor state of urban sewer systemswhich leak sanitary wastes into aquifers;

* disposal of municipalsolid wastes in unsafe dumps from which organic wastes are leached into the aquifer; and

* poorly maintainedand unsafelyconstructed household latrines, especially in newlydeveloping parts of the city where sewer services is not available.

2.51 The aquifers supplyingBishkek are under considerablepressure and will need to be expanded or supplementedby a new and additional source over the next 10-20 years (an expansionof the Alaarchi well field has already been approved). A major new field has been identified, Issik-Atainskoe,with a capacitynearly equal to the two existing fields. Developmentof this new field would avoid the growing problemsof managingthe pollutionof the existingaquifers, but at considerableexpense. The high cost of shifting prematurely to a new source before it is needed to meet real growth in demand should be comparedwith the cost of better operation of the existing well fields. Improved operations would be directed towardpreventing the intrusionof the contaminatedwater into the deeper, exploitedportions of the aquifer, and greater efforts to control pollution from industrial, municipal, irrigation, and livestock sources. In addition, the reported high losses and unaccounted-forwater in the present municipal distributionsystem should be reduced before major investmentsto expand supply are undertaken. BackgroundPapers: Water Resource 67 Managementin the Kyrgyz Republic

Pollution of GroundWater Near Kara Balta

Ground water of the West Chu aquifer in the area of the major industrialcity of Kara Balta has been subject to serious contaminationby industrialsources, includingsugar and rug factories, and the huge industrialassociation Yuzhpotymetat. The aquiferis particularlyvulnerable because it consistsof highly permeablerocks, with little natural protection,and a lack of pressure in the top and middle parts of the dischargecone. The aquifer is used by the Vodokanalto supply drinkingwater to Kara Balta and the surroundingtowns and villages.

Contamination,detected in several parts of the aquifer, has resulted from leaching and infiltrationof industrialtailings. The pollutedwater has the form of a pear-shapedplume elongatednorth-south along the directionof flow, and presentlyextending to a depth of about 150m. The tailings cover an area of about 240 ha and have accumulatedover a periodof 35 years. Despitethe installationof five extraction wells to remove leachates(which have never functionedat full capacity)and the lining of some newer sections of the tailings to prevent infiltration, the concentration of pollutants in the ground water remainsextraordinarily high: TDS (4.6 gIl), sulfates (3.5 g/l), nitrates (370mg/I), nitrites (100 mg/I), ammonia (325 mg/I), Mn (200 mg/I), and Mo (4.4 mg/I). Remarkably, no negative impact on the major Vodokanalwater supply wells has yet been detected.

2.52 Greater use of the shallower, sometimes polluted groundwater for technical or non-potable uses for which it is suitable would also ease the pressure on the aquifer and conserve high quality water for drinking purposes. About 130,000 m3 of water per day are already withdrawn for these uses in Bishkek.

Threats to Surface Water Quality

2.53 Most surface water bodies in Kyrgyzstan have low levels of pollution. Observations in all river basins show an adequate oxygen regime (concentrations are above 5-6 mg/l) and low content of organic and nutrient substances (BOD5 is usually below 2-3 mg/I, nitrates below 1 mg/l). River water is especially clean, sometimes even pristine, in the upper parts of Naryn and Amu Darya Rivers, and other mountainous rivers.

2.54 Water in the drains, canals, and rivers near cities and industrial areas is often used by nearby households for washing and other non-potable uses and by children for recreation and sometimes drinking. This water is generally very badly contaminated with sanitary wastes, livestock manures, and industrial toxic and hazardous wastes. Such "hot spots" are located in most populated Chu river basin, lower sections of Kara Darya and Naryn tributaries in Osh and Djalal-Abad Oblasts, and the Tyup rivers flowing into Issyk-Kul Lake. Elevated concentrations of nitrites (up to 0.2 mgN/l), ammonia (1 mgN/1), oil and grease (0.5 mg/I), phenols (0.001 mg/1) and pesticides (0.002 mg/I) have been detected in these rivers.

2.55 As noted earlier, many small towns and villages must still rely on surface water supplies that are particularly vulnerable during spring floods and infrequent but very intense summer rains. During summer and fall when flow of the small and medium sized rivers is declining or very low, the assimilative capacity of these rivers is also low and the health risk associated with biological and other contaminates very high. The Sanepid service has reported micro-biological contamination up to five times the standard, and intestinal disease microbes 300 times normal. BackgroundPapers: Water Resource 68 Managementin the Kyrgyz Republic

2.56 In summary, the main sources of these threats are:

* the poor condition of municipal sewer systems, and the poor performance of existing biological treatment facilities;

* improper disposal of municipal solid wastes that allows leaching of contaminated liquids into nearby rivers and drains;

* unsafe handling and storage of livestock manures; and

* improperly stored toxic wastes, and the absence of adequate pre-treatment of industrial liquid wastes.

SurfaceWater Quality in the Chu River Basin

The Chu River is consideredone of the mostpolluted in Kyrgyzstan,in large part because of the cities and industrialsites located along its banks. Data were collectedby Hydromet from the end of 1960s unto 1991 on some of the most impactedriver sites. These data were used for analysesof long-term surface water quality changes. Six sites were selectedon the Chu river upstreamand downstreamof cites (Tokmak,Milyafan, Vasilyevka, Nizhne-Chuyskiy); two sites were selectedon the Alaarchariver (upstreamand downstreamfrom Bishkek),and two sites were located on the rivers Alamedin.Records of major ions (Ca, Mg, HCO3, SO4, Cl, TDS), nutrients (NH4, NO2, NO3, P04 , Si, Fe), organic substances (COD, BOD5), and pollutants (oil and grease, surfactants, phenols, Cu and Zn) were investigated.

Non parametric statisticswere used (SeasonalKendall slope estimateswhich are the most appropriate for water quality data analysis). The reliabilityof available data is questionable,however, particularly in the case of pollutantsfor which analytical techniqueschanged during the period. Data on the major ions, nutrients and organic substancesare more consistent and reliable.

The general conclusiondrawn from the analysesof these records is that during last 10-15 years basic surface water quality in the Chu basin has not deteriorated. Moreover, in some cases clear improvements can been observed. This is evident in the measured concentrations of organic compounds(COD and BOD,) which decreasedor remained stable for all studied sites. No clear trend can be establishedfor nutrients: concentrationsof phosphatesand ammoniahave tended to decrease, while concentrationsof nitrite and nitrate are stable or slowly increasing. Concentrationsof total dissolvedsolids did not changebut chloridesincreased in fiveof the six sites on the Chu river. Almost all pollutantrecords showed declining or static concentrationsand current concentrationsare usually below MACs.

F. DRINKING WATER QUALITY

2.57 Drinking water tested at municipal taps is increasingly failing to meet the applicable standards, due to the lack of protection of water sources, and lack of maintenance of distribution pipes and related facilities. This condition is a major factor in the observed increase in viral hepatitis and intestinal disease with unstated aetiology. BackgroundPapers: Water Resource 69 Managementin the Kyrgyz Republic

2.58 Tests of drinking water in Issyk-Kul exceed the norm for bacteriological contamination in 46.5 percent of the tests, and departures from the norm in Sulyukta are 40.8 percent, both well above the average for Kyrgyzstanas a whole. Other locations with similar conditionsinclude Tasn-Kumyr(25.5 percent of the tests), Kok-Jangak(28.8 percent), Kala-Kul(23.6 percent), Ala-Buka(41.2 percent), and Talas (36 percent). In these areas, the Saniped reported 18 discharges from waste water treatment facilities into open reservoirs and upstream from intakes to the centralizedpiped water supply systems.

G. CONCLUSIONSAND RECOMMENDATIONS

2.59 Somekey conclusionsof this brief assessmentof current issuesconcerned with water management and water supply are described below. Priority actions are proposed in three areas - policy reform, institutionalstrengthening, and targeted interventions. They are summarizedin Table 2-14.

Conclusions

2.60 Many detailed findingsand conclusionsare included in the assessment. Summarizedbelow are the major conclusions:

- There are sufficient quantities of water of excellent quality available for domestic and industrialuse for the foreseeablefuture. Water availabilityis likely to become a constraint to expanded irrigation, land reclamation,and improved productivity of irrigated areas, however, unless there are significantimprovements in efficiencyin the distribution and use of water on farms, and a major effort made to increasewater conservation.

i The regulation of landuse and enforcement of pollution prevention has been seriously inadequate in areas where human activities could directly contaminatewater sources. This has resulted in negative heath impacts in the form of increasedmorbidity and mortalityfor populationswith vulnerableraw water supplies--particularlyin communitiesthat rely on open water sources.

- The present system for financing maintenance, rehabilitation, repair, replacement, and modernizationof infrastructurefor drinking water, and irrigation water supply is inadequate. In most areas, the distributionsystem is alreadyover 30 years old--includingintakes, pumps, disinfections equipment, canals, gates, and distribution pipe systems. Major health and economiccosts are already evidentand will inevitablygrow as the present infrastructureages, and performanceand functions deterioratefurther.

* The key water managementorganizations on whichthe Republicdepends for soundprotection and managementof this vital resource have been seriously weakened. Reduced size and improved efficiency of government organizations have been legitimate aims during the transition period. The present loss of highly trained staff (especiallyyounger staff) and the lack of equipmentand maintenancewill likely leavethese organizationspermanently crippled. This will have direct health and economnicconsequences as the water supply deteriorates.

Recomnnendations

2.61 The collapseof the Soviet Union and the subsequenteconomic and institutionalchanges have set in motion an erosion of basic water managementand sanitation infrastructure. The failure to maintain infrastructurethat is essential for the health and economicwell-being of the populationhas important BackgroundPapers: Water Resource 70 Managementin the Kyrgyz Republic

near term health and economiccosts, and long-term financial consequencesthat should be considered now. Massive investments in sophisticated technology are not needed to reverse this process. Instead, the emphasisshould be on the gradual introductionof new institutionalarrangements, on halting the brain drain from public sector organizations, and on simple, well known and low-cost investments in the impressive water managementand sanitation infrastructurethat already exists in the country. There should also be a modest program to expand these services to vulnerablegroups.

2.62 The Table below outlines a limited number of recommendationsthat focus on addressingthese needs. The recommendedactions and interventionsshould complementthe NEAP recommendationsfor improvingmonitoring and assessmentof public health. In addition, the three types of action outlined below are closely interrelated, and should be integrated and coordinated with each other to the extent possible.

2.63 Policy Reforms. The recommendationsfor priority policy actions focus in particular on the issue of mobilizing local funds to finance essential infrastructure operation and maintenanceservices for domestic, industrial,and agriculturalwater supply. Localgovernment organization and financeis a large issue the Government will need to confront, but immediate measures can to be identifiedto mobilize funds for rehabilitationand essential maintenance,and operations includingthe purchase of chemicals. The gradual increase in domestic and industrial tariffs, and the gradual introduction of water chargesfor delivery of water to farmers are essentialsteps.

2.64 InstitutionalStrengthening. The two recommendationsfor institutionalstrengthening focus on (i) improvingthe process for priority-setting,planning and capital budgetingby strengtheningthe linkages among different agenciesto ensure the flow of timely health and economic impact data, and (ii) preserving and utilizing the expertise and institutionalexperience of the Republic's water managementorganizations:

(i) As financingfor rehabilitation,repairs, and extensionsof service into new areas is extremely limited, priority-settingmust be rigorously based on the relative impact of different choices on health and the local economy. This type of benefit-analysisrequires good quality and timely data on such things as water quality, public health, flow distribution, water shortages and outages, and production in irrigated areas.

(ii) The governmentmust make every effort to ensure that the water managementorganizations are fully functional and that key technical people remain with these organizations. The restructuringthese organizationhave undergone was necessary in part, but the government shouldtake urgent steps to ensure that these economicallyvital organizationsare not crippled. The economy and the health of the people will suffer if action is not taken.

2.65 TargetedInterventions. Targeted interventionsare recommendedto address the highest priority problems of water supply contamination, and vulnerable population groups. Interventions could include completion of projects already underway; rehabilitation,repair or replacementof facilitiesthat are not functioningproperly, includingpump stations, wells, pipe networksand mains, intakes, reservoirs and storage tanks, irrigation and reclamationsystems, treatmentworks (disinfectionequipment), sewers and private sanitation facilities; and purchase of spare parts and chemicals. Priorities would be determinedbased on the project's impact on the followingfour factors:

* Health. The proposed projects shouldproduce tangiblehealth impacts in the form of reduced incidence of water borne disease, decreased child morbidity and mortality, or diminished presenceof high risk factors. These includebacterial contamination, nitrates, or other factors BackgroundPapers: Water Resource 71 Managementin the Kyrgyz Republic

for which the exposures under current conditions at the specific location can be shown to represent a high health risk.

* Productivity. The projects or interventionsshould produce economicbenefits in terms of increasedagricultural productivity or income, reductions in the cost of water supply, or an increase in local employment(particularly an intensiveuse of local labor).

* Equity. The projects should employ low-cost measures using local materials, businesses, contractors, and labor, and be directed toward areas with especially low income.

* Technicaland FinancialFactors. Proposedprojects should demonstratethat they are based on a least-cost approach with respect to investment, operation, and maintenance; can be implementedquickly with existingtechnology and available materials; are capable of being implementedin stages, and address problems which are recognizedas very high priority. The size of each individualproject would be restrictedin order to spread the limited available funds to all oblasts. The proposed projects should demonstrate that local authorities are committedto the plan, and are developingthe necessary financialmechanisms to fully fund operation and maintenanceof any infrastructurewithin a reasonableperiod of time.

2.66 An inter-ministerialor multi-agencyteam should form an emergency working team for two purposes. (i) An integratedwater planning/managementstudy should be undertakento review available data (which unfortunatelyare often inconsistent),identify data gaps, and gain an interdisciplinaryover- view of the present condition of the water management and supply system, including operation of reservoirs, etc. An integratedwater resourcepolicy plan whichbalances the needsof the differentsectors and interest groups concerned with water supply, such as agricultural, industry, hydro-power, and municipal services. (ii) The multi-agencyteam would solicit, evaluate and select proposals from the concerned agencies and local units of government. They would issue guidelines for identificationand preparationof project proposals, develop, describe, and issue criteria for projectevaluation and selection, visit project sites, and compile and possiblycollect data on which to base the evaluationof subprojects. The proposal guidelinesshould includewell-defined procedures for preparation of the feasibility study, includinga standardized, and simplified report format.

2.67 This would be a multi-year program. Each year, the working team would select the projects to be included in the priority program and submit this "umbrella" proposal to the central governmentfor support. The team would also notify the concernedlocal governmentson the outcomeof their proposals and the financial arrangementsthat will need to be made by the recipients. It is anticipatedthat central governmentgrants for selected projects will be cost-sharedby the concernedlocal government. Donor assistance may be sought to finance technicalassistance for the initial one or two years of the program, and for longer-termsupport for investmentfinancing. Considerationshould also be given to supporting a village grant and/or credit program to support essential works and incomegenerating activitiesat that level.

2.68 Donor assistancewould also be soughtto financeessential and complimentarytechnical assistance needs which might include:

* Assistance in developingmunicipal and oblast governanceand financial reforms.

* Assistance in strengthening health assessment at the oblast and rayon level, including strengtheninglocal units of Sanepid,Goskompriroda, GoskomGeol, and MOWE monitoring capability, and establishingjoint information systemsin the related areas. BackgroundPapers: Water Resource 72 Management In the Kyrgyz Republic

* Assessmentof the rehabilitationand modernization needs for irrigationwater distribution,and preparation of studies and proposals to gradually reform agricultural water pricing and increase cost recovery in the sector.

* Developmentof cost-managementprograms for the organizationsin charge of maintenance of municipal and irrigation services.

* A wide range of training and capacity-buildingactivities at the oblast, rayon, and municipal levels including, for example, the introduction of financial managementsystems such as market-systemaccounting procedures at the municipal level.

Pilot and DemonstrationProjects.

2.69 To deal with the most urgent problems, and to demonstrate immediateaction at the local level a number of pilot and demonstrationprojects should be consideredwhich demonstrate new approaches, materials, and techniques, and have immediate local benefits.

* Low-cost sanitationdemonstration projects including the introductionof new latrine and septic tank designand constructionmethods, emphasizing opportunities for incomegeneration (from constructionof slabs, latrine construction,etc.) and comnmunityparticipation.

3 Improved operation and performance of existing wastewater treatment plants; introduction and pilot testingof lower-cost (in terms of investmnent,operation, and maintenance)treatment systems for simalltowns and villages with piped water and sewer service. BackgroundPapers: Natural Resources 73

3. NATURAL RESOURCES

A. AGRICULTURE

3.1 Overview. The Kyrgyz Republichas about 1,200,000 ha of arable lands, which is equivalent to 7 percent of the total territory and 13 percent of the manageablelands (excludinglakes, rivers, glaciers and mountainrocks). Approximately850,000 ha are irrigated (70 percent of the arable lands), although a 1993 estimate reducedthis area by 100,000 ha based on the poor state of the irrigation networks. The principal crops are cereal (winter wheat, spring wheat, winter barley, and maize), feed crops (maize for silage, alfalfa, spring barley), potatoes and vegetables(tomato, cabbage, melon, pepper), and other crops (cotton, tobacco,sugarbeet and silk) (see Table 3-1). The crop sector contributes40 percent of the gross value of agricultural output (livestock is valued at 60 percent of the output). The entire agricultural sector comprises 30 percent of Kyrgyzstan'sGDP. In 1990, about half of the total value of exports was from agriculturalproducts.

3.2 The main crop producingregions are the Fergana Valley in Osh and Dzhalal-AbadOblast; the Chui and Talas valleys; and the Issyk-Kulbasin. About 625,000 ha were cropped with cereals in 1993, of which almost half were irrigated. One third of the cereals are grown in Chui Oblast while the remainder was evenly distributed over the other regions. Chui is also the main area for sugarbeet production. Cotton is mostly grown in the Fergana Valley, rotated with alfalfa (35,000 ha). Potatoes and late cabbage are grown in Issyk-Kul, while early vegetablesare primarily grown in the Fergana Valley. Fruit orchards can be found on the lower slopes in all regions.

Table 3-1: Cropped area (irrigated and rainfed) for the majior crops (1993)

Crop TotalArea IrrigatedArea | RainfedArea (ha) (ha) (ha) Cereals 623,800 326,400 297,400 Maize 40,700 29,100 11,600 Cotton 20,300 18,800 1,500 Tobacco 22,200 20,800 1,400 Sugarbeet 12,100 11,000 1,100 Potatoes 26,600 8,900 17,700 Vegetables 14,900 7,900 7,000 Watermelon 1,500 1,100 400 Maizesilage 71,500 68,500 3,000 Lucerne 350,000 225,400 124,600 Fruits/grapes 37,400 14,200 23,200 Total 1,221,000 732,100 488,900

Source: TechnicalWorking Group on Agriculture(Ministry of Agriculture) BackgroundPapers: Natural Resources 74

3.3 Yields are generally low on irrigated lands by world standards, but they are about three times higher than yields in non-irrigated areas. Average yields for irrigated cereals (wheat and barley) are about 3.5 to 4 ton/ha, while average rainfed yields are in the range of 1.2 to 1.5 ton/ha. In dry years, rainfed crops may even fail completely. Cotton yields generally range from 2.2 to 3.2 ton/ha. Sugarbeet production is rising again and the average yield for sugarbeet is now about 25 ton/ha. In the mid- eighties, yields had declined to less than 10 ton/ha due to nematode infections and soilborne diseases, as a result of neglecting crop rotation requirements.

3.4 Agricultural policy has been directed towards national self-sufficiency in cereals for food security, with a number of supporting regulations such as compulsory marketing and centrally controlled farm management. In the present economic situation, however, credit is difficult to obtain, and farms are turning away from commercial production to local food self-sufficiency. This trend is evident in the fall in marketed and processed output, which is greater than the fall in actual production. In addition, the restructuring process of the 480 collective (Kolkhoz) and state farms (Sovkhoz) has been rather slow, further complicating agricultural policy reform efforts. Out of the 480 collective and state farms, only 165 have been reorganized so far, and many of these reorganizations have resulted in little or no change in the management structure.

3.5 Shifting crop mixes. Farm prices are now fully liberalized. One of the goals of freeing the price of wheat, for example, is to encourage a shift in consumption to imported wheat which can be produced more cheaply in neighboring republics. Then the good irrigated soils of Kyrgyzstan's valleys could be planted with higher value crops which can be sold locally and in adjacent countries. Even without such policy interventions, a collapse of trade, increased use of barter, payment-in-kind, and a movement to local food self-sufficiency are changing the cropping mix. It is difficult to project what all the changes will be or in which crops the Kyrgyz Republic has a comparative advantage under a market system. These changes may have unforeseen environmental repercussions, however--both positive and negative. For instance, wheat and other cereals require relatively few chemical inputs compared to cotton and vegetables, so watersheds which currently have low chemical inputs may undergo degradation as the crop nmix changes. To replace the formerly subsidized sources of feed, former hay meadows on fragile soils and steep slopes are now being planted with grains--increasing erosion in these areas. Potential changes such as these need to be identified and assessed for their environmental impact.

3.6 The use of agro-chemicals has declined steadily from 7,303 tons in 1980 to 1,900 tons in 1993 (see Table 3-2). This would be equivalent to an average use of 5.2 kg/ha in 1980 and 1.4 kg/ha in 1994. These figures are comparatively low--average use of agro-chemicals in the USA is 6 to 7 kg/ha, and in the European Union is 6.6 kg/ha. The reasons for the decline in chemical use include increasing costs of both services and materials, severe state budgetary constraints and a weak supplier economy. Of the agro-chemicals used, insecticides and herbicides are considered the most harnful to the environment.

Table 3-2: Use of agro-chemicals per year in Kyrgyzstan (tons) (1980-1993)

1980 1981 1985 1990 1991 1992 1993

7,303 6,139 4,364 4,530 3,479 2,380 1,900

Source: Agricultural Working group of the State Committee on EnvironmentalProtection. BackgroundPapers: NaturalResources 75

3.7 Most of the pesticides are used on irrigated crops, particularly on cotton, for control of thrips and wilt. Agricultural experts estimate only about 40 to 50 percent of the crop's pesticide needs are currently met in Kyrgyzstan, however, and average use is estimated presently at less than 2 kg/ha. Most of the herbicides were used on cereals and maize, and to a lesser extent on cotton, sugarbeet and vegetables (mainly onion. The bulk of herbicides on cereals was applied in Issyk-Kul Oblast, where they may damage the lake ecosystem (Issyk-Kul lake is a closed lake without outflow). Most insecticides and fungicides are used on cotton. Since cotton is grown in rotation with lucerne, the pesticides used for that crop also go into the system (see Table 3-3). Hence, the cotton-growing areas in the Fergana Valley are the most affected by pesticide contamnination. Tobacco, another crop which demands high pesticide applications, is also grown in the cotton area. Primarily women and children work in the cotton and tobacco fields. Most of them are unaware of the health risks involved and do not use any protective measures. Local experts report that residual pesticides have contaminated approximately 380,000 ha. Unfortunately, there is currently no monitoring of agro-chemical persistence or morbidity in the exposed population.

Table 3-3: Use of agro-chemicals on the main crops in Kyrgyzstan in tons (1993)

| Insecticides I Fungicides | Herbicides I Defoliants Total

Cotton 84.3 931.0 29.2 212.0 1,256.5 Cereals 1.1 0.2 84.2 0.0 85.5 Maize 2.1 0.0 80.0 0.0 82.1 Fruit trees 15.1 17.5 0.0 0.0 32.6 Tobacco 3.9 1.0 0.3 0.0 5.2 Lucerne 21.9 0.2 2.6 0.0 24.7 Grapes 4.5 19.8 0.0 0.0 24.3 Vegetables 3.4 8.7 11.7 0.0 23.8 Potatoes 2.5 16.4 2.4 0.0 21.3 Sugarbeet 6.5 2.5 14.0 0.0 23.0 Total 145.3 997.3 224.4 212.0 1,579.0

Source: Workinggroup of the State Committeeon EnviromnentalProtection

3.8 There is presently an critical lack of herbicides, resulting in dramatic yield reductions, which has only partly been solved by grants from the Dutch Government and credits from the Japanese Government. Pesticides, however, are available. In general, the problem of pesticides is not the total quantity applied per ha, but instead poor handling practices, inefficient watering systems, and soil erosion, leading to runoff from the fields and pollution of water resources. Anything done to reduce erosion and runoff would also reduce pesticide levels in surface water, because pesticides are either dissolved in water or attached to eroding particles. Inadequate storage, transport and handling are responsible for the most serious environmental hazards, however. Pesticide spills are washed into waterbodies during floods in BackgroundPapers: NaturalResources 76

much higher concentrationsthan are found on fields. Although Kyrgyz scientistshave varying views about pesticide contaminationof soils, 'point pollution' due to inappropriatestorage and handling is of great concern, and appropriate regulationsand control mechanismsare needed.

3.9 Fertilizeruse is also not excessive in Kyrgyzstan,including nitrogen which is usually the most serious threat to groundwater. Averageuse of fertilizer, even in the best days, was only 180 kg/ha, and has since declinedto less than 140 kg/ha. This compares with typical rates in the 1980's of 770 kg/ha in the Netherlandsand 410 kg/ha in West Germany. Average use of manure is about I to 5 ton/ha, while averageuse of manure in the Netherlandsis about 100ton/ha. Fertilizer and manure spills during storage, transport and use, are sources of localizedcontamination of ground and surface water with bacteria and nitrates. Improper disposal of livestock wastes is also a source of ground and surface water contarninationand is discussed below. The remedy for pollution does not lie in reduced fertilizer use, but in better handlingand storage practices, as well as in better farm managementand soil conservation practices, which result in more efficient uptake of fertilizers.

3.10 Soil erosionand poorlymanaged water runoffare key problems in the agriculturalsector. The diffuse 'non-point' pollution of soil erosion is closely associatedwith on-farm practices and techniques. Contour ploughingon sloping, rainfed fields is not widely practiced, resulting in increasedsoil erosion and water runoff. Irrigation is typicallypracticed by furrow irrigation (gravity) on sloping plots which are generally too large. Thus the water in the furrows accumulates too much kinetic energy which loosensand suspendstop soil particles. In addition,although most precipitationis in the form of (gentle) snow, there are annual springmelts, and intensiverainfall events in both spring and fall. The peak runoff events which occur during these periods carry tremendous erosive power. Over the years, many irrigation plots have thus lost their natural fertility, and increasingamounts of fertilizers and pesticides have been necessaryto maintainproductivity. Soil conservationmeasures which are standard practice in other parts of the world are rarely used in the Republic. The practices includesuch simpletechniques as mulching,contour ploughing,ridging, strip cropping,terracing, reduced tillage systems, reducedsizes of irrigation plots, and utilization of sprinklers instead of furrow irrigation.

3.11 Salinizationproblems presently affect an estimated 20 percent of the cultivated area, occurring particularly in the lower parts of the Chu and Fergana Valleys. These problems are caused by poor irrigationpractices (applyingtoo littleor too much water) and the absenceof adequatedrainage systems.

3.12 In summary, erosion is the primaryenvironmental issue in the agriculturalsector, reducing the productivity of the land, and compromisingwater quality. This is a diffuse pollutionproblem, affectingmost agriculturallands. Other environmentalissues includepoint pollution causedby improper storage and handling of agro-chemicals,and salinization of irrigated lands, caused by inappropriate irrigation practices.

3.13 Recommendedactions include:

(a) Introductionof soil conservationtechniques such as mulching, contour ploughing, strip cropping, reduced tillage, and improved irrigation practices;

(b) Improved storage and handling of agro-chemicals, and increasing monitoring and penalizing of inappropriatehandling; and

(c) Improvementof irrigationsystems and constructionand rehabilitationof drainagesystems for the restoration of saline lands. Background Papers: Natural Resources 77

(d) Updating legislation and standards which govern the use of agro-chemicals, and promoting the use of integrated pest management in agriculture practice.

Livestock

3.14 The NEAP Agricultural Working Group estimates the number of livestock were 14.5 million sheep equivalents in 1994. The Institute of Pastures estimates the carrying capacity of Kyrgyzstan's rangelands is only seven million sheep equivalents. The present livestock density of two sheep equivalents per ha is the highest of all FSU Republics. Sheep are economically the most important component of the country's herds. The sheep population, which is used for both meat and wool production, grew from 2.8 million in 1913 to 10.5 million in 1990 under FSU agricultural policy. In 1994, sheep were estimated at 7.7 million head. The total number of horses is approximately 300,000 or 1.8 million sheep equivalents (one horse equals six sheep equivalents), and the number of cattle one million head, or five million sheep equivalents (one cow equals five sheep equivalents).

3.15 Presently, the number of sheep is declining due to the changing economic situation. Many animals are being sold for revenue, or because farmers cannot feed so many animals. Most pastures are located at great distances, and there is a shortage of good winter pastures. Feed grain imports--on which the excessive livestock population was dependent--were heavily subsidized in the past, and have now declined. Between 1985 and 1993, public sector sheep flocks on state and collective farms were reduced from 8.7 million to 4.2 million head, while sheep in the private sector increased from 1.5 million to 4.6 million head. As a result, grazing pressure has increased considerably around settlements.

3.16 The total pasture area in Kyrgyzstan is estimated at some 8.8 million ha. The pastures consist of 3.6 ha of high altitude summer pastures (above 2,500 m), 2.9 million ha of spring/fall pastures (between 1,500 and 2,500 m) and 2.3 million ha of winter pastures, usually on lower rainfall southern slopes. The summer, spring and fall pastures are principally annual grasses, which are reasonably resilient under heavy grazing. The winter pastures are composed primarily of crop residue, or perennial browse and shrub species which are hardy, drought tolerant and cold resistant, but if overgrazed are lost from the pasture and replaced by woody weeds and ground covers which are very poor forage. In addition, there are supporting forage areas of some 600,000 ha, consisting of 400,000 ha irrigated alfalfa and other legumes, and the remaining 200,000 ha of hay lands.

3.17 Average pasture productivity on an annual basis has declined almost linearly by approximately 33 percent since the 1960's and presently amounts to 300 kg/ha of dry matter. This decline is in direct proportion with the increase in stock numbers and is clearly a result of overgrazing. Productivity of summer pastures have declined from 640 kg/ha to 410 kg/ha and of spring/fall pastures from 470 kg/ha to 270 kg/ha during the last 30 years. Productivity of winter pastures has decreased dramatically during the last 30 years from 300 kg/ha to less than 100 kg/ha. Encroachment of woody weeds has affected some 5 million ha. Of those, 540,000 ha are severely affected, minimizing their value as forage lands.

3.18 Pasture degradation in the form of erosion has affected some 4.5 ha, or about half of the total pasture area. Soil compaction resulting from high livestock densities generally leads to accelerated soil erosion on pastures on steep slopes and wind erosion on the lower and drier pastures. Black soils during moist conditions are particularly sensitive to compaction, resulting in reduced infiltration capacity and increased surface run off. Erosion is made worse by cultivating hay meadows on fragile and steep slopes- -often such fields are ploughed in the direction of the slope, accelerating run-off and gullying. BackgroundPapers: Natural Resources 78

3.19 Livestocknutrition is insufficientin general, and in a critical state during winter. Despite some 700,000 tons of crop residues which form a mainstayof winter feed in the absence of winter pastures, livestock are reliant on relatively high-cost supplementaryfeeding during winter. Imported grain feed amountedto 1.6 million tons before the interruptionof inter-republictransfers, and in 1993, the amount of grain fed to animals dropped to 700,000 tons. Consequently, most livestock is underfed, with estimated grain shortages of 50 percent of that required, 30 percent for hay and 40 percent for silage. These feed shortages, particularly in winter, have resulted in a high proportion of tender and broken wool, and reduced meat production.

3.20 Inadequatemanure storage and disposal from livestock farms, includingdirect dumping onto soils and into water courses, often results in higher concentrationsof nitrates in both surface and ground water. One hundred large livestockand poultry yards generate approximatelyeight million tons of liquid manure wastes per year. In 1984, a special directivewas issued to move all temporaryenclosures which were near water courses, 80 percent of which have since been removed. Treatment facilities exist on only four livestockfarms and ten poultry farms. Proper technologyis needed to process the manure into fertilizer. Biology Instituteresearchers are experimentingwith a wormcompostprocess to treat livestock wastes, but reduced governmentbudgets have hindered wide-scaleexperimentation with the process. The Institute of Crop Farming has requested government support for large-scale production and testing of vermiculture and composting,but no support has yet been given. A public information campaign to improve waste disposal and storage practices at livestock farms, in combinationwith stronger fines, would help reduce groundwaterpollution from this source.

3.21 Past livestock policies were aimed solely at increasing livestock numbers, irrespective of economic or environmentalconditions, and have resulted in considerabledegradation of the pasture resources. In the present economic situation, and in the absence of a full and marketabletitle to land, many people consider livestock a form of security and store of wealth. Sector specialists have recommendedthat future strategies be directed towards decreasing livestock numbers, changing flock structure (throughhigher turn-offof prime lambs), and increasingforage production. A recent directive (May, 1994)stated thatpastures will not be subject to privatization,nor subdividedinto smallplots. The Ministryof Agricultureis not convincedthat individualfarmers, regionalcouncils and village committees will be able to managethe pastures in a proper way. Instead, the pastureswill remain under the Ministry of Agriculture, which is planning to lease the pastures to herders.

3.22 The key environmentalissue in the livestocksector is the degradationcaused by uncontrolled grazing and excessivenumbers of animals. Overgrazinghas resulted in serious deteriorationof pastures, occurring in the form of loss of productivity, accelerated soil erosion, wind erosion, deforestationand increasedoccurrence of land slides. In some regions, this has resulted in serious forms of desertification, while in other areas sedimentationis occurring in the water supply reservoirs. It is not known to what extent hydropower reservoirs are subject to sedimentation. Although livestock numbers have been declining since the transitionperiod, they are still twice the carrying capacity of the land. The issue of uncontrolled grazing will be very difficult to resolve in nation of traditionally nomadic herdsmen. Nevertheless, tremendous benefits can be gained by restricting grazing animals designatedzones, and instituting improved managementpractices such as rotational grazing. This would also permit more various land uses, such as agroforestry and forest regeneration.

3.23 An additional environmentalissue related to livestock is pollution of water courses through inappropriatestorage and disposal of manure. Elevatedlevels of nitrates and bacteria in domesticwater downstreamresult. Public education, fines, vermiculture and compostingare tools which can be used to combat this problem. Background Papers: Natural Resources 79

3.24 Recommended actions:

(1) Although the main solution is the reduction of stock numbers, a landuse planning system should be developed, whereby land is zoned according to its land capability. The information needed to determine carrying capacity of the land is readily available from the Institute of Land Use and Utilization ("Geprozem"). Clear land tenure will assist any program to become self-regulating--land lease holders will control trespass of livestock and will have incentive to reduce their flocks to sustainable sizes. Thus, in addition to private tenure and area allocation, each lease holding should have a grazing permit for a specified number of animals per hectare. Introduction of grazing management practices such no-grazing zones and rotational grazing, should be part of the lease-hold requirements as well.

(2) Part of the solution to reduce stock lies in changing the flock structure from meat production using ewes and wethers, to production from a flock oriented toward seasonal prime lamb. A growing market exists in the Middle East and could be further developed. Iranian buyers are already purchasing lambs from Kyrgyzstan. The standards of the industry must be thoroughly upgraded and enforced, however, if the sale of meat products on hard currency export markets is to be expanded. At present, no establishment could meet standards of the European Union or United States Department of Agriculture. Provision of credits to private enterprises for the purchase of self- contained mobile abattoirs would also help the industry become more competitive.

(3) A public information campaign to improve waste disposal and storage practices at livestock farms, in combination with stronger fines, should help to prevent or reduce groundwater pollution from this source. Efforts to explore techniques like vermiculture and composting to turn the wastes into a safe, useful product should be also supported.

B. FoREsrRY

3.25 The area under forest cover, including dense shrubland, is estimated at 843,000 ha, of which 101,600 ha are forest plantations. This is about 4.2 percent of the country, or less than 8 percent of the manageable land area. Most of the forests are located between 1,300 and 2,400 meters above sea level. The extent of forest cover differs among oblasts: Dzhalal-Abad has the most forest cover (9.0 percent), followed by Osh (5.1 percent), Talas (3.6 percent), Issyk-Kul (2.7 percent), Naryn (2.2 percent) and Chui (2.1).

3.26 The natural forests of Kyrgyzstan are composed of more than 120 woody species. On the Northern ranges of the Tien Shan, the forests are mainly composed of spruce (Picea schrenkiana). In the Western Teen Shan, in dryer areas protected from northern winds, pistachio (Pistacia vera) and almond stands (Amugdaluscommunis) grow. The famousgenetic centre of walnuts is in the more humid areas in the south--Juglans regia is the dominant walnut species. Apples (Malus spp.) and maples (Acer spp.) grow in the walnut understory. On dryer mountain-sidesin both the North and South, various species of Juniper occur ("Archa").

3.27 Based on assumptionsabout the prevailing climate and soils, and on historical accounts, there must have once been forest cover over much of the country. The single most important cause of the depletionand disappearanceof the forests has been the enormouspressure of millionsof grazing animals, particularly sheep, which eat all natural regeneration. The Kyrgyz people have been livestock-keepers Background Papers: Natural Resources 80

since time memorial. The conversion of forest cover into rangelands and pastures has been taking place for centuries. Nevertheless, historical accounts of travellers in the past report densely forested hill-sides.

3.28 At present, there is forest cover on 4.8 percent of the territory'. In the last 20 to 30 years, Kyrgyz naturalists estimate the forest cover has been reduced about 50 percent. Although the loss of vegetation cover is mainly due to the large numbers of livestock, there are other contributing factors as well. During the second World War and the 1960s, there was extensive cutting of the forests. Since the collapse of the FSU, coal and LPG (liquified petroleum gas) have become unaffordable for many people and organizations. This has resulted in a sharp increase in reliance on traditional fuels, particularly firewood (dung cakes are also used). Uncontrolled fuelwood cutting has increased dramatically--further contributing to the process of deforestation. In addition, up to 500,000 cubic meters of wood were once imported annually from neighboring republics. These supplies are also greatly curtailed, although polewood and timber are still needed. Illegal harvest will increase over the next few years, if inexpensive energy and timber sources are not developed.

3.29 Forest policy is made by the Forestry Department, which used to be an independent State Committee, but recently has been integrated into the State Committee on Environmental Protection (Goskompriroda). Since 1948, when the Soviet Union recognized the serious state of depletion and degradation of the forests in Kyrgyzstan, policy has focussed on forest protection and the reforestation of state lands. Five national reserves were created, and today two parks exist covering 115,000 ha. New legislation has been adopted by Parliament (Forestry Code, 1993) with the objective of protecting the existing forests and increasing forest cover to eight percent of the country.

3.30 The administration of forests at a national level falls under the Forest Department, an executive agency employing about 2,000 people, and responsible for 2,573,000 ha of state land (14 percent of the country). In the past, up to 55 percent of the State Forest Land has been leased (without fee) to Kolkhoz, Sovkhoz, or neighboring republics as rangelands. At the local level, the Forest Department is represented by thirty-two Leskhozes ("forestry farms"), which manage 95 percent of the state forest land. The Leskhozes are organized into three Regional Directorates: Dhzalal-Abad, Issyk-Kul and Osh. Recently, as part of the process of fiscal decentralization, budgeted funds for the Leskhozes have been channelled through the Oblast administrations, giving the local authorities more discretion over the allocation of funds. As forestry is generally not a priority of local akims, Leskhoz funds have been subject to reallocation to other uses, resulting in funds reductions of up to 70 percent in some cases.

3.31 Forest management is undertaken by the Leskhozes guided by ten-year management plans which have been established with the assistance of foresters from Russia, Kazakhstan, or other neighboring republics. The Leskhozes are responsible for protecting the forest; they have their own nurseries and generally their own processing units. They are productive entities and members are involved in livestock- keeping and agriculture, as well as forestry-related activities. Although current local production efforts complement budget transfers from the state, income from them is not enough to make up for government budget cuts of up to 70 percent. The Leskhozes barely have enough money to continue payment of staff salaries, let alone carry out forestry activities.

3.32 Silvcultural practices are well established in Kyrgyzstan. Nurseries are typically 6 to 10 ha in size and contain a mixture of various seedlings which are planted bare-rooted in the field during March and April. Planting on mountain slopes is done manually, digging small terraces of one-by-two meters

1/ The KyrgyzstanEnergy SectorReview states4.2 % of the countryis forested,representing a standing stockof 23.5 million m3, consistingof 843,000 ha of closed forestand 2 million ha of dispersedforest. Background Papers: Natural Resources 81

(or 600 per ha) and planting eight seedlings per terrace. On gentle slopes and flat areas, furrows are ploughed, in which the seedlings are planted. The survival rate of plantations depends strongly on rainfall, which is often very unreliable, and on pressure from grazing animals. In the past, timber harvesting was often in the form of industrial clear felling, but this has now been banned. Sanitary and maintenance cuttings (thinnings) are still widely practiced. Felling is done either by chainsaw or axe, while transport of logs is by animal traction and by truck.

3.33 Wood production is very low. Official roundwood production is 40,000 to 50,000 cubic meters per year, and total production is estimated at not more than 80,000 cubic meters, of which a third may be from poplar plantations. By and large, this cannot supply the national needs, which are at least ten times higher. Most of the national consumption of timber was and is imported from other FSU republics on the basis of barter trade (for example, wood for meat). Reliable information on statistics for timber consumption is lacking. Fuclwood is currently the main wood product, due to the high demand fuel, and the generally low quality of the standing stock.

3.34 Sheep and cattle, which graze on forest lands, are the primary non-wood forest products. The Republic's forests also produce important quantities of fruits and nuts (such as walnut, almond, pistachio, apple. plum, apricot, cherry, and pear). In the South, several Leskhozes have their own fruit-processing units. Other valuable nonwood forest products are honey, particularly in the Dhzalal- Abad area, and game such as bear, wolf, the rare , mountain goat, and the Marco Polo sheep.

3.35 The catchment protection function of forests in Kyrgyzstan may appear to be less important than in otlher countries due to the relatively low precipitation and its modest contribution to total stream flow (ten percent--most of the stream flow is melt water from glaciers). Furthermore, much of the precipitation is in the form of snow, with much less impact on the soil compared to rain. Nevertheless, forests have a strong regulating effect on the movement of surfacewaters, buffering both peak and low flow periods-- they promote storage of some of the water in the soil during spring melts and the slow percolation of water downslope to streams during drier months. In addition, the forests play an important role in the protection of steep hill slopes, by stabilizing the soils and substrate through their roots and surface litter. Maintaining forest cover on vulnerable slopes will reduce the likelihood of landslides occurring, and will potentially save lives and preserve productive lands.

3.36 Forestry research and education. Research is mainly done within the frainework of the National Academy of Sciences, and performed in three institutes: the Institute for Forests and Nut Culture in Bishkek; the Institute for the Biosphere in the South; and the Institute of Biology. Before independence, the Institute for Forests and Nut Culture had a staff of 103, including 38 scientists, and 5 laboratories and experimental stations, but budget cuts have reduced the staff by two thirds. Research is currently focusing on nut and fruit production, and spruce and juniper forests. Foresters in the republic used to be trained in neighboring republics. In 1993, two faculties were created in Dhzalal-Abad and Karakol, each of them potentially matriculating five forestry specialists a year.

3.37 The key management issue in the forestry sector is the on-going degradation of the forest caused by uncontrolled grazing by too many livestock animals, over-exploitation of the forest in the past, and insufficient planting and protection of new trees. Illegal cutting may be an increasing issue of concern, as well, due to the enornous gap between supply and demand for wood products such as firewood and construction wood. Wildlife habitat loss, increased soil erosion, and the occurrence of mud flows and land slides are directly related to the loss of tree cover. BackgroundPapers: Natural Resources 82

3.38 External support for forest management. The Swiss Organization for Development and Cooperation(Intercooperation) is planningto provide funds and technicalassistance to the forestrysector. Five projects have been identified, of which three are likely to be implemented,starting with a pilot phase in 1995. The five projects include:

(a) Developmentof a forest informationsystem as a basis for planning and monitoring the sustainableuse of the forest resource;

(b) Assistance to improve the development, implementationand monitoring of forest managementplans for the (northern) spruce area;

(c) Developmentof models for sustainablemulti-purpose forest and rangelandmanagement plans in the (southern)walnut and fruit tree area;

(d) Reforestationactivities in non-forestlands, irrespectiveof ownership, and assistance in the developmentof private timber processingunits and wood products marketing; and

(e) Support for training programs for forest technicians,by strengtheningthe two forestry schools, and provide field training and training courses for Forest Departmentstaff and others.

Recommended actions:

1. Review and revise present forest policy, and combine forest production and protection objectives. The present policy emphasizes the protective role of forests in terms of soil conservationand habitat. Most managementobjectives, including reforestation,are directed to this purpose. This is highly commendable. Policy which focusessolely on the protectiveaspects of forests, however,does not adequatelyrecognize the importanceof meetingthe nationaldemand for wood products. If this demand is not met at least in part, uncontrolledcutting of firewood which is logistically and politically difficult to control, will increase the pressure on natural forests. Productive and protective roles can be combinedin both natural and plantation forests on the basis of sustainable resource management. Production potential exists in the natural conifer stands, through selectivecutting--although this requires specialharvesting techniques due to the difficultterrain. Productionpotential also exists in plantingfast-growing tree species such as poplar, both on the Leskhozesand other lands;

2. Thelocal and internationalrangeland leases of forest departmentland shouldbe re-evaluated, and either be revokedor strict controls shouldbe institutedon the number of livestockpermitted, based on the specific carrying-capacityof the leased land.

3. Leskhoz lands need to be characterizedand zoned accordingto land capability,determined by soils, slope, aspect, vegetation(current and original),preservation value, and proximityto water and settlements. Currently, there is little separationbetween the forest and rangelandsand the primary stress on forests is grazing pressure. Stocking rates, as prescribed in the Forestry Code should be strictly enforced to permit natural regeneration and increase the survival rates of planted seedlings. Livestock must be excluded from most of the fragile hillsides and upper watershedsmanaged by the Leskhozes. BackgroundPapers: NaturalResources 83

4. Recognizingthe extreme financialvulnerability of the Leskhozes,rinancial inputs are urgently needed at the Leskhoz level. Without a better economic base for these communities, further degradation of the forest resource base is unavoidable. Financial inputs are required for equipment purchase and maintenance, underwriting general operating costs, labor (for tree planting), and credit facilities. Many leskhozescurrently collect non-wood forest products such as fruits, honey, nuts, etc. These products have potentiallyexcellent regional markets, but short- term credit to pay for processing equipment, labor, transport and marketing is non-existent. Dramatic budget cuts require the leskhoz communitiesemphasize extractive activities (such as herding livestock),as forest managementactivities provide less income in the short-term. Until the state budget can fully support forestry personnel for timber and wildlife management, productiveactivities which do not degrade the forest--suchas fruit and nut processing,and small wood processingenterprises (furniture and accessories--mustbe supportedwith funds, credit and technicalassistance.

5. State funds for budgetedfor forestry activities should be spent for that purpose as much as possible, even thoughthey are administeredthrough local government. With public budgetsvery constrained, local administrationsmay choose to place higher priority on productive activities with short time-frames, such as agriculture;income in forestry is often quite low or deferred for decades. It is understandable that authorities feel forestry funds are better spent on other purposes. A strong forestry program is essential to the long-term economic vitality of Kyrgyzstan,however, for the ecologicaland economicreasons discussed above. Forestry funds, which are already reduced in the Republicanbudget, should not be further eroded at the local level. Decentralizationof forestry funds to the local level shouldoccur in parallel with capacity- building of local forestry management.

6. Restructuringthe forestry sector. Productive functions of the leskhozes before independence were heavily subsidized, and emphasizedlivestock production and forest extraction rather than sustainableforest management. As the Forest Departmentestablishes its new priorities, several areas should be considered:

(a) Information management. A first step in developing new policy directions is ready access to good information. Hand-maintaineddata exists on each of the leskhozes. This should be standardizedand computerizedsuch that it can be combinedand shared among forestry experts. The databaseshould provide information on standing stock, growth rates, production, and consumption,in addition to market informationsuch as regional and world timber prices.

(b) Segregationof short-termand long-termproductive activites. Some of the productive activitiesof the Forest Departmentare clearly public forest managementfunctions, while other activities lend themselves to a more private-sector type of management. For example, timber managementhas a low return for a number of years, and given the current condition of most of the forests, will be difficult to make a self-supporting activity in the short and medium-term. The Leskhozesare multi-disciplinaryproduction units, however. In addition to timber managementand harvesting, they are engaged in productive activities such as agriculture, collecting and processing non-wood forest products such as honey and fruit, and furniture-making. In a supportive policy environment, with access to credit, these latter activities will be easily self-supporting, and should be managedlike private enterprises. Background Papers: Natural Resources 84

(c) The implementingactivities of the Forestry Department must be separated from its regulatory and protective functions. For example, regulationof activities should not be performed by the same offices that gain revenues by performing the activities (i.e. permitting).

3.39 Although it may be possible for the Leskhozesto support long-term forestry with short-term productiveactivities, this would mean the Leskhozesare unfairly bearing the costs of a broad public good (sustainableforestry). Those aspects of land managementin the Leskhozes with wide-reachingsocial benefits--suchas watershedmanagement, soil conservation,habitat protection, and long-termsustainable forest management--shouldbe managedand supportedseparately from short-term productiveactivities. Short-termactivities, however, must be managedin such a way that they complementthe long-termgoals.

3.40 Both short and long-term economicactivities on forest department lands should be includedas part of the National Forest Plan and national biodiversitystrategy. Exactly how the administrativeand regulatory division is made between self-sustainingand governmentsupport activities is a "mid-term" problem, which should be negotiated in stages among the Leskhozes, the Forestry Department and Ministry of Finance.

C. WATERSHEDPROTECTION

3.41 The key elements in watershedprotection are site-specific. They include the geomorphology, soil characteristics,vegetation cover, rainfall intensityand landusein a given watershedarea. Watershed protection plays an important role in the prevention of soil erosion, floods, mud flows, land slides, siltation of rivers and sedimentationof reservoirs and irrigation schemes.

3.42 The largest river basins in Kyrgyzstanare the Amu Darya, Syr Darya, Chu, Talas and Sary- Djaz, with an averageannual volume of 44.5 km2. The largest watershedsare the Naryn watershed(30 percent of the territory) and the Kara Darya (16 percent), both feeding the Syr Darya river, the Tarim watershed( 11 percent), the Issyk-Kulwatershed (8 percent), the Chu watershed(7 percent),and the Amu Darya watershed (7 percent). The flow of most of these rivers is regulated by reservoirs, both for hydropower generationand for irrigation.

3.43 The major sourceof water for most rivers in Kyrgyzstanis snowfallon the high mountainslopes which are covered in part by permanent glaciers. Streamfloworiginates primarily as melting snow and glacial ice. Rainfallcontributes only 10 percent of total stream flow. Sincerainfall, by its kinetic energy, is considered the most importantfactor in the process of soil erosion, one would expect little erosion in Kyrgyzstanbecause most precipitationis in the form of snow. The oppositecase is true, however. The occurrence of soil erosion is high.

3.44 There are several causal factors in the high erodibilityof the land. First, the intensityof rainfall events is very high at times. When large amounts of rain fall in a short period of time on compacted soils, the run-off and accompanyingdegradation can be severe. Second, the steep slopes and fragile, unstructured soils, often with a very thin humus layer, are naturally very susceptibleto soil erosion. Areas in the lower and drier parts of the countryhave becomedesertified, and vulnerableto wind as well as water erosion. Finally, Kyrgyzstan'shighly dynamicgeomorphology, with frequent earthquakes,also predispose the land to large-scaledisplacement in the form of dangerousmud-flows and land slides. Background Papers: Natural Resources 85

3.45 Acceleratederosion, or human-inducederosion, is a criticalcausal factor to these slides. In many cases, it may be impossibleto distinguish whether the slide or flow is caused solely by natural events (such as high rainfall in combinationwith seismic activity) or by human activities. Overgrazing is the primary human-inducedactivity of concern. Too many animals destroy the soil structure, and remove anchoring vegetation, aggravating any native predisposition the land has to move. Removing the vegetationalso changesthe temperatureand water conditionsin the soil and surface layers, perpetuating erosion- susceptibleconditions. The numerousanimal paths which zigzag across the slopes, can develop into gullies which undercut slopes and eventuallycause flows and slides. The result is that evidenceof landslides and mud-flows are visible throughout the countryside. In 1994, mud-flows and landslides caused the death of 99 people. Moreover, 637 families were subsequentlyresettled and another 1,203 families still need to be resettled.

3.46 The degradationof watershedsleads to increasedsurface runoff during rainfall events, carrying with it large quantitiesof sediment. The poor storage capacity of the soil also causes higher storm peaks and greater erosive power in the water, which is easily seen in the deep incisions made by many rivers, the piles of rocky debris, and their wide stream beds. A lower base flow also results when there is little soil storage capacity, forcing greater reliance on storage reservoirsto meet the Republic's water needs. The extent of sedimentationin downstream reservoirs caused by erosion and mud flows in the upper catchments is therefore of great importance, as the country is dependenton hydropower and irrigation. There have been reports of significantloss of reservoir storage capacity due to sedimentation,but there is little or no systematicdata availableon sedimenttransport in rivers. Since the long term effects of stream and reservoir siltation are often far reaching, both economicallyand environmentally,systematic monitoring should receive high priority.

Reconunendedactions

3.47 The most pressing issue in watershedmanagement is the protectionof slopes against erosionand massive land movement in the form of mud-flows and landslides. A managementplan directed toward protecting watersheds by preventing erosion, and reversing the loss of vegetative cover will have a number of beneficial effects. It will enhance the productive capacity of the land, preserve lives, and lower the economic and social costs incurred by downstream sedimentation, reduced water quality, floods, droughts, and community dislocations. To develop a comprehensivewatershed management policy, the following actions are recommended:

a. Make a country-wideassessment of the present status of watersheds, includingsoil type, vegetation cover, level of soil erosion, and susceptibilityto mud flows and land slides. Social and economic descriptions of communitiesin the watershedsshould be overlaid with the biophysicaldata. Most of this informationis alreadyavailable--it simply needs to be brought together for purpose of comprehensivepolicy analysis. One or two key watersheds might be chosen as test sites to initiate this kind of inclusive and cross- disciplinary analysis.

b. Initiate projects to rehabilitate the most critical watersheds, which may be achieved by revegetatingsteep slopes and reducing livestock pressure. These projects should be designed in conjunctionwith the communitiescurrently engaged in productive activities on the affected land.

c. Establish a long-term monitoring program on river siltation and the sedimentationof reservoirs. BackgroundPapers: Natural Resources 86

3.48 In the long-term, it is strongly recommended that a single Ministry be responsible for integratedwatershed management of all the upper catchmentareas. Apart from soil conservation, protectionagainst mud flows and land slides, and water conservation,this body would also be responsible for forestry, biodiversityconservation, and hunting regulation--allactivities taking place primarily in the upper catchments.

D. BIODIVERSITYCONSERVATION

3.49 Ecosystem diversity in the Kyrgyz Republicis naturally high due to the diverse landscapetypes and microclimates. Elevations vary from about 400 meters (1,303 feet) to 7,439 meters (24,177 feet), with a wide variety of habitats ranging from desert to broadleaf and conifer forests to high alpine ecosystems. The aquatic habitats consistof wetlands,perennial and intermittentstreams and rivers, and fresh and salt water lakes, includingthe world's seconddeepest inland water body (Lake Issyk-Kul). The Western Teen-Shanhave the broadest range of ecosystems(22 out of 24 classes); followedby the Inner Teen-Shan(18 classes out of 24), the Alai and Northern Teen-Shan(16 classes), and the Issyk-Kuland Central Teen-Shanregions (12 classes each).

3.50 As a result of the diversity of ecosystemniches, speciesdiversity is also naturally high. There are, for example, well over 500 speciesof vertebratesincluding 83 mammals,368 reptiles and 75 fishes, along with about 2,000 species of fungi, at least 3,000 insect species and over 4,500 species of higher plants. Table 3-1 lists the numbersof known and endemicspecies. Due to the great variationin altitude and moisture in the country, habitats that would be separatedby hundreds or thousandsof kilometerson a plain are juxtaposed, supporting significantly higher species richness than is found in neighboring republics. In addition, many of the plant and animal species are endemic to either the Kyrgyz Republic or Central Asia. These factors combine to make the Kyrgyz Republic a key site for biodiversity conservationin the region.

3.51 There is little informationon the present status and trends of biodiversityin the country and the informationthat does exist is often contradictory. Nevertheless, about 10 percent of the mammalsand birds found in the Republic are listed as endangeredspecies in the Red Data Book, published in 1985. In total, 65 plants, 13 mammals, 33 birds, 3 reptiles, 2 fishes and 18 insect species are included. In actuality, these numbers probably should be much higher, because surveys are incomplete,and most wildlife and many plants have been severely depleted throughout the country. Research on the biodiversity of Kyrgyzstan began in the early 1800. Most of the existing data is in the form of inventoriesand taxonomicstudies performed before 1990.

3.52 The network of protectedareas include five Zapovedniki(strict nature preserves), which were establishedfor nature conservationand scientificresearch, and hence not open to the public; two national parks, where recreation is permitted; and seventy Zakazniki (other protected areas), which include landscapeparks, forest parks, zoologicalparks, botanicalgardens and natural monuments.The Zakazniki protect particular species, preserve representativeor unique natural sites, as well as provide conditions for "the organized rest [or relaxation] of people". The total area covered by these protected areas amountsto 558,700 ha, equivalentto 2.7 percentof the total territory. The protectedarea systemcaptures only remnants or islands of several ecosystems. Most of the areas are too small to maintain viable populationsof plants or animals within their borders. Some ecosystemsare not represented at all. Table 3-2 lists the current protected areas. An expansion of the protected area network has been discussed. This would involve the creation of seven more National Parks and eight more protected areas. Althoughthis expansionis needed to better protect habitats, the severe lack of funds makes any expansion in the near future unlikely. Background Papers: Natural Resources 87

3.53 Kyrgyzstan has not yet ratified any international conventions. The Government has expressed interest in signing the Biodiversity Convention, and following UNESCO's reconmuendation, one Zapovedniki, Sary Chelek Reserve, is part of the network of Man and the Biosphere reserves (MABs). The Issyk-Kul Reserve is included in the RAMSAR convention.

Table 3-1: Diversity of the Biota of the Kyrgyz Republic

Biota # of Species2 Species Richness3

World Kyrgyz World [ Kyrgyz

Algae 70,000 300 1.4 1.5

Protozoa 40,000 130 0.8 0.7

Plants 350,000 4,500 7.0 22.6

Fungi 100,000 2,000 2.0 10.1

Vertebrates 45,000 500 0.9 2.6

Round Worms 15,000 700 0.3 3.5

Mollusc 70,000 50 1.4 0.3

Cancroids 40,000 100 0.8 0.5

Spiders and ticks 75,000 250 1.5 1.3

Insects 950,000 3,000 18.0 15.2

2/ Number of known species, rounded to nearest thousand.

3/ Number of species per one thousand square kilometers. BackgroundPapers: Natural Resources 88

Table 3-2: National Parks and Protected Territories

Name I Oblast Year Area (x00 1 Description _ __ I I__| ha) (Altitude, species, ecosystems)

National Parks Ala-Archa JChui 1976 2.2 1600-4875 m. / 600 species of plants, 26 mammals, 240 birds

Kyrgyz-Ata Osh 1992 1m. /600 plants, 26 mammals, 160 birds

State Reserves

Issyk-Kul Issyk-kul 1948 18.9 1607m. / 120-150 species of higher plants, 12 fish, 240 birds

Naryn Naryn 1983 59.9 2200-4320m. / 50 mammals, 1870 plants

Besh-Aral Dzhalal-Abad 1979 63.2 1100-4000m. / 1200-1500 species of plants, 150 birds, 45 mammals

Sary-Chelek Dzhalal- Abad 1960 23.8 1200-4247m. / 981 plants, 157 birds, 40 mammals

Karatal- Janyryk Naryn 1994 5.9 2100-3800m. / Central Teen-Shan Ecosystem Complex

Sarychai- Ertash Issyk-Kul 1995 72.0 3000-4500m. / High mountain steppe

Special Nature Reserves

Kemin Chui 1966 0.6 1400-1500m.

Ak-Suu Chui 1975 7.6 1600-4331m. / Krygyz Range ecosystems

Chichkan Talas 1972 36.0

Gulcha Osh 1972 0.5 1500-1800m. / Riverine Ecosystem

Teploklu- chensky Issyk- kul 1972 29,0 2000-5000m. / North-West & South-East slopes of Terskey Ala-Too

Djety-Oguz Issyk- kul 1958 31.6 2000-5000m. / North slope of Terskey Ala-Too

Djarla- Kaindy Chui 1976 18.7 1300-4416m. / Kyrgyz Range Ecosystems

Tup Issyk - Kul 1976 19.1 2000-4500m. / Natural boundary Chelindy-Sai--headwaters of Tup

Ak-Buura Osh 1976 13.6 1 100m. / Water-meadow ecosystem of Ak-Buura River

Kirovskiy Talas 1976 28.7 2000-4488m. / Ecosystem of Talas Ala-Too

Kochkorsky Naryn 1977 2.3 1800m. / Water-meadow of Kochkorka River

Toguz-Toro Naryn 1975 26.6 1200-2300m. / Ecosystem of Baidoshtol River

Chandalash Dzhalal- Abad 1977 44.1 2500-3000m. / Ecosystem of Chatcal valley

Yassy Dzhalal- Abad 1977 6.2 1012m. / Water-meadow ecosystem of Yassy River BackgroundPapers: Natural Resources 89

3.54 Administrative oversight of the protected area network has recently been assumed by the Department of Protected Areas under Goskompriroda. Previously, the reserves were administered by the State Forestry Inspection. The NationalParks and most of the other protected areas were under the regional authoritiesor other organizationssuch as the National Academyof Science. The Department of ProtectedAreas has little actual authority over the protected areas. The regional authorities, through which the budgets are channelled, have more power, sometimes imposing other revenue-generating objectivesonto the protected areas such as firewoodproduction or livestockgrazing. The departmenthas a staff of four people in Bishkek. The five reserves that the Department considers under their jurisdiction have a total field staff of 219. As a result of this shortageof staff and funds, comprehensive policy is not developed, and true protection is not enforced. A national commitmentto a Biodiversity Conservation Strategy is badly needed.

3.55 Managementof the protectedareas is highly autonomous. Each protectedarea has a Director and a support staff of rangers and wardens ranging from 5 to 30 people. Managementand protection of the areas depend strongly on the influenceof the director and the regional authorities. Local communities are usually not involved in managementplanning. The most serious managementproblems are lack of logistics(transport) and finances,particularly in the larger and more remoteparks in the mountainswhich are difficult to reach. In addition, lack of local community commitmentand economic necessity create pressures in the form of livestockgrazing, legal and illegal hunting, and firewoodcutting--all of which can seriously threaten conservationgoals.

3.56 For most wildlife, the relatively small and unconnectedprotected areas do not offer sufficient protection from habitat loss and hunters. Most big mammals need large territories for feeding, and corridors to move to differentareas depending on the season. Wildlife--exceptin remote areas--quickly feels the impact of human activities. Loss of habitat (deforestation),competition with livestock, and hunting and poaching have caused the number of wild animals to shrink. The most critical situation involvesprotecting the habitatsand populationsof the most valuable(both economicallyand scientifically) species of big mammals, such as mountainsheep, djeyran, mountaingoat, snow leopard, teen-shanbear, lynx and Menzbir's marmot.

3.57 Hunting is allowed on 14.9 million ha of land, i.e. in 75 percent of the country. Of this area, 11.3 million ha are under the manageinentof 89 hunting enterprises. Of these, 72 hunting enterprises are under the Central AdministrativeBoard of Hunting and Hunting Supervision in Goskompriroda, which was formerly the HuntingAssociation under the Committeeof Forestry. The other 17 are divided among several agencies, clubs and associations, such as the Military, the Union of Consumers, and the Forestry Department. By the end of 1990, the staff of these enterprises numbered493 persons. Licenses to hunt may be issued by Goskomprirodaand by each of these enterprises, as well.

3.58 The primary game animals are capricorn (mountain goat), Marco Polo sheep, roe deer, wild boar, wolf, marmot, fox, badger, musk-rat, hare, weasel, squirrel, himalayan snowcock, chukar partridge, pheasant, quail, pigeon and waterfowl. Hunting used to be a privilege particularly for party members of the FSU. Nowadays,it attracts wealthy westernpeople, particularlyfrom the USA, Mexico, Germany and Arab nations. The price for hunting one sheep is equal to about US $19,000. It is generally hoped that the number of game will increasewith the continuingdecline of livestock. Apart from trophy hunting, animals like fox, marmot and wolf are hunted for their fur. Poachers are mainly interested in fur species, snow leopard and bear. BackgroundPapers: Natural Resources

3.59 Wildlifestock management is done through habitat improvement,breeding, feeding in winter time, placingsalt licks and transportinganimals from densely populatedareas to sparselypopulated areas. Animalsare counted annually in January and February. This count serves as the basis for determnining the hunting quotas for each species, which are generally about 10 percent of the population. Another important managementtask is control of the area, i.e. apprehensionof poachers. In 1994, there were about 1,000 cases of poaching reported to the Hunting Board. Followingprosecution, 30 percent of the fine goes to the individual who apprehendedthe poacher.

3.60 The primaryissues in biodiversityconservation are the continuousloss of habitat and the lack of effectiveprotection granted in the protectedarea network. Related issues are the continuouspressure of hunting and poaching, and the ubiquitous presence of domestic animals, which are in direct competitionwith wildlife.

Recommendations:

3.61 The followingactions are recommendedto promote biodiversity conservation:

* A national strategy for biodiversity conservationshould be prepared, which articulates its relationshipwith other sectorsof the economy, such as forestry, farming, and tourism. Through a national strategy, the specific (and varying) goals of the protected area network would be clarified, and the attention of international agencies and donors4 focussed on the areas of most utility to the conservationand developmentgoals of the Republic.

* Alliances should be formed with the international community in efforts to protect biologicalresources, by signingthe Conventionon Biodiversity,CITES, RAMSAR,and other internationaltreaties, agreementsand protocols directed to this end.

* Landsunder both completeand partial protectionshould be expandedto create a network of habitats designedto protect both critical and representativespecies and communities. These lands should be located both in rural/wildernessareas and in cities, towns and villages as "micro-reserves"--preservinggreen spaces in settled areas which have naturally fallen outsideof economicactivities. Migrationcorridors shouldbe established among the protectedareas, through these micro-reserves. Under the current network of protected areas, critical ranges and habitats are not adequatelyconserved.

* The hunting license system shouldbe reviewed and a populationsof all the hunted and endangeredanimal speciesthoroughly counted--including noting the number of breeding pairs. Based on this count, critically re-assessthe allowed take. Althoughcompetition

4/ Actionsby donor organizationsin this field are as follows:The World Bankis assistingthe Kyrgyz Republic,Kazakhstan and Uzbekistanon the conceptualizationof a regionalbiodiversity project; and NABU,a GermanNGO, is supportingthe establishmentof a Man AndBiosphere (MAB) reserve (UNESCO) which would coverthe catchmentof Lake Issyk-Kul,including the EasternTeen Shanmountains (70,000 sq.km. or 35percent of the country). At present,NABU is researchingthe area and the possibilitiesof conservationzonation. At a conferenceorganized in CholponAta, Issyk-Kul(July 21-23, 1994)a resolutionwas accepted,stating amongst othersthat 'followingthe recommendationof the Rio Conference,and as contributionto Agenda21 and the Conventionon Biodiversity,the Teen Shanmountains are proposedas a WorldHeritage site." The German Associationfor TechnicalCooperation (GTZ) is financingthe project. BackgroundPapers: Natural Resources 91

from livestock may be decreasing, the prevalence of guns and lack of enforcement capabilitiesmean that competitionfrom humansmay be increasing--itmust be assumed more animalsare actually killed than allowed for in the quotas. In addition to reducing animal populations,the emphasison hunting makes wildlifewary and difficult to observe by others, reducing the possibility of attracting the very large world-wide market of tourists who want simply to observe and photograph wildlife.

* Improveenforcement of protectedarea boundariesthrough cooperativemanagement with the communitiesand individualsliving legitimatelywithin or adjacent to the areas. Not all economic activities are in conflict with park management. Extensive grazing and fuelwood gathering (including sanitation cutting) often is in conflict with biodiversity conservation. Intensive activities (animal pens and agroforestry) in strictly confined areas, and controlled levels of harvest of non-timber forest products, may not be in conflict. The local populationmust be involved finding solutions for the existingpark- populationconflicts. Parks managementmust also be able to enforce the agreements.

* Formal structures should be established to integrate public input into environmental decision-making, and participation should be actively elicited during environmental assessments of developmentplans and projects. Although the Nature Protection Law requires participation, no responsible authorities, procedures or guidelines have been established to implement the requirement. As a result, public participation in environmentaldecision-making is minimal or absent.

- A public educationcampaign should be launchedwhich focusses on the importanceand uniqueness of the biological resources of Kyrgyzstan, emphasizes their fragility, and encouragescreative ways of managinggardens, fields and forests to preserve the native species of the Republic.

E. TOURISM

3.62 The Kyrgyz Republic is interested in developing its tourism sector, particularly ecotourism. Ecotourismrefers to visits made for the purpose of seeing and experiencingnatural and cultural heritage. It includes what is also knownas adventuretourism, such as trekking, mountaineering,horse-back riding, white water rafting, and skiing. It also includes nature study, wildlife viewing or photography, and visiting nationalparks and protected areas, and cultural and historical sites. The basic characteristic of ecotourismis that it is non-extractive:it does not consume the resource on which it is based (as opposed to hunting, for examnple).Moreover, ecotourismmay be an importantsource revenue for the funding of protected areas.

3.63 Kyrgyzstanhas a good ecotourismpotential, due to its outstandinglyrich natural heritage, and long and interestingcultural heritage. Its magnificentmountains are second only to the Himalayas, and the many deep blue lakes and wild clean rivers, as well as colorful valleys and deserts, are unrivalledin scenic beauty. The country's wildlife is unique and diverse, although difficult to observe because of intensive hunting. The country is rich in cultural history. The ancient silk route winds through the country, and monumentsand archeologicalsites from diverse cultures and historical periods dot the landscape. Osh, a key point on the silk route, is one of Central Asia's oldest towns. Other prerequisitesfor successful developmentof tourism, however, such as infrastructure and services, are either missing or insufficient. BackgroundPapers: NaturalResources 92

3.64 Tourismdevelopment has been fragmentary. During the Soviet period, it was concentrated mainly around Lake Issyk-Kul, with its beaches, and beautiful views of the mountains. There are numerous hotels along its shore, as well as health resorts and sanatoriumsassociated with warm springs and medicinalmineral waters. In other parts of the country, tourismdevelopment is virtually absent, with the exception of some Zakazniki for local recreation. Until recently, many parts of the country were closed even to FSU residents: nature reserveswere not open to the public, and nationalparks were only for special visitors. Kyrgyzstan was a remote part of the USSR, and it was extremely difficult for foreigners to visit: as a result, it is virtually unknownto most people, and it is far off the normal tourist routes.

3.65 Trophyhunting has been an important form of elite tourism in Kyrgyzstan,both during and after the Soviet period. Licensedhunting is allowed on 75 percent of the territory. It is possible to prey on animals which are protected in other parts of the world, such as Marco Polo sheep, Siberian mountain goat, and wolf--andforeign hunters are coming increasinglyfrom the West.

3.66 As yet there is very little tourism of any kind in the Republic--muchis needed to provide the infrastructure, facilitiesand services which tourism requires. Tourism services and infrastructureare poorly developed. For instance, although the country has an extensive road network, it lacks maintenance. Other services, such as foreign language-speakingguides, bed-and-breakfasts,and clear administrativeprocedures for travel aroundthe country (such as tourist visas, and internaltravel permits) are insufficientlydeveloped. Investmentshould be aggressively pursued, however, as developmentof a well-organizedtourism industrycould aid efforts to conserveprotected areas, stimulaterural economies in some areas, and directly impact the national economy by generatinghard currency revenues.

3.67 There is widespreadconcern about the negative environmentalimpact of tourism on nature. Althoughtourist traffic can be destructive if not carefully planned and controlled, the impacts of trail erosion, and uncollectedtrash are generally minimalcompared to consumptiveuses such as uncontrolled grazing, firewood cutting, hunting and agriculture. The impact of visitors depends on the carrying capacity of the resource and the number and behavior of the visitors. Natural areas can absorb surprisingly large numbers of people, provided that proper management measures are taken. For example, visitors may be deliberatelyconcentrated in relativelysmall areas ("honeypots") with support services and park guides, while most of the wildernessareas remain visited only by technical climbers or naturalists, perhapsby special pernit. In this way, the parks and preserves can combineconservation with intensivevisitation, and create both national and internationalinterest in the protected areas system.

3.68 Visitationis an important factor of both cost and income. In other countries, such as the USA, 10 percent of the 1992 budget may be spent by the Parks Service on nature management, and the remaining 90 percent on guiding visitors in their enjoymentof the areas. Althoughvisitation imposes a burden on the Parks Service, costs such as patrolling and road maintenancecan be offsetby visitor and business concessionfees. Furthermore, parks and preserves can generatesubstantial income for the local and regional economythrough direct and indirectlinkages with other enterprises impactedby the tourism industry. It must be emphasized,however, that tourism is not a panacea for revenue and employment generation: it requires proper marketing and substantial investments in infrastructure, facilities and services. BackgroundPapers: Natural Resources 93

3.69 The principal environmental issue in the tourism sector is the current over-emphasis on hunting tourism. Wildlife is scarce, and up-to-date inventories of threatened and endangered species are incomplete. Until realistic plans for species recovery and natural resource management are in effect, opening the country to foreign hunters will have two negative impacts: the numbers of wildlife will further decline, and the remaining (scared) wildlife will be very difficult to observe by non-hunting visitors--thus reducing the ecotourism potential of the country.

3.70 The European Bank for Reconstruction and Development (EBRD) is preparing a project to support the efforts of both the public and emerging private sectors in Kyrgyzstan to develop its tourism potential. EBRD will focus on supporting small and medium enterprise initiatives which are essential for tourism to grow. The EBRD tourism project has two objectives: (i) to promote Kyrgyzstan as an ecotourism destination, centered on unique, unspoiled sites while assuring their protection; and (ii) to promote local culture and protect the national heritage by reviving and marketing traditional handicrafts. Both of these objectives will support the development of private enterprises such as small hotels, rest camps, tour operators, travel agencies, guides, park wardens, and vendors for handicrafts, books and maps. The proposal focusses on development of the Ala Archa National Park.

Recommendations:

3.71 Recommended actions include the following:

* A tourism master plan for the international market is needed to focus internal and external initiatives on the types of international tourism Kyrgyzstan can most easily develop in the near term (ecotourism), and the type of institutional and physical infrastructure needed to promote it in its most likely markets. A plan is currently being developed, funded through the IFC.

* Social and environmental impact procedures should be established which must be adhered to by all sponsors of proposed tourism projects--both national and international.

3 The hunting license system should be reviewed and placed under the jurisdiction of one agency. Hunt quotas should be adjusted to promote rapid population recovery. This is critical to assure the long-term viability of a prosperous ecotourism industry. Background Papers: Natural Resources 94

A Brief Culeraw fntory

The Kyrgyz Republic has a complex cultural history, woven from the movements of the great nomadic groups of Central Asia, and marked by the fortressesand caravanserai of warring tribal groups and ancient trade routes. The current nation is comprised of an ethnic mix of Kyrgyz, Russians, Ukrainians, Uzbeks, Uigurs and Dungans(Chinese Muslims). The Kyrgyz languagehas been the official language since 1993, but most of the urban residentsspeak Russian.

Kyrgyzstan was first inhabited about 300,000 years ago, during the Lower Paleolithic period. Neolithic settlementshave been found in caves near Naryn and around Lake Issyk-Kul. As early as 1,000 B.c., Kyrgyzstan was a key link in the transcontinentaltrade routes. Later, during the Middle Ages, it was one of several routes for the Silk Road that linked Eastern Europe and China. Zoroastrian, Buddhist,early Christian and Muslim artifacts have been found beneath city of Tokmok, which was a strategic setdement along the Chu River for the trading and warring tribes who roamed the region. Tokmak was one of the few sites in the region that was not destroyed by Genghis Khan during his eleventhcentury rampage. The city of Osh,at the head of the Fergana Valley, is the site of one of the oldest trading cities in Central Asia, and was the regional center for Islam in the Middle Ages.

Althoughthe existence of the Kyrgyz as a people dates to at least 200 B.c, they did not migrate to the land called Kygyzstanuntl about the 16th century. They are of Turkic-Mongolstock, and trace their origin to the region around the Yenisei River in southern Siberia. The Kyrgyz are a pastoral nomadic people with strong tribal traditions--theirname is derived from Turkic 'kyrk + yz", or the Forty Clans. Their history on the land has been tomnby wars, particularly with the lowland Uzbeks. Four times between 1845 and 1873 the Kyrgyz were defeated by the Uzbeks (Kokands). This strife led the Kyrgyz to ally with the Russians, who colonized the region, and confiscatedthe better agricultural lands in the valleys. Land conflicts, combined with compulsory military service in the Russian army led to a bloody revolt in 1916, during which up to one-third of the Kyrgyz fled to neighboring countries. In 1924, however, the Soviet regime established Kirghizia, and in 1926 declared it a Sovietautonomous republic, recognizing the Kyrgyz as a nation.

The majority of the Kyrgyz remained nomadic until forced to settle during Stalin's push for colleeivization in the late 1920's. The people went first into kyshuiks, transitional villages, and then into cities, towns and onto collective and state farms: sovkoz, kolthoz and leskhoz. Not all Kyrgyz were successfullysettled, however, and many among thoseon the sovkhoz,kolkhoz, and leskhoz are only partially settled still, moving seasonallywith their herds into the high mountains in the spring, summer and fall. The nomadic lifestyle may have been constrained during Soviet domination, but stockraisingis still the basis of the economy. Only a small number of people have adopted industrial employment.

The Kyrgyz have rich resources to share with the world, as this new stage in their history begins. The Kyrgyz cultural arts remain strong. Both women and men are skilled horseback riders, and fine leather goods, silver jewelry, and briuiant felt carpets arc still crafted. They have a long tradition of story-telling and songs, accompaniedby the akomuz, a stringed instrument. The Manas epic poem is one of the longest poems in the world's traditions. It is a million lines long, and is said to have curative properties for the people who listen to it. BackgroungPapers: The mining 95 and MetallurgicalSector

4. THE MINING AND METALLURGICAL SECTOR

4.1 The Kyrgyz Republic is located within the Central Asian Fold Belt in the Teen Shan Mountain System formed by the collision of the Siberian and the North Chinese, Tarim, Karakul, Tadzhik and Kazakhstan-North Teen Shan plates. The country is still seismically very active. As a result of its complicated geological history, the Kyrgyz Republic possesses rich and diverse mineral resources, including gold, silver, antimony, mercury, uranium, and a range of base metals and rare earths.

4.2 Mining and metallurgy (M&M) are important sectors in the Republic's economy, accounting for 10 percent of industrial production and 11 percent of the workforce in 1992. The minerals produced include antimony and antimony oxides, mercury, gold, uranium oxide, minor rare earths (lanthanum, cerium, dysprosium, erbium, gadolium, holmium, etc.), molybdenum and calcium fluoride. A mine and processing plant for tin and tungsten is currently under construction.

4.3 The mining and metallurgical sector is facing serious financial and market-related problems. The sector was developed oriented to the traditional markets of the FSU, which have now collapsed. Under the FSU, for example, uranium was a critical strategic asset and in high demand for the military and energy program. Since independence, uranium operation has ceased, with the exception of the processing of uranium oxides at Kara-Balta using imported concentrates. Although the Republic has a significant world and inter-republic share of the antimony and mercury trade (13 and 20 percent respectively), the market is small. In addition, the world markets for rare earths, tin/tungsten, and molybdenum are depressed, and the future of these industries is not promising. Gold production is the only sector which is attracting notable interest on the part of foreign investors. The development of commercial gold deposits in joint venture with foreign companies is being considered, and further exploration for bulk deposits is likely.

4.4 The cost of energy, which is often 50 percent or more of the cost of production, must be considered in any analysis of this sector. The Kyrgyz Republic is dependent on other states of the FSU for most of its oil and gas supplies. With the constriction of supplies from the other republics, and the increase in demands for hard currency payments for fuel, the costs of energy have risen over sixty-fold, reducing profitability in a sector which was already suffering from inefficiencies due to antiquated technologies and the departure of skilled technicians and managers after independence. In addition to these concurrent factors which make the transition to a free market economy especially difficult, the majority of the senior and middle level managers are unprepared for the adjustments required by the changing economic environment.

4.5 EnvironmentalConcerns. The mining and metallurgical sector is expected to meet the cost of on-going pollution control, and site rehabilitation after productive activities cease. Although there are extensive standards and regulations governing the M&M sector, established during the Soviet period, mining in the Kyrgyz Republic has neglected environmental, safety and occupational health standards. Norms existed but were often ignored, and environmental monitoring virtually ceased over the last few years. The current severe cash flow reduction diverts attention from environmental problems, and probably means even less control over polluting operations.

4.6 The area of land directly damaged by mining works is estimated to cover 3,700 hectares; the volume of mining wastes is estimated at 43 million cubic meters. Mineral smelters release sulphur dioxide, arsenic and other pollutants into the atmosphere. Mines and metallurgical plants also produce large quantities of solid wastes. In particular, sulfur is commonly associated with mineralization in the Kyrgyz Republic, and therefore it is also associated with the waste products from beneficiation processes. BackgroungPapers: The mining 96 and Metallurgical Sector

Combined with moisture, oxygen and bacterial activity, dilute acid is generated. This acid leaches the waste rock or concentrate residue, drawing into solution some of the remaining mineral fractions. T'his mobilizes the metal salts, enabling them to be flushed out of the waste concentrations in rains or floods, contaminating surface water run-off. Eventually these contaminants make their way through the natural water drainage system, causing widespread but diffuse water pollution. The rivers are fast-flowing in the specific geographic regions where this mineralization occurs, and they flow into major inter-republic river systems. Although most of the drinking water supplies in the Kyrgyz Republic are drawn upstream from pollution sources, it is possible for contaminated water to make its way into irrigation canals, which are used for washing, cooking, recreation, and livestock, as well as for crops.

4.7 In short, few of the waste deposits from mining operations or metallurgical processes are adequately controlled. Almost all can be the source of diffuse air or water pollution, and in some cases toxic elements and reagents may migrate through the food chain. Examples of these pollutants include mercury compounds, arsenic, fluorides, and sulphur-based compounds in association with many base metals, and radiation from uranium and thorium waste materials. The extent of pollution from these sources still needs to be accurately assessed to determine the how serious the problem is. It is certain that to a greater or lesser extent, pollution is occurring and will continue. A comprehensive database must be acquired to assign priorities and to determine the cost of imposing standards and cleaning-up requirements.

4.8 The Haidarkan and Kadamzai Combinats alone are believed to have produced millions of tons of wastes, which contain hundreds of thousands of tons of mercury and antimony compounds, arsenic, fluorides, a wide range of sulphur-based compounds of heavy and base metals, and radioactive contamination from uranium and radium. Infiltration of toxic effluents into the air and ground water is strongly suspected at these two Combinats and at Orlovsky Combinat. The Sanitary and Epidemiological Service has data indicating the presence of mobile toxins in the environment and in people around the combinats--the highest rates of infant mortality and children's morbidity are found in the immediate areas. Overall, however, chemical mobility, epidemiological and ecosystem health data are scattered or non- existent, and it is impossible at this time to accurately assess the true extent of environmental damage associated with the sector.

4.9 Likewise, it is not possible at this time to determine the nature or extent of problems association with radioactivity around uranium mines, discard dumps, and active areas such as the coal mine at Kadzhy-Sai. Table 4-1 summarizes the discussion of hot-spots associated with mining activities which follows. The closed uranium mine at Kadzhy-Sai, adjacent to Lake Issyk Kul, is of interest in light of plans to develop the lake as a tourist center. Sites such as the uranium oxide combinat at Kara-Balta have been called by local experts "clear and present dangers to the health and safety of numbers of people". For most sites, however, insufficient information is available to accurately determine environmental conditions within and around the combinats. Environmental managers do not exist at each combinat-- usually the staff engineers are responsible for environmental controls along with other duties. In addition, the surveys of the sector which are readily available are not sufficiently detailed to serve as the basis for serious recommendations. Unfortunately, the lack of data makes any statement about conditions at sites controversial, but the absence of environmental oversight also makes the existence of hazardous conditions likely obsolete, poorly maintained or non-existent. Support may be needed to meet the cost of obtaining modem equipment. Backgroung Papers: The mining 97 and MetallurgicalSector

Table 4-1: Hot-Spots related to Mining Activities'

Site Primary Product Problem J Significance

Kata-Balta Combinat Uranium Oxide (i) Transshipment of hazardous materials; (ii) (i) Possible accident Molybdenum suspected leaching of toxins into the groundwater; (ii) potential wide-spread low-level Rhenium (iii) radioactive dust blown from tailings surface. ecosystem and human health Gold degradation

Former Uranium mine: Uranium ore (i) Unmonitored radio-active wastes located within Potential health impacts on proximate Min-kush settlement a seismically unstable, flood plain area; (ii) site communities including Min-kush located within the watershed for the Kekemeren (12,000 pop.), and village (2,000 River and Toktogul reservoir. pop.) on mine property.

Former Uranium mine: (i) Uranium ore in association (i) Site is proximate to Lake Issyk-Kul -- Broad-scale public health and Kadzhy-Sai settlement with brown coal; (ii) Current insufficient containment of run-off exists, and ecosystem impacts associated with coal extraction by private unmonitored run-off from waste occurs; (ii) Lake radon. enterprise. waters and bottom mud contain low-level radioactivity; (iii) contaminated metal from old mine machinery is being salvaged and sold; (iv) unregulated private sale of radioactive coal for fuel occurs.

Former UJraniummine: Uranium ore Radioactive tailings dump, including toxic Erosion is threatening to carry Tuyuk-su chemicals and reagents. materials to the Tuyuk-su River, with associate broad-scale, low-level impacts.

Kadamijacombinat Antimony and Antimony Waste concentrates associated with sulphides and Public health impacts including (settlements of Kadamjay Oxides arsenic (As, SO,, and NO.) released into weakened immune systems' and Terek-Say) atmosphere. Metals--Au, Zn, Ag, and Pb--also associated wastes. Migration of toxic effluents into ground water.

Haidarkan Combinat' Mercury, mercury (i) Toxic effluents containing antimony, mercury Mercury compounds locally mobile in (settlementsof Haidarkan, compounds, and calcium and mercury compounds infiltrating ground water vegetation. 29% of the local residents Chauvay, and Uluu-Too) fluoride mined fmm wet and migrating to the Chauvay River; (ii) water found to have mercury in their surface and underground pumped from the wet mine is preferentially used systems; 26 % of the workers suffer operations in local agriculture; (iii) Stack emissions (CO, immune system deficiencies.' SO2, Hg, F, and NO.) exceed standards. Potential broad-scale ecosystem impacts.

Orlovka Combinat Rare Earths: thorium-bearing Thorium-bearing wastes, cadmium, moybdenum, Contamination of 20 km2 by (The Kyrgyz Mining & lanthanum, cerium, Pb, Cu, Zn, Be, and others. radioactive waste waters; human health Metallurgical Plant) dysprosium, erbium, impacts through cultivation of the land (settlements of Orlovka, gadolium, holmium, etc.; (grain and potatoes) and building Kashka, Ak-Tyuz village, zinc and lead materials; toxic levels of lead and llyich State Farm, and other heavy metals found in children Kichl-Kemin Village) l

Makmalzolto Combinat Gold: both vein and open pit Saturation of the dumps containing cyanogens (Makmal) l

1/ This table is intended to be representative of the type and extent of current problems associated with mining wastes--it is not intended to be all-inclusive.

2/ Local consultant's report.

3/ Also referred to as Khaidarken (local report).

4/ Per local consultant's report. Backgroung Papers: The mining 98 and Metallurgical Sector

4.10 Targeted interventions in the mining and metallurgical sector should be decided only after generating scientific evidence for hazard assessments. Funding should initially be found for monitoring equipment. In some cases, such as seismic testing, it may be more cost-effective to lease the equipment. Monitoring programs should focus on air and water pollution analyses and measurements of local and spread radioactivity (the latter can be effectively and quickly accomplished using airborne methods). Rock dumps, residue dams and waste impoundments must be investigated for integrity and stability. In the absence of reliable data, this base data substantiation phase is essential to plan objectively and should not be by-passed. It is an important cost-saving step, as the information gathered will help narrow spending priorities. On phase one information should be collected and assessed to prepare proposals for phase two -- defining remedial measures. Some sites will likely be identified as urgent, requiring priority action. It must be emphasized that any economic cost/benefit analysis applied to proposed actions in this sector should be augmented by factors such as safety, risk and hazard.

Hot-Spots in the Mining and Metallurgical Sector

4.11 There are several critical "hot-spots" identified in the mining sector at the site of current or former mines and metallurgical plants. Six of the sites are discussed below, including Kara-Balta, Min- kush, Kadzhy-Sai, Kadamzai, Haidarkan, and Orlovka. There are additional uranium, coal, gold, and other open pit and underground mining sites around the country for which there is little information. Local and international experts believe there may be problems with miners' health due to exposure to toxics, as well as more generalized environmental problems resulting from improper disposal of mine and refinery wastes, distribution of contaminated water to agricultural fields and burning radioactive coal for fuel.

RadioactiveTailings: Kara Balta Combinatand AssociatedMine Sites

4.12 The Kyrgyz Republic has produced uranium for the FSU since 1955. As uranium was a strategic resource for the military program, all mines producing uranium were administered by the former Ministry of Medium Machine Building and enjoyed preferential treatment, including in their budgets. Concentrates from all local mine sources and neighboring states were sent to a central refining plant at Kara Balta, sixty kilometers west of Bishkek, where uranium oxide and molybdenum were refined. Local uranium mining has ceased (adding to the hardship in the mining sector) but numerous surface tailing deposits at remain at each of the many mining sites. The list of dump sites is documented and available.

4.13 The different tailings of concern include:

* Waste rock from the mining operations usually containing low level radioactivity;

* Low grade milled residues, usually contained in pond impoundments where concentrating circuits was the first stage of the process;

* Waste residue;

* Low grade coal of high ash content, originally mined for its association with uranium, now mined to use as fuel. BackgroungPapers: Themining 99 and MetallurgicalSector

4.14 The Kara Balta Uranium Recovery Plant. The Kara Balta plant was the central processing plant for uranium concentratesreceived from many mining centers in the FSU. The plant produced a refined uranium to a high degree of purity. Some additionalproducts are also producedincluding refined gold. Due to the political and economic restructuring of the FSU and the depression of world prices in uranium, local mining has ceased, although concentrates are still shipped in from other sources for refining. Informationon the concentrationof uranium containedin the concentratesis not available,but all the leachedresidues were deposited at the site. The exact condition of the site is very controversial, but petitions to the governmenthave been made by the surrounding communityto clean up the site.

4.15 Superficialsurveys of the Kara Balta site indicatethat it has been operatedin what appears to be a responsiblemanner. In particular, the tailings impoundmentwas viewed. Technically this has been carried out to a very high specificationand is in a containedarea with drainagearrangements. The whole design approach was to minimize liquid leakage and air borne dust. It is a large, well-run depository. Containmentsare currently being preparedfor cyanide-contaminatedresidues arising from gold recovery. An independentand thorough survey of the area would be required to confirm that the tailing disposal dump does or does not pose a direct threat to human health.

4.16 TechnicalStaff. The laboratoryfacility which is the main analytical facility of the combinat is old and poorly equipped. The laboratory has a wet chemical analytical ability only. There were no modern tools such as spectrometers, atomic absorption, scanning X-ray analyzers, ICP's, etc. The laboratory staff, however, are experiencedanalysts, trained in the top facilities in Russia, and are the foundation for strengtheninglocal capabilityon radiation monitoring, although it may be desirable to make the lab independentof the Kara Balta facility.

Min Kush (Main Tailing Deposit)

4.17 This tailing deposit of 450,000 m3 covering 3.2 ha is stored in a valley through which a strongly flowing water-course runs. The water arises from melting snow and in the wet season is joined by a tributary which is normally dry. At that time, floods can occur. A dam controls downstreamflooding. The tailings were deposited following the design developed by the appropriate experts in Moscow accordingto good civil engineeringstandards. The adequacyof the dam constructionis unknown. The whole upper surface of the tailing was covered by a layer of fairly compactedsoil about one meter deep. A grass covering has establisheditself. There is an underwaterdrainage collection system in operation. No monitoringof this drainage system has ever been undertaken,however.

4.18 Below the dam, a village of about 2,000 people live in the old mine property houses. Further downstream, the town of Min Kush has a populationof about 12,000. A water diversion in a culvert over the dam dischargesinto a mountainstreamn which eventuallyjoints the Kekemerenriver whichflows into the Toktogulreservoir. The local populationshas expressedgreat concern about this tailings dam. If there were to be a wash-away,the radioactivetailings could be carried into the river and contaminate the water with radioactivity for a great distance downriver. In addition, the dam is located in a seismicallyactive area. There is a both suspectedfault line above the dam and upstream a large area of loose-lookingsoil has been cut into by the tributary stream. Flood, flash flood conditions or a major seismic disturbancecould precipitatean event of disastrous proportions.

4.19 The backgroundradioactivity on the surface of the dump was within the maximumperrnissible limit of 100 mkrR/hr. In one small area where the top layer had been disturbed, the background count exceededthe permissiblelevel. This could be easily corrected. No monitoring for radioactivity in the underdrainagesystem has ever been undertaken,which must be corrected. The opinion was expressed by local experts that radon gas does not leak up through the surface, but there is no evidence that this BackgroungPapers: The mining 100 and MetallurgicalSector

has ever been checked, and therefore it may be an inaccurate conclusion. If radon does escape, it would probably migrate downhill. As the half life of radon is 3.8 days, decaying as a radioactive dust, it could contribute to low grade background radioactivity over a wide area.

4.20 The location of this tailings site has received a lot of attention and public concern because it is in a flood zone, the associated water diversion is poorly designed, and the site is potentially a serious hazard. Moving the dump by either transportation or pumping, to a site 13 km away, in very difficult terrain, has been proposed as a remedial measure. Alternatives to wholesale removal exist and should be considered.

Recommendationsinclude:

* A full analysis of airborne and water born contamination must be conducted and a monitoring program established. This should include radon emission. The initial analysis must be integrated with any feasibility study for remedial actions.

* People should not be allowed to live on old mine property. Although hardship would be experienced, the inhabitants of the village below the site should be relocated away from any radiation.

X The question of dam location should be treated as a serious project on its own and deserves a separate feasibility study and recommendation of remedial actions.

* The hydraulic limitations of the existing construction is the potential cause of a wash- away occurring. The existing installation does not appear adequate to safely convey flood waters away from the dam. Also, the unstable area above the tailings dam could create unsafe conditions.

* An independent investigation, using local civil engineering experts should consider a river diversion well above the present collection system. This, coupled with a large canalized water course to one side the tailings site, designed to handle floods, may be the only remedial action necessary.

* The tributary should also be canalized and be led into the main stream also well above the existing natural junction.

* The need for the small existing water dam would then end and the area behind it could be filled in as suggested below.

* The seismic activity in the area needs to be analyzed. A seismic survey and location of the fault needs to be undertaken by reliable geologists skilled in this technique. After this has been completed a decision could be made as to whether or not a landslide should be artificially induced. The soil arising from this could be used to fill the existing area immediately upstream of the existing inadequate dam wall. If the final decision is not to move the tailings, the landslide soil could also be used to supplement the covering of the surface of the tailings area to make it more impermeable. BackgroungPapers: The mining 101 and MetallurgicalSector

Kadzhy Sai

4.21 The Kadzhy Sai uranium mine operated from 1949 to 1967, in close proximity to Issyk-Kul Lake. Uranium was extracted from brown coal (shale) with a high ash content. The coal was incinerated and the heat utilized for power generation. The uranium was extracted (leached) from the ash after incineration. It is not known what, if any, emissions occurred, as some precaution against this occurring must have been in place. The dump is small in volume, as the tailings are only ash. It is properly constituted, covered and there is only a low emission rate within limits. The state of the tailings is therefore considered satisfactory and not a hazard. Runoff, however, occurs and to contain this, a small earth pack dam has been constructed. This creates a pool area below the tailings to curtail leakage from the area. The small dam is well built, but if the holding pool below the dump fills after heavy rains, it could begin to undermine the main dump. The dam wall should be removed and a "swinuning pool" type containment should be provided to contain 100 year storm flood levels.

4.22 Adjacent to this dam is another covered dump containing some radioactive material and equipment resulting from the break-up of the uranium recovery plant. This was constructed in line with disposal standards current at the time it was built. The old mine is now overrun with dwellings, however, and local residents have discovered the buried equipment (electric motors for example). Radioactive waste materials are being retrieved and sold for scrap metal. This can not be allowed to continue.

4.23 Recommendations:

(i) The Kadzhy Sai materials dump should be broken up and the equipment disposed of in a different way in accordance with current thinking.

(ii) People should be re-located to areas further from any source of radiation. Although this may cause hardship, the public health costs and future political ramifications are likely to be greater. Perhaps the IAEA should be consulted for assistance, if this has not been done already.

(iii) Another possibility may be to move the ash and equipment dumps to other sites. The volumes are not large.

(iv) A general survey should be carried out to determine the exposure of the local population to direct and background radiation. There is a high concentration of people in the immnediatearea who may be exposed to unacceptable levels radiation.

4.24 Uranium recovery from the coal at Kadzhy Sai was stopped when lower cost ore was discovered in other states of the FSU and sufficient uranium was being produced from other sources to supply the demand for the program. The brown coal still contains uranium and is therefore radioactive. The coal is still being mined by a private enterprise and the coal sold. The radioactivity in the coal is not removed. The entire operation must be curtailed and regulated. Sale of radioactive coal could result in wide spread radioactivity and radon emissions in homes where the coal is being burned or stored. It is urgent that this enterprise be investigated and regulated without delay.

4.25 The coal seam which is being mined underlies Issyk-Kul lake as well. At one time experiments were conducted to extract uranium from the water of the lake. It is therefore probable that a very low level of radioactivity is contained in the lake water. The mud at the lake bottom near the underlying seam is reported to be radioactive. This should be investigated as it may have implications for any future tourism development plans centered on water sports. BackgroungPapers: Themining 102 andMetallurgical Sector

AntimonyMine: Kadamzai

4.26 The KadamzaiCombinat, located on the edge of the FerganaValley, refines very pure antimony and antimony oxides. It provides 13 percent of the world's market--asignificant share. The oxides are used in plastics and rubber goods; the metal in the automotive industries and steel alloys.

4.27 Only 10 percent of the ore used comes from the two mines nearby which are of very good purity. Twenty-fivepercent is bought from Tajikistan and Kazakhstan,and the balance from other sources in Russia. The transport costs add a heavy burden to the purchase price which the combinat did not have to pay previously. The new price structure of buying concentratesstrongly influencesthe margins. Add to this the recent rise in energy costs and the now long standing depressed antimony free market price of products has in a short time critically upset the viability of the mine. The antimony mine is in an extremely weak position.

4.28 Some of the Russian concentrateof Siberian origin contains gold, further contributing to the Combinat's financialdifficulties. Under the FSU, this material was stockpiledafter antimony recovery, but now it must be returned to the source. Russiahas been planning to build its own plant for two years, and for eleven months no Russian material has been available for purchase. The availability of processing material for purchase is very unclear, therefore. In addition, there has been no investment for 20 years, and the entire operationis based on outdatedtechnology and equipment. If Russia persists in building a new plant, it could be the death of the mine.

4.29 To survive, a change to higher added value products is being assessed which is based on French technology. This would be based on alternativeproducts sold to supply a growing market in the plastics industry with a larger margin potential. A similar but alternativeproduct is also up for consideration based on UK technology. Productionof very pure antimonymetal could be a further possibility,but the very large capital expenditureto install a new electro-winningplant would be financiallysuspect without proper financial appraisal. Lack of experiencein the free market and limited capabilitiesin the financial analysis, makes the decision procedure for Kyrgyz officials, and no feasibilitystudy has been conducted yet.

4.30 EnvironmentalIssues. All of the concentratesat Kadamzaiare associatedwith various sulphides and some contain arsenic as arcenopyrite. Therefore, a pyro-metallurgicalroute, as is used to recover the antimony, causes real environmentaland health problems. This was very apparent in the plant--to the extent that it may need to be condemned. Sulphurand arsenic fumes end up to a greater or lesser extent being emitted from the stack or in the plant. In both cases it is a hazard. As the ore contains about 0.6%, an estimated250 tons are emitted annually. The exact containmentof arsenic and sulphides in the process must be determined and a mass balance made--thematerials must go somewhere in the system. Only antimony is accountedfor in the recovery process--theexcuse is lack of funds.

4.31 Apparently no monitoring of the stack discharge has ever been adequatelyperformed and no monitoring at all is being conducted now. Therefore, the quantities of As, SO2, NOx or any other emissionsare unknown. The same is true for metal or salt content in water discharged. Filtration from the toxic effluentdumps into the ground water are reported. Despite trench mitigation efforts in 1988, toxins have been traced 0.5 km away from the Vuadyl settlement.

4.32 In conclusion, little attention to care, maintenance or up-dating the technology used in the installationcoupled with a depressedmarket and the inexperiencein dealing with the fluctuationsof free market, make this a poor and vulnerableoperation. The followingactions are therefore recommended: BackgroungPapers: The mining 103 and MetallurgicalSector

* A complete sampling of airborne and water-conveyed contaminants must be made. Full analysis of the impurities in all water paths to the environment must be investigated. In metallurgical terms, a full plant audit is called for which includes mass balance analysis.

* The Sanitary and Epidemiology station should carry out a similar assessment in the adjacent human population. The toxic hazard to operators within the extraction/recovery areas must be critical. The existing regulatory body (State Committee for the Environment) should be much more vocal as to what is being condoned in this plant, regardless of the lack of funds.

Mercury Mine: Haidarkan Combinat

4.33 The Haidarkan Combinat provides 64 percent of the CBS production and 20 percent of the world production of mercury. Haidarkan Combinat previously exported to Russia Kazakhstan, and the Ukraine; in 1993, US, India and France joined its export list. The mercury it produces is used primarily in electrical and electronics industries, manufacturing chlorine and caustic soda, and manufacturing measurement and control instruments. It processes a complex ore, rich in mercury, and including some antimony. The ore types are associated with sulphide and fluoraspar (CaF2 ).

4.34 The sale of mercury to the FSU is now depressed due to the poor demand. Due to the availability and use of substitute materials, world mercury prices are stagnant or declining. The current level of mining cannot be sustained. Further, due to over staffing at reduced output, low grade of ore being mined and the steep rise in the cost of energy which accounts for 70-80% of the total production costs, the mine is experiencing severe cash flow problems. The operation is not viable at the current price of $1000 per kg.

4.35 There are plans to reduce the work force by about 30 percent. This will create socio-economic problems in the surrounding community which is dependent on the mine. Lower grade areas of the mine are also to be put on a care and maintenance basis in an attempt to extend the life of the mine.

4.36 The pro-active plan of the Chief Engineer, who has wide experience at other enterprises in the FSU, is to start re-processing waste dumps containing mercury in a specialized process to be tested in a pilot plant operation. The incentive to start this work is in the concurrent recovery from the wastes of selenium, which has a value of five times the value of mercury. Mercury processing from the current operation will only be carried out to meet any demand in excess of the recovery circuit. The viability of the operation is not at all certain. A three-to-five year period is the probable time frame required to implement and test the re-treatment.

4.37 EnvironmentalFindings in the surface and undergroundmine. The technologyand equipment is an outdated pyro-metallurgical operation using gas to heat the ore to elevated temperatures in rotary kilns and open hearth furnaces of antiquated design. To make matters worse, the FSU obviously absorbed the full production costs and fiscal transfers were kept to a minimum--only covering costs to keep mine in production. Therefore, little maintenance was done and the plant was not upgraded to improve efficiency or safety. This situation has lasted for a long time. As the viability of the operation is in doubt, it would not be attractive to invest money in the mine, although it reportedly contains a good resource of high grade ore (cinnabar). BackgroungPapers: The mining 104 and Metallurgical Sector

* The ore contains sulphides and fluoride, in addition to mercury--all of which are very hazardous. Althoughthere is serious risk to undergroundworkers, miners are checked irregularly due to lack of funds. Control checks of the ventilationshould be made.

* The mine is wet, generating weakacids underground,placing into solution other metals, and mobilizingfluoride and sulphate salts. When pumped out of the mine to the surface, the water may eventually contaminatethe nearby river, flow across the border and join the upper reaches of the Syr Darya in Uzbekistan. In fact, the effluencescollector of the Chauvay metallurgicalplant is not sealed, so effluences with a high concentration of mercuryare migrating to the Chauvay River.

* Methyl mercury may be generatedby anaerobicdigestion. This is migrates through the food chain. Only mercury, which is the metal of production interest, is monitored in any outflow. No systematicmonitoring has been practiced for the last five years, however. Informationon metal salts draining across the mine boundary does not exist.

* No run-off from the tailingswas reported but a small stream draining from the dump was observed. The likelihoodof a contaminatedplume after precipitationis high, although the managementis adamant that there is no chemical reaction on the dump. A further serious finding was that the water pumped from the wet mine is preferentiallyused for unspecifiedagricultural purposes, further increasingthe likelihoodof mercury mobility through the environmentand human population.

4.38 Environmental findings on plant and air emissions. The direct heating of the ore to very elevated temperatures (700°C and above) with gas creates airborne emissionsthat are very difficult to contain. Stack gases containingCO, S02, Hg vapor, F and NO, must occur despite filtration. Mercury alone is monitored and it can exceed the allowable quantity by a factor of four. A rough estimate of some 40 tons of Hg emittedannually is possiblewithout even consideringthe other emissions. Additional emissionsfrom the kiln smeltingare probable as well, althoughan exhaust systemwith filters in the stack is in operation. Precipitateis removed from the filters as a wet sludge, impoundedand then returned to the process for smelting. Some antimonyis also containedin the residue.

4.39 In summary, the operation is depressed, and operating at a loss. There is little prospect of privatizationin the foreseeablefuture. As the operationis in severe difficulty, health and environmental problems are not addressed due to lack of funds. The three-to-five year time frame for rescuing the mine may be far too long from both an environmentaland economic point of view. Air and water monitoring need to be initiatedurgently to target immediateimprovements, and to know what remedial actions are needed when the mine eventually closes. Environmentalmonitoring of the tailings dumps and residue impoundmentsmust be reinstated and maintainedwell after closure of the mine.

4.40 Critical environmentalexposures to mercury and antimonycompounds may be occurring at the mine and within the broader community surrounding the mine. The occupational hazards to which operators are exposed, as well as hazards to the wider communitymust be assessed. Toxins appear to be migrating through the environmentand threateninga far broader environmentalimpact down stream. The Sanitary EpidemiologyStation, which is doing commendablework, has collectedsome publichealth data. This should be gathered and integrated into the broader environmentalassessment of the mine. The significanceof poor environmentalmanagement at the mine in terms of long term public health and ecologicalliabilities cannot be overstated. Backgroung Papers: The mining 105 and MetallurgicalSector

Orlovka Combinat (The Kyrgyz Mining and Metallurgical Plant)

4.41 The Kyrgyz Mining and Metallurgical Plant extracts and processes rare earths such as lanthanum, cerium, dysprosium, erbium, gadolium, holmium, etc. Thorium-bearing lanthanum is the most critical element among these in terms of the environmental problems. Five waste depositories are associated with the plant, two active and three closed. These contain thorium-bearing (i.e. radioactive) cadmium, molybdenum, lead, copper, zinc, and beryllium wastes. The exact condition of these dumps and mobility of wastes from them is unknown. It is known that Waste Depository #2 broke in December, 1964, flooding 20 km2 with radioactive waste waters. The depository was reconstructed and continued in use until 1971, and mitigation efforts were undertaken in the surrounding countryside. The Sanitary and Epidemiological Service has tracked subsequent human health impacts from the continued cultivation of the land (primarily grain and potatoes), and the use of contaminated materials for construction. Toxic levels of lead and other heavy metals have been found in children in the region. Strict monitoring of the mobility of toxic elements should be instituted and impoundments reconstructed if necessary.

4.42 Institutional Oversight. Institutional oversight of the mining and metallurgical sector is presented below, including the administrative structure, legal and regulatory status, and data available.

4.43 Surface and sub-surface resources are the property of the State, although privatization of certain operations is being considered. Currently, the functions of the State to own, regulate and operate mines are confused. The institutions currently involved in the administration of the mining sector include the State Committee on Geology (which maintains and updates the geological data base), Kyrgyzaltin (the State holding company operating industries in key minerals), The Ministry of Energy (which oversees coal mining), the Ministry of Economy and Finance (in charge of taxation), the State Committee on Environmental Protection (responsible for monitoring, inspection and enforcement), and the Academy of Sciences (responsible for basic geological research and theory). A new government oversight structure has been recommended by Bank sectoral studies, which creates a Ministry of Mines. This new structure would emphasize supervisory as opposed to operational functions.

4.44 The State Committee on Geology has existed since the 1930's. It explores for all types of minerals, identifies and tests ore-bodies, and conducts preliminary technical and economic studies. The Committee is responsible for geological cartography, geophysical and geochemical surveys, and maintains a high quality geological data base. The data base includes base maps and surveys for essentially the entire country. Geological and topographical maps are available for sale at the scale of 1:200,000. Detailed geological maps and geophysical and geochemical surveys exist at 1:50,000 and 1:25,000, but much of the data at these scales are considered "state secrets" and are not available to the public.

4.45 The staff of the State Committee on Geology has a reputation for professionalism and excellent training. The Committee is very compartmentalized, however. A legacy of secrecy also exists which makes obtaining existing data or conducting cross-disciplinary analysis of environmental issues difficult or impossible. Encouraging a more team approach to issues would help alleviate this situation.

4.46 The Academy of Sciences complements the State Committee on Geology-scientists at the Academy conduct basic geological research and test new theories. In 1992, the Academy's Institute of Geology commenced a survey of heavy metal deposits to develop a map of natural and man-made long- term ground pollution. This study is assessing:5

5/ Duchemin,July, 1993,Kyrgystan. Environmental Health Services in Europe. WHO-OMSDraft Report. Copenhagen:WHO Bureau for Europe. Backgroung Papers: The mining 106 and Metallurgical Sector

* natural sources of mercury, arsenic, lead and beryllium carried to irrigated fields by erosion;

* arsenic pollution from antimony smelters;

* lead deposits in industrial zones around Bishkek; and

* chromium and zinc deposits around Bishkek.

Sectoral studies have suggested that the geology section of the Academy be absorbed into the State Committee on Geology. The motivating factor is lack of funds.

4.47 Kyrgyzaltin was formed by Presidential Decree in 1992 "to increase the production of gold, develop the raw materials base, ensure rational use of industrial potential, implement new technologies, develop social infrastructure in the interest of local populations affected by mining activities, and ensure environmental protection."6 All mining and metallurgical enterprises, which were formerly under the Ministry of Industry, were placed under Kyrgyzaltin--except coal. These enterprises include:

* Kara-Balta Combinat (Uranium oxide/molybdenum)

* Kyrgyzoloto or Makmalzolto Combinat (Gold)

* Kyrgyz Mining and Metallurgical Combinat (Rare earths)

* Kadamzai Combinat (Antimony)

l Haidarkan Combinat (Mercury)

* Sari-Jass Combinat (Tin-tungsten)

* Tash-Kumir Semi-conductor plant

Kyrgyzaltin has the authority to create foreign and domestic joint ventures, and provides marketing, design/engineering, construction, technology and other advisory services. Although it is regarded as a self-sustaining state enterprise, the president of the firm is appointed by the Prime Minister.

6/ Quoted from the MiningSector study, page 26, para. 1.84. BackgroungPapers: The mining 107 and MetallurgicalSector

4.48 The reassertion of central control over valuable State assets through Kyrgyzaltinmay facilitate the developmentof a rational and coherentstrategy for the sector during the current economic transition, including a strong command and control environmental regulatory structure. It may suppress the developmentof a competitivesector, however, making it difficult to reduce direct or indirect subsidies, or impose market incentives for better environmentalmanagement.

4.49 TheMinistry of Energy operates eight undergroundand open pit coal mines. These mines have limitedreserves and there are technicaldifficulties extracting the resource. They are not competitivewith mines in other areas of the CBS but are consideredstrategically important by the GOK as gas and oil fuel supplies become more uncertain. Production at the Kyrgyz Republic sites has fallen due to lack of equipment and supplies, and the departure of technical experts. The MOE plans to increase coal production for industrialapplications, but these plans may be difficultto actualize,and although there are two coal-fired power plants, no more are likely according to sectoral studies. There are associated environmental liabilities such as SOx and particulate emissions from coal-burningplants, unhealthy conditions for workers within the mines, and radioactivecoal beds being actively worked and the coal sold. Data are very limited, however, on the extent of these problems.

4.50 The State Committee on Environmental Protection (Goskompriroda), which is discussed in far more detail in the Chapter on Institutions,is responsiblefor administeringenvironmental regulations and laws in the mining sector. The powers and responsibilitiesof Goskomprirodain relation to the sector are unclear, however. For example, the Committeedoes not have staff inspectors, equipmentor funds for inspections. Like the State Committeeon Geology, technicians,although individuallyhighly skilled, tend to be too specialized--notgrasping the comprehensiveapproach whichis required for environmental research and monitoring.

4.51 In theory, all mining plans require environmentalimpact assessments, which must be submitted to the Committee on EnvironmentalProtection for approval. Conditions for environmentalprotection have not been specified either in the general legislation goveming the sector, nor in the various investmentagreements which are being negotiated with internationalpartners. Standards and fines for noncomplianceexist and can be severe, but it is unclear what the level of fines are, whether they are enforced and timely, and who is liable--individuals,enterprises, or the state. The effectivenessof the penalties is therefore questionable.

4.52 Legal Regime. The Law on Sub-SoilResources, passed in 1992, is the primary law governing the mining and metallurgicalsector. Several presidential decrees also interact with he sector:

* "CreatingState Concern 'Kyrgyzaltin' (10/15/92);

* Decision of the State to "Improvethe Output of Gold" (12/31/92);

* "Organizationof Kyrgyzaltin"(1/18/93);

* "On Enterpriseswithin State ConcernKyrgyzaltin Not Liable to Privatization"(4/06/93).

4.53 The Law on Sub-SoilResources designates that all sub-soilresources are the property of the state, managedthrough a "State Fund" of the Jogorku Kenesh. The Republichas authorityover and primary responsibilityfor policy, strategy, legislationand regulations, geological research, compiling the state "mineralbalance", signing internationalagreements, and protectingsub-soil resource users. The regions or oblastsare empoweredto coordinatewith the republicon conditionsfor granting rights in each oblast-- sharing usage payments, and jointly carrying out developmentand implementationof the projects. The BackgroungPapers: The mining 108 and MetallurgicalSector

municipaland districtgovermnents (akimiat and rayon) are empoweredto grant licenses for quarrying "commonlyavailable" minerals, developingminerals for the use of local industries, and regulating the constructionof buildings and land uses. Although the state owns all sub-surfaceresources, exclusive rights to resource exploitationmay be granted to "juridical persons and citizens". Exploration rights, however, are not exclusive; most exploration is conductedby the State Committeeon Geology.

4.54 Transferable licenses are issued permittingthe exploitationof resources, after extensiveex ante regulation and negotiationof the terms and conditions. The State retains the power to set the standards for geological exploration, establish mineral delivery quotas, govern the supply of raw materials and payment norms and determine the level of production. Licensees must submit all geological data obtained,provide miningplans and environmentalimpact assessments, conduct safe activities,protect the environment, rehabilitate the land, and pay regular fees. Licenses may be cancelled if they fail to comply, or the technologies used endanger the health and safety of personnel or near-by residents. Revokingthe license (rather than penalties or fines) is the only real mode of enforcementavailable. In addition,there are no explicitprovisions in the law covering the orderly shut down and rehabilitationof mined-outareas.

4.55 The existing regulatoryand enforcementcapacity of the sector may be enhancedby separating the production and regulatory functions currently combined in Kyrgyzaltin and the Committee on Geology. Sectoral studies have suggestedthat the existing institutionsbe reorganizedand reformed to focus on overall coordination and supervision of the sector, which should strengthen environmental management. To this end, the creation of a Ministry of Mines is recommended, with several departmentswhich would

* assume the responsibilities of the current Committee for Geology regarding the administrationof the Law on Sub-SoilResources;

* maintain a registry of mining enterprise permits and titles, and which includes documentation of the licensed activities, and permitted emissions ("environmental passportization");

* evaluate mining work programs;

* assess payments and royaltieson licensees, includingenvironmental charges and fines;

* oversee mine and environmentalsafety, and enforce compliance with environmental, health and safety standards; and

* assumethe role of Kyrgyzaltinas a temporaryholding company for governmentmineral assets--supervisingmineral asset disposal,and maintaininga databasewhich is organized in such a way that informationuseful for market analysis may be extracted.

4.56 The State Committeeon Geologymay be subsumedunder this Ministry of Mines or, combined with the GeologyInstitute of the Academy of Sciences, form an independententity committedto basic geologicalresearch, analysisand education. This Committeecurrently prospects for all typesof minerals, identifiesand tests ore-bodies,and conductspreliminary technical and economicstudies. Sectoralstudies suggestthat exploration,testing and evaluationshould be left to the contractingenterprises and investors. Rather, the Committee should focus on geological research, develop technical programs in the earth sciences, and establish computerized information systems (GAS) capable of mapping resources and activity for analyticalpurposes: BackgroungPapers: The mining 109 and MetallurgicalSector

* land use patterns--including settlements, agricultural, and potential tourism usages;

* exploration and exploitation licenses;

* geological structures, including active seismic zones;

* geophysical and geochemical data; and

* hydrological data.

Reconunendations for the Mining and Metallurgical Sector.

4.57 Environmental surveillance and control of the M&M industries must be restored. Existing deposits and industries fall into four categories with different but overlapping regulatory needs: (i) uranium mining and processing, (ii) non-ferrous minerals--mercury and antimony, (iii) lanthanum and rare earths, and (iv) coal, building materials and stone. The main characteristics of these industries and their associated wastes should be characterized and systematized. The key issues are as follow:

* Uranium. Uranium and other radioactive materials are the primary issue of concern. Uranium itself is associated with sulfides which cause various acids to form. The sulphide association is critical as it mobilizes uranium, radium and other metals in water. Any old mine site, recovery plant tailings or residue must be checked for radioactive and other toxic mobility as part of the action plan. As explained above, this applies to coal as well.

3 Smelters. Almost all the minerals sought in the Kyrgyz Republic are found in association with sulfides. When minerals are associated with sulphur, the method of smelting concentrate is the metal recovery route that has been most extensively used. All smelters must be monitored as part of the action plan. All routes to the environment, air borne and water borne occurrences covering all the lesser metal constituents associated with the primary one, and salts need to be taken account of in any monitoring program.

* Toxicity and heavy metals. When toxic metals such as Hg, As, or particular metals such as Cd or reagents are used in the beneficiation process (cyanide for gold recovery for example), these should tested for mobility and monitored.

* Storage integrity. Existing waste dumps, residue dams, and processing waste impoundments must be all investigated for stability and integrity without exception.

4.58 The mining sector is a key sector in the economy of the Kyrgyz Republic, and mechanisms for better organizing governmental oversight should receive serious attention. Appropriate laws should be drawn up guiding proper conduct in the industry. A "stand-alone" Ministry of Mines and Metals would facilitate the organization of oversight functions. A lead agent in the form of a Committee on Mining and Metals within the Ministry should also be considered. As lead agent, the M&M committee would coordinate with other ministries to focus environmental management. Currently, oversight bodies are fragmented and lack the power needed to regulate the industry on health and environmental issues. Institutional structures must put in place can implement and enforce environmental regulations and reclamation requirements. The separation of duties currently embodied in both Kyrgyzaltin and the State Committee on Geology may serve as a model. Backgroung Papers: The mining 110 and Metallurgical Sector

4.59 An Environmental Management Plan should be in place for every mine, covering prospecting and exploration, life of the mine, closure and long term post closure maintenance. Every mine should only be allowed to operate if it remains in compliance with the standards set at each stage of its life. This is a crucial step in any plan for sustainable development. The permit system is a powerful tool (which must be used fairly) by which the onus can be placed on the enterprise to operate within the norms set by the management plan, by making the issuance of permits conditional to compliance.

4.60 Environmental benefit-cost analysis must be applied to project evaluation. When the full environmental and social costs of an activity (or lack of activity) are integrated, different conclusions may be reached about the viability of particular activities. For example, standard economic analysis concludes that recycling metals contained in waste deposits is either marginal or nonviable. If this question were revisited, integrating the full environmental costs of toxic mobility, human health liabilities, and clean-up, recycling tailings may become a more attractive solution.

4.61 External support exists in support of the following sector reforms:

* Clarification of mining sector policies and strategies(included under the Bank rehabilitation loan); and

= Legislative reform including the mineral industry (included under the rehabilitation loan).

4.62 It is imperative that environmental factors, including legislative, standard and regulatory considerations be integrated into any efforts of sectoral reform. Donor support should be actively sought for environmental review of the sites, clean-up, technological improvements, and institutional strengthening, including the application of market-based incentives. Background Papers: 111 The Industrial Sector

Urban Environmental Liabilities

Urbangrowth. While most of the populationstill live in rural areas, cities in the Kyrgyz Republic have nearly doubled in size in the past 25 years, exceeding 2.2 percent populationgrowth annually. A large migration from rural to urban areas, particularly to Bishkek, has occurred in recent years as a result of the economic down-turn.The provision of urban infrastructurehas not kept up with the growth, however--public roads, housing, water supply and sanitation are incomplete and poorly maintained. Even in Bishkek, where infrastructure is most developed, more than 20,000 people rely on tankers for water and do not have adequate waste disposal facilities. The morbidity rates from respiratory effects due to air pollution is estimated to be 160/100,000 in the Republic, higher than either Uzbekistan (110/100,000) or Kazakhstan (100/100,000). The urban poor suffer the most from pollution-relatedhealth problems. Low-income families often face substandard housing and water supply, lack of sanitation facilities, poor solid-waste collection, industrial pollution, and housing built on lands which may be subject to natural hazards.

Air pollution. The primary sources of air pollution in cites such as Bishkek, Osh, Tokmok and Kara-Balta are thermal power stations, cement plants, chemical industries, urban transport, and mining wastes. In Bishkek, more than 140,000tons of air pollutantsare discharged annually into the atmosphere. The city's thermal power station, which uses high sulfur fuel, discharges almost 50 percent of the total sulfur dioxide emissions in the Republic. Urban transport, though still moderate in towns and cities, is a major cause of urban air pollution due to the wide-spread use of low-grade, leaded gasoline, and old vehicles. Morbidity rates are highest in urban areas -- 263/100,000in Bishkekas compared to 54/100,000 in the more rural town of Naryn. Even in minute quantities, lead emissions can be very harmful to young children--impairingneurophysiological development and promoting respiratory disorders.

Urban Water Supply and Sanitation. Today, 20 percent of the water distribution networks in major cities do not meet sanitary regulations. Most of the distribution networks are more than 40 years old and need major rehabilitation. Althoughgenerally drinking water is relatively good quality, about 12.5 percent of the water samples tested showed some level of bacterial contamination and nearly 20 percent of the samples were contaminated with pesticides. Pretreatment of industrial wastewater is insufficient, overloading municipal treatment plants. Furthermore, wastewatertreatment plants in most cities and towns do not function to capacity resulting in the discharge of partially treated domestic and industrial wastewater into surface and ground water bodies. Out of 227 pretreatment and treatment plants, 131 need rehabilitation. Groundwater in Bishkek and Kara-Baltahas been periodically contamirnatedby sewage leaking from the pipe networks.

Solid and Hazardous Wastes. Solid wastes are generally dumped into open landfills , creating potentialrisks to human health through direct exposureor throughleachate contaminationof municipal water supplies. In Bishkek, the solid waste dump is located close to the Ala-Archawater reservoir (which is also a tourist area in the summnermonths) and a potential health risk. Proper disposal regimes must be developed, as waste generationwill only increase as the populationand the economy grows. BackgroundPapers: 112 The IndustrialSector

5. THE INDUSTRIAL SECTOR

A. GENERALOVERVIEW

5.1 Compared with other countries of the Former Soviet Union (FSU) the Kyrgyz Republic is one of the least industrialized,with very few highly polluting basic industries, other than the mining and metallurgicalsector. In 1991, the industrial sector comprisedabout 38 percent of the GDP. The most important industries are mechanical and electrical engineering (vehicle assembly, washing machines, electrical appliances, etc.), light industry (mainly textiles), and food processing. Together, these accounted for about 75 percent of industrial production and 80 percent of industrial exports in 1991. Other significantindustries include the chemical, leather goods, and constructionindustries. The most polluting industries located in the Republic are mining and metallurgical enterprises, cement, electroplating,tanneries, foundries, slaughter houses, and textiles.

5.2 Many of the industrialenterprises are using out-of-datetechnologies and processingequipment, which have been poorly maintaineddue to lack of funds. With the break up of the FSU, the financial positionof these enterpriseshas further deteriorated. Industrialrestructuring will influencethe industry mix--themost significantshort-term environmentalbenefits may be gained through market-inducedshifts away from inefficient or unneeded industries which are no longer viable, to potentially less polluting processes. Non-ferrousmining (such as gold)and hydroelectricpower generationappear to be promising sectors--bothof whichcan have tremendousenvironmental impacts if not managedwell. Light industry, including electronics, food processing and textiles also show promise, and environmentalregulations should be responsiveto potentialgrowth in these areas.

5.3 For the most part, pollution control equipmenthas been installedin industrial enterprisesto treat liquid and gaseous emissions. Due to the heavy pollution loads from the outdated equipment and technology,and lack of maintenanceof pollution control equipment, however, pollutant emissions are mostly above acceptablenorms. The highest pollution levels are registered in Bishkek, Osh, Tokmok, and Kara-Balta. Types of air-borne pollutantsin these cities includedust, benzopyrene,sulfur dioxide, oxides of carbon and nitrogen, formaldehyde,and heavy metal salts. Childrenand people over sixty are particularly affectedby pollution, with lowered immune systemsand generally higher morbidity rates (263/100,000in Bishkekas opposed to 55/100,000 in Naryn). Air pollution is in more detail below.

5.4 Hazardousindustrial wastes have been largelyuncontrolled. Someof these wastes, such as items containingmercury, are deposited in municipalsolid waste dumps, others are deposited in uncontrolled sites, and in some casesenterprises are storing them temporarilyon their plant sites. There are no special treatment facilities or controlled landfills for hazardous industrial wastes in the Republic. Industrial effluents from enterprises in urban areas are mostly discharged to municipalsewers after rudimentary pretreatmentand constitutea heavyburden on overstretchedmunicipal sewage treatment facilities. Water pollution is discussed in greater detail in Chapter 2 on Water Resources.

5.5 Monitoring industrial discharges is the responsibility of the polluting enterprise itself. Independentchecks by the Committeeon EnvironmentalProtection (Goskompriroda)personnel at the national and oblast levels are now infrequentand very limited in scope due to budget constraints. The situation has deterioratedso much, that the Committeeknows it is now unable to detect and follow-up on deliberate misreportingand incompleteanalysis of pollutant emissions.

5.6 Finally, the level of pollution fees levied on polluting enterprises is too low to encouragethese enterprises to provide effectivecontrol of emissions. They would rather pay the pollution levy than to take corrective measures to reduce emissions. More often than not, the pollution fee is waived as the Background Papers: 113 The Industrial Sector

polluting enterprise claims an exemption due to economic difficulties. Goskompriroda almost never requires operators of municipal sewage treatment facilities to pay the pollution levy--which reduces the treatment facilities incentive to enforce pretreatment standards on polluting enterprises that discharge in municipal sewers. Cases have been reported where new enterprises are being constructed without adequate pollution control equipment, including those funded by bilateral agencies, further compounding the problems.

B. Toxic INDusrRLALWAsTE DISPOSAL

5.7 The disposal of toxic wastes has been a key governmental concern since 1984. Decrees have been issued to address the problem, but they have been difficult to implement due to lack of funds, equipment and information. Before 1984, decontamination and storage of toxic industrial wastes in the former Soviet Union was unorganized. Few enterprises had storage sites equipped with control measures to prevent migration of toxic materials into the ground, and due to lack of adequate oversight, enterprises were able to avoid proper treatment and disposal of the wastes they were producing. Thus, metallurgical, chemical and other branches of industry reduced costs for many years by ignoring waste treatment at the expense of the environment.

5.8 Throughout the Republic, information on hazardous wastes is insufficient to conclude what the extent of toxic contamination might be or to set priorities. Data over the years are inconsistent, and there is little detail on the chemical composition of wastes. The considerable divergence of data can probably be explained by the failure of every enterprise to routinely report the nature of their wastes, and different understandings of the meaning of "toxic industrial wastes." In order to better assess the problem, Goskompriroda sent a questionnaire to 109 industrial enterprises. Of those contacted, only 63 enterprises responded. Thirty-one of these acknowledged that they generated toxic wastes. Based on the responses, Goskompriroda estimated the volume of waste. For instance, as many as 95,700 mercury lamps (with as much as 65 mg of mercury each) and 1,300 mercury thermometers (with 2 grams each) are disposed of each year at uncontrolled sites. Approximately 5,000 tons of toxic wastes suitable for incineration are generated annually, and approximately 10,000 tons of inorganic toxic wastes are generated.

5.9 According to Goskompriroda, a facility to contain and treat hazardous wastes is needed. Plans have been developed, but lack of funds has prevented their implementation. To determine the most efficient program for dealing with toxic wastes, however, a thorough assessment is needed of the chemical composition, and quantities of toxic wastes being generated by industry. Once that information is available, an evaluation of the feasibility of various options for waste minimization and recovery as well as treatment and disposal.

Recommendations:

5.10 To address the problems of pollution and waste minimization in the Republic, the following actions are recommended:

* a list of the most polluting industries in the Republic should be drawn up to identify priorities for future regulatory and enforcement activities in the industrial sector;

* future investments in polluting industries should be linked to requirements to reduce pollution emissions through the strengthening of already established procedures such as the "environmental passport", or through the introduction of a more conventional pollution permit process; BackgroundPapers: 114 The IndustrialSector

0 for the most polluting industries (e.g. the cement factory, electroplatingworks, etc.,) a comprehensiveindependent environmental audit of the plant should be carried out with the assistance of the plant management,and an environmentalmanagement action plan drawn up to be incorporatedinto the enterprise'sbusiness plan and into Goskompriroda's pollution permit or environmental passport process. These agreements should be reinforced with financial incentives to encouragecompliance such as taxes or fees, as well as firmly enforced penalties for non-compliance;

* EnvironmentalImpact Assessmentregulations need to be modernized, and institutional capacity strengthened to ensure compliance of newly established enterprises with environmentalstandards;

* the capacities of the Republican and oblast laboratories of the Committee of EnvironmentalProtection need to be considerablyup-graded and expanded to support their independentmonitoring capability;

* a priority action plan should be drawn up for the regulation, treatment and disposal of hazardous industrial wastes, includingstorage of banned pesticides.

Air Pollution

5.11 The cities of Bishkekand Osh have the highest air pollution levels in the Kyrgyz Republic, at least two to three times above the average per capita emissions in the Republic. In 1992 dust in air in Bishkek exceeded two times the maximumpermissible concentrations(MPC), with pick highs 7 times above the MPC; in Osh the average was 3 times above the MPC with 4.8 pick highs. Cases of pollution above the MPC are registered also in Tokmnok,Kara-Balta and Dzhalal-Abad. Particulates, nitrogen dioxide, sulphur dioxide and carbon dioxide make up 70.4 to 98.5 percent of the pollution emissions. The levels of heavy metals in air is relativelylow, with the exceptionof lead in Bishkek(pollution from transport), where the average annual concentrationis above the MPC, and the pick average monthly concentrationis almost 5 times above the MPC.

5.12 Stationarysources alone emit about 737 thousandtons pollutants (642 thousand tones solid and the rest - gaseous), of which 643 thousandtons (87.3 percent) are removed at the source. The removal rate for particulates is estimated to be between 84 and 92 percent, whereas only between 10 and 30 percent of vaporous and gaseous emissions are treated. The main point sources are combined power plants in Bishkek and Osh, industrialenterprises (productionof heavy machinery)and the construction industry (cement factories). The combinedpower plant in Bishkekalone produces about 70 percent of point source pollution in the city.

5.13 Although there are only 371.2 thousand vehicles in the country, autotransportemits some 200 thousand tons and contributessignificantly (about 68 percent) to air pollution. About 25 percent of this amount is emitted in Bishkek. The main reasons are (i) use of low quality fuels, (ii) old and badly maintainedpark, (iii) lack of equipmentfor car tuning to minimizeemissions, (iv) heavy dependanceon autotransportfor interrepublicantrade, and (v) bad road conditions.

5.14 Generally emissions are decreasing--dueto contractionsin the economy rather than increasing emissions control. In 1992, particulate emissions were down 20 percent from 1988; vaporous and gaseous emissionsdown by 35 percent. Data on the emission levels of various pollutantsin the cities of Bishkek, Osh and Haidarkan between 1992 and 1993 are shown in Table 2-10. Although overall concentrations and frequency of peak events of particulates, benzopyreneand sulphur compoundsare BackgroundPapers: 115 The IndustrialSector tending downward, some emissionsare increasing. For example, emissions of nitric oxide, inorganic particulates and coal ash in Bishkek, and emissions of formaldehydeand coal ash in Osh are higher in 1993 than 1992. These increases are probably due in part to a switch to cheaper, lower grade fossil fuels as incomes have declined.

5.15 Bishkek: Air pollution sources and trends. The city of Bishkek is an administrative, industrial and cultural center for the Republic. Bishkek's climate, geographical position and meteorological conditionsslow the dispersion of atmosphericpollutants. Located in a basin near the head of the Chu valley, it is subject to atmospheric inversions especially during the winter months and at night, accumulatingpollutants in the lower levels of the atmosphere.

5.16 There are over 270 industrial, municipal and transport enterprises (of which 50 are significant polluters) within the municipal area which have both routine and intermittentatmospheric. Very large polluters, such as oil refineriesand metallurgicalplants, are not located in the city. Seventy-eightpercent of the city's pollutantsare emitted by the municipalpower plants. Other primary sources of air pollution are the construction, light machinery, glass, shoe, furniture, textile, and food industries, and vehicular transport. In 1993, there were over 75,000 cars, trucks and buses in the city. About 38,000 of them belongedto the state, includinga fleet of 6,000 buses. Local experts estimate the state share of pollution emissions is as much as 74,000 tons; in 1990 private transport's share was estimated at 4,800 tons. Recently the private transport share of total air pollution is decreasingbecause of the sharp rise in fuel prices. In addition, there are few environmentalcontrols on vehicle repair facilities. For instance, 10 out of 30 engine cleaning facilities do not recycle or treat their waste water.

5.17 There are more than 40,000 individual houses in the city, many of which burn coal for heat. Emissionsfrom home coal stoves were estimatedat 2,000 tons in 1990. Despitetheir relativelylow level of overall emissions, however, emissionsfrom home coal stoves are a particular hazard to the health of the people who use them. In addition,, coal mined from at least one area (Kadzhy Sai) is radioactive, and poses a radon hazard in the homes that use it.

5.18 Accordingto the Town BuildingInstitute, Bishkekis divided into two pollution zones: east and west. The main polluters in the eastern zone are Power station 1, Kyrgyzavtomash(a machine-building plant), Building materials Plant 1, Auto-AssemblyPlant, Drills Plant and "Djanar" firm. Hydromet reports that in this zoneoverall pollutionlevels are 5 to 10 timesthe MaximumPermissible Concentration (MPC). Formaldehydelevels fluctuate 2 to 10 MPC, particulates 1.3 to 3.8 MPC, nitrogen dioxide 1.7 to 3.0 MPC, and carbonmonoxide 3.2 to 4.8 MPC. In the western zone, overall pollutionlevels are also 5 to 10 times the PD. There the main sources of pollution are the Kyrgyzmebel (Kyrgyzfurniture) Industrial Association, the Lenin plant, the Frunze agricultural mechanical engineering plant, the Bishkekstroimaterialy--agroup of buildingmaterials enterprises, and the Dastan Transport Association. Formaldehydelevels fluctuatebetween 6.8 to 10 PD and particulatelevels are often up to 4.7 PD. Other emissions are usually within the standard PD.

Insttutional Oversight

5.19 Article 15 of the Law on EnvironmentalProtection (1991) required a national systemof technical and meteorologicalstandards be establishedto protect human and ecosystemhealth from toxic levels of air pollution. Until the current draft "Law about AtmosphericAir Protection"is passed, the laws of the former USSR are in force. The GOK implementsthe laws by establishing standards, regulationsand procedures. Background Papers: 116 The IndustrialSector

5.20 In theory, stationarysources are allowed to emit pollutantsonly when existing standardsare met and the state has issued a permit for the emissionsto take place. Polluting entities must ensure that the required controls are instituted, keep any preventionor mitigationtechnologies in good operating order, routinely monitor and report pollution emissions, and take additional steps to further reduce emissions. The State Committeeon the Environmentis in charge of tracking pollutantsfrom stationarysources and enforcing emissions standards and regulations; the State Motor-TransportInspection in the Ministry of Internal Affairs is in charge of vehicular emissions.

5.21 There are a number of additional agencies which interact on air pollution control issues. The State Sanitary-EpidemiologicalService is in charge of regulationsand sanitary norms in connectionwith human exposure to toxic pollutants. It establishes "sanitary-preventivezones" around industries with hazardous emissions, for the purpose of protecting workers and communities,and oversees any control actions related to toxic emissions. Hydromet is in charge of monitoring atmosphericpollution. They operate monitoringsites in the cities of Bishkek,Osh, Tokmok, Cholpon-Ata,Karakol, and Djalal-Abad.

5.22 Legal and Regulatory Context. In 1992, fees for pollutant emissions were establishedby the PresidentialDecree "Local and RepublicanFunds for EnvironmentalProtection." The State Committee on the Environment, and heads of the regional and municipal public administrationsare responsible for implementingpollution fees and siting polluting industries in the republic.

5.23 Article 35 of the Constitutionadopted by the Kyrgyz Republicin 1993, makes a clean and healthy environmenta state priority. Laws which impact the regulationof air pollution includethe Law about EnvironmentalProtection, the Law for Protectionof the Health of the Nation, and the President's Decree on Local and Republican Funds for EnvironmentalProtection. When there is no law or inadequate coverage of the law in a particular case, the State standards, regulations, procedures and technical requirements of the FSU are in force. Therefore, the 1980 USSR Law for AtmosphericAir Protection is still the primary law guiding behavior, although a new law is being drafted.

5.24 The former law imposescriminal penalties for the followingacts by individualsor enterprises:

Exceedingthe MPC standards for emissions;

* Exceeding the established norms for harmful physical influence on the ambient atmosphere;

* Emitting pollutants without the proper pernits;

* Improper use of or failure to use installed pollution control technologies;

* Operating facilities which do not have the required air pollutioncontrols;

* Producing and operating motor vehicles, planes, boats or any other mobile unit which does not meet the establishedemission standards;

* Putting into practice any inventions, projects or plans which do not meet the national requirementsfor ambient air protection; BackgroundPapers: 117 The IndustrialSector

* Violationof health and safety rules regarding the loading, transporting, and disposingof industrial or household wastes, or agricultural chemicals, which lead or could lead to ambient air pollution;

* Failing to follow the instructionsor proceduresestablished by the regulating agencies.

Recommendations:

5.25 Prevention is generally far cheaper and more effective than clean-upafter the fact. Much of the pollution in the Republiccan be reduced through careful selectionof the raw materials and technologies used in production. In particular, switching to more energy and materials efficient technologies, and recycling waste products will have a tremendous impact on effluents and emissions. As funds become availablefor investment, the following steps must be includedin efforts to reduce ambient air pollution:

* Phase out old, polluting industrieswhich are no longer economicallyviable;

* Introduce improved, less-pollutingproduction technologies,and in particular, institute waste recycling;

* Repair and maintain existing pollution control installations and introduce up-to-date control technologies;

* Switch from more polluting fuels such as soft coal and diesel to hydropower, electricity, natural gas, and liquid gas;

* Monitor and enforce existing emission standards;

* Implement a phased-inprogram for pollution permits and fees which reflect true social and environmentalcosts of emissions. Background Paper: 118 The Energy Sector

6. THE ENERGY SECTOR

6.1 Energy supply is a critical issue in the Kyrgyz Republic. Althoughthe Republichas coal reserves estimated at 2 billion tons, some oil and natural gas, and significant hydropower capacity, it remains dependenton unreliable external sources of energy which are costly in terms of hard currency demands. The Republic is also richly endowed with renewable energy resources such as solar and geo-thermal energy. The "Kun" State Business Project has been set up to research and develop these alternative energy resources, but these sources are far from becomingeconomically viable on a large scale..

6.2 Coal. Between 1991 and 1994, coal consumptionin The Republicdropped from 4.3 million tons to about 1.6 million tons'. Kyrgyzstanproduced about 800,000 tons of coal in 1994. Kazakhstanis the primary source of imported coal. The coal is a good lignite, with an average heating value of 4,000 kcal/kg., and a sulphur content of less than one percent. Ash content ranges from 10-35 percent (but is generally closer to the high end) dependingon the ore body and efficiencyof extraction. It is important to note that both production and consumptionof coal are declining rapidly due to high transportation costs, increasingprices of imported coal, and contracting consumptionin depressed industries.

6.3 Most of the Republic's coal is mined in the south, where as much of the coal is consumedin the north. A spur of the Teen Shan mountainsbisects the country, making transport of the coal (by road) extremely costly. The north is therefore supplied by coal from Kazakhstan. The cost of coal to consumers has increased relative to electricity and renewable biomass fuels. This is causing many communitiesto begin switching from coal to electricity, as well as placing increasingpressure or the limited renewablewood and other biomass resources of the Republic.

6.4 Residential consumptionof coal may decrease (with very substantial environmentaland health benefits to consumers and the population at large),as householdsexpand their use of electricity. It is possible, however, that there will be an overall increase in the use of coal for central heat and power generation in the Republic if inter-republictrade in oil and gas continue to decline. Heating in urban areas is providedby gas/coal/mazotfired central combined-heat-and-powerplants (CHPs)providing water heating in summer and space/water heating in winter. Due to the rising natural gas prices, CHPs dependenton gas have switchedrapidly to coal and mazot firing. In rural areas without CHPs, heating is providedby coal, wood, and manure/strawfuels. Somecommunities are graduallyinstalling additional transformer capacity (both with and without governmentfinancial assistance)to support the conversion to electric space and water heating and electric cooking. The shift to electrical heating--drivenby the unreliability of the CHPs--isoverloading the distribution networks, however, and transformer capacity is not being added at the rates needed. Poor households still have to rely on wood and manure/straw fuels.

6.5 Increased coal consumptionby CHPs and other power production in coal-fired boilers will increaseatmospheric emission of dust, S02, and greenhousegases (CO2 and CO) relative to using natural gas. The greatest enviromnentaland health impacts will be from increaseddust emissions, particularly in CHPs and in coal-firedelectric power stations with poorly operating(and in some cases non-operating) dust collectors. The highest priority will be to upgrade equipment, as well as maintain and operate dust

I/ KyrgyzstanEnergy Sector Review. BackgroundPaper: 119 The EnergySector

collectors in the CHPs whichare locatedn urban areas.2 In addition, substantialquantities of ash collect as residue at the coal-firedCHPs and other boilers. This will present a disposalproblem, with the need to evaluate options for cost effectivereuse, such as in cement and building-productsmanufacture as well as to minimizethe area of land occupiedas disposal sites, and to control dust generation at these sites.

6.6 Appropriate measures will also have to be taken to mitigate the environmentalimpact of coal production in both open pit and underground mining operations. The areas of concern include: dust control; minimizationof land disturbancethrough life-cycleapproaches to mine design, operation and closure; and control of acid drainage from pits, waste piles and underground workings. Particular attention needs to be given to mine workers' health and safety; control of underground fires and explosions; safe extraction of coal bed methane for local consumption;and control of surface subsidence in undergroundmining operations.

6.7 PetroleumProducts. As the governmentno longer controls the import of petroleum products, the exact consumptionlevels of petroleumproducts is not known. Petroleum product consumptionis currently estimated at anywhere 896,000 and 1.8 million tons per year. Drilling activity in the republic is low, due to lack of funds. The present production rate is approximately110,000 tons oil/year and 30 mil. m3 natural gas/year.3 (Natural gas consumptionin 1993 was 1.3 billion m3 per year.) Although Kyrgyz authorities have systematic plans which include environmental controls, there is a lack of material, spare parts and financial resources for operations, monitoring complianceto regulations, and respondingto emergencysituations. Pipelinesare increasinglycorroded internally, and pipeline sections pass as free spans over difficult trenches and riverbeds. There have been no reported ruptures, but breakagecould occur from mud slides, severe floods or earthquakes;and although the volumesof oil in the pipelines are not large, leakage could still be serious if it occurred in a critical watershed. On the whole, however--in spite of old equipmentand lack of resources--theoil industry does not represent a major threat to the environmentnow, or in the near term. Emissionsinto the air and soil are low. Sites are clean; equipment is maintained; abandoned wells are sealed; and the oil is under low pressure, reducingthe possibilityof catastrophicrelease. Potentialnew discoveriesof oil shouldbe well monitored for their environmentalimpacts.

6.8 Hydroelectricity. Due to its significanthydropower capacity, the Kyrgyz Republichas a surplus of electricity. There are 5 large and 13 small working hydropower stations in the Republic with a capacity of 3,000 MW. 75 percent of the Republic's electricity generation capacity is provided by hydropower. Although 100 percent of the populationis provided with electricity for lighting purposes, electricity utilization per capita is the lowest in Central Asia. The Republichas an enormousuntapped hydroelectricgenerating potential. Current exploitationonly amounts to 11 to 15 percent of their total hydro potential, but further developmentwill require enormous capital outlays.

6.9 A master plan of the country's hydroelectricresources was completed in 1993 which identified promising projects for development. The major constraintfor developmentis the lack of markets. The installed capacityexceeds current domesticuse. In addition, the operationof the reservoirs to satisfy the irrigation needs of downstream countries is in conflict with the power needs of the Kyrgyz Republic.

2/ A feasibilitystudy for retrofittingthe BishkekCHP is underwayunder USAID financing. The resultsof this studyare not yet available.

3/ Source: Environmentalassessment performed for the WorldBank by Novatech,December, 1994. BackgroundPaper: 120 The EnergySector

Nevertheless, there is an intent to increasethe exploitationof the hydroelectricitygenerating potential of the Republic, and efforts must be directed toward minimizing environmental and social impacts. Particular attention must be given during the planning stage to: (i) site selection for constructionof dams; (ii) dam height; (iii) design for water level fluctuations;(iv) minimumflow releases;(v) dam safety and protection from seismic activity; (vi) control of sedimentation;(vii) aesthetic considerations;(viii) resettlementof communitiesimpacted by water level rise; (ix) impact on cultural and historical sites; (x) impacts on fisheries (especiallymountain trout); (xi) impacts on alternativeproductive activitieson the land affected; (xii) impactson natural flora and fauna; and (xiii) impacts on tourism.

6.10 Priority should be given to exploitingthose resourceswhere these impactscan be minimized,and to integrating a multi-sectoral review process into planning and evaluating projects. It is particularly important to take an overview of all of the hydroelectricdams proposed for the country--notto consider them in isolation from each other, especiallythose in the same water basin. Environmentaland social impact assessmentmust, therefore, be fully integratedinto the technicaland economicevaluation of these resources. Examples have already been identified in the Kyrgyz Republic where dam safety has been compromisedby improper siting near fault zones and areas of seismic activity, improper construction methods, etc. Dam failures can lead to catastrophicimpacts on downstreamcommunities and economic activities. The followingbox briefly elaborateson hydroelectricdevelopment along the Naryn River.

6.11 In deciding priorities for siting hydroelectricschemes, particular recognitionshould be given to alternativeuses of these resourceswith importanteconomic potential. For example, the Western Karakol River may have great economic potential for white water rafting and other water-related tourism activities. These opportunitiescould be lost if the river is developedfor hydropower. The value of these alternative activities, combined with fisheries, agriculture, or other uses of the land may equal or outweigh the benefits derived from energy development. Economicanalysis of alternative development options which includesenvironmental and social impactsmay show that hydropowergeneration is not the optimal use of a particular water resource.

6.12 Fortunately, in the Kyrgyz Republic (as opposed to the heavily populatedregions of South and East Asia) the need for resettlementof communitiesdisplaced by rising water appears is minimized. For instance, it is estimated that hydroelectricgenerating capacity could be increased from 3,000 MW to 11,400 MW in the Republicwith the need to resettleonly 2 communitysettlements of 500 people in total. On the other hand, key habitats for preserving regional biodiversityare located in the Republic along watercourses, and competition for water among various human and natural populations may be intensified. Background Paper: 121 The Energy Sector

Hydropower and Envirommental Costs

A number of large hydroelectricpower plants (HEPP) have been built on the lower reaches of the Naryn River. They include the Toktogul, Kurpsaiskaya, Tashkumyrskaya, Uchkyrganskaya, and the ShamaldysaiskayaHEPPs. The construction of the Kamnbaratynskaya-2has stopped for lack of funds, and Kambaratynskaya-1is still at a design stage. More than ten hydroelectricpower plants are planned for construction along the middle and upper reaches of the Naryn River and on its tributaries, the Alabuga and the KokmergenRivers, althoughthe lack of funds may delay these projects indeftnitely.

The environmentalcosts of hydropowerdevelopment have received inadequateattention in the past, with profound economic costs. Energy was developed as part of the central FSU plan, but was poorly integrated into the local economy. Currently, electrical productionin Kyrgyzstanexceeds the capacity of the technical infrastructureto service demand, while the Republic's dependenceon imported fossil fuels is resulting in severe fuel shortages throughout the country. The overall trend in the economy is switching to electricity.

The loss of valuable biological resources and increased competition for land and water as a result of hydropower projects are cause for environmentalconcern, and have been inadequately considered in previous development plans. For example, more than thirteen thousand hectares of fertile soils were flooded by the Toktogul Reservoir. In additionto constricting downstreamwater supply to Uzbekistan and the Area Sea Basin, the dam destroyed the fragile ecological balance within the region and the once beautiful area surroundingthe reservoirwas transformed into a desert. The reservoir and the associated HEPP are located on one of the largest faults in the region--the Talasso-Ferganski,and landslides associated with desertificationare increasing.

Potential damage to dams from earthquakes is perhaps the most important environmental liability of development along the Naryn River. The region is seismically very active, and operating HEPPs are located on fault lines where quake activity may reach magnitudesof 9 to 11. The damage from dam system failure and resulting floods could be catastrophic. After the large earthquake near the Toktogul Reservoir in August, 1992, however, there were no large-scale protests against the dam--like those against the Tehri Dam in India after the earthquakeadjacent to it. Public awarenessin the Republic is low regardingthe potential environmentalproblems associatedwith large hydro-powerprojects.

To establish a strong foundationfor hydro-power development, research and analysis is needed in the following areas:

* Access to the considerable body of international knowledge on the social, economic, and environmentalimplications of various forms of hydro-powerdevelopment;

* Examinationof the environmentalliabilities of large dams, such as vulnerability to seismic activity, flooded lands and lost resources, and changes in regional hydrologicalregimes;

* Estimation of the true economy of hydropower in the Republic of Kyrgyz, integrating environmentalcosts and liabilities into the project appraisals.

Monitoring for the environmental impacts of current hydropower projects should be initiated. Comprehensivewatershed plans shouldbe developedwhich place both large and small energy projects within the context of the regional ecology and social systems, and balance competinguses of the land. BackgroundPaper: 122 The Energy Sector

6.13 TraditionalFuels. Rural communitiesrely on traditionalfuels (firewoodand dung cakes)as well as coal and liquifiedpetroleum gas (LPG), as the table below indicates(Table 6-1). Rising prices may be causing large shifts to wood and dung, acceleratingdeforestation, loss of organic materials in the soil, and soil erosion.

Table 6-1: HouseholdEnergy Sources (in %)

EnergySource Republic Urban Rural

Electricity 100 100 99

DistrictHeat/Steam 23 52 1

NaturalGas 24 56 0

LPG 24 18 29

Kerosene 4 0 7

Coal 52 32 67

Firewood 66 28 95

DungCakes 49 5 81

Source: KyrgyzstanEnergy Sector Review

6.14 Forests are not officially a major energy resource in the Republic. Only about 4 percent of the country is forested, and the annual reforestationefforts total about 3,000 hectares. The official annual harvest is only 40,000 m3 . Due to their sharply curtailed budgets, the local units of the State Forest Departmenthave little regulatingand enforcementcapability in the forest lands, and uncontrolledcutting of trees is rampant. A 1993 householdsurvey 4 estimated500,000m 3 were illegallytaken from roads and hillsides. The actual amount cut may be even higher. Greater attentionmust be given to the reliance on wood fuels by energy sector planners, if widespreaddenudation is to be avoided.

6.15 Prices. The tremendousincrease in energy prices since price liberalizationbegan, is one of the most important changes in the Kyrgyz Republicrelated to the economictransition period. The average unit price of energy imports increasedby fifty-fold in 1992, and by an additionaleighteen-fold in 1993. In 1993, the country importedabout US$171 million in energy goods. In 1994, imports are expected to reach about US$206million, or 30 percent of total imports. The Republicnow pays world prices for oil imports from Russia and Kazakhstan, and 60 to 80 percent of world prices for natural gas imports from Uzbekistan. Table 2-8 estimates the country's energy balance.

4/ KyrgyzstanEnergy Sector Review. Background Paper: 123 The EnergySector

6.16 Price increasesprovide a strong incentivefor energy conservationin all sectors of the economy, potentiallyleading to considerablereductions in emissions. In 1992, overallenergy consumptiondeclined by 18 percent, with a parallel reduction in pollution emissions. Higher energy prices should help lead industrial restructuringaway from heavy industry toward less pollutingtechnologies in lighter industries and services. It will also force all producers to become more efficient, which should reduce resource waste and associated environmentaleffects. Removing energy subsidies is one of the most painful measures of market reform and vulnerable to social pressure, however. In addition, Increasing prices forces shifts to altemative fuels, some of which are more polluting, such as lower quality coals, or more ecologicallydamaging, such as wood stripped from fragile forest reserves.

6.17 Domestic energy trends are summarizedin table 6-2 below. While overall sales have been relativelyconstant, sales to industrialconsumers have declined considerably,balanced by a large growth in sales to residential consumers. Likely future trends of energy consumption/supply will be towards increaseduse of electricity generally, but particularly in rural areas; increased pressure on exploiting limited wood and biomass resources in rural areas; increased exploitationof hydroelectric generating potential; and increasedcoal use through installationof cogenerationunits in existingCHPs fired by coal to produce electricity, in newly constructedpit head coal-fired power stations; and in industrialboilers.

Table 6-2: 1992 estimated energy balance5 (in tons of oil equivalent x 103)

Oil Gas Steam Lignite Electricity Total

Production 0.13 0.06 1.43 0.80 2.86 5.28

Imports 1.55 1.66 1.78 0.85 5.84 Exports 0.13 0.75 1.41 2.29 Consumption 1.55 1.72 2.46 0.80 2.30 8.83 and Losses

6.18 Critical fuel shortagesand rising prices inevitablymean that rural communitiesand workers who have been displacedby unemploymentrely increasinglyon fuelwood, straw and manure. The negative impact of this kind of fuel extraction from the land can be profound--increasingsoil erosion, degrading the few forests, and expandingdesertification. The expansionof reliance on these types of fuels needs to be assessed and addressedas an urgent environmentaland social priority.

6.19 These likely future trends provide the background for evaluating the environmentaland social impacts of adjustments in the energy sector in order to develop an appropriate energy sector environmental action plan to mitigate such impacts through technological, policy and regulatory mechanisms. It is important to point out that, in relation to other countries in the FSU, the Kyrgyz Republichas a low energy consumptionper capita and low incomeper capita. This can be seen in Figure

5/ Source: The WorldBank Energy Sector Review. BackgroundPaper: 124 The Energy Sector

2-1, which correlates energy consumption per capita with income per capita in nine countries. As the energy sector develops, the country must seek an energy mix which is relatively cheap, and conservation measures which can be quickly and inexpensively implemented. An example is industrial and home energy audits coupled with public education and assistance on better insulation and energy conservation.

Table 6-3: The Power Market in the Kyrgyz Republic (GWh)

Sector 1990 1991 1992 1993 % Growth

l ______[______I ______(19 90-93)

Industry 3,417 3,509 2,974 2,489 (10.0)

Agriculture 1,848 1,986 1,872 1,846 0

Residential 945 1,455 1,951 2,455 37.5

Other 1,139 1,179 1,315 1,195 1.6

TOTAL 7,349 8,129 8,112 7,985 2.8

6.20 Recommendations:

In summary, it is recommended that:

* maintenance and operation of dust collection equipment in existing coal burning CHPs, power and industrial boiler facilities is of high priority in the short to medium term when investment funds will be severely constrained;

* the maximum electricity generating potential of existing hydropower facilities should be exploited consistent with agreements on international water allocations (long term agreements which balance power/irrigation water exports with fossil fuel imports should be drafted);

* a comprehensive evaluation of environmental and social costs and benefits be incorporated into decision-making in evaluating alternative options for energy supply;

* modern economic analysis of alternative use (eg. tourism) of water resources planned for exploitation of hydroelectric potential should be incorporated into decisions relating to priorities in development of this potential. This analysis should be done on a country- wide basis. The analysis may show that certain areas should not be exploited for this purpose, but should be set aside as conservation areas; BackgroundPaper: 125 The Energy Sector

* an independentevaluation of the safetyof existingdamns, particularly those in seismnically active zones and near major faults should be undertaken;

* low cost means of providing energy for low income rural communitiesfor space/water heating and cooking to take pressure off limited renewableenergy resources should be investigated;fuelwood planting projects should be promoted; and

* options for increasedreuse of ash from coal burning facilities shouldbe evaluated. BackgroundPapers: Legislation, 126 Standardsand Enforcement

7. LEGISLATION, STANDARDS AND ENFORCEMENT

Institutional and Policy Framework

7.1 Current status. The Kyrgyz Republic inherited a basic institutional and policy framneworkfor environmental management from the former Soviet Union. Due to low priority of environmental protection, this framneworkdeveloped at a relatively later stage than in the West. Until 1998, when USSR and Republican Committee on Environmental Protection was established, there was no specialized environmental protection agency in the Soviet Government. Since independence the country has taken steps to adjust its environmental policy framework and institutions to the specific needs of the new state. Environmental responsibilities are delegated to the Parliament, the President, the central Government and the Oblast administrations'. They are defined in the new Law on Environmental Protection of 1991.

7.2 The Parliament (Jogorku Kenesh) is in charge of (i) defining the overall nature protection policy framework; (ii) developing and endorsing laws and regulations; and (iii) approving Government proposals on resource charges and taxes. During the first year of independence, there was a three-member parliamentary commission on environment. Due to financial constraints it was merged with the agriculture commission in a Commission on Agriculture and Environment (CAE), which coordinates and supervises proposed legislative changes in the field of the environment, as well as the incorporation of environmental issues in the agenda of the Parliament. While the Environmental Sub-Commission is actively promoting its agenda, since agriculture is a key sector for the Kyrgyz economy, the problems of this sector dominate the CAE's activities. Other Commissions also have environmental responsibilities assigned within their terms of reference (see table 7-1). According to the Constitution, a 105-seats Jogorku Kenesh is designed to replace the previous one, a 350-seats Soviet Supreme (after elections on February 5, 1995). The restructuring of the Jogorku Kenesh is expected to change the current composition and functions of the parliamentary Commissions.

7.3 Environmental responsibilities are delegated to the President's office2. The President has the authority to (i) establish specific rules of natural resource use; (ii) define and announce the boundaries and status of ecological emergencies and ecological disaster zones; and (iii) approve the procedures for collection and use of environmental protection funds. The President is also responsible for signing all laws adopted by the Jogorku Kenesh, including the environmental legislation, and for conducting international negotiations, signing and submitting for ratification to the Jogorku Kenesh international conventions and treaties.

7.4 In the central Government, a Governmental Decree passed in December 1992 assigned responsibilities for executing the State's nature protection and environmental management policy with the following agencies: the State Commnitteeon Environmental Protection (Goskompriroda), the Ministry of Internal Affairs, the Sanitary-Epidemiology Service (Sanepid), the State Committee on Geology and Underground Protection, the State Land Regulation Inspection, the State Forestry Inspection and the State Inspection on Industrial and Mining Safety. In addition, environmental functions are delegated to the

I/ Detailson the legislativeand regulatoryframework in the KyrgyzRepublic with regardto the enviromnent are providedin AnnexXX.

2/ When the President'sOffice was formed, overseeingenviromnental issues was assigned, among other functions,to one of the Presidentialadvisors. As a result of personalchanges, this functionwas abolished. Steps to improve the environmentalmanagement system, as well as to join some internationalconventions (eg, the Biodiversity Convention) may require a number of legislative and regulatory interventions of the President, and the availabilityof environmentalexpertise (of staff or consultant)in the President'soffice. Background Papers: Legislation, 127 Standards and Enforcement

State Agencyon Hydrometeorology(Hydromet), which carries out monitoringof air, water and soil quality. Environmentaldata are collected in the State Committee on Statistics (Goskomstat)and incorporated in the macroeconomic analysis, provided by the State Committee on Economy (Goskomekonomika).The Ministryof Water Economyhas both expertiseand responsibilitiesin water resourcesmanagement. The Committeeon Geologyis involvedin monitoringand explorationof ground water resources. The Ministryof Agricultureis involvedin environmentalpolicy issuesconcerning soil degradation,application of agrochemicalsand farming.

Table 7-1: Key Commissions of the Jogorku Kenesh

Commission Primary 1 Environmental I Responsibilities Responsibilities

Agricultural, Food and Ecological Affairs Agriculture Agriculture Land reform Soil conservation Ecology Land reform Forestry Air and water pollution control Pesticides, food safety National parks and wilderness Global questions

Science, Industry Development, Energy, Science Energy policy, conservation New Technology and Transportation Affairs Energy policy Road air pollution Industrial issues Scientific research Communication Global questions Transportation

Economic, Budgeting, Finance and Prices Budget Appropriation funds for programs Affairs Bank issues Taxation Taxation User fees Economic Global questions forecasting

Health and Social Affairs Public health Public and Occupational health Social welfare Pesticides Global questions

Legislature, Human rights, Defence, National Human rights Environmental laws, penalties Security and Fight with Crimes Affairs Civil, criminal codes Defence National security l

Trade, Consumer Goods, and Services Consumer rights Food safety Affairs Trade issues Consumer services

International and Interparliamentary International and International Conventions Connection Interparliamentary affairs

Building, Architecture and Industry of Building Construction safety guidelines Building Materials Constructing Architecture

Education, Culture,Language, International Education Environmental education relations, Sport, Tourism, Youth Cultural Affairs International issues Sport Tourism Youth

Keneshs, Public Affairs Local Governments Local responsibilities on environmental issues Local Keneshs Publicity BackgroundPapers: Legislation, 128 Standardsand Enforcement

7.5 Goskompriroda is the key agency in charge of environmental policy and nature protection regulations. It was created in 1988 as a part of an all-FSU effort to strengthen the institutions in the environmental sector by replacing the Government Commission on Environmental Protection and taking the status of a ministry. According to the Environmental Protection Act of 1991, a special Government Decree (No. 71 of February 16, 1994) defines the position of Goskompriroda within the Government, and spells out its responsibilities. The Decree requires that Goskompriroda coordinates the system of environmental management within all sectors of the economy, develops and enforces all environmental standards and regulations, and assists the Government in designing and implementing policy and investment programs for environmental protection. Environmental data collection, pollution control, provision of permits for the use of natural resources, management of parks and protected areas and environmental impact assessment are the main operational responsibilities of Goskompriroda.

7.6 Goskompriroda consists of one central office and seven local branches (one in each of the Oblasts and one in the city of Bishkek), with a total staff of about 150. The central office has 42 employees and its Chairman is a member of the Ministerial Council. The structure of the central office (fig. 1) includes: (i) Department of Control and Inspection (with 14 staff); (ii) Department of Ecological Expertise (with 7 staff); (iii) Department of Economics, Environmental Management and Forecast (with 5 staff); and an International Relations and Science Division (with 5 staff). The rest of the Committee are support staff.

7.7 The Forestry Inspection and the Administration of the Hunting Enterprises were subsumed under Goskompriroda according to the decision of the Government. They now form two separate Departments, with relative managerial and budgetary autonomy from Goskompriroda. As a result of the merge, Goskompriroda has undertaken new functions (overseeing forestry production, and licensing hunting and fishing) in addition to enforcement of environmental regulations. Normal practice in other countries is to keep institutionally separate responsibilities for developing and enforcing environmental regulations, including control on licensing hunting and fishing, from practicing nature resources-based activities. An organizational chart for Goskompriroda (central administration and local branches) was approved by Government Decree No. 71 on February 16, 1994 (fig. 2).

7.8 There is both compelementarity and overlap among the agencies that are currently assigned to participate in development and implementation of the state environmental policy. Even when complementarily is dominant, the vertical hierarchy in Government inherited from the former Soviet Union leads to poor coordination among parallel activities. In order to improve the efficiency of environmental policy coordination, formal links among the above agencies should be established. On a Government level this requires placing all ministries and committees with environmental management functions within the Government under the supervision of the same Deputy Prime Minister. Also, it was proposed that the high level Steering Committee for the preparation of the NEAP should continue to supervise and monitor the implementation of the NEAP, serving as a coordinating body in the field of environmental policy.

7.9 The most important information agency for the governmental system of environmental protection is Hydromet, which is in charge of monitoring the quality of air, water and soil. The data, collected by Hydromet's stations, should be used by Goskompriroda in the analysis of the state of the environment, as well as for determining pollution from point sources and imposing appropriate sanctions. Currently, however, the ability of the two institutions to collaborate is rather limited, mostly due to staff and procedural constraints. As a result, Hydromet accumulates a significant amount of information, which is of limited use for the policy makers. On the other hand, Goskompriroda is under pressure to collect the necessary data, and duplicates the activities of Hydromet. Background Papers: Legislation, 129 Standards and Enforcement

Figure I

DIAGRAM OF MANAGEMENT OF STATE COMMITTEE ON ENVIRONMENTAL PROTECTION

Stete Commetaeeon EnvironmentalProtection

Chief Management e ieCf n m on Forest Enterprises

branches | |EcobogicalScientific Ceta Insecio Management BssY ku Osh l Hungandenformation on analytical on fruh and anagemen Management Center Control nut foresto on forests on forests

_ 0 ~~~~~~~~~~~~~~~~~~~Forest | |Forest | |Forest BJshkek Citi State reserves |Enterprises ||Enterprises ||Enterprises| Commettee and national parks

|Tomak Balykchy Inter-ralon __ inter-raion Inspection inspection Chui Oblast Issyk-ltul Kar -BIty _ Commettee _ Oblast commettes Inspection I nter-raion __ of analytical -!Iinspection n control

Kyzylkiya TmTsh-Kumba | inter-raolonn inter-raisO. in pection | | | l § | | ~~~~~~~~~~~inspection Osh Oblast _ | Galal-abad L ,Inspectio|n Comrnettee Oblast commettee n |Inspection |of analytical ll| _ of analytical conro control

Insecio Ma Ols Talas Oblast l Inseto of analyicaI Commettee Comttnee | |of analytical |control | control

Oblast [ Ihuntingr |enterprises Chief management| on nunting | Enterprise Hunting| n enterprisesand management |enterprise | control |'Kyrgooo I

| Inspection on P ress-center | small boats ' Asa'a BackgroundPapers: Legislation, 130 Standardsand Enforcement

Figure 2

Structure of the Headquarterof the State Conmmitteeon EnvironmentalProtection

Chairman of the State Committee on EnviromnentalProtection 1 (staff Member)

First Deputy Chairman Deputy Chairman L ~ (saf~ member)l

Main control-inspection Department 14 (staff members)

Department on Ecological Appraisal 7 (staff members) I Department on Economics and Forecasting of Natural Resources Using 5 (staff members)

Department on Scienceand InternationalCooperation 5 (staff members)

Department on Accounting and Finance 5 (staff members)

General Department 3 (staff members) Background Papers: Legislation, 131 Standards and Enforcement

7.10 A proposal for merging the two agencies was submitted to the Parliament two years ago, and declined at that time. There are two constraints to this merge: (i) institutional incomparability between the Committees; and (ii) broader mandate of Hydromet. Aside of environmental monitoring, Hydromet is also responsible for systematic observations on hydrometereological and climate changes, climate forecasts and international cooperation within the World Meteorological Organization and the Intergovernmental Council on Hydrometereology. While the long term objective should be the establishmnentof an integrated environmental monitoring system, in short to medium term this should be achieved by improving environmental data collection and informational exchange between Goskompriroda and Hydromet. The existing laboratories and monitoring systems of the two Committees should be integrated in a coordinated air and water quality assessment process. Goskompriroda should appraise the existing data base for air, water and soil, and order from Hydromet special surveys in the priority areas. For this purpose, an air and water quality assessment unit should be established in Goskompriroda, with the objective to coordinate environmental monitoring and enforcement.

7.11 In the local administrations, environmental management is the responsibility of the six oblast and one city Committees on Environmental Protection. Although they are subdivisions of the State Conmmitteeon Environmental Protection, and report to its Chairman, the oblast Committees are also accountable to the local Governors. The Chairmen of the branches are appointed by the Chairman of the State Committee on Environmental Protection, but consultation with the oblast management is an accepted practice. One of the Deputy Governors is personally responsible for the performance of the environmental authorities. Visits at the oblast Committees show that they are understaffed and very restricted in their capacity to perform their duties by lack of proper equipment and vehicles.

7.12 Local Priorities. Although the Kyrgyz Republic is not a large country, there are very significant differences among its different regions. The topography and environmental conditions vary greatly among oblasts, as do the cultural and economic situations. As a consequence, oblasts have different priorities for development and environmental protection. The Issyk-Kul Oblast places high priority on tourism development. Protection of the lake and forests in the oblast is of high priority. The Osh Oblast focusses more on agriculture and light industries, and experiences relative shortage of clean drinking water supply in some rural areas. Dealing with uranium tailings and wastewater treatment are of more significant concern for Naryn and Dzhalal-Abad Oblasts. Water protection, reforestation and environmentally sound development of new mining operations (eg, gold mining) are the highest priorities of the Talas Oblast. In the Chui valley the main issues are water supply and land use. In addition to these differences, transport and communications among the oblasts are difficult. Consequently, it is necessary to decentralize environmental management. This requires that the NEAP process itself should be decentralized to take into account the differences among the regions. The central governmnentneeds to improve communications with the Oblasts.

7.13 Recommendations. A successful implementation of a NEAP will require strengthening of the environmental authorities. In the center, additional staff will be needed by the State Committee on Environmental Protection to: (i) enhance the capacity of the Economics Department and of the Ecological Appraisal unit (which should be upgraded into an Environmental Impact Assessment Department); (ii) strengthen the policy and regulatory capability of the Committee; (iii) provide legal expertise (currently lacking in the Committee); and (iv) improve the licensing and permitting capacity of the inspectors. The Committee should be provided with office facilities and the staff should be assisted in going through essential training programs (in environmental policy, environmental impact assessment, risk assessment, use of economic instruments, computer and language skills etc.). In the branches, highest priority should be given to supporting the inspectors in performing their controlling functions (especially in the remote areas). For this purpose, the Oblast offices should be provided with additional staff, vehicles and portable monitoring equipment. BackgroundPapers: Legislation, 132 Standardsand Enforcement

7.14 The evolutionof Goskomprirodainto a true standard setting,monitoring and enforcementagency will require strong commitmentfor reform and a clear vision of the steps leading to a modern and effective institution. For this purpose, a definition of Goskompriroda'smain objectives in the context of the overall policy reform, and a stronger mandate to carry out its tasks are essential. Problems of coordination with other relevant agencies in the government need to be resolved, even under the constrainsof government'spreoccupation with the difficultiesof economictransition. In addition,better coordination of donor activities is necessary to avoid a supply-driven approach that atomizes scarce resources among a myriad of issues, problems and objectives.

7.15 A necessary pre-condition for Goskompriroda's success is to carry out a comprehensive institutional analysis to define objectives, assess realistically the human and financial resources and prepare a technical assistance and training program for institutionalstrengthening based on needs and absorptive capabilities. A key by-productof this exerciseshould be the design of a workable system of inter-institutionalrelations allowing Goskomprirodato carry out its mandate, in collaborationwith other agencies (eg, Sanepid and Hydromet). In this respect, the environmentalmonitoring system should be strengthened,taking into accountthe role and the needs of all relevant institutions. On discrete tasks (designof policy instruments,policy enforcement, project development etc) Goskomprirodashould utilize the technical assistance from various donor programs by focusing on key issues within an agreed framework. Expertise for these tasks, which is not available in Goskompriroda,should be contracted from outside (from research institutesor consultingfirms) on a short term basis. Access to externally funded technical assistanceshould be extendedto the regionalbranches.

Enviromnental legislation

7.16 Environmentallaws. The Kyrgyz Republic inherited its legislation from the former Soviet Union, including a system of environmentallaws, standards and regulations. In a centrally planned, output driven economy with soft budget constraintsand generous concessionsfor non-compliancethere was little respect for legal requirements,and the environmentallaws were systematicallyviolated. Since independencea legislative reform has been in progress in the Kyrgyz Republic in order to provide an implementable, market oriented legal framework for environmental improvements. The Kyrgyz Republic's Law on EnvironmentalProtection (LEP), adopted by the Jogorku Kenesh (the Parliament)on April 17, 1991, sets forth the basic legislative framework for preserving natural and environmental conditionsand guaranteeingefficient use of natural resources. The LEP introduces a number of basic principles of environmentalprotection:

* citizens' rights to a healthy environment;

* priority of protectingthe environmentas a public good over private economicactivities;

* requirementto pay for the use of natural resources, includingfor pollution(the "polluter pays principle");

* use of natural resourceswith a view to the needs of present and future generations;

* the "public right to know" principle; and

* delegation of policing power to specific agencies to assure the enforcement of the environmentallaws and the penalties for violationsof these laws. BackgroundPapers: Legislation, 133 Standardsand Enforcement

7.17 A major contribution of the Law has been the assignment of implementation responsibilities to the national Government, the provincial Governments and the specialized environmental protection authorities. The Law also specifies: the procedures for ecological appraisal (similar to those for environmental impact assessment), with the objective to ensure that all development programs, urban plans, investment projects, production processes and activities with significant environmental impact are designed and operated in an environmentally sound manner; the safety procedures for preventing and mitigating the impacts of ecological accidents; and the procedures for establishment and management of protected areas. The LEP delegates significant rights and responsibilities, including the right to determine the special regimes of protected areas.

7.18 Currently all environmental laws and regulations, inherited from the previous system, are in a process of revision. Given the limited environmental capacity in the country, technical assistance would be needed to develop a coherent legislative system, which corresponds to the requirements of the economic transition, and to the implementation capacity of the environmental authorities. In order to allow for continuity and easy adjustment, the new legislative body should preserve the principles and definitions from the existing legislation, which are compatible with the requirements of the market economy.

7.19 Environmental Liability. The concept of liability is included in all the environmental statutes, as well as in other Laws, including the LEP, Law on Enterprises, Law on Peasant Enterprises, etc. The government may sue for monetary compensation for both economic and environmental harm, and the money would then be used to restore the environment to its original condition. Individuals and enterprises may bear both civil and criminal liability in accordance with the laws on Environmental Protection, Land Reform, Enterprises, Land and Forestry Codes of the Kyrgyz Republic for the following offenses:

3 violation of the standards, regulations, rules and other technical requirements established for environmental protection;

* failure to fulfill the state requirements for environmental audits or assessments;

- failure to comply with environmental requirements and regulations during planning, location, design, construction, remodeling, start-up, operation, or liquidation of enterprises, installations, mobile equipment, or other objects;

* dumping untreated sewage, effluents, or emissions into the environment, or disposing without authorization harmful wastes for which disposal permits are required;

* use of natural resources over and above established limits, without a permit, or after the expiration of a permit; and

* failure to observe established standards and limits on pollution, or on physical and other harmful effects on the environment.

7.20 A key environmental liability issue, still not addressed by the Kyrgyz Republic legislation, concerns responsibility for past pollution in case of privatization. Both foreign and domestic investors need to know who would assume the financial burden of the cleanup. For the Government, assigning environmental liability for the inherited environmental damage is critical for assuring that the public will be protected from negligence of the new owners. There are a number of options: (i) transferring the cleanup responsibility to the new owner, provided that the price of the cleanup is deducted from the BackgroundPapers: Legislation, 134 Standardsand Enforcement

purchasing price of the enterprise; (ii) the Government assumes full responsibility for past pollution, and uses some of the purchase funds (or other funds) for the cleanup; (iii) the investors pays a full price and assumes full responsibility for the cleanup, provided that the expenses are tax deductible, and that the Government provides other compensation measures (waiving export/import duties, providing other tax privileges etc.); and (iv) a combinations of the above3. A decision should be made in the Kyrgyz Republic on which of these options should be applied.

7.21 Foreign Investments Legislation. Foreign investments in the Kyrgyz Republic are regulated by the Law on Foreign Investments of June 28, 1991. The Law provides special privileges as an incentive to foreign investors to apply environmental protection measures. Foreign investors are eligible for significant tax benefits in case of: (i) introduction of new pollution abatement equipment; (ii) production of air or water protection equipment; (iii) extraction, development, or processing of mineral resources (in mining, forestry and agriculture) in an environmentally sound manner.

Environmental standards

7.22 The Kyrgyz Republic still relies exclusively on the ambient environmental standards of the former Soviet Union, setting maximum permissible concentration of polluting substances in air, water and soil. Standards also exist for noise, vibration, electromagnetic fields and radioactivity. Standards were established, however, with little consideration for the costs of enforcement. They were commonly violated, with or without consequences for the polluters (sanctions and fines imposed by the environmental authorities). Many of the enterprises simply incorporated the costs of non-compliance in their financial balances.

7.23 Standards for ambient air quality for 1080 pollutants were established by two FSU government agencies -- the Ministry of Health and the State Committee of Ecology. They, and their subordinates in the republics, have been responsible for monitoring the level of compliance, resulting in an overlap in the monitoring systems. The adopted standards and guidelines exceed the capacity of the monitoring system. They are generally too stringent, and therefore are not taken very seriously by the key industrial polluters. In the case of standards for hazardous substances, when there is a need of a stringent regulation, the ambient air quality standards should be supplemented with point-source emission standards, and/or technology-based rules. Emission limits were recently introduced into the practice of environmental management, as required by the procedure of issuing emission permits and the pollution charge program. However, there is no clear and well-developed methodology to set up the limits. Phasing-in somewhat lower (and therefore more attainable) standards and/or limits, combined with case- by-case compliance schedules and firm enforcement, should gradually create a better environment for implementation of the Kyrgyz Republic air pollution policy.

7.24 Similar observations can be made for ambient water quality standards. Numerous maximum permissible concentrations were established for different polluters to protect drinking and surface waters. Most of the standards can not be adequately monitored by the existing laboratories, and only exist on paper. As in the case of air, the system of ambient water quality standards should be simplified and made attainable and enforceable. In accordance with that, waste water discharge limits should be established for all major sources. The enterprises should provide records on their discharge levels to the environmental authorities, which on their side should have the capacity to carry out regular tests of the actual content of the waste water.

3/ Major privatizationprograms are now in progress in all former socialistcountries. The accumulated experienceon dealing with the issue of environmentalliability was summarizedin a recent World Bankreport on EnvironmentalLiability and Privatizationin Central and Eastern Europe (Report No. 11686-ECA). BackgroundPapers: Legislation, 135 Standardsand Enforcement

7.25 Recommendations. Steps to be taken include: (i) revision of the standards and limits based on projected enforcement costs and expected benefits, and setting of realistic target dates for their implementation;and (ii) incorporationof three types of standards(ambient standards, emission standards and new source performancestandards) in a coherentregulatory system, (iii) developmentof individual compliancetimetable for all major pollutionsources through interactionsamong all concern parties (the environmentalauthorities, the managementof the pollutingsources and the public). Currently two factors -- delays in passing the new environmental laws, and lack of experience -- create obstacles to the introductionof the new standards. As a result, the environmentalauthorities continueto tolerate cases of non-complianceon the ground that standards are too high and that the polluter cannot possibly bear the compliance costs. Since all FSU countries are going through a similar process of improvingthe systemof environmentalstandards, exchange of informationand staffamong the environmentalauthorities shouldbe encouraged. For this purpose, assistancefor the Kyrgyz Republicfrom external donors should be requested. At the first step, technical assistanceefforts should focus on (i) methods for defining the limits, based on cost-effectiveness(cost-benefit, when possible) analysis, and (ii) strengthening the institutionaland legal frameworkto enforce them. For the interim period when such institutionaland legalcapacity is still lacking, technology-basedrules shouldbe introducedfor a limitednumber of sources (those which impose a real health hazard to the population).

Enforcement

7.26 The objectiveof enforcement is to achievecompliance with environmentalstandards. There are two broad categories of enforcementinstruments: command and control type measures, such as permits with legal (civil or criminal) sanctionsfor violations,and market based instruments,such as pollutionfees and extraction fees for natural resources (see following box).

Commandand Control Methods

7.27 Until recently all FSU countries relied heavily of central planning and direct control from Moscow in setting their environmental regulations. Similarly to other policy areas, environmental requirements were issued without comprehensive economic analysis, and effective enforcement procedures. In this sense, the policy measures inherited from the FSU focused mostly on commands, and less on control for implementation. While most of the CAC methods, developedin the West, were also introducedin the FSU, their efficiencyis much lower, due to weak enforcement.

7.28 Emissionpermits. All enterprises are required to obtain emissionpermits. The emission limits develop for each new (or substantiallymodified) enterprise are incorporated in a maximumpermissible emissions book. The emissions book serves to document emission rates and control methods and subsequentchanges to those emissionsand controls. These emission rates are effectivefor one year after start-up. Then, adjustments are made based on operating experience during the first year and Goskompriroda(the central or the oblast level inspectorate,depending on the size of the enterprise)issues a permit that officiallyestablishes the emission limits. If ambient standardsare exceededoutside of the sanitary protection zone, the permit will be temporary waived and the enterprise must submit a plan to Goskomprirodathat specifies the steps that will be taken to further reduce the emissions. Lack of proper monitoringconstraints the efficiency of the emission permits as a regulatory instrument. Background Papers: Legislation, 136 Standards and Enforcement

RegulatingEnvironmental Externalites: Command-and-control versus Market Incentives

Economistsview the environmentas aneconomic good: the societycannot five andfunction vAthout dean waterand:air, or withoutnatural resources,like imineralsand crops. Manyenvironmental resources, such as air, are freelyaccessible to everyone,and easilypolluted by .groups and individualsduring their activities.Pollution imposessocial costs becauseit reducesthe .value:of these assetsfor Canyone who usesthem. In a market econiomypolluters do not volunteerto payfor thesecosts. When a pollutingprivate enterprise estimates the cost -ofproduction, it generaillycounts only the cost of the materialand labor raquiredto makea product-it does not considercostssuich as the damageto publichealth in near-bycommunities caused bythe pollution.Economists call this problema negativeenvironmental external. people experiencecosts or lossesin welfaredue to the activitiesof the factory,but they are not compensatedfor the losss (theoretically,the enterprisemight paythe communityfor the cost of specialcare for thier children,for puttingair purifiersin their houses,or for relocating ,theirhomes to a placewth claner air), Economiststarequick to point outhat environmentalexternalities may iibe positive,too. For examplei,only one personmay planta garden,but everybodywho appreciatesthe beauty .of the gardenbenefits. Froman economicperspective, a negativerenvionmentalexternality should be 'Intemalized'-thepolluter shouldpay the costshe or shecaused to the communities.A freemarket rarely forces a polluterto acknowledge :these coststo society-governmentusually must intercedeand compelthe polluterto pay.

Thereare two waysfor the governmentto intervene:

* "Command-and-control'regulation (CAC -whenthe governmentsets and enforces standards for the amouontof polution that can be relesed into the environment,and prescribesthe technologyor behaviorthat must be used to meetthose standards,and

* ^Marketincentives when the: government sets pollution standards and then applis charges,fines, or tradeablepollution permits to enforcethose sandards, but does not dictatethe technologyor behaviorthat mustbe used-leavingit up to the individualpolluterto find the mosteficient meansto reducepollution.

Thesetwo approachesshare common ground and commongoals: they bothrely on pollutionprevention legislationand standards,and they both:'internalizelthe externalites-forcing polluters to recognizethe cost to societyof theiractivities, and to developmore environmentally-friendlytbusiness behavior. The approachesdiffer In the degreeof state Intervention,however, whiKh Is muchhigher underthe command-and-controlapproach.

ManyveconomistsarguethatCAG.costs socetymore than market-incentiveapproaches. Itrequiresalarge bureaucracyto administerit, slowsprivate decision-making, and discowragesinnovations, because there are no financialIncentives to reducepollution beyond what is requiredor to experimentwkth leSs poluting production techniques.All agree,however, that whensocial risks bre very high,such as in caseof radiationhazards, CAC may be the safestapproach.

Market-basedinstruments for environmentalmanagement work best in a marketeconomy. In a market ieonomy, if ienteprisesarrequlted to paytenvironmental charwes which take accountof the socialcosts of extraction.and pollutionmofnaturat resources,the NOpration of enterpriseswill be modifiedto makemore efficient use of resourcesand to reducethe volumeandhpotenial toxicity :of anywastes that are produced. The former centrallyplanned economies are eagw to aboish inefficnt CACregulations and applyamarketbased approach. Westemreconomies havedeveloped this steponly recenety,however, within mature market economies, and with welstablished, firmlyenorced command-andconl regulationsothstill lackingIn the transitionalcountries.

In the KyrgyyzRepublic,0tho iitional farnl or at martecnomywUidevelop over an extended period. It will take time beforeproperty rights aare arifiedand marketrules become effective.The dominanoe of state-ownedindustries wih limitedacountability and softbudget constrai.sta means that economi incentives provided.by market-basedinstruments inevitably will be lesseffective. Thereforea shifting from CACto market basedinstruments should also happenover time 1 in parallelwith the transitionto a marketeconomy. : 7 : f :: :: :: :: TTy;::me n:; ar: :Xa anf::: o:: to:0a make: BackgroundPapers: Legislation, 137 Standardsand Enforcement

7.29 The existing system of annual reviews allows for issuing temporary permits, which creates considerableuncertainty for the enterprisesand puts a heavy administrativeburden on the environmental inspectors. A new permittingsystem shouldbe designedbased on integrated air and water permits with a validity of five years. In order to simplifythe permittingprocess, Goskomprirodashould introduce minimum emissionvalues, below which changesin the operationof an enterprisewould not require new assessment. While the new integrated permit would be issued for five years, this does not necessarily imply that the emissionand discharge limits would be kept constant for the whole five year period. The permit could stipulate a gradual reduction in pollution, based on an agreed complianceschedule. The current annual planning and approval exercise would be changed to consider only those permits which have expired, while the rest of the permits would be used only as a source of information to prepare summary reports on planned emissions/discharges. Both environmental improvements and cost considerationsshould be taken into accountin the process of settingthe emission reductiontargets. Since there is limited in-countryexperience in negotiatingpermit applications,the Goskomprirodastaff should be assisted in developingand implementinga more flexible, but strictly enforced permittingsystem.

7.30 An effectively implementedpermit system would require setting interim ambient standards focusedon major air and water pollutants. Accordingly, the emission standards should be designed as periodicallyrevised plant/locationspecific emission limits to meet the revised ambient standards for the targeted pollutants. This approach calls for an important role of local and regional governments in determiningsuch emissionlimits and complianceschedules after negotiationswith the affectedenterprises in order to find least cost solutions. While standards are more realistic for water than air quality, the approach remains the same: setting interim effluent limits and complianceschedules, and introductionof sewer ordinances.

7.31 In additionto the permits, a program of issuing "ecologicalpassports" for each enterprise was initiated in 1991. The passport is a document which describes total (i.e., summnarizedover all point sources in the area of the enterprise) authorized air emissionsand wastewater dischargesper year plus the authorized consumption of certain natural resources. It serves as the basic document for the calculation of pollution and natural resource fees. The passport is based on the emission book and permitted wastewaterdischarges taking into accountthe planned production level of the enterprise. The passport for each enterprise is checkedby the inspectorsof Goskomprirodain order to ensure compliance with the discharge limits.

7.32 Licenses. Pursuant to the Law on the Subsurface,licenses for the use of mineral resources are auctionedamong agenciesand individualson competitivebid basis. The Law on the Subsurfaceprovides the State Committee on Geology with authority to propose licenses for extraction of natural resources. A PresidentialDecree on "The LicensingOrder of Some BusinessActivities", signed on June 19, 1992, established a licensing procedure for dam construction (implemented by the Ministry of Water Resources), and for commercial collection of herbs (implemented by the State Concern "Kyrgyz Pharmacy Industry", in concordancewith the State Forest Inspection at Goskompriroda). Licenses for hunting, fishingand bird catchingare provided by Goskompriroda. Competitivebidding is required also for geological research, according to Governmental Decree on the "Investors Guarantees for the Conductingof GeologicalWorks", signed on April 8, 1994. Althoughall licenses shouldbe granted on a competitive basis, this is not always the case. Transparent procedures should be established and monitored by independentauditors and NGOs, to assure proper implementationof the licensing.

7.33 CivilPenalties. Civilpenalties for pollutionare leviedby the Code on AdministrativeViolations, which incorporatesa chapter on civil liability for environmentaldamage. They should be enforced by Goskompriroda,Sanepid, and the courts. There are concerns that these penaltiesare not very effective, mostly because they are not stringent enough to change behavior. An existing flat penalty rate is BackgroundPapers: Legislation, 138 Standardsand Enforcement independentof the nature of the damageand expected rehabilitationcosts. In addition to fiscal sanction, the penaltiesmay includecriminal sanctions(imprisonment), as well as closure of the pollutingenterprise. At the momentthe threat of plant closure is a blunt instrumentand lacks credibilityin cases where closure will result in significantunemployment.

7.34 Environmentalimpact assessment. Currently Goskomprirodaprovides such services as State EcologicalAppraisals and State EnvironmentalControl. The State EcologicalAppraisal unit should be transformedinto an EnvironmentalImpact Assessment division, and staff shouldbe trained in supervising both EIAs and environmentalaudits. A new regulationfor environmentalimpact assessmentand auditing procedures should be developed to ensure that all development programs, urban plans, investment projects, productionprocesses and activitieswith significantenvironmental impact are designed, operated or transferred to a previous or a new owner in an environmentallysound manner. All production processes and activities, requiring a mandatoryEIA, should be listed in a Ministerial Ordinance.

7.35 At the present time the following is subject to state ecological appraisal:

* draft national plans, basic guidelines, research or engineering projects, pre-draft and draft documentson the developmentof economicand other activitiespertaining to the use of natural resources;

* drafts of technical norms, environmental and economic regulations and procedures, pertaining to all types of economic activities(including investments, taxation, licensing and other regulations,related to the natural resourcesutilization, includingjoint ventures with foreign firms);

3 documentson the developmentof new technicalequipment, technology, materials and substances,including those purchased abroad;

e documents on closure of natural resources use (including confiscation of materials), as well as on their export and import;

* documents on issuing of licenses and certificates;

* technicaland economicsubstantiation and estimates,draft plans for construction, remodeling, enlargement, and retooling, as well as liquidation of national economicenterprises, facilities, and complexes;

* documentson the ecologicalsituation of individual regions.

7.36 Environmentalaudits. Many enterprises, currently under operation, need to assess their economicviability and competitivenessin market conditions. For this purpose, the full costs of operation (includingall environmentalexternalities) should be taken into account. Environmentalaudits shouldbe carried out, to identify environmentalexternalities, as well as potential low costs pollution abatement measures.

7.37 Environmentalplanning.While central planning was abolishedafter independence,establishment of goals, policies, and procedures, including those in the field of environment, continues to be implementedby the State Committeeon Economics.Goskompriroda proposes environmental protection measuresto the State Committeeon Economicsto be embodiedin the Annual Forecast(a substitutionof the former Annual Plan). Planning of environmentalprotection measures is also carriedout by the local BackgroundPapers: Legislation, 139 Standardsand Enforcement administrations.Environmental protection measures are incorporatedin national, sectorial, and territorial programs and plans for the developmentand location of productive forces, plans for the use of natural resources, short - and long-range plans for the production and financial activities of enterprises, and special ecologicalprograms. In order to utilize the planning traditions, while at the same time avoiding the negative impact of centralization,a gradual shift toward settingpriorities and objectivesat local level should be encouraged. The process of transformationof the State Committee on Economics from a planning to a forecasting agency should be continued. Data on pollution loads and environmental expenditures, currently collected by this Committee, should be provided on a regular basis to Goskompriroda,and incorporatedin annual reports on the state of the environment.

7.38 Monitoring. Environmentalmonitoring has strong traditionsin the FSU, dating back to the early 1960s. The initial development of monitoring agencies, however, was not related to environmental protection, and, as a result, extensivemonitoring network was created as a part of two agencies -- the State Agency on Hydrometeorology(Hydromet) and the Sanitary-EpidemiologicalService. When Goskomprirodawas created in 1988, the monitoringnetwork in these two agencies was not integrated in the system of environmental control, and the new environmentalagency had to develop its own monitoring capacity, to a great extent an overlap of the existing networks. Currently in the Kyrgyz Republicthe Hydrometstations are much better positionedto collectdata on air, water and soil pollution. In addition, the Sanitary-EpidemiologicalService monitors indoor pollution and pollution in sanitary zones, related to occupationalhealth.

7.39 Central and Oblast Laboratories of the Committee on Environmental Protection. In the previous Soviet system, heavy reliance was placed on self reporting by enterprises under the control of Sector Ministries. This includedthe reporting of pollutant emissionsto air, land and water. It was this data which was used by the Commnitteefor EnvironmentalProtection to assess pollution fees for each enterprise. Recognizing that such a system was open to considerable abuse, the Committee for EnvironmentalProtection establishedone central and five oblast laboratoriesto independentlycheck the emission data reported by the enterprises and to check the environmentalimpacts of these emissions.

7.40 Currently due to budget constrains and low staff salaries these laboratoriesare losing qualified staff and have greatly reduced schedulesof independentchecks due to insufficientchemicals, glassware and spare parts for analytical equipment, as well as lack of transport to visit enterprises and collect samples. Moreover, out-datedwet chemicalmethods of analysis as practiced in the laboratoriesare time consuming and require a wide range of reactive chemicals to analyze the large number of chemical constituents in different effluent samples. Calculations of pollutant concentrations are carried out and recorded manually. Productivityis, therefore, extremely low comparedwith that of the range of modem analytical equipment linked to computers that is now availablefor such pollution control laboratories. Similar constraints exist in the Hydromet's and Sanepid's laboratories. In addition, lack of proper coordinationbetween Goskompriroda, Hydromet and Sanepiddiminishes the utilizationof data, collected and processedunder severe restrictions.

7.41 The staff of the central and oblast laboratoriesare well qualifiedand dedicatedprofessionals, but would require retraining in modem analyticaltechniques as these are introduced. They are already well practiced in QA/QC laboratory procedures and carry out QA/QC inspections of environmentalcontrol laboratories in the enterprises under their jurisdiction. In addition, they operate a training and certificationprogram for analyticalchemists working in these laboratories.

7.42 The Central laboratoryof the Committee for EnvironmentalProtection also acts as the regional laboratoryfor the ChuiskOblast, and is responsiblefor monitoringsome 100 enterprises of which 20-30 are large scale operations. It consistsof four analyticaldivisions: water pollutionanalysis; air pollution BackgroundPapers: Legislation, 140 Standardsand Enforcement

analysis; soil analysis; and radiological analysis. The water pollution analysis division analyses liquid effluent samnples as well as river water and pond samnplesat points of discharge. The air pollution analysis division samples and analyzes industrial waste gases discharged to atmosphere, as well as ambient samples in the vicinity of industrial enterprises. It is also responsible for monitoring emissions from cars, trucks and buses, and carries out sampling and analysis of ambient conditions in urban areas affected by traffic pollution. The soils analysis division analyzes samples provided by agricultural enterprises to recommend dosage rates for fertilizer applications and to identify the polluting constituents of contaminated soils. The radiological analysis division monitors the uranium processing plant operations at Kara-Balta and at abandoned uranium mine sites.

7.43 Key factor for transforming Goskompriroda into a modern enforcement agency is the improvement of its monitoring capacity. For this purpose, the existing laboratories should be upgraded both in terms of facilities and equipment, and in terms of staff qualifications. Monitoring capacity in Hydromet and Sanepid should be taken into account, and efforts should be made to avoid duplication by utilizing all monitoring stations. It is recommended that:

* The system of environmental laboratories (the Central and five oblast laboratories of Goskompriroda, as well as Hydromet's stations, providing environmental monitoring services) should be supplied with analytical chemicals, glassware and spare parts in order to restore their original analytical capability and to improve their productivity and coverage of industrial pollutants (including hazardous wastes) through the purchase of modern analytical and computer equipment;

* Extra efficiency and productivity gains would be achieved by integrating the Hydromet air and water pollution analytical services with that of the enhanced laboratory capabilities of Goskompriroda. As indicated above, improved coordination between the monitoring services of Goskompriroda and Hydromet should be encouraged. Monitoring capacity, provided by Hydromet, should be specified and assisted in the same manner, as Goskompriroda's laboratories (in case there is no overlap);

* Laboratory staff should be retrained in modem analytical and computing techniques with selective intensive training of senior analysts at similar laboratories in other countries, so that they will be qualified to retrain other staff in central, oblast and enterprise laboratories;

* The new analytical procedures available should be introduced and adopted as standard methods of analysis;

* Vehicles should be provided to the laboratories so that they can effectively carry out their independent sampling and analytical program; and

* Adequate laboratory space to house the upgraded and expanded analytical capabilities of the Central and oblast laboratories of the Committee for Environmental Protection, and Hydromet's water quality and air quality monitoring facilities should be provided as necessary. BackgroundPapers: Legislation, 141 Standardsand Enforcement

Market Based Enforcement Instruments

7.44 Prior to 1987, the FSU government was relying on command-and-control approach for environmental management. Insolvency of centrally planning methods in general, disclosed in the late 80s, promoted strong interest in market-based regulatory instruments. In 1988, the government issued a decree that called for a radical reorganization of environmental management. The decree established the All-Union and Republican Committees on Natural Resources and Environmental Protection (Goskompriroda); specified the need for pollution charges, including both fees on emissions within the limits and fines on emissions above the limits; and proposed to set up a network of earmarked environmental funds to allocate the revenues from the charges. In 1991-1992, most of the newly emerged countries of the FSU established similar national pollution charge programs that typically impose fees on air, water and solid waste discharges and earmarked the revenues for environmental protection. The programs were commonly designed to serve two main purposes: (a) to provide economic incentives for polluters to bear pollution abatement costs, and (b) to raise revenues needed to subsidize environmental services at the regional level (such as municipal wastewater treatment, solid waste disposal and cleanup facilities). However, fee rates were set well below marginal costs of pollution abatement or associated costs of environmental and health damage and have been constantly eroded by inflation; therefore, they have not provided real incentives for pollution reduction.

7.45 Following the common trend in introducing economic instruments for environmental management, the Kyrgyz Republic adopted a fairy comprehensive system of pollution fees and fines. The fees serve the revenue-raising role, which is an important income source for Goskompriroda and its Oblast branches. Unfortunately, key issues for successful implementation of a new regulatory program, such as capacity of monitoring and enforcement, adequate financial and legal regulations, institutional support building, and administrative costs of implementation were not considered. As a result, collection rates are rather low, and no evaluation mechanism exists to provide environmental managers and other stakeholders with real-time information about the status of the programs.

7.46 Two critical factors -- high inflation and rapidly deteriorating financial situation of the main polluters -- have further eroded the revenues from the fine system. Many enterprises claim exemptions from the pollution fines on financial ground. Exemptions are also requested because polluting enterprises often operate more than 50 % below their capacity, and register significantly reduced pollution load. Since Goskompriroda has no capability to monitor the actual pollution, it is forced to accept these claims, although in some cases there is no direct correlation between production and pollution loads (due to outdated technologies or shifts to cheap and highly polluting energy sources and row materials).

7.47 The Kyrgyz Government recognizes the need to impose charges, fines and fees, which provide real incentives to eliminate or restrict environmental damages. Ordinance No. 317 from July 19, 1993 of the Ministerial Council establishes fines for soil degradation linked to the damage costs. In addition to the pollution charges, Goskompriroda also collects licensing fees for seasonal hunting and fishing, and for collection of medicinal herbs. Goskompriroda took steps to bring hunting and fishing fees, as well as licensing fees for collecting medical herbs, in line with inflation. Two ordinances of Goskompriroda (No. 18 and 19, from July 23, 1993) introduced new licensing fees and fines. These adjustments should be integrated in a system, covering all types of charges, fees and fines. In order to provide inflationary protection, environmental charges, fees and fines should be gradually adjusted to price increases.

7.48 Another policy instrument, classified as a market incentive, is the contract between the Oblast enviromnental conmmitteesand each of the pollution enterprises. Based on these contracts, the enterprises make small contributions to the account of the environmental authorities (to be divided among the central and the local environmental administrations). In return, the extra-budgetary accounts provide BackgroundPapers: Legislation, 142 Standardsand Enforcement

funding for the highest priority environmental activities in the respective oblasts. This contracting system is possible only under pressure from the Government, and has a rather administrative character. While hardly responding to market conditions, the contracting does encourage negotiations between the business community and the environmental authorities, and establishing a spending focus on local priorities.4

7.49 Environmental Funds (EFs). Local and Central (Republican) Environmental Protection Funds are established with a Presidential Decree from July 21, 1992. Such Funds are common practice in the former socialist countries (see following box). They collect their revenues from enterprises in the following forms: (i) charges for pollution within the limits and for permitted waste disposal; (ii) charges for pollution above the limits and for non-permitted waste disposal; (iii) fines for accidental point source pollution; (iv) charges for unsustainable use of natural resources; (v) compensations for environmental damage caused by illegal activities; and (vi) fines for administrative violations. All revenues are collected in extra-budgetary accounts of the Oblast branches of Goskompriroda, which are required to make a 15 percent transfer to the extra-budgetary account of the central administration. The local funds are distributed for the following: (i) subsidized construction of waste utilization/waste disposal units in the Oblast; (ii) subsidies to local enterprises for high priority environmental expenditures (including assistance for paying bank loans); (iii) financing the construction of environmental health recreation centers; (iv) salary bonuses for environmental protection; and (v) accumulation of funds for emergency activities. The central funds are used for three main purposes: (i) nature protection and rehabilitation; (ii) legislative and monitoring services, and ecological appraisal; and (iii) training, research and policy design (both internally and externally provided). The distribution of funds is transparent (although the overall supervision of the funds is centralized in Goskompriroda).

7.50 Vehicles . Increase of motor vehicles through import of old cars and trucks from the West and aging of the existing fleet are major causes of air pollution in the populated parts of cities. Goskompriroda plans to develop a vehicles import tax in order to: (i) encourage import of environmentally safer vehicles (and contribute to emissions reduction, and (ii) raise funds for environmental activities, including monitoring and control of pollution from mobile sources. The tax would transfer earmarked funds from vehicle users to the environmental fund.

7.51 Offsets and emissions trading. Flexibility in enforcement can reduce the enterprises' cost of complying with emission/discharge limits. In some countries, adjacent sources of the same pollutant (or class of pollutants) are allowed to seek a least cost solution to attaining ambient or overall for the region emission limit by over-controlling those sources where reductions in emissions/discharges are less expensive. They can then "count" these reductions toward the reductions that would otherwise be required on nearby sources that would be more expensive to control. Although this practice is not specifically prohibited in the Kyrgyz Republic, it is not currently used. It is, however, of significant interest to the environmental authorities, which are willing to implement it. In order to reduce the cost of compliance with environmental standards, a mechanism which allows and encourages offsets and trading of emissions/discharges within certain selected airsheds and river basins should be introduced. Goskompriroda should prepare detailed examples and guidance on the use of these instruments for the environmental inspectorates and enterprises. The instruments are best suited for areas where there are a significant number of point sources of similar pollutants.

4/ It is not clear to what extend local priorities are really taken into account. There is evidence that Goskomprirodahas a strong say on the distributionof the contract revenues. Background Papers: Legislation, 143 Standards and Enforcement

EnvironmentalFunds in TransitionEconomie: Lesons from Exprience

Mosttransition economles Inherited their environmental funds (EFs) from theeanrarced extrabudgetaly accounts of thecentral planning era. Non-compliancetees (dulgaria, Hungary) or emissioncharges (Poland, China) constiuted the malnrevenue sources of EFsexpressing theIntention of policymakers to Influencethe behavior o polluters.Under central planning, however, polluters were Insensiti oprtce-based Incentivetnstruments, and EFa servedmalnly as tools for centrliztng and redistributingenvironmental levis for envlronmentalprotectIon purpses.

The transRionto marketeconomy combines private sector development with public enterprie restructuring,and Imposesa shift from sofr to hard budgetconstraints. Enterprisesand Govemmentslose and gain In thisproess. The enterpriseslose the cushionof state subsidlesand gain conlrolover financil decislons.The Govemmentslose direct Investmentcontrol, and gain a free hand to developand enforcenon-biased to productlontargets pollcy measures. In responseto thecombined effect of policyInstruments, environmental reguations and enforcement,the roleof enterprisesIn financingenvironmental Investments Is expectedto Increasedramatically, while the roleof EFs shouldgradually diminish.

In theearly stage of transilonfrom centraltyplanned to marketeconomles, however, there are severalfactors that constrainthe evolution of an effecttveenvironmental fnancdng system. ThoseInclude 0) weaknessesIn the Implementaionof environmentalregulations and enforcement; Q1)tailure to recoverthe costs of public envronmenWalservices; (111) fInancIaly constrained enterprises; ov) slow pace of privatltzaiion(v) weak or non-existingfinancial markets; i) uncertaintlesIn the politia and fiscal systems;and (vil) Inadequatepublic pawicipaElonand accessto inromatlon.

In thesecircumstances, despite budgetary reforms promoting consolidated state budgets, the roie of EFshas been preserved,and even strengthened.They are broadlyused to prorvdea relativelysteady flow of financialresources for environmentalprotection.

EarmarkedenvironmentW funds can be establishedwith donor ssistanceas well. Lessonsfrom the WoridDank's experience show that revovilngpollution abatement funds (PAFs) couid be veryuseful In financinglow-cos environmental Improvemnbt. The key factorfor PAFs to be successfulIs sound managerial practices, combined with strong capacity to appralseproposals and supervise the disbursementof funds. A PAFIs currentlybeing established as a part of a WorldBank environmental project In Russi, andEC PHAREIs providingfnanci support to similarnational tunds In Hungaryand Poland.

Thereawe, however, numerous problms with the currentstructure of environmerntalfunding that relis heavly on EFs:

o Althoughemnission dcarges are the mostdirect and effectivemethod of Intemaltizingenvironmental damage, the currentpractice of eying verylow emissioncharges on a large numbr of pollutantsmakes the admIntstratlonot thecharge sysem ineffcient;

o Subsidlesprovided through EFs, without parallel improvements In enforcementof environmentalstandards and regulions, maei pollutersreluctant to spendtheir own moneyfor environmentalInvestments In aitidpatlon of public monles;

o Sincemost EFs provide both public and commercialfinancng, commercialbanking operations may overshadow or overtakeEFs main purposeof environmenafinancing;

o Revenueallocatlon is rarelysupported by cear environmentalprioritis; tnis, aswell as insufficienttransparency and accountability in the decisionmaking process add to non-optimalus of ftunds

Therore, EFsshould be conitderedas only temporaryfinancing mechanisms with a limitedmandate during the trnsition period. EFs should (i)srengthen the environmentalpolicy mwok by developinrgstong montoringand enforcenentcapablits; p) fnnce priority Inmvesmentswhere no alaemlSe to publicfWiance exists; iN)accelere posiive,environmntal Improvementsby mobiiizingentarprise and privateresources to financecost-ffctive environmentalInvestments; and tv) facilltleea constructiverelationship betwen the nironmental policy authorityand regulatedsector using carrots and slicks. Theiropetion shouldbe subjectedto a numberof rules, including:

o Targethigh prioity areasonly:

o Usefunds to strengthenthe monitoringsystem, graduniy makeit inpdent from the stae budget,and morecapable to assist enforcwntr of environmenalregulations;

o Useftinancing toie as leverageto inducecomplience with *evIronmentalreguabions;

o Supportthe changeIn managnwemenpracicrs end the identincationof coat-effectivealternative soiutilons; o Mobilizeenterprise resourc to ensureentrprise commitment; and o Settime limb on eerpflsesupport TheEPa should significantly Improve their capabilties to detenrinespending priortites: apprise a selectprWOeds; and supervise the achievementof eWironmenta Improvements. Clea financing priorilles nd cst-ffectivenesscritea sWhould guide thir resourcealocation andtransparency and accountability should be bulit In the decision mswng processes Background Papers: Legislation, 144 Standards and Enforcement

7.52 Recommendations. The advantages of raising revenues for the financing of environmnental programs through pollution charges (see box below) should be assessed. The alternative method of financing, i.e., relying on the central government budget, has substantial costs (so-called deadweight losses) caused by distortions in the economy due to general taxes needed to raise revenues. In the current economic situation, the opportunity to generate fiscal revenues in a non-distortionary fashion should not be left unexplored (as economists say, a "double dividend" arises when taxes on externalities replace taxes which have positive social costs). However, the comprehensive system of effluent charges, as it is set up now, suffers from an excessive complexity, while institutional and monitoring capacities are inadequate. The system should be simplified and reduced to a limited number of standard pollutants and large polluting sources. Personnel training program is needed, and evaluation (oversight) mechanism should be built into the system, including collecting information on administrative costs and environmental effects on a systematic basis. Other pollution charge schemes, which require lesser monitoring capacity and lower administrative costs, might be considered. For example, user charge for collective wastewater treatment is a possibility to recover environmental investments in a simple way. Donors' assistance may be requested to help with the design of the most appropriate pollution charge scheme.

Use of Pollulion Charges Pollutioncharges are inutroducedin five differentvariants. They are goal-specificand again depend on constraintsto implementation.

* EMuent charges are based on the quantityand/or quality (how much or how toxic) of the dischargedpollutant. They require correctly set standards,and efficient monitoring system. Neither of them are now availablein the KyrgyzRepublic. Effluent pollution charges should be paid by economicagents (usually firms, buthouseholds could also be included),which discharge polluting substancesinto air, water bodies andlor in the soil. The level of these charges should be determinedby the government.

* User charges constitutepayments for the cost of using public facilitiessuch as publiclyowned water treatmentand sewerageplants. These charges are verybroadly imposed, and shouldalways be based on abatementcosts. They are regulatedprices, and should respond both to market signals,and to socialpriorities. Settinguser chargesfor water treatmentservices in the Kyrgyz Republicshould (i) be a responsibilityof the water companies;(ii) allowfor cost recovery,(iii} provideincentive for pollutionreduction; and (iv)support the socialsafety program. These charges are now too low, and their upward adjustmentproceeds slower than inflation.

* Product charges are leviedagainst a productor a productcharacteristic (e. g. detergentsolubility) with a negativeenvironmental externality. They provide a substantialincentive for changing consumers'behavior, and for environmentallysound research and development on the supplyside. Productcharges can be introducedrelatively easily in the former centrallyplanmed economies duringthe price adjustmentperiod, whenprice fluctuationsare common,and consumersare more tolerantto price increases.The supplyside is subjectto someconstraints in reactingto product taxes/chargesbecause of high share of cbemical industry, and its low product transformation capacity.

* Administrativecharges are paymentsboth for servicesrendered, such as the registrationof toxic chemicalsor pesticides,and implementationand enforcementcosts. These charges are patticularly suitable for introducing a permit system.

* Tax differetiao imposesfavorable pricing on environmentallyfriendly products. This is more a subsidy-typeincentive, which supports market restructuring. Due to insufficienttax system,and to generalrejection of subsidiesof any type, tax differentiationdoes not seem very appropriatefor the Kyrgyz Republic. Background Papers: Legislation, 145 Standards and Enforcement

7.53 Financing Environmental Protection. According to the Law on "The Budget of the Kyrgyz Republic" state environmental expenses for national environmental programs are covered by the Republican Budget. Every province (oblast), district (rayon) and city (gorod) has its own budget adopted by its local council. Partially, environmental protection measures are financed by the local budgets. Due to budgetary constraints both state and local environmental expenditures are funded mostly from the earmarked extra-budgetary accounts, replenished from pollution charges and fees for the use of natural resources. The procedures for the formation and use of local and national earmarked environmental protection funds is defined by the President. These funds are established to finance measures for environmental protection, the reproduction of natural resources, the recovery of environmental losses, environmental cleanup operations following accidents and disasters, compensation for damages, and unforeseen expenditures. Increased concern with the potential environmental hazard of uranium tailings has led the Government to preparing draft tailings regulations. According to the draft, a new earmarked fund will be established for financing mitigation plans for the existing tailings, which will be financed from a transfer of one percent of the income from mining to a special "Kyrgyzaltin" fund. The problems of environmental financing, which need to be addressed, include: (a) clear allocation of responsibilities for financing of different types of mitigation and other environmentally-related activities across the budget, the environmental funds (extra-budgetary accounts) and the emerging private sector; (b) developing procedures for co-financing; and (c) setting clear financing priorities for the environmental funds and the Budget while building transparency and accountability in the decision making process.

7.54 Since 1990 the level of environmental spending was dramatically decreased as a result of severe economic decline. The share of environmental investments in the national income has fallen from 0.44 percent in 1985 to a record low of 0.05 percent in 1992, and 0.12 percent in 1993. Normally, even in developing countries, these investments account for more than 0.5 percent of the GNP. As a result, environmental protection activities were paralyzed, and the Kyrgyz Republic experienced the paradox to pay less attention to its environmental problems than under the Soviet system (which was supposedly neglecting environmental hazards). In order to reverse this trend in parallel with the economic recovery, the Kyrgyz Government needs to implement environmental regulations, which force the newly emerging private sector to make proper environmental investments.

7.55 The question of enforcement of the environmental standards and regulations is a central one for the success of the Kyrgyz environmental policy. Building an efficient monitoring system (with support from the donors) and improving the collection and dissemination of information would be critical. An annual report on the state of the environment should be prepared. The Ecological Scientific and Information Centers, are well placed to carry out this task, provided that they are strengthened, and linked with the monitoring stations. Public access to information creates an additional incentive to the enterprises to comply with the environmental requirements.

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