On July 24 a web-journal towardfreedom.org published an article by Lital Khaikin “Between Sacred Waters and Natural Capital: Resistance to Hydroelectric Dams in Mongolia”
In recent years, Mongolia has sought to expand its construction of hydroelectric dams in the northern provinces, where large watersheds connect Mongolia to the Buryat’ Republic in Siberia. Since the introduction of Mongolia’s Action Plan for Implementation of the Green Development Policy for the period of 2016–2030, the country has identified the river-systems in the northern provinces of Khövsgöl, Bulgan, Orkhon, and the Selenge as potential sources of hydroelectricity.
These plans would have direct effects on the Selenge and Eg rivers, as well as the larger Baikal basin within Russia. The Green Development Policy also presents hydroelectric development as the next step for Mongolia to transition from fossil fuels. The country, however, has experienced a significant loss of rivers and lakes in the past 20 years, signaling to the dramatic effects of the extractive and agricultural industries on Mongolia’s water sources. Hydroelectric projects, as well as the central mining industry, continue to demonstrate a lack of transparency, accountability for transboundary environmental impacts, and a resistance toward meaningful consultation with impacted communities.
Only the Eighteen Percent
In 2013, the World Bank’s Mining Infrastructure Investment Support (MINIS) provided financing of technical assistance and feasibility studies for Mongolia’s planned Shuren Hydropower Project and a water diversion project on the Orkhon River. Located on the Selenge River, the proposed Shuren dam would have had a 250 MW capacity. The Orkhon River would have seen a 33-100 MW hydropower installation and water diversion project that would send water from the north to the mining zones in the South Gobi.
The Selenge River is considered a transboundary body of water under UN protocol. Originating in northern Mongolia, the Selenge River has Ramsar protected wetland status and is an integral tributary to the Lake Baikal in Russia, contributing to about half the lake’s volume of water. With a geologic history of over 25 million years, the Baikal is designated as a UNESCO World Heritage Site and is known to contain about twenty percent of the world’s unfrozen fresh water. The Orkhon River is in turn a major tributary to the Selenge, with the Upper Orkhon Valley 200 km upstream from the planned diversion also holding UNESCO World Heritage status.
As the contentious project pushed ahead, former project manager for Shuren Hydro, Borzhigin Gendensuren Yondongombo, was quoted in Regnum stating that Mongolia would be building the Shuren dam on the “eighteen percent of the river that is on [their border]”. This statement characterizes the overall tone Mongolian officials have taken around the Shuren and Orkhon hydro projects. By deliberately disregarding the cross-border issues of water management, this approach neglects a nuanced understanding of cumulative impacts on an already sensitive ecological system.
The Baikal basin is in a precarious state as lower levels of precipitation in recent years have contributed to a decline in the flow of water to the lake from the Selenge. In combination with higher than normal air temperatures and decreases in precipitation in the Transbaikalia region, the long-term ecological effects of hydroelectric development in Mongolia could have transformative effects on the Baikal. Russian protection policies for the Baikal have also proven to be insufficient, as the region has been exploited through illegal logging, mining development and industrial pollution such as that from the Baikalsk Pulp and Paper Mill until its closure in 2013. More recently, residents of Irkutsk have advocated against the construction of China’s AquaSib factory that was intended to bottle 190 million liters of fresh water per year from the Baikal.
This encroachment of heavy industry threatens the fragile balance of the Baikal and the river-systems that are connected to it. Darina Dabaeva, a researcher from Buryatia, writes about the effects of Russia’s own hydroelectric development on the Baikal basin: “After the construction of the Irkutsk hydroelectric station (1956) Lake Baikal became an artificial water reservoir, as its level is being determined, to a greater extent, not by natural factors but the interests of the hydropower industry.”
The plateau encompassing Mongolia and Inner Mongolia (China) has in turn experienced a shrinking of lakes due to large-scale human intervention, from the demands of water-intensive coal-mining, to overgrazing and agricultural irrigation that disturbs groundwater and rivers. Satellite imagery confirms an escalation in the degradation of grassland following the 1990s—changes that carry permanent consequences for the livelihoods of Mongolian herders and rural populations.
Despite the interconnectedness of the water-systems between Mongolia, Russia and China, the UN Economic Commission has found that Mongolia does not currently have a legal framework for an Environmental Impact Assessment in a transboundary context. Concerns about the environmental impacts and lack of transparency from the MINIS-funded dams have been raised since 2012 by the Buryat’ Regional Association, Greenpeace Russia, UNESCO, and the advocacy group Rivers without Boundaries (RwB). In response to the MINIS environmental and social assessment in 2017, RwB concluded that there was a lack of information made available on the Orkhon water-diversion pipeline to the South Gobi, while damming the Selenge River and its tributaries would have cumulative effects in both Mongolia and Buryatia.
“Shuren will flood extensive croplands,” says Russian conservation scientist and RwB coordinator, Eugene Simonov. “All these resources are largely irreplaceable; restoration of livelihoods will be problematic due to a lack of similar resources in other places occupied by other communities. So people most likely will migrate to slums of the City of Ulaan Baatar. In Russia, impacts on fisheries, and change of water availability and quality is the main concern for locals.”
Concerns have also been raised about dams’ impacts on heregsuurs (graveyards) and other archaeological sites in the Selenge River and the Orkhon River valleys. Sukhgerel Dugersuren, director of the research group Oyu Tolgoi, states, “I am afraid the government is quietly digging out and selling the sacred burials in the Selenge valley. We have information from the field that there is extensive forest cutting, digging of burial and other archaeological sites, so that by the time they finally carry out a regional environmental assessment, they can [claim] ‘limited’ impact.”
An Internal Matter
Faced with the evidence of the far-reaching impacts of the MINIS project on the Selenge and the Baikal basin, the World Bank froze the tender process in 2017, effectively cancelling Mongolia’s plan to construct the Shuren dam. Despite this cancellation, Mongolia continued to pursue the development of another 315 MW hydroelectric dam known as the Egiin Gol, which would be situated on the Eg River. The Eg Riger is connected to the Selenge-Baikal basin as a tributary to the Selenge River. Since the Eg does not cross an international border, Mongolian officials tend to see the construction of the Egiin Gol solely as an internal matter. The impacts on a river basin however often come from the remote headwaters of a tributary, as Simonov describes, so the impact of a dam on a tributary must be understood within the larger context of the Selenge-Baikal basin.
Mongolia has been pursuing the construction of the Egiin Gol dam since the 1990s, and revived the project after Shuren Hydro encountered opposition from civil society organizations and UNESCO. China’s EXIM Bank agreed to finance the Egiin Gol in November 2015 with a loan of roughly $1 billion (USD), the majority of which would go toward building infrastructure. That year, the Government of Mongolia signed a contract with the China Gezhouba Group that enabled the Chinese company to start “preparatory works”, which would include the construction of an access road to Ulaan Baatar. Faced with continued protest from several Russian communities and international CSOs, China’s EXIM Bank froze the loan by late March 2016, and Gezhouba’s bulldozers were ordered to stop. Then, in April 2017, the Mongolian government created a new state company called Eg River Hydro Power Plant LLC which now holds land and development rights for hydroelectric projects on the Eg River.
Without financing from the World Bank, the Egiin Gol is not bound to the same environmental standards as the MINIS-funded Shuren and Orkhon project. Studies concluded in 2015 by Belgian company Tractebel Engineering had approved the feasibility of Egiin Gol. However, assessments of the Egiin Gol were considered incomplete by the UNESCO World Heritage Committee, through their International Union for Conservation of Nature (IUCN) 2015 mission report. In a letter to EXIM Bank’s President, Liange Liu, without Boundaries described how joint assessment agreements made between Mongolia and Russia in 2008 “have never been implemented due to unwillingness of either side to finance joint river basin management plan.”
Rivers without Boundaries also described to EXIM Bank how feasibility studies continually increased Egiin Gol’s proposed capacity from 220 to 315 MW. Simonov indicated that the dam would have “impacts on migratory fish spawning in Selenge River, drastic change in winter flows (a 3-10 fold increase), and deterioration of conditions in Selenge River Delta—a critical part of a World Heritage site and Ramsar wetland.” A dam on the Eg River would inevitably impact the Selenge, and so the Egiin Gol project could not have sufficiently considered the downstream effects on the Selenge-Baikal basin.
RwB cited a current lack of Mongolian and Russian legislation that would require basin-wide impact assessments. Simonov emphasized the importance of such a basin-wide approach in Egiin Gol’s Environmental and Social Impact Assessment, which would “cover all potential dams and Egiin Gol Hydro among them.” Assessments that do not consider hydro’s impacts on interconnected water systems endanger the integrity of these delicate ecologies, which extend beyond political borders.
“That is why we support such a basin-wide approach to assessment and planning,” Simonov says in response to the difference in environmental accountability standards between the Egiin Gol and the MINIS-supported project. “And that is why the World Heritage Committee insists that a REA/SEA is done before any individual project assessments.”
The UN Convention on the Protection and Use of Transboundary Watercourses and International Lakes includes in its definition of transboundary impacts the “effects on the cultural heritage or socio-economic conditions resulting from alterations” to environmental factors. The earlier MINIS consultation process was found to be lacking in a meaningful process of public participation. Documents about the project were released to the public only two weeks before the consultations, and studies on water in the Gobi were not released “due to confidential matter”. Similarly, the Egiin Gol project has not held adequate consultations with potentially impacted communities. Simonov states, “We still do not have any solid evidence on when and where there were any consultations on Egiin Gol EIA.”
This avoidance of meaningful public engagement can compromise the integrity of traditional rights to water, pastures, livelihood, and cultural heritage. The construction of the Egiin Gol, Shuren, and Orkhon dams would have displaced significantly larger populations than what has already been caused by mining development, including the internal displacement of about 500 members of Mongolian herder communities. Changes in fish population and migration would significantly affect the livelihoods of both fishermen in Russia, who rely on Baikal cisco (Omul whitefish) as a key food staple in the Baikal region, and the Mongolian catch-and-release sport industry, which relies on Siberian Taimen. Sukhgerel also indicated that the loss of cropland has raised concerns around Mongolian food sovereignty.
“Mongolia to date has not developed, and approved, a resettlement policy and standards for protecting its population,” says Sukhgerel. “It allows the private sector to do as it pleases in cases when local populations have to vacate land. Currently the practice is to continue affecting with noise, dust and water contamination until people move off on their own. In the cases where people complain or ‘make noise’, they make piecemeal payments to shut them up.”
In Mongolia, both the MINIS and Egiin Gol projects have been represented in a selective light that favors industry stakeholders. Hydro development is framed by financiers and government officials as economically beneficial, appealing with promises for improvements in infrastructure and the quality of daily life. “The so-called consultations in Mongolia as a common practice are used to promote or ‘sell’ a project without telling the local population how they will be affected,” says Sukhgerel. “They tell people only about great, positive changes or clearly indicate that they need to support it for national interests.”
Such promises for ‘development’ from international stakeholders are used to manipulate internal division by pitting communities in Mongolia against one another. “One dangerous ‘consultation’ topic that is carried by the government as well as the World Bank’s Mining Infrastructure Investment Support (MINIS) project”, describes Sukhgerel, “is that the Gobi population has the right to demand transfer of water from Orkhon, and that they should demand to expedite the project. A population in one region demanding access to a traditional water resource of another could result in social conflict.”
A Question of Priorities
The insufficiency of regional consultation in both the Shuren-Orkhon and Egiin Gol projects is part of a larger issue of deliberate exclusion of local populations in Mongolia by both state and multinational actors. China’s funding for the Egiin Gol was ultimately withheld in 2017 in the face of these environmental and social concerns, but the process of the Egiin Gol’s development reveals a continuing pattern of neglect for traditional land rights that is only becoming more volatile as Mongolia attracts more multinational companies and foreign investment.
When the Oyu Tolgoi mine in the South Gobi was undergoing construction in 2013 (jointly owned at the time by Rio Tinto, Ivanhoe Mines and Erdenes MGL), Rio Tinto and the World Bank refused to recognize the indigenous status or historical land claims of herders in the Gobi. A collective letter of concern, submitted to the World Bank’s International Finance Corporation (IFC) in 2013 by Gobi Soil, Soum Citizens’ Representatives’ Khural, and herders from the Javkhlant bagh, stated: “We are legitimate owners of the pastureland with historical rights supported by traditional customs. However, the company does not accept it, yet it provided no justification to further their position. The company thinks we are not ethnic minorities so that we have no right to claim land access.”
The Oyu Tolgoi mine required a water-diversion project on the Undai River in the South Gobi. The mine’s development prompted a coalition of Khanbogd herders to form the NGO Gobi Soil. Gobi Soil and fellow Mongolian NGO Oyu Tolgoi Watch described how diverting the Undai River would “deteriorate pastureland yields” along the river, costing irreversible damage to herders’ livelihoods. The letter to the IFC described how Rio Tinto’s mine was monopolizing the scarce water supply through the river diversion, “thus overpowering and domineering to use our water supply and pastureland”.
The nomadic requirements of herders do not always fit so comfortably outside the perimeters of hydro or mining projects. This pits the needs of local people against those of powerful multinational corporations that are actively privatizing Mongolian resources. “Herders have already lost access to the area fenced off by Rio Tinto,” says Sukhgerel, “but when they heard the river was going to be cut—blocked by a cement dam and waters piped to stop outside the licensed territory—they understood this as killing of a live organ of nature.”
Through a capitalist logic, “economic development” is equated with the construction of ever-more infrastructure projects that almost exclusively provide for the needs of mining and energy conglomerates. The entitlement to land, air and water that these projects seek to justify requires the devaluation of traditional means of land stewardship. This includes the practice of nomadism, which is deeply linked to regional climatic fluctuations and does not follow the same logic of large, private industry. “If you look at it from the point of view of World Bank and such development actors,” says Sukhgerel on the perception of ‘economic viability’ in herding, “they will say ‘not viable’ due to a small size production that cannot access or compete in global markets. But if you look at it as providing for a population of 3 million – then yes, it has provided, and we were pretty self-sufficient in decent quality, ecologically clean food until 1990. Does Mongolia have to, or strive to, compete in everything in global markets?”
By 2018, Rio Tinto had invested about $1 billion a year in the Oyu Tolgoi copper and gold mine. The multinational wanted to undergo a $5.3 billion expansion for which “according to a landmark 2009 agreement, a domestic power source must be found by 2022.” Rio Tinto signed an agreement with Mongolia to provide this additional power to Oyu Tolgoi (this time cited as by mid-2023), through the construction of a 300 MW power plant at the Erdenes Tavan Tolgoi coalfields. An independent expert panel found in its 2015 review of the mine’s expansion plans that herders’ water resources would be severely affected, resulting in the complete loss of the Bor Ovoo spring, fencing that would cause longer distances for herders’ access to water, and watershed impacts leading to the loss of summer pasturelands and water sources. To top it off, Oyu Tolgoi LLC holds exclusive rights to use the water resources for the duration of its mining license.
“The traditional nomadic lifestyle is recognized as a cultural heredity rather than a livelihood need that is dictated by climatic and ecological conditions,” describes Sukhgerel. “The government does not recognize the right of herders to traditional pastures and water sources. Yes, the government is proposing to semi-privatize pasture by issuing possession on utilization licenses. There are maybe very few pockets of areas where this can be done up in the northwest, but it is not sustainable elsewhere in the country.”
The resulting displacement of rural populations forces people to migrate to Ulaan Baatar and the southern Dornogovi—despite the government’s recent ban on migration to Ulaan Baatar through 2020. This influx drives the depopulation of rural areas, devalues both traditional lifestyles and relationships to the land, and continues the spiral of unsustainable energy consumption. The population in Ulaan Baatar has nearly tripled since the 1990s and much of this growth has occurred in ‘informal’ settlements known as gers. Ulaan Baatar remains one of the most polluted capitals in the world, with nearby coal plants and the burning of raw coal in the city contributing to record-breaking air pollution, with the Bulletin of the World Health Organization reporting in 2019 that approximately 200,000 gers contribute to about 80 percent of the city’s winter pollution.
Without environmental and social protections for rural populations from the encroaching extractive industries, and the potential ecological damages of hydroelectric dams, this pattern of internal displacement and stress on Mongolia’s resources will only continue. As global corporate monopolies continue to force people out of their homelands, there must be protections in place to both validate and empower traditional means of land stewardship, which require environmental responsibility and a deep understanding of ecological relationships that transcend geopolitical boundaries. To date, Mongolia’s participation as only an “observer” in sessions on environmental assessment in transboundary contexts does little to protect the integrity of larger ecological systems in which its industries are implicated. When local people—not industry representatives—speak, they show that despite reaching for “green” policy, Mongolian energy development is not especially concerned with the livelihoods of its people, rather with the growing interests of industrial conglomerates.
 Mongolia’s first hydroelectric dams, like the Taishir, were constructed with Soviet assistance.
 «Строительство Эгийнской ГЭС — это вопрос независимости Монголии», REGNUM, January 7, 2018.
 Regional Environmental Assessment and Environmental and Social Impact Assessment (REA/SEA), May 2017. Matrix
 China Gezhouba Group has previously developed projects in Cambodia, Laos, Malaysia, Pakistan, and Myanmar, and was also involved in the controversial Grand Ethiopian Renaissance Dam that threatens water shortages on the Nile with the dam’s water diversion.
 China-Backed Hydropower Project Could Disturb a Sensitive Siberian Ecosystem, Eugene A. Simonov, https://www.transrivers.org/2017/1913/
 Convention on the Protection and Use of Transboundary Watercourses and International Lakes, Helsinki, March 17, 1992.
 Undai River Complaint, February 3, 2013.
 According to Mining.com
 Report from International Organization for Migration, link.
 Air Pollution in Mongolia, Bulletin of the World Health Organization 2019;97:79–80 | doi: http://dx.doi.org/10.2471/BLT.19.020219