The Ilisu Dam, the World Commission on Dams and Export Credit Reform
The Final Report of a Fact-Finding Mission to the Ilisu Dam Region

The proposed Ilisu Dam on the River Tigris in the Kurdish region of Southeast Turkey has generated immense international controversy. Turkey’s largest planned hydroelectric project would affect an estimated 78,000 people, mainly ethnic Kurds.

The companies that want to build the dam have sought financial backing from the export credit agencies (ECAs) of their countries, including Britain, Switzerland and the USA. In January 1999, the ECAs attached four conditions (relating to resettlement, water quality, downstream flows and archaeological preservation) to be met before they would issue export credits.

From 9-16 October 2000, an international Fact Finding Mission of Non-Governmental Organisations from the UK (including The Corner House), the USA, Germany and Italy went to the region of the planned Ilisu Dam to assess the Turkish government’s progress meeting the four conditions. This report presents their findings.

Contents

• Acknowledgements
• Summary
  • Concerns
  • The Four Conditions
  • The Fact Finding Mission and its Remit
  • The Mission's Key Findings
  • The Mission's Conclusions
  • The Mission's Recommendations
• Section 1: Background to the project
  • The Companies, the Export Credit Agencies and the Concerns
    • The companies
    • The export credit agencies
      • Other Funders
    • Major concerns
    • Human Rights and the Repression of the Kurds
  • Box 1: A History of Repression
  • Box 2: The Experience of War
    • Ilisu, GAP and Forcible Assimilation
  • Box 3: The GAP - Claimed Benefits
  • Box 4: Dams and the GAP
    • Euphrates Basin: 14 dams and 11 Hydroelectric Power Projects (HEPP)
    • Tigris Basin: 8 dams and 8 Hydroelectric Power Projects (HEPP)
    • Resettlement: Lack of Consultation
  • Box 5: "Your happiness will bring our success"
    • Flawed Environmental Impact Assessment
    • The Destruction of Hasankeyf
    • Water Wars - The Risk of Regional Conflict
• Section 2: The mission and its findings
  • The mission's remit
    • The Fact Finding Mission and its Remit
    • The Mission's Key Findings
  • Evaluating progress in meeting the four conditions
    • Condition one: "Draw up a resettlement programme which reflects internationally accepted practice and includes independent monitoring"
    • Confusion over the number of affected people
    • Doubts on Promises to Trace Missing Villagers
  • Box 6: GÖÇ-DER: The Immigrants Association for Social Co-operation and Culture
    • Refugees from the Ilisu Dam Region: Testimony
      • Unrealistic Assumptions on Compensation Claims
  • Box 7: Problems Obtaining Compensation
    • False Claims over Improved Resettlement Practices
  • Box 8: The Birecik Dam: The Companies and the Banks
  • Box 9: Resettlement - Improving Prospects or Slow Death
    • Lack of Land Titles
• Box 10: European Court of Human Rights Cases Relating to GAP
  • Yasar and others v Turkey. (Judgment):
  • BT and others v Turkey. (Settled):
  • V.N.K. and 44 others v Turkey. (Settled):
  • Inadequate Consultation
    • Host communities
    • Relying on Presumed Economic Growth to Relieve Post-Project Impacts - A Breach of Standards
    • Institutional Failures and the Need for Reform
    • Resettlement and Regional Conditions
    • Independent Monitoring
  • Condition two
  • Condition three
  • Condition four
• Box 11: The Murat Cano Court Case
• Box 12: HASANKEYF and Turkish Obligations under International and European Law
  • Conclusion

• Section 3: Ilisu, The World Commission on Dams and ECA reform
  • Issue three: Ilisu - a litmus test of the ecgd's and hermes' commitment to reform
  • Box 13: WCD - The New Benchmark
    • Institutional Support
      • Ilisu and the WCD
  • Box 14: Ataturk's Victims: The Continuing Misery
    • Companies and financiers involved
    • Health impacts
    • Social and Environmental impacts
    • Resettlement and compensation issues
    • Impacts on neighbouring countries
  • Box 15: A Tragi-Comedy in 90 Seconds
    • The OECD Draft Agreement - Failing to Meet the Challenge of Reform
• Issue three: Ilisu - a litmus test of the ECGD's and HERMES' commitment to reform
  • The Mission's Recommendations
• Appendix 1: Jakarta Declaration
  • Introduction
  • Call for Reform
  • Conclusion
• Notes and references

Acknowledgements

This report is based on an international Fact-Finding Mission to the region of the planned Ilisu Dam in Southeast Turkey between 9th and 16th October 2000.

The authors of this report are:

Nicholas Hildyard, The Corner House, UK

Antonio Tricarico, Campaign "An Eye on SACE", Italy

Sally Eberhardt, Kurdish Human Rights Project, UK

Heike Drillisch, World Economy, Ecology and Development, Germany

Douglas Norlen, Pacific Environment Research Center, USA

The Fact-Finding delegation would like to thank all those within Turkey who assisted with Mission, providing accomodation, interpretation and information about the Ilisu project. Thanks are due to the many individuals, including local officials, journalists, civil servants, historians and lawyers, and to local and national organisations, including the Human Rights Association of Turkey (IHD) and GÖÇ-DER. In the UK and US, we would like to thank Angela Barber, Dean Bialek, Harun Duzgoren, Koray Duzgoren, Kate Geary, Rebecca Wood and the Center for Inetrnational and Environmental Law (Washington, DC). Finally, we would especially like to thank the many refugees and villagers who shared their concerns and experiences with us.

For more information on the Ilisu Dam Campaign, see www.ilisu.org.uk.

For more information on the international campaign to reform export credit agencies, see www.eca-watch.org.

The price of this publication (£5) covers printing and other costs associated with its production and distribution. If you would like to order additional copies, please contact the Kurdish Human Rights Project (UK) at khrp@khrp.demon.co.uk or by telephone at +44 207 287 2772.

Summary

Few infrastructure development projects have caused as much international controversy in recent years as the proposed Ilisu Dam in the Kurdish region of Southeast Turkey. Scheduled for construction on the River Tigris, some 65 kilometres from the Syrian border, the dam is intended to generate 3,600 gigawatt-hours of peak hour electricity a year and is Turkey's largest planned hydroelectric project. The dam forms part of the giant Southeastern Anatolia Project (known as GAP after its Turkish name, Guneydogu Anadolu Projesi), a network of 22 dams and 19 power plants: it would be built by a consortium of European and US companies for the Turkish government's State Hydraulics Works Department (DSI). Financial backing is being sought from the export credit agencies (ECAs) of the companies' respective national governments, with Britain, Switzerland and the USA signalling provisional approval. Once constructed, the $2 billion dam would be transferred from DSI to the State electricity company, TEAS, which would then be responsible for its operation.¹

Concerns

Concern over Ilisu has centred largely on the failure of the project to meet international standards for infrastructure projects involving forcible resettlement and shared rivers. As planned, the dam would flood an area the size of Manchester, submerging or partially submerging some 183 villages and hamlets² and the ancient town of Hasankeyf, a site of international archaeological significance. Yet, at the time that the project was provisionally approved by supporting ECAs, no resettlement plan had been drawn up for the estimated 78,000 people, mainly ethnic Kurds, who will be potentially affected by the dam. Nor had there been any consultation whatsoever with affected people or their elected representatives: indeed, until late 1999, local Mayors had not even been informed that the project was going ahead. The dam's environmental impacts were also largely unassessed: although the companies seeking contracts for the dam had commissioned an Environmental Impact Assessment [EIA], independent reviews had revealed it to be wholly inadequate. Moreover, despite fears that the dam could adversely affect the water quality of the River Tigris, disrupt downstream wetlands and irrigated agriculture, and exacerbate the potential for regional conflict over water between Turkey and its neighbours, Syria and Iraq, there had been no consultation with downstream states, as required under international law.

The Four Conditions

In response to growing pressure from the public, NGOs and parliamentarians, the ECAs attached four conditions to their support for the project which the Turkish government must meet before export credits are issued. The four conditions, announced in December 1999, are as follows:

1. Draw up a resettlement programme which reflects internationally accepted practice and includes independent monitoring;
2. Make provision for upstream water treatment plants capable of ensuring that water quality is maintained;
3. Give an assurance that adequate downstream flows will be maintained at all times;
4. Produce a detailed plan to preserve as much of the archaeological heritage of Hasankeyf as possible.

Whilst, on paper, these conditions would go some way to meeting the concerns of critics, there are considerable doubts whether they can or will be met in practice. One concern, highlighted in a recent report by a World Bank consultant hired by the ECAs to assess the Turkish authorities' draft resettlement plan, lies in the lack of institutional capacity within Turkey to undertake a resettlement programme to international standards. Another relates to the ability - and will - of the ECAs themselves to monitor compliance, the rigour with which they will do so, and the political leverage available to them should the Turkish authorities renege on the conditions.

More intractable are the implications for compliance of Turkey's well-documented repression of the Kurdish majority in the region, its abject failure to abide by previous commitments to curb human rights abuses against the local population and its racist policies of enforced assimilation of ethnic Kurds into mainstream Turkish society. Indeed, continuing human rights abuses are central to the controversy over Ilisu. Human rights violations - relating to intimidation - have already been documented in connection with the dam and whilst intimidation, torture, denial of freedom of expression and repression remain the norm in the area, the prospects of a just outcome to the project remain distant, if not unattainable.

The Fact Finding Mission and its Remit

In October 2000, an international Fact Finding Mission of Non-Governmental Organisations from the United Kingdom, the USA, Germany and Italy was established under the aegis of the Kurdish Human Rights Project and the Ilisu Dam Campaign. The Mission was charged with:

1. Assessing the progress being made by the Turkish government in meeting the four conditions laid down by the ECAs; identifying the institutional and other problems that remain outstanding; and evaluating the prospects of their being resolved;
2. Assessing whether or not the conditions, even if met, are sufficient to bring the project into line with evolving international best practice. The Mission was explicitly charged with reviewing Ilisu in light of new guidelines developed by the World Commission on Dams;
3. Identifying corporate governance failures in the practices and procedures of the supporting ECAs that have contributed to the controversy over Ilisu; assessing the extent to which these failures will be addressed by new procedures under consideration by the OECD's Working Group on Export Credits; and proposing corrective action;
4. Evaluating whether or not continued support for Ilisu could be justified by the UK government in the light of new procedures being developed by the UK Export Credit Guarantees Department (ECGD) as well as by the other governments' stated commitments to reform their ECA's guidelines in order to take account of environmental, social and developmental criteria.

The Fact-Finding Mission visited the Ilisu region from 9th-16th October 2000. The Mission met with affected people, prominent municipal officials, lawyers and local professional associations relevant to the project. Throughout its time in the region, the Mission was followed by state security police, who also sat in on one interview uninvited. Security police also attended a press conference held by the Fact-Finding Mission on its return to Istanbul, threatening that the press conference was illegal.

Members of the Mission also attended the launch of the World Commission on Dams (WCD) in November 2000, conducted informal interviews with a number of Commissioners and with leading members of the WCD Forum, the 68-member consultative group set up by the WCD and consisting of key representatives from government, the private sector, multilateral development agencies and affected communities.

The Mission's Key Findings

The Mission's main findings are set out in this report. The Mission confirms earlier concerns that:

• Conditions in the region make a fair and just resettlement to international standards unattainable;
• Well-documented failures of past and current resettlement projects in Turkey, acknowledged by the Turkish government, have still to be addressed in any substantive way;
• Doubts still exist as to the true number of people who would be potentially affected;
• Consultation with the affected people in the Ilisu area has been piecemeal, inadequate, biased in its format and constrained by an air of intimidation. Some key consultations which are reported to have taken place have in reality not occurred;
• Host communities have not been asked to draw up resettlement plans and their budgetary requirements have not been assessed, in contravention of World Bank standards;
• The adequacy of the socio-economic surveys required to meet international standards has been questioned;
• Lack of capacity and institutional fragmentation render a coherent resettlement programme unachievable. Major institutional reforms will be necessary before there can be any confidence that resettlement will be carried out to international standards. There is also a need to overhaul existing compensation procedures;
• Planned sewage treatment facilities in upstream towns are inadequate to ensure water quality in the reservoir area, either because they will not cover the entire population or because they are still at the feasibility stage;
• The downstream impacts of Ilisu may be underestimated because no comprehensive analysis has been undertaken of the cumulative impacts of both Ilisu and its companion downstream dam at Cizre. The two projects are independent but have been wrongly represented as separate and unconnected. Because Cizre is an irrigation dam, water fed to it by Ilisu will be largely lost to downstream flow.
• Time and financial pressures on investigations and salvage of the archaeological wealth of the affected area render such rescue efforts reckless, haphazard and contrived. More important, efforts to salvage archaeological resources are limited to artefacts and cannot extend to the thousands of caves in the area, even though the cave civilisation is the essence of the irreplaceable treasure that is Hasankeyf.

The Mission's Conclusions

The Mission concluded that:

• The four conditions imposed by the ECAs have yet to be met - and the prospect that they will be met in the future is remote. Whilst the social, political and economic rights of the Kurdish majority in the region remain unrecognised - and indeed repressed - there can be no confidence that the Turkish authorities will abide by the conditions. Serious concerns also exist over the capacity - and will - of the ECAs themselves to monitor and ensure compliance.
• Even if met, the four conditions leave many key concerns (particularly those relating to transparency and human rights) unaddressed and would fail to bring the project up to international standards. The project violates each and every one of the WCD's major policy recommendations and would still be in breach of WCD standards even if the four conditions were met in full.
• The history of ECA involvement in the Ilisu project reveals major deficiencies in current ECA practice and procedure. In particular, the lack of common mandatory standards have encouraged a "band-aid" approach to project financing that works to the detriment of affected communities and industry alike. The OECD Working Party's proposals for ECA reform - particularly its emphasis on "benchmarking" - will exacerbate rather than remedy this deficiency.
• Continued support for the Ilisu Project is in breach of both the spirit and the letter of the new Business Principles adopted by the ECGD. Ilisu is thus a litmus test of the ECGD's commitment to the new principles: proceeding with the project would signal a fatal lack of purpose in reforming the ECGD and in embracing the principles of sustainable development, as espoused by the UK government. Support for the Ilisu project would also conflict with the German government's intention to reform the Hermes guarantee system according to environmental, social and developmental criteria, stated in its coalition agreement. Granting a guarantee for the Ilisu dam would discredit all such reform efforts.

The Mission's Recommendations

In the light of its findings, the Mission will be pressing the ECAs involved in Ilisu to refuse export credit support for the project. In addition, it urges the Turkish Government to consider alternatives to large dam projects like Ilisu that would not impose increased hardship or threaten internal displacement of its Kurdish citizens and other minorities. Alternatives to Ilisu exist - for example, by addressing the 15-25% electricity losses through poor transmission. The Mission also urges the Government to respond to calls for peaceful, political solutions to the Kurdish question.

More generally, the Mission recommends a deep reform of current export credit agency practice. In particular, it urges ECAs:

1. To adopt the proposals set forth in the "Jakarta Declaration for Reform of Official Export Credit and Investment Insurance Agencies," which is supported by over 300 NGOs worldwide;
2. Accordingly to adopt mandatory, legally-binding standards, with accompanying "positive" and "restrictive" screening procedures, that would weed out projects that did not meet international environmental, development and human rights standards prior to their being considered for support and ensure compliance with those standards once support has been approved;
3. Adopt the Report of the World Commission on Dams and endeavour to ensure that all future hydropower contracts in which they are involved comply with the Set of Guidelines for Good Practice (contained in Chapter 9 of the Report). At a minimum, companies seeking support for projects involving dams should be required to explain why specific WCD principles and guidelines are held to not be applicable and attach this explanation as an appendix to the project's Environmental Impact Assessment;
4. To undertake and make public a human rights assessment of any project for which export credit support is being considered, detailing the extent of compliance by the national government with international human rights agreements and standards.

Section 1: Background to the project

The Companies, the Export Credit Agencies and the Concerns

Few infrastructure development projects have caused as much international controversy in recent years as the proposed Ilisu Dam in the Kurdish region of Southeast Turkey. Scheduled for construction on the River Tigris, some 65 kilometres from the Syrian border, the dam is intended to generate 3,600 gigawatt-hours of peak hour electricity a year and is Turkey's largest planned hydroelectric project. The dam forms part of the giant Southeastern Anatolia Project (known as GAP³ after its Turkish name, Guneydogu Anadolu Projesi), a network of 22 dams and 19 power plants; it would be built by a consortium of European and US companies for the Turkish government's State Hydraulics Works department (DSI), with financial backing from the export credit agencies of the companies' respective national governments. Once constructed, the dam would be transferred from DSI to the State electricity company, TEAS.⁴

The companies

Plans to build the Ilisu Dam were first mooted in 1954. Although pre-feasibility studies were completed in 1971 and the final design for the dam was approved in 1982,⁵ the project remained on the drawing board until the late 1990s.

One reason for the delay lay in a lack of finance. From 1984, the Turkish security forces were engaged in a vicious armed conflict against the Kurdistan Workers' Party (PKK) throughout the Kurdish region of Turkey. The war, which was costing $10 billion a year in military terms alone,⁶ left the Turkish government unable to fund the project on its own account. The conflict also led to the World Bank, the world's largest multilateral development agency, signalling that it would be unwilling to finance infrastructure projects in the region.⁷

In 1996, the Turkish government sought to raise the necessary finance by offering Ilisu to the private sector as a Build-Operate-Transfer project. No bidder could be found, however, raising questions over the projects commercial viability. A year later, the State Hydraulic Works (DSI) selected the Swiss turbine manufacturer Sulzer Hydro as the main contractor for the project.⁸ The project was never put out for international tender.⁹

Whilst Sulzer Hydro - sold to Austrian VA Tech in 1999 - retained responsibility for the electromechanical works, in conjunction with ABB of Switzerland, it subcontracted the civil engineering works to a consortium led by UK construction company Balfour Beatty. Other companies in the consortium included Impregilo of Italy, Skanska of Sweden and three Turkish construction companies, Nurol, Kiska and Tekfen. According to the DSI, the engineering consultants to the project are the UK firm Binnie and Partners (now Binnie, Black and Veatch), although the company, which was part of the original design team, has told the Ilisu Dam Campaign that they "are not involved yet and are awaiting the project to be funded."¹⁰ As yet, no contracts have been signed between the DSI and any of the companies in the consortium.¹¹

ABB's involvement in the dam ceased in March 2000, when it sold out its hydropower business to the Anglo-French energy giant Alstom, handing over all its contractual responsibilities for Ilisu (and other controversial projects, such as the Three Gorges Dam in China) as part of the deal. Three months later, ABB announced a new focus on alternative energy technologies, such as wind and solar - a market the company described as "huge".¹² ABB stated that it expected to increase its sales in renewables and small-scale power generation from $400 million to $1.4 billion by 2004. The decision followed a decade long campaign by Swiss, Swedish and international NGOs to persuade ABB and other power generation companies to reconsider their involvement in hydropower¹³ - a campaign that had included tactics from mass letter writing to protests and shareholder actions. ABB has said that the decision was taken on the basis of an overall market analysis - but that the company took the growing sensitivity of major shareholders regarding social and environmental concerns "very seriously".

In September 2000, the Ilisu consortium lost another of its original members, when Skanska, which had a 24 per cent share in the project, announced its withdrawal from the project. Unlike ABB, whose place was filled by Alstom, Skanska has yet to be replaced. Although the company told the Financial Times that the decision resulted from unspecified negotiating problems which were unrelated to public protests over the social and environmental impacts of the project, company spokesperson Thor Krussel told the Turkish newspaper Ozgur Politika that the firm did not participate in projects which are "not to the benefit of society and the environment."¹⁴ In an interview with the London Guardian newspaper, Krussel also pointed out that the company's environmental policy had been updated so that the company was now committed to "caring about people and the environment" in all its work. Krussel stated: "Skanska will abstain from participating in construction projects when in our judgement a project will result in serious risks to the environment or to society at large."¹⁵¹⁶

Of the companies remaining in the consortium, Balfour Beatty, Impregilo and Sulzer Hydro have all been criticised for their involvement in a number of dams which have resulted in adverse social and environmental impacts (see Table 1). As a member of the Lesotho Highlands Project Contractors (LHPC), Balfour Beatty is currently being prosecuted in Lesotho, on corruption charges arising from the consortium's involvement in the Lesotho Highlands Water Project.¹⁷ In a judgement given in October 2000, in a similar case against the Highlands Water Venture (HWV) consortium, (which includes the Italian company, Impregilo), the Court of Appeal in Lesotho ruled that partnerships per se could not be charged because they lacked legal personality. The prosecuting authority in Lesotho has yet to decide against which of the individual members of HWV they will now proceed. The effect of the Court of Appeal's ruling is that a similar procedure will be adopted in the charges against LHPC when the matter comes before the court in August 2001. Balfour Beatty has also fallen foul of the law in a number of other countries: in 1996, it was banned for five years from competing for projects in Singapore, following a corruption inquiry, and in 2000 the offices of Balfour Beatty-Massachusetts Electric were raided by the FBI in relation to fraud allegations over the company's contract for constructing Amtrak's electric systems for Northeast Rail Co.¹⁸ In recent years, Balfour Beatty has been prosecuted in the UK for its failure to uphold health and safety standards during construction of some of the UK's most high-profile projects - notably the Heathrow Tunnel Extension - and a number of senior Balfour Beatty staff are currently facing possible corporate manslaughter charges as a result of the Hatfield train crash in October 2000, in which four people died and 30 were injured on a stretch of line for which the company had the maintenance contract.

Table 1: The companies and their record

Company	Role in Ilisu	Corruption Allegations	Impacts of Past/Current Dam Projects
Alstom, France/UK	Electromechanical Works. Took over from ABB		Tucurui, Brazil: Flooded more than 2,000 square kilometres of rainforest, displaced 24,000 people and led to virtual elimination of several indigenous groups. Three Gorges Dam, China: Involves forcible relocation of 1.4 million people. Itaipu Dam, Brazil: Drowned large area of rare Atlantic Forest, displaced 42,000, major adverse health impacts, widespread corruption associated with project
Sulzer Hydro (Acquired by VA Tech in October 1999), Switzerland/ Germany/Austria	Electromechanical Works		Three Gorges Dam, China: Forcible relocation of 1.4 million people. Nathpa Jhakri, India: World Bank withdrew from project after miscalculations in the height of the dam were revealed. Only produced half of anticipated power.
Balfour Beatty, UK	Construction	Lesotho: current prosecution for corruption. Next hearing August 2001. Singapore: 5-year ban following corruption allegations, denied by company USA: under investigation for fraud	Pergau, Malaysia: Dam built with illegal use of UK development aid. Samanalawewa Dam, Sri Lanka: reservoir of dam could not be filled because its bed leaked so badly. Dam now described as "a write off". Inadequate resettlement Victoria Dam: Inadequate resettlement Lesotho Highlands Water Project, Lesotho: Inadequate resettlement, alleged corruption, striking workers sacked, shooting of workers evicted from construction site.
Impregilo, Italy		Lesotho: being considered for prosecution for corruption as an individual entity.	Bakolori, Nigeria: No compensation to 12,000 people evicted. 126 protestors massacred by police. Chixoy, Guatemala: 400 Maya Ache indigenous people who lived in reservoir area massacred. Yacyreta, Argentina: Project described as "a monument to corruption". Lesotho Highlands Water Project, Lesotho: Inadequate resettlement, alleged corruption.

The export credit agencies

Although the DSI is the project developer, the financing for Ilisu has (at the Turkish government's request) been handed over to the construction consortium which has been charged with raising the full construction costs for the project.¹⁹

The financial package for Ilisu will be arranged by the Union Bank of Switzerland (UBS). With approximately half of the construction costs being made up of imports from Western Europe and the USA, the companies in the consortium sought government-supported export credit guarantees from the Export Credit Agencies (ECAs)²⁰ of nine countries - Austria, Germany, Italy, Japan, Portugal, Sweden, Switzerland, the UK and the USA.

In November 1998, the Swiss export credit agency, Exportrisikogarantie (ERG), approved provisional export credit support of 470 million Swiss francs for the Ilisu contracts of Sulzer Hydro and ABB.²¹ Sulzer Hydro, which was bought up by VA Tech of Austria in 1999, has also applied to Hermes, the German export credit agency, for a 150 million DM (approx. $75 million) credit, or approximately 5 per cent of the project's total costs. The Hermes application is still pending: after intense campaigning by NGOs and wide public criticism, government officials promised that no decision will be taken until a resettlement action plan and environmental impact assessment have been submitted.

In the UK, the Secretary of State for Trade and Industry has announced that the government is "minded" to approve a $200 million credit for Balfour Beatty, whose joint venture in the US, Balfour Beatty International, has also applied for a further $20 million from Ex-Im Bank, the official US export credit agency. Ex-Im has issued a "Letter of Preliminary Commitment" and is reviewing Balfour Beatty's application. It is generally held that Ilisu will fail to meet Ex-Im's existing standards or the revised standards that Ex-Im is currently considering adopting (see p. 84).²²

Italy's export credit agency SACE has similarly given approval for a $152 million guarantee to Impregilo, although this has still to be confirmed by the Interministerial Committee on Economic Planning (SACE having formally requested an opinion on its financial involvement in the project).

Sweden, which had been considering an export credit for Skanska, is no longer involved in the project, following Skanska's withdrawal.

Other Funders

According to the GAP Regional Development Administration, funding from United Nations Development Programme (UNDP) will be used for planning the resettlement of those affected by the dam, "constructing a Hasankeyf museum" and "preparing a document which contains rescued historical material".²³

Major concerns

When first approved by the consortium of companies and export credit agencies supporting the project, Ilisu was in violation of a range of internationally accepted guidelines for development projects, as exemplified by those required for World Bank-financed projects. Not only did it abrogate five World Bank policy guidelines on 18 counts, but it was also in breach of core provisions of the UN Convention on the Non-Navigational Uses of Transboundary Watercourses and the UN/ECE Convention on the Protection and Use of Transboundary Watercourses and International Lakes (Helsinki 17 March 1992). The project had no resettlement plan and there had been no consultation whatsoever with affected people or their elected representatives, such as local mayors. The dam's environmental impacts were also largely unassessed: although the companies seeking contracts for the dam had commissioned an EIA, independent reviews had revealed it to be wholly inadequate. Moreover, despite fears that the dam could adversely affect the water quality of the River Tigris, disrupt downstream wetlands and irrigated agriculture, and exacerbate the potential for regional conflict over water between Turkey and its neighbours, Syria and Iraq, there had been no consultation with downstream states, as required under international law.

Since the announcement of export credit support for Ilisu, a number of reports - from both Non-Governmental Organisations²⁴ and official sources²⁵ - have exposed massive deficiencies in the planning and implementation of the project. In the UK, the involvement of the ECGD in the project has been subject to a number of parliamentary inquiries. In July 2000, the parliament's International Development Committee concluded: "We have here a project proposed for ECA support that, despite having been in preparation for many years, fails almost every internationally agreed test in terms of both consultation and planning for environmental and social impacts ... The Ilisu Dam was from the outset conceived and planned in contravention of international standards, and still does not comply."²⁶ Following publication of the report, Ann Clwyd MP, a member of the committee and Chair of the Parliamentary Human Rights Group, visited the region. Other MPs from the UK, Italy and Germany have also undertaken fact finding missions, reporting critically on the dam.²⁷ A delegation of the German parliament's Human Rights Committee has also concluded that the Ilisu dam should not be constructed and that the German government should not give an export credit guarantee support. The Committee also recommended that the Turkish government should register Hasankeyf as a World Heritage Cultural Site.²⁸

Public and parliamentary concerns have centred on a cluster of key issues:

• First, that the long and continuing history of repression of the Kurdish majority in the region by the Turkish State makes a just outcome to the project unrealisable;
• Second, that the project, which will flood the homes of up to an estimated 78,000 people, fails to meet the most basic international standards with regard to resettlement and environment;
• Third, that the destruction of the ancient Kurdish town of Hasankeyf, a site of international archaeological importance, which would be partially submerged under the dam's reservoir, is an unacceptable price to pay for the project; and
• Fourth, that the dam has the potential to exacerbate regional conflict over water between Turkey and its downstream neighbours, Syria and Iraq.

Criticisms have also been raised over the lack of transparency with regard to key project documents, notably the Environmental Impact Assessment, and over the failure to consider alternatives to the dam (see pp. 89-91).

These concerns are considered in more detail below.

Human Rights and the Repression of the Kurds

Central to the controversy surrounding the Ilisu project is the continuing repression of the Kurdish majority in the region by the Turkish State. Such repression has a long history and is rooted in policies aimed at integrating the Kurds into mainstream Turkish society, if necessary by force. To date, the Turkish State's policy of assimilation has involved widespread human rights abuses, the brutal suppression of local Kurdish customs and culture, the outlawing of the Kurdish language, the imprisonment, rape and torture of political opponents, and the enforced resettlement of Kurdish villagers (see Box 1 below: A History of Repression)

Unsurprisingly, the region has been wracked by conflict, most recently in the form of a bitter, 16-year-long war between the Turkish security forces and the Kurdistan Workers' Party (PKK), during which an estimated 4,000 villages in the area were destroyed, and at least 3 million people forced to flee their homes.²⁹

The majority of the evacuations took place in the early 1990s and were carried out with great brutality, whole villages being razed to the ground; villagers, including children, being raped, abducted, killed, tortured or beaten up; and livestock slaughtered. By the end of 1992, entire districts, including Sirnak, Silopi and Eruh (all overlapping the Ilisu region), had lost all their villages, with the exception of one village guard district.³⁰ In July 1997, the Chairman of the Turkish Parliamentary Committee established to look into the problem of village evacuations confirmed that almost 365,000 inhabitants of 3,185 villages and hamlets had been forced out of their homes since 1990 as a result of the war. The US State Department cited a "credible estimate" of between 380,000 and 1 million for the numbers that have been forced to move.³¹ Other figures have been put as high as 10 million.

Since 1995, the figures have disclosed a declining but nevertheless continuing pattern of forced evacuation. In 1997, the Human Rights Association of Turkey (IHD) reported that 22 villages and hamlets had been evacuated and sometimes burned by State agents. These included three instances of forcible evacuation from in Eruh district, Siirt province and the forced evacuation of three hamlets in Besiri, Batman province. Both Eruh and Besiri districts are potentially affected by the proposed dam. Further evacuation and destruction by soldiers has been reported since then.

Most recently, the true colours of Turkey's State-sponsored "Back to the Village Programme," which claims to have returned thousands of evicted villagers to their homes in the Southeast, have been exposed by a series of horrifying events in autumn 2000. On 3 October 2000, villagers who had been told they could rebuild their village in the Lice district of Diyarbakir were forced to re-live the horrors of the war a second time as they watched the homes they had rebuilt over a 6-month period razed to the ground by Turkish soldiers who told them, "This hamlet does not have a place on the map and the people cannot live here." In a similar incident also in October 2000, three villagers in Hakkari province who had received permission to return to their village were killed by Turkish soldiers from the neighbouring province of Sirnak. A fourth, wounded victim, the sole survivor of the operation, was arrested and bodies of the three killed have not been returned to their families.

Although in September 1999, the PKK abandoned its armed struggle in the pursuit of a political settlement to the as yet unresolved "Kurdish question", much of the area is still under Emergency Rule and human rights abuses, including torture, remain commonplace. In their bi-annual report comparing figures on human rights abuses from the first half of 1999 to the first half of 2000, the Human Rights Association (IHD) makes clear that the PKK's cease-fire has had little effect on Turkey's extra-judicial killing and death by torture statistics which have decreased by a mere 0.6%.³² Despite assurances at senior levels that substantive steps are being taken to suppress the practice of torture, the Turkish Parliamentary Human Rights Commission, reporting in March 2000, concluded that there have been no improvements in torture practice since 1998 when it had conducted an earlier investigation.³³

Under such circumstances, a free and open debate on the merits of the Ilisu project is nigh on impossible. Indeed, a number of human rights abuses directly associated with the dam have already been documented: critics of the dam have been subjected to intimidation³⁴ or accused of belonging to the PKK, a crime punishable by up to 15 years imprisonment, whilst organisers of a rally to celebrate the history of Hasankeyf were forbidden by the local Governor from distributing a petition expressing concern over the dam. Such human rights abuses raise major concerns about the likelihood of a successful development outcome to the Ilisu project.

As of February 2001, none of the ECAs supporting the project, or considering support, had published any assessment of the implications of continuing repression in the region for Ilisu, nor indeed of the repercussions of construction of the dam on the rights of the marginalised in the region. In the UK, it has emerged that the Department of Trade and Industry (DTI) was not even informed by the Foreign Office of the human rights implications of the project, provoking the International Development Committee to comment:

"We are astonished that the Foreign Office did not raise any questions about the proposed Ilisu Dam and its effects on the human rights of those living in the region. The large-scale resettlement of a population, many of whom may well question the very legitimacy of the Government which moves them from their homes, must surely demand some detailed analysis from the Foreign Office. We would expect comments on the necessity of a genuinely transparent, free and fair consultation process; discussion of the relation between the removal of communities and drift to the towns on the one hand and on the other any conflict-related tactics and military strategy of the parties to the conflict; certainly an analysis of the human rights of the affected community and the extent to which the building of the Dam could possibly infringe or affect them. We criticise the Foreign Office for failing to raise these issues in detail with ECGD and DTI Ministers."³⁵

Although the Foreign Office denies that it failed to advise the DTI on the human rights implications of Ilisu, it has refused to release the relevant papers to the International Development Committee (see pp. 100-101).³⁶

Ilisu, GAP and Forcible Assimilation

Concern has also been expressed over the political motivations underlying Ilisu's development objectives and indeed those of the wider GAP project of which it is part. In particular, the history of State repression in the region has led many to view the GAP as "war by other means".

There is little doubt that the majority of GAP officials and field workers are deeply committed to the programme's overt aims of poverty alleviation and economic development (see Box 3: The GAP - Claimed Benefits). There is little doubt either that the majority of people in the region, which is one of the poorest in Turkey,⁴⁹ seek means to improve their living standards and to gain access to modern technologies, health care and education. But poverty alleviation and economic development are not the only - or even the most important - objectives motivating the GAP. From its inception in the mid-1970s,⁵⁰ the project has been underpinned by the Turkish State's long-pursued policy of assimilating the region's Kurdish majority into mainstream Turkish society and culture. Indeed, the Turkish government's official publicity for the project explicitly states that the GAP is intended to "dramatically change the social and cultural make-up of the region." The Director General of DSI has also stated:

"We do not have Kurdish people. We are all Turkish people. We do not look on Kurdish people as a minority like in the USA. All are citizens of Turkey no matter where they come from and who they are. Turkey's policy is that the citizens in GAP region will not be treated differently from other regions just because of their ethnic origin. We have a lot of Kurdish people in the government and some are in key positions."⁵¹

To many Kurds who have been displaced from their homes in recent years, such statements have a sinister ring to them. Indeed, it is widely held in many quarters that the GAP project has been promoted by the Turkish authorities as a means of altering the demography of the region through the displacement of Kurds into larger towns so as to exercise more effective control over the region. As the UK Defense Forum notes:

"From the outset, the Southeast Anatolia Project has had profound security implications. It is no coincidence that the project is situated in the Kurdish region of Turkey - where a bitter civil war rages between the Kurds and the Turkish military. The expected security benefits are twofold, by increasing the income of hitherto impoverished Kurds, the government in Ankara hopes the new wealth will induce the people to support the government. More pragmatically, the project will transform the geography of Turkish Kurdistan. Improved communications, combined with new industries and farms, will shepherd the Kurds out of their traditional mountain fastness into planned urban areas where the government can keep greater control over them. An underlying motive of the project is to deny the Kurdish guerrillas the environment in which they operate."⁵²

This view has been confirmed by Turkish soldiers interviewed by Britain's Channel 4 News. The soldiers admitted that their interest in the Ilisu project was entirely strategic. When the Ilisu waters rise, the PKK guerrillas' escape routes to the mountains would be cut off.⁵³

GAP's claimed development objectives are also thrown into doubt by the skewed distribution of its benefits and its failure to tackle key structural causes of poverty. Indeed, it is clear that the last people to benefit are Kurds, and in particular poorer Kurds. Despite massive investment in the region through the GAP, for example, the social infrastructure of the east and southeast remains the most neglected in Turkey: per capita income is barely 42 per cent of the national average; only 9 per cent of children complete secondary school; the average literacy rate is 27 per cent lower than the national average; and the Southeast receives less than 10 per cent of the national development budget. As David McDowall, author of A Modern History of the Kurds, points out, such neglect "is longstanding and institutionalised, partly as a result of Turkey's longstanding determination to crush all expression of Kurdish identity" and "contradicts official claims of concern."⁵⁴

McDowall also points to the failure of the GAP to grasp the vital need for land reform, a key requirement if rural poverty in the region, where landlessness is widespread, is to be addressed. Instead GAP planners have opted for the development of capital intensive agriculture - an indication to many critics of the shallowness of GAP's claimed poverty alleviation objectives. "The reason is simple", argues McDowall. "The landlord class largely control the vote of their villagers, useful in offsetting the dissident vote that finds expression in the region's towns." Neglect of land reform means, according to GAP's own master plan, that 8 per cent of farming families still control over 50 per cent of the land, 41 per cent hold 5 hectares or less (barely subsistence level), while 38 per cent have no land at all. GAP has little or nothing to offer this 79 per cent. "In such conditions the capital required for this massive project will come either from entrepreneurs living elsewhere in Turkey or from abroad. In short, the indigenous population is unlikely to benefit from the investment opportunity or have the education and skills to benefit from the projects."

In addition, "the most fundamental ingredient of development, full local participation has been missing". As a result, says McDowall, "Local people feel powerless in the face of something they either do not want or know nothing about."

These problems - though critical to assessing the claimed benefits of GAP in general - have yet to be investigated by the ECAs considering support for Ilisu, despite the dam now being promoted as "a key project within the GAP, one that has the potential to contribute to all of its aims."⁵⁵

Resettlement: Lack of Consultation

Critics argue that the continuing repression and lack of basic freedoms in the region make a fair and just resettlement of the 78,000 people who will potentially be affected by the project unattainable. The dam would create a reservoir approximately the size of the UK city of Manchester,⁵⁶ affecting some 183 settlements⁵⁷ and hamlets and the town of Hasankeyf. Consultation with affected communities has been minimal; critics are fearful of speaking out against the project; there is no accurate data on the numbers that will be affected; no resettlement plan has yet been drawn up for those who will be forced to move to make way for the dam's reservoir, in violation of international standards for infrastructure projects involving forcible evictions;⁵⁸ and no compensation package agreed. Moreover, the history of resettlement at other dam sites bodes ill for those who would be forcibly evicted by Ilisu.

When Ilisu was first presented to the ECAs supporting the project, it was claimed that some "12-16,000" people would be affected, with 50 villages being flooded by the dam's reservoir. In September 1999, however, a list obtained by a delegation to the region, organised by Kurdish Human Rights Project (KHRP), put the figure at 68 villages, with 57 more whose land would be partially flooded. All in all, the KHRP Mission estimated, a minimum of 25,000 people would be affected - twice the numbers admitted by Balfour Beatty. KHRP also discovered that at least 19 villages in the reservoir area have already been evicted at gunpoint, in many cases their houses being razed to the ground. The Fact Finding Mission also drew attention to the large number of people who had already been forced to leave the reservoir area as a result of military operations against the PKK but who would like to return if able to do so. These villagers, the Mission argued, should be counted as project affected people, with full rights to compensation. This has now been acknowledged by the project developers and the ECAs.

Subsequently, in December 1999, Britain's ECGD issued a report on "Stakeholders' Attitudes to Involuntary Resettlement in the Context of the Ilisu Dam Project". The report estimated that at least 36,000 people would be affected by the project and noted that the Turkish authorities had still not produced a detailed resettlement plan "even though the final design of the Ilisu Dam project was approved as early as 1982."⁵⁹ The study also cast serious doubts on the value of assurances from the Turkish authorities as to resettlement, noting that past resettlement projects in Turkey have (with one exception) failed to meet international standards.⁶⁰

The report warned that land tenure and land title problems had not been addressed in the resettlement planning for Ilisu and that no host areas had been identified for resettlement. It also expressed concern that providing appropriate compensation would be complicated by a number of factors: the lack of registration deeds and proof of ownership, forced land confiscation and absentee rural families. Although the report acknowledged that the Turkish Government is in the process of modernising its national policy and legal framework governing involuntary resettlement, it warned that "evidence from previous resettlement projects indicates that implementation is problematic".

The report also highlighted the lack of consultation with local people, noting that "local stakeholders have been waiting for more than 20 years to be informed directly about resettlement, despite the fact that the project design was approved by the government in 1982"⁶¹ and that "open consultative processes are not part of the institutional culture or political system."⁶² Lack of consultation and mistrust of the DSI were already widespread, the report stated, and "local stakeholders believe that they have no forum to express their concerns over adequate compensation for expropriated assets, decisions over new settlement locations and loss of social and cultural capital."⁶³

The ECGD's report was published on the same day as the UK Secretary of State for Trade and Industry, Stephen Byers, announced that the UK was "minded" to support the project, subject to four conditions, one of which stipulated the drawing up of a resettlement plan which reflects internationally accepted practice. In doing so, the UK government appears to have ignored one of the key conclusions of the ECGD's report, which explicitly states that a resettlement plan drawn up so late in the planning cycle would be in violation of internationally accepted standards. Such standards, the report notes, "clearly specify that planning for the involvement of different stakeholders should start as early as possible in the project cycle": by contrast, involvement of stakeholders in the Ilisu project "will be reactive rather than proactive, with the DSI intending to convince the public of the merits and benefits of the project, rather than trying to establish constructive engagement with different public stakeholders in the reservoir area."⁶⁴

Since the publication of the ECGD's report, the Turkish authorities have drawn up a draft Resettlement Action Plan (RAP), employing the consultancy firm SEMOR to undertake surveys of the numbers likely to be affected and their socio-economic conditions. Investigations undertaken by NGOs monitoring the Ilisu project reveal that the company has limited experience of working on resettlement, its main expertise apparently lying in the organisation of seminars and tourism (seeBox 5: "Your happiness will bring our success").

This mosque, used today by the people of Hasankeyf, contains the tomb of Imam Abdullah, grandson of Cafer-i Tayyer, the uncle of the prophet Mohammed. It is visited by some 30,000 pilgrims every year. In addition to the many ancient ruins which would be destroyed by the Ilisu Dam, this mosque and gravesite also stand to be submerged by the waters of the dam's reservoir.

Independently, the Swiss Export Credit Agency hired Dr. Ayse Kudat, a senior sociologist at the World Bank, to help ensure that the resettlement plan and compensation proposals met international standards. A leaked copy of Dr. Kudat's review of the Turkish Government's Draft Resettlement Action Plan (RAP) was obtained by the Ilisu Dam Campaign and other NGOs internationally in August 2000.

The report confirmed most of the misgivings voiced by the earlier more cursory ECGD report and revealed that:

• The numbers who may be affected by Ilisu are 2-3 times higher than previously estimated - possibly as many as 78,000;
• Sweeping institutional reforms within Turkey are needed before "best practice" - as defined by World Bank or OECD guidelines - can be achieved;
• The Turkish government has failed to consider alternatives to the Ilisu project, which violates both World Bank and OECD guidelines;
• The project was approved before a resettlement plan was drawn up, which flouts both World Bank and OECD guidelines;
• The Turkish authorities have failed to draw up a full socio-economic census, which violates World Bank guidelines;
• There are major gaps in information needed to draw up a resettlement plan to international standards;
• No resettlement budget has been prepared - in violation of World Bank and OECD standards - and, it is suggested, a paper commitment from Turkey to make the money available cannot be trusted;
• Major economic and political obstacles must be overcome before it can be ensured that affected people will not be worse off than they were before the project, as the World Bank demands;
• The special provision to protect the livelihoods of women has been ignored, in violation of World Bank guidelines;
• Pastoralists will not be compensated for their land loss, in contravention of OECD guidelines.

The report promises compensation for those who have already been forcibly evicted from the reservoir area of the dam due to the 16-year conflict in the region. Nonetheless it provides telling evidence that the needs of this category of displaced villagers are being ignored as a result of "security concerns". For example, Kudat states that:

"DSI field staff calculate that 24 villages (together with their hamlets) lack land/title registration. These villages are still under security, and to most, there is no permission to enter. Their infrastructure and homes are ruined and their populations are spread around the country. Thus, to bring together the land/title registration officials and the villagers is not easy. Despite high levels of landlessness, the displaced communities are still concerned that lack of land/title registration would make it difficult for them to get compensated for whatever they have remaining. The fact that they have lost their trees and gardens is another major concern."⁶⁵

The problems caused by the continuing State of Emergency in the region are also highlighted elsewhere in the report. For example, Kudat points out thatthe ability of the DSI to implement and enforce the resettlement action plan is hampered by the security situation. All five provinces affected by the construction of the Ilisu Dam are still under OHAL (that is governed under "extraordinary circumstances" regime) and as Kudat comments "the Ministry of Interior and the military have very different sets of priorities"⁶⁶ from the DSI. The complexity and magnitude of how best to address the needs of previously displaced population "goes beyond the ability of the project and the solutions require the decisions of security agencies".⁶⁷

The report also acknowledges that the Turkish Government has failed to give adequate consideration to alternatives to the Ilisu project. This violates both World Bank and OECD guidelines for projects involving involuntary resettlement.⁶⁸ As Kudat notes:

"While it is today too late for the Ilisu resettlement plan to have an impact on dam design, the public still wants to know whether or not alternatives were considered and whether adverse impacts on settlements could not be reduced, particularly with respect to Hasankeyf's cultural heritage. Although some 10 alternatives were considered at the time the location of Ilisu was selected, the implications of other technical alternatives for resettlement are unknown."⁶⁹

Although a final resettlement plan was promised by the Turkish authorities for August 2000, the plan has yet to be completed. UK Minister for Trade Richard Caborn claimed in December 2000 that "the timing of the Resettlement Action Plan (RAP) is less certain but a first stage report could be available around the turn of the year."⁷⁰ At the time of printing, this first stage report had still not been released.

Flawed Environmental Impact Assessment

Just as there was no resettlement in place when the ECAs first granted provisional approval for Ilisu, so the project lacked an acceptable Environmental Impact Assessment.

According to Balfour Beatty, the Ilisu Consortium was "well aware from the outset of the considerable environmental impact that all hydro-electric power schemes tend to have".⁷¹ As soon as it discovered that Turkey had yet to conduct a formal EIA for Ilisu, the consortium therefore commissioned Hydro Concepts to produce one. Subsequently, Balfour Beatty stated that the EIA had confirmed "that there are no problems as regards the potential effects of the project on local flora and fauna, climate, landscape, ground water, earthquake risk, flooding risk, sedimentation and erosion."⁷² It is impossible to test such claims, since the EIA has yet to be released to the public - despite the threat of legal action by Friends of the Earth under European Union freedom of information legislation.

In December 1999, the UK government released a desk review of the EIA report (though not its crucial annexes) undertaken by Environmental Resources Management (ERM). In addition to highlighting a number of serious impacts that would follow dam construction, such as lowered water quality, ERM deemed that the report did not meet international standards of best practice⁷³ and was deficient in many important respects.

Although ERM described the EIA as "well prepared", it highlighted a number of key areas which the report had entirely overlooked. The report gave no consideration, for example, to the cumulative effects of the dam in conjunction with other projects. No information was made available on the effects of altered river flow on wetlands downstream. In addition: "Little or (in most cases) no details are provided regarding the time-tabling of proposed data collection and mitigation measures, the institutional responsibilities and capacities for their implementation, the estimated resources needed (financial and manpower related) and the proposed methods or sources of finance." And while the dam's supporters claim a clean source of climate-friendly energy, ERM pointed to possible adverse climatic impacts from methane (a potent greenhouse gas) that would be released from rotting organic matter in the dam's reservoir.

The ERM report also warned of serious doubts over the Turkish authorities' institutional capacity to carry out the necessary environmental mitigation measures and stipulated that an "essential pre-condition for ECGD support" should be a requirement to undertake "an outline institutional review" before a decision is taken on whether or not to support the project.⁷⁴ Despite this recommendation, the UK government not only elected to give conditional approval for the project in the absence of such a review, it also failed to make such a review a condition of export credit support.

Other "essential preconditions" urged by ERM were also rejected by the government. These included ERM's recommendations that:

• consideration be given "to the formation of an international basin committee (or authority) where any future problems can be aired and addressed";⁷⁵
• "full and comprehensive EIAs be carried out to [international best practice] standards prior to any other major infrastructure developments in the region, including the Cizre Dam, other GAP schemes and any major transmission projects associated with the Ilisu Dam";⁷⁶ and
• each of the ECAs involved in the project should have "a say (and a right of veto) in the composition and terms of reference" for any independent monitoring panel.

Although the project had already provoked the Syrian government into protesting at the highest possible level over the possibility that the dam - in conjunction with other GAP projects - will be used as a political weapon by the Turkish authorities (see Water Wars - The Risk of Regional Conflict section below), ERM's terms of reference specifically excluded any analysis of "any of the social, economic or political impacts associated with the development."⁷⁷

A new EIA has now been commissioned by the Ilisu Consortium ("as the original report is now two years old, an update is underway") and is now in the hands of the DSI. Despite promises by the ECGD and other ECAs to release the report, the UK government has acknowledged that it is not in a position to do so, since the EIA is the property of the consortium.

The Destruction of Hasankeyf

The Ilisu reservoir will flood the city of Hasankeyf, situated at a bend in the Tigris around 60 miles south east of Diyarbakir. Historians claim that the first settlers came to Hasankeyf in ancient Mesopotamia as many as 10,000 years ago. Sited on the river in a place of enormous strategic significance, in the intervening years layer upon layer of civilisations have been interwoven or been built on top of each other, yet the caves for which the city is justly famous are still inhabited, in a way of life which is culturally unique. The city is a formidable store of historical information and artefacts, including cave churches, ornate mosques and Islamic tombs, creating an astounding complexity of architectural and religious heritage spanning several civilisations, from the Byzantines and Sassanides through the Omayyads, Abbasides, Hamdanides, Mervanides and Artuks to the Eyyubians and most recently the Ottomans.⁷⁸

Hasankeyf was awarded complete archaeological protection by the Turkish Department of Culture on April 14, 1978 (decision A-1105) under which the town, in its entirety, should be protected against negative impacts. This indicates that it is not sufficient to preserve individual relics in museums, and that the competent authorities do not judge the destruction of Hasankeyf to be acceptable.⁷⁹

Balfour Beatty describes Hasankeyf as "the decaying remains of a medieval city".⁸⁰ The company argues that the city's citadel is on a cliff and would therefore remain safe on a dramatic promontory above the lake. It acknowledges that "lower parts of the town would be flooded", however, "relocation of a few key buildings [is] under consideration" and "none of these buildings [are] considered by UNESCO to be of world importance."⁸¹ To date, Turkey has never applied to UNESCO to include Hasankeyf in the World Heritage List - so UNESCO has not been required to express a view on the importance of Hasankeyf, and therefore this claim cannot be made by the company with any veracity. UNESCO can only designate a site as a result of a request made by the State party to the Convention Concerning the Protection of the World Cultural and Natural Heritage.⁸²

The company has, thus far, clearly and completely failed to appreciate that the greater part of the historical significance of Hasankeyf lies beneath the surface which is currently visible. The citadel is a small fraction of the significance of the site. The flooding of the 'lower parts of the town' would without doubt result in the complete loss to humanity of the cave dwellings themselves, and the rare and unique way of life which still exists within the caves. Whilst moving certain buildings may indeed be a physical possibility, moving the cave dwellings is clearly not, as they have been hewn from the ground over thousands of years.

In the company's view, the Ilisu project might in fact prove to be a catalyst for generating funds for the preservation of the main citadel. The Turkish Ministry of Culture, says the company, is the best body to decide on the merits of rescuing individual buildings and the ECAs involved should request regular reports on the activities of the Ministry of Culture. However, it appears that the Turkish Ministry of Culture has taken no interest whatsoever in Hasankeyf since its designation as a site of cultural heritage to be preserved, twenty-one years ago (see pp. 72-78).

Little or no account has been taken by the project developers of the deep historical and spiritual significance of Hasankeyf to the Kurdish population, both locally and globally. For example, the Kurdish people's equivalent of Romeo and Juliet, the Mem-o-Zin, is set in Hasankeyf - the equivalent of Verona. Many within the Kurdish community see the flooding of Hasankeyf as part of a wider political strategy to eradicate Kurdish culture.

Concern has also been expressed by archaeologists over the destruction of Hasankeyf. In January 2001, Professor Martin Hall, President of the World Archaeological Congress (WAC), wrote to UK Prime Minister Tony Blair expressing "grave concern" over Britain's proposed support for Ilisu and urging its withdrawal from the project.⁸³ WAC argued that the government's condition with respect to the potential cultural impacts of the dam - to "produce a detailed plan to preserve as much of the archaeological heritage of Hasankeyf as possible" - is inadequate and unlikely to be met. Inadequate because "the cultural heritage impact of the dam reservoir extends far beyond the purely physical confines of Hasankeyf itself";⁸⁴ and unlikely to be met because "circumstances prevailing in the region" make it "very difficult to draw up and implement a satisfactory preservation plan." Noting with "particular alarm" that other sites affected by DSI-managed dams - notably the remains of the Roman city of Zeugma, which has now been flooded by the Birecik Dam (see p.72 and also Box 8: The Birecik Dam: The Companies and the Banks)- had only been subject to last minute 'salvage archaeology' operations, WAC states: "Such working conditions can never lend themselves to the fulfillment of the condition set with respect to the archaeological heritage at Hasankeyf." WAC further noted that the cultural impacts of the dam are very likely to be "severe, irreversible and disastrous for long-term social stability within affected communities and in the region generally."

Professor Olus Arik, head of the Turkish State-organised archaeological dig at Hasankeyf, has himself called into question the adequacy of the rescue archaeology mission at Hasankeyf. "We need a minimum of fifty years here and we have just nine or ten - unless of course we can stop the dam," he told History Today.

The Turkish Ministry of Culture is spending about £76,000 on archaeological explorations throughout the area to be flooded by the Ilisu dam and related works downstream. The Hasankeyf archaeology team will receive about £15,000 of this. Professor Arik compares this to a glass of water in the desert.

The mission's official aim - to preserve as much of Hasankeyf as possible and make it into a national museum, with artefacts and selected buildings rescued from the lower and middle towns - is also treated with scepticism by Professor Arik: "We need a proper restitutional project. You can't just carry stones away".⁸⁵

Water Wars - The Risk of Regional Conflict

Fears have been expressed in a number of quarters that Ilisu - in conjunction with other GAP dams - could severely disrupt the downstream flow of the Tigris to Syria and Iraq, affecting communities reliant on seasonal agriculture and heightening political tensions between Turkey and its neighbours in what is already a volatile region. The fears have been heightened by the armed conflict that has dogged the region since 1984, with Turkey increasingly at odds with Syria for harbouring the PKK.

Turkey is already known for its aggressive water policies. "Neither Syria nor Iraq can lay claim to Turkey's rivers any more than Ankara could claim their oil", President Demirel said when opening the Ataturk Dam in 1992.⁸⁶ In February 2001, similar views were expressed by Mas'oud Yalmaz, Turkey's Deputy Prime Minister, who told the Arab daily newspaper Al-sharq Al-Awsat that Turkey views the Euphrates river as a Turkish river and not an international one. He dismissed Syrian opposition to the series of dams that Turkey is building on the river stating, "The Euphrates reservoir is very important for the future of economic development in Turkey." Despite Yalmaz's assurance that his country is not seeking conflict with Syria, he reiterated the view that Turkey had the right to determine the amount of water allowed to Syria unilaterally, stating, "The division of water will not be equal as the Euphrates, like any other Turkish river, should be basically used for serving the interests of the Turkish people.⁸⁷

In the past Turkey has already threatened to block water flows to its downstream neighbours: indeed, in the late 1980s, Turkey blocked the flow of the Euphrates for 9 days.⁸⁸ As a result of dams already built on the Euphrates, combined with drought in the region, the flow of water to Iraq is estimated to have been reduced by 20 per cent.⁸⁹ Only last year Turkey announced unilaterally that it was going to reduce the flow of the Euphrates to Syria to one third of the previously agreed amount due to severe drought in the region.

Already analysts are stating that wars could be sparked in the region over - and with - water. The spare storage capacity of Ilisu's planned reservoir alone would be sufficient to block the flow of the River Tigris for an average of two to three months per year. Syria, which has for years demanded a mathematical division of the water, has protested to Britain over its involvement in the dam.⁹⁰ Noting the strategic importance of Turkey's abundant water resources, a report by the UK Defence Forum (a think-tank which advises the government on regional risks) has warned that the GAP project as a whole is:

"one of the region's most dangerous water time bombs. The dispute has not erupted yet because the project has not yet reached its full potential. By the time of its planned completion in 2010, the vital interests involved give it the potential to become one of the region's most dangerous flashpoints."⁹¹

The project developers argue that these fears have been overplayed. They contend that:

• Ilisu is designed for power, not irrigation and that hydro-electric uses do not impair downstream flows;
• unlike the Euphrates, significant tributaries join the Tigris downstream of the Ilisu site; and
• the proposed operational regime will ensure a satisfactory level of discharge in all seasons.

Balfour Beatty claims that minimum rates of discharge have now been agreed for the critical impounding period. They also argue that a major objective of the ECAs involved is to agree with the Turkish Government on "a management regime for the flow of water that is consistent with [the UN Convention on Non-Navigational Use of Transboundary Watercourses] but does not require formal assent of any other state".⁹²

The details of the agreement on minimum discharge rates during impoundment are yet to be released. It is therefore impossible to evaluate the extent to which they meet Syria and Iraq's concerns over the project. Moreover, as Tony Juniper, Policy and Campaigns Director for Friends of the Earth (England, Wales and Northern Ireland), notes:

"The assurance that flow rates will be maintained can only be proved in practice. Should Turkey decide in the future to use water for political purposes, there would be little that the participating export credit agencies could do about it. And should disputes over water escalate into conflict, then most of the countries supporting the dam would be under pressure as NATO members to side with Turkey."⁹³

A legal opinion commissioned by Friends of the Earth has concluded that if Turkey fails to consult with its downstream neighbours prior to progressing the Ilisu proposal, it will be in breach of international law.⁹⁴ The legal implications for ECGD support for the project are significant, according to Juniper:

"Because even the loosest interpretation of export credit rules cannot justify assistance to another country to violate international treaties, then action might be taken in the British courts to challenge any decision by the UK to grant a credit."⁹⁵

Turkey argues that, from the very beginning, it has informed Syria and Iraq of its plans regarding every GAP project.⁹⁶ However, in July 2000, the Syrian Minister of State for Foreign Affairs confirmed that:

"the Government of the Republic of Turkey has not officially informed, consulted, or negotiated with us about the implementation of the Ilisu Dam Project on the Tigris as stipulated by the rules of international law and the relevant agreement on the Tigris river and other agreements concluded between the two countries."⁹⁷

Iraq has similarly stated that "construction of the dam will constitute a breach of international law and it would seriously harm Iraq's rights to the river waters."⁹⁸ In August 2000, Dr. Fahmy AL-Qaysi, Director of the legal department of the Ministry of Foreign Affairs, stated: "The State of Iraq did not receive any official notification from the State of Turkey concerning its plans to construct the Ilisu Dam and learned about the Turkish side intentions through media reports."⁹⁹

In the UK, ECGD support for the project is therefore vulnerable to legal challenge. Significantly, the UK government has announced that it will require evidence of consultation between Turkey and its downstream neighbours before any export credits for Ilisu are approved.¹⁰⁰

Section 2: The mission and its findings

The mission's remit

In response to the widespread international concern over the cultural, social and environmental impacts of the planned Ilisu Dam, the Export Credit Agencies (ECAs) backing the project imposed four conditions that would have to be met by the Turkish government in order for the project to obtain export credit support. The four conditions, announced in December 1999, were as follows:

1. Draw up a resettlement programme which reflects internationally accepted practice¹⁰¹ and includes independent monitoring;
2. Make provision for upstream water treatment plants capable of ensuring that water quality is maintained;
3. Give an assurance that adequate downstream flows will be maintained at all times;
4. Produce a detailed plan to preserve as much of the archaeological heritage of Hasankeyf as possible.

Whilst, on paper, these conditions would go some way to meeting the concerns of critics, there are considerable doubts whether they can or will be met in practice. As already noted (see above p.28), the ECA's own August 2000 review of the Turkish government's draft resettlement plan highlighted a number of concerns, notably regarding the lack of institutional capacity within Turkey to undertake a resettlement programme to international standards. Another set of concerns relates to the ability - and will - of the ECAs themselves to monitor compliance, the rigour with which they will do so, and the political leverage available to them should the Turkish authorities renege on the conditions.

More intractable are the implications for compliance of Turkey's well-documented repression of the Kurdish majority in the region, its abject failure to abide by previous commitments to curb human rights abuses against the local population and its racist policies of enforced assimilation of ethnic Kurds into mainstream Turkish society. Indeed, the continuing conflict in the region is central to the controversy over Ilisu. Human rights abuses - relating to forced evictions and intimidation - have already been documented in connection with the dam and whilst intimidation, torture, denial of freedom of expression and repression remain the norm in the area, the prospects of a just outcome to the project remain distant, if not unattainable.

The Fact Finding Mission and its Remit

In October 2000, an international Fact Finding Mission of Non-Governmental Organisations from the United Kingdom, the USA, Germany and Italy was established under the aegis of the Kurdish Human Rights Project and the Ilisu Dam Campaign. The Mission was charged with:

1. Assessing the progress being made by the Turkish government in meeting the four conditions laid down by the ECAs; identifying the institutional and other problems that remain outstanding; and evaluating the prospects of their being resolved;
2. Assessing whether or not the conditions, even if met, are sufficient to bring the project into line with evolving international best practice. The Mission was explicitly charged with reviewing Ilisu in light of new guidelines developed by the World Commission on Dams;
3. Identifying corporate governance failures in the practices and procedures of the supporting ECAs that have contributed to the controversy over Ilisu; assessing the extent to which these failures will be addressed by new procedures under consideration by the OECD's Working Group on Export Credits; and proposing corrective action;
4. Evaluating whether or not continued support for Ilisu could be justified by the UK government in the light of new procedures being developed by the UK Export Credit Guarantees Department (ECGD).

The Fact-Finding Mission visited the Ilisu region from 9th-16th October 2000. The Mission met with affected people, prominent municipal officials, lawyers and local professional associations relevant to the project. By the second day of its day of its visit, after its presence in the region had been noted by the authorities, the Mission was followed by State security police, who also sat in on one interview uninvited. State security police also attended a press conference held by the Mission on its return to Istanbul, threatening that the press conference was illegal.

Members of the Mission also attended the launch of the World Commission on Dams (WCD) in November 2000, conducted informal interviews with a number of Commissioners and with leading members of the WCD Forum, the 68-member consultative group set up by the WCD and consisting of key representatives from government, the private sector, multilateral development agencies and affected communities.

The Mission's Key Findings

The Mission concluded that:

• The four conditions imposed by the ECAs have yet to be met - and the prospect that they will be met in the future is remote. Whilst the social, political and economic rights of the Kurdish majority in the region remain unrecognised - and indeed repressed - there can be no confidence that the Turkish authorities will abide by the conditions. Serious concerns also exist over the capacity - and will - of the ECAs themselves to monitor and ensure compliance. Export credit support for the project should not therefore be approved.
• Even if met, the four conditions leave many key concerns (particularly those relating to transparency and human rights) unaddressed and would fail to bring the project up to international standards. The project violates each and every one of the WCD's major policy recommendations and would still be in breach of WCD standards even if the four conditions were met in full.
• The history of ECA involvement in Ilisu project reveals major deficiencies in current ECA practice and procedure. In particular, the lack of common mandatory standards have encouraged a "band-aid" approach to project financing that works to the detriment of affected communities and industry alike. The OECD Working Party's proposals for ECA reform - particularly its emphasis on "benchmarking" - will exacerbate rather than remedy this deficiency.
• Continued support for the Ilisu Project is in breach of both the spirit and the letter of the new Business Principles adopted by the ECGD. Ilisu is thus a litmus test of the ECGD's comittment to the new principles: proceeding with the project would signal a fatal lack of purpose in reforming the ECGD and in embracing the principles of sustainable development, as espoused by the UK government.

The Mission's detailed findings from its visit to the area are set out below. Its findings with respect to Ilisu and the World Commission on Dams and export credit agency reform follow in Section 3.

An estimated 78,000 people, most of them ethnic Kurds like these young boys, stand to be affected by construction of the Ilisu Dam.

Evaluating progress in meeting the four conditions

Condition one: "Draw up a resettlement programme which reflects internationally accepted practice and includes independent monitoring"

Under pressure from the Export Credit Agencies (ECAs) backing Ilisu, the Turkish government has promised to undertake a resettlement plan to international standards. In early 2000, the DSI commissioned SEMOR, a Turkish consultancy firm, to undertake surveys of the numbers likely to be affected and their socio-economic conditions in order to draw up a Resettlement Action Plan (RAP). Public information available on SEMOR suggests that its past involvement in resettlement is limited to just one other project - the Izmir Water Project. (see Box 5 above: "Your happiness will bring our success"). Independently, the Export Credit Agencies (ECAs) hired Ayse Kudat, a sociologist formerly at the World Bank, to review the draft RAP. Kudat's review - sent to the agencies in early August - highlighted major concerns over the draft plan, including seven violations of World Bank and OECD guidelines (see footnote 103 below).

The Fact-Finding Mission confirmed these concerns. In particular, the Mission found that:

• Well-documented failures of past and current resettlement projects in Turkey, acknowledged by the Turkish government, have still to be remedied in any substantive way, casting doubts on the value of reassurances received from both the Turkish authorities and the companies that Ilisu oustees will be properly resettled;
• Doubts still exist as to the true number of people who would be potentially affected;
• Consultation with the affected people in the Ilisu area has been piecemeal, inadequate, biased in its format and constrained by an atmosphere of intimidation. Some key consultations which the Turkish government apparently claims to have taken place have in reality not occurred;
• Host communities have not been asked to draw up resettlement plans and their budgetary requirements have not been assessed, in contravention of World Bank standards;
• The adequacy of the socio-economic surveys required to meet international standards has been questioned; and
• Lack of capacity and institutional fragmentation render a coherent resettlement programme unachievable. Major institutional reforms will be necessary before there can be any confidence that resettlement will be carried out to international standards. There is also a need to overhaul existing compensation procedures.

The Mission found numerous continuing violations of World Bank and OECD standards with respect to resettlement planning and concluded that the lack of basic freedom of expression, movement and political rights in the region makes the prospect of a just and fair resettlement to international standards unattainable. Moreover, its own experience of being constantly followed by the security forces, in conjunction with evidence that critics of the dam have been intimidated, led the Mission to conclude that whatever measures for independent monitoring are agreed on paper, they are unlikely to be observed in practice.

These concerns are explored in greater detail below.

Confusion over the number of affected people

Originally, the project sponsors and the companies involved in the Ilisu project put the number of people affected at 12,000-16,000.¹⁰² Following the findings of a previous Fact-Finding Mission in 1999, this number was increased to 25,000. Subsequently, a report by the British government put the numbers still higher - at 35,000. The Kudat report states that even this figure is a gross underestimate. According to Kudat, 78,000 people would be potentially affected by the project, and she clearly stresses the importance of this higher figure:

"...the RAP should be prepared for the maximum estimate of potentially affected populations. This is justified both on grounds of the international principles used and on the assumption that the affected communities will grow in size."¹⁰³

The Kudat figure includes those already evicted (or forced to migrate) from the Ilisu reservoir area as result of internal conflict in the region, but who may wish to return once peace is fully restored. Kudat does not give separate figures for this category of affected people, but does point out that 85 of the 183 villages to be affected have already been evacuated.¹⁰⁴

The Mission confirmed Kudat's figures for cleared villages, independently obtaining a list of 85 villages which, in many cases, had been burned as a result of security operations carried out by Turkish government forces in the 1980s and 1990s and from which all the residents had been forcibly evicted. The Mission also met with GÖÇ-DER (Immigrants Association for Social Co-operation and Culture), a Turkey-wide NGO providing support for those displaced from the region. From GÖÇ-DER, the Mission learned that a minimum of 45,000 people have already been removed from the reservoir area and possibly upwards of 50,000 (see Box 6: GÖÇ-DER - The Immigrants Association for Social Co-operation and Culture). This is 3-5 times higher than the number acknowledged by the DSI, whose Director-General stated in February 2000: "Perhaps up to 10-15,000 people have moved from [the] area because of economic and security reasons."¹⁰⁵

The ECAs should verify whether Kudat's figures were based on similar estimates and, if not, whether this raises the numbers of potentially and actually affected people. If the numbers are higher than Kudat's estimates, the ECAs should insist on a reassessment of the resettlement budget, which has yet to be finalised, in addition to a related re-evaluation of the financial viability of the project.

Doubts on Promises to Trace Missing Villagers

Kudat stipulates that provisions should be made to compensate those who have already displaced from the reservoir area as a result of the war, since, once the dam has been built, they will be unable to return home. This principle has also been accepted by the ECAs and the companies involved in the project and, to its credit, by the Turkish government.

In May 2000, Balfour Beatty told its shareholders that, "a major programme is to be initiated by DSI to trace the former inhabitants of [evacuated] villages and determine their legal rights to compensation."¹⁰⁶ The Mission sought to evaluate the DSI's progress in this regard and was considerably concerned to learn that, as of October 2000, no effort had been made by the Turkish authorities to contact GÖÇ-DER, despite its central role and expertise in assisting evicted communities. GÖÇ-DER is one of the few groups in Turkey working with war refugees from the Ilisu area and it is reasonable to assume that it would be a first port of call in any attempt to trace former residents, particularly given the absence of any official government or intergovernmental body monitoring or providing help for refugees from the war. The failure to contact GÖÇ-DER would indicate either a lack of institutional capacity to carry out the DSI's promised programme of research into the whereabouts of former inhabitants, or a lack of political will to do so, or both.

The Mission also learned from interviews with war refugees that no efforts have been made by the DSI to consult directly with those forcibly evicted from the reservoir area with a view to assessing their potential compensation claim. The liabilities that need to be met in any resettlement budget are thus largely unknown.

Unrealistic Assumptions on Compensation Claims

According to Kudat, the majority of those evicted from the reservoir area as a result of the war are unlikely to claim compensation:

"It may be safe to assume that less than half of the partially impacted among them would return to their communities between now and 6-7 years from now when the dam might be complete. The remaining may no longer be interested in pursuing compensation if all they have left is a largely destroyed traditional home. A similar assumption may be entertained for the fully affected vacant communities as well."¹⁰⁷

The Mission challenges this view, which it holds to be superficial and lacking in evidence. War refugees from the reservoir area were emphatic in interviews with the Mission that they would seek compensation if their land were flooded by the dam. The Mission has no doubts that this view is widely-held within the refugee community.

It is important to stress, however, that those interviewed were primarily seeking justice and an acknowledgement of their rights, and not just monetary recompense. It is equally important to note that many refugees may feel constrained from seeking compensation due to financial constraints, lack of public funding, fear of being unable to prove land titles and a general climate of intimidation against the population's use of the legal system.

This atmosphere also makes it difficult for those previously displaced by the war to submit an official request to go back to their land. Kudat's assumption that "the governor's office list of people who have signed up to return to those displaced communities affected by Ilisu should provide one indication [of the likelihood of return]"¹⁰⁸ therefore seems highly unrealistic.

False Claims over Improved Resettlement Practices

Both Kudat and the companies involved in Ilisu have acknowledged problems with resettlement in the past. As Kudat comments: "In the Turkish context, past failures have been particularly severe with respect to inadequate and inappropriate delivery of resettlement housing, lack of concern with the well-being of self-settlers, transparent participation of affected populations in resettlement decisions, and monitoring of social impacts during and after dam construction."¹⁰⁹

Balfour Beatty, however, has argued that Turkey's resettlement procedures now meet international standards. According to a briefing prepared by Balfour Beatty in 1999:

"Turkish laws and procedures regarding resettlements have been amended over recent years and adapted to internationally comparable standards. The experience with already completed hydroelectric projects has led to noticeable improvements of the relevant legal basis. In particular, the principles have been established that all persons affected by a resettlement - regardless of their status - will, at their choice, either be resettled with a new house or land, or given monetary compensation sufficient to set up business in a town or city."¹¹⁰

The Turkish authorities - which vigorously defend their past record on resettlement¹¹¹ - similarly point to the resettlement of the 30,000 people relocated as a result of the Birecik Dam as evidence of their commitment to ensuring "participatory" resettlement and their success in delivering improved local living standards. The resettlement programme, administered with funding from the United Nations' Development Programme (UNDP), started in 1997¹¹² and the reservoir began filling in December 1999 (see Box 8 below: The Birecik Dam: The Companies and the Bank).

In February 2000 - several months after the villagers had already been moved - Mr. Kaya Yasinok, Vice-President of the GAP Administration, told a seminar hosted by the Turkish Embassy in London:

"Our approach to the resettlement of the people affected by the Birecik Dam Project assumes that the adverse consequences of resettlement can be minimised through careful planning and intervention ... The [resettlement] project involves the participation of people living in 45 affected settlements, and addresses such issues as the selection of sites for resettlement, economic investments in new areas and employment ... As part of GAP's commitment to the principles of sustainability and participation, local people and all the relevant parties are informed about each stage of the project ... At every stage of the project, local people and other parties are involved and their participation is ensured ... [The plan] explicitly includes a process which assists in the adaptation to a new mode of life ... [The] ultimate aim is to enable individuals to attain a higher standard of living than they experienced before the project."¹¹⁶

Such claims are important, since Turkey's past and current track record on resettlement provides the best indication available of the likely outcome at Ilisu. The Mission was therefore gravely concerned to learn of serious resettlement failures at Birecik:

• Far from the resettlement programme being participatory, the inhabitants of approximately 18 villages located in the area close to the construction sites were forcibly evacuated by soldiers in 1996 and 1997 and received no compensation at all.
• Over a thousand villagers from Kavalica, a village close to Halfeti, were forced to abandon their homes and belongings when they awoke to find their homes partially submerged by the rising reservoir. Project officers had failed to alert them of the rising waters. The villagers had not left their houses because they were still waiting to receive compensation promised by the government.
• Numerous families received no compensation whatsoever, because they did not have land rights, and still have not been given houses despite promises that they would be re-housed. Several cases contesting compensation have been taken to European Court of Human Rights (see Box 10: European Court of Human Rights Cases Relating to GAP);
• Villagers who have been moved to new resettlement sites complained that their new houses are over-crowded and had not even been finished when they moved in. Leaking ceilings appears to be a common complaint. One oustee told the Mission, "In the new villages, it is like death";
• The Mission was also deeply shocked to learn of the apparent indifference shown by the project authorities to the loss of ancestral graveyards to the reservoir. No assistance was given to villagers to move their graveyards. Where tombs were moved, it was only because villagers used their own money and labour to move them. The psychological impact on many villagers of seeing their ancestral graves flooded is reported to have been severe. As a member of the Chamber of Architects in Diyarbakir told the Mission: "People were psychologically devastated because they watched their cemeteries going underwater ...When people realised that they would leave their ancestors' graves under water, they didn't want to leave anymore"¹¹⁷
• Of particular concern is the complete absence of any viable employment for those resettled. The displaced villagers, having been moved into the State's shoddily constructed housing units (on which they will also have pay rent for the next 3 years), find themselves in desolate areas where the government's promised commercial centres and factory jobs have not materialised. One evicted villager mourned the end of nearly three centuries of fruit farming which his family had practised on the same land uninterrupted since the 1700s. He and his family had lost their home, their livelihood, and their way of life, which included a sense of cultural continuity. They had been re-housed on a hill overlooking the Birecik reservoir, and he had secured temporary work as a security guard at what little remained of the archaeological site at Zeugma (known as Apamea-Seleucia in ancient times, one of the most important trade and cultural centres of the Hellenistic period and referred to by modern-day archaeologists as "a second Pompeii"). Knowing his job was short-lived, he saw no realistic possibility of further work in the area and had a bleak picture of his family's fate.
• One result of this lack of economic opportunity is that those who received compensation are rapidly running through their savings. Many see no prospect other than emigration to local conurbations, where services are already overstretched and unemployment levels are high.

These findings are particularly significant - and disturbing - given that the resettlement debacle at Birecik was taking place at the very time that the Turkish authorities and companies were reassuring the international community, including Export Credit Agencies, that everyone would be properly compensated and that there would be no repeat of previous resettlement failures, such as that at Ataturk (see Box 14: Ataturk' Victims: The Continuing Misery). The Mission recommends that no export credits be approved for Ilisu until there is clear, independently verified evidence that the problems of past resettlement have been satisfactorily addressed and resolved.

Lack of Land Titles

The terms of compensation for Ilisu have yet to be announced.¹²⁰ The experience of those relocated by other GAP projects, however, has set a precedent which does not give rise to any expectation that compensation will be prompt, adequate or effective. Turkish law on resettlement has frequently been flouted and poorer, landless oustees have suffered disproportionately. In the case of the Ataturk and, most recently, the Birecick dams, for example, it was predominantly landowners who were compensated for resettlement: those who lacked title to land did not get compensated despite assurances that they would be.

It is therefore of grave concern that the vast majority of people in the Ilisu reservoir area lack titles to land. In Hasankeyf, for example, the Mission confirmed Kudat's estimates that the vast majority are landless. Within the project area as a whole, it has been estimated that only a fifth of those who would be affected have title to their land.¹²¹

Assurances from the Turkish authorities that those without title will be compensated must be treated with extreme caution. Past experiences suggest that such assurances are more honoured in the breach than in the observance. In Hasankeyf, the Mission learned that residents who were forced out of the caves in the 1960s were provided with houses, but that they were not awarded title to them until three years ago - at which point they had to pay for the houses, even though they had already paid for them when they first moved in. The experience at Birecik is also significant, given that the authorities failed to fulfil promises to compensate those without land.

The Mission notes with considerable concern that land registries do not even exist for some of the villages that would be affected by Ilisu. According to the Kudat report: "It is of utmost importance for DSI to provide guidance by earmarking the lands that are to fall under the reservoir for partially affected displaced communities. DSI should establish procedures to do so for the large number of displaced settlements without a land/title registration system."

The Mission also notes with great concern that those deprived of access to pasture lands because of the dam's reservoir will not be compensated under current compensation law, in contravention of OECD guidelines. The OECD guidelines state: "Customary land ownership and usufruct rights must be recognised for compensation purposes to avoid the destitution of former users."

Kudat acknowledges that "access to pasture lands commonly held by the communities ... will be jeopardised in communities that will be fully affected." Those forced to sell their cattle, however, will not be entitled to compensation. According to Kudat:

"The national legal framework does not address the issue of common property resources for pasture in a comprehensive manner. The policy vacuum with respect to common property resources has so far meant the disregard of the potential income restoration for the livestock owners."¹²²

The Mission recommends that no export credits be awarded until land registration has been satisfactorily completed and the right to compensation for the loss of common property resources secured in law. This is important not only to ensure that landless families currently living in the reservoir area are properly compensated in the event of the dam being built, but also to ensure that those (possibly as many as 50,000) who have been forced to migrate from the reservoir area due to the conflict also receive just compensation.

Inadequate Consultation

International standards require full consultation with affected communities, in addition to a full socio-economic survey. World Bank guidelines state:

"The affected hosts and resettlers need to be systematically informed and consulted during preparation of the resettlement plan about their options and rights."¹²³

And again:

"Resettlement plans should be based on recent information about the scale and impact of resettlement on the displaced population. In addition to describing standard household characteristics, socio-economic surveys should describe (a) the magnitude of displacement; (b) information on the full resource base of the affected population, including income derived from informal sector and non-farm activities, and from common property; (c) the extent to which groups will experience total or partial loss of assets; (d) public infrastructure and social services that will be affected; (e) formal and informal institutions...; (f) attitudes on resettlement options. Socio-economic surveys, recording the names of affected families, should be conducted as early as possible..."¹²⁴

The Kudat report notes that a total of 2,100 households have been consulted, covering 45 settlements, a third of households in Hasankeyf, and "over 100" displaced households. This is out of a total of 183 settlements to be affected by the Ilisu dam. In effect, less than a third of the settlements affected have been surveyed. Others, admits Kudat, were not consulted because of the security situation in the region: "Some communities, although not displaced, were not accessible for security reasons at the time of the socio-economic surveys."

The Fact-Finding Mission interviewed villagers in Hasankeyf who expressed concern over the consultation process. They stated that SEMOR, the consultancy firm contracted by the DSI, had interviewed 300 people of whom 80 per cent were illiterate or could not speak Turkish. The women and elderly people had to work through translators provided by SEMOR rather than family members, which many found socially awkward. The villagers were told that the decision to build the dam had been taken and they were then given options as to how they would like to be resettled: did they want a new village elsewhere? or cash to resettle by themselves? how many rooms would they need in their new houses? would they like to work on dam construction? It is important to note that the villagers were not offered compensation in land - a breach of World Bank guidelines which "encourage 'land for land' approaches, providing replacement land at least equivalent to the lost land".¹²⁵ As the Kudat report states, there is hardly any land available and what little there is would, according to Kudat, probably not be acceptable resettlement land to the villagers.¹²⁶

A questionnaire in Turkish was handed out to villagers in Hasankeyf and some neighbouring settlements. The first question asked villagers whether or not they were in favour of the dam. Many told the Mission that they felt that they had no option but to answer in the affirmative, although opposed to a dam that would flood Hasankeyf. This was in part due to the perception that the dam was a fait accompli and, in part, due to their experience that opposition to the dam is misconstrued by the authorities as evidence of sympathy for the PKK movement.

Villagers told the Fact-Finding Mission that they were concerned that the answers they gave to the questionnaire may have been subsequently altered. They stated that SEMOR representatives filled the forms in with pencil, but asked them to sign the form in ink. As one villager commented, "We are worried that our answers were changed when SEMOR got back to their hotel." Because the Fact-Finding Mission was unable to see copies of the questionnaires used, it was unable to pursue this matter further. It strongly recommends that ECAs request copies of the original documents.

Representations made by villagers to the Mission led it to conclude that the socio-economic survey undertaken by SEMOR may not have been as rigorous as claimed in the Kudat report. Villagers interviewed in a settlement outside Hasankeyf told the Mission that SEMOR had questioned them about the yields of their harvest, the ownership of the houses, the number of animals they owned and other issues related to their socio-economic status. However, villagers interviewed in Hasankeyf were adamant that no such questions had been put to them in the questionnaires they completed.

The Mission acknowledges that it interviewed only a small sample of villagers during its visit. Nevertheless, the consistency with which villagers of Hasankeyf denied being asked about their socio-economic status merits investigation by ECAs.

It is clear that no efforts have been made by the authorities to consult directly with local municipal officials in Hasankeyf on the resettlement plan or other issues related to the dam. Officials interviewed told the Mission that they had not been consulted on the archaeological rescue plan for Hasankeyf. No one in Hasankeyf and Batman to whom the Mission spoke had seen a copy of the draft Resettlement Action Plan - or indeed heard from SEMOR since its one week visit to the area.

The Fact-Finding Mission was disturbed by the pressure that has clearly been exerted on Hasankeyf residents to express support for the dam. The Mission was told of a recent visit by a Swedish delegation to the town when banners were displayed in favour of the dam, carrying slogans such as "I love my country, I love my dam". No banners opposing the dam were permitted. The Mission also heard of the difficulties that villagers have had in organising events to express the opposition to the dam. In June 2000, for example, the Save Hasankeyf Platform had organised a festival to celebrate Hasankeyf, but permission was denied for any petition to be circulated and for any interviews to be given to the press. Given the very serious consequences attendant on being suspected of sympathising with the PKK, the authorities' association of opposition to Ilisu with separatism is a major deterrent to any meaningful dissent. Put bluntly, people are frightened to take a public position against the dam. In February 2000, the mayor of Hasankeyf cut short a visit to Europe, where he was scheduled to talk to the Minister responsible for the UK ECGD, after receiving anonymous death threats.

However, the Mission was told by the muhtar (the elected headperson of a village) of Hasankeyf, "I am now declaring that we don't want a dam that would flood Hasankeyf. If you see anything written or said by me to the contrary, it is because I have either been put under pressure or my statements have been falsified".

It is perhaps significant that the Mission was repeatedly told by those it interviewed that, in their opinion, the dam would not be built if it was in western Turkey, or that there would be a better chance of voicing opposition in the West. Many also considered the dam to be a tool for crushing their Kurdish identity.

Host communities

International guidelines stipulate that host communities - those which will receive the people evicted by Ilisu - must be consulted.

The Kudat report claims that such consultations have taken place. However, all of the information gathered by the Fact-Finding Mission indicated the reverse.

The Kudat report claims that "Consultations were held with governors, mayors and representatives of the government agencies responsible for RAP implementation." However, the Mission specifically asked the Mayors of Diyarbakir and Batman whether or not they or their office had been consulted. The Mission was told that no such consultation had taken place.

Both Mayors stressed the problems that the two cities were already experiencing in providing infrastructures - schools, hospitals, health care, sewage, etc. - for the existing population, which has massively swelled because of immigration due to the upheavals of the conflict and the forced eviction of many villages.

Major efforts are being made to address these issues and, in Diyarbakir, the Mayor expressed confidence that, with international funding, current infrastructure development (including 50,000 to 60,000 new houses) "would enable the city to deal with the problems of past immigration". However, an influx of new migrants from Ilisu would place a number of additional strains on infrastructure with which neither city could cope without central government funding. No request has been made by the central government to either Diyarbakir or Batman to produce a report about their funding requirements and no promises of funding have been forthcoming. The Mission also notes that village and town level officials have not been given the opportunity to meet with their counterparts in areas where people are being settled from past dams. The opportunity of learning from past experience is therefore being lost.

The Mayor of Batman stressed his concerns over further immigration to the city, noting that in addition to infrastructure problems, the number of people committing suicide in the city has risen threefold in the last 15 years. This problem is, in his view, directly related to the traumas of village evictions, subsequent migration and the problems the villagers have encountered in trying to settle and start a new life. As the Mayor commented, "Immigration from those resettled into Batman is a great concern....There is a conflict in cultures between those that are resettled here and those that are already here....It is the adaptation process that is difficult. There is already 50 per cent unemployment, infrastructure problems, sewage problems, colonisation problems...and health facilities, schools, etc. are not adequately funded."

The failure to consult host communities and their elected representatives breaches World Bank guidelines on two counts. First, the guidelines require such a consultation: "The [resettlement] plan should address and mitigate resettlement's impact on host populations. Host communities and local governments should be informed and consulted ... Conditions in host communities should improve, or at least not deteriorate."¹²⁷ Second, the guidelines require a detailed resettlement budget to be prepared as part of the Resettlement Action Plan: "Where large-scale population displacement is unavoidable, a detailed resettlement plan, timetable and budget are required."¹²⁸ Without a detailed assessment of the budgetary requirements of the host communities, any budget proposed under the RAP would misrepresent the true scale of resettlement costs and overestimate the financial viability of the project. The Mission notes that assessing these budgetary requirements will require detailed and lengthy consultation and research over a period of several months. ECAs should ensure that such a budget for host communities is in place - and properly assessed - before accepting the Resettlement Plan.

The failure of the Turkish authorities to assess the budgetary needs of the host communities adds to - and reinforces - concerns already raised by the Kudat report, which noted that, as of the beginning of August 2000, no resettlement budget had yet been prepared for the project. Kudat also suggested that a paper commitment from the Turkish authorities to make the money available cannot be trusted:

"A resettlement budget is yet to be prepared and is likely to exceed previous estimates. The key challenge will be for the national budget to provide a convincing commitment by the State to this budget."¹²⁹

Relying on Presumed Economic Growth to Relieve Post-Project Impacts - A Breach of Standards

According to international standards, resettlement projects should ensure that those resettled are not worse off than they were before the project.¹³⁰ Relying on future economic growth alone to restore or improve the living standards of a displaced population is specifically discouraged under World Bank guidelines. The World Bank states:

"Normally, general economic growth cannot be relied upon to protect the welfare of the project-affected population."¹³¹

It is clear from the Kudat report, however, that the proposed resettlement plan breaches these two key guidelines. Kudat notes, for example, that securing the livelihoods of landless and poorer people will be dependent on future growth in the region:

"Whether post project situations will improve ... depends on the developments of the next decade that currently appear to be positive but are difficult to predict with any certainty."¹³²

Kudat also says:

"Whether the poor among the affected populations could be worse off depends on the near term economic and political outlook of the region."¹³³

And:

"While it is unlikely that rural resettlement could be managed to restore completely and/or improve incomes in all cases, urban opportunities will grow and could be managed to the advantage of affected populations."¹³⁴

The Kudat report itself acknowledges that "it is generally risky to build a resettlement plan solely on the basis of a region's development."¹³⁵ In a tacit admission that such development is by no means assured, the report recommends that, in the case of host communities, "the RAP should ... consider host community needs should the expected positive regional developments not take place in a timely fashion."¹³⁶

Significantly, the Kudat report clearly spells out the failure of past GAP projects to benefit affected communities, causing significant social problems and economic impoverishment. A footnote is more explicit:

"The urban centres of the Southeast Turkey that received high levels of migrants suffer from widespread unemployment and poverty. Educational levels are high and typhoid, dysentery and other infectious diseases are widespread. Staff shortages in schools and in the health sector are still acute. In some parts of the city of Diyarbakir, people continue to drink water from the irrigation canals."¹³⁷

The Fact Finding Mission confirms that future economic growth in the region is ultimately contingent on the successful outcome of a peace process that will bring an end to conflict and the restoration of democratic rule. Currently the region is under Emergency Rule, severely curtailing basic freedoms. This point was made to the Mission repeatedly. The Mission also notes that commercial companies and international development agencies have also expressed concern over the security of future investment whilst the region remains under Emergency Rule.

Given the economic and political instability of the area, the Mission therefore believes that future economic growth cannot be presumed. Even if the hoped-for growth does occur, it is the view of many of those whom the Mission interviewed that growth cannot be relied upon to secure employment and services for the thousands of people who would be affected by the Ilisu Dam and its accompanying downstream project at Cizre. Central government support would also be needed: such support, however, is already lacking throughout the region and does not appear to be forthcoming.

Institutional Failures and the Need for Reform

Although the Kudat report is upbeat in its assessment that some aspects of the proposed Resettlement Action Plan will meet international standards at least on paper, it highlights major institutional limitations that stand in the way of the Plan's realistic implementation.

These include a lack of institutional capacity and a lack of communication between implementing agencies. Kudat argues that overcoming these problems will require sweeping institutional restructuring and reform. The Kudat report states: "In a number of areas, additional data will have to be collected if best practice is to be achieved. Also, new institutional arrangements should be formulated and agreed upon between concerned institutions." It continues: "The GAP framework alone will not resolve all the institutional complexities of the resettlement projects. There is a need to have a more unified institutional framework, a single earmarked budget for resettlement implementation, and mechanisms for quality assurance, enforcement and monitoring and evaluation... "

Kudat points out that the ability of the DSI to implement and enforce the RAP is hampered by the security situation and by the lack of coordination with other institutions which each act independently and have separate budgets. All five provinces affected by the proposed construction of the Ilisu Dam are still under Emergency Rule and, as Kudat comments, "the Ministry of Interior and the military have very different sets of priorities" from the DSI. The complexity and magnitude of how best to address the needs of previously displaced populations "goes beyond the ability of the project and the solutions require the decisions of security agencies".

The Mission supports these views. In addition, as already noted above, it found evidence that the laws on expropriation and compensation failed to ensure that compensation be prompt, adequate and effective - the standard required by international law. Under current procedures, the ownership of all immobile properties and resources to be expropriated should be determined by a cadastral survey. A valuation committee consisting of five permanent members, including two representatives of the affected communities, and five others should then be established in each district to value the expropriated property. Landowners who are dissatisfied with the evaluation have just one month to appeal. Moreover, an effective appeal requires the services of an attorney, which those in the lowest income groups are unable to afford.

In addition, as evidenced by the case of the Ataturk Dam, some lawyers have exploited the resettlement situation, collecting 10-15 cases for each village as a way to earn more money for themselves. Typically, an appeal can take one year and involves visits to the local court, which can be time-consuming and expensive for poorer villagers. Many villagers are simply unaware of their legal rights to appeal and the one-month period in which to do so. Many are also illiterate and are often intimidated by the process. Some speak only Kurdish.

Even where a challenge is successful and higher compensation is agreed, it may take years before such compensation is paid. Although this will incur extra costs for the authorities, who must pay a penalty for non-payment, the country's high inflation rate makes non-payment a cheaper option than payment. By the time villagers receive the compensation they are due, its extra value is likely to have been significantly reduced by inflation.¹³⁸ The consequence is a system riddled with loopholes that benefit the state and which results, on average, in only one sixth of the compensation due ever being paid.

Without a proper legal framework that guarantees prompt compensation that is not conditional upon holding title to land, the Turkish government's assurance that everyone affected by the Ilisu project will be compensated lacks credibility. In the absence of such a legal framework, ECAs should not support the project.

Resettlement and Regional Conditions

Previous Fact Finding Missions and independent reports on the Ilisu project have stressed the difficulties of achieving a just resettlement programme in an area which continues to be wracked by conflicts and which remains subject to emergency laws, none of which have yet been repealed. The Kudat report notes how security considerations have restricted access to villagers,¹³⁹ thus preventing a full assessment of their population densities and the socio-economic status of villagers.

The Fact-Finding Mission found additional evidence of the impacts of Emergency Rule in the region. The Mission heard of how the climate of intimidation had adversely affected the outcome of previous resettlement programmes. At Urfa, it learned that in the case of the Ataturk Dam:

"People are too afraid or unaware how to appeal (the valuation of their property). If ever one person approached an expropriation officer he would be viewed as a trouble maker and feared even by his own neighbours."¹⁴⁰

Human rights groups, other NGOs and the independent press also face a constant threat of closure. The Mission learned of one incident in which an NGO had been sued after publishing a map showing the location of villages razed by the military during the war, and another in which an NGO had been closed down after producing an innocuous human rights poster showing pictures of refugees, people holding banners and migrant camps.

The Mission concludes that the essential prerequisites to an internationally acceptable resettlement plan-freedom of speech, of press, and of association necessary to conduct credible consultation - do not exist. It is of particular concern, for example, that several leading NGOs critical of the Ilisu project are not recognised by the Turkish government.

Independent Monitoring

The failure of Turkish authorities to abide by Turkish law governing resettlement in many other GAP projects, coupled with concerns over the lack of a resettlement plan and the fragile political conditions on the region, has led the ECAs considering support for the project to stipulate that an independent monitoring body be established to ensure compliance of the Ilisu project with agreed international standards.

The Mission considers that such a condition is unlikely to be met. The Mission itself faced repeated refusals by DSI authorities to release any information about the Ilisu project or to establish a constructive dialogue with independent foreign experts. Its own experience of constant police surveillance also reinforced the view already expressed by NGOs that the scope for truly independent monitoring is severely restricted by existing security measures in the region.¹⁴¹

Condition two

"Make provision for upstream water treatment plants capable of ensuring that water quality is maintained"

Concerns have been expressed that current levels of sewage and other waste entering the Tigris river, principally from Diyarbakir, Batman and Siirt, will severely degrade the water quality of the proposed Ilisu reservoir, threatening public health and leading to possible eutrophication and the release of methane, a significant quantity of greenhouse gases. This issue was not properly assessed in the original Environmental Impact Assessment (EIA) for the project (yet to be released to the public) but was highlighted in a subsequent desk study of the EIA undertaken by Environmental Resources Management (ERM) for the UK government (see above pp. 30-31). ERM noted:

"There appears to be no mention of hydrogen sulphide/methane monitoring behind the dam wall, although this could potentially be a risk for such a deep reservoir with high eutrophication potential."¹⁴²

The Fact-Finding Mission met with the Mayors of Diyarbakir and Batman to learn of plans to address sewage problems in the cities. In Diyarbakir, the first stage of a new sewage treatment plant has been commissioned with funding from the German government through Kreditanstalt fuer Wiederaufbau (KfW). The companies involved include Lurgi Bamag GmbH, Passavant-Roediger Anlagenbau GmbH, and Vinsan Veziroglu Insaat Sanayi Ve Ticaret A.S. In Batman, a feasibility study will be undertaken shortly but no plant has yet been commissioned and project finance has still to be arranged.

The Mission welcomes these initiatives. The planned project in Diyarbakir will go a long way to remedying the severe sewage problems currently faced by the city. However, the Mission is concerned that the new sewage treatment plant will not be sufficient to secure the water quality of the Ilisu reservoir. Even when all the proposed plans are in place, 20 per cent of the sewage from Diyarbakir (whose population is currently estimated at 1.7 million) will still not be connected to the sewage system. It is also unclear whether or not factories discharging waste to the Tigris will be connected to the system.¹⁴³ This will leave the waste from some 340,000 people untreated, with potentially severe consequences for water quality in the reservoir. In addition, the Mission was told by the head of the Bar Association in Diyarbakir that people are required to pay for their sewage and for potable water. This means that those resettled to Diyarbakir would have to pay as well, and it is uncertain whether their compensation package provides for this. In Batman, as noted above, sewage treatment plans are still only at a feasibility stage.

The Mission concludes that this condition has not been met and cannot be met until the one hundred per cent coverage is guaranteed for Diyarbakir, Batman and Siirt, with full project plans and finance in place. The Mission also recommends that the revised EIA being undertaken by Sulzer Hydro examines whether industrial effluent, which is likely to increase with economic growth in the region, will be adequately treated and whether the regulatory regime is sufficient to ensure proper management of the system.

There is as yet no published resettlement plan for the tens of thousands of people who will lose their homes, lives and livelihoods to the Ilisu Dam. The Mission urges international Export Credit Agencies to undertake and make public a human rights assessment of projects like Ilisu for which export credit support is being considered. This assessment should detail the extent of the project's compliance with international human rights agreements and standards.

Condition three

"Give an assurance that adequate downstream flows will be maintained at all times"

Concern has been expressed by Syria and Iraq over the downstream impacts of the Ilisu project, the fear being that Turkey will deny water to downstream states. Recognising that Turkey is obliged under international law to consult with its neighbours on any project which might infringe on their rights to the shared waters of the Tigris, the British government has stated that "there should be a published assurance that the required consultation of neighbouring states has been carried out."¹⁴⁴ No such consultation has yet taken place (see above p. 36).

The view that water from the dam will affect power relations with neighbouring countries in the region was shared by the Mayor of Diyarbakir during an interview with the Mission in which he noted, "I'm aware of the issue of the conflict with Syria and Iraq [from the dams in the GAP system, including Ilisu]. As the amount of available water decreases, the government will be more conservative with it, which will increase conflict. If there is not a fair plan, there will be a serious conflict." However, far from there being a fair plan with Syria and Iraq, there is no plan; not even the most rudimentary, legally required consultation.

Furthermore, the strained political relations between Turkey and its southern neighbours could easily be worsened in the next year by the need for the Turkish government to block more water flow from both the Tigris and Euphrates rivers in order to make up for water shortages which have affected the reservoirs of already existing dams. Because of the severe droughts which affected eastern Turkey in the past year, the Keban, Karakaya, Ataturk and Karkamis hydro-plants, which account for one-fifth of Turkey's national output, are experiencing their lowest water levels in ten years. Officials said the levels in the dams were so low that it might take four or five years before they return to normal.¹⁴⁵ This led Turkey unilaterally to declare that it will reduce the promised downstream flow of the Euphrates from 500 cubic metres/second to 160 cubic metres/second. The fact that the water is now so low also raises doubts about Ilisu as a means of meeting Turkey's future energy needs (see pp. 89-91).

The dam will not only impact on international power relations: it will also affect the livelihoods and development opportunities of those living downstream, especially those in Iraq. The greatest burden is likely to fall on the rural poor and those who depend directly on the waters of the river. The Mission did not inquire directly into the projected impacts of Ilisu on downstream flow. However, independent engineers who have assessed the project told the Mission that, contrary to claims by the project sponsors, Ilisu is not intended only for generating hydroelectricity. The dam was planned for use in conjunction with a further 45-metre dam downstream at Cizre, which will irrigate some 66,000 hectares. The water from Ilisu's reservoir will be used to feed this dam and ensure a year-round supply of irrigation water. The two projects should therefore be considered as one when considering their impacts on downstream flow, although construction at Cizre will begin three years after Ilisu, owing to its smaller size.

The Mission was also told that the site of the Ilisu Dam was specifically chosen to allow for the maximum reservoir size - 11 billion cubic metres. Alternative sites are available on the Tigris which would produce the same amount of power (3.8 billion kWh/year) but with a significantly smaller reservoir. One interpretation put on this was that the size of the proposed reservoir reflected a political choice motivated by a desire to ensure sufficient storage at Ilisu to allow for the control of downstream flows to Syria and Iraq. The Mission notes that a major reason given by Ilisu proponents for supporting the dam appears to be the belief that the dam would enable Turkey to exert political control in the region. As a member of the State security police put it to the Mission: "The dam means power - who has the water has the power."

The Mission asked DSI for project documents but was told that no documents on either project are available to the public - and that they will not be available until construction has begun.

The link between Cizre and Ilisu suggests that the impacts on downstream water flow can only be assessed properly if both dams are considered together. The Mission therefore calls for a strategic environmental assessment to be made a condition of approval for any export credits, in order to evaluate fully the cumulative impacts of the two projects on the river basin as a whole. Export Credit Agencies may also wish to inquire whether or not the project sponsors misrepresented the nature of the Ilisu project, given its connection with the proposed Cizre Dam.

Condition four

"Produce a detailed plan to preserve as much of the archaeological heritage of Hasankeyf as possible"

A previous September 1999 Fact Finding Mission to the region, on visiting Hasankeyf, established that only a restricted site evaluation was being conducted by a single archaeological team. This evaluation, led by Professor Olus Arik, was deeply constrained by lack of time and money and had resulted in only a minute amount of exploratory excavation of the site. The October 2000 Mission sought to establish the extent to which that exploratory excavation had increased or expanded in its ambit. The Mission's specific objectives were:

• To discover what methodologies were now being used to analyse the site at Hasankeyf and other sites of paramount archaeological significance in the region due to be submerged by the reservoir;
• To discover what plans have been put in place with the intention of saving, ex situ, a proportion of the artefacts of Hasankeyf and other sites of paramount importance;
• To discover the extent to which there has been or is any ongoing consultation with local populations over the importance and significance to them of their monuments, graveyards, and places of worship.

The Mission first made a visit to the Birecik Dam at the Belkis/Zeugma site. There were no archaeologists on site to consult. The excavations at Zeugma are documented as being sophisticated but wholly inadequate. The speed with which the Birecik Dam has been constructed and filled has conclusively deprived civilisation of the opportunity to document and map the enormous quantity of significant remains now lying at the bottom of the reservoir. At the very least, what is known to have been destroyed is a Roman Legionary Fortress, a Roman bath and an early Bronze Age cemetery. In addition, countless mosaics and frescoes at Roman villas at Zeugma have been lost. What has also been lost is the cultural and natural wealth of the ancient settlement of Apema and that at the mounds of Tilobur, Tilbes, Tilmusa and Horum. It is worth noting that it would be inconceivable for such uncontrolled archaeological destruction to have been sanctioned in a country belonging to the European Union.

The Mission had the opportunity to speak to a number of resettled communities who were deeply aggrieved that they had been forcibly parted from their homes and associated heritage and that they were no longer able to worship in their traditional places or to tend the graves of their families. In summary, the work which had to be done so hastily at Birecik to preserve a tiny fraction of the archaeological heritage of the region is devastatingly inadequate in almost every particular. The extraordinary achievements of the archaeologists working round the clock on site were only possible after negotiations with the Turkish government resulted in a few weeks' extension of their licence to work, before the reservoir was filled and the site lost. Archaeologists consider that the mosaics that were lifted are the most outstanding examples of their type.

The Mission then visited Hasankeyf itself. The Mission was not able to establish contact with any of the archaeologists who are thought to be working on the site, as this work appears to be limited to the summer season. It was established that many artefacts have already been removed to be preserved ex situ. The Mission was told by dignitaries in the community that an aerial survey of the area had been done some ten years previously. However, this photography was thought to have been part of a reconnaissance operation, and was not in the nature of an archaeological survey. There is a certain amount of labelling that can be seen on parts of the site. The Chamber of Architects in Diyarbakir, which includes a number of professional archaeologists, has stated that although a programme to assess removable pieces has been run by the Middle East Technical University based in Ankara through the support of DSI, it has focused on a mere counting of monument pieces and evaluating whether or not they are movable. Such a programme cannot even begin to constitute an adequate archaeological survey of a site of such vast complexity and age. Such a survey would involve the co-ordination of specialists of each of the relevant eras. Members of the Mission, in discussion with experts from a number of the different periods which cover the history of Hasankeyf, have been made aware of the large number of different civilisations which are reflected in different ways, not only in Hasankeyf but also in the surrounding area for many miles. What would be lost in the flooding of Hasankeyf cannot be properly estimated in any event, since so much of the material lies buried beneath the more recent civilisations which have occurred there.

The Mission was repeatedly told that flooding Hasankeyf would violate Turkish law. One prominent lawyer interviewed by the Mission stated: "The government cannot build this project legally because Hasankeyf is a Class 1 protected area."¹⁴⁶ Hasankeyf was listed as a national protected site in 1978 and again in 1980 when a new order was issued. Flooding the town would therefore require the special permission of a council, based in Diyarbakir, responsible for local sites protected under the law. Without permission from this council, argued the lawyer, the flooding of Hasankeyf would be illegal.¹⁴⁷ The council, which is appointed by the Minister of Culture, has not yet given a permission to build the dam. A meeting was planned in March 2000, but was postponed in order to take account of the conditions imposed by the ECAs. The Mission notes that the ECAs involved in the project are prohibited under their own guidelines from supporting activities that contravene host country laws. In this regard, it is of significance that a legal case has already been lodged by an Istanbul-based lawyer, Murat Cano, contesting the legality of the dam.

Conversations with local dignitaries also revealed the existence of a deep and abiding sense of cultural heritage, in particular, the enormous expanse of time - some 10,000 years - which is bridged at Hasankeyf. These conversations also indicate the extent to which, for the last 30 years, those dignitaries have seen Hasankeyf in a state of enforced declined, both because the town has been starved of the funds necessary to protect its heritage and because it is denied the possibility of generating funds through tourism as a result of the town's protected status. The Chamber of Architects has also commented that "the historical sites have a meaning if people living in them don't move away; it is important to say that Hasankeyf should be completely saved."

Already archaeologists have made major finds at the site. For example, until recently, nobody knew that Hasankeyf was the site of Kulliye University, which dates from the 14th century Eubyan period. According to myth, the university campus had one room for each day of the year. The ruins of the site, close to the town's ancient mosque of Sultan Suleyman, were unearthed in 1986 but the discovery was not publicised. A team from the Istanbul Technical University, headed by Professor Metin Ahunbay, has now started new excavations close to the ancient mosque and worked for a two-month period with 110 students during the summer of 2000. The Ministry of Culture recently visited Hasankeyf and assured people that a budget for a further six months works has already been allocated. It is not clear who is in charge of the disbursement of such money.

It is not possible to ascertain whether or not any sophisticated methodology has been used on the Hasankeyf site as a whole to determine what it contains. However, villagers asserted that there have been no recent geophysical surveys whether involving the use of magnetometry, resistivity meters or ground penetrating radar. They have only observed limited physical excavation: it is therefore not know what treasures will be lost other than those which are already above ground. The Mission was conducted around Hasankeyf by people whose families had only recently ceased to occupy the caves, which had been carved centuries ago into the side of the mountain.¹⁴⁸ Against their will, these families had been forced to move out of their homes in the caves into housing units situated next to the river, with which they are not satisfied. Whatever plan is made to preserve artefacts from this site, it will be impossible to preserve the ancient caves themselves since they will inevitably be flooded if the dam goes ahead. The caves are integral to the essence of - and are an irreplaceable part of - the site. Indeed, they are the reason why the site has received such international acclaim. Furthermore, though the mission was unable to examine any open vertical sections in the town that might have given an indication of the true depth of cultural deposits buried below ground, Olus Arik has recently indicated that below ground archaeological deposits at the site are very extensive indeed.¹⁴⁹

Some of the cave dwellings in Hasankeyf which are still inhabited and which would be submerged by the waters of Ilisu.

The archaeological rescue condition imposed by the Export Credit Agencies seems to imply that Hasankeyf is the only site of major cultural significance which is facing submersion (see World Archaeological Congress discussion above, p. 33).¹⁵⁰ This is not so. International archaeological interest is revealing that this site is one of a series of sites to be flooded which form a crucial part of humanity's understanding of its transition from hunter-gatherer to settled agriculture. It is now becoming clear to the archaeological community that seven years - the estimated time that it would take to construct the dam - is wholly insufficient to make either an accurate or a complete survey of what would be lost in the resulting flood. Members of the archaeology profession take the view that this site is of at least the same significance as Ephesus, which is still under excavation one hundred years after the explorations began.

According to sources within the archaeological profession who are familiar with these sites, such time frames are the norm. The accelerated time frame for excavation in the Ilisu project area is unrealistic and contrived. The Mission concludes that the constraints of time and money imposed by the dam construction schedule make a mockery of any claims that a full and competent investigation of the archaeological wealth of the affected site is being made.

Meanwhile, according to sources within the archaeological profession, the findings of international teams of archaeologists have similarly not been made public, and it is not clear that all findings have been wholly revealed to the Export Credit Agencies. The Mission will not be able to reveal in detail these findings unless permission is obtained from Turkish authorities. We strongly urge Export Credit Agencies to request permission to make this information publicly available, both for themselves and for society as a whole.

The Mission also strongly recommends that any proper archaeological and historical survey of the region must include proper consultation with the local communities affected. The mission agrees with the views expressed by the World Archaeological Congress (see above p. 33) that the local values placed upon material culture histories, and the research questions that may therefore take precedence in any subsequent scheme of research, should be of equal or greater importance than those arbitrarily assigned from outside (largely by archaeologists, bureaucrats or historians, very few of whom have ever been anywhere near the area). This is rendered doubly important by the very limited existence of any written record/history for the region over the last five hundred years or so

The Mission notes that the principal professional association of archaeologists within Turkey, ICOMOS - Turkey, has stated that "in the long run, the Ilisu dam will be a social, cultural and environmental disaster."¹⁵¹

Conclusion

The Fact-Finding Mission concludes that the four conditions imposed by the Export Credit Agencies have still to be met - and the prospect that they can be met in the near future is remote. It will therefore be pressing the ECAs to refuse export credit support for the project.

Section 3: Ilisu, The World Commission on Dams and ECA reform

In addition to evaluating the progress - or lack of it - being made by the Turkish authorities in meeting the four conditions laid down by the export credit agencies considering support for Ilisu (see Section 2), the Mission was charged with:

1. Assessing whether or not the conditions, even if met, are sufficient to bring the project into line with evolving international best practice. The Mission was explicitly charged with reviewing Ilisu in the light of new guidelines developed by the World Commission on Dams;
2. Identifying corporate governance failures in the practices and procedures of the supporting ECAs that have contributed to the controversy over Ilisu; assessing the extent to which these failures will be addressed by new procedures under consideration by the OECD's Working Group on Export Credits; and proposing corrective action;
3. Evaluating whether or not continued support for Ilisu could be justified by the UK government in the light of new procedures being developed by the UK Export Credit Guarantees Department (ECGD).

The Mission's findings on these three issues are detailed below.

Issue three: Ilisu - a litmus test of the ecgd's and hermes' commitment to reform

The Export Credit Agencies (ECAs) considering Ilisu do not stipulate the standards against which compliance with their four conditions will be measured. On resettlement, for example, they merely state that a plan must be drawn up to "international standards".¹⁵²

Since the ECAs set out their conditions, the World Commission on Dams (WCD), an international body charged with drawing up new guidelines for the hydro industry, has reported: its report is widely regarded as setting the benchmark for best practice in dam projects - and hence for "international standards."

Significantly, the UK government has implied that it considers that Ilisu should meet the WCD standards in order to obtain UK export credit support. In February 2001, Chris Mullin, Parliamentary Under-secretary of State for International Development told a seminar organised by the British Dam Society and the Institute of Civil Engineers: "Our government has made it clear that we will only support Ilisu if a number of conditions are met. These conditions reflect the criteria identified by the Commission."¹⁵³

US Ex-Im Bank, which has issued a "letter of preliminary commitment" to Balfour Beatty for Ilisu, has also stated its intention to incorporate "elements" of the WCD guidelines into its Environmental Procedures and Guidelines (EPGs), which are currently undergoing revision. The draft text of the new Ex-Im EPGs "encourages participants of hydroelectric and water resource projects to follow to the extent possible the principles and guidelines set forth in the Final Report of the World Commission on Dams".¹⁵⁴ While Ex-Im has reviewed Balfour Beatty's application, it is thought unlikely that Ilisu will meet its existing or revised policies much less the WCD's guidelines.

The Fact Finding Mission has reviewed the WCD guidelines and finds that Ilisu, as currently planned, violates all of them in each and every particular. Whilst welcoming the UK government's view that Ilisu should meet the WCD guidelines, the Mission refutes its claim, as expressed by Mr. Mullin, that the four ECA conditions, once implemented, would bring Ilisu into compliance with the WCD's guidelines.

The ancient town of Hasanekyf holds over 10,000 years of history. The Zeynel Bey Mausoleum pictured here is just one of the many important cultural and archaeological sites which may be lost to the Ilisu Dam.

Ilisu and the WCD

The WCD published its report, Dams and Development, in November 2000. The report sets out a new framework for decision-making on water and energy development which "reflects a comprehensive approach to integrating [the] social, environmental and economic dimensions of development", in addition to "creating greater levels of transparency and certainty for all involved".

The new framework embodies five core values - equity, sustainability, efficiency, participation and accountability - which, the report makes clear, have frequently not been met in past projects.

• Equity

  The WCD's report states, "The poor, other vulnerable groups and future generations are likely to bear a disproportionate share of the social and environmental costs of large dam projects without gaining a commensurate share of the economic benefits."

• Sustainability

  The WCD notes that dams are a major factor in the degradation of watershed ecosystems, fragmenting and transforming aquatic and terrestrial environments with a range of effects that vary in duration, scale and degree of reversibility.

• Efficiency

  The evidence gathered by the WCD indicates that dams have generally fallen short of their performance targets on electricity production, irrigation, water supply and flood control.

• Participatory decision-making

  The Commission states, "The WCD documents a frequent failure to recognise affected people and empower them to participate in the process." It also notes the corrupting influence of vested interests on decision-making.

• Accountability

  The WCD's report makes repeated reference to the lack of accountability of dam planners, builders and operators to affected people and society in general.

In order to ensure that future dam projects comply with these principles, the Commission proposes a set of guidelines for water and energy resources development, based on seven strategic priorities and corresponding policy principles:

• Gaining Public Acceptance
• Comprehensive Options Assessment
• Addressing Existing Dams
• Sustaining Rivers and Livelihoods
• Recognising Entitlements and Sharing Benefits
• Ensuring Compliance
• Sharing Rivers for Peace, Development and Security

The Mission has reviewed the Ilisu project in the light of the above strategic priorities. Its findings are set out below. For ease of reference, the WCD guidelines are set out first, followed by an evaluation of Ilisu's current compliance or non-compliance and an evaluation of the extent to which the ECA conditions would bring the project into line with the WCD guidelines.

• Gaining public acceptance

WCD Guidelines

"Public acceptance of key decisions is essential for equitable and sustainable water and energy resources development." Decisions relating to the planning and implementation of a project must be jointly negotiated by affected communities and the project developers. The negotiations should be conducted through a stakeholder forum in which "those whose livelihoods, human rights and property and resource rights ... are core stakeholders."¹⁵⁶ Negotiations "should result in demonstrable public acceptance of binding formal agreements among the interested parties with clear, implementable arrangements for monitoring compliance and redressing grievances."¹⁵⁷ Where indigenous groups are affected, the project must have their prior informed consent.¹⁵⁸

Evaluation of Compliance

As noted in Sections 1 and 2, the Ilisu area has been devastated by armed conflict, and remains under emergency rule. Freedom of expression and freedom of association do not exist, and the Kurdish communities affected by the Ilisu dam cannot voice their opposition to the project. In this context, the conditions do not exist for ensuring "an open and transparent process" in which negotiated agreements on all key decisions can be reached between all stakeholders, as recommended by the WCD. As a result, the WCD's pre-condition for project approval - that "all key decisions" should enjoy "demonstrable public acceptance" - has not been, and cannot be, met. The continuing Emergency rule - and accompanying security presence - also renders compliance through independent and transparent review unachievable.

More specifically, the project currently fails to meet the following WCD guidelines with respect to "demonstrable public acceptance":

• No stakeholder analysis has been undertaken in order to identify key stakeholders for inclusion in a stakeholder forum empowered with negotiating agreement on key decisions:¹⁵⁹
• No stakeholder forum has been established (and none is contemplated) and stakeholders have not "participated in the project design and the negotiation of outcomes that affect them";¹⁶⁰
• Key decisions are not being agreed through a negotiated process in which all stakeholders "have an equal opportunity to influence decisions";¹⁶¹
• No measures have been taken, or are contemplated, to address power imbalances between various stakeholders¹⁶² in order to ensure "an open and transparent decision-making process in which the rights and entitlements of vulnerable groups [are safeguarded]";¹⁶³
• The project proponents have not undertaken to prohibit acts of intimidation against stakeholders;¹⁶⁴
• Access to the "information, legal and other support necessary for informed participation in decision-making" has not been made available, particularly for vulnerable groups;¹⁶⁵
• Where consultation exercises have been held, communities have not been given "sufficient time to examine various proposals and consult amongst themselves";¹⁶⁶
• The Turkish authorities have failed to demonstrate a willingness "to negotiate in good faith through all key stages, from options assessment to final implementation, operation and monitoring";¹⁶⁷ and
• Stakeholders have not "participated in baseline, impact and investigative studies"¹⁶⁸ and have not been invited to do so.

The Mission notes that, even if the conditions imposed by the ECAs are met in full, the project would still be in violation of the WCD's guidelines with regard to its first strategic priority. For example, there is no requirement to set up a stakeholder forum; no requirement to take measures to address power imbalances between stakeholders; and no commitment by the Turkish authorities - or indeed the ECAs themselves - to abide by a negotiated decision-making process involving all stakeholders.

• Comprehensive options assessment

WCD guidelines

"Alternatives to dams do often exist" states the report. Development needs and objectives should be "clearly formulated through an open and participatory process" before any one option is selected. In the assessment process, "social and environmental aspects" should have "the same significance as economic and financial factors."¹⁶⁹ The assessment of options should continue "through all stages of planning, project development and operations." Planning "must give priority to making existing water, irrigation and energy systems more effective and sustainable before taking a decision on a new project."¹⁷⁰

Evaluation of Compliance

The Mission considers that Ilisu fails this second strategic priority on all counts:

• No participatory assessment of development needs and objectives has been undertaken - and none is planned. Moreover the institutional arrangements for such an assessment do not exist in Turkey. Indeed, as the ECGD's own social assessment of the Ilisu project points out, "Open consultative processes are not part of the institutional culture or political system."¹⁷¹
• No comprehensive, participatory options assessment has been undertaken - and none is planned. Assessments of alternatives to Ilisu have been minimal: no consideration has been given to the solar energy option, nor to the use of gas fired power stations, nor to the "no dam" option. Yet alternatives to Ilisu exist which are both economically competitive and less socially and environmentally destructive.

Given the potential offered by abundant solar energy in the region, it may also be argued that the Republic of Turkey would be better advised to opt for a solar programme, particularly in view of the potential opportunity for Turkey to establish a competitive edge in the technology. In addition to possible cost advantages, embarking on such a programme could promote Turkey to a leading position in a key technology for the 21st century. At present, no other country has established a mold-breaking programme in this area. A large-scale solar programme would also be likely to be highly beneficial to Turkish trade. The use of solar energy avoids the import of fuel. Indigenous production would ensure that the overwhelming majority of the value of the projects would be retained in Turkey, with Turkey lining itself up to become a major exporter of solar technology in the future. Moreover, because solar power is flexible, a solar programme can easily be adjusted as power requirements emerge. An additional advantage would be that solar plants can be installed in relatively small numbers near key areas of demand, so avoiding the need to expand the power grid at great cost.

Gas-fired plants also appear to offer a cheaper alternative to Ilisu. In November 1998, the Swiss government guaranteed contracts for Ankara gas power project. At US$380/kW, this project costs less than a third of Ilisu. The recent private sector investment in three gas-fired power plants in the Marmara region has also demonstrated the attractiveness of this option from a financial point of view. The Mission was also informed that the Marmara plants' contribution to power supply in Turkey was sufficient to allow the government to reject the Akkuyu nuclear project without the danger of creating power cuts.

The attraction of such alternatives is enhanced still further by recent drought in the GAP region which has caused an acute shortage of electricity due to low water levels in many large hydro reservoirs, which are experiencing their lowest water levels in ten years. Officials said the levels in the dams - which supply one fifth of the nation's electricity - were so low that it might take four or five years before they return to normal.¹⁷²

• Priority has not been given to improving the effectiveness of existing energy systems, as recommended by the WCD, or to improving the performance of existing dams, despite numerous studies that have repeatedly documented the inefficiency of Turkey's existing energy systems. Yet a number of independent studies reveal that demand-side management and improvements in transmission both represent less costly, more sustainable alternatives to Ilisu. A January 2000 report on Turkey by the International Energy Agency, citing the Turkish Government's own State Planning Organisation's 1996-2000 Five Year Development Plan, concludes that "energy efficiency is considered the cheapest energy source [and] potential gains to be achieved by increased energy efficiency are substantial."¹⁷³ The IEA estimates "the total energy saving potential for the three consumptive sectors to be approximately 13.2 mtoe [million tonnes oil equivalent] per year, corresponding to slightly more than the current final energy consumption in the energy sector."

The World Bank similarly notes that "considerable problems have plagued operations of the existing power infrastructure." In generation, "the plant availability factor has remained low (40-60%) [and] the losses in the transmission and distribution network continue to be high at 18% of total generation (mainly in distribution)."

• No attempt has been made to compare the Ilisu site's environmental and social impacts to those of other possible dam sites. The WCD recommends that, where a comprehensive options assessment leads to a dam being selected, "the same multi-criteria approach proposed for the earlier stages of option assessment" must be used to "determine its precise location, alignment and height." The DSI, however, has actively refused to consider a number of possible alternative dam sites whose impacts would be less severe than Ilisu. Even where sites have been considered, the DSI has failed to compare environmental and social impacts.¹⁷⁴

The Save Hasankeyf Platform has undertaken its own assessment of one alternative dam design and concluded that a reduction of 55 metres in the height of the dam would leave Hasankeyf untouched, albeit for a reduction in the dam's power output.¹⁷⁵ The Fact Finding Mission also learned that two independent engineers have proposed another alternative consisting of a small reservoir upstream of Hasankeyf which would be used to channel water into a second basin not far from the Ilisu site where water could be passed into turbines. The Mission was told by engineers that such an option would provide the same amount of energy as Ilisu. The Mission was also told that the Turkish Prime Minister is reported to be interested in exploring this option. However, sources told the Mission that top ranking officers in the DSI oppose any changes to the original project design for Ilisu. The Mission is not in a position to evaluate these claims but recommends that they should be examined.

The conditions laid down by the ECAs do not address the issue of options assessment - and will not therefore bring the project into line with the WCD's guidelines with respect to this second strategic priority.

• Addressing existing dams

WCD Guidelines

"Opportunities to improve the efficiency, environmental and social performance of existing dams and optimise their benefits must be taken.¹⁷⁶ Outstanding social issues associated with existing large dams should be identified and assessed - and "processes and mechanisms ... developed with affected communities to remedy them."¹⁷⁷ The WCD is emphatic that "priority must be given to financing a negotiated reparation plan before funding new dam projects in a specific location or river basin in a country."¹⁷⁸

Evaluation of Compliance

Here again, the Mission found the Ilisu project to be in complete violation of the guidelines proposed by the WCD:

• No "comprehensive post-project monitoring" has been undertaken of dams already built under the GAP;¹⁷⁹
• No mechanisms are in place - or are being put in place - to make reparations for the loss of livelihood and other damages suffered by those who have been forced to move as a result of dams already built as part of GAP. Existing dams in the area have already displaced hundreds of thousands of people. Most of those evicted have not received any compensation or rehabilitation:¹⁸⁰ as the Mission confirmed in meetings with those evicted to make way for the Ataturk Dam, the problems suffered by those who have been evicted by past dams are severe (see Box 14: Ataturk's Victims - The Continuing Misery).
• Funding new dam projects is being given priority over funding "a negotiated reparation plan", contrary to the WCD's recommendations.¹⁸¹

The ECA's conditions do not address reparations or improving the performance of existing dams. The conditions will not therefore bring Ilisu into compliance with the WCD guidelines in respect of its third strategic priority.

• Sustaining rivers and livelihoods

WCD Guidelines

The WCD report stipulates: "A basin-wide understanding of the ecosystem's function, values and requirements and how community livelihoods depend on and influence them, is required before decisions on development options are made." Priority should be given to options that avoid impacts on the environment, followed by "the minimisation and mitigation of harm to the health and integrity of the river system."¹⁹² States should observe the precautionary principle, exercising "caution when information is uncertain, unreliable, or inadequate and when the negative impacts of actions on the environment, human livelihoods, or health are potentially irreversible."¹⁹³

Evaluation of Compliance

The Mission found that Ilisu directly violates the WCD guidelines on sharing rivers and livelihoods. It notes that:

• No assessment of the cumulative social and environmental impacts of the dams already built on the Tigris and Euphrates has ever been carried out, and so far, there is no environmental impact assessment for Ilisu which measures up to international standards.
• The precautionary principle is being flouted by the Turkish authorities, the companies and the ECAs involved in Ilisu. The ECGD's review of the Ilisu Consortium's own Environmental Impact Assessment reveals major uncertainties over the environmental impacts of the dam and large areas of ignorance - yet the ECAs are still considering the project in defiance of the precautionary approach.

The issue of shared rivers is addressed by the four conditions laid down by the ECAs. However, no requirement is made for a basin-wide assessment of the cumulative impacts of existing and planned projects. The condition would therefore fail to bring Ilisu into line with the WCD guidelines with respect to the WCD's fourth strategic priority.

• Recognising entitlements and sharing benefits

WCD Guidelines

The rights of affected people must be recognised. "Mutually-agreed, formal and legally enforceable mitigation, resettlement and development provisions" should be jointly negotiated by the project developer and affected people.¹⁹⁴

Evaluation of Compliance

As noted in Sections 1 and 2, the rights of communities affected, or potentially affected by Ilisu, have not been recognised by the Turkish authorities. In particular, the following entitlements - all specified by the WCD - have been denied to villagers:

• The right "to participate in negotiating the outcomes of the options assessment process";
• The right "to participate in negotiating the implementation of the preferred option"; and
• The right "to negotiate the nature and components of mitigation and development entitlements".¹⁹⁵

In addition:

• Ilisu lacks a Mitigation, Resettlement and Development Action Plan, accepted by affected people and backed by "a master contract that outlines the obligations of government and the developer";¹⁹⁶
• No performance contracts have been signed - or even considered - between the government and individual affected families, as recommended by the WCD. Such contracts should specify "entitlements (compensation, resettlement where necessary and direct benefits from the project), delivery schedule and recourse procedures"; and
• No legally enforceable benefit sharing mechanisms have been negotiated with affected communities.

None of the four conditions laid down by the ECAs addresses the issue of benefit sharing. The conditions would not therefore bring Ilisu into compliance with the WCD's fifth strategic priority.

• Ensuring compliance

WCD Guidelines

The WCD's report states: "A clear, consistent and common set of criteria and guidelines to ensure compliance [with commitments made for the planning, implementation and operations of dams]" should be adopted "by sponsoring, contracting and financial institutions". The WCD recommends a Compliance Plan should be drawn up and be subject to independent monitoring. The costs for establishing compliance mechanisms and ensuring their effective application should be "built into the project budget."¹⁹⁷

Evaluation of Compliance

The Mission notes that the WCD's recommended mechanisms for ensuring compliance are entirely absent from Ilisu. For example:

• No "clear, consistent and common set of criteria and guidelines to ensure compliance" has been adopted - let alone agreed - by "sponsoring, contracting and financing institutions";¹⁹⁸
• No "Compliance Plan"¹⁹⁹ has been agreed - let alone considered - for Ilisu;
• No independent review panel²⁰⁰ has been agreed for Ilisu;
• There are no requirements for the DSI, as project sponsor, to set up performance bonds "to provide financial security that obligations will be met";²⁰¹
• No provisions have been made in the project budget "for compliance mechanisms and related institutional capacity".²⁰²

Although the ECAs' first condition - on resettlement - specifies the need for independent monitoring, the condition fails to meet other compliance requirements stipulated by the WCD. Moreover, as noted in Sections 1 and 2, there are grave doubts that independent monitoring is possible whilst the region remains under Emergency Rule.

Other suggested compliance mechanisms also fail to meet the WCD guidelines. For example, the UK Export Credits Guarantee Department has undertaken to write "clawback" mechanisms into any contract undertaken in support of Ilisu, whereby the credit could be voided if its conditions are not met. No details have been made public, however. In addition, it is also questionable whether clawback conditions, though welcome, would suffice to ensure long-term compliance with agreements undertaken by the Turkish authorities, for example on environmental mitigation and resettlement, since the involvement of Balfour Beatty, the company which would receive ECGD support, is likely to be over before many problems emerge.

• Sharing rivers for peace, development and security

WCD Guidelines

The WCD recommends that rivers must be shared for peace, development and security. The storage and diversion of water on transboundary rivers should be based "on principles of equitable and reasonable utilisation, no significant harm, prior information and the Commission's strategic priorities."

Evaluation of Compliance

As noted in Sections 1 and 2, the planned Ilisu Dam threatens to disrupt the flow of the Tigris to Iraq and Syria. Turkey refuses to consult these riparian countries on the impacts of Ilisu and other dams. Professors Crawford, Sands and Boisson de Chazournes concluded in a detailed legal opinion for Friends of the Earth (England, Wales and Northern Ireland) that building the Ilisu Dam without such consultation would violate international environmental law on several counts. Their conclusion has been confirmed in an independent legal opinion prepared by Astrid Epiney, professor of international law at Freiburg University, Switzerland. The WCD report recommends that "where a government agency plans or facilitates the construction of a dam on a shared river in contravention of the principle of good faith negotiations between riparians, external financing bodies withdraw their support for projects and programmes promoted by that agency".

• The Mission concludes that, even if met, the ECAs' four conditions leave many key concerns (particularly those relating to transparency and human rights) unaddressed and would fail to bring the project up to international standards. The project violates each and every one of the WCD's major policy recommendations and would still be in breach of WCD standards even if the ECAs' four conditions were met in full.
• Issue two: ECAs and governance

The Ilisu project tells us much about political oppression and the lack of democracy in Turkey. But it also tells us much about the governments considering support for Ilisu. In particular, it reveals:

• the depth of some of these governments' commitment to human rights and the environment;
• the lack of coherence between stated government policies and actual departmental practice; and
• governance failures in the management of the ECAs involved.

In the UK, for example, the government is publicly committed to paying "particular attention to human rights [and] transparent and accountable government" and to ensuring "that the full range of government policies affecting developing countries, including environment, trade, investment and agricultural policies, takes account of our sustainable development objective."²⁰³ In line with the new policy, announced in 1997, large capital projects in the South are to be avoided. British Foreign Secretary Robin Cook has also committed Britain to a new "ethical foreign policy" in which Britain would "once again be a force for good in the world ... Our foreign policy must have an ethical dimension".²⁰⁴ In Germany as well, the Social Democrat/ Green government was widely expected to give stronger emphasis to environmental and human rights criteria in its foreign policy.

Ilisu flies in the face of such commitments, revealing a massive gulf between the rhetoric and reality of government policy. Parliamentary scrutiny of the Ilisu case has also revealed the decision making procedures that led to the UK's giving conditional approval for the project to be deeply flawed. Despite the government's "ethical foreign policy", for example, investigations by the House of Commons' International Development Committee revealed that "the Foreign Office did not raise any questions about the proposed Ilisu Dam and its effects on the human rights of those living in the region".²⁰⁵ Meanwhile, in evidence to the committee, the Minister responsible for the UK Export Credits Guarantee Department (ECGD) denied that his department had any responsibility for human rights - this despite the government's announcement that all departments should take account of sustainable development objectives (seeBox 15: A Tragi-Comedy in 90 Seconds).

The UK's International Development Committee has also drawn attention to the failings of the "band-aid" approach to standards exhibited by Ilisu. The Committee notes:

"Much has been said of the need to monitor any commitments made. Certainly, the conditions must be public, clear and to internationally agreed standards. There must be independent monitoring procedures with the agreement that any cover becomes void should the monitors conclude that something has been broken. But the unbiased observer must surely conclude that something has gone very wrong when conditionality has been used in this way - with ECAs and Governments bending over backwards to secure the deal. The Turkish authorities had not complied with international standards - why was the project not simply rejected for cover? Is it always the case when such conditions are not met that ECGD simply asks for the required plans to be produced, and on that basis cover is given? How seriously can such commitments be taken?"

The committee concluded:

"There is good reason for the expectation that relevant international criteria should be met before a proposal is agreed and cover sought - it is a sign of political will, institutional capacity, developmental commitment and good faith. The shotgun wedding approach to export credit that we find in the case of the Ilisu Dam does not in our view bode well for the implementation of commitments but is rather the worst form of export credit practice ... We do not believe that fundamental conditions met at the last minute, and only as a result of export credit agency pressure, can be treated seriously."

The Mission agrees; and would argue that the institutional failures identified by the International Development Committee will not be rectified whilst export credit agencies lack mandatory, transparent and legally-enforcible human rights, environmental and development standards. Without such standards, in the Mission's view, ECAs are operating in an effective policy vacuum, with staff and exporters alike denied a clear set of rules to abide by. Under such circumstances, the pressure to disregard human rights and environmental concerns will remain.

The Mission recommends that, at a minimum, export credit agencies should introduce:

• A restrictive list of projects which will not be considered for support because of their established adverse environmental, human rights or development impacts;
• A positive list of projects which will receive favourable consideration because of their contribution to the national and international sustainable development objectives;
• Mandatory human rights, environmental and development standards, drawn up in consultation with project-affected communities and civil society and aimed, inter alia, at ensuring that all projects which pass the initial screening process
  • have the minimum impact on the environment;
  • safeguard the lives and livelihoods of those directly affected by ECA-backed loans;
  • minimise the need for resettlement and ensure that those resettled are better off than prior to the project;
  • assess alternatives to the proposed project, including the option of the project not being implemented;
  • ensure the full and active participation of affected people and interested groups in the decision-making process surrounding the project; and
  • ensure that projects have been rigorously and transparently screened for their full, climate change impacts.
• Internal procedures, including career penalties and rewards, to ensure that inappropriate projects are screened out and that approved projects comply fully with agreed environmental and development standards.
• Transparent decision-making procedures that permit public scrutiny of, and input into, the approval, implementation and operation of ECA-supported projects.

The Mission believes that such standards would not only provide exporters the certainty they need in order to plan ahead but would also enhance policy coherence within government, particularly with respect to human rights and the environment. In addition, they would provide the public - and project affected people - with the legal means of holding ECAs to account for the impacts of the projects they support.

The OECD Draft Agreement - Failing to Meet the Challenge of Reform

It is therefore of grave concern to the Mission that the some ECAs within the OECD ECA Working Party, which is currently negotiating an agreement on common environmental standards for the export credit agencies of its member governments, oppose mandatory standards in favour of the so-called "benchmarking" proposal, a "pick-and-mix" approach, whereby proposed project standards are simply compared with various international standards and then agreed to on a project-by-project basis.

Not only would such an approach prove bureaucratic, costly and time-consuming for exporters, but it would perpetuate the very institutional failures that have bedevilled Ilisu. Under the draft agreement, which the Mission has reviewed in detail, ECAs will not be required to reject projects that fail to meet international standards but will instead only be encouraged to impose mitigatory measures as conditions for support.²⁰⁶ This is precisely the approach criticised by the International Development Committee (see above pp.100-101).

Of further concern is the discretionary nature of the agreements reached. For example:

• There is no requirement to undertake Environmental Impact Assessments for projects: rather, "members shall, where appropriate, request an EIA for the most sensitive projects identified by their respective screening and scoping procedures;"²⁰⁷
• ECAs are not required to abide by a single set of standards; rather, they "shall use, whenever possible on an agreed basis, examples of best practice," with "national, host government standards, international financial institutions' standards" serving as "reference points, or benchmarks."²⁰⁸ The Mission notes that, on past experience, this is likely to lead to the lowest common denominator and least onerous standards being adopted.

The agreement also eschews any negative or positive listing of projects, requiring only that ECAs "screen all applications in order to identify those projects which may have adverse environmental or social impacts." The Mission believes that such a requirement confuses information gathering with screening; the agreement gives no guidance as to how ECAs should act on the information gathered. No criteria are laid down that would direct staff as to which projects to screen out, or indeed which projects should be positively encouraged. As such, the agreement provides a flimsy and inadequate basis for ensuring that future projects contribute postively to sustainable development.

The procedures laid down in the agreement are also completely lacking in any requirement for transparency or public participation. The choice of standards, for example, does not have to be justified publicly - and is thus not open to even rudimentary public scrutiny.

The Mission concludes that the OECD's proposed reforms fail to respond to the challenges thrown up by Ilisu. Largely discretionary and devoid of legally-binding rules that would weed out unacceptable projects prior to their approval, the agreement will serve to perpetuate the very problems that Ilisu has highlighted. As a result, under the proposed benchmarking approach, the proposed Ilisu dam could be allowed to proceed despite its severe risks to human rights and the environment.

Issue three: Ilisu - a litmus test of the ECGD's and HERMES' commitment to reform

As a result of the public outcry over Ilisu, the ECGD has announced a new set of new "Business Principles" which it argues will address the concerns raised. To its credit, the ECGD has moved beyond the built-in agenda of the OECD export credit negotiations by embracing the need to address human rights and development issues, in addition to environmental impacts. However, in the Mission's view, the reforms embodied in the Business Principles fall far short of a credible and coherent response to the growing public concern over the ECGD's activities. In particular:

• The legal status of the Business Principles is unclear;
• The Business Principles are largely discretionary; as such, they fail to provide the incentives, penalties and binding rules that would make them a suitable instrument for governing the ECGD's business practice;

A further deficiency is that the Business Principles commit the ECGD to very little. On sustainable development, for example, the ECGD merely undertakes to "increase its awareness and understanding of project impacts, including environmental, social and human rights issues."²⁰⁹ The Principles also commit the ECGD to a policy of "constructive engagement", with the aim of improving projects in which it is involved, without providing any guidance as to how this will be achieved without a repetition of the "band aid" approach that has characterised Ilisu.

The Principles also lack enforcement mechanisms. No staff incentives and sanctions are laid down to ensure that the principles are acted upon. No guidelines are provided for implementing the Principles and there are no mandatory standards which staff are required to follow. In addition, no role is given to affected communities in the decision-making process on projects. There is no requirement for the ECGD to consult project-affected communities and those adversely affected by ECGD-backed projects will still be denied automatic means of redress.

Despite these deficiencies, the Mission believes that the Principles signal a new direction in ECGD practice. In particular, the Mission welcomes the ECGD's undertaking to "ensure that our activities take into account the government's international policies, including those on sustainable development, environment, human rights, good governance and trade."²¹⁰ The Mission believes that continued support for Ilisu would be in breach of both the spirit and the letter of this commitment. In particular, the continuing denial of civil, political and human rights in Southeast Turkey brings Ilisu into flagrant conflict with the UK's stated commitment to an ethical foreign policy. The Mission thus views Ilisu as a litmus test of the ECGD's commitment to its new objectives: proceeding with the project would signal a fatal lack of purpose in reforming the ECGD and in embracing the principles of sustainable development, as espoused by the UK government.

In Germany, the Government of the Social Democrat Party and the Party of Buendnis 90/Die Gruenen (The Greens) announced in its coalition agreement of October 1998 that it would "initiate reform of foreign trade promotion, especially the granting of export credit guarantees (Hermes) according to environmental, social and developmental criteria". In January 2001, the government published its first draft of the new policy proposal.

While the Mission welcomes the German government's commitment to initiating environmental, social and developmental criteria into Hermes' granting guidelines, it is deeply concerned about the proposal now presented.

The only binding standards mentioned in the current proposal are those of the importing country. However, as the Ilisu project shows, environmental legislation and its implementation in developing and transitional countries are often inadequate. The observance of World Bank standards therefore only presents a minimal criterion that should be upheld in projects that apply for a Hermes guarantee from the very beginning of project planning. Ilisu is a sad example of belated attempts to bring a project up to international standards by means of imposed conditions. The exercise is both time-consuming and not likely to render the desired results in any case.

This lack of binding standards is especially worrying in light of the fact that all projects with a German contribution of less than 20 per cent are exempt from screening. If this was the rule with other ECAs as well, a case like Ilisu, where no country alone takes a 20 per cent share, could have gone ahead without even rudimentary examination despite the severe environmental, social and human rights impacts that are set out in this report.

As the ECGD's report on the Ilisu Environmental Impact Assessment highlights, it is essential to have both clear criteria for the drafting of an EIA as well as sufficient capacity to evaluate those EIAs submitted. The draft guideline, however, leaves open the question of which kinds of environmental studies should be prepared for which kinds of projects.

As far as developing an adequate enviromental guideline therefore, the Mission recommends that a minimum baseline include a comprehensive screening procedure for all guarantee applications, the creation of independent EIAs according to clearly defined international standards for projects which pose threats to a country's environmental, social and human rights situation, and the observance of World Bank standards at an early stage of the project design. Meanwhile, as the announced Hermes reforms have not yet been implemented in a substantial way, the Ilisu project remains a central test case for the German Government's willingness to respect environmental, social and human rights criteria in its guarantee policy.

The Mission's Recommendations

In the light of its findings, the Mission will be pressing the ECAs involved in Ilisu to refuse export credit support for the project. In addition, it urges the Turkish Government to consider alternatives to large dam projects like Ilisu that would not impose increased hardship or threaten internal displacement of its Kurdish citizens and other minorities. Alternatives to Ilisu exist - for example, by addressing the 15-25% electricity losses through poor transmission. The Mission also urges the Government to respond to calls for peaceful, political solutions to the Kurdish question.

More generally, the Mission recommends a deep reform of current export credit agency practice. In particular, it urges ECAs:

1. To adopt the proposals set forth in the "Jakarta Declaration for Reform of Official Export Credit and Investment Insurance Agencies," which is supported by over 300 NGOs world-wide;
2. Accordingly to adopt mandatory, legally-binding standards, with accompanying "positive" and "restrictive" screening procedures, that would weed out projects that did not meet international environmental, development and human rights standards prior to their being considered for support and ensure compliance with those standards once support has been approved;
3. Adopt the Report of the World Commission on Dams and endeavour to ensure that all future hydropower contracts in which they are involved comply with the Set of Guidelines for Good Practice (contained in Chapter 9 of the Report). At a minimum, companies seeking support for projects involving dams should be required to explain why specific WCD principles and guidelines are held to not be applicable and attach this explanation as an appendix to the project's Environmental Impact Assessment;
4. To undertake and make public a human rights assessment of any project for which export credit support is being considered, detailing the extent of compliance by the national government with international human rights agreements and standards.

Notes and references

1 Balfour Beatty, "The Ilisu Dam Project: Information for Shareholders", London, 9 May 2000.

2 Kudat, A, "Ilisu Dam's Resettlement Action Plan (RAP) - Achieving International Best Practice", Working Document, Distributed to ECAs, 16 August 2000. Hereafter: Kudat Report.

3 The GAP project was first launched in 1977, when the DSI drew together all its planned programmes for the Euphrates and Tigris basins under one package. In 1989, the Turkish government established the Southeastern Anatolia Project Regional Development Administration (GAPRDA) to oversee the GAP project and to ensure co-ordination between the agencies and institutions concerned. The GAP Higher Board is the most senior decision-making body of GAPRDA and is responsible for decisions pertaining to planning, design and work programmes. The Board is headed by the Minister of State in charge of the GAP, the Minister of State responsible for the State Planning Organisation and the Minister for Public Works and Reconstruction.

4 Balfour Beatty, "The Ilisu Dam Project: Information for Shareholders", London, 9 May 2000.

5 Five firms undertook the design for the dam. Of these one was Turkish and four were foreign, including three from the United Kingdom, among them James Williamson and Partners, and Kennedy and Donkin. See: Turkish Embassy, Altinbilek, D., "The Ilisu Dam Project", in Water and Development in Southeastern Anatolia: Essay on the Ilisu Dam and GAP, London, 2000, p.31.

6 McDowall, David, A Modern History of the Kurds, London, 2000, p. 444.

7 The World Bank declined to fund any GAP projects in 1984, reportedly for environmental reasons and because of fears it would increase the danger of cross-border conflict with Turkey's neighbours to the south. The Director General of the DSI also acknowledges that a prime reason why the World Bank (and other multilateral development banks) have fought shy of funding the GAP is the ongoing conflict in the region: "If there is tension in the area, then yes, the World Bank, for example, will not wish to become associated with the project." See: Turkish Embassy, Water and Development in Southeastern Anatolia: Essay on the Ilisu Dam and GAP, London, 2000, p.69.

8 Balfour Beatty, "The Ilisu Dam Project: Information for Shareholders", London, 9 May 2000.

9 Bosshard, P. "A Test Case of International Policy Coherence: A Case Study of the Ilisu Hydropower Project (Turkey)", Berne Declaration, Zurich, March 1999, p.1.

10 Altinbilek, D., "The Ilisu Dam Project", in Turkish Embassy, Water and Development in Southeastern Anatolia: Essay on the Ilisu Dam and GAP, London, 2000, p.31. Also pers. com. between Kate Geary, Ilisu Dam Campaign, and Chris Scott, Binnie Black and Veatch, 1st February 2000.

11 According to Balfour Beatty, "The contract between DSI and the construction consortium is still under negotiation. No construction work will go ahead unless and until negotiations are completed, not only on the contract but also on the environmental mitigation measures required by the project and on the financing ... This is not expected before Spring 2001." Balfour Beatty, "The Ilisu Dam Project: Information for Shareholders", London, 9 May 2000.

12 Marsh, P., "ABB focuses on 'green' energy to boost revenues", Financial Times, 9 June 2000.

13 See for example: Berne Declaration, High Risk - Low Return? ABB's Hydropower Strategy under Review, February 1998.

14 Ucar, C., "Skanska withdraws from the Ilisu project, saying it will harm both the people and the environment", Kurdish Observer, 30 September 2000.

15 Brown, P., "Swedish firm deals blow to British-backed dam project", The Guardian, 26 September 2000.

16 Sources interviewed by the Fact Finding Mission strongly suggest that the company's decision was prompted by concerns that the project would not be able to meet international standards.

17 Lang, C., Hildyard, N., Geary, K., Grainger, M., Dams Incorporated: The Record of Twelve European Dam Building Companies, A Report by The Corner House, Swedish Society for Nature Conservation, Stockholm, 2000.

18 "Fighting Graft: Clear Laws and Firm Enforcement are Essential Weapons", Asia Now - Asia Week. Web site accessed 13 February 2000. See also: Burt, T., "BICC appeals over contracts ban", The Financial Times, 16 February 1996.

19 Balfour Beatty, "The Ilisu Dam Project: Information for Shareholders", 9 May 2000, p.1.

20 Set up to assist companies to export capital and project-related goods and services, Export Credit Agencies provide companies with government-backed insurance against the main commercial and political risks of operating abroad, in particular, of not being paid by their creditors. To obtain an export credit guarantee, the exporter takes out insurance with an ECA, which undertakes to pay the exporter for the exported goods should the importer default on payment. If it does have to pay up, the ECA passes on any debt that is not covered by the premiums it has received to the government of the importing country, adding it to the stock of bilateral debt owed to the ECA's home government.

21 When the Swiss government approved its guarantee, it requested that resettlement for the project comply with international standards, and be regularly monitored through an independent body. The guarantee was only to be ratified once the Ilisu consortium, the Turkish government and the ECAs involved had agreed on, and established, a mechanism to achieve this. According to a Swiss government spokesperson, the same condition was supported by the German, Swedish and US governments.

22 Export-Import Bank of the United States, "Summary of Minutes of Meeting of Board of Directors", 20 January 1999.

23 GAP/UNDP, "GAP - Sustainable Development Programme", Annex 1 - Project 24 "Sustainable Urban Living and Social Development Programmes in Batman", GAP, 1997, p.60.

24 Bosshard, P. "A Test Case of International Policy Coherence: A Case Study of the Ilisu Hydropower Project (Turkey)", Berne Declaration, Zurich, March 1999; Kurdish Human Rights Project, The Ilisu Dam - A Human Rights Disaster in the Making, A report on the implications of the Ilisu Hydro-Electric Power Project, Batman Province, Southeast Turkey, London, November 1999.

25 See for example: International Development Committee (IDC), "ECGD, Developmental Issues and the Ilisu Dam: Report together with Proceedings of the Committee, Minutes of Evidence and Appendix", Sixth Report, House of Commons, Session 1999-2000, The Stationary Office, London - hereafter International Development Committee: Trade and Industry Committee, "Application for support from ECGD for UK participation in the Ilisu Dam Project: Report, together with Proceedings of the Committee, Minutes of Evidence and Appendices", House of Commons, Session 1999-2000, The Stationary Office, London, 2000.

26 International Development Committee, "ECGD, Development Issues and the Ilisu Dam", Sixth Report, Session 1999-2000, House of Commons, The Stationary Office, London, July 2000, p.vii. Hereafter: International Development Committee - Sixth Report.

27 Ann Clwyd reported that her visit had left her "disgusted" at the Turkish government's lack of meaningful consultation with the thousands who will be affected by what she called "this miserable dam" and "shocked" at the scale of human misery and suffering that Ilisu would unleash. The dam, she said, would "result in serious human rights abuses for the Kurdish minority, cause environmental havoc and could even spark off war in the region." See: Ann Clwyd, "Stop this Miserable Dam - Ann Clwyd Returns from Turkey", Press Release, 17 July 2000.

28 Report of Journey of the Fact-Finding Mission of the Human Rights Committee of the German parliament to Turkey, 19-26 November 2000.

29 Many have moved to the urban areas: the population of Diyarbakir has grown from 300,000 in 1990 to more than 1.2 million today, bringing a climate of unemployment, currently estimated at 60%, and the development of shanty town areas. Others have moved to western Turkey, and some to join their families in western Europe.

30 See Kurdish Human Rights Project, "Mentes and others v Turkey, a KHRP case report on village destruction in Turkey", September 1998.

31 US State Department, "Country Reports on Human Rights Practices 2000: Turkey", February 2001.

32 Insan Haklari Dernegi (IHD), "Human Rights Report on the First Six Months of the Year 2000", p. 3.

33 McDowall, David. "Turkey in Europe: Opportunity for Change?" Kurdish Human Rights Project, London, 2000

34 In February 2000, for example, the Mayor of Hasankeyf was forced to cut short a visit to Europe after receiving anonymous threats. The Mayor had been scheduled to talk to officials of all German ministries responsible for the granting of a Hermes guarantee, several members of the German parliament as well as the Minister responsible for the UK's Export Credits Guarantee Department (ECGD).

35 International Development Committee, Sixth Report, p.ix

36 International Development Committee, "Exchange of Letter Concerning the Ilisu dam", Fourth Special Report, House of Commons, Session 1999-2000, The Stationary Office, London, July 2000.

37 The nine provinces are: Gaziantep, Diyarbakir, Sanliurfa, Mardin, Adiyaman, Batman, Kilis, Sirnak and Siirt.

38 According to the GAP administration, just over 50 per cent of this figure will be spent on dams and irrigation infrastructure. As of February 2000 - thirty years after the project was first launched - the Turkish government had raised just 43.3 of the total projected expenditure. See: Olcay Unver, "The Southeastern Anatolia Project (GAP): An Overview", in Turkish Embassy , Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, pp.14-15.

39 Embassy of the Republic of Turkey, Washington DC, www.turkey.org/ Cited in: Sahan, E., Mason, S., Gilli, A., Zogg, A., "Southeastern Anatolia Project in Turkey - GAP, Swiss Federal Institute of Technology Zurich, 2000, p.1.

40 The figure of 27 billion kilowatt hours of electricity takes no account of abstraction of water for irrigation. Once this is taken into account, the figure would be reduced. See: Olcay Unver, "The Southeastern Anatolia Project (GAP): An Overview", in Turkish Embassy, Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, pp.15-16.

41 Southeastern Anatolia Regional Development Administration www.gap.gov.tr. Cited in: Sahan, E., Mason, S., Gilli, A., Zogg, A., "Southeastern Anatolia Project in Turkey - GAP, Swiss Federal Institute of Technology Zurich, 2000.

42 Altinbilek, D., "The Ilisu Dam Project" in Turkish Embassy, Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.30.

43 Unver, O, "The Southeastern Anatolia Project (GAP): An Overview" in Turkish Embassy, Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.19.

44 Unver, O, "The Southeastern Anatolia Project (GAP): An Overview" in Turkish Embassy, Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.16.

45 According to the GAP Administration, "a little over $2 billion has come from international institutions and the equivalent of 1.5 billion is coming from a build, operate and transfer scheme on the Euphrates river from a European consortium".

46 Unver, O, "The Southeastern Anatolia Project (GAP): An Overview" in Turkish Embassy, Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.17.

47 "Turkey set to re-examine the GAP", International Water Power and Dam Construction, September 1999.

48 "GAP is causing barrenness of the soil", Ozgur Politika, 28 April 2000

49 In a report on Turkey published by the United nations Development Programme (UNDP) is 1997, the authors noted that the highest poverty rates in Turkey were to be found in the east and south east. See: www.undp.org/rbec/pubs/nhdr97/summary/turkey.htm. See also: Olcay Unver, "The Southeastern Anatolia Project (GAP): An Overview", in Turkish Embassy International Water Power and Dam Construction, London, 2000, pp.13-14. See also: "Turkey set to re-examine the GAP", International Water Power and Dam Construction, September 1999.

50 Until 1997, plans to develop the Tigris and Euphrates were not coordinated. In 1977, the State Hydraulics Works brought the various projects planned for the two river basins under a single authority, entitled "GAP".

51 Quoted in ECGD, "Stakeholders' Attitudes to Involuntary Resettlement in the Context of the Ilisu Dam Project, Turkey", Department of Trade and Industry, London, 1999, p.25.

52 Marsh, N., "Wars Downstream", UK Defence Forum, www.ukdf.org.uk/ts5.htm

53 Rugman, J., "Turkish dam tests Cook's ethical vow", The Observer, 8 August 1999.

54 McDowall, D., "Ilisu: the economic and political context", www.ilisu.org.uk

55 Altinbilek, D., "The Ilisu Dam Project" in Turkish Embassy, Water Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP", Lodon, 2000, p.30.

56 Juniper, T., "Stuffing Turkey", The Ecologist, Vol. 30 - No. 6, September 2000, p.52.

57 Kudat, A., "Ilisu Dam's Resettlement Action Plan (RAP) - Achieving International Best Practice", Distributed to Export Credit Agencies 16 August 2000, unpublished - hereafter, Kudat. The total figure of 183 settlements appears on p.18. This would appear to include hamlets: the number of villages affected is given as 56 (p.3).

58 World Bank policy states: "Involuntary resettlement is an integral part of project design and should be dealt with from the earliest stages of project preparation."

59 ECGD, "Stakeholders' Attitudes to Involuntary Resettlement in the Context of the Ilisu Dam Project, Turkey", London, 1999, para. 3.6

60 Ibid, p.19.

61 Ibid, p.29

62 Ibid, p.51.

63 Ibid, "Summary and recommendations", unnumbered.

64 Ibid, p.51.

65 Ibid, p.14, footnote 7.

66 Kudat, p. 27.

67 Kudat, p. 6.

68 World Bank guidelines state: "Involuntary resettlement should be avoided or minimised where feasible, exploring all viable alternative project designs."68 The OECD's Development Assistance Committee guidelines, which the UK government says it will use to assess the project, go further: "Alternatives to displacement and resettlement should be fully considered before decisions on displacement and resettlement are taken... In every case, the alternative to refrain from carrying out the project (the "non-action" alternative) should seriously be considered".

69 Kudat, p.10

70 Richard Caborn letter to Kate Geary, Ilisu Dam Campaign Co-ordinator, 5 December 2000.

71 Balfour Beatty, The Ilisu Dam Project: Information for Shareholders", 9 May 2000, p.2.

72 Balfour Beatty, "Ilisu dam and hydro-electric power project: project briefing", July 1999.

73 ERM concluded: "The scope of work to date would need to be extended to bring the analysis to international best standards."

74 ECGD, Environmental Review of Ilisu Dam Project: Desk Review of EIA and Associated Documents, Environmental Resources Management, London, 1999, p.13.

75 Ibid, p.13.

76 Ibid, p.14

77 Ibid, p.1

78 For further information on Hasankeyf, see Appendix 3, (Ancient City of Hasankeyf booklet) and the Hasankeyf website http://www.hasankeyf.cjb.net

79 Bosshard, P. "A Test Case of International Policy Coherence: A Case Study of the Ilisu Hydropower Project (Turkey)", Berne Declaration, Zurich, March 1999.

80 Balfour Beatty, "Ilisu dam and hydro-electric power project", July 1999, p.15

81 ibid

82 UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage adopted 16 November 1972.

83 Letter from Martin Hall, President of the World Archaeological Congress to Prime Minister Tony Blair, 16 January 2001.

84 WAC notes: "Hundreds of different cultural sites, dating to every period of human history, fall within the total catchment area of the proposed dam reservoir, and are therefore threatened with destruction through inundation, or associated construction and irrigation works. Individual sites of local, regional and international significance include examples dating to the Neolithic, Chalcolithic, Neo-Assyrian, Late Roman, Byzantine and later medieval periods respectively. Many other sites of crucial importance to any adequate understanding of the more recent histories of the local populations in this region, including ancestral graveyards, are also under threat of destruction and/or prevention of access."

85 Young, P., "Hasankeyf - A City in Peril", History Today, November 2000.

86 Quoted in Bosshard, P., "The Ilisu Forum: An NGO Perspective - Vested Interests and Politics", International Water Power and Dam Construction, April 2000, p.36.

87 Asharq Al-Awsat,12 February 2001

88 Turkey had originally announced that the flow would be blocked for 16 days but relented after protests from Syria and Iraq. See: Turkish Embassy, Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London 2000, pp. 68-69.

89 Channel 4, "Thirsting for Water", 30 September 2000, directed by Christopher Mitchell. A higher figure is given by Mohammed AL-Najim of the School of African and Oriental Studies, London: "The water problem of Tigris and Euphrastes rivers is being seriously affected by ... GAP. The emerging effects are that the water volume, at the entrance point on the Syrian border, has now been decreased to half of its original amount". See: AL-Najim, "Tigris-Euphrates Water - Political, Economical and Regional Relations", SOAS, University of London, unpublished.

90 Christopher Walker, "Mubarak acts as Turk move rattles Syria", The Times, 5 October 1998

91 Marsh, N., "Water Wars", UK Defence Forum, p.6 www.ukdf.org.uk/ts5.htm

92 Balfour Beatty, "Ilisu dam and hydro-electric power project", July 1999

93 Juniper, J., "Stuffing Turkey", The Ecologist, Vol.30, No. 6, September 2000, p.53.

94 Friends of the Earth, "In the Matter of an Application Pursuant to Export and Investment Guarantees Act and in the Matter of the Proposed Ilisu Dam", Unpublished Legal Opinion, 2000.

95 Ibid.

96 Turan, I., "International Aspects of Water Issues", in Turkish Embassy, op.cit., p.41.

97 Letter to Friends of the Earth from Nasser Kaddour, Syrian Minister of State for Foreign Affairs, 3 July 2000.

98 L.N. AL-Saidi, Iraqi Interests Section, Embassy of the Hashemite Kingdom of Jordan, Letter to Friends of the Earth, 24 March 1999.

99 Dr. Fahmy AL-Qaysi, Director of Legal Department, Ministry of Foreign Affairs, Letter to Friends of the Earth, 18 August 2000.

100 House of Commons Trade and Industry Committee, "Government observations on the Sixth Report from the Trade and Industry Committee (Session 1999-2000)", House of Commons Stationary Office, London, 2000.

101 The conditions do not stipulate the standards against which compliance with this condition will be measured. However, the standards most commonly cited by the ECAs are those of the World Bank and the OECD's Development Assistance Committee. For further discussion, see Section 3.

102 The German Ministry of Finance, failing to do an independent assessment of their own, absurdly set the number of people to be resettled at 8,000 as of December 1999.

103 Kudat, A., "Ilisu Dam's Resettlement Action Plan (RAP) - Achieving International Best Practice", Distributed to Export Credit Agencies 16 August 2000, unpublished - hereafter, Kudat, p.26.

104 Ibid, p.24.

105 Altinbilek, D., "The Ilisu Dam Project" in Turkish Embassy, Water and Development in Southeastern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.34.

106 Balfour Beatty, The Ilisu Dam Project: Information for Shareholders, 9 May 2000, p.3.

107 Kudat, p.26.

108 Kudat, p.25.

109 Kudat, p.6

110 Balfour Beatty, "Ilisu Hydro-electric Power Plant (HEPP), Turkey", Outline Briefing Paper, June 1999, p.7.

111 Professor Dogan Altinbilek, Director-General of the DSI, told a seminar held at the Turkish Embassy in London in February 2000: "In the course of building 197 large dams, as well as many much smaller, we have never proceeded without first reaching an arrangement with the local people." See: Turkish Embassy, Water and Development in Southeatern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.32.

112 Yasinok, K., "Participatory Resettlement in GAP: A Case Study", in Turkish Embassy, Water and Development in Southeatern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.22.

113 This box draws substantially from: Jim Bodgener, "Birecik dam opens BOT floodgates" , Middle East Economic Digest, December 1, 1995

114 "672-MW, $1.6-billion Birecik Project in Turkey reaches financial close" , Independent Power Report, November 17, 1995

115 "Bank of America strikes deals in US and Europe", Petroleum Economist, August 2000

116 Yasinok, K., "Participatory Resettlement in GAP: A Case Study", in Turkish Embassy, Water and Development in Southeatern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, pp. 22, 24, 25, 28.

117 Interview, 12 October 2000. Refugees displaced by the war also stressed to the Mission the importance of ancestral graves in their lives. As one woman put it when explaining why she wanted to return to her burned out village: "We want to go back home to the bones of our fathers."

118 Ackermann, W., "Summary and Recommendations" in Ackermann, W. et al., Man-Made Lakes: Their Problems and Environmental Effects, American Geophysical Union, Washington, DC, 1973, p.28.

119 Planners and water bureaucrats tend to view land merely as a commodity, one piece being easily exchanged with another or for cash. They may fail to comprehend its spiritual and emotional significance for many people, both indigenous and non-indigenous. Moving from one piece of land to another is thus seen as unproblematic. For example, Ernest Ravan of the International Institute for Hydraulic and Environmental Engineering notes: "Dams are not planned to submerge highly developed areas. Often the quality of life of the displaced indigenous population was low, and therefore could be an opportunity to improve living standards; the construction of large dams can sometimes prove such an opportunity. If the people prefer, however, to continue living as they have in the past, they can do so by moving upstream in the river valley."

120 Bosshard, P. "A Test Case of International Policy Coherence: A Case Study of the Ilisu Hydropower Project (Turkey)", Berne Declaration, Zurich, March 1999, p.3.

121 Interview - Chamber of Architects, 12 October 2000.

122 Kudat, p.26.

123 World Bank, Operational Directive 4.3(8)

124 World Bank, Operational Directive 4.3(11)

125 World Bank, Operational Directive 4.30

126 Kudat, p.21.

127 World Bank Operational Directive 4.3

128 World Bank Operational Directive 4.3 (4)

129 Kudat, p.31.

130 World Bank Operational Directive 4.3 (3b). The World Bank and the OECD both state: "All involuntary resettlement should be conceived and executed as development programmes, with resettlers provided sufficient investment resources and opportunities to share in project benefits. Displaced persons should be ... assisted in their efforts to improve their former living standards, income earning capacity and production levels, or at least restore them."

131 World Bank, Operational Directive 4.3(18)

132 Kudat, p.7.

133 Kudat, p.16

134 Kudat, p.22.

135 Kudat, p.25

136 Kudat, p.25

137 Kudat, p.25-26.

138 Although most commentators agree that inflation works against those resettled, Professor Dogan Altinbilek, Director-General of DSI, disagrees: "If a person chooses to go to an urban settlement, they are provided with a house and rehabilitated in this new area ... As to repayment, the first five years is a grace period. Without being charged interest, they must then repay for any new houses they are given. In a country where inflation is more than 50 per cent, this is just like a gift, because after 20 years, the original investment is next to nothing." This analysis ignores the fact that the vast majority of those resettled were not making any repayments on the houses they lived in before they were moved. See: Altinbilek, D. "The Ilisu Dam Project", in Turkish Embassy, Water and Development in Southeatern Anatolia: Essays on the Ilisu Dam and GAP, London, 2000, p.33.

139 Kudat, p. 30.

140 Interview with displaced villagers, 11 October 2000

141 Letter to Heinz Lienhard, Sulzer Hydro, from the Berne Declaration and others, 6 October 1999.

142 Environentmental Resources Management, "Environmental Review of Ilisu Dam Project: Desk Review of EIA and Associated Documents", Report commissioned by UK Export Credits Gruarantee Department, December 2000, p. 9.

143 Interview with Chamber of Architects, Diyarbakir, 13 October 2000.

144 Lean, G., "Dam backed by Blair flouts international law, says Syria", The Independent on Sunday, 16 July 2000.

145 See Water Power & Dam Construction, Willington Publishing Ltd., 30 September 2000.

146 Interview with members of Diyarbakir Bar Association, 13 October 2000.

147 Several of those interviewed noted, with irony, that Hasankeyf's protected status was regularly invoked to prevent people from building new houses in the town. This has limited the possibility of tourism, which could provide a valuable source of income for local people.

148 Most of the people of Hasankeyf born before 1967 were born and lived in the caves - this applies to an estimated 80 per cent of Hasankeyf's inhabitants.

149 Arik cited in Young, P., "Hasankeyf: a city in peril", History Today, November 2000, volume 50(11), pp.3-4.

150 There are some grounds for believing thjat the UK government has accepted the wider impacts of Ilisu. In a letter of 21st January 2000, Richard Caborn, the Minister of state responsible for ECGD, states: "We expect that the [Environmental Impact Assessment Review] will include more information on the proposals for the salvage archaeology for Ilisu. You may also be aware of the publication last year of "Salvage Project of the Archaeological Heritage of the Ilisu and Carchemish Dam Reservoirs Activities in 1998" (ISBN 975-429-152-7). Although this concentrates on Carchemish, as this is impounding first, it does make clear that preliminary work on the salvage archaeology associated with Ilisu has commenced and will extend beyond Hasankeyf. We have been told that the report of the activities in 1999 will be published shortly".

151 ICOMOS 2000, Heritage at Risk. ICOMOS World Report 2000 on Monuments and Sites in Danger, K.G. Saur, München, 2000.

152 It is generally understood that the standards referred to are those of the World Bank and the OECD's Development Assistance Committee. Other international standards also cover forced resettlement. Article 11 of the International Covenant on Economic, Social and Cultural Rights covers the right to adequate standard of living, including the right to adequate housing. There is a very clear General Comment on Forced Evictions which sets out stringent measures that governments (including donors) need to take action to minimise harm to affected groups and individuals. Article 22 of the ICESCR places an obligation on the international community including multilateral and bilateral donors to ensure that development cooperation is "advisable" and does not erode people's rights (in the context of displacement of Kurds at a time of such instability in the region, as ECAs must be aware, the potential for misinterpretations of the resettlement of the population even in optimal circumstances is obvious).

153 Keynote address of Chris Mullin MP, Parliamentary Under-secretary of State for International Development to Institute of Civil Engineers /British Dams Society Seminar, "After the World Commission ... Dams in the Future", 1st February 2001.

154 Ex-Im Bank, "Environmental Procedures and Guidelines", Table 9, Hydropower and Water Resources Management (Dams and Reservoirs) - Draft, unnumbered, Washington, January 2001.

155 A number of international companies, including ABB, Alstom, Atlas Copco, Coyne & Bellier, Enron, Harza, Hydro-Quebec, Lahmeyer, Voith Siemens and Skanska, all assisted the WCD in developing guidelines for the future of water and energy development.

156 World Commission on Dams, : "In the past 30 years resettlement was [only] provided for about 100 families annually.", Earthscan, November 2000, p.279.

157 Ibid, p.217.

158 Ibid, p.218.

159 Ibid, p.279. "The government planning body sponsoring the planned interventions is responsible for initiating the stakeholder analysis leading to the constitution of a forum and will participate in it. The final structure of a stakeholder forum should be decided upon in a consultative process."

160 Ibid, p.271.

161 Ibid, p.280.

162 Ibid, p.280: "Authorities should make available adequate financial resources to enable stakeholder groups who are politically or financially weak, or who lack technical expertise or organised representation to participate effectively in the process."

163 Ibid, p.217.

164 Ibid, p.218.

165 Ibid, p.217.

166 Ibid, p.217.

167 Ibid, p.217.

168 Ibid, p.269 and p. 268: "Meaningful participation in preparatory studies is central to the success of the investigation and the ultimate outcome ... Preliminary negotiations with project-affected people, their community representatives, and other stakeholders are central to the preparatory studies in considering mitigation measures for any unavoidable adverse impacts and investigating benefit sharing plans."

169 Ibid, p.221.

170 Ibid, p.224 (italics added).

171 Export Credits Guarantee Department, "Stakeholders' Attitudes to Involuntary Resettlement in the Context of the Ilisu Dam Project, Turkey", Summary and Recommendations", unnumbered.

172 "Drought causes energy deficit for Turkey", International Water Power and Dam Construction, September 2000.

173 International Energy Agency, Turkey - Update, International Energy Agency, Vienna, 2000.

174 Kudat, A., Ilisu Dam's Resettlement Action Plan (RAP) - Achieving International Best Practice", unpublished, circulated to ECAs, August 2000, p.10.

175 Interview with Chamber of Engineers, Diyarabkir, 13 October 2000.

176 Ibid, p.225.

177 Ibid, p.225.

178 Ibid, p.230.

179 Ibid, pp.225-226. The WCD recommends that such evaluations should "be comprehensive, integrated, cumulative and adaptive" and that they should be participatory. Moreover, "where dams are part of a larger river basin and regional development scheme, the evaluations should take into account basin-level evaluation of all project and programme components linked to the dam that affect the environment and society."

180 As Ayse Kudat points out in her preliminary assessment of the draft resettlement action plan for Ilisu: "There are still a large number of people affected by previously constructed dams who are still waiting to be resettled, sometimes for many years." She also notes: "In the past 30 years resettlement was [only] provided for about 100 families annually."

181 Ibid, p.230.

182 The official figure from GAP authorities is 75,000.

183 Until recently the average yearly inflation ratio in Turkey has reached over 50 per cent.

184 This section draws substantially from John Wicks, "Harnessing the waters", SHZ Publications, Switzerland, September 1992

185 The Hydropower component of the dam was planned to generate 8.9 billion KWh of electricity annually before irrigation started; when the first scheme of irrigation went into operation it was expected to generate about 8.1 billion KWh of energy per year. According to project authorities 882.000 hectares of land would be irrigated by the water of the impounded in the Ataturk reservoir: 476.000 hectares by gravity flow through the 57.8 km long Sanliurfa tunnels system and the remaining 406.000 hectares by pumping.

The 166-meter-high and 1664-meter-long Ataturk Dam created a reservoir which has a surface of 817 square km and a total storage capacity of 48.7 million cubic meters.

The Ataturk dam is the ninth-largest rockfilled dam in the world. Construction work started in 1981 and all the eight hydropower units, totalling 2,400 MW installed capacity, came into operation at the end of 1993.

The dam was built downstream of the 1,800 MW Karayaka Dam, the first water scheme downstream of the old Keban Dam built on the Upper Euphrates under the GAP project which was completed in 1988 and cost US$1.2 billion.

186 Two ABB subsidiaries, Asea Brown Boveri AG from Germany and ABB Tecnomasio from Italy, were also awarded contracts.

187 This section draws on an interview with journalist Mehmet Dikec.

188 The closure followed further exposés by the journalist. In particular, a series of articles called for the closure of an illegal chemical dump in the area. A local MP told the journalist, "Who are you to say that? You don't have the right to call for its shutting down."

189 Section based on interviews with two villagers from the Ataturk area: Mustafa Karael from Ercek, (200 inhabitants) and Ali Isik from Nasreddin (250/300 inhabitants). Both villages were submerged in 1992.

190 Zheng Jiinfa, "Southeastern Anatolian Project - miracle for Turkey", The Xinhua General Overseas News Service, July 4th,1989

191 Turkish National News Agency, 27th August 1990

192 Ibid, p.234.

193 Ibid, p.237.

194 Ibid, p.240.

195 Ibid, p.240.

196 Ibid, p.243.

197 Ibid, p.244.

198 Ibid, p.245.

199 Ibid, p.244.

200 Ibid, p.246.

201 Ibid, p.247.

202 Ibid, p.248.

203 Department for International Development, Eliminating World Poverty: A Challenge for the 21st Century, White Paper on International Development, The Stationary Office, London, November 1997, p.50

204 Killing Secrets, "A Force for Good in the World? Labour's Ethical Policy", Killing Secrets Information paper, killsecrets@msn.com, 1997. Robin Cook, the Foreign Secretary, has since denied that he was in fact announcing an "ethical foreign policy". In November 1998, he said: "I've given up trying to get this across. I've never used the phrase. I never said there would be an 'ethical foreign policy'. What we have sought to do is put into effect our values."

205 International Development Committee, "ECGD, Developmental Issues and the Ilisu Dam: Report, together with the Proceedings of the Committee, Minutes of Evidence and Appendix", House of Commons Session 1999-2000, The Stationary Office, London, 2000, p.xiii.

206 "Members shall evaluate all the information and decide whether to provide official support, and if so, whether this shall involve pre-conditions, eg. Mitigation measures, covenants, monitoring requirements." See: Working Party on Export Credits and Credit Guarantees, "Draft Agreement on Common Approaches on Environment and Officially Supported Export Credits Among Members of the Working Party on Export Credits and Credit Guarantees (ECG)", Confidential Draft, OECD, Paris, 6 December 2000, p.6.

207 Ibid, p.6.

208 Ibid, p.6.

209 ECGD, Business principles, ECGD, London, December 2000.

210 ECGD, "Business Principles", December 2000.