59th ADB Annual Meeting — Safeguards and Accountability Concerns in the ADB Urban Transport Electrification Project in Kyrgyzstan
Project information: Kyrgyz Republic: Urban Transport Electrification Project (UTEP, Loan 4149‑KGZ / Grants 0808‑KGZ, 0809‑KGZ, USD 50.65 million)
Prepared by: #BishkekSmog Initiative (Bermet Borubaeva),bishkek.smog@gmail.com, +996 550 869838
Summary of Problem
The ADB-financed Urban Transport Electrification Project (UTEP) in Bishkek was designed to complement—not replace—the city’s existing zero‑emission system of electric transportation (trolleybus). Instead, implementation has resulted in the complete replacement of other electric transport that was funded before by the European Bank for Reconstruction and Development (EBRD, 23,5 mln$). The Bishkek City Hall replaced electric vehicles (trolleybuses) with e-buses through the ADB UTEP project.
UTEP expectations: existing 185 zero‑emission electric vehicles + 120 ADB e-buses = about 300.
UTEP implementation: half of the trolleybus routes have been replaced by ADB e-buses, and half of them now operate with compressed‑natural‑gas (CNG) buses, increasing emissions and economic dependence on imported gas.
FACTS: 1) All trolleybus routes were replaced with electric/gas buses.
2) Six trolleybus routes were replaced by e-buses: № 2, 4, 5, 6, 10, and 11 (However, route № 5 had to be significantly altered to ensure sufficient battery power for operation).
3) Trolleybus routes № 7, 8, 14, and 17 were replaced with gas buses.
Despite ADB’s acknowledgment (letter from Country Director Joonho Hwang, 3 April 2025) that the removal was a unilateral local decision, no enforcement or supervision measures have been taken for more than one year.
The resulting outcomes contradict ADB’s safeguards standards, climate, governance, and gender commitments under its Country Partnership Strategy 2023–2027 and threaten Kyrgyzstan’s Paris Agreement NDC Measure 1.9 (“Expansion of the trolleybus fleet”).
Environmental & Social Harms and Human Rights Violations
Environmental: Zero‑emission fleet reduced; CNG routes emit more than before; Bishkek now ranks among the world’s most air-polluted capitals.
Social and Gender: 600+ workers dismissed without a transition plan, trainings, or fair income support; loss of accessible, low‑floor transport for more than 10 000+ disabled residents, lack of sustainable public transportation.
Governance: Loan covenant ignored, tender records withheld, failure to disclose information, and reports that do not comply with requirements and project indicators.
Human Rights: no access to information, limited access now for people with disabilities, violation of Labour rights, access in decision making, especially for women, environmental rights, and civic space restrictions documented by UN Special Rapporteurs. Lead complainants were several times detained — important that they are women human rights defenders who are the most vulnerable group and most affected by the ADB project.
Core Integrity and Safeguards Issues
- Feasibility Study by Grütter Consulting AG – alleged misrepresentation of data, undeclared conflicts of interest, and pre‑determined pro‑battery‑bus bias. No meaningful consultations and SCO involvement.
- Failure of ADB Supervision – non‑enforcement of covenants despite official admission of breach.
- Obstruction of Access to Information – ignoring the release of project information and monitoring data, contrary to ADB policy.
Requests to the Board
- Check into Grütter Consulting AG, the consultant procurement process, project reports, and all payments for workers were done.
- Verify covenant compliance and coordinate the comparable mitigation plan adopted with trolleybus‑e‑bus complementarity. Was the Transition Action Plan implemented?
- Initiate safeguard assessment of environmental and social outcomes and organize working groups.
- Grant full whistleblower and witness protection under AO 2.10 to civil‑society complainants facing retaliation.
Conclusion
The Bishkek UTEP, intended as a climate and governance flagship, currently delivers climate regression, social harm, and loss of public trust. Early, decisive Board action is essential to uphold ADB’s integrity standards and safeguard the Bank’s climate credibility.
Supporting partners: CEE Bankwatch Network, Bir Duino Kyrgyzstan, IAP, IDEA CA, Association for People with Disabilities (Bishkek)
