Lake Baikal in 2022.
Technical Report compiled by Eugene Simonov
This Report is an updated review of conservation status of Lake Baikal, first published in 2020 in
a collection of papers dedicated to the 25th anniversary of World Natural Heritage in Russia
was updated through monitoring conducted by many conservation activists and scientists. The
manuscript reflects the situation with Lake Baikal conservation as of May 1, 2022
Unique values of the Lake Baikal
Lake Baikal is the oldest (25–30 million years) and deepest (1637 m) freshwater lake on the
planet, with the largest volume of fresh water (23,000 km3). From ancient times, it was revered
as a unique natural phenomenon by many peoples of Asia: Evenks, Mongols, Buryats and
Chinese. In the past, the local Russian population used to refer to Baikal as “the Holy Sea.”
The inscription of Lake Baikal on the World Natural Heritage List took place on 5 December
1996 through a decision made during the 20th session of the UNESCO World Heritage
Committee. The decision adopted by the Committee noted that the Lake is a “limnological
miracle” and a territory that meets all four natural criteria of the Convention concerning the
Protection of the World Cultural and Natural Heritage:
the geological rift system that gave rise to Lake Baikal was formed in the Mesozoic period.
Baikal is the oldest and deepest lake on Earth. Various tectonic forces still continue to operate
here, as is evidenced by the emergence of thermal flows from the depths of the lake.
the evolution of aquatic organisms throughout this long period has led to the formation of a
unique endemic flora and fauna. Lake Baikal is of exceptional value for the study of evolution.
the picturesque landscape around the Baikal basin with mountain ranges, boreal forests, tundra,
lakes, islands and steppes provides an exceptionally picturesque environment. Baikal is the
largest reservoir of fresh water on Earth, containing 20% of all global reserves.
Lake Baikal is one of the most biodiverse lakes on Earth. (According to the inscription
document) It contains 1500 species of animals and plants.
Ongoing inventory keeping has resulted in annual increases in the number of species known in
Lake Baikal. Of the 2595 species and subspecies of animals, 56% are endemic (Timoshkin et al.,
Every year 30–90 km3 of water flows in and out of Lake Baikal. Moreover, the waters flowing in
and out of Lake Baikal are often very different in their hydrochemical and biological
composition. In the deep part (approximately 400 m below the surface), Lake Baikal waters
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satisfy Russian and international quality standards for drinking water supply (Grachev, 2002),
which cannot be said about the waters of many tributaries of Lake Baikal and its shallow waters.
The Lake Baikal World Heritage property covers about 89,000 km2 and includes the Lake itself
and its catchment basin, with the exception of the three largest tributaries—the Selenga,
Barguzin and Upper Angara rivers. In addition, the property does not encompass the four urban
areas on the lake’s shores: Slyudyanka, Baykalsk, Babushkin and Severobaykalsk. The
Barguzinsky, Baikalo-Lensky and Baikalsky State Nature Reserves, Pribaikalsky and
Zabaikalsky National Parks, a small part of Tunkinsky National Park, Kabansky and
Frolikhinsky National Wildlife Refuges, as well as many protected areas of regional significance
that are located inside the property.
Figure 1: Composition of the Lake Baikal WH property.
Legal protection of the World Heritage
A Federal Law “On the Protection of Lake Baikal” was adopted in 1999 for the protection of
Lake Baikal. It defined the Baikal Natural Territory (BNT), which is divided into a Central
Ecological Zone, a Buffer Ecological Zone (remaining watershed inside Russia), and a Zone of
Atmospheric Influence. The Central Ecological Zone corresponds to the area of the World
Heritage property, but also includes four urban areas on the lakeshore. The Federal Law “On the
Protection of Lake Baikal” prescribes that any project in BNT should be subject to a thorough
Environmental Impact Assessment and entitles Russian Government to issue three most
important bylaws (regulations):
1. “On the List of Activities Prohibited in the Central Ecological Zone of the Baikal Natural
Territory” (List of Prohibitions), which limits what industries and land-use types are
allowed at the World Heritage property.
2. “Standards for Allowable Impacts on the Unique Ecosystem of Lake Baikal” (SPI),
which limits impacts from recreation and other important land-uses, but primarily it
limits concentration of pollutants in discharged sewage and lists prohibited toxic
3. “On the Maximum and Minimum Limits of Water Level Fluctuations in Lake Baikal,”
which seeks to prevent mismanagement of Lake Baikal’s water resources via Irkutsk
Hydro dam operations.
The Lake Baikal property is a record holder in terms of violations of the Convention’s
regulations and nonfulfillment of obligations by the State Party to the Convention. Although
Lake Baikal is not included on the List of World Heritage in Danger, decisions regarding the
protection of the property were made during 23 out of 24 Committee sessions held since 1996.
Typically, this much attention is only paid to properties included on the List of World Heritage
In 1996, the International Union for Conservation of Nature (IUCN) assessed the state of Lake
Baikal’s ecosystems as “good,” but pointed to many problems that needed to be addressed. When
Lake Baikal was inscribed on the World Heritage List, several special recommendations were
given to the Russian authorities:
• To adopt and strictly implement the Federal Law “On the Protection of Lake Baikal.”
• To re-profile the Baikalsk Pulp and Paper Mill (BPPM) in order to eliminate the main
source of pollution
• To reduce the discharge of pollutants into the Selenga River
• To increase resource support for the activities of nature reserves and national parks
adjacent to the lake
• To continue supporting research and monitoring of Lake Baikal.
To date, Russia has not fulfilled its original obligations, in particular the obligations to prevent
pollution of the Lake with waste from the Baikalsk Pulp and Paper Mill. The number of negative
impact factors classified by the World Heritage Committee as “threats” requiring immediate
action has grown over the years. While the Committee only identified two types of threats in the
1997 “State of Conservation Report,” the 2021 SoC Report lists seven categories: flaws in the
regulatory framework, regular violations of protection laws (in the field of forest and land use,
illegal construction, etc.), impacts from fires in natural areas, tourism pressure and government-
sponsored development, the unresolved threats from BPPM site , as well as threats from existing
and planned dams.
In February 2022, Russia presented its own official report on the State of Conservation of Lake
Baikal, which states that “No major changes are foreseen within the World Heritage Site”.
Fig. 2 by Vadim Kantor/Greenpeace. Village on the shore of Lake Baikal, 1 Sep, 2003.
Disruptions to the Lake ecosystem
During the last 10 years (2010 − 20), scientists have documented an alarming number of
problems occurring mostly in the near-shore zone of Lake Baikal. This zone is critical to the
health of lakes, because it sequesters nutrients entering from the land, harbors the majority of
lake biodiversity, and it is an essential energy source for lake food webs (Vadeboncoeur et al.,
2011). The serious problems at Lake Baikal include harmful algal blooms triggered by nutrient
pollution, mass mortality of endemic sponges caused by pathogens, pollution from PCB’s and
microplastics, and fluctuating lake levels. Here we describe the scientific understanding of these
problems, their causes and consequences as well as their likely future trajectories.
Enormous blooms of filamentous algae, forming dense mats, blanketing the nearshore substrate
of Lake Baikal were first noticed in 2010–11 at multiple sites (Kravtsova et al., 2014; Timoshkin
et al., 2016). Consisting of a non-native strain of Spirogyra, these blooms usually appear next to
coastal settlements at a depth of 0.5–0.6 m but they can extend downwards to depths of ≥ 20 m.
The blooms clog the nets of fishers and strongly suppress native plant and animal communities
(Rozhkova et al., 2018). In addition, they foul beaches with massive algal wash-ups in some
areas of the lake (e.g., Senogda Bay, Barguzin Bay) making beaches unusable due to the large
pile-ups and stench from the decomposing algae. Untreated human sewage, entering the
nearshore zone via incoming streams and rivers (Khodzher et al., 2017) and contaminated
groundwater, are driving the explosive growth of this nuisance alga, because the sewage contains
excess plant nutrients (nitrogen and phosphorus) that fertilize algal growth (Timoshkin et al.,
2018). The emergence of this problem in the 2010s coincides with a sharp increase in
unregulated tourism and building construction near the lake shore (Timoshkin et al., 2018).
Unfortunately, homes, hotels, and buildings surrounding the lake either lack sewage treatment or
are serviced by unlined cesspools resulting in untreated human sewage moving into groundwater
that then flows into the lake.
Importantly, forest fires also release nutrients that flow from the land into the nearshore zone,
and forest fires have increased dramatically in frequency and spatial extent in the Lake Baikal
region over the last 15–20 years (Kharuk and Ponomarev, 2017; Bondur et al., 2020). Recent
observations in northern Lake Baikal suggest that when fire-released nutrients enter the substrate
of the nearshore zone, they trigger blooms of a filamentous cyanobacteria Tolypothrix,
previously shown to produce the dangerous neurotoxin, saxitoxin, which can cause paralysis or
respiratory failure in birds and mammals when ingested (Belykh et al., 2016).
Mass mortality of the endemic sponges is another hallmark of the ongoing coastal crisis at Lake
Baikal (Timoshkin et al., 2014). First reported in Bormotov (2011), dying and diseased sponges
are now found throughout the lake at depths of 0–40 m where they are succumbing to
opportunistic pathogens (Khanaev et al., 2018; Belikov et al., 2019). The loss of the sponges is
concerning because they are exceptionally efficient filter feeders, and their enormous biomass in
the nearshore zone exceeds that of all other bottom-dwelling macro-organisms by more than 10-
fold (Khozhov, 1972; Pile et al., 1997; Masuda, 2009). Of the lake’s sponges, the branching
sponges (Lubomirskia baicalensis) are most susceptible to the current disease (Belikov et al.,
2019), and it is unknown if they are capable of regeneration. Sadly, the growth rate of this
particular sponge is exceptionally slow so it may take a century before the luxuriant sponge
forests return to their former state.
Industrial pollutants of concern include persistent organic pollutants (POP’s) and the recent
discovery of microplastics in the lake’s water (Mamontova et al., 2020; Karnaukhov et al.,
2020). Fortunately, POP concentrations in the pups of the Baikal seal (or nerpa) (Pusa sibirica)
have generally declined since high levels were first reported in the 1990s (e.g., Nakata et al.,
1995; Grosheva and Surnina, 1998), but localized groups of people who consume seal meat and
use its blubber as a feed supplement for chickens and cows from which eggs and milk are
consumed are at a high risk of cancer (Mamontova et al., 2020 Microplastics were recently
detected in the water of L. Baikal (Karnaukhov et al. 2020; Il’ina et al. 2021); however, Moore et al.
(2022), using more precise methods, found that concentrations are 100-1000x greater than those
reported in the earlier studies. Highest concentrations occurred in Maloe More where tourism is most
concentrated. The chemical composition of the microplastics strongly suggests their origin is the
fragmentation of plastic rubbish, highlighting the need for solid waste infrastructure that is lacking
around most of the lake (Moore et al. 2022). This pollutant is of concern, because recent work shows
that gammarids, represented by nearly 300 endemic species in L. Baikal, can fragment microplastics into
very tiny pieces (< 1 µm). Such very small microplastic fragments may cross cell membranes and
bioaccumulate in plant and animal tissue (Mateos- Cárdenas A. et al. 2020)
Fig. 3 by Andrey Suknev. Near-shore waters experience severe algal blooms.
Fluctuations in lake level are an increasing threat for Lake Baikal and they will exacerbate
nearshore nutrient pollution described above. Both the increased frequency of flooding and
extended droughts caused by climate change and the manipulation of natural lake levels by the
Irkutsk hydroelectric dam located on the Lake’s sole river outlet (Angara River), will magnify
lake level fluctuations and change their temporal dynamics (Zohary and Ostrovsky, 2011).
Abnormally low and high lake levels each separately contribute to coastal nutrient pollution
which is already a serious problem at Lake Baikal due to the lack of sewage treatment. When
lake level falls, a hydraulic gradient is established that pulls groundwater into the nearshore zone.
If the groundwater is contaminated with nutrients, as it is at localized sites around Lake Baikal
(Timoshkin et al., 2018), coastal eutrophication results (Naranjo et al., 2019). Likewise,
abnormally high lake levels resulting from flooding or the insufficient release of lake water
through the Irkutsk dam causes the inundation and decomposition of organic matter previously
on land as well as coastal erosion. The result, again, is nutrient release into the nearshore zone
which can trigger excess algal growth.
Importantly, many of the serious problems afflicting Lake Baikal are likely to worsen in the
future with climate change. For example, decreases in winter ice cover and increases in lake
surface temperature, both of which have already been reported for Lake Baikal (Shimaraev et al.,
2002; Hampton et al., 2008), will accelerate lake evaporation (Woolway et al., 2020). High rates
of evaporation, if not offset by an increase in precipitation or inflows, will cause a decrease in
lake level and the corresponding problems described above. Likewise, it is believed that climate
change may act synergistically with nutrients in large lakes to increase the severity and spatial
extent of eutrophication (nutrient pollution), thereby compromising the clean drinking water and
recreational opportunities that such lakes provide (Jenny et al., 2020).
The situation is aggravated by the fact that the existing state environmental monitoring system
for Lake Baikal is not designed to record most of the above-mentioned changes.
Poor management is the greatest threat to the Lake Baikal
Lake Baikal is far from being neglected by Russian authorities, who regularly issue decrees,
instructions, and orders intended to boost its protection, but without much positive consequence.
The latest Orders of the President of Russia dated September 12, 2019 imply that the efforts to
protect Lake Baikal have not yet reached their goals, and that all previous instructions have not
been implemented. While by this document, the President called on the Government to introduce
several urgent measures, the Order which apparently has not been fulfilled within two and half
years and has become the major failure of the new Government Commission on Lake Baikal
reestablished in October 2020. This has several root causes.
First, the new State Commission for Protection of Lake Baikal (chaired by vice-premier) failed
to emerge as capable institutional tool. Since October 2020 it has held only 2 sessions, its
materials and decisions are not publicly available, except for two press-releases
. The Ministry of
Natural Resources and Ecology (MNRE), which serves as the Commission’s secretariat, has no
capacity or vision to manage Lake Baikal and responsibility for the Lake shifted 4 times between
3 departments in 2 years.
“The Strategy for Lake Baikal Ecosystem Biodiversity Conservation” created with support of the
GEF and approved by three provinces of the basin and national ministry in 2001 was equipped
with Implementation Plan, but has never been systemically implemented, since national
authorities had no interest and provinces had no vehicle for coordination and their own financial
resources and legal responsibilities. The “Strategy” remains the only comprehensive attempt to
create a long-term vision and plan or conservation of Lake Baikal
Secondly, unfortunately, the program for protection of the Lake Baikal under the National
Project “Ecology”, is an extremely eclectic set of activities haphazardly planned by various
departments. There is no evidence that Lake Baikal would benefit from its implementation, since
the Project was not subjected to an Environmental Impact Assessment or public consultations. Its
action plan does not have scientifically justifiable performance indicators, no due system for
monitoring and control of financial expenditures, it has minimal traceable achievements in Lake
Baikal conservation, has clear signs of inefficient expenditures and many loopholes for
corruption. National Project “Ecology” is designed to distribute money in ways beneficial to
selected major beneficiaries (e.g. large corporations, regional bureaucracies, selected officials),
but has no underlying management plan addressing key problems of Lake Baikal. Budget cuts
are also very likely to reduce available funding in near future due to the costly military operation
and some activities were already postponed because of a need to substitute imported water
treatment technology due to sanctions imposed on the country.
The third sign of overall mismanagement and deterioration is weak and worsening legal and
enforcement situation. On one hand the Law on protection of Lake Baikal and subordinate
regulations are not implemented properly, while in last 3 years significant weakening
adjustments and exceptions are introduced into Lake Baikal - related legislation to facilitate
inappropriate development inside and adjacent to this World Heritage property(WH).
Finally, the ecological monitoring system has not been designed to register properly ecosystem
response to human impacts. Existing monitoring system fails to register changes in shallow-
water ecosystems, where active eutrophication and erosion are observed in recent years. This
makes impossible planning and implementation of science-based environmental programs
In this review, we analyzed primarily the main immediate threats to the ecosystems of the Lake
Baikal World Heritage property that can directly lead to the degradation of its Outstanding
The “Infrastructure” projects get exemption from the EIA procedures
The Baikal Natural Territory (BNT) is located along important transport routes such as the
Trans-Siberian Railway and the Baikal-Amur Mainline (BAM). On July 31, 2020 Russia adopted
a new Federal Law, which till December 31, 2024 abolished environmental impacts assessments
requirements within the boundaries of Baikal Natural Territory for projects in “main
infrastructure.” The “main infrastructure” may include roads, bridges, road protection and
service projects, railroads and associated projects, ports and associated projects including
artificial islands and water infrastructure, airports, multi-modal transportation hubs, associated
civil engineering projects, communication infrastructure, and other construction projects
included in the “Lists of Main Infrastructure Projects” to be developed by the Government of the
Russian Federation. More than 140 specific engineering projects associated with modernization
of two main railroads within the BNT were included in the first “list”. The same law allows
These concerns have been shared and explicitly expressed by Siberian Academy of Science Council on Lake
Baikal Protection (e.g. in December 2021 when discussing “2020 State Report on Lake Baikal” 20.12.2021
clear-cutting in the forests and transfer of forest lands into other categories for the purposes of
modernization of the infrastructure associated with Trans-Siberian and Baikal-Amur railroads
(which run across the World Heritage property for several hundred kilometers).
Environmental Impact Assessment is the only legal mechanism in Russia, which guarantees to
citizens and their associations the right to truthful information about the status of the
environment and their participation in decision-making on environmental issues. Besides that,
construction of any projects associated with modernization of transportation infrastructure at
Lake Baikal without prior assessment of environmental risks may lead to destruction of
important natural properties as well as to accidents and catastrophes.
Law adoption caused public outcry and Russian Railways were instructed by government to sign
voluntary monitoring agreements with research institutions and NGOs, creating a very
questionable practice of “corporate responsibility” in place of abolished EIA.
On 25th March 2022, as a part of “anti-sanction measures”, the Government of Russia sent for
parliamentary approval draft amendments to the law on “main infrastructure”
, which widened
application of abovementioned easements to “modernization and expansion of (any) priority
infrastructure projects” of national, provincial and municipal significance. The draft two
additional categories: “oil, gas and oil product pipelines” and “other infrastructure proposed by
the Government of Russia” (except for residential real estate development projects).
Corresponding amendments were suggested for laws on Lake Baikal, protected areas, urban
development code, etc.
Publication of this draft law has triggered wide discontent among scientists, environmental
activists, and some lawmakers. Urged by environmental NGOs, concerned citizens sent more
than ten thousand critical responses on the draft law to the Environmental Committee of the State
Duma. This protest was supported by remaining semi-independent media and resulted in drastic
reduction of weakening amendments. Resulting law, published on May 1
, now extends
easements only to additional transportation infrastructure, “government funded social
infrastructure”, “industrial projects undertaken for environmental purposes or to substitute
imports” and oil&gas pipelines. Additional EIA waiver is granted only to pipelines when it
comes to agricultural lands, protected forests and protected natural areas. Resulting law does not
change regulations on Baikal Natural Territory. However, the new law paves way to “Power of
Siberia-II” gas pipeline development outside of Lake Baikal watershed and allows the
government to weaken requirements and postpone archaeological surveys in the areas of priority
infrastructure projects. Nevertheless, so far it signifies a victory of common sense and
preservation of existing safeguards for protected areas.
Threats of oil and gas pipeline construction
The most heated debates historically were caused by oil and gas pipeline construction projects
that have come up regularly over the past 20 years. As special easements for pipeline
construction are proposed in new “anti-sanction” legislation, this issue is worth revisiting.
Final law published on May 1 http://publication.pravo.gov.ru/Document/View/0001202205010005
On July 17, 2001, Russian Prime Minister Mikhail Kasyanov and Chinese President Jiang Zemin
signed an agreement on the development of a “feasibility study” for the Angarsk-Daqing gas
pipeline planned by Yukos, a private company, and the China National Petroleum Corporation.
This led the World Heritage Committee to immediately request an Environmental Impact
Assessment (EIA). The oil pipeline was to run through the Tunkinsky National Park and cross
several rivers flowing into Lake Baikal. The project received a negative environmental impact
assessment and encountered political difficulties which derailed it.
At the same time the ESPO (East Siberia-Pacific Ocean) oil pipeline project began to be
implemented, which was promoted by the state-owned Transneft Corporation with full support
from the government. The project reached the pre-construction stage on the Northern coast of
Lake Baikal. Russian NGOs have effectively coordinated a risk prevention protest campaign
along the entire pipeline route from Irkutsk Oblast to Primorsky Territory. The Committee’s firm
intention to inscribe Lake Baikal on the List of World Heritage in Danger and opinions from
independent experts in 2006 led the Russian President to map an alternative route on the map,
hundreds of kilometers north of the lake.
Figure 4. Gazprom tender documentation, October 2021
In 2018–21 Russia and Mongolia (with alleged consent of China) have been investigating a new
route for a gas pipeline through Mongolia. In fall 2020 Gazprom has signed a Memorandum of
Intent with counterparts in Mongolia to establish a subsidiary company to advance the pipeline
project, then completed feasibility study and in February 2022 started engineering design
The gas pipeline route through the Lake Baikal World Heritage property, along with another one
through Tunka Valley, are considered the two best options—convenient for supplying gas to the
pipeline not only from fields in Western Siberia, but also from the Kovykta Field located west of
Baikal. The project may affect the Lake Baikal World Heritage property or other areas of the
Baikal Natural Territory. Construction of this massive infrastructure across terrain will alter
natural landscapes, while attempts to build it along existing transportation routes may increase
risks of major accidents. Some scientists suggested building such a pipeline on the Lake Baikal
bottom, where construction may cause major disturbance in benthic ecosystems.
The exact intended route of planned pipeline has never been disclosed. However, Gazprom in
2021 commissioned a detailed study for a route crossing Tunkinsky National Park outside of the
Lake Baikal World Heritage property, which suggests that it was considered as the most feasible
(but still illegal, since the pipeline would cross a national park and does not serve needs of local
population). Given heavy impact on the whole protected area pipeline construction there may
still negatively affect the World Heritage Site, which includes part of Tunkinsky National Park.
As for the current ability of Gazprom to undertake any pipeline construction, while under
international sanctions, it will be tested by implementation of another more advanced project– a
gas pipeline from Sakhalin Island already agreed with China in February 2022.
Coastal development and tourism press
Tourism has always been considered the most important type of economic activity at the BNT,
but without proper planning and control its impacts are detrimental to natural sites. From the first
decision to implement protection measures for Lake Baikal, the World Heritage Committee
raised issues of clarifying the boundaries of protection zones and ensuring protection regulations
are upheld on the lakeshores.
The property lacks a comprehensive plan for managing visitors to the parks and nature reserves,
and that converts tourism business from an opportunity for sustainable development into a threat
to the Outstanding Universal Value of the property.
In the last decade, illegal land sales on Lake Baikal shores have become widespread due to the
growing popularity of the Lake among tourists. The situation is further aggravated by the fact
that land protection regulations have also made land sales and development difficult for local
residents who legally own them. This has caused widespread discontent among the population,
which land speculators use to their advantage.
According to Russia’s 2022 State of Conservation (SoC) Report half-dozen agencies are busy
identifying illegal buildings and taking measures to eliminate them, including within the
"Газпром" и Монголия перешли к проектированию газопровода "Союз Восток" - РИА Новости, 28.02.2022
boundaries of the UNESCO World Natural Heritage site – Lake Baikal. The number of
enforcement proceedings on the demolition of illegal buildings in the coastal zone of Lake
Baikal in Federal Bailiff Service Directorate for the Irkutsk region amounted to: 8 enforcement
proceedings - in 2019, 9 enforcement proceedings - in 2020, 14 enforcement proceedings - for 10
months of 2021, in the Directorate of the Federal Bailiff Service of Russia for the Republic of
Buryatia: 7 enforcement proceedings - in 2019, 10 enforcement proceedings - in 2020, 12
enforcement proceedings - for 10 months of 2021. Over the past two years, 45 statements of
claim were sent by Baikal prosecutors’ to the courts to demolish and dismantle 198 buildings
erected in violation of environmental laws. The Report testifies that only small fraction of
violations disclosed by the Baikalsky Prosecutors’ Office end up in the courts. Despite many
frantic activities of many agencies to curb illegal construction it is actively increasing.
Besides, despite prosecutor’s “claims sent to the courts to demolish and dismantle” and even some
decisions to demolish property made by courts, many (guest)houses stand unscathed, since their
owners refuse to demolish at their own expense, while the procedure of forced demolition done
with funds from state budget is complicated and lengthy.
Figure 5: Recent Development in Huzhirsky municipality in Prib.Nat.Park Imagery by Greenpeace,
Thus, when Greenpeace representatives and Olkhonsky Prosecutors visited Huzhir municipality
in Pribaikalsky National Park a construction of an, allegedly, private dwelling was discovered,
built without permit from National MNRE and without “approval of socio-economic activity”
(coordinates N53.199660 E107.354513)
The increase in number of structures erected within World Heritage property boundaries is
facilitated by weakening of legislation. Thus according to Gov. Decree from 31.12.2020 № 2399
“On the List of Activities Prohibited in the Central Ecological Zone of the Baikal Natural
Territory” limitations on construction in the Central Ecological Zone apply only outside of the
“borders o settlements” (apart from “special types” of facilities ).
However, “borders of settlements” in many cases are yet to be delineated, thus allowing local
administration and businessmen to build guesthouses, often under disguise of “private individual
dwelling” in natural areas not yet affected by human development. Thus, new regulations open
such attractive natural territories for development.
At the same time, local authorities are trying to expand the territory of settlements.
According to the Master Plan of the Huzhirsky municipality of the Olkhon Island by 2041 are
with residential development will expand 2.2.times by 4.7 square kilometers, while population
will increase by 50%
. Area for recreational development will expand 8-fold, while lands
belonging to farmers were included within the borders of settlements, thus opening those to
construction of buildings without necessary restrictions
Figure 6… by Greepeace (2021), Construction Site on Olkhon Island
Thus, there are plans to significantly expand the build-up area within the boundaries of the
property, primarily for recreational purposes, which will lead to an increase in recreational
pressure and, with a high probability, the flow of pollutants into terrestrial ecosystems and the
lake, as well as the destruction of habitats of rare and endangered animals and plants (for
example Imperial Eagle
, Olkhon vole
, Mongolian toad
or endemic plant Olkhon skullcap -
Craniospermum subvillosum - Red Book of the Russian Federation).
Expanding limits of settlements will also allow to legalize many land-plots and buildings, which
up to now are considered “illegal” (e.g. placed on undeveloped natural territories), including
those for which courts have issued demolition orders
Coastal development not only degrades the ecosystem of the coast, but also increases the illegal
discharge of waste waters. An inspection of the Irkutsk coast tourist campsites by Federal
Service for Surveillance on Consumer Rights Protection and Human Wellbeing
(Rospotrebnadzor) showed that 90% of campsites do not meet sanitary and environmental
requirements, and can be a source of lake pollution. The mechanism of pollution through
groundwater seepage from such a private development has been described in detail in recent
Development of special economic zones
The degradation of the World Heritage property by the inappropriate development of tourism is
encouraged by Government programs. In 2007, two Special Economic Zones of Tourist-
Recreational Type (SEZ TRT) were established on the shores of the lake. They combine federal
public investments in infrastructure and benefits for business residents with looser environmental
In the 2022 SoC Russia again failed to disclose EIAs and Strategic Environmental Assessment
(SEA) of the development plans for the special economic zones, which were repeatedly
requested by the World Heritage Committee for many years.
Neither of two SEZ has lead to beneficial sustainable development and much of infrastructure
built in Buryatia’s “Baikal Harbor” SEZ is currently deteriorating.
According the website of the Government of the Russian Federation
"Last October, Green
Flow Baikal Co., a resident of the Baikal Harbor SEZ, began construction of a hotel with 153
rooms in Turka. Completion of construction is expected in the III quarter of 2023. Another
investor, Cosmos Hotel Group, has begun the implementation of the project at the
Bezymyannaya Bay site. The first phase involves the construction of a five-star hotel with 100
rooms, 14 duplexes and 12 cottages. The implementation period is 2022–2024. Investors are
being sought for the construction of a ski resort on Mount Bychya, three investors have
announced their projects." Thus, without any SEA, development is planned within the existing
boundaries of the Baikalskaya Gavan SEZ, including the territory yet unaffected by economic
activity (Mount Bychya) and attempts are made to expand it to new natural areas. The Ministry
of Development of Far East proposed new amendments to the “Law on Lake Baikal Protection”
to ease expansion of existing special economic zones to new forested areas with subsequent
conversion of their lands into non-forest categories, where construction is allowed
explanatory note to the draft law proposes to change the boundaries of the Baikal Harbor SEZ to
exclude 1,119 hectares at the Bychya Mountain and include instead the Mamai Mountain area in
Kabansky District of the Republic of Buryatia, which is currently not affected by intensive
economic activity and belongs to the forest fund lands. The draft law insists that there will be no
change in the total area of the SEZ "Baikal Harbor" and “the Mount Mamai area is already
spontaneously used for skiing without observing the norms of legislation in the field of
In the fall 2020 the newly appointed governor of Irkutsk Province made a similar proposal to
extend “Gates of Baikal” SEZ to several coastal zones of Lake Baikal to ease construction of
, Deputy Prime Minister Yuri Trutnev held a meeting on the development of the SEZ February 1, 2022,.
tourist facilities capable to receive up to 3 million visitors annually. The “anti-sanction”
package of measures considered by the Russian Government in 2022 includes speeding up
allocation of land for tourism and recreational development (since population locked by
sanctions inside the country will need to access more recreational opportunities). According to
Irkutsk press, on March 2, 2022 a major meeting was held by Russia’s principal development
bank “VEB” to find “areas of economic growth” and it was proposed to greatly intensify tourist
use of Lake Baikal in 2022 to overcome economic hardships.
Lake pollution and its regulation
The 2010 “Standards for allowable impacts on the unique ecosystem of Lake Baikal” establish
strict limits on the concentration and volume of pollutants in wastewater that is discharged into
Lake Baikal and its tributaries. Authorities and business argued that the required degree of
purification was unattainable, while scientists claimed that the standards were not strict enough
to prevent the Lake’s eutrophication. None of the existing sources of discharges treated sewage
up to those requirements, but it was almost impossible to justify new projects with wastewater
discharges, since such thorough treatment required significant investments.
In March 2019, the Ministry of Natural Resources of the Russian Federation published a new
draft text of the Standards, which proposed to increase the concentration of pollutants allowed
for discharge on the Baikal Natural Territory. Scientists and non-governmental organizations
have publicly criticized the project, but officials insisted that this measure was necessary to
urgently spend budgetary funds on new municipal water treatment facilities in accordance with
the National Ecology Project.
As a result of the ensuing public debates, a working group was created at the initiative of the
Russian Academy of Sciences. The working group developed a compromise version of the
document. It also established strict rules for discharges directly into the Lake (while discharges
in its water protection zone are not permitted at all) but weakened the standards for discharges
into tributaries. The least stringent standards are offered for small wastewater treatment plants.
This was supposed to pave the way for mass construction of new treatment facilities, including
those serving tourist camps. The debate was centered on requirements for municipal wastewater,
while separate strict limits were imposed on pollution from industrial sources with implicit
understanding that most such sources should be phased out of Lake Baikal World Heritage Site.
How this discourse has changed in 2022 is described in the section on Baikalsk Pulp and Paper
Some experts claim that the standards developed in 2020 are not backed by proper scientific
evidence. Scientists also argue that, in addition to limiting their concentration, it is necessary to
limit the total amount of pollutants that are discharged into Lake Baikal. If the widespread
construction of campsites and hotels continues, this will lead to a large increase in pollution, no
matter what kinds of treatment facilities the new structures are equipped with. Unlike the 2010
Standards, the new 2020 Standards do not limit the total volume of pollutants entering the Lake.
Other experts argue that the problem is not only in the number of wastewater treatment plants,
but also in their accessibility to the population, the availability of personnel qualified to work at
these facilities, and technical support that would ensure they continue to operate properly.
Therefore a proper action plan for implementation of the Standards matters not less than setting
There are also other important negative impacts on Lake Baikal that are not yet regulated by any
standards, such as plastic pollution. According to Greenpeace, plastic accounts for 87% of all
garbage on the shores of Lake Baikal.
The 2022 SoC Report by Russian Federation illustrates complete failure to monitor water
pollution with sufficient rigor. It generally characterizes Lake Baikal waters as “conditionally
clean”. However it refers not to the abovementioned Standards developed specifically for Lake
Baikal, but to the “Standards of the maximum permissible concentrations of harmful substances
in the waters of water bodies of fishery significance (MPC), approved by Order of the Ministry
of Agriculture of the Russian Federation No. 552 dated December 13, 2016”. This shows that
existing monitoring system is inconsistent with specific requirements of Lake Baikal protection.
Baikalsk pulp and paper mill (BPPM) and new development at this former industrial area
The mill started operating in the fall of 1966 and has been the primary source of pollution in
Lake Baikal for half a century. The BPPM discharged 120,000 cubic meters of wastewater
containing significant concentrations of suspended solids, organochlorine compounds, nitrates,
phosphates, heavy metals, etc., into the lake daily. Atmospheric emissions exceeded 30,000 tons
per year. Sewage from the mill created an area with pronounced negative ecological changes in
Lake Baikal for the first time, and the forests on the surrounding slopes were drying out due to
For over 10 years after the property was nominated for the World Heritage List, attempts were
made to organize a closed water circulation at the mill. All of them failed. In the summer of
2010, Russia promised UNESCO to stop the pollution by December 2012, but failed to deliver
on the promise. In 2013, the mill was finally closed, the former owners have not taken
responsibility for the site’s rehabilitation, and billions of rubles were allocated by the state to
clean up the waste that had accumulated from the BPPM.
The BPPM area is affected by massive mudslides, and there is a significant risk that storage
ponds containing 6 million tons of waste (mainly lignin sludge) may fail and the waste will end
up in the Lake. In August 2019, heavy rains contributed to an extraordinary rise in water levels,
which led to overflow of one of the sludge storage ponds resulting in pollution of the Lake.
Government’s effort in site remediation is divided in three tasks: industrial waste management
(contracted to Rosatom-FEO), industrial site remediation (managed by Vnesheconombank -
VEB) and mudslide-prevention (outsourced to Irkutsk Provincial Government) clearly lacking
coordination and common interrelated plan. EIAs\SEAs for BPPM Site Remediation have been
never attempted despite many requests from UNESCO.
A comprehensive project for rehabilitation of the former industrial site, which is necessary for
the BPPM reclamation, has not been planned or implemented in time due to the inaction and
disagreements between Irkutsk Oblast authorities and the BPPM Creditors Council, which
includes VEB, En + Group and other actors with different, often conflicting interests. To date,
efforts to eliminate the waste from the BPPM and rehabilitate the industrial site have not had
much progress. Due to new international situation and economic sanctions in March 2022 start of
most practical activities was postponed for one year or more.
Currently VEB is preparing a Master Plan for Baikalsk Municipality which envisions 30-60%
increase in Baikalsk population and massive development with huge influx of temporary
workers, which may have negative impacts on the Lake. Masterplan includes construction of
lucrative lakefront properties right inside water-protection zone, which currently does not have
residencies or businesses. It is unclear what are environmental performance indicators (KPI) the
VEB uses and how they are compatible with activities in enclave enclosed within World
Heritage property. However, since VEB’s Center on Baikal Development was put under western
sanctions in late February, its ability to carry out planned activities with due rigor will likely be
Changes in protection regime effected or proposed in order to “enable remediation of BPPM”
bear new threats for the Lake Baikal. The Decree “On the List of Activities Prohibited in the
Central Ecological Zone of the Baikal Natural Territory” amended in 2020 allows building in
Baikalsk Municipality any facilities necessary for rehabilitation of the lands degraded by
Baikalsk Pulp and Paper mill, even if they belong to “I and II class of environmental danger.” It
may happen that the utilization of accumulated waste will be implemented using technologies
posing a threat to the Lake.
Activities of Rosatom’s subsidiary FEO tasked to clean-up BPPM sludge ponds are increasingly
non-transparent and worrying, mainly due to their lobbying power and ability to waste state
funds earmarked for Lake Baikal. In addition Russian Government contracts FEO through
“Krasny Bor” Facility for Waste Treatment Management, which Director and Vice-Director
were arrested in April 22 on fraud and theft accusations
Objectives to decrease the level of water in the sludge ponds that are very difficult or even
impossible to implement given the strict allowable impact limits, despite FEO’s spending 400
000 000 rubles in 2021 on untested equipment. On March 15 the Government disclosed for
public consultation a draft amendment to 2 tables in "Standards of allowable impact on Lake
. In both tables allowable concentrations for multiple industrial pollutants to be
dumped into the lake and its tributaries were increased, some of those by 1000%. The draft says
that the only reason for weakening the norms is necessity to proceed with “reclamation of
accumulated environmental damage” at the sludge ponds of the Baikal Pulp and Paper Mill.
Rosatom cannot use huge portion of state environmental remediation funds without violating
existing Standards. The draft does not contain or refer to any reasonable assessment of
consequences\impacts and possible alternative solutions. It does consider implications of
allowing discharge of greater pollution throughout the Baikal Natural Territory. It argues that
norms amended in 2020, included indicators which could not be measured with required
precision. However, the newly proposed amendments also lack scientific justification and valid
implementation plans consistent with the law.
Siberian Branch of the Russian Academy of Science disagreed
with changes proposed to
concentrations for pollutants released into tributaries, arguing that:
- Suggested allowable levels are far higher than currently discernible\measurable
pollution concentrations and therefore allowing greater pollution is in direct violation to
article 14 of the “Law on Protection of Lake Baikal” which prescribes regular revision of
norms “to reduce pollution”, while proposed changes increase pollution.
- The list of substances in this Table #2.3 has not been expanded to include 18
individual “especially toxic substances” containing chlorine and dioxins, while aggregate
indicator for all such substances was increased 1000-fold in both tables (due to deficiency
in presently certified monitoring measurement methods).
Siberian Academics also generally condemn the idea of allowing discharge directly into the
Lake, suggesting it should be subject to complete prohibition and there should be no “Table 1”
incentivizing discharge of any pollution into the Lake. However, they agree with proposed
changes to Table 1 on technical side, since previously used figures could not be measures by
methods certified\accredited in Russia for pollution monitoring. Nevertheless the President of
Russia Academy of Sciences, likely lobbied by FEO, later signed a letter approving some of
unreasonable changes to this regulation, thus trying to silence provincial academics opposing it.
Rosatom\FEO is also lobbying to downsize the water protection zone of Lake Baikal near the
Babkha (Babkhinsky) area of sludge ponds. According to Russian laws waste cannot be buried in
water-protection zone and thus untested “lithification” technology, promoted by Rosatom, cannot
be applied there. Since basic science-based technology selection was largely falsified and overall
spatial plan or the post-remediation area non-existent, there is real threat that approval of
“lithification without removal” means that sludge ponds will be simply covered by geomembrane
and the problem of BPPM waste will be passed on future generations.
Outside of Baikalsk municipality an industrial park was planned in the coastal village of Kultuk,
in the same Slyudansky district of Irkutsk Province, in the spring of 2019, its first element, a
small Chinese-invested drinking water bottling plant, became the target of mass public protests
of a national scale, which led to a halt in construction. It became evident that the land for the
plant was obtained illegally without a proper environmental assessment, and that it is located in
an important wetland habitat for birds. During the protests, it turned out that another eight similar
industrial facilities were planned in the Kultuk Industrial Park.
The Impact of the Irkutsk Hydro on Lake Baikal
Lake Baikal is a reservoir of the Irkutsk Hydropower Plant. The construction of the hydropower
dam on Angara River created backwater that spread throughout Lake Baikal and raised its water
levels by 1 m. The Lake began to fulfill the function of a reservoir for both annual and long-term
regulation, which made it possible for the plant to produce the cheapest electricity in the country.
Due to the need to regulate the water supply for the coordinated operation of the entire Angarsk
cascade of hydropower plants and water transport on the Yenisei River, daily and seasonal
fluctuations of Lake Baikal levels have changed substantially (Atutov et al., 1999).
Creation of this reservoir became the single most significant source of human disturbance for the
unique ecosystem of Lake Baikal.
The Irkutsk Hydropower Plant intensified the negative factors affecting the ecosystem of the
Lake, especially during extreme climatic events, low water levels, and floods. The general rise in
Lake Baikal’s water levels, the additional discharge of organic matter into the Lake due to
flooding and erosion of the coasts, as well as the high pollution levels in the tributaries
(especially the Selenge River) have affected hydrothermal, hydro-chemical, and hydro-biological
processes in ecosystems located mainly in the shallow part of the Lake and in the delta sections
of its tributaries. In water-abundant periods, the shores of the Lake were destroyed by intensive
erosion, which affected the populations of endemic invertebrates and fish living in shallow water
and in the surf zone (Kozhova and Pavlov, 1995). The populations of bighead sculpins
(Batrachocottus baicalensis)—a key species in the diet of Baikal Cisco or omul (Coregonus
migratorius) and Baikal Grayling (Thymallus spp.)—are the first to be affected. Shallow bays
known as “Baikal Sors,” many of which are nurseries of young Baikal Omul, are also exposed to
dangerous effects of artificial water level manipulation.
The reason for these negative impacts was not only the natural high water level, but also the
desire of engineers to maintain the maximum possible supply of hydropower resources in the
Irkutsk reservoir. To reduce the damage from hydropower, the Law “On the Protection of Lake
Baikal” ordered the Government of the Russian Federation to determine the acceptable
fluctuation range for the Lake Baikal water level. The restriction of 1 m on the range of
fluctuations, introduced by Decree of the Government of the Russian Federation No. 234 dated
March 26, 2001, favorably affected the ecological state of the Lake Baikal ecosystem. These
restrictions were successfully observed until 2014, when the natural low water period at Lake
Baikal coincided with the filling of the newly constructed Boguchany Reservoir on the Angara
River and an overly optimistic inflow forecast. The lake level rapidly fell below the prescribed
Figure 7. Lake Baikal and Hydropower.
In 2015, a sensible solution to the problem was proposed—to maintain the water level in the
lake by reducing winter discharge into the Angara River from 1300 m3/s to 1050 m3/s, which is
closer to natural winter discharge in pre-damming times. However, this would have required
deepening the water intake structure at the Cogeneration Coal Thermal Plant 10, which is owned
by En + Group, and this option was rejected by the company.
To address the critical situation, the Government of the Russian Federation adopted an interim
resolution “On the Restriction of Water Level Fluctuations in the Autumn-Winter Period of
2014/2015” on February 4, 2015. It lifted the 1 meter restriction for the 2014–15 season and the
water level was dropped below 456 meters ASL. Later, two similar interim decrees were issued
for the 2016–17 and 2018–20 seasons. The 2018 Resolution No. 1667 increased the permissible
range of lake level fluctuations from 1.00 m to 2.31 m. Meanwhile by 2020 period of water
scarcity ended and gave way to water-abundant years.
In 2020, fearing future floods, water management authorities attempted to make permanent the
2.31 meter range of permissible water level fluctuation . Draft Resolution “On the Maximum and
Minimum Limits of Water Level Fluctuations in Lake Baikal” presented for comments in
September 2020 allowed raising the lake level 85 cm higher than original resolution from 2001.
Public outcry led by Civic Chamber of Russian Federation
and resistance from Republic of
Buryatia made it impossible for a new Minister of Natural Resources Kozlov to approve
permanently this range. In early 2021 The Ministry promised to commission a study “On
environmental impact of changes in the water level of Lake Baikal in the regulation range with
marks of 455.54 m - 457.85 m on the state of the Lake Baikal ecosystem, as well as to determine
possible damage to economic and infrastructure facilities of the coastal territory”. The Terms of
Reference for the research have not been made public despite multiple requests from NGOs.
There is no monitoring of water level fluctuation impacts on Lake’s ecosystems to support such
analysis with relevant data. The start of this research program has been postponed for 9 months,
suggesting that lengthy studies are used by the Government as an excuse to carry on current
damaging mode of water level regulation. The Government reissued another interim resolution
with the same water level fluctuation range for 2020-21 in April 2021 and later published
another draft resolution for 2022-24 period (until the end of the intended study). Meanwhile in
2020 and 2021 artificially raised level of Lake Baikal has already caused considerable damage to
low-lying coastal ecosystems and local communities.
As a consequence of high water level coupled with wave action (especially during storms)
stretches of low-lying lakeshores experiences significant negative impact, some of it irreversible.
Erosion severely affected coastal forests, meadows and other low-lying habitats, inundated and
partly destroyed sand-bars - ecological barriers dividing cold open lake from its warmer shallow
bays. Such artificially high-water also negatively affects various facets of biodiversity from
juvenile fish in shallow bays to nesting waterbirds and their offspring in Selenge Delta Ramsar
wetland. It also caused significant damage to local settlements and infrastructure as demonstrated
be selected photos made by RwB Expedition in 2021
Recommendations issued by the Civic Chamber of Russian Federation
Rivers without Boundaries in October 2021 commissioned an expedition to Buryatia Republic, which
documented the destruction. Full report available at https://www.researchgate.net/publication/357506027
Figures 8 and 9. In the Oimur Settlement (Kabansky District) erosion in 2021 has eaten away 3 meters deep
into the coastal meadow. The cliff lines are now approaching houses.
Figure 10. In the coastal forest the soil layer near Town of Turka was washed away, while fallen trees are
rapidly utilized by local population. Similar forest destruction occurs on all low-lying forested shores.
Figure 11. Raising lake level pushes groundwater up above earth surface inundating coastal meadows and
forests with long-term consequences for natural communities and their traditional use by local people.
Figures 12-14. Natural stands of 70-year old pine-trees are destroyed, while all the organic matter seeps out
into the lake, exacerbating the problem of algae blooms and eutrophication of Lake Baikal, increasing damage
to aquatic biodiversity, especially endemic species of shallow-water communities.
Figure 15. High water coupled with storms greatly increases erosion of sand bars, or spits, which are providing
shelter to smaller bays or inlets, where the water is much warmer and full of life than out in the open lake.
Many species of juvenile fish will come to feed in these more productive shallow waters.
Figure 16. The rich pasturelands of the Selenga Delta are inundated by groundwater and there is limited
space left for grazing livestock in many villages of the Kabansky district. This is reminiscent of the 1970s,
when the lake first reached record levels, and local farmers had to slaughter entire herds of cattle.
Figure 17. Historic lakeshore communities already experienced resettlement as the Irkutsk Dam raised lake
level by one meter by 1958. Today the lake again is entering the town of Turka and many villages. In 2020
this barrier fence in a backyard had to be moved by one meter and now will have to be moved again.
In Irkutsk Province in 2021 high water level threatened habitats and populations of endemic and
relic species which are confined to sandy and gravel beaches. In particular it caused harm to the
largest known population of the red-listed endemic plant Craniospermum subvillosum .24
Extensive damage to Zabaikalsky National Park was reflected in the State of Conservation Report
submitted in 2022 by Russia to UNESCO (Page 24): “High water level in Lake Baikal in 2020 and
2021 has a negative impact, there is a noticeable erosion of sandy beaches, erosion and collapse
of coastal terraces, accompanied by the loss of individual trees of different species. The tourist
and transport infrastructure suffers from autumn storms in conditions of a high level of Lake
Baikal. So, as a result of flooding of beaches over the past year, about 40 tourist parking lots with
picnic tables and campfires were under water. Buried containers of toilets and garbage containers
are prone to being squeezed out of the ground by rising groundwater. ... As a result of the flooding
of the Chivyrkuisky Isthmus, the water level in some sections turned out to be higher than the level
of the only dirt road from the village of Ust- Barguzin to the village of Kurbulik. The roadbed was
damaged for 10 km.“
All those are consequences of a "slight" artificial increase (by 23 cm to the 457.23 water mark)
over previously accepted maximum levels for the lake. However, “temporary regulations” adopted
in 2021 allow raising the level by additional 62 centimeters (to the 457.85 water mark).
Fig 18. Drowned “Trout Farm”on Telyachii Island of Angara River in Irkutsk was built very recently.(Source Dr.
Vitaly Ryabtsev https://ekogradmoscow.ru/2012-11-25-08-44-50/2012-11-25-08-49-32/ushcherb-dlya-bajkala-
The key reason why the level was so high in 2020 and 2021 (i.e. far higher than would be expected
considering just current inflow) is that outflow of water through Irkutsk Hydropower Dam was
reduced compared with its design parameters and original “rules for water resources management”.
We see two main reasons for consistent decision-making that causes damage to Lake Baikal.
Firstly, in many floodplain areas below the dam (mostly in Irkutsk City) businessmen and
municipalities have recently built summer houses, recreation facilities, fish farms and shopping
centers. Intensive release of water downstream (which would happen naturally without a dam and
is envisioned by dam design as well) may lead to inundation or restrict access to those facilities.
Therefore, Irkutsk City and Irkutsk Province governments use all their influence to prevent such
“emergency situation” from happening and do not undertake sufficient measures to stop land
grabbing in the floodplain and to remove houses\facilities conflicting with necessary water release.
Secondly, Irkutsk Hydro managers (as most Russian hydropower managers) are categorically
opposed to “wasting” water through spill gates (not through turbines), which they see as direct
threat to their revenues from sales of electricity. Since in 2021 the Irkutsk Hydro started renovation
of turbines and only 2500 cum/sec could be put through remaining turbines, which led to very late
agreement to open spill gates only on July 2. Those gates were shut again on October 24 under
various questionable excuses when lake level was still at high mark of 457.15 meters ASL.
Therefore in 2021 the maximum outflow through the dam barely reached 3600 cum/sec, while it
should have been at least 4000 once the lake level exceeded the 457.00 mark (actual Irkutsk
reservoir regulations allow to discharge up to 6000 cum/sec). Duration of the spill gates use was
also insufficient to safeguard the lake and even to guarantee that level could be sufficiently
lowered by beginning of possible high inflow in summer 2022.
In 2015, the World Heritage Committee requested a justification for existing water level
regulations. Since 2016, the Committee has urged Russia to produce an Environmental Impact
Assessment (EIA) of potential impacts of existing water use and management regulations on the
Outstanding Universal Value of the property, and not to introduce any further changes in the
regulations until their effects on the property are fully understood. In 2018, a report from the
Russian Federation stated that the State Party does not consider it necessary to conduct a “full
EIA of these impacts”, while its 2022 SoC claims that such impact on the OUV has been already
assessed in 2015. Given such attitude of the authorities we predict that in near future Lake Baikal
will continue to be used as a flood-control reservoir to solve shortcomings of Irkutsk Hydro
operations caused by illegally built buildings in the Angara River floodplain and to ensure that
no water is wasted without producing electricity. Lake’s water level on Jan.1 2022 was at 546.74
or 35 centimetres higher than multi-year average, while water release by the Irkutsk Hydro was
limited to 1500 m3\sec. It is highly likely, that even if we have “average” inflow in Lake Baikal
later in 2022, the Water Authority will still have to raise water level above previously prescribed
limit of 457 meters (which is already up to 1 meter higher than natural lake level before the
creation of the reservoir). That is why, despite solid evidence of extensive damage to the Lake
Baikal ecosystem from high water levels, the Government of Russia on March 16, 2022 reissued
new “temporary” Decree #379 “On minimum and maximum levels of the Lake Baikal in 2022-
2023” with the same 2.3 meters of allowed water level fluctuation
. Issuing such a decree again
contradicts all previous Decisions of UNESCO World Heritage Committee.
Dam construction on tributaries
The planning process for hydropower plants in Mongolia, which, dates back to Soviet designers,
was reactivated in 2012 with support from the World Bank (Shuren Hydropower Plant Project on
the Selenge River and waterworks on the Orkhon River) and China’s Export-Import bank (Egiin
Gol Hydropower Plant Project). In 2014, the World Heritage Committee ordered Mongolia to
invite an IUCN monitoring mission for an assessment. Its detailed report formed the basis of the
Committee’s decisions in 2015. The Committee demanded that Mongolia adjust the Egiin Gol
HPP EIA, conduct an EIA of the remaining HPPs in accordance with UNESCO requirements,
and evaluate the cumulative impact of all planned HPPs on Lake Baikal. The WH Committee
recommended that Russia and Mongolia jointly conduct a strategic environmental assessment
(SEA) of any hydraulic structures and water resources management in the Lake Baikal basin.
Figure 19. by Eugene Simonov/RwB. Delta of Selenge River at Lake Baikal was once altered by
Russian hydropower and now threatened by dam building in Mongolia.
Extensive work on planning the SEA, promoting alternative development paths, and filing
complaints with the World Bank’s Inspection Commission and other potential dam financiers
was carried out by environmental activists, primarily by the leader of the Buryat Regional
Organization for Baikal (BROB) Dr. Sergey Shapkhaev (1948–2018). This work resulted in two
important outcomes. First, the Chinese investor cancelled their plans to build the Egiin Gol HPP.
Second, the World Bank cancelled feasibility studies for two other hydropower projects. The
World Bank was forced to order a comprehensive regional environmental assessment (REA) for
hydropower in the Lake Baikal Basin. Thus, the immediate threat of new hydropower
development in the Lake Baikal Basin was removed, as their international funding was cut off.
However, the MINIS Project was closed December 31, 2019, and World Bank safeguards will no
longer be enforced if the REA moves forward.
The “Agreement for Cooperation in the Electricity Sector” signed between Russia and Mongolia
in December 2019 includes environmental safeguards and likely makes new hydropower dams in
Mongolia unnecessary. With unlimited access to the capacity of the Siberian Energy System, the
production of wind and solar energy will be a more cost-effective solution for Mongolia than the
construction of hydropower dams on rivers with variable flow discharging into Lake Baikal.
However, Russia’s 2022 SoC Report shows that during last 4 years a dialogue on transboundary
rivers with Mongolian side was severed and they failed to reach any robust agreement on the
subject. For example, additional EIA for the Egiin Gol HPP continues in Mongolia without
participation from Russia, despite its stated goal to assess impacts on Lake Baikal ecosystem.
There are open calls in Mongolian press to restart Egiin Gol construction alluding to Russian
invasion in Ukraine as a consequence of unequal cooperation in energy sector and therefore a
need for Mongolia to pursue independent energy policy.
In 2019 the Great Khural of Mongolia amended Article 2 of the “Water Law”27 so that it no longer
contains a provision #2.2 "international law shall be followed in the case if provision of this law
conflicts with Mongolia's international agreement". We assume that this was a direct reaction to
the World Heritage Committee decisions constraining unilateral development of hydropower dams
on transboundary rivers terminating at World Heritage Properties (e.g. Lake Baikal and
Landscapes of Dauria).
Mongolia’s 'A new revival policy to stimulate economy’, issued in December 2021, among key
pledges featured “Blue Horse” Program28 , specifically construction of a water transmission
pipelines from Orkhon and Kherlen rivers to Gobi, and undertaking “all possible measures” to
develop Egiin Gol Hydro29. The “Blue Horse” Program also includes an on-going attempt to put
a dam on Ulz River upstream of the “Landscapes of Dauria” transboundary WH property without
any proper assessment and consultation, as well as other 30 dam projects, which altogether may
negatively affect 2-4 WH properties and up to 11 Ramsar sites30. Those plans are presented by the
Government of Mongolia as fulfilling its obligations under the Paris Climate Agreement.
There is a large Kholodninskoe Deposit of polymetallic ores within the boundaries of the Lake
Baikal UNESCO World Heritage property, not far from the lake. It was discovered in 1968, and
reconnaissance was conducted from 1974 to 1988. After exploration, the deposit was part of the
state’s reserve until 2005. As believed by experts on Lake Baikal, if this ore deposit were to be
developed, it would be practically impossible to avoid a full-scale environmental disaster.
The inscription of Lake Baikal into the UNESCO World Heritage List incentivized the State
Party of the Russian Federation to start adopting relevant legislation, under which the extraction
of metal ores in the Central Ecological Zone of the Baikal Natural Territory was banned in 2001.
However, the exact boundaries of this zone have not been legally approved yet, which left open
the option of obtaining a license to develop the Kholodninskoye Deposit. The “UDE 13040 TE”
license was obtained by InvestEuroCompany Ltd. on March 29, 2005, and the boundaries of the
CEZ of the BNT were approved on November 27, 2006. The license holder used this as
precedent to insist they have the right to develop the deposit, while the environmental
community objected. Additionally, the UNESCO World Heritage Committee has repeatedly
stated that mining is incompatible with the status of a World Heritage property.
УСНЫ ТУХАЙ /Шинэчилсэн найруулга/ https://legalinfo.mn/mn/detail/8683
Analytics on Blue Horse Program available at
Although the deposit has not been developed over the past 8 years, the license has not been
cancelled either. In 2012, the Russian authorities decided to suspend the license for 2 years. The
final stage was the termination of the right to use subsoil in this area, which became possible
only after the intervention of the General Prosecutor’s Office of the Russian Federation. On
November 28, 2017, the license for the Kholodninskoye Deposit expired.
The Baikal Natural Territory is rich in minerals, therefore, the precedent for preventing threats is
important for the protection of Lake Baikal in the future.
Lake Baikal fisheries
Local communities have been fishing on Lake Baikal since ancient times, and fishing is
foundational to this region’s traditional way of life. However, because the population on the
shores of Lake Baikal has increased and fishing equipment became more sophisticated, the legal
and illegal catch of the main commercial species, primarily Baikal Cisco (omul whitefish), has
sharply increased over the past 100 years. In addition to fishing, the condition of wild fish stocks
can be negatively affected by climatic fluctuations, the regulation of the water levels by the
Irkutsk Hydro, the rapid eutrophication of coastal waters and the restructuring of their
ecosystems, as well as by the introduction of alien species. As a result, schools of sturgeon and
whitefish have been decimated, and the number of omul populations have steadily declined and
reached a level where fishing companies could not catch fish even within the limits of modest
quotas. As a result, a complete ban on industrial fishing has been in place for Lake Baikal since
In spite of the ban, the omul population is not expected to recover quickly, since no effective
measures have been taken to rectify the situation. Instead of implementing initiatives essential
for protecting Lake Baikal’s aquatic biological resources—to combat poaching, for example—
the authorities prefer to blame the fauna of the lake for all its problems. The cormorant and the
Baikal seal are regularly depicted as the main threats to the omul. Cormorant, previously
considered rare on Lake Baikal, was not only excluded from the Red Data Book of Buryatia, but
also included in the List of hunting resources of the Republic. Every year, proposals are made to
open commercial hunting for the Baikal seal, even though scientists argue seals don’t harm the
omul—the fish swim faster, and the seals can’t catch them.
Judging by performance indicators of the Lake Baikal component of the National Ecology
Project the funds allocated for fisheries are not spent on protecting wild fish populations and
preventing negative impacts on them, but on the artificial reproduction of omul and sturgeon in
hatcheries. Such a one-sided approach is unlikely to help the wild populations of Lake Baikal
fish to recover, as the fry released into the lake are subject to pressure from the same natural and
Thus, the Lake Baikal omul population crisis may last for many more years.
Forest management and forest fires
Fires in natural territories are among the most important factors in ecosystem degradation
throughout the Baikal Natural Territory and Siberia as a whole.
A significant part of the forests within the boundaries of the Lake Baikal World Heritage
property have been subject to catastrophic fires in 2015–16 and 2019, which contributed to the
degradation of both terrestrial and aquatic ecosystems.
Although the fire impact assessment requested by UNESCO bodies was not carried out yet by
the government, Doctor of Biological Sciences Oleg Timoshkin has concluded that fires are one
of the most influential factors in the deterioration of the Lake’s ecosystem. Fires cause the
following adverse effects:
• The influx of nutrients and toxins into the lake, which causes significant negative changes
in aquatic ecosystems with low nutrient density, even in areas without wastewater
• Increased erosion, which negatively affects the flushing of suspended solids into
tributaries and the Lake.•
• The degradation and aridization of landscapes.
Fires and subsequent outbreaks of pests create excuses for intensive “sanitary” forest felling
inside the World Heritage property.
Almost all experts agree that forest fires are one of the most widespread and powerful factors of
ecosystem degradation in the BNT. Nevertheless, the modern forest management system
increases the risk of fires instead of reducing them.
In January 2019, the Russian Presidential Council on Strategic Planning approved the National
Ecology Project. The suggested measures include a
proposal to amend the law “On the Protection of Lake Baikal” and the Forest Code of the
Russian Federation “in terms of the option to transfer forest lands to lands of other categories and
carry out sanitary clear-cutting in forests located in the Central Ecological Zone of the Baikal
Natural Territory,” which means within the boundaries of the World Heritage property.
The issue of sanitary clear-cutting near Lake Baikal has been discussed for several years already.
Felling in the Central Ecological Zone of the Baikal Natural Territory may really be necessary in
some cases: for example, when there is a need to cut down dead forest around settlements and
infrastructure in order to reduce fire hazards and the risk of fires spreading to these settlements
and facilities. But if sanitary clear-cutting near Baikal is allowed for all protected forests without
taking into account the specific needs of this unique territory, it will inevitably lead to a
significant increase in the scale of forest fires and lake pollution, as well as other threats to the
There are two main reasons for this. Firstly, under the existing forest management system of the
country, sanitary clear-cutting can be carried out on a significant scale only as commercial
activity, being financed from the proceeds from the sale of harvested wood. Allowing sanitary
clear-cutting near Lake Baikal, in practice, means allowing ordinary commercial logging, which,
in the Baikal Region, is also one of the main causes of forest fires: the majority of them start near
infrastructure facilities and logging sites.
Secondly, logging in the mountains with the use of conventional and road equipment always
leads to a sharp increase in soil erosion. Increases in sanitary felling near Lake Baikal will lead to
more clay, sand and nutrients washed off into the lake and watercourses flowing into it.
There are reasons to believe that forests that were not razed by fires or have recovered after fires
will be allotted for sanitary clear-cutting. Therefore, the condition of the remaining forests will
worsen, and the fire hazard will increase due to the development of road infrastructure, which
increases accessibility of forests.
Fig. 20 (by Denis Sinyakov)/Greenpeace.
A camp of loggers engaged in “sanitary felling” in Pribaikalsky Wildlife Reserve right on the Baikal
lakeshore inside the World Heritage property. The Reserve lost 43,000 hectares out of 70,000 to
wildfires and was open to logging “to prevent pest outbrakes.” 29 Sep, 2018.
The action plan of the National Ecology Project also entails lifting the ban on the transfer of
forest land into other categories of land. The action plan does not specify the purpose for which
the transfer ban can be lifted. It may be a matter of transferring land from the forest fund to other
categories for any purpose, including the construction of new industrial, sports and tourist
facilities, which the World Heritage Committee has repeatedly opposed.
Thus, the on-going attempts to introduce amendments that weaken legal protections for the
Baikal Natural Territory and the Lake Baikal World Heritage property at the federal level will
lead to environmental deterioration in the Lake Baikal Basin, the destruction of ecosystems, and
the violation of the Outstanding Universal Value of the World Heritage property.
Climate adaptation and World Heritage Property Management
Inadequate actions in the field of forest fire prevention and mitigation are the manifestation of a
much broader problem: the management system of the World Heritage property doesn’t properly
address the impacts of climate change on Lake Baikal’s ecosystem and on territory management.
The ecosystem crisis caused by the anthropogenic pressure is likely to be exacerbated by climate
fluctuations, which are thought to have contributed to:
• An increase in the average water temperature in Baikal by 1.3 degrees, which may
amplify effects of localized eutrophication and facilitate the introduction of alien species.
• An unprecedented 23-year drought, which led to record low lake levels in 2015.
• An increase in the frequency and scale of forest fires, which are already difficult to deal
with due to the collapse of the Forest Management System in Russia.
Russia does not have an actionable plan for adapting the management system of the World
Heritage property to climate change yet (Fig. 11).
Should Lake Baikal be inscribed on the list of World Heritage in Danger?
According to paragraph 172 of the Operational Guidelines for the Implementation of the World
Heritage Convention natural WH property should be considered “in ASCERTAINED
DANGER” if faced with specific and proven imminent danger, such as:
A serious decline in the population of the endangered species or the other species of Outstanding
Universal Value for which the property was legally established to protect, either by natural
factors such as disease or by human-made factors such as poaching.
Endemic sponges of Lake Baikal and many other key freshwater species are in pronounced
decline due to combination of human-made and natural factors.
Severe deterioration of the natural beauty or scientific value of the property, by human
settlement, construction of reservoirs which flood important parts of the property, industrial and
agricultural development including use of pesticides and fertilizers, major public works, mining,
pollution, logging, firewood collection, etc.
Rampant property development on the lakeshore, development of major transportation
infrastructure and potential flooding due to change in water level regulation, multiple pollution
sources—all those factors fall into this category.
Human encroachment on boundaries or in upstream areas which threaten the integrity of the
Establishment of special economic zones, opening natural areas to development, dam building
and other dangerous human activities in Selenge River basin—all belong to this category.
The WH property may be also considered under POTENTIAL DANGER due to major threats
which could have deleterious effects on its inherent characteristics. Such threats are, for
a modification of the legal protective status of the area.
Several key regulations governing protection of Lake Baikal have been weakened in 2015–21.
planned resettlement or development projects within the property or so situated that the
impacts threaten the property.
Major development projects in tourism, transportation and other sectors are being actively
planned and promoted by authorities.
outbreak or threat of armed conflict.
Even this, unfortunately, is now relevant to Lake Baikal, albeit indirectly, as many conservation
programs are delayed due to international sanctions and changing economic priorities due to
unfolding invasion in Ukraine.
the management plan or management system is lacking, inadequate, or not fully
Despite decades of communication with the UNESCO the overall management plan\system for
the property has not been created.
threatening impacts of climatic, geological or other environmental factors.
Lake Baikal is extremely vulnerable to climate change, but this is not sufficiently appreciated by
It is obvious that Lake Baikal fully satisfies criteria for inscription on the List of World Heritage
Taking into account the observed widespread environmental degradation and the systemic
problems that Lake Baikal is facing (e.g., the lack of an effective management system), this
property deserves to be inscribed on the List of World Heritage in Danger. Inscribing the
property on this list in times of peace may trigger development of a comprehensive plan for
solving the accumulated problems of Lake Baikal. Such a decision by the UNESCO World
Heritage Committee would be consistent with the spirit of the instructions of the President of
Russia, issued in September 2019, but still awaiting implementation.
Unfortunately, current political situation makes putting Lake Baikal on the List of “World
Heritage in Danger” a potentially counter-productive move in near future, since it will be
interpreted by vast majority of stakeholders as another act of political sanctions imposed on
Russia and therefore intentionally ignored by relevant Russian agencies.
On the other hand, recent success in preventing legislators from opening the Baikal Natural
Territory to wider development of infrastructure shows that some mechanisms to prevent further
deterioration of the Baikal Lake ecosystem are still available to conservation community.
However, there is great likelihood, that all branches of the government will opt to solve their
war-time problems at the expense of Lake Baikal’s ecological health. Expedited development of
facilities for domestic tourism at all costs, which should substitute no-longer accessible
international destination, is the most obvious case of negative impacts on the Lake increasing
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