ICOLD members - Brazil

COMMENTS ON THE WCD REPORT

A contribution from the Brazilian Committee on Dams – January, 2001

The Commission´s two objectives were:

• to review the development effectiveness of large dams and assess alternatives for water resources and energy development; and
• to develop internationally acceptable criteria, guidelines and standards, where appropriate, for the planning, design, appraisal, construction, operation, monitoring and decommissioning of dams.

Comments on the Review

a) Development Effectiveness.

It seems that a major handicap of the Commission’s work was the small and unrepresentative number of dams chosen to carry out both the case studies and the cross-survey. Indeed, what is the representativeness of the 125 dams surveyed with respect to a universe of 45,000 dams?

Drawn from such a limited sample of dams, the Commission’s conclusions are far too general to be accepted as being applicable to the worldwide and more than a century-old dam construction experience. Even taking into consideration the explanations given in the Report as to the criteria that were used to select the sample to carry out the review, one is left with the impression that biases were not eliminated as it would be desirable, since many of the selected dams are well known to suffer from some controversy either in their conception or implementation.

The literature has been focusing on these cases since long time and a variety of reasons have been presented and discussed to explain what happened in each particular instance so that many lessons have already been learned as how to avoid the occurrence of what could perhaps be considered as technical, economical or political flaws. Such lessons were spread throughout the technical and administrative levels involved with dams, more so under the general public and media pressure that developed around them, and were incorporated into practice since then.

It seems that indisputably successful cases did not deserve the same degree of the Commissioners’ attention as if no important lessons could be learned from them. It should be recognized that the simple fact that they are not under the same degree of dispute as those selected, may mean that they have met a significant degree of public acceptance. And they largely outnumber those that are being argued upon.

Another point is that the dams analyzed belong to a wide range of dates of completion.It would certainly have led to more reliable conclusions if they had been classified according to their age in decades, and the increasing progress in environmental studies and mitigation acknowledged.

The total number of large dams registered in Brazil is 594, built along more than a century, most of them quite successful. The construction of more than 200 dams for power production in the last 40 years, resulted in a significant increase in the standard of living of the population as a large majority do have electricity in their households. There was also an enormous increase in the industrial production, which would not have been possible without developing the nation’s waterpower potential since conventional thermal resources are very scarce.

There has also been a significant improvement, in that same period, of the availability of water to households, through the construction of many dams, resulting in a marked increase in health conditions.

Another subject that we would like to comment is the assertion that “Large dams have demonstrated a marked tendency towards schedule delays and significant cost overruns”.

The first comment is that the whole report is written under the perspective of government-built and owned dams, as opposed to the present tendency of privately owned dams (we estimate that this is the case of 80% of the dams under construction in Brazil today).

Also, it is meaningless to talk about cost overruns and delays if they are not compared with delays and cost overruns of other public works. It is well known that there are nuclear and conventional thermal plants built under government ownership with a much worse record than hydro, as it is the case of many other kinds of public works. If such a comparison is not made in a careful manner, it seems that the dams were bad, whereas the conclusion should be that the public administration was bad.

The four Brazilian dams surveyed, Tucurui, Balbina, Samuel and Curuá-Una, do not represent the dams in Brazil at all. They are all in the Amazon region, where very few dams were built so far, and besides the higher potential for environmental problems, they were subject to more delays and consequent cost overruns than the ones that have incurred in this type of problems in the rest of this country, which by no means represent a majority.

Inflation and the public policies to control it along several decades have distorted the relative pricing structure and accountability and should be taken into consideration as a major factor.

These single factors are enough to greatly distinguish the four chosen dams from the majority of dams that were built in the country under more stable economic situation.

b) Environmental performance.

As regards the environmental performance analyses carried out by WCD, it may have been hampered by the same lack of representativeness mentioned above.

The way it deals with the new information on production of GHGs reveals a certain lack of “bona fide”, since it phrases only half-correct conclusions, based upon an interim study and in ambiguous interpretation of facts, that are misleading the media and the general public to draw a false conclusion, which is largely spreading the idea that dams in tropical regions are as bad as conventional thermal plants or even worse.

The assertion contained in the Executive Summary that the gross greenhouse gas emissions data from the Brazilian Case Study are significant when compared with emissions from an equivalent thermal power plant, are not supported in the main Report, nor in the specific report on Tucuruí.

Furthermore, the owner of Tucuruí, Eletronorte, informed that although this specific case study report has not been published in its final version, its current version is less representative of the results and final conclusions contained in the Final Report that was submitted to the Commission in May, 2000, by the Technical Group coordinated by COPPE/UFRJ (Federal University of Rio de Janeiro). Such Final Report had been written by that Group under a contract with WCD, discussed with and accepted by a Committee formed by stakeholders, regional research experts and Eletronorte. It was found that WCD reviewed this report and introduced more emphasis in the negative aspects related to the dam and minimized the positive ones.

The Commission’s Report did not appropriately acknowledge the progress that has been achieved in mitigation measures. The Brazilian current practice shows that there has been a considerable improvement in the decision-making process, as well as in the implementation and operation of the most recent dams. Principles and notions such as ethics, morality, transparency, precaution and sustainability are being increasingly incorporated as it can be easily recognized. To draw a picture of the present Brazilian practice based on Tucuruí, Balbina, Samuel and Curuá-Una is a big mistake and enormously unfair.

It is worth mentioning the important contribution of the dam construction activity in the country in extending the basic knowledge about national ecosystems and history. As paradoxical as it may appear, the contribution to the knowledge of the aquatic fauna and other biomass is notorious, as also is the contribution to the national archaeology, through the research, identification and rescue of relics from areas to be inundated, which would have otherwise remain unknown.

Another aspect is the existence of a very large hydrometeorological gauging and monitoring network, covering a country of continental scale, which has supplied primary data and information for improved dam design and operational criteria, besides providing increasing efficiency in the use of the natural resources, for the benefit of the whole society in quite a wide range of activities.

These aspects were not adequately considered in the WCD Report, leaving an impression that the dam activity in general lacks global consistency in project formulation and that past errors still prevail in the most recent projects. Neither consideration is given to the fact that in-depth scientific and technical knowledge necessary to improve insight into water and energy options has only been accumulated in the last four decades and environmental considerations started to develop in the last three decades.

c) Social performance.

Again in this case, the conclusions seem to be worse than it would be the case if the dams in the WCD Knowledge Base were statistically chosen to provide for a wider range of examples and situations.

The social performance looks like only related to the vicinity of the dam, not including adequately all the beneficiaries on a regional or national scale. It is also most intriguing, rather than fair, to read the following paragraph on page 19 of the Report: “It is only fair to note that popular action also supported dams. Farmers in Madrid recently marched to demand more water and more dams for irrigation.” It is the only reference of this kind in the entire Report, in spite of the fact that many benefits from dams have been acknowledged.

Interesting enough is also the fact that the Report mentions as being US$13 million the annual amount of royalties paid by Itaipu (page 127). The correct amount as demonstrated in the Itaipu web page (www.itaipu.gov.br) is an average of about US$ 100 million per year since 1985. In the year 2000, that amount was about US$200 million!

It seems that the Report tends to minimize the importance of the beneficial aspects of dams.

d) Alternatives.

The Report mentions and sponsors an interesting list of alternatives. These alternatives are valid but fail to meet the increasing demand of water and electricity. The Report fails to acknowledge that it is much more effective to control the demand in a developed society with per capita consumption above 8,000kwh/y, than in a developing country, like Brazil, where it is around 2,000kwh/y.

COMMENTS ON CRITERIA AND GUIDELINES

The criteria and guidelines proposed are good to very good. They are very similar to what ICOLD and some National Committees have been proposing lately. It looks like a state-of-the-art report. However, when the criteria and guidelines are detailed in the text there are several points that are not acceptable, for instance:

“The stakeholder forum participated in assessing alternatives for the detailed layout of the dam, associated infrastructure, and its operation”.

“Improved prediction of project costs by using a frequency distribution of the cost overruns for similar projects”.

In the first case, it is obvious that it is very difficult, if at all possible, to have stakeholders assessing “alternatives for the detailed layout of the dam, associated infrastructure, and its operation”. Assuming that this would be desirable and possible, a question of who would be willing to pay to carry out such a recommendation should immediately be raised. Considering this is a very specific and technical matter, it seems that such a recommendation is made with the only aim to introduce an unnecessary delay and cost in the process.

In the second case, the Brazilian experience shows that cost overruns are not an attribute of dam construction, but are related to other circumstances like inflation, planning, budget management and inadequate procedures of the public administration. Hence, a frequency distribution of cost overruns in dam construction would be meaningless.

In Brazil a considerable progress has been experienced in the last years as to communicating and having the public involvement in the decision-making process related to public and private infrastructure and industry works. This is a long evolving process since the Environmental Law came into being in 1981. EIAs and public hearings have been used for this purpose but the results are still modest since this process requires the development of human resources capacity on both sides of the table. There is no doubt that this is an evolutionary process requiring time, knowledge and training for promoters and stakeholders on how to develop a constructive relationship based on mutual confidence.

There are several papers published in the last two decades on this subject, describing the Brazilian experience in negotiating dam implementation. To mention one of them, “Hydro in Brazil: resolving environmental conflicts”, by Canali et al., in Water Power and Dam Construction, April 1988, deals with the Uruguay river basin development, specially the recently finished Itá dam. In a more general fashion, it is worth mentioning the publication called Mobilização Social by José Bernardo Toro A. and Nísia Maria Duarte Werneck, two authors from the State of Minas Gerais, produced under the auspices of the Ministry of the Environment, in 1995. Several universities, research centers and authors on social sciences have produced a solid knowledge basis, which is progressively being incorporated in the current practice through manuals, regulations and laws.

Most significant is the way the 1988 Federal Constitution deals with the wrights of indigenous peoples. It is established that all water resources development schemes, including hydropower projects, as well as all mining projects, in indigenous peoples’ land can only be authorized by the Congress, after consultation with the affected communities, their rights of sharing exploitation revenues being assured.

Conclusions

The Report has two very distinct parts. When it deals with the development effectiveness and social and environmental performance of the existing dams, it merits little credit by the way the dams in the Knowledge Base were chosen.

Besides, it must be stressed that the utility of dams, their efficiency, cost and benefits, and social and environmental compatibility should have been analyzed and judged taking into account the overall development they are part of.

In Brazil, the dams have provided a significant increase in the standard of living of our society. However, the general “conclusion” reached by WCD, that the dams in general had a poor performance, is what has been published intensively by the local media.

When proposing guidelines and a new decision model, the second of its mandate, WCD adopts an indisputable approach, as it lays their foundations on the broad-spectrum Declarations that constitute benchmarks for public policies of all modern nations. These Declarations deal with human rights or environmental protection, such as the United Nations Declarations on Human Rights (1948), on the Right to Development (1986) and on the Environment and Development (Rio 1992), all converging to assure citizens’ rights and to reaffirm ethical principles that should be observed by citizens, governments and nations in the constant search for well-being and development.

It can be said that the general principles of the WCD Report do not innovate with respect to what is already provided by the present Brazilian Laws and dam planning practice. However, we understand that many of the procedures proposed are not directly applicable as stated, deserving further discussions and improvement.

“The Commission's framework for decision-making is based on five core values - equity, sustainability, efficiency, participatory decision-making and accountability.

It proposes:

• a rights-and-risks approach as a practical and principled basis for identifying all legitimate stakeholders in negotiating development choices and agreements;

• seven strategic priorities and corresponding policy principles for water and energy resources development - gaining public acceptance, comprehensive options assessment, addressing existing dams, sustaining rivers and livelihoods, recognizing entitlements and sharing benefits, ensuring compliance, and sharing rivers for peace, development and security; and

• criteria and guidelines for good practice related to the strategic priorities, ranging from life-cycle and environmental flow assessments to impoverishment risk analysis and integrity pacts.”

These recommendations unfold in a sort of check list to be followed in decision making to implement or not to implement a dam. However, they raised controversy since the moment they were published by WCD, not for the principles they are based upon, but because of inadequate details of the way WCD proposes they be used. Moreover because of the risk that their use become mandatory as a result of a hastened consensus, setting a much too high standard for all countries that are presently considering the implementation of new dams. Needless to say that these are developing countries, which would then have to bear a very heavy burden of requirements, no matter their technical or institutional capacity. It should be stressed that such a heavy burden do not refer to political or moral reforms mainly, but they certainly include an enormous technological effort to collect all data and have all the apparatus and methodologies to understand and perform multi-criteria decision making studies, in order to answer all the questions that the proposed new model will require from governments, entrepreneurs, citizens and stakeholders alike.

According to the Report “The debate about dams is a debate about the very meaning, purpose and pathways for achieving development. Through its Global Review of the performance of dams, the Commission presents an integrated assessment of when, how and why dams succeed or fail in meeting development objectives. This provides the rationale for a fundamental shift in options assessment and in the planning and project cycles for water and energy resources development.”

It is quite possible that if not adequately absorbed and treated, the new guidelines and criteria will cause significant cost increases and schedules overruns, and thus lead to the adoptions of less adequate alternate solutions as compared to those that would be the natural choice, considering the prevailing conditions in a given country, as it is the case of Brazil, where there is still an enormous hydropower potential that can and should be developed before other costlier alternatives.

The WCD Report had the merit of bringing into discussion important points related to the dam business. The results are however unbalanced by what seems to be a prejudice in not properly considering a larger sample of dams, including well succeeded examples. Despite that, the dissent about dams is put in evidence to justify a rather self-confident tone in the Report.

We believe that there is a long way to go until the Report is fully digested and its meritorious points accepted by all parties involved in a new dam project.