ICOLD members - Canada

Comments from Canada

- Some Canadians do not fully endorse the WCD report and recommendations. The main critic is the biased diagnostic of the past performance of large dams. The overall impression is that dams are negative to the environment and that many benefits are ignored. Even if we agree with WCD recommendations on the policy framework and strategic priorities, we consider that many specific recommendations and implementation guidelines are unrealistic or excessive. They could be easily applicable to developed countries, but could not be so easily adapted to developing ones and surely not be applied to past project or the one in the pipelines.

- The geographical distribution of commissioners is odd although this may be a coincidence: why two delegates by country when Russia and China - for example - are absent? The report says commissioners are acting, as individuals not representing their organizations or country, is it realistic?

- Much emphasis in the report is put on assessing other options to large dams. This is not surprising when you consider that the WCD mandate was to both: 1. Review the development effectiveness of large dams and 2. Assess alternatives for water resources and energy development. The same applies to the emphasis given to dams being evaluated "in the broader context of development choices". These are "generalized premises" that lead and drive the report results.

- In the section on What is the debate About? this becomes obvious when it is said - as a conclusion - that building dams today is rarely only a local or national decision about cost and benefits but one where dams in general are the focus of a global debate about development strategies and choices.

- Not at all evident that the choice of detailed case studies are representative. What criteria were used? The number (8) seems insufficient given the scope of the mandate and broadness of the conclusions found in the WCD report. The North / South and temperate / tropical / desert distribution seems uneven or at least should be explained. Impacts are obviously very different depending on the climate, geography and culture. Why choose as an example the Grand Coulee dam on the Columbia River, which is presently part of one of the most controversial and complex hydropower river basin in North America? Again, why choose the Pak Mun dam on the Mun-Mekong River basin in Thailand? Pak Mun is one of most controversial project in the region and - beyond doubt - the most contested hydropower project in Thailand?

- WCD Knowledge Base: ICOLD, IHA and/or others should consult or verify "systematically" the validity and accurateness and asses the limits of the 8 case studies, country papers on China, India and Russia, the survey of 125 large dams and most importantly on the 17 thematic reviews on social, environmental and economic issues, on alternatives to dams and governance and institutional processes. Some very complex thematic paper as only scratched the surface of the issues related to dams and did so on a very limited budget. The WCD reports - at least it summary -seems much more categorical and definitive.

- WCD Evaluation of Performance: Should the criteria to evaluate the performance of dams be solely the "targets set by their proponents" that provided the basis for government approval and financing? Conclusions are broad, general and often far-reaching. They should also be validated by specific references and numbers (and check i.e. reports appendixes and quality of data).

- Technical, Financial and Economic Performance. Numerous affirmations need to be verified or put in context with much more nuance. For example, "irrigation dams have typically failed to recover their costs" is a generalization which is false as soon as you begin qualifying the statement: type, where, what were the economic benefits, effect on GNP, ... Half of the world's dams are built exclusively for irrigation. Most of them are not cost effective or beneficial (more accurately formulated)? Another example: municipal and industrial water supply have had poor cost recovery means nothing as stated and here one may even wonder why cost recovery is emphasized. The marked tendency towards schedule delays and cost overruns is surely not specific to dams, it applies to most after war large engineering and construction projects and has seen marked improvements in cost planning. The statements on dam safety and integrated flood management are not, as implied, the results shortcomings related to the effectiveness of dams, but concerns that have appeared or evolved through time.

- Technical, Financial and Economic Performance (continued). The summary report says that it is surprising that substantive evaluation of project performance is so few and narrow in scope. ICOLD, IHA and others should provide examples to the WCD.

- Ecosystems and Large Dams Performance: Once again "the WCD Knowledge Base make it clear" and its conclusion "on balance more negative" "in many cases have lead to significant and irreversible loss of species» are very general and far reaching affirmations that have little meaning when not properly put in context and backed by data.

- Ecosystems and Large Dams Performance The reports present the greenhouse gases emitted by reservoirs in an incomplete and almost misleading and biased way. Sounds wrong to say the emissions are significant relative to emissions from equivalent power plants? Why not refer to "net" emission instead of "gross" emissions? It also seems like a cop out (running away) to say more research is required on a case by case basis to demonstrate the capacity of hydropower to offset climate change.

- People and Large Dams: 40 to 80 million people displaced? Where does this data come from? On the whole this section repeats what is already very well known - documented and presented by many - about the shortcomings of relocation and down stream effects on peoples livelihood. Most everyone involved in large dams agrees on these shortcomings of the 60/70/80 and are know working hard - often cross agencies - towards improving practice through better policies and procedures. For example, most resettlement plans now take into account livelihood and even have the improvement of the social and economic welfare as a goal (WB). There are more and more good practice case studies around (i.e. in China who has become the leader). Thus the WCD report seems to be emphasizing well known shortcomings while ignoring the lessons learned and the most recent good practices. ICOLD, IHA and /or others should provide the WCD with these more recent practices and put in these criticisms in the context of current practices.

- People and Large Dams (continued): On the other hand, the WCD report touches a sensitive issue and is most probably quite often accurate when it says that the "the poor, other vulnerable groups and future generations are likely to bear a disproportionate share of the social and environmental costs... without gaining a commensurate share of the economic benefits". The inequities in the distribution of costs and benefits towards local populations ethnic minorities and other vulnerable groups is a core issue the dam industry and other constituencies must better address. This has already begun, for example in the work currently being carried out ADB and others agencies in Laos.

- People and Large Dams (continued): " the true economic profitability of large dams remain elusive as the environmental and social costs of large dams were poorly accounted for in economic terms" Does the WCD ignore the planning process and macro-economic analysis of government organizations or private enterprises ? Sure the environmental costs are the weak link, but economic and social benefits are often well documented. This is once again a general and far-reaching statement that probably merits a response.

- People and Large Dams (continued): and " failures ... have led to the impoverishment and suffering of millions giving rise to the growing opposition to dams by affected communities worldwide". This is ideology almost propaganda: back it with data, show tendencies where and when, and current practices.

- Options for Water and Energy Resources Development: The Dam Industry (or at least the hydropower industry) should be able to say categorically that it agrees with every statement on page 18 (4 bullets) of the report overview and already applies and actively promotes such policies and practices when applicable, although in certain circumstances it cannot substitute itself to the agencies and governments responsible for such policies and practices.

n Decision-Making, Planning and Compliance: A general but important comments is that many of the criticism towards dams can be applied to almost every large infrastructure project: roads, airports, channels, including urban planning and housing development. Many urban planning schemes are seen as mistakes today, but practice improves from learning and everyone cannot be compensated for past decisions that were thought at the time to be sound. This may be evident, but when assessing a dam built in the 1950, it is only fair to use as a yardstick the criteria and context of the time.

This should be keep in mind when the WCD reports present the difficulties of foreign assistance, corruption problems and, in particular, when the WCD Knowledge Base is cited to reveal " a generalized failure to recognize affected people as partners in the planning process, with rights, and to empower them to participate in the process". Most of the countries in the world do not even have the basic institutions to allow such democratic participation. Many developing countries consider (as we once did) basic infrastructures as key components of their development that will benefit the people down the road. And, most important, participation and partnership must defined and adapted according to the cultural, social and political context. There are serious barriers to overcome if the WCD attempts to impose too literally our western views of "participation" and "partnership" to all irrespective of differences. Furthermore, when one opens the debate to "rights", we must keep in mind the present political and human rights landscape in the world where democracies and the rule of law vary enormously.

Within this context and limitations, We believe it is in the best interest of the Dam Industry (or hydropower industry) to agree with the WCD and support participation and transparency as earliest as possible in the process. The 5 bullets on page 19 of the report overview are hard to refute and there is certainly some basis to the last paragraph arguments on the momentum that can carry a project with little room for environmental or other social considerations.

- Decision-Making, Planning and Compliance (continued): "failure of dam proponents and financing agencies to fulfill commitments made, observe statutory regulations and abide by internal guidelines» is a killer and we al know of examples, some quite famous. These "bad or worse practices" tend to reflect upon the whole industry and affect its credibility.

- Decision-Making, Planning and Compliance (continued): Recommendations based on recent examples and good practices are for the most part already implemented or seem at first glance acceptable with the exception of: 1. Resolving past inequities and injustices (drop it or must be specific criteria as to when and how and limited or linked to operations) 2. Incentives, sanctions and recourse mechanisms for environmental and social performance (must be careful not to generalize or duplicate the existing practices or regulatory frameworks or financial operatives).

- How Can We Achieve Better Outcomes? Human rights "per se" can be a component among others, even an important, but cannot be the basis for dam or any other major infrastructure assessment: This is a reality check. But once you read beyond the ideological discourse, the rights and risks approach seems to be there for the sole purpose of finding a way to allow stakeholders to be included and taken into account in the assessment process where they are not. The WCD is trying to determine who has a legitimate place at the table, who should negotiate and how: no small task, although nothing new! To say in such a manner that this will provide a more effective framework for integrating economic, social and environmental dimensions seems pretentious. How will it do so? Figure 2(From rights and risks to negotiated agreements: a framework for options assessment and project planning) sounds like they want to create a review and mediation process that will be "independent".

- How Can We Achieve Better Outcomes? (continued): The five core values: equity, efficiency, participatory decision-making, sustainability and accountability. Should not represent a problem to the Dam Industry. We should support them. All will depend on how each value is defined and there is a lot of room there to maneuver taken into the constraints that need to be addressed.

- Strategic Priorities for Decision-Making: Gaining Public Acceptance: Seems to go way to far, not on the principle which we should agree with, but on the how to or what must be achieved. Who must make available support to all stakeholders? who must negotiate agreements ?, what are informal indigenous peoples representative bodies ? Again, we should agree with the principal but it sounds very idealistic as such without more development on the how to and who is responsible.

- Strategic Priorities for Decision-Making: Comprehensive Options Assessment: "development need and objectives are clearly formulated through an open and participatory process before" Sure, but this is basic public policy and government planning way before the energy options appear of which the dams constituents have little if any control. So we can agree, but have no control on the matter. "Social and environmental aspects are given the same consideration as technical, economic and financial» We should have no problemon this item, even be willing to promote it. But, of course, the scope of these considerations would limit themselves to what the project proponent or agencies involved can control or influence. " Increasing the effectiveness and sustainability of existing dams and energy systems should be a priority:" We should also agree on this item and document what is already being done for the benefit of the WCD and other parties.

- Strategic Priorities for Decision-Making: Addressing Existing Dams: We believe that sooner or later, industry, organizations and governments will not have a choice but to address the outstanding social issues and worse dam cases. Principles can be designed, but it should remain limited to specific types of problems with flexibility on how each case is approached. The process has already begun through licensing in the USA (and the Endangered Species Act), New Zealand and elsewhere. However, it should not be extended at large to all dams solely by principle. It should apply only to "problematic" dams and future dams.

- Strategic Priorities for Decision-Making: Sustaining Rivers and Livelihoods: Most of what is in this section, we should support and promote and emphasize what is already being done. Our support depends on the emphasis given to each item, for example, how you define the precautionary approach.

- Strategic Priorities for Decision-Making: Recognizing Entitlements and Sharing Benefits: "The state and the developer bear the onus»! Agreements become a legal document thus much more binding. Are they universally applicable? Profit Sharing is definitely not extendible to all contexts it needs to be further debated and put in context before making it a principle. It depends on the cultural, social, political and even legal circumstances. Entitlements seem more promising.

- Strategic Priorities for Decision-Making: Ensuring Compliance: This item is at the heart of good practices and represent a significant part of where improvement of the efficiency of environmental and social assessments is required i.e. in the sense that the best studies in the world are worthless if the mitigation measures and other recommendations are not implemented and follow through adequately. The report calls for an independent review of compliance. We believe it depends on the context. Where the government or other agencies have the capacity to do so, they should review themselves.

- Strategic Priorities for Decision-Making: Sharing Rivers for Peace, Development and Security: Don't see anything new here that you cannot already find in International agreements or transboundary rivers policy. The GEF has an important program that should be cited by the WCD as addressing international cooperation on global water issues on transboundary waters.

- A New Focus for Planning and decision-Making: The five critical decision points identified by the WCD are standard. The issue here is to test compliance at each stage before giving the green light to the next. Not realistic in the abstract, but can be livable if put into context and adapted to each decision points.

- A New Focus for Planning and decision-Making: Dams in the Pipeline: The "call for an open and participatory review of all ongoing and planned projects to see if they need to bring them in line with the WCD report" seems out of lineand to be applied on a case by case depending on specific circumstances. The decision is to the proponent, financial institution or government. It is impossible to reach 100% of the Stakeholders.

- A New Focus for Planning and decision-Making: Dams in the Pipeline: By far, except probably for its database, the most important part of the WCD report is the Criteria and Guidelines section in Chapter 9, 43 pages of how and what to do. This can influence the feasibility of ongoing or future projects. We would suggest comments by ICOLD, IHA and others be detailed and well documented in order to respond to the report. We could decide to simply ignore them and build industry wide criteria and guidelines that are more viable and realistic. We should evaluate the impact on projects in the pipelines in terms of costs and scheduling.

- What's Next? : They are recommending that professional associations develop processes for certifying compliance with WCD guidelines and that ICOLD World Register of Dams include social and environmental parameters, we agree.

- What's Next? (continued): they are recommending that the private develop and adopt voluntary codes of conduct, management systems and certification procedures for best ensuing compliance with the WCD guidelines, including through ISO 14 000, we agree.

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- What's Next? (continued): they are recommending bilateral and multilateral agencies respect their guidelines and shift towards programs and option assessments, no comment.

- CONCLUSION: based on reading the overview, we need to review the WCD data base and put in perspective its many general statements and, most importantly, react to its guidelines which are the cornerstone and most probably the only lasting result of the report which can affect the Dam and Hydropower industry.

PL, GG 08-02-2001