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Response to the Final Report:
International Hydropower Association
IHA Comments on the Final Report of the WCD - February 2001
The problem, though, is not the dams. It is the hunger. It is the thirst. It is the darkness of a township. It is township and rural huts without running water, lights or sanitation. It is the time wasted in gathering water by hand. There is a real pressing need for power in every sense of the word. Nelson Mandela (WCD Launch, 16 November 2000, London)
Thus Nelson Mandela eloquently expressed the root of environmental and social degradation: under-development and poverty. The International Hydropower Association aspires to help alleviate underdevelopment and poverty, and we believe that this is also the aim of the sponsors of the World Commission on Dams. It is in this context, and as a member of the WCD Forum, that we wish to express a number of concerns on the WCD's Final Report and propose a way forward.
The objectives of the WCD 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.
We feel that the report recognizes and develops a number of constructive principles, such as:
a fair and realistic assessment of options
sector and river basin studies to get a portfolio of broadly acceptable projects
protecting some rivers and developing full cascades on others
involving the people affected and making them beneficiaries
retrofitting existing dams with a hydropower component
guarantees for social and environmental mitigation works
However, the overall tone of the Report is undoubtedly negative as regards the role of reservoirs, which undermines the constructive elements. The opportunity was not taken to use the Forum as a sounding board ahead of publication of the Final Report, despite the claim in the overview that the Forum was consulted throughout the process, which could have helped set the right tone.
The Report rightly exposes the plight of the disinherited; those who suffered and were not compensated for their lands, or livelihoods, as a result of some poorly planned dams. It demonstrates the significant changes in aquatic ecosystems after dams have regulated a river; however, less attention is given to the needs of millions for water supply, irrigation for food, flood control and power for industry, schools and homes.
Dam proponents do not deny that reservoirs bring about environmental and social changes. These predicted changes, both positive and negative, are ingredients for the process of options assessment. The fact that there have been projects with adverse environmental and social impacts in the past does not mean that a system which could obstruct water resources development in the future is needed. In our opinion the Report of the WCD, while failing to acknowledge fully the critical role of reservoirs for the welfare of society, goes way beyond the point of stopping unfavourable projects from being developed, by recommending criteria/guidelines which could impede well conceived and urgently needed projects. In some developing countries this could have the effect of imposing under-development and thus failing to alleviate poverty.
Dams and the Environment
The report's observations on the negative environmental impacts of dams are presented in detail, but little is said about industry's increasing efforts to mitigate these. It must be borne in mind that all human activity affects the environment in some way, whether for good or bad. The Report also acknowledges that in some cases "enhancement of ecosystem values does occur, through the creation of new wetland habitat and the fishing and recreational opportunities provided by new reservoirs."
Similarly, some forms of energy have a greater impact on the environment than others, and while such comparisons cannot always be precise, it is important to note the advantages of hydropower over other forms of electricity. Relying on a clean and renewable resource, hydropower converts the natural flow of water into electricity without wasting or depleting water in the production of energy. Hydropower produces very few greenhouse gases. Studies have shown hydropower to produce some 60% less than coal-fired powerplants and 18% less than natural gas powerplants. Hydropower represents 19% of all the electricity produced in the world and without this contribution to world energy needs the climate changes associated with greenhouse gasses would be more advanced. To date, only about one third of the identified projects have been developed, so there remains a significant potential for hydropower development to continue to contribute to improving the problem of climate change.
Local Communities and Process
Today, in many countries, hydropower projects are subject to a comprehensive environmental assessment that covers the planning, construction and operation of the facility. And in many countries legislation also requires the participation of all parties involved, including the local population that might be affected by the development of the project. Local communities are invited to collaborate in identifying ways to alleviate some of the negative impacts of a project (for example, reforestation, wetland establishment and fish reclamation), and to ensure that they benefit from the project (improved quality of life, employment and business opportunities, and long-term share of revenues). This rigor is not universal, but is increasingly common.
WCD review of development effectiveness
Few would dispute that the report gives a bleak picture of the social, environmental and economic costs of dams, while barely addressing or recognizing their benefits. One of the first stated aims of the WCD was to remove the impasse that had developed between those for and against dams, at a time when a number of NGOs had called for a moratorium on the construction of dams. It is unfortunate that the same organizations are now using the Report to vindicate their claims.
The Report underplays the correlation between reservoir development and human life expectancy, and the fact that energy and water security are prerequisites for environmental protection. It also does not acknowledge that more than one billion people benefit from hydroelectricity.
The WCD acknowledges that it has reviewed a small fraction of the more than 45,000 large dams. Indeed only eight dams have been investigated in detail, seven of which were developed more than 20 years ago, most of them at a time when environmental assessment and mitigation did not even exist as a concept. The main criterion for selection of the case studies was based on the number of adverse impacts that could be demonstrated by each dam.
With regard to the WCD estimate that 40-80 million people have been displaced by dams, we would like to put on record that even the original author of this extrapolation (World Bank 1994) has expressed disappointment and surprise that the Commission adopted these figures without further research. We are disappointed with this approach. If this strategy is applied, the WCD should have presented the other side of the argument, making it clear that more than 1,000 million people benefit from hydropower. Taking the worst-case WCD figures for displacement, and assuming hydropower represents one large dam in four around the world, then about 10 to 20 million people would have been displaced by hydropower development - many of them have an improved quality of life following resettlement, through the provision of better housing, education, sanitary services, training, and so on.
The WCD states that the aim of any project must be the sustainable improvement of human welfare. We consider that dams have performed well in this respect. For example:
About 1 billion people depend on food produced by dam-related irrigation. There is no suggestion of how this food could have been produced by other means.
The report paints a negative picture of health impacts of dams, while the positive aspects are not mentioned:
1. huge benefit of food production
2. major reductions in respiratory problems, and premature deaths, by reduction of emissions of SO2, NOx, particulates and toxic metals emitted by fossil fuel combustion
3. hydropower schemes, with few exceptions (namely large, shallow reservoirs coupled with small installed capacity) offset greenhouse gases in a significant way and is one of the most important combatants of climate changes. Hydro should be credited for it.
4. benefit of having inexpensive electricity to support essential services, such as local food processing industries
5. benefit of having drinking water all year round, even in dry periods
6. reduction of the intensity of floods, which are a major threat to health.
These benefits of dams are hardly covered in the Report.
Cost overruns
Contrary to the assertion in the Report, World Bank data on cost overruns show a slightly better performance for hydropower projects when compared with thermal projects.
Construction delays
If public works should not be built because of construction delays, virtually nothing would ever be built. There are many examples of projects which have encountered construction delays and have still been highly useful and profitable.
These two problems are not specific to dams, and therefore should not be used as arguments against them.
Analysis of Options
The Commission's report creates an analytical bias that puts the blame, and therefore the onus of improving its ways, exclusively on dams, and not on any of the other options. Although it is proposed that all projects should be investigated thoroughly, Fig. 9.2 (p263) proposes that all five key decision points (relating to needs assessment, selecting alternatives, project preparation, project implementation and project operation) should apply only to dams. Following the second stage for "non-dam options", the advice is simply: "Assign responsibility for implementation".
To assess the development effectiveness of large dams, it is important to compare dams with other options for water storage (groundwater, decentralized storage and rain-fed systems) and the power sector (coal, nuclear, gas or oil). Thermal power, which, together with hydropower, provides nearly 100 per cent of today's electricity, will continue to provide most of it in the foreseeable future.
The report fails to recognize that if a hydro plant is not built, the replacement option will in fact be a fossil-fuel or nuclear powerplant with consequent environmental impacts and political concerns. Instead, the Report proposes theoretical potentials of decentralized micro power and fuel cells, which might be appropriate for remote areas, but cannot contribute significantly to the anticipated future demand in urban and industrial areas.
The IHA does not pretend that hydropower can meet exclusively the world's increasing energy demand. We believe, however, that hydropower can contribute significantly to the supply of clean renewable electricity. In addition, hydro reservoirs offer the only way to store energy at an industrial scale. Therefore, it helps thermal plants operate more efficiently (generating less pollution by steady-state operation), and, at the same time, hydropower offers the essential backup to the intermittent renewable sources (for example, wind and solar power), which cannot provide a reliable service alone.
For fuel cells, the Commission fails to recognize that hydrogen is not a source of energy, and must generally be produced by fossil-based sources. This means that costs will remain high and environmental benefits uncertain.
We support the Commission's proposals concerning demand-side management, which should produce large benefits for some countries; but demand-side management cannot solve long-term growth in electricity demand nor address the basic energy needs of the 2 billion people that are lacking or the 3 billion population growth expected by 2050.
The WCD Recommendations
The Commission refers to the UN Declaration of Human Rights (1948), to the Declaration on the Right to Develop (1986) and to the Rio Declaration on Environment and Development (1992). This is universally accepted. Also, the core values identified by the Commission: equity, efficiency, participatory decision-making, sustainability and accountability, are similar to those which have been adopted by the IHA. If all countries could integrate these values into their respective energy and water resources policies, we believe that there would be reliable, affordable, and safe access to water, food, and electricity with minimal impact on the environment world-wide.
Strategic priorities
We are in basic agreement on the principles, but their implementation requires further consideration and must always be in accordance with national legislation in order to make it applicable.
Gaining public acceptance.
From the key Message:
"Decision making processes .... are used that enable informed participation by all groups of people, and result in the demonstrable acceptance of key decisions." (p.215, our emphasis)
Public acceptance is an objective for most decision makers, particularly politicians, and the IHA supports the notion of seeking public support for projects.
Experience tells us that the requirement for complete public consensus would stall almost all progress. The competing nature of interests involved in water resource development (navigation, recreation, water use, energy, fisheries, riparian community needs) make such consensus elusive.
The proposal that a broad open and public debate will bring a unanimous decision is naοve. Public debates, if well managed, will clarify the particular interests and positions of each interest group (including local people and project proponents), but the fact remains that governments will have to arbitrate.
Similarly, it is not clear if stating that the decision-making process must be guided by the free, prior and informed consent of indigenous and tribal people is effectively giving a veto right to development projects. Should this be the case, it would mean giving such a right to one constituency, at the expense of the rights of others. This contradicts the spirit of the Report's emphasis on equality.
Comprehensive options assessment.
All options must be treated at the same level and with the same degree of detail, with sufficient data available. However, the options assessment should not be allowed to become an open-ended process, otherwise none of the options would be implemented.
Addressing existing dams.
The notion of optimizing benefits from existing dams is coherent, but it assumes that there is still much room for such optimization. The real life situation for most hydropower dam operator is that such operation is under strict regulatory operating rules, including existing environmental and social considerations.
Many jurisdictions do impose such operating rules and where such rules do not exist, the dam operator often self-imposes its own rules, in terms of dam safety, agreements with local communities, and environmental matters.
Furthermore, even when dams where built prior to EIAs (20-30 years ago), the major refurbishment required to maintain the civil, mechanical and electrical works of a dam are nowadays submitted to a full process of environmental and social assessment, allowing the public to revisit the dam's operations.
The proposal for a "comprehensive, integrated, cumulative and adaptive" periodic evaluation at intervals of 5 to 10 years (p.227) is unnecessarily frequent and an inappropriate use of resources. Each evaluation might easily take some years, particularly if it is a participatory process. This could mean a continuous cycle of reviewing and potentially changing operating parameters. Under these conditions, financial planning would be impossible and investment for new projects would not be found.
If this frequency of evaluation were to be imposed, there is no mention in the Report of the compensation which would be required if revenues from a project were diminished following a significant shift in the operating mode.
Dams are evaluated every 25 or 50 years at re-licensing or refurbishment, or earlier if specific issues arise, and this has worked well in most countries where such procedures are in place.
IHA recognizes that major past grievances must be addressed through dialogue and negotiation between governments, dam owners and operators and affected parties based on scientific studies and equity principles.
Sustaining rivers and livelihood.
From the Key Message:
"Rivers, Watersheds and Aquatic ecosystems are the biological engines of the planet".
This summarizes the underlying philosophy that man should not interfere with nature, and therefore, implicitly, dams should not be built. Unfortunately, such statement are slogans rather than science.
The requirement in section 4.1 reads:
"A basin-wide understanding of the ecosystem's function, values and requirements, and how community livelihoods depend on and influence them, is required before decisions on development options are made."
Such an understanding of ecological processes does not exist today. It takes a generation of scientific teamwork to understand the ecology of a boreal pond, let alone of a complete watershed. Stating the above as a prerequisite for development is a guaranteed postponement of any project.
IHA supports that necessary studies should be conducted to ensure the correct balance is achieved between sustaining rivers and required development. Changes do not necessarily detract from the value which rivers provide to the environment.
Recognizing entitlements and sharing benefits.
Recognizing entitlements and sharing benefits with local communities are essential preconditions for sustainable development, and the IHA supports the concept of benefit sharing. However, we are concerned about the practicality of all affected people being part of the negotiation process.. The approach is a heavily legalistic process with binding contractual agreements (p.242-243). Master contracts and performance contracts, with communities and families, binding the government(s) and developer(s). The intent is noble, but the end result would be a lawyer's dream, diverting resources from the just beneficiaries. It should also not be overlooked that 'affected people' also include those who will not receive services if the project is blocked. The interests of those affected by non-construction of a project should also be taken into account.
Ensuring compliance.
The Report addresses an important issue, that of compliance, or lack thereof. The common wisdom regarding compliance is that there are rogue projects, which represent a small fraction of all dams, where compliance to existing regulations or best current practices is lacking. Ensuring compliance would then mean identifying such problem cases and ensuring that specific measures are taken, tailored to the local conditions to solve the problem(s).
The approach by the Commission is quite different: It proposes an all-encompassing solution, the creation of Compliance Plans, for something that might really affect only a fraction of projects. This is, again, an unnecessary burden imposed on all, including those who quite willingly already comply.
We endorse the recommendation in the Report for incentives for those organization which have a positive track record in compliance. (policy principle 6.5).
Compliance should be under the auspices of the relevant competent government authorities, and in the event that such an authority does not exist, it should be created.
Sharing rivers for peace, development and security.
This Strategic Priority addresses the specific problem of transboundary rivers, emphasizing the need for co-operation between political jurisdictions on issues relating to dams and water diversion. Among the proposed solution, the policy principle 7.3 is problematic, as it puts the authority of "an independent panel" above that of a state, raising issues of national sovereignty.
It is essential to respect existing treaties between countries, especially as these have often taken several years to negotiate and include set procedures for project development. Countries with transboundary rivers will not welcome imposed conditions that supersede such agreements.
Criteria
The WCD has identified five key decision points in the process of planning and project development, known as 'WCD criteria':
Needs assessment
Selecting alternatives
Project preparation
Project implementation
Project operation
History tells us that this process is more complicated. The list of criteria proposed is not complete, and their proposed application is not clear as regards definition of relevant expertise and responsibilities. Based on the experience of some decades of political and technical issues, three major phases are generally developed in sequence: water resources planning, the establishment of development plans and implementation.
Water resources planning involves the definition of a policy and of objectives. The needs and resources are determined, quantified for the short-, medium- and long term, and scheduled, with all their uncertainties, potential risks, necessary flexibility and so on.
Development plans are the 'fruit of the planning tree'. To satisfy the needs, different options are considered, taking into account technical, economic, social and environmental aspects. Criteria of choice are established by those with relevant knowledge and experience involved in a transparent process. The choice itself between options is made at the political level, by a weighting of the different criteria. In many countries public consultations are held prior to governmental decisions.
The government is deeply involved, at the highest level, in these first two phases, because it is fundamental to the development of the country. The government must take care of the general interest of the population, without neglecting the minorities. The protection of social and environmental interests at this stage is realised within a political framework. Depending on the development stage of a country, an important preliminary phase of pre-planning may be required in which this political framework is engaged, with specific national laws and rules.
The third phase concerns the stages of implementation of a scheme, from the feasibility studies through to operation. In particular, two essential stages, the concession and authorization to build, offer strong protection to the potentially affected people. Prior to this, an environmental and social assessment report is established under the jurisdiction of the legal authorities, and the early involvement of potentially affected people is essential to develop informed opinion, good mitigation measures and efficient compensation packages.
WCD Guidelines
Within the 26 WCD guidelines there is often an unclear definition of the process, division of responsibilities, scheduling and financing between the parties involved. For such detailed guidelines to be applicable to all projects in all countries, there may first have to be some degree of world-wide standardization of national/regional political and legal frameworks.
We understand that the guidelines were developed as a starting point for further refinement, and not with the intention of them becoming laws for compliance with the recommendations. We believe this to have been a common misunderstanding by reviewers of the WCD Report, to the point that the guidelines are now assuming this status. There is a strong lesson to learn from this.
Indeed, the guidelines demonstrate many good ideas in the Report, but also demonstrate the difficulty of adding detail to general values, while maintaining international applicability. There is a tendency to be too specific, and some guidelines are contradictory or overlapping. For example, guideline 16 implies that each project should have a fish pass, which may not be appropriate in all cases. By way of further explanation, the first few guidelines are briefly discussed:
No. 1 - Stakeholder Analysis: the suggestion of financially supporting stakeholders, including external NGO groups, throughout the planning and project cycles would create a lose-lose situation for the developer. It takes away the independent nature of such a group if support is given, on the other hand, the developer will be considered negatively if the support is not given.
No. 2 - Negotiated Decision-Making Processes: if taken literally, the guideline implies that all stakeholders should be involved in every detail of the design: the selection of the plant's electronic control system for example. The guideline also demonstrates the major risk of this proposal, that is, if members of the forum do not share a genuine desire to find an equitable solution.
No. 3 - Free, Prior and Informed Consent: this overlaps with No. 2 to some extent. Also, it implies that a very small minority might stop or delay a project against the wishes of the majority in a local community. It also implies that this consent should be sought time and time again throughout the entire planning and project cycles.
No. 4, 5 and 6 - Strategic Impact Assessment, Project-Level Impact Assessment and Multi-Criteria Analysis: show a preoccupation with environmental and social aspects; such assessments should balance all aspects including technical and economic aspects. The proposal that such analyses should be driven by a stakeholder forum in unrealistic.
No. 7 - Life-Cycle Assessment: the IHA supports life-cycle analyses, but it would be impractical to carry it out for every project. In the case of both energy and water storage options a representative sample should be taken for each source available to a country and comparisons made to aid future planning.
No. 8 - Greenhouse Gas Emissions: as with No. 7, we recommend that appropriate and realistic studies are carried out on representative cases and not for every project. There remains a lack of incentive for this research while there is no credit for avoided emissions.
Conclusion
The fundamental purpose of creating a reservoir, which is development, is not reflected in the Report. Reservoirs are necessary to store water, which is not evenly distributed in space or time. 45,000 dams exist, and a large number will have to be built during this century if we wish to supply the 2 billion people currently without water and the 3 billion increase in population expected by 2050. Climate change will impose more water storage, more flood control infrastructures and more electricity production facilities with low emissions. Hydropower can make a significant contribution.
A development policy in a country should be implemented in accordance with the demographic pressure, with efficiency, in a democratic way. Local people should have a say in the general design and in the mitigation and compensation measures relating to implementation and operation.
The result of decision-makers hastily imposing the 26 WCD guidelines (making them regulations) would be that the process of studying and constructing dams would become extremely lengthy, costly, and even more uncertain. Financing organizations might only support countries applying these rules, some aspects of which are impractical. This would initiate a process of sustainable under-development, and may increase divisions between countries that have developed reservoirs and those that have not.
There is no justification for human suffering, particularly in the implementation of infrastructure intended to promote human development, be it roads, airports, or dams. Efforts should be made for all stakeholders to benefit. Negative impacts should be avoided if possible, and otherwise mitigated and compensated fairly.
Long before the existence of the WCD, the focus on environmental and social aspects of reservoir development was established, and today few would deny that they are the profession's core values, alongside technical and economic considerations.
As has been documented in the IHA/CHA/IEA-Hydro White Paper , we strongly support fair and realistic assessment of water and energy development options.
The IHA, with its membership in 61 countries, will work with parties committed to solving the problem of insufficient supply of water and energy in an environmentally, socially, technically and economically acceptable way. That is, refining existing principles for a clear, efficient process of assessment, selection, licensing and management of good projects, in accordance with state authority.
The WCD has raised very important issues and it has proposed a set of core values and strategic priorities that we share in principle. However it has proposed guidelines which are not always practical or universally applicable, and could thus prevent good projects from going ahead if they become 'regulations'.
The IHA recommends that the World Bank take the lead in forming a working group that will try to design a fair and feasible process to select, design, build and operate new dams with a real involvement of the local population.
The working group would start from the issues identified by the WCD: the strategic priorities, core values and the concept of negotiated outcomes. But this working group would have to include dams owners and operators, energy and water resources planners and politicians, especially from developing countries with different political and social system and values.
At the start it will have to recognise that reservoirs are needed and dams will continue to be built because in many countries they provide the only way to obtain water and energy security. More and more knowledge to plan, design, build and operate better dams is available today, and the hydropower profession is convinced that it is possible to develop general guidelines, which can be used as a true development tool within the context of the policies of individual countries.
As an organization committed to promoting the highest standards for the planning and implementation of future projects, the IHA is ready to participate with the World Bank in developing realistic guidelines.
The WCD attempted to shift the balance of power in dam decision-making from developers and governments to the potentially affected local population. The IHA agrees local populations should have more say in the decision-making process. However, in the pursuit of that noble goal, we believe that the Commission went too far by proposing a de facto veto right for a small minority, which is politically unreasonable and to the detriment of all. The Commission should have provided the parameters for arbitrating the competing rights, and should have clearly integrated the central role of the state in the proposed five key decision points and 26 guidelines.
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The International Hydropower Association Response Committee was selected on the basis of experience and regional representation:
Adams, P. (BC Hydro, Canada)
Altinbilek, D. (DSI, Turkey)
Bartle, A. (IHA)
Devernay, J-M. (EDF, France)
Kalitsi, E.A.K. (VRA, Ghana)
Karmacharya, J.L. (NEA, Nepal)
Klimpt, J-E. (Hydro Quebec, Canada)
Lafitte, R. (IHA)
Lempιriθre, F. (Hydrocoop, France)
Li, F. (Aquarius, China)
Micol, J-G. (ALSTOM, Belgium)
Nombre, A. (A.I.T.G.C., Burkina Faso)
Ospina, C. (Ingetec S.A., Colombia)
Prasad, Y. (NHPC, India)
Puranen, H. (Kemijoki Oy, Finland)
Roo, H.E. (EDELCA, Venezuela)
Takimoto, J. (EPDC, Japan)
Taylor, R.M. (IHA)
Viotti, C. (Consultant, Brazil)
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