A Critique of the International Hydropower Association's New Assessment
Protocol
October 2010
Summary
The International Hydropower Association, a lobby group of the dam
industry, recently published the recommended final draft Hydropower
Sustainability Assessment Protocol (IHA Protocol). The authors call the
new Protocol a "sustainability assessment framework" which has "the
potential to make a substantial contribution to advancing sustainability
in the hydropower sector". Yet the document risks weakening existing
social and environmental standards in the dams sector, and allows the
hydropower industry - an interested party - to define which projects are
considered sustainable.
The IHA Protocol is a pure assessment tool. Measuring the respect for
rights and standards is not the same as respecting them. The Protocol does
not define any minimal requirements of sustainability or a bottomline of
acceptability for hydropower projects. It does not even require respect
for human rights, international conventions and national laws. The
Protocol's authors claim that the document's level 3 score "describes
basic good practice on a particular sustainability topic [which] projects
in all contexts should be working toward". Yet this score, and the
Protocol overall, falls behind relevant social and environmental standards
which international organizations have adopted and governments have
committed to.
The IHA Protocol was prepared in an exclusive process, without the
participation of dam-affected people and Southern NGOs. The use of the
Protocol is being controlled by the International Hydropower Association.
By hiring their own consultants and preparing their work program,
individual dam developers will have much influence over the assessment of
specific projects. The process by which the Protocol was prepared and is
being used is in stark contradiction to the principles of participation
and accountability which were espoused by the World Commission on Dams
(WCD) process.
The IHA Protocol has been published for endorsement, but has so far not
been endorsed by any member institutions of the Forum which prepared it.
Civil society organizations call on governments, international
organizations, civil society groups and other institutions not to endorse
or otherwise support a document which risks weakening existing social and
environmental standards and concentrates control over the definition of
sustainability in the hands of the hydropower industry.
Lack of independence
The IHA Protocol was prepared by a Hydropower Sustainability Assessment
Forum (HSAF), which included 14 hand-picked representatives of the dam
industry, governments, financiers, and large NGOs. Southern NGOs and
affected people were not invited to participate in the HSAF process, and
were not consulted in a meaningful way. The Forum's official goal was to
develop a "broadly endorsed sustainability assessment tool to measure and
guide performance in the hydropower sector". Halfway through the process,
this goal was redefined as developing a sustainability assessment tool
based on the IHA's existing sustainability guidelines.
The IHA claims that the new Protocol will allow an objective assessment of
hydropower projects. Yet the document's language is often subjective and
vague. The Protocol defines "objective evidence" as "qualitative or
quantitative information, records or statements of fact, either verbal or
documented", including "personal observation" by a project's assessor.
The Protocol does not require that projects be assessed by independent
auditors (or "assessors"). Assessors will need to be licensed by the IHA,
will be selected and paid by the project developer, and will often hail
from other hydropower companies. Project representatives will arrange the
program of assessors, including their interviews with third parties, and
will select interpreters. Project representatives have to be notified in
advance about any independent research that assessors intend to do, and
have the right to respond to any issues raised by affected people and
third parties. In contrast, there is no requirement that affected people
are consulted as part of an assessment.
Even though the Protocol was prepared by the Forum, the IHA asserted its
control over it at the end of the process over considerable opposition
from other Forum members. The use of the Protocol, including the public
assessment of projects, requires a license from IHA, and the document may
not be reproduced, stored or transmitted without the written permission of
IHA. Consequently, affected communities will not be allowed to counter the
greenwashing of a project by an industry consultant with their own
assessment. A privately owned and controlled document is not an
appropriate tool of public policy.
Weak language
The IHA Protocol is divided into four sections to coincide with different
phases of the project cycle: (1) Early Stage, (2) Preparation, (3)
Implementation and (4) Operation. The document scores projects from 1 to
5. It defines a 3 score as "basic good practice", and a 5 score as "proven
best practice". Brief scoring statements "guide" assessors on how to
allocate scores. Additional language - the "assessment guidance" -
"assists" assessors in this task. This approach leaves a lot of room for
interpretation to the assessors, who will be selected and paid by the
project developers.
The language in the scoring statements tends to be weak, vague, and
general. To be considered "basic good practice" (3 score), projects have
to jump through a series of bureaucratic hoops, but have to fulfill few
substantive requirements. The language for the 3 score regarding the
outcome of downstream flow regimes at the preparation stage for example
simply stipulates that "plans for downstream flows take into account
environmental, social and economic objectives, and where relevant, agreed
transboundary objectives".
The scoring language for the highest score regarding indigenous peoples at
the project preparation stage does stipulate that "consent has been sought
and gained by directly affected indigenous groups for the project". This
is positive, although the language is weaker for the basic good practice
score. Many stipulations for project preparation can be circumvented if a
developer assesses a project at the implementation or operation rather
than the preparation stage.
The IHA Protocol undermines existing standards and obligations in a number
of areas:
. The strategic priorities of the World Commission on Dams (which all
major interest groups have endorsed) call for a comprehensive and
participatory assessment of needs and available options to identify the
best water or energy solution. The options assessment process addresses
"the full range of policy, institutional and technical options", and gives
social and environmental aspects the same weight as economic interests.
The IHA Protocol does not include any such stipulations even for its
highest score.
. Many governments and financial institutions, including the Asian
Development Bank and the banks endorsing the Equator Principles, require
that the cumulative environmental impacts of projects be evaluated. The
IHA Protocol only stipulates that cumulative impacts be "scoped".
. Most multilateral development banks prioritize land-for-land
compensation for displaced communities over simple cash compensation. The
IHA Protocol simply states in its Assessment Guidance that "strong
consideration may be given to land-for-land compensation". The
International Network on Displacement and Resettlement - a network of the
world's leading resettlement specialists - has strongly condemned the
inconsistency of the Protocol with the existing resettlement policies of
international organizations and national laws.
The IHA Protocol is 177 pages long. Yet it largely ignores important
topics such as the human rights impacts of dams, issues arising regarding
transboundary rivers, greenhouse gas emissions from reservoirs, and the
risk that dams may trigger earthquakes.
Conclusion
The IHA Protocol is a voluntary scorecard for dam builders that allows the
hydropower industry to control the assessment of its own projects without
any mandatory bottom-lines. It could easily be used to legitimize
unsustainable and irresponsible practices in the dam industry, against
which local communities continue to struggle.
Environmental standards and the rights of dam-affected communities have
been successively strengthened by the UN, many governments, international
banks and the WCD during the past decade. In contrast, the IHA Protocol
represents a major step backward from existing social, human rights and
environmental standards and is likely to be used by industry and others to
greenwash destructive dams.
The use of the new Protocol is being tightly controlled by the
International Hydropower Association, a private interest group whose
members have a stake in a positive outcome of assessments. Public use of
the document is not possible without a license from IHA. A copyrighted
document of a private interest group is not an acceptable tool of public
policy.
While IHA admits that the new Protocol is an assessment tool and not a new
standard, it nevertheless aims to replace existing standards with this
voluntary tool. The industry lobby is already urging the European Union to
assess hydropower projects which aim to sell carbon credits to the
European market by the IHA Protocol, rather than to require that they
comply with the WCD framework.
After the recent experience with deregulation, civil society groups
working with dam-affected communities will not accept an approach that
aims to replace binding standards with voluntary industry commitments to
"good practice". So far, none of the HSAF members have endorsed the
Protocol. We call on all governments, international organizations, civil
society groups and other institutions not to endorse or otherwise support
the IHA Protocol.
This critique has so far been endorsed by 54 organizations, international
networks, and independent experts. The full list of endorsements is
available at www.internationalrivers.org/en/node/5905.
The new Protocol is available at http://tiny.cc/hgkzq.
________________________________________________
This is International Rivers' mailing list on the role of international financial institutions in promoting large dams.
You received this message as a subscriber on the list: ifi@list.internationalrivers.org
To be removed from the list, please visit:
http://salsa.democracyinaction.org/o/2486/unsubscribe.jsp
No comments:
Post a Comment