NGO's Concerned Over Asian Development Bank's Support for Dams
11/26/97
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RELAYED TEXT STARTS HERE:
Headline: NGO's Concerned Over Asian Development Bank's Support for Dams
Source: Patrick McCully
Campaigns Director
International Rivers Network
Date: 11/26/97
Mr James E. Rockett
Manager, Energy Division (West)
Asian Development Bank
PO Box 789
0980 Manila
Philippines
Fax 011 63 2 636 2000
Dear Mr Rockett
We are writing to express a number of concerns over the ADB's Se Kong-Se
San Basin and Nam Theun River Basins Hydropower Development Study TAR:REG
30003 (the Study). We would also like to request further clarification of
some issues raised by this technical assistance project.
Dam building in the Se Kong-Se San watershed will have major social,
economic and environmental implications both in the basin itself
(incorporating southern Lao PDR, part of the central highlands of Vietnam,
and north-east Cambodia) and on the Mekong mainstream in Cambodia and
Vietnam -- the Se Kong and Se San river systems together contribute more
than ten per cent of the flow of the Mekong at the gauging station at
Kratie in Cambodia. We therefore intend to monitor closely the process
through which dams on the Se Kong-Se San basin are planned and constructed.
We have already been closely following existing and proposed dam projects
in the Nam Theun watershed and intend to continue monitoring dam-building
on this river system.
Pre-Determined Conclusion to Build Dams
The 'Broad Terms of Reference for Consulting Services' (BToRs) in Appendix
2 of the Study states that the consultants should "identify at least six
[dam] projects suitable for early implementation within these basins" and
prepare terms of reference for "prefeasibility and/or feasibility studies
of these projects" (para K.1). Elsewhere the Study says that ToRs for
"about six most promising hydropower projects" will be developed" (para
14). The Study is thus beginning with a pre-determined conclusion that at
least/about six dams (in addition to the nine already underway or scheduled
to soon begin construction) in these watersheds will be economically viable
and "sustainable and environmentally acceptable".
This conclusion has been made before any detailed gathering and analysis
has begun of key design data, such as the hydrology, sedimentology,
meteorology, geology, ecology, demography and socio-economic
characteristics of the basins, the cumulative downstream impacts of the
proposed dams on the Mekong, or the costs of electricity from these dams
compared with costs of supplying electricity to Thailand and Vietnam from
other sources (supply of power to Thailand and Vietnam is the main purpose
of the proposed dams). The conclusion that at least/about six more dams are
viable and acceptable has also been made without any consultation with
potentially affected populations.
Indeed the main purpose of the study would appear to be to ensure that
"environmental and social impacts from one project now will not adversely
affect a better project in the future" - rather than to ensure that local
people and environments do not suffer from the planned cascades of dams.
The Study is thus being done mainly to ascertain the best sequence for the
construction of dams on these rivers, not to ascertain whether the rivers
should be dammed.
Given these pre-determined conclusions, the hydropower consultants on the
Study will obviously conclude from their subjective examination of the data
that they gather that at least/about six or more dams on these basins will
indeed be economically viable, sustainable and environmentally acceptable.
After the Study is finished pre-feasibility and then feasibility studies
will be written followed by environmental impact assessments (all by dam
industry consultants who experience has shown to be heavily biased in their
assessments of dam viability). Our experience with the dam planning process
leads us to predict with reasonable certainty: a) that these studies will
conclude that the proposed dams should be built; b) that any predicted
adverse social and environmental impacts will be "acceptable" or "not
serious" and can be "mitigated"; and c) any unpredicted impacts will be
monitored and then mitigated. Past experience also suggests that no
detailed assessment will be made of the success or failure of environmental
and social monitoring and mitigation at a representative sample of other
similar hydro projects, and that no assessment will be made of the actual
economic and technical performance of other similar projects. The
consultants who conclude that the dams should be built will then likely
tender for contracts on dam construction.
Although it is widely recognized that the most serious negative consequence
of dam-building in the Mekong watershed is the depletion of the diversity
and yield of fish which provide the bulk of animal protein for the
watershed's inhabitants, the BTORs nowhere mention the need for careful
assessment of the impacts of the proposed dams on fisheries. In fact, the
only context in which fish are mentioned in the BToRs is as a "project
benefit" which the consultants should identify. We therefore expect the
consultants to exaggerate the likely benefits from reservoir fisheries
while playing down the likely impacts of dams on wild fisheries. We expect
that these conclusions will be made without giving any detailed assessment
of projected and actual long-term yields of fish from existing reservoirs
in the region, or of the impacts on wild fisheries of existing dams.
The draft ToRs for the Study give a list of "key personnel" which the
consultants should engage to undertake the Study and decide on the
environmental and social "acceptability" of the proposed dams (no personnel
are listed in the final "Broad ToRs"). It is extremely worrying that no
expert on Mekong fisheries is listed despite the complexity and importance
of this issue.
We are also concerned about the heavy engineering bias of the "key
personnel" listed in the draft ToRs. Out of 10 personnel listed, 5 are
engineers and 1 a dam planner. Only two of the personnel might have some
environmental expertise (the "watershed management expert" and
"environmental/regional planner") and neither appear to be required to have
knowledge of the complex ecological impacts of dams. One social
anthropologist is listed but does not appear to be required to have
knowledge of the impacts of forced resettlement or the other social impacts
of dams such as the loss of fisheries and other resources downstream.
Concerns over Consultant Competence and Vested Interest
We have a number of concerns over the selection of the consultants who will
be chosen to carry out the Study and also over the possibility that the
same consultants (or affiliated companies) may also receive further
contracts for pre-feasibility, feasibility, and environmental impact
studies of individual dams, and then for design and construction contracts
on the same projects.
The ADB's "Guidelines on the use of Consultants" state that "Consultants to
be engaged by the Bank and its borrowers must be fully competent for the
work to be assigned to them" and that "The engagement of consulting firms
will have to be based on . . . their capacity to render their services in a
demonstrably impartial manner". We believe, however, that in its
involvement in the hydropower sector in Laos the ADB has so far not abided
by these guidelines and request that they will be more strictly applied in
future.
For example, the ADB chose Norconsult International to write the ToRs for
the Study despite the serious and well-documented shortcomings in the
most-important study Norconsult has done for a Laotian dam - the
NORAD-funded environmental and social impact assessment for Nam
Theun-Hinboun. The optimistic conclusion of this assessment - that Nam
Theun-Hinboun Dam would have "significant beneficial environmental impacts"
- has been strongly criticised by reviewers from three Norwegian government
agencies. Many of the findings of the Norconsult EIA have also been
contradicted by the NORAD-funded review carried out by consultants Norplan
AS, Hydroconsult AB, Wildlife Conservation Society, Norwegian Institute for
Nature Research, Norwegian Institute for Water Research, MIDAS and Burapha.
The cover of the Summary EIA for Nam Theun-Hinboun presented to the ADB
Board prior to their approval of a $60 million loan for Theun-Hinboun in
November 1994 states that the SEIA "has not been evaluated/assessed by the
Bank. The Bank's assessment of the report and evaluation of the
environmental impacts related to the Project will be included in the
documentation presented to the Board." We have not been able to obtain this
assessment and would be grateful if you could send this to us.
The ADB's "Guidelines on the use of Consultants" state that firms "which
are associated with, affiliate of, or owned by contractors . . . will
normally be acceptable only if they agree to limit their role to that of
consulting engineers and to disqualify themselves, their associates and
their affiliates for work in any other capacity on the same project."
Norconsult should therefore not have been given the Theun-Hinboun EIA
contract as they are part-owned by Norwegian utility Statkraft, a
shareholder in the Theun Hinboun Power Company. NORAD have admitted that
there was a conflict of interest in this case.
Norconsul's vested interest in playing down the negative social and
environmental impacts of Theun-Hinboun was further strengthened by the fact
that they were also given contracts for engineering and construction
supervision on the project. We are concerned that the same momentum of
vested interest is influencing Norconsult's work for the ADB. Norconsult's
1994 'Subregional Energy Sector Study for ADB' has been extremely
influential in setting international policy on energy infrastructure
expansion in the Mekong watershed bioregion. The decision to undertake the
Se Kong-Se San and Nam Theun basin hydropower study was "based on the
recommendations of the [Norconsult] Energy Sector Study" (para 10).
Norconsult were then chosen to write the ToRs for the basin hydropower
study.
The consultant guidelines state that "After termination of their
engagement, such consultants may be required to abstain from any subsequent
work on the same project, if so decided by the Bank." We would be grateful
if you could clarify under what conditions the Bank decides that
consultants should "abstain from any subsequent work on the same project".
Do these conditions apply to the process of planning and building
hydropower projects in Laos?
IRN has already raised this issue in relation to the ADB giving consultants
Sogreah Ing,nerie contracts for the EIA, detailed design and construction
supervision of the Nam Leuk hydro project. ADB's response to our raising of
this issue - that Sogreah were appointed "in line with standard Bank
operating procedures" and that at the time they were given the EIA contract
they had not yet been awarded the work to do the construction supervision"
- is we believe inadequate and only heightens our concern that ADB
consultants have a vested interest in making optimistic conclusions about
the viability of the projects they are assigned to assess.
As the French government is co-financing the Study, we believe that out of
the seven dam engineering consultants short-listed by the ADB the
French-led consortium of Compagnie Nationale du Rh"ne (CNR), Coyne et
Bellier and Acres International is the most likely to win the contract. We
would therefore like to draw your attention to the 1994 "Mekong Mainstream
Run-of-River Hydropower" report written by CNR and Acres International. An
IRN review of this study found it to be seriously flawed on methodological,
economic and technical grounds. The study also seriously plays down the
likely impacts of the projects. One example of this is that the Executive
Summary of the study states that "environmental impacts of the proposed
projects are expected to be . . . not severe". Yet the fisheries volume of
the study, written separately by Don Chapman Consultants, Inc., warns that
the proposed dams "may cause a wholesale decline in the fishery throughout
the lower Mekong River".
Whichever of the shortlisted dam engineering consultants is chosen for the
Se Kong-Se San Nam Theun Study, we would like to know what review of their
previous work the ADB has undertaken to ascertain that the consultants
comply with the ADB's guidelines as being "fully competent for the work to
be assigned to them" and having a "capacity to render their services in a
demonstrably impartial manner". We would also like to know whether or not
the consultants will be ruled out from bidding for contracts on later
phases of the six or more projects they will recommend as "sustainable and
environmentally acceptable". IRN would be glad to supply the ADB with
information on dam projects which the short-listed consultants have worked
on in the past.
Need to Look at Impacts of Current Dams
Two dams are already under construction on the Se Kong-Se San basin - Yali
Falls (Vietnam) and Houay Ho (Laos) - and MoUs have been signed for three
more - Se Kaman 1, Se Nam Noy/Se Pian, and Se Kong 4 (all in Laos). On the
Nam Theun, one dam is under construction (the ADB-funded Theun Hinboun),
one is due to begin construction in 1997 (Nam Theun 2), and MoUs have been
signed for two more (Nam Theun 1 and Nam Theun 3). Reservoir area logging
is underway at at least three of these dams, Se Kaman 1, Nam Theun 2 and
Houay Ho.
No assessments have been done on the cumulative ecological and social
impacts of these projects on their sub-watersheds or on the Mekong
mainstream (the 1993 EIA for Yali Falls written by Swiss consultants
Electrowatt, for example, assessed downstream impacts for only 8 kilometres
below the dam) and very little information is available describing the
impacts of each individual project or explaining their economic and
technical justifications. Instead of pushing ahead with the process of
building yet more dams in these basins, we believe the ADB should undertake
the long-term process of gathering and analysing data on the impacts of the
projects which are already underway or scheduled to begin soon. We believe
that no further projects should be proposed on these basins until a
competent and honest assessment based on empirical evidence of the impacts
of the dams already being built on these basins is done and made publicly
available.
We look forward to receiving your answers to these questions and your
comments on the issues we have raised.
Yours sincerely
Patrick McCully
Campaigns Director
International Rivers Network
also endorsed by
Aviva Imhof
Aidwatch
Australia
Gr inne Ryder
Probe International
Canada
Maria Anik Tunjung Wusari
International NGO Forum on Indonesian Development (INFID) Indonesia
Frida Rustiani
AKATIGA Foundation
Indonesia
Stephanus Djuweng
Institute of Dayakology, Research and Development (IDRD)
Indonesia
Sandra Moniaga
ELSAM
Indonesia
Leonard Simandjuntak
PELANGI
Indonesia
Mihoko Uramoto
Mekong Watch Network
Japan
Gopal Siwakoti
INHURED International
Nepal
Marvic M.V.F. Leonen
Legal Rights and Natural Resources Center, Inc.
LRC-KSK/FoE-Philippines
NGO Working Group on the ADB
Philippines
Violeta Corral
Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC)
Philippines
Larry M. Manaog
National Coalition of Fisherfolks for Aquatic Reform (NACFAR) Philippines
Dej Poomkacha
NGO Coordinating Committee on Development (NGO-COD)
Thailand
Andrea Durbin
Friends of the Earth, US