A Scorecard is Not a Standard

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The Hydro Industry’s Latest Attempt to Greenwash Dams

The International Hydropower Association most likely won’t be celebrating the World Commission on Dams’ tenth anniversary this year, but the dam builders’ organization will be hosting its own private party. Dam-affected people and Southern civil society groups are not invited – they might bring an unwelcome dose of reality. The guests of honor at this party will be big funders of big dams: public and private banks, export credit agencies and buyers of carbon credits.

The reason for this self-congratulatory celebration is the forthcoming launch of the Hydropower Sustainability Assessment Protocol, essentially a scorecard for dam developers to rate their projects on environmental and social issues. The Protocol is being developed by the International Hydropower Association (IHA), in a process that many see as a way to circumvent the more stringent, inclusive and far-reaching standards put forth by the World Commission on Dams (WCD). The IHA Protocol does not require dam builders to meet any minimum standards, nor does it provide incentives for them to improve the performance of bad projects. In fact, the Protocol appears to be more smoke and mirrors to win over dam funders than a serious attempt by an industry to improve its product.

A flawed process

The IHA, together with the World Wildlife Fund (WWF) and The Nature Conservancy, launched the Hydropower Sustainability Assessment Forum in 2008. The other hand-picked participants in the 14-member Forum include representatives from governments, funding agencies, and NGOs Oxfam Australia and Transparency International. The Forum’s goal was to develop a “broadly endorsed sustainability assessment tool to measure and guide performance in the hydropower sector.” Dam-affected people and Southern civil society networks were not given a seat at the negotiating table.

Through a series of closed-door meetings, the Forum members developed a draft Sustainability Assessment Protocol in August 2009. The 229-page draft Protocol amounted to a complex scorecard for rating dam projects, from very poor to excellent, across a long list of criteria.

The draft Protocol missed the forest for the trees. It failed to outline any minimum standards that dam developers must follow or rights that they must respect. For example, even a hydro project that violated national and international law or the rights of local communities could receive a “good practice” score. The Protocol’s complicated approach focused on evaluating dam developers’ processes and plans instead of the outcomes and results they achieved. The assessment of the project would rely primarily on information provided by the dam builder or its consultants. Verifying facts on the ground – including through discussions with affected people – would not be encouraged or likely even feasible in a meaningful way, given that assessments would be expected to be completed in three to five days.

After the release of the draft Protocol, the Forum launched a limited three-month consultation. According to an internal report on the process, “in practice many events were awareness-raising and not truly consultation, because it takes some time for stakeholders to understand the Protocol sufficiently to provide informed comment and feedback, and in many cases the engagement activities were a first introduction to what the Forum and the Protocol were about.” For example, the main meeting with dam-affected people which took place in Ghana was “more of an awareness raising exercise” due to the participants’ “limited prior knowledge of the HSAF process.”

Most of the feedback that the Forum received on the draft Protocol was based on general questions (such as “What do you think of the Protocol in terms of its appropriateness, quality and applicability?”) and was solicited through an online questionnaire. This hardly constituted a robust consultation exercise that could overcome the deficiencies of the closed Protocol drafting process.

Complex and confusing

A common response to the draft Protocol from a variety of stakeholders was that it is too complex and difficult to apply. A number of civil society respondents criticized the Protocol as a weakening of existing standards, such as the World Commission on Dams (WCD) framework.

Some of the strongest criticism came from the 60 resettlement specialists from more than 20 countries that make up the International Network on Displacement and Resettlement (INDR). Their detailed submission said the draft Protocol is “deficient and incomplete for objectively evaluating the dam projects’ social sustainability. Specifically, the IHA draft: totally overlooks the impoverishment risks imposed on the population affected by dam construction; … proposes a flawed and imbalanced scoring methodology; and does not include important elements already introduced in internationally accepted resettlement policies and mitigation practices or in some countries national policies in this area.”

During the consultation, dam industry respondents expressed concerns that “the Protocol was asking for many things beyond what an industry would normally deal with.” A communication sent by the head of the IHA reference group for the Forum to all IHA members asserted that the Protocol’s stakeholder support and consultation requirements should be limited to “relevant” aspects – meaning, presumably that local communities would be consulted primarily on resettlement and compensation packages rather than on broader questions regarding whether or not a project should go forward and how.

The industry respondents also argued that an international standard should not “challenge” – or presumably go beyond – national law or regulations. They reiterated concerns expressed by other respondents that the draft Protocol was too long and complex, arguing that “a major condensation and simplification is required, before the protocol will become an acceptable tool for the industry.”

Dam industry pushes back

The dam industry was initially just one of the Forum members jointly responsible for drafting and agreeing to the Protocol. But facing a lengthy draft that they felt pushed them too far, the dam industry started flexing its muscles and asserting authority over the Forum process. It now appears that industry is trying to gain veto power over the process. The final draft Protocol is apparently being revised based on what industry is willing to accept, not on what the Forum members are interested in putting forward.

This power grab has led to an official change in the objective of the Forum and the Protocol. As the Forum enters its final meetings, it has identified a new aim: “to develop an enhanced sustainability assessment tool to measure and guide performance in the hydropower sector, based on the hydropower sustainability guidelines and assessment protocol as developed by the IHA, that the Forum would recommend for adoption by IHA and endorsement by HSAF members” (emphasis added). Gone are the goals of a “broadly endorsed” tool. What industry seems to want is something that reflects what the IHA already agreed to in its notoriously weak sustainability guidelines and assessment protocol (see for example WRR, Oct. 2006).

Due to these late-in-the-game changes and other drafting delays, the Forum process missed its original deadline, and it is not clear when the final Protocol will be released. However, based on some industry comments available on the Forum website, it seems likely that the revised Protocol will be weaker than the August 2009 draft.

For example, the dam industry is trying to limit as much as possible what would be expected of them to achieve a “best practice” score – hardly the mark of dam developers interested in improving social and environmental performance and encouraging progress from other IHA members.

Furthermore, they are suggesting changes to the Protocol that would create more loopholes for dam builders, such as replacing “minimize the area flooded per unit of energy (GWh) produced” – a standard that at least would encourage dams with smaller reservoirs – with “avoid exceptional greenhouse gas emissions,” which is so vague as to mean almost nothing. Industry also proposes to assess critical project aspects themselves rather than through independent experts.

This was not the process that the Forum members signed up for and agreed to. The real question now is: what will they do in response to industry’s attempts to weaken the Protocol?

As the IHA process comes to a close, the World Commission on Dams framework remains the clearest and most legitimate global benchmark for protecting rights, allocating risks and evaluating the environmental and social impacts of dam projects. While the draft IHA Protocol may reference some of the same issues, all indications are that its final incarnation will fail to define clear minimum standards with which dam developers must comply or rights that they must respect.

Measuring respect for rights is not the same as respecting rights. This is a key difference between the WCD and the draft IHA Protocol. An assessment tool that fails to put human rights concerns front and center cannot truly evaluate the environmental and social sustainability of a dam project. Given the clear intentions of industry to avoid increased accountability and stronger standards in the Forum process, the IHA Protocol is likely to be just another propaganda tool for big dam builders.