(This is part of ongoing correspondence on this topic)
14 September 2010
To: Brian Dames, Chief Executive Officer, Eskom
By e-mail: email@example.com
Dear Mr. Dames:
We appreciate the time taken to reply to our letter on the Mphanda Nkuwa Dam, and hope that we can continue to keep the lines of communication open. Unfortunately, it is highly unlikely that all of our concerns will be resolved by the EIA process alone, and even more unlikely that the project will comply with the standards set out by the World Commission on Dams – which still remains the best standard for ensuring a project’s risks don’t outweigh its benefits.
We believe by placing all expectations of resolving the dam’s potential problems on the EIA process is risky, given how flawed Mozambique’s environmental review process is at this time. Mozambique’s EIA process too often allows project approval based on superficial studies. Even when done to a decent standard, recommendations for mitigation are not followed, as there is no functional mechanism to ensure its compliance.
But perhaps the most glaring flaw in the Mozambican EIA process was confirmed by our government’s announcement in August that the project was approved before the completion of the EIA. An EIA is a prerequisite for evaluating a project’s impacts; it becomes meaningless if it is done after project approval. The government has also announced that construction on Mphanda Nkuwa will begin in 2011, which leaves little time for true public participation once the EIA findings are released. This is a fundamental flaw in terms of environmental management legislation in Mozambique and indeed globally.
We know the project cannot meet the guidelines of the World Commission on Dams, since it has already failed many of its basic tenets, including those on comprehensive options assessment (there has been no analysis of what other options could best meet Mozambique’s needs or indeed Southern Africa’s needs); addressing the problems from existing dams (the Zambezi is already suffering from previous large dams, and it has been demonstrated that better environmental flows could improve its health); and sustaining rivers and livelihoods (which would ensure strong scientific analysis of ecosystems and social issues is undertaken before a project is approved), to name just three.
We are encouraged to hear you say that Eskom places importance on social and environmental issues, but this raises new questions in light of the Mphanda project. We hope you can answer these questions soon:
• What is Eskom’s position regarding the fact that the project has been approved before the EIA has been completed?
• What mechanisms has Eskom put in place to ensure that the high standards you mention (e.g., the World Commission on Dams and World Bank) are met and followed on projects from which it sources energy?
• What steps is Eskom prepared to take if these standards are not met?
• Will Eskom decline to get involved if it is shown that this project’s EIA has not met these standards?
Mozambique has extensive hydropower potential, but not all attempts to exploit this potential will be sustainable. The impacts of hydropower dams are well known, and therefore, should be approached with caution using the highest of standards to minimize the impacts. Both the history of the process around Mphanda Nkuwa Dam and the current reality have shown this to be a risky project.
We look forward to your reply.
JA! Justica Ambiental, Friends of the Earth Mozambique
groundWork, Friends of the Earth, South Africa
Biowatch South Africa
South Africa Water Caucus
Centre for Civil Society Environmental Justice Project (University of
KwaZulu-Natal, South Africa)
Port Elizabeth Renewable Energy Centre
South Durban Community Environmental Alliance
African Rivers Network (Pan African)
Citizens for Justice-(CFJ), Friends of the Earth Malawi
Friends of the Earth Ghana
National Association of Professional Environmentalist (Uganda)
Kulali Development Foundation (Zambia)
Survivors of Lesotho Dams (Lesotho)
Transformation Resource Centre (Lesotho)
Society for Water and Public Health Protection (Nigeria)
Environmental Rights Action (Nigeria)
International Rivers Network (USA)
Download Eskom’s original letter, to which this is a response.