Ms. Mechtild Rössler
Director World Heritage Division and World Heritage Centre
UNESCO World Heritage Centre
7, Place de Fontenoy
June 9, 2018
Subject: Protection of World Heritage Sites in Africa threatened by water infrastructure
Dear Ms. Rössler,
We would like to thank you for leading the protections for our heritage sites and for tackling some of the difficult calls as made in the recently published draft decisions. We are writing to raise concerns about six endangered World Heritage Sites in Africa, which are now threatened by large dams. These are the Dja Faunal Reserve, Lake Turkana National Parks, Lower Valley of the Omo, Selous Game Reserve, Serengeti National Park, and Niokolo-Koba National Park. All are facing threats from construction of hydropower dams upstream or in the vicinity of these properties of Outstanding Universal Value. Free-flowing rivers lie at the core of these sites, acting as both biological corridors and sustenance for faunal habitats and human lives.
We support the resolution adopted by the 40th session of the World Heritage Committee in Turkey in 2016, which “considers that the construction of dams with large reservoirs within the boundaries of World Heritage properties is incompatible with their World Heritage status, and urges States Parties to ensure that the impacts from dams that could affect properties located upstream or downstream within the same river basin are rigorously assessed in order to avoid impacts on the Outstanding Universal Value (OUV)”. We urge the WHC committee with your leadership to take every effort to ensure that all heritage site properties are afforded adequate protection. In light of this we wish to point out a few major concerns below.
1. We have grave concerns about Lake Turkana and the Omo Valley in Kenya and Ethiopia respectively. These properties, as correctly reported in the draft decisions, are already experiencing low water levels and other impacts due to irrigation and hydropower development in Ethiopia. Beyond this, we would like to note that these risks and impacts will be further aggravated by the construction of the proposed Gibe IV and V.
We note with concern the lack of implementation of previous decisions (i.e 36 COM 7B.3, 39 COM 7B.4 and 40 COM 7B.80), with which the state parties failed to comply. Despite the call that all developments be halted until completion of an SEA, the state parties proceeded nonetheless and continued to submit insufficient information on assessments, in total disregard of the WHC decisions.
We note with concern that the Draft Decision: 42 COM 7B.44 extends more time for the state parties to continue ignoring the WHC decisions and we fear that no actions will be taken. We are very concerned that while the state party of Ethiopia submitted its report on developments on the Kuraz Sugar Estates, they failed to disclose their intentions to construct two additional dams the Gibe IV and V and to include in their report to the WHC, the advancements they have made towards implementation of Gibe IV. Ethiopia granted Salini the contract to construct Gibe IV in 2016.
We applaud the measures being taken by the WHC and the proposed draft decision Decision 40 COM 7B.92, to inscribe the Lake Turkana property on the List of World Heritage Sites in Danger.
2. The Niokolo-Koba National Park was listed a World Heritage site in danger in 2013 yet the governments of Guinea, Gambia and Senegal are planning to build the Sambangalou hydropower dam upstream of the park that will cause irreversible damage to biodiversity and ecosystems. According to the Environmental Impact Study, the Sambangalou dam will have major impacts on the river regime, it will reduce the quantity and quality of water downstream, and also cause the loss of soils, vegetation, and faunal habitats – all impacts that cannot be mitigated. We note the draft decision of the committee in 2018, requesting a detailed Environmental and Social Impact Study of the dam in conformity with international standards applied to World Heritage sites and we hope that this request is followed through and pressure exerted on the State Parties to meet their obligations.
3. We are further concerned about the Serengeti National Park and in particular the planned cascade of dams that will disrupt the flow of the Mara River. We call on the WHC to insist that the state parties of Tanzania and Kenya provide adequate protection to the Mara River basin and the Serengeti Park in line with its “Outstanding Universal Value”. Further, we remain concerned about the Selous Game Reserve also listed as a World Heritage site in danger, yet the State Party of Tanzania has plans to develop the Rufiji Hydropower within the WHC property.
In the past International Rivers and its partners have made calls to the World Heritage Committee and the UNESCO World Heritage Centre to inscribe in danger WH sites threatened by dams and document the risks dams caused to World Heritage sites. In line with the resolution at the 40th Session in Turkey, mentioned above, we reiterate our past calls and request that your draft resolution 42 COM 7B.92 of 2018, to inscribe Lake Turkana on the list of World Heritage site in danger, be adopted; and we request that you do the same for the Dja Faunal Reserve, Serengeti National Park and the Lower Valley of the Omo. We further ask that the committee continue to document the risks that these dams pose to our ecosystems, and that the 42nd session of the committee urge host state parties to respect the World Heritage convention and implement decisions that are adopted by the World Heritage Committee.
We thank you for your attention to this matter and you have our support in the protection of the above World Heritage Sites.
Rudo A. Sanyanga
International Rivers, Africa Program Director
International Rivers, Policy Director
Mr Lazare Eloundou Assomo, Deputy Director, World Heritage Centre
Mr Guy Debonnet, Programme Specialist, World Heritage
Mr Edmond Moukala, Chief, Africa Unit