Green from far, but far from green

“the hydropower certification scheme promoted by the Mphanda Nkuwa Office

In late October JA participated in a course on the new “Hydropower Sustainability Standards” (HSS), which reiterated the issues and concerns regarding certifications, guidelines, best industry practices and other non binding methods that try to address the devastating impacts of mega-dams. The benefit for the industry is that these methods are non-binding, optional and can be designed to fit the specific wants and interests of the sector. All this, while fashioning the illusion of being more “sustainable” or whatever new green-washing marketing terminology is fashionable.

The difficulties involved in attempting to regulate and improve any industry are understandable. If the standards, guidelines, and requirements are grounded in science, and honestly incorporate human and environmental needs and costs, it would pose an impossibly daunting task for corporations to even consider. If regulations were legally binding, it would impose a great risk on the corporation, knowing well they often fail to meet even the most basic standards. Groups involved in trying to improve industry standards, especially through certifications mechanisms, are left with the easy, inexpensive and inconsequential processes, that usually circumvent critical problems and impacts.

The HSS is a certification scheme that attempts to push hydropower projects to achieve the best industry standards. Herein lies the fundamental issue: In an industry where even the best industry standards can fall short of being sustainable, scientifically sound or just; achieving such goals is still something very far from adequately dealing with the real life impacts of dams. At the same time formulated goals grounded in science and true sustainability – measurably human and environmental – are continuously ignored by the hydropower industry. Despite these obvious obstacles at hand, at the very least with the HSS scheme there could be the possibility of moving the dial of hydropower projects in to a positive spectrum of the hydropower industry norms.

This article is not a comprehensive critique of the “Hydropower Sustainability Standards” (HSS) as that would result in a very long and technical document, and ultimately would only interest a very narrow audience. Instead it serves as generative feedback combining our experience with the HSS course and analyses of the information available on the HSS site, highlighting certain issues, trends and concerns with the certification, which is lacking in the current media coverage.

Transparency and access to information? Only when the client agrees.

Justiça Ambiental was invited to participate in this two-and-a-half day course, and several discussions around the Mphanda Nkuwa Dam project were included in the agenda. Given the lack of information on the latest iteration of the Mphanda Nkuwa Dam project, including lack of response to JA’s letters and emails since August this year, any information was welcomed.

While the HSS website lays out numerous claims of transparency, noticeably all project assessments required an annex where all documents used in the certification process are listed. In a country where accessing documents linked to mega development projects is a challenge, the hope was that increased access to information could be one of the positive outcomes of the scheme.

Unfortunately, the Mphanda Nkuwa Dam was not discussed nor any significant information about it was given, in neither of the first two days that we participated. Furthermore, all the documents supplied for assessments are listed, but not necessarily made available to the public. If the project proponent or government classifies any supplied document as restricted to the public, HSS respects that request and even makes claims of secure information management to instill confidence in their clients. At the end of the day, their clients are paying over $100.000 USD for the certification and so they must respect the client’s needs, and put their loyalty where the money is. There are certain documents that are required to be made publicly available for a project to achieve a pass in the “Communications and Consultation” section of the assessment, but the criteria is vague and seems to cover easily available documents that even a non-transparent country like Mozambique publicly releases anyway.

Other existing dams? Just ignore them.

During the introduction to the HSS it was positive to see the acknowledgment of the importance of the World Commission on Dams (WCD) report, but sad to realize how minimally the HSS meets some of the fundamental recommendations of the WCD. HSS certifications are structured around specific projects and have no real mechanism to deal with accumulated impacts, intersectionality and externalities. Rivers are highly interconnected systems with complex inter-linkages, requiring potential solutions to be centered around accumulated impacts, existing dams and the complex interactions of the numerous ecosystem functions, and more. The strength of the WCD was exactly the focus on this complexity, inter-connectivity and accumulated impacts. In this way, certification of dam projects is highly problematic when approached on a project to project basis; and so hard to align with WCD recommendations. To better understand just look at the WCD recommendations on “Comprehensive Options Assessments” and “Addressing Existing Dams” and then look at how HSS fails to deals with these issues.

To start, the HSS fails to prioritize needs assessments and starts the process much later than what is recommended by the WCD. Secondly, the fundamental issues raised by the WCD in “Addressing Existing Dams” such as optimizing benefits from many existing dams; addressing outstanding social issues and strengthening environmental mitigation and restoration measures are completely lacking in the HSS. This is especially concerning in relation to the Mphanda Nkuwa dam, as it has been designed to function based on the Cahora Bassa dams flow, which is a dam that doesn’t meet environmental and social flow requirements. If Cahora Bassa dam suddenly decided to meet these flow requirements, the Mphanda Nkuwa dam would have high economic risks.

Project is too bad too pass? Try again with flexible methods and VERY weak requirements.

Many of the these weaknesses of the HSS are due to the tailoring of certification schemes to fit the needs of specific projects. Not only does it have to be simple enough to be cost effective and quickly – time is money – but it is structured to the benefit of the project proponents’ scope of interest and control. So the project’s shortcomings can actually be used in deliberate and strategic ways.

Breaking down climate change assessment and how the HSS defines good and best practices: first off, it is vague and the differences between good and best industry practices are small and inadequately defined. Secondly it uses weak methods or doesn’t specify/limit the use of certain problematic methods and their deployment. Thirdly it sets low standards, limits, upper bounds, etc.

For example, when assessing greenhouse gas (GHG) emissions related to a project, rather than assessing the emissions based on their impact on the carbon cycle from both up and downstream of the dam site, it utilizes geographically limiting parameters, resulting in a lower estimate than the total measurement of emissions caused by a dam project. The HSS capitulates further, setting the GHG emissions upper bound to 100 gCO 2 e/per kWh, which is an extremely high amount and easy for most projects to achieve and report. In its own documentation, the HSS notes that the industry average is between 24-28 gCO 2 e/per kWh. Even the International Energy Agency (IEA) recommends 50 gCO 2 e/per kWh limits and notable scientists and civil society groups have demanded further reduction. The HSS’s claim to good or best practices is deceitful.

Of further concern is the reality that HSS certification facilitates climate bonds financing; opening the door for offsetting, false solutions, carbon markets and delays in mitigating emission reductions, but that is a whole other (crucial) topic of debate.

Mphanda Nkuwa: always claiming to be what it’s not.

Not all performance requirements are as weak or easy to manipulate as the climate change mitigation and resilience requirements, but it is still common to find gaps, low standards, weak methods, vague terms and missed opportunities to set true best practices or follow scientific directives. When reflecting on using the HSS to assess the Mphanda Nkuwa Dam, these weaknesses become concerning. As with many dams, Mphanda Nkuwa Dam has complex interconnected impacts that could never be accurately assessed with the approach used by HSS, which expects a two to four person consulting team to somehow possess wide ranging expertise of an ecosystem that has been barely researched and so lacks foundational scientific data. Concerns around the Mphanda Nkuwa Dam’s impact on sediments, seismic risks, amongst other issues remain unanswered. For example, the HSS sediment analyses are vague and again highlight the project specific approach, focusing more on project specific erosion, sedimentation and water quality. The HSS does not seem to restrict known problematic methods, nor recommend scientifically sound basin level sediment modeling with sampling over time or seasons. As for the seismic risks, the situations has far graver implications.

When these more complex issues were raised to the facilitators, one reply was that we have to be careful of paralysis due to analysis. Someone else in the course mentioned the goals have to be approached in small enough steps so as to encourage the industry to try improve. If the HSS were just another set of tools that project proponents could use to assess their project it would not be a bad thing. The concern is in the name of the certification and what it claims “Certified Sustainable Hydropower”. It is a large and misleading claim precluding obvious inadequacies that lay dispute to any claim of sustainability. Too much effort is expended to satisfy and legitimate the dam sector, for example the basic certification requires that “Projects have undergone an independent assessment and have met the minimum requirements of the Standard, and have received a total advanced requirement score below 30%”. It is not very ambitious, to say the least. There is the silver and gold certification, the highest of which requires the project to “meet a minimum of 60%” on all 12 criteria.

Overall we strongly feel the HSS “Certified Sustainable Hydropower” is a self-fulfilling concoction by the dams sector for the dams sector. It has very good visuals, info graphics and strong worded claims that purport benefits to projects that achieve it’s certification. In addition, it provides entry for the dam sector players to enter carbon markets, which has far reaching and dubious implications.

Refined, objectively calibrated tools that focus on impact assessment, and developing solutions to fundamental issues related to dams development, and less on marketing unattainable promises. Many of these tool are cheaper and some are even free. For example Riverscope1 from TMP systems is a free geospatial tool, which used data from 281 dams to develop its methods and is very useful in identifying risks, alternatives and solutions for dam projects. It does not provide certification, claiming a project to be sustainable, but a functional tool for those legitimately focused on even development. Riverscope is not exhaustive in analyzing myriad issues and impacts resulting of dam development nor does it claim to be, yet still delves into more detailed analyses than the HSS. At the end of the day the biggest issue with the HSS is the claim of “Certified Sustainable Hydropower” – an ambitious claim that has not come even close to realization.

The Mphanda Nkuwa dam project continues to be how it has always been: wrapped in opacity and fraught with risks that have not been adequately analyzed nor discussed by the Mozambican society. But its next move will be to claim its “sustainable hydropower certification”.

1https://riverscope.org/

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