On 16 November 2000, almost exactly ten years ago, Nelson Mandela released the report of the World Commission on Dams (WCD) in London. The WCD, it may be recollected, was a 12-member Commission representing dam builders, engineering companies, NGOs, affected peoples movements etc. set up in 1998 at the initiative of the World Bank and the International Union for Conservation of Nature to assess the development effectiveness of large dams worldwide. Even with the diversity of its members, it delivered a unanimous report, vindicated many of the serious criticisms of large dams, and come out with a set of criteria and guidelines under which large dams should be built.

The WCD report carries with it the credibility that comes from broad participation, including those whose voices are normally not heard. Ten years later, the WCD's relevance has only grown, a testimony to its farsighted treatment of contentious issues, and to the meticulously assembled knowledge base.

It is ironic then, that as the WCD completes ten years, the hydropower industry has brought out its Hydropower Sustainability Assessment Protocol in September 2010. The Protocol has been described as "a sustainability assessment framework for hydropower development and operation." Unlike the WCD report, however, this document has come out of a highly exclusive process. Predictably, therefore, it has serious problems, and it risks undermining and weakening of social and environmental standards for dams and hydropower.

Moreover, it threatens to sideline the WCD. The International Hydropower Association (IHA) that led the process to develop this Protocol expects "over time this Protocol may inform the evolution of or be adopted as the assessment approach used by governments, banks and other institutions." In other words, replace the WCD as the main framework to assess large dams and hydropower projects. This expectation is not surprising at all.

The WCD faced strong resistance from several Governments (including India) and the dam building establishment, primarily because its recommendations included an increased role for the maginalised people in decisions related to dams, equal weightage for social and environmental impacts, and called for a more equitable sharing of the benefits and costs. Witness India's response to the WCD report that "... emphasis on equity in a wrong manner is dangerous. Many countries including India and USSR have learnt hard way that too much emphasis on equity can only perpetuate poverty." At the same time, the WCD received wide acceptance, and many elements of the framework - if not its entirety - are becoming part and parcel of the standards to which dams are being held accountable.

Dam standards are important to protect the environment and communities as dams are built all over the world. But with climate change being used as reason to push dams and hydropower even more, and the Clean Development Mechanism (CDM) and Carbon Trading opening up huge markets for "carbon credits" that can be obtained from hydropower - the standards to which these dams are subjected become crucial financially also. This is because carbon credits are accepted for trading only if they are from "sustainable" projects. Thus, stringent criteria like those set by the WCD could lead to fewer projects qualifying for the money-spinning CDM.

With NHPC, India's leading state-owned hydropower company on the Board of IHA, several other Indian hydropower developers as members, and one of the test trials of the Protocol being carried out on NHPC's Teesta V project, it is likely that the Protocol will be pushed in India as an indicator of sustainability. All the more reason, then, to understand the problems and limitations of the IHA's Protocol and reiterate the importance of the WCD framework.

The 'Protocol' of vested interests

The Protocol is essentially a score sheet - project scores ranging from 1 to 5 are given for a number of different elements of sustainability. Assessments are made for four phases of any project - Early Stage, Preparation, Implementation and Operation - and scoring is done for all but the first stage. There are a total of 62 topics for scoring in sections 2-4; these include Governance, Economic Viability, Project Affected Communities and Livelihoods, Environmental and Social Management, Cultural Heritage, Labour and Working Conditions, and so on. A score of 3 for any topic is equivalent to "basic good practice" and a score of 5 is awarded for a "proven best practice".

The Protocol does not claim to be a standard, saying "Organisations may hold different views on what levels of performance are linked to a sustainable project, and the Protocol makes no specification on requirements for acceptable performance." In other words, projects performing differently on the same topic may have the same score. This, however, will allow projects to conform to weaker or lower standards and still present the image of being "sustainable".

Notwithstanding this disclaimer, the Protocol does say that it is designed so that a level 3 score, of good practice, is "broadly consistent with the IHA (International Hydropower Association) Sustainability Guidelines 2004". These Guidelines were brought out by the IHA in 2004 to "to promote greater consideration of environmental, social and economic aspects in the sustainability assessment of new hydro projects and the management and operation of existing power schemes" and do constitute a benchmark of sorts even if not full-fledged standards.

Not only are these guidelines considerably weaker than those in the WCD recommendations, this also means that the Protocol is essentially designed to assess projects against a standard developed by the Hydropower industry itself - which clearly has a vested interest in the standards being less stringent.

For example, the WCD requires a basin-wide understanding of the ecosystems and how communities depend on and influence them, "before decisions on development options are made." In other words, a basin-wide comprehensive study is a prerequisite for assessing individual projects. The Sustainability guidelines of the IHA, on the other hand, take a policy position that "Environmental Assessments (EAs) should be applied at the project level." These EAs are only required to "take account of higher level regional or national ... assessments ... including assessments already completed for the relevant river basin(s)." Thus, a river basin level assessment is not mandatory but needs to be considered only if it is already done.

Not only are the Protocol's guidelines considerably weaker than those in the WCD recommendations, this also means that the Protocol is essentially designed to assess projects against a standard developed by the Hydropower industry itself - which clearly has a vested interest in the standards being less stringent.

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This Protocol has also been developing in an exclusive manner. While the Forum put together by the IHA to build this Protocol included some civil society organisations, these have been the large International NGOs like WWF and Oxfam, and there has been no involvement of dam-affected people, dam critics and other southern dams-related struggles and movements. These groups were invited much later in the process to provide some inputs, but these consultations were too little, too late and too limited. In any case, movements of dam-affected people have argued for seats at decision-making tables, not merely being "consulted" - which is more often than not a process by which people are heard and then ignored.

The implementation of the Protocol will be controlled by the IHA. Only those who are licensed by the IHA can assess a project. Further, it is expected that the assessment will actually be carried out by the assessor working closely with a representative of the project. This representative, called the Lead Project Representative, will be the main point of coordination for the assessment and will arrange, among other things, the agenda and the interview schedules for the assessor, provision of an interpreter etc. Clearly, such an arrangement is hardly likely to result in a truly independent assessment of the project, or provide space to critical voices.

Given all this, it is clear that the Protocol is a tool developed by the industry, by excluding the people affected by such projects, to be administered by consultants who will be licensed by the industry body and often paid for by the project, and who will conduct the assessment in close coordination with the project promoters! Further, the Protocol allows a project to get high scores and create an impression of sustainability, even if complies with standards weaker than the WCD, or those adopted by many internationally agencies.

This document can at best be useful for some of IHA's internal workings. However, as a credible, publicly accountable means of measuring and ensuring sustainability - and that includes justice, equity and human rights - it is totally inappropriate. The WCD remains the only comprehensive framework that has emerged from a widely participatory process, with the voices of the affected people having a meaningful say. It is important that instead of such limited tools like the Protocol, the WCD framework should be adopted as the central approach to define just, sustainable, equitable planning, decision-making and implementation of dams and other water resource projects.