World Bank Should Address Legacy in Inga Rehab

Thursday, May 24, 2007

RE: Concerns of proposed Regional and Domestic Power Markets Development Project (ID P097201)

Read a letter to the World Bank from Congolese NGOs

To the World Bank Board of Directors:

We commend the Bank’s interest and commitment to refurbish existing energy infrastructure at the Inga site in Democratic Republic of Congo (DRC). However, the legacy of the Inga dams and the interest in further hydropower development of the Inga site raise several issues which create a more complex context for the Bank’s proposed Regional and Domestic Power Markets Development Project (RDPMDP).1 The following issues demand further attention before the Bank approves financing for this project.

Comprehensive Inga community development plan

The dams have not improved the quality of life for those living in the Inga region and have in fact resulted in negative impacts which need to be addressed. Contrary to the Integrated Safeguards Datasheet for RDPMDP, local groups report that there are outstanding social and environmental impacts from the Inga 1 and 2 dams.2 Local community members have identified the following as part of the Inga legacy:

  • During the original construction, there was no consultation process, and no compensation was given beyond inadequate resettlement for identified land use rights holders.
  • Those displaced were removed from the area and provided inadequate housing: small rooms regardless of family size without water or sanitation facilities.
  • Many indirect and unofficial promises were made to affected communities in terms of community development and job creation, but nothing happened.
  • Employment created by the Inga dams has been insignificant. Only a few people currently work at the Inga hydropower site and priority has not been given to local people.
  • Many people lost their livelihoods and sense of belonging. Cultural losses also went uncompensated.
  • Villages less than 1km from Inga continue to lack access to electricity.
  • Healthcare and education are difficult for Inga communities to access due to cost. Community members must pay for healthcare at the medical clinic which was built for SNEL personnel. School fees for their children are reportedly beyond the ability of ordinary villagers to pay.

The dam affected communities demand reparation and adequate living standards. In addition, a large number of people are now facing expulsion from the SNEL concession. This displacement is an integrated part of the development of Inga and calls for Bank attention.3 Local communities are also bracing for future impacts from further development of the Inga site. (Currently, there is a census underway to register those who will be displaced by construction of Grand Inga.)

In order to address the legacy of the Inga dams, ensure that the local communities are amongst the first beneficiaries of further development of the Inga site, and streamline the management of local social and environmental impacts, the RDPMDP should include a comprehensive community development plan which:

  • Is developed in a participatory manner with the affected communities;
  • Addresses the environmental and social legacy of the Inga dams, including detailed social and environmental evaluations of the region since construction;
  • Provides infrastructure for community development, including but not limited to health, housing and education, which will improve the region’s standard of living;
  • Addresses the anticipated displacement and resettlement anticipated for further development of Inga, including the displacement of those within the SNEL Concession;
  • Includes benefit-sharing with the local communities from the Inga dams;
  • Sets up a framework to address community grievances of impacts related to all Inga hydropower operations; and
  • Provides a framework for regular, participatory evaluation of environmental and social impacts related to the operation of dams at Inga.

Financial support for government preparations for further development of Inga is component 4b of RDPMDP.4 The Bank has also suggested that it may support further development of Inga in the future. Including a comprehensive Inga community development plan in the context of RDPMDP will be to the Bank’s benefit as well as to the benefit of local communities, the government, and future project developers. It will promote better relations between the local communities and other stakeholders before any further expansion of the hydropower site takes place. Early and streamlined management of local social and environmental impacts of hydropower development at the Inga site will also be the most cost-effective way to address these.

Environmental concerns: A Category "A" project?

The 2002 report, Biodiversity Survey: Systematics, Ecology, And Conservation along the Congo River by Dr. C. Shumway et al, reports that water samples in and around the Inga reservoir contain extremely high levels of heavy metals, especially lead and cadmium.5 The report found the level of lead alone to be four times higher than what the US Environmental Protection Agency considers hazardous.6 According to the report, this pollution poses danger to human health via drinking water and fish consumption and may also pose risks to other species.

In addition to these dangers, this contamination will complicate the planned dredging of the Inga reservoir and removal of contaminated sludge. Although the Integrated Safeguards Datasheet states: "The dredging sludge will be tested for chemical pollution. Based on the test results a safe disposal place will be identified", we believe that stronger action is required to ensure that appropriate design and mitigation measures are in place, before project implementation begins.

Based on available data, we believe that the RDPMDP should be reclassified from a Category B to a Category A project under the Bank’s OP/BP 4.01. There is precedent for this: in 2003, the World Bank approved the Nura River Cleanup Project (ID P059803) as a Category A project to complete a dredging and toxic clean up Khazakstan’s Nura River.

The RDPMDP should also include more detailed studies of the heavy metal pollution, especially in fish consumption and drinking water supplies of local communities. Such studies should identify the source of pollution and lead to the provision of a management plan to clean up the contamination and to monitor for future contamination.

Reclassifying the RDPMDP as a Category A project will also support further evaluation of the Inga legacy as part of developing a comprehensive community development plan.

Demonstrated improvement in fiscal responsibility

One objective of the RDPMDP is to increase export revenues through sales of electricity to neighboring countries. However, this objective is of questionable value for poverty reduction, given the lack of fiscal transparency in the DRC and the country’s poor track record with corruption and effective spending. The Bank’s INT department has even conducted an internal inquiry into the mis-management of its funds in DRC, but has neglected to release the report or its findings. An October 2006 declaration by members of Congolese and southern African civil society organizations (see attached) demands that: "Corruption [...] be eradicated from the management of the incomes generated by the hydroelectric exploitation of the site of Inga, by ensuring the greatest transparency in the system of perception of the receipts, their redistribution and their assignment."

A minimum standard of fiscal transparency and management is necessary, not only for electricity exports, but across the DRC’s broad range of revenue generating activities. Demonstrable improvements in DRC’s fiscal responsibility, transparency and management should be evident prior to the Bank’s approval of the RDPMDP. Without evidence of such improvements, the potential poverty reduction benefits of this project are questionable. In addition, the Bank’s report on mis-management of Bank funds in DRC should be released prior to the board’s consideration of the project.

In conclusion, we recommend that the Board insist on the following prior to approving financing for the RDPMDP project:

  • A participatory, community development plan for the communities affected by Inga 1 and 2, and those which will be affected by further development of the Inga site, be prepared and implemented in the context of RDPMDP;
  • The RDPMDP be re-classified as a Category A project and include detailed assessment of environmental risks related to heavy metal contamination and evaluations of Inga’s social and environmental legacy;
  • Demonstrable improvements in fiscal responsibility, transparency and management by the government of DRC, particularly SNEL; and
  • The public release of the Bank’s internal report (INT audit) on the misuse of its funds in DRC, prior to the approval of any additional funding for the DRC.

These actions will help address the legacy of Inga 1 and 2 and dramatically improve RDPMDP’s ability to achieve its development goals. Thank you for your attention to these matters.


Terri Hathaway
Africa Campaigner


  1. This project, ID P097201, is also identified as the Southern Africa Power Markets Program APL1-b and has previously been identified by its French acronym, PMEDE.
  2. From the Integrated Safeguards Datasheet: "The environmental impacts of the construction and operation of the Inga 1 and Inga 2 Hydropower Plants were and still are moderate and manageable. There are no legacy issues to consider." (p. 3) ... "The population who had the land use rights at the time of the construction of Inga 1 and Inga 2 has been adequately compensated." (p. 6)
  3. From the Integrated Safeguards Datasheet: "Presently there are around 6,000 former SNEL workers living within the Concession. SNEL is negotiating with the Government of DRC to resettle these old workers outside the Concession, but this is not related to the project." (p. 6) According to local reports, this population was threatened in 2006 with being forcibly displaced without proper compensation nor negotiation, allegedly for further development of Inga. Although this situation is currently calm, we fear that resettlement will be poorly managed and will lack adequate oversight.
  4. From the Project Information Document: "Component 4: Capacity Building (US$ 31.2 million): [...] Subcomponent B: strengthening MoE’s capacity to develop sector reform and to support further development of the Inga site." (p. 4)
  5. This report was conducted under the Congo River Environment and Development Project (CREDP) and published by the New England Aquarium. CREDP is financed by USAID and implemented by Innovative Resources Management (IRM). The report is available at
  6. From Shumway et al: "The EPA considers a lead level of 40 μg/L ‘imminent and substantial endangerment, based on toxicological studies on young children,’ (, and the lead level found is 4 times greater than this." (p. 55)