Letter to IHA Regarding Lack of Civil Society Participation in HSAF

Monday, January 12, 2009

Dr. Refaat Abdel-Malek
International Hydropower Association
Nine Sutton Court Road
London Borough of Sutton, SM1 4SZ
United Kingdom

Dear Dr. Abdel-Malek,

We are writing to express concerns regarding the International Hydropower Association's
Hydropower Sustainability Assessment Forum (HSAF) as the process to revise the Sustainability
Assessment Protocol reaches its halfway point. In particular, we are concerned about the lack of
outreach to and opportunities for input from dam-affected people, social movements and civil
society organizations in the five HSAF meetings that have been held to date. It is during these
meetings that the critical work of reviewing the existing Sustainability Assessment Protocol and
debating the essential components of sustainability in hydropower development was conducted.

The limits on participation for the HSAF process began with its formation in early 2008, as a
small and self-selected group of governments, funding agencies, industry representatives and
NGOs were chosen as HSAF members. The diverse views of dam-affected people, social
movements, indigenous peoples and civil society organizations cannot be adequately presented
by the few NGOs that are HSAF members.

Furthermore, from a review of the materials on the IHA website, it is clear that most of the
outside presenters invited to attend the five HSAF meetings held so far are from the hydropower
industry, government, consultancies or funding agencies. Many of these stakeholders share a
"pro-hydro" perspective, and it seems little information has been provided to HSAF members
emphasizing the environmental and social challenges of hydro development - especially from
the perspective of those directly impacted by dams.

The HSAF process is missing the opportunity to learn from, be guided by and include the critical
knowledge of those who have been affected by hydro development or are primarily concerned
about protecting rivers and supporting the livelihoods of communities that depend upon them.
Having a diversity of views at the table is also essential if the goal is to ensure that any revised
Sustainability Assessment Protocol would be a credible evaluation tool for hydropower projects.

We understand that the HSAF will soon post an outline of the revised Sustainability Assessment
Protocol and invite comments on this draft for a period of approximately six weeks. While the
draft may be posted on the web and targeted interviews may be conducted with specific
stakeholders, it appears that no mechanisms have been developed to ensure comprehensive and
meaningful consultation on the draft with dam-affected people, indigenous peoples, social
movements and civil society organizations.

A credible, comprehensive and meaningful consultation process with civil society should meet a
number of basic requirements:

  • Meaningful participation. Information dissemination and the consultation itself should not rely solely on web-based forms of communication. Materials should be mailed or otherwise available in hard-copy to participants as necessary, and face-to-face consultation meetings in a number of regions of the world with a range of stakeholders (including civil society groups, affected people and indigenous peoples) should be conducted. Proactive communications should take place with a diverse array of stakeholders to ensure that they are aware of the consultation process and that their participation is encouraged. Workshops should be broadly advertised in the regions in which they take place to ensure maximum possibility of representation from a variety of stakeholders.
  • Adequate time. Consultation materials - including necessary background information - need to be provided to stakeholders with adequate time (three to four weeks) to allow for review and preparation before any consultation workshop.
  • Appropriate language and format. Key consultation materials must be available in an appropriate language and format so that they are easily understandable to a broad array of stakeholders, including civil society organizations, social movements and affected communities. The consultation workshop itself should be conducted in the appropriate language with interpretation available as necessary.
  • Sufficient resources. Comprehensive and meaningful consultations cannot be conducted on the cheap. Adequate funding is required to produce appropriate materials and bring a meaningful number of civil society organizations, social movements and affected communities to consultation venues.
  • Responsiveness to feedback. A clear process for documenting and incorporating the feedback received through the consultation process must be developed and explained to consultation participants. A document outlining the feedback received during the consultation period and how/if the Sustainability Assessment Protocol was changed as a result should be produced. Further comment and reflection on that document should also be encouraged.

We look forward to hearing how the IHA intends to rectify the shortcomings noted above and to
ensure meaningful consultation with civil society organizations, social movements and, in
particular, dam-affected people in the next phase of the HSAF process.

Patrick McCully
International Rivers