Letter to IUCN Concerning Lom Pangar’s Independent Expert Panel

To:

Mr. Paul Noupa
UICN, Bureau Régional pour l’Afrique Centrale
BP. 5506 Yaoundé, Cameroun
paul.noupa@iucn.org

Cc:

Mr. Achim Steiner, Director General, IUCN Headquarters
Mr. Ger Bergkamp, Acting Head, IUCN Wetlands & Water Resources Programme
Dr. Jean–Yves Pirot, former Head, IUCN Wetlands & Water Resources Programme

Dear Mr. Noupa,

We are writing to voice our concerns about the proposed Lom Pangar Dam and IUCN’s role in this project. Lom Pangar is already raising serious economic, environmental and social concerns (a detailed fact sheet on the project is attached). Three of the most significant issues are:

1. Dubious contribution to solving Cameroon’s energy crisis and addressing the energy needs of the population: Lom Pangar will increase the hydro–dependence and thus vulnerability of Cameroon’s energy supply; the primary beneficiary will likely be the Alucam aluminum smelter which already benefits from subsidized rates; and access to electricity will not increase for those off the existing grid. The current grid loses over 30% of generated electricity during transmission and distribution, some of which could be recoverable energy through efficiency upgrades.

2. Devastating effects on Cameroon’s remaining forest: Lom Pangar’s 700 km2 reservoir would drown one of Africa’s last hardwood forests, also a significant area of biodiversity, and create new access to other parts of Cameroon’s protected forest. Significant costs were added to the Chad–Cameroon Pipeline Project to ensure protection of this region, which would now be devastated by Lom Pangar.

3. Chad–Cameroon Pipeline Impacts: Lom Pangar’s reservoir would also submerge 20 km of the pipeline. Because it was not built to withstand the extra pressure of the reservoir, the pipeline would have to undergo a costly excavation and be either rerouted or reinforced, resulting in associated costs.

The Lom Pangar Dam and the process being used to justify will be costly choices to the people of Cameroon. If a needs–oriented planning process had been implemented under a WCD framework rather than a project–oriented process, we believe that Lom Pangar Dam would not have been identified as the optimal solution.

International Rivers Network (International Rivers) hosted a teleconference with Mr. Achim Steiner, IUCN General Director, and Mr. Ger Bergkamp, on March 30, 2005. (Ms. Nikki Reisch of the Bank Information Center also participated.) Several issues regarding IUCN’s role in the Lom Pangar project were raised, namely:

1. The exploitation of IUCN’s narrow participation to legitimize the entire Lom Pangar process and project;

2. The passive facilitation role and lack of an explicit position on Lom Pangar by IUCN; and,

3. The lack of information shared by IUCN Cameroon with civil society groups who are attempting to participate in the decision–making process of this project.

We address these issues again here.

IUCN Role Exploited

IUCN has chosen to participate in this project by facilitating the project’s Panel of Independent Experts, which is mandated to review the coming Environmental Impact Assessment against international standards on social and environmental impacts, including the WCD guidelines. Of great concern to us is that IUCN’s narrowly focused participation in this project is being exploited by the Government of Cameroon to legitimize the fundamentally flawed decision–making process for this project. IUCN is helping legitimize this flawed process while remaining silent on the lack of compliance with key WCD guidelines throughout the Lom Pangar project. Yet the Government of Cameroon has stated it considers its use of the IUCN–facilitated expert panel to demonstrate incorporation of WCD recommendations into this project. We fear that without clarifying the limited scope of the Panel’s mandate, IUCN will be used to provide uncritical project approval, effectively green–washing the Lom Pangar Dam.

After IUCN’s vital role in the WCD process, we are greatly concerned that its current role in Lom Pangar may compromise IUCN’s reputation without critically questioning the purpose or process of the Lom Pangar Dam. The adoption of Recommendation 3.24, "Financial institutions and the World Commission on Dams recommendations" at IUCN’s Third World Conservation Congress in November 2004 indicates continued IUCN support for the WCD framework, as well as the need for IUCN to play an active role in encouraging the adoption and implementation of WCD principals.

Silent Approval

The decision–making process for Lom Pangar Dam is being conducted without regard for the recommendations of the World Commission on Dams. The lack of a comprehensive needs and options assessment prior to the selection of this project is just one of the more serious missing elements that would help Cameroon make the best decision regarding which energy projects to develop. The "energy alternatives" assessment planned for the EIA process is limited in scope. Because the aluminum sector is the single largest consumer of electricity in Cameroon and requires huge amounts of energy at the expense of other Cameroon energy users, an analysis of the aluminum sector’s impacts on the economy is also vital at this time. Another key issue is that the Lom Pangar planning process is proving to be secretive and non–transparent.

It is our opinion that, by taking a passive facilitation role and not speaking out on the lack of transparency or the dismissal of WCD standards, IUCN is legitimizing this project, and setting a precedent for what may qualify as "WCD compliance" in the future.

Information Sharing

Although the Expert Panel is mandated to guarantee public consultation, the IUCN office has instead become yet another barrier to public participation and information sharing. The IUCN Cameroon office has repeatedly ignored requests by civil society groups to provide project information. (Note the attached letter dated October 25, 2004.) IUCN continues to refer local requests for information to ARSEL, the governmental regulatory agency for electricity without promoting greater assistance and transparency from the government offices, which also have a reputation for poor transparency and poor dissemination of information. (Note attached letters from ARSEL regarding release of the 2001 concession agreement.) These concrete actions of IUCN’s office in Cameroon are helping to obstruct participation of civil society and maintaining the project’s existing lack of transparency. IUCN is providing virtually no assistance to civil society groups that are bringing forward legitimate concerns regarding the process. We find this situation unacceptable.

In Conclusion

As members of civil society, we request the following:

1. We fear that the Government of Cameroon will exploit IUCN’s narrow involvement in the Lom Pangar Dam project to effectively provide rubber stamp approval of the entire project and decision–making process. In order to be accountable for its actions, IUCN must explicitly identify and publicize the extent and limitations of IUCN’s role and mandate within this project.

2. By its participation, IUCN is perceived to be taking an implicit, supportive position on the Lom Pangar Dam. IUCN must clearly identify its actual position on the Lom Pangar Dam, and identify under what criteria and conditions IUCN will support or oppose this project, congruent to the existing mission and values of IUCN.

3. If IUCN continues its participation in the Lom Pangar Dam, IUCN must actively assist in providing information to all stakeholders and guarantee a transparent process. This includes urging government and other involved agencies to make project information available and accessible in a timely manner, and ensuring the right of public participation in the decision–making process.

Sincerely,

Attachments:
Letter: Initial Request for Information
Letter: Acknowledgment of Initial Request
Letter: Second Acknowledgement