The HSAF Process – A Non-Starter?

Peter Bosshard

The Hydropower Sustainability Assessment Forum (HSAF), a task force led by the dam industry, is currently preparing a new protocol to assess the sustainability of hydropower projects. A recent consultation found that the HSAF protocol will be “toothless” unless it incorporates clear minimum standards. The Forum says that it is seeking “broad endorsement” for its new assessment tool. So how did it respond to the key finding of its consultation?

As I reported earlier on this blog, the Hydropower Sustainability Assessment Forum is currently developing a new assessment tool for the hydropower sector. The HSAF protocol will cover approximately 80 different aspects of hydropower projects, which will allow to rate the sustainability of dams. The dam industry hopes that it will be able to attract carbon credits and concessional finance for projects that pass a future HSAF scorecard.

HSAF is a self-selected body of hydropower companies, governments, financial institutions and large NGOs. Affected people and Southern civil society organizations have not been included. HSAF started a belated public consultation process in January 2009, halfway through its process.

HSAF’s Key Components Document, which provides the basis for the consultation, does not include any social environmental standards which projects need to fulfill in order to be considered sustainable. In particular, the document does not stipulate that projects comply with norms such as human rights, free prior informed consent of indigenous peoples, labor rights, the right of access to information, ecological no-go zones, or international competitive bidding. Instead, it proposes to assess the performance of projects along all aspects – including for example the compliance with national laws – on a sliding scale.

International Rivers published a detailed critique of the Key Components Document in March 2009. We believe that an exclusive club such as HSAF is the wrong body for developing new guidelines and standards for the hydropower sector. Yet any tool that HSAF develops needs to recognize and incorporate existing social, environmental and human rights standards, including UN human rights norms and the framework of the World Commission on Dams. Failing to do so would ignore hard-won lessons of earlier development disasters.

HSAF recently published a report on the outcome of their consultation. According to the report, about 180 people accessed the Forum’s online questionnaire. Thirty people, mainly from hydropower companies and financial institutions, left detailed comments. Interestingly, the need for minimum social and environmental standards was a recurrent theme in the feedback to the consultation.

Most financial institutions and governments have to consider minimum standards in their project decisions anyway, and want them to be included in the HSAF protocol. Financiers commented that a protocol without such standards would be “toothless”. According to the consultation report, even the hydropower industry “wants a sustainability standard to assess prior to an investment which issues will arise during the construction and commissioning of a dam”. Indeed, minimum standards don’t only protect the rights of affected people; they also create predictability for financiers and investors.

When NGOs questioned the late date of the consultation, the HSAF coordinator assured us that “all is not set in stone, that engagement is not meaningless and a waste of time, that it is not too late, that there is important protocol content that has the potential to be improved, and that this is an opportunity that we hope is not missed”. So how did HSAF respond to the near-unanimous request for minimum standards in the consultation?

When they met to discuss the outcome of the consultation on March 10-13, the HSAF members agreed to clarify how their protocol will relate to the WCD framework and the IFC performance standards, which private banks have to implement as part of the Equator Principles. Yet HSAF declined to incorporate minimum standards into their protocol.

The Forum’s official response to the consultation states: “The Draft Protocol will set out a spectrum of performance on key hydropower sustainability issues without specifying guidelines or minimum standards on acceptable hydropower sustainability performance.” At the World Water Forum in Istanbul we were told that HSAF will not even use terms such as “best practice”, “good practice”, “satisfying” and “acceptable” to avoid the impression of setting minimum standards in their protocol.

HSAF is currently finalizing their draft protocol, and will hold a second consultation on this document in August-October. The Forum’s failure to integrate the most important feedback from the first phase of the consultation will strengthen the voices which consider the belated outreach effort a public relation exercise and farce.

Civil society will not accept a hydropower protocol that ignores internationally recognized social and environmental standards. If the HSAF process indeed aims to develop a “broadly endorsed” assessment tool for hydropower projects, as its founding documents state, the current proposal is a non-starter.

Peter Bosshard is the policy director of International Rivers. His blog, Wet, Wild and Wonky, appears at