International Rivers Comments on the West Nile Electrification Project (Uganda)

Friday, May 10, 2002

Current Status: Registered on 10 February 2007

International Rivers Comments on the World Bank Prototype Carbon Fund West Nile Electrification Project in Uganda

Submitted to the PCF


International Rivers has closely reviewed documents available on the proposed PCF West Nile Electrification Project in Uganda. We have a number of concerns regarding the procedures followed in developing the project, the estimation of electricity produced and carbon emissions prevented, and project compliance with CDM additionality requirements.

Procedural concerns:

The available project documents do not specify if the proposed hydroelectric facilities will involve an impoundment, and if so, what will be its size. This is a critical piece of information since impoundments emit greenhouse gases. Greenhouse gas emissions have been recorded at all reservoirs where measurements have been taken. Methane and carbon dioxide emissions due to dams in the tropics are significant and can be equivalent to or exceed emissions from thermal plants per kilowatt hour produced (see WCD Thematic Review on Dams and Global Change). The issue of reservoir emissions must be explicitly addressed in any CDM hydroelectric project that includes an impoundment.

This project is considered a World Bank category F project. The IFC, with similar project categories as the World Bank, specifies in Annex F of its Environmental & Social Review Procedures that category F "subprojects comply with... IFC environmental and social policies unless the total project cost is less than $500,000." It is presumed that the same is true for World Bank category F projects.

An Environmental Assessment has not been made publicly available. The preparation of an Environmental Assessment and its full disclosure are key recommendations of the WCD, and are requirements of Category B World Bank projects. The effects of the project on fish and other aquatic life, land use change, and sediment transport have not been discussed in available project documentation.

There is also no mention of consultations with affected communities. Stakeholder consultations are another key recommendation of the WCD. The World Bank requires public consultations in preparation of an Environmental Assessment.

The last procedural issue we wish to raise is the lack of analysis of alternative energy sources. A comprehensive options assessment is also one of the main Strategic Priorities of the WCD. These Strategic Priorities have been endorsed by the World Bank. Also, World Bank policies specify that alternatives to a project must be considered in an Environmental Assessment.

Technical concerns:

A plant factor of 90% is expected according to the Projections of Emissions Reductions document. Such a plant factor is very unlikely; according to World Bank data, the average hydroelectric plant factor in developing countries is around 49% (1). Hydroelectric output has been consistently overestimated by hydrologists for reasons including insignificant attention to the impacts of droughts. Of 63 hydropower dams evaluated by the WCD, 55% generated less power than projected.

Further, estimates of future electricity produced must account for changes in hydrology patterns due to the effects of climate change. A recent paper by two Edinburgh University engineers presented at the Hydropower 01 conference in Norway in June 2001 (G. Harrison and B. Whittington, "Climate change: A storm brewing", International Water Power and Dam Construction, September 2001) states:

"Global warming and changes in precipitation patterns will alter the timing and magnitude of river flows. This will affect the ability of hydropower stations to harness the resource and may reduce production, implying lower revenues and poorer returns."

The paper notes that it is "imperative that project analysis takes account of potential climatic impacts." It also states:

"The techniques of hydropower appraisal are long established. However, the continuing reliance on historic flows to indicate future flow conditions is not prudent given the prospect of climate change."

The general trend of hydropower consultants to overestimate streamflow and hence power production and the greatly increased hydrological risks due to climate change add to a major risk that the emissions reductions achieved by this project would be less than estimated. Given such uncertainties, a range of expected emission reductions is appropriate for evaluating project attractiveness. Single values such as given in this case are inappropriate and highly misleading. Sensitivity analyses should also be required for the unit costs of power from the project allowing for hydrological risks and the likelihood of significant cost overruns (World Bank analyses show hydropower cost overruns averaging 30% (2); the WCD found average overruns to be 56%).

Lastly, a discussion of construction emissions was also missing from the Projections of Emissions Reductions.

Concerns regarding additionality:

This project is a component of the Uganda Energy for Rural Transformation (ERT) program funded by the World Bank. Our main question about the additionality of the project is that ERT funds small–scale rural renewable energy projects throughout Uganda. The PCF must justify why the West Nile Hydroelectric project is only viable with the addition of PCF funds and would not otherwise be funded by the ERT, and how the addition of PCF funds to the project increases the amount of renewable energy produced and therefore diesel displaced.

For the reasons discussed above the West Nile Project has not met World Bank, WCD and CDM requirements. We request that further information and analysis be made available before the project proceeds with additional opportunity for public comment.

We look forward to hearing from you on the issues we have raised.


Barbara Haya
Research Associate
International Rivers, Climate Program
May 10, 2002

1 Besant–Jones, The Future of Hydropower, p. 14;R. Hunt and J.M. Hunt , "How Does Hydropower Compare?", Independent Energy, November 1993.
2 J. Besant–Jones, "A View of Multilateral Financing from a Funding Agency", in Financing Hydro Power Projects "94, proceedings of conference sponsored by International Water Power & Dam Construction, Frankfurt, 22–23 September 1994.