UPDATE – 26 APRIL 2020: Deadline Extended
Good news! The deadline for commentary, which was to have been 30 April, has been extended (due to COVID-19):
In light of the current COVID-19 pandemic, the Zambezi River Authority (the Authority) and ERM have postponed all public disclosure meetings scheduled to take place between 17 and 22 April 2020. This decision is in response to government-mandated travel restrictions, stay at home orders, and bans on gatherings, which have been imposed in southern African countries.
Given the current level of global uncertainty associated with COVID-19, the Authority and ERM are unable to determine at the present time when these meetings may be reasonably rescheduled. The Authority and ERM will provide adequate notification of rearranged dates, once these have been established.
Please note that the review and comment period for the draft ESIAs will remain open until such time that the Authority and ERM are able to hold the ESIA disclosure meetings, or until further notice is given by the Authority and ERM. Your input remains key in the updating and finalisation of the ESIA studies and stakeholders are encouraged to continue reviewing the draft ESIAs and to submit questions and comments to ERM: email@example.com
Please respond, even if it you only write a single sentence. I think a good point to make is that a unique place like Batoka Gorge should not be viewed merely as a commercial asset of interest only to local ‘stakeholders’ (in reality we know that this, in any case, does not really mean the actual local people; it means the vested financial interests of the rich and powerful) but as an irreplaceable site of incalculable intrinsic value for the entire planet. We surely all have a stake in such places, as do our children’s children’s children…!
My Initial Response
I trust my response below to this Environmental and Social Impact Assessment (ESIA) speaks for itself!
To whom it may concern
Preliminary Comments on ESIA for Batoka Gorge Dam
My relationship to this project is that of a concerned global citizen who grew up in Zimbabwe, has a degree in ecology and who is employed by an environmental charity which, though based in the UK, does some work in Southern Africa.
The ESIA documents consist to a large extent of ‘shoulds’ and ‘coulds’. There are many fine words on mitigation options and strategies but there is no guarantee that any of these will be followed once the dam is a fait accompli. Given the outstanding ecological merits of the site (see, for example, https://www.internationalrivers.org/resources/batoka-gorge-dam-zambezi-river-8291), this is a cause for grave concern. In some cases these ‘mitigation options and strategies’ are downright risible. For example, in the document titled ‘Review of ESIA against the WCD and IHA Guidelines & background on the World Commission on Dams & International Hydropower Association’s Sustainability Guidelines & Hydropower Sustainability Assessment Protocol’ in the section on ‘Rare and endangered species’ the following are listed:
- Plans to manage this issue need to be developed prior to construction and options for mitigation identified and assessed.
- Habitats of critical importance should be identified (within a wider regional context) and impacts to these avoided or minimised as much as possible during the design phase.
- Targeted management plans need to be developed for species of conservation significance. Translocations or habitat rehabilitation may be options, along with identification of suitable habitat for ‘reserve’ management
As the habitat for several species (rare raptors at least) is being completely eliminated at the site, these words ring hollow. Suitable alternative habitats will already be occupied, meaning that populations will simply be significantly reduced. Without detailed knowledge of the interaction between sub-populations, population genetics, and the threats facing other populations it is impossible to be sure that some species will not be critically threatened.
With climate change an ever-growing threat, it is understandable that sustainable electricity generation should be a priority. However, large hydro-power projects have a notoriously bad track record as far as social and environmental impacts are concerned, as well as with regard to corruption. My comments above relate to the first two points. Here are just a few references on the last one:
Unless there is complete transparency with regard to the beneficiaries of this massively expensive project, I believe it is reasonable to fear that it will be riddled with corruption, and that any financial benefits will simply enrich an already wealthy few (who will siphon the money into tax havens), increasing inequality. In general, I would argue that sustainable solutions to power should put control in the hands of local communities and, in places like Southern Africa, solar power offers enormous promise. In the document titled ‘Proposed Batoka Gorge Hydro-Electric Scheme (Zambia and Zimbabwe) on the Zambezi River;. VOLUME I – Environmental and Social Impact Assessment (ESIA) for the Project Area of Inundation, Staff Villages and Quarries’ it would seem that solar power is dismissed with these words:
This indicates that solar is presently an undesirable technology from an investment efficiency perspective when compared to other technologies. Development of solar PV can therefore for now only be supported by strong renewable energy polices rather than technology competitiveness. This is consistent with the ENVIRONMENTAL RESOURCES MANAGEMENT BGHES ESIA REPORT 6-4 penetration of solar technology in other electricity markets (ZETDC, 2015). Where solar PV has penetrated the market significantly, high electricity tariffs reflect the cost of energy.
This ignores the fact that the cost of photovoltaics is falling rapidly. See, for example:
I am confident that the economics of these has changed drastically since the report was commissioned, and I urge the authorities to review these figures and project how they will continue to change in the coming years. The glib dismissal of solar power is a major flaw in the ESIA (and raises suspicions re vested interests/corruption).
The wording would also seem to suggest that power schemes should be judged primarily from the perspective of large-scale investment opportunities. At a time of massive biodiversity loss, coupled with climate change and growing inequality, should this be the main criterion? Solar power should, in my opinion, largely be diffuse, small-scale and locally owned, even down to the level of individual households. Grand large-scale schemes are wide open to wastage, delays, corruption, etc., to say nothing of losses in long-distance transmission, infrastructure failures, etc.
Another major point, related to the dismissal of solar, is the unpredictability of rainfall in this era of climate change. According to International Rivers (https://www.internationalrivers.org/resources/batoka-gorge-dam-zambezi-river-8291):
Harrison & Whittington (2002) carried out some climate modeling on the proposed Zambezi dams and found that the Batoka Gorge Dam is likely to lose 6-22% production due to declining rainfall as a result of a warming climate in the basin. In his 2012 report on the hydrological risks of planned Zambezi dams (Batoka included), Beilfuss reported that these dams are unlikely to deliver the expected services over their lifetime.
It follows that any assumptions regarding the dam’s future operation and generating capacity can only be considered to be wildly speculative. By contrast, solar energy is far more reliable.
Thank you in advance for considering these preliminary comments.
Robert Eric Swanepoel, PhD, MSc (Ecology), BVSc, MRCVS