Epupa Dam, Namibia / Reports

This speech, by Steve Rothert of IRN and in cooperation with Earthlife Namibia, explains a number of concerns about the project. Windhoek, Namibia.

An official submissions to the Namibian government on behalf of the Traditional Leadership of the Kunene Region, in relation to the proposed construction of a hydropower scheme on the Lower Kunene River.

SUMMARY OF COMMENTS

The feasibility study for the proposed Epupa Dam in Namibia is so riddled with incorrect conclusions, false assumptions and missing data that it cannot be used as a basis for a well–informed decision on the project, according to a group of outside experts who reviewed the massive report. The reviews, which were filed on Monday with the Namibian government, clearly indicate that the Epupa project has not been justified on economic, social, environmental or power supply grounds.

 

1. Executive Summary

From a hydrologist’s point of view, the Feasibility Study of proposed hydroelectric power dams on the Cunene River has some serious deficiencies. In order of importance, they are: 1) The study is organised so as to be virtually inaccessible to even a careful reader. Separate pieces of the same subject matter are scattered in illogical places throughout the voluminous corpus of the study. 2) Flow data, and estimations in the absence of data, are of low reliability. The entire hydrological analysis is based on the premise that a meagre 12 year streamflow record from a location 200 km upstream of the dam site can be linked with a longer record from another river basin to synthesise a reliable theoretical streamflow data base with which to assess the viability of a 1.9 billion dollar hydropower project. This proposition is shaky at best. 3) The analysis of the effects of changes in the river’s sediment regime as a result of building the dam are incomplete and ignore the most important issues, such as increased degradation downstream and upset of the sediment regime in the delta. 4) The study lacks a definitive appraisal of the thermal and nutrient regime in the reservoir and river. The potential of drastic changes in the temperature, oxygen and nutrient regimes of the reservoir and lower river to upset existing ecological and cultural relationships have been naively understated. These points are elaborated below.

The conclusion is that the Feasibility Study is not a sound basis for evaluating either the costs or the benefits of the project, nor for proceeding with major financial or other irreversible commitments to the project.

Summary
Contrary to assertions in the Feasibility Study, the Epupa hydropower scheme is not the "least cost" power alternative for Namibia. The cost of electricity produced by a combined-cycle gas-fired power plant would be 40% less than Epupa electricity. The consultant inappropriately uses assumptions in the analysis that underestimate the viability of alternative energy sources. Some assumptions are unnecessarily pessimistic, while in other cases the consultant ignored or misapplied relevant information from other continents. For example, using conventional assumptions about Solar Electric Generating Systems (SEGS) would result in 50 percent lower estimated costs than what the Feasibility Study indicates. Global experience with wind power demonstrates that the consultant’s assumption that developing wind power would require 20 years is greatly exaggerated. Wind power could make a substantial contribution to Namibia’s energy portfolio by the year 2005. The pessimistic prognosis on energy efficiency is unwarranted. Contrary to the consultant’s analysis, energy efficiency programs around the world demonstrate that all sectors of energy consumers can easily achieve modest efficiency improvements and that such improvements can improve economic performance of industry, not stifle it. Using more realistic and fact-based assumptions, the evaluation would demonstrate the competitiveness of alternative energy when compared to conventional sources and the Epupa hydropower scheme.

The author reviewed all sections relating to the project’s economic viability, except for the detailed appendix chapters, which were not available to the public outside of Namibia. The author’s comments are his own, and do not reflect the opinion of the institutions with which he is associated.

 

My comments are limited to those portions of the Environmental Assessment Report that deal with issues relating to the peoples who live in the impacted area of the Lower Cunene River, chiefly the Himba. Both international law and recognized professional standards require a very elaborate programme of study, consultation, careful scoping out of potential negative impacts on affected people’s lives, and a social mitigation programme for this Feasibility Study. This Report simply does not do this, a point conceded on page 2 of the Executive Summary. Hence, the Environmental Assessment Report of the Feasibility study is necessarily so incomplete that any scheduling of public hearings is premature: none of the project’s social issues can be adequately addressed in hearings until a full social mitigation study is completed.

The following is a brief review of some sections of the draft feasibility study (FS), focusing primarily on the Epupa Main Technical Report (Part B2). The Baynes Technical Report is a simple copy of the Epupa report, with only key words and appropriate sentences being replaced. Hence the focus below will be on the Epupa option.

Unfortunately, the study cannot be reviewed properly as the crucial figures and appendices (for example to Chapters 23 and 24) are missing.