Together with six other non-government organizations (NGOs), Ole Siosiomaga Society (OLSSI) was invited on 25 July 2018 by the Manager of the proposed EPC Alaoa Multi Purpose Dam Project to a related meeting with representatives of a few government Ministries and institutions, project consultants, ADB officials, and EPC staff.
Unfortunately only OLSSI turned up perhaps due to the late one-day advice and lack of supporting documents shared in the invitation to assist us prepare well and better align to the proposed project discussions.
Whilst OLSSI registered its objection on timing and lack of information we nevertheless tried to make the most of the opportunity quickly reading through the ‘overview summary’ and 73 pages of final inception report sent later on request the morning of the same day of the afternoon meeting.
I was genuinely interested to attend and rescheduled prior engagements. After all, this was the first time I knew there was such a government and EPC Alaoa Multi Purpose Dam Project. Every time I see the word ‘hydro dam’ something runs up my spine and I feel uncomfortable! Scared in fact! Especially for the people living around the proposed site area. So despite the process and timing problems with the invitation, I went because I was interested from a stakeholder civil society and local community perspective.
A dam proposed to be sited inland from some eight village communities downstream the Vaisigano River with close proximity to the urban Apia metropolitan, business center, and commercial focus of Samoa makes it even more concerning to say the least. So I needed to know and wanted to contribute.
The EPC invitation stated that EPC is undergoing Environmental Impact Assessment (EIA) Study for building this multipurpose dam in Alaoa for 3 purposes.
1. to stop or minimize impacts of major floods like the 2012 flood during Cyclone Evan that caused a lot of damages in Vaisigano River;
2. provide all season storage for water supply to Apia; and
3. for power generation from a new hydro to be built in Alaoa.
As part of its stakeholder engagement responsibilities, EPC invited NGOs to meet and discuss with the consultants and ADB the carrying out of the EIA study and safeguard issues related to the project.
On request for more information, Program Manager later added that “…we all witnessed damages of the flood during Evans in 2012...which caused 500 million tala of damages as well as fatalities and major damages to EPC hydro plants and other infrastructure...we realized the only solution is to construct a large dam in Alaoa to contain major flooding of Vasigano river...total EPC losses alone is in order of 50-70mi tala...that is why we submitted a request to ADB for establishing of this project for a flood control dam with hope to get some of climate change funding through GCF (Global Climate Fund)...that is how whole project started in 2016...GCF approved it in principle but required a a full feasibility study...our govt accepted to have ADB as the leading agency to spearhead the coordination of this project...ADB/Govt selected ENTURA consultant from Australia for feasibility study...technical and EIA...we have completed technical feasibility study, dam site selection, geotechnical drilling, and now is EIA.....results of all these studies will include in our Govt submission to GCF and other donor partners...for funding.if all goes well and funding is secured...we are looking into start construction in 2020..and it will take 2 to 3 years to build it.....this dam is 4 mi (million) cubic meters capacity...compared to Afulilo dam 10mi cubic meter capacity... 4 mi is allocated as follows...0.5mi for silt retention at bottom, 0.5m for water supply and 3 mi for flood control...”
For me, this was very useful information. It was clear from the Manager’s email that the three stated purposes for the project were to minimize flood like that caused by Tropical Cyclone Evans in 2012, to provide water storage, and secure additional power generation through the proposed hydro dam at Alaoa.
It was also clear that the proposed hydro dam was close to half the size of the Afulilo hydro power dam in terms of volume. Whilst all three stated purposes are laudable, they confirm my sense of fear over the possible impacts of such a hydro dam built close to villages and Apia. More stated facts are quite worrisome:
a. “EPC proposes to construct a large 4 million cubic meters dam at Alaoa” – close to half the 10million cubic meters in the Afulilo hydro dam! So this Alaoa project is a relatively large undertaking sited close to the 8 villages downstream along the Vaisigano River and proximity to the Apia Town area and its hinterlands.
By comparison, the area under the Afulilo hydro dam is around 600 acres. This Alaoa initiative is a relatively massive undertaking with the proposed hydro dam constructed in a much lesser area, more confined space, and with immense water pressure that need to be safely contained in a dam structure. At least the 600 acres of land area taken up by the Afulilo hydro project is expansive enough for water to be distributed rather safely throughout.
The Alaoa proposal on the other hand will be fraught with many design, safety, engineering and structural challenges in respect of site geography, lesser area, rugged topography, geology uncertainties, and how to safely manage the immense pressure of damming 4 million cubic meters of water in a dam with such constraints will undoubtedly be a human nightmare for EPC but especially a daily safety concern for those residing close to it in the likelihood of failure.
b. “Feasibility study for the project activities started in 2016” – this means the concept design and stated activities have been ongoing for the last 2 years. It was however evident that ADB, the consultants, EPC, and government ignored obligations to engage in stakeholder consultation on the project and this failure could render rejection of the project proposal should we pursue this to higher governance level of ADB and GCF as targeted donor. We were advised that the EPC only had their first meeting with the 8 village communities affected by the project the same morning of the day we had our NGO meeting in the afternoon.
c. “Government had accepted ADB as leading agency to spearhead coordination” - That is fine but ADB has clear policy and regulation to trigger and comply with in terms of indigenous peoples and local communities, on resettlement issues clearly relevant in any hydro-dam project, requirement for due diligence process, assessment of compensation to those affected by the project, etc.
Both ADB and ENTURA as selected consultant seem to have ignored those clear compliance issues and EPC failed to ensure putting in place an independent mechanism to check these compliance requirements are met. The serious and broader impact the Alaoa project poses on safety to lives and properties should failure occur cannot be overstated enough.
d. “ADB and Government selected ENTURA consultant from Australia for feasibility studies” – That is fine too. But ENTURA also have human rights, social justice, and safeguard issues they obviously ignored and EPC again had no independent accountability checks done to ensure they complied with those important responsibilities.
It was a concern that EPC missed an opportunity for a local capacity building component in the project to enable our local contractors to learn from ENTURA in this kind of macro-level work and we hope engagement of our locals especially in engineering and construction work are being considered in the project.
e. “The technical feasibility study, dam site selection, geotechnical drilling are completed” – These are all very well and useful for EPC in its attempt to meet its project goals quickly. However we hope that the accelerated attempt to meet deadlines for GCF submission does not compromise key safety concerns. Again the missed opportunity to engage locals in the work completed was an unfortunate missed opportunity.
f. “NGOs are now invited to input into the EIA” – Whilst EIA is a useful tool to assist in development consent and project approval, in large projects such as this we find that focusing on just EIA fails to delve into equally important issues of social impacts, cultural impacts, and a full cost benefit analysis that takes a comprehensive assessment as a basis for decision on feasibility especially in large projects such as this that safety issues become paramount. I pray the local EIA experts recruited to assist ENTURA in this consultancy as well as MNRE/PUMA go beyond the EIA and engage in a more comprehensive impact assessment and analysis of both benefits and risks and be bold enough to recommend the project not proceed when the risks far outweighs the benefits.
g. “GCF has approved the proposal in principle but require a full feasibility study” – I hope the notion of feasibility study will not fail the test on integrity, and the high standard integrity needed in making recommendations that fit the assessment. Far too many feasibility studies have been subjected to questions when money become enmeshed in the focus of consultants to align with the goals rather than the goals and decisions being ultimately guided by integrity and independence of the findings.
h. “EPC, subject to GCF approval, plans to start construction in 2020 and will take 2 to 3 years to complete” – This proves the urgency of the need and the option of it not going through is not part of EPC radar. I pray all the integrity checks and balances are sincerely vetted and assessed within that timeframe. For me, this is a highly risky project in terms of safety concerns in the event of design and construction failures be they short or long term. Safety is a key consideration that must dictate a decision for the project to proceed and must not be compromised on issues of costs considerations.
The following email documents what I said in the meeting sent to the Program Manager the next day 26 July 2018 copied others.
26 July 2018
Talofa lava Fonoti/all,
Thanks for the opportunity to have myself meet with your project team this afternoon. Pity the others invited from our CSO community were not able to attend but I hope my comments will have been helpful as your team progresses in the planned activities.
Whilst we recognize the laudable value of the proposed Alaoa multi-purpose dam project in terms of its three focus on flood protection, assist in seasonal water supply service for Apia, and additional hydro-power generation, it is still incumbent on us all to address not only the benefits but more importantly the risks and challenges.
I reiterate what I said during the discussion that my comments be taken in the spirit of cooperation and collaboration to ensure the high quality of the final outcome. Given that this ADB/ENTURA partnership together with government and EPC as part of the Global Climate Fund (GCF) supporting ADB as Implementing Agency in the wider Pacific Island Countries Program for seven countries that include Samoa in their attempt to transition to Renewable Energy, it will be interesting to see how this integrates with the activities of other PICs. More importantly, I asked as how this GCF initiative takes in the activities of the Vaisigano GCF programme that was approved during the GCF Board meeting hosted by Samoa government a couple of years or so ago. The specific treatment by that program of upland forest as a key consideration in relation to root causes of flooding and collateral damage is a benefit that I saw important for this GCF initiative.
I also shared my genuine concern with issues of dams and after watching TV last night on the devastating disasters in the country of Laos caused by failed dams during construction time with much loss of life, immense destruction of properties, failed dam concrete structures, etc. I could not emphasize enough the real concerns that I have on this kind of project and pray the team take this into account at all levels of this project given that some of the team also saw the same TV program and acknowledge the real drastic dangers of failures.
I wanted to take this opportunity to try and capture the other comments I made during our discussions this afternoon.
1. I regret the Alaoa Multi-purpose Inception report was only sent this morning pending our afternoon meeting. Whilst I was therefore unable to read through it to get better understanding and alignment, I found the quick read of the report useful.
Together with the brief introduction by Fonoti Perelini, the explanations from the ENTURA consultants, the comments from social safeguard expert Mavaega Tim O’Meara, the brief interventions from the EIA expert Toesulusulu Cedric Schuster, and the sporadic interventions from the others during the discussions these helped me respond and made comments in the short meeting.
2. Whilst Tim stated that all the land targeted in the project was government land, I registered my concern about the accuracy of this statement and asked that MNRE submit a true and genuine status of land ownership that the three components of the project propose to take. I suspect that there is a substantive percentage of land under customary land ownership and it was clear that villages have been and continue to work much of the land in question under agricultural and related development.
3. I impressed during the discussion that land ‘demarcation’ using remote Lidar aerial surveys without actual boundary marks on the ground are in many cases immensely problematic for the village communities and suggested that boundary demarcation be carried out on the ground to ensure there is no question about abutting uses, land ownership and occupation. It also helps to build trust with the villages involved and ensure long terms sustainability of the project.
4. I sought assurance to ensure that ADB and indeed ENTURA comply with due diligence process on the ground at project level and this include important stakeholder engagement at all levels of the project, compliance with ADB regulations and policies that deal with re-settlement and relocation, Indigenous and Local Communities triggers, appropriate compensation payout, meaningful consultations with the communities affected, etc.
I was concerned that the technical assessment of dam site selection, geo-technical drilling investigation, etc. has completed but there has been no community consultations held. The Inception report only refer to consultations with those ENTURA intended to be recruited as part of its consultancy team.
5. The consultation with the eight or so villages affected by the project allegedly took place this morning is necessary but it should have been part of the inception activities as the project clearly states that stakeholders such as village communities should be engaged at all levels of the project. It is my understanding that the meeting with the villages this morning was well documented and will be interested in an account of what they said in the consultation. From this, we will be also interested in how EPC and government accountably respond to all the village concerns as it was reported that the issue of there being no consultation during the Inception Phase was raised by the villages. We also trust that this first village meeting this morning will continue as ESS and project activities progress.
6. I was encouraged by the Inception report stating that some 68% of the area targeted for the project have dense and predominant rainforest cover and asked that this key feature of the landscape be enhanced as TC Evans caused USD$200million collateral damage much of which was caused by lack of proper land utilization management of upland forest.
7. On the related issue of biodiversity, noting that there will be immense heavy machinery, voluminous concrete imported into the area, huge earthworks involved, etc. I asked the EIA expert to ensure projection, conservation, and enhancement of biodiversity is secured nevertheless. Enhancement of rainforest cover is a key factor to assist on this.
8. I shared a concern from the Inception report when it stated that the option of using ‘concrete gravity dams’ were eliminated due to high quantity of cement needed and therefore accept ‘FSHD’ (faced symmetrical hardfill dam’) in the light of lesser cost estimation. Again I linked this to the issue of safety, human lives, security of villages downstream, Apia town area, infrastructures, and again security not being compromised because of cost factors. I also alluded to the report stating the ‘…huge risk of dams was in relation to leakages…’ is a concern and drilling as well as water pressure packers testing may give some solution as well as information on how to address this, but any alternative will not be a high standard security or full proof.
9. One point I missed was the lack of local capacity for drilling and having to outsource to outside consultancy in Australia/NZ – this could be part of a capacity building opportunity through this project for local contractors
10. Finally I cautioned about the current status of GCF not having the high level of expected funding and already having trouble meeting many of the submissions and hope that our Ambassador Aliioaiga Feturi who sits on the GCF Board will better advice on this given the Samoa government expectation that by the end of next year the project proposal will be submitted to GCF and start by year 2020.
On 07 September 2018 I sent this follow-up email to Program Manager and EPC team:
“It is over a month since we met and I submitted my related comments below and wonder as a matter of accountability to our stakeholder consultation if there have been some response to points I raised as they are important from our side. I look forward to hearing from you on this to help us obtain a better alignment and understanding as to how your team and EPC are responding integrating our comments into both the project design and implementation. Kindly refer to my comments in my email below of 26 July 2018 for your response please.
Program Manager replied same day to say “We have discussed points that you brought up as we are working on some of them as we progress with EIA study etc. I will put together a response to send you as well as record of meeting we had with 8 villages. Maybe you should join us to work on this and other similar projects. Will keep in touch”.
I was naturally excited to receive the formal response from the Program Manager and especially anxious to read up on the record of meetings EPC had with the 8 villages. From a civil society, NGO, and community perspective, we have accountability issues on meaningful consultations with affected communities, due diligence obligations to be met by ADB and consultants, compliance issues, triggering policies in ADB projects, risks concerns and safety fears in relation to dams constructions, complementarity with other donor funded projects, actual customary lands affected and demarcation of same, maintaining of existing rainforest cover, enhancement of biodiversity in site area, concerns about compromising safety to save costs, missed opportunity for local capacity building, etc. I was anxious to check.
Unfortunately, two more follow up emails this month on 13 and 18 September have been ignored. Promised response and record of meetings with villages have not been shared. I am therefore disappointed and unable to further contribute and concerned that EPC may have used the NGOs to tick their program delivery boxes. I implore on Program Manager and EPC that it is imperative for all concerned that they be more transparent on the Alaoa Multi Purpose Project as it is indeed a risky undertaking where the safety concerns on peoples’ lives and property are fundamental.
The outreach of the impacts is far more broad than they can ever anticipate and is incumbent on all of us to ensure those impacted are better informed.