Hydropower in Protected Areas and World Heritage Sites
UNESCO defines World Heritage sites as cultural, natural, and mixed sites of outstanding universal value, representing exceptional heritage and treasures. UNESCO's 'no-go commitment for World Heritage Sites' provides guidance for corporate sustainability, urging international cooperation to protect these sites, including from hydropower development.
Protected under international law as humanity’s legacy, World Heritage sites require careful attention in corporate policies. The World Heritage Committee urges banks, investment funds, insurers, and other relevant entities to adopt sustainability policies that prevent financing projects harmful to these sites and to ensure that their clients adhere to the 'no-go' commitment.
IHA position on new hydropower developments
The International Hydropower Association (IHA) has reaffirmed its commitment to sustainable hydropower, pledging not to develop future projects in UNESCO World Heritage Sites, which was reiterated by the San José Declaration on Sustainable Hydropower launched in September 2021. When responsibly planned, built, and operated, hydropower provides clean energy, water services, and flood and drought protection, promoting sustainable development for affected communities. IHA members commit to the 'no-go commitment' as part of joining the membership and will not develop future projects on the protected sites.
Read the news items:
8 December 2022 - IHA reinforces World Heritage Sites no-go commitment in new UNESCO guidance
6 September 2021 - Hydropower sector makes no-go commitment on World Heritage Sites, with duty of care for Protected Areas
Frequently asked questions
How are Protected Areas and World Heritage Sites defined?
While protection of parts of their territories is primarily a concern for national governments, it is also embedded in international agreements. Examples include UNESCO’s World Heritage Convention, the Ramsar Convention on Wetlands, and the various IUCN Categories for Protected Areas. IHA’s commitment considers all legally designated Protected Areas, according to these international and national agreements.
Why did IHA make the no-go commitment on World Heritage Sites and place a duty of care requirement on Protected Areas?
The no-go commitment on World Heritage Sites and duty of care on Protected Areas ensure that future hydropower projects are compatible with and contribute to the objective of Protected Areas, while not compromising the outstanding universal value of World Heritage Sites.
Why is there not also a no-go commitment on Protected Areas?
Because of the exceptional importance of World Heritage Sites to the planet, an increasing number of industries across different sectors (mining, oil and gas, banking, insurance) have made the so-called ‘No-Go Commitment’ to avoid new investments in activities damaging these sites.
For other Protected Areas (such as Ramsar Sites and IUCN Categories I-VI), as well as candidate Protected Areas and corridors between Protected areas, the duty of care commitment applies and requires a high standard of performance and transparency to ensure these projects are compatible with the objective of the affected Protected Area. These projects must not only apply the mitigation hierarchy but also often provide additional positive benefits such as catchment management and funding.
How many hydropower projects are located in Protected Areas and World Heritage Sites?
Global studies estimate that there are currently 984 Protected Areas containing one or more large dams, amounting to 1,249 large dams with 278 that are primarily used for hydropower (Thieme et al. 2020). Of the 1,121 World Heritage Sites listed under the World Heritage Convention, 57 are cited by UNESCO as being affected by water infrastructure with 16 affected by renewable energy facilities.
In addition, there are an estimated 500 planned hydropower projects in Protected Areas. Under the IHA duty of care commitment, these projects would be required to implement high standards of performance and transparency through a systematic application of the Hydropower Sustainability Tools or certification against the Hydropower Sustainability Standard. Any project planned in a World Heritage Site is subject to the no-go commitment for IHA members.
Are there examples of sustainable hydropower projects in Protected Areas?
Many examples exist of well-planned and sustainable hydropower projects in Protected Areas. Numerous countries and states have extensive Protected Area programmes covering a large part of their surface area, for example in Canada, Costa Rica, Iceland, Sarawak (Malaysia) and Tasmania (Australia). These countries are recognised for their clean energy programmes, mainly comprised of hydropower generation, and provide good examples of how sustainable hydropower and Protected Areas can coexist.
It should also be noted that the development of a hydropower project can lead to the creation of a Protected Area. This can happen either directly through the protection of its reservoir, for example as a wetland of international importance, or indirectly through biodiversity offsets. One example can be found in Germany where the reservoirs of the Edersee multi-purpose dam and its associated two pumped storage projects led to the creation of a Protected Area. In 2004, the Kellerwald-Edersee National Park was created around the reservoirs of the Edersee and Waldeck I and II projects. The national park even became part of a World Heritage Site of European Beech forests in 2011 and was extended to the northern shore of the Edersee in 2020.
What happens to existing hydropower projects located in a Protected Area or World Heritage Site?
Existing projects already located in a Protected Area or World Heritage Site should be able to continue operating as the new IHA commitments only apply to new hydropower developments. IHA recommends all hydropower projects, whether or not they are located in a Protected Area, apply the Hydropower Sustainability Tools and seek certification through the Hydropower Sustainability Standard.
Does the no-go apply to refurbishments or upgrades to existing projects in World Heritage Site?
Refurbishments or upgrades should not be interpreted as new projects unless they cause a significant expansion of the project impacts (e.g. raising of the dam and creation of a larger reservoir, or building of an additional powerhouse which increases the variability of downstream flows). The duty of care commitment should be applied and a precautionary approach be taken so as to avoid, minimise or reduce any negative of impacts on the outstanding universal value of the World Heritage Site, ideally using the opportunity of a refurbishment programme to address other mitigation measures (e.g. upgrading of a fish pass).
What is the objective of the duty of care commitment when affecting Protected Areas?
The objective of the duty of care commitment is to avoid that new hydropower projects negatively impact the conservation values of affected Protected Areas. If impacts cannot be avoided, they will need to be minimised and mitigated to ensure that the conservation objectives of the affected Protected Area are maintained. Offsets should only be considered as a last resort and after carefully considering alternatives, including alternative locations.
What about hydropower projects planned outside but in the watershed of World Heritage sites?
These projects are covered by the duty of care commitment, which applies to all Protected Areas. However, given the fact that World Heritage sites are recognised for their unique and irreplaceable Outstanding Universal Value, the focus should be on avoiding and minimising and mitigating residual impacts to ensure the Outstanding Universal Value of the World Heritage Site is not affected. In the case of World Heritage sites, compensation or offsetting are not an option.
What is meant by high standards of performance and transparency?
Projects affecting Protected Areas will be more visible and will find it harder to achieve public and regulatory acceptance, and access to capital. These projects need to make an extra effort to overcome these barriers, by pursuing demonstrably better practices than comparable projects, and by proactively engaging and informing stakeholders such as PA managers, rightsholders, conservation NGOs, and the general public. An objective and credible confirmation of the level of performance can be provided through Standard certification or alternatively an HSAP or HESG assessment, which should also be published alongside other key documents such as ESIAs.
What types of Protected Areas are included in the duty of care commitment?
All types of Protected Areas, as well as candidate Protected Areas and corridors between Protected Areas are included in the duty of care commitment. Depending on the category of PA, compatibility with PA objectives will be easier or more difficult to achieve. For example, it will be very difficult to justify an HPP in a wilderness area (IUCN Category I) while it may be easier in a multiple-use area (IUCN Category VI) where sustainable use of natural resources is a key objective. The mitigation and compensation requirements will vary accordingly.
If a project complies with IFC or World Bank performance standards, will it still need to be assessed or certified?
The duty-of-care commitment requires projects affecting Protected Areas to implement high standards of performance and transparency through a systematic application of the Hydropower Sustainability Tools or certification against the Hydropower Sustainability Standard, regardless of their compliance status with potential bank financing.
While bank safeguard frameworks are broadly equivalent in their requirements for Protected Areas, there are two main differences:
1. Scope: Bank safeguards do not apply to projects outside Protected Areas and with impacts on Protected Areas. Loss of connectivity and flow regulation caused by HPPs outside Protected Areas is a specific issue for hydropower and should therefore be covered.
2. Transparency: Safeguards compliance assessments are not usually published whereas the Hydropower Sustainability Standard assessments are. Transparency is critical for stakeholder acceptance in these sensitive projects.
What happens if a hydropower project does not meet the Hydropower Sustainability Standard?
Typically, most gaps can be closed through corrective actions within a reasonable amount of time. Gaps that cannot be closed (e.g. if no compatibility with PA objectives can be achieved, because no sites can be identified for a biodiversity offset and no other compensation measures are available) should call for a cancellation of projects. The reputational and material risks of pursuing a project in such a setting are too high.
What is meant by respecting the declaration of new Protected Areas?
Hydropower projects should consider how they can contribute to the Protected Area system. This may be as a compensation measure; a sponsorship/CSR measure; or an initiative in the HPPs’ own interest, to protect the watershed. In some cases, the HPP may own land with conservation value that can be turned into a private PA, or the reservoir may have value for waterbirds and other species and can be declared a Protected Area. Supporting new Protected Areas can be through lobbying efforts and/or through financial and technical contributions.
