ECA Watch: International NGO Campaign on Export Credit Agencies Export Credit Agencies: A Ball and Chain for People and the Environment
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Large Dams and the OECD

A Trojan Horse for Large Dams:
How export credit agencies are offering new subsidies for destructive
projects under the guise of environmental protection.
Produced for ECA Watch by: The Corner House, Environmental Defense, FERN, Friends of the Earth-Japan, the Halifax Initiative, International Rivers Network, Probe International and the World Developoment Movement
September 2005 (30 page PDF version)
  • The Birecik, Ermenek and Ilisu Projects Turkey:
  • Summary

    Under the guise of an initiative to promote sustainable energy technologies, governments are about to grant subsidised export credits for hydropower projects. This report looks at the experience over the last ten years with dams financed with official export credits. It finds that these projects have had massive social and environmental impacts, including large-scale involuntary resettlement, human rights abuses, the loss of critical habitats of endangered species, and, in some cases, greenhouse gas emissions greater than those from thermal power plants. If the governments go ahead with their plan, they will turn an environmental effort into a Trojan horse for environmental destruction.

    Introduction

    By Peter Bosshard, International Rivers Network; and Aaron Goldzimer, Environmental Defense
    Large dams are among the most socially and environmentally risky and controversial of infrastructure projects, and the export credit agencies of wealthy countries have a long history of granting public financial assistance so that their dam-building industries can build these projects in Southern countries. Official export credit agency support can be confirmed for 30 of the world's most controversial dams. The recent decision by industrialised-country governments to grant special export credit terms—amounting to new financial incentives—for hydropower projects in Southern countries threatens to result in publicly subsidised environmental destruction and impoverishment.

    In April 2005, the member governments of the Organisation for Economic Cooperation and Development (OECD)—known as the "rich man's club" of wealthy countries—decided to extend special financial incentives to renewable energy and water projects through the Arrangement on Officially Supported Export Credits. This responded to a long-standing demand from civil society organisations that export credit agencies do more to shift their portfolios from their heavy support for fossil fuel and large dam projects towards sustainable energy technologies. However, instead of shifting their portfolios away from high-impact projects like large dams, the OECD governments included hydropower in their definition of "renewable energy"—thereby allowing even more generous financial support for large dams than before.1

    While the preferential terms given to sustainable sources of energy like solar, wind, and geothermal are welcome, the extension of favourable financial terms to hydropower projects—already a long-standing and powerful industry—may be the most important impact of the new agreement on the global environment. If a realistic assessment of the recent past is any guide, more generous export credit subsidies for large dams will bring about major adverse environmental and social impacts in Southern countries.

    The impacts of large dams have been extensively documented, most comprehensively and authoritatively by the World Commission on Dams (WCD) in the year 2000.2 They can be summarised as follows:

    Social Impacts

    Large dams have displaced 40-80 million people. Millions more have been affected by the loss of land and fisheries, the disappearance of flood- recession agriculture, and water-borne diseases such as malaria that are spread by reservoirs. According to the WCD report, the failure to adequately resettle and rehabilitate people displaced by dams has led "to the impoverishment and suffering of millions".3

    Poor, marginalized rural communities, including indigenous peoples, have been particularly negatively affected by large dams. Resettlement and compensation plans have had a nearly universal record of failure, almost always failing to restore, much less improve, the livelihoods of affected populations. According to the WCD report, a "lack of equity in the distribution of benefits has called into question the value of many dams in meeting water and energy development needs when compared with the alternatives".4

    Environmental Impacts

    The WCD found that "large dams generally have a range of extensive impacts on rivers, watersheds and aquatic ecosystems" and "have led to irreversible loss of species and ecosystems". Dams have altered 60 per cent of the length of the world's large river systems and have caused a rapid loss of freshwater biodiversity. Up to 35 per cent of freshwater fish species are estimated to be extinct, endangered or vulnerable. Large dams have flooded hundreds of thousands of square kilometres of valuable ecosystems, including irreplaceable habitats for endangered species and the farmlands of the rural poor.

    The environmental impacts of large dams also include the emission of greenhouse gases. Because of their methane emissions, the climate impacts of tropical hydropower reservoirs have often exceeded those of conventional fossil fuel plants generating equivalent amounts of energy. Emissions from the Balbina reservoir in Brazil (a project financed with official export credits), for example, are estimated to be some 25-28 times higher per kilowatt hour than emissions from modern coal-fired power plants.

    Economic Impacts

    Historically, the benefits of large hydro projects have been overestimated and the costs vastly underestimated. The average of cost overruns for the 81 large dams that the WCD studied in its representative cross-check survey was 56 per cent.5 In addition to social and environmental costs that are not adequately taken into account, construction delays, cost overruns, and lower-than-projected power outputs have been the rule, rather than the exception. Furthermore, the functional lifetime of many dams is being severely impacted by sedimentation. Some large dams have silted up within a few years or decades. The huge Tarbela hydropower project in Pakistan, a dam financed with official export credits, has lost one quarter of its storage space to sedimentation. The World Bank estimates that 300-600 new large dams must be built every year simply to offset the loss of storage capacity due to the sedimentation of existing dams.

    Export credit agencies have for at least a decade claimed that they have learned lessons from the errors of the past and that their environmental guidelines adequately address the environmental and social impacts of the projects they finance. As the export credit agencies of the OECD countries look to extend even more generous financial terms to hydropower projects, this report looks at the social, environmental and economic track record of hydropower and other water projects that export credit agencies have supported during the last ten years.

    The case studies confirm that dam projects financed by export credit agencies continue to have serious detrimental social, environmental, and human rights impacts. Export credit agencies should, therefore, not allow their special export credit terms for large dams to come into effect—particularly under the guise of an environmental initiative—and should only support dams in the future under strict conditions adequate to the task, namely the recommendations of the World Commission on Dams.

    Further Reading

  • ECA-Watch, Website on export credit agencies and large dams, http://www.eca-watch.org/problems/dams/index.html
  • ECA-Watch, Race to the Bottom, Take II, September 2003, http://www.eca-watch.org/eca/race_bottom_take2.pdf
  • Hildyard Nicholas, The OECD Arrangement and New Subsidies for Dams: The Case for Strengthened Standards, The Corner House, August 2005.
  • McCully Patrick, Silenced Rivers, The Ecology and Politics of Large Dams, 2nd Edition, Zed Books 2001.
  • World Commission on Dams, Dams and Development: A New Framework for Decision-Making, Earthscan 2000, http://www.dams.org
  • Lesotho Highlands Water Project: Corruption and impoverishment

    By Lori Pottinger, International Rivers Network
    One of Africa's biggest infrastructure projects has succeeded in delivering water to South Africa but has left a trail of social ills and environmental problems in its wake. The Lesotho Highlands Water Project (LHWP), a huge inter-basin water-transfer scheme, comprises five dams, 200 kilometres of tunnels blasted through the Maluti Mountains, and a 72-megawatt hydropower plant. The project's primary purpose is to transfer water to South Africa. Two of the dams and the hydropower component have been completed at a cost of approximately $3.5 billion.

    Financing

    Financing for the project comes from the World Bank, the Development Bank of South Africa, the African Development Bank, the European Development Fund, European commercial banks, and the following export credit agencies: Germany's Hermes, the UK's Export Credit Guarantee Department, COFACE of France and SACE of Italy. In March 1993, the Norwegian Agency for Development Cooperation (NORAD) rejected an application by Kvaerner Energy for credit support, on the grounds that the contract supported a series of dams whose cumulative social and environmental effects had not been studied.

    Social Impacts

    The once remote mountain communities of the Lesotho Highlands have changed dramatically because of the project. More than 27,500 people have been affected by the first phases. Resettlement housing took years to complete. Since Lesotho has so little arable land, most of the displaced farmers did not receive "land for land" compensation, which meant they needed to be trained with new skills for alternative livelihoods—an effort that has mostly failed. The key strategy for restoring livelihoods was the Rural Development Plan (RDP), which was widely criticised; even World Bank reports called it "the sick man of the project". A June 1996 World Bank report stated: "After about eight years of implementation of RDP progress, a recent evaluation shows that, although there is some potential for this program in the Highlands, it cannot be trusted to restore incomes and sources of livelihoods as required by the treaty and Bank resettlement policy."6

    Health impacts have also been particularly severe. The dam's workforce of 20,000 moved into the Highlands, bringing AIDS to previously isolated communities. As a consequence, Lesotho has today one of the highest AIDS rates in Africa, and the Highlands have an inordinately high rate. The greatly reduced flow of water has also led to adverse health impacts for communities downstream of the dams.

    Environmental Impacts

    Many of the most important environmental and social studies were carried out too late to influence project design or to add meaningfully to the debate about project viability. Because the feasibility study for the project had declared that there were no major "environmental obstacles" to the project, the LHWP began without even an environmental impact assessment. In addition, there were no studies on problems such as erosion and sedimentation, although these issues are critical to the project's long-term viability. An instream flow requirements study (IFR), which analyzes how much water is needed in areas downstream of a dam to support life and livelihoods, was not completed before construction of the second dam had begun, greatly reducing the impact of the report.

    A number of rare and endangered species are known to have lost habitat because of the project. Diverting most of the river's flow has had substantial downstream impacts. If the entire project is built and Lesotho delivers as much water to South Africa as the original treaty requires, the IFR study reports that the rivers affected by the project could deteriorate to "something akin to waste-water drains".

    Corruption

    Widespread corruption was discovered in the LHWP in 1999, when more than twelve multinational firms and consortia were found to have bribed the chief executive officer (CEO) of the project. After the CEO himself was convicted of bribery, three major international firms were found guilty, and one (Canada's Acres International) was debarred at the World Bank. According to the Lesotho Attorney General, the court cases themselves have cost the government $4.3 million as of 2004—2 per cent of the country's annual budget for public services.

    Now that the World Bank is about to close its books on the first phase of the project, it admits it cannot guarantee that people were not made poorer as a result of the project—although this minimal requirement was an explicit commitment made by the parties to the project contract. Sadly, although the Bank considers the LHWP a project a model for future large dams in Africa, this case study clearly shows that the Bank safeguard policies are inadequate to address the challenges associated with large dams.

    San Roque Dam Project Philippines: Broken laws, broken promises

    By Hozue Hatae, Friends of the Earth-Japan
    The San Roque Multipurpose Project is one of the most controversial projects funded by Japan Bank for International Cooperation (JBIC) to date. The dam was constructed on the Agno River in the northern Philippines for four main objectives: electricity generation (345 megawatt capacity), irrigation of 87,000 hectares of land, flood control, and water quality improvements. Despite failure to comply with several JBIC policies and Philippine laws, and despite strong opposition from local communities, dam construction was completed, and the commercial operation of the power component began in May 2003.

    Financing

    The total cost of the project was $1.19 billion. JBIC and private banks provided $500 million in loans to the San Roque Power Corporation (SRPC), and JBIC alone provided $400 million in loans to the Philippine National Power Corporation (NPC). The financing for the power component has been disbursed entirely (as of January 2005), even though many outstanding environmental and social problems have not been resolved. The Philippines government also requested a JBIC loan for the irrigation component (some $160 million), which has not yet been implemented.

    Social Impacts

    Now that the dam has been built, sediment will be accumulating behind the reservoir. This will raise the level of the river bed and flood adjacent low- lying lands. This flooding will affect up to 20,000 villagers of the Ibaloi, an indigenous people who depend on the Agno River basin upstream of the dam. The sediment will eventually bury the Ibaloi's ancestral lands, including their homes, rice terraces, orchards, pasture lands, gardens and burial grounds. These impacts, acknowledged by project proponents, cannot be mitigated or avoided and will deprive the Ibaloi of their communities and their indigenous culture.

    2,545 families were also forced to give up their agricultural land to make way for the project, and more than 3,000 gold-panners lost their livelihoods. Most of these people were tenant subsistence farmers who met their basic needs from gold-panning, farming, gardening and animal husbandry. These tenant farmers were relocated after the NPC bought the land from the owners. The tenants were made to sign forms in English indicating their agreement to be relocated, even though most of them did not understand English. They were entitled only to cash compensation for their houses, land improvements, and crops and were given no alternative means to restore their livelihoods. As a result, the standard of living of those resettled has deteriorated. Six years after they were moved, many are struggling to survive in resettlement sites and lack sufficient sources of income. Some cannot afford to pay their electricity and water bills and have had to move away again.

    The Indigenous Peoples' Rights Act of the Philippines requires the free, prior and informed consent of indigenous peoples for projects that impact their ancestral lands. When the affected Ibaloi communities learned of the San Roque Dam project, they immediately raised their concerns with the government about the adverse impacts of this project. In spite of their efforts to defend their rights and appeal to the Philippine government, to JBIC, and to the power companies, through consultations, legal appeals, and petition letters, the project was still pushed through.

    Economic Impacts

    The Power Purchase Agreement between the SRPC and the Philippine government's NPC heavily favours SRPC. The cost of the power is greatly inflated, and the NPC has agreed to pay $10 million a month to the SRPC regardless of whether there is sufficient water available to generate power or not.7 Furthermore, now the Philippine government is responsible for paying back $400 million in loans to JBIC, increasing the debt burden of an already heavily indebted country.

    Further Reading

  • Development Disasters: Japanese-Funded Dam Projects in Asia—a report about JBIC and large dams in Asia, published by RWESA, FoE-Japan and IRN in March 2003, http://www.irn.org/programs/seasia/030309.irnjbic.pdf
  • Three Gorges Dam China: Pervasive abuse of human rights

    By Fraser Reilly-King, Halifax Initiative; Kevin Yuk-shing Li, International Rivers Network; and Pat Adams, Probe International
    In 1993, work began on the world's largest and most controversial hydroelectric facility, the Three Gorges Dam in China. When completed in 2009, the dam will provide up to 22,400 megawatts of electricity,8 and its reservoir will stretch 600 kilometres upstream. The reservoir is submerging over 20,000 hectares of farmland, two cities, eleven county seats, 119 small towns, 6,300 villages, and 1300 archaeological sites and will displace over 1.2 million people.9 For those directly affected, the combination of resettlement failures, inadequate compensation, flagrant corruption, and the collapse of the resource base that many depend on for their livelihoods is condemning them to a lower standard of living. Furthermore, in confidential official documents, Chinese officials reveal that the flood control benefits (one of the main justifications for the project) were vastly exaggerated.10

    Financing

    Export credit agencies from eight countries, as well as 26 private banks and the Chinese government, helped finance the dam. Canada's export credit agency, then called the Export Development Corporation (EDC), was the first to sign an export credit agreement for the dam, in 1995. Since then, export credit agencies have provided more than $1.4 billion in financing, or 6-8 per cent of the total budget. Loans, guarantees and insurance came from Canada's EDC, France's COFACE, Norway's GIEK, Germany's KfW and Hermes, Switzerland's ERG, Sweden's SEK, Spain's CESCE and Brazil's BNDES.11 Both the World Bank and the United States' Export-Import Bank did not provide any support for the project, largely because of environmental, economic, and/or transparency concerns.12

    Social and Agricultural Impacts

    Agriculture is the main economic activity in the affected region, and arable land is already extremely scarce. The loss of the valley's most fertile agricultural land and the further aggravation of soil erosion downstream from the dam is beginning to undermine local food security, especially since the land used for resettlement has proven to be insufficient and of poor quality. This will be compounded by the fact that silt from the Yangtze, which would normally provide important nutrients and ensure the future fertility of farmland, will largely be impounded by the dam. Meanwhile, hundreds of factories have been submerged by the reservoir, adding to the ranks of the unemployed in the region. The reservoir has also wiped out aquaculture facilities, as well as irrigation ponds and rice fields that had been used for raising fish, reducing fish production in the region by thousands of tonnes a year.

    Forced displacement and inadequate resettlement and compensation are producing some of the most severe impacts. A 2003 report published by the International Rivers Network found that:

  • Land and jobs that had been promised to displaced communities were either no longer available or of inferior quality, leaving many individuals landless, homeless and jobless.
  • Many of the resettlement villages consist of shoddily constructed buildings lacking sufficient infrastructure for water and power.
  • Compensation fell far short of the amount needed to restore livelihoods.
  • No independent grievance mechanism exists, and protests about resettlement problems have been quelled with repressive police tactics that have included violence and other serious human rights abuses.13
  • Corruption

    Corruption has exacerbated many of these dynamics. Millions of dollars have been siphoned off from resettlement funds by local bureaucrats, who have been charged with using stolen money in real estate schemes, leisure hotel construction, and stock market speculation. In 2005, the Xinhua news service reported that hundreds of cases of corruption, involving tens of millions of dollars, had been uncovered to date.

    Cultural Heritage Impacts

    The project will not only upend livelihoods but will also destroy vast treasures of China's cultural heritage. Over 1300 archaeological and cultural sites are being submerged, including temples and ruins dating from the ancient Daxi culture and tombs from the Warring States period and the Eastern Han, Ming and Qing dynasties. Officials in charge of salvaging important relics admit that, because of the tight schedule, 90 per cent will be lost.

    Environmental and Seismic Impacts

    The environmental impacts predicted by various assessments over the past decade are beginning to be felt:
    Unprecedented changes in river hydrology have impeded fish and river mammal migration, threatening the endangered Baiji Yangtze River dolphin and the Chinese sturgeon with extinction.

    Sediments trapped by the dam are failing to reach lowland floodplains downstream, thereby starving wetland areas of nutrients and possibly changing migratory bird habitats.

    Heavy metals from submerged coal and phosphorus mines, as well as mercury from impounded sediments, are leaching into the reservoir. The release of these elements, in addition to the chemical pesticides and fertilisers in the reservoir bottom, is creating a severely toxic reservoir environment.

    Landslides and seismic activity are likely to increase in the reservoir zone since the dam has been built in a geologically unstable region prone to earthquakes and landslides. Prominent scientists have warned that the impounding of such a large body of water is likely to trigger geological incidents, putting lives at risk. The construction of new settlements for people displaced by the dam has already triggered landslides and riverbank collapses.

    Further Reading

  • Three Gorges Probe, http://www.threegorgesprobe.org
  • International Rivers Network, Human Rights Dammed Off in China, January 2003, http://www.irn.org/programs/threeg/pdf/3gcolor.pdf
  • Nam Theun 2 Hydropower Project Laos: Ignoring alternatives, threatening livelihoods

    By Aviva Imhof, International Rivers Network
    The Nam Theun 2 Hydropower Project, in Laos, was given the green light earlier this year when the World Bank, Asian Development Bank, four export credit agencies and a host of private banks agreed to support the $1.3 billion project. The 48-meter high dam will be located on the Theun River, a major tributary of the Mekong. Water will be stored in a reservoir on the Nakai Plateau and diverted to a powerhouse, before being released into another Mekong tributary, the Xe Bang Fai River.

    Export Credit Financing

    The project is being supported by four export credit agencies, namely COFACE (France), EKN (Sweden), GIEK (Norway) and Thai Exim Bank. Together, they are providing $230 million in loans to the Nam Theun 2 Power Company, which is a consortium composed of Electricit"é" de France, two Thai companies and the Lao government. The project is supposed to generate foreign exchange for Laos by selling power to Thailand; this revenue is then intended to be used for poverty alleviation in Laos.

    Social Impacts

    Approximately one in 50 Laotians will be negatively affected by the Nam Theun 2 Dam; and as with many other hydropower projects in Laos, it is the poorest people, often subsistence farmers, who will lose their livelihoods as a result of the dam. Nam Theun 2 will displace 6,200 indigenous people living on the Nakai Plateau, and it will affect more than 100,000 people living in downstream communities along the Xe Bang Fai and Nam Theun rivers. The project will jeopardise food security for these people, who depend on freshwater fish for up to 80 per cent of their protein. It will also affect their ability to grow vegetables along the riverbanks during the dry season, deprive them of fresh drinking water and impair river transportation.

    Experience from other hydropower projects in Laos and elsewhere shows that replacing subsistence livelihoods is extremely difficult. Independent reviews of the plans for compensating villagers affected by Nam Theun 2 reveal that these plans are overly ambitious and have a high likelihood of failure.14 Meanwhile, there are no guarantees that the revenue accruing to the government from Nam Theun 2 will be used for poverty alleviation. The negative track record of other dam projects in Laos, such as Nam Leuk and Theun Hinboun, and the government's failure to transparently manage its revenues are strong indications that the poverty exacerbated by Nam Theun 2 will be far greater than any poverty alleviated by it.

    Environmental Impacts

    In addition to the social impacts, the reservoir on the Nakai Plateau will submerge an area of rich biological diversity that sustains one of the last remaining herds of wild elephants in Laos. Several other endangered and endemic species, such as the white winged duck, will have their habitat and/or migration routes flooded by the dam. The release of cold water from the bottom of the reservoir will also impact aquatic ecosystems downstream, which will likely lead to massive fish die-offs.

    Nam Theun 2 may also result in substantially higher greenhouse gas emissions than combined-cycle natural gas plants generating the same amount of electricity. The characteristics of Nam Theun 2—a tropical reservoir with a large drawdown zone—are similar to those of Brazilian reservoirs where high methane emissions have been measured. Extrapolations from the average net emissions per square-kilometer flooded calculated for four reservoirs in the Brazilian Amazon indicate that Nam Theun 2 could emit the equivalent of nearly 5 million tons of carbon dioxide every year. By comparison, a natural gas combined-cycle plant generating the same amount of electricity as Nam Theun 2 would emit the equivalent of around 2.53 million tons of carbon dioxide. In other words, Nam Theun 2 could have twice the greenhouse gas emissions and climate impacts of fossil fuel alternatives.15

    World Bank standards a failure

    Despite repeated calls from project critics for an assessment of Nam Theun 2's compliance with World Commission on Dams guidelines, the World Bank and other donors refused to conduct such an analysis. Instead, the World Bank said that it would rely on its own safeguard policies to determine whether to support the project or not. The four export credit agencies involved in the project primarily relied on the World Bank's appraisal to determine their own positions on the project. In doing so, the export credit agencies abdicated their environmental and social due diligence responsibilities.

    If a true, open and transparent options assessment process had taken place—as included in the WCD recommendations—it is likely that Nam Theun 2 would not have been considered the best option either for meeting Thailand's energy needs or for alleviating poverty in Laos. The World Bank claims that Nam Theun 2 will benefit Thai consumers, who will be forced to purchase over 90 per cent of the electricity from the dam for the next 25 years. But the economic analyses for the project, which were released just a week before the World Bank Board meeting, contain several startling errors and unjustified assumptions that make Nam Theun 2 appear in a favourable light compared to other alternatives.16 In addition, a World Bank report found that renewable sources of power and efficiency improvements could generate the same amount of electricity for the Thai market as the Nam Theun 2 Project, but at a 25 per cent lower cost.17

    Furthermore, without a series of legally binding mitigation and compensation agreements with affected people—another of the WCD recommendations—the rights of affected communities will be difficult to protect. There is no independent legal forum in which to seek redress if promises are not met. This is of particular concern for Nam Theun 2, because Laos lacks an independent judicial system, meaning that affected communities will have nowhere to turn when promises are broken. Indeed, the lack of an independent media and freedom of expression in Laos has prohibited open scrutiny of the project from the beginning—communities are unable to access information and freely express opinions and concerns about the project. Finally, the absence of adequate baseline data, particularly for the hydrological analysis, calls into question the technical and economic viability of the project. An independent review of the hydrological data for the project found that the power company's analysis is so deficient that it is impossible to predict how much water will be available for power generation.

    Nam Theun 2 is the most recent large dam approved by the World Bank. Taken with the evidence concerning social and environmental impacts presented above, it is clear that the World Bank's safeguard policies are inadequate for assessing hydropower projects.

    Further Reading

  • http://www.irn.org/programs/mekong/namtheun.html
  • The Birecik, Ermenek and Ilisu Projects Turkey: No lessons learnt

    By Judith Neyer, FERN, and Nicholas Hildyard, The Corner House
    Birecik and, if it is built, Ilisu, are both part of Turkey's $32 billion South Eastern Anatolia Project (known as GAP after its Turkish name, Guneydogu Anadolu Projesi). Consisting of a planned network of 22 dams, 19 power plants and ancillary irrigation and industrial projects, GAP is intended to use the waters of the Tigris and Euphrates Rivers to transform the Southeast of Turkey into a regional "breadbasket".

    GAP had been largely financed by the Government of Turkey, with $3.79 billion coming from foreign sources. Turkey's economic problems during the 1990s, however, led to an increasing reliance on external financing, including export credits from Germany, Switzerland, Italy, Austria and the USA. In addition to Birecik, dams funded through such export credits have included Ataturk, Karakaya and Karkamis. Export credit agency support is currently also being sought again for Ilisu, the project having been temporarily shelved in 2002, and for the Munzur and Hakari dams. The World Bank has declined to support GAP projects.

    Other dams are also planned outside of the GAP project, including the Ermenek dam. Ermenek is currently under construction. Financing was arranged after the Common Approaches (the OECD agreement on common environmental guidelines for export credit agencies) had come into effect for the export credit agencies involved, demonstrating the woeful inadequacy of the Common Approaches for managing the challenges of large dams.