The full body of the SEA reports provides the overall strategic context for the focused project by project
assessments. The SEA should be used for systematic comparison of how the proposed projects relate to the
strategic concerns, and how the project designers have addressed and mitigated these concerns. The SEA does
not provide a comprehensive cumulative impact assessment. The ESIA of the proposed project should include a
detailed assessment of cumulative impacts and its contribution to these.
The PNPCA process specifies the consultation within the various MRC and NMC bodies, but does not
necessarily specify consultation within the countries, e.g. at national, provincial or district level. Although this
will have been done at the ESIA stage by and for the developers, some form of more independent consultation
process would be appropriate to bring forward the views of line agencies, CSOs, and NGOs. The SEA provides a
model for such consultations. It is recommended that the MRC apply such a consultation process in upcoming
PNPCA applications.
Another tool which could be used to assess the sustainability of the proposed project against international
best practice is the Sustainability Assessment Protocol, (Section II) developed by the International
Hydropower Association. This review could be carried out by a team of independent assessors with the
collaboration of the developers and the regulating agencies. It is recommended that MRC consider application
of the SAP to contribute to the PNPCA process.
It is also recommended that a due diligence review of proposed developers' past performance should be
conducted as part of PNPCA review process or that access be given to the government’s own due diligence
reports. That review would assess the developers’ performance in applying national social, economic and
environmental safeguards, and in preparing and implementing robust and effective dam safety procedures,
including downstream release early warning systems.
The proposed mainstream dams will last for over 50 years, by which time the impacts of climate change will be
evident. The PNPCA process should:
(iii) include a request for a detailed statement from the developers of how the proposed design has been
adapted to take the risks of climate change into account
(iv) provide (through the MRC CCAI) a set of trends and ranges as the basic standards for climate change
that developers must apply in their design proposals.