Kanjeza Gorge Hydropower Project

Assessment by Meridian Environmental Partners · ifc_ps_ep4 · version: Every planted problem is present and can be found within a single document.

Clean Hard mode With known problems

Synthetic test data — fictional geography. Never merge into a real assessment.

How did the review perform?

problems caught

problems missed

false alarms

Caught 100% of the planted problems (recall), and 100% of what we flagged was real (precision).

What the review found

critical

Environmental flow assumed by ecology but never committed by engineering

The downstream fishery depends on 12.4 but the operating rule only commits 6.0, and nothing in the documents reconciles the two.

Rule: Two chapters disagree · Where: flow_regime.md fisheries_baseline.md

critical

Downstream livelihood-dependent settlements outside the survey frame

The survey frame in resettlement/household_survey.csv contains no 'downstream' records, so receptors in that category are counted nowhere.

Rule: Someone left out of the survey · Where: household_survey.csv executive_summary.md

critical

Vertical datum mismatch between geotech and inundation modelling

Levels use 'MVD-72 (national)' while modelling uses a global geoid, combined without conversion. A 2.3 m offset between them is never applied.

Rule: Mismatched measurements · Where: flow_regime.md

critical

Critical habitat determination weakened in the summary

The technical inventory establishes a critical-habitat determination, but the summary states it is not triggered.

Rule: A finding softened in the summary · Where: species_inventory.csv executive_summary.md

major

Mitigation measures with no budget, indicator or owner

Commitments C-04, C-05, C-07 have no budget, indicator or owner, and no assurance elsewhere that the chain reaches the ESMP.

Rule: A promise with no funding or owner · Where: esmp_commitments.csv

major

Offset proposed without documented avoidance analysis

An offset or compensation measure is proposed with no record that avoidance or minimisation was considered first.

Rule: Jumped to offsetting too soon · Where: biodiversity_assessment.md

major

Reservoir methane absent from GHG accounting

A mandatory source (reservoir methane from flooded biomass) is missing from the accounting (about 41200 tCO2e/yr in the ground-truth model), while the benefit side is reported.

Rule: A required source left out · Where: ghg_and_climate_risk.md

major

Recorded grievance never reaches an impact chapter

Grievance GRV-004 is open and unaddressed, and the community that raised it is absent from the affected-population survey — so the concern reaches no chapter.

Rule: A complaint that went nowhere · Where: consultation_log.csv

major

Headline affected-person figure disagrees with microdata

The headline figure (1840) disagrees with the underlying data (4963) by 63% and is not reconciled or footnoted.

Rule: A headline number that doesn't add up · Where: executive_summary.md household_survey.csv

major

Fisheries baseline predates a landscape-altering event

The baseline (February 2023) predates Cyclone Ndileka (March 2024) but is presented as current, with no caveat.

Rule: Out-of-date baseline · Where: fisheries_baseline.md

major

Reasonably foreseeable third-party scheme excluded from cumulative scope

A reasonably foreseeable third-party scheme sharing the same receptor is absent from the cumulative-impact scope.

Rule: A nearby project ignored · Where: flow_regime.md

Coverage — every obligation, and where the gaps are

5 of 15 obligations have no evidence at all yet — a lender's reviewer asks about these first.

Status	Who owns it	What's required
no evidence yet	hydrology and sediment	Assess sediment trapping and downstream geomorphic response over the operating life, including delta and floodplain consequences. WBG EHS Guidelines, hydropower
no evidence yet	stakeholder engagement	Conduct Informed Consultation and Participation for Category A projects, documented and proportionate to risk. EP4 Principle 5
no evidence yet	terrestrial biodiversity	Apply the mitigation hierarchy: anticipate and avoid, then minimise, then compensate or offset residual impacts. PS1 para 14
no evidence yet	resettlement and livelihoods	Where Indigenous Peoples are affected, obtain Free, Prior and Informed Consent for relocation, critical cultural heritage or land use impacts. PS7 paras 12-17
no evidence yet	cultural heritage	Identify cultural heritage including graves and sacred sites, and apply chance-find procedures and consultation on removal or relocation. PS8 paras 16-17
problem found	legal and regulatory	Publicly disclose the assessment documentation for a minimum of 30 days before financial close, accurately reflecting the underlying findings. EP4 Principle 10
problem found	climate and ghg	For Category A projects, assess climate change risk including a TCFD-aligned physical and transition risk assessment, an alternatives analysis for les… EP4 Principle 2 and Annex A
problem found	aquatic ecology and fisheries	Establish a current environmental and social baseline of sufficient detail to characterise risks and impacts, informed by recent conditions. PS1 para 7
problem found	hydrology and sediment	Assess cumulative impacts of the project together with other existing, planned or reasonably defined developments on the same receptors. PS1 para 8
problem found	legal and regulatory	Establish an ESMP in which every mitigation measure has an action, a responsible party, a budget, a timeframe and a monitoring indicator. PS1 paras 24-27
problem found	stakeholder engagement	Operate a grievance mechanism and demonstrate that concerns raised are assessed and responded to. PS1 paras 35-36
problem found	dam safety and geotech	Address community health, safety and security risks, including structural safety of dams and reservoir-associated disease. PS4 paras 5, 9
problem found	resettlement and livelihoods	Identify and compensate economic displacement, including loss of livelihood or access to resources where no physical relocation occurs, and restore li… PS5 paras 5, 25-29
problem found	terrestrial biodiversity	Determine whether critical habitat is present and, where it is, meet the no-net-loss and net-gain requirements with documented justification. PS6 paras 16-19
problem found	hydrology and sediment	Where the project affects a river system, sustain environmental flows adequate to maintain downstream ecosystem function and dependent uses. PS6 para 24

⬇ Download the governance report (PDF)