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GREATER MEKONG SUBREGION CORE ENVIRONMENT PROGRAM POLICY BRIEF: STRATEGIC ENVIRONMENTAL ASSESSMENT OF POWER DEVELOPMENT PLANS IN VIET NAM

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Greater MekonG SubreGion Core environMent ProGraM

policy brief: strategic environmental

assessment of power development

plans in viet nam

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POLICY BRIEF: STRATEGIC ENVIRONMENTAL

ASSESSMENT OF POWER DEVELOPMENT

PLANS IN VIET NAM

GREATER MEKONGSUBREGIONCORE ENVIRONMENTPROGRAM

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DisclaimerThe analyses and assessments contained in this reportare those of the authors and do not necessarily reflectthe views and policies of the Asian Development Bank(ADB) or its Board of Governors or the governmentsthey represent.

The ADB does not guarantee the accuracy of the dataincluded in this publication and accepts no responsibilityfor any consequences of their use.

Use of the term “country” does not imply any judgmentby the authors or the ADB as to the legal or other statusof any territorial entity.

Boundaries of all maps contained in this report should notbe considered authoritative. All information contained inthe maps have a high degree of generalization owing tothe small scale of data sets used for map compilation.

Authors and AcknowledgementsJohn Soussan, Sumit Pokhrel and Lothar Linde

Coordination and editing: Hasan Moinuddin andSarah Katz

The authors and ADB would like to thank developmentpartners, governments of Sweden, Finland,the Netherlands and the PR China’s Poverty ReductionFund for their generous contributions to the program.

Cover photo: Stephen Griffiths

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CEP-BCI Core Environment Program and Biodiversity ConservationCorridors Initiative

DSM Demand side management

EVN Electricity of Vietnam

IE Institute of Energy

MoIT Ministry of Industry and Trade

PDP Power Development Plan

PES payment for environmental services

PM particulate matter

SEA Strategic Environmental Assessment

SEDP Socio-Economic Development Plan

VEEP Viet Nam Energy Efficiency Program

ABBREVIATIONS

POLICY BRIEF STRATEGIC ENVIRONMENTAL ASSESSMENT OF POWER DEVELOPMENT PLANS IN VIET NAM

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004 POLICY BRIEF STRATEGIC ENVIRONMENTAL ASSESSMENT OF POWER DEVELOPMENT PLANS IN VIET NAM

Strategic Environmental Assessment ofPower Development Plans in Viet Nam

Under CEP-BCI Phase I, assistance wasprovided to Viet Nam in conducting aStrategic Environmental Assessment (SEA)of both Power Development Plans (PDP)VI and VII. The PDP is the national-levelstrategic development plan for powerproduction and utilization in Viet Nam. ThePDP VII provides a long-term strategicframework to guide the development ofthe power sector for the period 2011-2030.It analyzes likely future electricity demandscenarios by sector, taking into accountlikely future economic and socialdevelopment trends. It also assesses the

most effective, least costly (taking intoaccount full economic costs) methods formeeting this likely future demand.

The focus of the SEA of PDP VII was onoptimizing the potential contribution ofpower generation to national developmentthrough a strategic planning approach thatbalances economic development, socialequity and environmental sustainability.This, in turn, reflects the goals of the2006-2010 SEDP and the Viet Nam 2020Vision, which underline the nationaldevelopment aspirations of Viet Nam.These principles have been carriedthrough to the 2011-2015 SEDP, whichincorporates new regulations and decrees

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005POLICY BRIEF STRATEGIC ENVIRONMENTAL ASSESSMENT OF POWER DEVELOPMENT PLANS IN VIET NAM

on different aspects of sustainabledevelopment and environmentalprotection. These include: measures toensure reasonable, effective andsustainable use of natural resources inwatershed areas, the expansion of forestcoverage and the integration of climatechange into strategic planning and naturalresource management.

The central goal of PDP VII, to meet futuredemand through the most effective andresponsible strategy for the expansion ofgeneration capacity, is valid and essential.Meeting this goal require a series of trade-offs between the costs and benefitsassociated with different types of power

generation, each of which has a differentset of social, environmental and economiccosts (and benefits). The same is true forthe expansion of the power transmissionsystem, which is essential for distributingthe power generated to the right places.These contrasting sets of costs andbenefits have been examined in thisSEA, and clear conclusions andrecommendations have been identifiedon what is the most effective strategy forthe future development of the powersector in Viet Nam.

The calculation of power demand is basedon existing power consumption data foreach sector, combined with assumptions

Photo: Stephen Griffiths

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Figure 1.Power demand forecastfigures for the period upto 2030

800,000

700,000

600,000

500,000

400,000

300,000

100,000

100,000

02009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029

Low caseBase caseHigh case

on the speed and character of socio-economic development during the planperiod and on savings from energyefficiency improvements. Three growthscenarios have been used to estimatefuture patterns of demand: i) a highgrowth scenario in which economicdevelopment remains above 9 percent forthe period up to 2030; ii) a base scenarioin which growth is around 8 percent forthe period; and iii) a low growth scenariowhere economic growth is between7 percent and 7.66 percent for the planperiod. This analysis has led to thepower demand forecast figurespresented in Figure 1.

Comparing and Balancing Impacts: TheSEA has analyzed the potential social andenvironmental impacts of the package ofgeneration development optionscontained in the PDP VII base case. Themain conclusions of this analysis arepresented here. The impact of the plannedexpansion of the transmission lines inPDP VII are also discussed.

Thermal power constitutes the largestcomponent of the power generationsector in Viet Nam; it is also the source ofthe largest social and environmentalimpacts. The most significant impacts arethe atmospheric pollution resulting from

the combustion of fossil fuels, particularlycoal. Under the plans outlined in PDP VII,CO2, particulate matter (PM) and SO2

releases will increase more than seven-fold during the PDP VII period up to 2030,and those for NOx will increase three-fold.The impacts of these atmosphericpollutants will be severe and widespread.These impacts, it is estimated, will costViet Nam nearly US$9.0 billion per annumby 2030 unless actions are taken toreduce the levels of atmospheric pollutantreleases, particularly from coal-firedpower generation.

Hydropower is the second largest sourceof power generation in Viet Nam. It has thepotential to produce a number of adversesocial and environmental impacts. Theseinclude the loss of land, the disruption ofsensitive ecosystems, the displacement ofpeople and effects on the culture andlivelihoods of communities not physicallydisplaced, disruption to hydrologicalsystems and ecosystems that depend onthem and other effects. With hydropower,most of the social and environmentalimpacts are associated with thedevelopment of the scheme. The widereffects on people and the environment area mixture of both positive and negativeimpacts, with potential improvements todry season water flows having positive

Year 2011 2015 2020 2025 2030

PM 98.86 134.95 289.57 439.40 710.24

SO2 93.77 148.09 311.85 448.18 728.74

NOx 234.15 274.48 386.09 494.30 638.86

CO2 1,215.50 2,190.50 4,118.70 6,075.90 9,071.90

Table 1.Total environmental costsfor each pollutant (Unit:million US$)

POLICY BRIEF STRATEGIC ENVIRONMENTAL ASSESSMENT OF POWER DEVELOPMENT PLANS IN VIET NAM

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Figure 3.Construction of ahydropower dam inViet Nam, 2007(Photo: Jiao Xi)

Figure 2.Thermal power stationclusters in north andsouth Viet Nam

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benefits over whole river basins, whileseveral river ecosystems becomevulnerable to degradation in theimmediate vicinity of hydropower schemes.The impacts of hydropower developmentare complex and widespread, but manycan be minimized depending on how theschemes are planned and developed. Themore effective and sustainable approachesto hydropower have the potential toproduce the benefits such schemesgenerate without many of thenegative impacts.

Reservoir Area: This includes the landareas lost in the different categories andthe assessment of the impacts ondisplaced people. The total area that willbe submerged in the 21 schemes is 25,133ha, including 4,227 ha of natural forest,1,367 ha of plantations, 5,961 ha ofagricultural land, 737 ha of residential landand 12,810 ha of grasslands, bare land andother non-productive land use categories.It is estimated that the value of the cropsfrom the lost farmland would be aroundUS$2.9 million annually, whilst the totalresource value of the forest area lost(including environmental service functions)is estimated at US$72.4 million.

A total of 61,571 people will be displaced ifall 21 schemes are constructed, but the

number varies from scheme to scheme.Seven of the 21 schemes would requirelittle or no resettlement and a further threehave 650 or fewer people, whilst Bac Mewould result in the displacement of 10,700people and 14,800 at Ban Chat. The fourschemes, with more than 7,000 displacedpeople (Ban Chat, Bac Me, Huoi Quangand Lai Chau), would result in over 41,000displaced people, or two-thirds of the total.These schemes require special attentionwith regards to the issue of resettlement.Over 90 percent of the displaced peopleare ethnic minorities with a poverty ratemore than double the national average.These people are highly dependent onaccess to natural resources (includingforests) for their livelihoods and a closeconnection to where they live is anintegral part of their cultural identity.

Payment for environmental services(PES): A new national decree will apply acharge of 20 VND/kWh to act as paymentfor environmental services in the watershedof hydropower schemes in relation to soilconservation and water regulation. Thesecharges reflect environmental services thathave, to date, been treated as externalities.This will not be the case in the future andsuch charges, which will provide incentivesfor upstream resource owners to managetheir lands sustainably, need to be

Figure 4.Examples of Zones ofInfluence (ZOI) aroundhydropower schemes: left,Dong Nai 2; right, DongNai 2 and surroundingland use

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reflected in the assessment of the costsand benefits of hydropower development.The charge levels have been applied tothe planned generation levels fromhydropower for each year of the PDP VIIperiod (2011 to 2030). The levels of PESincome generated are significant: startingat US$41,182,000 in 2011 and risingrapidly over the next decade (during whichthere will be significant expansion ofhydropower generating capacity) to reachUS$71,152,000 by 2021 and stabilizingthereafter to be US$71,535,000 in 2030.

Nuclear Power will be a new developmentfor Viet Nam. It is a source of powergeneration that is characterized by risksthat are low probability but extremely highin impact if they do occur: reflecting theextreme hazards associated with the useand management of radiological materials.It is essential that Viet Nam develops thecapabilities and management systems tohandle radiological materials beforenuclear power development starts. There

are additional predictable impacts that area cause for concern, especially associatedwith the use and release of the very highlevels of cooling waters that nuclear powerstations require. The site selection of thepower station is the key issue here: anylocations in the proximity of sensitive orhigh value ecological areas must beavoided and the possible impacts ofcooling water on riverine and marineecosystems must be carefully assessed.

Improved Energy Efficiency: EVN’sDemand Side Management (DSM)Assessment Study shows that a savingspotential of around 36 percent could beachieved in the residential sector and morethan 20 percent and 12 percent could beattained in the industrial and commercialsectors. The World Bank’s CommercialEnergy Efficiency Program (CEEP), whichinvolves pilot projects in commercial andindustrial sectors, shows project savingsof 15-30 percent. Although challenging, itis possible to significantly improve energy

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Photo: John S

oussan

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Table 2.Energy Efficiency:Reductions in Demandfor Coal 2011-2030

Table 3.Reduction of PollutantEmissions Comparedto Base Case (Unit: ton,CO2: 1,000 tons)

Table 4.Reduction of HealthCosts (Unit: million US$)

Year 2011 2015 2020 2025 2030

Coal (106 tons) 10.90 28.2 57.9 89.6 135.1

Domestic 10.60 26.2 39.8 53.2 69.5

Imported 0.34 2.0 18.1 36.4 65.6

Coal reduction (106 tons) 0.60 3.8 19.2 26.9 56.3

Year 2011 2015 2020 2025 2030

PM -45.05 9.72 73.19 101.65 203.47

SO2 13.19 17.21 65.59 96.41 215.45

NOx 31.55 36.14 66.38 93.97 133.09

CO2 644.4 791.7 1,578.7 2,195.8 3,348.1

efficiency in Viet Nam. This studyconsidered achieving the 5-8 percentelectricity savings target set under theViet Nam Energy Efficiency Program (VEEP)for the period 2010-2015 and graduallyincreasing this savings target to 20 percentof the total electricity demand during theperiod 2015-2030. These targets wouldbring down the country’s electricityelasticity (ratio of growth rate of electricitydemand and growth rate of GDPdemand) from a high of 1.90 in 2010 to0.85 in 2030, which is consistent withthose of many efficient developing anddeveloped countries.

A scenario was analyzed in which the plansin PDP VII base case were adjusted toincrease energy efficiency according to thenational strategy. This scenario includes 46coal power plants with a total capacity of53,560 MW, including 28 plants in the north(four plants less than the base scenario),nine plants in central Viet Nam (three plantsless) and nine plants in the south (nineplants less), as well as a balance of otherthermal, hydropower, nuclear and othergeneration sources to meet the projecteddemand. Under this scenario, electricitygeneration savings increase from 1639GWh in 2015 to more than 22000 GWh by

2030. The reduction of the electricitydemand would, potentially, greatly reducedependency on coal-fired powergeneration: 16 coal-fired power plantsthroughout the country that were to becommissioned between 2027-2030, asidentified in the baseline scenario, wouldno longer be needed during this period.

The results show the potential of asustained effort to increase energyefficiency as a key element in any effort toreduce the negative impacts of coal-firedpower generation. The energy savingswould save over 56 million tons of coal ayear by 2030. This in turn will reduce CO2

emissions by over 100 million tons a year,SO2 emissions by over 72 million tons, NOx

emissions by over 42 million tons and PMemissions by nearly 10 million tons. Thesereduced emissions would have hugebenefits in terms of reduced climatechange, acidification impacts and greatlyreduced risks to human health from thepower generation sector. The economicvalue of these reduced social andenvironmental impacts is calculated to beover US$3.3 billion, a figure that would bemuch higher than any likely costs of theenergy efficiency measures andinvestments implemented.

Year 2011 2015 2020 2025 2030

PM 312.91 995.04 3,552.45 4,933.26 9,873.90

SO2 4,538.23 5,837.31 22,184.68 32,609.93 72,868.86

NOx 12,140.97 113,65.97 20,593.53 29,154.38 41,291.30

CO2 6,921.10 115,08.16 39,806.59 49,275.07 104,685.02

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Achieving these high levels of energyefficiency improvements requiressuccessful implementation, enforcementand large-scale replication of the measuresidentified in the Viet Nam Energy EfficiencyProgram (VEEP). This includes: i) legislativeframeworks on energy efficiency andconservation in all sectors of the economyare formulated and effectively enforced;ii) education and information disseminationsystems established, and projects in theresidential sector implemented; iii) energyefficiency standards and labeling systemsintroduced and assistance extended todomestic appliance manufacturers;iv) energy efficiency and conservationmanagement models developed, withsupport provided to industrial enterprises;and v) capacities strengthened in relationto energy efficiency and conservationin building design and management,as well as successful demonstration ofprojects related to building energyefficiency improvement.

One of the critical factors, in addition tothe regulatory and management measures,is the financing of energy efficiencyactivities and projects. An energy efficiencyfund could be established to supportactivities and leverage private sectorinvestments. Similarly, the market forenergy efficiency services and theestablishment of energy efficiency servicecompanies should be stimulated andsupported by the government.

Increased Renewable Energy in PowerGeneration: The second major element ofany strategy to reduce the levels of coal-fired power generation needed in thefuture is to generate the electricity fromother sources. Under the existing basecase of PDP VII, large-scale hydropowerwill be close to maximized in terms offeasible hydropower construction sites,nuclear power will be developed at a ratethat is feasible for Viet Nam, both oil andgas will be at levels that are as high as islikely to be economically and technicallyfeasible. This leaves further rapidexpansion of power generation fromrenewable energy sources as theoutstanding option for reducing coalconsumption and impacts throughsubstituting alternative powergeneration sources.

Under the baseline scenario, the share ofrenewable energies increases from 3.6percent in 2015 to 5.8 percent in 2025,but declines to 4.4 percent in 2030 due tothe rapid growth of coal-fired powergeneration. In absolute terms, renewableenergies’ capacity improves from 1679MW in 2015 to 6029 MW in 2030.Although significant, these figures can beregarded as conservative and are farbelow the levels of renewable energydevelopment that would be possible giventhe potential resource base of these energysources, particularly wind, solar power andmini-hydro. Consequently, the scope for amore vigorous development of renewableenergy as a means of replacing coal-firedpower generation has been examined.

The analysis examined an increasedproportion of renewable energy from 4.1percent in the base case to 8-10 percentbased on the PDP VII base case, whichwould mean a capacity expansion of anadditional 7800 MW by 2030 whencompared to the base case. The target isto attain a 5 percent share in 2015, 8percent in 2020 and reach close to 10percent in 2030. This entails raising thecapacity from 1979 MW in 2015 to 13829MW in 2030, more than double the levelpresently found in the PDP VII base casescenario. At present, grid-connectedrenewable energies are mainly from smallhydropower systems, which are projectedto increase from 461 MW in 2011 to 3,129MW in 2030. Wind power generation willincrease from the current minimal level to2900 MW by 2030. For this renewableenergy scenario, an additional 4800 MWof small hydropower systems and 3000MW of wind power plants are to beinstalled. This expansion would result inthe reductions in the use of coal for powergeneration and a reduction inatmospheric pollution.

These reduced emissions would in turnproduce a significant reduction inenvironmental costs compared to the basescenario of over US$1.7 billion by the year2030, reflecting the significant reductionsin environmental and human healthimpacts from the power generation sector.These savings would be permanent,sustained and would far outweigh any

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likely increase in the direct financial cost ofpower generation associated with the useof renewable energy in present conditions.In any case, it is likely that the relativeeconomics of renewable energy, whencompared to conventional powergeneration sources, will change in thecoming decades with technologicaldevelopments and economies of scale asthe amounts of renewable energy usedaround the world continues to expand.

Transmission Line investments in PDPVII will represent a major, but necessary,expansion of the transmission system.There will be adverse impacts, especiallyassociated with the clearance of landalong the routes of the transmission lines.The economic value of the forests lost isestimated at US$218 million. The lineroutes will pass through a total of 59protected areas and 39 key biodiversityareas. This has potentially negativeecological impacts due to thefragmentation of habitats, with severalareas likely to be divided into fragmentsthat could potentially compromise theintegrity of high value biodiversity areas.

General Recommendations

On SEAs: SEAs are a relatively newprocess in Viet Nam. Experience is growingbut their effective integration into strategicplanning is still limited. The use of SEAs asan integral part of the preparation of PDPVII has demonstrated the utility of thisapproach, providing a means throughwhich possible issues can be identifiedand alternative approaches are exploredbefore the plan is finalized. The integrationof the SEA process also provides a meansthrough which key stakeholders can beconsulted during the plan preparation.Executing an SEA requires capabilities thatare often beyond those found in manyplanning agencies, including the Institute ofEnergy (IE). It is recommended that furthercapacity development takes place in IE,as well as the MoIT and other agenciesassociated with them in planning, tostrengthen their capability to executean SEA independently with noexternal support.

It is further recommended that additionalefforts are made to ensure the necessarydata are available for undertaking SEAs.In this SEA, there were a number of data

Table 5.Reductions in Demandfor Coal with ExpandedRenewable Energy

Year 2011 2015 2020 2025 2030

Coal (106 tons) 11.20 31.9 75.8 111.9 177.5

Domestic 10.80 29.9 46.2 61.9 64.8

Imported 0.38 2.0 29.7 50.0 112.7

Coal reduction (106 tons) 0.00 0.1 1.2 4.6 10.6

Table 6.Reductions ofAtmospheric Pollutionfrom ExpandedRenewable Energy (Unit:ton, CO2: 1,000 tons)

Table 7.Reduction of Health Costsdue to Reduced Emissions(Unit: million US$)

Year 2011 2015 2020 2025 2030

PM -57.42 -15.65 4.59 17.48 40.00

SO2 0.87 2.34 2.76 14.37 40.12

NOx 31.33 35.43 32.77 43.71 46.98

CO2 638.50 694.20 938.80 1,472.50 1,739.90

Year 2011 2015 2020 2025 2030

PM -7.03 35.23 223.81 849.02 1,941.73

SO2 377.61 818.72 940.08 4,865.65 13,575.04

NOx 12,356.55 11,253.20 10,166.70 13,561.26 14,575.81

CO2 7,440.86 6,635.29 7,056.78 14,736.98 26,264.91

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limitations, most notably on aspects of thecalculation and valuation of the impactsof the different supply option proposals,the implications of climate change for thesector’s development and the verifiablepotential of renewable energydevelopment options. Steps need to betaken to systematically assess andaddress these data gaps so that futureSEAs can provide more rigorous analyses.

The current SEA Guidelines, as reflectedin Circular No. 05/2008/TT-BTNMT, dated8 December 2008, provide a strongnational framework for the execution ofSEAs. However, it has been found that thestructure of the SEA report, as set out inAnnex 1 of this Circular, is not the mostconvenient or effective one for producingan efficient SEA report. It is recommendedthat this required report structure shouldbe reviewed, drawing on internationalexperience and good practice inSEA preparation.

A key step in the full integration of socialand environmental issues into the PDP VIIis the internalization of all economiccosts into the calculation of the leastcostly alternatives for power generation.Important steps towards this have beentaken in this SEA but the full internalizationinto the base case scenario calculationshas not yet been possible. This should bedeveloped for future PDPs so that a morerigorous and transparent means tocompare the full implications of thedifferent power generation options isavailable within the core structure ofthe PDP.

The most important recommendations inthis SEA relate to the reduction of futuredependency on coal as a principle meansto generate electricity. The greatestimpacts come from coal-fired powergeneration, with impacts that will costseveral billion dollars per year by 2030. Astrategy that combines improved energy

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efficiency and accelerated renewableenergy development would go far inreducing these impacts and it isrecommended that such a strategy iselaborated on. This would include furtherassessments of the potential scale andthe best sites for renewable energydevelopment, as well as the meansthrough which greater energy efficiencycan be achieved.

The assessment of approaches to improvemanagement and operational efficiencyin the power sector needs to be explored.This includes options to charge a fee forthe use of cooling waters, polluter-paidfees that reflect levels of atmosphericemissions of particular pollutants, theestablishment of a managementmechanism for the collected fees and theimplementation of the recent nationaldecree on the payment or forestecosystems services in relation to upperwatershed management for hydropowerdevelopment. The MoIT should also define

and enforce clear regulations on thetechnologies to be used for thermal powergeneration so as to ensure that the higheststandards of power generation efficiencyand pollution mitigation are found.

For hydropower, a number ofrecommendations were provided for theachievement of a more sustainablehydropower development in the earlierSEA of the Hydropower Master Plan.These recommendations have beenexamined in this SEA and are still valid.The recommendations fall into threecategories: i) recommendations that areconcerned with the institutionalization ofSEA as part of the strategic planningprocess for the power sector; ii)recommendations that define actions thatare necessary if Viet Nam is to moreadequately accord with international bestpractice for sustainable hydropowerdevelopment; and iii) otherrecommendations concerning the largerpower sector development context.

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Actions in all three areas are needed. Thepresent practice of planning in the sectorhas many strengths but does notadequately take account of social andenvironmental factors, for instance indecisions on the cost and design ofhydropower schemes.

Further specific recommendations forsustainable hydropower developmentinclude the improvement of the existingpackage of support and compensation fordisplaced people, the multi-purposemanagement of reservoirs to ensure anintegrated approach to water resourcesmanagement, the development ofcommunity forestry and protected areaplans for the areas surroundinghydropower sites, and the preparation ofbiodiversity management plans inlocalities of high ecological value. It isfurther recommended that thecancellation of two planned schemes,Dak Mi 1 and Dong Nai 5, should beconsidered due to the probability oftheir severe impacts on biodiversityin the future.

For nuclear power, two keyrecommendations are made. The first isthe need for a series of steps to developthe regulatory framework and operationalcapacities for the safe development ofnuclear power. Central to this is thedevelopment of radioactive managementregulations and norms that meet thehighest international standards. Thesecond recommendations relate to the siteselection for nuclear power, as it isessential that the sites selected do notplace any sensitive ecosystems nearby atrisk from either the cooling waters or theaccidental release of radioactive materials.Sites must be avoided that are close toareas of either ecological sensitivity orhigh ecological value.

For the transmission lines, actions to limittheir impact on forest resources and highvalue ecological areas are needed. Thisincludes the active consideration ofre-routing line routes where they will resultin the fragmentation of key biodiversityareas or protected areas. The scope forincreasing the capacities of transmission

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lines to 1,000kV, in order to reduce thetotal number of lines, should be examinedwhere this is technically possible.

Taken together, these general and specificrecommendations would make a significantcontribution to reducing the adverse socialand environmental impacts of thenecessary expansion of the power sectorplanned in PDP VII. Many negative impactscan be reduced and vigorous actions to

ensure that this takes place are essential.Of course, all such impacts cannot beeliminated altogether and there should be atransparent recognition of the likely trade-offs needed for the effective developmentof the sector. Further analysis of costs,benefits and further consultations withrelevant stakeholders are both essentialand should be continued once the presentSEA finishes and PDP VII is finalized.

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