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Probe International's Reply to

Acres International's May 8, 1 9 ~ ) 2 Submission to

'l'he Assoeiation of Professional Engineers of Ontario,
Complaints Conunittee
Probe Internab onal's Complaint Concerning
Acres InternabonaI's Role in 01(:
Three Gorges Water Control Prqject Feasibility Study
Submitted October 19, 1 9 ~ ) 2
For consideration October 22, 1992

Probe International's Reply to
Acres International's Response to
Probe International's Allegations
1. Introduction
2. ,Jurisdiction: Probe International's response to
Acres' Submission A
:1. Allegations of Professional Misconduct, Negligence and
lnCOlnpctencc: Probe lnternational's response lo
:\cres' SubmIssion 13
Introduction and Summan' of' Wron
A, Inadequate Dam Safety Analysis
l3. Inadequate and FlaweclFloocl Control i\nalysis
C, Flawed and Misleading Cost-Beneil t Analysis
D. Other Major Flaws in the Three Gorges Water
Control Project Feasibl:Lz:ty Study
L: J
,' r
o (
1. Introduction
In its May 8, 1992 submission to the Registrar of Association of Professional
Engineers of Ontario (APEO), Acres International Limited (Acres) rejects both
the app'ropriateness of and the legal basis for APEO's exercise of jurisdiction over
the substance of Probe International's complaint against Acres International for
Acres' work on China's Three Gorges dam. Acres International also rejects Probe
International's evidence in Damlning The Three Gorges and our September 3,
1991 response, saying they do not constitute a substantive basis for our complaint
of professional and ethical misconduct, negligence, and incompetence.
Probe International maintains that the APEO has a legal requirement, a
legislative mandate, and a professional duty to all its members ancllicensees to
hold Acres accountable to Ontario-legislated standards, as outlined in the
Professional Engineers Act (lithe Act") and as confirmed by the former Eegistrar
of the APEO Furthermore, Probe International is of the firm view that Acres has
railed to refute Probe International's evidence of professional and cthic1l
misconduct, negligen.ce and and l)),\[ tlH' ;\!)Fn c()[lflnn
its jurisdiction over this matter and refer this matter to a 118;:ll'Ing.
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2. Jurisdiction
The Act states:
2(3) The principal object of the Association is to regulate the practice
ofprofessional engineering and to govern its nwmbers, holders of
certificates of authorization, holders of temporary licences and
holders of limited licenses in accordance with this Act, the
regulations and the by-laws in order that the public interest may be
served and protected.
The position of the Association on the question of jurisdiction, as set out by the
former Registrar, Peter Osmond, is unambiguous. In his lVlarch 25, 1991 letter to
Probe International, Mr. Osmond said:
With respect to the qllestions you raised) I lcould flrst confi.rll7. that
this Association takes the position that it has jurisdiction over aU
engineering activities of'its hcencees u'hereuer and howeuer those
actiu!ties tahe place
In its submission of May 8, 1992 Acres makes 1118ny arguments attempting to
convince the APEO to qualify or ignore the clear, unqualified jurisdiction it has
uneler the Act.
For example, Acres ci tes a cri tical review of Dcnnming the Three Gorges in Impact
Assessment Bulletin, to argue that the APEO should not have jurisdiction over
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Acres' 'Nork on the Three Gorges dam in China:
In several chapters, western values are used to make judgments about
the social impacts of the proposed project on the Chinese people.
Western values cannot be assurned to be applicable in the asseSSTnent
of international projects, especially in China. "The Chinese have been
socialized undRr different forms of government) land tenure
relationships) belief structures) norrns) values, and other cultural
dRf'initions. These charCLctenstics appear to have been ignored by
contributors to the text.
iii Can the Complaints Cornmittee of the APEO accept that APEO's jurisdiction is Cjualified
by standards and events in China?
In its iVIay 8, 1992 submission to the APEO, Acres ;:lrgucs that Quebec is lithe na tural
jurisdiction to resolve this matter" because Acres staff c1eliveredlJrofessional engineering
""""""'s "primarily in tbe Province of Quebec,"
iii The issue before the Board is its own jurisdiction, not that of Quebec:
Similarly, Acres argues that Canadian constitutional law limits the jurisdiction of
provincial legislation territorially and that "it would be an extraordinary proposition for the
APEO to aSSUI1J,e jurisdiction and substitute its own 'view on professional miscon.cluct for
that of the appropriate licensing and regulatory body in the jurisdiction in which a company
or individual renders professional engineering services,' simply by virtue of the fact that
such company or individual may be also licensed to practice engineering in the Province of
Ontario." Acres goes on to say that it would be contrary to "interjurisdictional comity and
the legislative mandate of the APEO to effectively second-guess the appropriate
maintenance of professional standards in another province with regard to professional
engineering services performed there."
Probe International is not asking APEO to "substitute" its own professional standards
for those of other jurisdictions. Nor is Probe International asking APEO to "second-guess
the appropriate maintenance of professional standards in <mother province." Probe
International is simply asking APEO to determine whether Acres and its staff, who are
licensed by APEO, delivered professional engineering services to the Three Gorges Weder
Control Project Feasibility Study that met Ontario's standards.
Acres argu.es that the "principal object" of the APEO, as set out in section 2(3) of the Act,
should be interpreted ClS the regulation of the practice of professional engi neering in
Ontario for Lhe protection of the Ontario public interest onl\'.
Again, Probe International rejects this restrictive interpretation and maintains thClt in no
way does the Act relieve licensees of their positive duty at all times to uphold the standards
of the licensing body whose licenses profess to a certain quaJi ty of engineering work.
Nothing in the Act limits the obligation of Ontario-licensed engineers to safeguard only the
lives. health, property, and welfare of Ontario citizens .
If the public outside Ontario cannot rely upon the APEO to enforce Ontario standards on
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out-of.-province engineering activities by its members, then Ontario engineers are not
professionally accountable for the effect of their actions on the public in the jurisdiction in
which they are practicing.
Again, Acres says "It is not evident to us that the exercise of jurisdiction by the APEO in
this matter serves in any way to protect the 'Ontario public interest'. Indeed," Acres
contimles, "it would appear contrary to ." the Ontario public interest ... to effectively seconcl-
guess the appropriate maintenance of professional standards in another province with
regard to professional engineering services performed thereII (emphasis added by
Again, the issue before the APEO is whether it has jurisdiction, not whether and how il
should exercise its jurisdiction.
JII Can the APEO deem the maintenance of high Ontario standards, under any
circumstances, to be contrary to the Ontario public interest'?
Acres claims there is a conflict between statements made by API;;O's former n.egistrar, IVJr.
Peter Osmond, in two letters to Probe International.
There is no conflict. Both of Mr. Osmond's statements are clear, unequivocal. and consisten t
with the Act. We also note: that APEO's position is consistent WiOl engineering practices in
the U.S. and the U.K.
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The Royal Charter of the Institute of Civil Engineers in the United Kingdom, the
professional standard-setting body for civil engineers in the U.K., states in its Rules for
Professional Conduct, section 9:
A member in connexion with uJorh in a country other than his own shall order
his conduct according to these Rules, so far as they (Lre (Lpplicable; but where
there (Lre recognized stcwdards of professional conduct, he shall adhere to
In the U.S., engineering state registration boards similarly consider the out-of-state
activities of their licensees. 1;'01' example, the North Dakota State Board of Hegistration for
Professional Engineers and Land Surveyors says "engineers who practice outside our
jurisdiction are expected to adhere to our standards as well as observe the stand8rds of the
jurisdiction which they are in."
Acres argues that it is not possible lito attribute speciflc d siems to Acres or its engineers.
even if they were subject to APEO jurisdiction," clue to /\cr8.'O corporate relationship to
CY,JV and the many parties involved in the Three Gorges proJccL Il also cites lhe declslOll
of lVIr. Luc Laliberte, Syndic of the O r d n ~ des ingenieurs du Quebec, wIlo found the OIQ had
no jurisdiction because it only regulates individuals.
III The difficulty of attributing responsibility is not at issue here, neither are the standards
('md practices of the OIQ. (1'he APEO must decide if it has jurisdiction to consider the
standards and practices of aJI its licensees, individual and cOl'lJorate"
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Acres also argues that Frobe International is abusing the process, claiming that Probe
International misrepresented a specific finding of the OIQ by translating the verb
"revoyait" to mean "revise" rather than "review."
The OIQ did not provide an official response in English, because as Mr. Laliberte noted, "By
virtue of Law 101, }'rench Language Charter CL.R.Q. c.e-11) we are obliged to write you in
As no official translation exists, there is no reason to accept Acres' translation.
According to the ]?-obert - the definitive French language authority for the Frenchspe8king
world - the verb "revoir,1I as used by Luc Laliberte in "revoyait," is defmed as "exanliner de
nouveau pour parachever, carriger" or the action of examining again for the purpose of
cOlTection, and directs the reader to the verb "reviser." The same is true for !{arraps
Shorter French (Lnd English Dictionary, as well as the Robert und Collins, Lastly,
La!'ollsse's defines "revoir" as lito see again; to meet again; to revise, to review, to re-
examine, II
F\lrtlwrmore, these various tr:msJations define actions similar to those described by ,J
"Chronology of Activities on the rl'hree Gorges Feasibility Study" (found in Acres' Exhibit L):
COl!7l1lents (!'Om 8C, C1])1\, the 'World Bank, Chinese and Reuieul Board aU
incOl]Jorated into Vols. 7)2,3,4)5)6,7)8,20 and n,
Feb/M8rch, 1988
Acres also argues abuse in citing the procedures and decisions of other regulatory boards.
In the case of Quebec, Acres states that the OIQ has resolved [this matter] together with a
reasoned decision in wri ting to Probe. II Acres adds that with the cooperation of CYJV, it lIis
providing the APEO with the particulars that were made available to the OIQ (Exhibit 1)
and informed that body's decision.
With the matter lI already authoritatively disposed of in
the appropriate jurisdiction,11 Acres argues that Probe International is abusing the process.
Probe International maintains that Mr. Luc Laliberte, Syndic of the OIQ, did not refute
Probe International's allegations of misconduct by Quebec-registered engineers in their
practice of engineering on the rl'hree Gorges feasibility study. In fact, Mr. Laliberte states
tllClt Ii our possible complaint against Hydro-Quebec International, SNC and Lavalin would
be, legally speaking, immediately rejected by the Disciplinary Commi Hee, as these firms
are not and cannot be members of OLll' professional corporation and, as such, CCLnnot lye
jlldged h:y ltS
(emphasis added by complainant). Because II no individual decision was taken
)1')' any particular engineer for which he/she could be held rcsponsible,1I Mr. Laliberte
explains lIit is impossible for us to attribute to either one or several of our Members toto) or
8ven partial responsibility for any hypotheses, solutions, and rccommcndations
found in
the Three C;'orgesWuler Conlrol Prqjecl Fensihilily ltc/y.
[n the case of B,C., Acres lntcrtwtional states:
The APEBC decision nUlhes cleor that mCLny olthe concerns presented by
Probe in its booh, J:.}r:Lnm1ing-'-.[he311reg_!Jorges, were to be the subject all/a
c07nplementary study which was to lollol.u the leasibillty study and cleol lulth
construction plunning) ellu{Tol/mentul issues Wid resetllenwnt issues" wllLch
was SZlspended by the People's RepubUc ol Chin.a (PRC) in July 1989, prior to
to ..
its completion. The APEBC suggests that "this report might have satisfactorily
addressed the issues raised by Probe." The APEBC stresses furth-er that the
Probe Complaint addresses concerns essentially beyond the Terms of Reference
of the Feasibility Study under attack, that the Probe critique consists of only
opinion evidence rather than the facts, "and the disciplinf? process of the
Association is not structured to arbitrate diverse opinions."
We maintain that the APEBC made findings of fact without full disclosure and without a
hearing, and through procedures differing from those of the APEO. Therefore we question
the weight that can be accorded to these findings. Moreover, given the opportunity to argue
our case before the APEBC, we believe that the APEBC's decision would have been
different. The APEBC also dismissed our complaint on the grounds that our criticisms
"tended to be opinions" and the APEBC is notstructurecl "to arbitrate diverse opinions." As
you will see from the following evidence and our two earlier submissions, we believe our
cri ticisms are beyond opinion and are a matter of professional standards.
II Once again, the issue before the APEO is whether it has jurisdiction. The existence of
other procedures in other jurisdictions is not relevant to the APEO in determining its own
iclrisdiction in this maLLer.
In sumrnary, the former Registrar's position is unequivocal, and Acres must accept the
/\PEO's jurisdiction in this matter. Acres' position raises several pertinent questions:
II ,should the APEO be bClrred frorn considering a licensee's record in a jurisdiction outside
Do Ontarians have a right to the reassurance that an Ontario engineer observes only the
highest standards, and that he not determine his standards by the expectations of his
If an Ontario engineer is found guilty of misconduct concerning his professional conduct
in another jurisdiction, does APEO have no jurisdiction to consider the impact or
implication of that misconduct on the reputation of other Ontario engineers?
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3. Allegations of Professional Misconduct, Negligence and Incompetence:
Probe International's Response to Acres' Submission B
Introduction and Summary of Professional Wrongdoing
Probe International submits that Damming The Three Gorges, our September 3, 1991
submission, and the body of evidence to follow illustrates errors, omissions, imprudent
assumptions, biases, analytic irregularities, inconsistencies, oversights, and substandard
engineering methodologies that were applied by Acres engineers in their work on the Three
Gorges Water Control Project FeasibiLity Study. We also submit that these failures
compellingly demonstrate the inadequacy of the review process in which consultants and
specialists took part.
\Ve believe this evidence contradicts Acres' argument that its work satisfJed the "highest
,,,md of professional excellence and ethics." We firmly believe that Acres has failed to
uately respond to our complaint, and that a prima {([cic case eXists for a hearing into
the matter.
OU 01 t
III rrhe CYJV engineers failed to employ the recommenclations of JCOLJJ Bulletins numbers
59 and 72 on clam safety precautioru; and selecting seismicity parameters, and therefore
neglected to apply these recommendations in the dam design and the econornic cost-beneflt
III CYJV engineers exaggerated and misrepresented the Three Gorges project's f100cl control
13 ..
Ii CYJV engineers failed to taJte into account uncertainty in their risk assessments and
Ii CYJV engineers failed to review existing data on sedimentation as required by the
Terms of Heference, thereby rendering their Hood control, navigation and electricity benefit,
and life-expectancy calculations unreliable and without scientific basis;
1\1 CYJV and its clients claimed they had "reviewed and analyzed, on an integrated basis,
the costs, benefits and other effects of the overall project" and concluded the project was
"feasible and financially viable
without first demonstrating the feasibility of resettling
close to one million people, as the Steering Committee and the rrerms of required;
1\1 CYJV concluded the Three Gorges project was "environmentally feasible" without the
c1c1ta ann analysis to prove it.
We suggest that CYJV engineers licensed by Ontario have demonstrated professional
misconduct and negligence based on the following provisions of HQgillatioJl :5:18/84 made
under the
8()(l) In this section) "negligence" meons em (Lct or on omission. in the carrying out of
the worh o{ a practitioner that constitutes 0 {ailure to maintain the standards tho t a
reasoTwole and prudent practitioner would nwintain in the circurnstcmces.
(l1Jhere the "worh o{ a practitioner" is defined in the Pr:Qf:;;siQ!HIl
Engill.f}....fDLftcl as IIJproctice o{pro{essional engineering) meCLTLS CLny oct
of designing, composing, evaluating, advising, reporting, directing or
supervising wherein the safeguarding ot lite, health, property or the
public welfare is concerned and that requires the application of
engineering principles, but does not include practising as a natural
scientist "]
86(2) For the purposes at the Act and this Regulation, "protessional
Tnisconduct" nwans,
(a) negligence;
(b) jc[ilure to nwhe reasonable prouisi,on tor the safeguarding of life, health or
property at a person who nwy (Je atfected by the Icorh jc)r which the
practitioner is responsible;
(c) jc[ilure to act to correct or report a situation thut the !Huctitioner believes
m.uy endanger the safety or the IDeljcIre ol the puZJlic,
lcu/un) to 1Ilolic respons!h1e !HOI'is!ons jc)r complying Ii'ith opjJlicable
statutes) regulations, standards, codes, hy./aws CLlI.cl rilles in connection luith
war!? being undertahen by or under the responsibility oj' the practitioner,'
(f) failure at a practitioner to present clearly to his employer the consequences
to be expected froni a cleuiation proposed in worh, if the professional
engineering judgment of the practitioner is overruled. by non-technical
CUlt/Writy in cases where the practitioner is responsible for the technical
adequCLc)' of professi.onal engi.neering u}orh;
91(1) It is the duty of a practitioner to tlte public} to his employer; to his
clients, to other rnembers of his profession} and to hirnselfto act at all tirnes
(iii) devotion to high ideals of personal honour and professional integrity;
(2)(i) A practitioner shall regard his duty to public welfare (IS paramount;
54. Every holder ot a licence, temporcLry licence or limited fiance who jJrouldes
to the public a seruice that is within the practice of professional engineenng
shall sign) date and offix his seal to every final drwuing. specijlcotioTl, plall,
report or other document prepared or cheched !)jI him as part 0/ the seruicc
before r:t is iss lied.
\\'e suggest Lll:lL CYJV engineers Jiccnsec11Jy OnLuio ))(\v(; demon Lnt
incompetence based on Lhe following provision of Lhe Acl:
29(3) The Discipline Committee may tind C1 II/ember of the Association or a
holder of a temporary licence or a hmited licence to be incompetent it in its
(aj the mernber or holder has displayed in his professional responsibilities a
lach of knowledge, shill or judgment or disregard far the welfare of the public
of a nature or to an extent that demonstrates the member or holder is unfit to
carry out the responsibilities of a professional engineer.
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A. Inadequate Dam Safety Analysis
The points contained in section A are dealt with in Chapter 10 of Damming The Three Gorges. A
more detailed technical discussion of this subject prepared by Dr. Philip Williams in 1990, and on
which Chapter 10 is based, is attached as appendix A.l to this submission.
With a project the size of Three Gorges, we believe a reasonably prudent engineer must consider
tbe worst-case scenario in its risk and safety analyses. Failure to do so demonstrates negligence
pursuant to section 86(1) and professional misconduct pursuant to sections 86(2)(a)(b)(c)(d) of the
Code of Professional incompetence pursuant to section 29(3)(a) of the Professional
Act; and a violation of sections 91(1)(iii) and 91(2)(i) of the Code of Ethics
A.l Inadequate 'l'rcatrnent of Ground Acceleration (appendix A 1 p2)
According to ACl'es, CYJV used lCOLD Bulletin No. 46 OCOLD H)8J) as the reference for
evaluating the seismic risk of the Tl)ree Gorges project. subseCluent documents incluclui!;
reo L)) hu lleti n s were a V;) ila hI eat th e ti me the feasibi li s tll dy was prepmcd and nvo of' t
dealt with the issue of seismicity
rCOLD Bulletin No. 59, Dum Ciwdelines (lCOLD 1987) stressed tl1C irnportance of usi ng the
"latest standards cmd methods" for evaluating seismic activities. rCOLD Bulletin No. 46, used by
CYJV, did not contain the latest standards. These standards were contained in the Guidelines for
Selecting Seismic Parameters For Lurge DOl!2 Projects prepared by USCOLD in 1985 which became
the basls for leOLD Bulletin No. 72 (TeOLD 1989). Bulletin No. 72 rnakes clear that the firsL
chapter of Bulletin No. 46 "summarily treated the problem of seismic input for dam analyses, II and
. 1g .
the objective of Bulletin No. 72 is to outline the II state of the art in this field" and to provide
guidelines to help dam designers to select the seismic input parameters concerning large dams.
According to leOLD Bulletin No. 72 page 17, the location and description of faults II should incl ude
documentation on the existence of or lack of historic or pre-historic activity (paleoseismicity) for
each fault." Although Acres says that CYJVs analysis of seismicity included a comprehensive
cataloging of earthquakes, this included historic activity only. CYJV failed to consider
paleoseismicity and, instead, limited its assessment to historic data (Vol 4 p 4-4).
CYJV also failed to adequately determine the key design parameter of ground acceleration CYJV
ignored the estimates of ground accelerations determined by the methodologies of severell
respected researchers, using instead the lowest available estimate (i.e. it used 0.17g insteCld of
05g). CYJV then used this lowest estimate as a "starting point for safety evaluation of the main
project structures" (Vol 4 figure 4.2, attached as appcncllx ;\2). with Californl
eal'tbquak8s indicates that even the highest of the estimates considered - O.Sg - may be optimlstic:.
Ground accelerations of 1.Og were measured at the Pacoina IJam during the ('3.5 magnitude San
Fernando earthquake.
l'nclerC'stirnating ground ;lcceleratiol1 is imprudent. parLicuL!rl\ in thiS case lwcwse, to
[CULl) criteria, Three Gorges would be an "extreme ]']sl\" project requiring the most COnS(TVClllV('
design approach (appendix A;3). If the more realistic ground acceleration estimate ofO.5g is usee! it
appears tJ1at the return frequency of the maximum earthquake ror which it is designed will be
exceeded about every 200 years instead of every 2000 years as intended (Vol 4 figure L1.6)
lVerLical accelerations of O.6g were measured about 20km a way
from the 7.1 magnitude Lama Prieta earthquake, as compared to the
O.12g that would have been predicted using CYJV's methodology.
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We suggest that the inadequate treatment of ground acceleration contained in the feasibility study
is unacceptable for a reasonably prudent engineer licenced in Ontario, and that it demonstrates
negligence pursuant to section 86(1) and professional misconduct pursuant to sections
86(2)(a)(b)(c)(d) of the Code of Professional Conduct, and a violation of section 91(2)(i) of the Code
of Ethics.
A.2 Inadequate Analysis of Reservoir-Induced Seismicity (appendix A.1 p3)
Acres' response does not properly address our allegation that CYtN failed to adequately consider
tbe risks associated with HIS, and therefore failed to incorporate the dTects ofFUS in their dam
lCOLD Bulletin No. 72, page 27 states: "Even if all the fmllts within a reservoir are considered
tectonically inactive, the possibility of reservoir-induced seismicity should not be totally ruled
out." 1
\1/e refer the Committee to volume 4 plate 4.8 (attached as appendix 1\.4) which shovls several
;1111ts running right under the dam site itself. Although these faults have not been confirm to be
in,luivc (as indicated by CY<JV's parenthetical qualiJiccltion that the L1UltS arc "generalh
), CYJV Ulrried out its analyses assuming that they were macLlvc. If' any 01 theSe'
fclUltS arc still active, increased ground acceleration and offsd after the dam is built must be
considered in a reasonably prudent design. CYJV engineers failed to do so. Reinforcing ICOLIYs
~ ~ ~ - - - - - - - - - - - - - - - - - - - ~ - - - ~ - - - - - - - ~ - - - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - -
l.The }\.oyna Dam in India initiated approximately a 6.0
earthquake, killing 200 people, in an area that had not
previously been seismically active.
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caution is the statement by Sherard, Cluff and Allen in Geotechnic that Ilconcrete dams on active
faults, or near some major active faults, are not advisable."
We suggests that CYJV's failure to adequately assess the risks of RIS reveals negligence and
professional misconduct pursuant to sections 86(1) and 86(2)(a)(b)(c)(d) of the Code of Professional
Conduct and a violation of section 91(2)(i) of the Code of Ethics. They also violated section 54 of
the Eegulationsby failing to sign and seal their drawings.
A.3 Inadequate Analysis of Structural Stability (appendix A.I p3)
Acres claims that the Three Gorges dam has been designed so as not to be endangerc:;d by both the
PMF event and the MCE event, using approaches and criteria consistent with internationcd
practice for feasibility studies ofJarge multi-purpose water resources projects. We disagree, and
suggest that CYJV failed to use acceptable design parameters and risk assessments to ensure
tructural s tabi Ii ty.
E3ecause CYJV failed to adequately evaluate the impacts of IUS and ground acceleration, they
could not take these crucial parameters into account in their structural stability ana s, I rJ)
13ulleLin No. 72 section 5.:!.1 on cOl1creLe (LIm::; r:xplains thaL c!vl1,unic nl1itc clement l'i'sponc:('
cll](]lyses, whicl1 require peak ground motion parameters, should be carried out for most clams In
higl1 risk or hazard ratings. CYJV failed to complete a d.yn81nic fini te clement response analysi s
even tbough Three Gorges would rate as an "ex treme risk" project according to ICC)IJ) critel'lcl
(appendix A.3). Hather than deferring this critical analysis until after project approval, as CYJV
did, it should have been included in the feasibility study.
lSherard, L, et aI, "Potentially active faulLs in dam
foundations," Geotechnic, vol. 24, no. 3, pp. 367428, 1974.
Although CYJV'$ structural analysis indicates tensile stress in the dam, CYJV fails to project
whether a higher, more realistic ground acceleration will cause cracking. Design changes to deal
with cracking would add significantly to the cost and feasibility of the project.
According to ICOLD Bulletin No. 59, section 4.7.4: "Due to the risk ofreservoir-inducecl seismicity,
in dams exceeding 100 meters high or storing more than 1. km3 of water, due cognizance should be
taken of the requirements to design for seismic loading even in regions without any historical
We suggest the CYJV's inadequate analysis of structlJxal stability reveals professional misconduct
pursuant to section 86(2)(a)(b)(c)(d) and negligence pursuant to section 86(1) of the Code of
Professional Conduct..
A.if Inadequate Treatment of Reservoir Landslides (Clppendix A.l rA)
defends CYJV's assessrnent of landslide risk by making two points. First, Acres sLates tlwt
some lAO landslides in the reservoir were catClloged and characterized, and the slopes were
evaluated for stability. Second, that waves triggered by landslides would not affect the safe!\ of'
the clam.
First, cataloging and evaluating landslides which occur in the area is insufTi.cient. Wiele
Ouct.uatlons in reservoir levels are highly likely to have a destabilizing effect on potential slide
areClS in the Three Gorges region because the region is already susceptible to major landslides.
According to ICOLD Bulletin No. 59 section 6.2.1: "Critical reservoir rim areas should be surveyed
for banks which may become unstable during or after reservoir fi.lling or drawdown the colletpse of
which rnay affect the safety of the clam or any other facility in the vicinity of the reservoir." CY,JV
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optimistically and mistal{enly assumes this crucial factor can be ignored because of the
unsubstantiated assertion that submergence of the toe will increase st?bility (Vol 4 p 5-11).
With respect to Acres' claim that landslide-induced waves would not affect the safety of the dam,
we refer the Committee to volume 4, figure 5.1 (attached as appendix A5) which shows CYS\T's
predicted landslide-induced waves of 20 to 50 m. Note that, although CYJV dismisses the
cCltastrophic impact of these waves because of lithe policy of resettling people to a level of
[elevation] 182 or higher
(Vol 4 p 5-12), the feasibility study says elsewhere that people will
remain at elevations 162 m. (Acres acknowledges this fact in its May 8, 1992 response in its
IISubmission 13
pg. 7, B.5(i).) Therefore, in the event of a 50 III wave, even when the reservoir is
drawn down to the 140 m flood control level, hundreds of thousands of people Jiving above 162 III
are at risk.!
Fina]]y, it should be noted that both natural and reservoir-induced earthquakes, whose frequency
ground acceleration rnagnitudes are grossly underestimated by CY,IV, \vi)) have a
effect on potential slide areas.
l3y failing to assess the nsk landsJides, CYJV has ignored tl1e risk to the I ,\\'elf,uc
;)Ild properLy ofLhe population it plans to IC;1\'e in the ,)ctive flood control rescnoir ;)1'(;;)
suggest this dCJnonstrates negligence pursuant to sectioll 86(l) and profession;\I misconducL
j)msuant to sections 86(2)(a)(b)(c)(d) of the Code of Professional Conduct; incompetence pursuant
to section 29(::3)(a) of the Professional Engineers Act; and a violation of section 91 (2)0) of the Code
of Ethics.
LA landslide-induced wave at the Vaiont Darn killed 4000 people.
?,:l -
A.5 Underestimation of Spillway Failure (appendix A.I p5)
Acres claims that, before CYJV recommended its spillway design, extensive reviews of
Chinese studies and models were carried out. We believe that reviewing previous and
ongoing models and studies is insufficient for estimating the risk of spillway failure.
CYJV did not carry out a risk assessment to determine the risks to public safety and the
economic costs of spillway failure, despite CYJVs recognition that the "discharge per unit of
width of the submerged spillway bays is well beyond the proven world experience." A
reasonably prudent engineer would at least have analysed the performance, reliabili ty and
frequency of failure of spillways at other mega-dams to cletermine the probability of failure
of spillways at Three Gorges.
As per CYJV's recommendation that lithe feasibility of SllCh a high unit discharge should be
reviewed during final design," CYJV should have been explicit th2\t spillway operations had
not been proven feasible.
We suggest that CYJV's recommendation to build the dam despiu' not proving that the
spillways will perform safely constitutes pursuant to n 86(1) and
professional rnisconducl pursuant to section 86(2)(a)(b)(c) and (el) or the Code of'
Professional Conduct.
A.G Ilisk of Cofferdam Failure (appendix A.I po)
Acres has presentecl information from the feasibility study in a way that tends to
unclerstate the risk of cofTerdam
- 24 .
Acres suggests that a 5 to 6 m water level difference between the upstream and
downstream side of the Phase II cofferdam is insignificant. We wish to point out that 5 to 6
metres of water stretching back over hundreds of kilometers of reservoir is not an
insignificant volume of water.
Acres also suggests that the consequences of failure of either the Phase II or Phase III cofferdams
would be "primarily limited to flooding the construction site." We disagree, and we refer the
Committee to three pages from the feasibility study contail1(;,d in appendix A.6. The Phase II
cofferdam will be buil t to eleva tion 90 and will store 1 km3; the Phase III cofferdam will be buil t to
elevation 135 and will store 12.4 km3. If a devastating flood wave washes out one of these
cofferdams, a large flood wave will be released with flow rates exceeding a hundred thousand cubic
metres/second that wendd overwhelm the Gezhouba Dam downstream, whose reservoir capacity is
less than 0.5 km3. The massive flood wave would continue downstream, devastating the Y,ll1gtze
flood plain, probably overtopping tbe Jingjiang dike, and drowning hundreds of thousands oC
'T'he eh ances of such an event are underestimated ]))' CYJv. The 12 percen t chance oC coCfercLlm
Cailure during tbe construction period used by CYJV is optimistic because it is b,lsed on ClIl
un istic construction eell] Ie. For exampl e, CYJV mates the FJ!wsc 111 cofTcl'CL1m wi]! hr'
built to 135 m in just () months. They do not project tbe increased risk of failure if the darn is
constructed over a longer, more realistic, schedule.
.._-_..... _---_._-----_...._--
1. Such 8. cofferdam failure occurred in 1986 on a much smaller scale in
the U.S. when the Auburn cofferdam was washed out in a flood, releasing
about 0.15 k m ~ - 3 and a flood flow in the order of 20,000 cubic metres/sec;
but fortunately the downstream Folsom reservoir was able to contain
the flood peak.
By failing to assess the risk of cofferdam failure CYJV has ignored the risk to the life,
welfare and property of the population near the project. We suggest this demonstrates
negligence pursuant to section 86(1) and professional misconduct pw'suant to sections
86(2)(a)(b)(c)(d) of the Code of Professional Conduct; incompetence pursuant to section
29(3)(a) of the Professional Engineers Act; and a violation of section 91(2)(i) of the Code of
Ethics. They also violated section 54 of the Hegulations by failing to sign and seal their
specifications and plans (e.g., see '1014 plates 4.15,4.16,4.17, etc.) .
.. :2 () .
13. Inadequate and Flawed Flood Control Analysis
All of the points contained under section B are dealt with in Chapter 8 of Damming The Three
Gorges. A more detailed technical discussion of this subject prepared by Dr. Philip Williams in
1990, and on which chapter 8 is based, is attached as appendix B.I to this submission.
Acres response does not address our allegations that CYJV failed to provide an objective and
systematic analysis of the reduction of flood risk expected from the project, and also failed to show
that the project was tlle most cost-effective approacb to providing this flood risk reduction,
B.I Misrepresentation of the Purpose of the Project (appendix B.1 pI)
Acres' response does not address our allegations, belt we believe the implications of its response
need to dealt with,
Acres states that the area that will obtain significant 1ood control ben ts is }9,4:)9 km2 with an
estirnated population in 1987 ofS).87 million. This fails to address the contradictions contained in
the feasibili study which we mentioned in our book and in our submission to APEO in m l'
I That j,;, the an,;) which the engineers chim \Viii be protected (l'om fl ))jIS
described in different parts orthe study as approximately: 20,000 sq.km, Lmill ion sq.km, G,700
sq.km, and 4,000 ,oC].km,
nather than completing a systematic evaluation of potential Oood control benefits, ,TV has
unquestioningly accepted for the primary goal of the Three Gorges dam operation the Chinese
government cliclclte of increasing 1ood protection of the Jingbei and Jingnan areas from a 250 year
flood to a 1000 year flood. This reducticn constitutes such a hypothetical, incremented increase in
f1()od protection that it would be considered highly unusual anywhere else in. the world. In order i

accomplish this lofty goal of flood protection for some people, CYJV has developed a plan that puts
people living in the reservoir area - people who, at 162 m, are currently at no risk of flooding - at
risk of inundation from a 20 year flood.
Furthermore, Acres attempts to exaggerate flood benefits by implying that flood protection for the
Jingbei and Jingnan areas constitutes over 80 percent of the total flood benefits from the dam.
This is not the case. According to the CYJV's own economic analysis (appendix 13.2), only 10
percent of the project's 1ood control benefits are attributable to the Jingbei and Jingnan areas.
The same economic analysis from CYJV's study (appendix 13.2) shows that approximately 80
percent of the flood benefits will accrue to areas that will remain flood-prone, i.e. flooel diversion
areas and beach areas
. IIowever, CYJV has calculated the benefits based on a dollar value per
square kilometer and the economic growth r:ate in this area equal to that in non-flooel-prone an;as.
'1'here is no logic in assuming that people will invest as much money in expensive ch'iellings 01
llstries in an area that they knO\v will be subject to flooding as they will in an area not subJecl
to flooding. Moreover, people who do build in flooel-prone areas generally nood-proof then' slruc
tures, thereby decreasing the cost of flood cl<lmages further.
13eC;Hlse the flood control analysis in the study is so rife with contr::ldictory c]ainls, l'x:lf;r-;cr:lled
beneflts, undcrestirnated costs, and distortions of fact, we can only conclude thal t' e
were unable to justify the feasibility of the Three Corges dam for reasons of flooel protection.
Instead, Acres invokes Chinese government policy to justify their deviation from acceptable
standards of analysis and practice. We suggest this constitutes negligence and proi'essional
misconduct pursuant to sections 86(1) and 86(2)(a)(d) of the Code of Professional Conduct.
l.Beach areas are strips of land next to the river which are on
the river side of existing embankments.
13.2 Unrealistic Operating Criteria (appendix B.1 p2)
Acres did not address the point we made in our complaint. As we pointed out in our submission of
September 3, 1991 and in our book (p.92), the operating experience of large multipurpose
reservoirs during large floods indicates that there can be substantial deviations from prescribed
operating procedures which result in greatly reduced flood benefits (see section B.2(iii) below).
Acres substantiates a very serious concern we have with their operating criteria. Acres confirms
there are no operating rules that will override political decisions and human error; instead,
decisions will be made by "consensus opinion."
B.2(i) Potential Conflict Between People Affected by the Filling Reservoir and Those
Getting Helief fronl Flooding' Downstream (appendix 13.1 p3)
For the first tin1e, Acres (representing CYJV) has acknowledged that its pl::=ln recornmends leaving
at least 500,000 people in the active flood control reservoir area. The resettlemen t and f100d
control experts who reviewed the CY,lV study for Probe International uncovered this fact after
comparing various population and resettlement figures contained in the feasibility study The
plight of these balfmillion people has been concealed from dccision-nwkers ;:lS this circulw;tance 1S
J)ot even mc;ntionecl in CYJV's Volume J. which 1S a 'Istand ,lione
document prep,)
rnakers and potential international funders.
ford SJOl]-
Acres says these 500,000 people Ilwill continue to be affected by flooding. II It must be made clear
that tbe construction of this dam will put these 50(),000 people at risk of flooding for the first tllne.
Currently, people living upstream, at elevations of 162 m to 182 m, are not at risk offlooding.
These 500,000 people will not avoid the devastating effects of flooding simply "by climbing a Cew
meters to complete safety. II We suggest that this comment shows complete disregard for public
welfare in general, for the particular circumstances of the infirm, and for the loss of livelihoods,
crops and property. Such an attitude demonstrates professional misconduct pursuant to section
. .
86(2)(b) and (c) of the Code of Professional Conduct and a violation of section 9l(2)(i) of the Code of
Acres' final point, that damages along the river without the dam would be gJ.'eater than damages
around the reservoir, is based on faulty analysis, CY,JV has assumed that people living upstream
slang the river who live with, and depend upon, annual flooding have made the same economic
investments in their flood-prone area as people who live in areas currently not prone to flooding
(i.e. the land at 162 metres that LinD be subject to flooding /))ith the reservoir). This assumption is
questionable. People living along the river, who have lived with flooding, flood-proof their property
and make investments appropriate to their own environmental circurnstances.
using its biased assumption, CYJV also distorts its benefit/cost analysis ACC01'd to
study, people in the active flood control reservoir - bet\veen 162 rn and 182 m - wh.o will be
elJsplacecl by the reservoir will carry with them their portable assets and thereby clecre8se the cosl
of floocl damage (Vol 7F p 24); while people currently living along the river are not credited wi th
,\n)' measures to decrease the cost of lewd damage (Vol 7 table 9.6, footrlOte ij). Note thc1t such an
Zlssurnption decreases project costs in the former case and increases project hencflts in the 1'1ttcr.
B.2(ii) Conflict with flower Generation (appendix 13.1 p3)
Acres' claim thst there is Iinot likely to be a change in the operation of the project in favour of
electric power production
is wrong. Chinese officials 8re currently talking 8bout a Iinormal 175-
meter-deep water storage level
(appendix B.3) rather than CYJV's recommended 160 m normal
pool level.
The Chinese government's decision to chose electricity benefits over flood control benefits based on
CYJV's study is a logical one. The electricity to be produced is a real, measurable benefit whereas
as discussed in section B.1 above, most of the flood control benefits are intangible.
CYJV knew that such a change in operating levels might take place. It would have been prudent
therefore to include a warning in the feasibility study about the implications of such a change in
operating levels. (For example, increasing the NPL from 160 m to 175 m will decrease the
efficiency of draining the reservoir. This would result in increased sediment build-up downstrearn
and in the reservoir which in turn would impair the ability to draw down the reservoir in advance
of floods.) We suggest the failure to point out these potential consequences is contrary to section
86(2)(0 of the Code of Professional Conduct, which instructs an engineer licenced in Ontario to
present clearly to his employer the consequences to be expected from a deviation from his proposed
B.2(iii) Conflict with Downstrerun Development (appendix 13.1 p3J
i\cres has not addressed our concern that operating procedures might be altered to protect down
slre21m development. instead. Acres has implied that dam operating rules, and some planned
i':d t1g dnd forecasting systems, will prevent a conflict beL\veen dam operations ancl downstream
:Vlost of the flood benefits claimed by CYJV result f)'om economic development in the river channel
(beach areas) and overflow dlversion areas that has yet to occur. Even though these areas will
remain flood-prone, CYJV has predicted that investment per square kilometer and economic
growth rate will be the same inside the existing embankments as outside. This assumption is
imprudent and impractical, but is necessary for CYJV to boost its projected Good control benefits.
In rational flood control planning, it is standard practice to specify Hood-prone areas downstream
:n -
of major dams as "floodways " and prohibit or control development in these areas. This allows dam
operators to follow operating procedures - which include regular high flood control releases -
without the fear of drowning out downstream developments.
When this practice is neglected and development in 1oodways occurs, operators will tend to stop
making regular releases of water in order to protect these areas. If this happens, too much water i
held in the reservoir and when a large 1ood occurs, large volumes of water must be released to
prevent dam failure. Such a large release will inevitably result in severe downstream damage!.
Had CYJV evaluated a II1oodwayl' below the Three Gorges dam, or even taken into account the
rational behaviour of people protecting themselves in nooel-prone areas, the ca!cll!ated flood
benefits would be substantially less.
B.2(iv) Spillway Operating' Assumption (appendix B.l p:3)
states that IIit was assumed thClt a fixed pClttern of reservoir operation \vould be rigidly
followed by the TGP operators." However, as outlined in our previous section B.2(iii), operating
procechlres ma.y be altered in order to protect downstream development. CYJV did not assess the
consequences if its assumption of perfect spillway u]JC;ration is not realized.
Acres also states that its assumption of perfect spillway operation "w ill generate a conserV,lUv(;
estimate of the potential benefits." 'rhis cannot be true since 3. conserv8tive estimate would have LiJ
consider impaired spillway capacity which would bClmper water evacuation procedures and there-
by decrease flood storage. CYJV's overly optimistic statements about spillway operations is con
l.As occurred in 1983 when the Bureau of H.eclamabon was forced
to make designat.ed releases, and f100el out. t.he communities
downst.ream of the Boulder darn on the Colorado River. Since the
dam's completion, the Bureau of Reclamation had neglected
controls on downstream development in nooel-prone areas.
trary to the advise of R. Lafitte, Chairman ofICOLD's Committee on Dam Safety who says
with respect to spillway design, estimates "should always be given with ranges,
demonstrating that they are imprecise calculations."
We suggest that CYJV's failure to carry out a systematic risk assessment or assess the range of
consequences ifits assumption is incorrect demons(;rates negligence and professional misconduct
pursuant to section 86(1) and 86(2)(21) of the Code of Professional Conduct.
13.3 F'lood Routing- Model Was Inadequate (appendix 13.1 p4)
In its response, Acres admits that due to IlinsufEcient data on the several hundreds of kilometers
of channels
CYJV was unable to use a hydrodynamic model. Instead, it deemed it Ilappropriatell to
demonstrate the feasibility of the project by using a flood routing model to simulate water levels at
on ly 12 locations over a 500 km stretch of river, like a series of reservoirs. This is unacceptable.
using CYJV's own figures, the degTee of error in the flood routing model is unacceptably
JV admits that a 20 cm change in w,lter level against a dike can mean 20 percent cl1cmge in
flood benefits (Vo] 7 p 9-32) Est.imates of river stages based on t.he j)J'(;c!ict.io]1s ort.his mode!
in only 12 places on a river like the Yangtze ". \vith a complex f10w net\vork, diversion areclS,
f100dplain lakes and large t.ributary flows - can be in error by several metres which could make t.he
difference between the preservation of dike integrity and total dike failure.
Such a large discrepancy between the model results and the actual water now volumes is indicated
in CYJV's own testing. To Ilvalidate
the flood routing model, CYJV cornpares computed versus
1. Lafitte, It, "Progress in dam safety in relation to flood
risks," Water Power & Dam Construction, September, 1992.
-,,----------- ---
observed flow volumes. The discrepancy between observed alld computed flow volumes during the
flood peal\: is about the same as the total flood storage of the Three Gorges reservoir - in the order
of 20,000 m3 to 30,000 m3 (appendix B.4). We believe that such a "validation" would be considered
unacceptable for planning a large flood control project in Ontario.
Given the inaccuracies with using (1 flood routing model, and the possible consequences of error,
we believe that it is negligent to present the findings of a flood routing analysis 3S representing
the river flow "reasonably well" as CYJV did (Vol 7 p 7-10).
fIad CYJV proceeded with the flood routing 1110del as a preliminary assessment, CYJV should
have said that there was a significant chance of error in the projected 1ood protection and that if
this chance of error were taken into account this could seriously affect the proposed reservoir size
and operation. Alternatively, CYJV could helve insisted that hydrodynamic modeling be completed
prior to the completion of the feasibility study CYJV did neither.
Uneler section 8C3(2)( ell of the Coele of Professional Conel uet, engineers mus t make responoi blc
provisions for complying with applicable standards. We suggest that the tools w;ecl by CYJV
engineers did not ensure compliance with acceptable standards.
13.,1 of Floocl Benefits (appendix 13,1 prj)
We cannot oven;tate the importance of CYJV's erroneous assumption that the investment per
square kilometer and the economic grO\VUl rate in 1ood-prone areas is equal to that in areas not
prone to flooding. Such em assumption is highly qtlestionable.
One of the basic tenets of flood I)1cmageI1H;nt planning is that Hood darnage potential and the type
and value of land use are closely related. Obviously people prefer not to build in Hood-prone areas
and if they do, they flood-proof their property and limit economic investment. These actions greatly
reduce the flood damage that would occur in the "without project
alternative, hence reducing the
net benefits for the project. In the case of Three Gorges, if the growth rate in flood-prone areas
without the project was 40 percent of the unrealistic g-lowth rate projected for these areas with the
project, total flood benefits would be zero (appendix B.5).
E.5 Ornission of Project Costs from the Cost-Benefit Analysis
13.5(i) Additional Population to be Hesettled (appendix B.l p6)
Acres implies "risk of loss of life" is the only criteria for resettlement compensation. We suggest
that failing to consider the welfare of the people affected, the potential loss of subsistence (,'OPS,
and the loss of property demonstrates professional misconduct pursuant to sections 86(1) a
2)(b)(c) of the Code of Professional Conduct, and violates section 9](2)(1) of tl1e Code of FLtJics.
\\'e would like the Committee to keep in mind that more than half a million people will be; Ct 11l
is area - between 162 ill and 182 In - some of whom will be affected by frequent flood \V
sdggest that designing an 'llleged flood control project which leaves people around the ed the
",'servoir to clirnb "hig)JCl' up e river han "when flood wdLers ,Ire stored wCl\1ld not Ill'
E.5(ii) Backwater Effects During Future Floods (appendix B.1 p6)
Acres' staternent that the "critical Dood stage at Chongqing (198 m) is not expected to be exceeded
during a l-in-100-year Good" is based on the estimates of sedimentation found in Volume of the
feasibility stucly. However, these estimates rely on a gross underestimation of the river's bcdioad

(0.05 percent of total sediment) - an unprecedented, low estimate (Vol 5 p 7-1 and Vol 5A p 3-1). A
higher, more realistic, level of bedload would have a severe impact on the aggradation of the
riverbed upstream.
Acres' statement that "Flooding [at Chongqing] to levels below 198 m will cause liWe damage" is
contrary to their own statistics which show damaging flows to occur above 186 m. A July 1981
f100d with a peak stage of elevation 19;:3 affected over 137,000 people and caused flood losses of 190
million yuan (x 0.2703 =: approx. U3$51 million) (Vol 7F table 2.2, attached as appendix 13.6). Even
using the optimistic assessment of upstream sedimentation contained in the feasibility study, at
Chongqing water levels for a lOO-year Hood will rise 1 to 2, metres within 30 years, affecting
hundreds of thousands of people. It appears that CYJV recognizes this, as it claims "future
upstream reservoirs and conservation measures" would n:duce sediment deposition. However,
neither the cost of these reservoirs or measures nor the cost of incremental flood damages in
Chongqing is included in project costs.
CYJV has failed in its sedimentation analysis to demonstrate the danl will function as predicted,
that the clam will not require costly remedial measures, and that the dam will not change the
c::xisting sediment regime m a \vay as to risk the and property of hundreds of thousancls
of people.
\Ve suggest that failure to carefully and thoroughly evaluate the effect of the Three Gorges clam OJ}
the sediment l'(;gime of the Yangtze HiveI' demonstrates professional misconduct and negligence
LA bedload equal to 2-8 percent of suspended sediment is widely accepted.
According to D.D. Simons and Fuat Senturk's Sediment
1977, "the amount ofbedlol1cl transported by a large, cleep river is about
[) t.o 25 percent of the suspended load."
According to Chinese engineer Vl.W.L. I-luang, M.C.E., Ph.D, the gravel and coarse sand,
typical of bedload, has accumulated to a depth of 35 metres at the Three Gorges dam site.
:s-_-fil- _
pursuant to sections 86(1) and 86(2)(a)(b)(c)(d) of the Code of Professional Conduct, violates section
9l(2)(i) of the Code of Ethics, and demonstrates incompetence pursuant to section 29(3)(21) of the
B.5(iii) Repairs to Dikes Downstream of TOP (appendix B.l p7)
Acres says that a "short length of the riveI'" may experience downcutting. According to CYJV's own
study (Vol 5 p 10-2), after 30 years scouring may reach] GO Ian downstream of the Gezhouba
dam. This is not a Iishort lengthII of river. According to CYJV (Vol 5 p 10-3) the most serious
problem this scouring might produce is a channel shift which would direct How against the flood
protection dikes at Jingjiang, undermining their integrity and possibly increasing the flood risk
beyond the current 250-year flood. These problems can be mitigated by river training, the
feasibility study concludes. HiveI' training cost for this reach of the river alone could easily exceed
US$l million/km. 'rhis scenario wendd add a half-billion dollars to the project cost, but is not
Included in CYJV's estimates.
B.5(iv) Flood Damag'es to CO;lstal llCi_,Oons due to Reduced Sediment Deposibon
(appendix B.] p7)
Acres suggests that our allegation is false because "the impacts on the Yangtze estuary as (1 result
of sediment deposition in the TGP reservoir are not expected to be significanL
CYJV admits in the feasibility study that there v-/ill be "coastal retreat" but that this retreat "will
be fairly limited" (Vol 5 J p 4-7). We wish the Committee to note, however, that the area at
the mouth of the ;{angtze is highly populated and intensively developed and any retreat could have
serious economic ramifications for the area, Moreover CYJV based this prediction on the
.. :)'7.
unprecedented and unrealistic assumption that the reservoir will have a IIhigh flushing efficiencyl'
and will therefore retain 90 percent of its storage capacity. CYJV did not calculate the impact if
this extremely optimistic assumption does not hold true.
According to World Bank Technical Report #71 - Reseruoir Sedimentation: Impact) Extent, and
Mitigation .. the only large clams that have successfully dealt with sedimentation through fltlshing
a r ~ , clams whose reservoir is practically emptied prior to the flood season (e.g. the old Aswan dam).
Given the lack of success of flushing regimes at other large dams, CYJV's prediction that nearly
the same amount of sediment will reach the coast with the clam as reaches the coast without the
dam is questionable in the extreme. It shoulcl be pointed out that in ICOLD Bulletin No. 59 section
6.3.2 it states: liThe accuracy and reliability of suspended silt and soLid bed flow data derived from
histoLical records should be checked by comparison with data from neighboring drainage areas
with similar geornorphologic characteristics." The section of volume 5 of the feasibility study W111Ch
discusses tbis aspect of the sedirnentation analysis has bad so rnany parts removed pursu,lnt to
the Access to Information Act that it is difficult to determine why CYJV did not do such d
There are many outstanding questions about CYJV's analysis of sedirnentdtion, particularly
whether or not a review of existing clata took place. The Terms of I\cference for the feasibJli
study include: "3.3 (vii) Prepare, input and analyse sedimentation data to provide an assessment
comparable to that of the Chinese sedimentation program" (Vol LA p 1-4). And yet, under
Compliance un:th the Tenns a/neference, the same vol ume says, "The 'ferms of Reference rela tee!
specifically to sediment, articles 3.3 (iv), (v), and (vi), have been met by CYJV" (VoiLA p 2-7). No
mention is made to section 3.3 (vii) which specifically requires an analysis of sediment<ltion datel.
Apparently such an analysis of existing sedimentation data did not take place. In the
sedimentation volume, although CYJV says that the llfield data used to construct and calibrate tly
physical models are especially important for [theJ Three Gorges Project,1I it admits that IICYJV did
not review these studies directli' (Vol 5 p 2-3). Despite not seeing them, CYJV concludes "that the
basic data are adequate and probably are better in both quality and quantity than are usually
available for a project of this kind.
CYJV also lists the main sedimentation reports prepared by several Chinese agencies and
research institutes. CYJV admits it did not even review these reports but concludes instead that
"A number of brief surnmary reports and publications from these groups were made available by
YVPUI (Vol 5 p 8-:3).
Since sediment can have a negative impact on virtually all dam operations including but not
limited to flood control, navigation and power generation, the importance ofCYJV's omission
cannot be overstated. According to lCOLI) Bulletin 59 section ().3.2 the "origin and reliability of 'il.
data should be checked to avoid reliance on basic errors which may have been introduced into
observation and data processing systen1s and procedures."
\Ve l'C'Cjuest that the mmittee determine whether or nol C:YJV eXal1lil1 imell[;lliol1
, and of what that data consisted. ]i' C;YJV faded to cornplete such an examination, we sugf;esl
this constitt.ltes negligence and professional misconduct pursuant to sections S()(1) and
86(2)(a)(b)(c)(cl) oUhe Code of Professional Conduct. We also suggest that the failure to clearly
point out to its client that the impacts of sedirnentation could not be determined without reviewing
and incorporating existing data constitutes professional Il1isconduct pursuant to section 8(-)(2)(0 of'
the Code of Professional Conduct.
B.6 Risk of Catastrophic Dam Failure
B.6(i) Increased Risk of Dike Failure (appendix B.1 p9)
We repeat that, contrary to what Acres claims, 160 km of downcutting is not II localizedII and the
protecti.on of the Jingjiang dike may require river training which has not been included in the cost
estimate (Vol 5 pp 10-2 and 10-3).
F'urthermore, Acres' statement that Ilwater level fluctuations downstream of Gezhouba will be
small II is contrary to its own findings which indicate that water f1uctuations may occur as far a\vay
as 40 km downstreanl of Gezhouba (Vol 1 p 13-11). The problem of increased undercutting
<.md erosion along this reach is likely to be compounded by the daily peaking po\ver now
fluctuation of between 3200 and 12000 m3/seconcl.
We suggest that neglecting to assess the potential risk of dike failure, and to include the cost of
repairs to these dikes in the project costs,n,veals negligence and professional misconduct
pursuant to sections 860) and 86(2)(a) oftbe Code of Professional Conduct.
B.(j(ii) Damages in the Event of a Dam Failure (appendix 111 p9)
In its response, Acres attempt.s t.o limit the issue ofdem) failure to t.he probability ofspillwclY
failure. This reinforces our point that CYJV failed to carry out a systematic risk analysis of aU
possible failure rnodes. As present.ed in section A above, some of the more serious omissions
include: seismicity, landslides, structural design, cofTerdam fail ure, etc. Such a systematic risk
analysis, according t.o ICOLD Bulletin No. 59 section 21.1, should include an emergency action
plan t.o Iideal wiLl), but. not be limit.ed to'l a series of measures including the preparation of
"inundation maps for flows up to the design flood, and for catastrophic conditions caused by dam
failure, inclusive of the corresponding risk analyses.
As pointed out in our section A above, CYJV failed to address the issue of dam design and safety.
It has also failed to assess the risk to human life and darnages that would result in the event of
darn failure. We suggest that failing to do so demonstrates negligence and professional misconduct
pUrS1Jant to sections 86(1) and 86(2)(a)(b)(c)(d) of the Code of Professional Conduct; incompetence
pursuant to section 29(3)(a) of the Professional Engineers Act; and a violation of section 91(2)(i) of
the Code of Ethics.
The risk of catastrophic failure of the dam as presently planned could easily be of the same order
of magnitude as the risk of a 1000 year flood - for the prevention of which the project is being
proposed. If the potential cost of dam failure 1 were included in. the assessment of the project it
would be clear that property damage would be so large that even with a 1 in 10,000 year failure
probability, any flood benefits claimed for the dam would be negated.
B.G(iii) H.isks Associated with Large Increases in Population (appendix 13.1 p10)
Acres has not add our allegation. As noted earlier, C JV predicts invesLment pel' square
kilometer and econolnic growth rates in the beach areas and flood eli version areas equal to that in
non-Hood-prone areas. In fact, tlleir estimate of f100d beneflts depends on such growth. To include
these areas in a floocJ benefit calculation is questionable (as already outlined) but to ignore the
increased risks to these people - who are being encouraged to move into the flood way of the clam -
is unacceptable for a reasonably prudent design.
l.Mark, RK., "Disasters as a Necessary Part of Benefit-Cost
Analyses," SciQnce, vol. 197, September 16, 1977.
1'1W13E IN'l'EHNA'l'lONAL
Eather than dealing with our concern, Acres provides information about the flood storage
capacity of the dam. As discussed in sections B.5(ii) and B.5(iv) above, CYJVs estimate of
sedimentation and the flushing ability of the dam is unrealistic. In fact, CYJV's projected
flushing ability is unprecedented and extraordinarily optimistic particularly given the
potential cohesive nature of the sediment in the Yangtze. The World Bank's Technical
Paper #71, Reservoir Sedimentation states:
Sediment f7ushing is a useflll method to fget! rid of the existing deposits. It becOlnes
nwre attractiue when the silting up of a reseruoir has reached an advanced stage. In
the future) it lulU find wider lise us sedinwntation or world rescruoirs hecomes worse.
The efficiency offlushing depends on the rate with luln:ch the d.eposits can IJe
reentrained hy the flow. Existing hnowledge) mostly gCLlned from lahorCLtory studies
and theoretical inuestigations) su.ggest that rate oj'reentrCLinmen.t Z>i reseruoirs i.uil! (ie
strongly effected by the cluy content oj' depos its)' 1Il.i7u'rcdogy oj' cluys CLnd chen/lcCLI
regime oj' !/)uter ... Processes oj' and relating to reel/troinment of deposits hewe !lot
lJeen. Investigated In. reseruoirs. Prototype research in thiS eJrea loll! he highly
CYJV based its reservc)]r seelimenL1tion analysis on a simpllst.ic 0111; dimension:!1 model
that ignores the complexities of now patterns in resel"\'OJr,; and ignores cohc:siol1 dCc:cLs or
fine sedimcmt. lfjust these factors alone were taken into account, it i,; extremely unli
that the fluslling predictions would be realized. According to the World BanI, Technical
Paper #71 lithe hydraulic and sedimentation processes in reservoirs are strongly threc-
dimensional and stratification can have a major effect on these processes ... A need exists to
develop more comprehensive mathematical models than the present one-eli mensional
We suggest that the failure to adequately assess the risk to people who move into the area
downstream of the project by underestimating the effect of sedimentation on the flood storage
capacity of the reservoir demonstrates negligence and professional misconduct pursuant to
sections 86(1) and 86(2)(a)(b)(c)(d) of the Code of Professional Conduct, and a violation of section
9l(2)(ii) of the Code of Ethics.
C. Flawed and Misleading Cost-Benefit Analysis
C.l Overestilllated Flood Control Benefits
Acres has not presented new information or arguments to rebut our evidence (as described in
Dwnnring The Three Gorges and our September 3, 1991 submission to the APEO) that they
overestimated flood control benefits.
Acres states in its May 8, 1992 response, that lithe flood control benefits attributable to Tep have
been conservatively estimated." We believe our two earlier submissions and section B of this
response illustrate how Acres, representing CYJV, has done the opposite by:
II misrepresenting the flood control capabilities of the Three Gorges dam in its feaslbility ~ ; t u d y ;
II exaggerating flood benefits in its May 8,1992 response to APEO;
Ii exaggerating flood benefits in its feasibili study by assuming investment and
development in flood-prone areas that would not be permitted in other jurisdictions in the
interest of public safety, and that \vould not spontaneously occur because of the obvious
risks to life and investments; and
Ling flood beneflts in its CCclsibility study by ignorillg disaster preparedn ss
For these reasons, we submit that l\cres engineers have failed to accurately evaluate the
flood control benefits revealing negligence and professional misconduct pursuant to sections
86(1) and 86(2)(a)(b)(c)(d)(f) of the Code of Professional Conduct, and a violation of section
91(2)(i) ofthe Code of Ethics.
C.2 Used an Unrealistically Low Discount Rate
Acres presents no new information to address this issue. Acres just states in its May 8,
1992 response that its base discount rate (10 percent) was determined "in consultation with
the Chinese Government and the World Bank."
However, as we stated earlier, since the World Bank's practice is to apply a 12 percent rate
of disccnmt in its economic appraisals a 12 percent discount rate should have been applied
to the Three Gorges dam. CYJV's failure to do so skewed, and thus exaggerated, the
project's net benefits (Vol :J table 7.3).
We suggest that Acres' choice of a 10 percent discount rate constitutes a failure to make
adequate provisions to meet acceptable standards, and therefore, dcrnonstrates professional
rnisconduct pursuant to section 86(2)(C]l of the Code of Professional Conduct.
C.;3 Used An Unrealistic Hate of Exchange
Tn Damming The Three and our September 3, 1991 subrnissjo)l to APED we describe
how CYJV's use of the adrninistered ange rate unden' ti !r1,1 the real cost of the dam.
Acres responded by changing the subject to the cost-benefit ratio, aI'!;uing tbat had CYJV
used a realistic exchange rate its cost-benefit model would "improve the economic viability
of the project as benefits increase more than costs."
But for reasons pointed out in section 13 above, in our September 3, 1991 submission to
A I ~ E ( ) , and in DanLming The Three Gorges, we believe the beneflts predicted by CYJV in its
cost-benefit model are biased, misrepresented and arbitrcu'ily calculated. As a result, its
cost-benefit predictions assuming different exchange rates have no credibility.
Acres response is irrelevant to our original point: if a free market exchange rate - which
reflects real costs - had been used, the estimated cost of the dam to the Chinese economy
wcyuld rise substantially (by 19.5 percent according to CYJV estimates, Vol 3 table 7.3). We
suggest that Acres chose to use the administered exchange rate to disguise the project's
total cost, thereby demonstrating professional misconduct pursuant to section 86(2)(d) of
the Code of Professional Conduct.
CA Overlooked, Unrealistically Accounted For, or Ignored Factors Affecting
Costs and Benefits
CA(i) Time and Cost Overruns
It is difficult to accept Acres' response that its feasibility study Ilfully documents the best
estimates of construction time and costs and the implications of time and cost overnlns"
when the studies on construction logistics were deferred to ComplemenLu'y Slllches \A/hich
were never completed. For this reason, we submit that CYJV does not have the necessary
information to conclude that the construction schedule it proposes can be achieved. Nor do
we believe the implications of its sensitivity analysis - cited in Dcunmlng The Three Gorges
were considered and ref1ected in the )'(;cornmendation to proceed.
Since the PlWI of Operation for the Complem.enrary Srudles recognizes that lithe Three
Corges project will be the largest construction project undertaken since the founding of' t.he
PRC,II CYJV should have satisfied itself that a project, \vhich is so vulnerable and
susceptible to time overruns, could actually be carried out. on schedule before issuing an
unqualified statement that lithe project as recommended is found feasible and financially
viable" (Vol 1 p 2-1). CYJV's failure to do so, we suggest, constitutes negligence and
professional misconduct pursuant to sections 86(1) and 86(2)(a)(d) of the Code of
Professional Conduct.
C.4(ii) Transmission and Distribution Losses
Acres claims in its response that losses in the electrical system are fully accounted for in
the load forecasts used in the economic analyses. However, the only references to
transmission losses we can find are in footnotes to Table 2.1 and Table 3.1, Volume 10, Part
LA, which state simply that transmission losses are included in the load forecasts. But no
estimates of those transmission losses, either in toted or broken down by region, are given.
VIe submit that Acres has not IlfuUy accounted" for the transmission losses, as it claims.
Furthermore, in the Province of Ontario engineers could not put forward proposals for the
expansion of the electricity supply systern \vitho1.lt detailed data on transmission and
distribution losses. CYJV's failure to do so suggests negligence and professionalrnisconduct
p1.usu,mt to sections 86( 1) and 86(2)(a)(d) of the Code of Professional Conduct.
C.4(iii) China's Shortage of Funds Not Included in His\{ Analysis
Acres has failed to address our point. Acres' argument, that an "important reason for
conducting the Feasibility Study" was to support applications to international agencies for
funding, is irrelevant. The reason for completing an economic risk analysis is to identify
various factors that would render a project uneconomic. As pointed out in Damming the
Three Gorges, CYJV's failure to consider China's lack offunds as an uncertainty in its risk
analysis is a major omission.
CA(iy) Cost of Decommissioning the Dam, Sediment Control and Dredging,
Repairing, Downstream Dikes
We suggest that Acres' argument that lithe project is unlikely ever to be decommissioned, II
cannot be substantiated in light of the many scenarios that would require early
decommissioning, for example, earthquake darnage, sabotage or acts of war, landslide
damage, and greater than predicted sediment accumulation. CYJV h'as not taken into
consideration the technical and financial requirements of a deactivation plan as outlined in
ICOLD Bulletin No. 59 section 23.1.
Acres claims in its response that "provision is made in the operating and maintenance cost
for periodic rehabi1i tation. II FIowever this "provision" is described in fou l' sentences (Volume
3, pp 4-13, 4-14), and refers to the staff costs of running the powcr plants, and the costs of
running and maintaining thc navigation facilities.
Meanwhile our evidence - that the costs of river training to correct channel shifting,
maintenance of dikes, and dredging the sediment from the reservoir, etc., have been
omitted - renlains unanswered.
We suggest that failure to take these costs into account consLiL1Jtes negligence "mel
professional misconduct pursuant to sections 86(1) and 86(2)(a)(cl) of the Code of
Professional Conduct.
C.4(v) Impacts of Inflation
Acres has provided no new information in its response.
48 -
C.5 Underestimated Resettlement and Environmental Costs
C.5(i) Environmental Costs
Acres argues that CYJV's allowance for environmental mitigation - equivalent to two
percent of the project capital cost - is "well in excess of any identifiable costs required to
complete the environmental impacts assessment, monitor the environmental effects during
and after cons truction and provide funds for mi tigation of unavoidable impacts. II
Since the environmental assessment was deferred to the Complementary Studies which
were never finished, we fail to see hO\v Acres can know that two percent is "well in excess of
any identifia.ble costs" of monitoring and mitigating environmental problems that have not
been studied or identified.
subrnit that Acres' method Cor determining the costs of monitoring and mitigating the
environmenta.l problems caused b.y the Three Gorges dam, is without scientific or economic
merit and constitutes negligence and professional misconduct pursuant to sections 86(1)
;wd S6(2)(;:\)(]))(c) of' the C:ode of'Prof'essional Conduct.
C.6(ii) Apparently Ignored Expenses
Acres' adrnission that inconvenience Lo waLer-borne transport \vill occur confirms our
complaint that CYJV distorted the cost calculations by omitting the cosL of disruption to
navigation downstream of Chongqing in its feasibility study.
Acres tries to justify omitting the $270 milJion compensation to the Ministry of
Communication for interruptions to navigation during construction of the dam on the
grounds that it wouldn't have affected the economics of the project lias it is a transfer cost
rather than a real resource cost to the Chinese economy. II By this reasoning many of the
costs of the Three Gorges dam - involving costs to state bodies - could have been similarly
ignored, and the dam's cost could have been falsely discounted even further. But the cost of
the Three Gorges dam to the Chinese economy, in the form of diminished navigation
activity, is real and should have been counted by CYJv.
These omissions, we submit, constitute a failure to maintain the standards that a
reasonable and prudent practitioner would maintain in the circumstances. We suggest this
constitutes negligence and professional misconduct pursuant to sections 86(1) and 86(2)(a)
of the Code of Professional Conchict.
C.5(iii) Lack of Socia'! Conscience in Project Optimjzation
response validates our complaint. Vie submit that trading off the public welfare J n
the interest of the highest net econonlic benefits constitutes professional misconduct
pursuant to sections 86(2)(b) and (c) of the Code of Professional Conduct and is a violation
of section 91(2)(i) of the Code of Ethics.
C.:5(iv) Underestimating the Jncrelnental Cost of Hesettlement
Acres' response confirms our original complaint that it did not assume increasing
diseconomies of scale in resettlement. Acres cites four resettlement cost estimates to
demonstrate it assumed that per capita cost of resettlement would increase as the number
of people resettled increased. However, CYJV's figures, shown in Volume 9, Figure 9.1
(attached as appendix C.1) do not demonstrate this relationship at all. From NPL 150 to
NPL 160, and from NPL 150 to NPL 170 the total cost of resettlement per person declines
cso -
even though the number to be resettled increases.
Furthermore, Volume 3, Figure 4.4 (attached as appendix C.2) shows that when
resettlement reaches its peclk for the recommended project - approximately 82,000 people
would be resettled each year from 1997 to 2000 - CYJ"V estimates that annual resettlement
costs would remain constant. Therefore CYJV has not assumed an increasing per capita
cost of moving people as the number of people resettled increases.
Both references demonstrate that CYJV has not recognized that stresses associated with
resettlement, and the miti[.;ating cost/person, rise exponentially w.ith the number resettled,
We submit that a failure to adequately account for these costs demonstrates misconduct
pursuant to section 86(2)(b) and (c) of the Code of Professiorlal Conduct and also violates
section 91(2)(i) of the Code of Ethics.
C. 5(v) Sedim.entation Effects Near Chongqinf';
Acres' defense - that the present va] ue of any incremental chunages caused by higher water
Ic\'(;)s resulting from sec]IJJ1Cnt deposition is so small CIS to be irr(,lev,m( in the cconomic
analysis - is based on a bedload estimate that is wildly at odds with other researchers.
CYJV estimates bedload to be 0.05 percent of total sediment, a generally accepted
estimate of bedload in large rivers is between 5-8 percent (see section B.5(ii) above),
gross underestimation of the amount of bedload has resulted in a severe underestimation of
the potential sedimentation effects at Chongqing.
As discussed in section B.5(iv) above, CYJV failed to cOlnplete an assessment of existing
sedimentation data. We therefore suggest that CYJV has failed in its sedimentation
- 51 -
---_..._---_..... _--------------------------------_.
analysis to demonstrate the dam will function as predicted, that the dam will not require
costly remedial measures, and that the dam will not change the existing sediment regime
in such a way as to risk the lives and property of hundreds of thousands of people.
We slJbmit that failure to carefully and thoroughly evaluate the effect of the Three Gorges
dam on the sediment regime of the Yangtze River demonstrates professional misconduct
and negligence pursuant to sections 86(1) and 86(2)(a)(b)(c) of the Code of Professional
Conduct, violates section 91(2)(i) of the Code of Ethics, and demonstrates incompetence
pursuant to section 29(:3)(a) of the Act.
C.G(vi) Treatment of Unregistered Population
'l'he llIlregistered or "Hoating population" accounts for between 10 percent to 30 percent of
the urban population to be resettled (approximately 27,000 to 80,(00) As pointed out in
The Three Gorges, and as confirmed by Acres in its response, CYJV used the
lowest possible estimate of IIf10ating population" in its compensation calculations, leaving
an indeterminate number of people to resettle themselves without compensation.
\\ (' s this constitutes pro ollal misconducL pursu,rnl. (0 sectiolls 86(2)(!J)(c) ,md a
violation of section 91(2)(i) of the Code of Ethics.
C.G(vii) Uncertainty in Numbers of Unregistered Population
Acres resporicls that "this matter does require further investigation and a new census," and
CYJV recornmends that one be done lias soon as a decision to implement the Three Gorges
Project has been made II (Vol 9 p 12-3). IIowever, since a new census could reveal
significantly more people deserving of compensation, and that by CYJV's own estimate this
52 -
additional population could increase the total cost of the project by 29 percent, we are
unable to understand why CYJV did not insist that a census be prepared first.
Failure to determine how many people would need to be resettled, and therefore what the
total costs of the project would be, seems to us to demonstrate professional misconduct and
negligence pursuant to sections 86(l)and 86(2)(a)(b)(c) of the Code of Professional Conduct
and violates section 9l(2)(i) of the Code of Ethics.
C.G Withheld Information
Acres' justification for withholding critical cost inforrnation further diminishes confidence
in its economic analysis.
rnilarly, Acres' deletion ofcruciCll information about the mathematical model used in its
sedimentCltion analysis is cause to doubt its veracity (Vo] 5A p 3-1, attached as appendix
3). Because sediment behaviour will affect flood control capabilities, navigation, and
po\ver generation, and could destabilize river banks, dikes and the operation of the clarno
the economic viahility of the Three Corges clam will be fundamentally affected this
('I'Llci ;11 clemen L.
.' :lJ
Do Other Major Flaws In The Three Gorges Water Control Project Feasibility Study
Dol Flaws with Resettlement
Documents submitted by Acres to APEO reveal that CYJV failed to demonstrate the
feasibility of resettling the people who would be displaced by the Three Gorges reservoir,
and thus failed to demonstrate the feasibility of the Three Gorges dam as per its Terms of
LJ nder the Terms of Iteference for the Three Gorges IVuter Control P7'OjectFeasibility Study,
CYJV was required to:
prepare un envi7'Onmcntai assessment which, Inter ulz:u) will ret/lew) evullwte and
recomnzend on the . . teeflnlcul and social feasibility oj'plans liJr resettlement of
Inlwhltunts und relocution ot lil.unlcipalz:ties, Industry) trcu/.spodatlon) etc. li'o711 oil
prq}ect areas.
T'hrec Gorges Feasibility Study. Terms of Eeferencc, June] G, 1986,
(Annex A of Exhibit I, Acres' Submission to
However, as explained in the Chronology of Activities on rI'hree Corges Fe,lsibiliLy Study
(Exhibit 1 in Acres submission), after reviewing the feasibility study draft reports at its
fourth meeting (September 14 to 18, 1987 in Beijing), the Steering Committee determined
that the IIfeasibility for EesettJernent could not be fully demonstrated wi thout further work
on land availability, non agricultural employment and irnpact on receiving areas and
populations. II
By January 22, 1988, the International Panel of Experts had reviewed the feasibility study
and reported that CYJV had complied with the Terms of Eeference, "except for problems
with resettlement, "
Tn order to cover this deficiency, Supplemental Terms of Eeference were incorporated into a
Terms of HeferCllce for Complementary Studies, The 'T'erms of Heference for the
Complementary Studies, signed on July 14, 1988, made demonstration of the feasibility of
the darn dependent upon first demonstrating feasibility of resettlement.
At the 5th Steering Comnu:ttee m.eeting, held in Montreal January Z8-23, Z.988) It 10US
conclu&:d that the dmftPeasibilityRcport on the Three Gorges Water Control Project
establishes the technical and econom.iccd fcasi/Ji1/ty of the project, subject to clear
demonstration of' the feasibiUt), and cost of resetilement.'/(emphasis addN! hy
Terms a/Reference Clnd Scope 0/ Work for Complementary Studies
Three Gorges IVater Control Project, February 4, 1988
(Annex A of Exhibit 1, Acres' ,Submission to APEO)
n Lo carry ouL these C'olllj)/imelltur\' Studies until ,'\'
1989, Yet in October 1988, CYJV issued Volume 1 of the Feasibility Study, and claimeclln it
This f('asibility stud,y has revlelued and ww,lyzed, 011 WI integrated basis, the costs)
bene/its and other effects oj'the oueml! prQject {rom. an International perspective. The
study has also sough t to address the concerns raised by the Steering COlnmittee
consisting CIDA Wid IBRD and its ]Janel 0/ Chinese CLnd interI2CLt!OIlO!
CYJV engineers thus concluded in Volume 1 of the Feasibility Study that II resettlement is
feasible at NPLs 150 and 160 assuming the financial and organizational resources
recommended are made available" and lithe project as recommended is found feasible and
financially viable
and "should be carried out at an early date.
Probe International suggests that CYJVs failure to carry out the Terms of Heference and to
warn its clients and the public of this failure's implications, and CYJVs subsequent
recommendation that the project is feasible and financially viable and should be carried out
at an early date, without demonstrating that resettlement is feasible, constitutes professional
misconduct, negligence and incompetence pursuant to sections 86(1) and 86(2)(a)(b)(c)(d)(f)
of the Code of Professional Conduct, section 9l(2)(i) of the Code of Ethics and section 29(3)(a)
of the Act.
Further evidence of Acres' ignorance about the feasibility of resettlement is found in its
J'(;sponse (,Subm:ssiol) 13, D.I) when; it indicates that only "sample areas
along the reservoir
were inspected and where it states ambiguously that "land is likely available to
accommodate the farm-based resettlement plans.
(emphasis added by complainant)
/\s for t.he aLLit.ucle of populations to be affected by Uw resettlement scheme, we direct tbe
Complaints Commit(;ee to our September 3,1991 submission which remains unansvv'cl'ed by
D.2 Inadequate Environrnental Assessment
Acres has failed to address our evidence - described in Dam.ming The Three Gorges <'md in
our September 3,1991 submission - t.hat its environmental assessment is "fatally flawed_"
{-j () -
Furthermore, the logic in Acres' argument to the APEO, that the Three Gorges dam is
environmentally feasible "providing that identified discreet gaps in the data base are fillecV
essential studies are done, and an "ongoing environmental monitoring and mitigation
program is implemented" is indefensible. No scientist can seriously declare his experiments a
success prior to obtaining the data, and doing the studies. As for mitigation, the reason to
conduct an environmental assessment before a project goes ahead is to determine whether or
not the costs of lTlitigation would render a project uneconomic.
Uy declaring the Three Gorges project "environmentally feasible" when neither Acres nor the
Chinese government have fllled the minimum requirements of a credible environmental
assessment, Acres demonstrates a profound misunderstanding of the nature and purpose of
environmental assessments and a profound disregard for the people whose livelihoods and
health wi]] be affected by the environmental consequences of the dam. Moreover, Acres'
;\rguments to the AT)EOmake a mockery of the scientific method.
suggest, as pointed out in secLion C.5.1. above, that Acres' method for determining the
costs of mOIl itoring and mitigatin[; the environrnental problems caused by the rrhree Gorges
d;un, is without scientific 0)' economic merit and constitutes negligence pursuant to section
1) of the Code of Prof'e:;sional ConducL. declaration that the Three (!elm
"environmentally feasible" in the absence of information to substantiate this claim
constitutes ll)'ofessional misconclucL, negligence, and incompetence pursuant to sections
] I, 8()(2)(a)(b)(c)(d)(f') of the Code of Professional Conduct, and :'1 \iolation of section
29(3)(a) of tbe Act and section 9l(2)(i) of the Code of Ethics.
Appendix A.I
A review of the dam safety analysis of the erDA Feasibility Study of the Three Gorges Project
Philip B. Williams Ph.D, P.E.
The consequences of failure of the proposed Three Gorges Dam would rank as history's worst
miln-made disaster. More than 300 million people live downstream on an intensively cultivated floodplain
that provides much of China's food. It is therefore reasonable to expect thilt a key design criterion for the
project is ensuring that the risk of failure is kept extremely low.
Because of the limited operating experience with large dam projects of this type, and the record
of safety incidents that have threatened the integrity of large dams in the last two decades, it is reasonable
to expect that the feasibility study wi]] utilize the best available techniques to demonstrate that the design,
construction, operation and decommissioning of the project will keep the risk of failure acceptably low.
Unf'ortunately, the feasibility study does not address the safety issue systematically or coherently.
It provides no acceptable risk criteria, no mapping of' the area and population at risk, no comprehensive
risk assessment that identifies all the potential failure modes, no identification of fail-safe measures.
BCC,Hlse safety is not analysed as a discrete topic, major failure mechanisms or combinations of failure
mechanisms are ignored. There are many such possibilities, for example, a reservoir-induced earthquake
that inillilks new landslides close to the dam or sabotage or military acticlil that disables spillway gCltes
immcdiately before the flood season or unanticipatecl delays in construction leading to the overtoppng and
washing out of one of the cofferdams.
Where some safety issues are discussed in different sections, major assumptions are made whose
effcct is to incrcase the risk of failure of the dam if the project is constructed as planned. The probable
risk of failure is likely greatcr than the one in 1000 year flood for which the project is designed.
Examples of these optimistic assumptions are:
1. .LInderestimation of earthquake ground acceleration
One of the most important structural design criteria for a dam is the estimation of ground
acceleration in the event of what is termed the maximum credible earthquake (MCE). There are
substantial uncertainties in the selection of the MCE and also in the prediction of ground accelerations at
various distances from the fault.
For the Three (Jorges design a 6.5 magnitudeearthquake OCCUlTing on a fault 17 km away was
selected (Vol 4 p 4-6). (It should be noted that the methodology used is ICOLD bulletin 46 based on US
Bureau of Reclamation procedures. Within the US these procedures have been frequently criticized by
engineering geologists as too optimistic in estimating MCEs.) For this MCE a horizontal ground
acceleration of 0.17 times gravity (g) was estimated as a "starting point for safety evaluation"
(Vol 4 p 4-7) and a vertical acceleration of 0.1 g simply estimated at 2/3 of the horizontal acceleration
value (Vol 4 p 9-8).
Even with information provided in the study this assumption represents the most optirnistic
interpretation possible of likely ground acceleration. Fig 4.2 of Volume 4 shows the range of different
estirnates to be between 0.17 and 0.5g. Experience with California earthquakes indicates that even this
upper limit may be optimistic, with 1.0g ground accelerations measured at the Pacoima Dam during the
6.5 magnitude San Fel'l1anclo earthquake, and vertical accelerations of 0.6g measured about 20krn away
from the 7.1 magnitude Loma Prieta earthquake, as compared to the 0.12g that would have been predicted
using the feasibility study methodology.
A reasonably prudent design to ensure the integrity of the dam would use ground accelerations at
least three times higher than those selected. If 0.5g is used it appears that the return frequency of the
maximum earthquake for which it is designed will be exceeded every 200 years instead of every 20GO
years as intended (Vo] 4 fig 4.6).
2. InadeguatQ.-,'lnal)'sis of Reservoi(:lllduced Sei;;I]lici ty
While the study recognizes that the dam's reservoir can initiate earihquakes, in developing
ground acceleration design criteria only histodcal records of earthquakes are llsed. This means that the
design acceleration selected are likely to be too low ai1CVor occur more frequently than expected. In
addition there appears to be substantial uncertainty regarding movement of the most important of these
faulls as the "need for careful assessment", that presumably has not yet been undertaken, is stressed
The treatment of reservoir-induced seismicity (RIS) is cursory and does not appear to recognize
the seriolls potential for damage to the dam that can occur. For example, the Koyna Dam in India initiated
approximately a 6.0 earthquake, ki1Jing 200 people, in an area that had not previously been seismically
active. The study appears to assume that RIS occurs only on faults that are presently proven active, and
implies that only shOJi lengths close to the dam site could be activated (Vol 4 p 4- 16). It does not identify
the length of identified faults passing under the dam itself (Vol 4 p 3-9) or the displacement that would
occur if these were activated. It appears that the dam is designed based on the optimistic assumption that
ll.Q movement will occur on these faults.
Even assuming the optimistic estimates of ground accekr'atio!1 during earthquakes, it is cle,lr thal
there are substantial unanswered questions related to the structural design of the dam whose satisfactory
resolution can add appreciably to the cost of the project. The structural analysis indicates tensile stresses
in the upstream face of the dam (Vol 4 Table 9.5). While it is not clear whether these are predicted to
cause cracking, because of what appear to be conflicting assumptions regarding the tensile strength of the
concrete during extreme load conditions (Yo] 4 p 9-19 and 9-12), cracking would almost ceriainly occur
with more realistic assumptions for ground acceleration. It is recognized thal even higher tensile stresses
would occur in the upper part of the dam but no dynamic response analysis of the dam has been canicd
out to identify where cracking could occur and what design modification needs to take place
(Vol 4 P 9-19).
Cracking can also occur due to inadequate control of temperature during placement of the
concrete. Because no comprehensive assessment has been carricd out, many possible failure modes have
not been analysed, including the performance of the dam during an earthquake with prior cracking;
dynamic loading from landslide-generated waves; higher than projected siltation levels; and rupture due
to fault movement underneath the dam.
4. mation sks.c.:ausecl by catastroJ2.i:lLc Iands lid ing
Although the risk of landsliding into the reservoir is discussed in the feasibility study, the threat
to people living around the reservoir and downstream and the threat to safe operation of the dam is
greatly underestimated. The seriousness of this issue is indicated by the experience of the Vaiont Dam
where a landslicle-generated wave killed 4000 people. The study has carried out no systematic analysis of
hazard zones at risk from the waves 20 to 50 m high it estimates could result from individual landslides
(Yol 4 fig. 5.1), but clemly tens of thousands of people living within and adjacent to the reservoir would
be killed by such events, which apparently occur at intervals in the order of a decade. (Apart from other
optimistic assurnptions, the analysis has mistakenly assumed [hat all people living in the reservoir will be
relocated above 182m.)
The feasibility study has not investigilted the effect of earthquakes, including those induced by
the reservoir itself, on ilctivating landslides on slopes it hilS rated as stable. Its conclusion thilt "no
significant change in slope stability will occur due to the project" (Vol 4 p 5-11) is highly questionable
considering the effect of reservoir level fluctuation, even on those slides whose toe is pemlanently
submerged in the reservoir. Nor has the study evaluated the effect of impilc( of landslide waves on
spillway gates at the time of rapid drawdown immediately prior to the flood season.
5. Underestimation of risk of spillwa:Lfailure
As the largest hydroelectric darn on the world's fourth-largest river, the Three Gorges project
incOlvorates many experimental technological innovations. One of these is the construction of the world's
largest spillways, each with a capacity of about 2200 m3/sec, the average flow of the Missouri River. The
study confidently asserts "there is no reason to believe that these structures could not be successfully
designed, constructed and operated" (Vol 4 p 12-7), even though the discharge per unit width is "weJl
beyond proven world experience". This confidence is undercut in the same paragraph of the report which
states "The feasibility of such a high unit discharge should be reviewed during final design",
In fact the limited operating experience of extremely large flows through such spillways indicates
a high possibility of failure due to cavitation and erosion caused by the extremely high velocities and
pressures that can threaten the integrity of the dam, as has occurred at the Tarbela, Glen Canyon and
Hoover Dams. With the Three Gorges Project it is possible that these problems will be aggravated by
abrasion from the high sediment load carried by flood flows.
Anothe;r questionably optimistic assumption is that minimal erosion and predictable scour
patterns downstream of the dam relying on the "good ancl homogeneous quality" of the rock in the plunge
pool area (Vol 4 p 12- ]2). Again, actual operating experience with scouring during very large flows over
spillways is vcry limitecl but il](licates a significant pussibility of failure that can threaten the integrity of
the dam - as again nearly occurrecl at Tarbela. Continual remedial works to correct scouring can add
significantly to operating costs of the project.
5. F,lil1!xe to cofferdam failur:f:
During the construction of the project a series of temporary cofferdams will have to be
constructed across the river. In Phase II a rockfill cofferdam will store about 1 km] of water to elevation
90 and is designed to withstand the 100 year flood "uncleI' emergency conditions" (Vol 4 P 1-8).
In Phase III of the project a temporary, rolled concrete cofferdam wm be constructed that will
impound about 12 km3 of watel' to elevation 135 (Vol 4 P 8-30) for a period of 4 years - although it is
uncertain whether an 85 m high dam can be constructed in the 5 month period allocated for it. This
cofferdam is designed to withstand the 200 year flood "under emergency conditions
(Vol 4 p 1-9).
If larger floods occur these cofferdams can qu'ickly wash out, releasing a large flood wave with
flow rates exceeding hundred thousand cubic metres/sec that would overwhelm the Gezhouba Dam
downstream whose reservoir capacity is less than 1/2 km3 (Vol 4 appendix A p 1-3). The flood wave
would continue downstream, probably overtopping the Jingjiang dyke downstream drowning hundreds of
thousands ofpeople. (Such a cofferdam failure OCCUlTed in 1986 on a much smaller scale in the US when
the Auburn cofferdam was washed out in a flood, releasing about 0.15 km3 and a flood in the order of
20,000 cubic metres/sec, but fortunately the downstream Folsom reservoir was able to contain the flood
'1'he feasibility study estimates, based on an optimistic construction schedule, the probability of
such a catastrophe to be 3% for Phase II and 2% for Phase 11T, making a total probability of about 1 in 20
(Vol J p 18-6). Such a risk should be considered unacceptable.
The risk of failure of the darn increases with its age as construction materials deteriorate,
mechanical systems such as spillway outlet gates fail; and the effects of a series of problems - such as
cO!Tosion, abrasion, siltation, and downstream scour - accumulate.
The planned economic lifetime of this project is 50 years, whilst Chinese culture has lived with
the Yangtze for 4CX)() years. Whether the physically safe lifetime of the. project is 50 or 200 years,
provision should be made in the feasibility plan for decommissioning the project in a way that ensures the
safety of those living downstream.

Ph.D, in Hydraulics, in fluvial sediment hydraullcs,
University of London, 'Ux[jversity College Civil and MunJdpal Eng:lnwnng
Department, United Kingdom,
Bachelor of EngJne--efing in ClyJ1 and Structural Enginooring,
Sheffield Univorsity, Civil Engineering Dtlpartment, Unitoo Kingdom
Civil Bnglneer No, 21483 (OJUfomia)
American instltuto of Hydrology, No, 359
European Engineer UK;ICE 182
Chartered Engineer 473117"50 (UK)
Philip WillIams & NsocietCB, Ltd,
Le<:turor in El1vironmental Planning
Dept. of Landscape Architecture, University of l...sliforniB., Berkeley
Dr. Philip B. WillIams, P,E.
Consultant in HydroIQl.D', San Francisco, California
Sonior Associate
Environmental Impact Planning Corporation, San Francisco, California
Mnlor Englneor
Bechtel, Inc., Plpe1!no Division, San Francisco,
Dr. WU!lams hU8 been engu.\:od in u wide range o( hydrologic lind engineering work sinCXl
ho hit Ph,D. and emigrated to ll1c u.s, In 1910, In 1976, he started work 8.5 (\ priV(jie
consultant,,forming Philip WJ11iams and Associates in 1979, Itt thels.at two decadet\1 he has developed
considerable expertise in II wide Tange of technIcal ll;SUes as well ali wHeT-relatoo policy l&ilue.s both
in the \).S. Hnd abroad. From his orlgingl research field of sediment hydrauIICtl, Dr. Williams bNJ
pioneered practiclll techI\ksl analysee In wetland hydrology, rIparian zone hyd.raulic:s, lake water
bllianees, the of climate cbange, and estuarIne Inflow management. HiB work h.M covered 8.
wide variety of probJel)'ls, IncludJng delineation or flood hazards, l\rrul)'jis of SCI! level rlsel Balt marnh
restoration de:ilgn, anal)'1Si.s of reservoir operatlon, harbor maintenance dredging pla.lU, watershed
sedlment yield analysIs, groundwater management plam, and coastal lagoon restoration.
Much of thi.., work hllZ been related to anrdyzJ.ng the e1lVlronmental effecU of hydrologic changes, and
tha has often involved working with ptOfessionll.l& of other disciplines to prepare feahibility Btudles,
mllnagemertt plans, or environmental impact slUc1{es. He hll8 directed and participatoo ill more than
250 !Such 5tu(1lcs, projecu OIl flODd control, wetland residential
national park plans, water rcsouro::-s development, nod estuarine managcIDGnt plans.
A.ni<.:ri,can Society of Civil Engineers
In,stitute of Civil Enginccr:J (UK)
Americ.an Water Associntion
Society of Ecologic Restoration and Management
Alncrle<ln Shore &. Beach Protection Society
Association of SCientists
US COmmittee on urge Dams
International Water Resources Association
Association of State Floodplain Managers
Associntton of State Wetland Manage:rr,
EstuarIne Research Federation
Williams, P.B" 1991. TIle esse against large dams, Civil Engineering, ASCE, New York. Augns( 1991.
W1!llams, B,B" 1991. Rivers 'lnd pllfnming the flow. 1n: J. Porritt, e<L, Save the Earth.
Thruer PublIshIng, Atlanta, GeorgJa.
Abbe, T, P. Goodwin, and P.B. Williams. Marsh erosion by wave action in Corte Mwiera Bay.
CDustal Zone 91 Conference Proceedings, Paper No, 245.
Abbe; T.;P.B. WllliHmJJ, and P, Faber, [n pro8s, Monitorlng thc physical 'I'1'thud
restoration proJCGt5, Co1l5ll;l1 Zone 91 COnference Proceedings, POHer-Puper No. 911.
Goodwin, P, and P.B. Williams, Short-term characteristics of coastal lagoon entrances [n CaliforrtilL
COl.\stal '91, SymposIum on QuantitatIve to l.-afistill Sediment. ASCE, Seattle,
WUliUlIlJ5, F,B., 1990. Chapter EIght, "Flocx.1 control analysIs,' and Chilpler Ten, "Dam safety anruY5i5,'
Ln: 0, Ryder (od.)" Damming the Three OorgCl\. Probe InternatIonal, Toronto, canada.
WHlialIlJ5, F,B" 199D, Rylhinking flood cor1Lro] channel design, Civil Engineering, ASCE, Now York,
January 1990,
Flof$heim, J,L. tlud P.B. WjllialilA, 1990. F100d loss reduction and erosion control. FapN pre&lnted
at The Coumry [n the City Sympmlul11, Portland, Oregon, April 1990.
COtlt5, R.N" M,L Swanwn, and P,B, Wlll!i.1ffi.'l, 1989. Hydrologic analysis for coi\JltB.l wetland
Pagfl 3
te1ltoratIon, Environmental Mllllagement, Vol. 13, No, 6,
Williams, PoB" 1989, Managing freshwater intlow to the San Francisco Bay Prc>eeedittgs of
the Fourth International Q:>n.ference 011 :Rogulated Rivero, Regulated Rivors, Vol. 4, No, 3,
Septomber 1969, .
Williams, P.B., 1989, Adapting water management to global clImate change. Villnch
ConkrenC{] on Developing Policies for ManagIng the Effects of Climate Change, Sp6Cial Issue of
C1imaUc C;:hange,
Wil liBmE, PoB., 1989. Rewrltlng CallfornIa's water plan. Bay Alert, January 19:89, Bay In.stltutc,
Wllljams, P.B., and MoL Swan.lOn, A new approach to flood protection design and ripariun
management. Procee<ilngs of the 2nd Otlifornia Riparian Systems Conference, 1988.
Williams, P.B" 1988, tile 1mpac't ot climate chango on San Francisco Bay, Proceedings of tilt Second
North American Conference on Proparlng for Cllmate Chnnge, DeccmbN 1988, Climate Institute,
WashIngton, D.C
WIlliams, P.B. and J. Morrison, 19-8& Warm Springs Marsh fe8toratioll, an e;xample of creative
miligatiort Proceedings of the National Symposium on Wetlands '88: Urban Wotlands and RiptlriRn
HabItat. Association of SWte WetJand Managers.
WIlliarrus, p,a and J. Galton Oale, 1988. Integrating tidal wetland restoration 1n coaswl flood bwsin
design - the ox.umple of Shorebird Marsh. Proceedings of the NatJonal SympoBlum on Wetlancil; '88:
Urban Wetlllnds and Riparian Habitat. Nsoc1l.1tion of State Wetland Mnnagers.
Williamll., P.B., A Shepherd, alld P. 1988, Monlwrlng a tlc.1B.l restoration site In San Ffllncilico
Bay" the Muz:z.i Mar:;h. Proceedings of the NatIonal Symposium on Wctll1ncM '88; Urban Wetl,mds
and Riparian Habitat. Association of State. Wetland Managers,
Williams, P,B, und M, How much fresh water doos San Francisco Bay need? Waterfront
Age, Vol. 4, No, 2, Spring 19&8..
Williams, P.B" M. J05se.lyn, 'and F. Wernette, 1987, River flow, salinity, and vegetation in
the managed and unman,<lged wetlands of Suisun Marsh: Paper prC\'3onted to the 9Lh Biennial
International Estuarine Research Conference, Now Orleans, October 1987.
Haltiner, J,P. and P.B, WlUJams, 1987, Hy(Jraullc design for salt lIHmh restoration. Pupe.r presented
at the 8th Annual Meeting oUhe Society of Wetland Sclontists, Seattle, WashIngton, May 1987,
Wllliam&, P.B., 1986, HydrologJc for coastal wetland restoralfon, Proceed!ng;s of the Sceond
A5s0datlon of Slale Wetland Managct.l SymposIum on Mltigatlol1, New Orlean3, October 1986.
Williams, PoB., 1983. Damming the world, Not Man Apart., VoL 13
No. 8, OetobN 1983.
Wllliam, P.B. and T.R Harvey, 1983, calJfomln coastal &ult m8r1ih restOration design, ASCB Third
Symposium on coastal and Ocean Management, Coastal Zone 83, June 1983.
P8gB 4
WI11!ams, P.B, and E, Areru, 1981. Wind and buIlding energy m1l5umption: an overview. ASCE
Conferenoo Preprint 81128, New York, May 1981,
Williams, P.R, 1979. The ErR procC8:J 3S a tool for implementing flood plain management policJes.
Proceedingn of Flcxxl ('.A) 11 ference, Sacramento, CaHfomin. C.a1iforniR DepL of Water
Resources, Rep. #44.
WilliUffil$, P.B., 1978. Darn design: is (he technology faulty? New February 2, 1978.
WIlliams, P.B., 1977, Taking another look lit clC\:trjcul gy8tem reliability. Public Utilities Fortnightly.
MRrch 17, 1977.
Williams, P.B. and P,H. Kemp. The initIation ofBcdlment ripples from artJflclal disturbances. ASCE
Dlvi5ion Journal. Junc 1972.
Wllliams, P.B. unci P,H, Kemp. Tho initiation of sexl!meot ripples on Out so.nd beds. ASCE
Hydraulics DlvJslon Journal. Aprll 1971.
Williams., P.B. a aI., 1970. Deposition velocftJes, transition Yclocilies, llnd spatial di5tributi0l1 of solids
in slurry pipelines, I-IydrotraDsjX)rt 1 Proceedlngs
Coventry, England,
Appendix A.2
0,6 ---,------------,.----------,--,----------------
2 150 100 80
Arnbraseys (1978)
Campbell (1981)-Average
Schnabel and Seed (1973)
From Figure 4, I
Esieva and Villaverde (1973)
20 10
o ~ + - - - - -
, Appendlx A.3
The potential ns associated with dams.: of stmcD.H"al components and
sOcio-cCDnom" ic The structural components of potential risk clepend
mostly on stqrage and on the height of the d.am, as the potentia) downstream
consequences are pr portional to the mentioned vs.lues.
Socia-economic risks can be expressed by a number of persons who need to be
evacuatedJn CClSt: 0 dunger and by potential downstream damage.
It is possible to ate the potential r1sk by weighting tbe mentloncd components,
n.ssociatJng a larger weighting factor 'to dams with larger storages, posing larger
evacuation rcquiren and entailing larger potential downstream d8TTlagc. In this
way a risk rating ca 1 be formulated and subdivided into different classes, ranging
from low to cxtrem ,
It should be ke::>t in mind that tbe above mentioned weighting or risk compo-
nents, and espcciall, the soci "e,cOIIOD11C risk components, are assessments based on
judgement aDd fen the lInpacr of the .socia-economic environment. Different
countries wilt there 'ore find it necessary to adapt the soclo-ec-Dllomic risk contri-
bution to suit reyuiling circumstances. The foregoing consideratloDS caD be
used as general gui Jance in this respecT.
The t\Yo following 'fables arc convenient to rate the risk iissociated with (bms
FOUl risk factors a e separately weighted as 10\\1, moderate. high or extreme:

;., ]20 120) I 1-0,/ 0,]
(6) (4) i (1) (0)
,I > 45 45-30 I 'J 0- 15 <. I 5
(6) (4)! (2) (0)
> j aoo 1000100 I 100-1 None
(l2) (8) II (4) (0)
Wgh lv\odcr atc Low NOlle
(J 2) _
Height (m)
Evacuotion Req jirerncnts
(No, of persons) ".".. """.
Potential Downstlcam Da-I
mil ge
-_. ") ,i,k (weighting poi"") .. .
- .. ..._,--._- ---/_....._..
cit)' (hrn
) +'"''
] II
.__...__.._ ..__ .. ..._ . ._ .. __..,. , . .__'._ ..__.. '_..__'._, __--0_._. _
Nt: SAHD b
CP. .... liiTE
- I)
LOA;) "'TfH HO
.LUlo'il.H..t - l,;A,H:
(EL .... O t)
(EL 56:+:)
CIPM Yangtze Joint
. MARCH 1988 J

." ..."


Appendix A.5
!2 16 20 2'4 27
If) N
:;:;: If)

24 20 16 12 8 4 Xintan 4 8
A - Calculated wove for 16 x 10
(Water Level = 150m) at lOOmis
8 - Physicol model test result for 16 x 10
entering reservoir
(Water Level = 130m) at 67 mls
C - Observed wove from June 12,1985 slide with 1,6x 10
entering reservoir
(Waier Level = 66m) at 31 mls
Volume 4
Appendix A.6
-" - -------
-------------.- ---
LEVEL (m) (km
) LEV El_ (m) (km
---_.. -_._-
110 4.60 140 14 .70 170 34.40
111 -
4.75 141 15 .16 171 35.32
112 4.91 142 15.62 172 36.27
113 5.09 143 16.09 173 37 .23
114 5.29 144 16.57 174 38.22
115 5.50 145 17 .06 175 39.22
116 5.7= 146 17 .56 176 40.25
117 5.98 147 18.07 177 41 .29
1U3 6.24 148 18.60 178 .36
6 ,- 1
149 19.14 179 43.46 ::J
120 6.80 150 19.69 180 4
121 7.11 151 20.27 181 45.71
122 7.43 152 20.87 182 46.87
123 7.76 153 21 .48 183 '13.06
1 8.10 154 22.10 184 /19.28
, ,) 1-
8.45 155 22 .74 185
126 8.81 156 23.40 1136 51 .80
127 9.17 157 24.0(3 187 5:3 . 10
12Ll 9.55 15Ll 24.77 188
9, 159 25 .118 189 55.80
'\ .--,,/"\
10,33 160 26.20 190
5;' .20
! j ')
10. :; 3 161 26.94 191 . b3
132 11 . 14 162 27 .70 192 60.10
, l. ')
11 .56 163 2Ll.47 193 61 . GO
1 J.J
11 .99 164 29.26 194 63.1
135 12 .42
1 C' C
30 . en 195 64.72 .0 :J
136 12.87 166 30.90 196 66.33
137 13.32 167 31 .75 197 67 .99
138 13.78 168 32.61 198 69.68
139 14.24 169 33.50 199 71 .41
..------------- -------_.----- ,---------"-----..-- ---------- - ------- -
4A - 1--- 2--
Table 1.1
A.6 can't
(m) (krn
60 0.14
-- 1--3 --
o. 1 9
Table 1.2
A.6 con't
The difficulty of achieving this schedule Is
discussed In Volume 2, Section 4.4.2 and Is
common to aJi altematlves. It Is CYJV's opinion
that wn:h adequate equipment, preparation and
training of key f)BrsDnneJ it is to construct
the RCC cofferdam within the time allotted. There
will bB no difference in the common construction
problems PDsBd fOf any alternative.
Proposals fOf different tyPBs of cofferdam are
mentioned In Section 8.1 of this volume. However,
thes("1 options would restrict navigation capacity
during construction and have not boon considered
for this feasibility study.
.2 Right Bank Intake Dam and Powerhouse
scheduled for competlon by the time the reservoir
Is raised to Its intermediate level of EI130 in JUly of
Year 12.
The excavations for the permanent shipi(s
(23 379 000 m
for the YVPO Base Scheme) are
the most difficult on the project. They have very
high rock cuts that call for careful coordination of
SUppDrt work. The open-cut work will have to be
carefully coordinated with the underground
The major drfferences in the prrnanent shiplocks
for various NPLs arise from changes in the height
of the head works, the numb! of locks and the
height of the lock walls. These are summarized in
the following table:
Dilm Oest CDp<l to Invert

t-----__ W;'-IL;'-I'... Lo
"Pk ..
YVPO Base 50 175 50 32.5 4D I 40 I 40 --.
I Ait. 1 50 185 60 32.5 I 40 I 40 i 40! --!
I All. 2 60 1 I 60 38 I 36 I 36 f 36 \ I
I .. __ J ..
The Increased length for five locks instead of fOlif
means more work but not more difficult work. While
construction of the permanent shiplock is a rnajor
undertaking there Is a time available for
construction even with an additional lock.
Lock Walls
Head Worb
DCL NPL Arrangement
Construction of the right bank
Intake dam In Stage III Is
possible within the time
scheduled by YVPO. However,
the rlgtit bank PDwerhouse civil
construction and Installation of
tudJlnes and generators Is
JUdged to require the same
overall duration as the lefl bank
powerhouse, 47 months from
tilE) start of powerhouse civil
construction to opmatlon of the
first unit. This means a six
month extension of the
schedule fOf first generation at
the right bank p0Wertiouse and.
IS to all schemes.
18.3.7 Navigation Facllitleg
_... ._--- ----
18.3.8 Schedule Risk
The probability of completing any phase of
construction on time has been estimated (see VoL 2
Section 5) and is shown below:


Preparatory Phase- .98-
Phase r .
Phase.I!.... .
Ph.a.w< fli to<
Pro{ec1 .96
CumulaUv8 .'
ProbabiHty .87
Construction of the permarH:lnt shlplocks Is
. 1 TemPDrary Shlpock
The construction equipment proPDsOO by YVPO Is
surtable to build the temPDrary shlpock In the
avaiiable time. The CYJV recommendation to
Increase the range of operating levels, would
require a gr8<lter volume of concrete to be paced.
This can be accommodated within the same
schedule and construction pan.
.2 Shlp/ft
Shlpift construction as scheduled by YVPO for its
Base Scheme Is Judged to bB practicable but not
economic. The CYJV alternatives do not Include
a shlpHft. ThIs Is dlscussBd In Sec1lons 8 and 12.
.3 Permanent Shlpocks
Volume 1 - 18-6 -
A review of the nood control analysis of the erDA Feasibility Study of the Three Gorges Project
Philip B. Williams Ph.D, P.E.
Although most of the economic benefits claimed for the proposed Three Gorges Project are
forelectricity generation, in the public arena the dam's advocate have claimed flood protection as the
pri mary need for the project. It is freq uen tl y stated that unless the dam is bui 1t, catas trophic flooding will
occur downstream on the middle reaches of the Yangtze floodplain, affecting millions of people.
The feasibility study's role, therefore, is to provide an objective and systematic analysis of the
changes in flood risk provided by the dam and to demonstrate that the project would be the most cost-
effective approach to providing additional flood protection. For a project of this magnitude - one of the
world's largest civil engineering projects, which can potentially affect hundreds of millions of people - it
is reasonable to expect that such an analysis would be accurate, use the best available techniques, and
havc a consistent methodology.
Unfortunately the study does not achieve these goals, for the following reasons:
I . EUIVir:&C2LtIJC:J2LQjl;;.i,;J jSj1Ji Srevu:se J 1 K ~ t
In the summary of the feasibility report (Yol 1 sections ].2 and 1.4.4) which is presumably
written for funders and key policy makers, it is stated that the project's main flood control function is to
protect 20,000 km2 of downstream floodplain inhabited by 10 million people. But throughout the study
there appears to be confusion over the main flood control goal; for example, in the volume summary (Yol
4 p 1) it states that the project "can provide flood protection to approximately 1 mil1ion km2"; but
elsewhere (Vo] 7 p 1-21) it states more precisely that the "primary flood control objective of the project
and its operation must be to guarantee the integrity of the major dykes protecting the Jingbei Plain and the
Jingnan Region" - an area of 6700 km2 (see Vol 7 table 9.2).
The computed flood benefits described in the detailed technical analysis do not substantiate even
the least grandiose of these statements. In the benefit analysis the average reduction of flood area is
claimed to be about 4000 km2 (Vol 7 fig 1.4) but this nurnber itself can be misleading. About three
quarters of the benefits claimed for the project are attributable to the reduction in the frequency, anclnot
the elimination, of flooding of just three areas - two overflow diversion areas and thefloodway area
adjacent to the river channel between the dykes (referred to as beach areas). Only about 10% of the f10exl
benefits are attributable to protecting the highly populated Jingbei Plain and Jingnan region (Vol 7 table
1.5) yet the flood control storage and operation is designed specifically for this 10% (Vol 7 P 1-10).
Only a detailed reading of the study reveals that the project goals and operational design of the
project are not as stated, but instead to upgrade protection for the Jingbei and Jingnan regions from the
current 250 year level to lOOO year f]oodlevel (Vol 7 p 9-10, table 9.2). This means that the flood control
operational design is not based on an objective benefit/cost analysis, but on a subjective judgment that
these areas require levels of protection higher than the 250 year flood (Vol 7 table 9.2).
2. 1.J n
The feasibility study has recommended an opel'ational plan for the dam that establishes the
,U110Ullt of flood flows released and stored based on dowilstrealll flood levels (Vol 7 section 8), 'ro
achieve the flood benerits cLlillled ror the project means that this operational schedule will have to bc
rigorously followed - particularly during large floods.
Actual operating experience or large multipurpose reservoirs during large floods indicates there
can be substantial deviations rrolll prescribed operating procedures, resuHing in greatly reduced flood
benefits, In common with these other projects, the Three Gorges design has flood control operational
cri teria that:
CQjlflicL}VitlL12Qwer j2Loduction _QQeration. Because power production provides cash
revenue there will be strong institutional pressure to operate the dam to maximize power
generation by delaying emptying of the reservoir for flood control or keeping the
reservoir higher than required to maximize power head. In fact the feasibility study
already acknowledges that the operating criteria may be modified once the project is
completed, to increase power generation at the expense of flood control (Vol I p 11 14).
Such changes are not reflected in the analysis of benefits.
CoUDicU'IiltLiJo\:VnstrC:_ilLlLQevelQprnenJ,.c Most of the flood benefits claimed for the
project result from growth of development in the river channel and overflow diversion
areas. During major floods dam operators frequently disregard operating rules and fail to
make required releases when faced with the certainty of flooding downstream property
versus the uncertainty of later catastrophic flooding. This can substantially reduce flood
con tro] effecti veness .
alj sti c: s Actu a1operati ng exper icnce sh0 ws
that when large floods occur there is a substantial risk that designated spillway release
capacity IS not achieved because of operator errors or malfunctions of the spillway (e.g.
the e/.pericncl' with Tarbela or Glen Canyon). 'rhis too can substantially reduce flood
control storage and flood benefits.
However, the most significant operational
problem not recognized in the study is that the Three Gorges project is unlike any other
flood control reservoir because about 500,000 people will be living in the designated
flood control storage space of the reservoir (Vol 7 appendix F tabl.c 5.1). Only people
living below the 162 meler power pool level will be relocated, and therefore everyone
between level 162 and 182 will be inundated by the storage of floodwater in the
reservoir, as well as additional hundreds of thousands affected by backwater upstream to
Chongqing. This means, for example, that in the event of say a 100 yearflood the dam
operators will have to choose between flooding out large numbers of people living in the
reservoir or large numbers of people living in the river channel and overflow diversion
areas downstream. In fact the analysis indicates that for such a flood more people may be
flooded in the reservoir than downstream (Vol 7 table 9-4). Whilst it is hard to predict
rational decision-making in these circumstances, it is likely that the operators will weigh
the certainty of reservoir flooding more heavily, meaning that larger flood releases will
be made, negating many of the claimed flood benefits.
3. ,walysis of flood le_'{<:JS-
The most important parameter that determines flood risk is the height of water against the lowest
point of the dyke, For large rivers like the Yangtze with a complex flow network, diversion areas,
floodplain lakes and large tributary flows, the water surface during a flood will not have a flat slope at a
particular flow rate but one that varies in time and space, As is recognized in the feasibility study (Vol 7 P
7-1), hydrodynamic models can be used to simulatc the water levels, but were rejected for this analysis
because "the accuracy of the input data is much beyond the scope of the present study". Presumably the
input claw referred to is detailcdmapping of downstream ch;mnel gcomctry, Instead of using a
hydrodynamic model an analytically crude flood routing model is used for project design, simulating
water levels at only 12 locations on thc more than SOO km reach of river downstream by modeling the
river as a series of reservoirs, This model therefore cannot be used to identify the times and locations
along the river where the progression of the flood flow would first overtop the dykes, Use of such a model
in a developed country would not be acceptable for flood benefit analysis.
The validation prescntcd for this flood routing model is not'convincing and shows a discrepancy
between observed and computed flows during the flood peak of about the same volume as the total flood
storage of Three Gorges (Vol 7 fig 7,3). The report acknowledges that the main reasons for this
discrepancy are hydrodynamic effects (Yol 7 p 7-8) but nevertheless concludes, "the model representS
reasonably well" the river flows (Yol 7 P 7-10). Even if this were true the direct translation of flows to
water levels throughout the river using this model would be subject to substantial error. The importance
of accurate water level predictions is emphasized in the study, which notes that even a 20 cm change in
water level against a dyke can mean 20% change in flood benefits (Yol 7 p 9-32).
The usc of a flood routing model instead of a hydrodynamic model means that there are likely to
be substantial errors in the project flood control operational design. In addition key hydraulic factors
affecting flood risk, such as backwater effects and channel characteristics, are underemphasized because
they cannot be siniulated in this model. This is likely to mean that flood benefits achieved by upstream
storage wi]] not be as large when all these other factors arc considered. It can also mean that it is possible
that the operational design could in some circumstances increase flood risks in some areas because the
model cannot predict where the flood peaks are likely to first overtop the dykes.
4. Flood benefits exaooeraled .. .. ____ __ .._ ..__. _
The inadequate flood analysis and unrealistic operating assumptions would both tend to
exaggerate flood benefits of the project. In addition, two other major assumptions have been made that
greatly exaggen\te the value of the flood benefits:
(Yol 7 p 1-16). Such an incrl:ase in real terms over the next 60 years for land that
wi]] continue to be for overflow diversion and "beach" areas downstream is highly
questionable, as it is highly unlikely that such an investment would be made in locations
that renrain flood-prone. In fact some flood agencies in the developed countries regard
the usc of any future growth in flood benefit analysis as conjectural and invalid.
Dse of the S,lrne economic grQwth rate;,s with and witho,ut the darn. One of the basic tenets
of flood management planning is that flood damage potential and the type and value of
land use are closely related. Obviously people prefer not to build in flood-prone areas and
if they do they are likely to flood-proof their property. These actions greatly reduce the
flood damage potential in the "without project" alternative, and hence the net benefits
claimed for the project. If, for example, the growth rate without the project was 40% of
that with the project, total flood benefits would be zero (tompare Vol 7 tables
9.3 and 9.5).
This calculation illustrates a fundamental planning error that permeates the flood control
analysis. By failing to clearly define the primary goal as flood damage reduction and
instead focusing on flood control (which is merely one tool for flood management) the
project designers have built in a methodological flaw. They have failed to analyse the
flood management of the Yangtze as a complete system that incorporates not only
"plumbing" but also hydrologic, geomorphic, social and economic factor's.
It is interesting to note that the study only recognizes people's rational response to flood
hazard when it calculates flood darnages to property within the reservoir (Vol 7
appendix F p 2-4).
S. PrQject CostUgU,Qxed
Even disregarding the necessity for relocating all the half-million population between the power
pool and flood control pool level, which in itself could increase project costs by at least 20%, if any
realistic flood control operation is to be carried out several other significant project costs have been
BackwaterJlo_Q<:LQ11mages upstLean_L The analysis of flood damages due to flooding of the
city of Chongqing by backwater froni the reservoir docs not take into account the
increase in river stage due to sedimentation. The feasibility report (Vol 1 p 11 10)
acknowledges the problem but claims a "critical" flood stage of 198 m whereas the flood
control analysis shows damaging flows to occur at elevation 186 m (Vol 7 appendix F p
2--1). With even the optirnistic assessment of upstream sedimentation contained in the
study, the 100 year flood level will rise at least 1-2 m within 30 years, affecting hundreds
of thousands of people in the city which has a total population of about 4 million. It
appears that the report recognizes this omission as it claims "future upstream reservoirs
and conservation measures" would reduce sediment deposition. Neither the cost of these
reservoirs or measures nor the cost of incremental flood damages in Chongqing are
included in project cost.
Cost downstream Although the deleterious effect of the clearwater
flows eroding the downstream dykes is acknowledged, the feasibility report claims these
problems will be managed by constructing river training works and dredging (Vol 1 p 11-
11). These costs, which can be ex tremcly large, are not included in the benefit/cost
__(;QastaLC:IQ,'iiQJl-. Unfortunately the feasibility study has not
analysed the role of reduced flood flows, and the capture of sediment, on shoreline
erosion and flooding dcnvnstream. At least 500 km of low-lying shoreline south of the
Yangtze River mouth depends on the extensive rnudflats onshore for protection against
coastal flooding. These mudflats are supplied by the sediment discharged from the
Yangtze. The costs of additional shore protection are not included in the benefit/cost
Because the primary goal of the study has been defined as flood control rather than flood damage
reduction, the importance of other components of the flood management system have been neglected. For
example, it is clear that with or without the project the existing dyke and diversion system provides
substantially greater benefits than flood control storage upstream on the Yangtze. Flood storage in the
floodplain lakes and diversion areas downstream is aboLlt 200 km3 as compared to the project's 31 km3.
Unglamorous alternatives that combine upgrading of critical dykes, modifications to overflow
areas, provision or refuges and perimeter dykes, flood proofing, noocl warning and appropriate zoning
were not examined. The feasibility report states that a long-term program of flood control works
improvements is already under way (Vol 1 p 16-3), but does not present this as an alternative nor discuss
how this affects the benefit/cost ratio. In particular, the study appears to have a somewhat contradictory
aversion for assessing the benefits of even small improvements in the dykes. On the one hand it states
without substantiation that it "would be uneconomic and impracticable" (Vol 7 p 1-2); on the other it
states that a 20 cm increase in height of dykes can increase flood benefits by 20% (Vol 7 P 9-32).
One important alternative component of an improved flood management system that was
investigated was the provision of ring dykes and refuge centers. The analysis concludes that "protective
dykes could be justified if the ilJ1nual probability of flooding is more than 1.5%" (Vol 7 appendix G p I
2). This means thill such measures arc cost-effective alternatives for the three diversion and beach areas
which provide most of the project's claimed flood benefits (sc.c Vol 7 table 9.2). This important
alternative analysis is relegated to an appendix and is not even mentioned in the study's summary of
alternatives (Vol 7 table 4.1).
Non-structural measures such as development restrictions in flood hazard areas can greatly
reduce f10exJ damages. This is recognized but only considered in justifying flood benefits in the reservoir
(Vol 7 appendix F p 6-1), Development restrictions that limit growth in the .overflow diversion and beach
areas that would limit growth to less than 40% of protected areas would negate all flood benefits for the
7. Faihlfe to consider costs of potential catastrophic failure
The study implicitly claims that the Three Gorges project will prevent major loss of life in an
extreme flood such as the 1000 year event. Thus there is repeated emphasis on the catastrophic
consequences of failure of the Jingjiang dyke, the major upstream dyke that protects about 2 1/2 million
people (Vol 7 p 2-3) and thefloocJ control operation of the reservoir is orientated towards managing water
levels to prevent its failure, even though the probability of flood damage is much larger in other areas.
A systematic impact analysis of the project would indicate that such benefits are likely to be
negated, and in fact the potential for loss of life could be greatly increased, for the following reasons:
Increased failure of clownstrearn dykes. There is likely to be an increased incidence of failure clue
to the downcutting of the ri ver-channel undermining the banks (Vol 1 p 11-1). The
inadequate level of analysis of this vitally important impact is illustrated by the statement
"channel morphology should not change significantly because the dykes that presently
border the river are in many cases protected by rip-rap" (Vol 1 p 16-3). The problem of
increased undercutting and erosion is likely to Ix compounded by the daily peaking
power flow fluctuation of between 3200 and 12000 cubic metres/sec. As important as the
physical impact, is the institutional impact of the project. 'J'he construction of the dam is
likely to take funds that might be allocated for upgrading and maintaining these levees. In
common with the history of other flood control dams the perception of improved flood
protection is likely to lead to reduced maintcnance and deterioration of downstream
levees and other flood management infrastructure.
Potential failure of the dafl} As is discussed in a later chapter, the risk of catastrophic
failure of the project as presently planned is probably of the same order of magnitude as
the 1CXX) year flood. Although no dam feli lurc inundation map has been prepared, the
potential loss of life would number in the mi1lions. Property damage would be so large
that even with a 1 in 10,000 year failure probability any flood benefits claimed for the
dam would be negated.
to settle in hazardous areas. Although the study recognizes
the presence of dykes can create a false sense of security leading to higher mortalities
when they fail (Vol 7 p 4-4), it has not applied this same relationship to the presence of
the clam itself. 'rhe analysis of benefits makes it clear that additional population is
anticipated to settle in flood-prone areas. What is not discussed is that these areas wi]]
inevitably become more hazardous over time as the reservoir silts up and the active flood
control space is reduced. Decommissioning costs have not been included in the analysis
so it is likely that as siltation occurs the operation would be modified to maximize
protection against smal1er floods. This leads to a scenario where cities and towns have
been built up in what were thought to be protected areas, ring dykes and refuge areas
have been long neglected and a lOOO year flood occurs, which the dam is no longer able
to control. Inevitably the loss of life in such circumstances is likely to be greater than if
the clam had never been built.

97;) .
3 944
42> 140
68 323
17 649
I 16
r ri t I i) : i:) y Ud n x 1() G/ km} '-In(j
.. 0
I. 16
C. i .5
0.. 0
I () . () /
9 j \/
1" 13
12" 17
in Reservoir
P j cd n
I .. Floo.1ing for l1ot-hor-1! Gench !\:O<:''::.
,A,roa Flood Damages
J I n 9 bo i
Jlngnan ion
Honghu Dlvers!on
Dongtlng Diversion
XII longhu
Sanzhou I! 11n Beoch, ;\<811
Other Beach Areas
Dongting Protocted Area
Jingjlong Diversion
Renm i nduyucn
Jlngjlong Extension
Shangbo I ! i zhou t3'3ach Area
Other Beoch Areas
Sub to t a I
Chonoiing]i Roolon
TABLE 1.5 - FLOCO CDf{THOL llff.f'f'ITS DYAnE}, ["elf'!, LOW NiD HIGi GF'<OliTH SCEN.-\RIOS
i D i SCOUrrr ED
IvY"'" "f)'" (v"""'c" '06 106 Ir6 '06
IIl--r\tt. 0Jr\"..Jl.:J i:- yu,Jn >< l' yucn x I yuan x ,0 yuan x I
1 1 (,",) (S) (A,) x (8) C::::) (A,) x (C)
9.2eo lH,) 340 15304 I 467
4.37 j 79<1 233 8 470 412
o /) 6U 1 8 2 81 2 13
1. 0 7 84 5 10 i 4 6 5 ] 6
1.80 ) 17i 57 295 77
59.00 14.3 24.1 1422
0.. 07 j 10 :167 78 150 526 106
0.52 61 3i9 828&J 431
2 389
3.12 20 56" 641
0.53 32 977 191
3 685 9
1 .. '} 'j 1,02 J ({
1.0 17 17
O. I I iJ'j C)CJ.1 96
963 I 943
3357 t I 5887
, , " 63 II I 84 \
I : I i 'I II b
Expoctf.;d i j()()d Controi! I I) ---.---- 1 ----
, Ii>2' I - r c-
, Be ne fit s : , i' ) 4 0 I I) I L ::J
I I_L I ._ ,L ,,_ _ -L- _

Appendix B.4
" ....
., ....
2>0 .....
70 -
80 -.,.----.----------------------------------,

. " ,.,
o -1-------,.--------,--------,-----
8 0 ..,.-- -----..---- -..--..--.- ----.----------..- ..-- -----..- ..---..--.. ----..-- -.----.-,

60 -
50 -
'/ . /,
" I ....

,: \
:' \....... " .....-'
w 40
g \.-
V1 <, 2>0
" , .......
a / . I '.'
f.) \ ..
" co MPUTE 0 FLOWS , "
YEAR 1954
-- 7... G
Volume 7
4 -- April 1992
Building a new
Appendix 8.3
\.II)C l)f te,\Cnlcrncf1l
lnulld:llion line 0: o:ld,wJ.ler
20 year,
326 townsbips) 291 ow resettle their people
wilhin their townShips. Ooty 3S \owmhips
have to evacuale their people to nearby ones..
'Therefore, the adven.c impact brought aoout
by long-distance migration p,n largely be
3, -D1C Three Gorges Project haJ a long (enn
o(cons(ruction, During the J8ye-.ars from the
preparation stage till complelion, therc will be
enough timc Lo arrange production and
livelihocxl [or the disp13ccd rc.siden15,
T1K most advantageous o[ all is lhal lhe
cenlral govefllrneflt has allached great im
portance to thc fescttlement issue, It has
revised the rcsCnkmefl{ polic.)' of a onetime
compcnslllion p<1c\.:age inlo a development
oriented rcs-cttlerncnt's.chemc. Sinc.e 198\ a
sp,ccial fund o[ 20million yu an (53,7 million)
a year tlas been cl1located 10 lhis end, It iJ a
never before enjoyed by thc Other
';.. rc..scrvoir arcas in thc country, Thc trial reset
tlemenl scheme Over the past .six years h.15
been succcs-,,{ul.
City. Togelher with ilS SUbordinate projec1.5,
it C-<ln create jobs (or more than 30)000
people. And marc peopk will be employed 3.., '
more projects will be set up if thc central and
1<X.al governmcn15 purpo.scfully do so during
the c.onstruction of the Three Gorges hydro-
pJWcr sUltion.
2. '1l1c displaced populaLion is relatively
dispcr.s-cd, with a big proyorlion being urban
populatIon. Th'e rcscltkment will be confined
to a narrcr"" strip of2,CXXJ blomelers along the
reservoir, For urban rc.sidenLs, it is only a
maIler Of'C\',ICU<1tion and emigriltion and rcs-
torallon o[ urb..:1Il funclions Y.ilhOtJlthe need
to cre-ate jobs. The 330,C(X) rural or
.15.S rx::rccl)t of the lotal displac-ceJ population,
ilccounl only for 2.92 rx-recfJt of the lOlal
f;,rming Ix)pulation i.-, tile 19 roufllic..\ and
their SUbmerged l.3nd is anI)' 2.56
perceot o{ the lotJI area, wilh 110,CXXJ,mu
being p,1dd)' or 2..3 o( {he tot,1!
paddy rlelds,
/'.\ctSlly perched On hillsides and mountain
.slopes, none o( tIle 32.6 and {ew
Yi!!;:ges will t>e cntirety under water. Of tlles-c
tial for devclopment. planllcd, part of thc
undeveloped land and low-yielding slopes will
tx: used through appropriille cultivation and
improvement to provide the 330,CXXl rural
people with onc mu e.aeh to grow cash crops
such as ornngc, le.(l, mulberry and medicinal
herbs, and half a mu each of high and slc.ady-
yielding farm field, This will ensure the
crnigrtlnl.s a stable means of livcliho::x:l and
wiJJ help them 10 prosper. -Bcsidc.:s, belween
the ebbing lines of 160 meters and 175 meters
there is an ebbing are.a of 160,C<Xl mu (10,666
he(1.3res) where {<lnncrs can grO\-'{ one crop in
; h-.: dry season '111cr( I:; :11..-.0 abund'H1l grazing
g:oui)(lln the rescrvoir :lreil!O develop stexK'
r;;.is:ng anel processing,
There will abo Ix: gcoJ fOf the
tXC1\lSC of the rietllourism resoureC$
the arca, ;llld the 0PIX)({Ullitics
bfouglll by the (orthcomlng development in-
dL:.>tncs of butlding m;l!erials, construclion,
and services to be promoted
,d0:1g with lhe construction of the super dilln
Resettling the rural areas
!ZC'_scllling (he 330,CX,X) farmen in tile r('--scr
voir Jrea mainly relics on lflC dc\'elopmenl O[
macro-agriculture, i.e., maling full ux o[ lhe
ri.eh <lgrieullural in the rc.:;.cr.... oir
.", .are<l to develop various bnds of fuming,
aquacu1lure <lnel animal breeding, proccs.sing
),':- o[ agriclJltufill <lnd stocK products, (lOU rural
a.nd t(N.11ship industries. In farming, it \\111
:r.nainly focus on the reclamation Ofw35tc !;wd
_grow. orange, lea, rnlllber0> mcJicinJl

t; r-' k . . b ., {d . } "2 . - IX .. -.. to' herbs and olhcr .:-'hlCh .are p,1r,
. . . fa erCJc{( e are [ 1(, .3}?OO <? . in/ing Eli B.adailg' '; titularly suiled to \he local conditions.
__ :-, L:
-- ..- --- ------- 1\1so, ullprexluctivc nclrls arc to ly,.:: 1m
proyed to allO'w f;lfmcrs to hJ\'c half 2 f)H! o(
stabJc and higl1')1c!ulng field per rXf5-0n [or
&f<1in produclion,
During Ihe fXlSl six years, ,:6 million yuan
million) been for the
development of terraced fklds and orange,
tea and mUltx:rf)', In 19 colllltie-s, 74,(D)
I11U (4,900 hcctarcs) of 1.1nd has been
reclaimed :1nd con,Qrueled, v,1th 47,700 mu
(3,ISD hcClarc.l) for grain, 38,100 rnu (1.,5\D
hecla res) for ortlngc..\ 930 mu (62 hectJrt.:i)
for !:0rnclo, 3,&XJ IDIJ (253 hcct:Ht.:i) [or teJ
and 5,7CX) nil] (380 hectJru) [or such fruits 2.S
' .. "){
'nlt: Three (;ort;cs area is :Jbunc!i1flt ill tile .
reYiUrCC5 o{ 13n(( .1gricuitlJrc, animal
hus;l,lndry, pnxJuclion, min .
::'.,' :in<! in :lddirion 10 f,l(> ,
:I;\d prli'.'c,\.\!Ilt', ;lI\J
L" cnvjfonmen,a\ C-;'P;\cII:r' io
tic the lk.p\;lccd lXoP\c.
icrr;;.\ of 1;\1)(1 rc:;..')urcc, !>,w,'C)'S ;ltHJ ell
h:l\'l: tlla: there:He I)c:1rly 20
mu (lJ mlilioll hccl.'re.s) o( mount:lIf)
,\1;",:'<.'5111 I:,C 19 where arc
If) tx: rcsculcd, II) which lownsillps
:U-;<) 1111111Cn mu of
;,'''y ,W ix:r;:cnl o(
u:r<..'nt .: 26 mdll\,[) nlU (2S-J,fKX) hee
, j .,f ('\> it 1\;11 cd 1:1 nd ;\1 ( kr...... )'lc Id t ur;!Ccd
\l.l\::h rnCH)." thuc 1\;\ hlg p\lll'1l
by U
gcs ArCIl EcoloQlcIl.l Development Offlce
under1he Stale
The rc:>cll!cn1cnl of huge number!> of
peopk 10 be cll.\p!:Jccd by the construction of
the Three Gorge5 fcs.crvoir onc of
the cotic,! L,:>SUC5 In the project, and must be
wellconceived and pl,lnncd if the project is 10
b<: Cl(fICO oul
Under (he current.scheme of <I normal i'JS
meterdeep w,ller S[(Hage level, the reservoir
<lrfcc{ \9 and cIlle5 In Sichu<l11
;lnd JI \JL'>C I prO"'IIKC.\ o{ which twO II
(OUr,IIC':;, \.10 10>1,'0$, :n;; ((l\I,'nships and 1':'51
\\111 lx: entlrel)' or p,l[\l)' 1I1und:ltcd.
t\(;:,)((]I!)1', to;j \ 9HS survt:y, [he rx)PUI3110{) of
Ihe Mca W;lS "I?_'),500, W\(ll urban and
_1.12,60G rur;1[ residents_ An estimated
.1)(,,iXX) I1HJ (2J,I"JXJ hcct;lrcs) of clllllv;Hrd
1;lnd ',qll be submerged. If we laKe lOW ile
(ounlthe fX)pul:llioo grO\I,-1h rille over the la.st
20 .1'(,3rs, there WIll be ilS I1WO)';1S l,133,&X)
p..:op:e lO I'>\.' CV(lcUJlccl and rl'scltlcd
on .<.ueb ;\ rnas.. "-Ive -",(;lie
(lu:.;rncnl.<. thc of :hc regIon's cuI
11\':llCd tll)U scarcity, b;lC),:v.-ard e("Doomy ;l110
CdL.'c;ltion .- !;lrgely due to lhe abs-cncc of
StC1\C InvCSlmenl in the P;"L\l, Tne prolonged
in,:cCl-sion in implementing the project has
IJ further burden. Nevertheless, the
has ()\vn ;'\OV;\l1\'I);o not shilred by
reserVOirs In the countr)',

TiHE ffiOJECI FE.ASIBIL1Tl ST1....x:rr

TABt. - ( 10rAl. OIS{XX.><TED FleX)'] i11Tlo;r - 12 R.fPK..fSEX1AT1YE Fl(XX)
--"s'* *
--_/ .
I SU).-lt.{ARY
Tot"j Flood Obmbg6S,
R"<)ion jl Roglon i O""'.go,
5 268 ) 6881__-10..9.5.6-
2 996 ) 2'0 6 2>6
Tl99 T9iB ---TTIT-
I 128
122)[ 2)1
70) 79< I )27
9 0'8
II 5 I) I
20 56)
, 968 6 461 I I <29
2898 TJ56 "'"663'5
I 777
2 296 I
< on
I 100 I '61 2 594
175 2 7)9
, 781 7 716
175 ) 260
I 251 , 690
17) ) 2}) 2 )12 ) 720
o "7 2 862 6 <5<
17) 2 667 I 2<0 , 082
17) 2 786 I 667 , 628
I)) 2 '10 -'
156 5 7' 1
175 2 '68
10< 6 7'5
170 ) 002 -' 252 8 09
17) 2 996 ) 2,0 6 'I I
Tot.el txpoctG-d PIer-A O<'Yl\llges.
(8'::se-D on HIgh Grv.-th Sce-nor 10)
following table
0.)2 0.07
! Expuetoo FlOC'{) (yu.:lnxl0
1 ArellS l! (lo-w 1.. 101 rllta)
t''''e rCXJting rrodeJ Indlcie for Jlngf1n ond lor J[rgl>el,
The If"Odel sho'><'s thDt __ h"n the dykes Drotectir>g OAe c(ell W'cter
compare to
10 ..... [<..1-1987
t,.,o Cr e-:: s.
i 2. 17
the results at
1 ;.&
lH:l.),:r1 Ar (l D $. i
" I at), Y\j"r.
O,;;r I IO'c,ar 1'----'-------1- 1
I I !
)!n9 f . .. JJIOccl"ou- 00"9[109IJln9001 I I 8''''0.n Totll[
on J I ""0 I """0 I)' 0_""
I i ---.L 1.
lchong I .
' I I i I
90 1;.00 16 i 0.00 0. 0.67 I 75 I 2 ) I ) 178 I
90 I 15.00 I' i 0.00 0.00 0.67 I 75 I 2 27) < 882
i 17 I 10.00 10 1 0,00 0.0, 0." 75 0089 , 191
126 liS. 00 1.5 0.00 0.00 O. ),3
9) I \.00 8 0.00 1.00 0.00
I ! 2 I I ,. 00 i I O. 00 o. no. I 7
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I OJ i ..!..1X2. i I 8" I ) 002 I I I'7 I .g.:.2 ) I 22!l. -'.Q.'!. ' .:E
, TIl I 88) 1 TI5IO I Ti0 i )00 I 25': 1 lJ' I nl9 I)) I 1'6 6' I 250 162
[ 1'5 I 5,0 i 6) I 066 I 006 I 106 1 ; : D 00 8,9 L 82 I 90 I 09 ! 15) 99
: I )n I <15 675 I __ __ ' '_'1L __"'-=-. )2 I ,5 I 25 i 97 60
I For Jlo9Jlong end Dongtlng A'tles. /}rl; in Ktr'? end demo-go potBntlQ]S cre In
/. For InlOri1\.Ctlon only.
3. ExcludIng ,j6"""Dges In r1S'$orvolr <lore".
..I, Th<; prob.::bility of floodIng elthe, Jing.'1<'ln or Jlngbol or t-0tr, 1<, pM yec.r. "'If
I t does itot r!'p,esent the 3ctu1 river ccurefely ..J<jl rD il"Hl btlt ..... ec,'
I avol" "ra (edU<&<:l llnd rho other Drtl Is uSuDi iy
i i
I H...:lJor Olve;:slon Ara..:!,> 1 ) .....,:,1 j"r
--->1 Jlncr I L I""
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\ '!):) l 8.7
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19 :).( 9.2
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19fJ! i 0.1
\ 968 1 1.0'
i 9 7D 9. Q(
I'fH 7.1.
1980 } 8,
1982 I 8:"
198;' 1 :> .( .
S """'0 I, I; H -1 -'--
,Cre-lh ![}ls.countl
1 R",tQ '
, '--L;---t e
! 105
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) t 098
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22 2 I)
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25 912
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6 ;
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5 7
.( 791.
J ......, i ) ", . ; : v ... . ) )., ( "(; <,
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15 19 i
8 685
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) 7 798

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TJ..8(. 9.5 Cff TOIN. DJ$.CI:.X.>(TE.D FLCXX) wiTH TtREE - 12 R:PRfS..t)<TAi;VE flOJO
0"'0' !Rowvol,j I i
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fDongllng ,v
d"yu".' 'Ic
Plcl.' !" VAI09 i JI I ""9' I
'ifjrC"Jr.:-:;!\ SM"o'('lS i I
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1931 00 i.25 e.!31 7.:'>0 )2 \;.Ot) i6 C.C{) 0.00 0.59 '\ SO \ 1..58 II .( 556 1 501...0\ I
\9;') I.).() 8.Q7 7. I.. i \ 5.00 :i. 0.00 0.00 0.62 I )/ I 591 I.. 769 1 5 )97 II
',952 '2. 0.') 7.)0 S7 ;2 O.CJ 0.00 0.20 'I 207 I 861 I ) 5./,) \ .( 615
19>' 0,91 1>,00 0,00 69 1>,00 Il 0,00 0,00 0,19 ( )8 I 991 I "0) I 5 <)) \'
19' i.I": 0.B6 ).')0 C. iP, O. is )1 .3.)0 6 0,00 0.00 O.C{) ( 306 I 091 950 7)1..
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\965 0.79 Y. G.7') O. 0.00)6 15.00 ! I 0.00 0.00 0.0-'> 1 i.0 577 I 1 6.(0 2 258 .
1970 0,00 0,06 7, l\ 0,00 0, 0,00 lO J. >0 j 0,00 0,00 0,02 I >2 5 i 082 I 670 I
0.9 1 0.')7 i.OO 0.00 0.97 )} 7.Yj ) 0.00 0.00 0.00 1 Jj7 6)0 9)7 705 I
0.09 2.20 \.)6 7.')0 0.09 i5.00 e 0.00 0.00 a.Db \ 90 218 J 891 2201 I
o 3.50 0.)2 ).')Q 0.1i. ?7 7.){) 0.02 0.02 0.00 j I.l,! 1.,91 1.>08 19,(1
')1) 0,62 I,)D ",JO 0, 0,)) 7,>0 u 0,00 0,00 0,0' I 1'0 8)9 I 205 [ 222) I
C,)' ",Do 0, )'1 10, 'I O,(y) 0,(0() 0, I) I '12 I 60) I 2272 I 2 991
f--- .--- -! .L .L- .. __'_ - ., , __ .__, " .. _'___,_ __' __' . --' ....., If--- Li----'-I '-- -j
Cu','" I'((NOI y"O" ,IOU, '0 .ld-loH7 I Tot,t Exooctod Flood 0",,"9"' I
:,c"'ntJ 10 ;::Ill r... ! 01'1 HIgh GrC"ofth I
1>0 \ I 00 I I 02 I I '020 I 0 691 I
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Hi C""" 81
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d I
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.( B 04 j
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6 I 260
I 109 JI
Rcog for.
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roc JI;'"\qjl'''{)9 "nd DonqlinG ;:;:,,,")101"' t3 ..
7 ;.
204 22 2
)0 i 26
5 0'
CTii79 .1'..:::* **
708 I
10 "21

) 228
I 976 I
I 209
) 985
2 2J 2
I )67
558 100
I 851 8 260

>99 2 629
)68 I 608
2)6 ] 02 <\

;Q6/ k,..,/.

I.. 6 i .(0
1}C' ) 87
il!!. I 1)1
7.5 ! 65
:"71 i 276
2! 0 i 279
.3 j
1) 7
; I.. 'I De',
s 979
10 962
] 6
52?! ] q
I 2\8 " )
7') 7 2.(9
.( /6 i ') 7
:> i 0 i 02
2 607 8E
I 5 \ S .(-58
926 799
2 70S 722
.( no \ I, 529
" )
: 9

.3 i
... :iT f

r or' In! a r- .... " r ! on on I y.
3. ,.,:: ,-;c>",.,ce$ i"
AFpendix B.6
Peak Discharge: 82 600 mJ/s
Peak Stage: El 193.38
Peak StaSJe exceeded EI 1:30 fo(' i) days
Gr a i n I, ancl
I es
ot e [' Cr 0 pS
26 952
08 132
61 2
I) p'
I, J
99 'In l
., ,r-
270 ):Ll
u ra 1
33 480
137 (jil/
Proelu c t ion

\.1000 kg)
rota 1
Total Loss
,IJ, 'I C [' (1 9 (: 1_ 0 S s
:3 U1L[) l ii (;
} .. -- ,.,.. . --, --, .._---" .. - , .. -...,- - ..,
/9 if 5 322
/ ]:-:8 000 yuan in 19i31
1 377 yuan/ha In 1981
Tot a 1:
!I vc (' aCJ e
190 x 10
yuan (IlC) cictJ) 1 s)
190 000 00O;ill d n :: lW6 y L1 an/ pe[' son
137 Oi)l in 1981
SOUf\CE: on "July 1981 Extra-orcJina Big F'lood in Cilongqing" by
ChonCJqing Floocl ConUo] Office, i'1aJch 19136.
_ J ....

Appendix C.l
(mi It i on yuan)
i I
3/, I
i I
NPL 180 II
3 867 II
3 765 I I
1 3% II
1 630 I I
695 II
171 II
! I
5{, I I
',6 I I
NPL 170 I
NPL 160 I
1 2 112 2
1 951l 2 1,18 3 31,1l
605 797 1 067
71,2 790 1 201,
283 IIl3 506
11 "
)() 1.6
20 26
5 29
NPL 150 I
i' , I
II""" . .
II 1.
I 2.
I 3
I I,.
I 5.
Ii q Lj,H:S
1111. CULTURAl.
Ii 12. I: f)UBLl!: HEALTHI 75 ql, ! 1')2 i 19B II
I i). liE,U,S 119/11
I 11,. KAfiAGEKENT 525 7:\6 922 II
I 1'). TOTAL I,ESLRVOIR COSTS 621.1 8030 1121.6 11,095 II
! I 17. TarAL COST Of RESETTLEKENT 6 8 093 11 :108 157 II
II 18. TOUI! / affected person (YUiln)I 116B6 11263 11609 11959 II
II 19. Totill / affected pel'son ($) 3 158 3 3 137 3 232 II
I1====================================================================================1 I
Volume 9
9-3 .- Table 9.1
Appendix C.2
jJ CZ1,coo
~ - l.lJ
o >-
a: :1:
w U
Q -'{
u.. W
1980 1990 1992 1994 1998 1990 2000 2002 2004
\ 200
i 000
t.d 'D
; ~ 0
, ..
130 C
>- '" :J
Vl >.
1988 1990 1992 1994 1998 1998 2000 2002 2004
Volume 3
\=j e[IS eignen: c:" \::; SJ:J i':':S e:l
ve rt u d0 (
Lal sur I'acces i:J


On the 'basis of the review and evaluation, CYJV is convinced that the
non-equilibrium approach used in the TGP model (i,e" the diffusion
equation) is the proper way to model suspended sediment deposition in
reservoirs ;Hld the suspended sediment loads of most rivers, For the
Yangtze, the suspended sediment load of generally fine sediments cornprises
99,95% of the total sediment load of the river, so the gravel bed load does
not need to be modeled for the feasibility level of study,
The theoretic31 basis for the TGP model is sound The
rnodel is fairly well formulated, Some approximations used in the m'odel are
not theoretically correct, but are reasonable and are treated as parameters
that can be calibrated in the model The hydraulics are
handled adequately, The seclimerlt function is almost identical to
Bagnold's equation for suspended load, has as much theoretical basis as
any sediment transport furlCtion, has been used in Russia, China and
Eastern European countries for over 40 years, and is easy to calibrate and
use It is well suited for the problem' at hand,
The TGP model has been calibrated and verified over a very broad rarlge
of conditions It has been used extensively and with good
results for over 15 years It was first applied to Gezhouba project in the
early 1970s and was subsequently verified after the project W;JS
constructed, Finally, and most important, the individuals who are doing
the modeling are the ones who developed the model, they have worked in
the data collection programs, they have intimate knowledge of the river,
the data, the theory, and the rnodel, They have worked on the Yangtze
and other Chinese rivers for over 30 years, CYJV agrees with Dawdy and
VarlO ni (193() ) t h 3 tat the presen t s tat e oft hescienee 0 f mat hem atic aI
rnocJeling of rivers I the modeler is more important than the model. The
Chirlese have very competent arld experienced personnel in their modeling
In c:orlclusion, CY JV believes that the results of the TGM model are as
reliable as any modeling efforts that could be undertaken at this time,
given the inherent uncertC1inties of these kinds of calculations, arld that
the results of the TGM model computations are a suitable basis for the
feasibility study and preliminary design of the Yangtze River Three Gorges
-- 3'-1 --
Association of Professional Engineers of Ontario
Office of the Registrar
February 8, 1993
Ms. Patricia Adams
Executive Director
Probe International
225 Brunswick Avenue
Toronto, Ontario
M5S 2M6
Dear Ms. Adams:
The Complaints Committee, at its meeting of January 21, 1993, considered your complaint against
Acres International.
The Committee's Decision and Reasons is attached in accordance with Section 25(4) of the
Professional Engineers Act 1984.
Please note that the complainant in a matter regarding the conduct or actions of a member of the
Association or a holder of a Certificate of Authorization has the right to apply to the Complaints Review
Councillor under Section 27 of the Act, copy attached.
Yours very truly,
1155 Yonge Street, Toronto, Onta.rio M4T 2Y5
George W. Piper, P.Eng.
Telephone (416) 961-1100
DUll' 10
a member' of a commlltee uF -the
Association; or
(9) In conducting an examination or Reaipl
review in resn<'ct of the ASSOCiation. the of
r'- information
Complaints Review Councillor may hear or
obtain information from any person and
may make such inquiries as he thinks fit.
(10) TIle Complaints Review Councillor is
not required to hold or to afford to any per-
son an opportunity for a hearing in relation
to an examination. review or report in
respect of the Association.
(1 I) Every person who is.
(a) a member of the Council;
(b) an officer of the Association;
27.-( 1) The Complaints Review Council-
lor may examine from time to time the pro-
cedures for the treatment of complaints by
the Association.
(2) Where a complaint respecting a mem-
ber of the Association or a holder of a cer-
tificate of authori71ltion. a temporary licence
or a limited licence has not been disposed of
by the Complaints Committee within ninety
days after the complaint is filed with the
Registrar. upon application by the complain-
ant or on his own initiative the Complaints
Review Councillor may review the treatment
of the complaint by the Complaints Commit-
hy ComplainlJ
to Complaints
flOI to inquiu
info m<nr
of complaint
power of
(3) A complainant who is not S<ltisfied
with the handling by the Complaints Com-
mittee of his complaint to the Committee
may apply to the Complaints Review Coun-
cillor for a review of the treatment of the
complaint after the Committee has disposed
of the complaint.
(4) In an examination or review in respec:
of the Association, the Complaints Review
Councillor shall not inquire into the merits
of any particular complaint made to the
(5) The Complaints Review Councillor in
his discretion may decide in a particular case
not to make a review or not to continue a
review in respect of the Association where,
(a) the review is or would be in respect
of the treatment of a complaint that
was disposed of by the Association
more than twelve months before the
matter came to the attention of the
Complaints Review Councillor; or
(b) in the opinion of the Complaints
Review Councillor,
(i) the application to the Com-
plaints Review Councillor is
frivolous or vexatious or is not
made in good faith, or
(ii) the person who has made
application to the Complaints
Review Councillor has not a
sufficient personal interest in
the subject-matter of the par-
ticular complaint.
(6) Before commencing an examination
or review in respect of the Association, the
Complaints Review Councillor shall inform
the Association of his intention to com-
mence the examination or review.
(7) The Council shall provide to the Com-
plaints Review Councillor such accommO<la-
tion and support staff in the offices of the
Association as are necessary to the perfor-
mance of the powers and duties of the C-Om-
plaints Review Councillor.
(8) Every examination or review by the
Complaints Review Councillor in respect of
the Association shall be conducted in pri-
(d) an employee of the Association,
shall furnish to the Complaints Review
Councillor such information regarding any
proceedings or procedures of the Associa-
tion in respect of the treatment of com-
plaints made to the Association as the Com-
plaints Review Councillor from time to time
requires. and shall give the Complaints
Review Councillor access to all records.
reports, files and other papers and things
belonging to or under the control of the
Association or any of such persons and that
relate to the treatment by the Association of
complaints or any particular complaint.
(12) The Complaints Review Councillor
shall make a repon following upon each
examination or review by him in respect of
the Association.
(13) Where the report follows upon an
examination of the procedure for the treat-
ment of complaints by the Association, the
Complaints Review Councillor shall transmit
the report to the Council.
(14) Where the repon follows upon a
review of the treatment of a complaint by
the Association. the Complaints Review
Councillor shall transmit the report to the
Council, to the complainant and to the per-
son complained against.
(15) TIle Complaints Review Councillor
may transmit a repon following upon an
examination or review to the Minister
where, in the opinion of the Complaints
Review Councillor. the repon should be
brought to the attention of the Minister.
(16) The Complaints Review Councillor
may include in a report following upon an
examination or review his recommendations
in respect of the procedures of the Associa-
tion. either generally or with respect to the
treatment of a particular complaint.
(17) The Council shall consider each
report. and any recommendations included
in the report. transmitted to it by the Com-
plaints Review CounCillor and sh:.lil notify
the Complaints Review Councillor of any
action it has taken in consequence,
Repon by
Repon to
by Council
In accordance with the provisions of Section 24 of the Professional Engineers Act R.S.O. 1990, a
meeting of the Complaints Committee was held in the offices of the Association, 1155 Yonge Street,
Toronto, on Thursday, January 21, 1993 to consider a complaint from Ms. Patricia Adams of Probe
International which was filed with the Registrar on October 19, 1990.
The Canadian International Development Agency ("CIDA") financed a Feasibility Report for the Three
Gorges Water Control Project ("Project") on the Yangtze River in China. A Canadian consortium known
as CIPM Yangtze Joint Venture ("CYJV") completed the study for CIDA. Acres International is one of
five members of CYJV.
The Complaint and Responses
This complaint was brought to the attention of the Association by means of a September 17, 1990 letter
from Probe International ("Probe") enclosing a copy of a book entitled :'Damrnl.o..g3he Three Gorges:
What Dam Builders Don't Want You To Know" (the "Book"). The formal complaint, which was based on
this letter and the Book and dated October 18, 1990, was received on October 19, 1990.' Probe
International is a Toronto-based environmental advocacy group interested in the effects of Canadian aid
and trade policies on the people and environment of the Third World.
A copy of the complaint and the book were forwarded to Acres International Limited ("Acres") by the
Association in October 1990, and Acres, by letter dated December 27, 1990, provided an initial
response. By letter dated September 3, 1991, Probe afforded to the Association a rebuttal to the Acres
response, prompting Acres to forward to the Association a further response dated May 8, 1992
enclosing a number of documents replying to the Probe position. Included in that material was the
Three Gorges Water Control Project Feasibility Study ("Feasibility Study") in the form in which it was
provided to Acres by CIDA. On October 19, 1992, Probe forwarded. to the Association a further
rejoinder to the Acres response, and Acres in turn on November 16, 1992 provided the Association with
a rebuttal of the Probe October 19, 1992 rejoinder.
By way of preliminary objection, Acres submitted that the Association and its Complaints Committee
("Committee") do not have jurisdiction to consider and deal with the Probe complaint because the
conduct in question took place outside Ontario and, in particular, in the Province of Quebec and in
China. In response, Probe took the position that the Association has inherent jurisdiction over the
conduct of its members no matter where that conduct takes place. The Committee concluded that the
Association's jurisdiction is such that it is entitled to impose discipline upon its members with respect
to professional conduct inside or outside Ontario or Canada: Re: Legault and the Law Society of Upper
Canada (1975), 8 O.R. (2d)585, (Ontario Court of Appeal).
Probe Position
As to the merits of the complaint, Probe's position may generally be summarized as follows:
(a) A member of the Association involved in a project outside of Ontario must ensure that the
project meets all standards applicable in Ontario.
(b) The conduct of the CYJV engineers with respect to the Project included errors, omissions,
Imprudent assumptions, biases, analytical irregularities, inconsistencies, oversights and
substandard methodologies, demonstrating inadequacy of the review process with respect to
which the engineers were retained. In particular:
(i) With respect to dam design and safety, CYJV engineers failed to employ the
recommendations of certain ICOLD (International Committee On Large Dams) Bulletins
relating to dam safety precautions and the selection of seismicity parameters, neglected
to apply these recommendations in the dam design and the economic cost-benefit
analysis, underestimated earthquake ground accelerations and risks caused by
landslides, underestimated the risk of spillway failure, accepted dangerously high risks
of cofferdam failure, did not perform adequate analyses of reservoir-induced seismicity,
structural stability and flood control and failed to demonstrate the technical feasibility
of the spillways.
(ii) The flood control analysis carried out by CYJV engineers was inadequate and flawed,
the purpose of the Project was misrepresented, the Project's flood control benefits were
exaggerated and misrepresented, and unrealistic operating criteria were recommended
and assumed.
(iii) CYJV engineers failed to take into account uncertainty in their risk assessments;
(Iv) CYJV engineers failed to review existing data on sedimentation as reqUired by the
Project's Terms of Reference, thereby rendering their flood control, navigation and
electricity benefits, and project life-expectancy calculations unreliable and without
scientific basis;
(v) CYJV and its clients claimed they had "reviewed and analyzed, on an integrated basis,
the cost, benefits and other effects of the overall" Project, and concluded the Project
was "feasible and financially viable", without first demonstrating the feasibility of
resettling almost one million people, as the Project's Steering Committee and Terms of
References required;
(vi) CYJV concluded that the Project was "environmentally feasible" without data and
analysis to prove this.
Acres' Position
As to the merits of the complaint, Acres' position may generally be summarized as follows:
(a) The Book, which is a critique of the Feasibility Study and the performance of the CYJV, contains
eleven chapters of which only two appear to have been written by a professional engineer.
(b) The work involved in the Feasibility Study reqUired contributions from many individuals in a wide
variety of professions and specialties, including economists, environmental scientists and other
specialists in fields other than engineering.
(c) A feasibility study necessarily involves preliminary design studies which, while sufficient to
establish the scale of development and probable project costs within acceptable levels of
confidence, do not deal in detail with all design matters and related issues, many of which will
be resolved in subsequent stages of the project cycle.
(d) To ensure that the objectives of the Feasibility Study were met and that the standard of practice
was consistent with international practice, several levels of quality assurance and review were
utilized, including internationally-recognized specialists who supplemented the main Project
team, a regular review of the Study by a "Project Review Board" of the most experienced
professionals from CYJV's participating organizations, a review of all technical work by
independent specialists retained by CIDA, and extensive participation, including ongoing input,
review of all interim and final reports and formal review meetings in Canada and in China, by
a panel of international experts established by the World Bank.
(e) It is normal practice with respect to major feasibility studies to bring together a broad range of
high-level professional expertise and judgment to consider the often complex issues to be dealt
with. In the case of the Feasibility Study, the CYJV team possessed a very high level of
professional expertise, the external consultants and specialists engaged in evaluation and
review of the work were of world-class calibre, and the Feasibility Study was subjected to review
of very substantial scope and depth.
(f) The Feasibility Study was carried out in compliance with high professional standards in all
disciplines, of which engineering was only one, and was subjected to expert review throughout
the course of the Project. Acres does not debase those standards for any purpose.
(g) With respect to the technical criticisms of the Feasibility Study:
(i) The spill capacity is adequate in accordance with international practice, and the dam
and other structures are not endangered by the Probable Maximum Flood event. The
design of the dam was consistent with the ICOLD Bulletins to which Probe made
reference and was based upon analyses considering, to a degree appropriate for
feasibility assessment, all foreseeable load scenarios with respect to reservoir-induced
seismicity, structural stability, reservoir landslide, spillway failure and cofferdam failure.
(ii) The Feasibility Study set out the Project's flood control benefits and costs; explained
the purpose of the project and the operating criteria; and concluded that the flood
routing type flow model used was appropriate for feasibility level investigation, about
90% of the flood control storage will be reserved indefinitely, the risk of loss of life to
the additional population is small and there will be little flood damage below '198m at
the critical flood stage.
(iii) CYJV Engineers recognized possible down cutting of the river bed with a potential
localized increase in the cost of dike maintenance and determined that the on-going
programs of dike maintenance will ensure that repairs will be made as required.
(iv) CYJV made detailed resettlement estimates for four schemes covering a range of water
levels, defined fOllrteen principles to guide the planning and implementation of the
resettlement program and recommended that additional studies be carried out.
(v) CYJV concluded that the Project was "environmentally feasible" on the basis of the data
already available, provided that gaps in the available database were filled and an
ongoing environmental monitoring and mitigation program was implemented.
The Complaint Committee's Review
In addition to reviewing carefully the Book and the submissions of Probe and Acres, the Committee was
assisted by the following input:
(a) Reports prepared by the International Panel of Experts retained by the World Bank on
behalf of the Government of China to review and comment upon the CYJV Feasibility
(b) Statements by the World Bank and CIDA regarding their review of the Feasibility Study;
(c) Reports with respect to international engineering projects, prepared by two Ontario
professional engineers with extensive international experience;
(d) Reports by an Advisory Panel of three experienced Ontario professional engineers who
were asked by the Committee to provide an independent opinion of the complaint;
(e) Information obtained from several senior geologists from Hubei and Jiangxi provinces
in China;
(f) A review of the Book by Ted L. Napier of Ohio State University; and
(g) A report by Philip B. Williams P.E.
In light of the complexity of the issues and the volume of the material and information relevant to this
complaint, the Committee appointed five of its members to constitute a Sub-committee to review fully
the information and material provided by Probe and Acres and to report back to the full Committee.
The Sub-committee met on ten occasions to consider this complaint, while the full Committee
considered the complaint at sixteen of its meetings.
In considering the information and material submitted to it and in arriving at a decision, the Committee
recognized that:
(a) Experts may fairly and honestly disagree about the required standards of practice of their
profession. However, if a professional's conduct is deemed appropriate by reputable members
of the profession, he or she cannot be properly found to be guilty of professional misconduct.
(b) A feasibility study cannot reasonably be expected to reflect the degree of certainty, finality and
precision required of a project's final design and working drawings; and
(c) While Canadian engineers are required, no matter where they are practising, to meet a standard
of care, competence and diligence expected in Ontario, they are not expected to impose
Canadian social and cultural values upon foreign entities whose cultures and values may, and
often do, differ significantly from those accepted in Canada. Also, Ontario professional
engineers practising outside Canada may base their work on generally accepted international
engineering standards.
Applying these principles to the voluminous and complex material and information relevant to this
complaint, the Committee has come to the conclusion that there are in this case varying opinions among
competent, experienced and reputable experts as to whether the Feasibility Study reflects an acceptable
standard of engineering practice on the part of the CYJV in general, and Acres in particular.
Given the scope, complexity and location of the CYJV Project, varying opinions as to some aspects of
the Project, including assumptions, analyses and conclusions, are inevitable. In the particular
circumstances of this case, even such superficially straightforward matters as physical dimensions of
the dam can be subject to valid and honest disagreement. This is all the more true in the many areas
where technical decisions are inevitably influenced by social, cultural and other non-technical
In the final analysis, the Committee has concluded that this is not a case in w ~ l i c h one side or opinion
is "right" and the other is necessarily "wrong". As in many cases involving the exercise of professional
judgement and expertise, there can be varying opinions as to the correctness or desirability of a
proposed course of action and the work performed in determining the advisability of that course of
After a thorough and careful review of the information and material, and considering the extent of
support for the Feasibility Study from reputable sources, the Committee has concluded that work of the
CYJV in developing the Feasibility Study reflected a level of care, competence and diligence that met
a standard reasonably to be expected of Professional Engineers in Ontario.
The Committee is, therefore, of the opinion that the evidence before it does not indicate professional
misconduct or incompetence on the part of Acres. Accordingly, the Committee directs that the
Complaint not be referred to the Discipline Committee.
Dated this _..42,--,/"I7,--t/ __day of 1993
..... ,'---;::-
J.B. W' es, P.Eng. (Chairman)
P.O. BOX 552, S1N. "P"
(416) 463-7085
(416) 469-3039 (FAX)
July 26, 1993
Complaints Review Councillor
Association of Professional Engineers of ontario
1155 Yonge Street
Toronto ontario
M4T 2Y5
Re: Probe International Complaint Regarding Acres International's
Role in the Three Gorges Water Control project Feasibility study
I am writing on behalf of Probe International ("Probe") to request
that you undertake a review of the treatment of my client' s
complaint against Acres International for its role in the Three
Gorges Water Control Project Feasibility Study, pursuant to section
27 (3) of the Professional Engineers Act, 1984. The Complaints
Committee issued its decision and reasons in this matter on
February 2nd, 1993.
The reason for the request for review is that the Complaints
Committee failed to comply with the minimal procedural protections
found in the common law duty of fairness. Although the Complaints
Committee exercises a highly discretionary administrative function,
it is not excused from the duty to exercise its powers in good
fai-th and to act fairly.
The law in Ontario clearly recognizes that an "investigating" body
such as the APEO Complaint's Committee, which does not make final
determinatiops, is nonetheless required to act fairly. The
compliance!with the procedural pre-conditions to the exercise of
the statutory power of such bodies is carefully scrutinized.
(Re Emerson and Law Society of Upper Canada (1984), 44 O.R. (2d)
729 (H.C'LJ.))
Probe requests that the Complaints Review Councillor undertake to
review the following aspects of the Complaints Committee's
The Decision to Not Refer the Matter to the Discipline Committee -
Because the Evidence Before It Did Not Indicate Professional
Misconduct or Incompetence on the P a ~ t of Acres International
Probe suggests that the Complaints Committee's decision, to not
refer the matter to a disciplinary hearing on the grounds that the
evidence before it did not indicate professional misconduct or
incompetence, is improper.
At page 4 of the Committee's decision it reads:
Given the scope, complexity and location of the CYJV
Project, varying opinions as to some aspects of the Project,
including assumptions, analysis and conclusions, are
inevitable .... In the final analysis, the Committee has
concluded that this is not a case in which one side or
opinion is "right" and the other is necessarily "wrong."
Also at page 4 of the decision it reads:
... the Committee has come to the conclusion that there are in
this case varying opinions among competent, experienced and
reputable experts as to whether the Feasibility Study reflects
an acceptable standard of engineering practice on the part of
the CYJV in general, and Acres in particular.
Contrary to the Committee's ruling, Probe suggests the above
finding is ground to justify a. hearing in order to assess
credibility, examine witnesses, and interpret the standards that
should be uniformly applied.
The jurisdiction of the Complaints Committee is not to determine
the resolution of the complaint but to determine whether or not the
allegation warrants further review. In order to carry out this
role, a recognized test has been adopted by both the courts and
administrative tribunals.
Are there reasonable grounds to believe the claim could be
If there are reasonable grounds then a hearing should be granted.
It is appropriate for the Complaints Committee to ascertain if the
complaint has merit. The Complaints Committee did this and found
that the Probe complaint had meri"t. However, the Complaints
Committee then went much further.
The Complaints Committee received unsworn, untested and undisclosed
evidence. It assessed the credibility of this evidence, and on that
basis concluded that the evidence before it did not indicate
professional misconduct or incompetence on the part of Acres.
In Singh v. Minister of Employment and Immigration (1985) 22 D.L.R.
(4d) 119 (F.C.A.), the Supreme Court of Canada was faced with an
appeal from a decision of the Immigration Appeal Board not to grant
a hearing to a person claiming refugee status. The test set out in
the Immigration Act which must be met in order for a person to
receive a hearing, was that a hearing would only be ordered if the
Board was "of the opinion there are reasonable grounds to believe
a claim could be established" at a hearing. The court found that
while oral hearings were not always required, where serious issues
of credibility were involved, however, an oral hearing must be
The Complaints Committee made decisions about the merits of the
Probe complaint based on submissions of persons who were judged by
the Committee to be "reputable" members of the profession. These
members were professional engineers unilaterally chosen by the
Committee to assist in its investigation, or members of an
International Panel of Experts chosen by the proponent of the
project - the Chinese Government - and the World Bank to review the
Feasibility Report. Probe had no opportunity to address the
"apprehension of bias" of the reputable members. The issues of
credibility, apprehension of bias and conflict of interest require
a hearing with cross-examination and argument.
The submission of my client then, is that the decision of the
Complaints Committee to reject the need for a hearing was flawed
for two reasons. First the Complaints Committee exceeded its
jurisdiction by not limiting its role to determining whether there
are reasonable grounds to believe a claim could be established.
Secondly, it is a breach of the principles of fairness to reject
the need for a hearing when serious credibility issues are in
A further reason the decision is flawed is that it can be
interpreted as a violation of section 7 of the Charter of Rights.
The Supreme Court of Canada, in Singh v. MEl, concluded that at a
minimum, the concept of fundamental justice included the principles
of procedural fairness to act fairly, in good faith, without bias,
and in a judicial temper, and must give the opportunity to persons
to state their case.
The Decision to Not Refer the Matter to the Discipline Committee -
Because Acres followed Generally Accepted International Engineering
Probe suggests that the Complaints Committee failed to act fairly
and in good faith when it concluded that Acres followed "generally
accepted international engineering standards" . Neither the
respondent to the complaint nor the Complaints Committee delineated
what generally accepted international engineering standards consist
of or how they are determined.
Only the complainant, Probe, identified and applied well known and
accepted standards to the - Feasibility Study. These standards
included the Ontario standards set by the PEAO's Code of
Professional Conduct and Code of Ethics, the u.s. Standards applied
to similar circumstances in the U.S., the standards of the
In'ternational Commission on Large Dams, and the standards of the
U. S. Commission on Large Dams. In the complaint, Probe applied
these standards to the work of Acres and clearly showed where the
respondent's work did not meet the standards.
The standards used by Probe in its complaint are well known and are
recognized by the international engineering community and the
general public.
The rejection by the Complaints Committee of the standards used by
Probe was never justified. The conclusion then of the Committee
that Acres followed generally accepted international engineering
standards was unsupported. At the very least, the investigating
body must delineate or define a standard before ruling on
The principle of fairness demands that the standards or regulations
to be applied by the investigating body be identifiable.
The Decision to Not Refer the Matter to the Discipline Committee -
Because of the Opinions of Reputable Members of the Profession
The Complaints Committee failed to provide Probe with a fair,
impartial and public hearing of its complaint.
'rhe Complaints Committee in its Decision and Reason took the
position that:
Experts may fairly and honestly disagree about the required
standards of practice of their profession. However, if a
professional's conduct lS deemed appropriate by repu'table
members of the profession, he or she cannot be properly found
to be guilty of professional misconduct.
The Complaints Commi'ttee was assisted In its review by many
external parties. The Committee was assis,ted by reports prepared by
an International Panel of Experts chosen by the World Bank and the
Government of China to review and comment on the CYJV Feasibility
Study; by reports prepared by two Ontario professional engineers
with international experience; by reports prepared by an Advisory
Panel of three experienced Ontario professional engineers who were
asked by the Commi,ttee to provide an independent opinion of the
complaint; and by information obtained from several senior
geologists from Hubei and Jiangxi provinces in China.
The Complaints Cormnittee accepted these various bodies' reports and
concluded that the reports were f:com "repu'table members of the
profession" without giving Probe an opportunity to comment on the
credibility, bias, conflict or vested interests of the members. The
error in accepting these untested reports is compounded by an
obvious apprehension of bias concerning the reports.
The names of these "reputable members of the profession" on which
the Committee bases its decision were never disclosed in the
decision. Probe did not have any input into the selection of the
members of this body that deemed Acres to have carried out its
Three Gorges project with care, competence and diligence. A basic
doctrine of fairness is that the evidence that the decision maker
relies on for its decision be disclosed to the parties unless it
falls under an exception to the rule. In this case, no reason was
given by the Complaints Committee for not disclosing the sources
and nature of its information.
Finally, the Complaints Committee accepted the International Panel
of Experts' support for the Feasibility study without addressing
the irregularity in that Panel's process, which Probe brought to
the attention of the Committee. There was no effort made to respect
the right of the complainant to have an opportunity to test the
impartialioty and reliability of this evidence before the Committee
deemed it to be worthy of basing its decision upon.
It is well established that "justice should not only be done, but
should manifestly and undoubtedly be seen to be done." The
Complaints Committee's decision to unequivocally accept the
evidence of certain members it deemed reputable over the evidence
of Probe's experts is unacceptable. The unilateral selection of the
members to assist the Committee is fraught with procedural
irregularities and causes an apprehension of bias.
The Decision to Not Refer the Matter to the Discipline Committee -
Because Acres Conduct Was Deemed Appropriate by Other Members of
the Profession
The Complaints Committee, In its decision and reasons, stated:
"if a professional's conduct lS deemed appropriate by
reputable members of the profession, he or she cannot be
properly found to be guilty of professional misconduct."
This statement is inconsistent with the statutory responsibility of
the Complaints Committee to maintain and protect minimum testable
standards of the profession. lot is suggested that the Complaints
Committee failed to base its decision on the merits of the
complaint but chose rather to base its decision on the opinions of
a select group of reputable members iot chose to consult.
This failure is compounded by the fact that the evidence of other
professional members, who were deemed reputable by the Complaints
Committee, were ignored. The Committee chose to ignore the opinion
of members who condemned the Acres study while it accepted the
opinions of members who condoned the study. The basis for accepting
one reputable member over another was not given by the Committee.
The fact that there exists a fundamental disagreement over the
standards that should be applied to the Three Gorges Study between
reputable members should have provided a basis for the Complaints
Committee to conclude that an oral hearing is warranted.
Probe International suggests that the Complaints Committee's
reliance on the opinion of a select group of reputable members of
the profession for its decision, is the most serious error in the
The function of the Complaints Committee to ascertain the merits of
a complaint against a member of the Association cannot be abdicated
or delegated to some select group of members. Otherwise the lawful
regulatory function of the Complaints Committee is delegated to the
members it is meant to regulate. Such a situation calls into
question the integrity of the self-governing body for the
engineering profession. It also impairs the ability of the
Complaints Committee to regulate fairly and impartially. Most
importantly it undermines the conclusion of the Committee in the
Probe Complaint to not order a hearing before the Disciplinary
Hearing Panel.
As I am sure you are aware, there has been a great deal of media
coverage, nationally and internationally, concerning the complaint
brought forward by Probe. As the findings of the Complaints
Committee are public, it is of the upmost importance that Probe
receive a response to the concerns contained in this letter at the
earliest date. It will certainly influence the manner in which my
client proceeds with these very important issues.
Thank you for your attention to this matter and I look forward to
hearing from you in the near future.
Yours truly,
Mark Mattson
and Solicitors
Nancy L. Backhouse
Certified by the Law Society of Upper
Canada as a Specialist in Family Law
39th Floor, 1 First Canadian Placc
Dircct Linc (416) 863-4378
September 14, 1993
Council of the Association of
Professional Engineers of Ontario
1155 Yonge Street
Toronto, Ontario
Nl4T 2Y5
Probe International
c/o Mr.Mark O. Mattson
Barrister and Solicitor
P.O. Box 552 Station "P"
Toronto, Ontario
M5S 21'1
Mr. J. M. Gardiner
Acres International Limited
480 University Avenue
Toronto, Ontario
M5G 1V2
Dear Sirs:
As the Complain t5 Review Councillor for the /\ssociation of
Professional Engineers of Ontario, 1 have been asked by the
complainant, Probe International, to review the decision by the
Complaints Committee of the above-noted matter. "My role is to
determine whether th i s complai at was properly anel fairly processed.
Pursuant to 26 of the Profess';on.ol Engineers Act,my role
does not extend to inquiring into the merits of the complaint.
P.O. Box 100. 1First Canadian Place, Toron!o, Canada M5X ':':(XI'ISJ!, Fax 1'11'.>:
Toronto )\ul'l11 York OUI\W;1 VanuI I.! \ (;1'
In Monlrcal-.\fiWatcd with \lc\laslcr
I have read the decision of the Complaints Committee dated
January 21, 1993. I have read the letter elated July 26, 1993, from
Mark O. Mattson, solicitor for the cornp1ainant requesting that a
review be undertaken. I have further reviewed this extensive file. I
have concluded that there is no basis to interfere with the decision of
the Complaints Committee.
Yours truly,
Nancy L. Backhouse
225 Brunswick Avenue
Toronto, Ontario
Canada tv'i5S 21'/16
Phone: (416) 964-9223
Fax: (416) 964-82:39
email: web:eprobe
,john Hollh>-.:'cll
January 10, 1995
J\lfs. Deborah Dileo
Association of Professional
Engineers of Ontario
1155 Yonge Street
Toronto, ON
Dear Ms. Dileo:
In 1990 Probe International filed a complaint against Acres International with the
Association of Professional Engineers of Ontario regarding the Three Gorges dam
project in China. That complaint was ruled on in February 1993.
We have received a number of requests for Probe International's October 19, 1992
argument to the Complaints Committee in response to Acres International's May
8, 1992 submission to the same committee.
As explained in our letter of February 10, 1992 to Mr. EricW. Smythe, Manager
Complaints and Discipline, we understand that the complaint and response
process was a public process, and that Probe International's argument is a public
document. However, because the Association of Professional Engineers of
Ontario did not respond to that correspondence, we feel compelled to notify you
bei:Cnewe release our October 1992 argument. The argument will be released with
the decision of the Complaints Committee.
If you have any concerns regarding the release of Probe International's argument
to the Complaints Committee please notify us within three business days
Yours sincerely,
.. __.. , _'') '}
\\,j" ,/. t<;:1
- .-/ I ./j"
,/ 1./(./-1"
Patricia Adams
Executive Director
iliO!)"" 111temCliionai is a Project of [:ilerqy Prol;c F:e:;earci;
CharitalJlr,1 Taxation f\Jurrtxlr 0599050-59