A Rapid Response Analysis

A Continental Call for Accountability, Climate Justice, and Energy Sovereignty: the Case of Inga 3

Executive Summary

If water is life then rivers must have life. The African Continental Forum on Mega-Dams and the Climate Crisis, held from June 25 to 27, 2025, in Kinshasa, Democratic Republic of Congo, brought together civil society organizations, community leaders, and environmental experts from across 15 African countries. The central focus of the Forum was the controversial Inga 3 Hydropower Project. Participants interrogated the economic, ecological, and human rights implications of the project and called for a moratorium on its development until robust, independent, and participatory impact assessments are conducted.

Inga 3 is envisioned to generate over 11,000 megawatts of electricity, primarily for export to industrial markets in South Africa and neighboring states. Yet the project raises serious questions about who benefits and who bears the cost. Communities near the proposed dam site face displacement, with little evidence of adequate consultation, compensation, or access to future electricity benefits. Although the World Bank itself has identified Inga 3 as a high-risk venture, key financiers remain interested. The analysis below outlines emerging concerns, critiques the current trajectory, and proposes strategic interventions rooted in justice, accountability, and long-term sustainability.

1. Policy Instruments and Legal Standards

This analysis draws on internationally recognized frameworks including the UN Guiding Principles on Business and Human Rights, specifically Principles 4, 6, and 18, which address state duties to prevent adverse impacts through oversight and transparency. It also references the African Charter on Human and Peoples’ Rights, particularly Articles 21 and 24, which safeguard the right to natural resource sovereignty and environmental well-being. Compliance with the World Bank Environmental and Social Framework (2022) and the UNFCCC’s guidance on Nationally Determined Contributions and just transitions remains essential for credibility and accountability.

2. Timeline and Critical Developments on Inga 3

The Inga 3 hydropower project has evolved over two decades against a backdrop of shifting political priorities, regional energy ambitions, and mounting public scrutiny. Initial feasibility studies, undertaken in the early 2000s, were promoted as part of a long-term strategy to transform the Democratic Republic of Congo into an energy export hub. However, early momentum stalled when international partners pulled back, citing inadequate institutional safeguards and lack of transparency. These concerns, repeatedly echoed in donor evaluations and multilateral audits, underscored persistent gaps in governance structures overseeing large infrastructure in fragile state contexts (World Bank, 2015; OECD, 2021). Despite these warnings, the project was revived between 2013 and 2018, now backed by a consortium of Chinese and Spanish firms under a private-public financing model, though key agreements and environmental data remain inaccessible to affected communities and civil society observers.

The period between 2020 and 2024 marked a significant institutional shift. The African Development Bank, through its Africa Hydropower Modernization Program, signed cooperation agreements with the DRC government, signaling renewed regional and donor interest. This support was justified on the basis of energy security and climate mitigation, echoing the broader push within African Union policy frameworks to position hydropower as a green, scalable energy source. Yet emerging evidence, from IPCC Working Group III reports to independent emissions modeling by Barros et al. (2011, Nature Geoscience) has challenged the climate credentials of large dams, particularly in tropical ecosystems where methane emissions from reservoirs often rival or exceed those of fossil-based plants. The tension between these projected benefits and under-assessed risks raises urgent questions: Who defines the parameters of a green transition? And whose environmental futures are being negotiated at the margins?

In June 2025, at the African Continental Forum on Mega-Dams, civil society organizations representing over 15 African countries issued a unified public statement rejecting the current trajectory of the Inga 3 project. This position did not reject energy development outright. Instead, it called for a rights-based reconfiguration of energy planning that accounts for social equity, ecological preservation, and long-term fiscal sustainability. This intervention reflects a broader shift in public discourse, one that aligns with the UN Guiding Principles on Business and Human Rights (Principles 4 and 6), which call on states and business actors to prevent adverse impacts by ensuring coherence across investment, climate, and human rights policy. The Forum’s statement challenges governments, lenders, and multilateral bodies to abandon the assumption that scale alone determines value and invites a more measured, transparent, and democratic approach to energy futures across the continent.

3. Key Issues Emerging from the Forum

a. Declining River Freedom and Expanding Hydropower

Only one-third of the world’s rivers remain free-flowing, according to a landmark global assessment published by WWF and McGill University in Nature (Grill et al., 2019). The rest have been fragmented or obstructed by dams, diversions, and engineered flows. In Africa, this trend is accelerating rather than slowing. With hydropower supplying an estimated 17% of the continent’s electricity (International Energy Agency, 2022), governments and development banks continue to promote large dams as central to their energy expansion strategies. The African Development Bank’s Hydropower Modernization Program reflects this approach, channelling significant financial resources into both the construction of new hydropower infrastructure and the rehabilitation of ageing facilities. This program, supported under the banner of climate resilience and energy security, assumes hydropower is a net contributor to low-carbon development.

Recent scientific assessments, however, cast doubt on the climate benefits of large hydropower reservoirs, particularly in tropical regions. Studies such as Barros et al. (2011, Nature Geoscience) demonstrate that dams can release significant volumes of methane, a gas with more than 80 times the warming potential of CO₂ over a 20-year period. Reservoirs, especially in warm and biodiverse regions like the Congo Basin, create conditions where organic material decomposes under water and releases methane in large quantities. These emissions are often uncounted in national climate inventories, creating a mismatch between declared mitigation efforts and actual atmospheric impact. The IPCC’s Sixth Assessment Report (2022) emphasizes the need to account for all greenhouse gas sources in land and water systems when evaluating infrastructure projects, especially under climate finance mechanisms. This raises critical questions about the classification of large hydropower as “green” energy under global climate frameworks.

In the case of Inga 3, the implications are concerning. The project would alter the natural flow of the Congo River, one of the last major rivers on the planet that still flows uninterrupted from source to ocean. Beyond its ecological importance, the river sustains the livelihoods of downstream fishing communities, floodplain farmers, and traditional water users whose rights and cultural practices are closely tied to its seasonal cycles. The proposed dam would affect sediment transport, aquatic biodiversity, and flood regulation in ways that may be difficult to reverse. These disruptions carry not only environmental costs but also legal and moral weight under African human rights standards and global environmental norms. Policymakers and international institutions must ask: can a project that undermines biodiversity, disrupts food systems, and contributes to hidden emissions truly be justified in the name of sustainable development? The answers will shape the credibility of Africa’s climate leadership and its ability to influence the global transition narrative on its own terms.

b. Inga 3: Built for Export, but at What Cost?

The stated goal of the Inga 3 project is to supply electricity to the Southern African Power Pool and large industrial consumers outside the DRC. Yet, the country’s domestic electrification rate remains among the lowest in the world. Under the DRC’s Energy Compact, adopted during the UN High-Level Dialogue on Energy, the government committed to increasing national energy access. Large infrastructure projects like Inga 3 risk undermining this goal by prioritizing export revenues over equitable distribution.

Forum participants asked critical questions about the meaning of development in this context. What happens to rural and Indigenous communities when their lands are submerged? How do planners calculate the social cost of displacing households, losing ancestral territories, or degrading rivers that support local economies? Participants from Ghana, Mozambique, and Nigeria shared examples where large dams led to long-term dispossession without meaningful benefits. These testimonies reinforce the view that development divorced from rights-based accountability cannot produce sustainable or equitable outcomes.

c. Governance Failures and Financial Risk

The World Bank has classified Inga 3 as a high-risk project, citing concerns about governance, environmental impacts, and institutional safeguards. Despite this, international financiers, including multilateral development banks and private consortia, have signaled continued interest. This persistence is shaped in part by geopolitical competition, industrial energy demand, and carbon accounting incentives that currently favor hydropower under international climate finance regimes.

The African Development Bank has noted that energy sector liabilities are a major contributor to rising sovereign debt burdens. Inga 3, projected to cost more than US$14 billion, could significantly increase the DRC’s exposure to long-term fiscal risks. Moreover, the absence of publicly available financial models, transparent bidding procedures, or enforceable community benefit-sharing mechanisms heightens concerns that the project will deepen inequality while producing energy that bypasses the very communities most affected by its construction.

4. Strategic Recommendations

The Inga 3 hydropower project presents an urgent case for applying international human rights standards to large-scale infrastructure planning. As it stands, the governance framework surrounding the project lacks the necessary transparency, participation, and accountability to ensure it serves both national interests and affected communities. In line with Principle 4 of the UN Guiding Principles on Business and Human Rights, which calls on states to ensure that their development agencies, investment arms, and business partners do not facilitate rights violations, governments and financiers must take immediate steps to recalibrate this project.

In the immediate term, basic transparency and due diligence conditions are still a concern. This need to be addressed. This includes the public release of all Environmental and Social Impact Assessments (ESIAs), feasibility studies, and signed financing agreements. These documents must not remain within the confines of government ministries or private consortia. Instead, they should be made accessible to a broader public and reviewed through independent, multi-stakeholder processes that include civil society organizations, technical experts, Indigenous groups, and subnational government actors. This is not a matter of administrative preference but of legal obligation. Principle 6 of the UNGPs emphasizes the responsibility of states to maintain institutional coherence and ensure that investment policy frameworks do not undermine their human rights commitments.

In the medium term, the Government of the Democratic Republic of Congo, in collaboration with its regional and international partners, should commission a full and impartial audit of the Inga 3 project. This audit must assess not just technical feasibility or financial return but also ecological integrity, community resilience, and energy justice metrics. Such an audit must include the voices of local communities, especially those at risk of displacement or environmental harm, and draw on regional expertise in energy policy, human rights law, and ecological science. The audit must also critically evaluate whether Inga 3 meaningfully contributes to the DRC’s national electrification goals, or whether alternative energy pathways, such as decentralized solar, mini-grids, and distributed wind systems, may deliver more inclusive, climate-aligned outcomes with fewer risks. This reflects the imperative of Principle 18, which calls for human rights due diligence processes that are context-sensitive and that actively involve affected groups in the identification, assessment, and response to risks.

Institutionalizing the principle of Free, Prior, and Informed Consent (FPIC) across all stages of the project, from planning to financing to construction, should become a non-negotiable governance benchmark. FPIC is not simply a procedural step but a foundational safeguard for Indigenous peoples and marginalized communities, and its absence undermines the legitimacy of any development intervention. Across Africa, there is increasing recognition that energy development cannot proceed without social license, and Inga 3 provides an opportunity to set a regional precedent. The African Commission on Human and Peoples’ Rights has already interpreted Articles 21 and 24 of the African Charter as protecting community rights to land, water, and cultural heritage, particularly in the face of extractive or displacement-inducing projects.

In the long term, systemic reform is required to address deep-rooted inequalities in energy access and decision-making. Large-scale infrastructure development has too often been top-down, urban-biased, and externally financed with little alignment to the realities of rural electrification or ecological stewardship. Energy finance should be reoriented toward community-led renewable systems, especially solar microgrids, which are cost-effective, climate-resilient, and socially acceptable. According to the International Renewable Energy Agency (IRENA), decentralized renewables can reach underserved populations faster and at lower lifetime costs than grid expansion in many African contexts. Moreover, distributed energy systems allow for greater democratic control, local job creation, and gender-inclusive benefits.

At the continental level, there is a compelling need to establish an African Commission on Energy and Ecological Justice. This body would function as an oversight and regulatory entity to review high-risk infrastructure proposals before approval. It would ensure that any large-scale energy project complies with binding standards related to environmental protection, fiscal transparency, and human rights. Such a commission could work in close collaboration with the African Union, UNECA, the African Development Bank, and national regulators. Its creation would not only fill a current institutional gap but would help restore public trust in energy planning processes that have, for too long, excluded those most affected by their outcomes.

Way Forward

This rapid response paper will be shared with key regional stakeholders and climate negotiators ahead of COP30. It reflects a growing consensus among African civil society that large-scale energy planning must no longer exclude the voices of those most affected. The question is no longer whether Inga 3 can be built. It is whether the model it represents can be sustained without violating the values of accountability, equity, and environmental justice.

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