ACHPR African Commission on Human and Peoples' Hiqhts Human Rights our Collective Responsibility Constitution of the Federal Democratic Republic of Ethiopia (Constitution)." The Complainants submitted that in breach of the Constitution, the Respondent State appropriated to itself vide Proclamation No. 456/2005 the power to arbitrarily evict pastoralists from land and transfer same to private hands." 87. The Complainants also submitted that the view that pastoralism is unworthy of the Respondent State' s protection is also reflected in the omission, from the first environmental impact assessment of Gibe III, of any reference at all to the impact of the dam on downstream communities. And that the Respondent State paid no attention to the report by the World Commission on Dams (WCD) on the impacts of large dams on downstream communities. 88. The Author submitted that it instituted this Complaint on behalf of the Complainants due to fear of the consequences for them and their families if they had lodged the Complaint themselves; and that it had not been possible to file witness statements of the people of the Lower Omo or obtain the assistance of local NGOs for the same reason. The Author claimed that, in January 2013, the officials of the Respondent State had informed a gathering of tribal peoples, nongovernmental organisations (NGOs) and missionaries in Jinka that there would be consequences if they disclosed any information about developments in the Lower Omo to foreigners.27 That journalists have been effectively muzzled in Ethiopia resulting to the point of fleeing the Respondent State more than any other country in the decade preceding 2013. 89. The Complainants also submitted that whatever the truth of the criticisms that continue to be levelled against Gibe III, it has had or will have at least two undisputable consequences for the Complainants: (a) It will eliminate the annual flood on which the Complainants depend for their subsistence; and (b) f,n Organ of the Africen Union The steady and constant flow of water down the Omo, which will replace the seasonal floods, will allow the irrigation of large tracts of land in the Lower Omo. This in turn will result in the displacement of the Complainants to make way for sugar cane, cotton and bio£uel plantations. An earth dam has already been built for this purpose, just over 200 km downstream from the dam. K ..'~ AI;,. 18 https:/achpr.au.lnVO 0 a