Jan 03, 2018 by Coalition

Joint Submission on WB’s Draft Guidance Notes

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On December 22nd, the Coalition together with 30 organizations sent to the World Bank a joint submission with recommendations on the Bank’s Draft Guidance Notes for borrowing countries regarding how to implement the Bank’s new Environmental and Social Framework.

The submission addresses two guidance notes relating to Environmental and Social Standards (ESSs) 1 – Environmental and Social Assessment, and 10 – Citizen Engagement. The submission highlights that these ESSs are purportedly intended to ensure that Borrowers design and implement projects that properly identify and mitigate social and environmental risks in a way that is transparent, participatory, and accountable, and therefore the Guidance Notes for Borrowers should provide additional information, explanation, and resources to guide implementation of the requirements contained in these ESSs.

According to the signatories of the joint submission, the draft Guidance Notes for ESS1 and ESS10, released for public comment on November 1, 2017, contain very little substantive guidance and do not provide adequate clarification, resources (such as references and definitions), or examples to support Borrowers in implementing the ESSs or to ensure adequate risk mitigation or community engagement. In some cases, the Guidance Notes use vague and abstract language that risks undermining the requirements in the Environmental and Social Framework.

Among other recommendations, the joint submission highlights that more concrete guidance is required on:

  • Avoiding adverse social impacts, including human rights impacts. The Guidance Notes are largely silent on this critical end goal of risk identification and mitigation.
  • Identification and assessment of social risks and impacts, especially those relating to human rights and impacts on “vulnerable and disadvantaged” groups. The guidance note for ESS1 do not provide guidance on how social impacts are to be assessed, and what is considered a “significant” impact. It is largely silent on the need for social and environmental assessments to be participatory and how that can be achieved.
  • Avoiding reprisal and retaliation. It is especially important that the Guidance Notes emphasize the Bank’s role in addressing risks of reprisals, since it is possible that Borrower governments might be complicit in or the perpetrators of intimidation and retaliation toward those raising concerns about projects.

In the submission, the Coalition and other signatories urged the Bank to “revise the Guidance Notes so that they provide substantive guidance, concrete examples, and references to additional outside tools and resources, with specific attention to disadvantaged or vulnerable groups,” and to prepare and release for public comment a new draft set of Guidance Notes incorporating the suggestions therein.

To see the full submission, click here. Or visit our World Bank page to find additional submissions from Coalition members.