Forest Policy and Forest Policy Implementation Review: our view

IUCN's letter to World Bank

The World Bank's Forest Policy Implementation Review and Strategy process (FPIRS) is entering its final stages.

After learning that the World Bank would not release its draft strategy and policy until it has already been sent to Senior Management, some 84 NGOs wrote to the IUCN ( International Union for the Conservation of Nature), which was facilitating the consultation process, urging it to demand that the World Bank change the process.

The NGOs' letter was followed on 29 January by a letter from IUCN's Acting Director General Simon N. Stuart to Ian Johnson. Stuart reminded him about the major aim of the forest policy consultation process:

Mr Ian Johnson
Vice President for Environmentally and
Socially Sustainable Development
The World Bank
1818H Street NW
WASHINGTON 20433
UNITED STATES OF AMERICA

29 January 2001

Dear Mr Johnson

I am writing to offer recommendations to ensure that the World Bank’s Forest Policy Implementation Review and Strategy (FPIRS) process remains as open, transparent and participatory as possible. A number of concerns have been raised by by staff and by members of the FPIRS Technical Advisory Group (TAG) when it met from 9-11 January 2001. You have, no doubt, seen the letter that was sent to me by representatives of 56 environmental NGOs on January 19^th 2001. (A copy is attached for your reference.) I recognize that the terrain is shifting quickly and that some of the concerns raised by the TAG members and the NGO letter have already been addressed by the World Bank. Nevertheless, I would like to take this opportunity to present IUCN’s recommendations to the World Bank on the next steps in the FPIRS process.

One of the toughest challenges in any consultation process is managing the expectations of the different stakeholders. In this case, the World Bank set very high expectations for how open, transparent and participatory the forest policy review process would be. The original "Consultation Process" document on FPIRS web site, which was agreed to with IUCN, indicates that the World Bank would share a copy of the strategy draft with all concerned stakeholders before its approval by World Bank senior management. During each of the regional consultations, the World Bank staff also indicated a clear intention to re-engage with the participants of the regional consultations and share a draft for their review and comment. We recognize that at some point in the policy/strategy development process, the World Bank needs to close the door and produce a strategy for itself and consult with its own staff. This is, after all, the World Bank’s policy and strategy, and we recognize that it is being written by World Bank staff and that it will ultimately be adopted by the Bank’s highest governing body.

The issue at hand centers on when the World Bank has chosen to close the door on the process. The original plan was for the draft strategy to go out publicly for wide consultations before the door was shut. Based on the timetable that was outlined at the TAG meeting and the fact that the document was circulated only to TAG members with the proviso that they not share it further, it appeared then that the World Bank was denying the participants from the regional consultations and other concerned stakeholders any opportunity to review and comment on a draft. This is the major source of the concerns over unmet expectations.

The FPIRS team has a very difficult challenge of trying to balance the concerns and interests of the internal constituencies of the World Bank with those of the external constituencies. IT is important to remember that the objective of the FPIRS process is not just to get a new policy formally adopted by the Board. Rather, the objective of the entire process underlying the FPIRS has been to build consensus on a forest policy and strategy that will have wide acceptance inside and outside that Bank so that it will stand a better chance of being well implemented than the 1991 policy/strategy. The proposed new strategy relies heavily on building partnerships both inside and outside the Bank in order to capitalize on the World Bank’s comparative advantage and accomplish more than it could on its own. Those external partnerships will not materialize if the Bank becomes too introverted in the later phase of the policy/strategy development process. This is not just a concern of the NGOs – these concerns were also voiced by representatives of several major bilateral donors at the TAG, institutions which will be essential partners in the implementation phase.

In order to ensure that the new policy and strategy enjoy widespread support for adoption and implementation, IUCN recommends that the FPIRS team pursue a two-track approach to its consultation strategy. The World Bank has a responsibility to obtain feedback on the draft strategy and policy from external stakeholders, particularly from all of those stakeholders who engaged with the World Bank through the FPIRS regional consultations. At the same time, it is also essential that the FPIRS team conduct thorough consultations with various constituencies within the World Bank itself. Having input and support from internal constituencies such as the Community of Practice, the Regional Vice Presidents and Country Directors, the Bank’s Senior Management, and the Executive Directors themselves are essential for the adoption of a new policy and strategy, to say nothing of their eventual implementation. The input from these two tracks will then need to be brought together by the FPIRS team in preparing revised drafts for OPC, CODE and the Board.

I note that the World Bank released the draft strategy discussion paper via its web site on January 19^th, with a request for feedback from interested stakeholders by February 15^th. While we consider this a step in the right direction, we recommend several additional steps to ensure an open, transparent and participatory process right through to final presentation to the Board of Executive Directors. To this end:

IUCN recommends that the World Bank publicly release a complete draft text of any revised Operational Policy on forests. Again, I note that the cover note of January 19th accompanying the draft strategy discussion paper indicates that a text will be forthcoming soon. It is important for the World Bank to lay its cards on the table at this point in the process so that various stakeholders can evaluate and provide feedback not only the strategy, but also the policy and the essential linkages between the two.
Given that the draft policy text has not been circulated yet, IUCN recommends that the FPIRS team should extend the deadline for feedback beyond February 15^th to allow further time for external and internal stakeholders to digest these documents and provide comments. The FPIRS team will also need to ensure that they have sufficient time to receive, assess, and incorporate the feedback that they get into a revised draft to be presented to OPC. The revision should reflect feedback from the external stakeholders, the internal stakeholders, and the Technical Advisory Group.
In order to ensure maximal transparency in the feedback process, IUCN also recommends that the FPIRS team compile a registry documenting each of the comments received, how they are or are not reflected in the revisions, and the rationale for that decision. Every stakeholder that comments is hoping to influence the draft, but it is unrealistic for every stakeholder to expect that each comment will be positively reflected in the revision, especially since some comments will conflict with others. But each stakeholder should be able to expect that their comments will be thoughtfully considered by the FPRIS drafting team. Compiling and then publicly releasing the registry will ensure that this expectation is met, and should also translate into a great deal more credibility for the revised document. I understand that the World Bank has compiled such a registry for comments on the draft Resettlement Policy, though it has not been released to external stakeholders. This is a useful precedent and I suggest that the Bank go one step further with the forest strategy and policy and make such a registry publicly available on the Bank’s web site.
If the FPIRS team does all of these things, it should meet the expectations that it created in the original consultation process design and in the regional consultations. Nevertheless, the World Bank should go one step further near the end of the process and solicit a second round of feedback before the final documents are presented to the Executive Directors for decision. IUCN recommends therefore that the FPIRS team release the revised strategy and policy after they have gone to CODE and before they go to the Board. This will go a long way to restoring confidence in the process as those versions will show stakeholders how their comments were incorporated into the drafts, and they will also reveal versions of the documents that bear the imprint of the World Bank’s Senior Management. I understand that the World Bank has committed to releasing the draft Operational Policy on Indigenous Peoples at this stage in its process, i.e. after CODE and before final submission to the Board. This is another useful precedent for the forest policy process to follow.

Compared to the process to develop the 1991 forest policy/strategy, I feel that the current FPIRS process has been a significant step forward for the World Bank in terms of openness, transparency and the willingness to seek out the views of multiple stakeholders, at least through the first TAG session. The nine regional consultations were a constructive innovation, and I commend the FPIRS team for reflecting a good deal of what they heard in those meetings in the draft strategy discussion paper. Implementing the recommendations set forth above should go a long way to restoring confidence in the FRIRS process.

As a closing suggestion, I would also like to suggest the World Bank re-examine the various steps in the consultation process for the forest policy/strategy, as well as other recent and on-going policy and strategy development processes in order to develop a set of best practices for World Bank consultation processes. A more consistent approach to consultation processes in general should help to set clearer procedural expectations both within and outside the World Bank for the future.

Sincerely yours,

Dr Simon N. Stuart
Acting Director General
IUCN - The World Conservation Union

CC:
James Wolfensohn, President, The World Bank
Marcus Colchester for the signatories to 19 January 2001 letter transmitted by the Forest Peoples Programme
FPIRS Technical Advisory Group Members )c/o Elisabeth Pelletier