Sent by World Rainforest Movement, Forest Peoples Programme and Environmental Defense, on behalf of 47 International NGOs.
Mr. James D. Wolfensohn
The World Bank
1818 H Street, NW
Washington, D.C. 20433
Via Fax: 202 522 3031 & Mail
Dear Mr. Wolfensohn,
We thank you for the opportunity to provide comments on the Bank’s draft policy for adjustment lending, now named Development Policy Lending (O.P. 8.60).
The undersigned NGOs have a long-standing interest in forest policy and many of us participated actively in the Bank’s consultations on its new “Forests Policy” (O.P. 4.36). This consultation process led to a broad consensus that the new Forests Policy should cover the impacts on forests of adjustment and programmatic lending. However this unanimous recommendation was swept aside with the promise by Bank management that the problem of forests and the impacts of adjustment lending would be addressed in a future revision of the Bank’s OP 8.60. During the Board discussion of the revised “Forests Policy”, several Executive Directors referred to the need to include references to the impact of structural adjustment in the new “Forests Policy”. In response, Bank management assured the Board:
‘Management plans to address the treatment of possible forestry impacts of programs supported by Bank adjustment operations as part of the treatment of overall environmental impacts of such programs in the ongoing update of Operational Directive OD 8.60 into a new OP/BP 8.60…. Management expects that the new policy will include specific provisions setting out a transparent mechanism for systematically addressing the environmental aspects, including in particular possible forestry impacts’
(Source: World Bank document # R2002-0195/2 Revised Forest Strategy for the World Bank Group: Management Responses to Executive Directors’ Comments and Suggestions. Dated 31 October 2002: page 4 (emphasis added).
The present draft of OP 8.60 (December 2003) does not reflect this commitment made to the Bank’s Board. The draft OP does not contain specific provisions that address the impact of structural and programmatic lending on forests.
While our focus here has been on the Bank’s promise with regards to forests, we are equally concerned about the lack of inclusion in the draft OP 8.06 of a requirement to hold public consultations on the development of these loans in borrowing countries. It is difficult to reconcile the lack of such a requirement with the Bank’s emphasis on transparency and country ownership in its discourse and publications.
Furthermore, we think that paragraphs 10 and 11 of the draft OP are not befitting an institution whose stated mission is poverty alleviation and sustainable development. These paragraphs require Bank staff to determine and to describe the effects of specific country policies supported by the Bank on the poor, especially on the most vulnerable groups, and on the environment and natural resources. Yet, the draft OP does not require that Bank staff ensure that effective measures are in place that will avoid or mitigate negative social and environmental impacts of Bank lending.
The new OP 8.60 will affect approximately one third of all Bank lending. In the absence of a firm requirement to ensure that these loans do not lead to negative social and environmental impacts, the Bank’s focus on achieving the Millennium Development Goals and its commitment to sustainable development have to be seriously questioned.
Mr. Wolfensohn, in your foreword to the 2003 Development Report you state that “Environmental and social assets matter greatly for well-being and productivity, but they are often neglected.” Yet it is this neglect that is most in evidence in the draft OP 8.60. We urge that the draft policy be substantially revised.
World Rainforest Movement
Forest Peoples Programme
On Behalf of:
Amici della Terra
Amigos da Terra/Amazônia Brasileira
Amigos da Terra
Censat Agua Viva
Centre for Environmental Information and Education
Cordillera Peoples Alliance
Friends of the Earth International
Friends of the Earth-US
KOUEDA KOUNG JEAN
Global Village Cameroon
Global Witness Phnom Penh
Grupos Ecologicos de Risaralda
Mary Turgi, CSC
Holy Cross International Justice Office
Dr Rowland Benjamin D.O.
Information for Action
Instituto del Tercer Mundo / ITeM
International Rivers Network
Japan Center for a Sustainable Environment and Society (JACSES)
Movimiento Madre Tierra
Rainforest Action Network
Rainforest Foundation US
Rainforest Information Centre
Rettet den Regenwald e. V.
Miriam A. Young
RFK Memorial Center for Human Rights
Elías Díaz Peña
Solidaritas Perempuan (Women's Solidarity for Human Rights)
The Bretton Woods Project
The Development GAP
Knud Vöcking Urgewald e.V.
Ann Kathrin Schneider
World Economy, Ecology and Development (W.E.E.D.)
Please direct response to:
World Rainforest Movement
11200 Montevideo - Uruguay
Tel. 598 2 413 2989; Fax: 598 2 410 0985
1c Fosseway Business Centre
Stratford Road. Moreton-in-Marsh, GL56 9NQ UK
Tel. + 44 (0)1608 652893; Fax + 44 (0)1608 652878
1875 Connecticut Avenue, N.W.
Washington, D.C. 20009
Tel. 202 387 3500; Fax 202 234 6049