The World Bank's Forest Policy Implementation Review and Strategy process (FPIRS) is entering its final stages. After having received input from numerous stakeholders throughout the world, the Bank suddenly appears to be less willing to share its draft new policy for meaningful input from all those engaged in the process, before presenting the policy to the Bank's Board of Executive Directors for its final approval.
This situation has generated great concern among a large number of NGOs. 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, which was facilitating the consultation process, urging it to demand that the World Bank change the process. Another letter was then sent to the World Bank's Vice President Ian Johnson. After expressing that the regional consultations implemented by the Bank "were promising steps towards a strengthened new Forest Policy", the letter noted that "the follow-up to these positive steps raises disturbing questions about the World Bank’s good faith in seriously consulting with civil society organizations. There has been little feedback and communication from the World Bank on the Forest Policy once the regional consultations were completed."
The NGO letter further stated that the World Bank publicly committed itself "to prepare a draft Forest strategy document which would be widely disseminated and discussed with stakeholders . . . before being presented to World Bank management. This promise appears to have been broken. On Christmas eve, a draft discussion strategy paper was sent to members of the Technical Advisory Group for their January meeting with the request not to make it public."
According to the letter, "it was only after strong concerns were voiced by NGOs as well as IUCN at a meeting with the World Bank’s Environment Department on January 16, 2001 that the draft discussion document on a strategy was placed on the World Bank’s website. However, we have not been given any assurances that revisions to the Forest Policy and Strategy will be made publicly available before their presentation to the World Bank’s Board of Executive Directors. At present, it is even unclear if World Bank staff is preparing a non-binding Forest Strategy or a new cross-sectoral Operational Policy on Forests."
The NGO letters were 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: "It is important to remember --he said-- 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.".
IUCN’s Director also reminded the Bank that "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."
Ian Johnson from the World Bank responded to IUCN, and the NGOs which had appealed to it, on February 7 and what follow are his remarks to IUCN's recommendations:
1. IUCN recommends that the World Bank publicly release a complete draft text of any revised Operational Policy on forests.
"The Bank remains committed to posting the revised version of Annex 5C (recommended revisions to OP 4.36 Forestry) on the FPIRS website as soon as this document is ready. We agree that it is important for various stakeholders to evaluate and provide feedback on these recommended revisions. A revised Annex 5C will be posted shortly."
2. IUCN recommends that the FPIRS team should extend the deadline for feedback beyond February 15th.
"We are encouraging interested individuals to send their comments as early as possible, with a suggested date of February 15, so that comments can be fully taken into account in the revisions currently underway. However, comments and feedback on the documents posted on the website are welcome at any time in the process and will be given serious consideration at all times."
3. IUCN 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.
"We will continue to track and compile all feedback being received by e-mail and comments sent for posting in the FPIRS Discussion Forum. We have been and continue to compile a registry of comments received and how they are reflected in the revisions being made to the documents. We will post a registry, or summary, of comments on the FPIRS website."
4. If the Bank does all these things, it should meet the expectations that it created in the original consultation process design and the regional consultations. Nevertheless, the World Bank should go one step further…IUCN recommends…that the FPIRS team release the revised strategy and policy after they have gone to CODE and before they go to the Board.
"It is our intention to make a revised strategy and policy available before the Board presentation."
With regard to Ian Johnson response on the first point, the fact is that the revised version of Annex 5 C is as yet (19 February) not available in the Bank's web site. IUCN's second recommendation is obviously linked to the first one. People need to read and study the revised version before making suggestions. The deadline should be changed and it's not enough to say that "comments and feedback on the documents posted on the website are welcome at any time in the process and will be given serious consideration at all times." Ian Johnson's response to IUCN's very precise 4th recommendation ("release the revised strategy and policy after they have gone to CODE and before they go to the Board") is so vague that it raises a huge question mark on whether the revised strategy will be open for discussion before its Board presentation or if the Bank's "intention" is to simply inform NGOs without providing a meaninful opportunity for comment.
It appears that, unless something changes, the Bank will again have missed another opportunity --as IUCN's Director says-- "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."
Article based on information from: NGO letter to Ian Johnson, 30 January 2001; IUCN letter to Ian Johnson, 29 January 2001; Ian Johnson's letter to IUCN, 7 February 2001.
