9 December 2003
October 5, 2001
Environmental Policy
Asian Development Bank
6 ADB Avenue, Mandaluyong City,
0401 Metro Manila, Philippines
Fax: 63 2 636 2000
Total pages: 16
Re: Comments on the Environmental Policy Working Paper, August 2001
Dear Sirs and Madams,
Thank you for the opportunity to comment on the Environmental Policy Working Paper. Your effort to conduct consultations on the draft policy with a wide-range of citizen groups in different countries is appreciated. We are happy to see that you have already integrated previous inputs from civil society into the August version of the paper. We are particularly pleased with the Bank’s emphasis on the link between poverty and environmental degradation and the Bank’s willingness to develop consultations and allow for public comments throughout the preparatory process. We believe this step sets a valuable precedent for future Bank policy reviews and revisions.
We are attaching a list with our recommendations for the Environmental Policy with the following main concerns:
- Many sections in the paper are vague and do not outline specific plans for implementation of the paper’s various components.
- In order to mainstream the Bank’s Environmental Policy, we urge that all loan agreements between the Bank and the borrowing governments should require the borrowing government to comply with ADB Environmental Policy. Only with such a provision in loan agreements can compliance of the policy be enforced in the project level.
- As the Bank moves towards the private sector lending and increasing more program/sector loans, it is not clear in the policy how environmental assessment, categorization, and accountability of the project holder on environmental-related issues will be addressed. We strongly urge the Bank to include provisions on these matters to specify the details.
- The paper fails to address who in the Bank is responsible for Environmental Policy compliance and what the consequences are for non-compliance.
- We believe that the Environmental Policy needs to lay out concrete mechanisms for community participation.
General and detailed comments on different parts of the draft policy are attached. We also include a review on how environmental issues have been dealt with in the ADB-funded Samut Prakarn Wastewater Management Project to highlight key concerns and problems from an actual project so that the Environment Policy that is being drafted is based on actual experience.
We hope our comments are of use to you and that you can integrate our recommendations into the final version of the Environmental Policy. We strongly recommend that the revised version of the Policy which has incorporated all the comments and input be made public at least one month prior to the Board approval.
Thank you again for your consideration.
Sincerely,
Shannon Lawrence, International Policy Analyst
Environmental Defense
Steve Herz, International Policy Analyst
Friends of the Earth - US
Haidy Ear-Dupuy, Policy Advisor, Sustainable Livelihoods
Oxfam America
Nurina Widagdo, Manager, Asia Projects
Bank Information Center
Attachments
Comments on the ADB Environment Policy (9 pages) (Acrobat pdf 31KB)
Recommendations for ADB Environmental Policy: The Case Study of Samut Prakarn (3 pages)
Addresses
Environmental Defense
1875 Connecticut Ave., NW.
Suite 1016
Washington, DC 20009
Tel: 202-387-35000
Fax: 202-234-6049
www.edf.org
Friends of the Earth – US
1025 Vermont Ave NW, Third Floor
Washington, DC 20005
USA
Tel: 202-783-7400
Fax: 877-843-8687
www.foe.org
Oxfam America
1112 16th Street,, NW, Suite 600
Washington DC 20005
USA
Tel: 202-496-1195
Fax: 202-496-1190
www.oxfamamerica.org
Bank Information Center (BIC)
733 15th Street, NW, Suite 1126
Washington, DC 20005
USA
Phone: 2020-737-7752
Fax: 202-737-1155
Email:
www.bicusa.org