In the framework of the process of reviewing the environmental and social policies of the Inter-American Development Bank, we participated in public consultations held in the cities of Buenos Aires and Washington DC. Together with a group of civil society organizations, we raised certain concerns and recommendations regarding the review and consultation process, as well as the content of the draft of the proposed Environmental and Social Policy Framework.

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In January, the IDB began the public consultation process on a new Environmental and Social Policy Framework (MPAS), which has included, up to now, face-to-face and virtual consultations in the cities of Brussels (Belgium), City of Panama (Panama), Kingston (Jamaica), Lima (Peru), Buenos Aires (Argentina) and Washington DC (United States). In addition, the reception of a first round of virtual comments regarding the draft is contemplated until April 20.

From Fundeps, we participated both in the face-to-face public consultation carried out on March 10 in the City of Buenos Aires and in the consultation carried out on March 13 in the city of Washington DC. In turn, we plan to send written comments regarding the draft released by the Bank in the framework of a joint work we have been carrying out with a group of civil society organizations in the region.

In general terms, the draft MPAS proposes two different sections: a Policy Statement that basically establishes the roles and responsibilities that will correspond to the IDB in terms of compliance with the socio-environmental provisions and requirements of the new Framework; and a second section that includes the detail of the Environmental and Social Performance Standards with which the borrowers must comply. The draft proposes the inclusion of ten Standards: 1. Assessment and management of environmental and social risks and impacts; 2. Work and working conditions; 3. Efficiency in the use of resources and pollution prevention; 4. Community health and safety; 5. Land acquisition and resettlement; 6. Conservation of biodiversity and sustainable management of natural resources; 7. Indigenous peoples; 8. Cultural heritage; 9. Gender equality; and 10. Stakeholder participation and disclosure of information.

The IDB has argued that the proposed MPAS is based on five guiding principles: the non-dilution of current policies; results orientation (that is, effective implementation); the proportionality of the responsibilities and the established requirements regarding the level of risk of the project; transparency and the idea of ​​”doing good” beyond “doing no harm”.

However, the analysis that we have carried out together with the rest of the organizations involved in this process allows us to glimpse that, at least as proposed, the current draft is far from effectively complying with each of these guiding principles. In general terms, a dilution of policies and socio-environmental protection can be seen in many of the Performance Standards; it is not clear how effective the implementation of said MPAS will be; The idea of ​​proportionality is not reflected in many sections of the draft; and practically no sections can be identified in the draft that propose “doing good” in the sense that the Bank proposes: that of facilitating more sustainable social and environmental results.

In turn, the entire review process being carried out by the Bank is far from being transparent and “offering significant opportunities for participation by all interested parties” as established by the IDB. Precisely, as usually happens with the consultation processes carried out by the IDB, this process has had important shortcomings, especially in the objective of achieving effective participation by stakeholders.

We have duly expressed all these criticisms and problems to the Bank’s representatives in each of the consultations in which we participate and we accompany them with specific recommendations and suggestions that they should take into account when preparing the next draft of the Framework. In addition, these recommendations will be sent in writing in advance before the expiration of the term to send comments virtually.

Having completed the public consultations and once the period for receiving comments and suggestions virtually ends, the Bank must prepare a new draft of the Environmental and Social Policy Framework to be presented to the Board of Directors. Subsequently, the new Draft will be published for a new round of virtual comments for a period of 30 days, according to the Public Consultation Plan approved by the Bank’s Executive Board. Upon completion of this period, the IDB will develop the final version of the Framework that will be submitted to the Policy and Evaluation Committee of the IDB Board for final evaluation.

The IDB is a member of the IDB Group. It is a source of long-term financing for the economic, social, and institutional development of Latin America and the Caribbean and, unlike IDB Invest that invests in private sector projects, the IDB is responsible for investment in the public sector.

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