Comments to New EBRD Strategy for Armenia

Comments to New EBRD Strategy for Armenia


“EcoLur” Informational NGO is submitting certain comments on the new strategy of the European Bank for Reconstruction and Development for Armenia. The letter addressed to EBRD Yerevan Resident Office Head Mark Davis particularly says, “The new strategy of the EBRD lacks any requirement on the mandatory assessment of the effectiveness of the projects implemented with the EBRD support, as the previous one did, not only in terms of the size of capital investment, but also in terms of socio-economic-environmental parameters, which reflect the situation in the interested groups – local population, civil society, business environment. As a rule, the monitoring of the projects is carried out only within the parties, which are directly interested in this loan. And their very opinion is prevalent, which particularly refers to Social and Environmental Assessment Impact of the project.

As a matter of fact, the policy adopted by the bank in social responsibility is not reflected and doesn't have any measurement. Mechanisms for monitoring and assessment of effectiveness of implemented projects need to be developed including civil society both in the development of proposals and monitoring of project effectiveness.

The priorities of the strategy need to be reviewed, which are presented exclusively based on the bank interests and officially directly relevant to them. The opinion of civil society is not a priority in the strategy, which has been raised many times to the top managers of the bank and public forms and in the press. First of all, it refers to Amulsar project. In the proposed Strategy Amulsar project is considered as an example of “responsible” mining industry. Whereas the strategy says nothing about numerous assessments of independent specialists, which value Amulsar project as unsustainable in economic viewpoint and extremely hazardous in environmental and social viewpoint. The objectiveness requires to present in the strategy negative assessments as well and then to consider Amulsar project in the viewpoint of priorities.

One of the points of the new Strategy for Armenia is devoted to public sector, which says, “Armenia has a diverse and active civil society with informal grassroots groups playing an increasingly prominent role in mobilising urban middle class civic activism. …T Armenia’s media operates without censorship, with authorities tolerating critical reporting. Freedom of the Internet is respected. At the same time, public trust in the political process remains low, resulting in a low rate of political participation. …”

Nevertheless, the role of the public sector in all the proposed solutions is ignored, which is reflected in the current policy of the bank, at least in Armenia. In recent two years the EBRD Office in Yerevan didn’t initiate any formal or non-formal meeting with those NGOs and non-formal movements which demonstrated activity in the monitoring of the projects funded by the EBRD.

Moreover, the PCM - the Project Complaint Mechanism of the EBRD, which should have demonstrated independence in decision-making process, without any ground turned down the complaints filed on Amulsar project implemented by Lydian International Company, where EBRD has 7.3% shares. An alternative EIA should be included in the project assessment, which will be considered in parallel with their own ESIA taking into account the current practice and to avoid further disputes.”

13:23 November 03, 2015


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