EcoLur’s Comments on EBRD Responsible Governance Policy Revision

EcoLur’s Comments on EBRD Responsible Governance Policy Revision


The European Bank for Reconstruction and Development is going to revise its responsible governance policy in the following directions: environmental and social policy, public information policy and grievance procedures. EcoLur took park in the workshop on EBRD policies in Tbilisi and makes the following comments:

Under the condition of Armenia not joining the EU Association Agreement and factual refusal from applying the main principles of European policies in governance based in transparency, accountability, wide public participation in decision-making, the relations with EBRD acquire special significance, which, to a great extent, affect on the socio-economic situation in the country are committed to ensure the compliance of the taken actions to such priorities as sustainable development, adaptation to climate change and minimization of consequences, European Union Water Framework Directive, international environmental conventions etc.

In this context, regular updating EBRD social and environmental policy should enhance the implementation of the European standards in our country, which the projects funded by EBRD should get as close as possible. The requirements to the business entities implementing their activities with EBRD funds should also be stricter.

Resource Efficiency: In most EU non-member countries, including Armenia, the assessment of resource efficiency in soil governance projects is missing, which are based on the balance of profit and loss. The assessment of expected damage should be determined and introduced, which is caused to health and environment, should be equivalent to be comparable with the assessment of socio-environment measures. It will make the bank’s policy on this criterion visible and accountable.

Human Rights: we think the policy run the bank doesn't protect human rights in a sufficient manner, as the liability vests on the business entities, while governmental bodies and EBRD are exonerated from this liability. Armenian practice shows that people's private property and land areas are seized for the purpose implementing such projects, which are not interesting for the people themselves. While governmental bodies alienate land areas from the communities and owners in violation of laws and human rights exercising the policy of pressure. When the guarantees of protection of human rights and possessions don't exist, institutions of democratic development represented by EBRD should be the guarantees of human rights and demand the compliance with these rights from all stakeholders, government, and business, should follow and protect human rights in all their investment projects and avoid the investment, where these rights can't be guaranteed.

Aarhus Convention and Espoo Convention

The factual public participation in EU non-member countries has imitation natures favored by the absence of procedures allowing to take public opinion into consideration. This also violates human rights and owners' rights and generates social tension in project affected areas. The requirements of the procedures, which take public opinion into consideration during project discussion, will enable avoiding most conflicts: among business entities and communities, different groups in one community, governmental bodies and public, as well reducing corruption risks.

EBRD understands local population affected by the project when it uses the term population. But the projects with high risks affect larger territories than those directly involved in the project infrastructure. Taking into consideration that EBRD mission says that its main aim is to support development of countries, the whole civil society should be the affected group. 

Introducing requirements on the assessment of impact in the projects EBRD across boundaries will promote the mitigation of tense conflicts occurring during implementation of projects with high risk degree (А and B), including not allowing manipulating with environmental categories in political aspect. 

Deferring accomplishment of project assessment following the approval of Board of Directors

Armenia joins Bankwatch's concerns in regard with the new loophole in the policy (Clause 40 of draft ), which says that EBRD’s Board of Directors has the discretion to agree a deferred level of project appraisal following Board approval and after the signing of the financing agreements in specific circumstances. This approval will require completion of further environmental and social appraisal. The project approval by the Board of Directors beats a political signal, that project implementation is feasible giving the client ground to refer to further appraisal as a usual formality.

The next clause (41) also has a provision, which causes concerns: it lays down alternative approaches to be subject to Board consideration on a case-by-case basis, which, as a matter of fact, allows any project to digress from the policy, of the Board of Directors gives its approval. This clause factually undermines the underlying reasons of the policy.

Biodiversity: The formulation changing the meaning of biodiversity conservation principles also causes concerns. It particularly refers to “compensation of biodiversity”. If the project impacts on red-listed species, some species are already on the verge of extinction or are extremely vulnerable, it's clear these species can't be compensated in any way. The formulation about the activities in protected areas is diluted by including such terms as 'mitigation' to prevent consequences etc. The status of specially protected areas already supposes that certain activities are banned in these zones. 

You can find the full version of the comments in Russian and Armenian.

16:42 March 14, 2014


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