Latin American civil society organizations "strongly recommend that CODE members send the first draft back to Management. Without structural changes to the Safeguard Policy proposal, we question if the second phase of consultations and the review process will be meaningful".
According to them, dilution of the current Bank Safeguards Policy is evident throughout the draft. Basic World Bank requirements to assess and manage environmental risks and impacts before approval are now relaxed by providing the unbounded deferral of appraisal of significant environmental and social risks or impacts to implementation.
A second major concern is that the draft proposed Social and Environmental Policy and ESSs significantly shift responsibility for safeguards implementation to borrowers, but provides less clarity than current exists on when/how the use of borrower systems would be preferable and acceptable. It remains unclear how the proposed draft will help the Bank and Borrowers make decisions to prepare or use borrower systems to effectively implement safeguards in countries where major dilutions of national social and environmental frameworks are being proposed or recently approved.
"The proposed draft misses opportunities to meet the highest international standards. The draft provides no binding language regarding international human rights standards and allows governments to "opt out" of compliance to the Indigenous Peoples Policy to protect Indigenous Peoples rights, which unequivocally undermines the international consensus regarding the specific and fundamental rights of indigenous peoples over their lands, resources and the course of their own development", the organizations argue.
LAC CODE Letter 24.07.14.pdf
