APPENDIX 3
Memorandum from Friends of the Earth-US
It has come to my attention that you are conducting
a review of the Export Credits Guarantee Department (ECGD) and
this may include issues such as environmental standards. Friends
of the Earth-US formally submits these comments for the record
as part of your review.
Friends of the Earth-UK fully recognizes that
this is a review by the United Kingdom of a part of your own government.
However, we feel that our input and experience working with export
credit, insurance and finance agencies (ECAs) could be of some
use, particularly in light of recent G8 mandates for common environmental
standards for such agencies. It is our experience that the adoption
of strong, clear and transparent standards can improve projects
where necessary and prevent unsustainable ventures from going
forward. Indeed, improving environmental impact and refusing to
support environmental destruction are basic concepts for most
international financial institutions. These concepts should be
a central part of ECGD's mission as well.
Now more than ever there is a need for international
adherence to the concept of sustainable development. As private
investment dollars outpace traditional public aid to developing
countries it is essential that ECAs begin to join the rest of
the international community in promoting internationally recognized
standards as a requirement of corporations seeking their support.
From our perspective a good starting point would be for ECAs to
apply World Bank Group environmental standards. Application of
World Bank standards includes adherence to their Pollution, Prevention
and Abatement Handbook and Operational Policies as well as consultation
with locally-affected people and environmental impact assessment
transparency.
For your review, I have enclosed a compilation
of Export Credit & Investment Insurance Case studies entitled,
"A Race to the Bottom: Creating Risk, Generating Debt and
Guaranteeing Environmental Destruction"[2].
As you will see, lack of internationally recognized standards
and transparency can create the very risk that ECGD is designed
to prevent. I encourage you to take a particularly close look
at the section on the proposed Ilisu Dam in Turkey.
Recognizing that this particular project is
quite sensitive and severely mishandled to date, Friends of the
Earth-US urges ECGD and all other ECAs to pull any support from
Ilisu. We will be making the same recommendation to our own Export-Import
Bank of the United States due to a number of violations of internationally
recognized standards. Also enclosed is a report on climate change
issues related to the U.S. Export-Import Bank and the US Overseas
Private Investment Corporation.
Friends of the Earth—US
10 September 1999
2 A copy has been placed in the library. Back
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