APPENDIX 8
Memorandum from the Environmental Defense
Fund
1. We understand that the Select Committee
on International Development is reviewing the UK's Export Credits
Guarantee Department. The Environmental Defense Fund (EDF) wishes
to submit comments for the record to assist the Committee in its
review. EDF is a US-based international environmental organization
with over 300,000 members and supporters world-wide. Although
EDF is not based in the United Kingdom, we hope our input and
experience working with export credit, insurance and finance agencies
(ECAs) may be of some use, particularly in light of the recent
commitment of G8 heads of state to develop common environmental
guidelines for export finance agencies, with the aim of completing
this work by the G8 Summit in 2001. The adoption of strong, clear
and transparent environmental standards can improve projects where
necessary, and ensure that risk to the environment does not eventually
result in political and financial risks that ECAs are supposed
to mitigate.
2. Moreover, in many OECD countries we believe
there is an increasingly untenable disconnect between the international
environmental commitments of governments, the environmental standards
that governments support in bilateral and multilateral development
finance, and the lack of corresponding standards in the bilateral
export finance activities of the same governments. Indeed, improving
environmental impact and refusing to support environmental destruction
are basic operating principles now for the public international
financial institutions, including their private sector finance
affiliates. We believe these concepts should be a central part
of ECGD's mission as well.
3. We believe a good starting point would
be for ECAs to apply World Bank Group environmental standards.
Application of World Bank standards includes adherence to the
Bank's Pollution, Prevention and Abatement Handbook and Operational
Policies as well as consultation with locally-affected people
and environmental impact assessment transparency.
4. For the review of the Committee, attached
is a copy of the Background Memorandum EDF[5]
circulated at an informal presentation before the OECD Trade Directorate
Working Party on Export Credits and Credit Guarantees last November.
The Memorandum examines the arguments and bases for higher, common
environmental standards for ECAs, considers different kinds of
environmental risk, and addresses certain concerns commonly expressed
by ECAs about the feasibility or desirability of such common standards.
5. Finally, together with numerous other
non-governmental organizations around the world, EDF urges ECGD
and all other ECAs to withdraw any proposed support for the Ilisu
dam in Turkey. We will be making the same recommendation to our
own Export-Import Bank of the United States because of this project's
manifest violation of numerous internationally accepted environmental
good practices, as well as the project's potential for extreme
cultural and social disruption which in practice will be virtually
impossible to mitigate.
Bruce Rich
Senior Attorney and Director
International Program
Environmental Defense Fund
Washington DC
September 1999
5 Export Credit Agencies: The need for more Rigorous,
Common Policies, Procedures and Guidelines to Further Sustainable
Development, Bruce Rich, Environmental Defense Fund, November
1998. Not printed. Back
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