Annex I
Summary recommendations of WWF 2002 submission
to ECGD review.
(A) ECGD MUST
ACTIVELY PROMOTE
SUSTAINABLE DEVELOPMENT
Align with Government commitments on sustainable
development
Current ECGD activities risk undermining Government
commitments on sustainability. The ECGD must adopt clear and specific
objectives with regard to sustainability, directly linked to ECGD
Business principles, UK Government sustainable development goals
and international commitments (for example, the Kyoto protocol
and the Convention on Biodiversity).
Monitor and report on performance of the ECGD
It is not yet clear how ECGD monitors and measures
the success of the overall organisation with regards to meeting
its Business `Principles, and UK Government commitments to sustainable
development. Targets must be set to reduce the overall environmental
impact of ECGD supported activities to ensure it adheres to these
commitments. These should include targets to reduce annual carbon
emissions in supported projects and the percentage of projects
impacting on high conservation value forests.
Demonstrate and exert leadership
Through setting an example by strengthening
its environmental policies and capacity, as well as through exerting
leadership in international fora like the Working Party on Export
Credits and Credit Guarantees (ECG) of the OECD, ECGD can work
towards the creation of a level playing field promoting environmental
excellence and sustainable development. The ECGD should push the
Common Approaches to reach international best practice. In the
process it can strengthen its own performance by reducing financial
and reputational risk, and capitalising on opportunities to offer
new products and services to clients.
Foster-and enhance the competitiveness of UK environmental
exports
There is an opportunity for ECGD to provide
real leadership in supporting UK environmental exporters, and
improving environmental quality in host countries. ECGD needs
to put in place incentives to encourage sustainable exports. These
could include: offering extended terms of finance, offering training
and grants.
(B) ECGD MUST
AMEND ITS
IMPACT SCREENING
AND ANALYSIS
PROCEDURES
Clarify and strengthen the screening and review
process
There is significant scope in the current process
for impacts to go unreported by the company. There is not a strong
legal requirement for the provision of complete, verifiable and
honest information, nor sanctions when information is dubious.
ECGD must require EIAs to be mandatory for all category A projects.
For category B projects WB standards should be adhered to. [110]The
EIAs must also require back-up documentation, and conduct spot
checks by independent reviewers for all three categories (A, B
and C).
Develop clear and consistent environmental sectoral
standards
The benchmarking approach means a lack of predictable
and consistent standards. The development of a set of clear ex-ante
standards could bring significant benefit to ECGD and the companies
it supports by allowing projects to be designed from the beginning
with these standards in mind. Following examples from the World
Bank/IFC, Ex-Im and ABN Amro in the private sector, clear screening
policies should be established for sensitive sectors or impact
areas, including forestry, mining, oil and gas, and water (dams).
These should be developed in consultation with stakeholders or
existing initiatives—such as the World Commission on Dams.
Those projects that do not meet these standards should be excluded
from support.
Improve the monitoring of projects
Procedures for follow-up, monitoring and enforcement
are very weak. Without adequate monitoring, there is a tendency
for environmental impact assessments to be used merely as a rubber
stamp to allow a project to go ahead, rather than to create a
work-plan to maximise positive environmental impacts and mitigate
damage. Monitoring should be necessary for all category A and
B projects, based on guidelines and in consultation with stakeholders.
Support a presumption of transparency
Transparency & disclosure is one of the
key issues being discussed as part of ECGD's consultation process,
and so may change in the near future. However, currently it is
one of the areas where ECGD falls furthest behind. Ex ante information
disclosure should take place 120 days before a decision on the
project is made. Disclosure requirements should be part of the
contract between ECGD and project sponsor. Information disclosure
should be extended to all projects and should include all information
that is not demonstrated to be of a commercially sensitive nature.
Develop an appeal process
Although ECGD decisions can be challenged through
the Parliamentary Ombudsman and judicial review, there is currently
no easily accessible appeal procedure. The ECGD should develop
an approach similar to the IFC and EDC, with a compliance officer
or ombudsman to which stakeholders can bring their complaints
if they feel a decision has not been in compliance with ECGDs
own business principles or international law.
Expand environmental capacity
It is unclear whether sufficient capacity (ie
staff with sufficient knowledge and time) currently exists within
ECGD to implement the engagement process and other environmental
policies. In order to adequately incorporate environmental dimensions
into ECGD activities greater capacity may be necessary.
110 The World Bank states "The scope of EA for
a Category B project may vary from project to project, but it
is narrower than that of Category A EA. Like Category A EA, it
examines the project's potential negative and positive environmental
impacts and recommends any measures needed to prevent, minimize,
mitigate, or compensate for adverse impacts and improve environmental
performance." Back
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