Risk classification Approach to determining and reviewing We appreciate that the proposed risk-based approach of the risk level of a project categorizing potential as High, Substantial, Moderate or Low risk is less rigid that the current system of environmental categorization with its static categories of A, B, C or FI. We find the approach proposed in the Environmental and Social Framework to be a useful change for the Bank. ESS1 Assessment and Assessment and nature of cumulative and Upstream Strategic Assessments are critical in understanding the management of indirect impacts to be taken into account broader risk profile of any particular project. These assessments environmental and Treatment of cumulative and indirect should therefore be a clear and specific requirement under ESS1 social risks and impacts when identified in the wherever relevant. In this way, many of the environmental and impacts assessment of the project social issues could be addressed in an integrated way. Establishing project boundaries and the Full cost accounting and an in-depth economic analysis of applicability of the ESSs to Associated alternative options, including the options in the mitigation Facilities, contractors, primary suppliers, hierarchy should be part of the environmental and social FI subprojects and directly funded assessment process. With regard to project boundaries, it is very important that the Circumstances under which the Bank proposed Environmental and Social Framework clearly define the will determine whether the Borrower will boundary criteria including for associated facilities. This is the be required to retain independent third only way any potential impacts could be adequately managed party specialists without them becoming burdensome on the borrowers. The proposed role in the Environmental and Social Bank’s Framework with regard to ssupply chains needs better clarity. How far down the chain such influence can be exerted and where the responsibility for compliance stops is not very clear since the definition is itself somewhat vague. Environmental and Legal standing of the ESCP and We understand that the Environmental and Social Commitment Social Commitment implications of changes to the ESCP as Plan would be incorporated in the legal agreement and will Plan (ESCP) part of the legal agreement therefore be legally binding. For this reason, it is critical that all commitments or actions specified in the ESCP be fully funded within the scope of the project. There needs to be clarity as to how will the Bank ensure compliance with the ESCP including with regard to supervision. ESS2 Labor and working Definition and necessity of and Overall we find ESS-2 to be well drafted and comprehensive. We conditions requirements for managing labor appreciate that the proposed Environmental and Social Framework provides for the non-discrimination principle as a
Risk classification Approach to determining and reviewing the risk level of a project We appreciate that the proposed risk-based approach of categorizing potential as High, Substantial, Moderate or Low risk is less rigid that the current system of environmental categorization with its static categories of A, B, C or FI. We find the approach proposed in the Environmental and Social Framework to be a useful change for the Bank. ESS1 Assessment and management of environmental and social risks and impacts Assessment and nature of cumulative and indirect impacts to be taken into account Treatment of cumulative and indirect impacts when identified in the assessment of the project Establishing project boundaries and the applicability of the ESSs to Associated Facilities, contractors, primary suppliers, FI subprojects and directly funded Circumstances under which the Bank will determine whether the Borrower will be required to retain independent third party specialists Upstream Strategic Assessments are critical in understanding the broader risk profile of any particular project. These assessments should therefore be a clear and specific requirement under ESS1 wherever relevant. In this way, many of the environmental and social issues could be addressed in an integrated way. Full cost accounting and an in-depth economic analysis of alternative options, including the options in the mitigation hierarchy should be part of the environmental and social assessment process. With regard to project boundaries, it is very important that the proposed Environmental and Social Framework clearly define the boundary criteria including for associated facilities. This is the only way any potential impacts could be adequately managed without them becoming burdensome on the borrowers. The Bank’s proposed role in the Environmental and Social Framework with regard to ssupply chains needs better clarity. How far down the chain such influence can be exerted and where the responsibility for compliance stops is not very clear since the definition is itself somewhat vague. Environmental and Social Commitment Plan (ESCP) Legal standing of the ESCP and implications of changes to the ESCP as part of the legal agreement We understand that the Environmental and Social Commitment Plan would be incorporated in the legal agreement and will therefore be legally binding. For this reason, it is critical that all commitments or actions specified in the ESCP be fully funded within the scope of the project. There needs to be clarity as to how will the Bank ensure compliance with the ESCP including with regard to supervision. ESS2 Labor and working conditions Definition and necessity of and requirements for managing labor Overall we find ESS-2 to be well drafted and comprehensive. We appreciate that the proposed Environmental and Social Framework provides for the non-discrimination principle as a