preparation and disclosure requirements should also be explicit for financial intermediary (FI) and framework project and subproject documents, including ESIAs and Environmental and Social Management Frameworks (ESMFs). For any documents that are proposed for preparation after Board review of a project, the Board should be provided with advance information in the Project Appraisal Document on the nature and content of the documents, the rationale for post-Board preparation, and the timeframe for such preparation and disclosure. Standards that support predictable requirements will benefit the Bank, its borrowers, and affected people. In a key departure from current requirements, which require key safeguard documents to be created before project approval, the Draft Framework states that the Bank will require the Borrower to structure projects so that they meet safeguard requirements a manner and a timeframe acceptable to the “in Bank.” This means, presumably, that projects can be approved by the Board before all safeguard assessments have been completed and plans formulated. Our research suggests though that the primary method to deal with this imbalance [frontloading] should be to increase engagement in the latter stages in the process, without reducing effort spent on clear upfront assessments and implementation plans, particularly for high-impact projects. This is particularly true for projects with higher risks. For these projects it is important for parties to understand up front what they are agreeing to do and how much these actions will cost. Lack of such clarity creates a high risk of conflict between the Bank, Borrower and affected communities during project implementation.
preparation and disclosure requirements should also be explicit for financial intermediary (FI) and framework project and subproject documents, including ESIAs and Environmental and Social Management Frameworks (ESMFs). For any documents that are proposed for preparation after Board review of a project, the Board should be provided with advance information in the Project Appraisal Document on the nature and content of the documents, the rationale for post-Board preparation, and the timeframe for such preparation and disclosure. Standards that support predictable requirements will benefit the Bank, its borrowers, and affected people. In a key departure from current requirements, which require key safeguard documents to be created before project approval, the Draft Framework states that the Bank will require the Borrower to structure projects so that they meet safeguard requirements “in a manner and a timeframe acceptable to the Bank.” This means, presumably, that projects can be approved by the Board before all safeguard assessments have been completed and plans formulated. Our research suggests though that the primary method to deal with this imbalance [frontloading] should be to increase engagement in the latter stages in the process, without reducing effort spent on clear upfront assessments and implementation plans, particularly for high-impact projects. This is particularly true for projects with higher risks. For these projects it is important for parties to understand up front what they are agreeing to do and how much these actions will cost. Lack of such clarity creates a high risk of conflict between the Bank, Borrower and affected communities during project implementation.
clean_summary_of_phase_2_consultations_and_bank_management_reponses_final_draft_for_consultation_july_1_2015.docx