increased risks of sexual exploitation, rather than address all groups deemed as a single entity. “vulnerable” More emphasis should be placed on gender issues as related to community health and safety, and the general development agenda in general. Climate change the Draft Framework improves upon current safeguard policies The second draft ESS4 has clarified that (which barely mention climate change), it does not show the level of extreme weather conditions or slow adaptation and resilience and concern for climate risks called for in the Bank’s own documents. For onset of events exacerbated by climate disaster risk example, despite the fact that Environmental and Social Standard (ESS) 4 change need to be addressed in reduction on Community Health and Safety recognizes in its introduction that infrastructure and equipment design and that are already subjected to impacts from climate change safety (ESS4, para 6). Preparedness and “communities may also experience an acceleration or intensification of impacts due to response to extreme weather conditions project activities,” the standard contains no requirements explicitly related have also been included under the to climate change. ESS1 on the Assessment and Management of requirements for emergency Environmental and Social Risks and Impacts presents a similar picture. We preparedness and response (ESS4, para recommend that the Bank create much more detailed and robust 19). requirements for understanding the effect that climate change will have on the project’s success and on the people and ecosystems that the project will impact. It is important to have safeguards for disaster risk reduction and mitigation. The paragraph on services safety seems vague and perhaps impossible. The provision on product safety has Product and services safety Introducing almost any service will have direct or indirect impact on been deleted and that of services safety community health and safety (be they positive or negative). A better has been revised to clarify the boundary standard could be something like risks and impacts” or of the requirement (ESS4, para 9). “minimize “avoid risk and impacts within the Borrower’s immediate control.” The scope of ESS4 is generally clear, with the exception of product and services safety. It is our opinion that this section should be deleted as it does not logically fit the scope and focus of the ESF. The Bank’s ESF is a risk management framework that is applied to lending activities within
increased risks of sexual exploitation, rather than address all groups deemed “vulnerable” as a single entity. More emphasis should be placed on gender issues as related to community health and safety, and the general development agenda in general. Climate change adaptation and resilience and disaster risk reduction the Draft Framework improves upon current safeguard policies (which barely mention climate change), it does not show the level of concern for climate risks called for in the Bank’s own documents. For example, despite the fact that Environmental and Social Standard (ESS) 4 on Community Health and Safety recognizes in its introduction that “communities that are already subjected to impacts from climate change may also experience an acceleration or intensification of impacts due to project activities,” the standard contains no requirements explicitly related to climate change. ESS1 on the Assessment and Management of Environmental and Social Risks and Impacts presents a similar picture. We recommend that the Bank create much more detailed and robust requirements for understanding the effect that climate change will have on the project’s success and on the people and ecosystems that the project will impact. The second draft ESS4 has clarified that extreme weather conditions or slow onset of events exacerbated by climate change need to be addressed in infrastructure and equipment design and safety (ESS4, para 6). Preparedness and response to extreme weather conditions have also been included under the requirements for emergency preparedness and response (ESS4, para 19). It is important to have safeguards for disaster risk reduction and mitigation. Product and services safety The paragraph on services safety seems vague and perhaps impossible. Introducing almost any service will have direct or indirect impact on community health and safety (be they positive or negative). A better standard could be something like “minimize risks and impacts” or “avoid risk and impacts within the Borrower’s immediate control.” The provision on product safety has been deleted and that of services safety has been revised to clarify the boundary of the requirement (ESS4, para 9). The scope of ESS4 is generally clear, with the exception of product and services safety. It is our opinion that this section should be deleted as it does not logically fit the scope and focus of the ESF. The Bank’s ESF is a risk management framework that is applied to lending activities within
clean_summary_of_phase_2_consultations_and_bank_management_reponses_final_draft_for_consultation_july_1_2015.docx