NGO Comments ​on Safeguard Policies & Project Implementation


EBRD Safeguards and the EBRD-ization of the World Bank

Massive dilution of WB Protections

The World Bank's newly-reconstituted safeguards team is pushing hard for the use of the EBRD as a model for Bank Safeguards, resulting in a proposal to gut existing protections for communities and the environment. The European Bank for Reconstruction and Development (EBRD) has extraordinarily weak safeguards policies -- evidenced, for example, by their projects in Ukraine which, over the years, have featured a stunning lack of transparency and disclosure. According to Central and Eastern European BankWatch Network, the World Bank's "safeguards team" is now led by the former EBRD representative who oversaw the recent extraordinary weakening of EBRD safeguards , converting the EBRD from "bad" to "worse" in terms of social and environmental protections. The recent weakening of the EBRD safeguards led, among other things, to the removal of protections for biodiversity, and ensured that safeguards are no longer mandatory. The new EBRD-influenced World Bank safeguards team, reconstituted after the retirement of the former head of the Safeguards Team, immediately proposed use of the flawed EBRD model at as a basis for dismantling World Bank safeguards (pg 14 and onwards). Instead of aiming for upward harmonization with the strongest protections for impoverished communities and the environment upon which such communities often depend, after heavy NGO criticism of the EBRD, the Bank safeguards team simply removed the term "EBRD" from their presentation to NGOs, and went on, as planned to produce draft new World Bank safeguards drawing heavily from the worst practices of the EBRD . 


The WB draft safeguards appear to be based on a toxic combination of weak portions of the IFC's Performance Standards and the newly watered-down EBRD safeguard approach, leading toto a direct dilution of existing Bank safeguards. EBRD safeguards are far weaker than those of other institutions, including the World Bank and the Asian Development Bank. According to CEE BankWatch analysis, EBRD safeguards are not mandatory and the EBRD's new safeguards even propose that clients can bypass normal project assessment requirements and use undefined “alternative approaches”. Not only that, the EBRD’s new safeguards propose deferring undefined aspects of project assessment until after Board approval. EBRD safeguards have been particularly weak in providing for sufficient disclosure and participation of affected communities and other stakeholders in decision-making. The EBRD’s troubled record in the Ukraine provides a stark example of the dangers of such an approach. In addition, the EBRD delegates important bank obligations to clients, and relies heavily on client self-reporting and self-monitoring, which has led to miscategorization of high-impact projects as “category B” and substantial negative impacts on local communities and the environment. New EBRD safeguards even propose a weakening of important biodiversity safeguards, including for critical habitats, and propose widespread use of “offsets”, including in critical habitats.

The World Bank draft safeguards contains all of these EBRD "race to the bottom" initiatives. This wholesale application of EBRD-type safeguards to the World Bank as outlined in the Bank's draft safeguards, results in a direct and substantial dilution of World Bank policy.