March 02, 2020

The Forum at the onset of this submission would like to state that this Phase 1 input process fails to meet the policy commitment of an ‘overall’ ESF review as articulated in the AIIB ESF1 and as committed to in the AIIB Articles of Agreement. It also needs to be mentioned that The AIIB has not provided any clarity on the methodological approach of this ESF Review and the response we have received from the Strategy and Policy Department of the Bank2 has been inadequate to explain what it means by a targeted update. For the last four years of AIIB Operations, the ESF delivery has been riddled with structural challenges in implementation in its projects in China, Myanmar, Bangladesh and others. Civil society has tried to engage with AIIB management, project team leaders and concerned officials on ESF to resolve the plethora of issues and have been left wanting of meaningful responses on the ground. The lack of ESF delivery was found evident in AIIB stand-alone projects such as Beijing Gas and the Bhola IPP in Bangladesh, as well as co-financed projects such as the Myingyan Gas Power Plant with other MDBs such as ADB and IFC, where civil society groups have flagged their concerns on AIIBs lack of clarity on ESF delivery. Project impacts have been severe environmental damage, adverse gender impacts, land grabbing and resettlement, pollution, lack of project information disclosure, lack of meaningful consultations, and in one instance death and accident of labor forces within a project. For the sake of brevity, the NGO Forum on ADB will focus on this input around the standalone Bhola IPP project, and use it as an example to illustrate the ground realities around AIIB ESF delivery for a standalone project.

Read the full submission here.

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NGO Forum on ADB Joint Submission, AIIB ESF Review Phase 2

November 10, 2020

​NGO Forum on ADB at the onset of this submission would like to state that this Phase2 input is in response to the Draft ESF released Sept 7, 2020. It needs to be noted that this current draft has significant changes in language on various aspects reducing client requirements, especially in categorization, and information disclosure. As a result, the draft ESF is a drastically weaker document in terms of ensuring community and environmental safeguards. This joint submission from NGO Forum on ADB calls out this draft to be an instrument to erode binding requirements by borrowers of AIIB from environmental and social responsibility surrounding projects. Before delving into the details it needs to be mentioned that the AIIB has not provided an assessment of its existing ESF delivery in the public domain. It should be noted that the AIIBs CEIU has not come up with a public report that has evaluated the effectiveness of the ESF 2016. We have further observed stand-alone projects such as Bhola IPP with severe environmental and social impacts for over 2 years without meaningful mitigation to harm, similarly gross discrepancies on information disclosure and lack of meaningful consultation persist with the Beijing Gas Project (stand-alone) along with co-financed projects such as Myingyan Gas Power Plant in Myanmar. Therefore what prompts the AIIB management to remove binding requirements from clients and borrowers with this new draft ESF must be questioned by all stakeholders engaging AIIB.

The Forum network thinks that this draft ESF, in general, fails to prioritize project-affected communities, whose rights should be at the center of project design, operation, and implementation. The network calls out the material weaknesses in provisions of this draft ESF and urges for significant rewrites to the sections identified in this submission. The Forum will highlight some of the problematic sections in the critique below to help guide AIIB towards a more responsible and binding ESF that holds clients accountable to the environment and communities.

Read the full submission here.