19 February 2020
Mark Dennis Y.C. Joven
Member of the Board of Directors Asian Infrastructure Investment Bank (AIIB)
Dr. Joachim von Amsberg
Vice – President – Policy and Strategy
Complaints - Resolution, Evaluation and Integrity Unit (CEIU)
Re: Request to Extend the Deadline for the Phase 1 ESF Consultation
Dear Dir. Joven,
This letter strongly urges your office to delay the phase 1 of the Environmental and Social Framework (ESF) review consultation as articulated on the AIIB website January 2020. As CSOs who have extensively participated in the bank’s consultation process in the past, we have not yet received a formal response in terms of the approach for this review from the ESF drafting team and AIIB Management.
Considering that there is a relatively small volume of projects approved and implemented since 2016, we expected the AIIB to describe its theoretical approach and methodology on how it will conduct this critical review of its ESF vis - a vis complementing its 3 year project portfolio. Several critical questions remain: Given that the AIIB has approved over 60 projects, will the bank evaluate the extent to which they all adhered to ESF requirements? Will the AIIB evaluate its ESF delivery in relation to its time bound information disclosure requirements pertaining to the projects? Will the bank conduct (or have conducted) any internal evaluations on operational delivery of its ESF to gather lessons learnt since 2016? Without having a clear sense on how the AIIB is approaching the scope of this ESF review it seems that the process for soliciting inputs is being too rushed.
It also needs to be noted that the consultation notice on the AIIB website was released mid-January with inputs being requested as near as 28 February 2020, which is extremely short notice for garnering informed, constructive and useful inputs to the ESF review. We have been actively monitoring AIIB standalone and co-financed projects extensively on the ground over the last 3 years and providing detailed inputs on ground realities on these projects will require more time for analysis and review of field data and researched material.
It needs to be mentioned that on the 9th of March 2020, there is a scheduled ESF workshop to be organized by the German government with the AIIB Eurozone and Wider Europe government shareholders. Thus the 28 February input deadline would disallow for the important outcomes of this workshop to be integrated into the Phase One consultation.
Considering the above mentioned concerns we urge the bank to provide us with its theoretical and methodological approach towards this ESF review and extend the Phase 1 deadline until the end of March 2020. We look forward to your utmost cooperation in this regard and are waiting to hear back from you at your earliest convenience.
NGO Forum on ADB
Endorsed by the following organizations:
Accountability Counsel, USA
Action for Ecology and People's Emancipation, Indonesia
Asian Peoples' Movement on Debt and Development (APMDD)
Armenian Women for Health and Healthy Environment /AWHHE/, Armenia
Bangladesh Working Group on External Debt (BWGED), Bangladesh
BothENDS, The Netherlands
Centre for Environmental Justice, Sri Lanka
Centre for Human Rights and Development, Mongolia
Coastal Livelihood and Environmental Action Network (CLEAN), Bangladesh
Community Empowerment and Social Justice Network (CEMSOJ), Nepal
Friends of the Earth US, USA
Green Advocates International, Liberia
Inclusive Development International, USA
Indian Social Action Forum
Initiative for Right View, Bangladesh
International Accountability Project, USA/Global
MiningWatch Canada, Canada
NGO Forum Cambodia, Cambodia
Pakistan Fisherfolk Forum
Progressive Plantation Workers Union (PPWU), India
Recourse, The Netherlands/Global
Safety and Rights Society, Bangladesh
WomanHealth Philippines, Philippines
Youth For Environment Education And Development Foundation (YFEED Foundation), Nepal
Youth Group on Protection of Environment, Tajikistan
Download the letter here.