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NGO Forum on ADB’s Response to the ADB’s Launch of its Climate Change Action Plan

5 December 2023

At COP28, the ADB announced the launch of a new Climate Change Action Plan (CCAP). In response, the NGO Forum on ADB urges the Bank’s management and board to review the collective concerns about the CCAP raised in an open statement endorsed by over 40 civil society organizations and social movements, and calls on them to take full advantage of CCAP’s ‘iterative’ framework by urgently reconsidering and rewriting its provisions.

To make a credible attempt to address the very real climate crisis at hand, an overhaul of the CCAP would include consideration of the following issues as minimum starting points:

  • Explicitly commit to a comprehensive rights based approachhinged on first doing no harm, and the corollary, to remedy and redress harms done. Climate demarcated financing which will lead to harms, losses and damages borne by affected communities, workers and surrounding ecosystems should be withdrawn from – and avoided – in the ADB’s pipeline. This would require for example, incorporating provisions into the CCAP to recognize and respect no-go zones for project development, inclusion of clear wording to ensure technical assistance, FIs and other financing modalities do not undermine the Conventions of the ILO and UN, and explicitly affirming a commitment in policy and practice to respect Indigenous Peoples’ and Local Communities’ rights to give or withhold free, prior and informed consent for projects that will affect their territories, lands, resources and /or livelihoods.

  • Thoroughly overhaul provisions which advance the financialization of planetary commons, the reduce the response to the climate crisis into “new business prospects for the private sector” and the flawed assumption that solutions can be found in “innovative carbon finance” (para 9). None of these approaches tackle greenhouse gas emissions at source, instead creating the very real risk of resource grabbing while inherently depending upon continued operations of high carbon emitting industries. In addition, we urge revisions to provisions suggesting the ADB will prioritize providing technical advice to governments to “design fiscal policies that provide incentives for the private sector” (para 55); as written it risks exacerbating pressure on governments to even further weaken existing environmental, labor, health and other social protections.

  • Commit to the polluters’ pay principles in policy and practice, and to internalize the “loss and damage agenda” (para 30). Provisions must be incorporated that mandate steps towards providing remedy, redress and reparations where communities have been affected by ADB’s climate finance in the past and have outstanding grievances. In addition, this would require a reversal of current approaches for supporting market based schemes that incentivize coal project operating companies to repurpose aging or stranded assets without accountability for remedying and redressing human rights harms and environmental damages.

  • Ensure that climate-demarcated sub-projects supported via financial intermediary (FI) arrangements, technical assistance, as well as investments in trade and global supply chains are i) screened to avoid exposure to coal, oil, gas and petrochemicals (for instance, by cross-checking against the Global Coal Exit List and the Global Oil and Gas Exit List), ii) explicitly required to exclude extractivist industries, including mining, smelting and other ecologically and socially damaging projects such as hydropower and waste-to-energy incineration, as none can be reasonably tagged as contributing to climate mitigation/adaptation, and iii) fully disclosed publicly with timely and specific information regarding the sites/operations receiving financing on ADB’s website. FI sub-projects must also be disclosed at project sites, providing communities with clear information on how they can file grievances and avail of the ADB’s Accountability Mechanism.

  • Commit to an urgent time-bound institutional review of exposure to fossil fuel associated interests of current and pipeline financing (across all sectors) and an immediate process for extricating the ADB institutionally from these partnerships in line with a 1.5C pathway.

  • Commit to forward-looking requirements and timelines across all sectors (including, but not limited to, revisions to the ADB’s Energy Policy) to ensure phasing out of current financing – and no new support – for fossil fuel associated projects. This includes technical assistance, bonds, equity finance, trade finance as well as financial intermediary, blended and direct project financing. While we recognize that fewer fossil gas projects are being directly financed by the ADB since the introduction of the 2021 Energy Policy, ADB’s online database still shows recent project approvals including for example for the 120MW Rokia Combined Cycle Gas Power Plant in Tripura, India (November 2022) and a coal to gas switching project in Almaty, Kazakhstan (March 2023) as well as support to the Indian Oil Company to pilot carbon capture, utilization and storage at refineries in Assam (October 2023).

  • Take into account the resource intensive toll of trade and global supply chain finance across all sectors and associated implications for people who work and live in multiple geographies affected by finance to be disbursed by the ADB. This would include consideration of how to close off associated loopholes for supporting the business of conventional energy (oil and gas) companies, as well as the implications for violations of the rights of coastal, riparian, forest dependent and small-holder or pastoralist communities as well as people in border zones and workers (not just at sites of production and shipping, but also, for example, at call centers).

  • Acknowledge the importance of environmental human rights defenders and workers’ rights advocates for advancing climate, energy, ecological and economic justice, and the need to ensure all climate demarcated financing, including via FIs, undergo robust reprisal risk, human rights and climate change vulnerability risk assessments prior to project approval.

  • Provide assurances on how the ADB will provide transparency and accountability in relation to the disbursement of blended climate finance to ensure stringent application of safeguards, access to information policy, and the accessibility of its own Accountability Mechanism when grievances arise.

  • Remove references to speculative ‘climate smart’ technofixes proposed in the current CCAP. By design, dependency on the “climate tech ecosystem” (pg 11) comes along with prohibitive patent regimes while failing to take into account the diverse realities of how climate change induced extreme weather and slow onset events impact communities, and obscuring the necessity for donor countries to provide finance based on their historic and current positioning as the primary drivers of the climate crisis. Building local, national and regional climate resilience requires:

    • explicit respect and recognition for community knowledge systems,

    • a commitment to follow evidence-based science to keep global heating thresholds to 1.5C (as per the reports of the Intergovernmental Panel on Climate Change, the World Meteorological Organization and UN Environment Programme, for example),

    • equitable, direct, rapid, managed fossil fuel phase out pathways as recommended by the reports of the Civil Society Equity Review, as well as

    • fully functioning, transparent, accessible and accountable flows of reparative financing for losses and damages.

  • Withdraw proposals for providing “a pipeline of PPP projects able to access green and blue finance” and revamp national legal and regulatory frameworks to “generate enabling environments for private sector finance” (para 39-41); public-private partnerships have a track record of undermining respect of workers’ rights, as well as accessibility and affordability of services in a range of sectors.

  • Withdraw proposals for financing resource-intensive schemes which exacerbate environmental, social and economic injustices and risks borne most heavily by marginalized communities, including as proposed in the CCAP. This includes but is not limited to waste to energy projects, hydropower projects, carbon capture and storage, promotion of ‘Climate Smart Agriculture’ ventures and promotion of plantations/agroforestry for carbon sequestration. (para 96; Appendix 1 and 2).

  • Remove references to detours from direct transition to distributed, decentralized renewable energy options; withdraw provisions which endorse schemes that will serve to extend the life of fossil fuel industries, such as carbon capture and storage as well as use of hydrogen and ammonia.

  • Withdraw proposals to support Debt for Nature or Debt-for-Climate Swaps; the heavy burden of sovereign indebtedness faced by many countries across the region will only be resolved by unconditional cancellation of the accumulated illegitimate debts. Debt for Nature/Climate Swaps have a track record of imposing conditionalities on borrowing member countries under duress, failing to be transparent or accountable to the public and instead leading to land/resource grabbing that exacerbate marginalization of land-dependent communities.

The above list is not exhaustive, but rather indicative of the range of concerns with the current version of the CCAP. We look forward to hearing specific timelines and processes regarding how and when the provisions of the CCAP will be opened up for further review and revision, during which time, we urge the ADB to seek broader input, including from communities where projects designated by the ADB for climate adaptation and mitigation are sited.



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