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Request for Extension of Deadline for Submission of Written Comments on ADB's Draft ESF

Nianshan Zhang

Head, Office of Safeguards

Asian Development Bank (ADB) 

Dear Mr. Zhang, 

This is in reference to the ongoing Phase 3 consultations pertaining to ADB’s draft Environmental and Social Framework (ESF). Consistent with the bilateral email of the NGO Forum on ADB (“Forum”) last 19 January 2024 and the Philippine country consultation last 26 January 2024, we are writing officially to express our request: 

  1. To extend the deadline of submission of written comments from 31 January 2024 to 31 May 2024; and

  2. That the same be reflected in ADB website’s safeguard policy review. 

The said request is aligned with ADB’s subsequent plans of regional consultations in South Asia and the Pacific and in – country consultations in India, Fiji and Cambodia respectively. As per the ADB website, the latest consultation will be with government stakeholders from Central West Asia indicatively scheduled for May 2024 (TBC). 

Thus, the extension of submission of written comments after the conclusion of the regional and in – country consultations is not only reasonable but also justified. As what the Forum has been raising in different platforms, the Phase 2 consultation was extensive from June 2021 – March 2023. The similar rigorous consultation process should likewise be the same now that the draft ESF has been released for public commenting. We reiterate that the ADB is at the critical juncture of the review process in ensuring that the highest standards will be upheld by the bank to protect the environment and project – affected persons. 

Thank you. 

Respectfully yours, 

Rayyan Hassan

Executive Director

NGO Forum on ADB

Endorsed by: Asia Pilipinas

Aksi! for gender, social and ecological justice, Indonesia

Asian Peoples' Movement on Debt and Development (APMDD)

Bangladesh Working Group on External Debt (BWGED), Bangladesh

CEE Bankwatch Network, Georgia

Centre for Environmental justice, Sri Lanka

Centre for Research and Advocacy Manipur, India

CLEAN (Coastal Livelihood and Environmental Action Network), Bangladesh

Community Empowerment and Social Justice Network (CEMSOJ), Nepal

Environmental Public Society, Armenia

Equitable Cambodia, Cambodia

Freedom From Debt Coalition (FDC)

Growthwatch, India

Indian Social Action Forum (INSAF), India

Indus Consortium, Pakistan

Initiative for Right View (IRV), Bangladesh

Legal Rights and Natural Resources Center-Kasama sa Kalikasan/Friends of the Earth,


Nash Vek Public Foundation, Kyrgyzstan

Pakistan Fisherfolk Forum, Pakistan

Participatory Research & Action Network- PRAAN, Bangladesh

Recourse, The Netherlands

WALHI, Indonesia

Youth Group on Protection of Environment (YGPE), Tajikistan


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