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Over the course of this week’s Asia Clean Energy Forum, hosted virtually by the Asian Development Bank, we have been alarmed by the absolute absence of space available to take into account the perspectives of peoples’ organizations representing the very communities and workers across the region whose livelihoods are at stake when ‘green’ energy infrastructure investments move forward. ADB’s Energy Portfolio: Yet to be Overhauled? We appreciate ADB President Masatsugu Asakawa’s assertion that an “overhaul of the energy sector” is needed, and ADB Energy Sector Group Chief Priyantha Wijayatunga’s acknowledgement that Paris alignment of financing means making all efforts to keep global heating below 1.5C. However, the fact remains that the ADB introduced a new Energy Policy in October last year which – despite ruling out investments in coal and coal-related infrastructure – still explicitly enables financing for the build up of carbon-intensive oil and gas dependent infrastructure, including LNG terminals, toxic waste-to-energy (WTE) incineration, the development of new hydropower projects, and vastly expensive fossil fuel dependent carbon capture ventures. We note that according to the ADB website, the Bank appears to be considering financing for the 280MW Nenskra Hydropower Project in Georgia, the Turkmenistan-Afghanistan-Pakistan-India (TAPI) Gas Pipeline Project, the Rokia 120MW Combined Gas Cycle Project in India, and a carbon capture scheme in collaboration with the Indian Oil Corporation, along with investments in companies with fossil fuel heavy portfolios via financial intermediary facilities. All of these projects, along with large-scale wind and solar schemes, such as the 500MW Zarafshan Wind Power Project in Uzbekistan, raise serious concerns among local, regional and international civil society groups. Beyond project financing, we also remain concerned about the impacts of ADB’s technical assistance to local and national governments – intended to spur on policy reforms and infrastructure developments – including potentially dire violations of human rights and ecological integrity. Examples include: ADB’s recently completed technical assistance for Sri Lanka providing advice on the build-out of infrastructure needed for a new liquified natural gas (LNG) facility – despite the reality that the current energy and socio-economic crises are specifically connected to heavy reliance on imported and highly volatile sources of fossil fuel energy sources, and ADB’s technical assistance for project preparation of a waste-to-energy facility in Cebu, Philippines – that has contributed to undermining national legal frameworks on solid waste management, clean air, and renewable energy as well as international commitments. Accordingly, it remains an open question as to how the ADB will proceed in overhauling its own implementation of policies, projects as well as technical assistance in the direction of a clean energy transition. Whether they will commit to a rights-based framework that upholds climate science as per recommendations of the Intergovernmental Panel on Climate Change for limiting global warming to 1.5C and avoids exacerbating borrowing country’s levels of indebtedness is yet to be seen. ACEF 2022: Private Sector Promotion of Plans Backed by the Fossil Fuel Lobby We have seen how this year’s focus at the Asian Clean Energy Forum on “Innovative and Integrated Solutions For a Low-Carbon And Resilient Future” has meant that private sector proponents have had the floor to promote infrastructure build-out for risky, speculative and resource-intensive technologies in the name of “Net Zero” pathways, prolonging the shift away from reliance on carbon-intensive systems, such as via carbon capture and storage for oil and gas as well as WTE operations, along with large-scale green/blended hydrogen production and transport ventures. We remain highly cognizant that key actors behind such a push for a ‘hydrogen society’ and for the expansion of carbon capture schemes are oil and gas companies, as by design, they are the ones who will reap the profit of prolonged reliance on fossil fuels. In this regard, we reiterate our collective assertion to the ADB that the surest way to tackle economic, climate and energy injustice, and to support a rights-based pathway that aims to avoid overshooting 1.5C, would be to pivot entirely away from systems that are carbon and resource intensive as well as heavy greenhouse gas emitters. We recall here the dire warnings of the IPCC’s Assessment Report 6, clearly pronouncing the narrow window left to avoid catastrophic global warming, and the IPCC’s suggestion that the best chance we have of limiting warming would rely on limited or no use of engineered carbon capture technologies. Carbon capture has already been exposed as a failed technology over decades of piloting, with systematically poor CO2 capture rates, incurring exorbitant increases in construction costs that are passed on in the cost of energy. Meanwhile, the infrastructure build-out needed to transport carbon and inject it into storage sites requires vast areas of land, risking dispossessing rural, peri-urban or Indigenous Peoples’ communities. Likewise, ‘green’ hydrogen made through the electrolysis of renewable energy is reliant on large-scale solar or wind farms that require onerous uses of local water and land resources. Ultimately then, it is far more economical and efficient for energy to be sourced directly from RE sources, appropriately scaled and designed to meet the needs of the communities it is intended to serve. It is also clear that any proposal to blend green hydrogen with blue or gray hydrogen would by default mean reverting to reliance on fossil fuels. There is no reason for the ADB to consider sinking scarce public resources into technocratic pathways that will delay the needed energy transition. Indeed, despite the Bank’s apparent preparedness to scale up climate financing, we await clear time bound commitments related to phasing out oil and gas reliant infrastructure and other climate-misaligned investments, including toxic waste-to-energy projects and large-scale hydropower projects. In this regard, we remind the ADB of their outstanding commitment to open up a period of consultation on forthcoming draft guidance notes that are intended to provide staff with criteria for screening investments in fossil gas, hydropower and waste-to-energy projects to civil society groups as outlined in the 2021 Energy Policy. Sidelined from ACEF 2022: Indigenous Peoples from Across the Region Notably absent from official ACEF sessions has been any perspective on locally relevant innovative energy systems being developed by Indigenous Peoples’ communities across the region. Nor has there been any clear attempt to remain cognizant throughout the ACEF conference of ensuring there is Free, Prior and Informed Consent from all project affected communities as part of an iterative process.This is particularly alarming given the reality that many of the energy systems discussed, including floating photovoltaic schemes, carbon capture, and hydrogen projects, could end up encroaching on ancestral domains or dispossessing people of their homes and livelihoods. Indeed, from the outset, before developers consider carrying out biodiversity sensitivity mapping as advanced by the ADB for solar and wind projects, it is imperative to ensure communities have had the time to come to a consensus on whether (or not) they agree to the project development, and that their decision to grant or withhold consent is accordingly respected. Furthermore, any plans to avoid bird flight paths or biodiversity hotspots when building such projects need to be ground-truthed by the intergenerational knowledge of local communities. Energy Transition Mechanism: Climate Credentials and Claims in Support of Just Transition Remain in Question Finally, in relation to the ADB’s Energy Transition Mechanism (ETM), which has been referenced in several ACEF sessions, we note that to date, this market-oriented scheme to retire coal projects has been characterized by a lack of transparency and has as of yet, failed to meaningfully take into account the perspectives of community-based and workers’ federations grounded in specific local and country contexts. In fact, there are no concrete commitments to ensure the ETM scheme will uphold UN and ILO Conventions (including ILO Convention 169) or the UN Guiding Principles on Business and Human Rights, nor assurances that comprehensive financing for the coal power projects targeted for retirement will be available to ensure site clean-up, land reclamation as well as reparations and redress for harms wrought on communities and workers. As a market-driven initiative, the Energy Transition Mechanism by design is intended to ensure investors earn a return while supporting coal operators to retire power plants over the course of 10-15 years, despite the fact that technically these plants could be replaced by lower cost new renewable energy projects. In effect, this means that the ETM risks far overshooting the nationally required targets to uphold a 1.5C trajectory, therefore blocking countries from aligning with the Paris Agreement goals. It also means that the ETM as it stands, will inherently burden local communities with heavy social costs. In fact, the support for a just transition under the ETM and development of ‘clean’ projects do not come along with any clear financing component nor any guarantees that fossil gas projects will not be built as part of the process. We are also concerned that the blended finance modality used to support the roll out of the ETM effectively means it will be difficult for affected communities to access grievance mechanisms and seek accountability. Conclusions: Beyond ADB’s Asia Clean Energy Forum 2022 Moving forward from this year’s Asia Clean Energy Forum, we reiterate our call on the ADB Management and Board to consciously pivot away from financing false climate and energy solutions. Decisions taken in this regard not only will have real impacts on peoples’ livelihoods across the region, but will also determine if the pathway followed is one which will hasten – or undermine – progress towards a just, inclusive, sustainable and rights-based transition. Regardless, we assure the ADB that civil society groups remain attentive to the plans advanced for green (and not-so-green) energy investments, ready to hold the Bank accountable – as for us, at stake is the stark reality of who may live and who may perish in the years ahead. Submitted by the NGO Forum on ADB along with the following local, national and international organizations: Aksi! for Gender, Social and Ecological Justice (Indonesia) Balkani Wildlife Society (Bulgaria) Bangladesh Working Group on External Debt (Bangladesh) CEE Bankwatch Network (Georgia) Center for Energy, Ecology, and Development (Philippines) Centre for Financial Accountability (India) Centre for Human Rights and Development (Mongolia) Change Initiative (Bangladesh) Coastal Livelihood and Environmental Action Network (Bangladesh) Collective for Energy Justice (India) Committee for the Abolition of Illegitimate Debt (India) Community Empowerment and Social Justice Network (Nepal) EarthRights International (USA) Environics Trust (India) Freedom from Debt Coalition (Philippines) Green Advocates International (Liberia) Growthwatch (India) Indian Social Action Forum (India) Indigenous Women’s Legal Awareness Group (Nepal) Japan Center for a Sustainable Environment and Society (Japan) KRuHA - People's Coalition for the Right to Water (Indonesia) Mekong Watch (Japan) Nash Vek Public Foundation (Kyrgyzstan) Progressive Plantation Workers Union (India) Oil Workers' Rights Protection Organization Public Union (Azerbaijan) Oyu Tolgoi Watch (Mongolia) Recourse (Netherlands) Rivers without Boundaries Coalition (Mongolia) urgewald e.V. (Germany) Youth Group on Protection of Environment (Tajikistan) BRICS Feminist Watch (Global) Programme on Women's Economic, Social and Cultural Rights (Global) International Accountability Project (Global) Asian Peoples’ Movement on Debt and Development (Regional) Global Alliance for Incinerator Alternatives-Asia Pacific (Regional) 350 Pilipinas 350.Org (Asia) Download PDF version here.

13th June 2022 To: Mr. Jin Liqun, President, Asian Infrastructure Investment Bank (AIIB) Mr. Ludger Schuknecht, V.P. and Corporate Secretary, AIIB Sir Danny Alexander, V.P., Policy and Strategy, AIIB Mr. Bob Pickard, D.G., Communications Department, AIIB – Via Email – Dear AIIB President Jin Liqun, Mr. Ludger Schuknecht, Sir Danny Alexander, and Mr. Bob Pickard: We appreciate the decision to extend the duration of the period for public comment on the proposed updates to the Energy Sector Strategy. However, with all due respect, we urge the AIIB to make this one month reflective of a more inclusive, meaningful process taking into account the global reach of the Bank’s current membership. As previously elaborated, this would include namely: Scheduling interactive discussion sessions with civil society in different languages, including listening directly to people already affected by AIIB’s energy sector investments and considering their recommendations for moving forward, Scheduling time to discuss concerns related to particular types of projects or about regional/country contexts, and Accepting submissions in major operating languages of member countries (i.e. not English only, including for example: Arabic, Bahasa, Bengali, Hindi, Nepali, Russian, Spanish and Thai). Given the constrained time frame available, at a minimum, we urge you to schedule separate sessions on the following (with translations and different time zone options): Fossil fuel financing and alignment with the Paris Climate Accord (1.5C Pathway) Financing new /expansion hydropower project schemes (in contrast to renewable energy systems needed for a just and sustainable transition) Gendered implications and considerations related to project financing under the Energy Sector Strategy, including universal energy access We look forward to a timely response. Thank you. Respectfully, Aksi! for Gender, Social and Ecological Justice (Indonesia) Bangladesh Working Group on External Debt (Bangladesh) Both ENDS (Netherlands) Centre for Financial Accountability (India) Center for Energy, Ecology and Development (Philippines) Civic Advisory Hub (Uganda) Coastal Livelihood and Environmental Action Network (Bangladesh) Committee for the Cancellation of Third World Debt (India) Defenders Protection Initiative (Uganda) Environics Trust (India) Environmental Public Alliance (Armenia) Equitable Cambodia (Cambodia) Freedom from Debt Coalition (Philippines) Friends of the Earth US (USA) Fundación Ambiente y Recursos Naturales (Argentina) Gender Action (USA) GrowthWatch (India) Indian Social Action Forum (India) Initiative for Right View (Bangladesh) KRuHA - People's Coalition for the Right to Water (Indonesia) Manushya Foundation (Laos & Thailand) Mekong Watch (Japan) Nash Vek (Kyrgyz Republic) Oil Workers' Rights Protection Organization Public Union (Azerbaijan) Oyu Tolgoi Watch (Mongolia) Pakistan Fisherfolk Forum (Pakistan) Recourse (Netherlands) Rivers without Boundaries (Mongolia) Sustentarse (Chile) Urgewald e.V. (Germany) VedvarendeEnergi (Denmark) Youth Group for the Protection of the Environment (Tajikistan) 350 Pilipinas (Philippines) Fundación para el Desarrollo de Políticas Sustentables /Foundation for the Development of Sustainable Policies (Argentina) BRICS Feminist Watch (Global) Inclusive Development International (Global) International Accountability Project (Global) International Rivers (Global) Just Finance International (Global) Programme on Women’s Economic, Social and Cultural Rights (Global) Rivers without Boundaries International Coalition (Global) 350.org Asia (Regional) Arab Watch Regional Coalition (Regional) Asian Peoples’ Movement on Debt and Development (Regional) Building and Wood Workers International - Asia Pacific (Regional) CEE Bankwatch (Regional) Global Alliance for Incinerator Alternatives-Asia Pacific (Regional) Latinoamérica Sustentable (Regional) NGO Forum on ADB (Regional) Download PDF version here.

Grupos de la sociedad civil descartan las consultas en línea del Banco Asiático de Inversión en Infraestructura por no ser ni significativas ni inclusivas 19 de mayo, 2022 Grupos de la sociedad civil de Asia, Europa y América Latina están organizando la primera salida virtual durante una sesión sobre la futura dirección del financiamiento del sector energético del Banco Asiático de Inversión en Infraestructura (BAII). El BAII se encuentra cursando en el proceso de actualización de su Estrategia del Sector Energético de 2018, y ha invitado al público a comentar sobre un borrador propuesto entre el 8 de abril y el 3 de junio. Sin embargo, la sesión de consulta en línea de hoy (de una hora de duración), junto con una sesión similar programada para mañana (también de una hora de duración) , son los únicos espacios de tiempo que el banco ha abierto para que grupos de todo el mundo planteen sus preguntas e inquietudes directamente al personal, durante el transcurso del período de consulta de ocho semanas, lo cual no da tiempo suficiente para un involucramiento o una discusión significativa. Tanya Roberts-Davis, estratega de políticas de energía y campañas de NGO Forum on ADB explicó: "Es absolutamente imperativo que el BAII, una institución financiera internacional que financia proyectos de infraestructura a gran escala con un impacto significativo en las personas, las economías y el medio ambiente en todo el mundo, participe en un proceso transparente, inclusivo y públicamente responsable para actualizar su marco estratégico guía de sus futuras inversiones en energía. De hecho, según cálculos propios del banco, el sector energético recibe casi un tercio de la financiación para proyectos. Sin embargo, solo ahora, después de repetidos llamados de grupos de la sociedad civil a la gerencia del banco, y apenas dos semanas antes de que finalice el período para que el público envíe sus aportes, estamos siendo 'invitados' a espacios de una hora para presentar breves comentarios sobre el borrador de la Estrategia del Sector Energético actualizada. Nos negamos a considerar una plataforma tan restrictiva como un espacio para discusiones, diálogos y debates genuinos, significativos e inclusivos”. El grupo de organizaciones de diversos sectores sociales tomó la decisión de sumarse a la sesión de consulta del BAII programada para hoy para leer un comunicado colectivo de denuncia, antes de realizar una salida masiva de la sesión como protesta en línea. Otros transmitirán un mensaje similar al boicotear el proceso por completo. Como afirmó Vidya Dinker de Indian Social Action Forum: “Estamos tentados a ser tan desdeñosos con el proceso del BAII como lo ha sido el banco con cualquier principio de consulta significativa o debida diligencia. Sin embargo, nuestro compromiso de elevar las preocupaciones de las comunidades afectadas y hacer que el BAII rinda cuentas, significa que estaremos allí hoy para decir claramente una vez más lo que hemos dicho antes al banco- llamarlos y afirmar que estas 'consultas' simbólicas no pueden ser utilizadas para legitimar lo que ha sido un proceso extremadamente apático e irrespetuoso. Cualquier Estrategia del Sector Energético actualizada que BAII adopte sin la debida corrección será inaceptable y en discrepancia con las obligaciones que se han auto establecido”. Maia Seeger de Sustentarse en Chile explicó además: “El BAII apenas está comenzando a financiar proyectos de energía en América Latina. A lo largo de los años, nuestros países en esta región se han visto afectados por el desarrollo de megainfraestructura energética realizada sin la debida consulta, con enormes impactos en los pueblos indígenas, las comunidades y el medio ambiente. Por lo tanto, estamos muy preocupados por los recursos que el BAII asignará para expandir los megaproyectos de energía en la región, por ejemplo, si incluirá plantas de hidrógeno verde con uso intensivo de recursos en Chile. A la luz de las malas prácticas que hemos visto con respecto a los procesos de consulta del BAII hasta la fecha, solo podemos esperar que las inversiones conduzcan a un aumento de los conflictos socioambientales en el futuro”. Nora Sausmikat de Urgewald en Alemania, afirmó: "Como banco multilateral con calificación triple A dedicado a financiar la 'infraestructura del mañana', los accionistas y la gerencia no deben ceñirse a tecnologías obsoletas que provocan crisis. Es hora de escuchar a la ciencia y a la gente, como se ha pedido durante los últimos seis años. ¡La actualización de la Estrategia del Sector Energético debe tener en cuenta las voces de la gente – ahora – y de manera significativa!” Mayang Azurin de Global Alliance for Incinerator Alternatives-Asia Pacific profundizó: “Instamos al BAII a resolver las flagrantes inconsistencias en las prácticas de inversión en su apoyo actual a proyectos de conversión de residuos en energía. Es hora de que el BAII descarte el apoyo directo e indirecto para esta tecnología tóxica y de alto consumo de carbono, ya sea como una forma de generación de energía o de gestión de residuos y la excluya claramente de la elegibilidad para el financiamiento bajo la Estrategia del Sector Energético actualizada. De acuerdo con este posicionamiento, instamos a la Junta a reconsiderar cualquier apoyo adicional para los proyectos residuos en energía actualmente financiados en las Maldivas y Turquía. Además, el BAII debe evitar seguir involucrándose en futuras inversiones en el sector retirando de inmediato el financiamiento propuesto para proyectos residuos en energía a través de préstamos de intermediarios financieros a China Everbright Limited. Seamos claros, dicho apoyo socava no sólo las ambiciones nacionales de seguir una trayectoria energética baja en carbono, sino también los compromisos internacionales de prohibir la producción de los mismos contaminantes que emiten los proyectos de conversión de residuos en energía, contaminando el aire, el suelo y el agua, de lo cual depende nuestra supervivencia." Para el grupo de expertos en el Centro para la Energía, la Ecología y el Desarrollo (CEED) en Filipinas, una consulta genuina con las partes interesadas y los expertos debería guiar al BAII hacia direcciones financieras alineadas con el clima que no tengan preferencia por los combustibles fósiles. Gerry Arances de CEED enfatizó además que: "En su Estrategia del Sector Energético 2022 propuesta, el BAII promueve el mito del gas fósil y el supuesto papel del GNL como combustible de transición para Asia, e incluso como contribuyente a la seguridad energética. Pero la expansión masiva del gas trae consigo una auge del metano que hará que no alcancemos nuestros objetivos climáticos y provocará precios de la electricidad más costosos incluso cuando ya se encuentran en su punto más alto. una política firme para deshacerse del gas fósil y centrarse en las energías renovables. Más aún, el BAII debe abordar las brechas evidentes en la implementación de su política que conducen a inversiones que contradicen directamente sus propios compromisos con el Acuerdo de París". Haciéndose eco de este sentimiento, Kate Geary de Recourse (Reino Unido/Países Bajos) concluyó: “En un momento en que el BAII se ha comprometido a alinear sus inversiones con el Acuerdo de París sobre el Cambio Climático, es vital que el banco haga bien sus inversiones en energía. Esto significa abandonar los combustibles fósiles y apoyar la energía renovable sostenible para mejorar el acceso a la energía en toda Asia, especialmente para las comunidades pobres. Una verdadera consulta abriría un espacio para que los más afectados por el cambio climático compartan sus preocupaciones y propongan alternativas; en cambio, el BAII ha optado por cerrar efectivamente la puerta a su compromiso". Información de contexto: Se han presentado en varias ocasiones desde enero de 2022, varias cartas abiertas firmadas conjuntamente por organizaciones de la sociedad civil en Asia, Europa y América Latina han planteado preguntas y preocupaciones sobre el proceso del BAII para actualizar su Estrategia del Sector Energético. Se puede leer una muestra de estas cartas aquí: https://www.forum-adb.org/aiibcommunications Estas cartas han pedido al BAII que: Publique los borradores de la actualización de la Estrategia del Sector Energético propuesta en los principales idiomas de los miembros regionales y no regionales; Programe sesiones de discusión interactivas en línea para zonas horarias e idiomas diferentes Participe en discusiones enfocadas con grupos de la sociedad civil sobre los distintos tipos de inquietudes referentes a los proyectos (como el financiamiento de represas hidroeléctricas o proyectos de energía a gas), así como en contextos específicos de países donde las inversiones del sector energético del BAII se han concentrado más hasta la fecha; Aceptar aportes escritos en los principales idiomas de los países miembros; y Responder proactivamente a la variedad de inquietudes sobre el riesgo de represalias que experimentan los miembros de la comunidad que hablan abiertamente en las áreas afectadas por el proyecto. El comunicado completo de denuncia realizado por grupos de la sociedad civil al BAII durante la Sesión del 19 de mayo se puede leer aquí: https://www.forum-adb.org/post/collective-statement-for-the-energy-sector-strategy-update

Civil society groups from across Asia, Europe and Latin America are staging the first ever virtual walk out during a session about the future direction of the Asian Infrastructure Investment Bank’s (AIIB) energy sector financing. The AIIB is currently in the process of updating its 2018 Energy Sector Strategy, and has invited public comment on a proposed draft between April 8th and June 3rd. However, today’s one hour online session together with a similar session scheduled for one hour tomorrow, are the only time slots the Bank has opened for groups from around the world to directly raise questions and concerns to staff over the course of the eight week consultation period, leaving no time for meaningful engagement and discussion. Tanya Roberts-Davis, Energy Policy and Campaigns Strategist from the NGO Forum on ADB explained: “It is absolutely imperative that the AIIB, an international financial institution bankrolling large-scale infrastructure projects that have significant impacts on people, economies and the environment across the entire range of borrowing member countries, engage in a transparent, inclusive, publicly accountable process for updating their strategic framework guiding future energy investments. Indeed, by the Bank’s own calculations, energy accounts for nearly one third of its project financing. Yet, only now – after repeated calls from civil society groups to the Bank’s management – and a mere two weeks before the end of the period of public input, are we being ‘invited’ to one hour time slots for submitting brief comments on the draft update of the Energy Sector Strategy. We refuse to consider such a restrictive platform as a space for genuine, meaningful, inclusive discussions, dialogue and debate.” The group of organizations from diverse social sectors made the decision to join the AIIB’s consultation session scheduled today in order to read out a collective statement of denunciation, before staging the online walk out, while others will convey a similar message by boycotting the process entirely. As Vidya Dinker from the Indian Social Action Forum affirmed: “We are tempted to be as dismissive of the AIIB’s process as the Bank has been of any principles of meaningful consultation or due diligence. However, our commitments to advancing the concerns of affected communities and to keep AIIB accountable mean we shall be there today to clearly say yet again what we have said before to the Bank - to call them out and state that these token ‘consultations’ cannot be used to legitimize what has been an extremely listless and disrespectful process. Any updated Energy Sector Strategy that AIIB adopts without due course correction will be unacceptable and at variance with their stated obligations.” Maia Seeger from Sustentarse in Chile further explained: “The AIIB is just beginning to finance energy projects in Latin America. Over the years, our countries in this region have been affected by the development of mega-energy infrastructure carried out without proper consultation, with huge impacts on Indigenous Peoples, communities and the environment. We are therefore highly concerned about the resources the AIIB will be allocating to expand mega-energy projects in the region, for instance, if it will include resource-intensive green hydrogen plants in Chile. In light of the malpractices we have seen regarding AIIB consultation processes to date, we can only expect the investments will lead to increasing socio- environmental conflicts in the future.” Nora Sausmikat from Urgewald, based in Germany, asserted: “As a triple A rating multilateral bank devoted to financing the ‘infrastructure of tomorrow” shareholders and the management should not stick to outdated crisis evoking technologies. It is time to listen to science and the people, as requested during the last six years. The updating of the Energy Sector Strategy needs to take into account the voices of the people – now – and in a meaningful manner!” Mayang Azurin from the Global Alliance for Incinerator Alternatives-Asia Pacific elaborated further: “We urge the AIIB to resolve the flagrant inconsistencies in investment practices in its current support to Waste-to-Energy (WTE) projects. It’s time for the AIIB to rule out direct and indirect support for this toxic and carbon-intensive technology either as a form of power generation or waste management, and clearly exclude it from eligibility for financing under the updated Energy Sector Strategy. In line with this positioning, we urge the Board to reconsider any further support for currently financed WTE projects in the Maldives and Turkey. In addition, the AIIB must avoid becoming further entangled in future investments in the sector by immediately withdrawing the proposed financing for WTE projects through financial intermediary on-lending to China Everbright Limited. Let’s be clear, such support undermines not only national ambitions to pursue a low-carbon energy trajectory but also international commitments to ban the production of the very pollutants that Waste-to-Energy projects emit, contaminating the air, soil and water our survival depends upon.” For the think-tank Center for Energy, Ecology, and Development (CEED) in the Philippines, genuine consultation with stakeholders and experts should guide AIIB to climate-aligned financing directions that hold no preference for fossil fuels. Gerry Arances of CEED further emphasized that: "In its proposed 2022 Energy Sector Strategy, AIIB peddles the myth of fossil gas and LNG's supposed role as a transition fuel for Asia, and even as a contributor to energy security. But massive gas expansion brings a methane boom that will cause us to miss our climate goals, and will trigger more costly electricity prices even as they are already at an all-time-high. AIIB cannot boast of being ‘lean, clean, and green’ if it cannot even take a firm policy to divest from fossil gas and focus on renewable energy. More so, AIIB must address the glaring gaps in its policy implementation which lead to investments that directly contradict its own commitments to the Paris Agreement." Echoing this sentiment, Kate Geary from Recourse (UK/Netherlands) concluded: “At a time when the AIIB has committed to align its investments with the Paris Agreement on Climate Change, it is vital that the bank gets its energy investments right. This means moving out of fossil fuels and into supporting sustainable renewable energy, to improve energy access across Asia, especially for poor communities. A true consultation would open space for those most affected by climate change to share their concerns and propose alternatives - instead AIIB has chosen to effectively close the door on their engagement." Background Information: Open letters jointly signed by civil society organizations across Asia, Europe and Latin America have raised questions and concerns about the AIIB’s process for updating its Energy Sector Strategy have been submitted on several occasions since January 2022. A sample of these letters can be read here. These letters have called for the AIIB to: Post translated draft texts of the proposed Energy Sector Strategy Update in major languages of regional and non-regional members; Schedule online interactive discussion sessions held in different time zones and languages Engage in focussed discussions with civil society groups on specific types of project related concerns (such as on financing for hydropower dams or gas power projects) as well in country-specific contexts where AIIB energy sector investments have been most concentrated to date; Accepting written input in major languages of member countries; and Proactively responding to the range of concerns about the risk of reprisals experienced by outspoken community members in project affected areas. The full statement of denunciation made by civil society groups to the AIIB during the May 19th Session can be read here.

From the outset, we want to be clear: we are present here for the purposes of conveying our collective denunciation of this online consultation. In no way do we consider this as a meaningful space for the expression of diverse civil society groups’ concerns related to the AIIB’s energy sector investments. From our perspectives, the period of public consultation should be considered a pivotal moment in the process of the Energy Sector Strategy update – not simply a tick-box exercise – most especially in light of the current context of compounded geopolitical, socio-economic, health, environmental, water and climate crises being experienced by populations across Asia and the Pacific, the Levant, Latin America, and Africa. Today we are therefore taking the opportunity to reiterate and reaffirm the calls made both in writing as well as during the AIIB’s ESS Update Information Session webinar last February, urging the Bank to provide assurances of an accountable, inclusive and transparent revision process by: scheduling online interactive discussion sessions held in different time zones and languages; engaging in focussed discussions with civil society groups on specific types of project related concerns as well in country-specific contexts where AIIB energy sector investments have been most concentrated to date; posting translated draft texts of the proposed Energy Sector Strategy Update in major languages of regional and non-regional members; accepting written input in major languages of member countries; providing transparent and clear language on the applicability of the Energy Sector Strategy to non-regional member states; and proactively responding to the range of concerns civil society groups have brought forward about the risk of reprisals experienced by outspoken community members in project affected areas. We have yet to receive a response from the AIIB addressing these points directly. As the project specific decisions made in the energy sector have significant long term repercussions for the future of people, economies and the environment across borrowing member countries, it is imperative for the Bank to engage in a transparent, inclusive, publicly accountable process for updating its strategic framework guiding future energy investments. Indeed, many of us have joined meetings in the past when we raised project-specific concerns about the AIIB’s recent and proposed investments in the energy sector, including mega-dams, gas power projects, and toxic waste-to-energy incineration technologies, explaining how they can end up implicated in human rights violations and undermining global climate ambitions. It is in this light that we refuse to consider this session today as a space for genuine, meaningful, inclusive discussions. If the AIIB management is serious about financing innovative, appropriately scaled renewable energy solutions and avoiding becoming branded as a laggard, we urge you to ensure the institution's investments neither undermine the spirit and aspirations of the Paris Agreement nor global ambitions for just energy transitions. Pursuing this way forward, however, would require a willingness to meaningfully engage, listen and take into account the views of communities and civil society groups raising questions about the AIIB’s current and prospective energy portfolio. It is in this context that we refuse to remain silent. Having provided you with this background, we are withdrawing from this platform today, in a position of collective denunciation.

There has been a significant clamor across multilateral development banks in “unlocking”, “catalyzing” and “mobilizing” private sector resources for development. In the case of ADB, this is embedded in its Strategy 2030 with a target that the bank will expand its private sector operations to reach one – third of its total operations in number by 2024. Emphasis is given on profitability, commercial sustainability and expansion in so – called new and frontier markets in the fragile, conflict and small island developing states. Financing modalities such as private equity funds to scale up public – private partnerships is one of the proposed mechanisms in mobilizing financial resources for development. Some of these projects are categorized as financial intermediary (FIs) or third party lending with limited ADB supervision. The shifts and changes in these new lending modalities have led to a more diverse portfolio which also poses more complex social and environmental risks and harm. Lack of information disclosure, accountability, meaningful consultation and risky sub – projects without adequate MDB oversight are some of the issues being raised by CSOs. As compared to the traditional lending modalities, there are a lot of unknown variables when dealing with financial intermediation. The World Bank’s private sector arm, the International Finance Corporation invests over half of its total portfolio in FIs. Inclusive Development International (IDI) and partners were uncovered more than 150 projects and companies funded by IFC intermediaries that are causing or are likely to cause serious environmental harms and human rights violations. There are valuable lessons that can be replicated from over a decade of campaigning by CSOs on financial intermediation on IFC and other MDBs to ADB. In 2019, a complaint was filed to ADB on a USD 400 million FI loan to support PPP projects including a road sub – project mired with various labor, occupational health and safety issues. The complaint was unfortunately deemed ineligible but this also served as a reminder for the Forum to take stock, have a better understanding on these lending modalities and ultimately strengthen its support to communities. Currently, ADB’s 2009 Safeguard Policy Statement is being reviewed. One of the upcoming safeguards consultations pertain to “Safeguards in the Private Sector Operations” scheduled on June 21 - 22, 2022. Accordingly, CSOs are encouraged to present their perspectives on how ADB implements the environmental and social safeguards in private sector operations which include investment projects, funds channeled through financial intermediaries, corporations, equities, and guarantees. It is also part of the broader intent of this knowledge sharing activity to generate an initial consolidation of issues and position to take for the said consultation. Objectives: For social, economic, gender, environmental and climate justice advocates concerned about MDBs particularly ADB's opaque FI portfolio. To learn more on FI lending at ADB and other MDBs in terms of what worked and did not work. To serve as an initial platform to discuss broader ADB FI campaign building. Download the reading list here | Download program here | Answer Quick Pre-Session Questionnaire here

Dear Secretariat of NGO Forum on ADB and everyone: Thank you for your letter to the Asian Infrastructure Investment Bank (AIIB) and for your comments on the public consultation on AIIB’s Energy Sector Strategy Update. AIIB strongly values public consultation as an integral process in updating its Energy Sector Strategy and as an important opportunity to hear feedback and suggestions from a wide range of stakeholders, including CSOs and NGOs. The public consultation of AIIB’s Energy Sector Strategy Update follows established practices and intends to be transparent, inclusive, and accountable. The consultation is also designed to ensure integrity by requesting for identifiable source of comments. AIIB commits to collate and duly consider all comments received during the public consultation and a summary of comments will be made publicly available. We sincerely encourage you to take full advantage of the consultation by submitting written comments and expressing your specific concerns on the draft strategy to essupdate@aiib.org. In addition, we will be holding two online sessions for CSOs in different time zones as platforms for you to directly communicate your comments and suggestions to the AIIB energy strategy team. Invitations with registration links will be distributed soon. We look forward to receiving your further feedback and suggestions on the draft of updated Energy Sector Strategy. Best regards, Asian Infrastructure Investment Bank Read AIIB’s Call for Public Input on the Energy Sector Strategy Update.

Manila, Philippines (5 May 2022) --- As the Asian Development Bank (ADB) launches the first stage of its 55th Annual Board of Governors Meeting with the theme “Positioning Climate Resilient Green Economy for the Post – COVID – 19 World,” civil society organizations from across the region collectively urged the Bank to reassess financing priorities and modalities, given its track record of investments that exacerbate indebtedness, deprive people of affordable and comprehensive universal health care services, increase levels of chronic hunger amidst the critical shortage of affordable staple foods, and facilitate dependency on fossil fuel reliant infrastructure among borrowing member countries. Rayyan Hassan, Executive Director of NGO Forum on ADB, stated: “The ADB has boldly claimed itself as the Climate Bank of Asia and the Pacific, but in its 2021 Energy Policy, the ADB still does not rule out resource and carbon-intensive infrastructures such as gas power plants, LNG terminals,, and transmission lines along with WTE incinerators.” He also asserted that “ADB’s support for COVID – 19 recovery must not result in creating markets for the private sector at the cost of further cutbacks in public expenditures on key social services. The ADB must avoid providing technical assistance or investments geared towards privatization-related reforms or models of public-private partnerships in the health care, education, energy, and water sectors, which we’ve seen consistently end up leading to violations of workers’ rights, and services that are typically inaccessible and substandard.” Hemantha Withanage, Chair of Friends of the Earth International, and Forum International Convenor for South Asia, explained, “On this occasion, we must not forget that Sri Lanka played a leading role in founding ADB in 1966. Since then, Sri Lanka has received USD 11.5 billion in loans, including 3.5 billion for the transport sector and 1.5 billion for the energy sector. About 13% of the total debts are for the ADB. Yet, Sri Lanka’s public transport sector has deteriorated, and the energy sector is in a real crisis.” He also added that the ADB, as a policy bank that advised Sri Lanka for decades of this development, should also take responsibility for funding corrupt regimes and non-beneficial projects. “The ADB development model has resulted in huge inequities with massive disparities between the rich and poor. Poor people are continuously being exploited in the labor market, being given fewer wages, and the Bank has perpetuated the patriarchal system of oppression.” NGO Forum on ADB firmly disagrees with the Bank’s recently suggested “Four Paths to a Climate-Friendly Energy Transition for Asia and the Pacific,” claiming “oil companies are on the front lines of the energy transition” and that “ESG scores have the potential to attract trillions of dollars in private sector capital to address climate goals .” Just, inclusive, sustainable transitions across South, Southeast, North and Central Asia, the Caucasus, and the Pacific cannot and will not be realized if power is wrested into the hands of the very transnational, multinational, and national corporations that have proven track records of committing human and environmental rights violations across the region. As explained by Tanya Lee Roberts-Davis, Energy Policy and Campaigns Strategist at the NGO Forum on ADB, “Over the past year, although the ADB has sought to showcase blue and green ‘climate smart’ financing, we have seen the Bank retain a business-as-usual portfolio of investments in resource-intensive energy projects that undermine rather than uphold the provisions of the Paris Climate Accord, principles of inclusive, sustainable, just transition, and the latest climate science as elaborated by the recent assessment reports of the Inter-Governmental Panel on Climate Change. This includes advancing loans for large-scale dam projects that have led to community outcry over the loss and damage incurred as well as proposed financing for new gas-powered projects and pipeline infrastructure, such as the highly risky 1600km Turkmenistan-Afghanistan-Pakistan-India (TAPI) pipeline. We affirm our solidarity with communities that continue to speak out against the injustices and rights violations wrought by such projects and our assertion that now, more than ever, it is imperative to shift investments as rapidly as possible towards supporting decentralized, low impact and appropriately scaled renewable energy options.” As the ADB Safeguards Policy Review is underway, the Forum network has also demanded that the Bank should and must not repeat its historical mistakes. In particular, on how the ADB’s continued lack of due diligence in conducting meaningful consultations and timely disclosure of project information which has led to severe harm to communities, from the street vendors in Kolkata to the indigenous Magar communities in Nepal and communities in Mongolia. Nadeen Madkour, Safeguards Policy Analyst of the Forum Network, stated, “The ADB should improve its safeguard delivery system to achieve genuine and pro-people sustainable development outcomes. We call for robust, rights-based, and just safeguard provisions that should not be seen as costs to be managed or risks to mitigate. There can be no genuine recovery if the Bank systematically fails to uphold safeguards, transparency, and accountability in its lending, investment, and technical assistance portfolio. ” The network believes that the ADB must have robust assurances of alignment with all international human rights frameworks, inclusive of the right to a clean, healthy and sustainable environment, as well as ensuring public disclosure and accessibility of associated guidance documents on gas, hydropower, and waste to energy projects.

NGO Forum on ADB Statement on the 55th ADB Annual Governors’ Meeting (First Stage) On the occasion of the First Stage of the 55th Annual Meeting of the Board of Governors of the Asian Development Bank (ADB), we take this opportunity to reiterate unresolved concerns arising from community-based, national and regional civil society organizations that monitor the investments, policies and implications of the ADB across the Asia and Pacific, and to urge the Bank to reassess its financing priorities and approaches. As this year’s virtual event is hosted by Sri Lanka and chaired by the Sri Lankan Finance Minister Ali Sabry, we collectively extend our solidarity with the diverse peoples’ movements across the region – including most notably in Sri Lanka, but also in Myanmar, India and the Philippines among others, mobilizing in defense of social, economic, environmental, gender and energy justice, and ultimately, livelihoods with dignity. We also remain alarmed by –and alert to – the range of devastating repercussions across the region stemming from the war in Ukraine, in particular for those with colleagues, friends and family members in Ukraine and Russia, as well as for those in closest proximity, across Central Asia and the Caucasus. At a time when the ADB has labeled this meeting as a time to advance the “Climate Resilient Green Economy for the Post – COVID – 19 World,” it is crucial that ADB’s support for COVID – 19 recovery does not result in further cutbacks in the developing member countries’ public expenditure on key social services. Specifically, we urge the ADB to avoid providing technical assistance or investments geared towards reforming the health, education, water and energy sectors through privatization or models of public – private partnerships, which we’ve repeatedly seen lead to services becoming less accessible, less accountable to the very people for which these services are supposed to support, and more reliant on workforces that are pushed to accept substandard working conditions. Over the course of 2021, ADB financing of large scale hydropower dams and expansive gas schemes, for example in Pakistan, India and Sri Lanka - despite being labeled as green, resilient or ‘climate smart’ – risk further exacerbating dispossession of affected peoples, depriving them of livelihoods, while placing the future of entire nation states into question (given the potential of carbon lock-in and loss of critical ecosystems relied upon for populations to survive, for example). As major riverbeds are drying up, flash floods, extended periods of drought and other extreme weather events are becoming the norm, it is clear that a just, and equitable process for phasing out fossil fuel dependence will be necessary. However, we firmly disagree with the ADB’s recently suggested “Four Paths to a Climate-Friendly Energy Transition for Asia and the Pacific” claiming “oil companies are on the front lines of the energy transition”, and that “ESG scores have the potential to attract trillions of dollars in private sector capital to address climate goals”. In contrast, from our perspective, it is the communities across the region, living in the most climate vulnerable areas of the world – including coastal regions and small island states threatened by rising sea levels – who are the ones taking the lead in driving forward demands for locally relevant, small-scale and community controlled energy systems. We have seen and felt first-hand the ways that ADB’s investments exacerbate indebtedness, deprive people of affordable and comprehensive universal health care services, increase levels of chronic hunger amidst the critical shortage of affordable staple foods, and facilitate reliance on resource-intensive, extractivist forms of energy. With our perspectives grounded in these lived experiences, we continue to assert that just, inclusive, sustainable transitions across South, Southeast, North and Central Asia, the Caucasus and the Pacific cannot and will not be realized if power is wrested in the hands of the very transnational, multinational and national corporations that have proven track records of committing human and environmental rights violations across the region. With the Asia Clean Energy Forum 2022 now on the horizon, we recall ACEF 2021 as a time when civil society groups spoke out firmly against the ADB’s energy policy (at the time, only a draft). Groups from across Asia and allies globally made a united decision to disengage with the session scheduled by the ADB during the formal program, and instead undertook our own online press conference. This was purposefully opened as a space for groups working with communities directly impacted by ADB financed energy projects to speak out –to explain directly why the ADB needs to stop approving new investments in gas, oil, large-scale hydropower dams, as well as waste-to-energy infrastructure, instead shifting towards decentralized, appropriately scaled renewable energy. Months later, in the lead up to the Board’s approval of the final version of the 2021 Energy Policy in October, civil society groups came together again to call for the Board to suspend the decision and go back to the drawing board. At the time, we urged a reconsideration of the Energy Policy provisions in order to enable a more nuanced consideration of: the current energy and climate challenges facing remote, rural, urban and peri-urban communities across Central, South and Southeast Asia and the Pacific; the latest climate data and analytics available (according to the IPCC Assessment 6 Reports); the need to shift support to enable the roll-out of decentralized, locally controlled and appropriately scaled renewable energy systems, including in island-based, remote and marginalized communities, support for just, inclusive, sustainable energy transitions with nuanced and appropriate approaches grounded in the different realities of Central, South, Southeast and North Asia, the Caucasus and the Pacific, comprehensive assurances of alignment with all international human rights frameworks, inclusive of the right to a clean, healthy and sustainable environment, as recognized by the UN Human Rights Council, and all ILO Conventions, as well as ensuring public disclosure and accessibility of associated guidance documents (on gas, hydropower and waste to energy projects). Although the Board approved the policy in October 2021, we continue to raise our concerns, and now in May 2022, are still reiterating the call for associated guidance notes to be made subject to public comment at a draft stage and public disclosure once finalized. We are also mindful that the ADB Annual Meeting will be a time when ADB looks back at agreements forged during COP 26. In this regard, we would like to remind the Bank of the statement issued by civil society groups across the region during the unveiling of the private-sector oriented Energy Transition Mechanism (coal retirement scheme) at COP26 in Glasgow. At that time, we outlined several key concerns including: the long timeline suggested for winding down operational coal-fired power plants (up to 15 years) and associated implications for local people, environment and economies; the likelihood of undermining national as well as international ambitions to uphold the provisions of the Paris Climate Accord and recommendations of the Intergovernmental Panel on Climate Change; the lack of assurances that the early retirement of coal plants will not result in the expansion of other fossil fuel reliant energy infrastructure; and the severe lack of opportunities provided to date for communities as well as civil society and people’s organizations to engage with the ADB’s processes of formulating this scheme. Up until now, nearly mid-way through 2022, civil society organizations still continue to raise significant concerns, specifically in the Philippines and Indonesia, about the expected piloting phase of this scheme in the year ahead. Finally, as the 2009 ADB Safeguard Policy Statement is currently under review, the Forum reiterates our demands for comprehensive, rights-based safeguards, accompanied by a robust implementation plan. Taking a precautionary approach, considering alternatives (including the no project option), and responding to community concerns should be considered as integral aspects of project implementation from the outset, not simply checkbox exercises. In addition, in light of the ADB’s own claims towards upholding climate resilience, it is time for the Bank to take the cue from MDBs already introducing respect for “no go zones” by integrating provisions as outlined by the model Banks and Biodiversity No Go Policy directly into its updated Safeguard Policy. Going forward, the ADB must also look towards more stringent application of “equivalence and acceptability assessments” prior to taking into consideration the potential use of country safeguard systems. Doing away with these assessments for the sake of flexibility and practical purposes is contrary to attaining more equitable, just development outcomes. Looking ahead, we urge the ADB to consider integrating provisions that would clearly uphold a zero tolerance position in regards to reprisals against community members and allied advocates at – and around – all project sites. There can be no genuine recovery, if the bank continues to systematically fail in upholding safeguards, transparency and accountability in its lending, investment and technical assistance portfolio. Endorsed by the following organizations - 350 Pilipinas, Philippines 350.org Asia, Asia Aksi! for gender, social and ecological justice, Indonesia Asian Peoples' Movement on Debt and Development (APMDD), Regional Bangladesh NGOs Network for Radio and Communication, Bangladesh Bangladesh Working Group on External Debt (BWGED), Bangladesh Bank Information Center, USA Building and Wood Workers International Asia Pacific, Philippines CEE Bankwatch Network, Czechia Center for Energy, Ecology, and Development, Philippines Centre for Environmental Justice, Sri Lanka CLEAN (Coastal Livelihood and Environmental Action Network), Bangladesh Committee for the Abolition of Illegitimate Debt (CADTM),, India Community Empowerment and Social Justice Network (CEMSOJ), Nepal debtWATCH Indonesia, Indonesia Environics Trust, India Environmental public society, Armenia Equitable Cambodia, Cambodia FIAN Sri Lanka, Sri Lanka Freedom from Debt Coalition, Philippines Friends of the Earth US, US Gender Action, Global Growthwatch, India Humane Society International, United States Indian Social Action Forum (INSAF), India Indigenous Women's Legal Awareness Group (INWOLAG), NEPAL Initiative for Rights View,, Bangladesh Life haven Center for independent living, Philippines Mekong Watch, Japan Oil Workers' Rights Protection Organization Public Union, Azerbaijan, OTWatch Mongolia, Mongolia Prakriti Resources Centre, Nepal Recourse, The Netherlands Sri Lanka Nature Group, Sri Lanka The Bretton Woods Project, United Kingdom Youth Group on Protection of Environment, Tajikistan Download PDF here.

2nd May 2022 To: Mr. Jin Liqun, President, Asian Infrastructure Investment Bank (AIIB) Mr. Ludger Schuknecht, V.P. and Corporate Secretary, AIIB Sir Danny Alexander, V.P., Policy and Strategy, AIIB Mr. Bob Pickard, D.G., Communications Department, AIIB – Via Email – Dear AIIB President Jin Liqun, Mr. Ludger Schuknecht, Sir Danny Alexander, and Mr. Bob Pickard: We are writing collectively to express significant concerns about the highly limited parameters of the call for public input on the draft text of the AIIB Energy Sector Strategy Update, and in particular, to urge an immediate reconsideration of the stipulated deadline as well as the unilingual written submission format as posted on the AIIB’s website. Since last September 2021, civil society organizations from across the Asia and Latin America regions as well as European constituencies have proactively raised questions about the Energy Sector Strategy Update process – in writing, in person during COP26 in Glasgow, and online during the civil society information session scheduled in late February 2022. We once again take this opportunity to call on the AIIB Management and Board to open up a transparent, inclusive, participatory and publicly accountable process, engaging community, national, regional and international civil society networks across the global span of the Bank’s membership. Crucially, the requirements for English written submissions within such a short span of time create serious barriers for civil society groups inclusive of all regional and non-regional member states to give meaningful, specific, evidence-based input. Moreover, with all due respect, there is no clarity on the extent to which we can expect comments provided by external actors during this time to be integrated into a revised draft text. In fact, although the draft text of the Energy Sector Strategy Update acknowledges that other MDBs “have updated their energy policies and strategies in recent years” (para 24), there is no indication that the AIIB is seeking to follow similar online public consultation processes on policy revisions that were recently initiated by peer MDBs (such as those of the ADB, which typically span over several months and enable both written as well as discussion based inputs). At a minimum, a more transparent and inclusive process would require: extending the deadline for input beyond 3rd June; posting translated draft texts of the proposed Energy Sector Strategy Update in major languages of regional and non-regional members and enabling options for submissions to be accordingly received and taken into account in other languages; permitting comments on the draft to be submitted anonymously, providing assurances that such inputs will be duly taken into account, publicly disclosing any approach or background paper on the Energy Sector Strategy Update that is informing the revisions proposed (e.g. CEIU’s Early Learning Assessments on energy projects) at the earliest possible date, i.e. during (rather than following) the public consultation period; publicly disclosing a timeline for the update with clearly defined opportunities for civil society inputs, as well as a commitment to disclose a collated list of public comments received with responses from the AIIB (for reference, see: the ADB Energy Policy Review: Summary of Comments from Stakeholders, published during their Energy Policy review in June 2021); scheduling online interactive discussion based sessions (non-webinar format) held in different time zones and languages to accommodate regional and non-regional members, and times for meetings to discuss sub-sector concerns, such as on hydropower dams, gas power projects, LNG terminals and cross-border pipelines (transmission and distribution), as well as those classified as ‘innovative and transformative’ in the draft updated text (e.g. including ‘low-carbon’ hydrogen, biomass methodologies and electricity storage technologies); providing transparent and clear language on the applicability of the Energy Sector Strategy to non-regional member states, including (i) defined expectations on what types of energy investments will be prioritized and promoted outside of the Asian region, and (ii) what types of modalities for financing will be deployed (financial intermediary on-lending; financial Institution/liquidity investments, private /public sector), so that civil society groups from other regions can respond accordingly, and proactively responding to the range of concerns civil society groups have brought forward to the Bank’s management, board and staff about the risk of reprisals experienced by outspoken community members in project affected areas by immediately (i) integrating a Zero Tolerance provision on reprisals within the text of the updated draft on the AIIB Energy Sector Strategy, as well as (ii) operationalising the Bank’s 2021 Environmental and Social Framework commitments to address retaliations by adopting and putting into practice an explicit Zero Tolerance protocol for all external relations, inclusive of the ongoing policy revision process of the Energy Sector Strategy. Socially and Environmentally Risky Investments in the Energy Sector Makes Transparency and Public Accountability of Paramount Importance Based on reviewing the draft text of the updated Energy Sector Strategy, we note that investments suggested in the future include developing hydropower dams, drilling for geothermal resources, burning biomass and/or biofuel for energy, building downstream and midstream gas projects, infrastructure for carbon capture and storage, as well as options for concentrated solar and ‘low-carbon’ hydrogen power. Importantly, civil society groups have already raised considerable concerns about the significant environmental and social impacts expected from energy projects that are in the pipeline but yet to be approved, such as the 280 MW Nenskra Hydropower Plant in Georgia, the Tamakoshi V Hydroelectric Project in Nepal, and the Unique 584MW Meghnaghat Combined Cycle Power Plant in Bangladesh (all of which are listed on the AIIB’s website as proposed “Category A” investments). Such a range of resource-intensive projects being considered across AIIB’s membership can only be expected to take a heavy toll on community and ecological health,[1] potentially leading to rising tensions within border territories when shared resources are at stake (e.g. transboundary watersheds). As project specific decisions made in the energy sector will have long term implications for the economic, social, environmental and geopolitical futures of several of the Bank’s borrowing member countries and their respective populations, a transparent, publicly accountable process for developing the strategic framework for investments in the sector is absolutely imperative. Notably, civil society organizations based in both regional and non-regional member countries are also alarmed by the increasing financial intermediary on-lending portfolio of the AIIB, including in relation to the energy sector – as there is limited systematic public disclosure of what subprojects are receiving financing, or which communities are affected by these investments, let alone translation of project information into locally relevant languages. Accordingly, this raises serious questions of transparency and accountability, given the lack of any effective options for there to be publicly verifiable assurances that loan conditionalities are being met, such as in relation to exclusions placed on coal and associated infrastructure, or for grievance redress.[2] In light of all the issues raised above, we continue to firmly call upon the AIIB Management and Board to extend the deadline beyond 3rd June to deliberate on the draft text of the 2022 Updated Energy Sector Strategy, taking the time to meaningfully listen to – and consider integrating – inputs from a range of societal sectors across the AIIB’s membership in a public, inclusive, accountable and transparent manner. First and foremost, this must include the scheduling of open, participatory online discussion sessions that seek public inputs on specific sub-sectors of project investments expected to be prioritized in the Energy Sector Strategy Update (e.g. inclusive of hydropower, downstream and midstream gas infrastructure, and renewable energy/emerging technologies) adjusted for timezone considerations and with translation options available. We are open to discussing the points raised herein. Given the highly limited timeline, we look forward to hearing a response within the coming two weeks, at the latest by Friday 13th May. For a meaningful, inclusive, multi-lingual, publicly accountable, and transparent consultation process with diverse sectors of civil society, 350.org Asia, Regional 350 Pilipinas, Philippines 3S Rivers Protection Network (3SPN), Cambodia Aksi! for Gender, Social and Ecological Justice, Indonesia Asociación Ambiente y Sociedad (Colombia) Asian Peoples’ Movement on Debt and Development (APMDD), Regional Building and Wood Workers International - Asia Pacific, Regional Bangladesh Working Group on External Debt (BWGED), Bangladesh Both ENDS, Netherlands CEE Bankwatch Network, Czech Republic Center for Energy, Ecology, and Development, Philippines Centre for Environmental Justice, Sri Lanka Centre for Financial Accountability, India Centro de Documentación e Información Bolivia, Bolivia Change Initiative, Bangladesh Civic Advisory Hub, Uganda Coastal Livelihood and Environmental Action Network (CLEAN), Bangladesh Committee for the Cancellation of Third World Debt (CADTM), India Defenders Protection Initiative, Uganda Environics Trust, India Environmental Public Alliance, Armenia Equitable Cambodia, Cambodia Forest Peoples’ Programme, UK Freedom from Debt Coalition, Philippines Friends of the Earth US, USA Fundación Ambiente y Recursos Naturales (FARN), Argentina Fundación para el Desarrollo de Políticas Sustentables /Foundation for the Development of Sustainable Policies (Fundeps), Argentina Gender Action, USA Global Alliance for Incinerator Alternatives - Asia Pacific, Regional Global Responsibility, Austria Growthwatch, India GT Infraestrutura, Brazil Inclusive Development International, USA Indian Social Action Forum, India Initiative for Right View (IRV), Bangladesh International Accountability Project International Rivers Just Finance International, Netherlands Koalisi Pemantau Pembangunan Infrastruktur Indonesia, Indonesia KRuHA - People's Coalition for the Right to Water, Indonesia Latinoamerica Sustentable, Regional Manushya Foundation, Thailand Mekong Watch, Japan Nash Vek, Kyrgyzstan NGO Forum on ADB Secretariat, Regional Oil Workers' Rights Protection Organization Public Union, Azerbaijan Oyu Tolgoi Watch, Mongolia Pakistan Fisherfolk Forum, Pakistan Protection International Mesoamérica, Guatemala Recourse, Netherlands Rivers without Boundaries Coalition, Mongolia Rivers without Boundaries International Coalition, Russia Sustentarse, Chile Urgewald e.V. Germany, Germany VedvarendeEnergi, Denmark Youth Group for the Protection of the Environment, Tajikistan 1 Although the AIIB’s PPM has only received one submission to date on behalf of complainants affected by the Bhola IPP Gas Project, the negative social and environmental implications of several other energy investments advanced by the AIIB since 2016 have been raised by community groups and allied organizations, including in relation to the Upper Trishuli-1 Hydropower Project in Nepal, the Balakot Hydropower Project in Pakistan and the Trans Anatolian Natural Gas Pipeline Project in Azerbaijan. 2 See for example, USD 100 million approved for the BDMG Renewables and Asia Connectivity Facility in Brazil earlier this year. Download PDF here.

Dhaka, Bangladesh - CLEAN (Coastal Livelihood and Environmental Action Network), a Bangladeshi environmental and human rights organization, and NGO Forum on ADB, an Asian-led network of organizations monitoring the ADB and AIIB based in Manila, formally filed a complaint against the Asian Infrastructure Investment Bank (AIIB) regarding the Bhola Gas Power Plant (Bhola IPP) (Project Number 000057). This is the first complaint filed against the Bank in its 7 years of operation. Bhola IPP is a 220 MW Combined Cycle Power Plant (CCPP) that intends to help improve Bangladesh’s power generation capacity and address shortages but according to impacted communities, this is not true. Grave concerns about the project were raised by impacted communities, particularly on the issue of land grabbing. According to affected families, there was coercion and intimidation from ‘middlemen’ appointed by the project developer, Nutan Bidyut Bangladesh Limited (NBBL) to forcibly acquire their lands at the lowest rates. Hasan Mehedi from CLEAN explained that “the land acquisition practice was in violation of the Bangladesh Acquisition and Requisition of Immovable Property Act 2017, which stipulates landowners to be entitled to thrice the market price from private companies. The company has also taken more land than they bought” There were also no records of sales or transactions on the first phase of the land acquisitions made by NBBL. The project also has harmful environmental impacts. The construction of the power plant, sand, and other structural waste deposited by NBBL has led to the Mandartoli Shakha Khal/River Channel over siltation. The NBBL embanked its northern part with sand sacks and has taken over half of the canal. The sand from the sacks has spilled out into the canal bed, causing siltation and the canal to dry up gradually. As of the moment, the canal is only 1-2 feet deep and has lost its water carrying capacity. Due to the destruction of the Mandartoli Shakha Khal, monsoon water overflows during high tide. It directly floods the Dakshin Kutba village, where an estimated 400 Betel leaf farms have been destroyed, displacing over 2000 families dependent on agriculture. Over 100 households are approximated to be directly waterlogged and left completely disconnected from public services, communication, health care, and other necessary services. In addition, there was no proper water, sanitation, and hygiene (WASH) plan for the labor colony constructing the power plant. The effluent, sewage, and waste are discharged in large amounts into the surrounding villages, leading to uninhabitable living conditions. The project site has also taken over half of all grazing land in the area, directly impacting goat herders, who are mainly women. Other problematic issues were also raised by impacted communities ranging from lack of Information Disclosure and Meaningful Consultation, poor and misleading translation of critical documents, and the absence of documentation or outputs from the consultation reports. Rayyan Hassan, executive director of NGO Forum on ADB, stated “local communities and civil society organizations are exhausted raising these issues to NBBL and AIIB management for the last three years with no meaningful resolution to the problems. This complaint is being sent as a last resort to ensure justice to the aggrieved communities to resolve the problems surrounding Bhola IPP. The AIIB accountability mechanism has never been tested until now, we hope it can deliver on its promised purpose.”

Asian Infrastructure Investment Bank's (AIIB) response to the two letters sent by NGO Forum on ADB network - Follow Up Correspondence Concerning the 2022 Energy Sector Strategy Update Collective Call for a New Forward Looking AIIB Energy Sector Strategy Download PDF version here.