This update was written with Mario Paniagua, Indigenous Peoples Senior Advisor at Fundación Tierra, Bolivia
In December 2022, the World Bank’s independent accountability mechanism, the Inspection Panel (IP), launched an investigation in response to a complaint filed by the affected communities, the Chiquitanos Indigenous Peoples Centrales, who were harmed by the Santa Cruz Road Corridor Connector Project in La Chiquitania, Bolivia. The investigation concluded in May 2023, when the IP published its report, which identified several areas of noncompliance with the World Bank's Operational Policies (OP), particularly OP 4.01 (Environmental Assessment), OP 4.12 (Involuntary Resettlement), OP 4.10 (Indigenous Peoples), and the Bank’s Policy on Investment Project Financing.
Following the Inspection Panel’s investigation, World Bank management prepared a management action plan (MAP) to address the findings and implement corrective measures. However, the MAP is insufficient, as it lacks a process and provisions for engagement and collaboration with impacted Indigenous communities on its implementation. The fact that the Bank proposed a MAP disregarding the participation of project impacted communities contradicts the IP's findings. Further, the MAP does not include measures to remedy the adverse impacts caused by the right-of-way acquisition processes, including compensation payments and the valuation methodology. There are also no corrective measures in the MAP to bring IPP projects into compliance with their stated objectives and their outcomes.
The IP’s findings of harm and noncompliance, some of which are inadequately addressed by the MAP, include:
- Free, Prior, and Informed Consultation (FPIC): The World Bank did not provide an assessment of the project’s potential adverse impacts with the Chiquitano communities. Further, the Bank did not facilitate an adequate process of FPIC with them on the project. Instead, the Bank held consultations focused solely on project benefits without addressing adverse impacts.
- Grievance Redress Mechanism (GRM): The GRM was not culturally appropriate nor developed in consultation with the Chiquitano representatives. There were also no procedures to accommodate the customary dispute resolution process used by the Indigenous People.
- Indigenous Peoples Plan (IPP): The IPP included economic, environmental, and public health projects meant to benefit the local Chiquitano community. However, many of the projects included in the IPP were poorly designed and did not achieve the intended outcomes. For instance, a women's handicraft center was constructed but was too small and lacked sufficient electricity to be useful to the community. Additionally, the IPP commissioned a livestock project which included the construction of new wells. However, these wells did not provide water for human or animal consumption, greatly reducing the project’s efficacy and failing to meet one of the community’s most critical needs.
- Compensation and resettlement: Compensation for the right-of-way was not properly paid prior to taking land and related assets, and there was no adequate process for compensation payments. Many Indigenous Peoples were also unaware of how compensation was calculated. Further, communities lacked understanding of right-of-way determinations and their land status. Although more than 40 consultation meetings were conducted, ineffective communication led to misunderstandings and grievances among community members.
- Lack of a social impact assessment or management plans and inadequate support in negotiating agreements with contractor for borrow pits: The World Bank did not include measures to minimize, mitigate, or compensate adequately for the negative impacts associated with the development of the borrow pits — excavation sites developed to extract materials used to upgrade the road. The investigation found that no social impact assessment or social management plan was developed for impacts from the borrow pits, including a closure plan. In addition, the Chiquitano communities did not receive adequate information or support to negotiate agreements with the contractor for the use of borrow pits. This lack of supervision and oversight during the negotiation process, combined with stringent nondisclosure and arbitration clauses in the agreements, left the communities at a disadvantage.
- Lack of identification or mitigation of project impacts on the atajados (artificial ponds that provide drinking water): The atajados are critical to the communities because these ponds guarantee access to clean, potable water for human and animal consumption. In the complaint, communities shared how the road construction adversely affected their atajados, including through increased sedimentation and contamination due to rainwater runoff from the road, and by obstructing water inflow. The Panel confirmed that the Bank and the borrower did not develop a social impact assessment or social management plan for project impacts on the atajados.
- Road safety, occupational health and safety, and labor working conditions: World Bank management did not adequately implement the ESIA and road safety measures to protect the community and workers’ human health, safety, and livelihoods, in noncompliance with OP 4.01. Further, prior to the IP complaint, World Bank management did not confirm the implementation of Occupational Health and Safety measures, including working conditions.
- Child sexual exploitation, abuse, and harassment (SEA/H): The Bank initially ranked the project as “low” risk for project-related gender-based violence (GBV) issues, despite high rates of GBV in the region and the high GBV risk posed by large infrastructure projects, detailed in a World Bank Good Practice Note. Further, the Bank did not assess the risk to adolescents of SEA/H committed by the influx of project workers, identify the community’s knowledge gap on where and how to report cases, or account for the local government’s limitations and lack of resources to handle SEA/H and GBV cases. However, the Panel notes that since 2019 and “since allegations of SEA/H have come to light,” the “Project’s system to prevent and manage SEA/H issues has been continuously strengthened and improved.” The IP’s report concludes that management is now in compliance with OP 4.01.
The Inspection Panel report describes how the Chiquitanos concerns were overlooked and inadequately addressed by the Bank and borrower. Many impacts could have been avoided or mitigated with earlier identification and thorough contextual analysis by World Bank management, including on the importance of Indigenous Peoples' rights, claims, vulnerabilities, and aspirations. The assumption made by World Bank management that the project as an "upgrade" rather than new construction would have minimal and manageable impacts led to an underestimation of risks and social contexts.
The Santa Cruz Road Corridor Connector Project caused significant harm, which could have been avoided with earlier collaboration with the affected communities. At a minimum, World Bank management must improve its transparency and consultation practices with the Chiquitanos around the MAP. Further, it’s critical that the World Bank Board of Directors remains engaged around this project and uses all available leverage to push the borrower to collaborate and consult with the Chiquitanos leaders during the implementation of the MAP and guarantee their participation throughout the entire process. Finally, we call on Bank management and the borrower to work closely with the Chiquitanos community when implementing the different actions included in the MAP.
For more information about the shortcomings of the MAP, read the letter of the Chiquitanos Centrales to the World Bank Board of Directors.