In October 2021, BIC, along with Asociación Ambiente y Sociedad (AAS), and Sociedad y Discapacidad (SODIS) held a panel at the World Bank’s Civil Society Policy Forum (CSPF) on the main challenges for implementing the Environmental and Social Framework (ESF) in Latin America and the Caribbean. The Panel also discussed opportunities to strengthen ESF implementation moving forward.
The major ESF implementation challenges raised by AAS, SODIS, and BIC centered around Environmental and Social Standard 1 (ESS1), Assessment and Management of Environmental and Social Risks and Impacts, ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Communities, and ESS10 Stakeholder Engagement and Information Disclosure. Without the rigorous implementation of the ESF, challenges around these three standards tend to compound and magnify one another. Where marginalized groups, including Indigenous Peoples, are not properly identified as stakeholders, they are often not engaged and particular risks to these groups are not assessed or mitigated.
The Lima Metropolitano BRT North Extension project, which SODIS and AAS highlighted, shows how the weak implementation of one of these standards (ESS10) affects the implementation of another standard (ESS1). Though the Environmental and Social Commitment Plan (ESCP) highlights universal access in the stations and underscores the need to consider accessibility issues in the areas surrounding the stations, meaningful engagement with persons with disabilities remains a major challenge that is impacting the accessibility and universal design of the project. Rather than holding accessible consultations with persons with disabilities and seeking their input to improve the project design, consultations were used to present project documents and designs that had already been approved. This means that key accessibility measures that could provide for more persons with disabilities to access project benefits may have been overlooked, perpetuating the cycle of inaccessible public transport systems in Lima and its surrounding areas. Many of the early key project documents are only available in English, making project information inaccessible, and there is no feedback loop in place for persons with disabilities to know if the input they provided during consultations has been integrated into the project.
The Bank recognized the challenges with ESF implementation identified by the panelists and shared with civil society some of the key barriers to proper ESF implementation that the Bank has identified over the last three years. The Bank representative stated that Borrowers often have questions on how to meaningfully engage stakeholders throughout the project cycle, especially in the current COVID-19 context, how to use stakeholder feedback to systematically improve project design, and how to set up effective grievance redress mechanisms. Also, the Bank highlighted that it is difficult to get the Borrowers to change their mindset from one-off consultation to a continuous process throughout the project. Ultimately, the ESF represents a challenge and an opportunity on the social side with the do-good approach where the Borrower must now look at differentiated measures for different marginalized groups to be able to access project benefits, but this change means there will be challenges as Borrowers begin to better understand how to implement the ESF.
Though robust ESF implementation is difficult, specifically in countries that do not tend to prioritize stakeholder engagement and the inclusion of marginalized groups, the strong standards of the ESF provide the Bank’s key added value to development projects. To address the challenges identified by civil society and Bank staff and strengthen ESF implementation, the Bank should:
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