76 NGOS WRITE TO MR. PETER WOICKE
September 9, 2004
Mr. Peter Woicke
Executive Vice President
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
cc: IFC Board of Directors, Rachel Kyte, Director, IFC Environment and Social Development Department
Re: Mandatory disclosure and right-to-know requirements for IFC-sponsored projects concerning pollutant releases and transfers
Dear Mr. Woicke:
We welcome the International Finance Corporation’s (IFC’s) decision to update and expand its Safeguard and Disclosure Policies and the Environmental, Health and Safety Guidelines. A number of important developments in international standards have occurred since the IFC last revised its policies and guidelines, and these reviews are an opportunity to better integrate emerging environmental norms into the IFC’s policy framework. We believe that the review of these policies must ensure greater inclusion of the viewpoints and concerns of affected communities and that the standards must be significantly strengthened, not weakened.
With this in mind, we are writing to urge the IFC to support the increasingly widespread use of Pollutant Release and Transfer Registers by applying mandatory disclosure requirements for pollutant releases and transfers to IFC-financed projects. We believe that communities have a right to know about the pollutants that are being released into their environment and that the IFC should require regular reporting and take steps to ensure that data for each project is available directly to local communities and all spheres of government and also electronically in a consolidated database. This should occur without regard to any lack of national government policy to enforce such a mechanism.
Both the IFC Safeguard Policy Review and the World Bank Group Extractive Industries Review highlighted the importance of improving reporting and monitoring during project implementation. By ensuring that essential information about pollutant releases and transfers is provided to local communities and the broader public, the IFC will advance its stated objectives of sustainable development and poverty alleviation. Enhanced transparency will help to promote meaningful citizen participation, avoid negative project impacts, maximize project benefits and contribute to the IFC’s ability to measure project outcomes in relation to targets established during project assessment.
In recent years, disclosure of pollutant releases and transfers has become an increasingly widespread policy tool adopted by many countries. In 2003, pollutant release and transfer register (PRTR) mandates were adopted through an international agreement negotiated under the auspices of the UN Economic Commission for Europe and signed by thirty-six European countries and economies in transition. That agreement, the Protocol on Pollutant Release and Transfer Registers, requires its parties to institute national PRTR systems, including both the disclosure of pollutant releases and transfers and the publication of those data by the government. The Protocol covers a wide range of pollutants, including toxics and greenhouse gases.
In addition, some developing country governments, including Mexico and Chile, are proceeding toward implementation of PRTR systems. In the United States, the Toxics Release Inventory (TRI), adopted in 1986 as part of the Emergency Planning and Community Right-to-Know Act, was a pioneering tool for requiring the disclosure of information concerning pollutant emissions and transfers. Comparable pollutant disclosure standards have been established in Canada, the United Kingdom and Japan.
Pollutant release and transfer registers have proven highly successful in providing data that is useful to communities, investors, policy advocates, policymakers, and businesses. Moreover, disclosure policies have resulted in significant voluntary reductions in pollutant discharges. For example, according to government data, US industry voluntarily reduced toxic releases by more than 45% over the first decade of TRI’s implementation. The increasing international adoption of PRTR policies is a strong indicator of the important benefits that pollutant disclosure has provided.
We believe that the IFC should take note of the widespread international success of PRTR policies and should use those policies as the baseline for pollutant disclosure requirements that would be applied to IFC-financed projects. To achieve these goals, the IFC should require project sponsors to publicly disclose complete release and transfer data for a wide range of toxics, greenhouse gases, and ozone-depleting substances. In addition, the IFC should itself ensure that this data for each project is publicly available both directly to local communities in local languages and electronically in a consolidated online database, and the IFC should also ensure the development of an implementation and monitoring protocol. Disclosure of releases by project sponsors and publication of the data by the IFC should occur on an annual basis. The IFC should also make publicly available the contract conditions with which project sponsors are required to comply regarding pollutant releases.
These disclosure requirements are an indispensable step toward ensuring the sustainability of IFC-financed projects. Without these requirements, independent assessment of the actual impacts of projects is not possible. We appreciate your attention to the concerns expressed here and welcome discussion of these issues.
Sincerely,
- Pamela K. Miller
Alaska Community Action on Toxics (ACAT)
United States - Laura Radiconcini
Amici della Terra/Friends of the Earth-Italy
Italy - Carlos Abanto
Asociacion Civil Labor/Friends of the Earth-Peru
Peru - Azad Aliev
Association of Social Economic Researches of Azerbaijan
Azerbaijan - Saulius Piksrys
Atgaja Community
Lithuania - Delphine Kemneloum Djiraibe
Chadian Association for the Promotion and the Defense of Human Rights (ATPDH)
Chad - Manish Bapna
Bank Information Center
United States - Henneke Brink
Both ENDS
The Netherlands - Markus Steigenberger
BUND/Friends of the Earth-Germany
Germany - Jaroslava Colajacomo
Campagna per la riforma della banca mondiale
Italy - Manana Kochladze
CEE Bankwatch Network
Czech Republic - Hildebrando VŽlez G.
CENSAT AGUA VIVA/Friends of the Earth-Colombia
Colombia - Petko Kovatchev
Center for Environmental Information and Education
Bulgaria - Damien Ase
Center for Environmental Law and Community Rights/Friends of the Earth-Papua New Guinea
Papua New Guinea - Peter Mihok
Center for Environmental Public Advocacy
Slovakia - Anne Perrault
Center for International Environmental Law
United States - Petr Hlobil
Centre for Transport and Energy (CDE)
Czech Republic - Ab. Victor Hugo Ricco
Centro de Derechos Humanos y Ambiente (CEDHA)
Argentina - Peter Sinkamba
Citizens for a Better Environment (CBE)
Zambia - Andrei Kelemen
Clubul Ecologic “Transilvania”
Romania - Isaac Rojas
COECOCeiba-AT/Friends of the Earth-Costa Rica
Costa Rica - Charmaine Rodrigues
Commonwealth Human Rights Initiative
India - Bob Shavelson
Cook Inlet Keeper
United States - Michelle Kinman
Crude Accountability
United States - Souparna Lahiri
Delhi Forum
India - Ana Golovic
Eko-Svet
Macedonia - Korinna Horta, Ph.D.
Environmental Defense
United States - Gary Cohen
Environmental Health Fund
United States - Leo Saldanha
Environment Support Group (R)
India - Peep Mardiste
Estonian Green Movement/Friends of the Earth – Estonia
Estonia - Tom Griffiths
Forest Peoples Programme
United Kingdom - Rudy Amenga-Etego
Foundation For Grassroots Initiatives in Africa (GrassrootsAfrica)
Ghana - Binnie O’Dwyer
Friends of the Earth-Australia
Australia - Graham Saul
Friends of the Earth-Canada
Canada - Sebastien Godinot
Friends of the Earth-France
France - Noble Wadzah
Friends of the Earth-Ghana
Ghana - Shoko Murakami
Friends of the Earth-Japan
Japan - Donald Pols
Friends of the Earth-Netherlands/ Milieudefensie
The Netherlands - Teresa Mart’nez Dom’nguez
Friends of the Earth-Scotland
Scotland - David Waskow
Friends of the Earth-United States
United States - Denny Larson
Global Community Monitor (GCM)/ National Refinery Reform Campaign
United States - Jason Mark
Global Exchange
United States - Koueda Koung Jean
Global Village Cameroon
Cameroon - Nino Dadalauri
Green Alternative
Georgia - Bobby Peek
groundWork/Friends of the Earth-South Africa
South Africa - Kalia Moldogazieva
HDC “Tree of Life”
Kyrgyz Republic - Pavel Pribyl
Hnuti DUHA/Friends of the Earth- Czech Republic
Czech Republic - Geoff Nettleton
Indigenous Peoples Links
United Kingdom - Andrzej Gula
Institute for Environmental Tax Reform
Poland - Nadia Martinez
Institute for Policy Studies Sustainable Energy and Economy Network
United States - Anyakwee Nsirimoivu
Institute Of Human Rights And Humanitarian Law
Nigeria - Peter Bosshard
International Rivers Network
United States - Yuki Tanabe
Japan Center for a Sustainable Environment and Society (JACSES)
Japan - Richard Harkinson
Minewatch
United Kingdom - Catherine Coumans
MiningWatch Canada
Canada - Tony Tweedale
Montana Coalition for Health, Environmental & Economic Rights (CHEER)
United States - Yury Urbansky
National Ecological Center of Ukraine
Ukraine - David Monk
Oregon Toxics Alliance
United States - Keith Slack
Oxfam America
United States - Ania Roggenbuck
Polish Green Net
Poland - Jan Cappelle
Proyecto Gato
Belgium - Wenonah Hauter
Food, Energy and Water Program
Public Citizen
United States - Oscar Rivas
Sobrevivencia/Friends of the Earth- Paraguay
Paraguay - Himanshu Thakkar
South Asia Network on Dams, Rivers & People
India - Ionut Apostol
TERRA Mileniul III
Romania - Nicholas Hildyard
The Corner House
United Kingdom - Sergey Solyanik
The Ecological Society Green Salvation
Republic of Kazakhstan - Simon Burall
The One World Trust
United Kingdom - Fernando Melo
Transparecia
Mexico - Rev. Douglas B. Hunt
United Church of Christ Network for Environmental and Economic Responsibility
United States - Knud Všcking
Urgewald e.V.
Germany - Alda Ozola
VAK/Friends of the Earth-Latvia
Latvia - Nur Hidayati
WALHI/Friends of the Earth-Indonesia
Indonesia - Daniel Owusu-Koranteng
Wassa Association of Communities Affected by Mining (WACAM)
Ghana - Paul Orum
Working Group on Community Right-to-Know
United States - Andrea Ploeger
World Economy, Ecology and Development (WEED)
Germany - Ivailo Hlebarov
Za Zemiata
Bulgaria