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,

  1. Pamela K. Miller
    Alaska Community Action on Toxics (ACAT)
    United States
  2. Laura Radiconcini
    Amici della Terra/Friends of the Earth-Italy
    Italy
  3. Carlos Abanto
    Asociacion Civil Labor/Friends of the Earth-Peru
    Peru
  4. Azad Aliev
    Association of Social Economic Researches of Azerbaijan
    Azerbaijan
  5. Saulius Piksrys
    Atgaja Community
    Lithuania
  6. Delphine Kemneloum Djiraibe
    Chadian Association for the Promotion and the Defense of Human Rights (ATPDH)
    Chad
  7. Manish Bapna
    Bank Information Center
    United States
  8. Henneke Brink
    Both ENDS
    The Netherlands
  9. Markus Steigenberger
    BUND/Friends of the Earth-Germany
    Germany
  10. Jaroslava Colajacomo
    Campagna per la riforma della banca mondiale
    Italy
  11. Manana Kochladze
    CEE Bankwatch Network
    Czech Republic
  12. Hildebrando VŽlez G.
    CENSAT AGUA VIVA/Friends of the Earth-Colombia
    Colombia
  13. Petko Kovatchev
    Center for Environmental Information and Education
    Bulgaria
  14. Damien Ase
    Center for Environmental Law and Community Rights/Friends of the Earth-Papua New Guinea
    Papua New Guinea
  15. Peter Mihok
    Center for Environmental Public Advocacy
    Slovakia
  16. Anne Perrault
    Center for International Environmental Law
    United States
  17. Petr Hlobil
    Centre for Transport and Energy (CDE)
    Czech Republic
  18. Ab. Victor Hugo Ricco
    Centro de Derechos Humanos y Ambiente (CEDHA)
    Argentina
  19. Peter Sinkamba
    Citizens for a Better Environment (CBE)
    Zambia
  20. Andrei Kelemen
    Clubul Ecologic “Transilvania”
    Romania
  21. Isaac Rojas
    COECOCeiba-AT/Friends of the Earth-Costa Rica
    Costa Rica
  22. Charmaine Rodrigues
    Commonwealth Human Rights Initiative
    India
  23. Bob Shavelson
    Cook Inlet Keeper
    United States
  24. Michelle Kinman
    Crude Accountability
    United States
  25. Souparna Lahiri
    Delhi Forum
    India
  26. Ana Golovic
    Eko-Svet
    Macedonia
  27. Korinna Horta, Ph.D.
    Environmental Defense
    United States
  28. Gary Cohen
    Environmental Health Fund
    United States
  29. Leo Saldanha
    Environment Support Group (R)
    India
  30. Peep Mardiste
    Estonian Green Movement/Friends of the Earth – Estonia
    Estonia
  31. Tom Griffiths
    Forest Peoples Programme
    United Kingdom
  32. Rudy Amenga-Etego
    Foundation For Grassroots Initiatives in Africa (GrassrootsAfrica)
    Ghana
  33. Binnie O’Dwyer
    Friends of the Earth-Australia
    Australia
  34. Graham Saul
    Friends of the Earth-Canada
    Canada
  35. Sebastien Godinot
    Friends of the Earth-France
    France
  36. Noble Wadzah
    Friends of the Earth-Ghana
    Ghana
  37. Shoko Murakami
    Friends of the Earth-Japan
    Japan
  38. Donald Pols
    Friends of the Earth-Netherlands/ Milieudefensie
    The Netherlands
  39. Teresa Mart’nez Dom’nguez
    Friends of the Earth-Scotland
    Scotland
  40. David Waskow
    Friends of the Earth-United States
    United States
  41. Denny Larson
    Global Community Monitor (GCM)/ National Refinery Reform Campaign
    United States
  42. Jason Mark
    Global Exchange
    United States
  43. Koueda Koung Jean
    Global Village Cameroon
    Cameroon
  44. Nino Dadalauri
    Green Alternative
    Georgia
  45. Bobby Peek
    groundWork/Friends of the Earth-South Africa
    South Africa
  46. Kalia Moldogazieva
    HDC “Tree of Life”
    Kyrgyz Republic
  47. Pavel Pribyl
    Hnuti DUHA/Friends of the Earth- Czech Republic
    Czech Republic
  48. Geoff Nettleton
    Indigenous Peoples Links
    United Kingdom
  49. Andrzej Gula
    Institute for Environmental Tax Reform
    Poland
  50. Nadia Martinez
    Institute for Policy Studies Sustainable Energy and Economy Network
    United States
  51. Anyakwee Nsirimoivu
    Institute Of Human Rights And Humanitarian Law
    Nigeria
  52. Peter Bosshard
    International Rivers Network
    United States
  53. Yuki Tanabe
    Japan Center for a Sustainable Environment and Society (JACSES)
    Japan
  54. Richard Harkinson
    Minewatch
    United Kingdom
  55. Catherine Coumans
    MiningWatch Canada
    Canada
  56. Tony Tweedale
    Montana Coalition for Health, Environmental & Economic Rights (CHEER)
    United States
  57. Yury Urbansky
    National Ecological Center of Ukraine
    Ukraine
  58. David Monk
    Oregon Toxics Alliance
    United States
  59. Keith Slack
    Oxfam America
    United States
  60. Ania Roggenbuck
    Polish Green Net
    Poland
  61. Jan Cappelle
    Proyecto Gato
    Belgium
  62. Wenonah Hauter
    Food, Energy and Water Program
    Public Citizen
    United States
  63. Oscar Rivas
    Sobrevivencia/Friends of the Earth- Paraguay
    Paraguay
  64. Himanshu Thakkar
    South Asia Network on Dams, Rivers & People
    India
  65. Ionut Apostol
    TERRA Mileniul III
    Romania
  66. Nicholas Hildyard
    The Corner House
    United Kingdom
  67. Sergey Solyanik
    The Ecological Society Green Salvation
    Republic of Kazakhstan
  68. Simon Burall
    The One World Trust
    United Kingdom
  69. Fernando Melo
    Transparecia
    Mexico
  70. Rev. Douglas B. Hunt
    United Church of Christ Network for Environmental and Economic Responsibility
    United States
  71. Knud Všcking
    Urgewald e.V.
    Germany
  72. Alda Ozola
    VAK/Friends of the Earth-Latvia
    Latvia
  73. Nur Hidayati
    WALHI/Friends of the Earth-Indonesia
    Indonesia
  74. Daniel Owusu-Koranteng
    Wassa Association of Communities Affected by Mining (WACAM)
    Ghana
  75. Paul Orum
    Working Group on Community Right-to-Know
    United States
  76. Andrea Ploeger
    World Economy, Ecology and Development (WEED)
    Germany
  77. Ivailo Hlebarov
    Za Zemiata
    Bulgaria