World Bank Proposal Said to Undercut Access Policy
Date: 14 October 2011
A World Bank proposal to revamp a substantial portion of its lending program would circumvent existing transparency requirements, among other things, according to critics.
The disclosure implications of the so-called Program for Results (P4R) are negative, according to civil society group comment letters.
The proposed policy “leaves the public uninformed about how funds are being expended, and how risks are being managed,” according to a letter from one consortium of groups, including the Friends of the Earth, the Sierra Club, the Center for International Environmental Law and 14 other U.S. and international organizations.
The Bank Information Center, a Washington-based NGO, wrote separately that “the transparency commitments under P4R, which are not clear at all,” would result in less timely disclosure of documents about proposed projects. BIC also signed the group comment letter.
The proposed policy does not reduce transparency by amending the 2010 Access to Information policy, but rather by excluding the new loan system its coverage.
The P4R proposal would allow Bank funding without requiring application of the Bank’s environmental and social safeguard policies. The Bank would approve a “program” for a recipient country, not specific projects. The overall goal is to expand the influence of the Bank safeguard policies to more government programs, rather than have the conditions apply only to specific projects. This thesis is also hotly debated during an ongoing consultation period.
Transparency Consequences Seen
One casualty of the proposal, critics say, will be transparency
The proposed program will be covered by the Bank access policy, but by its terms the Bank does not provide access to financial information related to the individual transactions under the umbrella of broad loans and trust funds.
“P4R, therefore, does not include a requirement to provide the public or local communities with important information about how funds are being used within the Program,” according to the group comment. The letter stated further:
No requirement exists to ensure that the public and communities know when or where a project is being implemented or even what its potential impacts are. As a result, communities and the public will not be aware of how risks are being managed for projects within the Program.
The letter also noted that assessments also would be done at the program level, possibly “still leaving the public in the dark on potential impacts of specific projects.”
A closer examination is provided by BIC’s Vince McElhinny, who wrote that “greater clarity” is needed on what P4R disclosures will look like.
McElhinney said it appears that various early stage documents typically disclosed for projects would not be released under P4R.
Also, he said, documents about P4R lending might qualify to be released just in advance of the board meeting at which they would be considered, but noted that the affected country has the right to block such “simultaneous disclosure.”
He recommended, “The proposed P4R program appraisal document, including all DLIs and M&E procedures should be disclosed in a draft well in advance of Board approval along with any proposed capacity building measures to assess the quality and ambition.”