Long-awaited ESF Guidance Notes fail to meet CSO expectations

6 December 2017

After waiting nearly 15 months for the release of the World Bank’s draft Guidance Notes for Borrowers, civil society organisations (CSOs) reacted with disappointment in a December letter signed by 29 CSOs, including Inclusive Development International and the Egyptian Initiative for Personal Rights, to what many felt were documents unfit for purpose.

The Guidance Notes (GNs) are meant to facilitate the implementation of the Bank’s Environmental and Social Framework (ESF) safeguards for development project lending approved in August 2016, by providing borrowers with tools across the ten core ESF standards. The notes were released for public comment on 2 November, with a closing date for comments of 15 December.

The joint letter, sent to Manuela Ferro, the World Bank Group’s vice president of operations policy and country services, underlined civil society’s dissatisfaction with the draft notes, expressing “deep concerns.” It noted that, “Throughout the safeguards review process, civil society … [was] assured that the Guidance Notes would reflect pressing questions and concerns about the ESF.” It went on, “While a small number of the draft Notes refer to resources and recommendations on certain issues, we feel the great majority of the objectives for the Notes are not achieved in these drafts.”

Despite the GNs being a vital feature of the Bank’s newfound ESF – which will increasingly rely on borrower systems (see Observer Autumn 2016) – they are not policy, and thus do not have to be approved by the World Bank’s board. It is unclear the extent to which feedback received during the current public comment phase will be integrated into the final versions of the notes  – which are due for release in early 2018 – as the Bank has previously declined to make them available for a full public consultation.