e.schnake assignment _final_

8/7/2019 E.Schnake Assignment _final_

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Essay topic 2: The growth of accountability mechanisms in

international financial institutions: practical experiences of the

World Bank, the International Finance Corporation and the

InterAmerican Development Bank

Course:LawandEconomicDevelopment(LAWS6928)

Professor:SureshNanwani

Student:ErichSchnake(ID309330033)

Essaywordcount:7970(body):1146(footnotes)

1 INTRODUCTIONSince 1990 there has been an increasing growth of accountability mechanisms in international

organisations, particularly with respect to activities undertaken by International Financial

Institutions (IFIs). Such mechanisms have been adopted mainly as a result of civil society

pressures, which in light of nondesirable impacts of projects financed the IFIs have questioned

the effectiveness of these institutions in the achievement of their goals and the fulfilment of

their own internal policies. In particular, concerns were raised in relation to the impact of

projects on the environment, involuntary resettlements, and indigenous people.

IFIs have always been formally accountable to their member governments, yet since the 1980s

Civil Society Organisations (CSOs) have proposed that IFIs should also be accountable with

regard to the impacts that IFIs financed projects had on people. These claims were somehow

originated by the shift in development models towards sustainable development. While the IFIs

started at the beginning of the nineties to introduce policies in relation to involuntary

resettlement, environment and indigenous people; CSOs, in light of the environmental effects of

the IFIs financed projects, started to advocate for the introduction of accountability

mechanisms that allowed affected people to complain to the IFIs for the effects of such projects,

which were not giving compliance to IFIs own sustainable policies.

The first IFI to introduce in its organisation an accountability mechanism was the World Bank

(WB)1 in 1993. The WB introduced in its structure the Independent Panel (the WBIP), as a

result of pressures coming both form the internal and external sources. Afterwards, other IFIs

have created their own accountability mechanisms, so far, the InterAmerican Development

Bank in 1994, the Asian Development Bank in 1995, the European Bank for Reconstruction and

Development in 2003, and finally the African Development Bank in 2003. Also, the International

Financial Corporation and the Multilateral Investment Guarantee Agency, World Bank Group

1ReferencestotheWorldBankcomprehendtheInternationalDevelopment Agency(IDA)andtheInternationalBankforReconstruction

andDevelopment(IBRD).


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(WBG) institutions that deal with private operations, created their own accountability

mechanism in 1999.

The role undertaken by IFIs is key in the development of states, particularly developing states.

However, the so called culture of approval, which refers to the incentives of IFIs staff members

to move large amounts of money to finance projects, has passed its toll. The approval of loansand grants in order to achieve their lending targets, but without regard to the projects social

and environmental impacts, has provoked the reaction of civil society movements in order to

make them accountable for the nondesirable outcomes of the financed projects. In some cases,

the approval of projects was been given even in contravention of IFIs own internal policies. 2

OriginsofIFIsAccountabilityMechanisms

The origins of IFIs accountability mechanisms are closely attached to the growth of citizen

engagement at international level, particularly in the development and direction of

supranational organisations. The shift in the perception of the nationstate from the traditionalsacred concept as supreme institution, which for 300 years sealed the option of citizens to look

for remedies to their problems beyond their national states, towards the recognition of

supranational principles to which regard states were subject, opened a gate to look for remedies

in the international sphere in relation to state actions that attempted against citizens rights.3

The Universal Declaration of Human Rights was the first and main example of the enactment of

supranational principles. Although the declaration lacked of the adequate instruments for the

enforcement of humans rights, it encouraged the appearance at the international level of civil

society organisations (CSOs) that advocated for the respect and expansion of such rights,

exercising long term pressure towards the development of the omitted accountability

mechanisms on human rights. The outcome of that activism at regional level is best reflected in

the creation of the European and InterAmerican courts/commissions for human rights. 4

Subsequently international pressure led national governments to allow, though in a limited

scope, citizen access to these supranational entities.5

A second example of the development of supranational principles is constituted by the

worldwide engagement with the notion of sustainable development, which reflected an

increasing interest of people on environmental matters. It was this second wave which had a

major impact in the activities developed by IFIs, as it will be shown.

Even though it is possible to trace back the discussion of environmental issues to the late XIXcentury, it is probably since the United Nations Stockholm meeting in 1972 when environmental

matters became an issue worldwide, ending up in the development international of the

environmental principles, and the creation of civil society organisations (CSOs) and

international organizations dedicated to the protection and conservation of the environment.

2DanaClark.UnderstandingtheWorldBankInspectionPanelinDemandingAccountability:CivilSocietyClaimsandtheWorldBank

InspectionPanel(Clarketaleds;Rowman&LittlefieldPublishers,2003),p6.(Clark(2003))

3RichardBissel.LearningProcessesinInternationalAccountabilityMechanismsinThePublicSectorInnovationJournal(2005),volume10,

p1.(Bissel(2005))

4Ibid.

5Ibid.


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Although not directly related, the noticeable proximity of the Stockholm convention to the

events of 1969 provides a reasonable explanation of its large impact in the world. As Richard

Bissell points out [p]erhaps itcouldhavebeenanticipated thattherisingconsciousnessofthe

earth as a single ecosphere would have been a stimulant for such activism. The image of this

planet,takenbypeopleorbitingtheglobeinspacecraft,transformedthementalunderstandingof

manycitizensfocussedonlyontheirowncommunityandcountry.6

However, projects financed by the IFIs had no particular consideration to their environmental

consequences. The traditional notion of development, which informed and directed the actions

of the IFIs, was understood in purely economic terms, and its application showed to clash with

the interests of environmental activists. This situation led activists to focus on IFIs activities in

order to change their practices.

The result of combining both interests led to the creation of the concept of sustainable

development. One of the first times that the term sustainable development was held publicly

was in 1980 in the World Conservation Strategy, a document of the International Union forConservation of Nature and Natural Resources (IUCN), where it was defined as theintegration

ofconservationanddevelopmenttoensurethatthemodificationstotheplanetdoindeedsecure

the survival and well being of all people.7 However, it was in the first report of the World

Commission on Environmental and Development (WCED), 8 called OurCommonFuture,From

OneEarthtoOneWorld (1987), where the concept of sustainable development was defined as it

is known today: sustainabledevelopmentseekstomeettheneedsandaspirationsofthepresent

withoutcompromisingtheabilitytomeetthoseofthefuture.9

As a response to the critics most of the IFIs incorporated the idea of sustainable development,

and adopted important safeguards policies and procedures. In particular, the World Bank (WB)adopted safeguards policies and procedures related to involuntary resettlement (1980), tribal

peoples (1982), and environmental assessment (1988).10 But, although the adoption of these

safeguard policies was highly valuable, no mechanisms were created to protest or complaint

against the IFIs for not complying with their own policies and procedures.

IFIsImmunity

Commonly international organizations lack of internal appropriate instruments where people

can recur to challenge their decisions, and look for remedy regarding the damages caused by

their actions. In the absence of internal remedy mechanisms, affected individuals have only the

chance to look for remedy before the local courts where the international organization is

located or where the alleged violation has taken place. 11 However, international organisations

6Bissel(2005),p1.

7IUCN(1980)ascitedbyDanielBarstowMagrawandLisaD.Hawke.SustainableDevelopment inDanielBodansky,JuttaBrunneeand

EllenHey(ed),TheOxfordHandbookofInternationalEnvironmentalLaw(2007),615.(MagrawandHawke(2007))

8AsitappearsintheUnitedNationsGeneralAssembly(UNGA)Resolution,theWCEDwasestablishedin1983tothepurposeofdevising

longtermenvironmentalstrategiesforachievingsustainabledevelopmenttotheyear200andbeyond.UNGAResolution38/161,1983,

[8].

9WCED.OurCommonFuture,FromOneEarthtoOneWorld(1987),Ch1,[49].

10WB.TheInspectionPanelat15Years(2009),p3.

11GerhardThallinger.PiercingJurisdictionalImmunity:ThePossibleroleofDomesticCourtsinEnhancingWorldsBankAccountabilityin

theViennaOnlineJournalonInternationalConstitutionalLaw(2008),vol1,p5.(Thallinger(2008))


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often rely in their jurisdiction immunity so as to avoid being challenged in their decisions in the

national forum of a member, including the host state, and perform and undertake their tasks

independently from their member states and free from pressures.12

The recognition by the IFIs of the idea that development was to be sustainable, in terms of

environment protection, was nothing but empty words for environmental activists when inpractice their activities did not accomplish their own safeguard policies on the matter, and there

were no institutional mechanisms to complain about such contraventions. The barrier placed by

the immunity of international organisations, led activists to push for a reform of the IFIs in

order to incorporate internal mechanism through which affected people by their decisions could

complain.

This essay aims to show how accountability mechanisms of IFIs have grow and develop as a

consequence of the civil society pressures in light of the experience of the World Bank, the

International Financial Corporation, and the InterAmerican Development Bank. For each of

these institutions we will review a case where the action of the IFIs has been considered to be incontravention of their own policies, motivating the action of the civil society, which have led IFIs

to the adoption of their current internal review mechanisms.

12Thallinger(2008),p5.


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2 THEWORLDBANKThe experience of the World Bank (WB) is significant not only because it gives the perfect

example of how internal and external pressures combined towards the creation of an internal

review mechanism, known as the Inspection Panel (WBIP), but also because it was the first

independent entity entitled to hear and investigate complaints from affected individuals,

establishing a precedent that was followed by other IFIs.

The chain of facts that led to the creation of the WBIP can be traced back to 1985, when the WB

gave its approval of financial support for building the Sardar Sarovar Dam (SSD). 13 Such

approval was, at the eyes of the opponents of the project, given in transgression to the WBs

own policies and procedures regarding environmental assessment and involuntary

resettlement.14 For this reason they believed that the WB had to be made accountable for its

consequences. In light of the situation, the WB President commissioned an independent

investigation on the matter to Bradford Morse and Thomas Berger, whose results confirmed the

accusations. The outcome of that report combined with the results of another investigation (theWapenhans report) regarding the performance of the WB, led to the idea that the WB needed a

reform, and finally, under internal pressures from donors and member countries, the Inspection

Panel was created.

TheNarmadaCampaign

The Narmada River is one of the most sacred rivers in India. It has a total length of 1312km,

measured from its origins at the Maikal ranges at Amarkantak, 1057 metres above the sealevel,

until it joins the Arabian Sea. The Narmada is part of Indias history and heritage, and has

supported an enormous variety of people and diverse sociocultural practices.

Since the beginning of the XX century there have been plans of flooding the Narmada for the

building of dams. Nevertheless, it was not until 1965 when those plans became feasible, though

disputes among the riparian states (Madhya Pradesh, Gujarat and Maharashtra) regarding the

sharing of the costs and benefits of the project delayed the activation of the projects until the

1980s. 15 Towards the late 1980s appeared the Narmada Valley Development Plan (NVDP),

which contemplated the construction of 30 big dams, 135 medium dams and 3000 small dams.16

In 1985, the WB gave its approval for financial support for building the Sardar Sarovar Dam

(SSD),17 which having a proposed height of 136.5 meters constitutes the largest and the most

important dam of the NVDP. The construction of the SSD was supported by the Indian

Government, which asserted that its development would irrigate over 1.8 million hectares and

extinguish the thirst of drought prone areas of Kutch and Saurashtra in Gujarat. 18 However,

there was a strong movement against the SSD, as its development would displace over 320,000

13Clark(2003),p3.

14Ibid.

15FriendsofRiverNarmada.Weblinktohttp://www.narmada.org/introduction.htmlreviewedonSeptember20

th,2010.

16Ibid.

17Clark(2003),p3.

18FriendsofRiverNarmada.Weblinktohttp://www.narmada.org/sardarsarovar.htmlreviewedonSeptember20

th,2010.


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people and affect the livelihood of around 1 million people.19 In general, the opponents believed

that the NVDP planning was unjust and iniquitous, servicing only for the interest of a small

group of people constituted by the developers, and that the purported benefits had no

comparison with its destructive effects on the river ecosystem and on the people whose

subsistence and living depended on the river.20 Moreover, they question the effectiveness of the

resettlement policies undertaken by the Indian government, which they claim have never

provided neither just compensations nor rehabilitation.21

The support given by the WB to the construction of the SSD was looked by the opponents as a

crucial factor that pushed the project forward without considering its social and environmental

impacts. 22 Most importantly, such approval was considered to be given in transgression to the

WBs own policies and procedures regarding environmental assessment and involuntary

resettlement, providing the reason for the belief that the WB had to be made accountable for the

consequences of its action. 23

Opponents to the NVDP, and particularly to the SSD, found broad support to their complaints inEurope, Japan and North America, particularly regarding the need that the WB made a

comprehensive review of the SSD project. In 1991 the WB President, Barber Conable,

commissioned and independent review of the project on Bradford Morse and Thomas Berger,

an independent team that became known as the Morse Commission. 24 This was the first time

that the WB accepted to submit one of its projects to the revision of an independent

commission. In June 1992, the Morse Commission delivered its report, which concluded that the

WB had not adequately considered the social and environmental impacts of the SSD project, and

that resettlement and rehabilitation of displaced people was not feasible under the present

circumstances.25 In particular the report referred to the WBs failure to comply with its own

safeguard policies regarding involuntary resettlement, environmental assessment, andindigenous people, and recommended to step back as the failures of the project could not be

overcome by patchwork studies.26 However, the WB response was not to step back, but rather

to continue forward with an alternative plan for the next six months. After such period, as the

new conditions established by the WB were not met and it became clear that the WB would

have to withdraw its support to the project, the Indian government announced its cancelation. 27

TheCultureofApproval

In light of the Morse Commission report and continuing concerns, from both within and outside

the Bank, in 1992 the then President of the WB, Lewis Preston, decided to entrust on Vice

19FriendsofRiverNarmada.Weblinktohttp://www.narmada.org/sardarsarovar.htmlreviewedonSeptember20

th,2010.

20FriendsofRiverNarmada.Weblinktohttp://www.narmada.org/introduction.htmlreviewedonSeptember20

th,2010.

21Ibid.

22Clark(2003),p3.

23Ibid.


25Clark(2003),p4.

26Ibid.

27Ibid,p5.


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President Willi Wapenhans an internal investigation to review the WB internal operations. The

internal report (the Wapenhans report) was completed in November 1992, and reached to the

conclusion that the WB had developed a culture of approval that reflected a promotion

incentives structure that encouraged staff to move financing to as many projects as possible

without regard to the potential impacts or effectiveness of its implementation. 28 The culture of

approval was the consequence of the banks policies that rewarded the staff for moving large

amounts of money out of the door and putted pressure to meet yearend targets. 29 This

situation, according to the report, had led the WB to poor project design and outcomes,

misinterpretation of the local priorities and needs of the borrowing countries, and deficiencies

in the implementation of the WBs own safeguard policies. 30 The report concluded that the WB

was going through a performance crisis with a 37.5% of the project completed in 1991

evaluated as failures, up from 15% in 1981, and 30.5% in 1990.31 Furthermore, the report found

out extensive contraventions of borrowers to the WBs loan agreements. 32

TheRioEarthSummit1993

The Earth Summit in Rio was held in 1992 principally stressing that world development was to

be achieved under a new ethical perspective that recalled on environment protection and

acceptance of the indigenous peoples culture. The Rio Summit was in large a response to the

1987 Brundtland Commission Report, Our Common Future (UN 1987), which gathered the

essential elements of this new perspective and called for a new way of development under the

notion of sustainable development. As well, the Summit made a strong call to increase the

participation by civil society in international law and policy decisions, reflecting an evolution in

international law towards a more participatory approach where affected citizens and people are

empowered to participate as actors at the international stage.33

At the time the WB was under internal and external pressures that called upon the need to

reform its internal policies so as to reflect the new perspective of sustainable development. The

Morse Commission report was delivered in June 1992, the same month of the Rio Summit, and

Wapenhans investigation was being undertaken at the time. Moreover, activists against the SSD

project were still campaigning. It is clear then, that the whole world was expecting the WB to

take some measures in line with the new ideals, and this pressure went further than just

wanting the WB to make some nice declarations, this pressure wanted measures effectively

implemented in line with sustainable development.

TheCreationofanAccountabilityMechanism

The World Bank Inspection Panel (WBIP) emerged as a consequence of the WBs own

experience and a particular world context that claimed for more participation of the civil society


29Clark(2003),p56.


31EisukeSuzuki&SureshNanwani.ResponsibilityofInternationalOrganizations:theAccountabilityMechanismsofMultilateral

DevelopmentBanksintheMichiganJournalofInternationalLaw(2005),vol27,p186.(SuzukiandNanwani(2005))

32Clark(2003),p5.



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in the international sphere decision making processes. The Morse Commission and the

Wapenhans reports, both delivered in 1992, added to the Rio Declaration led to the conclusion

that the WB needed to be reformed in order to respond to the worlds new commitment to

sustainable development. Nevertheless, a final push was needed for the creation of the WB

inspection panel.

In the beginning of 1993 the idea of reforming the WB, so as to improve its transparency and

accountability, gained support from the Congressman Barney Frank, who in the International

Development Agency (IDA) replenishment held in May of 1993 sent a clear message to the WB

administration that the United States of America would be willing to withhold funds if there was

no institutional reform.34 As well in February of 1993, the Executive Directors o four countries 35

circulated a proposal for the creation of an accountability mechanism, consistent in the creation

of an independent evaluation unit to asses the projects of the WB, so as to avoid situations as

the generated by the Narmada project.36

Finally, the WBIP was officially created the 1st of September of 1993 by two resolutions ofidentical content one of the International Bank for Reconstruction and Development (IBRD),

and other of the IDA.37 However, the resolutions specify that the Inspection Panel has only

jurisdiction regarding operations of the IBRD and the IDA, leaving aside the International

Finance Corporation, the Multilateral Investment Guarantee Agency, and the International

Monetary Fund.

TheWorldBankInspectionPanel(WBIP)

The WBIP is composed by three permanent members from different nationalities of the states

members,38 which are nominated by the President of the WBG and appointed by the Board.39

Member of the WBIP are appointed for 5 years nonrenewable terms, and after this period they

cannot be employed by the WBG.40

The panel investigates complaints filled by two or more people living in a country affected by a

WB financed project, local representatives, or the Board of Executive Directors. In some special

circumstances non local NGO are allowed to present claims on behalf of local people, provided

their authorization, and in case of serious alleged violation a single Executive Director.41 After

the claim is presented the Panel has to establish its eligibility, which means that the claim: (i)

has been presented by an adequate requester (ii) alleges of the violation of a WB policy that has

34Clark(2003),p78.

35TheNetherlands,Germany,MalaysiaandChile.

36DavidHunter,CristianOpasoandMarcosOrellana.TheBiobiosLegacy:InstitutionalReformsandUnfulfilledPromisesatthe

InternationalFinanceCorporationinDemandingAccountability:CivilSocietyClaimsandtheWorldBankInspectionPanel(Clarketaleds;

Rowman&LittlefieldPublishers,2003),p116.(Hunter(2003))


38RichardE.BissellandSureshNanwani.MultilateralDevelopment BankAccountabilityMechanisms:DevelopmentsandChanges(2009)

in3(2)CentralEuropeanJournalofInternationalSecurityStudies,p161.(BisselandNanwani(2009))

39Clark(2003),p10.

40BisselandNanwani(2009),p161.

41DanaL.Clark.ACitizensguidetotheWorldBankInspectionPanel(CIEL,2

nded,1999),p10.(Clark(1999))


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caused or is likely to cause a material adverse impact; (iii) the claimants have previously

attempted to raise their concerns with the WB management and have not been listened; (iv)

refers to a financed project of the WB (or under its consideration) before 95% of the funds have

been disbursed. 42

Once the claim has been deemed eligible, the Panel sends a copy of the complaint to thePresident of the WB acting in representation of the WBs management. The management has 21

business days to respond to the claim by disputing the alleged violations or acknowledging

them. 43 After the management answer, the Panel has to determine whether the claim shall be

subject or not for a full investigation, however, the Panel is not allowed to proceed before it has

obtained the approval of the Board of Executive Directors. 44

The Panels findings in an investigation are only advisory to the Board, which will have to decide

how to deal with them.45 One common alternative seems to be the preparation of action plans

in order to improve compliance of the WBs policies, both by the management and the

borrower.46 Yet such action plans are not covered under the scope of the WBIP, therefore, theWBIP is not allowed to monitor its implementation.47

In general, the functioning of the WBIP has been criticized for being highly susceptive to

political pressures of the WB members. In particular, the attribution of the Board to decide

whether to proceed with the investigation of a claim after the Panel has considered to be subject

to a full investigations, has been criticized for introducing a political factor in the procedure by

allowing the country where the project takes place to oppose to the investigation. 48 In addition,

it has been noticed that the Board has no deadlines to grant such authorization, which has

undermined the effectiveness of the mechanism. Moreover, it is possible to alert that there is no

real independence of the Panel as its reports to the WBs Executive Board, and it has only anadvisory role. Finally, the lack or limited functions to ensure compliance by monitoring the

implementation of the action plans hinders significantly the effectiveness of the mechanism.

42Clark(1999),P10.

43Ibid,p12.

44Clark(1999),p13.

45Ibid,p17.

46Ibid,p17.

47WB.1999ClarificationoftheBoard'sSecondReviewoftheInspectionPanel,para[15].

48Clark(1999),p14.


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3 THEINTERNATIONAL FINANCIALCORPORATIONThe International Finance Corporation (IFC) and the Multilateral Investment Guarantee Agency

(MIGA) are both part of the World Bank Group (WBG), yet as it was mentioned in the previous

section they were excluded from the jurisdiction of the WBIP.

There are no given reasons that explain why these institutions were excluded from the

compliance review mechanism of the WB. It seems that the fact that IFC and the MIGA were

focussed on the private sector, led the WB to believe that it was in the interest of no country to

establishment such mechanism, and therefore there was no need for its creation. However, the

WBIP is a mechanism that responds to the interests of local people and communities affected by

the WB projects, rather than the interest of the countries were projects are being undertaken.

Thus, it was reasonable to expect the reaction from the civil society in order to make the IFC and

the MIGA accountable. This reaction came about in the early nineties in Chile, when several

CSOs opposed to the development financed by the IFC of a hydroelectric dam in the Boboriver.

ThePangue/RalcoDamProject

The Bobo river is located in the boundary

of the LibertadorBernardoOHiggins Region

and the Araucania Region, in an area that

has been traditionally inhabited by the

Mapuches indigenous people. The Bobo is

probably the most important river in Chile,

being the second largest, and having the

widest river basin.

The Pangue/Ralco Dam Project (PDP) was

an initiative of the National Company of

Electricity Incorporated (ENDESA for its

initials in Spanish) that purposed the

construction of several dams for the generation of hydroelectric power in the upper basin of the

Bobo river. The development of the PDP implied the relocation of several indigenous

communities, the Pehuenche people (a branch of the Mapuches), which inhabited the area. 49 In

addition, it was asserted that the damming of the river would negatively impact theenvironment of the region by depriving downstreamecosystemsofthecriticalorganicnutrients,

[exacerbating]downstreampollutionproblems,[increasing]theerosionfromreleasedwaters,and

[reducing]thenutrientdepositsintheAraucoGulf,oneofChilesrichestfishingareas.50

The idea of damming the area for the construction of hydroelectric plants was first suggested by

ENDESA in 1985, and immediately several CSOs alerted about the involved impacts for the

environment and the Pehuenche people living in the area.51 However, because of its national

49Hunter(2003),p116.

50Ibid,p117.

51Ibid,p118.


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importance the project was probably to be carried out anyway, 52 yet what was really

surprising was that in 1992 the IFC approved a loan for the development despite being aware of

the disastrous impacts of the initiative.53

In 1995, the local CSO GrupodeAccinporelBio bio (GABB) lodged a formal claim before the

WBIP, asserting the violation of eight IFC and WBG policies, and the noncompliance by ENDESAof several grant conditions.54 As it was expected the claim was rejected because of the lack of

jurisdiction of the WBIP,55 but in 1996 the President of the WBG James D. Wolfensohn

authorized an impartial internal review of the environmental and social implications of the

project in order to establish if environmental and social covenants agreed between the IFC and

EDESA were violated.56

The independent review was entrusted to Jay Hair, President Emeritus of the IUCN, who

submitted his report on 1997.57 The report established how WB policies where violated by the

IFC management, and how the IFC staff in several occasions withheld information from the

IFC Board of Directors.

The whole process exposed the necessity of an accountability mechanism for the IFC and the

MIGA. It was demonstrated that not only projects supported by the WBG public sector lending

institutions were likely to have negative social and environmental impacts, but also projects

supported by the private sector lending arms. In the early 1996 the WBG Board committed the

IFC and the MIGA the study of an inspection mechanism to be applied to their operations.58 After

several proposals and consultations,59 in 1999 the Compliance Advisor/Ombudsman Office was

created.60

TheComplianceAdvisor/OmbudsmanOffice(CAO)

One of the principal missions of the IFC and the MIGA is to deliversustainabledevelopment

throughtheprivatesector.61 In order to achieve such sustainable development, and ensure that

social and environmental purposes are addressed, the IFC and the MIGA created the CAO, which

52Theoriginalprojectcontemplatedtheconstructionofsixhydroelectricpowergeneratorswithatotalpowerof2695MW,whichatthe

timewasaboutathirdofthetotalgeneratedenergy.RobinsonScott.ElProyectoHidroelctricoPangue,RoBoBo,Chileysu

importanciaparaelfuturodelasobrasdeinfraestructura[ThePangueHydroelectricProject BioBioRiver,Chile anditsImportancefor

theFutureoftheInfraestructureOuvres](1992),in2(4)RevistaAlteridadesdelaUniversidadAutnomaMetropolitana[Alteridades

JournaloftheMetropolitanAutonomousUniversity],p86.

53BarbaraRoseJohnstonandCarmenGarcaDowning.HydroelectricDevelopmentontheBoBoRiver,Chile:AnthropologyandHuman

RightsAdvocacyintheInTheWayofDevelopment(2004)(digitaleditionofTheInternationalDevelopment ResearchCentre,Canada),ch

13,p16.(JohnstonandGarcaDowning(2004)).

54Hunter(2003),p127.

55BisselandNanwani(2009),p165.

56IFC,TermsofReference:IndependentAdvisorforInternalReviewofPangueProject(1996),ascitedbyHunter(2003),p128.

57JohnstonandGarcaDowning(2004),p16.

58Hunter(2003),p135.

59CIEL.Linktohttp://www.ciel.org/Ifi/ifc.html.ReviewedonOctober6

th,2010.

60CIEL.Linktohttp://www.ciel.org/Ifi/ifcdes.html.ReviewedonOctober6

th,2010.

61CAOTermsofReference,Background.


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is an independent review mechanism that deals with complaints presented by people affected

by projects financed or insured by such institutions.62 So far 2009, CAO received 110 complaints

of which 67 have fulfilled the eligibility requirements,63 which can give us an idea of the

operability of the mechanism if we compare it to other mechanisms as the IIM, which in its

entire life reviewed only 5 complaints, and 69 cases of the WBIP, 64 which was instituted almost

7 years before the CAO.

The CAO is completely independent from the IFC/MIGA management. The Ombudsman has the

same hierarchy as the Executive VicePresident of the IFC and the MIGA, and its directly

appointed by the WBG President for a period between three and five years (renewable by

mutual consent), to whom it directly reports.65 In addition, to accomplish its mission the CAO

has an autonomous budget from the IFC/MIGA that determined directly by the WBG

President.66

The CAO has three roles: ombudsman, compliance, and advisory.

The Ombudsmans role is to respond and deal, using a flexible problemsolving approach, with

complaints raised by individuals, groups, or organizations affected by IFC/MIGA projects.67

Complaints may relate to any aspect of the planning, implementation or impact of a financed or

insured project by the IFC or the MIGA. The grounds on which complaints can be brought to the

Ombudsman are defined in ample terms in order to encourage thosewithconcernsabouta

projecttoseekredress.68 Under this logic it is also established that complaints can be lodged in

any language, by post mail, fax or email, with the only restriction that they have to be submitted

in writing.69 However, not every complaint is eligible for an assessment. The Ombudsman may

discard those complaints that do not relate to a project where the IFC/MIGA is participating or

is considering to participate, those that do not refer to environmental and social aspects, orthose clearly maliciousortrivialorthathavebeengeneratedtogaincompetitiveadvantage.70

Once a complaint has been deemed eligible, the Ombudsman directs the assessment of the

complaint, which aims to clarify the issues and concerns raised by the complainant in order to

find an adequate solution. The assessment may involve reviewing IFC/MIGA files, having

meetings with any stakeholder of the involved project, and visiting the project site, among

others.71 In case the stakeholder reached an agreement the Ombudsman will monitor and

62CAOOperationalGuidelines,Mission.

63CAO20089AnnualReport,p4.

64WBwebpage.Linkto

http://web.worldbank.org/WBSITE/EXTERNAL/EXTINSPECTIONPANEL/0,,contentMDK:20221606~menuPK:64129250~pagePK:64129751~pi

PK:64128378~theSitePK:380794,00.html.ReviewedonOctober6th,2010.

65CAOTermsofReference,Organization.

66Ibid.

67CAOOperationalGuidelines,section1.2.

68Ibid,section2.2.1.



71CAOOperationalGuidelines,section2.3.3.


13/22

followup the implementation of such agreements.72 On the other hand, if the stakeholders are

unable to reach an agreement, the Ombudsman will transfer the complaint to CAO Compliance

for appraisal. 73

The Compliance role refers to the power to supervise audits of the social and environmental

performance of the IFC and MIGA in relation to their financed or insured projects, so as toensure its compliance with their own policies, standards, guidelines, procedures, and

conditions.74 Compliance audits may be initiated: (i) by a request of a senior management of the

IFC, the MIGA, or the President of the WBG; (ii) by a complaint transferred by the Ombudsman;

or (iii) at the discretion of the CAO Vice President.75

Before carrying out a compliance audit, an appraisal shall take place in order to ensure that

compliance audits are initiated only for those projects that raise substantial concerns in relation

to environmental and social matters.76 If the CAO decides to carry out a compliance audit, it shall

first prepare a terms of reference document to be submitted to the IFC/MIGA management,

indicating the objectives and scope of the audit, and containing a schedule of the audit taskswith the time frames and reporting requirements.77 The findings of the audit in relation to the

compliance or non compliance of the IFC/MIGA with the social and environmental policies,

guidelines and standards, shall be reported. However, the IFC/MIGA senior management will

have the chance to add comments to a draft report before the final document is sent to the WBG

President.78 In case the report identifies that the IFC/MIGA has incurred in non compliance of

environmental and social policies, standards and guidelines, the CAO will keep the audit open

until its assured that the IFC/MIGA will move to compliance.79

Finally, the CAO advisory role is performed by providing advice to the President of the WBG and

the management of the IFC/MIGA in relation to environmental and social policies, guidelines,procedures, and strategic issues, among others, in order to improve their performance.80 In

general, the advisory role will be initiated by request, yet in light of special circumstances it may

be given directly, as for the case o particular concerns that arise during the course of an

investigation of the Ombudsman. 81 Advisory recommendations are monitored, and its

implementation is reported to the WBG President.82 The format of how recommendations are



74Ibid,section3.1.






80

Ibid,

section

1.2.


82CAOOperationalGuidelines,section4.4.3.


14/22

given will vary in attention to the particular circumstances, as they may require for an extensive

document or a simple note.83

The CAO is considered to be one of the most advance accountability mechanisms. It is possible

to highlight the real independence of its functions from the IFC and the MIGA management

ensured by its appointment procedure, and the fact that it reports directly to the WBGPresident. In addition, it draws the attention the fact that the CAO is vested with real

enforcement powers, reflected in its capacity to hold audits open until the IFC and the MIGA

have ensured compliance, and its faculty to monitor the implementation of its advisory

recommendations.



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4 THEINTER AMERICANDEVELOPMENT BANKThe InterAmerican Development Bank (IDB) was the first regional bank in adopting an internal

review mechanism to manage complaints of people affected by the banks projects. In 1994,

during the discussions of the Eighth General Increase in the Resources of the IDB, the Board of

Governors decided to establish an Independent Investigation Mechanism (IIM) in order to

improve the transparency, accountability and effectiveness of the Bank's performance.84

Through this mechanism the IDB committed to investigate allegations made by adversely

affected parties by banks financed operations in violation to its own policies. 85 The IIMs

function was to be performed independently from the management by a panel of investigators

appointed adhoc by the Board of Directors from a roster of 15 investigators.

TheCrisisoftheIIM

The IIM effectiveness as a mechanism to ensure IDBs compliance was questioned from itsbeginnings, mainly because it was asserted that it had no independence from the Board and it

lacked of a permanent budget and staff.86

The main point of concern was that the mechanism did not guarantee affected people access,

critique that takes force when it is noticed that the IIM received only five complaints during its

life almost 18 years, including two investigations of the YHD. The IIM panel was not

permanent, and therefore there was no possibility for people to have contact with them in order

to get information and advice. Also, the mechanism could not be used after 95% of loans were

disbursed.87 In addition, the fact that investigators were not vested with the power of

determining the eligibility of a claim, as complaints had to go through the Executive Board and

the IDBs management before the investigation was to be carried out, 88 undermined the

credibility of the institution as the management had aninherentconflictofinterestwithrespect

topotentialclaims.89 It is reasonable to believe that the expected reaction of the management

towards any complaint that questions its performance will be to deny the need for a panel

investigation. Finally, the investigators were limited only to make factfindings and not to

propose solution or remedies, task that was left to the Executive Board. 90 That situation does

not guarantee that the adequate measures will be undertaken.

Some of these problems can be noticed in the Yacyreta Hydroelectric Dam construction case.

84IDB.PolicyestablishingtheIndependentConsultation andInvestigationMechanism(February17

th,2010),p1.

85Ibid.

86CIEL.BriefCritiquetotheIDBInvestigationMechanism(1996).Linktohttp://www.ciel.org/Ifi/idbpres3.htmlreviewedonSeptember

23rd,2010.

87Carrasco(2009),p5254.

88EnriqueR.Carrascoetal.GovernanceanAccountability: TheRegionalDevelopmentBanks(2009),p52.(Carrasco(2009)).

89

CIEL.BriefCritiquetotheIDBInvestigationMechanism(1996).Linktohttp://www.ciel.org/Ifi/idbpres3.htmlreviewedonSeptember23

rd,2010.

90Carrasco(2009),p5254.


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TheYacyretaHydroelectricDam

The Yacyreta Hydroelectric Dam (YHD) was one of the largest construction projects ever

undertaken in Latin America. The YHD is located in the Parana River between Argentina and

Paraguay, and has 808 metres long and has 20 turbines with a power of 3200 MW. 91 The main

dam is formed by a barrage of materials 66 km long that closes its perimeter, and currentlyfloods at an altitude level of 76mt an approximated area of 1200 km2.92 However, it is projected

that the dam will function at a level of 83mt flooding over 1600km2.93

The YHD construction was funded by the IDB and WB. The project construction originally begun

in 1983 and it was ended in 1996, after countless delays provoked by environmental disputes

and corruption.94

As a consequence of the flooding of the reservoir, the YHD construction was expected to

displace over 50,000 people and affect the living of many other in the areas of Encarnacin

(Paraguay) and Posadas (Argentina).95

However, the project was pushed forward without theadequate public consultation, and a minimal or inexistent compensation or relocation packages

to the affected people.

In September 1996 a group of CSOs, leaded by the Paraguayan grassroots organization

Sobrevivencia, decided to bring the case before the WBIP and the IIM.96 In December of the

same year, a preliminary report of the IP and the IIM stated that the project appeared to be in

breach of the loans conditions, and recommended a full investigation.97 The final report,

delivered in 1997, confirmed the accusations regarding that the programs of the project on

participation, resettlement compensation, and environmental mitigation were insufficient to

meet the agreed conditions of the loan.98 Yet, no solutions were adopted, as political differences

between representatives of Northern and Southern countries put the decision on hold.99

However, CSOs representatives pressure had some effect. The IDB acknowledged the

importance of CSOs, and took some steps towards their incorporation in the decision making

process. In 1999 the President of the IDB, Enrique Iglesias, issued a memo establishing that

every country was to appoint a civil society contact that would meet with local organisations

91EntidadBinacionalYacyreta(EBY).Linkto

http://www.eby.gov.py/index.php?option=com_content&view=article&id=59:dtr&catid=37:obras&Itemid=74.ReviewedonOctober3rd

,2010.

92Ibid.

93Ibid.

94BankInformationCenter(BIC).Linktohttp://www.bicusa.org/en/Article.374.aspx.ReviewedonOctober3

rd,2010.

95BIC.Linktohttp://www.bicusa.org/en/Project.22.aspx.ReviewedonOctober3

rd,2010.

96BIC.Linktohttp://www.bicusa.org/en/Article.557.aspx.ReviewedonOctober4

th,2010.

97Ibid.

98

KayTreacle(BIC).TheWorldBankandtheIDBInspectionPanelClaims.Linktohttp://www.bicusa.org/en/Article.375.aspx.ReviewedonOctober4

th,2010.

99BIC.Linktohttp://www.bicusa.org/en/Project.22.aspx.ReviewedonOctober3

rd,2010.


17/22

and answer their information requests, and establishing in each country an Advisory Board

composed of CSOs members to serve as a civil society network. 100

In May of 2002, the CSO Federation of the People of Itapa and Misiones Affected by Yacyret

(FEDAYIM) presented a second claim to the WBIP and the IIM pointing the persistent and

progressive deterioration of the environment and the health conditions in the project area. 101While the WBIP immediately decided to undertake a preliminary assessment, which concluded

in the necessity to carry out a full inspection; the IIM coordinator [a]ftermonthsofsilence(...)

finallyacknowledgedthesecondrequestforreview,onlytodisagreethattheclaimistheresultof

IDBmiss action.102 Finally, in 2003, the IIM acceded to undertake an investigation. The report of

such investigation was delivered in February 2004, establishing that the IDB administration:

hadviolatedmanybankpolicies,principallytheBank'sInvoluntaryResettlementpolicy,andhad

failed to follow proscribed measures for Analyzing Risk of Poverty, Community Participation,

Data Gathering, Indigenous Communities, Difficulties in Transition, Compensation Packages,

Followup and Evaluation, Establishing Legal and Constitutional Frameworks, and Conflict

Resolution, as well as violations of the IDBs Environment policy, in terms of not adequately

addressingurbancreekandgroundwaterpollution.103

Furthermore, the investigation revealed that from a grant of US $130 million given to the EBY104

to mitigate the environmental and social impacts of the project only a third had been spent;

meanwhile poor affected people in the project area were suffering from inadequate sanitary

conditions, unemployment, and little engagement by project officials.105

The YHD case reveals how IDB Executive Board and IDBs management eligibility powers over

complaints hindered the effectiveness and promptness of the IIMs work by delaying the

acknowledgement of the complaints submitted and delaying the determination of its eligibility

to be revised by the IIM. In addition, the fact that a second investigation produced the same

results as the first one, shows us that the existence of a review mechanism does not suffice to

give an appropriate response to affected people, if the results of such review are not taken in

consideration by the management and the borrowers. That situation can be explained by the

IIMs lack of power to make recommendations, and the lack of enforcement mechanism, such as

monitoring the action plans agreed by the management.

TheIndependentConsultationandInvestigationMechanism

Not surprisingly and in light of the unsuccessful experience of the IIM, on February of this year(2010) the mechanism was recently replaced. The new institution is the Independent

Consultation and Investigation Mechanism (ICIM), and its creation can be traced back several

100EncyclopediaofEarth.TheInterAmericanDevelopmentBank.Linktohttp://www.eoearth.org/article/Inter

American_Development_Bank.ReviewedonOctober4th,2010.

101BIC.Linktohttp://www.bicusa.org/en/Project.Concerns.22.aspx.ReviewedonOctober4

th,2010.


th,2010.


th,2010.

104

EBYistheacronymsforEntidadBinacionalYacyret,whichmeansBinationalEntityYacyret,andreferstoinstitutioncreatedbytheYacyretTreatycelebratedbetweenArgentinaandParaguayin1973 thatisinchargeofadministrations oftheprojectimplementation .


th,2010.


18/22

years ago, in which the IDB has been looking to overcome the constant critiques to the IIM

posted by CSOs.

In 2005 the IDB made a proposal to improve its internal review mechanism the IIM by

creating the Consultancy and Compliance Review Mechanism (CCRM). However, in the public

consultation process such proposal was seen by accountability institutions as insufficient. 106

The Centre of International Environmental Law (CIEL) declared that such proposal fellshortof

providingproject affectedpeoplewithaneffectivevoiceat thebankandwasultimatelyshelved

withouteversecuringtheneededreforms.107 In particular, it was asserted that the requirement

that the harm suffered by the claimant was to be a direct consequence of the breach of a Banks

Operational Policy it was not removed, and that the proposed process failed to ensure the

independence of the mechanism from the Board, which had still a big say regarding the

eligibility of the complaints.108

Representatives of several CSOs (National Wildlife Federation, International AccountabilityProject, BIC and CIEL), leaded by David Hunter pointed out that the proposal presented by the

IDB unnecessarily restricted the access to the Mechanism and limited its independence,

undermining the potential that the Mechanism will ever work effectively for its intended

beneficiaries.109 On what refers to affected people access, the following obstacles where

mentioned: (i) the fact that affected persons were to have a special relation with the IDB,

determined by formal communications, in order to be entitled to lodge a claim; (ii) the idea that

only claims based on violations of the IDBs Operational Policies were to be admissible; (iii) the

subsistence of the rule that claims were only admissible before a 95% of a project funding was

disbursed; (iv) the imposition of the requirement that affected people must provide quantifiable

evidence of damage; and (v) the negative to allow the filling of complaints through email offax.110 Regarding the relation of the CCRM and the IDB Board, it was alerted a lack of

independence that was revealed by the power of the Board to elect the CCRM Executive

Secretary, who was the official in charge of reviewing all initial request and determine its

eligibility; and the obligation of the Executive Secretary to report to the IDB Board.111 Finally, it

was mentioned that the proposed mechanism failed to establish an adequate mechanism to

conduct effectivemonitoring ofpromisesor commitmentsmade as a resultofa claim.112 The

Compliance Review Panel, despite its name, was not entitled to monitor the implementation of

106BIC.Linktohttp://www.bicusa.org//en/Issue.20.aspx.ReviewedonOctober4th,2010.

107CIEL.Linktohttp://www.ciel.org/Ifi/IDB_4Apr08.html.ReviewedonOctober4

th,2010.

108CIEL.Linktohttp://www.ciel.org/Ifi/IDB_4Apr08.html.ReviewedonOctober4

th,2010.

109IDB.RecordofComments:PublicConsultationontheDraftConsultationandComplianceReviewMechanismoftheInterAmerican

DevelopmentBank(July,2005),p3.Linkto

http://enet.iadb.org/idbdocswebservices/idbdocsInternet/IADBPublicDoc.aspx?docnum=559818.ReviewedonOctober4th,2010.


DevelopmentBank(July,2005),p45.

111Ibid,p5.

112IIbid,p7.


19/22

the agreements over time, receive public comments, and report to the Board regarding the

progress of implementation.113

After the 2005 public consultation no action was undertaken until 2008, when the IDBs Board

requested the management for the development of an enhancedmechanismthatincorporatethe

lessons from the complaints received as well as lessons learned from the accountability

mechanismsofotherinstitutions.114 The same year, a new review mechanism the Independent

Consultation and Investigation Mechanism (ICIM) was proposed, which after a public

consultation process was approved by the IDBs Board of Executive Directors (the Board) in

February 2010. The ICIM consist of a two phase mechanism: consultation and compliance.

During the consultation phase, which is guided by the Project Ombudsperson, claims are

addressed by negotiations or mediation (section 44). To proceed with the compliance phase it is

required that the consultation phase has ended by any reason, or that the request has been

considered ineligible under the consultation phase (section 53). The compliance review phase

is directed by the Panel, and deals with those requests that reasonable assert that a Bank action

or omission has violated a relevant operational policy of the bank, which has resulted or is likelyto result in a direct material adverse effect to the requester (sections 53 and 56(f)).

In general, the ICIM has incorporated most of the recommendations made by CSOs.

Regarding the access to file a complaint the ICIM: (i) it is not required to mention which policies

are being violated; (ii) eliminates the restriction that claims were only admissible before a 95%

of a project funding was disbursed, and replace it by the restriction that claims have to be filed

before 24 months of the last disbursement (section 37(f)); (iii) affected people do not need to

provide quantifiable evidence of damage, rather the requester only needs to describe in general

terms the harm caused or likely to be caused by a IDB financed operation (sections 40(f) and56(f)); and (iv) it is established that requests can be filed in any format, allowing in this way the

filing of complaints through email or fax (section 31). Nevertheless, there are still some minor

restrictions, as the requirement that therequesterhastaken(previous)stepstobringtheissueto

theattentionofthemanagement (section 40(h)).

In relation to the independence of the ICIM from the IDB Board, some corrections have been

added, though, there are still some issues that may undermine the ICIM function. The Executive

Secretary continues to be appointed by the Board, yet it is no longer in charge of determining

the eligibility of the requests. However, the Ombudsperson and the Panel are also appointed by

the Board. Its independence, though, is ensured in case of the Ombudsperson by the election

procedure, which inasimilarprocesstotheoneusedfortheDirectorofEvaluationandOversight

OfficeoftheIDB (section 74), and in case of the Panel by not allowing the Panels members to

work for the bank inanycapacityforfiveyearsaftertheexpiryofhisorherterm (section 80).

Finally, in the ICIM the Panel is entitled to monitor and follow up any remedial or corrective

action agreed in the compliance review phase, and distribute semiannually reports to the

Board (section 74). However, such functions are subject to the Boards request, which may

undermine the purpose of giving monitoring powers to the Panel.


DevelopmentBank(July,2005),p7.

114IDB.TheIndependentConsultationandInvestigationMechanism.Linktohttp://www.iadb.org/MICI/index.cfm?lang=en&artid=7322 .

ReviewedonOctober4th,2010.


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5 CONCLUSIONThis essay has shown how accountability mechanisms of IFIs have grown and developed as a

consequence of the civil society pressures.

The experience of the World Bank is significant not only because it gives the perfect example of

how internal and external pressures combined towards the creation of an internal review

mechanism, known as the WBIP, but also because it was the first independent entity entitled to

hear and investigate complaints from affected individuals, establishing a precedent that was

followed by other IFIs. There are no given reasons that explain why the IFC and the MIGA were

excluded from the compliance review mechanism. However, again the pressure of civil society

in light of a particular case forced the creation of an adequate accountability mechanism.

Finally, the IDB experience is interesting because it was the first regional bank in adopting an

internal review mechanism. It did so mostly as a response to the creation of the WBIP, and in

order to anticipate problems as Narmada Campaign. However, the implementation of a

mechanism that was under the strong control of the IDBs board and management showed to

fail, as it did not give real solutions to the problems presented in the implementation of projects

financed by the bank. That was clarified in light of the Yacyreta Hydroelectric Dam case. As a

consequence, the IDB had to undertake a revision process of its mechanism that ended in the

creation, early this year (2010) of a new review mechanism, which has incorporated many of

the comments made by civil society organisations.


21/22

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Pictures

Picture 1. Ralco Hydrolectric Dam. Endesa webpagehttp://www.endesa.cl/ralco/pagina.html.

Picture 2. Entidad Binacional Yacyreta webpagehttp://www.eby.gov.py/index.php?option=com_content&view=article&id=93&Itemid=

29.

e.schnake assignment _final_

Documents