The Independent Consultation and Investigation Mechanism (ICIM)
2010 Annual Report
1300 New York Avenue, N.W. Washington, D.C. 20577 Tel: + 1 (202) 623-3952 Fax: + 1 (202) 312-4057 e-mail: mecanismo@iadb.org www.iadb.org/icim
The Independent Consultation and Investigation Mechanism (ICIM) Annual Report 2010
The mission of the ICIM is to respond to the concerns of citizens and communities about the impact of IDBfinanced operations, and thereby contribute to more inclusive and sustainable development outcomes in Latin America and the Caribbean.
Contents Abbreviations and Terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 Message from the President of the Inter-American Development Bank . . . . . . . . . . . . . . . . . . . . . . . . .5 Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 The Independent Consultation and Investigation Mechanism (ICIM) . . . . . . . . . . . . . . . . . . . . . . . . . .9 The ICIM’s First Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 How was it established? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 The new mechanism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 The ICIM’s mandate and main lines of action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 The ICIM at a Glance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 ICIM establishment and organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 The Substantive Work of the ICIM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 Case management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 Status of Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 Outreach, communication, and dissemination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 The Consultation Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 The consultation process: A forum for an informed dialogue and a process to seek a solution 19 Methodology and tools: A flexible and collaborative approach . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Compliance Review Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Adapting Compliance Review methodologies to ICIM’s policy . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Getting at the facts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Compliance: A valuable asset of the Bank . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 Looking Forward . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23 ANNEX I Comparison of the IIM and the ICIM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 ANNEX II Who We Are and What We Do . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 ANNEX III Synopsis of Selected Cases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 ANNEX IV Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
Abbreviations and Terms ADB
Asian Development Bank
EBRD
European Bank for Reconstruction and Development
ICIM
Independent Consultation and Investigation Mechanism
IDB
Inter-American Development Bank
IFC
International Finance Corporation
IIM
Independent Investigation Mechanism
Mechanism
Independent Consultation and Investigation Mechanism
3
ICIM
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
Message from the President of the Inter-American Development Bank Towards Greater Accountability and Effectiveness at the IDB The Inter-American Development Bank (IDB) is committed to becoming a more socially responsible institution, and therefore more sensitive to those who might be affected by its operations. To do so, the IDB is strengthening the Independent Consultation and Investigation Mechanism (ICIM), which began operations in 2010 as part of the Bank’s efforts to increase the transparency, accountability, and effectiveness of its programs and projects. The ICIM is a direct response to the concerns of communities and individuals. Not only does it allow the Bank to respond to those concerns, but it will also deepen our knowledge about the impacts and sustainability of Bank-funded projects. The design and implementation of our operations are guided by the most advanced social, environmental, and operational policies to achieve the intended results. Nonetheless, development is challenging and dynamic, and in spite of our commitment to excellence, it is always possible that things will not turn out as planned. In addition, affected populations have the right not only to be heard and to participate, but also to disagree with what is being done in their communities through our funding. The IDB has several ways to deal with such situations at the operational and country office levels. In this context, the ICIM constitutes a forum of last resort. It is an immensely valuable mechanism and one that greatly complements our overall accountability framework. Thanks to its independence, and to its record of addressing the concerns of affected parties respectfully, adequately, and efficiently, the ICIM is earning credibility and trust of our staff. I have no doubt that the ICIM will also earn the trust and credibility of all stakeholders through its commitment to impartial consultation processes and compliance reviews.
5
The Bank is genuinely committed to continuing to improve and to become a better, more responsive, and more accountable institution. Consistent with this commitment, a strengthened ICIM will play a key role in helping to ensure that IDB’s financing leads to growth and development in an ever more socially responsible and environmentally sustainable manner. In concluding, I would like to thank the Organization, Human Resources and Board Matters Committee of the Executive Board of Directors for their tireless and valuable contributions to the establishment of the Mechanism. I would also like to welcome ICIM staff, including the Project Ombudsperson and Panel Members, and the recently appointed Executive Secretary. I look forward to working with all of you in the institutionalization of this Mechanism, which is important for the governance of the Bank.
Luis Alberto Moreno
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
Acknowledgments Our special thanks to the IDB Board of Executive Directors, in particular to the members of the Organization, Human Resources and Board Matters Committee, chaired by Mr. Hugo Rafael Cáceres, and to Directors Vinita Watson and Marc-Olivier Strauss-Kahn. Special thanks, as well, to all the other members of the Interview Panel, for their constant support for the establishment of the ICIM and of its mission and objectives. We also want to extend our thanks to Ms. Ana-Mita Betancourt, ICIM’s first Executive Secretary, for her valuable contributions and leadership role in the creation of the Mechanism, and to Mr. Renato Puch, Executive Secretary a.i., for his commitment and support during the ICIM’s transition period in 2010–2011. Their vast experience with Bank-related policies and procedures was of paramount importance to the efficient achievement of our goals. Finally, special thanks to the members of our ICIM staff, Ms. Rebeca Garcia and Mrs. Sylvia Walker, for their support in the production of this report.
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ICIM
The Independent Consultation and Investigation Mechanism (ICIM) The predecessor to the ICIM, the Independent Investigation Mechanism (IIM), was created in 1994 in response to a mandate of the Inter-American Development Bank’s (IDB’s) Board of Governors to promote transparency, accountability, and effectiveness of IDB performance by providing a process to address complaints from parties that allege that they are or might be adversely affected by IDB operations. In 2010, in order to fulfill the mandate of the Board of Governors, the IDB Board of Executive Directors established an enhanced Mechanism that reflected the lessons learned from the IIM, the developments in the international accountability arena, and inputs from civil society through a substantial public consultation. As a result, a policy for the new Independent Consultation and Investigation Mechanism (ICIM) of the Bank was approved on February 19, 2010.
The IDB was the second multilateral development institution to establish an accountability mechanism; the World Bank established its Inspection Panel in 1993.
In accordance with the Cancun Declaration (document AB-2728) and the Report on the Ninth IDB General Capital Increase (document AB-2764), the IDB took steps to comply with the Board of Governor’s mandate to establish the Independent Consultation and Investigation Mechanism.
The ICIM is intended to serve as a direct line of response to the concerns of affected parties. Its goal is to facilitate a more open and effective dialogue with civil society regarding IDB-financed operations. The ICIM provides a forum to address complaints and monitor compliance with IDB policies in a transparent, balanced, and objective manner, thus deepening the understanding of the impact of the Bank’s operations. Since its inception, the ICIM has received 11 requests originating from citizens in six countries. This is encouraging because it signals that potentially affected parties are availing themselves of the Mechanism and know how to access it. 9
The ICIM’s First Year How was it established? In an effort to improve the existing The public consultation process Mechanism, IDB Management appointed an engendered more than 470 interdepartmental working group to devise comments and suggestions that an initiative that would include new features deeply informed the efforts to create aimed at enhancing the IIM’s role. The IDB held a robust and more responsive ICIM. public consultations in 12 countries, and via its Web site, in which over 190 organizations participated. This valuable process deeply informed the efforts to create a robust and more responsive ICIM. The process of formulating the new features of the proposed ICIM began in 2010, immediately after the ICIM Policy was approved.1 (Box 1 presents a timeline and actions taken with respect to the creation of the ICIM.)
The new mechanism The new Mechanism differs from the old one in a number of features, including the following:
• It is an independent investigative body, has a broad-based mandate, and reports
directly to the Board of Executive Directors. incorporates a problem-solving voluntary phase led by the Project Ombudsperson. It offers a time frame for receiving requests that is better aligned with the project cycle. Requests can be presented up to 24 months after project completion.
• It •
1
10
Document (GN-1830-49)
The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
In addition, while the IIM did require some disclosure of its activities to the public, all ICIM activities and operations are disclosed to the public. (See Annex I for a comparison of the IIM and the ICIM.)
The ICIM’s mandate and main lines of action The ICIM’s mandate is twofold:
• To provide a space and an instrument for parties who are potentially affected •
by Bank-funded operations to raise and address their concerns using consensual methods. To investigate allegations by affected parties about the Bank’s failure to correctly apply its own Operational Policies.
To comply with its mandate, the ICIM has concentrated during 2010 on the following three areas:
• ICIM establishment and organization. Implementation of the new Mechanism •
•
including staffing and operational institutional arrangements to become fully effective. Case management. The ICIM deals with requests in two phases. In the first, called the Consultation Phase, the Project Ombudsperson facilitates the identification of viable solutions to issues raised by potentially affected parties. The ICIM has authority to undertake independent investigations regarding possible policy violations and harm and, where warranted, can follow through with the Compliance Review Phase, during which the Compliance Review Panel independently investigates the possibility of violations of Operational Policies and harm. Cases that are ineligible for the Consultation Phase can be resubmitted by the Requester for review by the Compliance Review Panel. Outreach, communication, and dissemination. The ICIM engages civil society and other external and internal stakeholders to further the accessibility to and generation of knowledge about the Mechanism. To this end, internal and external dissemination activities are being planned for the current fiscal year.
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Box 1 Establishing the ICIM: A Timeline of Activities
According to the IDB Policy that created the ICIM, the Bank established and maintains an office, the Office of the Independent Consultation and Investigation Mechanism, or the “ICIM Office.” The Project Ombudsperson, the Compliance Review Panel, the Executive Secretary, and any other employees or consultants assigned to the Mechanism constitute the ICIM Office staff. After approval of the policy, the IDB Board of Executive Directors took the following important steps in establishing the ICIM:
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•
Competitive selection and appointment by the Board of Executive Directors of the Project Ombudsperson (September 1, 2010)
•
Competitive selection and appointment of members of the Compliance Review Panel (October 18, 2010)
• • •
Appointment of the Acting Executive Secretary (October 18, 2010)
• •
Development of procedures and guidelines for substantive and administrative work
•
Development and approval of the ICIM’s first budget for 2011.
Beginning the process and competitive selection of the permanent Executive Secretary Development of a five-day workshop of training and work sessions for the three parties of the Mechanism (Executive Secretary, Project Ombudsperson, and Compliance Review Panel), which took place October 18–22, 2010, and featured presentations and dialogue with over 20 representatives and senior Management officials of the Bank
Completion of institutional arrangements for the ICIM Office, including moving to offices suited to this purpose
The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
The ICIM at a Glance ICIM establishment and organization Scope The Mechanism applies to all Bank-financed operations, including those funded by the Multilateral Investment Fund, and it currently covers all IDB-Board-approved environmental and social policies and those related to equality in gender and access to information. The ICIM Policy states that, starting in 2013, the ICIM will address issues related to all Operational and Sectoral Policies2 (see Box 2). Box 2 Relevant Operational Policies
• • • • •
OP-102 Access to Information Policy (Revised version: May 2010) (GN-1831-28)
•
OP-765 Indigenous Peoples (February 2006)
2
OP-703 Environmental and Safeguard Compliance Policy (January 2006) OP-704 Disaster Risk Management Policy (February 2007) OP-710 Involuntary Resettlement (July 1998) OP-761 Women in Development (August 1987) Gender Equality in Development (Revised version: November, 2010) (GN-2531-10)
For operations initiated before the effective date of these Relevant Operational Policies, the ICIM will use the applicable predecessor policies as points of reference.
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Key guiding principles The key ICIM guiding principles are as follows: Focus on problem solving and policy compliance The ICIM will focus its efforts on problem solving, compliance review, and furthering the IDB’s adherence to its Board-approved policies and directives. Instrument of last resort The ICIM does not replace a Project Team’s efforts and roles or any other operational quality-control process, but rather complements them when necessary and requested. The ICIM process is activated only when the efforts of those closest to the operation have proven insufficient or unsuccessful. Greater accessibility Accountability mechanisms give project-affected populations a voice and further the Bank’s commitment to social and environmental sustainability. Thus, the ICIM strives for simplification to streamline procedures, and for greater communication to ensure that access by citizens and communities is not hindered. Independence The ICIM is an objective, fair, and predictable instrument. As an independent mechanism, it strives to build credibility and trust among operational units, IDB Management, and project beneficiaries. Impact The ICIM is meant to enhance the IDB’s role in achieving development effectiveness by contributing to greater social and environmental sustainability.
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
Efficiency and effectiveness The ICIM strives for rapid responses, realistic deadlines, and simplified guidelines. The ICIM is meant to enhance the Bank’s role in achieving development results and to contribute to them. Knowledge generation The ICIM is intended to be a source of knowledge and learning for operators and stakeholders, inside and outside the Bank. It is envisaged that by extracting lessons, documenting case-related work, and interacting with project leaders, the ICIM will support the creation of a common knowledge platform to provide information, advice, and guidance to development practitioners, and adequate responses to civil society.
Organizational structure The ICIM’s independence from IDB Management allows for a neutral and open dialogue with all parties involved. The Office staff includes an Executive Secretary, who administers the day-to-day operational infrastructure of the Mechanism; a Project Ombudsperson, who leads and manages the Consultation Phase; and a Compliance Review Panel comprising five individuals whose main function is to carry out the Compliance Review Phase (see Figure 1). A Panel Chair leads the Compliance Review Phase. (See Annex II for details on organizational structure and staff.) Figure 1 Organization of the ICIM Office
IDB Board of Executive Directors
ICIM
Project Ombudsperson
Executive Secretary
Compliance Review Panel 15
The Substantive Work of the ICIM Case management The ICIM Policy establishes two distinct functions and processes for dealing with requests submitted by affected parties. The first is the Consultation Phase, and the second is the Compliance Review Phase. According to this sequence, all requests received and analyzed by the Executive Secretary are forwarded to the Project Ombudsperson for the purpose of determining the eligibility or ineligibility of the Request for the Consultation Phase. Requests declared ineligible for the Consultation Phase are forwarded to the Compliance Review Panel for further investigation, if so desired by the Requesters.
Status of Requests Table 1 summarizes the status of the ICIM workload as of December 31, 2010. The table includes cases under the previous IIM and those received after inception of the ICIM on September 9, 2010. (See Annex III for details on selected cases, and Annex IV for details on various aspects of the ICIM workload.)
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
Table 1 Status of ICIM Workload NO.
COUNTRY
CASE
DATE RECEIVED
PHASE
STATUS
Requests carried over from IIM and reregistered 1
Paraguay
Loofah S .A .
Feb . 10, 2010
Registered Consultation/Ombuds
Assessment
2
Brazil
Serra Do Mar
May 31, 2010
Registered Consultation/ Ombuds Compliance Review/Panel
Ineligible/Ombudsperson Preinvestigation
Requests received by ICIM 3
Panama
Pando-Monte Lirio
Mar . 12, 2010
Registered Consultation/ Ombuds
Assessment
4
Argentina
Entre Ríos
June 28, 2010
Registered Consultation/ Ombuds
Assessment
5
Brazil
PROMABEN
Oct . 4, 2010
Registered Consultation/Ombuds
Assessment
6
Argentina
PROSAP II
Nov . 3, 2010
Executive Secretary
Analysis
7
Paraguay
Route 10
Nov . 10, 2010
Registered Consultation/ Ombuds Compliance Review/Panel
Ineligible/Ombudsperson Preinvestigation
8
Brazil1
Nov . 22, 2010
Executive Secretary/ Ombuds
Pending with IDB Management
9
Argentina
PROMEBA
Consultation/Ombuds
Pending with Requester/ Management
10
Suriname1
Sustainable Development for the Interior
Dec . 14, 2010
Executive Secretary
Resolved by IDB Management with the cooperation of Project Ombudsperson
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Costa Rica
Alfombra Costa Rica SIEPAC-0035
Dec . 20, 2010
Executive Secretary
Under review with IDB Management
Rodoanel Oeste
Nov . 29, 2010
1 As part of the Executive Secretary’s and Project Ombudsperson’s duties and responsibilities, operational teams and country offices have received guidance on generic problem-solving activities . There are two cases that were addressed to Management rather than to the ICIM . However, because the ICIM is likely to get involved, both the Executive Secretary and the Ombudsperson have in fact been following up on management’s actions . The first case concerned the Sustainable Development for the Interior (Saamanka People) project in Suriname . The second case concerned the Rodoanel project in Brazil and involved a request about access to information . This case was forwarded to the Structured and Corporate Finance Department because the information of private sector operations is usually confidential .
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Outreach, communication, and dissemination One of the most important goals of the Mechanism is to generate credibility and collaboration within and outside the institution. To this end, and in line with its transparency goals, the ICIM places great emphasis on outreach activities. These include:
• Development of the institutional web page (August 2010) • Development of the Public Registry of cases, including information needed to • • • •
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keep track of the status of applications Development of outreach materials Participation in the IDB Annual Representatives Meeting in Washington, D.C. (September 27–October 1, 2010) Participation in the Orientation Course for new IDB employees (October 5, 2010) Participation in the Tenth Annual IDB-Civil Society Meeting in Quito, Ecuador (November 4–5, 2010).
The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
The Consultation Phase The Consultation Phase provides Requesters, operators, and other relevant stakeholders an opportunity to address their concerns in a consensual, flexible, and effective manner. The ICIM has benefited from the experience of other international financial institutions in this area, and has learned much from the requests it has received thus far. It continues to refine its processes and to build a more effective mechanism to address stakeholder concerns.
The consultation process: A forum for an informed dialogue and a process to seek a solution The Bank’s ongoing focus on sustainability and effectiveness Other Multilateral Development Banks have is consistent with the need for established entities to consider stakeholder concerns. For instance, in 1999, the International Finance local populations to have their Corporation (IFC) established the Compliance Advisor voices heard and a space to air Ombudsman independent unit. In 2003, the Asian their concerns. Development work Development Bank (ADB), followed by the European is not an exact science and often Bank for Reconstruction and Development (EBRD), encounters unexpected difficulties. established entities that had the dual function of both In designing the Consultation compliance and problem solving. Phase, the IDB Board of Executive Directors made every effort to ensure that the voices of the affected parties are not only heard but that their concerns are addressed respectfully, adequately, and efficiently.
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Methodology and tools: A flexible and collaborative approach Because each situation and the concerns aroused are unique, the Consultation Phase does not follow a blueprint. Rather, the approach to this process is flexible, collaborative, and tailored to each specific case. The Consultation Phase is a voluntary, three-part process consisting of (a) Eligibility Determination, (b) the Assessment Phase, and (c) a solution-seeking dialogue, which includes the participation of all parties involved. The Project Ombudsperson uses a number of tools and instruments to find a solution. However, most importantly, the Project Ombudsperson strives to establish and facilitate a collaborative dialogue among all parties. This also allows the Project Ombudsperson to provide support and advice to operational staff and to make initial recommendations on systemic issues. Thus, the Consultation Phase is a solution-seeking exercise aimed at identifying options and avenues to address the requests of, and respond to concerns expressed by, individuals or communities with regard to IDB operations. As current trends show, civil society is demanding greater access to information and increased transparency and accountability, and it is crucial that such access exists for adversely impacted people. Consultation and dialogue processes are proving fruitful; international financial institution statistics indicate that between 50 percent and 70 percent of grievance cases are resolved through the Ombuds process.
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
Compliance Review Phase In 2010, the IDB Board of Executive Directors appointed a Compliance Review Panel comprised of five professionals who have demonstrated expertise and excellence in dealing with both compliance and harm in a balanced and comprehensive way. Members of the Panel enjoy a high degree of independence in fulfilling their responsibility of delivering impartial judgment about Bank adherence to its own policies and about any possible relationship between the alleged harm and alleged policy violations.
Adapting Compliance Review methodologies to ICIM’s policy During 2010, the Compliance Review Panel began to develop a methodology that would appropriately provide the Board with a factual account of the areas of noncompliance alleged by the Requesters. As the Panel gained more experience conducting Compliance Reviews, it refined its methodologies, thus enhancing the effectiveness and efficiency of its work. This process will continue moving forward.
Getting at the facts To achieve its objectives, the Panel reviewed the literature on best practices. The most important tools include:
• Reconstruction
of the decisionmaking steps leading to the final design of the project
HARM AnD COMplIAnCE: WHy IS IT IMpORTAnT TO ExAMInE THEM THROuGH SpECIAl pROCEDuRES? People and communities living in areas where there are projects financed by international financial institutions can be negatively affected or harmed during the implementation process. Some of the harm they fear or actually experience may be related to noncompliance with the very policies that have been specifically designed to prevent such harm. Mechanisms are needed to enable those who experience or fear project-related harm to express their concerns and to obtain an independent assessment of whether there is in fact noncompliance or potential noncompliance resulting in, or potentially resulting in, real harm.
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• Establishment and verification of a “Decision Timeline” of the various steps of • • • •
the project design and implementation Capturing the institutional memory of the evolution of the project and its design through file research and information from IDB staff and other sources both inside and outside the borrower’s country Understanding of the legal dimension of the project Site visits and research on the Requester’s observations and on facts related to the alleged harm and policy violations Review of public or other official documents and discussions with Project authorities.3
Compliance: A valuable asset of the Bank Compliance with the Bank’s Operational Policies is essential to ensure the development effectiveness of IDB-funded projects, programs, and operations. In fact, the application of policies that are commonly referred to as “Safeguards” is central to ensuring broadbased development effectiveness. This is because these Safeguards are meant not only to ensure that investments made by the Bank lead to large gains in productivity and socioeconomic development, but that they achieve those objectives in a fair and transparent way, thus ensuring that any potential social or environmental harm resulting from the implementation of a project will include mitigating measures. Adherence to these policies is equally important to safeguard the Bank’s overall reputation as a transparent manager of the funds with which it is entrusted. Thus, by insisting on compliance with its own rules, the Bank is advocating transparency and accountability not only as important development goals in the countries in which it works, but also as part of its own continuous institutional efforts to improve development effectiveness.
3
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While the Panel does not in any way investigate the borrower and its agencies, it might be necessary to obtain information from officials and from project-relevant documents related to either the alleged harm or to other aspects of the Request to better understand the case and to fulfill the Panel’s mandate of impartiality.
The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
Looking Forward The ICIM will continue to pursue an innovative course of ensuring accountability to the various stakeholders of IDB-funded operations—that is, people affected by projects, borrowers, and the Bank’s Board of Directors, staff, and Management. Some of the elements of the ICIM’s work can follow established practice, but others will have to be experimented with and adapted to the special circumstances of Latin America and the Caribbean and the demands of the IDB’s agenda for a Better Bank. The key to long-term success will be to maintain the Mechanism’s independence and flexibility while demonstrating that the results of both the Consultation Phase and Compliance Reviews are fair to, respectful of, and useful for all stakeholders. Responsible participation will be the prevailing theme throughout the coming year. The ICIM will continue to strive to involve all stakeholders through the establishment of open lines of communication that promote trust and credibility and that ensure a constructive dialogue between the ICIM and stakeholders. The ICIM aims to achieve these goals by improving its operations and strengthening its relations with civil society. These initiatives are consistent with the IDB’s efforts to develop and implement programs that are socially responsible and environmentally sustainable while truly benefiting individuals and communities in the most positive ways.
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ANNEXES
ANNEX I Comparison of the IIM and the ICIM Key Features
IIM (Old Mechanism)
Independence
Independent; reporting line to the President of the IDB
Reporting line
Investigators reported to the Board and Coordinator reported to the Administration
Key personnel
Mechanism Coordinator
ICIM (New Mechanism) Independent; reports to Board of Executive Directors
The entire ICIM reports directly to the Board Project Ombudsperson Executive Secretary
Panel of 3 independent experts
Panel of 5 independent experts
Functions
Investigation
Problem solving and investigation
Scope of policies
All IDB policies
Six IDB Operational Policies
Organizational infrastructure
Ad hoc office attached to Secretary of the Bank
An ICIM Office with an Executive Secretary, Ombudsperson, and Chairperson of the Compliance Review Panel; the Mechanism reports to the IDB Board of Executive Directors
Type of matters
Compliance
Consultation and compliance
Time frame for presenting a Request
Up to the day of the last disbursement
24 months after the last disbursement
Unpredictable deadlines
Predictable deadlines and spelled out processes
Procedures
Roster (chosen by Management) Investigation process
Consultation Phase led by the Ombudsperson
Sources of funding
Management Discretionary Budget
Board of Directors Corporate Governance Budget
Compliance Review Phase led by the Chairman of the Compliance Review Panel with two Panel Members
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ANNEX II Who We Are and What We Do The ICIM Staff The ICIM staff was appointed by the IDB’s Board of Executive Directors and comprises an Executive Secretary, a Project Ombudsperson, and a Compliance Review Panel of five experts. The ICIM office is located in the IDB headquarters in Washington, D.C. The Executive Secretary is responsible for the day-to-day administration of the office. The Executive Secretary’s work focuses on facilitating access by individuals and communities to the ICIM; carrying out information and outreach activities with Requesters, civil society, and other parties; and providing orientation about the application of the ICIM Policy. The Executive Secretary also ensures ICIM’s transparency through maintenance of the ICIM’s Public Registry; coordinates the ICIM’s activities with Management; and supports and advises the Project Ombudsperson and the Compliance Review Panel in connection with ICIM reports, documentation, and processes, and strategic planning and communications issues. The Project Ombudsperson leads the Consultation Phase in an effort to find a solution to a problem. By providing a neutral, nonjudgmental environment, the Project Ombudsperson enables concerns to be addressed through an open exchange of information between beneficiaries and Bank operators, thus facilitating the negotiation process and fostering a constructive dialogue among all interested parties. While maintaining her or his independence, the Project Ombudsperson facilitates opportunities to resolve requests in a flexible, balanced, and consensual way. Thus, the Ombudsperson can help transform a complaint or conflict into an opportunity to manage risks and ensure better and more participative development results. If requested, the Ombudsperson monitors the implementation of agreements. The Compliance Review Panel leads the Compliance Review Phase. In accordance with its mandate, its role is to investigate complaints and to bring to the attention of the Board of Executive Directors determinations on whether there was harm caused by IDB-funded projects or initiatives, and which Operational Policy or Policies, if any, were
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violated and how. If requested, the Panel will monitor implementation of decisions taken by the Board. The compliance Review Panel is headed by the Panel Chair.
Consultation phase Isabel lavadenz paccieri, project Ombudsperson Ms. Isabel Lavadenz-Paccieri, a Bolivian national, was appointed the first ICIM Project Ombudsperson in July 2010. Ms. Lavadenz worked at the World Bank for 12 years where she handled matters related to land and natural resource management, and rural development in the Latin America and South Asia regions. Most recently, she worked on climate change and governance issues, at the corporate level. From 2005 to 2007, on external service from the World Bank, Ms. Lavadenz served as Director of the Latin America and the Caribbean region at the International Fund for Agricultural Development (IFAD) in Rome. Before joining the World Bank, she held cabinet-level positions in Bolivia, with responsibility for sensitive reforms requiring permanent dialogue with peasant organizations, the private sector, and indigenous communities. She was the Principal Advisor to the establishment of the first National Ombudsman Office in Bolivia. Ms. Lavadenz holds a Master’s degree cum laude in Law from the University of San AndrÊs Bolivia, and did postgraduate studies in Sustainable Development and Conflict Resolution in Costa Rica and Bolivia, respectively.
Compliance Review panel Werner Kiene, Chairperson Dr. Werner Kiene, an Austrian citizen, is an international development practitioner. He has worked in several leadership positions with the Ford Foundation, German Development Assistance, the United Nations, and the World Bank. During his assignments, he has concentrated on the design, implementation, and assessment of
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sustainable development initiatives and, increasingly, on the governance structures and accountability required to ensure their success. Dr. Kiene holds Master of Science and PhD degrees from Michigan State University. He is a member of professional associations devoted to assessment and accountability issues and is engaged in board and advisory functions of several organizations involved in international development.
Gilberto Amaya, panel of Experts Mr. Gilberto Amaya is a specialist in international development, with 30-plus years of experience. He has served in senior management positions at the Pan-American Development Foundation (PADF), an affiliate of the Organization of American States (OAS); Enterprise Works Worldwide; and Appropriate Technology International (ATI). At ATI he assisted international development organizations, governments, nongovernmental organizations, and community-based organizations in the design and implementation of broad-based socioeconomic development strategies and programs to address issues of poverty and social exclusion. Mr. Amaya’s education includes a Master’s degree in International Development from the University of Pennsylvania and a Bachelor’s degree in Industrial-Mechanical Engineering from the National University of Honduras.
Mary Rose Brusewitz, panel of Experts Ms. Mary Rose Brusewitz is an experienced international attorney and concentrates her practice on Latin America. She is a partner at Strasburger & Price, where she heads the New York office of the firm. She is an adjunct professor at the University of Michigan Law School’s International Transaction Clinic and a member of the Board of the Microfinance Club of New York. Ms. Brusewitz has been active in the areas of dispute settlement, restructuring, project and structured financing, public-private partnerships, climate change, regulatory reform, microfinancing, and other areas relating to development of the Latin American region.
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Ms. Brusewitz earned her Juris Doctor Degree at the University of California, Los Angeles School of Law, and her Bachelor’s degree, summa cum laude, from the University of California, Los Angeles. She is licensed to practice in New York and speaks fluent English, Portuguese, and Spanish.
Mario Epstein, panel of Experts Dr. Mario Epstein is a citizen of Brazil. Throughout his career, Dr. Epstein has demonstrated a commitment to solving social and environmental conflicts arising from energy, industrial, or infrastructure projects. In his varied capacities, Dr. Epstein has spent many years working on development, social, and environmental issues for the United Nations system and international development banks in Latin America, Africa, and the Caribbean. He holds a Bachelor of Science degree in Nuclear Physics, a Doctorate of Science degree in Environmental Engineering, and a Bachelor’s degree in Social and Juridical Sciences. He is a member of the Brazilian Bar Association and serves as a volunteer Conciliator Judge in the Small Claims Court in his hometown in Brazil.
Dr. Korinna Horta, panel of Experts Dr. Korinna Horta served as a senior scientist at the Environmental Defense Fund from 1990 through 2009 and has worked as a consultant to the United Nations Research Institute for Social Development and other institutions. She has worked with policy makers, nongovernmental organizations, and community groups to promote socially equitable and environmentally sustainable development, focusing on building bridges between vulnerable population groups and global decision makers. Dr. Horta completed her PhD at the University of London School of Oriental and African Studies, and holds a Master’s degree in Latin American Studies and International Economics from The Johns Hopkins University School of Advanced International Studies in Washington, D.C., and a Licenciatura from the Universidade Nova de Lisboa, in Lisbon, Portugal. She is fluent in English, German, and Portuguese, and uses French and Spanish as working languages.
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ANNEX III Synopsis of Selected Cases ARGEnTInA Multiphase Development Infrastructure: Support Production Entre Ríos - 1914/OC-AR (AR MICI001/2010)
The project The objective of the project is to contribute to the development and competitiveness of the economy of the Province of Entre Ríos, Argentina. The project aims to sustainably increase the available basic economic infrastructure, ensuring the improved serviceability of important sections of the provincial road network and increasing the capacity and reliability of the electric system.
The Request
pROjECT InfORMATIOn AT A GlAnCE Sector: Private Sector Development Infrastructure and Public Service
–
Environmental Category: B Loan Amount: $100,000,000 Board Approval Date: November 14, 2007 Effective Date: April 17, 2008 Last Disbursement: October 17, 2012 Cofinancier: Not applicable
On June 28, 2010, a Request was Current Status: In execution submitted before the Independent Investigation Mechanism (IIM) expressing social and environmental concerns with regard to the Multiphase Development Infrastructure: Support Production Entre Ríos Project, in particular regarding its energy component. The Request states that the project has not been designed or implemented in accordance with local laws, that the environmental classification of the project has not been disclosed, and that the siting of the operation has resulted in the impairment of the agricultural productivity of nearby lands, and
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other negative impacts. The Requester also claims that the project does not include adequate safeguards for the protection of surrounding ecosystems and human environment. This Request was logged by the Executive Secretariat on September 20, 2010, once the ICIM was declared effective on September 9, 2010.
ICIM Actions After a thorough analysis of the Request and its compliance with the ICIM Policy, the Ombudsperson determined, on October 8, 2010, that the complaint was eligible for the Consultation Phase. The Ombudsperson initiated the assessment of the case, held meetings with the Project Team, and engaged in a dialogue with the Requesters. To better understand the perspectives of all stakeholders, the Ombuds team conducted a field visit November 28–December 6. The visit included completing a mapping exercise, obtaining the response of the Executing Agency, and identifying possible solutions. Local mediators were recruited. An Assessment Report outlining the main findings and agreed next steps has been produced and shared with all relevant parties. The team successfully encouraged the parties to agree to a dialogue process to analyze, discuss, and resolve the issues presented by the Requester. Preparations for the dialogue are ongoing.
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ARGENTINA Provincial Agricultural Services Program II (PROSAP II) - 1956/OC-AR (AR MICI002/2011)
The Project The main objectives of the program are to contribute to the development of the regional rural economies by making them more competitive, increasing their agricultural exports, and fostering a sustainable increase in the coverage and quality of the rural economic infrastructure for food and agricultural services.
The Request
Project Information at a Glace Sector: Agriculture and Rural Development Agricultural Development Environmental Category: B Loan Amount: $200,000,000 Board Approval Date: January 16, 2008 Effective Date: April 17, 2008 Last Disbursement: April 17, 2012
Cofinancier: Not applicable The Request was submitted on Current Status: In execution November 3, 2010, for ICIM consideration with observations related to the infrastructure work carried out in the context of the Modernizaci贸n del Sistema de Riego Canal Matriz Nuevo Alvear (Rio Atuel) Project and its negative impact on the archeological patrimony of the area around the General Alvear and San Rafael Oases, located in the Province of Mendoza, Argentina.
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
ICIM Actions On December 9, 2010, the Request was forwarded by the Executive Secretary to the Ombudsperson for determining its eligibility for the Consultation Phase. The case was declared Eligible on January 3, 2011, and the assessment phase begun. The Ombuds team met with the Project Team leader and established a dialogue with the Requester. All parties are amenable to a dialogue process and to working together to seek a robust set of mitigating measures. Through a collaborative process, IDB Management and the Executing Agency have already produced a technical audit report on the case and are taking the necessary steps to immediately avoid further impacts on the archeological patrimony in the area. A field visit by the Ombuds team is scheduled for the end of February 2011 to facilitate a dialogue with stakeholders and to move toward prompt resolution of the case.
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BRAZIl Program for Social-Environmental Recovery of the Serra do Mar and Sistema de Mosaicos of the Mata Atlântica - 2376/OC-BR (BR MICI001/2010)
The project The program’s general objective is to promote the conservation, sustainable use, and socioenvironmental recovery of the Serra do Mar mountain range, the Jeréia-Itatins Mosaic territory, and the marine conservation units and their surroundings, all in the state of São Paulo. The program will generate social and ecological benefits and promote the effective protection of biodiversity and the natural water sources that serve the metropolitan area of the city of São Paulo and the Baixada Santista region.
The Request A Brazilian nongovernmental organization called Mongue, Coastal System Protection, represented by Mr. Plinio Melo, submitted on May 13, June 15, and October 13, 2009, communications to the IIM with observations and complaints regarding the replacement of the existing environmental protection system in the project area through a so-called “mosaic approach” that intends to protect special and limited conservation units instead of a large contiguous conservation area. Of particular concern to the Requester
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pROjECT InfORMATIOn AT A GlAnCE Sector: Environmental and Natural Disasters Environmental Programs Environmental Category: A Loan Amount: $162,454,000 Board Approval Date: September 8, 2010 Effective Date: December 8, 2010 Closing Date: Not applicable Cofinancier: Not applicable Current Status: Not yet disbursed
The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
was the proposed establishment of such special conservation units, and changes in the conservation regime of the Ecological Reserve Jureia-Itatins in the Municipality of Peruibe, São Paulo, Brazil and the Bank’s plans to finance certain elements of this new approach.
ICIM Actions Based on the information available at the time, the Ombudsperson determined, on October 8, 2010, that the complaint was not eligible for the Consultation Phase as stipulated in the Mechanism policies.4 The Requester subsequently asked that his complaint be submitted to the Compliance Review Panel of the Mechanism. After a detailed review of new and additional information made available since then, the Panel Chair, in line with the policies of the Mechanism and without any judgment on the merits of the complaint, determined that the Request is eligible for a Compliance Review by the Panel. The complexity and the innovative nature of the project and the sometimes conflicting assertions of those involved in this complaint require on-site discussions with the Requester and the project authorities, and with the Project Team both in the Country Office and at IDB headquarters. This will ensure an impartial assessment of the situation, the alleged harm, and the alleged noncompliance by the Bank.
4
In this case, “Mechanism policies” refers to the rules of the old IIM Policy, because this Request was presented before formal approval of the ICIM Policy.
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BRAZIl Estrada Nova Watershed Sanitation (PROMABEN) - 1998/OC-BR (BR MICI002/2010)
The project The objective of the project is to help reduce the environmental and social problems faced by the inhabitants of the Estrada Nova watershed, located in the city of Belem, Brazil. The program’s aims include improving housing conditions among the population living in the area through urban planning, efforts to regularize land tenure, adoption of suitable housing solutions, and the establishment of recreational areas.
pROjECT InfORMATIOn AT A GlAnCE Sector: Water and Sanitation Environmental Category: A Loan Amount: $68,750,000 Board Approval Date: July 9, 2008 Effective Date: April 2, 2009 Last Disbursement: April 2, 2014 Cofinancier: Not applicable Current Status: In execution
The Request On October 4, 2010, a Request was submitted for ICIM consideration, which was forwarded by the Executive Secretary to the Ombudsperson for determination of its eligibility. The Request outlined issues related to resettlement and expropriation processes in the Estrada Nova community in Belem. The Request includes concerns regarding the land valuation process and its alleged inappropriate execution.
ICIM Actions On December 17, 2010, the ICIM Project Ombudsperson determined that the Request is eligible for the Consultation Phase. Since then, the assessment stage has begun and both the Requester and the Project Team have initiated an Ombuds-sponsored dialogue to search for a solution. A field visit is scheduled for February 2011.
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pAnAMA Pando-Monte Lirio Hydroelectric Power - 2266/OC-PN (PN MICI001/2010)
The project The project consists of the pROjECT InfORMATIOn AT A GlAnCE construction and operation of two hydroelectric power plants, namely, Sector: Energy - Alternative Sources of Energy Pando and Monte Lirio (together, the Environmental Category: A “project”), located in the upstream part of the Chiriqui Viejo River Loan Amount: $40,000,000 basin, province of Chiriqui, on the Board Approval Date: December 9, 2009 western side of Panama. The Pando Effective Date: June 17, 2010 plant includes a 32-meter-high dam. Last Disbursement: October 31, 2013 The Monte Lirio plant is located in a cascade downstream of the Pando Cofinancier: Electron Investment, S.A. plant. It includes a 15-meter-high Current Status: Not yet disbursed dam. The project will be connected to the domestic and regional electricity grids by the Central American Interconnected System through a 19-kilometer transmission line, and is expected to start delivering energy in early 2013. The total installed capacity would be 85 megawatts. The project is being implemented by Electron Investment S.A, a joint venture between Inveravante Inversiones Universales S.L., Spain; and the Panamanian entity Grupo Eleta.
The Request Sixteen Panamanian organizations and community representatives submitted, on March 10, 2010, a complaint to the IIM expressing social and environmental concerns with regard to the Pando‐Monte Lirio Hydroelectric Energy Project, financed by the IDB, the International Finance Corporation (IFC), the Andean Development Corporation, and other private investors. The Requesters highlighted, among other things, negative aspects of the process of the environmental impact assessment 37
and disclosure of information, water use, adverse impacts on fish and other species, destruction of mangroves located near the mouth of the river in the Gulf of Chiriqui, and the possibility of flooding to communities downstream and high levels of sedimentation. The Requesters also raised social concerns with respect to the granting of long-term water concessions in the already busy river. The Requesters stated that the project would damage roadways and negatively impact agricultural projects and the local economy. This Request was logged by the Executive Secretariat on September 20, 2010, once ICIM was declared effective on September 9, 2010. Since the Pando Monte Lirio Hydroelectric Energy Project is cofinanced by the IFC, the Request to the IDB was also submitted to the IFC, in January 2010. As a result of the collaborative approach between the Compliance Advisor Ombudsman unit and the ICIM, a Memorandum of Understanding was signed by the unit and the ICIM to respond to Requesters, which explicitly asked for a single Ombuds process. The organizations requested that the IDB and the IFC consider and address these concerns prior to proceeding with disbursements for the project.
ICIM Actions After a detailed review, the Ombudsperson, on October 8, 2010, determined that the complaint was eligible for the Consultation Phase. In opening the assessment stage, the Project Ombudsperson held numerous coordinating meetings with the IFC and conducted a field trip in November 2010 to participate in the meeting with the Requesters and the private company, and with local and national government officials. In addition, as part of the Assessment Phase, a thematic matrix was agreed between the parties and will be discussed with Requesters and stakeholders as part of the dialogue and solution-seeking exercise. The ICIM and the Compliance Advisor Ombudspersons are exploring options for facilitating a response from the relevant parties to the issues posed by the beneficiaries. The ICIM Assessment report will be issued in February 2011.
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pARAGuAy Development of the Industry of Products of the Vegetable Sponge PES-SP-SF-04-35-PR and Technical Cooperation ATN/SF-8984-PR (PR MICI001/2010)
The project The main objective of the program, which was financed with Social Entrepreneurship Program funds, was to increase the ability of the company, Loofah S.A., to produce loofah—a vegetable sponge—for the generation of additional income and employment, and to enable the diversification of the income of small loofah producers, peasant farmers, indigenous groups, and low-income families.
pROjECT InfORMATIOn AT A GlAnCE Sector: Microenterprises - Microfinance Environmental Category: Not applicable Loan Amount: Original: $210,000 Current: $102,497 Board Approval Date: December 7, 2004 Effective Date: February 8, 2005 Last Disbursement: August 8, 2008 Cofinancier: Not applicable Current Status: Fully disbursed
The Request The Request was submitted to the IIM on February 10, 2010, with observations related to a Non-Reimbursable Technical Cooperation awarded to Loofah S.A. in 2005. Disbursement of remaining Technical Cooperation funds had been cancelled. A Loofah representative stated that the company suffered economic impacts as a consequence of such partial cancellation. The Request was logged by the Executive Secretariat on September 20, 2010, once the ICIM was declared effective on September 9, 2010.
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ICIM Actions Given the circumstances of the case and the fact that Management was already taking action to resolve not only this case, but also the Loofah S.A. state of arrears, the Project Ombudsperson granted a reasonable period of time to Management in order to advance its own negotiation process. On December 16, 2010, the ICIM Project Ombudsperson determined that the Request was eligible for the Consultation Phase. As part of the assessment process, the Project Ombudsperson facilitated a number of meetings with the Project Team, the country office, and the Requester. At the end of December, an Amendment to the Loan Agreement was signed between the Bank and the Requester restructuring the loan and establishing revised conditions for the repayment by Loofah S.A. Under the guidance of the Ombudsperson, and thanks to the open and constructive attitude of the Project Team and Management, the Consultation Phase will provide an opportunity for addressing pending issues of Technical Cooperation funding and hopefully bring this case to closure by mid-2011.
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
pARAGuAy Program to Improve Highway Corridors in Paraguay – 933A/OC-PR (PR MICI002/2010)
The project The program was developed to improve Highway Corridors in Paraguay and includes among its main objectives to “… (iv) Increase by approximately 20,000 ha [hectares] the area of land set aside as environmental reserves and begin regularization of ownership of some 11,000 ha by indigenous communities in the area of influence of Route 10 in the section of the highway corridor between Asunción and Salto del Guairá.”
The Request
pROjECT InfORMATIOn AT A GlAnCE Sector: Transportation - Major Highways Environmental Category: Not applicable Loan Amount: Original: $82,300,000 Current: $81,445,258 Board Approval Date: June 26, 1996 Effective Date: May 20, 1997 Closing Date: June 11, 2008 Cofinancier: Not applicable Current Status: Fully disbursed
The Request was submitted on November 10, 2010. The Requesters allege that the Ache community has suffered harm and will continue to do so due to the Bank’s failure to enforce provisions in the Loan Agreement that were meant to safeguard their rights to ancestral lands. The Request also refers to earlier forceful evictions and to International Labour Organization Convention 169 that the Requesters allege supports the Ache community’s claims to the disputed land.
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ICIM Actions After gathering and analyzing all the information about the Request and the projects that are related to it, the ICIM Project Ombudsperson determined, on December 16, 2010, that the Request is not eligible for the Consultation Phase, as stipulated in the ICIM Policy, since the Requesters were not amenable to a dialogue and consultation exercise at this stage, and explicitly asked for a Compliance Review. According to the ICIM Policy, the Consultation Phase is voluntary and Requesters ought to be amenable and committed to participate in the dialogue process. Also, according to the ICIM Policy, once the avenue for the Consultation Phase is closed, Requesters can solicit the submission of the case to the Compliance Review Panel. The Panel Chair subsequently reviewed the available information and determined that the Request was eligible for a Compliance Review. Preparatory steps for such a Review were initiated in early 2011.
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The Independent Consultation and Investigation Mechanism (ICIM) 2010 Annual Report
ANNEX IV Figures Figure A IV.1 Issues Raised in Requests
Figure A IV.2 Case Distribution, by Phase
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Figure A IV.3 ICIM’s Request Load, FY 2010
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Figure A IV.4 Workload by Phase
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The Independent Consultation and Investigation Mechanism (ICIM)
2010 Annual Report
1300 New York Avenue, N.W. Washington, D.C. 20577 Tel: + 1 (202) 623-3952 Fax: + 1 (202) 312-4057 e-mail: mecanismo@iadb.org www.iadb.org/icim