The World Bank recently invited comments on the design of its Forest Investment Program. Rainforest Foundation UK and Greenpeace produced the following comments on the FIP design document along with suggestions for concrete changes to the text (available here, pdf file 111 kB).
Having noted the “undue urgency” with which the Bank is carrying out this process, Rainforest Foundation UK and Greenpeace focus on the following: strengthening safeguards; increasing transparency; addressing underlying causes of deforestation; including civil society and Indigenous Peoples in decision making processes, design and implementation of FIP; independent monitoring; and excluding from FIP activities that lead to deforestation and forest degradation.
Rainforest Foundation UK and Greenpeace Comments on the FIP Design Document
We welcome the opportunity to comment on the Forest Investment Programme Design Document and information notes, and appreciate the extension of the deadline for comments. However, we are concerned that there seems to be undue urgency to put the mechanism in place and secure financial commitments before the end of this fiscal year (June 09), in order to demonstrate results by Copenhagen. We believe that it is more important for the mechanism to be designed well than quickly.
In this spirit, we wish to make the following general observations:
- The information notes as currently formulated may do more harm than good and should be removed, or at the very least qualified as non-binding, individual contributions from the FIP secretariat that do not reflect consensus among participants in the design process.
- The design document still lacks crucial details regarding the kinds of activities that the FIP will and will not support, and critically, the criteria, standards and safeguards it will apply to the selection of FIP programs. These aspects must be more clearly defined at the design stage, before financial commitments are made, and not left up to the future work of the FIP sub-committee (FIP-SC). We believe that it is unlikely that the FIP will attract wide support until the parameters of its financial engagement are clarified, and instead may raise concerns from stakeholders, including potential funders, about engaging in unknown commitments.
- Transparency and disclosure provisions for the FIP must be strengthened to ensure timely public access to information, necessary to inform decisions before they are taken, and independent oversight of the performance/impacts of FIP-supported activities. [See proposed revisions to paras 12 c and 28]
- The FIP should focus on addressing the underlying drivers of deforestation and degradation – not just the proximate causes – both within and ouside the forest sector. Performance criteria should not be limited to emissions reductions, but be defined in such a way as to allow FIP support for the variety of activities and measures necessary to reduce underlying pressures on the forest wherever they originate, whether or not the impacts of those actions can be directly and/or immediately quantified in terms of emissions. Such measure should include improvements in forest governance, tenure and policy regimes, and demand-side management aimed at reducing demand for and trade in timber and agricultural products derived from degraded or converted forest land. [See proposed revisions to para 12 h]
- Criteria for selecting FIP programs and projects and for assessing performance must compromise, inter alia, forest governance indicators, including recognition of Indigenous Peoples’ and local communities’ land tenure and resource rights, enforcement of laws against illegal logging or unsustainable forest practices, and transparent, fair and equitable distribution of forest benefits, as well as measures of biodiversity maintenance and socio-economic impacts on Indigenous Peoples and other forest-dependent communities. [See proposed revisions to para 12 f and g, and para 34]
- Civil society and Indigenous Peoples should have a voice as full decision-making members on the FIP-SC, if they choose to participate, as well as in the design and implementation of FIP-eligible activities in their countries. The design document indicates that he FIP-SC will have extensive roles and responsibilities, including approval of review criteria and terms of reference for the expert group. It is particularly important that civil society and Indigenous Peoples have an opportunity to participate in these policy-making decisions. [See proposed revisions to paras 16 c and 17, and paras 19-20]
- The scope and timing of, and procedures for, monitoring and evaluation should be clarified and must include provisions for independent monitoring and verification of activities and impacts, as well as participation fo Indigenous Peoples and local communities in monitoring activities and evaluation. [See proposed revisions to paras 33 and 34]
- The design document should explicitly state that the FIP will not support activities that constitute or contribute to forest degradation and deforestation, including industrial logging and conversion of natural forests or other natural ecosystems to tree plantations or other types of industrial agriculture. These activities result in significant emissions of greenhouse gases, and as such, should not be supported under a financial mechanism aimed at mitigating climate change. An “exclusion list” stipulating those activities that the FIP will not support, such as established by the IFC for its operations, should be referenced in the design document and detailed in an annex. [See proposed revisions to paras 12 i and j, and proposed addition after para 11]
- Key terms used in the document, such as “forests”, “deforestation” and “degradation” must be defined (in a glossary or annex that presents the sources of the terms) and used consistently. [See proposed revision to para 9]
- The design document should more clearly stipulate which environmental, social and human rights safeguards, including relevant international agreements and norms, will apply to the FIP’s activities and how they will be applied – at what stage review of compliance/consistency will occur, and what will be done in cases where safeguards are not respected. The FIP should not preempt or undermine the negotiations underway at the UNFCCC, nor should the design or operation of the FIP undermine advances made in other agreements, such as the UNDRIP and CDB AHTEG. [See proposed revisions to para 12 c]