CIEL Letter to Maninder Gill Regarding Operational Directive 4.30

 

November 17, 1999

 

Maninder Gill, Coordinator
Resettlement Thematic Group
The World Bank
1818 H Street, NW
Washington, DC 20433

Dear Mr. Gill:

Thank you for the opportunity to comment on the World Bank’s proposed draft revisions to Operational Directive 4.30, Involuntary Resettlement. CIEL would like to register our appreciation for your efforts to make this a participatory process, including extension of the deadline by which to provide comments, translation of the draft into many different languages, and your attempts to disseminate information about this revision. While an internet-based system is not perfect, especially in terms of reaching people who are directly affected by involuntary resettlement, it has been an important step in expanding the dialogue. The posting of comments received on the World Bank web page was very helpful, and we hope that you will continue to utilize this forum to continue the consultation process.

Your letter inviting comments indicated that the Bank will provide a summary of comments received, together with an explanation of how those comments were addressed. In addition, we encourage the Bank to continue to recognize the intense interest of civil society in this process, and to call on the experience that is reflected in the body of analysis that has been submitted so far. We further hope that you will be able to expand the dialogue to reach communities that have direct experience with the Bank’s role in involuntary resettlement. In other words, the receipt of this round of comments should not mark the end of your dialogue and consultation with the interested public.

The Bank’s policy on resettlement is critically important to millions of people around the world. It is also critically important to the success of the World Bank as a development institution. Development-induced displacement poses a significant human paradox for Bank lending. The practice of involuntary resettlement has all too often resulted in a downward spiral of increased impoverishment and marginalization of local communities. The use of public funds for projects that undermine communities without adequate development benefits is profoundly disturbing from an institutional and governance standpoint. We call on the Bank to take leadership on the issue of development-induced displacement. We believe that the Bank should develop and abide by standards that respect the rights and interests of locally affected people, and give them an effective voice in decisions that so significantly affect their lives.

In recent years, the Bank has commissioned several internal reviews to examine its history of compliance with Involuntary Resettlement. The findings of such internal reviews, together with lessons to be drawn from accountability mechanisms and external analyses indicate serious problems in compliance with the policy on Involuntary Resettlement. Accordingly, this review/reformatting/revision of the policy provides an important opportunity to learn from past mistakes and failures and to implement changes to ensure a more effective approach to this issue, one which is critical to the Bank’s efforts to combat poverty and move towards sustainable and equitable development.

CIEL is surprised and disappointed that the review/reformatting/revision of the policy has largely failed to reflect the findings of the Environment Department, the Operations Evaluation Department, the Morse Commission, the Inspection Panel, and external critiques. Drawing from these past experiences, CIEL has identified "missed opportunitites" for correcting systemic and consistent problems in the implementation of the policy.

The length of these comments reflects the importance of the policy and the proposed changes. We believe that the review/reformatting/revision of the policy as reflected in draft OP 4.12 represents significant changes from OD 4.30. In Part I of these comments, we have tried to identify and analyze many of these changes. Part II discusses missed opportunities for strengthening the policy and improving its implementation by the Bank and borrowers. Part III contains comments on specific language in certain paragraphs.

We would like to encourage you to continue to engage in a dialogue and a sharing of experiences in the context of resettlement. There are some very important policy issues that are triggered by the Bank’s resettlement policy that demand a more comprehensive analysis than is reasonable in the context of comments on this particular policy. We recommend that the reformation of the policy be used as a catalyst to launch a discussion about the Bank’s role in development-induced displacement, the cumulative impacts of decades of failed implementation, and positive lessons that can be utilized and applied in future projects.

I look forward to hearing your thoughts on these ideas, and to having an opportunity for continued exchange of experiences and ideas. I wish you luck in compiling a matrix of comments received and how they are being incorporated in the next round of the policy. Thank you again for your patience and for your efforts to encourage public participation.

Peace,

Dana L. Clark
Senior Attorney

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