World Bank Environmental and Social Framework Consultation

Through US ICOMOS, ICOMOS has been actively involved in the consultation launched by the World Bank to re-write its policies regarding environmental and social development and assess the role of cultural heritage in managing these issues.

This World Bank Group is one of the biggest sources of capital in the developing world and its projects have an enormous impact – both good and bad -- on heritage.  In 2014 alone the World Bank Group committed $65.6 billion in loans, grants, equity investments, and guarantees to its members and private Businesses, including more than $22 billion in financing for private sector development.  The projects funded range from water and energy projects, to roads and infrastructure to, information and communication technology, to lumber, fisheries and natural resource extraction.  The Bank has stated that its core values include the protection of people and the environment and ensuring sustainable development outcomes. In that spirit, over the years the World Bank has shown a concern for identifying, protecting and managing cultural heritage in development projects, and ICOMOS has recognized these contributions even while urging improvement and challenging the Bank when it has failed to live up to its own ideal.

So, when the World Bank announced that for the first time in almost a decade it would be re-writing the policies by which it addresses these issue, ICOMOS immediately took note.  The proposed new Framework includes five elements, key components of which are The World Bank Environmental and Social Policy and the Environmental and Social Standards (the “ESS”). The ESS set out the requirements for Borrowers relating to the identification and assessment of environmental and social risks and impacts associated with projects in which the Bank invests. The ESSs are made up of 10 standards. ESS8 is dedicated to Cultural Heritage. ESS8, however, must be read in the context of the other ESSs. For example, ESS1 addresses Assessment and Management of Environmental and Social Risks and Impacts. In addition, a separate regime -- ESS7 -- covers Indigenous Peoples.

The Bank established a process for civil society consultation on this new Framework.  More on this process can be found here: https://consultations.worldbank.org/consultation/review-and-update-world-bank-safeguard-policies.  A key step in that process was the release on July 30, 2014 of draft Environmental and Social Framework documents for consultation.  ICOMOS was pleased to have this opportunity to present to the members of the World Bank’s Executive Committee on Development Effectiveness, staff and counsel feedback on these documents, which was submitted in advance of the March 1 deadline.  The ICOMOS comments were originally presented in draft form on November 12 in Florence, Italy during a meeting of the ICOMOS International Committee on Law, Administration and Finance.  These comments were further refined through an ongoing dialogue between ICLAFI and the International Committee on Archaeological Heritage Management (ICAHM). 

Attached are the final products of the ICOMOS engagement of the consultation process, including a cover letter and policy paper from ICOMOS entitled "Safeguarding Consultation Letter" addressing the draft Environmental and Social Framework documents released July 30, 2014; a paper entitled "Complying with and Furthering the Objectives of the World Heritage Convention in Regard to World Bank Document ESS" prepared by ICAHM which is an appendix to the above-referenced letter; 3) a document reflecting proposed wording changes to the cultural heritage standard (ESS8); and 4) a document reflecting proposed wording changes to ESS1, 7 and 10.  ICOMOS also acknowledges and appreciates its collaboration in this process with the Society for American Archaeology in this process.

Those participating in the consultation process also reported that it highlighted possible avenues for development by ICOMOS itself.  This could include increasing the capacity of National Committees in affected areas to participate and monitor Environmental Impact Assessment processes to assure they consider all direct, indirect and cumulative project-specific impacts on cultural heritage  and developing and implementing appropriate measures to address impacts. The need for early inclusion of qualified cultural heritage experts on EIA teams involved in the process of preparing development projects and advocating for integrating cultural heritage into the development process through Strategic Environmental Assessment (SEA) and other comprehensive planning processes would also be worthy of more ICOMOS attentoin.  Finally, we found that ICOMOS should become more involved in the International Association for Impact Assessment (IAIA), specifically in its Cultural Heritage Section.  Measures such as these would better equip ICOMOS and its national and scientific committees to be full partners with the World Bank as they begin to operationalize these new guidelines.

World Bank Consultations website 

♦ World Bank Draft ESS-8 Cultural Heritage - Final (Word document)
♦ Safeguarding Consultation Letter (PDF)
♦ ICAHM Comments WB Safeguarding Archaelogical Materials (PDF)
♦ ESS 1, 7 and 10 (Word document)