3. Environmental reviews
JBIC Guidelines for Confirmation of Environmental and Social Considerations

Here are JBIC's answers to Frequently Asked Questions (FAQs) about the Environmental Guidelines.


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3.1Q. Do the Environmental Guidelines require compliance with international standards in addition to acts, regulations and standards on environmental and social considerations stipulated by the government (including local governments) of the country in which a project is located?
3.2Q. What are the World Bank Safeguard Policies and the IFC Performance Standards, of which JBIC ascertains whether a project meets the relevant aspects?
3.3Q. What kinds of international standards and good practices could be used as a reference for environmental and social considerations in the Environmental Guidelines?
3.4Q. When acts, regulations and standards on social and environmental considerations established by the government (including local governments) of the country in which the project is located are lax compared with their international counterparts, how does JBIC respond?
3.5Q. How are the results of environmental reviews being used in the decision-making of JBIC and in the agreements of loan and investment?
3.6Q. The provisory clause of Part 1, Section 6 (1) of the Environmental Guidelines states that "in exceptional cases where, given the nature of the project, documents necessary for environmental reviews are not available at the time that a decision on the funding must be made, JBIC may make a decision on the funding on the condition that it will undertake the environmental reviews after decision making." In what case and in what procedures is this clause applied?
3.7Q. What are review procedures for Category FI?
3.8Q. The Environmental Guidelines set forth, "consultation with stakeholders, such as local residents, must take place after sufficient information has been disclosed. Records, etc. of such consultations must be prepared." (Section 2, Part 2) Will JBIC confirm whether consultations have taken place?
3.9Q. What issues will be considered with regard to gender, children's rights, HIV/AIDS and other communicative diseases by JBIC under the Environmental Guidelines?
3.10Q. In Part 2, Section 1. (3), "community health, safety, and security" is listed as one issue of the scope of the project whose impact should be considered. What do you confirm, in particular, regarding the use of security personnel in this respect?
3.11Q. In Section 1. (3) of Part 2 of the Environmental Guidelines, "While air could include greenhouse gases (GHG), specific requirements for environmental and social considerations on this issue are to be made based on the Common Approaches". What provisions exist in the Common Approaches? Let us also know about the state of standards of international financial institutions used as benchmarks.
3.12Q. There is a phrase "associated facilities" in Part 2, Section 1. (3) of the Environmental Guidelines, what facilities are does it refer to?
3.13Q. In Part 2, Section 1 (6) of the Environmental Guidelines of JBIC, there is a clause which states "critical natural habitats including critical forests areas" and "natural habitats including natural forests." Please identify what areas they are. Also, please provide specific examples of "significant conversion or degradation."
3.14Q. When the project involves involuntary resettlement, how does JBIC confirm the consent of the local inhabitants?
3.15Q. In Section 1. (7) of Part 2 of the Environmental Guidelines, there is a clause which states "It is desirable that the resettlement action plan includes elements required in the standard of international financial institution which JBIC benchmarks." Specifically, are the elements required by which standard?
3.16Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states "When a project may have adverse impact on indigenous peoples', various rights in relation to land and resources, such rights must be respected in accordance with the spirit of the relevant international declarations and treaties, and free, prior, and informed consents must be obtained." What are the international declarations and treaties relating to indigenous peoples?
3.17Q. Section 1. (8) of Part 2 of the Environmental Guidelines set forth that when a project may have any adverse impact on the rights of indigenous peoples, "free, prior, and informed consents must be obtained." What kinds of procedures and consent are required?
3.18Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states "It is desirable that the indigenous peoples plan include the elements required in the standard of international financial institutions which JBIC benchmarks." Specifically, what standards are required for the elements?
3.19Q. In the case that a project has a significant impact on the residents living around the project site, should JBIC listen to the voices of potentially affected residents in a field study conducted at the project site as a part of its environmental reviews?

 

3.1Q. Do the Environmental Guidelines require compliance with international standards in addition to acts, regulations and standards on environmental and social considerations stipulated by the government (including local governments) of the country in which a project is located?

A. JBIC examines compliance with environmental laws and standards of the host nation and local governments concerned in confirming environmental and social considerations. JBIC also ascertains whether a project meets the following standards.

  • World Bank Safeguard Policies or IFC Performance Standards; or
  • IFC Performance Standards in the cases of (i) limited recourse or non-recourse project finance projects, (ii) structured financing transactions that share characteristics with project finance, (iii) other financial institutions who are forming a significant part of the project applying IFC Performance Standards, and (iv) other projects recognized as appropriate.

In addition, if there is a relevant section of the Environmental, Health, and Safety Guidelines (EHS Guidelines) of the World Bank Group, JBIC will confirm whether the projects meet that section.
Where appropriate, JBIC also refers to standards established by other international financial institutions, other internationally recognized standards, and/or standards or good practices established by developed countries such as Japan as benchmarks.
However, since the natural environment, and the social and cultural background vary depending on countries and regions, it is considered not necessarily appropriate to apply a uniform standard to all the projects.

3.2Q. What are the World Bank Safeguard Policies and the IFC Performance Standards, of which JBIC ascertains whether a project meets the relevant aspects?

A. Specifically, they are as follows.

World Bank Safeguard Policies

  • Environmental Assessment (OP 4.01)
  • Natural Habitats (OP 4.04)
  • Pest Management (OP 4.09)
  • Indigenous Peoples (OP 4.10)
  • Physical Cultural Resources (OP 4.11)
  • Involuntary Resettlement (OP 4.12)
  • Forests (OP 4.36)
  • Safety of Dams (OP 4.37)
  • International Waterways (OP 7.50)
  • Projects in Disputed Areas (OP 7.60)

IFC Performance Standards

  • Assessment and Management of Environmental and Social Risk and Impacts (PS1)
  • Labor and Working Conditions (PS2)
  • Resource Efficiency and Pollution Prevention (PS3)
  • Community Health, Safety, and Security (PS4)
  • Land Acquisition and Involuntary Resettlement (PS5)
  • Biodiversity Conservation and Sustainable Management of Living Natural Resources (PS6)
  • Indigenous Peoples (PS7)
  • Cultural Heritage (PS8)

3.3Q. What kinds of international standards and good practices could be used as a reference for environmental and social considerations in the Environmental Guidelines?

A. JBIC recognizes that at present, there is no international standard that embraces all issues necessary for confirming environmental and social considerations and may be applicable throughout the world. JBIC has made reference to international treaties, the standards of international organizations other than the World Bank and IFC, standards and regulations in other advanced countries such as Japan, the U.S. and European countries(Note). Although there are many standards and good practices JBIC may turn to, specific examples are shown below.

(1) Pollution prevention/abatement

  • Regulation standards in Japan and in the U.S.
  • MARPOL Convention

(2) Natural Environment

  • World Heritage Convention
  • Ramsar Convention
  • Washington Treaty
  • The Red List of IUCN

(3) Social Environment

  • World Heritage Convention
  • Guidelines on Resettlement of DAC

(4) Specific Sectors

  • The Convention on Nuclear Safety and the relevant aspects of International Atomic Energy Agency (IAEA) standards
  • World Commission on Dams (WCD) Report, etc.

As it is difficult to enumerate all standards and good practices, including those not listed above, the Environmental Guidelines states comprehensively in Part 1. 3. (4) 3) that "Where appropriate, JBIC also refers to standards established by other international financial institutions, other internationally recognized standards, and/or standards or good practices established by developed countries such as Japan as benchmarks." If new standards are internationally established in the future, JBIC intends to use them as reference as well.
 

  1. (Note) In the Environmental Reviews of JBIC, World Bank Safeguard Policies and IFC Performance Standards are used for checking. Therefore, the Environmental Guidelines places importance on them not as "a reference" but as "meeting".

3.4Q. When acts, regulations and standards on social and environmental considerations established by the government (including local governments) of the country in which the project is located are lax compared with their international counterparts, how does JBIC respond?

A. The Environmental Guidelines sets forth in Section 3-(4) of Part I, that if after comparison with various standards and good practices such as the World Bank Safeguard Policies and IFC Performance Standards, "If JBIC believes the environmental and social considerations of the project substantially deviate from these standards and good practices, it will consult with the host governments (including local governments), borrowers, and project proponents to confirm the background and rationale for such deviation, and the measures to rectify it if necessary."
As a result of such effort, "If, as a result of its environmental reviews, JBIC judges that appropriate environmental and social considerations are not ensured, it will encourage the project proponent through the borrower to undertake appropriate environmental and social considerations." (Section 3-(5), Part 1) However, as different countries and regions have varying natural environments as well as social and cultural backgrounds, such factors must be taken into account.

3.5Q. How are the results of environmental reviews being used in the decision-making of JBIC and in the agreements of loan and investment?

A. The results of environmental reviews are used in making decisions on financing operation, for example, reflecting them in the agreement of loan and investment. As set forth in Section 6 of Part 1, JBIC is making the utmost effort to ensure that the following requirements are met through the agreements, depending on the nature and content of the project:

(1) Reporting monitoring results;
(2) Discussions with stakeholders when a problem arises;
(3) Agreements with the host government and others when they have an important role to play; and
(4) Conditions leading to the suspension of disbursements and other actions.

3.6Q. The provisory clause of Part 1, Section 6 (1) of the Environmental Guidelines states that "in exceptional cases where, given the nature of the project, documents necessary for environmental reviews are not available at the time that a decision on the funding must be made, JBIC may make a decision on the funding on the condition that it will undertake the environmental reviews after decision making." In what case and in what procedures is this clause applied?

A. Applicable examples of projects considered are acquisition of rights and interests in the early stages of natural resource development projects, or equity participation projects in which decision making is required in the stages where specific use of funds is not determined.
In these cases, JBIC will classify the categories of the project being planned based on the information obtained from project proponents. If the project is classified as Category A or B, environmental and social considerations are ascertained in the following processes.

[Before Decision Making]
Although sufficient materials are not obtainable for conducing environmental reviews, arrangements on environmental and social considerations are ascertained to the extent possible based on the information obtained from the project proponents. The information used for confirmation is disclosed to the public to the extent possible in addition to the information written in the screening form, while taking account of confidential matters in business. Also, even if it is a temporary result, the results of confirmation of environmental and social considerations are made public at the website immediately after decision making.
JBIC will explicitly stipulate in the loan agreement that development will not be made in the project until environmental reviews are conducted.

[After Decision Making]
When documents necessary for environmental reviews such as Environmental and Social Impact Assessment (ESIA) Report are obtained, usual environmental reviews are conducted. The ESIA report used for environmental reviews and the results of environmental reviews are made public at the website as usual.
In the case that appropriate environmental and social considerations are not confirmed in the above environmental reviews, JBIC suspends loan disbursement and demands prepayment to the borrowers based on the loan agreement.

3.7Q. What are review procedures for Category FI?

A. To ensure that practically the same level of environmental and social considerations are made for Category FI projects as for projects in other categories, the Environmental Guidelines set forth in Section 4-(3), Part 1, "JBIC checks through the financial intermediary etc. to see whether appropriate environmental and social considerations as stated in the Guidelines are ensured for projects in this category."

Specific steps may include:
(1) Identifying the implementation capacity of the financial intermediary for confirming the appropriateness of environmental and social considerations and delegating to it such confirmation as stated in the Environmental Guidelines;
(2) Requiring the financial intermediary to employ consultants to strengthen the institutional capacity for confirming the appropriateness of environmental and social considerations, if JBIC determines that it does not have a sufficient capacity for this task. Alternatively, once each sub-project is specified, JBIC will confirm the environmental and social considerations; and
(3) Making Category A sub-projects ineligible for funding

It is difficult to determine in advance what steps are most appropriate and JBIC has chosen to indicate the basic principles above. The Environmental Guidelines stipulates that the results of environmental reviews for Category FI projects should be published on the JBIC website at the signing of the financing agreement.

3.8Q. The Environmental Guidelines set forth, "consultation with stakeholders, such as local residents, must take place after sufficient information has been disclosed. Records, etc. of such consultations must be prepared." (Section 2, Part 2) Will JBIC confirm whether consultations have taken place?

A. The Environmental Guidelines acknowledge the significance of dialogue with the local residents to ensure appropriate environmental and social considerations.
In conducting environmental reviews, the Environmental Guidelines set forth in Section 3-(3), Part 1, "For Category A projects, JBIC checks the extent of stakeholder participation and information disclosure being undertaken for the project."
The Guidelines further provide, "JBIC may conduct surveys of proposed project sites by dispatching environmental experts to confirm environmental and social considerations if necessary." JBIC will thus confirm consultations with stakeholders.

3.9Q. What issues will be considered with regard to gender, children's rights, HIV/AIDS and other communicative diseases by JBIC under the Environmental Guidelines?

A. As the Environmental Guidelines are designed to assess natural and social environmental impacts of individual projects, JBIC will confirm the following issues for which consideration at the individual project level is thought to be appropriate, such as gender, children's rights, HIV/AIDS and other communicable diseases.
Firstly, for example, confirming gender consideration means that if the project involves resettlement, JBIC will confirm whether a mechanism is in place for providing adequate respect for women's opinions and views and not excluding them.
Confirming considerations for children's rights means that in the above project, JBIC will confirm whether there are adequate preparations for schools and healthcare facilities for children at the relocated site.
Confirming considerations for communicable diseases such as HIV/AIDS means that if the project involves large civil works and needs to set up a camp for workers, JBIC will confirm whether workers will receive adequate guidance on communicable diseases.
Regarding the question over the scope of checks in these areas, since there is a great diversity in the nature of the projects, it is difficult to apply a uniform rule, and it is thus more appropriate to consider it for specific projects.
Also, as a public agency, JBIC feels it should pay due respect to charters on human rights. In view of their diverse provisions and varying ratification status in different countries, the Environmental Guidelines touched on them in the preface rather without making specific reference to them in the main text.

3.10Q. In Part 2, Section 1. (3), "community health, safety, and security" is listed as one issue of the scope of the project whose impact should be considered. What do you confirm, in particular, regarding the use of security personnel in this respect?

A. In using security personnel, the Checklists stipulated "Are appropriate measures being taken to ensure that security personnel involved in the project do not violate safety of other individuals involved, or local residents?" as an item to be confirmed.
IFC Performance Standard 4 requires more specifically that the project proponents should meet appropriately the following items, and it is our understanding that the World Bank Safeguard Policy is being considered for revision in a similar manner.

1) When the client retains direct or contracted workers to provide security,

  • Client assess risks posed by its security arrangements to those within and outside the project site.
  • In making such arrangements, the client will be guided by the principles of proportionality and good international practice in relation to hiring, rules of conduct, training, equipping, and monitoring of such workers, and by applicable law.
  • Client will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force (and where applicable, firearms), and appropriate conduct toward workers and Affected Communities; and require them to act within the applicable law.
  • Client will provide a grievance mechanism for Affected Communities to express concerns about the security arrangements and acts of security personnel.

2) When the client uses government security personnel deployed to provide security services,

  • Client will seek to ensure that security personnel will act in a manner consistent above.
  • Client will encourage the relevant public authorities to disclose the security arrangements for the client's facilities to the public, subject to overriding security concerns.

3.11Q. In Section 1. (3) of Part 2 of the Environmental Guidelines, "While air could include greenhouse gases (GHG), specific requirements for environmental and social considerations on this issue are to be made based on the Common Approaches". What provisions exist in the Common Approaches? Let us also know about the state of standards of international financial institutions used as benchmarks.

A. (1) Common Approaches
GHG is referred to in the Common Approaches as an example of "environmental impacts" of environmental and social impacts to be specified in the passage "generation of significant air emissions, including greenhouse gas emissions" (IV CLASSIFICATION, Paragraph 10). However, our understanding is that this does not require additional measures with respect to environmental reviews, monitoring and information disclosure.
On the other hand, the Common Approaches set forth that OECD members shall continue to build a body of experience on the application of the Common Approaches through regular reporting and exchanges of information, and as part of this proposition, the Common Approaches requires reporting to the OECD on projected annual emissions during the operations phase of projects, where such emissions are projected to be in excess of 25,000 tonnes CO2-equivalent annually and where the member is in possession of necessary information, e.g. via ESIA report (VIII REPORTING AND MONITORING OF THE RECOMMENDATION, paragraph 42).
The Common Approaches also list support for thermal power plants as one of the issues that requires further consideration, and this will go further based on reporting of any actions taken to avoid, minimize and/or offset CO2 emissions for all new thermal power projects exceeding 700g/kWh emission intensity (Paragraph 43).
At present (March 2015), OECD is further considering and building a body of experience with respect to the methodologies of accounting GHG emissions and reporting or support for thermal power plants based on the above paragraphs. In the case that the Common Approaches are revised based on such considerations, JBIC intends to conduct operations in accordance with the Common Approaches.

(2) International Standards used as benchmarks
IFC Performance Standard 3, which is one of the international standards used as a benchmark, makes the following requirements for project proponents with respect to GHG emissions.

  • Client will consider alternatives and implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions during the design and operation of the project (Paragraph 7).
  • For projects that are expected to or currently produce more than 25,000 tonnes of CO2-equivalent annually, the client will quantify direct emissions from the facilities owned or controlled within the physical project boundary, as well as indirect emissions associated with the off-site production of energy used by the project. Quantification of GHG emissions will be conducted by the client annually in accordance with internationally recognized methodologies and good practice.

Although the World Bank Safeguard Policies does not set forth requirements for GHG emissions, our understanding is that it is under consideration for revision in the similar manner as in IFC Performance Standards.

3.12Q. There is a phrase "associated facilities" in Part 2, Section 1. (3) of the Environmental Guidelines, what facilities are does it refer to?

A. The "associated facilities" has the same meaning as "associated facilities" defined in the Common Approaches.
The associated facilities are those facilities that are not a component of the project but that would not be constructed or expanded if the project did not exist and on whose existence the viability of the project depends.
Such facilities may be funded, owned, managed, constructed and operated by the buyer and/or project sponsor or separately from the project. When undertaking a review of associated facilities, JBIC should, to a reasonable extent, assess the potential environmental and social impacts of associated facilities, taking into account the timing and location of their construction.

3.13Q. In Part 2, Section 1 (6) of the Environmental Guidelines of JBIC, there is a clause which states "critical natural habitats including critical forests areas" and "natural habitats including natural forests." Please identify what areas they are. Also, please provide specific examples of "significant conversion or degradation."

A. Regarding "critical natural habitats including critical forests areas," "natural habitats including natural forests" and "significant conversion or degradation," the following may be considered based on international standards used for benchmarks.

[See World Bank Safeguard Policies (OP4.04 Annex A and OP4.36 Annex A)]
1) Critical natural habitats including critical forests

  • Existing protected areas and areas officially proposed by governments as protected areas, areas initially recognized as protected by traditional local communities, and sites that maintain conditions vital for the viability of these protected areas.
  • Other examples similar to the regions specified above, may include areas recognized by traditional local communities as having the same level of importance as protected areas, areas with known high suitability for bio-diversity conservation, and sites that are critical for rare, vulnerable, migratory, or endangered species.
  • Critical forest areas are the forest areas that qualify as critical natural habitats indicated above.

2) Natural habitats including natural forests

  • Land and water areas where (i) the ecosystems bio-logical communities are formed largely by native plant and animal species, and (ii) human activity has not essentially modified the area's primary ecological functions
  • Natural forests are forest lands and associated waterways that qualify as natural habitats indicated above.

3) Significant conversion

  • The concept of significant conversion is the elimination or severe diminution of the integrity of a critical or other natural habitat caused by a major, long-term change in land or water use.

4) Significant degradation

  • The concept of degradation is modification of a critical or other natural habitat that substantially reduces the habitat's ability to maintain viable populations of its native species.

[See IFC Performance Standard 6 (paragraph 13 and 16 and footnote 7)]
1) Critical Habitats (including critical forests)
Critical habitats are areas with high biodiversity value, and areas including the following habitats

  • habitat of significant importance to Critically Endangered and/or Endangered species;
  • habitat of significant importance to endemic and/or restricted-range species;
  • habitat supporting globally significant concentrations of migratory species and/or congregatory species;
  • highly threatened and/or unique ecosystems
  • areas associated with key evolutionary processes.

2) Natural Habitats (including natural forests)

  • Areas composed of viable assemblages of plant and/or animal species of largely native origin,
  • Areas where human activity has not essentially modified an area's primary ecological functions and species composition

3) Significant conversion or degradation

  • the elimination or severe diminution of the integrity of a habitat caused by a major and/or long-term change in land or water use
  • a modification that substantially minimizes the habitat's ability to maintain viable populations of its native species.

3.14Q. When the project involves involuntary resettlement, how does JBIC confirm the consent of the local inhabitants?

A. As set forth in Section 2 of Part 2, the Environmental Guidelines place a premium on appropriate consultations with local residents. JBIC confirms, on the basis of the information provided by the borrower, whether the consensus has been reached among the residents through the appropriate consultation process. JBIC will make use of useful information provided not only by the borrower but also by the host government, private financial institutions cofinancing the project, and other stakeholders. As the Environmental Guidelines stipulate in Section 3-(3) of Part 1, "JBIC may conduct surveys of proposed project sites by dispatching environmental experts to confirm environmental and social considerations if necessary," and it also confirms whether consultations with residents have been conducted properly.
In addition, as stated in the Environmental Guidelines, JBIC also confirm loss of means of livelihood in the same way.

3.15Q. In Section 1. (7) of Part 2 of the Environmental Guidelines, there is a clause which states "It is desirable that the resettlement action plan includes elements required in the standard of international financial institution which JBIC benchmarks." Specifically, are the elements required by which standard?

A. The elements required are: OP4.12 Annex A of the World Bank Safeguard Policies, if the World Bank Safeguard Policies are used as benchmarks. And Guidance Note(Note)5 Annex A of IFC Performance Standards, if the IFC Performance Standards are used as benchmarks. Specifically, confirm websites of the World Bank and IFC.

  1. (Note) Guidance for ensuring conformity with IFC Performance Standards
The main points in OP4.12 Annex A are as follows.
  • Results of socioeconomic studies on resettlement
  • Definition of resettlers and eligibility for compensation and other support
  • Valuation method of losses and the method of compensation for losses
  • Specific content of compensation and support
  • Housing, infrastructure, and social services provided by public facilities in the resettled site
  • Participation in the resettlement process by resettlers and their community
  • Grievance procedures
  • Implementation schedule
  • Cost estimate and budget plan
  • The outline of monitoring and ex-post evaluation

IFC Guidance Note Annex A generally set forth similar points

3.16Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states "When a project may have adverse impact on indigenous peoples', various rights in relation to land and resources, such rights must be respected in accordance with the spirit of the relevant international declarations and treaties, and free, prior, and informed consents must be obtained." What are the international declarations and treaties relating to indigenous peoples?

A. The following declaration and convention correspond to the international declarations and treaties relating to indigenous peoples. These are international documents pertaining to the rights of indigenous peoples. However, they are not international standards such as the World Bank Safeguard Policies, with which JBIC Guidelines require conformity.

  • United Nations Declaration on the Rights of Indigenous Peoples
  • Convention concerning Indigenous and Tribal Peoples in Independent Countries (International Labor Organization (ILO) Convention No.169)

3.17Q. Section 1. (8) of Part 2 of the Environmental Guidelines set forth that when a project may have any adverse impact on the rights of indigenous peoples, "free, prior, and informed consents must be obtained." What kinds of procedures and consent are required?

A. When a project may have adverse impacts on indigenous peoples, sufficient consultations with them or their participation procedures must be taken based on information disclosure in a similar manner as in the case of ordinary local residents (in Part 2 of the Environmental Guidelines, this point is set forth in Section 1. (5)). On the other hand, regarding the various rights that indigenous peoples have on their land and resources, "Free, Prior, and Informed Consent (FPIC))" is required in addition to such ordinary procedures in light of their vulnerability.
Although there is no universally accepted definition of FPIC, we consider that it will be established through good faith negotiations between the project proponents and the affected communities of indigenous peoples, in addition to usual consultations and procedures for participation. What is called "consent" here does not necessarily require unanimity by all the participants and may be achieved even when individuals or groups within the community explicitly disagree.
FPIC is required in the circumstances that the inherent rights of indigenous peoples are affected, as shown below.

  • The circumstance that a project site is located on the lands traditionally owned and customarily used, and that when natural resources are commercially developed on such land, adverse impact is expected
  • The circumstance that indigenous peoples are relocated from communally held lands and their natural resources
  • The circumstance that a project may significantly impacts on their critical cultural heritage

This concept is in line with the interpretation of FPIC in IFC Performance Standard 7, and our understanding is that the World Bank is under consideration toward the revision of its Safeguard Policies in this manner.

3.18Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states "It is desirable that the indigenous peoples plan include the elements required in the standard of international financial institutions which JBIC benchmarks." Specifically, what standards are required for the elements?

A. In the case that conformity with the World Bank Safeguard Policies is required to be confirmed, it points to the content of OP4.10 Annex B of the World Bank, and that conformity with IFC Performance Standards is required to be confirmed, it points to the content of Guidance Note(note) 7 Annex A. Specifically, check websites of the World Bank and IFC.

  1. (Note) Guidance for compliance with IFC Performance Standards
The main points in OP4.10 Annex B are as follows.
  • A summary of the social assessment focused on indigenous peoples
  • A summary of results of the free, prior, and informed consultations with the affected indigenous peoples'communities
  • An action plan of measures to ensure that the indigenous peoples receive social and economic benefits
  • An appropriate action plan of measures to avoid, minimize, mitigate, or compensate for these adverse effects
  • The cost estimates and financing plan for the IPP
  • Grievance procedures
  • The outline of the monitoring and ex post evaluation mechanisms

IFC Guidance Note 7 Annex A also set forth generally similar items.

3.19Q. In the case that a project has a significant impact on the residents living around the project site, should JBIC listen to the voices of potentially affected residents in a field study conducted at the project site as a part of its environmental reviews?

A. The project proponent is the main actor conducting environmental and social considerations in the project, and JBIC is in the position of confirming its actions for considerations. It is unequivocally the project proponent that responds to stakeholders, including the residents affected by the project. JBIC confirms through environmental reviews whether appropriate response is made.
As part of such confirmation procedure, JBIC may make a case-by-case judgment and listen to the voices of the affected residents when recognizing it necessary, in cases where a significant impact reaches the affected residents in projects that involve large-scale involuntary resettlement or areas where indigenous peoples are living around, or in cases where the stakeholders directly send their opinions to JBIC.