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This compliance assessment analyzes the extent to which Oleoducto de Crudos Pesados Ecuador S.A. (OCP) Environmental Impact Assessment (EIA) complies with the World Bank Group’s (WBG’s) four applicable social and environmental policies 1 . A field trip to Ecuador was made to gather findings; interviews were conducted in the field and elsewhere; and a desk review of relevant documentation available was performed. This paper begins with the WBG’s Operational Policy (OP) 4.01: Environmental Assessment Policy. The paramount Analysis of Alternatives
needed to ensure the selection of the least impact route is inadequate in the EIA. The pipeline route was chosen before the Terms of Reference for the EIA were set, and without adequate public consultation, especially of affected people. The EIA does not evaluate the main impacts
of OCP, namely those imposed by a doubling of oil production in the Amazon. Thus, the most important tenets of the WBG’s OP 4.01 were not complied with. The EIA does not comply with OP 4.04: Natural Habitats Policy because OCP violates the protected area financed by the Global Environment Facility and six other protected areas. OP 4.04 prohibits degradation of such critical natural habitats. The EIA fails to address effective means of minimizing the loss of other natural habitats and the need to create offsets. OP 4.12: Involuntary Resettlement Policy requires resettlement plans and an equitable compensation process, which are absent in the EIA. Finally, OD 4.20: Indigenous Peoples Policy requires an analysis of the OCP’s impacts on vulnerable ethnic minorities and AfroEcuadorians, and an indigenous peoples’ development plan, which are lacking in the EIA. OCP’s non-compliance with each of these four policies is documented and explained.
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