June 2, 2006
President Luis Moreno
Inter-American Development Bank
1300 New York Avenue, NW
Washington, DC 20577
Dear President Moreno:
We are pleased that the IDB is finally exercising its contractual right with TGP and Pluspetrol in moving forward with the audit. “The IDB will have the right, as part of the legal agreement [with TGP and Pluspetrol], to have an independent environmental, health, and safety audit performed, if warranted” (ESIR, 8.3, 8.19(viii)). “TGP and Pluspetrol will…[have] an annual environmental and social audit performed by an objective independent group during the operation phase of the Camisea project and [make] the results of such audit available to the public” (ESIR, 8.19(ii)[b]).
It is our understanding that Peruvian civil society organizations and indigenous federations have called for the involvement of the Netherlands Commission for Environmental Impact Assessment (NCEIA) and/or the International Network for Environmental Compliance and Enforcement (INECE) to help set up, design and oversee the audit process. We fully support and endorse this position. The NCEIA and INECE have the type of unimpeachable independence and credibility that is necessary to restore integrity to this project and bring stakeholders together on an agreed path forward. The NCEIA for example is not just an environmental consulting firm; rather it is a quasi-governmental agency with the international standing to, among other options, convene a working group of high-level eminent experts who could support the design, implementation and supervision of the audit. The NCEIA has been providing institutional support to the World Bank, OECD/DAC and the Convention of Biological Diversity for several years. Similarly, the INECE (founded by the US and Dutch environmental agencies, with support from the United Nations Environment Program, the World Bank, the European Commission, Environment Canada and the Organization for Economic Co-operation and Development) can also convene a working group of eminent, independent experts. Like Peruvian civil society organizations, we believe enlisting the NCEIA, the INECE, or both in the Camisea audit is essential to ensure that we move past the stalemate of widely differing interpretations of the environmental and social aspects of this project between the IDB and civil society.
The involvement of the Dutch Commission would require the direct invitation of the Peruvian government or the IDB, access to all the documents and field work sites, a commitment that its reports will be transparent and accessible to all, as well as a commitment that its recommendations will have weight. IDB staff has given the impression that the involvement of the NCEIA would not be feasible, but have never provided an adequate explanation as to why, nor why the aforementioned conditions can or should not be met.
It should be noted that in the last few years the World Bank has adopted, as standard practice, the establishment of “International Advisory Groups” for their high-risk projects such as the Chad-Cameroon oil pipeline and the Nam Theun 2 hydropower dam, from the beginning of the project cycle. This is qualitatively different and separate from the consulting firms of the Bank and companies – and in sharp contrast to the IDB’s practice of employing from a standard pool of ‘independent’ consulting firms.
This audit is an important opportunity to move all parties forward and provide a plan of action to which we can all subscribe. If the IDB instead employs yet another standard consulting firm and decides not to seek the involvement of the NCEIA or the INECE, the process will lack credibility with key stakeholders. This route would not be acceptable, nor would it serve the institutional interests of the IDB. We hope the IDB can use this opportunity to seek the support of the NCEIA and the INECE and embark on a process in which all parties can have faith.
Sincerely,
Maria Lya Ramos, Amazon Watch, [email protected]
Aaron Goldzimer, Environmental Defense, [email protected]
Ian Gary, Oxfam America, [email protected]
Lina Barrera, Conservation International, [email protected]
Cc:
Mr. Eugenio Diaz Bonilla
Mr. Havelock Brewster
Mr. Giorgio Leccesi
Mr. Luis Consenza Jimenez
Mr. Jorge Crespo Velasco
Mr. Rogerio Studart
Mr. Charles Philip Bassett
Mr. Jaime A. Pinto
Mr. Agustin Garcia-Lopez
Mr. Luis Echeverri
Mr. Hector Elias Morales
Ms. Adina Mercedes Bastidas Castillo
