November 1994 - World Bank Documents

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19829 November 1994 . - LATEN Dissemination Note # 11 People's Participation in Environmental Assessment in Latin America: Best Practices November 1994 William L. Partridge The World Bank Latin America Technical Department Environment Unit Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

Transcript of November 1994 - World Bank Documents

19829November 1994

. - LATEN Dissemination Note # 11

People's Participation in EnvironmentalAssessment in Latin America:Best Practices

November 1994

William L. Partridge

The World BankLatin America Technical DepartmentEnvironment Unit

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LATEN Dissemination Note # 11

People's Participation in EnvironmentalAssessment in Latin America: Best Practices

November 1994

William L. Partridge

The World BankLatin America Technical Department

Environment Unit

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Contents

Foreword ................... vIntroduction ................... 1Background ................... . 2The Role of the World Bank ............................ 3Popular Participation in EA in LAC: Results of the Review .... ..... 4Significance of the Country Legal Framework .................. 5Institutional Framework of Public Participation ................. 6Socia Actors Involved in EA Consultations ................... 9Phases of Participation in EA Work ........................ 10Social Mechanisms Utilized to Facilitate Participation ........... .. 12Principal Results of Participation .......................... 18Best Practices in Popular Participation in EA Work .... .......... 19

Boxes

1. Brazil-Extractive Reserves, FY95 ...................... 132. Eastern Caribbean-Solid Waste Management, FY95 ......... .. 143. Ecuador-Lower Guayas Flood Control Project, FY91 .......... 154. Colombia-Energy Sector Assistance, FY97 ................ 16S. Brazil Espirito Santo Water Project, FY94 .................. 17

Flgures

1. Improvements Due to Public Participation .................. 18

Annexes

A. Participation in 28 Projects With Completed EAs, Fiscal 1989-94 ... 25B. Phases of Participation in 26 EAs ....................... 27

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Foreword

The Dissemination Note Series of the Latin America and theCaribbean Region's Environment Unit (LAITEN) seeks to share the results ofour analytical and operational work, both completed or in progress. Throughthis series, we present the preliminary findings of larger studies in anabbreviated form, as well as describe "best practices" with regard to majorenvironmental issues currently confronting LAC countries.

In most cases, these notes represent 'work in progress' and as suchhave not been subject to either substantial internal review or editing.Therefore the findings, interpretations, and conclusions expressed in thesenotes are entirely those of the authors and should not be attributed to theWorld Bank, members of its Board of Executive Directors, or the countriesthey represent.

Since one of the key objectives of these notes is to stimulate debate,we would encourage readers to contact the authors directly should they haveany comments or suggestions as to how the analyses could be improved.

William L. PartridgeUnit Chief

Environment UnitLatin America and the Caribbean Region

The World Bank

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PEOPLE'S PARTICIPATION IN ENVIRONMENTAL ASSESSMIENTIN LATIN AMERICA: BEST PRACTICES

William L. Partridge'

Introduction

1. Genuine participation in the development process on the part of beneficiaries andother affected people is critical to sound project design, effective implementation,efficient management and sustainability.2 Nowhere is this more evident than inenvironmental assessment (EA). People's participation in EA of developmentinvestments is recognized as key to the identification of environmental impacts as well asto the design of adequate mitigation measures proposed to address them. The Bank hasmade public participation an integral element of its EA policy since 1989.3 Yet for theBank and many borrower governments in LAC, environmental nongovernmentalorganizations (NGOs) and the general public, popular participation in decisionmalingabout future development investments and their environmental impacts is a newexperience.

2. To learn the lessons of the LAC region's early experience with fostering people'sparticipation in EA, the LATEN division undertook a review of all EAs completed fromfiscal 1989 through fiscal 1994. This report contains the results of that review togetherwith recommendations regarding best practices that should be utilized in the future toimprove the degree of popular participation in EA work for proposed Bank investments.

1. The LATEN team which conducted the review upon which this paper is based was composed ofWilfliam Partridge, Maria Clara Mejia, Teresa Serra and Carmen Hess.

2. Wapenhans, W. 'Effective Implementation: Key to Development Impact,' July 24, 1992. See also'The World Bank and Participation: Report of the Learming Group on Participatory Development,'May 10, 1994.

3. EA guidelines for the Bank were first expressed in OD 4.00, Annex A in 1989 which were replacedby OD 4.01 Enuronmental Assessment in October 1991. The Bank Enuronmnental AssessmentSourcebook Update, dated October 1993, distinguishes consultation from participation by the degreeto which those involved influence or share in decisionmaking. This paper initially treats the two assides of the same coin, but adopts the distinction for analytic purposes in the end.

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3. Important progress has been made in the last few years to strengthen the role ofpublic consultation and participation in EA work, yet there is still a long way to go tofully implement the Bank's policies on popular participation. To place the progressmade in perspective it is useful to consider the following context.

Background

4. The quality of the human environment and rational management of scarce naturalresources have leaped to the top of the development agenda in Latin America in the1990s. But over the previous four decades, environmental problems ranked low in anylist of economic development priorities. Following the collapse in export markets for rawmaterials during the Great Depression, Latin American countries concentrated on rapidindustrialization led by public sector investment throughout the 1940-1960 period,coupled with declines in investment in rural production. Throughout the period millionsof people migrated from the countryside to the cities, fleeing conditions of rural poverty,to join the urban workforce. Simultaneously, a revolution in public health conditions inestablished urban areas resulted, for the first time, in the existing urban populationsreplicating themselves. Governments struggled to contend with this increasing pressureon urban areas through further expansion of investment in public sector enterprises andservices.

5. Despite rising costs, Latin American governments continued high levels of publicsector development investment during the 1970s. These conditions contributed to aneconomic crisis, marked by a cruel combination of deeper dependance on public sectorspending by urban middle and working classes simultaneously with a relative shrinkageof public sector resources. One result was the most dramatic widening of the century inthe income gap between rich and poor. The capacity of the public sector to redressaccumulated environmental degradation as well as the environmental impacts ofdeepening poverty collapsed by the end of the 1970s. Structural adjustments of the1980s brought with them not only a restoration of economic growth, but a marked shiftin people's tiinking about the role of government in the economy. This was combinedwith growing awareness of the severity of decline in the quality of the environment. Yetfinancial constraints have in most cases limited action until now.

6. After a decade of macroeconomic adjustment, Latin America has emerged out ofthe late 1980s with steadily growing economies, increasingly led by the private sector,accompanied by stronger reforms in the public sector. As government progressivelyfiees the private sector to expand and decentralizes public sector budgetary andadministrative control to local authorities, it has become evident that accountability ofgovernment to the governed has emerged as a central public sector issue. Accountabilityconcerning the quality of the environment has grown exponentially in recent years. TheRio Summit in 1992 signalled the crystallization of environmental concerns in LatinAmerica, which are today at the top of the international development agenda and areexpected to remain there well into the next century.

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The Role of the World Bank

7. The Bank responded to the new development agenda by shifting majorinstitutional and intellectual resources to environmentally sustainable investment. First,the Bank reorganized itself to create Regional Environmental Divisions/Units (REDs) innewly formed Technical Departments (TDs) to support the Country Departments (CDs)responsible for management of the lending portfolio, together with a centralEnvironmental Department (ENV) to guide environmental policy research. Second, theBank strengthened its procedures for managing environmental issues stemming from itsinvestment activities by issuing Operational Directives that established screening andassessment mechanisms for the entire lending portfolio. The objective of theseprocedures is to enhance environmentally positive impacts and mitigate environmentallynegative impacts of development investments. The Operational Directive instructs staffto ensure that the views of affected groups and local nongovernmental organizations(NGOs) are taken fully into account in the preparation of EAs. The REDs and ENVwere staffed with social scientists adept at working with different social groups, NGOs,local governments and other social actors.

8. Together these initiatives introduced a new era in Bank operations. Eachproposed lending operation is screened during preparation for potential environmentalimpacts by environmental experts. A course of action to assess those impacts and designmeasures to mitigate them is then agreed with the borrower. Once the project isappraised, the final project proposal, including legal agreements, is reviewed and clearedby the Regional Environment Division/Unit. Public consultation and participation is oneof the key considerations in evaluating the adequacy of EA documentation for a giveninvestment proposal.

9. OD 4.01 specifies that public consultations should occur at two key junctures:

(a) Scoping. When the scope of the EA is being defined, participation ofaffected communities, NGOs and other stakeholders can enhanceidentification of likely environmental issues and can strengthen the designof terms of reference (TOR) for the EA; and

(b) Draft EA Review. Once a draft EA document is ready for review by thepublic, participation of relevant stakeholders can assist in selecting sociallysustainable investment alternatives and environmental mitigation measuresas well as enhance chances for successful implementation.

10. For meaningful participation to occur at both junctures, it is important thatrelevant infornation about the proposed investment be made available in a timely mannerto participants prior to consultation. For the initial consultation at the scoping stage, theinformation should include a summary of the project description and objectives togetherwith a preliminary indication of the potential adverse effects of the project. For the

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review of the draft EA, a summary of the report's main findings and recommendationsshould be made available for discussion as well as the full report for those who desiregreater detail.

11. Popular participation in the preparation of EAs also serves the purposes ofidentification of the nature and magnitude of social or environmental impacts and ofensuring the adequacy of proposed mitigation measures, especially to those directlyaffected by the investment. Participation does not reduce the decisionmaidngresponsibility or authority of the borrower, but is a valuable way to increase the amountof information available to decisionmakers, to obtain feedback on the social andenvironmental compatibility of proposed investments, to identify likely mechanisms forsusta1ning environmental policies and programs and to facilitate cooperation inimplementing environmental measures and management plans.

Popular Participation in EA in LAC: Results of the Review

12. The EA documents for all LAC projects for which EAs were completed duringthe fiscal 1989-94 period were reviewed by LATEN to learn from experiences withpublic participation. A total of 28 projects were reviewed (see Annex A). Fifteenprojects were classified "A" and thirteen were classified "B" for the purposes of Bankenvironmental review. Projects that fall in the first class are those in which significantand diverse negative environmental impacts are expected, and which call for a full EA tobe completed. Projects with more limited, but nevertheless important environmentalimpacts, are considered "B" projects. The latter call for environmental studies whichidentify potential problems and explain the mitigation measures proposed for resolvingthem, but not a full EA as for "A" projects. In either event, public consultation andparticipation are important for both "A" and "B" projects.'

13. Annex A illustrates that public participation and consultation with affectedcommunities, local NGOs and local governments has intensified continually throughoutthe period reviewed. The nature of participation varies considerably over time amongthe projects reviewed, including the degree of participation, its timing in the EA process,social mechanisms used to organize participation and institutional response to the results.Therefore, a rigorous evaluation of the overall quality of public participation in EA workis not possible here.

4. Many *B projects have had full EA studies completed during project preparation. The reason forthis is that some countries require full EAs for all types of projects of a certain scale or cost,whereas the Bank classifies projects on the basis of the complexity and severity of environmentalissues associated with them.

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14. However, to structure the review the LATEN team posed the following set ofquestions:

* Had the country established a legal framework for public participation?* What were the institutional responsibility and administrative procedures for

public participation?* Which social actors were participants in the EA?* In which phases of the EA process did these actors participate?* What were the social mechanisms utilized to organize participation in the EA?* What were the principal results of participation in the EA process?

15. Information was gathered concerning each of these questions primarily from theEA documents submitted by the borrower. Where the documentation was insufficient orabsent, the review team interviewed task managers or members of the team thatconducted the EA regarding the processes of public participation utilized. The answerswe found to the above questions are discussed in the following sections

Significance of the Country Legal Framework

16. Despite the recent regional trend towards decentralization of decisionmaking andbudgetary authority in government on the one hand, and privatization of state monopolieson the other, most borrower governments were poorly prepared to meet the Bank'srequirements for popular participation in EA during the period reviewed. Most localNGOs and local governments were similarly inexperienced with any role other than thatof critic, and many experienced confusion and difficulty grasping the opportunitypresented by the Bank's requirement for popular participation in EA work.

17. This is understandable when it is acknowledged that highly centralizedgovernment based in traditions of authoritarian rule by a small elite segment of society,often violently reinforced through military intervention, have been hallmarks of civilsociety in Latin America for most of the twentieth century. Legal systems that evolveunder such conditions empower that small elite and not other social actors. This is nowchanging. Emergent democratization in the region, the essential accountability ofgovernment to the governed, is taking root today, yet "a major question still to beresolved in most countries is how to set up accountability systems where they have neverbeen invented or atrophied under centralized modes of government."5

18. During the period reviewed, only Brazil had established (in 1986) a legalframework mandating consultations with local governments and public hearings in the

5. Campbell, T. 'Participation, Choice and Accountability in Local Government: LAC and the U.S."LACrD Dissemination Note, May 11, 1993.

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EA process. Similar legal frameworks were not in place elsewhere in the region, and,with the exception of Colombia, they are still absent in other LAC countries.6

19. On the other hand, environmental ministries and secretariats in the regionsometimes consulted informally and formally with counterparts in other institutions ofgovernment and with the scientific communities of their countries. And environmentalNGOs throughout the region were pressing hard during the period reviewed for a greatervoice in development decisionmaldng and more transparent review of environmentalrisks. While the absence of statutory requirements for public consultation is obviously asevere constraint, these trends toward widening the discussion and review ofenvironmental impacts provided a more receptive atmosphere for the Bank's initiativethan might otherwise have been the case. Nevertheless, Bank staff responsible forensuring that EAs are carried out in compliance with Bank policies faced a challengingsituation then and now.

20. Taking into account the absence of an enabling legal environment, the mostremarkable finding of the review is that 26 out of 28 task managers were successful instimulating some degree of public consultation and participation in the EA workconnected to their project preparation process (See Annex B). Moreover, success wasachieved in very different social, economic and political contexts: Argentina, Bolivia,Brazil, Colombia, Chile, Ecuador, Mexico, and Paraguay. Creating processes of publicconsultation in the absence of support from domestic legislation is a tribute to both Bankand borrower staff creativity and perseverance.

Institutional Framework of Public Participation

21. The institutional capacity for implementing and utilizing effectively the results ofthe public participation process in EA were severely limited during the period reviewed(fiscal 1989-94). Most borrower agencies evolved over many years prior to undertaldngthese EAs without any need for popular participation. Indeed, most agencies such asministries of agriculture, irrigation, energy, and water supply and sanitation weredominated historically by technical and administrative specialists whose responsibilitiesrarely entailed direct consultation with the public. In the past such technicians soughtcompliance with sectoral initiatives and regulations from affected populations, notparticipation in the formulation of initiatives and regulations. Therefore, public

6. The first LAC legislation creating a statutory requirement for citizen participation in all developmentinvestment decisionmaking has recently appeared in Colombia (Proyecto de Ley 282/93 'lnscripciony tramite de los mecanismos de participacion ciudadana"; see the Colombian Gaceta del Congreso15, June 1993). New environmental legislation appeared shortly thereafter mandating publicparticipation in environmental assessment (Ley 99/93 Fundamentos de la Politica AmbientalColombiana"; see the Colombian Gaceta del Congreso 22, December 1993).

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consultations in EAs for almost all of the borrower institutions constituted an importantshift in their way of doing business.

22. We found that few of the institutions preparing the projects reviewed haddepartments or divisions responsible for organizing public consultations.7 One exceptionis the Argentina-Paraguay Yacyreta Project, which is building a hydroelectric dam andreservoir that will inundate 1,650 km2 of wildlands and portions of two cities, displacingabout 50,000 people. In the 1980s the project owner, the Yacyreta Binational Entity,created a Department of Complimentary Works (complimentary in the sense of outsidethe 'main' civil works-the dam and powerhouse) to manage environmental mitigation,population resettlement and replacement of highways, railways and other publicinfrastructure affected. Prior to beginning the formal EA process, this department hadestablished "neighborhood resettlement offices' in the affected areas which provided amechanism for direct public consultation with the affected people during the planningprocess. Public consultation and participation in the EA process was an explicit goal inthe planning stage, and the agency was suitably staffed and experienced. It disseminatedcopies of the draft EA (including resettlement plans) with a request for comments tosome 30 NGOs, scientific experts in local universities, and the local governments in thearea. The agency also enlisted the services of international environmental andresettlement specialists to prepare a public workshop at which all stakeholders couldexpress their views openly. The workshop was held in March 1993 in one of the citiessuffering greatest impacts to discuss and approve the final version of the EA prior toWorld Bank appraisal.

23. For the Bank too, public consultation and participation represents an innovation.In the Bank's institutional culture, project identification, preparation and appraisal arethe province of international experts.8 Genuine development experts of course recognizethat information, opinions and values of affected people, local leaders, national scientistsand political authorities are the building blocks with which sustainable development mustbe constructed. Unfortunately, the international development scene is dominated bymany firms and consultancy houses that pass for experts because they generate the same"blueprint" or "cookbook" project designs across countries and sociocultural contexts, acondition the Bank's traditional culture fostered through its emphasis on new lending.9Exerts rapidly churning out cookie-cutter projects have little need to understand theviews and capabilities of affected people. To justify the cookie-cutter approach, theyusually assert that such information as local people possess is either incorrect orirrelevant. This attitude, although extreme, still has its adherents in the Bank. And the

7. Many such agencies had an office of public relations, but these were responsible for delivering aone-way flow of information to the media. They had little experience with participation in a two-way exchange of information with the public.

8. Kearns, J. M. -Generating and Sustaining Commitment to Bank Projects.' May 1993. Washington,DC: The World Bank.

9. Wapenhans, W. 'Effective Implementation: Key to Development Impact.' July 24, 1992.

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attitude can also be found among environmentalists trying to impose cookbook solutionsto environmental problems from the top down, for whom too often people are perceivedas obstacles.

24. Where Bank staff succeeded in stimulating public consultation and participation inEA work, they required their counterparts to go beyond expert opinion to seek (a)verification of expert knowledge and (b) additional information not available to experts.By taking seriously the knowledge and views of local stakeholders, many convinced theircountry counterparts to treat participation seriously. For example, in preparation of theEA for the Ecuador Lower Guayas Flood Control Project, the Bank staff memberresponsible for reviewing draft terms of reference advised that the TOR be strengthenedby including consultations with local NGOs and local governments, to which hisborrower counterparts responded by altering the terms of reference to include suchconsultations. The results significantly altered project design to avoid negativeenvironmental consequences. In other instances, environmental experts themselves tookthe initiative to reach out in response to petitions for information from the affectedpeople among whom they were working, as in the case of the Chile Irrigation SectorProject. Here the consulting firm received requests from NGOs for information on theproject, to which the firm responded by organizing worldng meetings to reviewpreliminary findings, design a continuing consultation mechanism to permit NGOs toscreen subprojects during implementation, and finally to comment extensively on thedraft EA.

25. Sectoral EAs presented a special challenge. Sectoral investments finance a broadrange of activities, many of which are not fully defined at the outset. Unlike projects tobuild a dam and irrigation system or school buildings, the activities are not site specificbut rather will occur throughout the country at places that may not be identified at thetime the project is prepared. Therefore, sectoral EAs are particularly suited forreviewing sector investment alternatives, the effect of sector policy changes, institutionalcapacities and requirements for environmental review, implementation and monitoring,and the cumulative impacts of many relatively small, similar investments that do notmerit individual project-specific EAs.

26. Unlike project-specific EAs, it may not be appropriate to systematically consultrepresentatives of potentially affected populations during preparation of a sectoral EA.The borrower should, however, consult with government agencies, commercial andbusiness interests, nongovernmental organizations, scientific organizations and otherstakeholders with interest and expertise in the sector. The Bolivia Environment, Industryand Mining Project preparation was strengthened by a sectoral EA carried out by a teamof international consultants directed by the Secretary of Environment. Informationdissemination during implementation occurred in two seminars held in the capital inwhich the consultants presented preliminary technical findings to representatives of localgovemments, industrial groups, mining companies, environmental groups as well astrade unions, scientific organizations and other interested groups. Following this, theSecretary circulated a draft sectoral EA to 41 organizations for formal review and

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written comment, after which the consultants held a second round of seminars to discussthe written comments. The final report was strengthened by incorporation of views fromthe participants in these working meetings.

Social Actors Involved in EA Consultations

27. Whether an EA is project-specific or sectoral, it is very important to identifysocial actors who should participate in the EA process."0 Yet the EAs reviewed heredid not benefit from any systematic analysis of the social composition of the communitiesand societies in which they took place. Instead, the social actors consulted were thosewho presented themselves to the EA team and borrower agency in an ad hoc manner orwho were already known to the EA team and the borrower. In the absence of anysystematic social analysis, one would expect that those who participate are the morearticulate, better organized and informed social actors, often those with greaterresources. To the extent that weaker and poorer segments of the population do not havea voice, the public participation process is incomplete and inadequate.

28. The best way to insure that all social actors are identified and included inconsultations is to conduct a social assessment. A social assessment permitsidentification of the constituent social groups, their organizational structures (leadershiphierarchy) and interrelationships and their values and capabilities. Where this is notdone, the participation process may open doors only to the powerful and influentialsegments of a community. Consider, for example, the case of the YacyretaHydroelectric Project mentioned above. Property owners organized grassroots AffectedPeople's Neighborhood Commissions in the cities of Posadas, Argentina andEncarnacion, Paraguay at the time of the EA. In addition the Chamber of Commerce ofEncamacion, where the business district will be flooded by the reservoir, and anAssociation of Ceramicists, whose manufacturing of roof tiles and bricks is dependent onclay deposits which will be flooded, were also well organized. These groups readilystepped forward to participate in EA meetings. But other social groups, such assidewalk merchants in the business district, poor single women employed as domestics,renters and squatters employed in the informal sector, fishermen along the river'smargin, small farmers and others who are also affected were not so well organized.They did not find their views reflected in the existing commissions and groups claimingto represent affected people; the grassroots associations mainly represent the interests ofurban property owners and commercial interests rather than the poor and marginal whoconstitute the vast majority of the affected population. A social analysis could havedesegregated the affected populations and identified constituent interest groups, thusfacilitating more representative participation.

10. 'Stakeholders' is increasingly used to label the diverse social actors who may have interest in thedevelopment investment and its environmental significance. However, the phrase 'social actors*captures better the idea that relevant stakeholders are those expected to take action related to theproposed investment or those who are expected to be affected by the actions of others.

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29. Social assessment also permits identification of social actors who may be onlyindirectly affected by the project, but whose interest in and influence on the outcome canbe critical. These could include the local environmental NGOs, a society of engineeringprofessionals, provincial governmental offices, labor unions, religious organizations,political parties, school support groups, neighborhood improvement associations, and anynumber of other social groups. The Colombia Power Sector Technical AssistanceProject is a good example. A sectoral EA was completed by a specialized EA teamdirected by Electricity Interconnection (ISA, the national distribution agency) whichconsulted widely in the country during preparation, and circulated a draft of the report toover 40 organizations throughout the country for comments and suggestions, includingprofessional associations of engineers, university-based experts, business interests, andother governmental organizations at the national and state level.

30. It follows that a single participation strategy cannot involve everyone equally.Different social groups will have varying degrees of interest and relevance in any givendevelopment investment. The objective of social analysis, in addition to identifying therange of social groups that constitute the context of the project, should be to define thosegroups who will be social actors in this particular investment. In the Paraguay NaturalResources Management Project, for example, priority was given to indigenousorganizations and the NGOs which represented them because of their vulnerability underthe proposed changes in land use patterns contained in the project. Other stakeholderswere considered important too, but it was recognized that the indigenous peoples'interests were not well represented by those stakeholders. Separate consultations wererequired with indigenous groups, apart from other stakeholders, to ensure that theirviews were incorporated.

31. Often specific groups or organizations possess special knowledge or expertisewhich should be sought separately to improve the quality of mitigation measures. Forexample, in the case of the Yacyreta Project in Argentina/Paraguay a majorenvironmental cost is the loss of wildlands (wetlands, grasslands and gallery rainforest)to the darn and reservoir. The EA clearly identified the need to create protected areas ofsimilar size and biotic characteristics to that being sacrificed in order to preserve habitatsof endangered as well as other species of plant and animal life in the region. But viableoptions for creating a large protected area, some 1,650 kin2, appeared to the EA team tobe limited. This problem was taken directly to the Argentina Wildlife Foundation andthe Moises Bertoni Foundation of Paraguay, who together identified relativelyuninhabited wildlands downstream of the project which could be declared protectedareas. This solution was adopted by the Yacyreta Project and is in the process ofimplementation.

Phases of Participation in EA Work

32. When should stakeholders participate in the EA process? This review focussedon four stages at which participation would be useful: scoping, preparation of the EA

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study, discussion of the draft EA and review of the final EA. Annex B illustrates thepattemn of participation in each phase of the EA process.

33. Most strildng is the fact that only 13 out of 26 participatory EAs completed to1994 entailed participation of affected people or NGOs in scoping the work. Thus, inabout half of the 28 projects reviewed, terms of reference (the result of scoping) wereformulated by environmental experts without reference to the perceptions or priorities ofaffected people or organizations with intimate knowledge of local conditions.

34. This pattern probably is a product of the fact that EA work is, in a real sense,countercultural to the traditions of the Bank. Participation has never characteized theproject cycle of the Bank."1 Methods and procedures derived from Bank traditionsfavor borrower government, outside expert and Bank staff collaboration in identificationand planning of projects, so early consultation with beneficiaries hardly occurs to mosttask managers. Bank policy on EA work, however, calls for explicit consultation at theearliest stage, while alternative designs, policies, locations, financial arrangements andother elements are still in flux, so that environmental information is brought to bear onthe selection of the most efficient, effective and sustainable alternative.

35. Once terms of reference are agreed among the experts, consultation is much lesscountercultural for Bank staff. Not surprisingly, in EAs considered participatory by thisreview, the majority of such participation occurs once the scope of the EA has beendetermined by the experts (22 out of 26 cases). The question then is less a matter ofidentifying environmentally and socially sensitive or significant issues, and more aquestion of convincing affected people and other stakeholders of the validity and wisdomof the choices already made by experts. This can be a much more difficult and time-consuming proposition than participatory planning from the outset. Nevertheless, thereare exceptions where good TOR formulated by experts systematically introduced publicconsultations in the identification of issues, such as in the Ecuador Lower Guayas FloodControl Project cited earlier.

36. Of the 26 participatory EAs, 16 invited comments and suggestions fromstakeholders on the draft EA documents. This aspect of the consultation process issurprisingly weak. In the best cases, this consisted of mailing or otherwise distributingcopies of the draft EA to groups and organizations in the country, as was done in thecase of the Bolivia Environment, Industry and Mining Project and the Colombia PowerSector Technical Assistance Project. In both instances, ample opportunity to read andprovide written comments on the draft were provided to a range of interested parties.

11. Despite the growing demand for more participatory development over the last decade, it is estimatedthat 20 percent of task managers account for 70 percent of participatory initiatives in Bank-financedactivities. See Bhatnagar, B. and A.C. Williams, eds. 1992. 'Participatory Development and theWorld Bank." World Bank Discussion Paper 183. Washington, D.C., Page 7.

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37. Public dissemination and review of draft EA documents can also serve to identifysignificant environmental impacts that were missed during EA preparation. A case inpoint is the EA for the Organization of Eastern Caribbean States Solid Waste Project.To clean up the Caribbean Sea, the project supports new facilities on each island tocollect and treat ship-generated waste and deposit it in new landfills. The proposedlandfill sites were each subjected to a site-specific EA, which together made up theoverall EA. In the case of the island of Grenada, during discussion of the draft EAdocument at a public forum a local NGO pointed out that the site selected for thatparticular landfill was one of the last remaining habitats of the endangered GrenadaDove. This fact was not turned up by the EA prepared by professionals. As a result ofpublic participation, the Grenada component of the project was redesigned to protect thisendangered species while also obtaining the benefits of the landfill and its function in thewider initiative to clean up the Caribbean Sea.

38. The least constructive public contribution to the BA is where only the final EAdocument is made available for inspection by the general public. Here there is littleopportunity for comment or suggestion that can be incorporated into the EA. This wasthe practice in the Mexico Second Solid Waste Project. At the EA preparation and draftreview stages there was wide consultation with NGOs in major cities, includingprofessional organizations, but the borrower's response to Bank suggestions forconsultations with affected populations and local governments was merely to open areading room in its headquarters in the capital and publish an announcement in the pressinviting interested parties to journey there to read the final EA.

Social Mechanisms Utilized to Facilitate Participation

39. As Cermea notes, participation is achieved only by defining and organizingadequate methods and procedures.

'No matter how intense or loud, the advocacy for people's participation indevelopment programs remain empty rhetoric if it is not translated into a'how to' social methodology for making popular participation real.""2

40. In the paragraphs below, five social mechanisms are identified which wereused to organize popular participation in the EA cases examined by the review. 3When used in combination they can transform the act of consultation into one ofauthentic participation. The list below is not meant to be exhaustive, but by ignoring itscomponents, public participation is undoubtedly doomed to remain "empty rhetoric."

12. Cemea, M. M., -The Building Blocks of Participation: Testing Bottom-up Planning,3 1992. WorldBank Discussion Paper 166. Washington, D.C.

13. In the interests of promoting a common vocabulary for social assessment and participation, theterminology of the Participatory Leaming Group is adopted here. See "The World Bank andParticipation: Report of the Leaming Group on Participatory Development,' May 10, 1994, Page 8.

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Box 1. Brazil-Extractive Reserves, FY95

The Pilot Program to Conserve the Brazilian Rain Forest, a G-7 initiativeadministered by the World Bank, provides grants to finance projects whichreduce the rate of deforestation in the Amazon. The Extractive Reserves Projectis intended to test, in four different areas, the concept by which localcommunities are guaranteed exclusive access to rain forest areas as long as suchuse is sustainable and of non-timber forest products.

Public participation in the conceptualization of this project has been key.The very success of the participatory approach will be determined by the extentto which local communities will be able to adopt benign natural resourcemanagement strategies. The implementing agency of the project will be theBrazilian Institute for Renewable Natural Resources (IBAMA), but the NationalRubbertappers Council (CNS) and local reserve associations have been intimatelyinvolved with every step of the project preparation.

Participation early on fulfilled two objectives: first, to allow the localcommunities to influence the project design to best respond to their needs and,second, to ensure that they were fully informed about any impacts that mayresult from the project. In other words, local communities had already played amajor role in delineating the project and its expected environmental impacts.Therefore, the EA report focussed on compiling and analyzing the providedinformation to propose management plans and mitigation activities that will betested during the project implementation.

41. Consulting. The first type of public participation is to thoroughly consult with allaffected groups, preferably including ones that are socially mixed and that comprise bothmen and women. Consultation is the least intensive and in many ways the least"participatory" of the five social mechanisms identified, and should be viewed as aninitial step. It consists of disseminating information about the proposed investment andthen listening closely to the opinions and views of relevant social actors. Consultingmay be accomplished during formally organized meetings, community assemblies,special workshops or committees, during field trips and public information gatherings or,at best, by a mix of these. The advantages of public consultation are illustrated by theExtractive Reserves Project in Brazil (see Box 1). In that case, the people directlyaffected by the project were consulted from the very beginning. The result was that theyhad a major impact on the final project design, which was continuously adapted by theexperts to fit the needs expressed by the people.

42. To achieve an overview of the knowledge and opinions of all stakeholdersthrough consultations-especially in multicultural contexts-is not an easy task.Communication between social actors and the developers is often hindered by differentculturally constituted world views. Klitgaard recently reiterated this issue: 'That weshould take culture into account when discussing development has been known for atleast forty years. What is not known is how to take culture into account, both

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Box 2. Eastern Caribbean-Solid Waste Management, FY95

The project addresses the solid waste problems on land and sea in theEastern Caribbean. It is the first regional initiative of its kind where projects arebeing prepared simultaneously for six island nations and with multiple fundingsources. The OECS project will support the establishment of port receptionfacilities for ship-generated waste, improvement of domestic collection andenforcement, and upgrading of dumps to sanitary landfills on each island.Because solid waste management and the siting of sanitary landfills are politicallysensitive issues, particularly on small, tourism-sensitive islands, an importantpart of the EA process for this project was extensive public consultation.

In the initial stages of project preparation, over 200 persons fromgovernment, business and NGOs were consulted about project objectives andscope. After a preliminary final report was produced, it was proposed to thegovernments to hold a series of public fora to share information and stimulatediscussion. The fora were also designed to obtain feedback on the summary tableEAs prepared for each proposed sanitary landfill site.

Fora were held in all six island countries with participation from thenational and regional project coordinators. Some were held in the smallcommunities closest to the major landfill site and others in the capital city. Mostwere televised and one had radio and TV call-in audience participation. The forawere useful in increasing awareness of the project, in clearing upmisunderstandings, and in giving the public a voice to share their concerns withgovernment. In the case of Grenada, the forum was instrumental in bringing tolight an important issue overlooked in the EA for the island-i.e. the presence ofthe shy, endangered Grenada Dove in the area proposed for the landfill site.Because of this discovery, experts were hired to undertake further studies of thearea and propose means of protecting the dove while still addressing the needsfor solid waste disposal.

scientifically (methods and data) and practically."'4 What is now known is that the"how" can only be determined through linguistic and cultural knowledge of the socialactors concerned. A minimal step in this direction is to ensure that social and culturalspecialists acquainted with the local languages and cultures are part of the EA team.

43. Information Pooling. To deepen the process of consultation, a preliminaryordering of the collected information is presented to a broader interested audience thatdiscusses, refutes, analyzes and reorganizes the data. Once the audience has beenexposed to all the information available, it is often split into working groups to tacklespecific subjects. The presence of a qualified and able discussion leader can helpgenerate constructive proposals relevant to the particular topic by keeping the discussion

14. Klitgaard, Robert, 'Taking Culture into Account: From 'Let's' to 'How',' in Culture andDevelopment in Africa, I. Serageldin and J. Taboroff, eds. Environmentally SustainableDevelopment Proceedings Series No. 1. Washington, DC: World Bank. 1994, Page 75.

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focussed on the subject. Afterwards, each group reports its results back to the plenum.To illustrate their results they often use simple and flexible visual aids (e.g., pinboardswith message cards) to order their presentation. Finally, a skdlled analyst may write upa summary of the plenum sessions to establish its final results, copies of which can bedistributed among the participants.

Box 3. Ecuador-Lower Guayas Flood Control Project, FY91

The Lower Guayas River Flood Control Project is designed to reducerural and urban flooding, improve health and living conditions in the area,support agricultural development and protect natural resources and theenvironment. Thanks in large part to extensive consultation during EA withlocal NGOs, a national NGO and local scientific experts, the project design wassignificantly altered during project preparation to better safeguard important andsensitive habitats. Also, mechanisms for NGO participation during projectimplementation-in the form of monitoring roles-were built into the project inadvance and are currently operational.

The EA was conducted as part of feasibility studies, and TORsincorporated provisions for consultations with affected people and NGOs toensure that their views would be taken into account. The first meeting, in theform of a briefing session with the several NGOs present, was held prior toinitiation of project preparation. In later stages, a total of six consultativemeetings were held between the implementing agency (Development Commissionfor the Guayas River Basin), NGOs, university representatives, and EAconsultants (a team of Dutch and Ecuadoran consultants). The World Bankundertook three field trips in support of the process: at identification, preparationand appraisal.

The consultations resulted in two distinct outputs:

* The project design was changed to alter the alignment of floodevacuation canals, despite higher costs, to save an important wetlandarea from severe disruption.

* Similarly, a proposed large outlet from a new reservoir into a riverwas dropped from the planned development in response to NGOconcerns which argued that the outlet would damage mangrove forestin the estuary. Instead a multi-outlet design was developed incollaboration with the NGOs.

44. This procedure, however, is not prescriptive but only descriptive. There areother ways to make information pooling and dissemination happen. A case in point isthe OECS waste management project (see Box 2). In this project, communityassemblies, public fora, and even a TV talk show were used to gather environmentallyrelevant information. As a result of public consultation, one worldwide endangered birdspecies, the Grenada Dove, has been identified as being terminally threatened by a

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Box 4. Colombia-Energy Sector Assistance, FY97

The environmental assessment team conducted a wide consultationprocess among 45 relevant organizations. A preliminary draft of the sectoralenvironmental assessment (SEA) analyzed the main environmental issues andconstraints and proposed a five-year action plan for the electricity sector. Thispreliminary draft was circulated widely for comments and approval. It was sentto national ministries or institutes such as those for planning, energy andenvironment; other energy agencies such as those for petroleum and gas; NGOssuch as FUNDEPUBLICO, CODESARROLLO, the Alma Foundation, and soforth; the National University, private universities, and state universities;business and professional organizations like the Colombia Association ofEngineers, National Associations of Industrialists, and others; representatives ofpopulations living in the area of existing electricity plants; as well as to the 10electricity companies of Colombia. At the same time a two-day workshop todiscuss questions and suggestions took place, at the end of which an official actendorsing the SEA findings and recommendations was signed by all the powerutilities, Ministry of Energy, National Planning Department and the nationalinstitute charged with environment. The first draft was substantially improvedby reflecting the new institutional and legal framework adopted by theColombian government shortly before completion of the SEA. Throughparticipation, national agreements on environmental priorities for the electricpower sector were produced, clear institutional responsibilities to strengthenenvironmental management in the sector were defined, and necessary publicsupport to develop a strategy of sectoral expansion under environmentallysustainable conditions was achieved.

planned landfill. The plan is now in review and a program to save this bird species iscurrently being developed with the borrower.

45. Jointly Assessing. Another social mechanism to facilitate popular participation inEAs is to invite representatives of stakeholders to participate in joint assessment. TheEcuador Lower Guayas Flood Control Project is a positive example of the usefulness ofthis mechanism (see Box 3). Joint assessment entails still more significant participationby stakeholders compared to consulting and information pooling. In joint assessment,stakeholders are invited to directly contribute to the decisionmaking process by analyzingavailable information evaluating the likely environmental impacts of the proposed projectdesign and suggesting changes to enhance environmental benefits or mitigateenvironmental risks.

46. Decentralized Decisionmaking. A major obstacle to facilitate public participationin government agencies is the inflexible hierarchical command structure. Thesestructures must be altered if decisionmaking is to become democratic, binding andengaging for all stakeholders. A good example for how this can be constructively doneis the Colombia Energy Sector Project (see Box 4). A simple but organized inter-

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institutional exchange of expertise and opinions has substantially contributed todecentralized decisionmaking. Moreover, the collective nature of the exchange promotedconsensus on a new set of policy priorities related to the national energy sector. Finally,the participants agreed on interinstitutional cooperation to implement the project jointlyand successfully.

Box 5. Brazil Espirito Santo Water Project, FY94

The project consists of potable water, sewerage and sewage treatmentsystems in 12 urban areas in the Brazilian state of Espirito Santo. The majorenvironmental issues are the locations of sewage treatment plants. Publicparticipation in the EA process resulted in the identification of two locationswhere communities would seriously suffer from the construction of the facilities.

The proposed sewage treatment plant in the Mulemba Valley would haveeliminated clay deposits vital for the subsistence of traditional artisans, known aspaneleiras. Unfortunately, alternative sites for the facility were lacking.Scientists and artisans jointly decided on mitigatory measures which wouldsecure the local artistic tradition, life-style and livelihood of the people. Theartisans were guaranteed legal access to additional clay deposits; technicalassistance and training in new clay technologies were offered; transport andstorage of clay from the Mulemba Valley were organized; and assistance incommercialization techniques and a sales outlet in the state capital Vitoria werestarted.

In the second case, the proposed wastewater plant in the neighborhoodJoanne D'Arc exacerbated the cumulative impacts local people already sufferedfrom an existing composting plant, a quarry and an asphalt plant. During publicmeetings people expressed their distress about adding a sewage treatment plant.In discussions a solution was found in cooperation with the state water companyand the Secretary for Environment, which committed themselves to constructmore green areas, plant tree barriers and create a recreational area in JoanneD'Arc.

47. Empowering the Powerless. Offering project information to the public anddecentralizing decisionmaking in government agencies automatically empowers differentstakeholders and interest groups, provided final design decisions are not yet taken or ifagencies are flexible enough to modify design decisions already taken. When affectedpeople are empowered, it means they directly affect the project's design by suggestingchanges and by negotiating compensatory measures when a project risks altering theirlife-style and living standards in negative ways. For example, the Brazil Espirito SantoWater Project, as originally designed, would have negatively impacted two communities.By including these communities in the EA process, satisfactory mitigation measures wereachieved that counterbalance and even improve their current living situation (see Box 5).

48. In the Brazil case, public participation was organized in all phases of the EAprocess except final EA review. First, the terms of references for the EA were discussed

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with NGOs, municipal representatives, and government agencies. Next, the EA teamincluded community representatives who provided the local people's point of view.Third, the EA draft was presented to the broader public with the help of the press, TVand radio. Finally, communal meetings were organized which helped to give voice tolocal people's criticisms and suggestions. In this way, affected people were empoweredto address the issues that concerned them, and demand a constructive and affirmativeresponse from the project owner.

Principal Results of Participation

49. Overall, the early experience of the LAC Region with popular participation in EAwork has been positive. The quality of EA work has been significantly improved bytaking into account the information and views provided by affected communities, NGOs,local govemnments and other relevant stakeholders. Some outstanding examples ofspecific improvements which can be traced to public participation include those listed inFigure 1.

Fgure 1. Inprovements Due to Public Participation

Improvements Example Projects

Negative environmental impacts--missed by BAexperts-were identified by the public. This OBCS Solid Waste Projectdiscovery led to the protection of the GrenadaDove.

Unwarranted environmental costs were avoided by Ecuador Lower Guayas Flood Control Projectrealigning the canal design.

Mitigation measures not anticipated by EA teamwere identified and adopted due to contribution of Argentina Yacyreta Il ProjectNGO leading to the creation of protected habitats.

Affected people identified mitigation measures thatresolved negative social impacts by protecting an Brazil Espirito Santo Water Management Projectartisan community from the loss of clay depositsand an urban neighborhood from a severe declinein the quality of living conditions.

New areas are demarcated serving the protection ofa vulnerable ethnic group, the Tupi Guarani, which Paraguay Natural Resource Management Projectalso impedes the destruction of fragile naturalresources.

Change of national policy priorities were agreedupon by a wide range of stakeholders within and Colombia Power Sectorbeyond the sector.

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50. The lessons taught by the review of the 28 projects are valuable to developmentplanners because in many instances the quality of project design has been improved. Forexample, the OECS project shows that even highly qualified environmental professionalscan overlook a seriously negative project impact. Only broad public discussion of theproject with the islanders brought attention'to the endangered Grenada Dove. In thecases of Ecuador and Paraguay the respective project designs have been modified tobecome more socially appropriate and satisfactory to the project beneficiaries. In theArgentine and Brazilian cases, public consultation clearly increased the adequacy ofmitigation measures for those negatively affected by the planned projects. And last, butnot least, in some cases public participation may even lead to changes in national policypriorities, as Colombia's energy project demonstrates.

Best Practices in Popular Participation in EA Work

"It is towards the reinforcement of indigenous institutions that will provide for theincreasing empowerment of the poor within their own cultural reality that the nextstage of the Bank's work on participation must move.""

51. Genuine popular participation cannot be imposed, but must be grounded in theevolving sociocultural systems of borrower countries. The following are recommendedprocedures and measures which can assist in formulating participatory strategies that fitthe social and cultural context of any particular country. The focus is on learning howto identify and strengthen participatory processes that are derived from the social systemsin which they are embedded. There are four steps to this learning process approach.

52. Why have governments found it so hard to develop and implement wiseenvironmental policies? The World Development Report of 1992 answers this intricatequestion as follows: "A principal reason is that such policies often mean the withdrawalof entrenched 'rights'-to pollute or to use resources-that tend to benefit the wealthyand influential, often at the expense of the poor."'6 This statement is part of asomewhat more complex answer, however given the basic truth of the statement, oneimportant way to overcome this impediment is by maldng popular participation bear onenvironmental policymaking, monitoring, and enforcement. In other words, establishingthe principle of accountability to the public for "wise" environmental decisionmaking can

15. Serageldin, Ismail 'The Challenge of a Holistic Vision: Culture, Empowerment, and theDevelopment Paradigm in Culture and Development in Africa, I. Serageldin and J. Taboroff, eds.Environmentally Sustainable Development Proceedings Series No. 1. Washington, DC: World Bank.1994, Page 29.

16. World Development Report 1992: Development and the Environment. Oxford et al.: IBRD, OxfordUniversity Press 1992, pp.83 .

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serve as a springboard from which to tackle broader issues of historical "rights' topollute or mine natural resources. This can be achieved only through a transparent andparticipatory decisionmaking process itself.

53. All countries have existing ways in which social actors participate in public lifeor are barred from such participation. Ignore these institutionalized practices at yourperil. On the other hand, we recognize that existing participants tend to be the wealthyand influential members of society, not minority groups, the poor or the affectedpopulations. The challenge, therefore, is not so much to invent public participation butrather to strengthen and extend access for the broad majority of the population to theexisting participation process, with special emphasis on those affected by the proposeddevelopment investment.

54. The following recommendations are derived from the foregoing analysis. Theseare not intended as steps which must be taken in all situations or for all projects, but as'best practices" which can assist in facilitating participatory strategies in the particularsocial and cultural context of any country. The focus is on learning how to identify andstrengthen public participation in EA work that fits a given social system. We suggestfour steps to reach this goal.

55. Strengthen the Institutional Capacity. Despite existing practices that allow theelites of many countries to participate in development decisionmaking, it is important forall borrower agencies to shift their way of doing business so that it includesenvironmentally active, public participation in EAs by people other than elites. Few ofthe government institutions which prepare the projects have their own departments orstaff that are responsible for organizing broadly based public participation. As has beencorrectly noted elsewhere: "Most technical agencies lack the skils to fosterparticipation. High priority should therefore be given to increasing the organizationalweight of units that specialize in participation, to hiring professional staff trained in thesocial sciences, and to providing institutional incentives for participation. "n7 No matterwhether public participation in EA work is derived from domestic legislation or theefforts of individual task managers, borrower ownership is key to successful popularparticipation. Such ownership is expressed in the capacity to organize the process ofpublic consultation independently. The preconditions are, in fact, few and relativelysimple to fulfill:

(a) Suitable institutional resources are needed to permit planning ofparticipation, the best indicator of which is a staffof qualifiedprofessionals in social and communicative sciences, and a basic officeinfrastructure.

17. World Development Report 1992: Development and the Environment Oxford et al.: IBRD, OxfordUniversity Press 1992, pp.97.

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(b) Funds allocated to finance public participation are also needed-it costsmoney either to bring the stakeholders to you or to go to them. In eithercase the EA "owner" should pay the necessary equipment, transport andper diem but not the stakeholders.

56. Insist on Social Assessment. The second step to facilitate public participation inEA work is to ensure that the borrower agency or the EA team conducts an assessmentof the social context in which the planned project will be embedded. A socialassessment provides answers to three vital questions related to improving popularparticipation in EA work:

(a) Who are the relevant stakeholders? The objective is to define those socialgroups that will be social actors in the project and should be consideredstakeholders in a particular project; these may be NGOs, localgovernments, contractors, and other groups that benefit or are negativelyaffected (i.e. families that must be resettled, women, ethnic minorities). Itis obvious that different groups will have varying degrees of interest inany given development investment. To determine the degree andrelevance of that difference is an important result of a social analysis.

(b) What are the customary institutionalforms of decisionmaking in a givencountry? Each society has institutionalized ways through which followersrelate to their leaders and leaders are responsive to their followers. Somesocial systems and groups are basically democratically organized, whileothers are accustomed to hierarchical command structures or evenauthoritarian ones. It is safe to say that the latter two need specialattention and measures to facilitate public participation. However, fewgovernments can afford the costs of enforcing management programs thatlocal people do not accept because they contradict local knowledge andconviction, values, or ideology. Only if management programs "fit' localculture and knowledge will the communities support them.

(c) What are the customary forms of communication precedingdecisionmaking? Some societies are predominantly oral in exchanginginformation and reaching consensus; others prefer written material; andstill others are highly receptive to visual information. Naturally, in mostcountries there is some mix of these three forms in the process ofcommunication, interaction and negotiation. Which mix is most suitablefor a particular country can also be determined in a social assessment.

57. Identify Arenas for Consultation. A third step toward greater participation in EAwork is to delimit specific arenas where participation of specific social actors is desired.Not all social actors can or should be consulted on every detail of the proposed projects.In fact, massive participation would be highly inefficient, being too time consuming aswell as disheartening to those confronted with issues that surpass their expertise and

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experience. Answers to the following questions can help to optimize the participationprocess by delimiting arenas of interest.

(a) What decisions are purely technical and do not require public input?(b) WMich decisions are best made by the affected social groups themselves?(c) What decisions should be taken by political leaders or other

representatives (NGOs) of affected people?(d) Finally, which decisions are best left to the market?.8

58. Design Iterative Phases of Participatory Activities. The LATEN review of 28EAs revealed that, overall, public participation has increased in recent years, but that theextent, quality, and intensity of the participation is still far from ideal. This must changein as many phases of the EA work as possible.

59. First, and in general terms, it is necessary to have a better informed public inLatin America. More research on environmental issues is vital, as is dissemination of itsresults to the general public. This can be done via media like radio and newspapers, butalso via formal education, beginning with kindergarten and primary school. Today it iswidely recognized that well-informed citizens are in a better position to put pressure ontheir governments and on polluters and are also more accepting of the costs andinconveniences of environmental policies."9

60. Second, the LATEN review of the 26 projects that included popular participationrevealed that such participation is best integrated at the preparation phase of an EAstudy. The most striking lack of public participation concerns the scoping phase (seeAnnex B). The conclusion is clear: all stakeholders must be consulted as soon aspossible in the EA process. This is initiated by "getting all the cards on thetable'-informing people about the proposed project-before terms of reference arefinalized. For projects that have a geographical locale, adequate information has to begiven to the affected communities during the identification stage of the project cycle.Other stakeholders that should be addressed are those with expertise in the project area,target population, or project type. The EA team has to invite comments and questions

18. Philip Gerson argues that the willingness to pay (spend cash, contribute labor, devote time) is ameasure to assess beneficiary preferences among kdnds of investments as well as to ensure thatbeneficiaries are supportive of the alternative thereby selected. While this may be tmue in manysocieties, for mrilions of people measurement of willingness to pay is an entirely hypotheticalexercise. Not only have they little or no knowledge of factor markets, but their responses to themarket are largely the product of real life constraints on choices embedded in extremely unequalsocioeconomic systems and wildly lopsided political power structures. See Philip R. Gerson,Popular Participation in Economic Tzeory and Pracice, HRO Working Paper, No. 18.(Washington, D.C.: World Bank, December 1993).

19. World Development Report 1992: Development and the Environment. Oxford et al.: IBRD, OxfordUniversity Press 1992, pp.87.

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regarding potential environmental impacts of the proposed project, and provide feedbackto those who responded to verify the accuracy of information received.

61. It should be remembered that there are several ways to intensify and deepen thepopular consultation process. Above, in the section called "Social Mechanisms Utilizedto Facilitate Participation," several ways to transform consultation into more authenticparticipation were identified. This can be done by moving beyond consultation toorganizing official meetings to pool information jointly, holding workshops to organizeand revise that information, assigning responsibility for certain decisions to participantsand finally by handing over "ownership" of aspects of the project to some of theparticipants. Perhaps it goes without saying that each iteration of this process can befacilitated by including representatives of stakeholder groups in the assessment teams.

62. More also can be done by discussing the findings and recommendations given inthe EA draft with a wider audience. To do this, the EA draft must clearly identify theissues agreed during scoping, and present EA findings concerning the nature andmagnitude of those issues as well as measures proposed to mitigate a project's negativesocial and ecological impacts. The open discussion of the EA draft stimulatesconstructive critique and helps define alternative proposals that can achieve broader andbetter consensus. Another advantage of public participation at this stage is that theimplementing agencies can concomitantly elicit endorsement of their approach andenhance public participation later on in the implementation phase.

63. Also widely neglected has been popular participation in the discussion of the finalEA document. Given that, ideally, public participation should already have played amajor role in previous phases of EA work, the discussion of the final document can bedone by sending out copies to representatives of stakeholder organizations and organizinga final hearing to collect last comments and queries. These comments, suggestions orconcerns should then be included in the final EA document.

64. The experience of development work in recent years has shown that publicparticipation in EA work makes environmentally sound projects possible. This is truenot only for the EA process, but for project implementation as well. Developmentprojects are unquestionably more successful if they are participatory from the very startof the project cycle, i.e., during project design.20 This was documented in an earlierreview of 30 World Bank projects from the 1970s. It found an "average rate of returnof 18 percent for projects that were judged culturally appropriate but only 9 percent forprojects that did not include mechanisms for social and cultural adaptation."2 '

20. Uphoff, Norman. 'Monitoring and Evaluating Popular Participation in World Bank-AssistedProjects,' Bhuvan Bhatnagar and Aubrey C. Williams, eds., Paticipatoiy Development and theWorld Bank. Potential Directions for Change. World Bank Discussion Paper 183. Washington DC:IBRD 1992. Pp. 135-153.

21. World Development Report 1992: Development and the Environment. Oxford et al.: IBRD, OxfordUniversity Press 1992, pp.94 -5.

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Annex A: Participation in 28 Projects With Completed EAsFiscal 1989-94

FY of Consuld dwng EA process wtl.Project Board J Ait/Cr No. Approval Category Affected Loca Loca

Commnty NGOs Govt.

Brazil: Hydrocarbon Transport and 1991 A No No YesProcesing (Ln 3376)

Ecuador. Lower Guayas Flood 1991 A Yes Yes YesControl (Las 3276)

Bolivia: Agro Export Development 1992 B No Yes No(Cr 2322)

Chile: Transport Infrstructure 1992 B No Yes Yes(Ln 3426)

Ecuador. Runl Development 1992 B No Yes Yes(Ln 3390)

Jamaica: Energy Sector (Ln 3502) 1992 A Yes No No

Mexico: Irrigation and 1992 B No No YesDrainage Sector (La 3419)

TrintTobago: Busness Expansion 1992 B No No Noand Industrial Restructuing(Li 3432)

Argentina: Yacyreta II (Li 3520) 1993 A Yes Yes Yes

Brazil: Water Quality and Pollution 1993 A No No YesControl - Sao Paulo/Curitiba(La 3503 & 3505)

Brazil: Water Quality and Pollution 1993 A No Yes YesControl - Minas Gerais (La 3554)

Chile: Irrigation Development 1993 A No Yes No(aI 3528) .

Honduras: Transport Sector Rehab. 1993 B No No No(Cr 2458)

Paraguay: Rural Water Supply 1993 B Yes No Yes(Li 3519)

Ecuador: T.A. Mining (Ln 3655) 1994 A Yes Yes No

Paraguay: National Resource 1994 A Yes Yes NoManagement (Ln 3708) _ _

Paraguay: Highway VIII ( 3685) 1994 B Yes No Yes

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I FY of | Consulted during EA process with:Project Board EALnfCr No. Approval Category Affected Local Local

______________________I_______ _______JCommwdty NGOs Govt.Uruguay: Natural Resource Mgmt 1994 A Yes Yes Noand lirigation (Lan 3697)

Brazil Espirito Santo Water and Coastal 1994 B Yes Yes YcsPollution Control (Lan 3767)

Mexico: I. Solid Waste Mgmt 1994 A No Yes No(Ln 3752)

Belize: Power HI (Ln 3776) 1995 B No Yes Yes

Brazil: Ceara-Urban Development and 1995 A Yes No YesWater Resource Management(Ln 3784)

BraziL Exractive Reserves (G-7 Grant) 1995 B Yes Yes No

Paraguay: Asuncion Sewerage 1995 A Yes No Yes(Board date: 11194)

OECS: Solid Waste (Board date: 6/95) 1995 A Yes Yes Yes

Colombia: Energy Sector TA 1997 B Yes Yes Yes(Board date: 8/96)

Bolivia: Environment, Industry 1997 A No Yes Yesand Mining (Board datc: 9196)

Colombia: Bogota Urban Transport 1998 B Yes No Yes(Board date: 7/97)

Total Number of Project: 28 1S Yes 17 Yes iYes 113 No 1 No lO No

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Annex B: Phases of Participation in 26 EAs

IJ | Preparatlon of | Discuss | Fnal ReviewProjec j Scoping E EA Study De EA EA

Belize: Power II Yes Yes Yes No

Bolivia: Environment, Industry and Mining No Yes Yes Yes

Bolivia: Agro-Export Development No Yes Yes Yes

Brazil: Extractive Reserves Yes Yes No No

Brazil: Hydrocarbon Transport No No No Yes

Brazil: Ceara - Urban Development and No Yes No YesWater Resource Management l

Brazil: Water Quality - Sao Paulo/Curitiba No No Yes Yes

Brazil: Water Quality - Minas Gerais No Yes Yes Yes

Brazil: Espirto Santo Water and Coastal Yes Yes Yes NoPollution Control

Chile: Irrigation Development Yes Yes Yes No

Chile: Trnusport Infrastructure Yes Yes No No

Colombia: Urban Transport No Yes Yes Yes

Colombia: Energy Sector TA Yes No Yes Yes

Ecuador. Lower Guayas Flood Control Yes Yes Yes Yes

Ecuador: Rural Development Yes No Yes No

Ecuador. T.A. Mining Yes Yes No No

Jamaica: Energy Sector Deregularization Yes Yes Yes Noand Privatization

Mexico: Irrigation and Drainage No Yes No No

Mexico: Solid Waste II No Yes Yes No

Paraguay: Highway VIII No Yes Yes No

Paraguay: Asuncion Sewerage No Yes No No

Paraguay: Rural Water Supply No Yes No No

Paraguay: Natural Resource Mgmt. I Yes Yes No No

Uruguay: Natural Resource Mgmt. Yes Yes No No

OECS: Solid Waste Yes Yes Yes No

Argentina. Yacyreta II No Yes Yes Yes

Total Nunber of Projects: 26 1 Yes 22 Yes 16 Yes 10 Yes_ 13 No 4 No 10 No 16 No

LATEN DISSEMINATION NOTES

1QI T"itl e Date Autho

1 Sustainability, Yield Loss and Imediatismo: April 1993 Robert SchneiderChoice of Technique at the Frontier Gunars Platais

David RosenblattMaryla Webb

2 The Potential for Trade with the Amazon in April 1993 Robert SchneiderGreenhouse Gas Reduction

3 Land Abandonment, Property Rights, and April 1993 Robert SchneiderAgricultural Sustainability in the Amazon

4 The Urban Environmental Challenge in Latin August 1993 John DixonAmerica

5 An Analysis of Flooding in the ParanalParaguay September Robert J. Anderson, Jr.River Basin 1993 Nelson da Franca Ribeiro

dos SantosHenry F. Diaz

6 Ecology and Microeconomics as 'Joint Products": October 1993 John A. DixonThe Bonaire Marine Park in the Caribbean Louise Fallon Scura

Tom van't Hof

7 Forest Management and Competing Land Uses: October 1993 Nalin M. KishorAn Economic Analysis for Costa Rica Luis F. Constantino

George Guess

8 Pueblos Indfgenas y Desarrollo en America Latina December 1993 Jorge E. UquillasJean-Carlo Rivera

9 Prospects for Improved Management of Natural December 1993 Robert KirmseForests in Latin America Luis Constantino

George Guess

10 Assessing the Conservation Potential and Degree of February 1994 David M. OlsonThreat Among Ecoregions of Latin America and Eric Dinersteinthe Caribbean: A Landscape Ecology Approach (World Wildlife Fund)(Available in English and Spanish)

For back issues ofthe above, please contact: Environmental Unit (LATEN)

Latin America and the Caribbean Technical DepartmentThe World Bank1818 H Street, N.W.Washington, DC 20433U.S.A.

Tel. (202) 473-9379Fax. (202) 676-9373