World Bank Policies and Public Participation

Among the various activities of the World Bank, some of the most visible and controversial are the infrastructure projects they fund around the world. The projects are intended to improve quality of life and encourage economic development, and include irrigation systems, road and rail improvements, dams, port facilities, and even dumps.(Shown the right is World Bank-funded road construction in Tajikistan) Lesser known are the World Bank policies that mandate that project sponsors write lengthy, western-style environmental assessments and engage in mandated consultations with local NGOs and affected populations. Are you a member of an obscure indigenous people being displaced from your home by a huge new hydroelectric dam? Go to the environmental assessment hearing, listen to the PowerPoint, and be heard. This type of process happens frequently under World Bank policies pointed out to me by a former bank staff I met at an event this fall.

The bank’s so-called Safeguard Policies, designed to prevent “undue harm” to society and the environment as a result of “the development process,” do indeed mandate a bare minimum of public participation. The Environmental Assessment Policy requires,

the borrower consults project-affected groups and local nongovernmental organizations (NGOs) about the project’s environmental aspects and takes their views into account. The borrower initiates such consultations as early as possible. For Category A projects [those that “likely to have significant adverse environmental impacts that are sensitive, diverse or unprecedented”], the borrower consults these groups at least twice: (a) shortly after environmental screening and before the terms of reference for the EA are finalized; and (b) once a draft EA report is prepared. In addition, the borrower consults with such groups throughout project implementation as necessary to address EA-related issues that affect them.

In text reminiscent with the U.S. federal government’s mandates to cities in the 1950s regarding the relocation of people displaced for urban renewal projects, the World Bank’s Involuntary Resettlement policy requires (emphasis mine):

Involvement of resettlers and host communities:

(a) a description of the strategy for consultation with and participation of resettlers and hosts in the design and implementation of the resettlement activities;
(b) a summary of the views expressed and how these views were taken into account in preparing the resettlement plan;
(c) a review of the resettlement alternatives presented and the choices made by displaced persons regarding options available to them, including choices related to forms of compensation and resettlement assistance, to relocating as individuals families or as parts of preexisting communities or kinship groups, to sustaining existing patterns of group organization, and to retaining access to cultural property (e.g. places of worship, pilgrimage centers, cemeteries);5and
(d) institutionalized arrangements by which displaced people can communicate their concerns to project authorities throughout planning and implementation, and measures to ensure that such vulnerable groups as indigenous people, ethnic minorities, the landless, and women are adequately represented.

The Indigenous People’s Policy has similar language, recognizing the unique vulnerability of these populations:

A project proposed for Bank financing that affects Indigenous Peoples requires:

(a) screening by the Bank to identify whether Indigenous Peoples are present in, or have collective attachment to, the project area (see paragraph 8);
(b) a social assessment by the borrower (see paragraph 9 and Annex A);
(c) a process of free, prior, and informed consultation with the affected Indigenous Peoples’ communities at each stage of the project, and particularly during project preparation, to fully identify their views and ascertain their broad community support for the project (see paragraphs 10 and 11);
(d) the preparation of an Indigenous Peoples Plan (see paragraph 12 and Annex B) or an Indigenous Peoples Planning Framework (see paragraph 13 and Annex C); and
(e) disclosure of the draft Indigenous Peoples Plan or draft Indigenous Peoples Planning Framework (see paragraph 15).

As an aside, the views and leadership of indigenous peoples are particularly difficult for outside powers to pin down. Who, precisely, can speak for the group? I once had an interesting conversation with a Lakota tribal elder about why he felt the official tribal government, did not represent the “true” interests of the full-blooded tribal members like himself.


An interesting source of material about how these policies are actually implemented are the official Environmental Assessments, which are as a matter of policy all posted to the World Bank’s website. Let’s look at two recent environmental assessments to see what they have to say about the public consultation for the project. First, regarding a Tunisian irrigation project:

15. For the purpose of presenting the results of the analysis of equivalence and acceptability of the Tunisian national system of EA in the water sector, a public
consultation, in the form of an Atelier deInformation et de Concertationo took place at CITET in Tunis on October 28-30, 2008 under the patronage of the Secretaire deEtat. There were approximately 75 people in attendance (List Attached), including representatives of public and private sector entities, NGOs and the media, and
international donors including AFD and the ADB.

16. In addition to the presentation by Bank staff of the findings and conclusions of the SDR, five presentations were made by ANPE, MARH, and the consultants respectively
on: (i) the Tunisian System of EA in the Water Sector; (ii) the PISEAU II; (iii) the Resettlement Policy Framework; (iv) the DCPES; and (v) Environmental Health and Safety in Connection with Asbestos. Representatives of the World Bank introduced the context and methodology for the analysis of equivalence and acceptability of the national system of EA in the water sector and the results of this analysis as well as the gap filling measures necessary for the application of the Tunisian EA system to projects financed by the World Bank, and in particular to the World Bank-financed Sub-projects under the PISEAU II.

17. During the consultations, it was concluded that the report reflects the current status of the EA system in Tunisia and that the World Bank has in fact identified the gaps between the Tunisian system and the requirements of World Bank Operational Policy 4.00 on Piloting the Use of Borrower Systems to Address Environmental and Social Safeguard Issues in Bank-Supported Projects. The participants agreed in general with the DCPES as a way to guide the environmental and social management of activities to be financed by the PISEAU II consistent with the findings and conclusions of the SDR. The principal points raised during the consultation focused on the gaps observed between the Tunisian EA system and the requirements of the World Bank’s environmental policy. After explanation was given on the comments raised herein, the participants endorsed the
content of the report.

Another recent project I selected at random, the “Southern West Bank Solid Waste Management Project,” provided a process a bit more nuanced than a dry public meeting in the capital city:

The Consultation Team had to adjust the consultation plan after the meetings with the scavengers and the leaders of two communities near the existing Yatta landfill. Informal leaders of scavengers from Yatta city and formal leaders of communities near the Yatta landfill site wanted to discuss negative environmental and social effects and impacts of the site. The site was managed very poorly until 2006 and some of the complains needed to be crosschecked with responsible government authorities and with field data. Therefore the Consultant Team decided to interview a medical expert in Yatta district and an social expert of the Municipal Social Department. In addition, the Consultant decided to conduct a census of all scavengers working on an average summer day at the landfill site, and to prepare profiles of four scavengers households from Yatta city and four households from El Deirat village. The additional data was required to deal with conflicting information about number of scavengers, health conditions and the socio-economic backgrounds of the households of scavenger families that have children and adults picking waste at the landfill site.

Thinly-veiled threats raised during one community meeting even made it into the report:

The leaders of communities living near to the proposed regional land fill site in El Menya and the proposed transfer station in South Hebron have given their conditional support to the project components. They want their communities to benefits from improved infrastructure and employment opportunities. Their conditions concern the management of the facilities in accordance with international environmental and social standards so that the communities and these assets will be protected for negative impacts in the short, medium and long term. The community leaders also expressed a warning: if the SWM facilities are not properly managed and cause hinder to the neighboring communities these might react by blocking the operation of the solid waste management system.

Some might scoff at the actual power wielded by the community. Once the trash transfer facility was built, what power could they have to ensure environmental standards are upheld? In 1968 one U.S. community faced the precise same problem. Officials refused to re-route garbage and fuel trucks serving Boston’s Logan Airport from a densely populated residential street in East Boston — Maverick Street. The street’s residents sparked a political confrontation and re-routing of the trucks by physically blocking the street. The comparison opens up the question of what social and political factors must be present for procedural environmental assessments to result in community power.


Like with many mandated consultation processes, distrust and frustration is rife on both sides. According to one article about a World Bank process in Pakistan I found online, a group of 24 NGOs dropped out of an official consultation process in 2001, complaining “The nature and content of the consultations has to be meaningful” before they would participate. In other places and times hundreds of groups have boycotted the consultation processes, including this example from 2004. An independent 2004 evaluation of the public consultation process for a hydroelectric project in Laos (right) critiques the process, concluding:

From its beginning in 1996 to the present time, the Nam Theun 2 public consultation process was aimed not at empowering the public to engage in informed dialogue and debate about the project, but rather to justify the decision to proceed with it. ” although they point out, “Whether it would be possible for a more neutral and well-intentioned party to structure a participatory decision-making process that works in the context of Laos–and that would meet the universal standards of transparency and accountability that both the World Bank and WCD recommend–remains to be seen. But in the current situation, the Nam Theun 2 public consultation process has clearly failed to meet even minimal World Bank standards, much less the more rigorous WCD standards, and should not be accepted as an adequate basis for the approval of support for the Project.

A 2002 World Bank working paper evaluating public consultations in the environmental assessment policy concluded something similar, finding that although consultation had become common, “the current challenge for Bank operations focuses on the quality of public consultations and the extent to which they influence project design and effect project impact.”

I am very new to the area of megaprojects, only recently having ordered the Flyvbjerg and Altshuler/Luberoff recent books on the subject. However even from this cursory review, the application of consultation requirements in developing world contexts can serve to illuminate the many factors consultation projects in general are are based upon: the existence of a civil society, free and robust media, and the assumption the people affected by the project are protected from possible harms outside of the scope of individual projects. Indeed, maybe these policies only make sense in a country with a rule of law that can function as an arena of last resort. After all, without legal recourse, how substantive would many participation processes in the U.S. be? Although the precise impact of the policies seems varied, at the very least it is sparking new forms of local debate and information exchange and warrant further examination.

This topic is related to two others I hope to write about soon. In the U.S., state planning and zoning laws can mandate participation for urban planning at the local level, like the World Bank policies setting requirements to guide local planning. Around the world, a new approach to infrastructure development shifts the paradigm away from procedural assessments and consultations such as the environmental assessments described above, or used in the U.S. under the National Environmental Policy Act. In the emerging field of participatory budgeting, urban residents themselves decide which infrastructure projects should be built, through cutting-edge democratic processes.

World Bank photos: road construction in Tajikistan and Nam Theum 2 project.

Author: Rob Goodspeed


  1. Sadly, I don’t think it is as easy for indigenous people as “Go to the environmental assessment hearing, listen to the PowerPoint, and be heard.” Most are in remote locations, have not idea what an environmental assessment hearing is, nor where to go to voice their opinion. These mandates by the World Bank are more of a guise to look inclusive then to really try and include indigenous people’s voices.

  2. Thank you for your comment. I didn’t mean to imply the policies worked at all. In fact, in the article I describe the many ways doing an Environmental Assessment in a developing world context makes no sense. Some of the many barriers are cultural, distance, and language, not to mention the other factors that give similar type assessments power in the US context – our legal system, media, and democratic society. Given these obstacles and faulty assumptions, doing environmental assessments can be meaningless, as the critics I cite describe.

    At the end I discuss an alternative from toothless procedural policies (even if the project is very damaging, an EA alone has no power to stop it), participatory budgeting. I would be interested in your view about how indigenous peoples should be integrated into project planning. Should the World Bank discontinue all projects of a certain type (such as dams, as some have suggested)? Should the institution itself be abolished?

  3. Pingback: Barney Frank Threatens to Block World Bank Funding | DailyUN

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