EBRD Strategy Requests

The European Bank of Reconstruction and Development (EBRD) has been a repeated menace to Macedonia’s protected areas.

Criticisms of the bank’s hydropower policy have been mushrooming for its poor environmental record and low economic returns. The Standing Committee of the Bern Convention has suspended its attempts to fund a dam in National Park Mavrovo, main breeding area for the critically endangered Balkan Lynx. And the UNESCO World Heritage Committee has demanded abandonment of an express road the bank had hoped to finance in National Park Galichica.

Now the EBRD is revising its Macedonia strategy and Ohrid SOS submitted 15 guidelines in July to improve the bank’s performance as part of a public consultation process. Here is the breakdown:

1. All EBRD-financed projects must adhere to Motion 26 from the IUCN’s World Conservation Congress, Hawai’i 2016, which a) establishes the 6 IUCN Protected Area Management Categories as no-go zones for environmentally damaging infrastructure and industry development; b) requests development banks to refrain from investing in or funding activities “within, or that negatively impact protected areas or any areas of particular importance for biodiversity and ecosystem services that are identified by governments as essential to achieving the Aichi Biodiversity Targets”; and c) urges a public commitment to these principles from financial institutions.
2. Adherence to the above-mentioned Motion 26 must be extended to incorporate de-facto protected areas within the Republic of Macedonia whose biodiversity, habitats or rare species are known beyond reasonable doubt to fulfill criteria for designation within one of the 6 IUCN Protected Area Management Categories, but which lack formal recognition. In particular, this should apply to Mount Jablanica and Shar Planina.
3. Areas likely to act as important refugium zones during the current period of climate change, including but not limited to high mountains, specific areas of river valleys, and the tectonic lakes, must also be identified; their integrity maintained; and the migration routes to and from them secured.
4.  EBRD-financed projects should be cognizant of MAK-NEN, an inter-connected series of proposed protected areas compiled by the Macedonian Ecological Society and based on movements of the Eurasian Brown Bear. All reasonable steps should be taken to avoid disruption of these areas and to guarantee their meaningful connectivity.
5. Due to the intense cultural and ecological significance of UNESCO Lake Ohrid and the need for a science-based approach to its development, the EBRD strategy for the Republic of Macedonia must formally synchronize with the Society of Wetland Scientists’ Declaration on the Protection of the Lake Ohrid Ecosystem for all bank-financed activities in the region.
6.  The EBRD strategy must contain clear details of how it is harmonized with the Republic of Macedonia’s National Biodiversity Strategy and Action Plan and related nature protection documentation. Areas of actual and potential conflict between the two strategies should be described alongside the steps that will be taken to resolve them.
7. Future Strategic Environmental Assessments (SEA) for bank-financed projects with  environmental impacts must include quantified measures over a fixed, rolling time-period of Macedonia’s i) previous mitigation/biodiversity offset performance; ii) ability to implement mitigation/offsets long-term; iii) current ecological performance; iv) project compatibility with the National Biodiversity Strategy and Action Plan; v) implementation and effectiveness of environmental law; vi) political will to ensure environmental integrity; and vii) environmental awareness in the public and private sectors. These indicators should function like a credit system, and values that fall below a certain threshold either overall or for certain critical measures (mitigation performance; long-term mitigation ability; and ecological performance, for example) should automatically trigger a declined finance application. The methodology used to calculate the indicators should be clearly stated within the SEA.
8. Strategic Environmental Assessments must also include thorough financial details when economic gain is used to legitimize environmental impact, including estimated revenues, details of how much said revenue is likely to filter through to local communities, and the mechanism by which this filtering is expected. These must be compiled over various time-scales, including those that stretch inter-generationally. For comparison, robust calculations of direct and indirect ecosystem services under zero-change conditions must also be made over the same time periods. Again, the methodology by which all such estimates are gauged should be clearly stated.
9. Cumulative impacts for SEAs must routinely incorporate all other activities that will simultaneously affect relevant natural resources, even those that fall outside the scope of specific EBRD projects. In the event of non-disclosure or non-incorporation of such activities, the SEA must be deemed invalid and completed again with appropriate public consultation.
10. Climate change must also be factored in to both cumulative impacts and economic forecasts within SEAs. When biodiversity offsets are suggested, consideration must be given to how changing weather patterns may affect their success and appropriateness.
11. The teams comprised to develop Strategic Environmental Assessments should be disclosed and discussed with appropriate CSOs as part of consultation processes. The EBRD must also demonstrate a framework by which the expert data and opinions upon which assessment conclusions are based can be independently audited. 
12. Mechanisms for notification of public consultations to CSOs, stakeholders and members of the public must be improved via enhanced visibility, better identification of relevant parties and active invitation to them.
13. Clear, step-by-step guidelines must be established by the EBRD which describe how CSOs and members of the public can pursue and escalate complaints about public consultation processes within the framework of the bank. These should include unambiguous details of both the actions that the bank will take under specific conditions, such as when comments are removed from official processes, and the feedback that CSOs/members of the public can expect to receive.
14. A review of the EBRD’s hydroelectric strategy for the Republic of Macedonia should be undertaken by a team of independent experts approved either by the IUCN or WWF and the bank bound to accept their recommendations. In the meantime, non-hydro green alternatives must be prioritized.
15. The bank’s strategy must consider both direct investment in natural development infrastructure such as wetland rehabilitation and appropriate reforestation, and entwinement of these opportunities with existing/future investment plans. It must also reconfigure its strategy to prioritize public transport over road-building enterprises. As a precondition to investments or finances for projects that will have indirect ecological consequences, the bank must ensure that appropriate physical and personnel infrastructure for environmental protection, such as effective sewerage and waste disposal systems, is functionally in place.    

We hope the EBRD will be responsible enough to take these suggestions on board when it releases its future vision in 2019. Should the bank do so, it will truly become the world-leading financial institution it aspires to be.