Submission from the Center for International Environmental Law (CIEL) on the Draft Guidance Notes for the Environmental and Social Standards of the World Bank ESF

The Center for International Environmental Law (CIEL) submitted comments on December 20, 2017, regarding the World Bank's Draft Guidance Notes for the Environmental and Social Standards (ESS) of the Environmental and Social Framework (ESF). CIEL argues that the Guidance Notes are "severely lacking in substance" and often merely reiterate the standards or use vague language rather than providing the detailed implementation guidance necessary to prevent harm to people and the environment.

• CIEL asserts that the Draft Guidance Notes generally fail to provide the necessary detail for Borrowers to implement environmental and social obligations, often merely repeating the Environmental and Social Standards (ESS) or using vague language.
• Regarding labor conditions (ESS2), CIEL recommends that grievance mechanisms for workers be distinct from project-level mechanisms for affected people and must include protections against reprisals, confidentiality provisions, and the right for workers to be accompanied by representatives or counsel.
• For resource efficiency and pollution prevention (ESS3), CIEL suggests the World Bank reference the ChemSec SIN list of "Substances of Very High Concern" and the FAO's International Code of Conduct on Pesticide Management.
• CIEL argues that the Guidance Notes for ESS3 are insufficient regarding climate change and should explicitly require projects to align with a 1.5-degree pathway under the Paris Agreement to avoid "stranded assets" and high-emission pathways.
• In the area of community health and safety (ESS4), CIEL recommends incorporating the International Code of Conduct for Private Security Service Providers (ICoC) and UNLIREC/DCAF reports to better manage the risks posed by private security personnel.
• Regarding Indigenous Peoples (ESS7), CIEL emphasizes that Free, Prior and Informed Consent (FPIC) must be a process determined by the indigenous peoples themselves, not the Borrower, and should be an iterative process throughout the project lifecycle.
• CIEL highlights the need for specific protections and considerations for indigenous women in ESS7, noting they face structural discrimination and unique vulnerabilities that require disaggregated statistics and intersectional analysis.
• For cultural heritage (ESS8), CIEL recommends referencing the UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage and the UNESCO Convention for the Safeguarding of the Intangible Cultural Heritage to protect intellectual and cultural property rights.
• CIEL identifies a critical omission in the Guidance Notes: the failure to require Borrowers to disclose the existence of the World Bank Inspection Panel to affected communities, which is the primary avenue for seeking redress.
• CIEL argues that project-level grievance mechanisms (PLGMs) often lack independence because they are operated by project management; they recommend adopting the UN Guiding Principles on Business and Human Rights' effectiveness criteria.

APA

Center for International Environmental Law (2017). Submission from the Center for International Environmental Law (CIEL) on the Draft Guidance Notes for the Environmental and Social Standards of the World Bank ESF. https://www.ciel.org/wp-content/uploads/2018/01/CIEL-Comments-to-ESF-Draft-Guidance-Notes-December-2017.pdf

Chicago

Center for International Environmental Law. Submission from the Center for International Environmental Law (CIEL) on the Draft Guidance Notes for the Environmental and Social Standards of the World Bank ESF. 2017. https://www.ciel.org/wp-content/uploads/2018/01/CIEL-Comments-to-ESF-Draft-Guidance-Notes-December-2017.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Submission from the Center for International Environmental Law (CIEL) on the Draft Guidance Notes for the Environmental and Social Standards of the World Bank ESF |date=20 December 2017 |url=https://www.ciel.org/wp-content/uploads/2018/01/CIEL-Comments-to-ESF-Draft-Guidance-Notes-December-2017.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2017submission, author = {{Center for International Environmental Law}}, title = {{Submission from the Center for International Environmental Law (CIEL) on the Draft Guidance Notes for the Environmental and Social Standards of the World Bank ESF}}, publisher = {Center for International Environmental Law}, year = {2017}, month = dec, url = {https://www.ciel.org/wp-content/uploads/2018/01/CIEL-Comments-to-ESF-Draft-Guidance-Notes-December-2017.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }