Module 23
Public Consultation
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Public Consultation: Why Consult?
2
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Help identify opportunities and risks
Improved project design and implementation
Increase project ownership and sustainability
Specifically required by many of the Bank’s environmental and
social safeguard policies
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
General Obligation to Consult
3
Policy Requirements:
OP 4.01 requires that for all Category A and B projects . . . , during
the EA process, the borrower:
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Consults project-affected groups and local nongovernmental
organizations (NGOs) :
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about the project's environmental aspects, and
takes their views into account.
* OP 4.01, Environmental Assessment, para 14
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Meaningful Consultations: When/how/what
4
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For meaningful consultations between the borrower and
project-affected groups and local NGOs on all Category A and B
projects . . . the borrower provides relevant material:
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in a timely manner,
prior to consultation, and
in a form and language that are understandable and accessible to the
groups being consulted.
* OP 4.01, Environmental Assessment, para. 15
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
When: Timing and Information
5
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The Borrower initiates consultations with project-affected
people:
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For a Category A project, borrower consults at least twice:
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As early as possible, and
Throughout project implementation as necessary.
Shortly after environmental screening and before the terms of reference
for the EA are finalized, and
Once the draft EA report is prepared
The Borrower provides:
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For the initial consultation, a summary of the proposed project’s
objective, description and potential impacts.
After draft EA report is prepared, a summary of the EA’s conclusions
* OP 4.01, Environmental Assessment, para. 14
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
When should the Consultations be Conducted?
6
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When impacts are identified (mostly during preparation) and
during implementation, as required
Sufficiently before project appraisal
As part of preparation of safeguard instruments
For projects where designs are not final at the time of project
approval, during implementation (framework projects)
When design changes lead to new impacts
Consultation should be viewed as a process (that includes formal
and informal consultations).
Beyond specific policy compliance, if one is to effectively manage
risk, it should be carried out as much as needed.
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Who: Identify Key Stakeholders
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Who are they?
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Project affected people, and specific sub groups
Indirectly affected people
Interest groups (any one that could affect the project, positively or
negatively)
NGOs
Local governments
Selecting legitimate representatives- a complicated process?
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
How: Identify Appropriate Ways to Consult
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This will depend on the characteristics of the different groups of
people being consulted, and the issues:
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public hearings or meetings
focus group discussions (separate for men, women, youth, if culturally
appropriate)
households surveys
questionnaires
electronic venues
Method will depend upon topic, education levels of people being consulted,
local tradition, familiarity with electronic media
- Local legal requirements?
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
BP 4.01: Recording the Consultations
9
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PCD/PID records proposed consultations with project-affected
groups and local NGOs, and includes a preliminary schedule
For a Category A project:
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the EA report includes a record of interagency and consultation meetings,
including consultations for obtaining the informed views of the affected
people and local NGOs, specifying all means other than consultations that
were used to obtain their views
An Annex to the PAD summarizes the EA report; the Annex details the
consultations that have been conducted, the issues raised and how they
have been taken into account
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Documenting the Overall Process and Results
10
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A good record of all consultations should be maintained
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how stakeholders were identified and key issues discussed
what information was disseminated
any agreements reached with authorized representatives of any section of
stakeholders (signed minutes advisable)
means (other than consultations) used to obtain the views of affected
groups and local NGOs, such as: social surveys, rapid rural appraisals, focus
groups; and how these collected views were analyzed
form and manner in which the comments and suggestions received during
consultations have been taken into account in making decisions about
project design and implementation arrangements
points on which there is disagreement
For meaningful consultations, views must be taken into account; and, if
they were not, the reasons why some of the comments made by the
stakeholders cannot be accommodated
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Consultation: A Two-Way Process
11
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All participating stakeholders should be informed about the proposed
methods of documenting consultations, and whether views expressed will be
attributed to specific stakeholders
Methods for documenting consultations can vary: Ways of documenting
consultations other than on paper should be considered, such as small video
or audio recorders
Inform participants how they can access the record of consultations
Impacted communities need to feel that their concerns are answered in a
timely and appropriate manner (whether or not the response agrees with
their concern).
Stakeholders who oppose a project must be given an opportunity to
communicate the reasons why.
Responses to objections by impacted communities are specifically recorded
in documentation.
Any suggestions from stakeholders that cannot be accommodated should be
carefully recorded and addressed in project documentation
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Additional Obligations to Consult
12

OP 4.01 states that for projects with major social components,
consultation is required by other Bank policies:
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OP 4.10, Indigenous Peoples
OP 4.11, Physical Cultural Resources
Op 4.12, Involuntary Resettlement
Consultation and meaningful participation is also referred to in:
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OP 4.04, Natural Habitats
OP 4.36, Forests
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Indigenous Peoples
13
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For all projects that are proposed for Bank financing and affect
Indigenous Peoples, the Bank requires the borrower to engage
in a process of free, prior, and informed consultation.
The Bank provides project financing only where free, prior, and
informed consultation results in broad community support to
the project by the affected Indigenous Peoples.
* OP 4.10, Indigenous Peoples, para 1
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
OP 4.10: Free, Prior and Informed Consultation
14
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“Free,
prior,
and
informed
consultation with the affected
Indigenous Peoples’ communities”
refers to
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a culturally appropriate (in native language)
Respecting collective decision-making process
informed participation, not coerced
regarding the preparation and implementation of
the project.
It does not constitute a veto right for
individuals or groups”

OP 4.10, Indigenous Peoples, para 1,
Footnote 4
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Free, Prior and Informed Consultation
15
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“Free, prior, and informed consultation” is consultation that
occurs
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freely and voluntarily,
without any external manipulation, interference, or coercion,
for which the parties consulted have prior access to information,
on the intent and scope of the proposed project, and
in a culturally appropriate manner, form, and language”
* BP 4.10, Indigenous Peoples, para 2 (a)
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Broad Community Support
16
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Broad Community Support… (is when)
the borrower has gained the broad
support from representatives of major
sections of the community required
under the policy . . .
* BP 4.10, Indigenous Peoples, para 7
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
OP 4.12: Involuntary Resettlement
17
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. . . ……resettlement activities should be conceived and
executed as sustainable development programs……Displaced
persons should be meaningfully consulted and should have
opportunities to participate in planning and implementing
resettlement programs.
* OP 4.12, Involuntary Resettlement, para 2
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
OP 4.04 & OP 4.36: Meaningful Participation
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OP 4.04, Para. 9 (Natural Habitats): “The Bank expects the
borrower to take into account the views, roles, and rights of
groups, including local NGOs and local communities …and..
involve such people in planning, designing, implementing,
monitoring, and evaluating such projects.”
OP 4.36 (Forests): “…the meaningful participation of local
people and communities; indigenous peoples; nongovernmental organizations representing consumer,
producer, and conservation interests; and other members of
civil society, including the private sector.”
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Successful Consultation should:
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Ensure that adequate budget is made available to allow for
meaningful consultations: consultation plan
Assess the Borrower’s technical capacity to implement
meaningful consultation, explore ways to fill gaps/limitations
Work with Bank project Social Specialist
Hold meetings in places and at times convenient for stakeholders
Ongoing information disclosure and consultation (beyond
project preparation phase) should be part of project EMP/EMF
A broad Communication Plan/Strategy may be needed for more
complex projects, in order to help establish broad community
support for the project and to assist in reputation risk
management
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Key Points
20
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Identify key stakeholders
Ensure that project information is relevant and in language
accessible to stakeholders
Disseminate information in a timely and appropriate manner
before consultation starts
Consult early and on an on-going basis
Incorporate the results of consultation in the design of the
project
Provide feedback to stakeholders
Document the consultation process
Environmental Safeguards Accreditation Training, January 21 – 25, 2013
Module 23
Toolkit/Resources
21
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Stakeholder Consultations in Investment Lending: Guidance Note
(World Bank, November 2011) - http://wwwwds.worldbank.org/external/default/WDSContentServer/WDSP/
IB/2012/02/26/000386194_20120226233951/Rendered/PDF/67
1210WP00PUBL0ultations0Note0web20.pdf
Stakeholder Engagement: A Good Practice Handbook for
Companies Doing Business in Emerging Markets (IFC, May 2007)
Environmental Safeguards Accreditation Training, January 21 – 25, 2013