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[Policy letter] Public Information Policy revision letter to EBRD
Horst Reichenbach
Secretary General
EBRD
One Exchange Square
London EC2A 2JN
United Kingdom
Fax: +44 20 7338 6488
10 January, 2006
Dear Mr. Reichenbach
Re: EBRD’s Public Information Policy Review
During a meeting with Paul Martin CEE Bankwatch Network was informed that the EBRD is planning to review the Public Information Policy before the 2006 EBRD annual meeting. Since CEE Bankwatch Network has substantial experience with the policy implementation as well as with previous policies reviews and consultations organised by the EBRD, I would like to suggest the following measures to make the forthcoming policy review efficient and fruitful for all stakeholders.
Previous experience of EBRD organised consultation workshops involving various stakeholders, as was the case for the Environmental Policy review in 2003 and the Energy Policy review in 2005, has found such workshops to be broadly worthwhile and productive. Workshops participants - both bank and civil society representatives - have found interactive debates more efficient than the “blind” submission of comments to policy drafts. Such meetings have provided a valuable opportunity to discuss the most important issues and to generate feedback.
However, according to our information, the EBRD has not considered conducting consultation meetings during this year’s revision of the Public Information Policy. In June 2005, in contrast, the European Investment Bank held a public consultation workshop on its Draft Information Policy.
We realise that organising two intensive consultations in one year will require a significant amount of EBRD staff time not to mention financial resources. On the other hand, the Public Information Policy is one of the fundamental EBRD policies which cuts across the EBRD’s lending activities. Due consideration for stakeholders' opinion during the revision of the policy can only serve to improve the profile of the EBRD. Therefore, as a compromise, we suggest that the EBRD should conduct a dedicated workshop during the annual meeting in London in May this year. Traditionally, the meeting brings together representatives of civil society, business and the media that are most interested in EBRD activities and this will be an excellent opportunity to discuss changes to the Public Information Policy.
Related to the above, we would like to advise the EBRD to publish the draft Policy, submitted public written contributions and all consequent documentation on its website prior to the public consultation workshop. Ideally, the documents should be made available online in a timely fashion once they are issued by the EBRD or submitted to the EBRD.
Another possible improvement of the policy revision process could be achieved by inviting public comments and suggestions to changes in the policy prior to the development of a new draft for comments. Such an approach was taken by the EBRD during the recent review of the Natural Resources and Energy Policies. This will help the EBRD to identify the most important areas where the Public Information Policy needs to be changed.
We also would like to suggest that you invite the Aarhus convention secretariat to the review process. As you know, the Second Meeting of the Parties to the Aarhus convention adopted “Almaty Guidelines on Promoting the Application of the Principles of the Aarhus Convention in International Forums” and established a Task Force to enter into consultations regarding the Guidelines with relevant international forums. We believe that their input would be vital as the Aarhus convention is one of the bases for the EBRD’s policies and the Guidelines have direct relevance for the EBRD.
Finally, we would like to request that you publish the 2005 Report on Implementation of Public Information Policy before the start of the consultation in order that it is available at the time of the policy review (we note that the implementation Report for 2004 is date May 2005). Bearing in mind the greater proportion of EBRD activities conducted in the countries of the former Soviet Union, it would also be extremely helpful if the EBRD could set a precedent by making the translation of both the 2004 and 2005 implementation reports available in Russian.
I look forward both to your positive consideration of our proposed measures and to a fruitful review of the EBRD’s Public Information Policy.
Yours sincerely,
Yury Urbansky
International EBRD Campaign Coordinator
CEE Bankwatch Network.











CEE Bankwatch Network gratefully acknowledges EU funding support.