يـحيــى للهنــــدســــة
Yahya Engineering
Radical Transparency: Bettering ESHIA Public Disclosures through Trust
By Manishankar Prasad,
Date of Publication: 24 May, 2020
Stakeholder Engagement and Disclosure in Oman Stakeholder Engagement and Public Hearing in India
In a decade plus policy research and consulting experience, the term ‘Public Disclosure’ evokes sentiments of trepidation from internal and external clients, whenever the results of an ESHIA or a planning strategy project must be shared with the ‘public’. The ‘public’ is usually the very community in which the project is to be implemented, if a townhall style disclosure is carried out with images of fiery exchanges. Today, the public has a ‘meta’ meaning, as it involves anyone with an interest in the project from financial institutions, international non-profits, watch dogs and academic institutions. Every detail regarding a project are a few clicks away in this hyperconnected, information saturated era of open source intelligence.
Public Disclosure is a key tenet of environmental, social and governance or ESG norms set out by environmental regulators and financial institutions adhering to Equator Principles. Public Disclosure though is a function of the political economy of the place. The ‘culture’ of information depends on the systems of governance. Some countries do not have any formal mechanisms for public discourse nor of stakeholder engagement at least in the western sense, as they have traditional systems of governance such as the Majlis or Diwaniya (in Kuwait) or the community forum for deliberation and consultation in the Gulf. Formats of public consultation are being reconfigured to suit public disclosure and public consultation requirements of international lenders in the Gulf, as the post carbon economies mandate economic diversification. Many countries of the Gulf have tapped the international bond markets for bridging budget deficits in the light of the global economic pause due to COVID-19. Oman has tapped AIIB funding for major projects of national importance such as the Ibri-2 IPP 500 MW Solar Project which achieved financial close recently. Yahya Engineering was the EIA Consultant for the project and carried out all the social consultations for the initiative including a Resettlement Action Plan, one of a kind for the country.
Even if the public disclosure of an ESHIA document is mandated, responses of quality do not come in because the community is not skilled enough at digesting the technical planning data, and the ability of frame a cohesive response is a work of science communication. Public disclosures are mainstream, as can be seen with a simple internet search, that ESHIA report non-technical summary and sometimes the entire tranche of reports are listed online from Myanmar to Canada.
An excellent example of public disclosure is with EIAs in Singapore particularly for programs of national importance. MRT projects such as the cross-island line created a lot of buzz with the public as it cut through the Bukit Brown Cemetery, a cultural heritage site and a national reserve. The entire EIA report package prepared by global firm ERM was on the Land and Transportation Authority website as a part of the public disclosure process. On a similar note, the now halted Singapore-Kuala Lumpur High Speed Railway, had its more than thousand pages of the ESIA report on its project website.
Recently, an EIA for The Sisters Island Marine Park attracted attention among the environmental community with members of the public complaining on social media on the ‘technical’ language of the report and that the procedure for accessing the report with prior appointment during weekdays and in hard copy is restrictive. Project owners in this case National Parks Singapore, is a government body facilitates public disclosure[1] in a calibrated manner so that only the most serious of analysts and activists have access to the report.
A success story in public consultation and disclosure[2] is the Singapore Government’s roadmap for a ‘Long Term Low Emission Development Strategy’ which attracted heavy feedback from the civil society such as Nor Lastrina Hamid[3] and Melissa Low[4] as individuals active on the climate change scene and formal non-profits. The Singapore government has collated such excellent feedback (two thousand of them) and has issued a response on it as well[5].
India has a rich track record in public disclosures for environmental governance as each major project needs a public hearing, which is scheduled by issuance of newspaper notices and the EC or the Environmental Clearance is also published in a newspaper. However, the follow up of the questions raised during the public disclosure session (that can be pretty theatrical and loud) is different matter altogether. When project owners do not take the community’s consent in India, matters have escalated into sophisticated people’s movements such as the Narmada Bacho Andolan, the dam over the river Narmada spanning Gujarat and Madhya Pradesh. There was widespread resettlement of people in the project, which has led to intergenerational discontent, captured as an oral history archive by Nandini Oza.
The new emasculated EIA 2020 Draft legislation in India in the backdrop of the Vizag accident, which did not have a valid permit should be a wake-up call for regulators, trying to water down the tool in the name of investment promotion. The environmental community including Manthan led by veteran environmental activist Mr. Shripad Dharmadhikary has written a powerful critique of the new legislation in the India Development Review portal. Manthan, as an active civil society player has sent feedback during the consultation period open to the public. ‘Radical Transparency’ the key syntax introduced in this article, encourages the environmental ecosystem to embrace uncertainty by speaking to stakeholders on the other side of the isle, such as civil society actors.
Public disclosure is the end point of the planning public consultation process. For a successful social licence to operate, the consultation must be continuous with the most active of stakeholders, who are directly impacted. One of the reasons why public disclosures are perceived as performances of rhetoric as diversity as the voices spoken during the consultations are not recorded accurately (in many cases due to the language gap), as in many cases recording of interactions cannot be done to protect the identities of the most vulnerable, who often are doubly disenfranchised as migrant workers as poor, illiterate and precarious visa status holders. The COVID-19 pandemic has brought out the precarity of the visible, yet muted migrant worker back in the spotlight of attention. Interactions with communities must be transcribed verbatim, recorded with content and not only be tracked in broad brushstrokes of bullets which are opportunities for erasure and not for inclusion. How can communities in the project influence area take the project seriously if their voices are being silenced from the beginning?
Intent of good practice must be backed up with evidence.
Shabbily performed EIAs in fragile contexts will be on the radar of international watch dogs such as Amnesty International or Carbon Tracker[6], which raise questions, putting the viability of the project itself in doubt. Reputational capital is a key outcome of the ESG paradigm. Building trust through radical transparency creates the buy in for win-win solutions for the project owner and the community in a post pandemic world.
A concrete measure of building confidence in the project through best fit transparency measures would be to:
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Increase the time frame for public disclosure. One more month would not matter much over the horizon as a project lifespan is of 25 years on an average.
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Make the reports open for reading online
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Make the reports available in local languages, if possible, most of the report
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Many people in the community might not be literate, make an audio/video narration recording of the non-technical executive summary available on the project website
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Make a non-technical executive summary which is in a visual format with greater use of mapping for easier understanding. The inaccessibility of the ‘technical’ is watered down by the intervention of visual and spatial aids.
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Make a video of the project features for easier appreciation
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Invite watch dogs and community organisations to co-write the story instead of treating them as the other. Projects create local jobs which is the need of the hour in a global recession
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Understand the pain points of communities, listen with sincerity and be generous
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Create passionate supporters, like a Chicago Politician working through a campaign fund raising dinner
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Be innovative to accept solutions which have been attempted before by working with unconventional stakeholders
In this epoch, where conventions fall by the wayside due to the pandemic, communities will need greater trust to be nurtured in this low touch scenario. Public Disclosure is a window to create a high trust environment even if the digital realm is utilized for the event, for a low touch reality.
We at Yahya are thinking through the next generation of stakeholder engagement practices for shared value creation. Please reach out at manishankar@yahyaengineering.net for more
References:
[1] https://wildshores.blogspot.com/2020/02/eia-for-plans-for-sisters-islands.html#.Xsi-sWgzY2w
[2] https://www.nccs.gov.sg/public-consultation/
[3] https://www.nccs.gov.sg/docs/default-source/publications/Nor%20Lastrina%20Hamid.pdf
[4] https://www.nccs.gov.sg/docs/default-source/publications/Low,%20Melissa.pdf
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