Performance Standard 3 –
Pollution Prevention and Abatement
Stakeholder Feedback
Frequently Asked Questions
Does IFC use a dynamic analysis in its project-
related due diligence that takes into account
different contexts? For example, does IFC
evaluate issues such as water use and
technology in different contexts? Who makes
the final decision (IFC or client) about which is
the best choice?
Comments
In the objective section, changing “minimize” to
“reduce” may be perceived as weakening the
standard and is inconsistent with the standard’s
emphasis on pollution prevention rather than
abatement.
The “mitigation hierarchy” which requires
sponsors to “avoid or, where avoidance is not
possible, reduce, restore or compensate/offset
for risks and impacts to workers, communities,
stakeholders and the environment” in
descending order of acceptability should be
applied to the resource efficiency and
greenhouse gas emissions provisions of PS 3.
Quantify and publicly disclose GHG emissions
for all direct and indirect sources, as well as land
use change resulting from projects including
foregone carbon absorption in land set aside for
livestock and feed production. This is
particularly important for land intensive projects
such as forestry, agriculture, livestock mining,
oil and gas, and hydropower.
The cost-effectiveness test was removed from
the Performance Standards introduction, but
remains in the Resource Efficiency and
Greenhouse Gases sections. These sections of
PS 3 do not seem to require large-scale emitters
of GHGs to avoid emissions to the extent
possible.
Environmental pollution can result in violations
of the right to an adequate standard of living,
including the rights to food, water, housing, the
right to health and the right to life itself. PS 3,
IFC Response
IFC’s due diligence of the environmental and social assessment
undertaken by a project sponsor considers the local context as
well as the regional and global context when they are relevant.
This includes issues related to water, water management and the
implications of climate change. For example, recent projects with
captive power plants have adopted air cooled condensers, which
are a response to water stress in project areas. The client
proposes options and discusses them with IFC. This is often an
iterative process.
IFC has reviewed the text and replaced “reduce” by “minimize” as
appropriate.
The concept of “avoid” is difficult in this context. It could lead to
unhelpful discussions about the necessity of energy supply,
motorized transport, and levels of climate control for example. An
efficiency-based standard is more workable in a project-specific
context. Project induced greenhouse gas (GHG) risk on a
community cannot be defined, making appropriate project-induced
restoration, compensation and offset impossible to define.
These provisions are footnoted in the current PS 3 draft. In
addition, the footnote has been expanded to highlight the GHG
impact of decay or organic material. PS 3 does anticipate that
land-use change derived emissions shall be calculated.
This interpretation is correct. It would not be appropriate to drive
clients to enhance resource efficiency and reduce GHG emissions
to the limit of technical and financial feasibility without applying a
cost-effectiveness test. To do otherwise would lead clients to
allocate limited financial resources in a sub-optimal manner. IFC
believes that greater benefit will come through more systematic
implementation of cost-effective measures than by removing the
cost-effectiveness test. The benchmarking approach proposed in
PS3 will support implementation of these requirements. PS 3’s
Resource Efficiency and Greenhouse Gases sections apply to all
clients, not just to large-scale GHG emitters. Note also the
proposal to expand the definition of “cost-effective” to promote
greater attention to these issues.
It is correct that these rights are not explicitly mentioned in
Performance Standard 3 in these terms. However, these rights
will be safeguarded in practice through application of Good
International Industry Practice and the relevant Environmental
which deals with pollution and prevention of
pollution, continues to make no explicit
requirements for clients to identify and address
the risks or impacts that pollution may have in
relation to human rights.
PS 3 fails to require that clients ensure that their
activities do not compromise the availability of
adequate, safe drinking water and water for
domestic use.
Clarify the language in PS 3 to require clients to
prevent pollution and its negative impacts as a
primary objective. Although the current
language makes a number of references to
human health, there is no requirement for the
client to specifically identify health impacts of
pollution or other environmental damage
associated with the project. Similarly, there is no
requirement to ensure that governmental health
surveillance systems are monitoring these
issues and have sufficient information on the
potential and actual pollution that is occurring
as a consequence of the project.
The Performance Standard should require
consideration of affordable and equitable access
to water and sanitation.
Include a reference to apply PS 6 if the water
comes from surface waters that provide wildlife
habitat or other ecosystem services.
Note: IFC’s responses to questions and comments are based on the current draft (Version 2) of IFC’s
Sustainability Framework. They are subject to change as the Framework is further revised. No text in
the Framework or in these interim comments and responses is final until approved by IFC’s
Management and Board.
Health and Safety (EHS) Guidelines, in both cases as required by
PS 3. Point source discharge, and ambient considerations
required by the guidelines are set at levels which avoid adverse
impacts to the rights listed and are inherently considered in the
process of social and environmental due diligence.
This issue is covered in detail in the EHS Guidelines, sections 1.3
and 3.0 in particular. See also the answer above, on the role of
the EHS Guidelines and their use to complement PS 3 and others
PSs.
Please refer to the previous answers which describe the role of the
EHS Guidelines and the EHS Guidelines/PS 3 interface. Health
monitoring by the client may be required when there is a clearly
defined risk. In addition, we would expect clients’ ongoing
community engagement programs and SEMS to identify emerging
health issues and trigger appropriate monitoring and other
enquiries. IFC cannot require (though it can request) health
surveillance by government in the context of a private-sector
project.
PS 3, paragraph 9 “Water Consumption” requires that projects do
not adversely impact the physical presence of water. Paragraphs
6, 11 and 12 which refer to resource efficiency and pollution
abatement, in conjunction with EHS Guidelines, require that the
release of pollutants do not cause adverse impact to human health
and the environment. These separate provisions of PS 3
safeguard both the physical availability and quality of water.
IFC considers this concern as adequately addressed through
proposed PS 3, paragraph 9 covering water consumption.