Environmental Assessment
Volume A-6
Introduction
Consultation
In addition to national laws, there are various processes and planning initiatives
which may affect the development of a large project, including assessment of
potential impacts and of selection of environmental and social mitigation and
benefit enhancement strategies. While these do not prescribe consultative
processes for EAs within the jurisdictions they apply to, consultation is required
to ensure that project activities accommodate and complement to the extent
possible these already agreed participatory planning frameworks. These include
not only regional and commune development plans, but also donor-funded
environmental programs and sector planning by national government agencies.
Finally, ONE issued the ToR for the EA, that require various forms of public
exchange occur to inform the development of the EA; that the EA take into
account the opinions of those parties that are directly and indirectly affected or
interested in the project, cite the means used to do so, and provide a list of all
organizations that were contacted. Consultation follows the policies of the
Malagasy Environmental Charter, adopted in 1990, which recognizes
environmental protection as a top priority, the duty of each to protect it, and the
right of each person to be informed of and participate in decisions, thereby
exerting some influence on the environment.
While the TOR itself do not define a process for consulting, there is a
recommendation that not only written but also visual methods of presenting the
project are used, such as 3-D models, videos, poster boards and diagrams. The
project accordingly developed several different materials for purposes of
consultations (See Volume H, Appendix 5).
6.2.2
International Best Practice
International best practice for public consultation and information disclosure are
outlined in IFC documents as follows:
•
IFC Operational Policies (OPs), particularly
OP 4.01 Environmental
Assessment
; and
•
IFC’s Guidance Note F: Guidance for Preparation of a Public
Consultation and Disclosure Plan.
The IFC’s Operational Policy OP 4.01 requires public consultation and
information disclosure for all large mining projects, such as this project. IFC
particularly promotes early and ongoing public consultation and disclosure by the
project proponent, during scoping of EA issues for purposes of EA Terms of
Reference, during preparation of the EA and once a draft EA has been prepared.
Ambatovy Project
22
January 2006
