Submission to public consultations on EDC's ERF (October 2001)

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Submission to the public consultations on EDC's Environmental Review Framework

The NGO Working Group on the Export Development Corporation welcomes the opportunity to provide comments on the Environmental Review Framework (ERF). We have been asking for this opportunity since April 1999 when EDC first released the ERF. It is our recommendation that the second version of the ERF be released in draft, before its adoption by the Corporation. Version 2.0 of the ERF will include such critical information as performance and process standards and EDC’s stakeholders should have an opportunity to comment on the specifics of the policy. This process has been followed by EDC in its release of the draft disclosure policy and subsequent comment period.

A critique of the existing Environmental Review Framework can be found in our policy paper, Race to the Top, and in the introduction to Reckless Lending, Volume I. Our outline of a good environmental assessment process for EDC can be found in Environmental Assessment and the Export Development Corporation: The Shock of the Possible. All three of these documents are available on our website at www.halifaxinitaitive.org. This submission is based on these documents and our participation in the subcommittee on the EDC, convened by the Canadian Environmental Assessment Agency.