CATEGORIZATION: Category B The World Bank designates the project as Category B, meaning it will have potential adverse environmental impacts on human populations or environmentally important areas - including wetlands, forests, grasslands, and other natural habitats - which are less adverse than those of Category A projects. These impacts are site-specific; few if any of them are irreversible; and in most cases mitigation measures can be designed more readily than for Category A projects. The World Bank's B categorization comes from the 2011 project documents. However, in the more recent 2014 WB Project Information Documents, the Environmental Categorization is conspicuously missing. Nonetheless, these World Bank documents and the FCPF R-PP indicate that the proposed project will have a uniquely massive scope. World Bank documents state, (m)any of the activities that will be financed are national in scope and identifies five early action areas. This indicates that REDD+ activities may eventually extend to other areas as well. In addition, World Bank documents indicate that the proposed REDD strategies will affect many aspects of individual's lives and livelihoods, including central concerns such as income, housing, and food. Thus, potential breadth and depth of impacts from this project suggest that the project's environmental and social risks should be closely considered, and that the World Bank's stated categorization should be scrutinized. SOURCES: World Bank Environmental Categorization, accessed at http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/0,,contentMDK:20061220~menuPK:51564~pagePK:41367~piPK:51533~theSitePK:40941,00.html WB Project Information Document, Concept Stage, Report No. ISDSC6213, 2014 APPLICABLE SOCIAL AND ENVIRONMENTAL STANDARDS: Five World Bank safeguards (from the WB Operational Policies) have been triggered, three have not been triggered, and two safeguards are still to be determined. According to the Bank, the triggered safeguards are: * Environmental Assessment, OP/BP 4.01 * Natural Habitats, OP/BP 4.04 * Forests, OP/BP 4.36 * Indigenous Peoples, OP/BP 4.10 * Involuntary Resettlement, OP/BP 4.12 The safeguards still to be determined are: * Physical Cultural Resources, OP/ BP 4.11 * Pest Management OP, 4.09 Because this grant is specifically for funding REDD+ preparations, the safeguards process is not yet complete. World Bank documents indicate that a thorough assessment for each of the triggered safeguards is still to be accomplished, and will be done through the existing FCPF REDD+ readiness process. The Project Information Document states: (g)iven the highly specific nature of REDD+ Readiness, the Participant's Committee of the FCPF proposed using a Strategic Environmental and Social Assessment (SESA) as a way to address social and environmental safeguards during readiness... The SESA process is characterized by a strong analysis of the drivers of deforestation and the strategic options and a participatory approach to reviewing the potential environmental and social safeguard issues that will need to be considered during the preparation of the ENAREDD+ and the REDD+ Readiness process. Specifics on each safeguard are given below. Environmental Assessment The SESA will assess key social and environmental risks and potential impacts associated with REDD+, and will develop a management framework (ESMF) to give general guidelines to prevent and mitigate such risks and potential impacts. Natural Habitats The SESA will assess the possible risks associated with strategic options relating to forest habitats in protected areas and other sensitive habitats that are under private control or community. This analysis should be worked in close coordination with the CONANP and the National Commission for the Knowledge and Use of Biodiversity (CONABIO). Forests With regards to forests, the REDD+ Strategy will build largely on the experience of CONAFOR with the Community Forestry, Payment for Environmental Services (PES), and Sustainable Forest Management Certification programs During the preparation phase, these and other forestry and rural development initiatives will be evaluated in order to ensure lessons are incorporated early in the design and key social and environmental risks and potential impacts associated with REDD+ are considered in the ESMF. Indigenous Peoples Within the first few months of the grant period, the ENAREDD+ Consultation Plan, which is a condition of disbursement, will be prepared and will outline the specific process for the free, prior and informed consultation with indigenous peoples as required by OP 4.10 [...]. In addition, the SESA workplan includes studies that will analyze the potential impacts of the REDD+ strategic options on indigenous peoples and these will be used to inform the final version of the ENAREDD+. The main product of the consultation and SESA processes will be an ESMF with a stand-alone Indigenous Peoples Planning Framework (IPPF) or Indigenous Peoples Plan as appropriate. Per the requirements of OP 4.10 and the conditions of this grant, a representative group of Indigenous leaders will provide their broad community support for the IPPF prior to approval. The IPPF will be validated by a representative group of indigenous leaders and will provide a clear process for the development of specific Indigenous Peoples Plans if required and the process for attaining and documenting broad community support at the regional/local level for any future REDD+ actions financed by the World Bank. Involuntary Resettlement World Bank documents state, (t)here will be no acquisition of land or resettlement of persons and it is not anticipated that use of natural resources in national protected areas will be restricted by the strategic options that are currently included in the ENAREDD+." However, Bank documents note, "OP 4.12 has been triggered as the strategic options have not been fully defined and they may change during the process of finalizing ENAREDD+. During the SESA process, specific efforts will be made to review the potential risks and benefits of the strategic options identified in the ENAREDD+ in relation to the use of natural resources in protected areas. If necessary, a stand-alone Process Framework will be prepared to accompany the ESMF in order to manage any negative impacts and to ensure that appropriate compensation or livelihood support for those affected is provided SOURCES: WB Project Information Document, Concept Stage, Report No. ISDSC6213 (2014), accessible at http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/LCR/2014/03/20/090224b0823510b4/1_0/Rendered/PDF/Integrated0Saf0tion0Grant000P120417.pdf WB Project Information Document, Concept Stage, Report No. (BLANK) (2011), accessible at http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2011/10/26/000020953_20111026103302/Rendered/PDF/651430ISDS0MX0FCPF0readiness0preparation.pdf CONSULTATION PROCESS Bank documentation notes that REDD+ readiness is "a complex and challenging process." To be successful, the Bank notes, it will require "solid consultation with, and coordination amongst the various platforms at the policy level and at the multi-stakeholder level." Moreover, it is "expected" that a guiding document defining the national plan for consultations will be prepared before the final draft of ENAREDD+ is released for consultation. According to the Bank, "Particular attention will be paid to Indigenous Peoples and forest-dependent communities as well as to other vulnerable groups such as women and youth" in order to guarantee their full and effective participation." Summarizing the process of stakeholder engagement thus far, Bank documentation states "CONAFOR has been leading the preparation of the ENAREDD+ through a participatory process that is anchored by a multi-stakeholder technical advisory committee - Comité Técnico Consultivo or CTC-REDD+, which includes representatives of key governmental institutions (forestry and non-forestry), NGOs, indigenous peoples, forest community-based organizations, the academic sector and financial institutions". The committee's mandate is "to provide an open and transparent participation platform for the preparation of ENAREDD+. In addition,CONAFOR also works with other important platforms that have been established such as the Technical Advisory Committee of the REDD+ Working Group under the CICC (Comité Técnico Asesor del Grupo de Trabajo REDD+ or CTA del GT-REDD+) and the ENAREDD+ working group of the Consejo Nacional Forestal (CONAF). Bank documentation states that the FCPC grant of $950,000 will achieve the following objective: "At the local and state level, existing platforms will be strengthened in order to ensure that potentially affected stakeholders have an opportunity to raise specific issues and concerns regarding REDD+ that affect them. For example, the approach of the Community Forestry program includes the identification and integration of spaces for social participation and consultation (foros regionales or regional natural resources committees) in order to better plan, evaluate and monitor the construction of community development processes and to strengthen social capital. The FCPC grant would also finance additional human resources in CONAFOR "to support the strengthening of the existing multi-stakeholder -participative platforms" both at the national and the state level (regional CTC in five states). The FCPF grant requires that REDD+ preparations involve all major affected stakeholders. The stakeholders thus far involved include:  From Government: National Forestry Commission (CONAFOR); National Ecology Institute (INE); Ministry of Agriculture, Fisheries, and Livestock (SAGARPA); Commission on Protected Natural Areas (CONANP); National Biodiversity Commission (Conabio); General Directorate of Climate Change Policy (*recently created);:  From Academia: College of the Southern Border (Ecosur); College of Mexico (Colmex); College of Postgraduates;  From Civil Society: WWF; Pronatura; Conservation International; Greenpeace; Mexican Civil Council for Sustainable Forestry (CCMSS); Reforestemos México; Rainforest Alliance; SAO A.C.; FMCN; Pronatura; UNOFOC; It should be noted that local community groups, grassroots organizations, and indigenous groups have not been included in this initial list of stakeholders. While several large international organizations are mentioned, there is a historic disconnect between some organizations and groups on the ground which should be informed and included in any consultation and participatory process. Proper access to information and public participation in decision-making process are legally required with communities who may be affected by REDD+ implementation. Additionally, indigenous communities have the right to free, prior and informed consultation when their collective rights are being affected. Therefore, a concerted effort should be made to include all interested parties and stakeholders in this process, more so considering that consultation has been identified as an essential part of REDD+ implementation in Mexico. CONAFOR and CDI, the Bank notes, "signed a collaboration agreement in July 2013 that includes a mandate to design and implement consultation and dissemination activities specifically targeted to indigenous people, as well as the promotion of indigenous participation in the existing participatory platforms." Potential risks of the REDD strategy options applicable to Mexico, the Bank states "will be widely discussed with relevant stakeholders during consultations" and during the drafting of a new workplan to assess Social and Environmental Impacts. SOURCES: WB Project Information Document, Concept Stage, Report No. ISDSC6213 (2014), accessible at http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/LCR/2014/03/20/090224b0823510b4/1_0/Rendered/PDF/Integrated0Saf0tion0Grant000P120417.pdf FCPF Readiness Preparation Proposal (R-PP,) 65, accessible at http://www.forestcarbonpartnership.org/sites/fcp/files/Documents/tagged/Mexico_120211_R-PP_Template_with_disclaimer.pdf ENVIRONMENTAL AND HUMAN RIGHTS RISK ASSESSMENT RIGHT TO PROPERTY AND ADEQUATE HOUSING Because REDD+ strategies will concern massive areas of land, tenure issues are inseparable from REDD+ implementation. Tenure rights such as the rights to housing and property must therefore be monitored closely. Individuals and communities are particularly vulnerable to violations of these rights if such individuals or communities are physically located in forested areas, or if they access forests or utilize forests for income. The concept of fortress conservation, where conservation goals are met through rigid policies barring use and access, is generally considered a poor conservation strategy in areas where forests are in use by communities. Nonetheless, people or communities residing in or near forests should be aware of the potential to lose housing or property rights through use or access restrictions stemming from REDD+ strategies. The threats to rights to housing and property fall into two general categories. First, rights are violated when REDD+ policies directly remove ownership and/or access to land from people or communities that resided on or gleaned income from the land. Because of the nationwide scale of REDD+ strategies, and the difficulties inherent in recognizing and respecting the wide variety of land tenure scenarios, there exists a marked potential for individuals and communities to lose tenure rights like housing and access to property during REDD+ implementation. For example, the ENAREDD+ strategy, as articulated in the R-PP, calls for an expansion of the National Protected Areas program, which has the power to limit activities in forested areas. Expansion of this program into new forest areas or modification of existing policies for the sake of REDD+ could result in the loss of informal ownership of land, or access to land and other resources which are now relied on for sustenance or income purposes. Second, rights may be violated when REDD+ implementation is delegated to the community level. The World Bank Project Documents report that Mexico has a uniquely high percentage of its forestlands held by communities, and thus REDD+ will need to engage these communities during implementation. Rights to housing and property may be violated if safeguards fail to reach vulnerable groups within communities. A World Bank study highlights in particular the threats of elite capture, rent seeking, and gender bias when communities or other intermediaries are used to implement REDD+ components, such as the distribution of PES (payment for ecosystem services) monies or benefits, or delivery of certain REDD+ strategy components. It is therefore important to consider what safeguards will be in place to ensure rights are respected beyond the communal threshold. The following questions may be relevant to determining whether you or your community's right to property and adequate housing has been adversely affected by the World Bank's proposed funding. Remember that the World Bank requires that a Consultation and Participation Plan be implemented and that all major affected stakeholder be consulted. This consultation must occur at the national level, the regional (state) level, and the local level. - Who currently controls your access to housing and land? Are those people or organizations currently involved in REDD+ discussions? - Have you received information on REDD+ impacts on your ownership rights, land use rights, or access rights? Have these specific issues been discussed in any consultations with you, your community, or with your representatives? - Are there currently plans in place to inform you of REDD+ developments, especially impacts on ownership, use, or access to land? Are there currently plans to discuss REDD+ programs and their implications, costs and benefits, with you, your community, or your community leaders? - Have your representatives been participating in discussions regarding your rights to housing and property and how these might be affected by new forest policies? Have your representatives informed you of the outcome of these discussions? - Has your housing right, right to access, or right to use land, been affected by past forest policies or programs? - Are there options available (legal or otherwise) through which people can file a complaint and/or obtain a remedy if their right to housing or property has been affected? SOURCES: FCPF Readiness Preparation Proposal (R-PP,) 65, accessible at http://www.forestcarbonpartnership.org/sites/fcp/files/Documents/tagged/Mexico_120211_R-PP_Template_with_disclaimer.pdf LABOR RIGHTS AND LIVELIHOOD One of the most serious concerns with REDD+ implementation is that it may result in forest use changes that negatively affect the livelihoods of people and communities, without providing for adequate compensation and/or alternative livelihoods. The Readiness Preparation Proposal (R-PP) identifies a number of risks associated with the currently proposed REDD+ strategies. Many of these strategies carry risks to labor rights. Compensatory payments for ecosystem services provided by forests and forestlands may not initially compensate for loss of timber income, because the near-term timber production may be greatly slowed. In addition, PES are unlikely to equal income from illegal logging, meaning that some forest users will likely experience a drop in income if REDD+ decreases logging. In the livestock sector, the R-PP notes that PES are currently unlikely to be competitive with income based on current livestock practices, and that there is a lack of capacity to develop better alternative practices. That means that livestock ranchers risk losing income if REDD+ strategies require changes in their livestock practices. While these are just a few examples of the potential impact of REDD+ on labor and income, it should be remembered that REDD+ seeks to change existing labor and income associated with the use of forests and forestlands; consequently, if REDD+ is implemented poorly, it may be widely detrimental to incomes. The following questions may be relevant for determining if your community has been adversely affected by REDD+ implementation: * Do you work in the forestry industry, or in/near forestlands, and do you know how REDD+ will affect your land, income or job? Have you been informed of any changes? * Do you or your family expect to change jobs, or do you expect aspects of your job to change, due to REDD+ implementation? * Have you or your family lost income as a result of REDD+ implementation? * Do you have access to grievance mechanisms (legal or otherwise) in case your livelihood in affected? RIGHT TO FOOD REDD+ implementation is expected to have large impacts on land use and tenure rights. Among the biggest goals of REDD+ implementation is reducing forest degradation and deforestation associated with current livestock and agricultural practices. Because REDD+ will almost certainly affect livestock and agricultural practices the right to food should be closely considered. The following questions may be relevant for determining if your community has been adversely affected by REDD+ implementation. * Do you or your community expect to be deprived of your means of subsistence through REDD+? * Have you been informed of any changes you will need to make to your current livestock or agricultural practices? RIGHTS OF INDIGENOUS PEOPLES Bank documentation indicates that there are approximately 15.7 million indigenous peoples in Mexico (14.9% of the total population) that speak 62 distinct indigenous languages and" have lived in Mexico for thousands of years and developed highly complex societies that were fully functioning at the time of contact with the Spanish in the 15th century." This diversity, the Bank adds, "makes the preparation of a national level policy such as REDD+ extremely complex." Indigenous peoples are particularly vulnerable to rights violations under REDD+, because their tenure rights are often not officially recognized under state level or national level legal frameworks. In particular, the expansion of the National Protected Areas program may involve indigenous peoples' lands. Free, prior and informed consultation is a World Bank Operational Policy requirement, and must be followed in FCPF REDD+ implementation. However, World Bank policies only require consultation rather than full consent of the community. Currently, broad based approval from communities is the standard for going forward with REDD+ strategies, This leave room for questioning how effective any given consultation may be. The FCPF Guidance Document states that at minimum the following information should be supplied for free, prior and informed consent: a. The nature, size, pace, reversibility and scope of any proposed project or activity; b. The reason/s or purpose of the project and/or activity; c. The duration of the above; d. The locality of areas that will be affected; c. A preliminary assessment of the likely economic, social, cultural and environmental impact, including potential risks and fair and equitable benefit sharing in a context that respects the precautionary principle; d. Personnel likely to be involved in the execution of the proposed project (including Indigenous Peoples , private sector staff, research institutions, government employees and others) e. Procedures that the project may entail. The following questions may be relevant for determining if your community has been adversely affected by REDD+ implementation: a. Were you recognized as an indigenous group, and have you been consulted on REDD+ matters? b. Have you been supplied with information sufficient to make informed decisions? c. FCPF Guidance Document require that consultations be recorded along with all results from consultations-- has this occurred and do you have access to the documentation? d. According to the Guidance Document, Free within FPIC implies that no coercion, intimidation, or manipulation occurred. Was this requirement met in your community? e. According to the Guidance Document, prior implies consent has been sought sufficiently in advance of any authorization or commencement of activities, and with respect for the time required for communities to consult and deliberate. Was this requirement met in your community? RIGHTS OF MARGINALIZED AND DISCRIMINATED AGAINST GROUPS Marginalized and discriminated groups are particularly vulnerable in REDD+ implementation. Such groups may be insufficiently represented in decision-making and strategy formation processes at all stages of project planning , leaving them open to rights violations during implementation. The following questions may be relevant for determining if your community has been adversely affected by REDD+ implementation: a. According to FCPF Guidance Documents, special attention should be given to the inclusion of women and other vulnerable groups in decision-making. To your knowledge or in your experience, has this been the case in planning for REDD + with your group or community? b. Likewise, consultation with women and other vulnerable groups is required by the FCPF Guidance Document. To your knowledge, has this occurred with your group or community? c. If specific vulnerable groups like women, the young, or the elderly, have been adversely affected by REDD+, were they given prior notice of these impacts and adequately consulted on their implementation?

ACCOUNTABILITY MECHANISM OF WORLD BANK The World Bank Inspection Panel is the independent complaint mechanism and fact-finding body for people who believe they are likely to be, or have been, adversely affected by a World Bank-financed project. If you submit a complaint to the Inspection Panel, they may investigate to assess whether the World Bank is following its own policies and procedures for preventing harm to people or the environment. You can contact the Inspection Panel or submit a complaint by emailing ipanel@worldbank.org. You can learn more about the Inspection Panel and how to file a complaint at: http://ewebapps.worldbank.org/apps/ip/Pages/Home.aspx.