I. Recommendations (Page 6):

(i) Policy Non-compliance: At the beginning of the Report, the Panel should list all of the policies that the Panel was investigating and their assessment of them regarding compliance. This is a crucial piece of summary information as it will lay out the result of the investigation very clearly. Anyone reading the report (especially The Board) can then see very clearly all incidences of non-compliance and breach of policies which the Panel found on every Policy mentioned by the Requesters in their inspection request.

(ii) Specific recommendations: The Panel should make specific recommendations for each policy violation they identified.

(iii) Recommendation 3: This recommendation should apply not only to large scale canal irrigation projects. It should apply (at the very least) to all water sector projects and all infrastructure projects in Pakistan since the executing agencies are the same and the ADB Operational Department (SAR) is the same. The problem thus is systematic, and not confined to canal projects alone.

(iv) Compliance: On the recommendations page, the Panel should make a clear and strong statement that Board should ensure that the ADB brings the Project into full compliance with ADB policies. The fact that the Board Inspection Committee (BIC) decided in favor of the GRSC over-riding the views of the Requesters must also be mentioned.

II. Introduction

(i) On page 9, The Panel should mention the entire GRSC debacle between Para 13 and 14 since otherwise the reader does not know what exactly happened between April 2003 and December 2003.

III. Project History
In para 43, it's important to mention that the ADB initiated the multi-stakeholder process ONLY after tremendous pressure from NGOs. This was not something the ADB did of its own volition.

In para 44, can the Panel indicate the date on which ADB forst communicated the idea of GRSC to NGOs/Requesters?

III. GRSC:

The Panel's overall assessment of the GRSC must be included at some point in the report. The Panel, based on what they write about the GRSC in the report, should conclude that the GRSC was wholly inadequate and cannot be the basis for the implementation of the Panel's recommendations.
page 18, paras 61-63: The assessment of GRSC is not clear in these paragraphs. It seems to imply that GRSC's work was too narrow in scope and that nothing was really accomplished by GRSC, but the Panel does not state this directly. For example, it gives the impression that GRSC recommendations which were accepted by the government have been acted on or are currently being acted on and that these will address some of the harms outlined here. Do we know if GoP has acted on some of those GRSC recommendations?

Page 18, para 62: It should be made clear that the Matrix mentioned in this para was NOT developed following a participatory process as stated in the ToR of the GRSC.

page 25, para 88: The sentence "some issues remained unsettled and important tasks were left unfinished" makes it sound like GRSC actually accomplished something -- if so, what? The Panel should provide a clearer assessment of GRSC.

page 50, para 202: This point (regarding the GRSC) should be elaborated to explain what was it, in the Requester's view, about the GRSC that made them refuse to participate in the GRSC as it then formed. It would be useful for the Panel to record this and also give its view of the essential pre-requisites for meaningful participation which the GRSC did not contain.

page 51, para 206: "Even without going into discussions about shortcomings in terms of its composition and mandate, the most recent experience of the GRSC illustrates the problem [of participation]." The Panel needs to go into a discussion about these shortcomings- composition and mandate -- somewhere in report. Current references are vague in the sections before this, and leave the reader with a mixed impression of Panel's view on GRSC.

"As of 1 January 2004 there is again no forum where the voices of the affected people and their representatives can be heard, and where they can execute their right to participation..." This implies that the GRSC gave the affected people this opportunity and actually provided a forum for voice, participation, etc. Does the Panel mean to give this impression? If not, the Panel should restate this more clearly.

page 53, para 219: This para makes it seem that GRSC recommendations/mitigatory measures would address these problems if implemented. In earlier sections, the Panel raises questions about the adequacy of these measures. If this point isn't clarified (the Panel's assessment of the GRSC and its outcome), Management can use the GRSC recommendations, plus an enhanced commitment to monitor their implementation, as their proposed remedy/response.

page 54, para 227: "The inadequacy of the GRSC with regard to its mandate for activities such as long-term ... is discussed in Chapter 3...." As stated above, a clear, comprehensive discussion of these inadequacies is missing. The next paragraphs 228-232 point to some of the GRSC inadequacies that should be summarized in Chapter 3 as well as part of this comprehensive discussion.

Page 54, para 228: Why was the GRSC unable to finish its task? Was it because its consultant (International Resettlement Consultant) was away on leave for most of his tenure? Or was it that the ADB staff in Manila and in the Pakistan Resident Mission did not adequately monitor the GRSC, a body on which the ADB staked its claim as the solver of all problems.

IV. Other Specific Points

(i) Recommendation #3: add word "participatory" to this sentence so that it reads as: "…ADB needs to ensure that appropriate, reliable and transparent and participatory mechanisms are in place…"

Page 17, Para 57: Does the Panel mean "full re-appraisal" instead of "full appraisal"?

Page 18, para 58: This paragraph should be written more clearly.

Page 22, para 72: The phrase "at least as a matter of best practice" should be taken out since the ADB does have a duty to monitor the obligations of a borrower as mentioned in the loan covenants.

Page 26, Para 92: This para is really strong and sets an important precedent regarding compliance with environmental guidelines.

Page 28, Paras 100 - 101, 141: The panel should consider including a footnote or explanation that what the ADB had classified as Category C projects under an older policy it now classifies as Category A, to avoid any confusion about the magnitude of CRBIP's environmental impacts.

Page 34, para 130: Can the Panel shed some light on WHY the recommendation to transfer responsibility of EMP back to CRBIP was not followed up?

Page 35, para 138: Is the Panel sure this "final plan" was based on the ACTUAL feedback of stakeholders and it was not (yet again) a case of ADB staff writing up something themselves and then claiming it was developed following a participatory process?

Page 36, para 142: The Panel should provide its assessment/response for each of the questions it poses here. This section should not be left open-ended and subject to interpretation. If left open-ended, Management/Board can assume these to be mere observations; Panel must provide its findings to these questions.

Page 40, para 161: Can the use of agriculture chemicals and their run-off into drinking water sources (mainly the Canal) be the cause of the ailments (rashes, gastronomical problems) identified by affected communities and documented in the BIC/ED Trip Report (March 2004) ?

Page 42, para 169: Can the Panel expand a bit on pollution and waste management in the sugar industry and how it relates to the EMP?


Can the Panel incorporate more pictures from its field visit to make the case for certain points it makes in the text of the Report?