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From the preceding chapters, it is clear that it is in the enlightened self interest of banks to begin to develop the capabilities to review and understand the impact of their lending programs on the environment and on the human population that shares that environment.
The process of building this capability of environ mental impact analysis (EA) into the lending routines of the bank is, in fact, quite easily accomplished. The checklist provided in the preceding chapter outlines the major elements to be considered in reviewing the impact of a potential loan. It is neither inclusive of all the factors to be considered in a particular loan decision, nor should it be considered exclusive of other elements that may be of importance in a given case. Instead, this list will allow bankers to think systematically about the impact of their lending decisions and will help to structure an EA of the loan before it is made.
Some involvement in carrying out an EA should be the responsibility of every lending officer. He/she can prepare a short statement of the anticipated impact of the loan to accompany the project documentation to the loan committee. The loan committee should review this documentation before passing on the loan.
It is unlikely that any single loan officer will have all the expertise required to carry out EAs in the highly diversified fields in which a bank is required to lend. To overcome this difficulty, it is proposed that each local level bank appoint one or more of the loan officers as an Environmental Assessment Advisor to the loan committee. This person, who would function as the environmental ombudsman or spokesperson, will have the responsibility of developing an expertise in EA and will review all EAs attached to loans before they are presented to the bank's loan committee.
Paralleling this local structure, banks at the regional and national level will need to appoint a loan or administrative officer to develop EA capabilities to help the local banks in developing their EA capacities and to review the work of the local banks as well as carrying out some post hoc studies to determine if the original EAs correctly identified and estimated the environmental consequences of loans.
The regional and national level EA advisors will be linked to already existing and newly developing environmental impact assessment expertise both in international lending institutions, such as the World Bank and regional banks, and technical assistance organizations such as FAO, and national based development agencies, (USAID), European and Japanese development agencies), which can supply expertise.
Thus, EA, while carried out at the local level by loan officers who have taken on the additional responsibility of reviewing the consequences of lending on the environment, will be supported by a network of more specialized staff at the regional, national and international levels.