NATIONAL WILDLIFE FEDERATION

May 1, 2003

Chair of the Committee of Government Representatives
on the Participation of Civil Society
Secretaria del Área de Libre Comercio de Las Américas (ALCA)
8 Oriente N° 1006
Paseo San Francisco
Centro Histórico, Puebla 72000
México


By Electronic Mail and First Class Mail

EXECUTIVE SUMMARY

RE: Committee of Government Representatives for the Participation of Civil Society’s (CGR) AOpen Invitation to Civil Society in FTAA Participating Countries@ (May 2003)

Dear Sir/Madam:

The National Wildlife Federation (NWF) is pleased to provide the following comments in response to the Committee of Government Representatives for the Participation of Civil Society’s (CGR) “Open Invitation to Civil Society in FTAA Participating Countries” requesting a presentation of views on trade matters related to the  Free Trade Area of the Americas (FTAA).

The National Wildlife Federation is the United States’ largest not-for-profit conservation education and advocacy organization with over 4 million members and supporters. We appreciate this important opportunity to present our comments on the critical relationship between trade and the environment in the FTAA and its constructive role in future negotiations. Our comments are based substantially on prior submissions to the CGR and we look forward to a response.

The FTAA partners and the members of the World Trade Organization (WTO) recognize the reality and the importance of the trade and environment linkage. The San Jose Fourth Ministerial Declaration (March 1998) states as a General Objective “To strive to make our trade liberalization and environmental policies mutually supportive, taking into account work undertaken by the WTO and other international organizations.”

In light of these objectives we must note with serious concern the relative lack of progress in addressing environmental issues within the FTAA process that has occurred since the creation of the CGR. The absence of a specific work agenda and lack of precisely defined role for the CGR within the FTAA process raises serious questions regarding the current and future impact of the CGR as an effective vehicle for public input in the FTAA negotiations.

Despite these significant reservations regarding the current CGR process, we proffer our comments as part of our effort to contribute to the advancement of a constructive agenda for sustainable trade and investment in the FTAA negotiations. We believe that the FTAA negotiations have the potential to support a hemispheric integration process consistent with the vision articulated by the 1994 Miami Summit to link the advancement of human prosperity to three fundamental principles: social progress, economic prosperity, and a healthy environment. While we agree strongly with these goals, we remain concerned that the initial principles and negotiating objectives articulated in the San Jose Declaration fail to encourage the kind of trading relationship that promotes healthy economies and cleaner environments.

Regrettably, to date, few concrete steps have been taken to ensure that environmental issues are addressed by the FTAA. Specific opportunities for raising environmental concerns directly in negotiating sectors have yet to be identified. We note that a fundamental tenet of the FTAA negotiations is to turn “words into action.” In the interest of building essential broad-based public support for the FTAA negotiations, we urge the FTAA negotiators to take concrete actions towards assigning meaningful value to environmental concerns by fully integrating the following environmental protection goals in the FTAA negotiating agenda. Specifically, we seek immediate attention in efforts to:

< Improve FTAA Deference to National Environmental Standards and Multilateral Environmental Agreements (MEAs): Trade rules must be crafted so they do not diminish the environmental protections that nations have provided for their citizens and resources. Each FTAA member country must retain the right to develop and enforce high conservation measures through trade measures C even if they exceed the international norm C without running afoul of FTAA rules.

< incorporate environmental impact assessments (EIAs) into FTAA negotiations --- a broad and comprehensive assessment of trade‑related environmental effects, initiated immediately, is necessary to assess the positive and negative environmental implications of trade liberalization. The feasibility of working with the Tripartite Committee and other intergovernmental institutions to develop appropriate grant mechanisms to offset the costs associated with these reviews should be considered;

< eliminate environmentally damaging subsidies in natural resource sectors such as fisheries and forest products to reduce both environmental degradation and distortions in trade flows;

< promote public participation, openness, transparency, and accountability as cornerstones of the FTAA process to ensure dissemination of important information and instill public confidence in FTAA negotiations;

< allow countries to distinguish between products based on the way they are produced: the FTAA should permit each party to make distinctions concerning market access based partially on the environmental impacts of production, as long as there is no clear and convincing violation of national treatment.

< negotiate environmentally responsible investment rules;

< assist in the development of hemispheric cooperation and capacity-building in trade and environment as an integral component of the FTAA process.