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.