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To: LSE Consulting
From: ClientEarth, Fern and Conservation International
Subject: Comments on the draft interim report / Sustainability Impact Assessment (SIA) in Support of the Association Agreement Negotiations between the European Union (EU) and Mercosur.
Please find below our comments and recommendations on the SIA in Support of the Association Agreement Negotiations between the EU and Mercosur. They focus mainly on the Environmental and Human Rights analyses. We are available for further discussion – see contacts at the bottom of the document – and thank you for the opportunity to contribute.
As highlighted in the Trade for All Communication, SIAs are a key instrument in the formulating sound, transparent and evidence-based trade policies.
Firstly, we would like to recall that the purpose of the SIA studies is to inform trade negotiators and other stakeholders on the potential economic, social and environmental impacts of a proposed trade agreement while its negotiation is ongoing. However, given that negotiations were closed on 28 June 2019,1 the timing of the present draft interim report raises questions about the extent to which the (ongoing) SIA process has actually fed into the work of the negotiators. This is even more questionable since the present SIA draft interim report devotes only an extremely brief analysis of the likely agreement impacts, particularly on the environment and indigenous peoples’ rights.
Furthermore, the absence of preliminary findings in these regards severely restrains the stakeholders’ possibility to respond to proposed recommendations before the SIA is finalized.
Secondly, the baseline scenario is not based on the best available research, information and data. The failure to take recent data or events into account risks creating incorrect and biased results. This is particularly critical across the different parts of the environmental analysis, where the study fails to take into account the latest data on the deforestation situation and to draw conclusions from them to make sure future risk is taken into account.
Thirdly, the modelling of the draft interim report is based on two scenarios: conservative and ambitious. However, given that the final terms of the trade agreement are known, the SIA should take them into account to properly reflect their impacts on sustainability.
Specific comments on the Social Analysis (section 4)
1 See p. 4 of the Minutes of the Civil Society Dialogue Meeting on the EU-Mercosur