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Environment and tomorrow's World Bank
IVIEWPOINT
Environment and tomorrow’s World Bank Ken Piddington
The author is Adviser on Environmental Policy, Wellington, New Zealand. He served from 1988 to 1991 as the first Director of Environment at the World Bank.
0959-3780/93/040315-05
0
1993
One must begin at the beginning. When the International Bank for Reconstruction and Development was set up at the Bretton Woods Conference in 1944, none of the participants could have been expected to discern what issues would be high on the ‘reconstruction and development’ agenda half a century later. Indeed, after little more than a decade the (European) reconstruction segment was to be eclipsed by the (Third World) development imperative. This in essence dictated the profile of the World Bank until the dramatic end of the Cold War in 1989. This event re-introduced to the Bank agenda a large segment of economic reconstruction - this time in Eastern Europe and in the components of the former I_SSR. What did emerge at Bretton Woods was a brilliant idea. This was that a bank operating under international guarantee (and thus automatically backed by the strongest economic powers) could enjoy optimum credit rating in the world’s financial markets. It could therefore borrow at the most favourable rates, and lend to those of its members whose need was greatest (and which by definition would not have access to development funds unless they paid a much higher rate of interest). Most importantly, this new bank would be self-financing, because a very small margin in its lending rates (over its borrowing rates) would cover the institution’s operating and administrative costs. I find this core concept as valid today as it was in 1944, and I expect it to remain a useful
Butterworth-Heinemann
Ltd
component of international cooperation . It is certainly relevant to the environmental mission of the Bank in the 1990s if only because of the unique political and intellectual consensus which now exists about the need to integrate environment and development. Following the United Nations Conference on Environment and Development in Rio, there was some dismay over the Financial Times scoresheet which showed the World Bank as one of the ‘winners’ - and the non-governmental organizations (NGOs) as among the ‘losers’. But the debate about the role of the Bank has been based largely on the premise that its operations are an exclusive charge on the OECD taxpayer. In Washington, I was able to observe how this myth was promoted by congressional lobbyists to encourage a sense that the Bank should be responsive to US prescriptions on how to deal with environmental (and other) matters. The fact is that the main role of the rich country taxpayer is to be an underwriter, and the donor role will always remain secondary - and optional. Having sketched the genesis of the Bank as a development institution, I should add that over the decades many new forms of financing have been woven around the core Bretton Woods concept. The official records made no reference to adjustment lending, or even to IDA, MIGA and the myriad of trust funds which are today administered by the Bank as a matter of practical advantage. But in
315
Viewpoint
each case (and the Global Environment Facility is typical in this regard) there has been a sovereign decision by members of the donor community that this is the most efficient way to handle international transfers. This preamble is necessary in order to understand the recent phase of the Bank’s environmental record, and also as a lead-in to the more important discussion about where the institution needs to move in the years ahead. I deal with this below in terms of the components of environmental policy, and against the strengths and weaknesses of the World Bank. I comment on the issue of accountability and conclude with some suggestions, both for external critics of the Bank and for former colleagues who are carrying on the effort which was pioneered by Barber Conable in his 1987 speech to the World Resources Institute.
The policy mix Like most New Zealanders, I adhere to a cement-mixing philosophy. This leads me to see environmental policy as the blending in ideal proportions of certain components, together with the right sequencing of actions as you go through the process. The corollary to this approach is the principle of internalization. This means that the environmental function of any organization should be part of what everybody does (and of everything they do) rather than be held as the separate responsibility of one unit, however well qualified and influential the group may be. Cornell University in the USA has carried this principle into practice so that every activity on the campus is covered - from chemicals in the laboratory to waste from the cafeteria. It is a principle which is also applied increasingly by industry and by public officials at federal, provincial and local levels. There are two specific reasons why this has to be the basis for the work of the Environment Department in the World Bank. First, the integration of environmental and economic factors in development policy must be posed as a challenge to the development economists and technical experts throughout the Bank. And they can
316
GLOBAL
move up the learning curve only if they are given clear responsibility to operate within certain principles. There is a high risk factor, because the learning process may take up to a decade. I decided, however, that the more traditional - and bureaucratic alternative of building up numbers in the Department itself was not workable. In any case, some future reorganization will surely disband the Department, and in my view the strategy has to cover that situation. Secondly, the Country Departments in the Bank’s Operations complex handle the lending proposals and prepare projects. It is they who have the main interaction with policy makers in borrowing countries. In the end, it is not the Bank’s policy which will determine actual impacts on the environment in many regions of the world. This will come about through the collective policies of both the public and private sectors (including local NGOs) on the national and local scene. The Bank can be a powerful influence, but this has to be carefully orchestrated in what is called the ‘policy dialogue’ only in rare circumstances does the environmental ‘expert’ have direct input into this quasi-diplomatic process.
Strengths and weaknesses If one makes a traditional analysis of the overall capacity of the World Bank in the context of environmental policy, the conclusion which emerges is that its traditional strengths may prove to be its weaknesses, while some of its traditional weaknesses may become future strengths. The function of the policy dialogue is clearly a strength, particularly as it is conducted through Ministers of Finance and other powerbrokers. In OECD countries, it has generally been very hard to get this group to focus on environmental concerns. Colleagues in the Bank were puzzled when I told them that Treasuries did not normally speak with environmental colleagues before major policy decisions. But in many countries, doing business with the Bank now includes specific loans for environmental projects and this is accelerating the policy coordination which is still slow to emerge in indus-
ENVIRONMENTAL
CHANGE
December
1993
Viewpoint
trial countries - even in the ‘greener’ OECD members such as Norway and New Zealand. Having creative contact in the capital, or more accurately around the immediate perimeter of the Presidential palace, does not make the Bank a useful actor ten miles outside the city, or even in the sprawling acres of poverty which are now part of so many mega-cities in the developing world. This is a standard, and in my view valid, critique of the World Bank. It suggests that future recruitment and operational policy should bring in different talents and force different career patterns. In my experience, the best way to argue an environmental case is from the perspective gained by getting ‘mud on the boots’ and listening carefully to the views of local people. On the weakness side of the ledger, the lack of access to information about Bank activities and the absence of a clear process which confirms public accountability have been identified by many commentators. What I have noticed is that both elements have started to shift - marginally and too slowly in the eyes of some, but at breakneck speed if we take the span of comparison back to Bretton Woods. The main influence here has been that of environmental NGOs and of shareholder governments who were tired of dealing with them. By any standards, the flow of available documentation, including that which relates to policy options in developing countries, is staggering; some would say it is indigestible. The accountability issue has further to travel, and there is a real question about which groups (outside the governmental structure) can claim to represent the public interest in member countries. (There is a further, and more sensitive, question about ‘transnational’ environmentalism and the basis on which groups outside the developing country can claim to have a voice in decisions about the sovereign use of resources.) In both instances, however, it is environmental policy which has been the main impetus for change inside the World Bank. Nobody in the environmental corner - least of all the Director of Environment. or the incumbent
GLOBAL
ENVIRONMENTAL
CHANGE
December
1993
of the more recently created (1992) post of Vice-President for Environmentally Sustainable Development will be satisfied that the change is fast enough. It is however a process which is irreversible in terms of the Bank’s own ‘culture’, because the intellectual underpinning for the integration of environmental analysis in the development programmes prepared by the Bank’s experts is now enshrined in the 1992 World Development Report and in a large volume of papers produced by former colleagues in the Environment Department (and by other experts scattered throughout the institution) .
The problem of accountability It needs to be stressed that the World Bank is unusual in the weight it gives to intellectual analysis (as opposed to political pragmatism and operational expediency). Whether this will lead over time to a greater degree of accountability, as the term is understood in NGO circles, is open to considerable doubt. The very guarantees which were part of the Bretton Woods vision, and which continue to create the strength which the institution needs in the financial markets, work to reduce its transparency. In terms of political logic, the syllogism is very simple. All shareholders are governments - some governments are less than transparent - and in the absence of a ban such as that imposed in 1991 on borrowing by Kenya, the Bank is likely to reflect a minimum rather than a maximum level of accountability. This could be called the principle of intergovernmental complicity; you have to be obviously offside before the whistle is blown. My own view is that accountability is important, but not as an end in itself. Where it arises through a process, and where that process enables local citizens and ethnic minorities to have a real influence on proposals which affect them directly, I would argue that the political purpose of accountability is being served. It is also likely that environmental values will be upheld. Where ‘accountability’ is seen as a mere device, a can-opener to release information which will en-
able certain lobby groups in the North to generate (through selective quotation) an even higher volume of distorted propaganda about the activities of the Bank, I argue that the global pursuit of environmental goals is unlikely to be served. This is because neither the people nor the governments of the South will have become engaged in a process which links environmental progress with moves towards more genuine democratic choices by the public in question. This contradiction may be resolved in tandem with the political reforms which will continue in most of the shareholding countries for many decades to come. But it will not happen quickly. It will certainly not happen in the timeframe which has to be assigned to the priority agenda on issues of environment and development. These are questions of here and now. There is an immediate opportunity for both the Bank and its shareholders to do better and to invest in ‘environmentally sound and sustainable development’, to use the postRio phraseology. I have to ask whether ‘accountability’ is an element of higher intrinsic value than exhaustive technical analysis of environmental options. For it is in the latter area that the Bank has real strength, and real resources, to offer.
What next? Looking ahead there is therefore an intellectual and political dilemma which will face those who are specialist observers of the Bank and those who currently have the responsibility of moving the leviathan forward from inside. For the first group, which I have now joined, I offer one key observation: the Bank responds pragmatically to sound country-based analysis and intellectual rigour, it does not have any digestive capacity for rhetoric or for ecological theology. NGOs and academics alike will have greater impact if their focus is on specific problems in member countries, and if sweeping generalizations about what the Bank does are replaced by a critique which is targeted and Iogically intact. For the Bank itself, I take heart
318
GLOBAL
from the broader in-house disciplinary framework which is being negotiated in the wake of the 1992 World Development Report by Ismail Serageldin, the new Vice-President for Environmentally Sustainable Development. But I discern three questions which in the post-Rio follow-up require special attention - one relates to the Bank’s own self-assessment, one to environmental impact assessment (EIA) methodology and one to the country-based programmes. In brief compass they can be summarized as follows: How can the Bank produce a consistent and objective measure of its environmental performance? When we faced this problem in 1990, during the preparation of the First Annual Report on the Environment, it was obvious that a dollar figure on ‘environmental loans’ would help to measure the performance of a lending institution. But it was also obvious that we should include other measurements - staff numbers, training courses, in-house seminars and so on. If internalization is to run its course, the fact however is that these measurements will become less relevant. Something else is needed, which also deals with the qualitative aspects of the Bank’s role, and it should be arrived at through consensus with the ‘consumers’, ie the interest groups outside the Bank. Can the Bank advance professional techniques of environmental analysis, as it has in so many other fields? My suggestion here is that environmental assessment methodology (EA) as applied in the World Bank should be developed to incorporate the economic valuation of environmental costs and benefits, and unify this with the overall cost-benefit analysis which is traditionally used for all proposed investments. There are large problems in doing this - setting the appropriate discount rate is only one of them - but it is clearly the next step in making EA more relevant to the concerns of decision makers in both public and private
ENVIRONMENTAL
CHANGE
December
1993
Viewpoint
l
GLOBAL
ENVIRONMENTAL
CHANGE
enterprise. The Bank is one of the few places where there is an institutional capacity to carry this work forward. Having published a World Development Report in 1992 with very significant things to say about the opportunities as well as the challenges facing its members, what changes will the Bank now introduce into its country operations? Despite the controversy about structural adjustment, I favour the concept of ‘Environmental Adjustment Plans’, because this would make it clear that the integration of environment and development involves an adjustment from the previous situation (and in the context of the Bank implies that financial and other assistance is needed to bring this adjustment about). The National Reports which were produced for UNCED might provide a basis for this process in some cases (if not, who will ever put them to use?); in other instances the Bank already has Action Plans and other analyses which could be the starting point for the identification of
December
1993
investment priorities S-10 years.
over the next
Each of these questions raises larger issues, and each is important for the Bank. One can list a host of other actions, including the recruitment issue touched on above, designed to help Bank staff respond more competently to the environmental agenda. The leadership which the Bank can provide to the regional development banks and to other aid agencies could prove very important, but a deliberate programme (and some resources) will be needed for this purpose. The way in which the Bank interacts with the networks set up to handle sustainable development issues in the UN system following UNCED is another key element. The Bank is now inextricably involved in the debate on environmental issues at the global level - a fact which is dramatized by its role in administering the Global Environment Facility. But its unique capacity to influence national policy formulation may produce quicker and surer results for the environment and for its shareholders.
319
Environment and tomorrow’s World Bank Ken Piddington
The author is Adviser on Environmental Policy, Wellington, New Zealand. He served from 1988 to 1991 as the first Director of Environment at the World Bank.
0959-3780/93/040315-05
0
1993
One must begin at the beginning. When the International Bank for Reconstruction and Development was set up at the Bretton Woods Conference in 1944, none of the participants could have been expected to discern what issues would be high on the ‘reconstruction and development’ agenda half a century later. Indeed, after little more than a decade the (European) reconstruction segment was to be eclipsed by the (Third World) development imperative. This in essence dictated the profile of the World Bank until the dramatic end of the Cold War in 1989. This event re-introduced to the Bank agenda a large segment of economic reconstruction - this time in Eastern Europe and in the components of the former I_SSR. What did emerge at Bretton Woods was a brilliant idea. This was that a bank operating under international guarantee (and thus automatically backed by the strongest economic powers) could enjoy optimum credit rating in the world’s financial markets. It could therefore borrow at the most favourable rates, and lend to those of its members whose need was greatest (and which by definition would not have access to development funds unless they paid a much higher rate of interest). Most importantly, this new bank would be self-financing, because a very small margin in its lending rates (over its borrowing rates) would cover the institution’s operating and administrative costs. I find this core concept as valid today as it was in 1944, and I expect it to remain a useful
Butterworth-Heinemann
Ltd
component of international cooperation . It is certainly relevant to the environmental mission of the Bank in the 1990s if only because of the unique political and intellectual consensus which now exists about the need to integrate environment and development. Following the United Nations Conference on Environment and Development in Rio, there was some dismay over the Financial Times scoresheet which showed the World Bank as one of the ‘winners’ - and the non-governmental organizations (NGOs) as among the ‘losers’. But the debate about the role of the Bank has been based largely on the premise that its operations are an exclusive charge on the OECD taxpayer. In Washington, I was able to observe how this myth was promoted by congressional lobbyists to encourage a sense that the Bank should be responsive to US prescriptions on how to deal with environmental (and other) matters. The fact is that the main role of the rich country taxpayer is to be an underwriter, and the donor role will always remain secondary - and optional. Having sketched the genesis of the Bank as a development institution, I should add that over the decades many new forms of financing have been woven around the core Bretton Woods concept. The official records made no reference to adjustment lending, or even to IDA, MIGA and the myriad of trust funds which are today administered by the Bank as a matter of practical advantage. But in
315
Viewpoint
each case (and the Global Environment Facility is typical in this regard) there has been a sovereign decision by members of the donor community that this is the most efficient way to handle international transfers. This preamble is necessary in order to understand the recent phase of the Bank’s environmental record, and also as a lead-in to the more important discussion about where the institution needs to move in the years ahead. I deal with this below in terms of the components of environmental policy, and against the strengths and weaknesses of the World Bank. I comment on the issue of accountability and conclude with some suggestions, both for external critics of the Bank and for former colleagues who are carrying on the effort which was pioneered by Barber Conable in his 1987 speech to the World Resources Institute.
The policy mix Like most New Zealanders, I adhere to a cement-mixing philosophy. This leads me to see environmental policy as the blending in ideal proportions of certain components, together with the right sequencing of actions as you go through the process. The corollary to this approach is the principle of internalization. This means that the environmental function of any organization should be part of what everybody does (and of everything they do) rather than be held as the separate responsibility of one unit, however well qualified and influential the group may be. Cornell University in the USA has carried this principle into practice so that every activity on the campus is covered - from chemicals in the laboratory to waste from the cafeteria. It is a principle which is also applied increasingly by industry and by public officials at federal, provincial and local levels. There are two specific reasons why this has to be the basis for the work of the Environment Department in the World Bank. First, the integration of environmental and economic factors in development policy must be posed as a challenge to the development economists and technical experts throughout the Bank. And they can
316
GLOBAL
move up the learning curve only if they are given clear responsibility to operate within certain principles. There is a high risk factor, because the learning process may take up to a decade. I decided, however, that the more traditional - and bureaucratic alternative of building up numbers in the Department itself was not workable. In any case, some future reorganization will surely disband the Department, and in my view the strategy has to cover that situation. Secondly, the Country Departments in the Bank’s Operations complex handle the lending proposals and prepare projects. It is they who have the main interaction with policy makers in borrowing countries. In the end, it is not the Bank’s policy which will determine actual impacts on the environment in many regions of the world. This will come about through the collective policies of both the public and private sectors (including local NGOs) on the national and local scene. The Bank can be a powerful influence, but this has to be carefully orchestrated in what is called the ‘policy dialogue’ only in rare circumstances does the environmental ‘expert’ have direct input into this quasi-diplomatic process.
Strengths and weaknesses If one makes a traditional analysis of the overall capacity of the World Bank in the context of environmental policy, the conclusion which emerges is that its traditional strengths may prove to be its weaknesses, while some of its traditional weaknesses may become future strengths. The function of the policy dialogue is clearly a strength, particularly as it is conducted through Ministers of Finance and other powerbrokers. In OECD countries, it has generally been very hard to get this group to focus on environmental concerns. Colleagues in the Bank were puzzled when I told them that Treasuries did not normally speak with environmental colleagues before major policy decisions. But in many countries, doing business with the Bank now includes specific loans for environmental projects and this is accelerating the policy coordination which is still slow to emerge in indus-
ENVIRONMENTAL
CHANGE
December
1993
Viewpoint
trial countries - even in the ‘greener’ OECD members such as Norway and New Zealand. Having creative contact in the capital, or more accurately around the immediate perimeter of the Presidential palace, does not make the Bank a useful actor ten miles outside the city, or even in the sprawling acres of poverty which are now part of so many mega-cities in the developing world. This is a standard, and in my view valid, critique of the World Bank. It suggests that future recruitment and operational policy should bring in different talents and force different career patterns. In my experience, the best way to argue an environmental case is from the perspective gained by getting ‘mud on the boots’ and listening carefully to the views of local people. On the weakness side of the ledger, the lack of access to information about Bank activities and the absence of a clear process which confirms public accountability have been identified by many commentators. What I have noticed is that both elements have started to shift - marginally and too slowly in the eyes of some, but at breakneck speed if we take the span of comparison back to Bretton Woods. The main influence here has been that of environmental NGOs and of shareholder governments who were tired of dealing with them. By any standards, the flow of available documentation, including that which relates to policy options in developing countries, is staggering; some would say it is indigestible. The accountability issue has further to travel, and there is a real question about which groups (outside the governmental structure) can claim to represent the public interest in member countries. (There is a further, and more sensitive, question about ‘transnational’ environmentalism and the basis on which groups outside the developing country can claim to have a voice in decisions about the sovereign use of resources.) In both instances, however, it is environmental policy which has been the main impetus for change inside the World Bank. Nobody in the environmental corner - least of all the Director of Environment. or the incumbent
GLOBAL
ENVIRONMENTAL
CHANGE
December
1993
of the more recently created (1992) post of Vice-President for Environmentally Sustainable Development will be satisfied that the change is fast enough. It is however a process which is irreversible in terms of the Bank’s own ‘culture’, because the intellectual underpinning for the integration of environmental analysis in the development programmes prepared by the Bank’s experts is now enshrined in the 1992 World Development Report and in a large volume of papers produced by former colleagues in the Environment Department (and by other experts scattered throughout the institution) .
The problem of accountability It needs to be stressed that the World Bank is unusual in the weight it gives to intellectual analysis (as opposed to political pragmatism and operational expediency). Whether this will lead over time to a greater degree of accountability, as the term is understood in NGO circles, is open to considerable doubt. The very guarantees which were part of the Bretton Woods vision, and which continue to create the strength which the institution needs in the financial markets, work to reduce its transparency. In terms of political logic, the syllogism is very simple. All shareholders are governments - some governments are less than transparent - and in the absence of a ban such as that imposed in 1991 on borrowing by Kenya, the Bank is likely to reflect a minimum rather than a maximum level of accountability. This could be called the principle of intergovernmental complicity; you have to be obviously offside before the whistle is blown. My own view is that accountability is important, but not as an end in itself. Where it arises through a process, and where that process enables local citizens and ethnic minorities to have a real influence on proposals which affect them directly, I would argue that the political purpose of accountability is being served. It is also likely that environmental values will be upheld. Where ‘accountability’ is seen as a mere device, a can-opener to release information which will en-
able certain lobby groups in the North to generate (through selective quotation) an even higher volume of distorted propaganda about the activities of the Bank, I argue that the global pursuit of environmental goals is unlikely to be served. This is because neither the people nor the governments of the South will have become engaged in a process which links environmental progress with moves towards more genuine democratic choices by the public in question. This contradiction may be resolved in tandem with the political reforms which will continue in most of the shareholding countries for many decades to come. But it will not happen quickly. It will certainly not happen in the timeframe which has to be assigned to the priority agenda on issues of environment and development. These are questions of here and now. There is an immediate opportunity for both the Bank and its shareholders to do better and to invest in ‘environmentally sound and sustainable development’, to use the postRio phraseology. I have to ask whether ‘accountability’ is an element of higher intrinsic value than exhaustive technical analysis of environmental options. For it is in the latter area that the Bank has real strength, and real resources, to offer.
What next? Looking ahead there is therefore an intellectual and political dilemma which will face those who are specialist observers of the Bank and those who currently have the responsibility of moving the leviathan forward from inside. For the first group, which I have now joined, I offer one key observation: the Bank responds pragmatically to sound country-based analysis and intellectual rigour, it does not have any digestive capacity for rhetoric or for ecological theology. NGOs and academics alike will have greater impact if their focus is on specific problems in member countries, and if sweeping generalizations about what the Bank does are replaced by a critique which is targeted and Iogically intact. For the Bank itself, I take heart
318
GLOBAL
from the broader in-house disciplinary framework which is being negotiated in the wake of the 1992 World Development Report by Ismail Serageldin, the new Vice-President for Environmentally Sustainable Development. But I discern three questions which in the post-Rio follow-up require special attention - one relates to the Bank’s own self-assessment, one to environmental impact assessment (EIA) methodology and one to the country-based programmes. In brief compass they can be summarized as follows: How can the Bank produce a consistent and objective measure of its environmental performance? When we faced this problem in 1990, during the preparation of the First Annual Report on the Environment, it was obvious that a dollar figure on ‘environmental loans’ would help to measure the performance of a lending institution. But it was also obvious that we should include other measurements - staff numbers, training courses, in-house seminars and so on. If internalization is to run its course, the fact however is that these measurements will become less relevant. Something else is needed, which also deals with the qualitative aspects of the Bank’s role, and it should be arrived at through consensus with the ‘consumers’, ie the interest groups outside the Bank. Can the Bank advance professional techniques of environmental analysis, as it has in so many other fields? My suggestion here is that environmental assessment methodology (EA) as applied in the World Bank should be developed to incorporate the economic valuation of environmental costs and benefits, and unify this with the overall cost-benefit analysis which is traditionally used for all proposed investments. There are large problems in doing this - setting the appropriate discount rate is only one of them - but it is clearly the next step in making EA more relevant to the concerns of decision makers in both public and private
ENVIRONMENTAL
CHANGE
December
1993
Viewpoint
l
GLOBAL
ENVIRONMENTAL
CHANGE
enterprise. The Bank is one of the few places where there is an institutional capacity to carry this work forward. Having published a World Development Report in 1992 with very significant things to say about the opportunities as well as the challenges facing its members, what changes will the Bank now introduce into its country operations? Despite the controversy about structural adjustment, I favour the concept of ‘Environmental Adjustment Plans’, because this would make it clear that the integration of environment and development involves an adjustment from the previous situation (and in the context of the Bank implies that financial and other assistance is needed to bring this adjustment about). The National Reports which were produced for UNCED might provide a basis for this process in some cases (if not, who will ever put them to use?); in other instances the Bank already has Action Plans and other analyses which could be the starting point for the identification of
December
1993
investment priorities S-10 years.
over the next
Each of these questions raises larger issues, and each is important for the Bank. One can list a host of other actions, including the recruitment issue touched on above, designed to help Bank staff respond more competently to the environmental agenda. The leadership which the Bank can provide to the regional development banks and to other aid agencies could prove very important, but a deliberate programme (and some resources) will be needed for this purpose. The way in which the Bank interacts with the networks set up to handle sustainable development issues in the UN system following UNCED is another key element. The Bank is now inextricably involved in the debate on environmental issues at the global level - a fact which is dramatized by its role in administering the Global Environment Facility. But its unique capacity to influence national policy formulation may produce quicker and surer results for the environment and for its shareholders.
319