Some of the wording of the OPs has been re-sequenced, summarized and highlighted: please check against originals if you want to cite the OPs.

Safeguards in OP 4.36: Forestry (1993)	Safeguards proposed by Technical Advisory Group for Revised OP on Forests (December 2000)	Safeguards in Draft OP 4.36: Forests (June 2002) (bracketed text summarises draft language to save space)
Footnote: ‘Bank’ includes IDA and ‘loans’ includes credits. (The policy was not adopted by IFC until 1999).	The safeguard policy applies to all members of the World Bank Group.	Footnote: ‘Bank’ includes IDA. ‘Borrower’ includes the member country guarantor of a loan made to a non-member. Comment: The Bank has apparently rejected the TAG’s advice that the OP should also apply to IFC and MIGA.
1b. The Bank uses a sector-wide approach to forestry and conservation in order to address policy and institutional issues and integrate forestry and forest conservation projects with initiatives in other sectors and with macro-economic objectives.	The policy also applies to all Bank operations including structural adjustment lending, Economic and Sector Work and Country Assistance Strategies.	3. This policy applies to the following types of Bank-financed investment projects: .a. projects which have or may have an impact on the health and quality of forests and/or the welfare of people affected by these impacts; and/or .b. projects which are aimed at bringing about changes in the management, protection, and/or utilization of natural forests or plantations, whether they are publicly, privately or communally owned. Footnote: This policy does not apply to adjustment lending. (The Bank expects OP 8.60 (forthcoming) to address operational policy aspects of adjustment lending). 4. The Bank routinely uses environmental assessments, poverty assessments, social analyses, public expenditure reviews and other economic and sector work undertaken by the Bank to identify the economic, environmental and social significance of forests in its borrowing countries. Where the Bank identifies the potential for a significant impact of its country assistance strategy (CAS) on forests, it integrates strategies for addressing these impacts in the CAS for that country. 5. The potential impact of each Bank-financed investment project on forests is addressed through the project EA in accordance with OP/BP 4.01 (Environmental Assessment) Comment: The policy does not apply to structural adjustment and programmatic lending. The measures to be undertaken by staff to address impacts of CAS are not at all clear. The policy does apply to IBRD and IDA operations in other sectors which impact forests but the only safeguards for non-forestry project are those already  in OP 4.04..
	The policy should apply to all forest types.	(Draft Definitions a. the term ‘forest’ is used without qualification implying the policy applies to all forest types.)
1a. The Bank does not finance commercial logging or purchase of logging equipment for use in primary moist tropical forests.	Extend the proscription on Bank financing of logging to all old growth forests (boreal temperate, tropical dry and tropical wet) unless acceptable country-level exercises have been carried out to zone High Conservation Value Forests (HCVF). In accordance with the precautionary principle, all old growth forests are considered HCVF unless established otherwise, with demonstrable public acceptance, through inclusive and open processes of participation. Include an outright ban on negative impacts in forests defined as High Conservation Value Forests.	6. Where the Bank determines that a project would involve significant conversion or degradation of critical forest areas or other critical natural habitats, the Bank will not finance such a project. If the project, however, involves the significant conversion or degradation of natural forests or other natural habitats that the Bank determines are not critical, and the Bank determines that there are no feasible alternatives to the project, the Bank may finance the project provided that it incorporates appropriate mitigation measures (in line with OP 4.01 Environment Assessments and OP 4.04 Natural Habitats). 11. The Bank may finance projects involving commercial harvesting operations only where the Bank has determined on the basis of the applicable environmental assessment, or other relevant information, that the areas affected by harvesting are not critical forests or other critical natural habitats. … Comment: Instead of adopting a participatory approach to determining which forest are of ‘high value’ or ‘critical’ the Bank determines these values unilaterally.
	HCVF are defined as those forests that possess one or more of the following attributes: a)       forest areas fundamental to meeting basic needs of local communities (e.g.  subsistence, health) and/or critical to local communities’ traditional cultural  identity (areas of cultural, economic or religious significance) b)       forest areas that provide basic services (e.g. watershed protection, erosion control) that are crucial and unable to be effectively replaced by other land cover. c)       forest areas containing globally, regionally or nationally significant concentrations of biodiversity and forest areas that are in or contain rare, threatened or endangered ecosystems. Such areas are to be determined locally through a consultation process and based on internationally accepted standards.	(Draft Definitions c: Critical forest  areas are existing and proposed protected areas, areas initially recognized as protected by traditional local communities (eg sacred groves)  and sites that maintain conditions vital for the viability of these protected areas; or areas listed by the Bank based on systematic evaluations of such factors as species richness; the degree of endemism; rarity, and vulnerability of component species; representativeness; and integrity of ecosystem processes)    Comment: The Bank is promoting a very  non-participatory approach to the definition of critical forests
1a. The Bank may finance improvements in the planning,  monitoring and field control of forestry operations, where the borrower country has a commitment to move towards sustainable management and aims to retain as much effective forest cover as possible.	No changes proposed.	8. If a project proposed for Bank financing involves any investment in forests, the Borrower furnishes the Bank with relevant information on the forest sector concerning the Borrower’s overall policy framework, national legislation, institutional capabilities, and the poverty, social, economic and environmental issues related to forests. This information should include information on  the country’s national forest programmes or other relevant country-driven processes. Based upon this information and the project’s environmental assessment, the Borrower incorporates measures necessary to achieve the project’s objectives. These measures address, among other issues, the respective roles and rights of the government, the private sector and local people. Comment: The requirement for Borrowers  to have a commitment  retain forests and to sustainable management has been dropped.
1c. The Bank requires the borrower to identify and consult the interest groups involved in a particular forest area where the Bank involves the private sector and local people in forestry and conservation activities.	Ensure inclusive and participatory decision-making.
1d. Bank support to the forest sector is conditional on borrower’s commitment to undertake sustainable management and conservation-oriented forestry.  Borrowers should adopt policies and a legal and institutional framework to:	Ensure borrower or client adoption of policies and an institutional framework consistent with sustainability.
- Ensure conservation and sustainable management of existing forests	Any proposed Bank-funded logging operation should only take place in any particular forest ecosystem if a viable, ecologically representative protected area network exists for that particular ecosystem.	BP 5. During project preparation, the Borrower provides the Bank with an assessment of adequacy of land use allocations for the management, conservation and sustainable development of forest, including any additional allocations needed to protect critical forest areas.
- Promote active participation of local people and the private sector in the long-term sustainable management of natural forests	Ensure borrower or client adoption of a participatory approach to the management of natural forests.	(Participation is now only required for project involving certification.)
- Adopt a comprehensive and environmentally sound forestry conservation and development plan that clearly defines the roles and rights of government, the private sector and local people	Ensure adequate provisions to safeguard the interests of local people, including forest dwellers and indigenous peoples. Comment: The need to protect the interests of local peoples especially of those who are not indigenous and therefore not covered by OD 4.20 on Indigenous Peoples was emphasized during the 2nd TAG.	BP 5. The Borrower assesses the need to make provisions to safeguard the interests of local communities, specifically their rights of access to and use of designated forest areas….
- Undertake social, economic and environmental assessments of forests being considered for commercial use	No changes proposed.	(Emphasis is placed on OP 4.01 Environment Assessment)
- Set aside adequate compensatory preservation forests: i. to protect and conserve biological diversity and ii. to safeguard the interests of forest dwellers, specifically their rights of access to and use of designated forest areas	Secure the tenure rights of forest-dwellers as a precondition to Bank operations affecting forests. Comment: In the 2nd TAG meeting this recommend-ation was felt to be too strong, but the need to secure the tenure rights of forest-dwellers was stressed. Likewise, the new’ strategy’ makes poverty alleviation and community forestry projects a central objective. The need for social safeguards to ensure that these projects meet the needs and recognise the rights of the poor was stressed by the 2nd TAG.	Comment: The Bank has rejected the proposal to require regularizing the tenure rights of forest-dwellers, instead invoking OD 4.20 on Indigenous Peoples. However, there are two serious problems with this. First, the revised OP 4.10 on Indigenous Peoples no longer requires borrowers to regularize tenure of indigenous peoples. Secondly, OP 4.10 only applies to Indigenous Peoples who, according to the Bank’s own figures, only make up around 180 million of the world’s 1 billion forest dependent people.
-Establish institutional capacity to implement and enforce these commitments	No changes proposed.	This requirement has been dropped.
1e. The Bank distinguishes investment projects that are exclusively for environmental protection (eg protected areas and watershed management) and which are supportive of small farmers. Projects in this limited group may be appraised on the basis of their own social, economic and environmental merits. However, they may be pursued only where broad sectoral reforms are in hand, or where remaining forest cover is so limited that preserving it in its entirety is the agreed course of action.	No changes proposed.	11c. (The Bank will finance forest harvesting where the operations are to) be conducted by small-scale landholders, or be under community forest management or joint forest management arrangements by local communities, and be monitored by the Borrower with the meaningful participation of the locally affected communities.  BP 7. Where the Bank is considering support for community-based forest management and development, the relevant project design will take account of the broader role of trees outside forest areas in rural livelihoods; the institutional, policy and conflict management issues involved in improving the participation of indigenous people and the poor in the management of trees and forests; any special market considerations, including market conditions relevant to indigenous people and the poor living inn or near forests; opportunities for promoting the involvement of women; and the development of relevant research to support these developments.
1f. In areas of high ecological value, the Bank finances only preservation and light, non-extractive use of forest resources.	No changes proposed.	See 11. above.
1f. In areas where retaining natural forest cover and the associated soil, water, biological diversity and carbon sequestration values is the object, the Bank may finance controlled sustained-yield forest management.	Bank support for operations in non-HCVFs are conditional  on internationally accepted certification standards. Any proposed Bank-funded logging operation would need to be sustainable at the stand level, meaning FSC or equivalent.	11… In addition, for each harvesting operation, one of the following three conditions must be met. The operation must: .a. meet standards for responsible forest management and use, based on independent forest certification systems acceptable to the Bank; or .b. include a time-bound, phased action plan acceptable to the Bank for achieving independent certification standards; ( or c) above) 12. … a forest certification system for each such commercial harvesting operation should be based upon the following principles and criteria: .a. compliance with relevant laws; recognition, under the Borrower’s legislation of the documented land tenure and use rights as well as the rights of indigenous peoples and workers; good community relations; encouragement of environmentally sound multiple benefits accruing from the forest; prevention or minimization of the environmental impacts from forest use; rigorous forest management planning; active monitoring and assessment o relevant forest management areas; and the maintenance of critical forest areas and other critical natural habitats affected by the project. .b. The certification system should be adapted to national laws and institutions, and be based upon performance standards that are defined at the national level and are compatible with generally accepted principles of sustainable forest management. The system should be based upon objectives and measurable parameters, and should incorporate independent assessment of forest-management performance. In addition, the system should be developed with the meaningful participation of local people and civil society, including the private sector, and NGOs representing consumer, producer, and conservation interests. Certification systems decision-making procedures should be cost-effective, fair transparent, and be designed to avoid conflict of interest.
	Any proposed Bank-funded logging operation would have to demonstrate clear poverty alleviation benefits and local benefit sharing. Comment: This was stressed  in the2nd  TAG meeting. It was emphasised that this provision should also apply to the IFC and MIGA.	Comment: This proposal was ignored by the Bank.
	Any proposed Bank-funded logging operation would have to include some form of corporate code of conduct (or performance bond or some other mechanism) to ensure that there were not corrupt practices.	Comment: This proposal was ignored by the Bank
1f. The Bank finances plantations only on non-forested areas (including previously planted areas) or on heavily degraded forestland.	No changes proposed.	10. The Bank does not finance plantations that involve the significant conversion or degradation of critical natural habitats. Where the Bank finances plantations, preference is given to siting such projects on unforested sites or lands already converted  (excluding any lands which have been converted in anticipation of the project).   Comment: Plantations may now be established  in cleared  forests though the Bank ‘prefers’ not to.
2. The Bank does not finance projects that contravene applicable international environmental agreements.	The Bank does not finance projects that contravene applicable international environmental and human rights agreements.	(The requirement has been dropped) Comment: The Bank has not only rejected  the proposal that it should require  borrowers to respect their human rights obligations but it has dropped the requirement that they adhere to applicable international environmental agreements..
	Improved monitoring and evaluation.	BP 9. (Resources are made available for effective supervision. Supervision reports will be publicly disclosed in the case of Bank support for harvesting operations… BP 10 Progress with implementation of mitigation measures will also be disclosed).
	Establish adequate enforcement mechanisms.	Comment: No additional accountability or enforcement mechanisms are required by the draft policy.