consultations were carried out, which would imply, in practice, that they only had two days to incorporate the suggestions and recommendations expressed in the consultations, if they actually incorporated them. This raises serious doubts regarding the true importance and consideration given to the public consultations in the approval process of the SESA and of the project itself, especially considering that it is a “B” environmental and social category project. A similar case is the project AR-L1328: Global Credit Program for Reactivation of the Productive Sector, financed by the IDB, which consists of a USD 500 million investment loan from pending disbursements and uncommitted balances of nine loan operations previously approved by the Bank in Argentina, for “the implementation of a global credit program for the reactivation of the productive sector, with the objective of addressing the health, economic and social consequences produced by the COVID-19 emergency.” The funds are intended to improve MSME access to short and medium-term credit and the action is expected to support MSMEs sustainability in the face of the crisis generated by the COVID-19 pandemic. In this case, the short period required by the approval process can also be highlighted, since, according to the documentation published by the Bank, the Argentine government requested the reformulation of the loan contracts on April 30, 2020, and this was approved by the Bank on June 22, 2020. That is, a little over a month and a half after the request was made, which is striking, especially due to the number of projects and funds committed. In this sense, an aspect that raises concern in relation to the accelerated approval process of financing through quick disbursement windows involves the participation and public consultation processes that must be carried out for certain projects (especially for those categorized under environmental and social impacts A or B). To begin with, the context of the pandemic and the restrictions implemented by the government have made it very difficult to establish face-toface public consultations and participation processes, which has led to the implementation of alternative modalities. However, it seems that these measures implemented to adapt to the new context aren’t really effective and may end up causing serious shortcomings in terms of such participation and public consultation in projects that, due to their strategic nature in trying to face the impacts of the pandemic, demand truly effective, inclusive, open and participatory public participation processes. Again, let us take as an example the IDB-financed project AR-L1326: Immediate Public Health Response Project in the context of the COVID-19 Pandemic to contain, control and mitigate its effect on the provision of health services in Argentina. According to the SESA carried out for the project, due to the program’s classification as Category B (according to IDB Policy OP-703), the program and its projects required stakeholder mapping, community relations, public consultations, and the establishment of a complaint and grievance handling mechanism. The SESA provides information about the Public Consultation format implemented in this case, noting that as a consequence of the pandemic and the confinement measures implemented by the Argentine government and “the time pressures to prepare the Program expeditiously to address a situation of emergency the modality implemented in this project consisted of a virtual public consultation, divided into five sessions of two-hour duration by regions of the country.” In its response to the request for information sent in relation to this project, the Argentine government specified that “the first consultation prior to the start of the project was carried out on April 23 and 24, 2020, in a virtual modality.” According to the SESA, the public consultation sessions on the project were open to anyone who registered and the calls for the consultations were published on the website of the Ministry of Health of Argentina. In addition, it states that relevant information was provided about the project (objectives, expected beneficiaries, possible environmental and social impacts and the corresponding management plans for them) prior to the consultation. In the event, according 27 DFIs FINANCING IN ARGENTINA DURING THE PANDEMIC: COVID-19 PROJECTS AND TRANSPARENCY SHORTCOMINGS

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