Products & Policies | Ex-Im Bank Policies | Environment

Environmental Procedures and Guidelines

Introduction

1. Overview of Ex-Im Bank's Environmental Procedures
2. Application Screening & Categorization, and Environmental Information Requirements
   • Category A: Large Greenfield Projects or Projects located in, or impacting a Sensitive Site
   • Category B: Expansions, Upgrades and Projects having Limited Environmental Impact
   • Category C: Categorical Exclusions
   • Category N: Nuclear
3. Sources of Environmental Information
   1. The Applicant and Project Sponsors
   2. Other U.S. Government Agencies: Multinational Institutions
   3. Other Sources of Environmental Information
4. Environmental Information Requirements Pertaining to Ex-Im Bank Programs
   1. General
   2. Long Term Loans and Guarantees Based on Sovereign or Corporate Risk
   3. Long Term, Limited Recourse Project Financing Program
   4. Medium-Term Loans, Guarantees and Insurance
   5. Credit Guarantee Facilities (CGFs)
   6. Short-Term Insurance
   7. Working Capital Guarantee Program (WCGP)
5. Project Monitoring

List of Annexes

Annex A Environmental Guidelines (World Bank Guidelines in Condensed Form)

Table 1: Industrial Projects and General Infrastructure
Table 2: Pulp and Paper Mills
Table 3: Iron and Steel Mills
Table 4: Mining and Milling
Table 5: Oil and Gas Development
Table 6: Thermal, Gas Turbine and Engine Driven Power Plants
Table 7: Forestry Operations
Table 8: Petroleum Refineries and Petrochemical Facilities
Table 9: Hydropower and Water Resources Management
Table 10: Liquid Natural Gas, Liquefaction & Regasification Plants

The Charter of the Export-Import Bank (Ex-Im Bank) requires the Bank to establish procedures to take into account the potential beneficial and adverse environmental effects of goods and services for which support is requested, consistent with the mandate to foster expansion of exports. The Charter also authorizes the Board of Directors, in its judgment, to grant or withhold financing support after taking into account the beneficial and adverse environmental effects of proposed transactions.

The Charter also directs the Bank to operate its financing programs in a manner that is competitive with support offered by principal countries whose exporters compete with US exporters. In response to these Congressional mandates, Ex-Im Bank will act to maintain U.S. exporters' competitiveness in the global marketplace while taking into account the environmental effects of the projects it supports.

In December 2003, agreement was reached among the Export Credit Group of the Organization for Economic Cooperation and Development (OECD), which includes the United States, on adoption of the "OECD Recommendation on Common Approaches on Environment and Officially Supported Export Credits; 2003 Review Revised Version" (The Common Approaches). Adherence to this Agreement is intended to ensure consideration of the environmental effects of projects on a consistent basis among the major Export Credit Agencies (ECAs). Ex-Im Bank will work within the OECD to foster compliance among ECAs with the provisions of the Common Approaches and to minimize differences in the way ECAs apply their environmental policies under the Common Approaches.

Ex-Im Bank's Environmental Procedures and Guidelines were first issued on February 1, 1995 following implementation of interim procedures in October 1993. The Procedures and Guidelines were revised on April 2, 1996 and again on April 2, 1998, and they were extended without revision on March 1, 2001, December 5, 2002 and July 1, 2003 following reviews of their effectiveness in mitigating adverse environmental effects of Bank-supported projects as well as their effect on the competitiveness of U.S. exporters.

These Procedures and Guidelines were revised on July 1, 2004 to be consistent with the principles and intent of the OECD's Common Approaches on the Environment and will remain in effect until such time as they are amended by Ex-Im Bank. In 2006, the Common Approaches are expected to be reviewed for their effectiveness by the Export Credit Group of the OECD.

The Procedures and Guidelines have been developed under the direction of Ex-Im Bank's Engineering and Environment (E&E) Division and reflect input from consultations with U.S. exporters, other U.S. Government Agencies and Non-Governmental Organizations.

1. The application of Ex-Im Bank's Environmental Procedures is tailored to the characteristics of the various Bank programs, in a form consistent with the OECD Common Approaches.
2. All applications for which the Ex-Im Bank financial exposure is greater than $10.0 million will be formally screened and categorized as to their potential for environmental impact and the extent, if any, of subsequent environmental review. Only those transactions pertaining to a physical project¹ (any commercial, industrial or infrastructure undertaking that results in the construction or the extraction of a tangible asset at an identified location), which has the potential for adverse environmental effects, will be subject to an environmental review.
3. For medium-term transactions², including those covered under Credit Guarantee Facilities, an environmental review will be undertaken only for those transactions, which upon screening, are categorized as pertaining to projects which have the potential for significant adverse environmental effects because they are to be carried out in a sensitive area or are likely to have an adverse impact on such an area.
4. Short-term transactions and transactions having a repayment term of less than two years, including Working Capital transactions, generally will not be subject to environmental screening or review.
5. Ex-Im Bank's E&E Division will provide advice and counseling to exporters and borrowers unfamiliar with the requirements of these procedures, especially in cases involving small and medium-sized exporters.
6. Applicants are required to provide environmental information satisfactory to Ex-Im Bank in support of their applications. In the course of undertaking its evaluation of the environmental effects of projects, Ex-Im Bank may also make use of information provided by other sources, including government entities, intergovernmental organizations, and non-governmental organizations (NGOs).
7. Consistent with the OECD objective of fostering transparency, predictability and responsibility, and to help elicit useful information concerning the environmental effects of projects from interested parties without disclosing proprietary information related to the project or application, when Ex-Im Bank receives a final application for long-term financing for a physical project requiring an environmental review, it will follow the process set forth below:
   • Ex-Im Bank will list the project, its location and a brief description of the project, on the Pending Transactions List located through its WEB site, (www.exim.gov), at http://www.exim.gov/products/policies/environment/envproj.cfm.
   • In addition to the above, for those applications wherein Ex-Im Bank requires submission of an Environmental Impact Assessment or comparable environmental documentation (hereinafter "EIA"), it will either make a copy of that document available to interested parties³ or will direct interested parties to a source such as a publicly accessible web site, where the document can be reviewed. The EIA will be made available for at least 30 calendar days prior to Ex-Im Bank's issuance of a Final Commitment. Instructions on how to obtain the EIA will be posted on Ex-Im Bank's Pending Transaction List page.
8. Consistent with the Common Approaches, projects will be evaluated against host-country environmental guidelines and international environmental guidelines. The international guidelines generally applicable will be those of the World Bank ⁴ as set forth in the Pollution Prevention and Abatement Handbook (PPAH), as well as the World Bank Operational Safeguard Policies that are referenced in Annex A.
9. To provide guidance to exporters, Annex A sets forth the scope of the environmental guidelines applicable to projects and includes specific quantitative and qualitative guidelines condensed from the PPAH and from those World Bank Operational Policies that are applicable to Ex-Im Bank transactions.
10. For those projects in which the European Bank for Reconstruction and Development (EBRD), the African Development Bank, the Asian Development Bank or the Inter-American Development Bank is involved, Ex-Im Bank may apply the guidelines, in whole or in part, of the respective Multilateral Development Bank (MDB) to the project in order to facilitate U.S. exporter participation in these projects.  Where such MDB guidelines are insufficient to adequately consider the potential environmental effects of the project, applicable elements of the World Bank Guidelines will be used to supplement the MDB guidelines.  In any event, the Ex-Im Bank Board shall be advised of any material differences between the MDB guidelines applied to a project and the corresponding World Bank Guidelines.
11. For those applications relating to nuclear projects, Ex-Im Bank has formulated separate Nuclear Procedures and Guidelines that are set forth in a separate document.
12. For those projects that Ex-Im Bank determines may significantly affect the quality of the human environment of the U.S., its territories or possessions, or Antarctica, Ex-Im Bank will require adherence to the environmental review procedures required by the National Environmental Policy Act (NEPA), as stipulated in 12 CFR, Chapter IV, Part 408.
13. Projects should, in all cases, comply with the relevant environmental standards of the host country, and when the applicable international environmental guidelines against which the project has been evaluated are more stringent, these guidelines should be applied.
14. If a project does not meet the applicable environmental guidelines, Ex-Im Bank's Board of Directors will take account of the environmental impact and other factors relevant to the project in determining whether to provide financial support, to provide financial support conditioned on the implementation of measures to mitigate the project's adverse environmental effects, or to decline financial support.
15. Ex-Im Bank will seek to identify and support projects and products that are environmentally beneficial, including support for clean, alternative and renewable energy projects. (Ex-Im Bank's Environmental Exports Program, which provides financial incentives for environmentally beneficial transactions, is set forth in Annex F.)
16. To assist in the management of the major anthropogenic greenhouse gas, carbon dioxide (CO2), the Bank will track the estimated amount of CO2 emissions from projects it supports in the power sector and, to the extent practical, from projects in other sectors that may cause significant production of CO2. The estimated annual amount of the aggregate CO2 directly produced by these projects will be reported in Ex-Im Bank's Annual Report.
17. Consistent with the OECD Common Approaches, Ex-Im Bank will make available to the public a list of those transactions that were approved during the past year for which it conducted an environmental review.

Ex-Im Bank's goal is to require only the extent and detail of environmental information that is necessary to enable the Board of Directors to evaluate the environmental effects of a proposed transaction. The majority of project-related transactions that Ex-Im Bank supports are covered under its long-term programs. Therefore, applicants requesting long-term financial support for a transaction ("Long-Term") ⁵ must include a completed "Environmental Screening Document" (Annex B) with their applications to Ex-Im Bank. The information contained in this document will enable the E&E Division to screen and categorize each application in order to determine the type of environmental information required and the extent of its subsequent environmental review. Depending on the information provided in the screening document, Ex-Im Bank will categorize the transaction as either A, B, C or N. The definition of these categories and the level of information generally needed to review transactions within the categories are summarized below.

Category A: Large Greenfield Projects or Projects located in, or impacting a Sensitive Site

Included in this category are transactions that cover exports for:

1) Large, greenfield projects (or major extensions to large projects) as listed in Annex D, The "Illustrative List of Sensitive Sectors and Areas" from the Common Approaches. These include large greenfield projects in sectors such as hydroelectric, mining, forestry, commercial oil & gas development, pipelines, transmission lines, chemical plants, refineries, thermal power plants greater than 300 MWt, pulp & paper, and industrial processing plants that have the potential to cause significant adverse environmental effects.

2) Any project to be constructed in, or likely to have a perceptible impact on, environmentally sensitive locations (as described in Annex D) such as National Parks and other protected areas identified by national or international law, and other sensitive locations of international importance (for example, Ramsar Convention sites, IUCN protected areas and UNESCO World Heritage Sites) or of national or regional importance, such as wetlands, forests with high biodiversity value, areas of archaeological or cultural significance, and areas of importance for indigenous peoples or other vulnerable groups.

For Category A applications, Ex-Im Bank will require submission of an EIA (as described in Annex E) and related documentation describing the environmental effects of the project. EIAs should be submitted in English. The EIA and related information should be sufficient to identify the environmental impact of the project and measures needed to mitigate the adverse environmental effects, and to evaluate whether, or to what degree, the project meets relevant host-country and applicable international environmental guidelines.

Category B: Expansions, Upgrades and Projects having Limited Environmental Impact

Included in this Category are transactions related to projects having the potential for environmental impacts that are less adverse than Category A projects. Typically, these impacts are site specific; few if any of them are irreversible, and mitigation measures are readily identifiable and available. This category generally includes new thermal power plants with capacities less than 300 MWt (~140 MWe), small to medium scale manufacturing and industrial facilities not impacting an environmentally sensitive location, and nominal upgrades to existing projects that do not result in a large amount of additional capacity. For the environmental review of transactions classified as Category B, Ex-Im Bank will require submission of environmental information sufficient to establish whether or not the project meets relevant host-country environmental guidelines and applicable international guidelines.

For transactions covering exports for the expansion or upgrade of existing plants, Ex-Im Bank requires environmental information that focuses on the environmental effects associated with the actual expansion or upgrade portion. If the existing facility is determined to have continuing serious adverse environmental effects, Ex-Im Bank may require appropriate mitigation in order to support the expansion or upgrade project.

If, during the review process of a Category B transaction, the project's environmental information indicates that the transaction should instead be designated as Category A, Ex-Im Bank will promptly notify the exporter, buyer and/or project sponsors of the requirement for an EIA, and the transaction will be reclassified as Category A for purposes of its environmental review.

Category C: Categorical Exclusions

Transactions classified as Category C are excluded from further review because they are likely to have minimal or no adverse environmental impacts. This category includes transactions related to the export of a product (or products) not identified with a physical project; or exports relating to projects of the type that have little or no potential to cause environmental effects and do not impact sensitive locations. Included in Category C are transactions covering the sale of aircraft, locomotives, railway signaling, telecommunications equipment, radar equipment, air traffic control systems, satellite projects, electronic data processing equipment for existing facilities, hospital equipment, and pre-project services such as environmental and feasibility studies. No further environmental information is required for Category C applications.

Category N: Nuclear

All transactions associated with nuclear power projects, nuclear research reactors and related facilities or the production of nuclear fuel are designated as Category N. Due to the special health and safety issues associated with this sector, information requirements for Category N transactions are contained in a separate document titled Ex-Im Bank Nuclear Procedures and Guidelines.

A. The Applicant and Project Sponsors

It is in the applicant's or project sponsors' interest to submit the required environmental information as soon as possible in order to avoid delays in case processing. However, if complete environmental information is not available at a preliminary stage, such information must be submitted for evaluation by the E&E Division before Ex-Im Bank can act on a request for a Final Commitment.

In cases requiring an EIA, the applicant may obtain from the buyer or project sponsors a copy of the EIA in English that is already prepared for the project. For this category of project, an EIA usually will have been prepared in anticipation of requirements of host-country authorities and/or international lending institutions. During the course of the application's review, Ex-Im Bank's Environmental Analyst will advise the applicant and/or the project sponsors if additional or updated environmental information is required.

B. Other U.S. Government Agencies; Multinational Institutions

In cases considered appropriate by Ex-Im Bank, the E&E Division will consult with other U.S. Government agencies, U.S. embassies, and/or multilateral development banks to obtain information on the environmental effects of projects.

C. Other Sources of Environmental Information

For Category A transactions, information on how to obtain the EIA or information authorized for release by the project sponsors will be posted on the Pending Transaction List page of Ex-Im Bank's Web site. In order to protect competitively sensitive information, neither the Pending Transaction List, nor the EIAs will provide specific information about the identity of the exporter, contract value or the products for which Ex-Im Bank financing is sought, unless otherwise authorized for release by the buyer or project sponsor. Ex-Im Bank is prohibited by the Trade Secrets Act, 18 U.S.C. 1905, from disclosing confidential business information unless such disclosure is authorized by law.

Interested parties may provide information or comments regarding potential environmental issues associated with such projects by responding in writing to the E&E Division at Ex-Im Bank. Providing information does not give legal standing to any person or group to participate in the Ex-Im Bank decision-making process. Ex-Im Bank will review and may take into account the environmental information provided.

If material received by Ex-Im Bank from sources other than the applicant gives rise to environmental concerns, Ex-Im Bank will give the applicant an opportunity to provide further information addressing these concerns during the period in which Ex-Im Bank undertakes its environmental review.

A. General

The level of environmental information required of a transaction relates directly to the extent and complexity of the project's potential environmental effects. Ex-Im Bank will require information sufficient to identify the project's potential environmental impact and enable it to determine whether, and to what extent, the project meets the relevant host-country and applicable international environmental guidelines. Information related to the potential beneficial environmental effects of a project should also be provided when applicable.

For those transactions requiring submission of an EIA, Annex E describes the type of information about the environmental effects of a project that should be contained within an acceptable EIA. In addition, a copy of the EIA, with authorization by the buyer or project sponsors for its release to interested parties, is normally required unless the buyer or sponsor has already made an English version of the EIA available by posting it on a publicly accessible Web site.

The scope and level of detail required by Ex-Im Bank to meet the information requirements of the environmental guidelines for specific transactions may vary. In evaluating a transaction's environmental effects, Ex-Im Bank may consider factors such as the availability of information from other sources and the scope of the U.S. exports supported by Ex-Im Bank relative to the scope of the overall project.

Ex-Im Bank's E&E Division is comprised of engineers specializing in various industrial sectors who possess expertise with respect to certain environmental elements applicable to projects within their respective sectors. The Division's Environmental Analysts, together with the engineer assigned to evaluate the technical aspects of a project, are available to provide guidance to applicants on matters related to Ex-Im Bank's environmental information requirements.

B. Long Term Loans and Guarantees Based on Sovereign or Corporate Risk

A Final Commitment Application may involve conversion of a Letter of Interest (LI), conversion of a Preliminary Commitment (PC), or it may be a stand alone application.

Letters of Interest

Letters of Interest (LIs) are non-binding expressions of Ex-Im Bank's willingness to consider participating in a transaction. Ex-Im Bank generally issues LIs within seven business days of the receipt of an application. LI applications for long-term transactions must be accompanied by a completed Environmental Screening Document (Annex B) that will be used for initial categorization of the transaction and to inform the applicant as to the scope of environmental information required for a subsequent Final Application. This initial categorization is preliminary and subject to revision once the characteristics of the project are more fully defined at a subsequent application phase.

Except in rare instances involving projects that are known to have potentially severe adverse environmental effects, LIs will be issued with no prior environmental review. For LI applications initially screened as Category C, no mention of environmental requirements will be included in the LI. For those LI applications relating to a physical project (Category A, B or N), Ex-Im Bank will provide information with the LI alerting the applicant as to the need for an EIA, if applicable, (as described in Annex E) or the nature of information needed by the E&E Division to evaluate the project. This allows the applicant a maximum amount of time to gather the required environmental information in order to avoid processing delays at the subsequent Final Application stage.

No LIs will be issued for nuclear cases, without prior review by the E&E Division. Nuclear transactions are subject to the provisions of Ex-Im Bank's Nuclear Procedures & Guidelines.

Preliminary Commitments

Preliminary Commitments (PCs) are issued after Ex-Im Bank's staff and Board of Directors analyze the financial soundness, technical feasibility, and environmental effects of a proposed transaction. Applications for a PC must include a completed Environmental Screening Document (Annex B). Based on the information provided in the screening form, the E&E Division will inform the applicant promptly of the category of the transaction and the scope of additional environmental information required to process the PC.

Ex-Im Bank understands that in certain cases, not all the information needed to evaluate the project against host-country or applicable international environmental guidelines is accessible to applicants at the PC stage. In these cases, based on recommendations of the E&E Division, Ex-Im Bank will condition its issuance of a PC on a subsequent review and satisfactory evaluation of such information at the Final Commitment stage.

In those cases where a PC is requested for a series of long-term transactions pertaining to physical projects for a single borrower or end-user ("Long-Term Facility") Ex-Im Bank will condition its PC on a subsequent review and evaluation at the Final Commitment stage for each resulting transaction identified within the PC.

If environmental concerns are sufficiently serious and adequate information is available for evaluation, Ex-Im Bank may decline to issue a PC on environmental grounds. If a PC is issued, the PC Approval Letter will identify information that will be required in the Final Commitment application. PC letters may identify environmental issues that should be addressed (for example, by proposed mitigation measures) at the Final Commitment stage.

Final Commitments

Final Commitments (or Final Applications) for long-term transactions are approved by Ex-Im Bank only after the completion of all financial, technical, and environmental analyses. If no PC has been issued, the applicant for a Final Commitment must submit a completed Environmental Screening Document (Annex B). All long-term final applications, except those designated as Category C, will undergo a complete environmental evaluation in accordance with the review procedures and information requirements noted above. In order that interested parties have sufficient time to review and provide information and comments to the E&E Division about the environmental effects of Final Commitments designated as Category A, the transaction's EIA should be made available to interested parties for at least 30 calendar days prior to Ex-Im Bank's issuance of a Final Commitment.

No Final Commitment will be authorized unless Ex-Im Bank, in its sole judgment, has received sufficient environmental information to enable the E&E Division to assess the environmental effects of the project. The environmental information provided will be evaluated against the relevant host-country guidelines and the applicable international guidelines.

C. Long Term, Limited Recourse Project Financing Program

Applications for Letters of Interest for limited recourse project financing must be accompanied by an Environmental Screening Document (Annex B) that will be used for initial categorization of the transaction and to inform the applicant as to the scope of environmental information required for a subsequent Final Application. This initial categorization is preliminary and subject to revision once the characteristics of the project are more fully defined at a subsequent application phase.

The E&E Division will be involved in the early stages of processing a Limited Recourse Project Financing application. As part of determining whether Ex-Im Bank will issue a Preliminary Project Letter (PPL), the E&E staff will consider whether the project will raise any potentially insurmountable environmental problems that could lead Ex-Im Bank to withhold financial support for the project. If such problems are identified, Ex-Im Bank shall notify the sponsor and may provide guidance with respect to mitigation measures that could be adopted in order to address these environmental problems.

When an EIA is required (Category A), the applicant or sponsor of the Project Finance transaction should submit an EIA to Ex-Im Bank as soon as possible, but in no event later than the time of application for a Final Commitment. The EIA also should be made available to interested parties for at least 30 calendar days prior to Ex-Im Bank's issuance of a Final Commitment. An Environmental Analyst from the E&E Division will review the EIA, request further information as necessary from the sponsors or exporters, analyze all relevant information, and prepare an environmental evaluation of the project. The evaluation may include recommendations to the Board of Directors with respect to conditions that must be met to obtain financial support.

As is the case with the financial and technical reporting requirements associated with the evaluation of Limited Recourse Project Finance transactions, Ex-Im Bank reserves the right to require the sponsor to bear the expense of outside specialists to prepare an independent report with respect to any element of the project's environmental effects.

D. Medium-Term Loans, Guarantees and Insurance

Medium-term financial support provided by Ex-Im Bank through its loan, guarantee, and insurance programs generally covers the export of capital goods and services that are not purchased in conjunction with a particular greenfield project. Applications for Medium-Term transactions will not require submission of an Environmental Screening Document (Annex B).

Ex-Im Bank will internally screen medium-term applications for Final Commitments based on the information contained in the application. For those unusual medium-term transactions where the environmental screening reveals that the underlying project presents the potential for significant adverse environmental effects because it is to be carried out in a sensitive area or likely to have an adverse impact on such an area, the applicant will be informed and required to submit environmental information sufficient for Ex-Im Bank to undertake an environmental review of the project against relevant host-country and applicable international environmental guidelines. Applications for most medium-term transactions will not be subject to an environmental review.

E. Credit Guarantee Facilities (CGFs)

The CGF program is designed to reduce up-front administrative time and cost and thereby better serve small and medium-sized exporters. CGFs only address medium term transactions. Most CGFs provide guarantees of medium-term lines of credit between U.S. and foreign financial institutions that are used to finance U.S. exports consisting of a wide range of capital goods to a variety of end-users, or certain recurring capital goods to a specific foreign buyer. In most cases, Ex-Im Bank is not informed of the specific exports supported by a CGF until after financing for the transaction has been authorized. CGFs of this type will not be subject to an environmental review.

Some CGFs may consist of Ex-Im Bank guarantees of medium-term lines of credit in which the borrower is also the end-user of the export (typically an industrial company rather than a bank), and consequently information on the nature of the export and its end-use may be available prior to Bank action. Applications for these CGFs will be screened for their potential environmental effects. In the unusual case where the screening of a medium-term transaction covered under a CGF reveals that the underlying project presents the potential for significant adverse environmental effects because it is to be carried out in a sensitive area or likely to have an adverse impact on such an area, the applicant will be informed and required to submit environmental information about the project, sufficient for Ex-Im Bank to undertake an environmental review of the project against relevant host-country and applicable international environmental guidelines.

Chemicals, pesticides and other such commodities are not eligible for medium-term financing under CGFs. Nuclear related exports also are not eligible for support under Ex-Im Bank's CGF program.

F. Short-Term Insurance

The scope of the Common Approaches does not include transactions having repayment terms less than two years. Short-term financial support for exports provided by Ex-Im Bank export credit insurance generally covers commodities, consumer goods, and other non-capital goods and services. These products typically have limited, if any, environmental consequences. Ex-Im Bank Insurance support for these transactions is provided against risks of non-repayment and generally provide coverage for a term of up to one year. With the exception of nuclear-related exports, no environmental screening or review will be conducted of short-term transactions. (Applicants should refer to Ex-Im Bank's Nuclear Procedures and Guidelines for all nuclear related exports.)

Ex-Im Bank will not provide insurance for chemicals or pesticides that are banned or severely restricted in the U.S. A list of items ineligible for export credit insurance is contained in Annex C.

G. Working Capital Guarantee Program (WCGP)

Ex-Im Bank provides short-term working capital support directly to U.S. exporters for activities related to the production or supply of items within the United States for subsequent export. With the exception of nuclear-related exports, no environmental review will be conducted of WCGP transactions. (Applicants should refer to Ex-Im Bank's Nuclear Procedures and Guidelines for nuclear-related WCGP transactions.)

To ensure that projects supported by Ex-Im Bank are constructed and operated in accordance with the relevant host-country and applicable international environmental guidelines, Ex-Im Bank will monitor the environmental performance of Ex-Im Bank supported Category A projects through the term of the Ex-Im Bank financial support, particularly those aspects of projects subject to any Ex-Im Bank financing conditions pertaining to the implementation of measures to mitigate a project's environmental impact. Monitoring will be conducted through the review of information provided by the sponsor and through site visits.

Ex-Im Bank's Environmental Analysts, who are responsible for undertaking the environmental evaluation of proposed transactions, will undertake, as required, the monitoring of the environmental aspects of transactions following their authorization. The Environmental Analysts serve as Ex-Im Bank's primary resource on environmental matters, including the environmental performance of Ex-Im Bank supported projects.

¹An export of trucks to a construction company for its ongoing and general use does not represent a transaction pertaining to a physical project, whereas the export of trucks to a mining company, which will use them in conjunction with the development of a new mine, would represent a transaction pertaining to a physical project.

²These transactions have a principal liability of $10 million or less, excluding exposure fee, and repayment terms of seven years or less. Transactions of $10 million or less, which because of special financing enhancements receive repayment terms in excess of seven years, are considered medium term transactions.

³Prior to the release of an EIA, Ex-Im Bank will require that the Project Sponsor formally agree to make the EIA available for public disclosure in a form that does not contain proprietary business or commercial information.

⁴World Bank Guidelines set forth in the PPAH and relevant operational policies in effect as of December 18, 2003

⁵These transactions have either a principal liability > $10 million or a repayment term > 7 years, but do not include those transactions that because of financing enhancements receive a repayment term > 7 years.