The President
The Vice President
The Speaker of the House of Representatives

As your advisors on environmental and infrastructure issues along the U.S. border with Mexico, we write to express our continued support for the North American Development Bank (NADB) and the Border Environment Cooperation Commission (BECC). Both agencies were created in 1993 under a bilateral side agreement to NAFTA to improve environmental infrastructure in the U.S.-Mexico border region. The NADB was established specifically to help finance projects in the U.S.-Mexico border after certification by BECC.

Recent media reports in both the United States and Mexico indicate that over the past few years, members of the U.S. Department of Treasury have discussed an attempt to close down the NADB with members of Mexico's Secretariat of Finance and Public Credit. In fact, Treasury spokespersons have acknowledged these talks in public statements. While it appears that a shutdown has been averted for now, the Good Neighbor Environmental Board remains very concerned that this issue may arise again, and that the benefits of NADB still are not fully understood.

Any movement toward eliminating the NADB is, in our view, extremely regrettable because the Bank and the Commission are the very institutions helping to provide solutions to environmental infrastructure needs in the border region: As of December 31, 2005, NADB had provided $704 million, through grants or loans, to 90 border environmental infrastructure projects in both the U.S. and Mexico border regions. These projects have an estimated total cost of $2.35 billion dollars and demonstrate NADB's ability to leverage additional capital. As a result of these NADB grants or loans, many of the recipient communities have improved their potable water facilities or wastewater treatment plants; in some cases, these funds have made possible the development of facilities where none had existed before. NADB's water and wastewater programs are directly and indirectly benefiting more than 6 million people on the U.S.-Mexico border.

We recognize that all institutions have room for improvement, and we respect the recent reforms your administration made to the NADB and the BECC. Just last year, you issued Executive Order 13380 regarding membership of a combined NADB-BECC board. In addition, in April 2004 you signed into law HR 254, which made changes to the NADB and the BECC, preceded by a Statement of Administration Policy (February 26, 2003) that read:
" The Administration strongly supports passage of H.R. 254, which authorizes key reforms of the North American Development Bank (NADB) and the Border Environment Cooperation Commission (BECC). Since taking office, President Bush has worked closely with Mexico's President Fox to make these institutions more effective in addressing the critical environmental needs of the communities of the U.S.-Mexico border region and, thus, improve the quality of life for the region's 12 million residents…"
In January of this year, to fulfill Executive Order 13380, U.S. members were appointed to the combined board. With this series of reforms to NADB and BECC having recently occurred, we believe these changes should be allowed to work their course. In addition, we strongly urge members of the new board to hold a public meeting as soon as practical and act on pending projects.

The U.S.-Mexico border region continues to be an area of tremendous environmental and infrastructure needs. More than $900 million in water and wastewater infrastructure needs were identified in 2005. The dissolution of the NADB would create serious problems for border community residents and, ultimately, for the nation. Rather than consider terminating the NADB, we advise, instead, that the NADB be strengthened through continued funding and a recommitment by the members of its Board, as well as high ranking staff within the U.S. Department of Treasury, to advance its important work.

 Sincerely yours,

Paul Ganster,
Chair

Note: As the U.S. Environmental Protection Agency and the U.S. Department of
State are members of the combined BECC-NADB board, the Good Neighbor Environmental Board representatives from those agencies have recused themselves from this Comment Letter. In addition, the representatives from the U.S. Departments of Agriculture, Health and Human Services, Interior, and Transportation also have recused themselves, as has the U.S. Commissioner of the International Boundary and Water Commission.