June 2011 New Rules of Procedure and Accountability Counsel Response

On 21 June, 2011, the State Department published revised Rules of Procedure governing the U.S. NCP. While there are advances with regard to timelines and the issue of parallel proceedings, in other respects the procedures represent a failure to consider the overwhelming consensus in comments from civil society on most issues and even take a step backward with regard to transparency.

On 23 June, 2011, Accountability Counsel’s Executive Director Natalie Bridgeman Fields met with Assistant Secretary of State Fernandez and other interested members of the government, civil society and business to discuss the outcomes of the review process. Accountability Counsel presented a letter to Assistant Secretary Fernandez endorsed by 10 other civil society organizations expressing concern about the new rules of procedure. We also presented a detailed annex to the letter that analyzes the deficiencies in the new rules.

On 23 July, 2011, we authored a civil society letter to Assistant Secretary Fernandez detailing our suggestions for the creation of an advisory board. We received this letter in response.

We are continuing our engagement with the State Department and believe that further changes are necessary for the U.S. NCP to effectively lead the way to address community concerns with violations of the OECD Guidelines.