Environment
Support Group ®
S-3, Rajashree Apartments, 18/57, 1st Main
Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560
041. INDIA
Telefax: 91-80-6341977/6531339
Email: esg@bgl.vsnl.net.in Website: http://www.altindia.net/esg/index.htm
Mr. H. N. Sinor
Deputy Managing Director
ICICI Bank
Mumbai
19
June 2002
Reg.: ICICI’s potential investment in the Bangalore Mysore
Infrastructure Corridor Project
Dear Mr. Sinor,
According to The Economic Times dated 13th June 2002 (copy enclosed),
Mr. Ashok Kheny, Managing Director, Nandi Infrastructure Corridor Enterprises
(NICE) has stated that he “expect(s) the consortium of financial Institutions
led by ICICI to release funds to the 2000 crores project upon receipt of the
comfort letter allaying their reservations over various aspects to facilitate
early financial closure.” Keeping this
in view we would primarily wish to confirm with you if this is true.
The reason for our suspicion is that NICE has been given to
making several misleading, even erroneous statements, including to the press
and the government, with regard to the BMICP.
To point just one instance, which would be of crucial importance in your
decision, we would like to highlight how the MOU signed in 1995 and the
Framework Agreement developed on its basis in 1997 is void ab initio.
The MOU and Framework Agreements are based on NICE’s claim
that M/s Vanasse Hangen Brustlin (VHB), a Boston based design company, is part
of the project consortium. The Chairman
of the Board of VHB, Mr. Richard Hangen, has categorically, and rather
strongly, denied such involvement in an email correspondence with the
undersigned (copy enclosed), and also dismisses any likelihood of VHB
supporting the project. Such claims of
the involvement of VHB have also been made in litigation connected with this
matter in the High Court of Karnataka.
Whether NICE claimed a role for VHB merely to promote an investment that
is clearly not feasible, particularly in securing financial commitment, is an
issue that is to be settled. What is
important to note, however, is that when a company is claimed to be part of the
consortium, and that company denies such a role, it would amount to all
agreements secured on such claims would be void ab initio.
With this in view we wish to enquire:
In our understanding, it would require ICICI to rule out all
doubts, before committing to finance this project. From the gross in-transparency and human rights violations that
have marked the clearances thus far for this project, it would reflect adversely
on the reputation of ICICI to proceed with supporting the project, in case this
news is really true, as reported by the press.
Besides it would violate the letter and spirit of a recent
Circular No. IECD No. /08.12.01/2001-02 dated 20 February 2002, issued by the
Reserve Bank of India to all banks and financial institutions on “Financing of
Infrastructure Projects”. Para 3 of
this Circular absolutely relates with the circumstances of the BMICP, and the
same is reproduced here for your attention, especially with regard to the
interest of your shareholders:
“3. In respect of infrastructure
projects, where financing is by way of term loans or investment in bonds issued
by government owned entities, banks/Financial Institutions should undertake due
diligence on the viability and bankability of such projects to ensure efficient
utilization of resources and creditworthiness of the projects financed. Banks
should also ensure that the individual components of financing and returns on
the project are well defined and assessed.
Lending/investment decisions in such cases should be based solely on
commercial judgment of banks/Financial Institutions. There should be no compromise on proper credit appraisal and
close monitoring of the projects financed and banks should ensure that only
projects that are intrinsically viable are financed. State Government guarantees may not be
taken as a substitute for satisfactory credit appraisal and such
appraisal requirements should not be diluted on the basis of any reported arrangement
with the Reserve Bank of India or any bank for regular standing
instructions/periodic payment instructions for servicing the loans/bonds.” (Emphasis not in original)
Mr. Kheny’s claim to obtaining a “comfort letter” from the
State Government should not deter your judgment in complying fully with RBI’s
rider.
Your earliest clarification in this regard will be deeply
appreciated.
Thanking you,
Yours sincerely,
Leo F. Saldanha Rajmohan
Pillai
Executive Director Research
Coordinator
Environment Support Group (Infrastructure
Finance)
Cc: Smt. R. K.
Makhija, General Manager, Reserve Bank of India