The impact of UK overseas aid on environmental protection and climate change adaptation and mitigation

Written evidence submitted by Water Witness International

1. Summary

· The Select Committee’s decision to explore these issues is well informed and timely and I welcome the invitation to provide this evidence which draws on 17 years experience as a regulator, NGO worker, researcher and consultant.

· Based on this experience the causal linkages between improved performance in environmental protection, mitigation and adaptation to climate change, economic growth, poverty reduction and attainment of the MDGs are unequivocal.

· Without environmental protection institutions which deliver rational land planning and development control; water resource management and pollution control; disaster risk management; and environmental health, agricultural extension and forestry services, opportunities for sustainable economic and livelihood development in developing countries are severely compromised. Without these ‘nuts and bolts’ of environmental protection in place and working for the public good, talk of adapting to and mitigating climate change is largely rhetorical.

· The Coalition’s development priorities of ‘tackling climate change, supporting adaptation and low carbon growth’ and ‘boosting economic growth and wealth creation’ are therefore mutually dependent on improving the performance of environmental protection institutions.

· In most developing countries environmental protection is neglected, subverted or otherwise dysfunctional. The reasons include a lack of resources and capacity but also include complex, inter-related issues of low public sector pay and motivation; political will, institutional incentives and accountability; and corruption or capture by powerful interests.

· Development effort on the environment tends to bypass these systemic problems, focusing instead on short term ‘place’ based or otherwise poorly planned or executed projects. These can provide a mirage of progress which masks the root causes of institutional failure and can undermine the prospects for functional environmental protection regimes.

· As a new and politically popular issue the climate change agenda suffers from power struggles and low levels of coordination among beneficiary governments and donors alike. Emergent action on climate change in some developing countries is therefore piecemeal, uncoordinated and in places counterproductive.

· DFID has a great deal of influence and credibility in the international development arena but traditionally ‘does not do’ environment. The UK government should use this influence and DFID’s expertise to support improved environmental protection institutions as a platform for economic growth and the climate change response. It should also demand greater coherence and focus among the donor community.

· Four aspects of environmental protection: the knowledge base; functional institutions; accountability; and private sector engagement, should be targeted with an increased package of flexible aid. Examples of effective development interventions on environment protection which make better use of British expertise and promote efficient and joined-up government are available.

· The priorities set out in the DFID business plan are encouraging. However, the freeze on administrative costs alongside increases in programme budget risks reduced aid efficacy and inefficient spending. Also, the heavy emphasis on results based interventions could jeopardize vital investment in issues such as environment protection and climate change where outcomes are not easily measurable.

· Technical support on environmental protection must also be improved to move away from the current reliance on short term consultancies and capacity building workshops which are widely regarded as an expensive circus which works against locally owned and sustained action.

I have structured my response to highlight the key points of these arguments using examples and to specifically address the questions and requests for information made by the inquiry.

2. Introduction

This submission is based on hands on experience of environmental protection, climate change and international development in Africa, Asia, South America and the UK since 1993 and on recently completed PhD research which examines how aid can best be directed to support effective environmental and water management in sub-Saharan Africa. Understanding of the issues stems from working in progressively senior positions in the UK with the Environment Agency, and later in Africa with NGO’s including WaterAid, VSO and WWF; and latterly as a consultant to bilateral and multilateral donors including DFID for whom I have delivered assignments in Ethiopia, Uganda, Tanzania and across SADC. In 2009 I founded Water Witness International, a charity which works for improved performance and accountability in water management in developing countries. I am also a Research Fellow at the School of International Development, University of East Anglia and a board member of the Alliance for Water Stewardship, an international effort to develop a private sector standard for sustainable water use and management.

3. Key points and recommendations

3.1 Effective Environmental Protection [1] regimes in developing countries are a fundamental requirement for poverty reduction. There is clear evidence that the negative impacts of poorly performing environmental protection institutions are shared by communities, government and the private sector alike, but that the poor suffer most acutely [2] . A useful example is the case of Karibu Textile Mills Ltd in Dar es Salaam, Tanzania. Established in 1998 and employing 900 staff this textile bleaching and dye works makes an important contribution to the local economy, but despite being required by law the site does not treat its wastewater prior to discharge to the Kazinga River. The resultant chronic pollution stretching 2.5 km downstream has destroyed a local fishery worth $34 000 per year and brings health problems for the local community [3] . Installation of adequate treatment facilities would make net economic sense though the local and national regulators appear unable or unwilling to enforce this requirement.

3.2 Effective Environmental Protection regimes in developing countries are a fundamental requirement for economic growth. Although sometimes contested by developing country politicians who fear that strict environmental controls may divert investment elsewhere, the concept of ‘shared risk’ [4] is useful in articulating the important contribution of robust environmental protection to private sector growth. To be economically viable, private sector investment requires a reliable, good quality resource base, a healthy workforce and a social licence to operate. Thus they also need working environmental protection regimes just as much as the poor. Convincing examples include:

§ Asparagus grown in Ica accounts for most of the US$230 Million per year generated by Peru’s fresh asparagus trade. Because expansion of the business was not rationally planned or regulated by a functional Environment Protection regime, water demand for asparagus irrigation outstripped supply in 2002 and groundwater levels are now declining at the fastest rates seen globally. As costs of water acquisition increase, social conflict is growing and farms are beginning to close, taking with them any short lived economic benefit [5] .

§ Gomba Estates Ltd was once the largest exporter of fresh vegetables to the UK from Tanzania, with a turnover of several million dollars and 600 staff. But in 2008 the company closed operations, taking these jobs and revenue with it, citing unreliable water resource availability for irrigation as the primary reason. The problem was not necessarily insufficient flow in the river supplying the farm, but rather, there was a lack of water resource management functionality to coordinate water use ‘turns’ among water users [6] .

3.3 Effective Environmental Protection regimes in developing countries are a fundamental requirement for climate change adaptation. The impacts of climate change in developing countries will be felt primarily through changes in the intensity and frequency of floods and droughts; weather related damage to infrastructure; changes in agricultural regime viability and the distribution and frequency of crop, livestock and human disease [7] . All these impacts concern sectors where government service provision has traditionally been poor or neglected under normal climate variability, namely water resource management; flood and drought management; land planning and development control; agricultural / rural extension and environmental health. Thus investment for adaptation which gets these regimes working properly with ‘duty bearers’ serving ‘rights holders’ be they citizens or private sector enterprises is a win-win scenario and one which given significant uncertainties in how climate will change must be a priority.

3.4 Effective environmental protection regimes will also play a predominant role in climate change mitigation, through forest management, emission controls, planning for low carbon development and critically, given the huge significance of agricultural performance for carbon emissions from developing countries, effective agricultural and rural extension. It is these ‘nuts and bolts’ of environmental protection and governance which are needed to pave a sustainable future under a changing climate. Planning and development control is a particularly vital aspect of the climate change response. It allows statutory management of new development, can align resource use to sustainable exploitation and specify climate smart infrastructure, and is therefore an important vehicle for both adaptation and mitigation. Despite the importance of these service areas, they have rarely been the focus of climate change action to date. Rather, investment in climate change in developing countries has been geared towards serving international climate negotiations and the needs of development partners at the expense of robust action for domestic climate resilience and mitigation [8] .

3.5 Environmental protection regimes in most developing countries are dysfunctional. There are numerous formidable barriers to improved performance. Their significance varies between and within developing countries and although it is critical that interventions are based on situated analysis of local conditions rather than a ‘one size fits all’ approach, some generic insights are possible [9] . One universal problem is simply a lack of technical capacity, financial and personnel resources and political prioritization for investment in the public sector roles described above. However there is a danger that simplistic diagnoses such as a ‘need for more capacity building’ can mask a set of ‘tacit’, more complex problems. These include ambiguous legal authority, state immunity, regulatory capture and manipulation by powerful interests, corruption and organisational problems including top down management and low staff retention and motivation.

3.6 Overseas Development Assistance and NGO efforts have a poor track record in improving the performance of environmental protection regimes in developing countries. It would be wrong to lay the blame for poorly functioning institutions solely at the door of developing country governments - the interventions of development partners also play a role. Many tend to bypass systemic institutional problems and focus on short or medium term projects within specific geographical or topic areas. Investing in particularly important ecological areas or species can bring positive results, but when interventions fail to address the drivers of degradation or generate institutional capacity and incentives for ongoing protection, sustainable impact is unlikely. Moreover, ploughing funds into the environment or related sectors without addressing systemic problems underlying poor performance invites inefficiency and failed projects. The Water Sector Development Programme in Tanzania - at several hundred million dollars, the largest ever sectoral donor support programme of its kind - may potentially provide a worrying example. Following last years water sector review this struggling programme was labelled ‘a car crash in slow motion’ [10] . The way that overseas aid is delivered can also undermine progress. In particular the ‘tyranny’ of workshop culture [11] and short term consultancy assignments, led by sometimes ill-informed expatriates tend to erode the workplace motivation of local practitioners. As well as being wasteful, by diverting scarce local management resources, drawing capable personnel away from public service to the better paying salaries of donors and NGOs, denying self-determination, such efforts can undermine the long term prospects for functional environmental protection regimes.

3.7 Effective action on climate change in developing countries also faces formidable barriers. Research undertaken in 2010 shows that emerging action on climate change in some developing countries is piecemeal, uncoordinated and possibly counterproductive [12] . Climate change is a new and politically fashionable issue, into which there is an expectation that significant new funds will be channeled. Government departments in developing countries and donor partners themselves are therefore jostling for position, eager to be identified as leaders and coordinators on the issue. In some instances commitments under the Paris Declaration [13] have been forgotten with multiple donors supporting multiple strategic climate change planning exercises within the same country. This is a significant problem since the very nature of the climate change challenge demands strong leadership and close coordination. Specifically, responding to an uncertain future climate necessitates action by multiple players and sectors, none of whom have a clear mandate for leadership and for which there is no blueprint. In the absence of robust accountability and budget tracking mechanisms it is easy to envisage an increase in the unproductive spend and effort that is already evident in some countries. Explicit focus on the core functionalities of environmental protection, robust civil society accountability monitoring and closer collaboration between development partners should be promoted to counter this.

3.8 DFID enjoys an excellent reputation within the international development community, and should use its influence to improve performance in environmental protection and to drive greater coordination and efficiency on the climate change response. DFID has carved out an international leadership role on climate change, but the expectation that DFID simply ‘doesn’t do’ environment and natural resources which persists inside and outside the organization presents a problematic disconnect between dialogue and action. Support for these sectors has been dominated by other donors, notably the World Bank, UNDP and the Scandinavians, yet their interventions have not always performed well. Rather, DFID has focused on more generic governance reform and has pioneered new aid modalities such as General Budget support and sector wide approaches. These innovations are commendable but it appears that the organizations internal architecture and priorities, and constraints in the way it can spend money and deploy personnel sometimes conspire against the flexibility which is required to analyze and unlock the complex problems which constrain genuinely sustainable development in the countries where it works. One example concerns the Alliance for Water Stewardship’s work in developing market standards for sustainable water resource use and climate adaptation. Although such innovative mechanisms clearly represent a route to ‘smarter’ economic growth and efficient environmental protection through private sector engagement and co-regulation, DFID has been unable to commit any form of support to this effort.

3.9 Examples exist which demonstrate how DFID and HMG can help unlock progress in environmental protection. One of the most successful recent environmental protection interventions in East Africa was initiated by DFID at relatively low cost. ‘Introducing Risk-Based Environmental Management Approaches in Kenya’ (REMAK) saw Environment Agency staff seconded to the Kenyan Environment Management Authority to provide strategic support for environmental regulation. This practitioner-to-practitioner support has made a very significant contribution to operational environmental protection law in Kenya, is well liked by the recipient organisation and has been internationally commended. However, spending controls and bureaucratic restrictions tend to conspire against this common sense approach of using UK practitioner expertise to support developing country environmental practitioners. This is surprising since it has been demonstrated to be successful, value for money and could generate inward revenue for HMG through a model used by others such as the US Environment Protection Agency.

3.10 Priorities set out in the DFID business plan are largely encouraging, though there are areas of concern. Firstly, the cap on administration spending which accompanies a significant increase in programme spending invites lower levels of aid efficacy. DFID Country Programme staff appear to be already overstretched, with the workload on climate change in particular outstripping human resource capacity. To make a coherent and positive impact on climate change and Environment Protection, the UK government should be careful to match the funds it commits with personnel capability to advise and oversee effective use of funds. Channeling funds through other donors, NGOs and multilaterals makes sense in some instances, but an over reliance on these vehicles for delivery will weaken accountability and efficacy in these key areas. Secondly, the desire to focus on results is understandable but could potentially skew UK aid spend onto issues where results are most easily measured (such as health, infrastructure and education) at the expense of sectors such as the environment which are no less important but where results are less tangible or time bound. It is challenging to measure results such as ‘avoided environmental degradation’ or ‘enhanced climate resilience’. Planning and development control regimes have a critical role in sustainable economic growth and reduced weather related damage but it is difficult to imagine how investment here could be justified under ‘results driven aid’.

3.11 The UK government through DFID should explicitly target four aspects of environmental protection in developing countries with an increased package of flexible aid. These aspects are 1) a sound research and knowledge base; 2) adequately resourced institutions with sufficient authority and independence; 3) institutional incentives towards public good outcomes through greater transparency, accountability and civil society oversight ; 4) an enabling environment and incentives for sustainable resource use by the private sector.

4. Answers to specific questions set by the inquiry:

4.1. Does UK Aid avoid exacerbating environmental degradation and worsening climate change? I have personally seen no evidence that UK Aid exacerbates environmental degradation or worsens climate change directly. However there is evidence from the case study of asparagus in Peru to show that investments via the International Finance Corporation, of which the UK government is a board member, have lead to unsustainable resource use and heightened vulnerability to climate change [14] . Although the IFC are now revising their safeguards, a retrospective review of all major IFC investments is needed to ensure that the tragedy unfolding in Peru has not been instigated elsewhere. The UK government should demand this. There are also examples of investments by other donors which result in resource degradation and heightened climate change vulnerability because of dysfunctional environmental protection and Environmental Impact Assessment regimes in recipient countries.

4.2. How well does the aid programme manage the tensions between boosting economic growth and environmental protection? I would argue that emphasis of ‘tension’ between economic growth and environmental protection advances an unhelpful false dichotomy. Economic growth needs to be based on sustainable natural resource use for its benefit to be felt equitably and in the long term. There is a pressing need for local decision making in developing countries to determine whether any new investment or project is desirous in advancement of the local public good. At the moment DFID does not actively support that capability and thus there is a danger that economic growth beyond that screened by donors is based on unsustainable natural resource use.

4.3. To what extent does the UK Aid programme address the environmental causes of poverty and how are environmental protection and climate change mitigation and adaptation prioritized? In the recent past UK aid has tended not to focus explicitly on environment or natural resource management sectors.

4.4. To what extent have environment protection and climate change mitigation and adaptation been mainstreamed in the government’s aid programmes? The process of Strategic Programme Reviews should ensure that UK aid ‘does no harm’ in respect of climate change. However, there is a risk that Strategic Programme Reviews and ‘mainstreaming’ may not generate sufficiently proactive or innovative action on the issues in Section 3.

4.5. Are there differences in the environmental impact of DFID’s bilateral work compared with UK-funded multilateral aid or with other programmes which assist developing countries? In terms of development assistance directed at improving the performance of environmental protection regimes my overall impression is that bilateral DFID spend would generate better value for money and greater impact than that directed through multilaterals.

5. Response to information requests

5.1. Examples of aid projects / programmes which have:

5.1.1. specifically aimed to tackle environmental/climate change issues and did so successfully:

§ DFID supported REMAK project in Kenya

§ Social accountability monitoring in water resource management, Shahidi wa Maji / Water Witness International Tanzania

5.1.2. specifically aimed to tackle environmental/climate issues but failed to meet such objectives:

§ There are numerous projects within which objectives have not been fully achieved or where inefficiencies have arisen through a lack of prior analysis and understanding of the political economy, incentives and drivers of change.

5.1.3. harmed the environment and/or exacerbated climate change mitigation/adaptation

§ Although the impacts are cumulative the IFC / Ica investment in asparagus is a useful example.

10 January 2011

[1] Environmental protection has been interpreted as the organisational functionalities for sustainable natural resource management including water and land resource management and planning, pollution control, environmental health, soil and forest management, disaster risk reduction including flood and drought management, etc.

[2] UNEP, UNDP- Poverty Environment Initiative 2009. Making the economic case: A primer on the economic arguments for mainstreaming poverty-environment linkages into national development planning.

[3] Tawasanet et al. 2009. Water Sector Equity Report , Tanzania .

[4] WWF , 2009. Investigating Shared Risks in Water.

[5] Hepworth N, Postigo J, and Guemes B, 2010. Drop by Drop: Understanding the impacts of the UK 's water footprint through the case study of Peruvian Asparagus. Progressio/Water Witness International/CEPES, London .

[6] Hepworth 2009. A Progressive critique of IWRM in sub-Saharan Africa . PhD Thesis, University of East Anglia .

[7] DFID 2010. Vulnerability to Climate Change in Tanzania .

[8] Heinrich Böll Foundation 2010. Climate Change Preparedness in Africa (series) . Nairobi

[9] Hepworth 2009. A Progressive critique of IWRM in sub-Saharan Africa . PhD Thesis, University of East Anglia .


[11] The proliferation of non-essential training workshops and meetings supported by development partners where participants receive significant financial attendance incentives (per diems). See Twaweza 2010. F or example in 2008 half of an annual US$700 K provided to an East African Environment Management Authority f or implementation of environmental law was spent on per diems, wo rkshops and travel allowances.

[12] Heinrich Böll Foundation 2010. Climate Change Preparedness in Africa . Nairobi

[13] OECD 2005. Paris Declaration on Aid Effectiveness.

[14] Hepworth N, Postigo J, and Guemes B, 2010. Drop by Drop: Understanding the impacts of the UK 's water footprint through the case study of Peruvian Asparagus. Progressio/Water Witness International/CEPES, London .