Civil Society Achieves Greater Access to Information on Upcoming GCF Projects

Author: Tara Daniel

Civil society, Indigenous Peoples, and local community observers to the GCF achieved an ideological victory concerning our role in the GCF, which should also result in tangible opportunities for observers and rightsholders to strengthen their meaningful engagement with the Fund. The Information Appeals Panel (IAP) upheld an appeal from civil society observers who were denied basic information about upcoming GCF projects, and in that ruling, the IAP recommended that access to this information become a standard part of the GCF process moving forward. This ruling and these recommendations are an affirmation of the principles of transparency and proactive information disclosure for which observers have advocated for years while also reifying the importance of our engagement in GCF projects earlier in the process.

The Information Disclosure Policy (IDP) of the GCF, adopted in 2016, provides a framework and principles for access to information about the Fund. From its opening paragraph, the IDP affirms the fundamental premise of the policy is inextricably connected to valuable functions that civil society, Indigenous Peoples, and local communities contribute to the Fund’s operations: “Through the implementation of this [Policy], the GCF recognizes the need to ensure public access and stakeholder participation in fulfilling its role.” The IDP, which establishes its first principle as maximum access to information, demonstrates that essential preference for disclosure over denial by prescribing timelines for information disclosure, describing the specific and narrow instances when information should not be accessible, and providing the framework for information requests as well as appeals, when such requests are denied.

The CSO Active Observer team used this request and subsequent appeals process to obtain more information about the funding proposals for GCF projects that should be coming up at GCF Board meetings this year. At the 25th meeting of the Board in March, the GCF Executive Director made a statement indicating the number of anticipated proposals for the B.26 and B.27 meetings to be held later in the year. In May, prior to knowing anything about the next GCF Board meeting given widespread uncertainty about travel as well as virtual meetings, the CSO Active Observer team decided to seek information that would help us prepare for upcoming meetings.

The CSO Active Observer team submitted an information request for an indicative list of B.26 and B.27 proposals, knowing that basic information about the proposals such as the project titles, countries, and accredited entities would improve observers’ ability to review and analyze proposals, engage with accredited entities and officials in countries, and conduct advocacy prior to the Board meeting. We also requested, if possible, basic summary information on the proposal, as is contained in the first part of the full proposal template.

At the end of their 30 working day review period, the Secretariat denied this request. The Secretariat indicated that it had already provided some information–given that the environmental and social disclosures for category A/Intermediation-1 and category B/Intermediation-2 proposed projects and programs were sent in compliance with their disclosure timelines–and then cited the standard timelines for disclosing the full project proposals 21 days prior to each Board meeting as reasons to not give any further information. The Secretariat refused to give this basic information any earlier by variously justifying that it could be gleaned through individual outreach to accredited entities and GCF departments, or was confidential information, or could not be produced by their project management system.

In August, amidst preparation for the B.26 Board meeting, the CSO observer team appealed this denial to the IAP, comprising the Heads of each of the Independent Units. This appeal, which addressed each of the Secretariat’s reasons for denial, was filed in the hopes of not only obtaining access to information that will aid observer preparation for B.27, but also receiving an opinion that would reaffirm the role of the IDP in enabling, not blocking, maximum and proactively supplied access to information.

As part of the appeal process, the Secretariat responded with further justifications, and our rebuttal focused on their “misguided approach of adhering narrowly to the letter of the IDP without considering, appreciating, or fulfilling its overall directive toward maximum disclosure.”

In their ruling on September 22, the IAP found each of the Secretariat’s reasons for denial to be inapplicable. The Panel underscored the proactive spirit of the IDP, specifically highlighting that time-limits set by current policies are minimums, and that earlier disclosure is both possible and advisable. The IAP upheld that using the IDP to withhold this information would “render nugatory the GCF’s policy goals of early stakeholder engagement in GCF activities, including the development of measures to mitigate, manage and monitor environmental and social risks and impacts.”

Furthermore, the IAP agreed with our reasoning to such an extent that they recommended access to this information moving forward, beyond the B.27 scope of the original request. Not only should “other relevant and publicly disclosable information be routinely and proactively made available by the GCF Secretariat at the earliest stage possible for all funding proposals,” but an “appropriate public platform” should be developed. The reasoning fully supports one of the fundamental assertions of GCF civil society, Indigenous Peoples, and local communities observers, that early stakeholder engagement strengthens the GCF’s ability to fulfill its obligations to the communities it should be serving as well as ensures its adherence to key policies, such as its environmental and social management system and Indigneous Peoples Policy.

While it remains to be seen if the Secretariat will act on these recommendations, “this represents a great opportunity for the effective inclusion of the different stakeholders of the observer network in the monitoring of the Fund’s actions, especially for those who may be affected by the actions of the GCF in their territories,” as CSO Active Observer for developing countries Eileen Mairena summarized. Information on this ruling should also be an agenda item at the next GCF Board meeting, thus giving the CSO Active Observers opportunity to publicly indicate the extent to which the GCF Secretariat has honored the ruling in the lead up to that meeting.

If implemented, these recommendations can positively change how observers prepare for Board meetings. Mairena continued: “Above all, it gives us the opportunity to generate a real exchange and preparation for the actions of the Fund prior to the meetings and the approval of the funding proposals, to be able to approach our NDAs and accredited entities to establish an inclusive and real dialogue.” Rather than waiting to see the full proposals 21 days prior to each Board meeting, observers would know basic information about a proposal earlier in the project lifecycle. This information can be used to strengthen our engagement, analysis and advocacy, including enabling:

  • targeted outreach to the accredited entities for each proposal (who may voluntarily share more proposal details directly with observes)
  • targeted connections with on-the-ground partners in communities where the project/programme may be implemented (to discover if they have been engaged and solicit their feedback)
  • better planning for technical analyses once full proposals are available (by securing the time of key experts and collaborators on the proposal sector, approach, or region)

As Erika Lennon, CSO Active Observer for developed countries, celebrated, “In an observer network seeking to meaningfully engage and hold accountable an institution committed to delivering billions of dollars of finance for climate action every year, this decision can be a game-changer.” Early knowledge about potential GCF projects/programmes before the proposals are fully developed and reviewed by the Independent Technical Advisory Panel or submitted to the Board is essential for local communities, Indigenous Peoples, and civil society who are vital partners and should be involved from the beginning of project design. We will continue to advocate for transparency of the entire GCF proposal pipeline, but this new insight into upcoming proposals is a vital step toward a new modus operandi–one not dictated by reacting and hustling to fully developed proposals in the few weeks prior to each Board meeting, but one facilitating dialogue with depth, consideration, and deliberation with accredited entities, National Designated Authorities, and the communities they should be serving. True country ownership requires the involvement of impacted communities from early in the project cycle and an increasingly transparent pipeline is a key component to achieving that.

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