Acronyms
AAA Accra Agenda for Action
ADB Asian Development Bank
AEF Aid Effectiveness Forum
CDM Clean Development Mechanism
COP Conferences of the Parties
D&D Deconcentration and Decentralisation
DSENRE Department of Science, Education, Natural Resources and Environment
GEF Global Environmental Fund
GoV Government of Viet Nam
HCS Hanoi Core Statement
HIV Human Immunodeficiency Virus
LMDG Like Minded Donor Group
MARD Ministry of Agriculture and Rural Development
MOF Ministry of Finance
MoIT Ministry of Infrastructure and Transport
MONRE Ministry of Natural Resources and the Environment
MPI Ministry of Planning and Investment’s
NGO Non-Governmental Organisation
NTP National Target Programme
NTP-RCC National Target Programme for the Response to Climate Change
OCCA Steering Committee for Climate Change Adaptation and Mitigation
ODA Overseas Development Assistance
PD Paris Declaration
PG Partnership Group
PGAE Partnership Group on Aid Effectiveness
REDD Reducing Emissions from Deforestation and Forest Degradation in
Developing Countries
SD&CC Sustainable Development and Climate Planning
SEDP Socio-Economic Development Plan
UN United Nations
UNDP United Nations Development Programme
UNFCCC United Nations Framework Convention on Climate Change
VN Viet Nam
WB World Bank
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Executive Summary
Background
This report is one of five country studies that have been commissioned by the Capacity
Development for Development Effectiveness (CDDE) Facility
1
supported by the Asian
Development Bank, Government of Korea, Government of Japan, Swedish SIDA and
UNDP as part of a regional dialogue process also supported by the OECD DAC. The
purpose of the initiative is to develop a set of recommendations regarding the
programming of climate change finance at the national level. The initiative seeks to
strengthen the management of climate change finance by beneficiaries and donors through a
consideration of Aid Effectiveness principles. Findings from the country studies will be
discussed in a workshop to be held in Bangkok, October 19-20 2010.
Interviews for this Viet Nam study were conducted with officials from key ministries and
with the external funders who were available over a three day period. This was thus a very
rapid exercise, and is not a comprehensive study. It can only begin to raise key issues and
is meant to be a prompt for discussion.
The UNDP UNFCC, UNDP, the World Bank and the Stern Review have all assessed that
Viet Nam is one of the countries particularly vulnerable to the adverse effects of climate
change, notably sea level rise
2
. Viet Nam is a signatory to the UNFCCC and the Kyoto
Protocol and has been an active participant in the Conferences of the Parties (COP). Viet
Nam has associated itself with the Copenhagen Accord. It is already benefiting from
considerable external funding for climate change from both global climate change funds
(such as GEF, CTF, UN-REDD), and bilateral sources (see Annex A).
Viet Nam is seen as a leader in aid effectiveness, having established mechanisms for donor
co-ordination in accordance with the Paris Declaration and Accra Agenda for Action
principles as localised in the Hanoi Core Statement. The Aid Effectiveness Forum (AEF)
was officially established in February 2010 to provide the overarching architecture for
government-donor co-ordination for ODA.
The Role of the Government
There is a growing understanding of the potential impacts of climate change on Viet Nam
among the country’s leadership. Climate change does not feature in the current Five Year
Socio-Economic Development Plan (SEDP). However, it is expected that it will be
incorporated into the next plan (2011-15).
The National Target Programme to Respond to Climate Change (NTP-RCC) has been
designed to strengthen and consolidate capacity building and research as well to initiate
action with sector ministries and provinces. It is not a national plan with costed
implementation projects, rather the NTP-RCC will lead to the identification of activities
and funding requirements. Ministries and provinces have been asked to develop costed
action plans for the response, but this process is not yet complete. In addition, other
1
More information on the CDDE Facility can be found at www.aideffectiveness.org
2
See Dasgupta, Susmita et al. (2007): The Impact of Sea Level Rise on Developing Countries. A Comparative Analysis. World Bank Policy Research
Working Paper 4136, February 2007, the UNFCCC 2007 “CLIMATE CHANGE: IMPACTS, VULNERABILITIES AND
ADAPTATION IN DEVELOPING COUNTRIES”, Stern, Nicholas et al (2006): The Economics of Climate Change: The Stern Review.
Cambridge,
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policies and programmes exist with an immediate bearing on climate change action that are
however not obviously addressed under the NTP-RCC and the forthcoming action plans.
These include policies on natural disaster risk management, energy efficiency, renewable
energy, and forestry, most of which have national-international coordination and dialogue
forums. An overarching strategy on climate change to address this and to ensure
prioritisation of action does not yet exist but is expected to be developed.
Most of the climate change funding provided to Viet Nam to date does not appear on the
government’s budgets, nor can it yet be fully captured using government systems. Any
reporting on financing for climate change, or its use, takes place through secondary
mechanisms.
The Ministry of Natural Resources and the Environment (MONRE) is the focal point for
climate change under the UNFCCC. While the Ministry for Planning and Investment
officially co-ordinates external financing and overall development planning and MOF is
responsible for budgeting, MONRE is tasked with the co-ordination of the national
response to climate change. However, it does not possess the mandate to coordinate other
ministries, and itself will not be the beneficiary of the largest sums of climate change
assistance that are likely to be given to ministries such as the Ministry of Agriculture and
Rural Development (MARD) the Ministry of Industry and Trade (MOIT), the Ministry of
Construction (MOC) and the Ministry of Transport (MOT), and provinces. This has
resulted in a lack of institutional clarity that the GoV still needs to address.
The Role of Donors
Although it has been the subject of some discussion in the AEF, there is no single forum
for the co-ordination of donor funding for the national response to climate change. Given
the lack of a single strategy, donors are also not yet aligning behind government plans.
Neither are they implementing their plans in a fully harmonised way. As a result they are
not working in a way that is consistent with the Hanoi Core Statement.
External funders are using grants and loans, project and budget support modalities to
support climate change activities. These funds come both from bilateral programmes and
from global funding sources, including the GEF. Respondents from the Ministry of
Finance noted they would prefer all assistance for climate change to be fully integrated into
national plans and provided in the form of budget support. It is recognised at present this
is not achievable, but should be the objective, according to them. However, whilst there
are some notable exceptions (such as JICA and AFD assistance for the NTP), the majority
of funding remains in a project-based modality.
Indeed there is not yet a formal commitment from external funding partners to align with
government activities for climate change or harmonise their activities beyond the umbrella
of the Hanoi Core Statement. There is no memorandum of understanding or Heads of
Mission agreement that deals explicity with climate change. Donors do expect to include
some elements of climate change financing within the next ODA framework that will
coincide with Viet Nam’s next five year plan. There is thus intended to be a higher level of
formal coherence with national budgeting processes than at present.
The Nature of Climate Change Financing
Viet Nam demonstrates the problem of defining what climate change financing is. Some
traditional ODA channels and activities, in part or in whole, deal with adaptation to or
mitigation of climate change (for instance funding for renewable energy or disaster risk
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management). For this ODA funding, provided as grants or loans by multilateral or
bilateral partners, it is possible to debate whether elements of this funding are additional to
‘business as usual’ ODA. Fundamentally, however, such funding would have to have
been provided, in spite of climate change.
Alternatively some funds use specific channels, and to be accessed have to be identified as
funding new and additional activities that will be necessary in order to adapt to or mitigate
climate change impacts. These funds are only required because of the detrimental effects
on development that will result from climate change. Such funding is seen not as
traditional ODA, but additional ‘climate finance’. Furthermore, climate finance has
introduced new modalities for funds transfers, with a range of different channels, including
the opportunity for trading of carbon credits between institutions and countries. It thus is
arguable whether its operation should adhere to Aid Effectiveness principles at all.
However, whilst Vietnam is able to directly access such funding, it does so through
traditional funding partners who manage such funding, and the funds in operation share
many of the same characteristics as ODA.
Conclusions
Viet Nam will require billions of dollars of external funding if it is to fully respond to the
challenge of climate change. The country is beginning to benefit from such funding, for a
wide range of adaptation and mitigation activities. Viet Nam does have the foundations in
place for a coherent response to climate change in accordance with aid effectiveness
principles. However, clarity on what should be included when discussing climate change
financing and the division of roles and responsibility within both GoV and among donors
needs to resolved, if the full response is to be developed. In particular, should all elements
of climate finance be provided in accordance with Aid Effectiveness principles, even
though it additional to ‘business as usual’ ODA? It is expected that the implementation of
the next five-year SEDP will overcome some of this uncertainty, and lead to increased role
clarity between line ministries. Donors will need to improve their co-ordination, and in
particular move to implement more fully their prior commitments to the Hanoi Core
Statement. Unfortunately, some of the difficulties result from the requirements of the
international architecture, and the definitions and operation of funding mechanisms, that
are outside Viet Nam’s control.
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1. Introduction
This report is one of several that have been commissioned by the Capacity Development
for Development Effectiveness (CDDE) Facility
3
supported by the Asian Development
Bank, Government of Korea, Government of Japan, Swedish SIDA and UNDP as part of
a regional dialogue process also supported by the OECD DAC. The purpose of the
initiative is to develop a set of recommendations regarding the programming of climate
change finance at the national level. The initiative seeks to strengthen the management of
climate change finance by beneficiaries and donors through a consideration of Aid Effectiveness
principles. Findings from the country studies will be discussed in a workshop to be held in
Bangkok in October 2010, with a view to influencing the country and regional response.
The analysis seeks to prompt discussion and debate on the nature of financing for climate
change, particularly in relationship to the principles for Aid Effectiveness articulated in the Paris
Declaration (PD) and the Accra Agenda for Action (AAA). The findings will be synthesized with
findings from similar studies in Bangladesh, Cambodia, Indonesia, the Philippines and Viet Nam.
It will be used as an input into a regional workshop to be held from October 19-20 2010 in
Bangkok.
This report considers current external climate change financing mechanisms, specifically
identifying whether and how aid effectiveness principles are being applied.
The process for the analysis included interviews with a limited range of stakeholders
(donors and government) as well as consideration of other written material in country.
Whilst led by an international consultant, it benefited significantly from contributions from
the UNDP funded project based in the Government of Viet Nam’s Ministry of Planning and
Investment’s Department of Science, Education, Natural Resources and Environment
(MPI/DSENRE), the Sustainable Development and Climate Planning (SD&CC) project,
Mr. Johan Kieft and Mr Le Duc Chung. Any findings are the author’s alone.
2. Country context
In the early 1990s, Vietnam was among the poorest countries in the world. Two decades
later, it has achieved Middle Income Country (MIC) status,
4
along the way lifting nearly
half of the population above the national poverty line.
5
Vietnam began its transformation from a command to a market economy in 1986, when
the 6
th
Party Congress launched the Doi Moi or ‘Renovation’ reform programme. Though
its impact has been dramatic, the transformation was a carefully managed process.
Economic transformation was accompanied by rebuilding ties with the international
community. In 1993, Vietnam resumed relations with the international financial
institutions (World Bank, IMF and ADB) and bilateral donors, giving it access to large-
3
More information on the CDDE Facility can be found at www.aideffectiveness.org
4
I.e., per capita GNI of more than US$995, which Vietnam achieved in 2009. According to some definitions,
a country must reach this figure in 3 consecutive years to qualify as a MIC, which would put Vietnam on the
threshold.
5
MPI, “Midterm Review of the 2006- 2010 SEDP Performance”, 2008.
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scale development assistance. It became an ASEAN member in 1995 and signed a
Bilateral Trade Agreement with the United States in 2001. In 2006, it became a member of
the World Trade Organization, and embarked on an ambitious programme of economic
reforms aimed to increase the country’s global competitiveness. The Vietnamese economy
responded rapidly to these reforms, growing at an average of 7.5% between 1990 and
2008.
Over the last two years, growth rates have slowed as a result of the global financial crisis.
There have also been important changes in the nature of economic growth, linked to
Vietnam’s achievement of MIC status. As productivity has increased, higher value-added
exports such as electronic products have become more important. There has been a major
real-estate boom (prices jumped 263% in 2007), with FDI shifting from industry into
hotels and other real estate.
The shift towards MIC status has also affected the nature of the aid dialogue in Viet Nam.
Traditional aid partners (particularly bilaterals) are beginning to leave or reduce their
programmes, and Viet Nam’s relationship with regional partners is becoming more
important.
Government and donor commitment to aid effectiveness is strong in Viet Nam. The 2005
Hanoi Core Statement (HCS) provides the framework for a highly organised engagement
around the Paris and Accra principles. The HCS brought together various reform
initiatives and efforts underway for some years, including National planning processes,
Public Financial Management, Public Administrative Reform, Deconcentration and
Decentralisation (D&D), as well as Sector reforms and SWAP-type approaches. The
country’s engagement with donors is managed by the Ministry of Planning and Investment
(MPI) in collaboration with the Ministry of Finance. MPI leads on the implementation of
the Hanoi Core Statement
Following on from the earlier Partnership Group on Aid Effectiveness (PGAE), the Aid
Effectiveness Forum (AEF) was officially established in February 2010 to provide the
overarching architecture for government-donor co-ordination around aid (and now
development) effectiveness issues. The AEF is an umbrella body for twenty Partnership
Groups (PGs), setting the overarching context for the relationship of the Government of
Viet Nam to external funding partners. The individual PGs deal with specific sectoral or
thematic issues.
In addition, the AEF (consistent with the spirit of the Accra Agenda for Action) brings
Civil Society Organisations, the National Assembly and International Non-Governmental
Organisations in to the dialogue with government.
The AEF meets in the week preceding the Consultative Group meeting between external
partners and government, allowing it bring aid effectiveness issues to the attention of
senior figures on both sides of the development partnership.
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3. Ownership
The 2008 Viet Nam Monitoring Survey for the Paris Declaration
6
notes, “…ownership
specifically concerns a country’s ability to carry out two, inter- linked activities: exercise
effective leadership over its development policies and strategies; and co-ordinate the
efforts of various development actors working in the country.” The survey concludes that
Viet Nam does both these activities well at a strategic level, but there are vulnerabilities for
policy-making and planning at sub-national level.
Viet Nam is a signatory to the UNFCCC, the Kyoto protocol and has also associated itself
with the Copenhagen accord. Viet Nam is thus committed to implementing the decisions
of the Kyoto Protocol and the subsequent Conferences of the Parties (COP). Viet Nam is
therefore eligible to apply for most forms of climate financing, and the country is involved
in both the UN-REDD and Clean Development Mechanism processes. Consequently, the
government has sought to implement the guidelines that derive from the international
agreements. These include institutional requirements, such as the identification and
tasking of the relevant focal points, and development of policies that enable the local
implementation of the global agreements.
The Prime Minister has provided the most senior leadership on climate change to date.
However, whilst committees of the National Assembly have discussed elements of the
agenda, as yet there is no statement from the National Assembly that relates to a climate
change policy at the highest level. Climate change does not feature in the current Five
Year Socio-Economic Development Plan (SEDP) nor in the guidance framework for the
next SEDP
7
. However, indications are that the next Party Congress, to be held in early
2011, will pay particular attention to climate change, and climate change will be
mainstreamed in some form into the 2011-2015 SEDP. It is also reported that the National
Assembly may propose that a new Committee for Natural Resources, Environment and
Climate Change is established to replace the current Committee for Science, Technology
and Environment.
Respondents indicate that there was a growing understanding of the potential impacts of
climate change on Viet Nam among the country’s leadership. The role of the Prime
Minster as chair of the National Climate Change Steering Committee, recent development
of national programming and ministry action plans on climate change all demonstrate
commitment to action.
Viet Nam is particularly vulnerable to the adverse effects of climate change, notably sea
level rise and its associated impacts
8
. However, as the recent UN-LMDG Joint Country
Analysis noted “Despite media attention and discussion at the national level, it is evident that at the
grassroots level many of the communities which are most vulnerable still have little knowledge of climate
change and its potential effects.”
9
The climate change response therefore remains a top-down
process, which has not yet engaged the energies and the self-interest of Vietnamese
communities.
6
OECD, 2008 SURVEY ON MONITORING THE PARIS DECLARATION: MAKING AID MORE
EFFECTIVE BY 2010
7
In Instruction No.751/2009/CT-Ttg
8
See Dasgupta, Susmita et al. (2007): The Impact of Sea Level Rise on Developing Countries. A Comparative Analysis. World Bank
Policy Research Working Paper 4136, February 2007, also the UNFCCC 2007 “CLIMATE CHANGE: IMPACTS,
VULNERABILITIES AND ADAPTATION IN DEVELOPING COUNTRIES”, and Stern, Nicholas et al (2006): The
Economics of Climate Change: The Stern Review. Cambridge,
9
van Arkadie, B et al “Joint Country Analysis of Vietnam – UN-LMDG” July 2010
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Since 2003 the focal point for activities related to the UNFCCC has been the Ministry of
Natural Resources and the Environment (MONRE). In a decision dated April 6
th
2007,
the Prime Minister formally assigned responsibility to MONRE and other related
ministries/sectors (including local authorities) to implement the Kyoto Protocol and Clean
Development Mechanism (CDM).
A year later in July 2008, MONRE published the draft National Target Program to
Respond to Climate Change
10
(the NTP-RCC).
“According to the World Bank (2007), Vietnam is among the countries which are hardest hit by
climate change and sea level rise. Mekong and Red rivers’ delta are projected to be the most
seriously inundated. With sea level rise of 1 meter, about 10% of the population would be
directly affected and lost of GDP would be about 10%. If sea level rises by 3 meters, about 25%
of the population would be directly affected with GDP lost of about 25%.”
Extract from draft document; the National Target Program to Respond to Climate Change, July 2008
As well as identifying the potential impact of climate change on the natural environment,
economy and society of Viet Nam, the NTP-RCC assigned roles and responsibilities for
the national response. On the 2nd December 2008, the Prime Minister issued a formal
decision, approving the National Target Program to Respond to Climate Change
11
(Decision 158). Decision 158 sets out that the NTP will be implemented in three phases:
“ - First Phase (2009 - 2010): Starting up
- Second Phase (2011 - 2015): Implementation
- Third Phase (after 2015): Development”
The initial, starting up, phase seeks to provide the foundations for implementation. Thus
it focuses on developing the knowledge base, specifically a coherent scientific basis for
planning. The decision was to complete the analysis of possible climate change impact
scenarios, then pilot different projects to assess impacts on vulnerable processes and
locations. At the same time as building technical knowledge and capacity, the initial phase
seeks to strengthen the institutional response.
4. Strengthening the capacities of organization, institutions and policy on climate change
Review the current legislation and policy system, and assess the current way of addressing climate
change in the State’s legal documents and policies; develop, supplement and perfect the legal
document system, mechanisms and policies to ensure the legal basis for activities to respond to
climate change.
a) Targets to be achieved by 2010
- Basically develop a framework of legal documents, mechanism, and policies to respond to
climate change;
- Develop, promulgate and implement a mechanism for coordination among the ministries,
sectors, and localities, and the NTP management and implementation apparatuses.
Extract from Decision on approval of the National Target Program to Respond to Climate Change Decision
158/2008/QD-TTg of 2
nd
December 2008
The NTP-RCC has an explicit objective to ensure that climate change is incorporated into
national and provincial plans. Specifically, it sets out that each line ministry and local
administration should have a Climate Change Action Plan. These are being put in place,
though the system is not yet fully functioning. MONRE’s role, according to the NTP-
10
Implementing the Government’s Resolution No. 60/2007/NQ-CP dated 3
rd
December 2007
11
Decision 158/2008/QD-TTg of 2
nd
December 2008
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RCC should be to co-ordinate these plans, set guidelines for submission and comment on
them to ensure their technical appropriateness.
It should be noted that the NTP-RCC is not, in reality, a national plan for climate change;
rather it created the policy framework for building the national response. Thus while it called
upon line ministries to develop their own action plans, it did not specify what these plans
should contain. Therefore it was not a document that identified all activities or projects
for funding. However, it set in process a mechanism for the development of ministry level
plans that, when collated, may become an overall list of activities for implementation and
funding.
This fully collated list has yet to emerge. The most advanced ministries, MARD and the
Ministry of Infrastructure and Transport (MOIT) have taken divergent approaches.
MARD has developed a list of projects and MOIT has re-presented its existing
commitments under the Energy Efficiency law and the Renewable Development action
plan. However, while the government has not yet instructed MONRE to reframe the
NTP-RCC to include the details outlined in line ministry action plans, there was an
expectation from some respondents interviewed for this study that it will. This should, in
theory, lead to a single schedule of funding requirements.
Among other things, the NTP-RCC currently identifies how the co-ordination of climate
change should take place, and begins to describe the role of external funding partners. As a
result a Standing Office for the NTP-RCC has been put in place, as well as an Executive
Board, chaired (according to decision 158) by the Minister of MONRE. The Standing
Office and the Executive Board are accountable to the Prime Minister and the National
Steering Committee, which he chairs.
“The National Steering Committee for the National Target Program to Respond to Climate
Change (hereinafter referred to as the Steering Committee) comprises of: the Prime Minister -
Chairman; Minister of the Ministry of Natural Resources and Environment - Standing Vice
Chairman; Minister of the Ministry of Planning and Investment - Vice Chairman; Minister of the
Ministry of Finance - Vice Chairman; Others Members are the Minister of the Ministry of
Agriculture and Rural Development and Minister of the Ministry of Foreign Affairs.”
Extract from Decision on approval of the National Target Program to Respond to Climate Change Decision
158/2008/QD-TTg of 2
nd
December 2008
Other line ministries, notably the Ministry of Agriculture and Rural Development
(MARD), have a considerable stake in the development of the national response. MARD
has established a steering committee for climate change adaptation and mitigation
(OCCA), and a series of (primarily adaptation) projects for funding (totalling up to $12bn
for five years) on activities ranging from rural infrastructure to agriculture systems
adaptation. These are set out in its “Action Plan Framework for Adaptation and
Mitigation of Climate Change of the Agriculture and Rural Development Sector Period
2008-2020”. It is notable that this funding, however, does not include that for REDD
12
,
for which the Forest Management Division in MARD is the designated focal point. Viet
Nam is currently implementing its US$4.5m pilot programme
13
to make Viet Nam “REDD
ready”, which will result, it is expected, in a series of REDD projects within an overall
policy framework. Again, this REDD programme will be costed and include funding
requirements.
12
United Nations Collaborative Programme on Reducing Emissions from Deforestation and Forest
Degradation in Developing Countries
13
http://www.un-redd.org/UNREDDProgramme/CountryActions/VietNam/tabid/1025/language/en-
US/Default.aspx
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In the context of the Government of Viet Nam, MONRE is a young and junior ministry
(it was established in 2002). In contrast, MARD is large, powerful and has been at the
centre of the development of Viet Nam for the last 30 years. It has excellent policy
capacity, many more human resources than MONRE, and long established donor
partnerships. While MONRE has the task of co-ordinating the government’s policy
response to climate change (setting guidelines for and approving climate change action
plans with every line ministry), it is inhibited in that it does not readily have the status or
capacity to perform these tasks.
Viet Nam arguably exhibits a characteristic that is being replicated in several countries that
have implemented the institutional requirements of the global climate change governance
bodies. By requiring the designation of focal points with particular responsibilities for
particular policy areas (e.g. MONRE for the UNFCCC, KP and CDM Designated
National Authority, MARD for UN-REDD and Aforestation/Reforestation, as well as for
the UNCCD) irrespective of the country context, unhelpful dynamics between ministries
and agencies for the co-ordination of climate change policy may result. In particular, this
can affect how policy ministries relate to each other over the competition for, and access
to, funding for climate change from the different channels. Climate change, like its related
issue Disaster Risk Reduction, cuts across sectors, and arguably requires management that
is seeks to integrate, not fragment policy, implementation and budgeting processes.
Since donor relations and overall Social-Economic development are managed by the MPI,
this ministry is also a critical player in the management of external climate change
financing. Decree No. 131/2006/NĐ-CP dated 9 November 2006 provides guidelines on
ODA management and utilization. It regulates the establishment, operation and
completion of national systems for ODA, including setting out how projects should be
managed and monitored and how information is to be shared between Vietnamese
agencies and donors. Decree 131 identifies that whilst sectoral or thematic policies are to
be determined by the appropriate ministry or agency, financial planning relating to ODA is
the responsibility of MPI, in co-ordination with the Ministry of Finance (MoF).
In interview, officials from the MOF said they were recommending that MONRE build on
its role as set out in the NTP and develop a set of clear criteria for priority projects, which
other line ministries should use to plan accordingly. Line ministries and provinces should,
it suggested, design their projects based on these priorities, and then submit projects to
MONRE, MOF and MPI for approval (the latter being defined in this role as set out in
decree 131). This is a step change since the current NTP process identifies that MONRE
only set broad guidelines for ministries to set their own priorities and design their own
activities.
Again it is worth reinforcing, however, that the leadership for individual climate change
projects is not MONRE, even though it is the focal point for the UNFCCC. By the same
token, MONRE or line ministries should not submit projects directly to the Prime
Minister for approval, but should submit proposals through MPI. MPI report that they
have communicated this process (which is the generic one for external financing to the
donors).
MPI also report that they have not to date had discussions with donors on the dynamics of
climate change financing specifically. Certainly it appears that donors are not yet fully clear
how the agenda for climate change is fully owned within the GoV and the respective roles
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