How are GCF no-objection procedures being interpreted?
What are the current practices and expectations of Accredited Entities & National Designated Authorities?
The Green Climate Fund (GCF) no-objection procedure aims to ensure that projects are consistent with national climate strategies and developed using country-driven approaches. The initial purposes and basic principles were adopted in 2014 and later linked explicitly with country ownership requirements. The GCF allows for flexibility by recognising that ‘countries may establish their own nationally appropriate process for ascertaining no-objection to funding proposals according to the country’s capacities and existing processes and institutions’.
This sixth edition of GCF Insight explores the status of no-objection procedures and how they are being interpreted and implemented by Accredited Entities & National Designated Authorities (NDAs). The survey involved 84 respondents from NDAs, accredited entities and consultants and was conducted between 13 and 21 June 2017.
The survey confirmed that the development of NDA no-objection procedures is at an early stage – less than one third of responding NDAs consider that they have a full working procedure in place. Furthermore, some respondents describe the no-objection procedure as ‘extremely slow and complex’. So far, only two-thirds of projects submitted to NDAs have received letters of no-objection since the beginning of GCF operations. Although refusing to issue a no-objection letter does not appear to be a common practice, the practice of requesting “significant adjustments” in the project design is fairly common (60% of NDAs reported they had made such a request).
According to feedback from NDAs, communication with accredited entities is usually more intensive at the earlier stages (like project identification and concept note development) and slows down for the development of full proposals. Concerning time standards and guidelines for replying to requests, 76% of the surveyed NDAs do not these. Despite this, Accredited Entities and NDAs reported fairly consistent timescales for receiving letters of no-objection: usually less than 3 months.
Accredited Entities tend to think that a convincing description of country ownership and ability to demonstrate sufficient experience in the project area are crucial for securing a no-objection letter, while NDAs prioritise the alignment of projects with national development strategies and country priorities / country work programme and focus on the most urgent climate-related issues.
In terms of expectations, NDAs have slightly stronger views on the importance of interaction across all areas including the development of the annual entity programme, project identification, development of the concept note and full proposals. This is in line with comments made by some NDAs, which state that an Accredited Entity should consult the NDA before any proposal initiation. They also noted that adequate communication allows for fast tracking project approval.
As part of its independent work with the Fund, E Co. strives to provide deeper thinking and experience sharing to help ensure project formulation goes beyond business as usual
Initiatives like the GCF insight series increase the accessibility of the Fund, providing nuanced surveys and reports that deliver a thorough understanding of proposal development. Knowledge sharing initiatives such as these will enable a stronger pool of GCF applicants—and better proposals with greater stakeholder collaboration and country ownership. Contact us to discuss how we can support your GCF proposal.