Delegating, but How? A Comparison between the EU and the UNFCCC as Principals in Public Climate Finance Implementation
This is part of our Campus Spotlight on Maastricht University, and a Roundtable on Maastricht University Student Research.
Scholars in the field of international politics often point to climate change as an example of a problem more efficiently solved by delegating authority to international institutions. However, the loss of state sovereignty associated with such a transfer of decision-making power makes this problem-solving strategy contentious. The global climate regime is characterized by this paradox between the need for cooperation and sovereignty principles. The Paris Agreement can be understood as the most recent instance in which states agreed to give up a degree of sovereignty and resources to improve the climate situation. Experts such as Christoff, Oberthür and Groen, or Voigt describe this Agreement as a success, with Seo lauding the “ambitious goals, extensive obligations and rigorous oversight” (153). Others, including Grabbe and Lehne, Lyster or Obergassel et al. hold that the Paris Agreement fails to satisfactorily address its main objectives. Bodansky and Chasek et al. add that the lack of enforcement mechanisms creates difficulties for implementation. Zahar (2016) explains that the lack of a fixed budget was denoted as additional obstacle. Implementation, according to Raustalia and Slaughter, may be defined as “the process of putting international commitments into practice: the passage of legislation, creation of institutions (both domestic and international) and enforcement of rules” (539). Bowman and Minas (2019) point out climate finance, the employment of public, private or alternative financial means to support climate change action, as one of the most important means of climate implementation. Timperley and Pearce add that multilateral climate funds represent an important policy tool for international organizations seeking to implement and enforce climate commitments. They hold that public climate finance administered by such funds can fill the gaps left by both non-financial instruments and the private sector.
The European Union (EU) has, as noted by Espa, historically pushed for a legally binding climate regime on the global level. However, despite the “frontrunner” position observed by Delreux and Happaerts (2016, 244), there is a wide agreement that the EU’s environment- and climate policy has suffered from its own “implementation gap” (e.g. Benson & Jordan; Delreux & Happaerts; Jänicke; Krämer; Teichmüller). Still, Grabbe and Lehne argue, the EU’s climate policy possesses very strong legal and financial instruments compared to other relevant international climate agreements, such as the United Nations Framework Convention on Climate Change (UNFCCC; “the Convention”) (Grabbe and Lehne 2019). They advise the EU to close its implementation gap through an intensified use of these instruments, rather than a reliance on soft and market-based mechanisms. Consequently, I aim is to investigate the use of legal and financial instruments by the EU in the implementation of climate policy goals.
Listed as the EU’s main funding mechanism for climate action is the Programme for Environment and Climate Action (LIFE; “Programme”). Given the unique characteristics the EU’s legal framework as compared to international organizations such as the UN, it is interesting to see how, and under whose supervision, LIFE is conducting its work. I investigated the relative position of the Programme by comparing it to a multilateral climate fund of the UN framework: The Green Climate Fund (GCF; “Fund”), denoted as “one of the most important, perhaps the most important, policy instruments that have emerged from the UN meetings” (Seo 2017, 122). Both funds are comparable in their operation, and both represent a mechanism by which implementation duties in the field of public climate finance have been delegated by an international organisation.
Through this comparison, I found two main differences in the institutional design of the funds. First, the GCF is given a high degree of responsibility (146), and independence (Bowman and Minas, 2019). The EU approach relies more on inter-institutional networking and supervision. There is much less personal visibility or transparency in the LIFE system—it is unclear who personally is tasked with implementation. Second, while both the Convention and the EU provided guidance to their agent and spend resources on comprehensive monitoring, the possibility of sanctions, specifically the termination of the instrument, was much more present for LIFE. This conveys the impression that the EU’s lack of an overarching framework for public climate finance is the deliberate results of cost-benefit calculations. The conceptual framework suggests that the effective functioning of an agent such as a fund may be hindered by both a lack of oversight as well as overly rigorous oversight. In this case, the binding legal framework employed by the EU seems suitable to the implementation of international climate agreements, even compared to the GCF’s new governance approach.
I used the principal-agent model as a conceptual tool for my research. This model, drawn here from Pollack and Kassim and Menon,  holds the core assumption that various actors delegate power to institutions to facilitate “mutually advantageous cooperation among rational egoists” (Pollack 1997, 103). Kassim and Menon explain that climate change, a problem of collective action, tends to encourage upwards delegation (123). Such delegation to so-called agents, in this case multilateral climate funds, helps the delegating actors, principals, to implement their goals and preferences. Due to the nature of their relationship, the agent is assumed to possess an informational advantage in the implementation. Its own preferences may affect implementation unbeknownst to the principal. Therefore, it is crucial for the principal to avoid losing control over the agent. However, the control mechanisms employed by a principal may negatively impact agent effectiveness. Too little control can lead to implementation of undesired preferences, whereas excessive control over the process can leave the agent ineffective. Control mechanisms create costs for the principal. The choice of approach impacts the “effectiveness of delegation” and is therefore crucial (Kassim and Menon 2003, 125). The principal must take the decision between risking agency loss or an independent, yet effective functioning of the agent. The assumption is that the greater the amount of control, the less effective the agent becomes.
Pollack, Kassim, and Menon as well as Furness present two main methods of agent control: administrative procedures, or ex-ante controls, and oversight procedures, also called ex-post controls. Ex-ante controls are built into the institutional design of an agent. They include the scope of agency activity, legal instruments available to the agent, procedures that the agent must follow, the agent’s mandate, and the oversight measures that the agent must follow ex-post. Agent controls create costs for the principal while at the same time limiting the agent’s action potential. Ex-post controlsappear in two different shapes. First, a principal may use monitoring to mitigate the asymmetrical distribution of information. This entails the investment of resources, such as time, personnel and effort. Secondly, the principal may use sanctions to provide feedback to the agent. The information obtained through monitoring often forms a necessary precondition for the use of sanctions. Sanctions may take the shape of budgetary control, control over appointments and the power to override agency behaviour through new legislation and to revise administrative procedures laid down in the agent’s mandate. However, oversight procedures impose costs upon the principal. Before adopting a control mechanism, the principal should therefore conduct a cost-benefit analysis (Pollack, 1997; Furness, 2013). Review of such a cost-benefit analysis can provide insight into the workings of the principal.
Presenting the Funds
The Conference of the Parties to the UNFCCC created the GCF in 2011 as an operating entity to implement its climate finance preferences (Bowman and Minas 2019). The Fund functions under the Financial Mechanism of the Convention, and provides technical expertise for its funding decisions. The arrangements are designed so that “the GCF is accountable to and functions under the guidance of the COP” (1), which establishes the Convention as the GCF’s principal. In case of LIFE, the European Commission (“Commission”) is responsible for initiating the EU’s environmental and climate policy legislation, which requires inspection and possible alterations through the European Parliament (“Parliament”) and the Council of the European Union (“Council”) before it may be passed as law (Nugent 2016). Through Regulation 1293/2013, Parliament and Council delegated the authority for implementation and supervision of the Programme to the Commission (Publications Office 2013, 8), which subsequently chose to involve the Executive Agency for Small and Medium-Sized Enterprises. It is notable that an agency from the Directorate-General Enterprise and Industry is tasked with climate and environment policy implementation, normally the domain of the Directorate-General for Climate Action or the Directorate-General for Environment (Delreux and Happaerts 2016). The mandate for LIFE includes the implementation of both internal Union programmes, such as the 7th Environmental Action Programme (Publications Office 2013), and international agreements, such as the Paris Agreement (European Commission 2017, 3).
This research was based on my previous understanding and assumption that the institutional and legal background of an institution, such as the EU and the UNFCCC, would shape the way they create their implementation instruments. Therefore, I investigated the differences and similarities within the institutional set-up of the GCF and LIFE. The theoretical lens of the principal-agent model is used to focus on the control mechanisms installed in said institutional set-up. The legal documents created to set up the respective funds were analysed using indicators derived from the literature on principal-agent theory.
Similarities between the Funds: allocation criteria and monitoring
While not being completely identical, the two implementation instruments display certain similarities in their administrative procedures. On the one hand, in the case of the GCF, funded projects must follow the eligibility criteria set out by the Convention (Kim 2013). However, much action is conducted via the Board. While grants and concessional lending are designated as the primary financial instruments, the Board may design other instruments or modalities (GCF 2011). The Fund cooperates with other UN bodies e.g. through independent correspondence of secretariats (Kim 2013) and is encouraged to engage with the private sector (Bowman and Minas 2019). Therefore, several bodies within the Conventions framework are invested in the guidance to the Fund. The Convention is responsible for investing in its own control mechanisms, but monitoring is open for participation from outside sources. The Fund has, up to this point, demonstrated that it is willing and able to act according to the guidance received from its principal (Bowman and Minas 2019). However, it does not follow its mandate concerning the distribution of funding between mitigation and adaptation.
The financial instruments of the LIFE programme, on the other hand, include grants, public procurement contracts, contributions to financial instruments and other interventions to achieve its objectives (Publications Office 2013). The Commission must provide transparency concerning the implementation of the Program’s funds, including objective and accountable criteria to track climate-related expenditure (Publications Office 2013). LIFE has the obligation to protect the financial interests of the Union through “the prevention, detection, and investigation of irregularities, the recovery of funds lost, unduly paid or incorrectly used and, where appropriate, penalties” (191). Enforcement includes the involvement of institutions such as the Court of Auditors and the European Anti-Fraud Office (202). While the Commission reports to the Parliament, Council, Committee of the Regions and European Economic and Social Committee, it enjoys discretion concerning the details of its implementation (Publications Office, 2013).
It is visible that the agent’s basic mechanisms are laid out in advance (197), and that both follow pre-determined supervision mechanisms that include regular guidance from their principals and outside sources (GCF 2011). However, in both cases, they have some leeway in the “fine-tuning” of implementation. Both must prove that they implement the feedback and provide details on project implementation. The two agents are linked within other institutional actors of their respective framework. However, institutional interaction seems more pronounced in the case of the EU. A final point is that the GCF does not follow its explicit mandate on the allocation of mitigation and adaptation finance (Williams 2019). The monitoring mechanism alone does not ensure that the Convention’s preferences are implemented.
Instrumental differences: transparency and sanctions
After presenting the basic similarities of the funds, I now turn towards the most important differences that I found through my research. In the GCF context, the Convention directed notable authority for governance and oversight of the Fund to its Board, which has “full responsibility for funding decisions” (GCF 2011, 3). The Convention relies on the Board and its risk-assessment mechanism for the placement of resources. This gives the Board an opportunity to realize its own preferences. However, the UNFCCC provides guidance to the Fund (GCF 2011) to communicate preferences, for example policy gaps that it wishes to see filled. The Fund is tasked with channelling donations from developed states towards developing states for climate change mitigation and adaptation. The Board is authorized to set out the specifics of implementation and operationalize the Fund (i.e. the creation of an accountability mechanism and financial risk management framework used to monitor the investments of the fund) (GCF 2011). The Board, and, consequently, the Fund, have a broad variety of instruments at their disposal.
Board selection requirements are utilized by the UNFCCC as an ex-ante control, helping to ensure equal representation in the decision-making between developing and developed states (GCF 2011). Transparency is ensured through a public list of each member of the Board (GCF 2020). The Board itself supervises the lower levels of implementation, including monitoring, measurement framework, guidelines, periodically reviewed performance indicators and other supervision of the implementation of the funds (GCF 2011). Each meeting of the Board shall be monitored by representatives of the Convention and accredited observers, meaning two civil society and two private sector representatives (GCF 2011). Consensus was determined as decision-making procedure in advance (Bowman and Minas 2019). In practice, the absence of consensus has prevented the adoption of decisions and even led to the disruption of Board meetings altogether.
In the EU context, the Commission is responsible for political choices, such as the definition of objectives, strategies and priority areas of action (DG ENTR 2013), and constitutes the primary implementing agent. In the context of the Programme, the Commission has the right to pass further legislation required for implementation (Nugent 2016), which it has used so far to make minor changes to the instrument. The Commission designs the indicators to assess added value and implementation of LIFE-funded projects (Publications Office, 2013). While the two Directorates-General for Environment and for Climate are involved in the implementation (European Commission 2017), the Executive Agency for Small and Medium-Sized Enterprises manages not only LIFE but also several other programmes (European Commission 2020). The Commission regularly draws upon the expertise of other institutions, such as the European Investment Bank or the Court of Auditors (3). Furthermore, LIFE must communicate with funds from various policy domains to avoid overlap (Publications Office 2013). Therefore, it is visible that the Commission engages in cooperation with other specialized agencies within the EU framework in LIFE’s implementation.
The Commission’s principals have set out various monitoring requirements. Firstly, the Commission shall publish a list of projects under its support and ensure the implementation on a national level. Second, LIFE must submit to a mid-term and a final evaluation by an independent outside agency. Third, the Commission needs to present its multi-annual work programmes, demonstrating how implementation will take place. The work programmes must also demonstrate that the evaluations of previous LIFE programmes are being implemented. The institutional design of the current LIFE programme presents the Commission with several legal instruments for implementation. These instruments are linked tightly into a network of EU institutions that cooperate and supervise each other.
While the GCF and the UNFCCC represent a clear principal-agent structure, in the case of LIFE, it is more difficult to see to whom these labels shall best be attached. While the main authority lies with the Commission, a plethora of EU institutions are involved in the implementation process. Second, through the personal visibility of the Board Members, the GCF provides a mechanism for transparency that is lacking in the case of LIFE. However, LIFE is tightly inserted into a dense inter-institutional network and must justify itself to those other institutions. The argument could be made that the UNFCCC and the EU follow two different approaches towards agent transparency and accountability.
The Convention may limit the Fund’s resources, derives from member state’s Nationally Determined Contributions (Bowman and Minas 2019) if they do not find implementation to be satisfying (Kim 2013). However, only 20 of the Contribution Agreements to the GCF are legally binding, and the US exit from the Paris Agreement has threatened the GCF’s ability to operate successfully (Bowman and Minas 2019). Therefore, the safety of funds and subsequent implementation possibilities are limited (Bowman and Minas 2019). This undermines the Convention’s ability as a principal to exert budget control over its agent.
The European Parliament and the Council may withdraw the Commission’s discretion to pass implementing acts. The Commission, the Court of Auditors, and the European Anti-Fraud Office have the authority to conduct audits, on-the-spot checks, and inspections, and can help the Programme to retrieve funds improperly dispersed (Publications Office 2013). Besides the option of taking away the agent’s legal resources, strong measures are available in the case of unjustified implementation of funds. The strongest possible sanction would be the discontinuation of the LIFE programme. It is publicly documented that, should there be lack of added value, the funding instrument will be replaced after 2020 (European Commission, 2017). The documents indicate that it would be entirely possible for the EU to terminate LIFE and/or replace it with another agent. Until 2020, LIFE has passed and been approved by the Union’s cost-benefit evaluation. The same replaceability cannot be found in the case of the GCF. Furthermore, in the case of LIFE, the Parliament and Council may take away the Commission’s resources, such as the right to pass implementing acts. The Convention does not seem to have the authority to take away the Board’s extensive resources, or at least this authority is not mentioned in any publicly available documents. It also seems unlikely that the Convention will exercise strong budgetary controls soon. Both principals have sanctioning instruments at their disposal, but the enforcement and control mechanisms of the EU, and the relative flexibility they possess in the creation of new instruments, are much more prominent within the institutional set-up of their agent. In contrast to the Green Climate Fund, the Programme for Environment and Climate Action must continuously prove its value as an implementation agent.
Kirstin Herbst graduated from Maastricht University with a Bachelor of Arts in European Studies. She is currently continuing her education with a MSc in Environmental Governance.
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Photo: Brussels, Belgium. 1st June, 2018.Press conference by EU Commissioner Karmenu VELLA on the Life programme for Environment and Climate Action | Shutterstock
Published on November 10, 2020.