The FINAL report of the Intergovernmental Committee of Experts on Sustainable Development Finance is out

I had been dreading this for the last few weeks particular when a couple of members let me know what was and wasn’t in the report. So today I got up went to my favourite local cafe order a couple of strong coffees and read the report.

For those who do not read this blog often I would share with you that I have had serious concerns about the way this committee’s work was going from before the zero draft. I have blogged on it a number of times and also put forward a set of 21 areas I would hope would be covered in the report. A warning to young readers this blog contains an unhappy and disappointed Felix.

Unhappy because of what the report could have been and disappointed because it means the work still will have to be done for next year. The cupboard of ideas is bare...

Stakeholder engagement

All of this could have been so different. Stakeholders were excluded from the meetings unlike the SDG OWG or other Intergovernmental Committees on different issues of sustainable development over the last 20 years. This is infact the ONLY body on sustainable development to exclude stakeholders. The governments who decided that should be ashamed of themselves. They should also be ashamed of themselves when they in para 21 have the audacity to say:

“Building of the moralities and spirit that led to the Rio Declaration and the Monterrey Consensus, we consulted widely with a range of stakeholders, including civil society, the business sector, and other major groups. This outreach was integral to our work and included multi-stakeholder consultations, regional meetings, and calls for constitutions on our web site. We are all grateful for all the inputs we received.” (UN, 2014)

I cannot think of ANY stakeholder organization that has anything but contempt for the way this committee has operated in secret. How many examples do we need to give on when over the last 20 years these kind of committees would be open to stakeholders to participate in eg Ad Hoc Open-ended Intergovernmental Group of Experts on Energy and Sustainable Development, The Intergovernmental Panel of Forests to name two!

(from: http://filipspagnoli.wordpress.com/2008/08/10/human-rights-facts-53-good-governance/ )

Content

I take a deep breath here and wonder what they have actually been doing over the last few months. The report is as had been expected heavily Monterrey focused. Let me be clear I have no problems with the report having the Monterrey material in it because debt, aid, trade are critical to dealing sustainable development and poverty eradication. But and this the big But the report that was asked for is as they say in para 1:

“255. We agree to establish an intergovernmental process under the auspices of the General Assembly, with technical support from the United Nations system and in open and broad consultation with relevant international and regional financial institutions and other relevant stakeholders. The process will assess financing needs, consider the effectiveness, consistency and synergies of existing instruments and frameworks, and evaluate additional initiatives, with a view to preparing a report proposing options on an effective sustainable development financing strategy to facilitate the mobilization of resources and their effective use in achieving sustainable development objectives.”

The report does NOT seem to remember two other paras in the Future We Want:

“253. We call on all countries to prioritize sustainable development in the allocation of resources in accordance with national priorities and needs, and we recognize the crucial importance of enhancing financial support from all sources for sustainable development for all countries, in particular developing countries. We recognize the importance of international, regional and national financial mechanisms, including those accessible to subnational and local authorities, to the implementation of sustainable development programmes, and call for their strengthening and implementation. New partnerships and innovative sources of financing can play a role in complementing sources of financing for sustainable development. We encourage their further exploration and use, alongside the traditional means of implementation.

254. We recognize the need for significant mobilization of resources from a variety of sources and the effective use of financing, in order to give strong support to developing countries in their efforts to promote sustainable development, including through actions undertaken in accordance with the outcome of the United Nations Conference on Sustainable Development and for achieving sustainable development goals.”

Which paras you take as your starting point and which you don’t do then lead to a report taking a particular direction.

Content against my 21 suggestions

My 21 issues from the report	How does the report do	What should it have said
1.Differential approach to countries in different levels of development and what financial packages might be most useful for those countries (could be based on the UNDP Human Development Index);	Not done:	This suggestion I have to admit does have some problems associated with it as some of the levels of development that are in the HDI do not have formal UN definitions. But I am sure this could have been finessed. What this approach would have done is help focus the financial considerations to the countries requirements e.g. an LLDC needs different packages than an LDC or a medium developed country.
2.The mechanisms to help countries move from one level of development to another as funding portfolios change;	Not done:	What is needed is a clear set of guidance for how countries stabilize their new status as they move from one level to the other. though there is some recognition of the continued role that 0DA play to LDCs
3.What regulations need to be put into place to ensure the FDI does not impact negatively on sustainable development;	(125) FDI remains the most stable and long-term source of private foreign investment to developing countries, and has a critical role to play in financing sustainable development. However,  policymakers need to monitor the quality of FDI to maximize its impact on sustainable development. Governments should, as appropriate, adopt policies that encourage linkages between multinational  enterprises (MNEs) and local production activities, support technology transfer, provide local  workers with opportunities for further education, and strengthen the capacity of local industry to effectively absorb and apply new technology. Corporations that embrace human rights principles, labour, environment and anti-corruption values, as in the Global Compact or other international social and environmental standards, may serve as a model for other enterprises. At the same time, host governments should require all companies, including foreign investors, to meet the core labor standards of the International Labor Organization, and encourage EESG reporting, making sustainable development an essential element in company strategies.	It should have a suggestion of regulation to address this.
4.A recognition that FDI only helps some middle income countries;	The report does expose that perhaps I was wrong to be so stark - there has been growth in FDI outside middle income countries Africa saw a 6.8% rise in FDI and “FDI flows to developing economies reached a new high of US$759 billion, accounting for 52% of global FDI inflows in 2013.
5.A section on what local and regional governments might be able to achieve and what financial portfolio might be available to them;	No section on this only gets a cursory mention of the role that subnational can play: (75) At the same time, 13 countries have initiated some form of national or sub-national carbon taxes. Some mention of local level financing (98) Local bond markets can thus play an important role in financing long Term sustainable development and The effective cooperation for sustainable development, including its financing aspects, requires a global partnership with the meaningful involvement and active participation of developing and developed countries, multilateral and bilateral development and financial institutions, parliaments, local authorities, private sector entities, philanthropic foundations, civil society organizations and other stakeholders	Huge missed opportunity to identify the role that local and sub-national governments could play
6.A deep dive into what role Capital Markets could do to help sustainable development;	Not a very deep dive but a start: (85) Governments can use National Development Banks to strengthen capital markets and leverage investments in sustainable development. For example, some NDBs finance (part of) their activities through the issuance of bonds that allocate funds raised to a particular use, such as green infrastructure with the proceeds allocated to specific classes of investment (e.g. green bonds). (89) An enabling environment is essential for reducing risks and encouraging private investment. In addition, governments can work to develop local capital markets and financial systems for long-term investment, within a sound regulatory framework. (98) To successfully develop local capital markets, policymakers need to build institutions and infrastructure, including supervision, clearing and settlement systems, effective credit bureaus, measures to safeguard consumers, and other appropriate regulation	It lacks depth in what needs to be done
7.Action on Sovereign Wealth Funds was originally suggested in the UN Sustainable Development Panel Report – to advance this we should have text suggested on how to amend the Santiago Principles (Generally Accepted Principles and Practices (GAPP));	Sovereign wealth funds handle public money, but are managed like private investors. The report does not explain what can be done to address SWFs.	Santiago Principles -  Generally Accepted Principles and Practices (GAPP) a.Amend GAPP 14. Principle Dealing with third parties for the purpose of the SWF's operational management should be based on economic and financial and sustainable development grounds, and follow clear rules and procedures. b.GAPP 18. Principle The SWF's investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles. i.GAPP 18.1 Subprinciple The investment policy should guide the SWF's financial and sustainable development risk exposures and the possible use of leverage. c.GAPP 19. Principle The SWF's investment decisions should aim to maximize risk-adjusted financial returns in a manner consistent with its investment and sustainable development policy, and based on economic and financial grounds. d.GAPP 19.1 Subprinciple If investment decisions are subject to other than  sustainable development, economic and financial considerations, these should be clearly set out in the investment policy and be publicly disclosed. e.And add a new sub principle GAPP 22.3 Subprinciple: Independent opinions for the SWF commissioned from rating agencies on the credit risk of debtors (private or public) shall be based on financial and non-financial criteria including sustainable development. Credit rating agencies shall be required to demonstrate to the SWF their competency to undertake such ratings (evaluation framework, qualified analysts). Monaghan (2012) Rating Sovereign Raters: Credit Rating Agencies – Political Scapegoats or Misguided Messengers? (Manchester: Infrangilis).
8.The UN Sustainable Development Panel Report and the High Level Panel Report on Post 2015 Development Agenda to introduce in Stock Exchanges the requirement for all companies to report or explain on their Sustainable Development Report. We should see text and a date for this to happen – 2020?	Recognizes (48) (105) that corporate reporting is important. (125) Corporations that embrace human rights principles, labour, environment and anti-corruption values, as in the Global Compact or other international social and environmental standards, may serve as a model for other enterprises. At the same time, host governments should require all companies, including foreign investors, to meet the core labor standards of the International Labor Organization, and encourage EESG reporting, making sustainable development an essential element in company strategies.	Should set 2020 for compulsory reporting of all companies listed on any stock exchange
9.How to expand the role of micro-finance, micro-credit and micro-insurance to support the base of the pyramid;	(91) Many governments have thus provided and/or welcomed providers of financial services for the poor, including through microfinance institutions, cooperative banks, postal banks and savings banks, as well as commercial banks. (94) s. With the growth of microfinance institutions, both managers and regulators should be concerned about the need to balance expanding access to financial services with managing risks, including social risks of household indebtedness.  (95) Frequently, SMEs’ financial needs are too large for the traditional moneylenders and microcredit agencies, while large banks tend to bypass this market, due to administrative intensity, the lack of information and the uncertainty of credit risk. By providing credit information, credit registries/bureaus, and collateral, and insolvency regimes could help extend SME access to credit. (102) A robust regulatory framework should consider all areas of financial intermediation, including shadow banking ranging from microfinance to complex derivative instruments. Enhancing stability and reducing risks while promoting access to credit presents a complex challenge for policymakers, since there can be trade-offs between the two. Policymakers should design the regulatory and policy framework to strike a balance between these goals. For example, the European Union included special provisions (e.g. Capital Requirement Directive IV) in its implementation of Basel III to reduce the capital cost of lending to SMEs. There are also calls for financial sector regulatory systems to be widened from focusing on financial stability to include sustainability criteria.	Good language on this.
10.How cooperatives or mutual funds can be utilized for sustainable development;	Very little attempts to engage this community (91) Many governments have thus provided and/or welcomed providers of financial services for the poor, including through microfinance institutions, cooperative banks, postal banks and savings banks, as well as commercial banks. (96) Cooperative banks, post banks and savings banks are also well suited to offer financial services to SMEs, including developing and offering more diversified loan products	Could have suggested regulatory changes to open these funds more.
11.What role the IFIs should play in implementing sustainable development;	(116) International Monetary Fund (IMF), the World Bank and the other international and regional financial institutions (IFIs), are key sources of medium and long-term finance for the countries that draw upon them. Important financing modalities include public loans to governments, equity and debt finance for the private sector and a range of blended financing instruments, including risk-mitigating. (119)  the Committee recommends that the level of concessionality of international public finance should take into account both countries’ level of development (including their level of income, institutional capacity, and vulnerability) and the type of investment. Concessionality should be highest for basic social needs, including grant financing appropriate for least developed countries. Concessional financing is also critical for financing many global public goods for sustainable development. For some investments in national development, loan financing instruments might be more appropriate, particularly when the investment can potentially generate an economic return. instruments such as credit and political risk guarantees, currency swaps and arrangements combining public and capital market funds (e.g. on traditional infrastructure projects). When employed according to country and sector needs, and building on their specific advantages, they can help mitigate risk and mobilize more upfront financing than would be available from budget resources alone, as discussed in Section VI.E on blended finance. It is also important to ensure that LDCs are not refrained from accessing, solely on the basis of their income, less concessional funds from IFIs and DFIs. Financially viable projects should instead be considered on a case-by-case basis,	Could have provided guidance on how to do this
12.IFIs should be audited against the SDGs to ensure their actions do not go against what will be agreed in 2015 – a do no damage clause;	Nothing on this	IFIs set up an annual audit of their projects and ensure they are doing at least no harm
13.What reform of trade rules might help deliver the SDGs and to ensure that trade supports sustainable resource use and not the opposite;	(72) Similarly, countries should correct and prevent trade restrictions and distortions in world agricultural markets, including by the parallel elimination of all forms of agricultural export subsidies and all export measures with equivalent effect, in accordance with the mandate of the Doha Development Round. (75) deals with ‘cape and trade’ (153) In addition, the increased prevalence of global value chains has tightened the link between trade and foreign direct  investment. To achieve a better balance between investor rights and the sovereign capacity for recipient states to regulate within areas of public interest, the international community could consider, as appropriate, a further elaboration of standards for investment in areas that directly impact domestic sustainable development outcomes, and ensure that investments do not undermine international human rights standards. (154) In general, the proliferation of bilateral investment treaties and other trade agreements covering investment issues renders the mainstreaming of a sustainable development perspective in investment regimes more difficult.	Some attempt to link trade and human rights but little to layout a framework that would be robust to supporting sustainable development.
14.I expect to see some thoughts on the role that local, national and international green bonds and the role they might play;	Only one mention of Green Bonds: (85) Governments can use NDBs to strengthen capital markets and leverage investments in sustainable development. For example, some NDBs finance (part of) their activities through the issuance of bonds that allocate funds raised to a particular use, such as green infrastructure with the proceeds allocated to specific classes of investment (e.g. green bonds).	Should have identified what a role Green Bonds could play could have utilized the work on Climate Bonds to develop this. Or the work that Maurice Strong did for Rio+20 on Earth Bonds.
15.What can green banks do to promote sustainable development we now have examples in places like the UK and Australia;	No mention of the role these might play	A set of recommendations based on the experience of Australia and the UK
16.The report needs to address intergenerational equity – environmental resources and ecosystems must be carefully managed to ensure the value of assets are there for future generations;	(68) Governments can also design policies to ensure that a share of resource earnings are saved and invested for the benefit of future generations, as in sovereign wealth funds (SWFs).	This should have been a core element of the whole report and integrated through all the recommendations
17.There should be suggestions on international liability to actions taken within national boundaries that have environmental impacts beyond national jurisdictions;	Nothing on this	Could have suggested the setting up of a Court of Arbitration and Conciliation to deal with this.
18.Reform of credit rating agencies requiring them to build in sustainability criteria;	Nothing on this	Reform of the rules for Credit Rating Agencies to include sustainability criteria OR create under the World Bank an International Credit Rating Agency and take it out of private hands.
19.Taking away subsidies from fossil fuels and agriculture;	Some suggestions here (41) In all subsidy decisions, however, any adverse impacts on the poor and the environment need to be addressed, either through appropriate compensating policies or through better targeting.  (71) Countries should review the efficacy of all subsidies as a matter of sound fiscal management. Countries should consider rationalizing inefficient fossil fuel subsidies that encourage wasteful consumption by removing market distortions, in accordance with national circumstances, including by restructuring taxation and phasing out those harmful subsidies, where they exist, to reflect their environmental impacts. Such actions should fully take into account the specific needs and conditions of developing countries and minimize possible adverse impacts on their development in a manner that protects the poor and affected communities (72) Similarly, countries should correct and prevent trade restrictions and distortions in world agricultural markets, including by the parallel elimination of all forms of agricultural export subsidies and all export measures with equivalent effect, in accordance with the mandate of the Doha Development Round.	Could have included clear recommendations on how --- these are general statements
20.Addressing the issue of resilience funding for disaster relief preparation;	Good recommendation here (80) There is also an urgent need for governments to invest adequately in disaster risk mitigation and in systems that build resilience against shocks, as well as in environmental preservation, especially in areas where local populations depend on natural resources.
21.A plan for introducing the Tobin Tax.	No recommendation (51) The Leading Group on Innovative Financing for Development has pioneered on a voluntary basis a number of fund-raising mechanisms to raise additional resources, including the international solidarity levy on air tickets,37 the funds from which are contributed to UNITAID to help purchase drugs for developing countries. Eleven countries using the euro currency are currently envisioning a financial transaction tax from 2016, albeit without earmarking funds for development or financing of global public goods as of yet. Some countries (e.g. France) have, at the national level, put in place a financial transaction tax, with part of the proceeds used to finance ODA programmes.	Should have recommended the introduction of a Financial transaction tax by 2020.

 So perhaps the two co-chairs of the SDG OWG should have been asked to take control of this Committee at least we would have had the input, dialogue and I am sure a better outcome. 

My suggestion is the report should be noted and then left  in a filing cupboard in level 3 of the basement of the UN building. This will mean that there is so much more that needs to be done in this area that it exhausts me to just think about it. We cant end up like Ralph Steadman indicated we would after Rio...or will we?