CLIMATE CHANGE

State Should Further 

Improve Its Reporting 

on Financial Support 

to Developing 

Countries to Meet 

Future Requirements 

and Guidelines

Report to the Ranking Member, 

Committee on Foreign Relations, 

U.S. Senate

September 2013

GAO-13-829

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-829, a report to the

Ranking Member, Committee on Foreign 

Relations, United States Senate

September 2013

CLIMATE CHANGE

State Should Further Improve Its Reporting on 

Financial Support to Developing Countries to Meet 

Future Requirements and Guidelines

Why GAO Did This Study

In 2009, the United States and other 

developed nations pledged to 

contribute funding approaching $30 

billion in new and additional assistance 

between 2010 and 2012 for developing 

countries to address climate change. 

This type of assistance is called 

“climate finance” and funding for this 

period is known as “fast-start finance.”

The pledge was made under the 

Framework Convention, a treaty that 

seeks to address climate change. 

State is the lead agency responsible 

for reporting the United States’ FSF 

contributions between 2010 and 2012 

and plans to continue reporting on U.S.

climate finance in the future. GAO was 

asked to review climate finance. This 

report examines (1) the extent to which 

the United States contributed to FSF,

(2) how State collected and reported

U.S. FSF data, and (3) what is known 

about the effectiveness of U.S. FSF

activities. To address these objectives, 

GAO reviewed FSF data, interviewed 

agency officials, and visited three 

countries receiving significant FSF 

assistance in three regions.

What GAO Recommends

To ensure the United States meets

future climate finance reporting 

requirements and guidelines under the 

Framework Convention, GAO 

recommends that State determine how 

it will collect and report climate finance 

information and review current 

capabilities for meeting the 

requirements and guidelines. GAO 

also recommends that State, in 

consultation with USAID, consider 

providing a budget code to improve 

tracking of climate change assistance.

State agreed with GAO’s 

recommendations. 

What GAO Found

To implement the United States’ fast-start finance (FSF) commitment, the 

Department of State (State) reported that the United States contributed $7.5 

billion in fiscal years 2010 through 2012 for a variety of activities related to 

climate change. State, the U.S. Agency for International Development (USAID), 

and the Department of the Treasury (Treasury) provided $2.5 billion for activities

under the Global Climate Change Initiative (GCCI) that were designed to address 

climate change as a primary goal. State reported that USAID and other agencies, 

including the Millennium Challenge Corporation (MCC), the Export-Import Bank 

of the United States, and the Overseas Private Investment Corporation provided 

$4.9 billion for activities that were not part of the GCCI but had climate-related 

benefits. Contributions consisted of grants, loans, development finance, and 

export credit. The majority of these funds were reported as supporting mitigation 

activities focused on clean energy or sustainable landscapes. According to State, 

the U.S. FSF contributions were “new and additional” because the funding was

appropriated on an annual basis and not guaranteed from one year to the next.

Between 2010 and 2012, State improved its method for collecting data for its 

FSF reports, but it is uncertain how it will meet future reporting requirements and 

guidelines. Following its initial FSF report in fiscal year 2010, State developed a 

structured data collection tool to facilitate and standardize data collection across 

the agencies. Nonetheless, challenges in tracking climate change assistance 

remain. USAID, the largest FSF contributor, is not able to track climate change 

obligations and expenditures because of the lack of a dedicated State/USAID 

budget code for climate change assistance. While the FSF reports were

voluntary, reporting is required beginning in 2014 based on decisions by the 

Conference of the Parties to the United Nations Framework Convention on 

Climate Change (Framework Convention). Future reports must contain climate 

finance data elements that State did not include in the FSF reports and, in some 

cases, does not currently collect. For example, State does not collect information 

on the annual status of climate finance contributions provided, committed, and/or

pledged, as specified in the new reporting guidelines. State officials said that they 

have not determined how they will collect and report this information.

The overall effectiveness of U.S. FSF activities is difficult to determine because 

of the challenges involved in monitoring and evaluating assistance to address 

climate change. These challenges include difficulties in measuring the effects of 

individual activities within the larger context of global climate change, and the fact 

that many of these activities are just beginning to be implemented. Under the 

GCCI, State, USAID, and Treasury fund activities with a primary goal of 

addressing climate change, and State and USAID are refining their climate 

change performance indicators to improve monitoring of these activities’ results.

USAID is also drafting an evaluation plan for its climate change assistance.

Treasury does not directly monitor and evaluate its climate change funding but 

requires the multilateral institutions that receive and implement this funding to 

monitor and evaluate these activities. Other key agencies’ FSF activities were not 

part of the GCCI, and these agencies’ approaches to monitoring and evaluation 

vary based on their respective missions and requirements. For example, MCC 

primarily assesses its projects on the basis of the progress made in achieving its

goal of poverty reduction.

View GAO-13-829. For more information, 

contact Thomas Melito at (202) 512-9601 

or melitot@gao.gov, or J. Alfredo Gomez 

at (202) 512-4101 or gomezj@gao.gov.
Page i GAO-13-829 Climate Change

Letter 1

Background 3

State Reported That the United States Contributed $7.5 Billion to 

FSF, Supporting a Variety of Activities 7

State Improved Its Data Collection over the FSF Reporting Period, 

but Has Not Determined How It Will Meet Future Reporting 

Requirements and Guidelines 18

Determining Effectiveness of FSF Activities Poses Challenges; 

State and USAID Are Refining Their Approach to Monitoring and 

Evaluating Activities That Address Climate Change 29

Conclusions 38

Recommendations for Executive Action 39

Agency Comments 39

Appendix I Objectives, Scope, and Methodology 41

Appendix II Comments from the Department of State 43

Appendix III GAO Contacts and Staff Acknowledgments 47

Tables

Table 1: Funding for Global Climate Change Initiative (GCCI) 

Activities, Non-GCCI Activities, and Total U.S. Fast-Start 

Finance (FSF) Funding by Agency, Fiscal Years 2010-2012 

(dollars in millions) 12

Table 2: Placement of Climate Change as a Sub-Element in State 

and USAID’s Foreign Assistance Framework 21

Table 3: Comparison of the Future Framework Convention 

Biennial Reporting Criteria and State’s Current Data 

Collection for Climate Finance 25

Table 4: State and USAID’s Standard Global Climate Change 

Indicators 33

Contents
Page ii GAO-13-829 Climate Change

Figures

Figure 1: Comparison of Areas of Focus within UN Framework 

Convention and U.S. Global Climate Change Initiative 

Pillars 7

Figure 2: Total U.S. Fast-Start Finance (FSF) Funding by Agency, 

Fiscal Years 2010-2012 (dollars in millions) 9

Figure 3: U.S. Fast-Start Finance (FSF) Funding by Adaptation and 

Mitigation Activities, Fiscal Years 2010 through 2012 

(dollars in millions) 10
Page iii GAO-13-829 Climate Change

Abbreviations

CIF Climate Investment Funds

EPA Environmental Protection Agency

Ex-Im Export-Import Bank of the United States

Framework Convention United Nations Framework Convention on

Climate Change

FSF fast-start finance

GCCI Global Climate Change Initiative

GEF Global Environment Facility 

MCC Millennium Challenge Corporation

OMB Office of Management and Budget 

OPIC Overseas Private Investment Corporation

State Department of State

TFCA Tropical Forest Conservation Act

Treasury Department of the Treasury

USAID U.S. Agency for International Development

USTDA U.S. Trade and Development Agency

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-829 Climate Change

441 G St. N.W.

Washington, DC 20548

September 19, 2013

The Honorable Bob Corker

Ranking Member

Committee on Foreign Relations

United States Senate

Dear Senator Corker:

Increasing concentrations of greenhouse gases in the atmosphere have 

altered the earth’s heat and radiation balance and contributed to changes 

in the earth’s climate, according to the National Research Council and the 

United States Global Change Research Program. Greenhouse gases trap 

some of the sun’s energy and prevent it from returning to space, warming 

the atmosphere. The effects of a warmer climate could have important 

consequences for human health and welfare by altering weather patterns, 

increasing the frequency and intensity of storms and droughts, changing 

crop yields, and contributing to flooding in coastal areas, among other 

things. While climate change can have positive and negative effects, the 

World Bank reported that the most pronounced negative effects are likely 

to occur in less economically developed countries.

In 2009, the United States and other developed countries jointly 

committed to providing developing countries with funding approaching 

$30 billion in assistance between 2010 and 2012 and committed to jointly 

mobilize $100 billion a year in public and private funds by 2020.1 These 

funds are intended to be used for activities that aim to address the causes 

and impacts of climate change. We refer to this funding as “climate 

finance,” and we refer to climate finance for the 2010 to 2012 period as 

“fast-start finance” (FSF). This commitment was made under the auspices 

of the United Nations Framework Convention on Climate Change 

(hereinafter referred to as the Framework Convention), a treaty that seeks 

to address the challenges posed by climate change, with 194 countries 

and the European Union as Parties.2

 1

U.N. Doc. FCCC/CP/2009/11/Add.1, Dec. 2/CP.15, ¶ 8 (Dec. 18, 2009) [hereinafter 

Copenhagen Accord].

The U.S. Department of State 

2

See United Nations Framework Convention on Climate Change, U.N. Doc. A/AC237/18 

(1992), reprinted in 31 I.L.M. 849 (1992) [hereinafter Framework Convention]; and 

Copenhagen Accord, ¶ 8.
Page 2 GAO-13-829 Climate Change

(State) is the lead agency for international climate negotiations and for 

reporting to the secretariat of the Framework Convention on progress in 

fulfilling the U.S. climate finance commitments. In three annual reports to 

the Framework Convention secretariat, State reported on the amount and 

characteristics of U.S. FSF. Each report included a summary of the U.S. 

FSF funding, an overview of global and regional activities, and fact sheets 

on countries that received funding for that fiscal year.

You asked us to review aspects of the assistance the United States 

provided to address its FSF commitment under the Framework 

Convention. This report examines (1) the extent to which the United 

States contributed to FSF and the types of activities this funding 

supported, (2) how State collected and reported data on U.S. FSF funding 

and its plans for future reporting, and (3) what is known about the 

effectiveness of U.S. FSF activities.

To address these objectives, we focused primarily on the following six 

U.S. agencies that provided over 95 percent of the U.S. FSF funding: 

State, the U.S. Agency for International Development (USAID), the 

Department of the Treasury (Treasury), the Millennium Challenge 

Corporation (MCC), the Export-Import Bank of the United States (Ex-Im), 

and the Overseas Private Investment Corporation (OPIC). We 

interviewed agency officials and reviewed agency strategies, planning 

and programming documents, indicators, and monitoring and evaluation 

plans and reports. In addition, we reviewed and analyzed FSF funding 

data, criteria, and guidance. We also reviewed Framework Convention 

climate finance commitments, reporting guidelines, and requirements. We 

conducted fieldwork in three countries—Ethiopia, Indonesia, and 

Mexico—which we selected based on a range of factors, including FSF 

funding levels and sources, areas of focus, project implementation status, 

geographic diversity, country income level, recommendations from 

agencies, and congressional interest. These countries serve as illustrative 

and not representative examples. In these countries, we met with U.S. 

embassy officials and implementing partners, host-country government 

officials, multilateral development banks, and other bilateral donors. We 

also visited project sites and met with local implementing partners and 

recipients of the assistance. Appendix I provides more information on our 

scope and methodology.

We conducted this performance audit from May 2012 to September 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 
Page 3 GAO-13-829 Climate Change

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

In 1992, the United States and most other countries negotiated the 

Framework Convention with the aim of stabilizing atmospheric 

concentrations of carbon dioxide and five other greenhouse gases.3 The 

Framework Convention includes a pledge from developed countries to 

assist developing countries in implementing these objectives.4

Efforts to address climate change under the Framework Convention 

generally fall into two categories—mitigation and adaptation. According to 

the Framework Convention, measures to mitigate climate change include 

efforts to limit manmade emissions of greenhouse gases and enhance 

greenhouse gas “sinks.” The Framework Convention defines “sink” as 

any process, activity, or mechanism that removes a greenhouse gas, an 

aerosol, or a precursor of greenhouse gas from the atmosphere. For 

example, preserved forests, which store carbon dioxide, serve as 

greenhouse gas sinks. The burning of fossil fuels for energy accounts for 

about two-thirds of global manmade emissions. The remaining third 

stems from industrial and agricultural processes, land use changes such 

as deforestation, and waste such as methane emitted from landfills.

The 

Framework Convention also recognizes the special situation of countries 

designated by the UN as least developed countries. The Conference of 

the Parties is the supreme decision-making body of the Framework 

Convention and all Parties to the Convention are represented at the 

Conference of the Parties. In 2001, the Conference of the Parties further 

noted that least developed countries have a lower capacity to cope with 

and adapt to the impacts of climate change, and recognized certain 

developing countries as particularly vulnerable to those impacts.

The Framework Convention website defines adaptation as adjustments in 

ecological, social, or economic systems in response to actual or expected 

 3

The five other gases are methane, nitrous oxide, and three synthetic gases—

hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. 

4

Framework Convention, art. 4.

Background

The Framework 

Convention Provides the 

Primary International 

Forum for Addressing 

Climate Change
Page 4 GAO-13-829 Climate Change

climate change and its effects, to alleviate potential damages or to benefit 

from opportunities associated with climate change.5 For example, an 

adaptation effort might involve assessing vulnerabilities to rising sea 

levels, droughts, or fires, and then planning and executing activities that 

address these vulnerabilities.

One of the key outcomes of the 2009 meeting of the Conference of the 

Parties was the Copenhagen Accord. As part of the accord, the United 

States and other developed countries voluntarily pledged to provide up to 

$30 billion in “new and additional, predictable, and adequate” funding, 

now commonly known as fast-start finance, to help developing countries 

address climate change over the 2010 to 2012 period. According to State 

officials, the fast-start pledge, and the longer-term goal of mobilizing $100 

billion per year from public and private sources by 2020, was critical to 

securing the broader 2009 Copenhagen Accord. State explained that the 

Copenhagen Accord included a commitment from major emerging 

economies to list, for the first time, the specific actions they would take to 

limit their emissions. Under this Accord, developed countries also agreed 

to a balanced allocation of resources between climate change mitigation 

and adaptation activities, with adaptation funding as a priority for 

countries most vulnerable to climate change impacts.6

In subsequent meetings of the Conference of the Parties, developed 

countries reaffirmed various Copenhagen climate finance commitments. 

At the Cancun meeting in 2010, the Conference of the Parties invited 

developed countries to submit information on their climate finance for the 

2010 to 2012 FSF period to the secretariat of the Framework Convention 

for compilation into an information document. These reports during the 

FSF period were voluntary and were not based on specific reporting 

In addition, the 

Conference of the Parties established the Green Climate Fund, intended 

to centrally channel multilateral funding for climate finance. According to 

State and Treasury officials, as of July 2013, the design and structure of 

this institution was still under development, and the Fund was not yet 

operational.

 5

United Nations Framework Convention on Climate Change, “The Adaptation Process,”

FOCUS: Adaptation, accessed September 16, 2013, 

http://unfccc.int/focus/adaptation/items/6999.php.

6

Under the Copenhagen Accord, priority countries for adaptation finance include least 

developed countries, small island developing states, and Africa. Copenhagen Accord ¶ 8.

Developed Countries Made 

Voluntary Climate Finance 

Commitments through the 

Framework Convention
Page 5 GAO-13-829 Climate Change

requirements. At the 2011 meeting in Durban, the Conference of the 

Parties agreed to adopt reporting requirements and guidelines as part of 

required reports beginning in 2014. At the meeting in Durban, the 

Conference of the Parties also agreed that developed countries should

• describe how their financial assistance addresses the needs of 

developing countries regarding adaptation and mitigation;

• provide information on the financial assistance they provided, 

committed, and/or pledged to help developing parties mitigate 

greenhouse gas emissions or adapt to adverse effects of climate 

change and any economic and social consequences of response 

measures;

• describe the amount, type, funding source, financial instrument, and 

sector of their financial assistance, and indicate how they classified 

funding as new and additional; and

• report on their efforts to leverage private financial sources.

The Durban agreement also included provisions for developed countries 

to further develop plans for long-term climate finance beginning in 2012.

Following the FSF commitment, the United States elevated global climate 

change as a development priority through government-wide strategies. 

First, in May 2010, the White House issued the President’s National 

Security Strategy, which emphasizes, among other things, the need to 

increase investments to address global climate change to improve the 

resilience of developing nations, minimize the impacts of climate change, 

conserve forests, and promote clean energy technologies. Then, in 

September 2010, the White House announced the Global Climate 

Change Initiative (GCCI), which seeks to integrate climate change 

considerations into foreign assistance.7

 7

Following the GCCI announcement, the White House released in October 2010 a 

strategy document on reducing emissions from deforestation and forest degradation. This 

strategy outlines the U.S. approach for increasing carbon sequestration by forests in 

developing countries. In November 2010, State and USAID initiated the U.S. Government 

Enhancing Capacity for Low Emission Development Strategies program, an interagency 

effort to support developing countries’ efforts to increase sustainable development while 

slowing the growth of emissions.

According to State officials, the 

The United States Elevated 

Climate Change as a

Development Priority
Page 6 GAO-13-829 Climate Change

administration began placing a priority on assistance to address climate 

change in its fiscal year 2010 budget request, which reflected a significant 

increase over baseline funding levels. Beginning in fiscal year 2010, 

State, USAID, and Treasury began receiving annual appropriations that 

were used to finance a wide range of bilateral and multilateral programs 

and activities under the GCCI. The GCCI focuses U.S. efforts to address 

global climate change within three pillars, or areas of focus—adaptation, 

clean energy, and sustainable landscapes. Specifically, State describes 

activities within each of these pillars as follows:

• Adaptation activities increase resilience to climate change for the 

most vulnerable communities in areas such as food security, water 

management, coastal management, and public health by helping 

communities respond to increasing climate and weather-related risks.

• Clean energy activities support decreasing emissions growth through 

mitigation activities such as the deployment of clean energy 

technologies, policies, and practices. They often include support for 

infrastructure projects. According to State, the United States’ clean 

energy activities focus on countries and sectors offering significant 

emission growth reduction potential over the long term, as well as 

countries that offer the potential to demonstrate leadership in 

sustained, large-scale deployment of clean energy.

• Sustainable landscapes activities focus largely on helping countries 

address unsustainable forest clearing and support the sustainable 

management of forests at the national and local levels. The United 

States’ sustainable landscape efforts focus on developing countries 

such as Indonesia and Mexico that have demonstrated a commitment 

to address climate change and have a high potential to reduce 

emissions from deforestation, forest degradation, and other land-use 

activities.

The Framework Convention and the GCCI have similar areas of focus, 

although two of the U.S. GCCI pillars—sustainable landscapes and clean 

energy activities—involve activities defined as mitigation activities under 

the Framework Convention (see fig. 1).
Page 7 GAO-13-829 Climate Change

Figure 1: Comparison of Areas of Focus within UN Framework Convention and U.S. 

Global Climate Change Initiative Pillars

To implement its FSF commitment, State reported that, from fiscal year 

2010 through 2012, the United States contributed $7.5 billion to support a 

variety of activities that address the causes and impacts of climate 

change. U.S. FSF funding included activities that were part of the GCCI 

and were designed to address climate change as a primary goal, as well 

as activities that were not part of the GCCI, but were reported to have 

climate-related benefits. U.S. FSF funding included a variety of financial 

instruments, such as grants, loans, loan guarantees,8 and export credit 

insurance.9 The majority of the U.S. FSF funds supported mitigation 

activities focused on clean energy or sustainable landscapes. According 

to State officials, all U.S. FSF funding was considered to be “new and 

additional” resources because the funding was appropriated on an annual 

basis. State, USAID, and Treasury financed activities with a primary goal 

of addressing climate change, as part of the GCCI, which represented 

about one-third of total U.S. FSF funding.10

 8

Loan guarantees cover the repayment risks on the foreign borrower’s debt obligations, 

guaranteeing a lender that, in the event of a payment default by the borrower, the agency 

will pay the outstanding principal and interest.

USAID and agencies such as 

MCC, Ex-Im, and OPIC, provided funding for activities that they reported

as having climate-related benefits but were not funded as part of the 

GCCI. This funding represented about two-thirds of total U.S. FSF 

9

Export credit insurance helps U.S. exporters sell their goods overseas by protecting them 

against the risk of foreign buyer or other foreign debtor default for political or commercial 

reasons, allowing them to extend credit to their international customers for short-term or 

medium-term sales. 

10According to State, 98.7 percent of federal funds that supported activities as part of the 

GCCI activities counted toward the U.S. FSF commitment

State Reported That 

the United States 

Contributed $7.5 

Billion to FSF, 

Supporting a Variety 

of Activities
Page 8 GAO-13-829 Climate Change

funding. These non-GCCI activities may have primary goals other than 

addressing climate change, such as poverty reduction and food security, 

but they were reported to have climate-related benefits.

State reported that 17 U.S. agencies contributed a total of $7.5 billion to 

FSF in fiscal years 2010 to 2012, largely for activities with mitigation 

benefits.11 Six of the 17 agencies—State, USAID, Treasury, MCC, Ex-Im, 

and OPIC—provided about 97 percent of the total $7.5 billion in U.S. FSF 

funding, according to State documents. Figure 2 shows the breakdown of 

total U.S. FSF funding by key agency.

 11The 17 agencies were State; USAID; Treasury; MCC; Ex-Im; OPIC; the Departments of 

Commerce, Defense, and Energy; the Environmental Protection Agency (EPA); National 

Aeronautics and Space Administration; National Oceanic and Atmospheric Administration; 

National Science Foundation; U.S. Army Corps of Engineers; U.S. Forest Service; U.S. 

Trade and Development Agency; and the Peace Corps.

State Reported That 

Multiple U.S. Agencies 

Contributed $7.5 Billion 

over the FSF Period, 

Largely for Mitigation 

Activities
Page 9 GAO-13-829 Climate Change

Figure 2: Total U.S. Fast-Start Finance (FSF) Funding by Agency, Fiscal Years 2010-

2012 (dollars in millions)

About 80 percent ($6.1 billion) of the total U.S. FSF funding supported 

mitigation activities and the remaining 20 percent ($1.4 billion) supported 

adaptation activities. While developed countries agreed to provide a 

“balanced allocation for adaptation and mitigation,” the Copenhagen 

Accord did not define the meaning of a “balanced allocation.”12

 12During the FSF period, Australia reported contributing its FSF funds roughly equally 

between adaptation and mitigation activities. Many other countries reported contributing 

more toward mitigation than adaptation activities.

State 

officials told us that in the absence of such a definition, State’s approach 

to the U.S. FSF commitment was to focus on those activities that were 

most cost effective and had the greatest near-term impact, and that these 

tended to be mitigation activities. State officials also said that the United 

States planned to develop and expand adaptation activities in the future. 
Page 10 GAO-13-829 Climate Change

Figure 3 shows U.S. FSF funding for adaptation and mitigation activities 

in each of the three FSF years, as reported by State. According to State’s 

FSF report, U.S. funding for mitigation activities was provided in the form 

of grants, loans, loan guarantees, or insurance assistance, whereas U.S. 

funding for adaptation activities was provided solely in the form of grants.

Figure 3: U.S. Fast-Start Finance (FSF) Funding by Adaptation and Mitigation 

Activities, Fiscal Years 2010 through 2012 (dollars in millions)

Note: State’s 2012 FSF report includes climate finance data from fiscal years 2010-2012.

While developed countries pledged to provide “new and additional 

resources,” the Copenhagen Accord did not define this term or specify the 

level of funding that each nation would provide to reach the overall target. 

State officials said that the United States defined “new and additional 

resources” as any funding appropriated for activities addressing climate 

change in a given year because appropriations are enacted each year 

and therefore are not guaranteed in future years. Hence, under State’s 

definition, all funding allocated from an appropriation in a given year is 

considered “new and additional” even if the activities had been funded in 

prior years. For example, as part of U.S. FSF funding, State included a 

total of $107.8 million from State and the Environmental Protection 

Agency (EPA) for the Multilateral Fund for the Implementation of the 
Page 11 GAO-13-829 Climate Change

Montreal Protocol, which was established in 1990. According to UN 

officials, the definition of “new and additional” varies by country and only a 

few countries have publicly stated their definition. For example, Germany 

defined “new and additional” as funds that were “additional to the support 

related to addressing climate change already provided in 2009, as well as 

sourced from innovative financing mechanisms, namely the auctioning of 

emissions certificates.”13

State officials said that the United States increased its funding to address 

climate change after the FSF commitment. Before the commitment, State 

collected data from State, USAID, and Treasury on activities with a 

primary goal of addressing the causes and impacts of climate change, 

and State reported that funding for these activities tripled from 2009 to 

2010. During the 2010 to 2012 FSF period, State continued to collect data 

on such activities and categorized them as part of the GCCI. State also 

began to collect data on other activities from USAID and from additional 

agencies, including Ex-Im and OPIC, which were reported as having 

climate-related benefits but were not funded as part of the GCCI. For this 

report, we define the latter type of activity as “non-GCCI activities.” These 

activities may not have a primary goal of addressing climate change. For 

example, the development and distribution of drought-resistant seeds as 

part of a USAID food security project is intended to decrease the 

vulnerability of farmers in food-insecure areas. It also can be considered 

as a non-GCCI climate adaptation activity because it helps communities 

respond to increasing climate risks.

GCCI activities implemented by State, USAID, and Treasury with a 

primary goal of addressing global climate change represented about onethird of U.S. FSF funding. State reported that these three agencies 

provided about $2.5 billion for these activities from appropriations enacted 

for foreign operations over the FSF period. These agencies are the core 

implementers of the GCCI and addressing global climate change is a part 

of each of these agencies’ overall strategies. Table 1 shows the agencies’

funding for GCCI activities with a primary goal of addressing climate 

change, funding for non-GCCI activities, and total contributions to U.S. 

FSF funding.

 13Generally, emissions certificates are tradable permits in a cap-and-trade program, in 

which an overall emissions cap is set. Entities covered by the program must hold these 

certificates to cover their emissions.

GCCI Activities, with a 

Primary Goal of 

Addressing Climate 

Change, Represented OneThird of Total U.S. FSF 

Funding
Page 12 GAO-13-829 Climate Change

Table 1: Funding for Global Climate Change Initiative (GCCI) Activities, Non-GCCI 

Activities, and Total U.S. Fast-Start Finance (FSF) Funding by Agency, Fiscal Years 

2010-2012 (dollars in millions)

Agency

Funding for GCCI 

activities

Funding for non-GCCI 

activities Total FSF funding

State $455 $1 $456

USAIDa $1,022 $1,201 $2,223

Treasury $1,112 $0 $1,112

MCCb $0 $702 $702

Ex-Imc $0 $749 $749

OPICd $0 $1,991 $1,991

Othere $0 $224 $224

Total 2,589 4,868 7,457

Source: GAO analysis of State data.

Notes:

a

U.S. Agency for International Development (USAID).

b

Millennium Challenge Corporation (MCC).

c

Export-Import Bank (Ex-Im).

d

Overseas Private Investment Corporation (OPIC).

e

“Other” represents the remaining 11 agencies that have contributed to FSF.

Over the 2010 to 2012 FSF period, State contributed $455 million in funds 

to developing countries to support activities with a primary goal of 

addressing global climate change as part of the GCCI. State finances 

bilateral and multilateral activities in partnership with other U.S. agencies 

and multilateral funds. For example, State provided bilateral funding for 

the U.S. Africa Clean Energy Finance initiative with a goal of mobilizing 

U.S. investments in clean energy and energy efficiency across Africa. 

State also contributed toward the Least Developed Countries Fund, a 

multilateral fund supporting urgent adaptation needs of least developed 

countries. In Ethiopia, for example, the Least Developed Countries Fund 

helped design and implement adaptation activities, such as planting fruit 

trees to provide additional food sources and to reforest the land, to 

reduce vulnerability to the effects of climate change.

State and USAID Contributed 

U.S. FSF Funding through 

Bilateral and Multilateral 

Assistance
Page 13 GAO-13-829 Climate Change

Over the FSF period, USAID contributed over $1 billion in the form of 

grants to developing countries for GCCI activities that counted toward 

U.S. FSF. For example, USAID’s activities that address climate change in 

Mexico include mitigation projects supporting the development of the 

country’s low emissions development strategy, the planning and 

development of a strategy to reduce emissions from deforestation and 

degradation, and the development of systems to monitor progress against 

the strategies’ goals. For instance, USAID is working with the U.S. Forest 

Service to improve Mexico’s capacity for monitoring, reporting, and 

verification of carbon stored in forests (see sidebar). Starting in fiscal year 

2010, USAID reported increased funding for activities designed to 

promote adaptation and increased funding for mitigation activities to a 

lesser extent. Toward the end of the FSF period, USAID released its 5-

year Climate Change and Development Strategy, intended to strengthen 

the integration of climate change into USAID programming and accelerate 

the implementation of activities that focus on adaptation and low 

emissions development.14

 14State and USAID officials commented that with the inclusion of an integration objective, 

the Strategy made it USAID policy to incorporate climate change risks and mitigation 

opportunities into the broader portfolio of USAID programming, in particular into USAID 

missions’ Country Development and Coordination strategies. 

USAID and U.S. Forest Service Carbon 

Flux Tower in Mexico Supported 

Sustainable Landscapes

USAID funding of approximately $1 million, 

through an interagency agreement with the 

U.S. Forest Service, supports carbon 

monitoring sites in Mexican forests. With this 

funding, the U.S. Forest Service supported 

the establishment of two carbon flux towers in 

Mexico, which, according to project 

implementers, provide data on carbon 

concentrations by measuring the net 

exchange of carbon between the atmosphere 

and the forest. These sites are intended to 

provide a carbon monitoring benchmark for 

future sustainable landscape projects. The 

photo below shows a carbon flux tower in 

Hidalgo, Mexico.

Source: GAO.
Page 14 GAO-13-829 Climate Change

State reported that Treasury contributed about $1.1 billion toward U.S. 

FSF funding mostly through contributions to multilateral funds that finance 

activities promoting adaptation, clean energy, and sustainable 

landscapes.15 According to Treasury officials, these multilateral funds 

provide concessional loans and grants through multilateral development 

banks and other international institutions. After the FSF commitment and 

in line with the GCCI, Treasury acknowledged the importance of 

addressing climate change in its strategic plan. Over the FSF period, the 

majority of Treasury funding—about $915 million—supported the 

multilateral Climate Investment Funds (CIF), which involve financing 

instruments to support developing countries’ efforts to mitigate and 

manage the challenges of climate change by providing grants and other 

financing instruments that leverage financing from the private sector, 

multilateral development banks, and other sources.16

State reported that Treasury also contributed about $196 million to two 

other programs, the Global Environment Facility (GEF) and the Tropical 

Forest Conservation Act’s bilateral debt-for-nature program. According to 

Treasury, the GEF is intended to help developing countries address 

biodiversity, climate change, and other environmental problems.

For example, one

investment fund—the Clean Technology Fund—provided a loan for a 

private-sector clean energy wind farm in Mexico. Another financing 

instrument—the Forest Investment Program—will be used to provide 

loans and grants to the government of Indonesia to develop activities to 

reduce deforestation and forest degradation and promote forest 

management.

17

 15State officials noted that neither the United States nor any other country considers 

contributions to the general resources of the World Bank or other multilateral development 

banks as part of the FSF contribution.

In East 

Africa, for example, the GEF supported sustainable transportation 

16The CIF consist of the Clean Technology Fund and the Strategic Climate Fund, which 

are implemented through the multilateral development banks. The Clean Technology 

Fund seeks to provide developing and middle income countries with incentives to scale up 

technologies with a high potential for long-term greenhouse gas emissions savings. The 

Strategic Climate Fund supports programs to promote sustainable forest management, 

integrate climate resilience into development, and scale up renewable energy solutions in 

the world’s poorest countries.

17The GEF, established in October 1991 to promote global environmental protection and 

environmentally sustainable development, is an institution that serves as a financial 

mechanism for the Framework Convention and several other international conventions. 

Since 1994, the World Bank has served as the Trustee of the GEF Trust Fund and 

provided administrative services.

Treasury FSF Contributions 

Largely Supported Multilateral 

Clean Energy Activities
Page 15 GAO-13-829 Climate Change

solutions. State included about 50 percent (about $148 million) of 

Treasury’s contribution to the GEF as part of FSF. Treasury officials 

stated that 26 percent of the trust fund’s projects support clean energy 

and 24 percent focus on sustainable land use, while the remaining 50 

percent do not focus on addressing climate change and are not included 

as FSF. State also included as FSF funding all of Treasury’s 

contributions, about $48 million, to the Tropical Forest Conservation Act’s 

bilateral debt-for-nature program. Under this program, the United States 

“redirects” debt payments that would have been due to the U.S. 

government into forest conservation funds in the beneficiary country. 

These funds make grants, mainly to local nongovernmental organizations 

and community groups, to support forest conservation activities.18

Over the 2010 to 2012 FSF period, non-GCCI activities with reported 

climate-related benefits, implemented by multiple agencies, represented 

about two-thirds of U.S. FSF funding. According to U.S. agency officials, 

these activities were counted toward the U.S. FSF commitment but were 

not necessarily funded as a result of the commitment. State reported that 

16 agencies provided about $4.9 billion that was counted toward FSF 

through these non-GCCI activities. Four agencies—USAID, MCC, Ex-Im, 

and OPIC—provided the majority of this funding, representing almost 

$4.6 billion of the reported U.S. FSF total contributions (see table 1 

above).19 These four agencies used different mechanisms to finance nonGCCI activities, with USAID and MCC providing grants, Ex-Im providing 

export credit,20 and OPIC providing development finance.21

 18These local programs are governed by boards that include representatives from local 

environmental groups and institutions, the U.S. government, and the beneficiary 

government. 

Over the FSF 

period, total U.S. funding for non-GCCI activities varied from about $1.1 

billion in fiscal year 2010 to $2.4 billion in 2011, to $1.4 billion in fiscal 

year 2012.

19The other 12 agencies provided a total of $225 million that was counted toward the FSF 

contribution for activities that have climate-related benefits. 

20Ex-Im serves as the official export credit agency of the United States and helps U.S. 

firms export goods and services by providing a range of financial products, including direct 

loans, loan guarantees, and insurance.

21OPIC provides development finance through financing, loan guarantees, political risk 

insurance, and support for private equity investment funds.

Non-GCCI Activities 

Represented about

Two-Thirds of U.S. 

FSF Funding
Page 16 GAO-13-829 Climate Change

USAID provided $1.2 billion in grants for activities that primarily supported 

development needs such as food security and global health but were also 

reported to have climate-related benefits. These non-GCCI activities also 

may be counted toward other government goals and initiatives. For 

example, USAID supports climate change adaptation activities in 

Ethiopia, which USAID implemented as part of its food security program. 

As part of the President’s Feed the Future initiative, the USAID mission in 

Ethiopia initiated a multiyear food security project that promotes 

increasing agricultural growth capacity in several chronically foodinsecure areas of the country and also incorporates adaptation activities 

such as introducing drought-resistant crops. According to State and 

USAID in Ethiopia, these activities also have reported climate-related 

benefits because they reduce vulnerability to climate change. The USAID 

Ethiopia mission also supported other activities that had reported climate 

change adaptation benefits—such as land rehabilitation and construction 

of irrigation structures—as part of its contribution to the Productive Safety 

Net Program that the government of Ethiopia launched in 2005 to address 

chronic food insecurity (see sidebar).

In the FSF reports, State included $702 million in grants from MCC for 

non-GCCI activities because parts of MCC’s compact grants are reported 

to support activities with climate-related benefits in five developing 

countries. Four of the five compacts were signed during the FSF period, 

and one was signed prior to the commitment.22 23 For example, MCC 

signed a compact with the government of Indonesia for a total of $588 

million of which $332 million supported a project (known as the Green 

Prosperity Project) intended to increase renewable energy and 

sustainable land use practices, and strengthen the capacity for low 

carbon development. In another example, MCC signed a compact with 

the government of Moldova in which, in conjunction with its investment in 

 22State officials explained that they counted the Mongolia Compact as part of the U.S. 

FSF contribution even though it was signed in 2008, because it was amended during the 

FSF period. The compact’s amendment added a new project specifically relating to 

reducing urban air pollution by aiding the adoption of more energy efficient technologies. 

23MCC officials commented that MCC generally reported all relevant FSF funding for 

compacts based on the year the compact was signed. However, only a small portion of 

the compact amount is obligated at signing, and the balance of the MCC funding is 

obligated at entry into force. 

USAID and MCC Provided 

Grants to Fund Non-GCCI 

Activities with Climate-Related 

Benefits

USAID Dam Project in Ethiopia Supported 

Adaptation to Climate Change 

As part of USAID’s efforts to improve food 

security to rural communities in Ethiopia that

experience increasingly frequent droughts, 

USAID funds dam construction to help collect 

silt and store rainwater. The dam below was

built in partnership with USAID. According to 

project implementers, the dam collects

rainwater as it flows down the valley, which 

reduces erosion and replenishes moisture in 

the soil while retaining rainwater for future 

use.

Source: GAO.
Page 17 GAO-13-829 Climate Change

the rehabilitation of several large irrigation systems, MCC is funding a $2 

million river basin management program to improve Moldova’s capacity to 

manage its limited water resources in light of increasing demand for water 

and the expected effect of climate change. MCC’s goal is to reduce 

poverty by addressing the partner countries’ priorities for achieving 

sustainable economic growth, which may involve addressing climate 

change impacts. According to MCC officials, the agency has no specific 

goals or objectives related to climate change, but its agreements can link

poverty reduction and development with climate-related goals when a 

country’s priorities involve climate change concerns.

According to State’s 2012 FSF report, Ex-Im provided about $750 million 

through a range of financial products—such as direct loans, loan 

guarantees, and insurance—that supported non-GCCI clean energy 

activities. For Ex-Im’s financial products, State counted the nominal value 

of Ex-Im’s commitments made to eligible projects during the 2010 to 2012 

FSF period. For example, Ex-Im provided nearly $200,000 in insurance to 

a solar power-generating system in Mexico; State included this entire 

liability amount toward the FSF total. According to Ex-Im officials, Ex-Im’s 

export finance that supports clean energy projects is part of its larger 

mission to help U.S. firms export goods. Ex-Im has a carbon policy that 

aims to increase the private sector incentives and demand for renewable 

energy exports. This followed a congressional directive that at least 10 

percent of Ex-Im’s annual authorizations should be used for renewable 

energy technologies or energy efficient end-use technologies.24 According 

to Ex-Im officials, the agency has struggled to meet this target because of 

the market-driven nature of its work and because it can only fund 

activities with a reasonable expectation of repayment. On the basis of our 

prior work, we found that Ex-Im faces challenges in achieving its target 

but has increased its clean energy financing since the FSF commitment.25

State reported that during the 2010 to 2012 FSF period, OPIC provided 

about $2 billion for development finance that supported non-GCCI 

activities through a range of financial products such as loans, loan 

(See the sidebar for an example of an Ex-Im financed clean energy 

project.)

 24See Omnibus Appropriations Act, 2009, Pub. L. No. 111-8, 123 Stat. 524, 858.

25GAO, Export-Import Bank: Additional Analysis and Information Could Better Inform 

Congress on Exposure, Risk, and Resources, GAO-13-620 (Washington, D.C.: May 30, 

2013).

Ex-Im Provided Export 

Finance and OPIC Provided 

Development Finance for 

Non-GCCI Activities

Ex-Im Financed a Wind Farm in Mexico

That Supported Clean Energy as a ClimateRelated Benefit

Ex-Im provided a loan for exporting U.S. 

manufactured wind turbines to a wind farm in 

Oaxaca, Mexico, pictured below. This wind 

farm harnesses wind energy and connects to 

Mexico’s national grid. It is the same wind 

farm that also received a loan from the Clean 

Technology Fund, to which Treasury provided 

funds.

Source: GAO.
Page 18 GAO-13-829 Climate Change

guaranties, and insurance. In general, OPIC provides development 

finance for clean energy projects as part of its larger mission to support 

U.S. private investment in emerging markets. As with Ex-Im, State 

counted the nominal value of OPIC’s commitments to eligible projects 

during the fast-start period. For example, OPIC provided an investment 

guarantee of $20.3 million for the construction of two hydroelectric 

facilities in Mexico; State included the value of that loan toward the U.S. 

FSF funding total. OPIC also has an Environmental and Social Policy 

Statement that responds to a congressional requirement to reduce direct 

greenhouse gas emissions associated with projects in OPIC’s portfolio by 

30 percent over 10 years.26 According to State, OPIC financing with 

climate-related benefits has increased substantially, from about $8.9 

million in 2008 to an average of $663.8 million annually during the FSF 

period.

State improved its method for collecting data for its FSF reports, but it is 

uncertain how it will meet future reporting requirements and guidelines 

agreed to under the Framework Convention. After the FSF commitment, 

State faced a new and difficult challenge in collecting and reporting on 

U.S. assistance to developing countries to address climate change. 

Following its initial FSF report in fiscal year 2010, State developed a 

structured data collection tool to facilitate and standardize data collection 

across the agencies. Even with the data collection tool, challenges for 

tracking assistance remain. State and USAID do not have a dedicated 

budget code for tracking climate change assistance. With USAID climate 

change funding allocated to numerous missions, USAID, the largest FSF 

contributor, is unable to track GCCI obligations and expenditures and 

must undertake a manual inventory to obtain information on the types of 

climate change programs its missions are undertaking. While the current 

FSF report submissions are voluntary, reporting is required beginning in 

2014 based on decisions adopted by the Conference of the Parties.27

Future reports must contain certain data elements on each country’s 

climate finance contributions that State did not include in the FSF reports 

and, in some cases, does not currently collect. State officials stated that 

they have not determined how they will collect and report this information.

 2622 U.S.C. § 2191b.

27See U.N. Doc. FCCC/CP/2011/9/Add.1, decision 2/CP.17, ¶¶ 12-5 (Dec. 11, 2011). 

State Improved Its 

Data Collection over 

the FSF Reporting 

Period, but Has Not 

Determined How It 

Will Meet Future 

Reporting 

Requirements and 

Guidelines
Page 19 GAO-13-829 Climate Change

Following the December 2009 FSF commitment, State faced challenges 

collecting data on agencies’ FSF contributions but improved its data 

collection process during the 2010 to 2012 FSF period. Specifically, State 

faced challenges collecting data on fiscal year 2010 contributions from 

agencies for the initial FSF report but in fiscal year 2011 established a 

data collection tool in collaboration with the Office of Management and 

Budget (OMB) and developed a database for tracking FSF information. 

According to State officials, State’s method for collecting and reporting 

FSF data in fiscal year 2010 was less structured than in the following 2 

years because the United States decided to prepare the FSF report 

partway through that fiscal year and State did not have time to develop a 

structured data collection tool.

For fiscal year 2010, State gathered information on its own FSF activities 

and those of USAID as part of State and USAID’s broader annual process 

to develop internal operational plans.28

For fiscal years 2011 and 2012, State established a structured data 

collection tool and developed guidance in collaboration with OMB to 

facilitate and standardize data collection for the 15 agencies other than 

State and USAID. This guidance included criteria that agencies could use 

to determine if an activity should count toward FSF. For those years, 

State collected data on its own FSF activities and those of USAID through 

the process to develop internal operational plans, as it had for the 2010 

report, and asked OMB for assistance in collecting FSF data from the 

remaining agencies.

State and USAID’s guidance on 

compiling these operational plans included definitions of activities with 

addressing climate change as a primary goal and activities with climaterelated benefits, along with a list of eligible FSF activities under each of 

the three GCCI pillars. State did not, however, have an existing process 

to collect these data from other agencies that contributed to FSF. State 

officials said they reached out to individual agencies to obtain information 

on funding level, administering agency, and intended climate change 

benefits of each FSF activity. However, these officials stated that they 

faced challenges in obtaining FSF data from agencies other than State 

and USAID for the 2010 report.

29

 28The operational plans contained 1-year implementation plans and budget information for 

each country’s State and USAID mission office and included data on climate change 

funding and activities, which State used for the FSF reports.

State then worked with OMB to develop the data 

29OMB did not assist State in collecting FSF data for fiscal year 2010 but did review the 

budget information that State collected, according to officials from both agencies.

State Improved Its Data 

Collection Process for the 

2011 and 2012 Reports
Page 20 GAO-13-829 Climate Change

collection tool for collecting FSF data from those agencies. According to 

State officials, OMB’s participation in the data collection effort improved 

the FSF data obtained from other agencies for the 2011 and 2012 

reports. The tool consisted of a template for requesting data such as the 

name of the relevant activity, funding level, recipient country, and 

narrative description. State and OMB developed guidance to accompany 

the tool, which officials from both agencies said included a modified 

version of the guidance used by State and USAID to develop their 

operational plans and an adapted list of eligible FSF activities.30

State did not create a database to compile the FSF submissions for the 

2010 report but developed one for the 2011 and 2012 reports. In fiscal 

year 2010, State compiled the FSF data in a narrative document that 

became the 2010 FSF report. By fiscal year 2011, State had developed a 

database for FSF submissions that included aggregated funding data at 

the country, pillar, and agency level but did not include funding data at the 

individual activity level. In fiscal year 2012, State improved the database

by tracking the funding data at the individual activity level.

State officials said that for each of the 3 years, they went through an 

extensive review process to determine whether data included in the 

agencies’ submissions should count toward the reported FSF total. These 

officials stated that a small group of State staff reviewed and discussed 

the submissions, using their judgment to determine if they should qualify 

for FSF. In some cases, the review process involved follow-up 

discussions with agency officials. State officials said that the review 

process for each of the three FSF reports took approximately 3 months.

While State has improved its process for collecting FSF data with these 

changes, some challenges remain in tracking USAID’s climate finance 

data. According to USAID officials, State and USAID currently do not 

have a dedicated budget code for assistance that addresses climate 

change, which has created difficulties for tracking and gathering USAID 

data on such funding. USAID’s budget and accounting systems link to 

State and USAID’s standardized program structure for foreign assistance, 

 30State and OMB officials said that they adapted the list of eligible FSF activities so that 

the activities on the revised list would align more closely with those implemented by 

agencies other than State and USAID.

State and USAID Do Not 

Have a Dedicated Budget 

Code for Tracking 

Assistance to Address 

Climate Change
Page 21 GAO-13-829 Climate Change

which is sometimes referred to as the foreign assistance framework.31

Table 2: Placement of Climate Change as a Sub-Element in State and USAID’s 

Foreign Assistance Framework

This structure establishes a hierarchy of strategic objectives, program 

areas, program elements, and sub-elements. USAID officials stated that 

USAID’s financial managers currently code obligations down to the 

program element level but not the sub-element level. Therefore, USAID 

does not have obligation data for assistance that addresses climate 

change because climate change is currently a sub-element. Specifically, 

climate change is one of eight sub-elements under the Clean Productive 

Environment program element (see table 2).

Strategic Objective 4: Economic Growth

Program Area 4.8: Environment

Program Element 4.8.1 Natural Resources and Biodiversity

Program Element 4.8.2 Clean Productive Environment

Sub-Element 4.8.2.1 Clean Productive Environment Policy and Guidance

Sub-Element 4.8.2.2 Clean Production

Sub-Element 4.8.2.3 Clean Energy

Sub-Element 4.8.2.4 Climate Change

Sub-Element 4.8.2.5 Air Quality

Sub-Element 4.8.2.6 Sound Management of Waste

Sub-Element 4.8.2.7 Toxic Substances 

Sub-Element 4.8.2.8 Science and Technology as a Tool for Environmental 

Decision-Making

Source: State.

The absence of a dedicated budget code has implications for tracking 

climate change assistance. According to USAID officials, to track climate 

change programs below the level of which GCCI pillar they are in 

(adaptation, clean energy, or sustainable landscapes), USAID has to 

manually gather climate change funding data through a time-consuming 

 31The standardized program structure was jointly developed by State and USAID to 

establish a consistent way to categorize and account for foreign assistance managed by 

State and USAID. This structure includes five strategic objectives of U.S. foreign 

assistance—Peace and Security, Governing Justly and Democratically, Investing in 

People, Economic Growth, and Humanitarian Assistance—and defines the full set of 

program areas and associated activities that fall under these strategic objectives and 

establishes standard indicators for measuring performance.
Page 22 GAO-13-829 Climate Change

inventory of the numerous USAID missions’ climate change programs. 

USAID’s accounting database tracks the program element code 4.8.2 

(Clean Productive Environment), but this code also encompasses funding 

other than climate change funding. In addition, not all climate change 

funding may appear under the Climate Change sub-element 4.8.2.4. 

Funds that support activities that address climate change may also 

appear under other program element codes, such as natural resources 

and biodiversity. These officials stated that elevating climate change to a 

higher-level program area within the standardized program structure 

would provide several benefits, including enabling them to better track the 

agency’s activities that address climate change and related funding. This 

could also enhance the efficiency of efforts to track U.S. assistance that 

addresses climate change, which is a long-term priority of the 

administration and an integral component of U.S. commitments made 

through the Framework Convention.

The foreign assistance standardized program structure also serves as the 

foundation for State and USAID’s budget requests, annual operational 

plans, and performance reporting. The continuing categorization of 

climate change as a sub-element rather than as a program area does not 

appear to reflect State and USAID’s actions emphasizing climate change 

as a high priority. For example, State and USAID have included climate 

change as one of eight outcome-focused agency priority goals that reflect 

the highest priorities of both the Secretary of State and the USAID 

Administrator. According to State and USAID, these near-term goals 

advance the agencies’ joint strategic goals and reflect their strategic and 

budget priorities.

State and USAID officials said that State’s Foreign Assistance Bureau is 

leading a broader review of the foreign assistance standardized program 

structure, but State officials did not provide us with a time frame for 

completing this review. These officials stated that any changes to the 

standardized program structure would have implications for consistency 

with prior years. In addition, changing the placement of climate change 

within the structure would also affect the categorization of other 

environmental programs, and these considerations must be thought 

through carefully before making any changes.
Page 23 GAO-13-829 Climate Change

State voluntarily issued three annual FSF reports that included summary 

discussions of the U.S. funding totals and more detailed country fact 

sheets with descriptions of activities; however, the reports did not include 

a full list of all FSF activities and their funding levels or information on the 

disbursement status of FSF activities. State officials said that the FSF 

reports were intended for the diplomatic objective of demonstrating U.S. 

progress in meeting its fast-start commitment. State officials said that they 

shared the country fact sheets with some developing countries at 

conferences and negotiations and that this met their diplomatic objective 

of demonstrating to developing countries that the United States was 

providing adequate climate finance and meeting its commitment.

Regarding the reports’ content, each report included fact sheets on some 

of the countries that received funding for that fiscal year. However, the 

fact sheets, as noted in the 2012 FSF report, did not capture information 

on some sensitive activities. The country fact sheets provided high-level 

information on total bilateral and multilateral development finance and 

export credit contributions, and narrative descriptions of some FSF 

activities that included the funding level, administering agency, target 

beneficiaries, and intended climate change benefits of each reported 

activity. For example, the 2011 Mexico fact sheet noted that USAID 

provided $7 million to support the Government of Mexico in completing 

and implementing its national strategy to reduce greenhouse gas 

emissions from deforestation, focusing on helping the country strengthen 

relevant policy frameworks and build institutional and technical capacity 

that would reduce the rate of deforestation. While the fact sheet provided 

funding information on the aggregate level and provided examples of 

some individual activities, it did not identify all of the activities supported 

by the $7 million under Mexico’s national strategy.

According to State officials, the FSF reports were not intended as a 

financial accounting exercise. Because the FSF reports do not provide a 

full list of all the activities and their funding levels, it was not possible for 

us or other external parties to verify the reported $7.5 billion contribution 

over the FSF period. For fiscal years 2010 and 2011, two 

nongovernmental organizations tried to recreate the reported total and 

were unable to account for the total reported amount.32

 32The two nongovernmental organizations were the World Resources Institute, a policy 

research organization focused on environmental and socioeconomic development issues, 

and Climate Advisors, a consulting firm focused on U.S. climate change policy and 

international climate cooperation. 

One was able to 

The FSF Reports 

Contained Country Fact 

Sheets with Activity 

Descriptions, but Did Not 

Include All FSF Activities 

and Funding
Page 24 GAO-13-829 Climate Change

account for 91 percent of the total by analyzing publicly available 

information, and the other said that it was difficult to reconcile the 

numbers from the FSF reports with other publicly available budget data.

In addition, the FSF reports also did not include information on the 

disbursement status of FSF activities because State did not request 

disbursement information from other agencies and, instead, it requested 

that agencies report on the amounts either appropriated or obligated, 

which it included in the FSF reports using broad characterizations such as 

“amount provided” or “investments.” At any given time, the amount 

disbursed can vary from the amount appropriated or obligated, and the 

amount in the FSF reports may not have reflected the implementation 

status of the activity.

During our country site visits, we found examples of projects that were 

included in the FSF reports but had not begun implementation. State 

included a $332 million MCC project in Indonesia in the 2011 FSF report, 

but we found that the agreement for that project did not enter into force 

until April 2013 and that MCC had not disbursed project funding as of 

June 2013. In another example, State reported a $50 million OPIC activity 

in the 2011 Indonesia fact sheet but the activity had not begun 

implementation at the time of our January 2013 site visit to Indonesia, and 

an OPIC official said the “future success [of the project] appeared to be 

highly improbable.” OPIC reported that its $50 million commitment to the 

investment fund was canceled on May 14, 2013.

Climate finance reporting requirements and guidelines under the 

Framework Convention have evolved, and State plans to continue 

reporting on U.S. climate finance contributions; however, State has yet to 

determine how it will collect and report on this information in the future. In 

contrast to the current voluntary nature of the FSF report submissions to 

the secretariat of the Framework Convention, reporting will be required 

beginning in 2014 based on decisions adopted by the Conference of the 

Parties in Durban in 2011 and in Doha in 2012.33

 33U.N. Doc. FCCC/CP/2011/9/Add.1, decision 2/CP.17 (Dec. 11, 2011) and UN Doc. 

FCCC/CP/2012/8/Add.3, decision 19/CP.18 (Dec. 8, 2012). 

The Conference of the 

Parties decided that developed countries shall submit their first biennial 

reports to the Framework Convention secretariat in January 2014 and use 

specific reporting guidelines for the biennial reports to ensure that 

Future Climate Finance 

Reporting Will Require 

Information That Was Not 

Included in the FSF 

Reports, and State Has Not 

Determined How it Will 

Address These 

Requirements and 

Guidelines
Page 25 GAO-13-829 Climate Change

countries provided consistent, transparent, comparable, accurate, and 

complete information (see table 3 for a comparison of future reporting 

criteria relative to the information currently collected and provided in the 

FSF reports).34

Table 3: Comparison of the Future Framework Convention Biennial Reporting 

Criteria and State’s Current Data Collection for Climate Finance 

The Conference of the Parties also plans to consider the 

best approach for future reporting on climate-related private finance at the 

next meeting when it discusses the reporting guidelines.

Future reporting criterion

Data collected 

by State?

Included in 

Fast-Start

Finance (FSF) 

reports?

Status (provided, committed, and/or pledged) Noa No

Private financial flows leveraged by bilateral climate 

finance, to the extent possible

Noa Nob

Total amount (funding level) that is climate specific Yes Yes

Funding source (official development assistance, 

other official flows, other)

Yes No

Financial instrument (grant, concessional loan, etc.) Yes Yes

Type of support (mitigation, adaptation, crosscutting)Yes Noc

Sector (energy, transport, etc.) Yes Yes

Additional information (parties should report, 

as appropriate, on project details and the 

implementing agency)

Yes Yes

Explanation of how funds are climate-specific Yes No

Whether financial resources are new and 

additional and how this was determined

Yes No

Source: GAO analysis of State data and information from the United Nations Framework Convention for Climate Change (Framework 

Convention).

Notes: To make the comparison shown in the table, we analyzed the reports of the Conference of the 

Parties to the Framework Convention in Durban (2011) and Doha (2012) and State FSF reports.

 34U.N. Doc. FCCC/CP/2011/9/Add.1, decision 2/CP.17, ¶ 13 and Annex I. In addition to 

the new biennial reports, developed countries will also submit the sixth national 

communication to the Framework Convention secretariat in January 2014. Developed 

countries report to the Framework Convention secretariat through national 

communications and biennial reports with information on the steps the countries are taking 

or plan to take to implement the Framework Convention. Also, at the meeting of the 

Conference of the Parties in Durban in 2011, developed countries decided that in years 

when national communications are submitted, developed countries should submit the 

biennial reports as an annex to the national communications or as a separate report.
Page 26 GAO-13-829 Climate Change

a

State officials said they collect some of this information but not as specified in the new reporting 

guidelines.

b

In the 2012 FSF report, State provided an example of private funds leveraged by OPIC.

c

The 2012 FSF report included aggregate-level but not project-level information.

We identified six biennial reporting criteria that State will be expected to 

report on for climate finance contributions in 2014 but did not report on in 

the FSF reports, including two for which State does not currently collect 

data as fully as required by the Framework Convention’s new reporting 

criteria (see table 3). State officials said that they have not determined 

how they will implement these 2014 reporting requirements and 

guidelines.

State does not currently collect all of the data needed to meet the 

following two criteria.

• The annual status of climate finance contributions provided, 

committed, and/or pledged. Beginning in 2014, developed countries 

will be required to report on the amount of their climate finance 

contributions provided, committed, and/or pledged and should explain 

the methodologies used to specify the funds in each category. State 

officials said that there are no agreed-upon definitions for provided, 

committed, and pledged in the Framework Convention and that 

countries may choose which status to use in filling out the table 

showing the status of their climate finance contributions. State has not 

defined these terms yet and does not collect status data on FSF funds 

according to these categories. State has some status information for 

FSF activities, but according to State officials, has not been collecting 

this information according to the terms in the Framework Convention 

reporting guidelines, as they are new guidelines. 

• Private financial flows leveraged by bilateral climate finance. In 2011, 

the Conference of the Parties met in Durban and decided that 

developed countries should report in their biennial reports, to the 

extent possible, on private financial flows leveraged by bilateral 

climate finance and policies and measures that promote the scaling 

up of private investment in mitigation and adaptation activities in 

developing countries. In April 2013, State and Treasury convened a 

meeting to discuss how international donors could better coordinate to 

use public finance to mobilize private investment in climate-friendly 

infrastructure. However, State officials said that the parties did not 

focus on how they would incorporate private sector sources into future 

reporting on climate finance and that they will continue to work with 

the international community to develop a methodology for collecting 
Page 27 GAO-13-829 Climate Change

the information. Adding information on private sources of financing will 

add a layer of complexity to the already difficult task of reporting on 

public sources of climate finance because, among other things, 

information related to the financing and implementing of private-sector 

projects is often proprietary.

State collects data for the following four elements, but did not include this 

information in the FSF reports.

• The funding source (official development assistance, other official 

flows, or other). State did not provide this information in the FSF 

reports. According to State officials, State does collect this information 

for all agencies.

• Type of support (mitigation, adaptation, cross-cutting). In 2014, 

developed countries will be required to report on the type of support 

provided—mitigation, adaptation, or cross-cutting (those activities that 

support both mitigation and adaptation), and to the extent possible, at 

the country, region, project, or program level. In the fiscal year 2012 

FSF report, State provided only aggregated information on adaptation 

and mitigation contributions.

• An explanation of how each country determined that its funds are 

climate-specific. State had criteria it used to determine which activities 

counted as FSF for its internal reports and provided the criteria to 

agencies to help them determine which activities to include in their 

FSF submissions and which to exclude. Over the 2010 to 2012 FSF 

period, State refined the criteria to provide more guidance on what to 

count as an activity with a primary goal of addressing climate change 

versus what should count as having a climate-related benefit. In the 

2012 FSF report, State provided some information on the 

methodology for counting activities with climate-related benefits and 

some examples of activities under each pillar. However, State did not 

publish the criteria in the FSF reports. State officials said that these 

definitions for future climate finance reporting are still being discussed 

with both the Framework Convention and the Development 

Assistance Committee of the Organisation for Economic Co-operation 

and Development (OECD). State officials also said that they expect to 

be guided, in part, by those discussions, but anticipate the criteria 

they use will be similar to those used for the FSF reports.

• Whether financial resources are new and additional and how this was 

determined. As mentioned earlier, the Framework Convention did not 

define “new and additional resources,” and in developing the FSF 
Page 28 GAO-13-829 Climate Change

reports State counted all funding for activities that address climate 

change in developing countries as “new and additional.” However, 

State did not publicly define “new and additional” in its FSF reports, 

and will be required to do so in the 2014 biennial report.

To meet certain future reporting requirements and guidelines, developed 

countries will also need to provide information, such as total funding level 

and financial instrument, in two tables—one for contributions to 

multilateral funds and one for bilateral and regional contributions—for the 

previous 2 years.35 The information on bilateral and regional contributions 

is to be reported for each recipient country, region, project, or program, to 

the extent possible. State officials said that they are still in the process of 

determining which is the most appropriate category—country, region, 

project, or program—to use for organizing the bilateral table. However, it 

is uncertain how State will meet the requirements to report on the data 

elements, such as status or financial instrument, if it reports at the country 

or region level since the myriad activities in a given country or region may 

involve a variety of financial instruments. State officials also said that they 

are still determining the best use of their existing FSF database for future 

required reporting, so it is currently unclear how State will collect and 

maintain the data needed for the 2014 report.

 35In addition to the climate finance reporting requirements and guidelines for the 

Framework Convention parties, the United States also reports and will continue to report 

funding related to climate change through other venues, primarily the Credit Reporting 

System of the Development Assistance Committee at the OECD, and the Administration’s 

Foreign Assistance Dashboard. A 2012 OMB bulletin provides guidance on reporting to 

the OECD and for the Foreign Assistance Dashboard website as part of the U.S. 

government’s overall effort to make information on foreign assistance programs more 

transparent. The Foreign Assistance Dashboard is a key deliverable of the U.S. 

Government’s Open Government Partnership National Action Plan to promote openness 

and transparency. The Dashboard serves as a tool to visualize foreign assistance data. It 

can be found at http://www.foreignassistance.gov. In addition, the OECD developed a 

marker system in collaboration with the Framework Convention aimed at tracking resource 

flows for climate change activities. The markers, known as Rio Markers, categorize aid 

activities to indicate whether or not an activity targets climate change mitigation or 

adaptation as a principal or significant objective. Reporting with Rio Markers became 

mandatory with the 2007 report to the OECD.
Page 29 GAO-13-829 Climate Change

The overall effectiveness of U.S. FSF activities is difficult to determine 

because of the challenges involved in monitoring and evaluating 

assistance to address climate change. Measuring the effects of individual 

activities within the larger context of global climate change is difficult, and 

many activities are just beginning to be implemented. State, USAID, and 

Treasury fund FSF activities included in the GCCI. As part of this 

initiative, State and USAID are refining performance indicators to improve 

monitoring of the results of their activities that address climate change. 

USAID is also drafting an evaluation plan for its GCCI activities, although 

no evaluations have been completed. Treasury does not directly monitor 

and evaluate its GCCI funding, but requires the multilateral institutions 

that receive and implement this funding to conduct monitoring and 

evaluation. Other agencies, including MCC, Ex-Im, and OPIC funded 

activities that were not part of GCCI, and these agencies take varying 

approaches to monitoring and evaluating these activities based on their 

respective missions and requirements.

Efforts to monitor the outcomes and evaluate the longer-term impact of 

assistance to address climate change involve several key challenges. 

Measuring the effect of U.S.-supported mitigation activities on climate 

change involves estimating what greenhouse gas emissions might have 

been if the assistance had not been provided. Likewise, measuring the 

effect of adaptation activities involves finding ways to estimate what 

climate damages might otherwise have occurred. In addition, because 

U.S. assistance to address climate change encompasses a wide range of 

activities, the appropriate type of monitoring and evaluation depends on 

each activity and its intent. Specific challenges to monitoring and 

evaluating this assistance include the following:

• Assistance intended to address climate change occurs within a larger 

context. In cases where U.S. funded activities are intended to 

decrease emissions, it is difficult to measure their effect on climate 

change when overall emissions and atmospheric carbon dioxide 

levels are increasing. Climate change results from the long-term 

accumulation of greenhouse gases in the atmosphere, and the 

Environmental Protection Agency projects that greenhouse gas 

concentrations will continue to increase in the future unless annual 

emissions decrease substantially. In addition, according to a 2009 

U.S. Global Change Research Program assessment, the atmospheric 

concentrations of carbon dioxide—the primary greenhouse gas—have

Determining 

Effectiveness of FSF 

Activities Poses 

Challenges; State and 

USAID Are Refining 

Their Approach to 

Monitoring and 

Evaluating Activities 

That Address Climate 

Change

Linking Climate Change 

Assistance to Outcomes 

Poses Challenges
Page 30 GAO-13-829 Climate Change

been building up in the Earth’s atmosphere since the beginning of the 

industrial era in the mid-1700s, primarily due to the burning of fossil 

fuels and the clearing of forests.36 As noted by the National Research 

Council in 2012, current carbon dioxide concentrations are nearly 40 

percent higher than preindustrial levels, and, according to ice core 

data, higher than at any point in the past 800,000 years.37

• Monitoring and evaluation of activities under the three GCCI pillars 

involves varying assumptions and uncertainties. For example, for 

projects under the clean energy pillar, USAID and State monitor the 

reductions in greenhouse gas emissions attributable to U.S. 

assistance. However, attributing emissions reductions to a clean 

energy project requires an assumption that the project displaced 

existing or future sources of more carbon-intensive sources of 

electricity, such as that generated by burning fossil fuels. Therefore, 

the results and accuracy of monitoring and evaluation of these 

projects will depend on the validity of the underlying assumptions, 

which may be difficult to determine. It is also difficult to determine 

whether individual forest protection projects under the sustainable 

landscapes pillar materially influence overall emissions from forests if 

the projects do not address the social and economic forces 

contributing to forest degradation or destruction. Deforestation and the 

conversion of forested lands to agriculture in developing countries is a 

major source of greenhouse gas emissions. Efforts to protect or 

enhance forests can lead to the increased absorption of carbon 

dioxide from the atmosphere. However, our prior work has found that 

protecting a forest does not necessarily decrease the demand for the 

timber or conversion of forested land to other uses.38

 36Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate 

Change Impacts in the United States (New York, NY: Cambridge University Press, 2009). 

This document, referred to as the 2009 National Climate Assessment, is in the process of 

being updated, as the Global Change Research Act of 1990 requires that a scientific 

assessment be provided to the President and Congress not less frequently than every 4 

years. See information on the 2013 National Climate Assessment at 

http://www.globalchange.gov/what-we-do/assessment.

Instead, it may 

shift demand to other unprotected forested lands through a process 

37See National Research Council, Climate Change: Evidence, Impacts, and Choices

(Washington, D.C.: 2012). The National Research Council is the operating arm of the 

National Academy of Sciences and National Academy of Engineering.

38GAO, Climate Change Issues: Options for Addressing Challenges to Carbon Offset 

Quality, GAO-11-345 (Washington, D.C.: Feb.15, 2011).
Page 31 GAO-13-829 Climate Change

known as emissions “leakage.”39 In addition, our prior work has

identified challenges in measuring carbon stored by forests due to 

scientific uncertainties and the potential for protected forests to later 

suffer degradation from fire, storms, insect infestation, or future 

changes in land management.40

• Directly linking some activities to climate change outcomes is difficult. 

USAID officials stated that some specific activities intended to 

address climate change, such as training and capacity building, are 

particularly difficult to link directly to climate change outcomes, such 

as reductions in greenhouse gas emissions. For example, some 

USAID projects focus on capacity building to support recipient 

countries’ regulatory or legal reforms and national climate change 

plans, and may not have a direct link to greenhouse gas emissions. 

While these activities may provide important benefits in building local 

capacity, USAID officials acknowledged the challenges in linking 

these types of activities to emissions reductions. In Mexico, for 

example, USAID’s assistance has focused, in part, on supporting 

planning and policy development, including supporting the 

implementation of the country’s recently passed national climate 

change law. USAID officials stated that it was not clear how these 

types of activities will translate into greenhouse gas emissions 

reductions. However, State and USAID officials also emphasized that 

capacity-building efforts can yield important longer-term benefits, even 

if they are difficult to link to short-term outcomes.

• Assistance to address climate change is relatively new, and it is too 

early to assess outcomes. According to U.S. officials, many of the 

U.S. FSF activities have not been completed and, in some cases, are 

just beginning to be implemented. As discussed earlier, during our 

country site visits, we found examples of U.S. FSF projects counted 

toward the fiscal year 2010 or 2011 FSF totals that were only 

beginning implementation. For example, according to MCC officials, 

MCC’s Green Prosperity project in Indonesia just began to be 

implemented after the Compact entered into force in April 2013. While 

 39USAID officials commented that they see U.S. support for countries’ low emissions 

development strategies, which promote national-level greenhouse gas inventories and 

policy reforms, as a response to “leakage.” These officials commented that by monitoring 

greenhouse gas emissions and forest cover nationwide, countries will be able to monitor 

the net effect of all sustainable forest and land use efforts.

40GAO-11-345.
Page 32 GAO-13-829 Climate Change

MCC is developing a monitoring and evaluation plan for this project, it 

is too early to assess its results or impact. Also in Indonesia, USAID’s 

Forest and Climate Support project has been slower to begin 

implementation than originally anticipated, according to project 

officials. Implementing officials said that no project evaluations have 

been completed, although a midterm evaluation was beginning during 

the time of our visit.

State and USAID use a combination of standard and custom indicators to 

monitor U.S. FSF activities that are part of the GCCI and non-GCCI 

activities reported to have climate-related benefits. Following the launch 

of the GCCI in 2010, State and USAID developed a GCCI Indicator 

Handbook to provide guidance for project implementers in monitoring 

activities intended to address climate change, and the agencies have 

continued to revise these indicators to improve measurement of climate 

change activities. The handbook currently contains seven standard 

indicators to monitor the performance of State and USAID’s assistance to 

address climate change, including, according to USAID officials, two 

required outcome indicators. The first outcome indicator measures the 

quantity of greenhouse gas emissions reduced or sequestered as a result 

of the U.S. clean energy and sustainable landscapes projects. The 

second outcome indicator measures the number of stakeholders with 

increased capacity to adapt to the impacts of climate change as a result 

of U.S. adaptation projects. The remaining five indicators track outputs,41

 41Outputs measure the direct products and services delivered by programs or projects; 

outcomes measure the results of those products and services.

such as the number of people receiving training and the number of days 

of technical assistance provided (see table 4).

State and USAID Are 

Refining Indicators to 

Monitor Climate Change 

Activities, and USAID Is 

Developing an Evaluation 

Plan

State and USAID Are Refining 

Their Climate Change 

Indicators
Page 33 GAO-13-829 Climate Change

Table 4: State and USAID’s Standard Global Climate Change Indicators

Indicator

Indicator 

type

1 Quantity of greenhouse gas emissions, measured in metric tons 

of carbon dioxide equivalent,a reduced or sequestered as a result 

of U.S. assistance

Outcomeb

2c Person hours of training completed in climate change supported 

by U.S. assistance

Output

Number of people receiving training in Global Climate Change 

as a result of U.S. assistance

Output

3 Amount of investment leveraged in U.S. dollars, from private and 

public sources, for climate change as a result of U.S. assistance

Output

4 Number of institutions with improved capacity to address climate 

change issues as a result of U.S. assistance

Output

5 Number of stakeholders with increased capacity to adapt to the 

impacts of climate variability and change as a result of U.S. 

assistance

Outcomed

6 Number of days of U.S.-funded technical assistance addressing 

climate change that is provided to counterparts or stakeholders

Output

7 Number of laws, policies, strategies, plans, agreements, or 

regulations addressing climate change (mitigation or adaptation) 

and/or biodiversity conservation officially proposed, adopted, or 

implemented as a result of U.S. assistance 

Output

Source: U.S. Agency for International Development (USAID).

Notes:

a

The Environmental Protection Agency defines carbon dioxide equivalent as a metric measure used 

to compare greenhouse gases based upon their global warming potential.

b

According to USAID officials, this indicator is required for clean energy and sustainable landscapes 

projects.

c

Either version of this indicator can be used to report on training related to global climate change.

d

According to USAID officials, this indicator is required for adaptation projects.

These standard indicators are linked to U.S. foreign assistance strategic 

objectives and intended to facilitate the aggregating and reporting of 

quantitative information common to U.S. assistance across recipient 

countries. State and USAID use the standard indicators in performance 

reports that summarize project activities, achievements, and difficulties 

encountered. USAID officials described the GCCI Indicator Handbook as 

a first-generation resource for missions and stated that they continue to 

seek opportunities to improve the agency’s climate change indicators, 

including by researching indicators used by other agencies and donors.

In addition to standard indicators, State and USAID use custom indicators 

to capture dimensions of projects that are specific to individual countries 
Page 34 GAO-13-829 Climate Change

and that are not reflected in the standard indicators. For example, in 

Indonesia USAID uses a custom indicator to track the number of people 

with access to modern energy services as a result of renewable energy 

technologies through U.S. assistance. At the project level, USAID’s 

Indonesia Marine and Climate Support project includes custom indicators 

on the number of people reached through climate change public 

awareness campaigns and the number of risk and vulnerability 

assessments completed by local governments.

USAID has begun drafting an overall evaluation plan for the GCCI in 

accordance with its recently issued evaluation policy, and expects to 

complete this initial evaluation plan in 2013. While USAID has not yet 

completed evaluations of programs or activities under the initiative, it has 

begun some evaluations, including evaluations of pilot programs intended 

to integrate climate change goals into other USAID programs in selected 

countries. In January 2011, USAID issued a new policy that defines 

agency requirements for evaluations, including the commitment that 3 

percent of program budgets, on average, must be devoted to external 

evaluations. The new policy defines two types of evaluations:

• Performance evaluations focus on what projects have achieved, how 

they are being implemented, what expected results are occurring, and 

other questions related to program design, management, and 

operational decision making.

• Impact evaluations measure the change in development outcomes 

attributable to a defined intervention and require a rigorous 

counterfactual to control for factors other than the intervention that 

might account for the observed change.

USAID’s policy requires all large projects42 to have at least one 

performance evaluation and that evaluations be timed so that findings will 

be available to inform decisions about new strategies, project designs, 

and procurements. The policy further requires activities to undergo impact 

evaluation, if feasible, if they use new approaches or untested 

hypotheses and if USAID anticipates expanding them.43

 42USAID defines large projects as those whose dollar value equals or exceeds the 

average project value for the operating unit.

As previously 

43Consistent with USAID’s evaluation policy, State issued its own evaluation policy in 

February 2012, which also includes a requirement that large programs be evaluated at 

least once.

USAID Is Developing an 

Evaluation Plan for Climate 

Change Activities
Page 35 GAO-13-829 Climate Change

discussed, USAID issued its Climate Change and Development Strategy 

in 2012, and USAID officials commented that the evaluation policy has 

since shaped the agency’s approach to how it will evaluate its assistance 

intended to address climate change by putting greater emphasis on longterm impact evaluations. USAID’s climate change strategy includes a 

results framework with strategic objectives and intermediate results, 

including a combined strategic objective for clean energy and sustainable 

landscapes, and a separate strategic objective for adaptation.

USAID officials stated that the development of the evaluation plan 

included revising and updating the results frameworks to provide separate 

and more detailed frameworks for each of the three GCCI pillars: 

adaptation, clean energy, and sustainable landscapes. According to 

USAID officials, these results frameworks will provide a more detailed 

hypothesis, or a theory of change, to underpin USAID’s work in the three 

pillars. These officials further stated that in developing these results 

frameworks, they have reached out to monitoring and evaluation 

consultants and are conducting literature reviews to assess the 

hypotheses and assumptions outlined in the frameworks, including, for 

example, their assertion that a country’s enabling environment is key to 

reducing greenhouse gas emissions. In addition, these officials said that 

they are conducting a manual inventory of programs addressing climate 

change across USAID missions worldwide and selecting missions to 

conduct impact evaluations of these programs.

Although the evaluation plan has not been completed, USAID officials 

stated that the agency has initiated some evaluations of its pilot program 

to integrate climate change goals into other programs, such as the Feed 

the Future initiative. So far, USAID has competitively selected 10 USAID 

overseas missions for pilot integration projects, including a project in 

Ethiopia that aims to improve resilience to climate change by helping 

communities address conflicts over scarce natural resources. USAID 

officials stated that several of the missions participating in this pilot have 

developed evaluation plans.

In contrast to USAID’s and State’s bilateral programs, Treasury officials 

stated that they require the monitoring and evaluation of multilateral FSF 

activities funded through the Climate Investment Funds (CIF) and the 

Global Environment Facility (GEF) to be conducted by the multilateral 

development banks and other international institutions that implement 

these activities. These implementing institutions have their own 

monitoring and evaluation processes, including requirements both at the 

trust fund level (e.g., the Clean Technology Fund) and the implementing 

agency level (e.g., the World Bank). Treasury officials stated that the 

Treasury Delegates 

Monitoring and Evaluation 

of FSF Activities to 

Multilateral Institutions
Page 36 GAO-13-829 Climate Change

department does not directly fund CIF or GEF projects in specific 

countries, but provides annual contributions to these trust funds, which 

are implemented by multilateral development banks and international 

institutions, such as the Asian Development Bank or the United Nations 

Development Programme. Treasury officials stated that they lack the 

resources to directly monitor or evaluate CIF or GEF projects, and instead 

rely on a common system of oversight of these funds through 

participation on their governing boards. The Treasury officials stated that 

as members of the CIF and GEF boards, they review regular progress 

reporting on country programs and individual projects. GEF officials told 

us, for example, that Treasury actively participates on the GEF Council 

reviewing project reporting and querying implementers on project results. 

GEF officials further stated that implementing organizations, such as the 

World Bank, conduct performance monitoring using standard GEF 

indicators and tracking tools and also conduct final project evaluations.44

Each of the CIF funds has a results framework that is applied to individual 

country programs and, according to Treasury officials, serves as the basis 

for future monitoring and evaluation of the impact, outcomes, and outputs 

of the CIF-supported activities. The responsibility for reporting on 

progress rests with the CIF’s country focal points and with multilateral 

development bank staff. For example, the multilateral development banks 

implementing Clean Technology Fund projects in a country are required 

to report annually on the progress on core indicators. More specifically, 

the fund’s Geothermal Clean Energy Investment Project in Indonesia, 

financed and implemented through the World Bank, includes results 

indicators on annual greenhouse gas emissions reductions and increased 

supply of geothermal capacity.

In addition, each of the multilateral development banks has its own 

monitoring and evaluation process, and the banks’ evaluation units 

conduct evaluations of CIF projects as part of their regular 

responsibilities. Treasury officials stated that a broader evaluation of the 

CIF is being conducted by an independent committee and representatives 

 44According to Treasury officials, for the bilateral Tropical Forest Conservation Act (TFCA) 

activities that Treasury funds, Treasury also conducts oversight through (1) participation in 

the interagency group that monitors TFCA issues, (2) reports from local TFCA programs, 

and (3) evaluations of individual country programs that Treasury funds through allocations 

to USAID. The U.S. government, according to these Treasury officials, also has direct 

oversight of local programs through its participation on local TFCA country boards.
Page 37 GAO-13-829 Climate Change

of multilateral development bank evaluation units, and is due to be 

completed in 2013.

The other key agencies that contributed to FSF—MCC, Ex-Im, and 

OPIC—funded activities that were not part of the GCCI, and these 

agencies’ approaches to monitoring and evaluation vary based on their 

respective missions and requirements. These agencies’ funding supports 

activities with reported climate-related benefits.

• MCC monitoring and evaluation focuses primarily on poverty 

reduction. MCC’s mission is to reduce poverty through economic 

growth, and MCC officials stated that it monitors and evaluates 

projects primarily for progress in achieving this goal using economic 

indicators. According to MCC officials, MCC supports low carbon 

economic development and helps partner countries address the risks 

of climate change when it is consistent with MCC’s core mission and 

supports the primary and development objectives of a compact’s 

primary poverty alleviation goal. For example, MCC’s monitoring and 

evaluation plan for the Green Prosperity Project in Indonesia is 

focused on indicators related to increasing productivity and incomes, 

but the plan also includes indicators related to expanding renewable 

energy capacity and improving sustainable land use and forest 

management.

• Ex-Im monitors its projects counted as FSF according to broader 

agency requirements. Ex-Im’s primary mission is to assist in financing 

the export of U.S. goods and services to international markets. 

According to Ex-Im officials, Ex-Im does not have climate change 

indicators or related monitoring and evaluation requirements for its 

projects, but it monitors its projects counted as FSF according to 

broader agency requirements, including monitoring to ensure 

repayment. The officials also told us that for projects that Ex-Im 

determines may produce greenhouse gas emissions in excess of 

25,000 metric tons of carbon dioxide equivalent per year, the bank 

requires applicants to provide information on the anticipated quantity 

of greenhouse gas emissions.

• OPIC monitors greenhouse gas emissions of its projects to track 

progress against a mandated emission goal. OPIC is the U.S. 

government’s development finance institution and its primary mission 

is to mobilize private capital to promote development and advance 

U.S. foreign policy. OPIC has a congressional requirement to achieve 

a 30-percent reduction in the greenhouse gas emissions of its 

Other Agencies’

Approaches to Monitoring 

and Evaluating FSF 

Activities Vary
Page 38 GAO-13-829 Climate Change

portfolio over a 10-year period,45 and it monitors and reports annually 

on the greenhouse gas emissions associated with its financing to 

track progress toward achieving this goal. OPIC also reports on the 

anticipated renewable energy megawatts generated and greenhouse 

gas emissions avoided for selected clean energy projects, including 

the projects counted as FSF.

Assistance to developing countries to address the causes and effects of 

climate change has become increasingly important for the United States. 

Diplomatically, this assistance shows the United States’ commitment to its 

broader international agreements to address climate change. It also 

demonstrates the United States’ commitments to assist developing 

nations that face the most significant adverse impacts of climate change. 

As a member of the Conference of the Parties in Durban in 2011, the 

United States agreed to additional reporting requirements and guidelines 

beginning in 2014 but has not determined how to fulfill this agreement. 

State made progress in its ability to collect and report on assistance 

aimed to address climate change to developing countries and voluntarily 

submitted three FSF reports containing information on the range of U.S. 

FSF activities. However, challenges remain, including determining a 

method for incorporating private sector finance into U.S. climate finance 

totals. According to State officials, the FSF reports helped meet U.S. 

diplomatic objectives by informing recipient countries of the range of U.S. 

climate finance activities occurring in these countries. However, if State 

does not meet future reporting requirements, it will be more difficult to 

demonstrate to international parties the United States’ commitment to 

climate finance. While State has started working with its international 

counterparts to address some of the future reporting requirements, our 

findings show that State does not currently collect the data necessary to 

fully meet the 2014 Framework Convention reporting requirements and 

guidelines.

State’s challenges in collecting and reporting on foreign assistance 

intended to address climate change are compounded by the lack of a 

dedicated budget code to track over $1 billion in USAID climate change 

assistance, due to the placement of climate change as a sub-element 

within State and USAID’s foreign assistance standardized program 

 45OPIC’s requirement is to reduce the greenhouse gas emissions associated with projects 

and sub-projects in its portfolio by 30 percent over a 10-year period from June 30, 2008, 

and by 50 percent over a 15-year period from June 30, 2008. 22 U.S.C. § 2191b.

Conclusions
Page 39 GAO-13-829 Climate Change

structure. Without a specific line item for climate assistance for 

developing countries, the agency must manually review data for over a 

hundred missions. Without better accounting for this assistance at 

USAID, both agencies will likely spend substantial and potentially 

unnecessary resources manually tracking U.S. funding. Improving this 

accounting may involve tradeoffs that merit consideration before revising 

the standardized program structure. For example, changes to the 

placement of climate change within the program structure may affect the 

accounting for other types of environmental assistance. On the other 

hand, the United States has made international commitments to collect 

and report on climate change assistance to developing countries as part 

of the administration’s efforts to enhance the transparency of foreign 

assistance. Furthermore, providing this information could assist Congress 

in its oversight of foreign assistance for climate change activities.

We recommend that the Secretary of State take the following two actions:

1. To ensure the United States meets its future reporting requirements 

and guidelines under the Framework Convention, we recommend that 

State determine how it will collect and report climate finance 

information that will be required beginning in 2014. In doing so, State 

should review the capabilities of its current data collection and 

reporting process and consider what changes, if any, are needed to 

meet the requirements and guidelines.

2. As State conducts reviews of the foreign assistance standardized 

program structure, we recommend that State, in consultation with 

USAID, consider the merits of elevating climate change within the 

program structure to provide a specific budget code that improves 

tracking of USAID climate change assistance.

We provided a draft of this report for comment to State, USAID, Treasury, 

MCC, Ex-Im, and OPIC. We received written comments from State, which 

are reproduced in full in appendix II. State agreed with our 

recommendations and expressed willingness to take action. We also 

received technical comments from State, USAID, Treasury, and MCC, 

which we incorporated throughout our report as appropriate.

We are sending copies of this report to appropriate congressional 

committees; the Secretaries of State and the Treasury, the Administrator 

of USAID, the Chairman of the Export-Import Bank, and the Chief 

Executive Officers of the Millennium Challenge Corporation and the 

Recommendations for 

Executive Action

Agency Comments
Page 40 GAO-13-829 Climate Change

Overseas Private Investment Corporation. This report will also be 

available at no charge on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

Thomas Melito at (202) 512-9601 or melitot@gao.gov, or J. Alfredo 

Gomez at (202) 512-4101 or gomezj@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix III.

Sincerely yours,

Thomas Melito

Director, International Affairs and Trade

J. Alfredo Gomez

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-13-829 Climate Change

This report examines (1) the extent to which the United States contributed 

to fast-start finance (FSF) and the types of activities this funding 

supported, (2) how the Department of State (State) collected and reported 

data on U.S. FSF funding and its plans for future reporting, and (3) what 

is known about the effectiveness of U.S. FSF activities. To address these 

objectives, we focused primarily on the six agencies that provided over 95 

percent of U.S. FSF assistance in fiscal years 2010 through 2012: State, 

the U.S. Agency for International Development (USAID), the Department 

of the Treasury (Treasury), the Millennium Challenge Corporation (MCC), 

the Export-Import Bank of the United States (Ex-Im), and the Overseas 

Private Investment Corporation (OPIC). We reviewed and analyzed 

documents and interviewed agency officials from these six agencies and 

from the U.S. Trade and Development Agency (USTDA), the 

Environmental Protection Agency (EPA), and the U.S. Forest Service, as 

well as officials from the United Nations Framework Convention on 

Climate Change (Framework Convention), the Organisation for Economic 

Co-operation and Development, and nongovernmental organizations. We 

conducted fieldwork in three countries—Ethiopia, Indonesia, and 

Mexico—that we selected on the basis of FSF funding levels and 

sources; areas of focus (adaptation, clean energy, and sustainable 

landscapes); project implementation status; geographic diversity; country 

income level; recommendations from agencies; and congressional 

interest. In these countries, we met with U.S. embassy officials and 

implementing partners, host-country government officials, multilateral 

development banks, and other bilateral donors. We also visited project 

sites and met with local implementing partners and recipients of the 

assistance.

To understand the extent to which the United States contributed to FSF 

and the types of activities this funding supported, we reviewed 

Framework Convention climate finance agreements and requirements, as 

well as government-wide and agency specific initiatives and strategies, 

and planning and programming documents. We reviewed FSF activity 

and funding data submitted by these agencies to State, and reviewed 

State’s consolidated FSF data. We also reviewed State’s and other 

countries’ FSF reports and submissions to the Framework Convention. To 

assess the reliability of State’s FSF data, we interviewed agency officials 

about data quality control procedures and reviewed relevant 

documentation. In addition, agency officials walked us through their 

database and discussed the various controls used. We determined that 

the data were sufficiently reliable for the purposes of this report.

To examine how State collected and reported data on U.S. FSF funding, 

we reviewed and analyzed FSF funding data submitted by the agencies 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-13-829 Climate Change

to State and reviewed State’s own data on FSF. In addition, we reviewed 

State’s database for maintaining FSF submissions for the fiscal year 2012 

FSF report and interviewed State officials responsible for compiling the 

data and creating the FSF reports. We determined that the data were 

sufficiently reliable for our purposes. In addition, we reviewed the criteria 

used by State to determine the FSF eligibility of activities listed in agency 

submissions. We also compared the guidance for agencies on FSF 

submissions from State and the Office of Management and Budget 

(OMB). To examine State’s plans for future reporting, we reviewed State 

reports and the reports of the Framework Convention Conference of the 

Parties meetings. We interviewed agency officials from the six agencies

listed above, as well as officials from EPA, U.S. Forest Service, USTDA, 

and OMB. In addition, we obtained disbursement status data from the 

USAID program offices in Ethiopia and Indonesia for all FSF activities for 

fiscal years 2010 through 2012. USAID in Mexico was unable to provide 

us with disbursement status data for their FSF activities.

To examine what is known about the effectiveness of U.S. FSF activities, 

we focused on the six agencies listed above. To examine how these 

agencies monitored and evaluated the effectiveness of their FSF 

activities, we reviewed agency goals and indicators, monitoring and 

evaluation plans and reports, and interviewed agency officials.

We conducted this performance audit from May 2012 to September 2013 

in accordance with generally accepted government auditing standards.

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of State

Page 43 GAO-13-829 Climate Change

Appendix II: Comments from the Department 

of State
Appendix II: Comments from the Department 

of State

Page 44 GAO-13-829 Climate Change
Appendix II: Comments from the Department 

of State

Page 45 GAO-13-829 Climate Change
Appendix II: Comments from the Department 

of State

Page 46 GAO-13-829 Climate Change
Appendix III: GAO Contacts and Staff 

Acknowledgments

Page 47 GAO-13-829 Climate Change

Thomas Melito, Director, International Affairs and Trade, (202) 512-9601, 

or melitot@gao.gov. 

J. Alfredo Gomez, Director, Natural Resources and Environment, (202) 

512-4101, gomezj@gao.gov.

In addition to the contacts named above, Christine Broderick (Assistant 

Director), Michael Hix (Assistant Director), Sada Aksartova, Ming Chen, 

Debbie Chung, Marissa Dondoe, Cindy Gilbert, Jeremy Latimer, Grace 

Lui, and Alana Miller made key contributions to this report.

Appendix III: GAO Contacts and Staff 

Acknowledgments

GAO Contacts

Staff 

Acknowledgments

(320914)
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