International Food Assistance: Local and Regional Procurement Can Enhance the Efficiency of U.S. Food Aid, but Challenges May Constrain Its Implementation
Released: 2009-06-04T00:00:00

Letter

Background

Donors Provide Food Aid in Various Ways

Donors provide food aid primarily through procurements, vouchers, and contracts, most commonly working through international organizations, such as WFP, and NGOs. Procurements of food aid can be categorized geographically as International: Donor-financed purchases of food aid in world markets, which may include both developed and developing countries. For example, food purchased in Canada that is delivered to Uganda.

Regional: Donor-financed purchases of food aid in a different country in the same region. For example, food purchased in South Africa that is delivered to Uganda.

Local: Donor-financed purchases of food aid in countries affected by disasters and food crises. For example, food purchased in the southern part of Uganda that is delivered to the northern part of Uganda.

Donors may also provide vouchers that allow recipients to purchase their own food in the local market. This option is usually used when food is available, but disaster-affected populations no longer have the income or livelihoods that would enable them to purchase food. WFP launched its first food voucher operation in Africa in February 2009, targeting 120,000 people who were suffering from the impact of high food prices in the urban areas of Ouagadougou in Burkina Faso.

In addition, donors may contract with a commercial agent, such as a local trader, to purchase and deliver food aid. For example, in April 2009, the Canadian Foodgrains Bank (CFB) contracted with Kenyan traders to purchase food from sources outside the country and used several NGOs to distribute the food.

Donors Are Increasingly Providing International Food Assistance in Cash

As the volume of food aid in the form of in-kind commodities has declined, the volume of food aid purchased through cash donations has increased, as shown in figure 1.

With the exception of the United States, most major donors—including the European Union, the United Kingdom, and most recently Canada—now provide all of their food aid as cash that may be used for local and regional procurement (LRP) by WFP and NGOs. Previously, the European Union’s food aid policies called for procuring food in the donor’s domestic market. In 1996, however, the European Union essentially eliminated restrictions that tied procurement of food aid to European suppliers as it restructured its food aid and food security budgets to focus on improving food security. In 2005, Canada took similar actions, providing 50 percent of its food aid budget in cash available for LRP. In 2008, Canada opted to provide 100 percent of its food aid budget in cash.

Canada’s stated rationale for switching to 100 percent cash funding for food aid (which in some cases can still be used to purchase Canadian agricultural commodi- ties) was to provide more flexibility to its overall food security strategy, improve the efficiency of its food assistance, and contribute to the development of local and regional markets from which it purchases food aid. As one of the world’s largest food aid donors, Canada has provided an average of about $161 million (USD) to WFP, the Canadian Foodgrains Bank (CFB), and other NGOs annually over the last 4 years, with the vast majority of its contributions going to WFP.

Many donors place conditions on their cash contributions to WFP, such as stating a preference for procurement of food in developing countries or for LRP. However, according to WFP, the availability of more flexible funding has significantly increased over the years, as donors have gradually shifted to providing food assistance as cash without tying such assistance to purchases from domestic food suppliers.

WFP’s Use of LRP Has Increased, particularly in Developing Countries

In its strategic plan for 2008 through 2011, WFP identified use of LRP as one of its five main objectives. WFP’s stated policy is to purchase food aid at the most advantageous price available, taking into account the cost of transportation and shipping, with a preference for using LRP in developing countries wherever possible. WFP cited two primary goals for funding LRP: (1) to increase the efficiency of food aid delivery, expediting assistance to save lives during food emergencies and humanitarian crises; and (2) to support development by stimulating agricultural production and raising farm incomes, particularly by targeting smallholder farm households.

As shown in figure 2, WFP LRP has consistently exceeded international procurement of food aid, principally for emergencies, from 2001 to 2008.

WFP procurement in developing countries has been increasing, from $171 million in 2001 to over $1 billion in 2008 (see fig. 3). In 2008, WFP procured 78 percent of its food aid from developing countries and 22 percent from developed countries.

Of the top 20 developing countries from which WFP procured food in 2008, 16 were in Africa and Asia. As shown in table 1, in 2007, 9 of the top 10 developing countries (including 8 in Africa and Asia) from which WFP procured food also received food aid the same year. Africa received 54 percent of total international food aid provided, and Asia received 29 percent of total international food aid provided in 2007.

Donors Have Launched Various Initiatives That Support LRP

In an effort to address the global food crisis, donors have recently launched a number of initiatives, many of which specifically advance LRP of food aid (see app. II). These donors include multilateral organizations such as the UN, WFP, and the World Bank, and bilateral donors such as the United States. For example, in September 2008, WFP formally launched the Purchase for Progress (P4P) program, a $76 million pilot that is to be implemented in 21 countries, 15 of them in sub-Saharan Africa, in the next 5 years to improve the income of smallholder farmers and thereby increase their incentives for production. In July 2008, the Group of Eight (G8) issued a statement on global food security that called on donors to participate in making commitments to provide access to seed and fertilizers and help build up local agriculture by promoting local purchase of food aid. In April 2008, the World Bank’s New Deal for Global Food Policy called for changes including a shift from traditional in-kind food assistance to cash, vouchers, development assistance for local markets, and purchase of food from local farmers to strengthen their communities.

Local and Regional Procurement of Food Can Reduce Costs and Improve Timeliness of Food Aid Delivery, but Many Challenges Remain

Local and regional procurement (LRP) can offer donors a tool for reducing costs and shortening delivery time but faces multiple challenges. LRP can offer cost-saving opportunities over in-kind food aid from the United States if food is available in the recipient country or neighboring countries, and the cost of procuring locally or regionally is less than the cost of procuring and shipping from the United States. Additionally, LRP can save delivery time in emergency situations because it usually travels a shorter distance than in-kind food aid. Local procurement can also avoid delays that often occur when food crosses borders and has to go through permit and inspection processes. Despite these benefits, donors face challenges in making local and regional procurements, including insufficient logistics capacity that can contribute to delays in delivery, and weak legal systems that can limit buyers’ ability to enforce. Besides the benefit of reducing costs and delivery time, locally and regionally procured food may have the added benefit of being more culturally acceptable to recipients. However, evidence on how LRP affects donors’ ability to enforce food aid quality standards and product specifications has yet to be systematically collected.

LRP Can Reduce Cost and Delivery Time

LRP Is Generally More Cost- Effective than In-kind Food Aid from the United States

We found that locally and regionally procured food costs considerably less than U.S. in-kind food aid for sub-Saharan Africa and Asia, though the costs are comparable for Latin America. We compared the cost per ton of eight similar commodities for the same recipient countries in the same quarter of a given year and found that the average cost of WFP’s local procurements in sub-Saharan Africa and Asia was 34 percent and 29 percent lower, respectively, than the cost of food aid shipped from the United States (see fig. 4). For example, in the fourth quarter of 2002, the average cost of locally purchased wheat in Ethiopia was approximately $194 per metric ton while the cost of U.S. wheat shipped to Ethiopia in the same quarter was 38 percent higher, at approximately $312 per metric ton. Additionally, about 95 percent of WFP local procurements in sub- Saharan Africa and 96 percent in Asia cost less than corresponding U.S. in- kind food aid. However, the location of procurements affects whether LRP offers any cost-saving potential and if so, by how much. While local procurement in sub-Saharan Africa and Asia cost much less than U.S. in- kind food aid, we found that in Latin America, the cost of WFP LRP was comparable to the cost of food aid shipped from the United States. The average cost of WFP local procurements in Latin America was 2 percent higher than that of U.S. food aid, and the number of WFP’s transactions with a lower cost than U.S. food aid was close to the number of transactions with a higher cost. This difference is due in part to the fact that shipping from the United States to Latin America is usually less costly than shipping to Africa.

Local and regional procurement can offer donors the flexibility to take advantage of cost-saving opportunities, which exist when food is available locally or regionally and the costs of purchasing and transporting it are lower than the costs of purchasing and shipping it from donor countries. Donors can purchase food aid from surplus-producing areas within the affected country, or purchase at the subregional and regional levels to meet localized needs. For example, to meet the needs of Uganda’s large internally displaced population in the north, WFP has been purchasing maize and beans from the surplus-producing areas that are in close proximity to the regions in need. In 2007, Uganda was the largest source for WFP procurements in terms of tonnage. From 2001 to 2008, WFP purchased over 600,000 metric tons of maize and beans locally to meet needs in Uganda. Similarly, to meet needs in Zimbabwe in 2008, WFP purchased a large amount of food aid that year from nearby countries including Malawi; Zambia; Mozambique; and South Africa, a surplus- producing country. South Africa was the largest source for WFP procurement in 2008, amounting to more than $163 million, and food from South Africa fed people in both nearby countries and internationally (see table 2).

To ensure cost-effectiveness, donors can use the import parity price to guide purchase decisions. For example, WFP compares the lowest price potential sellers submit through its tender process with the import parity price, which includes the costs of commodity plus shipping and handling, from various potential procurement sites. WFP procures locally or regionally if the costs of doing so are below the import parity price. Recently, for a LRP funded by USAID, Save the Children compared the cost of locally or regionally procured wheat flour, vegetable oil, and lentils to the cost of in-kind food aid from the United States. It found that although locally procured wheat flour in Tajikistan had a higher price than U.S. wheat, the cost of commodity plus shipping was lower. According to WFP, LRP’s cost-effectiveness depends on many factors, such as the commodity, season, and exchange rates. For example, WFP often procures peas from Canada because of the availability and competitive pricing of these commodities in this market. In addition, a strong currency can hurt a country’s competitiveness. According to WFP officials, increases in the value of the South African currency partly contributed to WFP’s decision to decrease its purchases from South Africa in 2007 and then increase them in 2008 when the currency devalued. (Fig. 5 shows WFP procurement from South Africa from 2001 to 2008.)

According to WFP data, LRPs in sub-Saharan Africa generally have a shorter delivery time than food aid procured internationally. We compared the median delivery time for LRP to the median delivery time for food aid either procured or donated internationally for 10 sub-Saharan countries. We selected these countries because they had received both LRP and international food aid. We found that international in-kind donation took the longest, averaging 147 days (see fig. 6). Local and regional procurements took on average 35 and 41 days, shortening the delivery time from international donations by 112 days and 106 days, respectively. For example, in Malawi, in- kind international donations took 4 months (167 days) while locally procured food aid took about 1 month (32 days). Similarly, the median delivery time for regionally procured food going to Zimbabwe was 48 days versus 114 days for internationally procured food aid. (For the delivery times of the 10 selected sub-Saharan African countries, see app. III.)

Similarly, in a USAID-funded grant completed in April 2009, Save the Children was able to obtain wheat flour from Russia and Kazakhstan and transport it to Tajikistan within 2 months, while wheat flour from the United States took over 5 months to arrive in Tajikistan (see illustrative example in app. IV, which also compares the cost of U.S. in-kind food aid with the cost of LRP). USAID sent the other two commodities—yellow peas and fortified soybean oil—from its prepositioning site in Jacintoport (Texas) and was able to shorten the delivery time. It took around the same number of days for the yellow peas from the U.S. prepositioning site as the lentils procured within the region to arrive. According to DOT, prepositioning offers significant time savings. DOT’s analysis shows that sending U.S. prepositioned food could have reduced transit time in comparison to a regional purchase from South Africa that was delivered to Somalia.

Locally and regionally procured food can take less time for delivery because it travels a shorter distance than internationally procured food and does not risk delays when crossing borders. Local procurement has the benefit of avoiding import processes, such as meeting recipient countries’ sanitary and phytosanitary requirements, which can delay delivery. For example, if imported maize does not meet a country’s moisture content requirement, delivery can be delayed. Some governments require imported food aid to go through additional testing and certification for genetically modified organisms (GMO). According to WFP officials in South Africa, these requirements can take an additional 2 to 3 weeks.

Lack of Reliable Suppliers, Donor Funding Restrictions, and Other Factors Have Limited the Efficiency of LRP

Despite potential benefits, factors such as a lack of reliable suppliers, limited logistical capacity, weak legal systems, and donor funding restrictions have limited the efficiency of LRP, as explained below: Lack of reliable suppliers. Of the 11 WFP procurement officers we interviewed, 9 identified finding reliable suppliers and preventing supplier default as a challenge to implementing LRP. A World Vision representative in South Africa stated that the organization was involved in a local procurement in Mozambique that took 5 months because the supplier did not have food in stock and had to find alternative sources to purchase enough to fulfill his contract. When food was finally delivered, World Vision found that many bags were short of the quantity specified in the contract.

Poor infrastructure and logistical capacity. Limited infrastructure and logistical capacity could delay delivery. For example, according to some WFP officials and private traders we met with, South Africa’s rail system and ports are underinvested and have limited capacity to handle food aid during peak seasons. Food aid could wait up to 2 months for a warehouse at the port of Durban. According to DOT, increasing regional procurements from South Africa could lead to more congestion at the port of Durban. DOT believes that in-kind food aid from the United States or prepositioning sites could avoid the port congestion in South Africa by going directly to the port of entry nearest the destination. In addition, trade barriers in developing countries could also delay delivery of food procured regionally.

Weak legal systems. A weak legal system could limit buyers’ ability to enforce contracts. WFP generally requires suppliers to purchase bonds, which they will lose if they do not fulfill their obligations under the contracts. However, this requirement is not always feasible to implement, especially when procuring from small suppliers. For example, WFP usually eliminates its bond requirements for its purchases from smallholder farmers. Experts pointed out that it is critical to build in the time and cost of adequate quality testing and control, particularly in an environment where there are weak legal requirements for the producers or the exporting countries. For example, WFP’s procurement officer in Uganda told us that many of the smallholder farmers WFP purchases from had never seen a contract before, and WFP had to take actions to ensure that these purchases were delivered on time and met the quality specified in the applicable contracts.

Timing and restrictions on donor funding. Timing and other restrictions on donor funding limit the flexibility of implementing partners to decide when, where, and how to purchase food, according to WFP procurement officers. If donor funding is not available when there is surplus in the market and prices are low, WFP cannot take advantage of market opportunities. A procurement officer in Sudan, for example, stated that, in January 2009, he was expecting 100,000 to 200,000 metric tons of high-quality commodities to be available on the market, but that he would only be able to purchase 20,000 metric tons due to the timing of donor funding. A WFP procurement officer in South Africa stated that, although he may be able to convince headquarters staff to let him use WFP’s advanced financing facility to make a purchase, he may encounter problems if the anticipated donor funding does not come through with its commitment. With donor support, WFP has begun to test flexible financing mechanisms that are expected to facilitate LRP. These include the advance financing facility, a mechanism with which WFP finances a specific project to mobilize food based on specific forecasts of donor contributions to the project, and a forward purchase facility, a mechanism that allows WFP to take a market position at an optimal time without specific knowledge of where the purchased food will go or which donor’s funding will underwrite the specific procurement action. Some officers also noted that some donors’ preference for LRP may result in procuring locally or regionally when importing might be less expensive.

LRP Can Provide More Culturally Appropriate Food, but Views on Quality Are Mixed

LRP Can Provide More Culturally Acceptable Food

Local and regional procurement can provide food that is more acceptable to the dietary needs and preferences of beneficiaries in recipient countries. People tend to be more familiar with food grown in neighboring regions than food from different continents. For example, people in many African countries prefer white maize, and Ethiopians who receive yellow maize as food aid from the United States might sell it in the cattle market as feed, according to a WFP procurement officer in Ethiopia.

Views on Meeting Product Specifications and Quality Standards Are Mixed

Experts and practitioners have mixed views on how LRP affects donors’ ability to adhere to product specifications and quality standards—such as moisture content and the level of broken and foreign matter—which ensure food safety and nutritional content. However, donors have yet to systematically collect evidence that demonstrates whether food procured in different locations varies significantly in meeting product specifications and quality. Some experts contend that because locally and regionally procured food travels shorter distances and takes on average less time to arrive at its destination than internationally procured food aid, certain quality standards, such as moisture content, may be less critical. The longer grain has to travel, the more critical it is to control moisture content so that it does not become moldy and infested with insects. We have previously reported quality problems with U.S. food aid during long transit times. Regarding LRP food aid, 9 out of the 11 WFP procurement officers we interviewed for this review confirmed that quality was a challenge. They also noted, however, that some quality standards, which may often be difficult for suppliers in developing countries to meet, may not be very crucial to individual recipients. For example, due to the lack of modern processing facilities, rice from some developing countries may have a higher level of broken kernels, but some recipients may actually prefer such rice because it is better suited to cooking porridge, a common method of consumption. However, concerns persist about the quality of food procured in developing countries. The U.S. Wheat Associates noted that the ability to ensure food quality and safety could be jeopardized when purchases occur where standards are less rigorous than those of U.S. suppliers to food aid programs. We learned of a few examples of locally or regionally procured food not meeting quality standards. For example, representatives from WFP and NGOs told us that they had received food that turned out to be of lower quality or quantity than what was specified in the contract. A WFP procurement officer in South Africa reported that WFP requires the plants that manufacture maize meal or corn soy blend (CSB) to meet internationally accepted production standards, such as Hazard Analysis and Critical Control Point (HACCP), and hires surveyors to take samples for testing and assess whether the facility meets those standards. However, these surveyors recently found that 13 out of 15 maize meal plants were not in compliance with the standards and provided a list of activities the plants should undertake in order to improve. In addition, some factors that affect the efficiency of LRP also affect the ability to meet quality standards and product specifications. For example, a weak legal system limits buyers’ ability to enforce contracts, including imposing penalties when commodities delivered do not meet the specifications outlined in the contract. However, no evidence has been systematically collected on how LRP affects donors’ ability to adhere to quality standards and product specifications. A WFP official told us he does not believe there is any significant difference among different procurement types in the level of post-delivery loss, which is one measure of quality issues. However, WFP has not analyzed whether the quality issues are more severe for food procured locally or regionally versus food procured internationally.

Local and Regional Procurement of Food Aid Has Potential for Adverse Market Impacts That Can Be Mitigated by Better Market Intelligence

Local and regional procurement (LRP) has the potential to make food more costly to consumers in areas from which food is procured by increasing demand and driving up prices. While WFP has taken actions to help mitigate these impacts, such as coordinating with other implementing partners to gather market information, in some cases local purchases have adversely affected markets where the purchases were made. In particular, lack of reliable market intelligence—such as market prices, production levels, and trade patterns—makes it difficult to determine the extent to which LRP can be increased without causing adverse market impacts. Poorly functioning and unintegrated markets pose an additional challenge to avoiding adverse market impacts and expanding the use of LRP. Other challenges include lack of access to inputs and extension services, weak transportation infrastructure, and host government policies that inhibit food production.

Local Purchases of Food Aid Have Adversely Affected Some Markets

LRP can make food more costly to consumers by increasing demand and driving up prices. Although most of the WFP procurement officers we interviewed stated that local procurements of food aid generally do not affect market prices, our review of the literature and interviews during fieldwork show that there have been instances where LRP contributed to price hikes and price volatility in markets from which food is procured. However, the size of each of WFP’s local procurements tends to be small—on average about 298 metric tons, as compared with 671 metric tons for its international procurements. Additionally, WFP’s local procurements do not make up a large portion of the market for a food commodity in many developing countries, which reduces the risk of disrupting local markets. WFP’s local procurements of about 20,000 metric tons of maize in Burkina Faso in 2008, for example, amounted to less than 1 percent of a total market capacity of 700,000 metric tons. However, local procurements have also contributed to price hikes. In 2003, for example, when food aid donors tried to take advantage of low prices following 2 years of good harvests in Ethiopia, their purchases contributed to a rise in prices. Additionally, in 2003, WFP’s Uganda country office procured a large amount of locally grown maize from large traders based in Kampala in support of its operations in northern Uganda and in the Great Lakes region, particularly in Burundi. Due in part to this activity, maize prices in Kampala during this period were double those in Iganga (119 kilometers away). However, because maize is not a staple food in Uganda, consumers’ access to food may not have been adversely affected. WFP’s large local procurements in Uganda from a small number of large traders may also have contributed to an increase in the market power of those large traders.

While local procurements of food aid have adversely affected markets in several developing countries, particularly in sub-Saharan Africa, almost all of the WFP procurement officers we interviewed stated that they supported the idea of the United States increasing its funding for LRP. However, WFP procurement officers we spoke to, NGO officials in countries we visited, and other experts we met with agreed that increased use of LRP should be done incrementally and that significant challenges remain to expanding market capacity in many countries, particularly in sub-Saharan Africa.

Unreliable Market Intelligence, Poorly Functioning and Unintegrated Markets, and Other Factors Pose Challenges to Increasing LRP without Causing Adverse Market Impacts

Unreliable Market Intelligence

Food Procurement in Developing Countries, World Food Program, Executive Board First Regular Session (Rome: February 2006). have also noted that market information for many countries is very difficult for WFP or NGOs to collect and rely on when making purchasing decisions. For example, a 2005 study commissioned by the United Kingdom’s Department for International Development (DFID) of local procurement in Ethiopia noted that market information at the smallholder farmer level was non-existent and that there was no formal system for determining the domestic price of grain.

In efforts to significantly reduce the risk of contributing to price hikes and long-term food price inflation WFP uses import parity pricing, solicits tenders for small amounts of food early in the harvest season, and works with other parties involved in international food assistance to plan food aid interventions. In addition to serving as a measure for cost-efficiency, comparing local prices with import parity prices helps those involved in local procurement to determine whether a local procurement will “do no harm” to local markets and consumers by not making local procurements when local prices are higher than international prices. However, as a USDA study on LRP has noted, this standard may be constrained in cases where local prices for commodities are so much lower than import parity prices that it would require substantial price increases to reach the import parity threshold. WFP also tries to mitigate potential adverse market impacts by issuing tenders for small amounts of food early in the harvest season. Then, combined with available market intelligence, WFP determines whether its purchases have contributed to price hikes before putting out larger tenders. In addition to these tactics, WFP country offices work with other parties involved in food aid, such as donors, host government agencies, and NGOs, to coordinate efforts and share market information. For example, several WFP country offices in eastern and southern Africa created a country-by-country spreadsheet in the summer of 2008 to stay current on developments related to rapidly escalating food prices, such as government-imposed export bans.

Poorly Functioning and Unintegrated Markets

Even when market information is adequate, poorly functioning and unintegrated markets in sub-Saharan Africa and other developing countries still present challenges to expanding LRP while avoiding its potential adverse market impacts, according to food aid evaluations, experts convened for our roundtable, and fieldwork. Unintegrated markets are characterized by a lack of price transmission among markets. Additionally, there is difficulty in tracking informal cross-border trade and a lack of functioning commodity exchanges. When markets are not well- integrated, either within countries or regionally, large purchases of food by WFP, other food aid organizations, or donors can cause localized price hikes. For example, WFP officials in Burkina Faso noted that the government’s purchases for its strategic food reserve have correlated with price spikes. Because the markets for agricultural commodities in sub- Saharan Africa, in particular, are not always clearly defined and do not always account for natural geographic and ethnic boundaries, significant informal cross-border trading that does not heed international and regional trade agreements can occur. For example, approximately 30 to 50 percent of Uganda’s marketable surplus for maize is traded informally, often on bicycles across the borders to Kenya or Rwanda, according to WFP, USAID, and foreign government officials, and others we interviewed during fieldwork in Uganda. Additionally, WFP’s Uganda country office staff stated that it is difficult to effectively plan food aid interventions involving LRP in the neighboring Democratic Republic of the Congo due to lack of information about informal cross-border trading and volatile market conditions. The market effects of such trading can be difficult to track and create additional constraints to understanding and avoiding adverse price impacts when conducting LRP. Finally, in all of sub-Saharan Africa there is only one well-functioning agricultural commodity exchange, the South African Futures Exchange (SAFEX). Several countries are developing warehouse receipt systems that would allow farmers access to credit, but the countries face challenges such as farmers’ lack of awareness about marketing structures and banks’ reluctance to provide credit to farmers.

Factors That Contribute to Persistent Food Insecurity

Many of the factors that affect persistent food insecurity in sub-Saharan Africa and other developing countries are also challenges to the implementation and potential expansion of LRP. These factors include lack of access to inputs and extension services by farmers, weak transportation infrastructures, and weak or conflicting host government policies.

As we reported in 2008, smallholder farmers in developing countries, particularly in sub-Saharan Africa, have limited access to modern inputs and agricultural extension services such as enhanced seeds, fertilizer, and tractors. During our fieldwork, representatives from several farmer groups and associations told us they had experienced similar problems. In Burkina Faso, one farmer group in a food-deficit area had stopped growing maize for lack of fertilizer and seed and had started planting more cotton because it could receive government subsidies for that crop.

Weak transportation infrastructure in many developing countries makes it difficult for smallholder farmers to move their crops to market and for local markets to integrate regionally and nationally. The World Bank has reported that less than half of the rural population in sub-Saharan Africa lives near an all-season road.

Policies of host governments are not always favorable to supporting agricultural development, although the Comprehensive Africa Agriculture Development Program (CAADP) aims to address the lack of agriculture development in sub-Saharan Africa by focusing on budget prioritization and policy restructuring. USAID’s Initiative to End Hunger in Africa (IEHA) supports CAADP’s efforts by coordinating with other donors to provide technical and policy support for agricultural and market development.

These factors, combined with unreliable market intelligence and poorly functioning and unintegrated markets, continue to represent significant challenges to increasing LRP in many developing countries, particularly in sub-Saharan Africa.

LRP Has the Potential to Indirectly Support the Development of Local Economies by Increasing Demand for Agricultural Commodities and Raising Farmers’ Incomes

While the primary purpose of LRP is to provide food assistance in humanitarian emergencies in a timely and efficient manner, a potential secondary benefit is contributing to the development of the local economies from which food is purchased. This can be accomplished by increasing the demand for agricultural commodities, thereby increasing support for all levels of the commodity value chain, which includes individuals, businesses, and organizations involved in their respective agriculture production and marketing industries such as large traders, intermediate traders or middlemen, smallholder farmers, input suppliers, and processors. Figure 7 illustrates the agricultural commodity value chain supported by LRP.

The development benefits to local economies are secondary because in almost all cases WFP and NGO purchases are not large enough or reliable enough to sustain increased demand over time. Only recently has WFP acknowledged that LRP can contribute to local development. In several of the countries we visited, we observed WFP LRP initiatives under way that might support local economies in the long term and connect LRP to other food security initiatives. However, many of them are new and limited in scale. For example, in February 2009, WFP began a cash voucher program in Burkina Faso that will target beneficiaries in two major cities, Ouagadougou and Bobo Dioulasso, by providing them with vouchers that are redeemable for food commodities. In September 2008, WFP launched its P4P program, which had the goal of benefiting smallholder farmers directly by purchasing food from them. However, WFP officials recognize that these procurements will only amount to a small percentage of its total local procurements. With initial funding to manage and administer P4P from the Bill & Melinda Gates and Howard G. Buffett Foundations, pilot programs have been approved in 21 countries.

Legal Requirements for U.S. Food Aid May Constrain U.S. Agencies’ Use of Local and Regional Procurement

Certain legal requirements to procure U.S.-grown agricultural commodities for food aid and to transport up to 75 percent of them on U.S.-flag vessels may constrain agencies’ use of local and regional procurement (LRP). First, the Food for Peace Act supports in-kind food aid by specifying that funding under the Act can be used only to purchase U.S.-grown rather than foreign-grown agricultural commodities and thus cannot be used for LRP. Since 2002, appropriations for Title II of the Food for Peace Act have averaged $2 billion annually, none of which can be used to purchase foreign-grown food. However, from 2001 to 2008, through programs funded under a different authority, the Foreign Assistance Act, the U.S. government has provided approximately $220 million in total cash contributions to WFP that were used to purchase foreign-grown commodities. In addition, since July 2008, Congress has appropriated $50 million to USAID that can be used for LRP in addition to $75 million that the Administration allocated for LRP in International Disaster Assistance funding; and the 2009 Omnibus Appropriations Act provided another $75 million in development assistance funding to USAID for global food security, including LRP and distribution of food. Second, the Cargo Preference Act of 1954, as amended, which is enforced by the DOT, requires up to 75 percent of the gross tonnage of all U.S.-funded food aid to be transported on U.S.-flag vessels. There is disagreement among USAID, USDA, and DOT on how to interpret and implement certain requirements of cargo preference, such as the agency responsible for determining availability of U.S.-flag vessels. If these requirements remain ambiguous, U.S. agencies’ use of LRP could be constrained.

Legal Requirement to Purchase U.S.-Grown Food Limits Funding for Foreign-Grown Food

While most funding for U.S. food aid cannot be used to purchase foreign- grown food, a limited amount of funding has been used to support LRP. Programs under the Food for Peace Act, have been the main vehicles of U.S. international food aid. However, funding under the Act is restricted to the purchase of U.S.-grown agricultural commodities. Title II of the Food for Peace Act, administered by USAID, is the largest U.S. international food aid program providing humanitarian donations to respond to emergency food needs or to be used in development projects. Since 2002, appropriations for Title II have averaged $2 billion annually, none of which can be used to purchase foreign-grown food, as envisioned by LRP. However, a limited amount of U.S. funding has been authorized through the 2008 Farm Bill, the Foreign Assistance Act, 2008/2009 bridge supplemental, and the 2009 Omnibus Appropriations.

First, the 2008 Farm Bill established a 5-year, $60 million LRP pilot program, administered by USDA, to respond to emergencies and chronic food aid needs around the world. The pilot requires a study of LRP experiences, field- based projects, evaluations of field-based projects by independent parties, and a USDA report submitted to Congress by 2012. USDA is currently establishing guidelines for proposals to conduct field-based LRP projects and estimates completion of the guidelines by the end of summer 2009.

Second, the Foreign Assistance Act authorizes USAID and State to provide cash contributions to WFP and implementing partners to purchase foreign- grown commodities for specific program goals. From 2001 to 2008, the U.S. government, through programs operating under the Foreign Assistance Act, has provided approximately $220 million in total cash contributions to WFP for 1,265 LRP transactions. WFP received contributions from State’s Bureau of Population, Refugees, and Migration (PRM); USAID Office of Foreign Disaster Assistance (OFDA); and USAID country missions; among other programs. State officials stated that LRP can be used to fill gaps in refugee and internally displaced persons (IDP) feeding operations caused by lack of donor support; inflows of new refugees and IDPs; inability of donors to deliver food to an area quickly, or more recently, rising costs of commodities and transportation. Similarly, officials from USAID agreed that LRP offers an opportunity to respond to food security crises and increase the total amount of food aid the United States can provide by filling gaps in country before food shipped from the United States arrives.

Third, since July 2008, Congress has appropriated $125 million to USAID that can be used for LRP. USAID received $50 million in fiscal year 2008 supplemental appropriations to respond to the global food price crises with LRP, among other activities. Another $75 million in development assistance funding was made available to USAID through the 2009 Omnibus Appropriations Act for global food security, including LRP and distribution of food. For fiscal year 2009, the Administration made available for LRP $75 million in International Disaster Assistance funding. To implement LRP programs with increased authority, USAID/OFDA issued guidelines for LRP proposals in October 2008 specifying that organizations applying for funding must (1) demonstrate an urgent need for food aid; (2) relate to the factors associated with the emergency to the global food price crisis or to a declared disaster; or (3) provide compelling evidence that the use of local procurement will save lives, reduce suffering, and/or serve more people than by using international procurement of Title II food aid. By April 2009, USAID/OFDA had programmed $63 million in direct cash contributions to WFP and implementing partners to purchase foreign-grown commodities for vulnerable populations in Ethiopia, Kenya, Kyrgyzstan, Nepal, Pakistan, Somalia, Tajikistan, and Zimbabwe. Monitoring and evaluation plans for tracking program implementation, results, and outcomes are required with all awards.

Uncertainty Regarding Cargo Preference Could Constrain Agencies’ Implementation of LRP

Because the leading U.S. food assistance agencies and DOT disagree on how to implement the Cargo Preference Act, their use of LRP could be constrained. The Cargo Preference Act, as amended, requires that up to 75 percent of the gross tonnage of agricultural foreign assistance cargo be transported on U.S.-flag vessels. DOT issues and administers regulations necessary to enforce cargo preference. Among other things, the department has the authority to require the transportation on U.S.-flag vessels of cargo shipments not otherwise subject to cargo preference (hereafter referred to as “make-up requirements”) when it determines that an agency has failed to sufficiently utilize U.S.-flag vessels. In some cases, however, USAID and USDA officials disagree with DOT on interpretations of cargo preference requirements including (1) the agency responsible for determining availability of U.S.-flag vessels; (2) make-up requirements when U.S.-flag vessels are unavailable or when an agency waives cargo preference requirements during emergencies, also referred to as “notwithstanding authority;” (3) applicability of cargo preference requirements to public international organizations; and (4) methodology used for cost reimbursements.

Agency Officials Have Different Interpretations of Cargo Preference Requirements

Table 3 summarizes differences in agency officials’ interpretations of cargo preference requirements.

The differences in agency interpretations of cargo preference are discussed below. 1. Agency responsible for determining availability of U.S.-flag vessels: Officials from USAID, USDA, and DOT stated that their respective agencies have independent authority to determine U.S.-flag vessels are not available. According to USAID officials, the agency determines U.S.-flag nonavailability based on its USAID program needs but seeks prior concurrence from DOT’s Maritime Administration (MARAD). According to USDA officials, USDA determines the availability of U.S.- flag vessels based on programmatic needs, and DOT determines what constitutes a fair and reasonable shipping rate. Agency officials and industry experts noted that the availability of U.S.-flag vessels in areas such as Africa’s eastern coast is limited. DOT noted that a U.S.-flag vessel could ship food from one African port to another if the ship happened to be in the region conducting military operations or other business. However, most carriers do not currently provide regular regional service. U.S. officials in Kenya and South Africa confirmed this lack of regular service along Africa’s eastern coast. A shipping agent in South Africa stated that she was aware of two U.S.-flag vessels that frequent the port of Durban. Representatives of a coalition of U.S.- flag carriers indicated that U.S.-flag vessels could provide additional service in the region in the future but their decision to relocate vessels depends on the regularity of regional shipments. According to a 2008 report regarding efforts to improve procurement planning, USAID and USDA compete with DOD and other exporters for space aboard the relatively few U.S.-flag vessels, some of which are ill-suited for t carriage of food-grade commodities. Moreover, of the three participating liner service container carriers utilizing U.S.-flag vessels, only one services Africa, where 54 percent of international food aid was delivered in 2007, according to INTERFAIS data. 2. Make up requirements when U.S.-flag vessels are unavailable or an agency uses “notwithstanding” authority: Agencies disagree as to whether shipments made on foreign vessels, because U.S.-flag vessels were not available or because an agency waives cargo preference requirements utilizing authority to conduct a program notwithstanding any other provision of law, should count toward the maximum tonnage allowed on foreign-flag vessels. DOT has stated that it should, and any tonnage shipped on foreign-flag vessels that exceeds the 25 percent maximum tonnage should be made up the following year. However, USAID has the authority to implement emergency programs, including international disaster assistance, notwithstanding any other provision of law. With this authority, USAID has waived cargo preference requirements to ensure food aid delivery during emergencies. In those cases, it believes the tonnage shipped on foreign-flag vessels should not be counted toward the maximum foreign-flag tonnage allowed under cargo preference. DOT officials believe otherwise. Since 2005, USAID has used notwithstanding authority to override cargo preference four times, two of which were in 2005 when there were extreme price disparities between U.S.-flag and foreign-flag offers to transport emergency food aid to Kenya and Somalia. 3. Applicability of cargo preference requirements to public international organizations: Agencies also disagree on whether grants made to international organizations, such as WFP, must incorporate cargo preference requirements. According to DOT officials, if public international organizations use U.S. funding to purchase food and that food requires ocean shipping, U.S.-flag vessels should be given cargo preference. For example, in 2006, DOT notified the USAID West-Bank/Gaza mission that it had not conformed to the legal mandate in a U.S.-funded grant with WFP to purchase 16,000 metric tons of wheat flour for shipment to Tel Aviv. However, according to the USAID policy manual, public international organizations are allowed to abide by their own procurement rules. Therefore, international organizations that receive cash contributions for regional procurement of food are not required to ship on U.S.-flag vessels. 4. Reimbursement methodology: DOT is required to reimburse food aid agencies for a portion of the ocean freight and transportation costs that exceed 20 percent of their total program costs. However, agencies disagree on whether reimbursement levels are sufficient to cover the additional costs incurred by transporting the food on U.S.-flag vessels. According to USDA officials, DOT has been reluctant to reimburse USDA for any excess costs beyond 20 percent freight costs and has not gone on the record about reimbursement for USDA’s LRP pilot field- based projects. According to USAID, areas of ambiguity regarding reimbursements include: costs of ocean freight and transportation on U.S.-flag vessels that exceed 20 percent of program costs, transportation from overseas food warehouses to final destinations, foreign inland transport costs, and costs of ocean freight and transportation on U.S.-flag vessels when there is no foreign-flag vessel available for cost comparison.

Lack of Clarity on Cargo Preference Requirements Could Constrain LRP

With a lack of clarity on how to interpret cargo preference regulations, agencies’ ability to utilize LRP to respond to emergencies may be constrained. For example, as of October 2008, DOT has the authority to require the transportation on U.S.-flag vessels of cargo shipments not otherwise subject to cargo preference when it determines that an agency has failed to sufficiently utilize U.S.-flag vessels. DOT has not yet issued regulations governing how it will implement this new authority and USAID faces uncertainty regarding whether increased use of LRP will trigger imposition of make-up requirements.

Cargo preference could also constrain USAID’s and USDA’s LRP pilot programs if U.S.-flag vessels are unavailable. USAID officials indicated that given the limited volume of regional shipments relative to regular Title II shipments, the agency would probably not be able to meet the U.S.-flag compliance threshold if even one shipment could not be transported on a U.S.-flag vessel. According to a USDA official, countries chosen for its LRP pilot field-based projects will likely receive food shipments only once in a fiscal year. If U.S.-flag vessels are unavailable for service at that time, it is unclear how USDA will make up tonnage by country and program the following year since, according to officials, the pilot is of limited duration. In addition, USDA will not cut other country program budgets in order to make up tonnage by country for its LRP program.

Finally, the lack of clarity when USAID waives cargo preference through notwithstanding authority could constrain its ability to fully utilize the authority when responding to emergencies that require regional shipment of food in anticipation of potential sanctions by DOT. To date, USAID has used notwithstanding authority to waive cargo preference requirements on only four occasions, in part due to the uncertainty of a regulatory response from DOT. The $200 million that USAID has for LRP is available to be expended notwithstanding any other provision of law. According to USAID officials, the agency has not used its authority to waive cargo preference requirements for any of the LRP transactions funded through May 2009.

The MOU that outlines the manner in which USAID, USDA, and DOT coordinate the administration of cargo preference requirements was last updated in 1987 and does not reflect modern transportation practices or the areas of ambiguity related to LRP. In our 2007 review of U.S. food aid, we found that cargo preference can increase delivery costs and time frames, with program impacts dependent on the sufficiency of DOT reimbursements. Therefore, we recommended that USAID, USDA, and DOT seek to minimize the cost impact of cargo preference regulations by updating implementation and reimbursement methodologies of cargo preference as it applies to U.S. food aid. Since 2007, USAID and USDA have proposed a working group with DOT to renegotiate the MOU. To date, however, there have been few meetings and no agreement has been reached between the agencies.

Conclusions

The timely provision of food aid is of critical importance in responding to humanitarian emergencies and food crises. In 2007 and 2008, the number of chronically hungry people in the world grew by 115 million, despite an international commitment to halve the number of hungry people by 2015. While the United States has primarily provided in-kind food aid for over 50 years, it has been exploring expanded use of LRP. This tool has the potential to better meet the needs of hungry people by providing food aid in both a more timely and less costly manner. To fully realize this potential, however, challenges to its effective implementation must be addressed.

Concerns about the quality of LRP food aid persist, but aid organizations still do not systematically collect evidence on LRP’s adherence to quality standards and product specifications that would ensure food safety and nutritional content. Furthermore, experts and practitioners caution that scaling up LRP in recipient countries should be done gradually to ensure that the potential benefits of LRP are maximized while any potential adverse impacts are minimized or avoided. While accurate and reliable market data would help ensure that U.S. agencies and implementing partners make optimal decisions with regard to when, where, and how to procure food locally or regionally, such data are not yet available. Finally, the implementation of LRP may be constrained by U.S. agencies’ disagreement on a number of requirements associated with cargo preference, thus elevating the importance of an updated interagency MOU that resolves existing ambiguities.

Recommendations for Executive Action

To enhance the impact that LRP can have on the efficiency of food aid delivery and the economies of countries where food is purchased, we recommend that the Administrator of the U.S. Agency for International Development and the Secretary of Agriculture take the following three actions: systematically collect evidence on LRP’s adherence to quality standards and product specifications to ensure food safety and nutritional content; work with implementing partners to improve the reliability and utility of market intelligence in areas where the U.S.-funded LRP occurs, thereby ensuring that U.S.-funded LRP practices minimize adverse impacts and maximize potential benefits; and work with the Secretary of Transportation and relevant parties to expedite updating the MOU between U.S. food assistance agencies and the Department of Transportation, consistent with our 2007 recommendation, to minimize the cost impact of cargo preference regulations on food aid transportation expenditures and to resolve uncertainties associated with the application of cargo preference to regional procurement.

Agency Comments and Our Evaluation

DOT, USAID, USDA, and WFP provided written comments on a draft of this report. We have reprinted these agencies’ comments in appendixes VII, VIII, IX, and X, respectively, along with our responses. Additionally, USAID, DOT, State, and WFP provided technical comments on a draft of our report, which we have addressed or incorporated as appropriate. Treasury and MCC did not provide comments.

USAID generally concurred with our recommendations. With regard to the first recommendation, however, USAID noted that it may be more efficient for us to recommend that all food aid organizations collaborate in the development and implementation of systems to monitor quality assurance and product specification issues in all food purchases, including LRP. The recommendation does not preclude such coordination among the agencies. We recognize USAID’s and USDA’s efforts to date to implement our 2007 recommendation to develop a coordinated interagency mechanism to update food aid specifications and products to improve food quality and nutritional standards. Including actions to systematically collect evidence on LRP’s adherence to quality will make these efforts more efficient. With regard to the third recommendation, USAID commented that MARAD’s position on the applicability of the 75 percent threshold to USAID-funded LRP, rather than the 50 percent threshold, is devoid of legal merit. In providing information on agencies’ interpretations of cargo preference requirements as they pertain to LRP, we sought to identify areas where agencies disagree on the applicability and interpretation of these requirements. We did not attempt to adjudicate the differences in interpretation among the agencies involved. However, in technical comments to a draft of this report, DOT changed its position regarding thresholds and now concurs with USAID’S interpretation, thus eliminating this issue as an area of ambiguity.

USDA generally agreed with our report, noting that our comparisons of costs and delivery times were insightful. However, USDA observed that aggregating some of the commodities such as vegetable oil and beans could cause a loss of precision in our methodology. To obtain an overall picture of costs, we worked to ensure that we had the largest number of observations, over the longest possible time period, so some aggregation was required. USDA also stated that our report does not specify how differences in quality or specifications were handled. We recognize that the price of different commodities in the same category may vary depending on quality or specifications. However, we noted WFP’s assertion that its commodities meet both the importing and exporting countries’ standards, and there is no systematic evidence that U.S. commodities differ in quality compared to LRP commodities. Nonetheless, we recognize that there may be differences in the quality of certain commodities, and we note such differences in our illustrative example of LRP for Tajikistan. In addition, both USDA and DOT noted that we did not compare delivery times for LRP and in-kind food aid from prepositioning sites. Although we did not differentiate prepositioned commodities in our cost comparison, we included them in our data analysis and note that prepositioned commodities were a very small part of U.S. food aid during the time period we examined.

DOT stated that additional analysis may be warranted before concluding that LRP offers a tool to reduce costs and shorten delivery time. Although further analysis of LRP practices would be useful, our analysis demonstrated consistent results across 8 years of data. For example, local procurement in sub-Saharan Africa cost about 34 percent less than USAID commodities procured at around the same time and delivered to the same country. DOT also stated that it implements the cargo preference statute through regulation, not through an interagency MOU. While this is true, the regulations contain ambiguities that have previously required resolution through an MOU. Our report describes new ambiguities that could arise in applying cargo preference in the context of regional procurement. We believe that these ambiguities can be resolved by updating the MOU. Further, there is no requirement that establishing regulation precede a MOU nor does a MOU preclude the issuance of new regulation. The updated MOU, establishing consensus among the relevant agencies, could be reflected in any future regulation that DOT may draft and get finalized through the rule-making process.

WFP welcomed our timely examination of LRP as one of numerous tools to deliver effective and efficient food assistance to those in greatest need. However, WFP stated it was perplexed that concerns persist about the quality of food procured in developing countries, given the lack of evidence showing that LRP introduces quality challenges that are not already challenges to internationally procured and donor-provided food aid. We note that quality is one issue that many WFP procurement officers and several other officials we interviewed identified as a challenge for LRP. However, the lack of systematically collected data makes it difficult to objectively analyze how LRPs adhere to quality standards and product specifications. Our first recommendation addresses this issue. In addition, WFP offered some qualifications to our discussion of the impact of LRP on economies where food is procured, noting the lack of systematic evidence to suggest that current LRP practices adversely impact host markets. In this report, we explain several efforts that WFP and others have taken to significantly improve the availability and reliability of market intelligence in developing countries. Nonetheless, WFP, NGOs, U.S. agencies, host governments, and experts convened for our roundtable stated that the most significant challenge to avoiding potential adverse markets impacts when conducting LRP is unreliable market intelligence. Therefore, we are recommending improving the reliability and utility of market intelligence.

As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. We are sending copies of this report to interested Members of Congress, the Administrator of USAID, and the Secretaries of Agriculture, State, Transportation, and the Treasury. In addition, this report will be available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staffs have any questions about this report, please contact me at (202) 512-9601 or melitot@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 major contributions to this report are listed in appendix XI.

Appendix I: Objectives, Scope, and Methodology

Our objectives were to determine (1) the impact of local and regional procurement (LRP) on the efficiency of food aid delivery, (2) the impact of LRP on economies where food is procured, and (3) U.S. legal requirements that could affect U.S. agencies’ use of LRP.

We selected four countries for fieldwork based on geographic region, WFP procurement data, and the presence of WFP procurement officers in- country. We selected countries in sub-Saharan Africa, excluding countries with current conflict, because these regions within Africa have high prevalence rates of undernourishment. While this selection is not representative in any statistical sense, it ensured that we had variation in the key factors we considered. We do not generalize the results of our fieldwork beyond that selection, using fieldwork primarily to provide illustrative examples.

To understand the experiences of other donors with local and regional food procurement and corroborate information gathered in our literature review, we conducted semi-structured interviews with 11 principal WFP procurement officers in Africa and Asia. We focused on Africa and Asia because that is where the majority of food procurement abroad takes place. The 11 we interviewed represented all the principal WFP procurement officers that were in place in Asia and Africa at the time we conducted our fieldwork. We asked each procurement officer a series of open-ended questions on the factors impacting and actions that could be taken to improve: cost, delivery time, quality, market impact, and development. To ensure that the questions were clear and unambiguous, did not place an undue burden on respondents, and that respondents had the necessary information and time to answer the questions, we conducted pre-tests with WFP procurement officers in Sudan and Thailand. To determine which factors and actions were mentioned most frequently, we coded the officer’s responses to the questions. One analyst developed and applied the codes to the interviews and another analyst reviewed both the codes and their application. Based on that coding, we report data on the number of officers that mentioned each factor and action. The views we report are limited to WFP procurement officers in Africa and Asia and may not represent WFP procurement officers in other regions.

In addition, we reviewed economic literature on LRP practices and recent reports, studies, and papers issued by U.S. agencies, multilateral organizations, and bilateral donors. These sources were chosen because they represent a wide cross section of the discussion on LRP and are written by the leading authorities and institutions working in the field.

In the four African countries that we selected for fieldwork—Kenya and Uganda in East Africa, South Africa in southern Africa, and Burkina Faso in West Africa—we met with U.S. Agency for International Development (USAID) and other U.S. officials; World Food Program (WFP) country office staff; and representatives of nongovernmental organizations (NGO), smallholder farmer groups, and commodity exchanges. We also visited several sites where food aid may be locally purchased and where food aid is delivered.

In Washington, D.C., we interviewed officials from U.S. agencies, including USAID; USDA; the Departments of State, Transportation (DOT), and the Treasury; and the Millennium Challenge Corporation (MCC). We also met with the International Food Policy Research Institute (IFPRI) and the World Bank. In New York, we met with the Rockefeller Foundation, the Alliance for a Green Revolution in Africa (AGRA), and Columbia University. In Rome, we met with FAO, WFP, and the International Fund for Agricultural Development (IFAD). We also met with the U.S. Mission to the UN (USUN) in Rome and several bilateral donors’ permanent representatives to the Rome-based UN food and agriculture agencies. In addition, in Washington, D.C., we convened a roundtable of 10 experts and practitioners—including representatives from academia, research organizations, multilateral organizations, NGOs, and others—to further delineate, based on our initial work, some of key issues and challenges to the implementation of LRP.

To examine the impact of LRP on the efficiency of food aid delivery, we focused on the cost, delivery time, and quality. To evaluate LRP cost efficiency, we compared WFP’s costs with USAID’s. WFP’s costs are based on WFP’s procurement data from 2001 to 2008 and USAID’s costs are based on USAID’s Line 17 reports from fiscal year 2001 to 2008. We did not evaluate the impact of prepositioning on U.S. food aid costs, although we did not exclude the commodities shipped from prepositioning sites, albeit small in value relative to overall U.S. food aid for the time period we examined. WFP’s procurement data include information on the commodities purchased, the date of the purchase, the origin of the commodities, the recipient of the food aid, the contract terms, and the purchase prices. To assess the reliability of the data, we (1) reviewed existing documentation related to the data sources and (2) interviewed WFP and USAID officials familiar with the data sources. Accordingly, we determined that the data were sufficiently reliable for the purposes of this report. Since WFP’s procurements are under different contract terms, the purchase prices include different costs. For example, most of WFP’s international procurements are under the term free on board (FOB), which normally does not include ocean shipping and handling. USAID’s data include the costs for commodities and ocean shipping and inland transportation, storage, and handling (ITSH). To make the costs comparable, we included different USAID cost components depending on the contract terms of the corresponding WFP purchase. See table 4 for details of the corresponding WFP contract terms and USAID cost components.

For each WFP purchase, we searched for a “match” in USAID’s data. A match is defined as a purchase transaction of a similar commodity, in the same quarter of the same year, for the same recipient country. The commodity groups we selected are beans, corn soy blend (CSB), maize, maize meal, rice, sorghum/millet, vegetable oil, and wheat, which represent the majority of food aid for both WFP and USAID. We aggregated the more detailed commodities in USAID’s data. For example, we aggregated many types of beans (red beans, kidney beans, black beans, pinto beans, and other beans) into the bean commodity group. We compared the WFP’s per metric ton cost with its match of USAID’s cost. See table 5 for the number of matches in our analysis, which occurred for 8 commodities out of approximately 37,000 transactions from 2001 to 2008.

We compared the costs by region (sub-Saharan Africa, Asia, and Latin America) and by procurement type (local, regional, and international). To account for DOT cargo preference reimbursements, we reduced USAID ocean freight costs from 25 to 35 percent and found that it did not change our results significantly. Based on previous GAO work, we consider 25 percent to be a reasonable value to account for cargo reimbursements over the 8-year period. We analyzed the percentage of WFP transactions that had lower costs than USAID’s and the cost differential. See fig. 8 below for a histogram of cost differential comparison.

The cost differences between U.S. food aid and LRP of similar food products, around the same time frame, and for the same countries we identified represent potential cost-saving opportunities. However, many factors can reduce or even eliminate the amount of savings, including whether food is available in the local and regional markets, and how much additional purchases in these markets will drive up prices. We discussed this methodology at the expert roundtable we conducted, and the experts indicated that our methodology was sufficient in controlling for various factors that may influence costs to make the costs comparable.

To evaluate the impact of LRP on delivery time, we relied on interviews with WFP officials and representatives from various organizations we met with during fieldwork in the four countries we visited. In addition, WFP generated delivery time for 10 countries in sub-Saharan Africa that we selected by procurement type. The countries that we selected had received food aid purchased or donated internationally, as well as through LRP. Our analysis of the aggregate delivery time consisted of the average of the median delivery times for each of the 10 countries across the four procurement types. To evaluate the impact of LRP on the quality, we interviewed U.S. agency officials, WFP officials, and NGO representatives. We reviewed assessments of WFP local and regional procurement. We discussed with WFP the methodology it used in order to generate the delivery time and the limitations of the methodology. We determined the data are sufficiently reliable for our purposes. We chose to use WFP data because they included a substantial amount of both international and local and regional procurements. We did not compare WFP’s delivery time to U.S. in-kind delivery time. We also did not evaluate the impact of prepositioning on U.S. food aid delivery time.

To examine the impact of LRP on the economies of countries where food is procured, we relied on the responses of WFP procurement officers to our semi-structured interview questions; our economic literature review of LRP practices, reports, studies, and papers’ and our interviews with WFP, U.S. government, NGO, World Bank, and private-sector officials in Washington, D.C.; Rome; and the countries we visited for fieldwork in sub- Saharan Africa. We also discussed our preliminary findings on the potential market risks, market intelligence, and development benefits associated with LRP at our expert roundtable and received validation and further input.

To examine U.S. legal restrictions that could affect U.S. agencies’ use of LRP, we reviewed U.S. programs authorized in the 2008 Farm Bill, the Food for Peace Act of 1961, the Foreign Assistance Act, and the 1954 Cargo Preference Act, as amended, and appropriations for fiscal years 2002 to 2008. To better understand agency interpretations of applicability of cargo preference, we collected information from USAID, USDA, and DOT officials with regard to U.S.-flag vessel availability, compliance thresholds, notwithstanding authority, and application to international organizations.

The information on foreign law in this report does not reflect our independent legal analysis but is based on interviews and secondary sources.

We conducted this performance audit from June 2008 to May 2009 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: Key Donor Initiatives That Support LRP

The following is a summary of some of the key donor food security initiatives in recent years, many of which support LRP. (See fig. 9.)

Appendix III: Delivery Time by Procurement Type in Ten Selected Countries

To evaluate the impact of local and regional procurement on delivery time, we relied on lead time data provided by WFP for 10 countries in sub- Saharan Africa that we selected, all of which had received locally and regionally procured food aid and food aid donated internationally. The delivery time (also referred to as “lead time”) reflects the number of days elapsed between the date of the purchase order and the date WFP took possession of the food in the recipient country. The data cover the period from 2004 to 2008.

As shown in figure 10, international in-kind donations took the longest time, averaging 147 days. Local and regional purchases took on average 35 and 41 days, shortening the lead time from international donations by 112 days and 106 days, respectively.

Appendix IV: Illustrative Example of U.S. In-kind Food Aid Compared with LRP

Vegetable oil (fortified)

Vegetable oil (unfortified)

Issue call forward or

April 2009 Commodities may not be identical. For example, the protein level for U.S. wheat flour may be different from the wheat flour from Kazakhstan. Soybean vegetable oil from the United States is fortified, while cotton seed oil from Russia is not fortified. Yellow peas were provided from the United States, and lentils were provided from Russia.

U.S. in-kind food aid was a USAID Single-Year Assistance Program funded through Title II of the Food for Peace Act. LRP was funded through USAID’s 2008 supplemental appropriations.

Appendix V: Results of Interviews with WFP Procurement Officers

To identify factors that could limit the efficiency of LRP, steps WFP has taken to improve the efficiency of LRP, and factors that limit or strengthen the positive development impacts of LRP, we conducted semi-structured interviews with 11 WFP procurement officers in Africa and Asia.

Figure 12 lists the factors that WFP procurement officers reported limit the efficiency of LRP and steps they identified could improve and ensure the efficiency of LRP.

Strengthening agricultural infrastructure includes actions such as provision of raw materials or establishing bagging and processing facilities.

Figure 13 lists factors that limit the positive development impacts LRP could have and actions to improve or strengthen such impacts. The WFP procurement officers discussed topics, some of which we had identified as factors affecting food security in a previous report, namely, agricultural productivity, rural development, and governance, as shown below. Officers also discussed specific characteristics of WFP business practices.

Agricultural productivity. Several officers reported that small farmers’ lack of access to inputs and markets or the underdeveloped nature of agricultural markets more generally limits their ability to create positive development impacts with LRP. Up to seven officers suggested actions to improve agricultural productivity. For example, the Thailand officer suggested actions to support small farmers in Laos by providing training on the corn soy production process. The Pakistan officer suggested strengthening agricultural markets by establishing seed nurseries.

Rural development. Two officers indicated that poor rural development, such as inadequate land holdings or inadequate access to information in remote areas, limits their ability to create positive development impacts with LRP. However, eight officers suggested actions to strengthen rural development through, for example, providing equipment to dry grain or educating communities on food fortification.

Governance. Several officers noted that due to the relatively small size of LRPs, particularly those conducted through WFP’s P4P program, their ability to result in positive development impacts are limited and ultimately depends on whether local governments also have sound agricultural policies in place that support LRP.

WFP business practices. Four officers mentioned that imperfect market impact information is a challenge to creating positive development impacts with LRP. Four officers discussed the importance of market impact monitoring. Two officers also suggested changes to WFP business practices, such as merging LRP with the P4P program.

Appendix VI: GAO Literature Review of Selected Studies on the Use of LRP

This appendix summarizes selected studies on LRP, including several analytical studies conducted by WFP to assess its use of LRP in sub- Saharan Africa (see table 6). The studies describe the types of markets and the trading environment in which LRP is conducted, as well as the impact of LRP on local markets and the extent to which those markets are integrated; the studies also provide an estimate of savings achieved through LRP. The first study in the table presents the types of questions that should be addressed when undertaking LRP. The remaining studies can be reviewed with these questions in mind.

The report proposes a number of questions that should be asked when making decisions about LRP.

What kind of supply response will the LRP market have?

Can traders supply the demand without price increases on the local market?

Is the market integrated with other supply markets so traders have incentive to import additional food into the market?

What is the local price relative to the import parity price (IPP)? Should both of these prices include all costs?

Do local traders behave competitively? Can traders exercise market power by raising prices so as to extract most of the gains from transfers?

What is the likelihood of supply disruptions or delays due to breach of contract, insufficient storage capacity, supplier inability to deliver on contract terms, government interference (such as export bans and currency controls), and logistical bottleneck?

Study: Food Procurement in Developing Countries, World Food Program, Executive Board, First Regular Session, Feb. 2006, Rome.

Report summarizes other WFP studies on LRP in Bolivia, Burkina Faso, Ethiopia, Nepal, South Africa, Uganda, and Congo.

The vast majority of WFP operations is in response to emergencies and has wide fluctuations in needs.

WFP’s food purchasing tends to be irregular and unpredictable, which seriously limits its ability to contribute to market development.

WFP has not had success in procuring directly from farmers and farmer groups. The case studies indicate that supporting farmers and farmer groups has mixed results and may lead to higher prices paid, higher administrative costs, more contracts, and greater risk of default. In many low-income countries, national market intelligence systems are weak, and reliable and timely data are not available.

Often, it is not the cost of the food, but the management costs associated with local procurement in surplus-producing regions where there is little or no market infrastructure that is prohibitive. These management costs include monitoring and supporting the completion of contracts, the costs and risks of contract default, and risk of inadequate food quality.

Study: World Food Program Local and Regional Food Procurement-An Analytical Review (Ethiopian Case Study), Final Report. Addis Ababa: June 2005.

Year: 2001-2004

Country: Ethiopia

Commodity: Corn and wheat In 2003 there would have been a cost savings of $78 per ton on locally purchased wheat and corn.

Based on analysis in 1996-2004, 60-70 percent of the markets are integrated.

Producers receive 75 percent of retail price in Addis Ababa, leaving a 25 percent retail margin.

Ethiopia’s grain marketing system is constrained by lack of access to financial resources, inadequate infrastructures, poor roads, inadequate access to market information, storage facilities, lack of standards and grades, high transfer costs, and nonfulfillment of delivery options. Traders deal with small annual volume and do not hold grain in storage for seasonal arbitrage.

Delivery of the product is a real challenge, particularly ensuring the quality of the product delivered. Rejection of delivery for failure to fulfill quality standards is frequent.

Since traders do not keep stocks on hand, contract default is a problem when traders are unable to procure the proper amount or quality at the expected price.

Default occurs if traders get a better offer; there are problems with traders not honoring their commitments. Transport shortages and tariff increases hinder timely delivery.

Study: Local and Regional Food Procurement in Uganda an Analytical Review, A study report prepared for the Economic Analysis and Development Policy Unit in the Strategy, Policy and Program Support Division of the World Food Program, Serunkuuma and Associates Consult, June 2005.

Year: 2001-2004

Country: Uganda

Commodity: Corn and beans In 2003, WFP spent $12 million less on corn and beans purchased from Uganda than if it had imported these commodities.

While imports from the United States and South Africa may cost less at port, added inland transportation costs made them more expensive than LRP. LRP delivered food to beneficiaries in 3 months while international procurement delivery took an average of 6 months.

Locally, in 2003, 7 of 8 markets in Uganda appeared integrated. Regionally, Uganda markets were integrated with Tanzania markets but not with Kenya markets.

WFP contracts require higher quality than locally traded corn—high moisture content and is subject to rot.

Poor post-harvest practices, storage facilities, and equipment such as dryers and shellers affect quality of final product leading to high post-harvest losses and increased costs to clean the grain.

Intensification of local purchase contributed to reduction in corn exports.

Supplies still come from a small number of companies or farmer groups, suggesting high concentration and potential for monopolistic behavior. Lack of sufficient storage capacity and access to bank loans without WFP contracts are constraints to smaller traders. High cost of borrowing and unavailability of long-term finance are additional constraints.

Many traders enter into contracts with WFP before they have stock, putting them at a higher risk for contract default. This also adds pressure on markets because large quantities are purchased in a short period of time, which may lead to drastic price changes.

Study: Food Aid Procurement in South Africa: an Analytical Review of WFP Activities; Nick Vink, Thulasizwe Mkhabela, Ferdie Meyer, and Johann Kirsten; April 2005.

Year: 2001-2004

Country: South Africa

Commodity: Corn

In June 2003, farmers received 53 percent of the retail value of corn meal.

During the period of analysis, WFP’s unit price for maize was above South Africa’s average prices. This difference in price may be due to the transportation differential, contract delivery terms, and the exchange rate. Traders charge a $5-$10 risk premium to account for the time that elapses from submitting a tender to receiving an award.

While WFP has been active in buying corn in the South African market, WFP purchases represent a very small portion of the market—1/5 to 3/4 of a percentage point of the gross value of South African agricultural production.

South Africa has a functioning futures commodity market called the South African Futures exchange (SAFEX), which was established after deregulation when the corn board was abolished.

Purchase prices are determined by comparing SAFEX prices to the IPP, which is the representative price for purchases on the world market.

Study: Democratic Republic of Congo Food Procurement Assessment Mission Euateur, Katanga, Orientale, North Kivu and South Kivu Provinces; World Food Program; May 2007.

Years: 2001-2006

Country: Democratic Republic of Congo

Commodity: Corn and pulses There is no continuity in WFP purchases; quantities vary significantly from year to year.

There are zones of food insecurity alongside zones considered food-secure. Factors hampering production and purchases include the following:

Poor road and rail infrastructure;

Excessive official and unofficial (illegal) duties and taxes;

Disruptions to the trading system, which are often/mainly political, such as Lack of permanent market buyers; Lack of storage, drying, cleaning, milling, and bagging facilities; Lack of access to seeds and fertilizers; Lack of substantial storage or stocks available; Limited facilities for cleaning, drying, and milling;

Quality problems, including moisture content, infestation, and losses due to poor storage.

Study: Impact of WFP’s Local and Regional Food Purchases (A Study Case on Burkina Faso) Final Report Submitted by Institut de Sahel Comite’ Permanent Inter-Etats de Lutte Contre La Secheresse dans le Sahel, Mali.

Year: 2002-2005

Country: Burkina Faso

Commodity: Corn, corn meal, sorghum, and cowpea

During the period it took an average of 34 days between the invitation for tender In 2004, prices paid for corn by WFP were lower than the IPP in 6 of 7 LRP operations. The price differential ranged from 43 to 72 percent of prices paid by WFP. and the signing and implementation of the contract.

Suppliers stated that there were delays in WFP payments.

WFP purchases did not change the level of integration between markets.

Market participants indicated that WFP purchases resulted in price increases of between 5 to 10 percent.

Many organizations intervene in local markets unexpectedly and without prior consultation, simultaneously purchasing large quantities. Such activity contributes to price increases and should be harmonized.

WFP contracts were concentrated to a limited number of suppliers. There were 15 suppliers, and 3 of them received more than half the payments made.

Other organizations enter the market with food aid purchases, contributing to price increases. Donors should coordinate.

Study: Local and Regional Food Aid Procurement: An Assessment of Experience in Africa and Elements of Good Donor Practice, David Tschirley, and Anne Marie Del Castillo, Michigan State University International Development Working Paper No. 91, 2007.

Year: 2001-2005

Country: Kenya, Uganda, Zambia and Mozambique

Commodity: Corn and corn/soy blend The report cites an analysis by Clay, Riley, and Urey to compare estimated costs of food aid from the United States with LRP in three countries. LRP was 66 percent less expensive than in-kind donations for all commodities. LRP cost 61 percent less for corn and 52 percent less for corn soy blend.

Compared local prices to import parity prices, 2001-2005.

Local purchase saved the United States nearly $68 million. These savings would allow 75 percent more food aid to be provided.

The results were mixed. WFP paid a 10 percent premium in Kenya from 2001 to 2005, an 18 percent premium in Uganda from 2001 to 2004, and the local market price from 2000 to 2005. In Zambia, WFP paid the local price over the period. Some evidence shows that LRP contributed to price surges in Uganda in 2003 and Niger and Ethiopia in 2005 to 2006.

Contract default is a major risk of LRP.

Limited pool of qualified traders with certified financial capacity, access to physical infrastructure, and trading experience.

Most sales remain concentrated in a very small number of trading companies and larger farmers.

WFP instituted a program of direct procurement from small farmers.

Assessments suggest that this approach is expensive, time-consuming, and unreliable, and has little developmental impact. Food quality is a risk of LRP. In Kenya, at least two documented cases of aflatoxin poisoning from infected corn resulted in dozens of deaths.

Study: The United States’ International Food Assistance Programs: Issues and Options for the 2007 Farm Bill, Christopher B. Barrett, February 2007.

Year: 2007

Country: United States

Commodity: Not applicable; general discussion of U.S. food aid

On average, LRP is 66 percent cheaper across all commodities than direct purchase. 36 percent of U.S. food aid shipments to Ethiopia, Kenya, and Tanzania from 1998 to 2002 cost less than comparable local market purchases. The study mentions timeliness of LRP versus direct shipment.

Local and regional purchases are not always simple, available, or effective everywhere.

Some markets are too thin to absorb a significant increase in commercial food demand without driving up prices.

Quality control, transport capacity, and trader market power limit donors’ procurement options.

Even taking freight and administrative costs into account, it is sometimes cheaper to import food aid from the United States. Legislative restrictions on food aid program result in added costs, delayed deliveries, and reduced cultural appropriateness of commodities. These costs are attributable to restrictions placed on food aid with respect to shipping, bagging, and processing. These restrictions include the tying of food aid to domestic procurement of commodities, minimum volumes, minimum nonemergency volumes, value- added minimum, bagging minimum, cargo preference, restrictions on use of ports, monetization requirements, and overhead reimbursement for operational agencies.

Study: The Development Effectiveness of Food Aid: Does Tying Matter? Organization for Economic Cooperation and Development, 2006

Year: 2002-2003

Country: Various donating and recipient countries

Commodity: Wheat, corn, cornsoy blend, vegetable oil, and rice

Analysis of food aid transactions by a representative group of 16 donors and 15 selected recipient countries. The study looked at resource transfer efficiency (RTE) by comparing the cost of direct aid transfers with the hypothetical cost of an alternative commercial transaction (ACT). The actual cost of direct transfers was on average 50 percent more than local food purchases and 33 percent more than food procured in third countries. The range of difference in costs varies widely among donors, commodities, mode of transport and destinations—from 10 percent below to 55 percent higher than the cost of alternative commercial imports.

While LRP generally cost the least, its cost-effectiveness varied widely. LRP in Africa— Ethiopia, Malawi, Zambia, and Kenya—appeared to cost the least. LRP in India, Jordan and Mauritania cost more than LRP in Africa. The highest costs for LPR were in Haiti.

Comparison includes international transport costs to the same destination, The ACT equates to the import parity price (IPP); therefore, local purchase would not be efficient if the overall cost exceeded the IPP. Therefore it would be expected that LRP costs would be less than IPP or most cost-efficient. LRP is the least-cost alternative. For purpose of study treated all direct transfers of food aid as de facto “tied.” overland transport cost to the point of border entry for land locked countries.

Comparison does not include internal transport from port or borders to point of distribution, handling, and/or internal storage.

Calculations do not account for transaction costs of organizing and importing food products.

Appendix VII: Comments from the U.S. Agency for International Development

The following are GAO’s comments on the U.S. Agency for International Development letter dated May 15, 2009. 1. Our recommendation to systematically collect evidence on LRP’s adherence to quality standards and product specifications does not preclude such collaboration as part of efforts, consistent with our 2007 recommendation, to develop a coordinated interagency mechanism to update food aid specifications and products to improve food quality and nutritional standards. We agree with USAID that including actions to collect evidence on LRP’s adherence to quality will make ongoing efforts to improve food quality more efficient. 2. In providing information on agencies’ interpretations of cargo preference requirements as they pertain to LRP, we sought to identify areas of ambiguity where agencies disagree on the applicability of these requirements. We did not attempt to adjudicate the differences in interpretation among the agencies involved. However, in technical comments to a draft of this report, DOT changed its position regarding thresholds and now concurs with USAID’s interpretation, thus eliminating this issue as an area of ambiguity. This is reflected in the final report. 3. See comment 2. 4. We modified text to reflect USAID’S agreement with DOT’s definition of vessel type.

Appendix VIII: Comments from the U.S. Department of Agriculture

The following are GAO’s comments on the U.S. Department of Agriculture’s letter dated May 15, 2009. 1. To obtain an overall picture of costs, we worked to ensure that we had the largest number of procurement transactions, over the longest possible time period for which we had data so some aggregation was required. We acknowledge the variations in the cost differentials in figure 4 that provides the range of differences between USAID and WFP local procurement in sub-Saharan Africa. Our analysis demonstrated consistent results across 8 years of data. For example, 95 percent of local purchases in sub-Saharan Africa cost less than USAID commodities to the same country procured at around the same time. We did not differentiate the prepositioned commodities in the cost comparison, but they were included in our data. However, they represented a small part of U.S. food aid during the period of time that we examined. 2. The issue of quality is one that many WFP procurement officers and others we interviewed identified as a challenge for LRP. However, the lack of systematically collected data makes it difficult to objectively analyze how LRPs adhere to quality standards and product specifications and whether LRP differs in quality from U.S. commodities. Our first recommendation addresses the issue of quality, which would also include improving nutritional standards. 3. We added information to clarify MARAD’s role as the determining agency of “fair and reasonable rates” but note that DOT interprets its role as the sole agency responsible for determining U.S.-flag availability. 4. While we recognize that there is no widespread evidence of LRP causing adverse impacts in markets, we believe that there is a preponderance of information to show that in many developing countries there is a lack of reliable market information. Widespread evidence of any impacts, adverse or otherwise, will not become available in many countries until market intelligence systems are made more reliable and widely used. Therefore, it is important to focus on the potential risk for adverse impacts on markets in areas where LRP is practiced.

Appendix IX: Comments from the U.S. Department of Transportation

The following are GAO’s comments on the U.S. Department of Transportation’s letter received May 22, 2009. 1. Although further analysis of LRP practices would be useful, we believe that the results of our analysis demonstrate consistent results over 8 years of data, with 95 percent of local purchases in sub-Saharan Africa costing less than USAID commodities to the same country around the same time. Although we did not differentiate prepositioned commodities in our cost comparison, they were included in our data analysis. However, it is important to note that prepositioned commodities were a very small part of U.S. food aid during this time period. Nonetheless, we recognize that prepositioning can affect delivery time, which was the case in the Tajikistan example where prepositioned food from Jacintoport shortened delivery time. Additionally, DOT questioned an illustrative example we used in this report on potential cost savings in purchasing wheat in Ethiopia because it believed the country had severe shortage in 2002. Although there may be limited capacity for local procurement, disasters are often localized, and there may be surplus regions within the country or in nearby countries. This is precisely a rationale for LRP. In fact, WFP purchased 74,000 metric tons of wheat in Ethiopia locally in the last quarter of 2002, and the average price was lower than wheat procured from the United States. 2. Ocean shipping is one of the many stages in food aid procurement and delivery. While DOT found that the ocean transit time from a prepositioning site averaged only 24.5 days, trans-Atlantic shipping, which account for majority of U.S. food aid to sub-Saharan Africa takes longer. Therefore, the ocean transit time DOT provided in its letter does not represent the typical U.S. food aid delivery time. In addition, other stages of food procurement and delivery add time to the entire process. In order to do a fair comparison of delivery time among various procurement types and to ensure comparability in the procurement and delivery stages, we identified countries that had received significant amount of LRP and international food aid from the WFP. Although the breakdown of the different elements in the delivery time might be useful (which we could not do from the data provided to us by WFP), it does not change our finding that LRP to these countries took less time than international food aid. 3. Although DOT does implement cargo preference statutes through regulation, the regulations often contain ambiguities that have required resolution through a MOU. Our report describes new ambiguities that could arise in applying cargo preference in the context of regional procurement. We believe that these ambiguities need to be resolved— and can be resolved—by updating the MOU. Further, there is no requirement that establishing regulation precede an MOU nor does a MOU preclude the issuance of new regulation. The updated MOU, establishing consensus among the relevant agencies, could be reflected in any future regulation that DOT may draft and get finalized through the rule-making process.

Appendix X: Comments from the World Food Program

The following are GAO’s comments on the World Food Program’s letter dated May 15, 2009. 1. The issue of quality is one area that many WFP procurement officers we spoke with mentioned as a challenge in local and regional procurement. In addition, quality is an area of concern expressed by organizations such as the U.S. Wheat Associates. However, the lack of systematically collected data makes it difficult to objectively analyze how LRPs adhere to quality standards and product specifications. Our first recommendation addresses this issue. 2. In our report, we explain several of the efforts that WFP and others have taken to significantly improve the availability and reliability of market intelligence in developing countries. Yet, as WFP’s own documents state, in many low-income countries national market intelligence systems are weak and unreliable, and timely data are not always available, which may limit the effectiveness of WFP’s market intelligence efforts. 3. We modified text, adding language in the report to explain that the use of import parity prices to determine when to switch from local procurement to regional or international procurement may be constrained. Specifically, in some countries, commodity prices may be so much lower than import parity prices that it would take substantial price increases to reach the import parity price threshold. 4. We recognize that WFP’s market position in many countries is very small (less than 1 percent in Burkina Faso, for example) and we state that in the report, noting that this limits the effects that LRP can have on prices. Also, recognizing that it is difficult to demonstrate an absolutely causal relationship between a discrete WFP local purchase and a discrete price increase, we note that LRP, when combined with other market interventions, unreliable market intelligence, poorly functioning and unintegrated markets, and other factors, has the potential to cause price hikes and reduce consumers’ access to food. Therefore, we recommend improving the reliability and utility of market intelligence in order to guard against the risks associated with a lack of reliable market information.

Appendix XI: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the person named above, Phillip Thomas (Assistant Director), Sada Aksartova, Kathryn Bernet, Carol Bray, Ming Chen, Debbie Chung, Lynn Cothern, Martin De Alteriis, Mark Dowling, Etana Finkler, Katrina Greaves, Kendall Helm, Joy Labez, Andrea Miller, Julia A. Roberts, Jerry Sandau, and David Schneider made key contributions to this report.

Related GAO Products

International Food Security: Insufficient Efforts by Host Governments and Donors Threaten Progress to Halve Hunger in Sub-Saharan Africa by 2015. GAO-08-680. Washington, D.C.: May 29, 2008.

Foreign Assistance: Various Challenges Limit the Efficiency and Effectiveness of U.S. Food Aid. GAO-07-905T. Washington, D.C.: May 24, 2007.

Foreign Assistance: Various Challenges Impede the Efficiency and Effectiveness of U.S. Food Aid. GAO-07-560. Washington, D.C.: Apr. 13, 2007.

Foreign Assistance: U.S. Agencies Face Challenges to Improving the Efficiency and Effectiveness of Food Aid. GAO-07-616T. Washington, D.C.: Mar. 21, 2007.

Darfur Crisis: Progress in Aid and Peace Monitoring Threatened by Ongoing Violence and Operational Challenges. GAO-07-9. Washington, D.C.: Nov. 9, 2006.

Foreign Assistance: Lack of Strategic Focus and Obstacles to Agricultural Recovery Threaten Afghanistan’s Stability. GAO-03-607. Washington, D.C.: June 30, 2003.

Foreign Assistance: Sustained Efforts Needed to Help Southern Africa Recover from Food Crisis. GAO-03-644. Washington, D.C.: June 25, 2003.

Food Aid: Experience of U.S. Programs Suggest Opportunities for Improvement. GAO-02-801T. Washington, D.C.: June 4, 2002.

Foreign Assistance: Global Food for Education Initiative Faces Challenges for Successful Implementation. GAO-02-328. Washington, D.C.: Feb. 28, 2002.

Foreign Assistance: U.S. Food Aid Program to Russia Had Weak Internal Controls. GAO/NSIAD/AIMD-00-329. Washington, D.C.: Sept. 29, 2000.

Foreign Assistance: U.S. Bilateral Food Assistance to North Korea Had Mixed Results. GAO/NSIAD-00-175. Washington, D.C.: June 15, 2000.

Foreign Assistance: Donation of U.S. Planting Seed to Russia in 1999 Had Weaknesses. GAO/NSIAD-00-91. Washington, D.C.: Mar. 9, 2000.

Foreign Assistance: North Korea Restricts Food Aid Monitoring. GAO/NSIAD-00-35. Washington, D.C.: Oct. 8, 1999.

Food Security: Factors That Could Affect Progress toward Meeting World Food Summit Goals. GAO/NSIAD-99-15. Washington, D.C.: Mar. 22, 1999.

Food Security: Preparations for the 1996 World Food Summit. GAO/NSIAD-97-44. Washington, D.C.: Nov. 7, 1996.