MCC Serious and Smart About Environmental and Social Impact

As more and more attention is put on implementation delays of Millennium Challenge Account compacts--including it being the principal reason for low Congressional budget allocations--here's an interesting model through which the MCA is trying to remove implementation constraints without sacrificing its principles of performance-based disbursement and adherence to institutional policies.

The MCA model was built on an assumption that the set of eligible countries, because of their strong policy performance, would be ready, willing and able to design and implement their own development programs. In practice, what the MCA is finding is that countries are "ready" and "willing" but not quite as "able" as it may have assumed, particularly with regards to the fiduciary procedures and impact assessments that are critical to program effectiveness and foreign assistance accountability. In a creative move that balances country ownership with MCC guidance to speed up implementation, the MCC's department of Environmental and Social Assessment (ESA) held "ESA College," a week-long event that convened the environmental and social impact representatives from all 10 of the country teams with compacts currently in implementation. For the first half of the week Cheryl Wasserman, associate director for policy and analysis at the US Environmental Protection Agency (EPA) who manages international capacity building, led a course on reviewing environmental impact assessments. Later in the week, they discussed social and gender issues and resettlement. Today (Friday, July 20), the teams are conducting a site visit to Washington, DC's Woodrow Wilson Bridge to look at an example of informal landfills and other environmentally beneficial externalities that were developed in conjunction with the recent bridge rehabilitation project; an interesting case study since infrastructure comprises the bulk of MCC compact projects.
On Wednesday, July 18, ESA College held an outreach event where members of the environmental NGO community were invited to meet the country representatives, hear where they are in their process of environmental and social impact analysis/mitigation, and ask questions. I, along with NGO representatives from the World Wildlife Fund, Conservation International and IUCN-The World Conservation Union attended. Through their stories, country representatives show an MCA model that is:

• Serious: The MCC’s resolve on adherence to its environmental guidelines in the face of push-back from Honduras set an important signal, particularly given pressure to sign more compacts.
• Attentive to sustainability: In response to a question about whether the environmental impact assessments looked at impact analysis for the compact time period only (5 years, in most cases) or if it was projected beyond the completion of funding, representatives from both Georgia and El Salvador said it was critical that they project impact beyond the compact period to ensure the sustainability of their development strategy.
• Adaptable for Impact: Cape Verde provided an example where the results of an environmental impact assessment caused the revision of a project. In their agricultural project they had considered drilling to tap into underground water sources, but concluded it might damage the environment and eliminated it.
• Participatory: Ghana's MCA board has an environmental NGO on it that was selected by the Ghanaian environmental community at large. In terms of social participation more broadly, Ghana has three zonal committees (one for each geographical region of compact activity) that meet quarterly; each has NGO representatives chosen by the community.

I thought the outreach event was a great opportunity for the MCC to showcase the seriousness with which they take environmental and social assessment. The word I’ve heard is that they’re relatively groundbreaking, not necessarily as much in terms of actual guidelines but in terms of follow through and pressure to comply.
ESA College is one of three technical training sessions hosted by the MCC. It joins Procurement College and Monitoring and Evaluation College held earlier this year. These MCC Colleges are a great idea--an operation-specific nuts and bolts complement to MCC University held in the spring. MCC rightly attributes its low disbursement rates and slow start to implementation to underestimated in-country capacity constraints that delay the policy and operational foundations required to proceed to the programmatic components of the compact. Instead of easing up on its requirements in order to speed disbursements, however, the MCC is instead tackling the issue by building a better understanding of its requirements and boosting the capacity to meet them. Though the MCC had taken some earlier steps to streamline pre-implementation processes--publishing guidelines, for example--these colleges provide an improved opportunity for guidance and training, as well as for dialogue (both with the MCC and among implementing countries) and feedback, all while keeping countries in charge of their own implementation.