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MADAGASCAR: ENVIRONMENT PROGRAMME SUPPORT PROJECT
RELEVANCE TO GEF
1. This project is highly relevant to the conservation of biodiversity. In particular, it systematically covers the full range of GEF strategic ecosystems (arid and semi-arid, forest, mountain, coastal and freshwater) in one of the world's highest priority biodiversity countries, containing high diversity, a very high degree of species endemism, and facing severe threats from slash-and-burn agriculture and land hunger amongst marginal farming communities. The urgency for addressing these concerns is paramount and unquestionable, and GEF can provide a key role in this process.
2. The brief given, however, does little justice to the task in hand. Many of the comments below are critical of the design and presentation of the GEF components and of the programme as given. This may be a question of presentation in a very limited brief. Or it may be a question of unclear distinctions between GEF objectives and overall programme objectives and actions. But it may also represent underlying design weaknesses that must be addressed. The sums of money involved in the programme are vast, and as such should carry great weight. But if they are built on poor logic and vision, and an unclear brief, the long-term impacts and achievement of sustainable biodiversity conservation are likely to be questionable.
OBJECTIVES
Problems with the Brief
3. There are a number of general problems with the brief which are dealt with a more detail below. These are:
PROJECT OBJECTIVES
4. This is a very large and complex programme. This makes it relatively easy to be clear about the higher level objectives, as these can be framed in very general terms: biodiversity conservation and sustainable resource use. However, it become more difficult, yet all the more essential because of the scale and complexity of the programme, to be clear about the specific objectives. These objectives are not clear in the brief, either the objectives of the programme, or of the components supported by GEF.
5. Objectives cannot be defined, as they are in the brief, as a set of activities. What will be the expected results of these activities? To what objective will these results contribute? What is the central problem and the central beneficiary which the GEF project is addressing? The only objective framed in the brief is a tautology: "the overall (GEF) objective of helping EP2 fully meet all of its biodiversity conservation objectives". Is the central objective of GEF support, or of the programme, institutional reform and development, or participatory resource management, or regional programming of land management?
6. There must be a central objective, to which all project results contribute, and whose impact can be measured and monitored. The set of project results that are anticipated can then be the subject of a series of targetted activities which are developed in a logical manner. The use of a logical framework would help this process greatly.
PROJECT DESCRIPTION
7. Sustainable soil and water management: no GEF funds
8. Multiple use forest ecosystem management: despite proposing full community participation in design and implementation, the language used remains top-down (e.g. "strategy is to make local communities responsible..." etc); there is no sense of the role of communities in national ecological forestry inventories and zoning; or of the process of participatory formulation of management plans; there is no discussion of the need for local institutional development to assist with this process, or of the mechanisms or policy and legal framework for establishing this; there is no sense of how conflicts between community needs and biodiversity needs will be negotiated or resolved.
9. National Parks and Ecotourism: the large proportion of funds for this component continues to exaggerate the imbalance between "biodiversity" areas, and those subject to community development and local resource management, despite the intention to deal more strongly with rural development nearby and away from formally protected areas. To "ensure effective conservation" (objective ii) by means of improved infrastructure, equipment and staff sounds more like protection rather than ensuring community participation and ownership of new approaches and ideals, and runs counter to the lessons learnt from EP1 and the stated approach. The promotion of ecotourism, likewise, is not portrayed in terms of local benefits or beneficiaries: what will be the policy, legal and fiscal framework for unsuring ecotourism is used to create local incentives rather than enmity?
10. Management within National Parks is often less serious a problem than managing threats from outside National Parks, or more distant, and yet the resources committed to this component are highest of all. This is not discussed within this component, despite the lessons clearly pointing in this direction.
11. Marine and coastal environment: this is a very brief section, yet GEF proposes $2m for field inventories and setting priorities for new conservation areas. Establishment of local level management is mentioned but not developed. In any areas of intervention, what has been the experience in Madagascar, or in EP1, of local community management? Has this been successful, what are the issues to address in communitiy participation, empowerment, and local mangement control? The lessons again point to community participation and local institutional development as being a key part of any intervention.
12. Urban environment: no GEF
13. Local resource management and land tenure security: no GEF
14. Regional programming: the AGIR approach is not spelled out, so this section remains somewhat obscure. Regional programming does appear, however, to be central to the approach of the EP as a whole, and deserves better treatment in the brief, as it encapsulates local participation and empowerment to plan and manage land resources.
15. Regional Fund: no GEF
16. Strategic activities: this section is poorly developed, and receives a relatively smaller amount of support, despite the central nature of an enabling policy and legal framework to all other components of the programme.
17. Support activities: again, the focus of GEF work is on research and survey, whereas the real need is for widespread rural development inititiatives. This does not appear to have a high priority, despite the lessons pointing in this direction.
18. Although GEF funding is used to contribute to most of these areas of activity, it is not always clear what is the overriding logic of GEF intervention in most components. This could be clarified by a more sharply focussed GEF objective. A specific and clear GEF objective would allow improved management and monitoring of effectiveness and impact. As currently expressed, it is not always clear whether these are simply top-up funds for a raft of other activities which are part funded by other donors. Or stand-alone contributions which can be clearly earmarked. In either case, the need for coordination amongst all the donors and stakeholders is paramount.
APPROACH
The Basis of the Approach
19. Throughout the brief, the basis of the approach is not clear, and appears contradictory in a number of cases. These have been outlined above, principally in cases where the analysis and evaluation of EP1 points to the need for institutional support, policy development and rural community development, and yet the GEF programme that emerges for EP2 focuses on PA and forest management, research and information generation.
RATIONALE FOR GEF FUNDING
20. The higher level rationale for funding is based on the value and imminent threat to the country's biodiversity. The more immediate rationale is based on the "significant progress" that has been made over the past 6 years of EP1, and the need for further support to this. However, there is very limited evidence of this progress given in the brief. If the major effort has been towards institutional development, as alluded to in the background section, a more critical and informative evaluation of this progress should be given to justify further support.
SUSTAINABILITY AND PARTICIPATION
21. The programme will promote sustainability through innovative measures to strengthen local community involvement and integration of conservation and sustainable resource use with regional development. Forestry institutions will be revitalised, and root causes of biodiversity degradation will be addressed. These excellent propositions in the brief do not appear to be backed up by a set of institutional strengthening processes and activities which will deliver such sustainability and participation, nor which will convincingly address the root causes of biodiversity loss.
LESSONS LEARNT
22. Comments above indicate the areas in which the brief appears deficient in addressing lessons learnt. These lessons are well presented at the beginning, but become subsequently diffused.
ISSUES, ACTIONS AND RISKS
23. One policy risk highlighted is that government transparency and credible economic reforms can only materialise if the government can overcome internal differences and reticence towards comprehensive reform. And yet this comprehensive reform appears to be a major conerstone of EP2, making this a killer assumption. If comprehensive reform is central to institutional development and new approaches to environmental management, greater assurances about government willingness, leadership and policy backing for the programme must be obtained, and cannot simply be left as a risk. What political backing exists for this programme?
24. Likewise, policies that might discriminate against tourism development cannot simply be left as risks outside the programme, if ecotourism is to be a major potential source of revenue for conservation initiatives. What assurances have there been from GoM that the political and enabling policy backing for such developments will be forthcoming?
25. Institutional uncertainties and competition are also cited as risks outside the programme. And yet the experience of EP1 suggests that in 1994 exactly this happened, with the creation of a separate ministry for the environment. If the institutional set-up is so central to effectiveness and impact of the programme, as it surely is, then much greater government commitment should be in evidence. And if institutional capacity is weak, as is stated on several counts, why is institutional development and strengthening not explicitly and centrally stated in project design. Rather than focussing on the resources, the programme should surely be focussing on the institutions and communities that lie at the heart of effective environmental management. At best, the current brief offers only that institutional analyses are being currently carried out for ONE, ANGAP and others. Why were such analyses not central to the design of EP2?
PROJECT IMPLEMENTATION
26. All implementation arrangements, including monitoring and evaluation, are to be spelled out in an implementation manual. This is highly unlikely to have any impact. Experience with manuals in many institutions is that at best they are difficult and laborious to use, and at worst they remain on shelves. For such complex new approaches, institutional arrangements, planning procedures and processes of change envisaged in the programme, there is unquestionably a need for urgency, leadership, effective implementing teams, and above all a vision which is built and shared at all levels, through effective communication, training, and empowerment. This applies in institutions and local communities, and from senior government officers down to front-line staff. This cannot be achieved by a manual. And it cannot be achieved without a programme of support explicitly aimed at achieving this.
27. GEF will be in a position to facilitate the changes in roles: but how? This is not spelled out at all. There is no budget for this, no programme of institutional reform, no component dedicated to this, no institutional analysis and baseline, no explicit GoM support for this, no indicators and measurement.
BACKGROUND INFORMATION
28. The background information is presented in the form of a country context, which is brief and informative, focussing principally on biodiversity values, and a broad macro-economic and environmental context. There is, however, no background on the social characteristics of the rural population, or the main forces driving the socio-economic strategies of local communities in different land types, classes of wealth, or land ownership. Nor is there any analysis of the key institutions or government policies impinging on the project.
29. The main focus of the background briefing is an evaluation of the first phase of the Environment Programme (EP1). This focusses on certain key lessons: that biodiversity concerns cannot be separated from broader environmental concerns, and these are the product of local and regional land use and land management - therefore decentralised rural development must be a crucial initiative in the programme. It is not obvious that this lesson has been accepted in EP2, as this appears to be given a low priority on resources and effort;
FUNDING LEVEL
30. Comments on the imbalance of proportions of the overall budget allocated to different activities or components are given above: namely, that the focus of GEF funding on biodiversity inventory, site identification and prioritisation, and effective management (does this in fact mean protection?) appears to do little to attack the root causes of biodiversity loss. The key component in this is the programme of regional and district action, which is not developed in the brief but left somewhat cryptic.
31. The amounts involved in all components are very substantial, and without further breakdown of costs it remains difficult to provide any sensible review of the budget.
32. The section of incidental domestic benefits is extremely weak, and seems to illustrate a major weakness with the design: that to address the root causes of loss of biodiversity, these "domestic benefits" should be central to the programme, as a way of building incentives and improved livelihood strategies for local communities, who are the very agents which are leading the changes in land use and loss of biodiversity. The brief currently sees these benefits of the programme as incidental, and limited to some NTFPs and ecotourism revenues. Local communities require both empowerment and strong economic incentives, in the short-term as well as the long-term, to change patterns of land use and livelihoods to accomodate the needs of biodiversity conservation.
33. The section on cost-effectiveness makes little sense, and says nothing about why and how GEF funding will ensure greater cost-effectiveness in biodiversity conservation.
INNOVATION
34. The main innovations offered by such Environment Programmes lie in the attempts made to develop cross-sectoral linkages and intergated planning processes. While there are elements of these in EP2, the GEF contributions to these are not clear. The main focus of GEF actions appears to be in biodiversity inventory, research, planning and protection, all of which are a necessary part of an integrated programme, but none of which are innovative.
STRENGTHS / WEAKNESSES
35. The strengths and weaknesses of the project have been outlined above, and some suggestions have been given for improving the structure and design, which should enable a clearer focus for action, and clearer indicators by which GEF may measure its progress and impact.
COMMENTS FROM TASK MANAGER
36. Programme versus Project. This is a request for a GEF contribution to the funding of the increment to a national programme - to which all donors will contribute - to enable that programme to more fully address the globally significant biodiversity of Madagascar. This is NOT a free-standing "GEF Project". Since it is impossible to separate biodiversity issues from broader environmental issues, and in view of the global importance of Madagascar's biodiversity and the interest of all donors in this, the GEF project was formulated and appraised as a part of the overall environment programme. Specifically, through the pre-investment feasibility study financed under the GEF pilot phase the requirements for addressing Madagascar's biodiversity were defined. However, a key finding of this work was that a biodiversity "component" of EP2 would not be an effective way to address the problems facing Madagascar's biodiversity as these cut across a wide range of environmental activities. Consequently the GEF project was prepared as a true "increment" to the broader environment programme, with biodiversity elements added to many components of EP2 to extend them beyond what Madagasar would do on its own in order to generate additional global biodiversity benefits. Further, through the full participation of all donors in this process, the "incremental" elements to be addressed were shared between a number of donors, including the GEF, in such a way as to ensure the complete financing of the global biodiversity increment without GEF paying the full incremental cost. The result is that every donor, with the exception of the GEF which contributes only to incremental components, is contributing to both baseline and incremental components of the whole programme. The objectives for the GEF contribution form a part of the objectives both for the global biodiversity "increment" and the environment programme as a whole. The process of translating the entire proposal, including both the incremental biodiversity component as a whole, and the limited GEF component, into a limited set of monitorable indicators with corresponding quantified objectives is still on-going (we have a two inches thick report that has to become a two pages table !!!).
37. Balance between Activities. I'll try to better reflect in the brief the fact that there is indeed a deliberate attempt to better balance funding between the protected areas and the rest of the programme. The protected areas programme per se represents only 21 per cent of total cost. A lot of emphasis is being put on forest management through transfer of management responsibility to local communities (the local resource management component and the Forest management component), as well as on the soil-conservation rural-development-type activities at village level.
39. Local participation. The reality of the proposal is that (i) forest management will be transfered to village communities, and a new cadre of "mediators" will be put in place in order to allow villagers to dialogue on a more equal footing with the forest service when negotiation the management plans. This will require a new law, which is being passed, and represents a mojor shift in policy. (ii) The Regional programming cum Regional Fund components are based on the input of so-called multi-local participatory processes, as shown by the diagram in annex to the brief.(iii) villages around protected areas will continue to receive funding at the level of 50% of entrance fees, for them to finance local development projects.
40. Issues and risks. I agree that comprehensive reform is a major cornerstone. The IMF and the World Bank are trying their best to convince political forces in the country that they have to enter into a process of structural adjustment. We are quite sure it will come, we do not know when. There is nevertheless political committment to the environment programme, including at the level of the President himself, as reflected by some of the institutional arrangements (National Environment Council to be attached to the presidency), and it is hoped that this will prevent the 1994 type of situation to appear again.
41. Programme implementation. The word "manual" must be misleading. What we mean is that the Malagasy institutions will put in writing (and thus will have to agree between themselves) all the key implementation arrangements. The manual is only the translation of the process. New features such as decentralization of programming and budgeting or the operation of the Regional Fund will be tested in a pilot operation during the second half of 96, with UNDP funding and technical assistance. The written document is just a vehicle to force addressing the issues before the problems occur.
42. Funding level. See comments above on Programme versus Project. Programme costing is based on detailed preparation reports for each component, detailed review by the various members of the two multi-donor appraisla teams, and compiling data using the standard WB Costab software. There is a LOT of detail available behind the scene.
43. Incidental domestic benefits. I agree the section is week. We are still working on the economic analysis of the problem, trying to quantify the domestic benefits of some of the components in terms of agricultural productivity, timber and charcoal production and the like. The main message is intended to be: some of the benefits (biodiversity) are global, and hence the case for GEF contribution, but there are also many domestic benefits and the Environment Programme is a integral part of the economic development strategy of the country.
FURTHER COMMENTS FROM REVIEWER
42. Following your comments on my first draft review of 21 st May, and receipt of the SAR for the entire Madagascar Second Environment Programme Support Project, I offer these further comments:
43. Many of the queries raised in my review are answered in your comments and in the full SAR. I can only suggest that these are incorporated into your revised GEF Proposal, to make it a stand-alone document that is clear on the points of uncertainty. For example, relating to a number of queries raised, the SAR is clear on socio-economic background, overall NEAP framework, other relevant donors and projects, the programme objectives and outputs, evaluation lessons, the overall development approach, institutional and local community development, the risks and assumptions, programme coordination, its organisation and management, approaches to improving M&E, the intention of the "manual", programme conditionalities, and the ways in which EP2 has evolved and moved on from EP1.
IN RESPONSE TO YOUR SPECIFIC COMMENTS:
44. Programme vs project. I understand that this is not a GEF project. In this case, the programme objectives and outputs should be made clear, and that GEF is simply one of a series of inputs to the programme. However, I remain concerned that GEF would wish to monitor its own contributions, and not simply put money into an overall pot without keeping an eye on how it is spent and what its impact is. In this case, one would expect at least some clear GEF-related outputs with indicators that can be measured and monitored.
45. Balance between activities. If you can reflect a better balance between the work in protected areas and the rest of the programme, this would be good, in particular the emphasis on forest management through transfer of management responsibility to local communities. However, if this balance is not reflected in the overall budget, the balance may be difficult to strike.
46. Local participation. You mention a new cadre of village mediators, and the sharing of revenues with local communities around National Parks. These are new and excellent ideas, and should be emphasised in the brief. The Regional Fund is already mentioned.
47. Issues and risks. If there IS strong political commitment to the new environment programme, the relevant section in the Brief could be rephrased to reflect this more strongly.
48. Project implementation. The queries about the implementation manual, and the coordination of the multi-donor and multi-level activities is well addressed in the SAR, and could be reflected in the Brief.
49. Incidental domestic benefits. The brief could be clarified to show that the intention is for GEF to pay for delivering global benefits (biodiversity), and the rest of the programme pays for delivering local benefits. Neither kind of benefit is incidental.
50. I hope that these comments are of some help. I have had very limited time to do justice to the full SAR, but a very quick read suggests that it has all the essential elements that concern me. The brief would take a limited amount of amendment to clarify these points, and I believe would become a stronger proposal.