What is good, and what is missing, in the new World Bank Climate Change Action Plan?

On May 4, the World Bank published a blog inviting civil society  to “Join the conversation on our new Climate Change Action Plan” (CCAP) — until May 18. While the Bank did not share a CCAP draft document, the blog included a link to the 27-slide slide deck from the Bank’s climate change team.  

BIC welcomes a new World Bank CCAP, and from what we see in the slide deck, the CCAP  has many positive elements. It recognizes that climate is central to development and lays out appropriate principles to guide a green transition, particularly that people must benefit from systems transitions, resources need to be mobilized at scale, and natural capital is critical to address climate change. The CCAP commits to a 21 percent increase over FY20 in WBG average share of climate finance (35 percent vs. 29 percent), and perhaps more importantly, it focuses on achieving impact, not just inputs.[1] Also, the CCAP intends to address broader institutional transformation through the adoption of “Country Climate and Development Diagnostics” and integrating climate in national development plans, supporting a ‘whole of economy’ approach. Overall, the inclusion of these elements is positive.  

That said, given the accelerating pace of climate change, the plan does not go far enough, and key elements remain unaddressed, at least as presented in the slide deck. These gaps include:

1. Stop Fossils Funding: What will the Bank do not only to improve its climate programs, but to stop supporting fossil fuels, particularly through indirect means such as policy finance, financial intermediaries, investment guarantees, and technical assistance? Will the Bank revise its Development Policy Financing policy to prevent future subsidies to fossil fuel production and consumption? These are key questions since we know that the Bank has provided some $12 billion in financing that supported fossil fuels since the Paris Agreement.
2. Scale up Nature: Given that agricultural and land use change account for almost 25 percent of GHG emissions, how will WBG programs in this area be scaled up to be proportionate to the problem?  IPBES estimates that investment in nature-based solutions could contribute around 37 percent of the climate change mitigation needed by 2030.[2] What will the Bank do differently to fully take advantage of the opportunities offered by nature-based solutions, especially as these have been consistently underfunded relative to their potential for both mitigation and adaptation?
3. Metrics: What new institution-wide metrics will the Bank adopt so that impacts of WBG programs are tracked, reported, and used to achieve better outcomes? On the mitigation side, these need to address an increase or conservation of carbon sinks along with emissions reductions, and in adaptation, increased resilience as well as reduced disaster risk. This issue is most critical for forests and land use, as the sector that is often the biggest contributor, and the most vulnerable, to climate change in World Bank client countries. 
4. Inclusion: Although the CCAP mentions taking an inclusive approach, it is not clear how that will be accomplished, and how marginalized communities, including Indigenous Peoples and Afro-descendants, will be incorporated and empowered in the WBG’s climate action. The Bank has administered the successful Dedicated Grant Mechanism for Indigenous Peoples and Local Communities (IPLCs); why is it not proposing to build on this success?
5. Gender: Since harmful climate impacts expose and exacerbate gender inequalities, the CCAP (and all Bank activities and outputs) should explicitly address joint climate/gender issues, including the potential contribution of IPLC women in climate action. It’s not clear how gender will be integrated in the new CCAP. 
6. Global advocacy: The Bank previously acknowledged the need for it to play the role of explainer and advocate for strong climate policies, including carbon pricing. Although carbon pricing is mentioned as part of the whole-of-economy approach, the need for continued advocacy remains and deserves stronger recognition and commitment.
7. Paris Alignment: The CCAP commits the Bank to 100 percent Paris alignment by 2023, and for IFC/MIGA by 2025. For this to be credible, the Bank needs to share more detail on its approach and how it will explicitly target a 1.5C pathway. 
8. Transparency for climate finance targets: For each project, the Bank should report what sub-components are counted as climate finance within the project information documents. This would help promote transparency around how new and larger climate finance targets are being met.

Finally, there is the issue of process: one of the reasons we and others have such a list of questions and concerns is that no draft document, apart from the slide deck, has been shared. A two week comment period does not meet the Bank’s own standard for stakeholder engagement. Who actually knows what’s in the new World Bank Climate Change Action Plan? Until we see the document, that may be the biggest unanswered question. 

For a full review of the World Bank CCAP slide deck, see our slide by slide commentary here.

See also: joint CSO letter to World Bank President David Malpass on the call for a 'whole of institution' World Bank Group approach to climate action.

[1] The World Bank Group in FY20 exceeded its target of 28 percent of its finance providing climate benefits. The WBG also committed in December 2018 to provide $133 billion of its own resources for climate action in 2021-25, or an annual average of $26.6 billion. This compares to $21.4 billion provided in FY20, an average increase of $5.2 billion or 24.3 percent in dollar terms above the FY20 level. The higher increase in dollar terms reflects the Bank’s projected growth in its overall portfolio.

[2] Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) is an independent intergovernmental body established by States to strengthen the science-policy interface for biodiversity and ecosystem services for the conservation and sustainable use of biodiversity, long-term human well-being and sustainable development. It was established in Panama City, on 21 April 2012 by 94 Governments. It is not a United Nations body, but the United Nations Environment Program (UNEP) provides secretariat services to IPBES. See here for more information on IPBES.