17
management was also very time intensive, and the financial and performance reporting as onerous and not straight forward.
85
The differing expectations by donors have created some costs and frustrations. One is that some donors do not seem to realize the disparity in views and agendas within the group, another
is that SC meetings were used for somewhat different purposes and thus did not respond to this variety of expectations. Donors complained that the Bank treated the MDF as its own ATM,
to which one Bank staffer replied that this is what a trust fund is: donors provide funds for the Bank to manage, and it does so using its standard procedures.
86
2. Strong Commitment but Still Less Convincing
The ICCTF model has been pioneering in the field of climate change funds. Indonesia was amongst the first countries to set up a dedicated nationally administered institution to direct
finance to its climate change response strategies, in the context of efforts to implement its national climate change strategy.
87
ICCTF also has become a key financing institution that is recognized at international, regional, national and local levels.
88
During the first phase of its development, the ICCTF has solidified its institutional framework and has become a legitimate financing mechanism to actualize the GOI’s
commitment to create a low carbon economy. To ensure that all of its activities are aligned with national priorities, ICCTF has developed its own Business Plan along with its targets,
investment strategies, priority programmes and proposed activities with budget.
89
85
Id. at 58.
86
Id. at 65.
87
Aidy Halimanjaya, supra note 66, at 34.
88
UNDP Indonesia, supra note 63, at 15.
89
Id.
18
However, with a capitalization of 11.4 million, it is a relatively small source of finance in a country that accesses hundreds of millions of dollars of concessional support from a variety of
donors for climate related purposes.
90
Additionally, ICCTF will need to demonstrate adequate safeguard policies if it wishes to access international funds such as the Adaptation Fund, the
Global Environment Facility, or indeed the Green Climate Fund, as all three now require implementing entities to meet minimum safeguard policy standards.
91
The slow process of operationalizing the fund and reaching agreement raise another problem. The need for senior ministry representatives to sign off on key decisions has also
resulted in delays on decision making process.
92
In practice, very little international funding to support Indonesia’s response to climate change has been channelled through the ICCTF, and there has been little engagement with the
ICCTF as a key domestic stakeholder. Indeed the largest multilateral programs currently active in Indonesia are implemented by multilateral institutions such as the Asian Development Bank
ADB and the World Bank, with little participation or involvement from the ICCTF.
93
3. Problems with the Program Accountability
