Climate Change Risk Mitigation by U.S. Foreign Assistance Agencies

Climate Change Risk Mitigation by U.S. Foreign Assistance Agencies

Climate Change Risk Mitigation by U.S. Foreign January 5, 2021
Assistance Agencies
Nick M. Brown
Many in Congress have a keen interest in climate change, and determining how best to address
Analyst in Foreign
that issue is a source of continuing discussion. Gaining increased attention in such discussions are
Assistance and Foreign
federal efforts to reduce the risks of a changing climate by planning for and adapting to projected
Policy
climate change, both in federal agency operations and in achieving agencies’ respective missions.

Emily M. Morgenstern
Specifically, U.S. foreign assistance agencies—the U.S. Agency for International Development
Analyst in Foreign
(USAID), the Peace Corps, the Millennium Challenge Corporation (MCC), and the U.S.
Assistance and Foreign
International Development Finance Corporation (DFC)—are considering how climate change
Policy
may affect both overseas programming and internal operations. For example, USAID requires

climate assessments at each stage of its program cycle to help ensure that potential climate
change or variability does not put development gains at risk. The Peace Corps considers how

climate change may affect volunteers’ physical safety.
Congress provides funding for and conducts oversight of the foreign assistance agencies’ efforts to mitigate the risk of
climate change primarily through annual Department of State, Foreign Operations, and Related Programs (SFOPS)
appropriations measures. Some Members in the 116th Congress have introduced legislation that would codify certain aspects
of this work. Although some recent legislation has been considered and passed by one chamber, no stand-alone legislation
has been enacted. Congress may consider what role it will play, if any, in supporting or directing agency efforts to mitigate
the risk of climate change in the future.
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Contents
Introduction ..................................................................................................................................... 1
Foreign Assistance Agency Operations and Programs .................................................................... 3
USAID ...................................................................................................................................... 3
Agency Operations.............................................................................................................. 3
Overseas Programming ....................................................................................................... 5
Peace Corps ............................................................................................................................... 7
Millennium Challenge Corporation .......................................................................................... 7
U.S. International Development Finance Corporation .............................................................. 8
Issues for Congress .......................................................................................................................... 9
Funding Oversight ..................................................................................................................... 9
Codification of Efforts to Mitigate the Risks of Climate Change ........................................... 10
Climate Resilience, Agency Sustainability, and Environmental Risk ..................................... 10
Interagency Coordination ......................................................................................................... 11

Figures
Figure 1. USAID Country Strategy Risk Assessment Matrix ......................................................... 6
Figure 2. USAID Country Strategy Climate Risk Assessment Process .......................................... 6
Figure 3. USAID Project and Activity Climate Risk Assessment Process ...................................... 6

Contacts
Author Information ........................................................................................................................ 12

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Climate Change Risk Mitigation by U.S. Foreign Assistance Agencies

Introduction
Congress has demonstrated continued interest in how U.S. foreign assistance agencies address
climate-related issues. To mitigate the risk of climate change for both internal agency operations
and foreign assistance programming, Members have provided related funding and directives in
regular Department of State, Foreign Operations, and Related Programs (SFOPS) appropriations
measures.1 Members have also pursued oversight mechanisms, including reporting requirements
and Government Accountability Office (GAO) audits.
In addition to congressional efforts in this area, several executive orders have guided agencies’
efforts to mitigate climate change risk. On October 5, 2009, President Barack Obama issued
Executive Order (E.O.) 13514, which mandated a whole-of-government strategy to reduce
greenhouse gas emissions and included plans for each federal agency.2 On November 1, 2013,
President Obama directed federal agencies to take actions “to enhance climate preparedness and
resilience” under E.O. 13653. Section 5 of the order directed agencies to develop plans that
integrate climate change into agency operations and overall mission objectives. Specifically, these
plans were required to include a number of components, including the potential impacts of
climate change on the agency’s ability to accomplish its mission, operation, and programs; how
the agency would address those impacts; and the cost associated with such actions. Finally,
focusing on foreign assistance agencies specifically, President Obama in 2014 issued Executive
Order 13677, “Climate-Resilient International Development.” This policy requires all agencies
engaged in international development to integrate climate resilience considerations into their
overseas work.3
Although the Donald J. Trump Administration has continued several of these policies, it has
rolled back or rescinded others. The Administration extended federal planning to increase energy
efficiency and reduce greenhouse gas emissions. However, the Council on Environmental Quality
(CEQ) within the Executive Office of the President no longer requires—but still encourages—
smaller agencies, including those profiled here, to develop sustainability plans.4 The
Administration terminated government-wide climate preparedness and resilience efforts by
rescinding E.O. 13653, but E.O. 13677 remains in place.
Foreign assistance agencies have adjusted planning and operations as a result of these actions,
though their interpretations of the executive orders have differed. These agencies, which appear to
have stopped updating their annual sustainability plans in 2017, have terminated planning efforts
to mitigate the risk of climate change to agency operations. However, several agencies continue
to assess climate change risk as they design programs.

1 Traditionally a foreign assistance authorization bill would provide for the spending of monies on the various U.S.
foreign assistance priorities. However, a comprehensive foreign assistance authorization has not been completed in
more than 30 years. As such, the annual SFOPS appropriations legislation has been the primary legislative vehicle for
foreign assistance policy.
2 Executive Order 13514, “Federal Leadership in Environmental, Energy, and Economic Performance,” 74 Federal
Register 52115-52127, October 5, 2009. President Obama later revoked the order and replaced it in 2015 with E.O.
13693, “Planning for Federal Sustainability in the Next Decade,” which expanded on the E.O. 13514 requirements.
3 Executive Order 13677, “Climate-Resilient International Development,” 79 Federal Register 58231, September 26,
2014 (E.O. 13677).
4 Council on Environmental Quality Office of Federal Sustainability, Implementing Instructions for Executive Order
13693: Planning for Federal Sustainability in the Next Decade (revoked), June 10, 2015, p. 8,
https://www.sustainability.gov/pdfs/eo13693_instructions.pdf; Council on Environmental Quality Office of Federal
Sustainability, Implementing Instructions for Executive Order 13834 Efficient Federal Operations, April 2019, p. 5,
https://www.sustainability.gov/pdfs/eo13834_instructions.pdf.
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This report focuses on agencies’ planning to reduce the risk of climate change for operations and
programs; it does not include analysis of programming aimed at addressing developing countries’
own climate risk. Specifically, this report discusses how the foreign assistance agencies—the U.S.
Agency for International Development (USAID), the Peace Corps, the Millennium Challenge
Corporation (MCC), and the Development Finance Corporation—are addressing climate change
in their respective internal operations and overseas work planning. The report also discusses key
issues that may be of interest to Congress as it considers future funding for and oversight of these
activities. These issues include options for congressional input, the relationship of climate risk to
other priorities such as environmental degradation, and responsibilities for climate risk
management within and among U.S. foreign assistance agencies.
Agency Terminology
The fol owing compilation of climate change terms commonly used in executive agency publications is provided to
help Congress understand agencies’ terminology in policy and strategy documents. These terms may be defined
differently in other CRS reports. 5
Adaptation: Adjustment in natural or human systems in anticipation of or in response to a changing environment
in a way that effectively uses beneficial opportunities or reduces negative effects.6
Climate Change: Persistent change in climate, including normal climate variability, over decades or longer.7
Climate change mitigation: Actions that result in net reductions in greenhouse gas concentrations in the
atmosphere.8
Climate risk: The potential for negative consequences due to changing climatic conditions. Climate risk consists
of individual climate risks—potentially severe adverse consequences for development programs (or for humans
and social-ecological systems) resulting from climate-related hazards interacting with vulnerable societies and
systems exposed to climate change.9
Climate risk management: The process of assessing, addressing, and adaptively reducing climate risks.10
Climate variability: Variations in climate (including the normal highs and lows, wet and dry periods, hot and
cool periods and extreme values) that can refer to day-to-day variability, year-to-year variability, and even decadal-
scale variability.11
Resilience: The ability to anticipate, prepare for, and adapt to changing conditions and to withstand, respond to,
and recover rapidly from disruptions. Unlike adaptation, resilience is sometimes interpreted as meaning a return
to predisruption conditions.12

5 Those definitions are available in CRS In Focus IF11446, Weather and Climate Change: What’s the Difference?, by
Jane A. Leggett.
6 Executive Order 13653, “Preparing the United States for the Impacts of Climate Change,” 78 Federal Register 66824,
November 6, 2013 (E.O. 13653).
7 USAID, 2014. Climate-Resilient Development: A Framework for Understanding and Addressing Climate Change, p.
27, https://pdf.usaid.gov/pdf_docs/PBAAA245.pdf.
8 E.O. 13677, p. 58235.
9 USAID, Climate Change in USAID Country/Regional Strategies: A Mandatory Reference for ADS Chapter 201,
revised April 26, 2017, p. 24, https://www.usaid.gov/sites/default/files/documents/1876/201mat.pdf. (Climate Change
in Country/Regional Strategies).
10 USAID, Climate Change in Country/Regional Strategies, p. 3.
11 USAID, 2014. Climate-Resilient Development: A Framework for Understanding and Addressing Climate Change, p.
27, https://pdf.usaid.gov/pdf_docs/PBAAA245.pdf.
12 E.O. 13653, p. 66824; also cited in E.O. 13677, p. 58235.
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Foreign Assistance Agency Operations
and Programs
USAID
Agency Operations
Although the majority of USAID’s efforts to mitigate the risks of climate change focus on its
overseas programs to help developing countries, the agency has pursued some actions related to
its internal operations. The primary documents outlining these efforts are from the Obama
Administration. According to USAID, the plans referenced below were implemented
successfully, but are now outdated. Therefore, some elements of those plans may not have been
maintained during the Trump Administration.
In 2012, in response to E.O. 13514, USAID issued its Climate Change Adaptation Plan. The plan
“[assessed] climate change risks, vulnerabilities, and opportunities for USAID mission, programs,
and operations; [discussed] USAID’s current and past adaptation activities; and [identified]
agency-level actions to understand and address climate change vulnerability.”13 Operationally, the
plan focused on four areas—assets; infrastructure and support systems; health and safety; and
security. In doing so, it sought to address both the nearer-term effects of extreme weather events
and climate variability and the long-term considerations related to climate change. The plan
identified three lines of effort to address these four areas:
 Partnership with the Department of State. The potential partnership would
focus on adapting operations to make agency assets less vulnerable to climate
change. Together USAID and State would develop an inventory of jointly owned
assets, assess their respective climate vulnerabilities, and determine and
implement actions to reduce those vulnerabilities.
 Climate Smart Missions. USAID missions could request to become “climate
smart.” If selected, a mission would receive funding and technical support to
integrate climate change adaptation into its operations and supported field
programs.
 Training. USAID sought to pursue new trainings or to modify existing trainings
on climate change adaptation related to operations.
In 2014, in response to E.O. 13653, USAID issued a supplement to the 2012 Climate Change
Adaptation Plan. This supplement detailed 35 additional actions the agency would take to
specifically address the E.O. 13653 requirements, some of which have been implemented.14
Actions related to agency operations largely fell within three areas:
 Procurement and awards. USAID sought to streamline its procurement for
climate-related assessments through one central funding mechanism, and to
ensure that the climate-related language it used in its award documents was
consistent. The agency also planned to establish incentive awards to reward

13 USAID, USAID Climate Adaptation Plan, June 2012, p. 3, https://www.usaid.gov/sites/default/files/documents/
1865/Agency%20Climate%20Change%20Adaptation%20Plan%202012.pdf.
14 USAID, USAID Climate Change Adaptation Plan for FY2015, June 2014.
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USAID staff or implementing partners who were leading efforts to adapt to
climate change through project design and implementation.
 Leases and construction. While USAID does not solely manage a majority of
its facilities, the 2014 supplement detailed a number of criteria upon which lease
and construction decisions were to be made.15 In selecting sites for potential
facilities and construction, USAID would use industry methods such as
conducting floodplain mapping, carrying out environmental risk assessments, and
consulting coastal area construction standards. In addition, the agency would
work with the Department of State’s Overseas Building Operations for all co-
located facilities. When negotiating leases, USAID would pursue flexible
agreements that it could terminate if a long-term evacuation became necessary.
 Continuity of operations. Each USAID mission has an Occupant Emergency
Plan (OEP) that includes “procedures for evacuating buildings or sheltering-in-
place to safeguard lives and properties.” The 2014 supplement recognized that
climate change could increase the number and strength of weather events that
might trigger the OEP. To address potential operational disruptions related to
weather or climate events, USAID reported having already increased staff
telework opportunities and established alternate work location plans.
While USAID notes that the 2012 plan and 2014 supplement were implemented successfully, in
viewing publicly available documents, it is unclear how much progress USAID had made before
E.O. 13514 was revoked and replaced in 2015. The Trump Administration revoked E.O. 13653 in
2017.16 In some cases, USAID did not take action as initially planned. For example, according to
USAID Operational Policy, USAID did not create any incentive awards for those who led climate
change adaptation efforts.17 Tracking compliance of other agency actions is more challenging. For
example, mission security and emergency plans are largely not available to the public.
In addition, the way in which the 2012 plan was originally written—using language that gave the
agency broad flexibility to pursue the proposed actions—made it difficult to measure the
agency’s success in meeting its stated goals. For example, the document stated that the agency
would “explore” a partnership with the Department of State. This language enabled USAID (or
the Department of State) to forgo the partnership if the agency determined it was not the preferred
course forward. Although the 2014 supplement generally used more direct language, USAID
continued to build options into its action items.

15 In 2014, USAID solely managed only 15% of its facilities; the remainder were leased or co-located on Department of
State property. Co-location of USAID missions with U.S. embassies was mandated by Congress following the 1998
bombings of the U.S. embassies in Kenya and Tanzania. Like USAID, the Department of State was subject to the
various executive orders. The department has sought to address the risks of climate variability and climate change in its
facilities, but has done so with varied success. For example, the GAO in 2017 indicated that in some instances, the
Standard Embassy Design has been criticized for not being easily adaptable for posts with varying climates and
underperforms in those that are very hot, cold, or humid. U.S. Government Accountability Office, EMBASSY
CONSTRUCTION: State Needs to Better Measure Performance of Its New Approach, 17-296, March 2017.
16 E.O. 13514 was revoked on March 19, 2015, and replaced by E.O. 13693, “Planning for Federal Sustainability in the
Next Decade.”
17 USAID’s Automated Directive System (ADS) details awards in Chapter 491. Last revised in 2016, the policy makes
no mention of climate change. USAID, ADS Chapter 491 USAID Incentive Awards Program, June 13, 2016,
https://www.usaid.gov/sites/default/files/documents/1877/491.pdf.
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Overseas Programming
USAID’s guidance continues to require consideration of climate change issues at each stage of its
program cycle. To manage these efforts, each USAID mission maintains a designated climate
integration lead; the Office of Global Climate Change at the agency’s Washington, DC,
headquarters serves as a resource for operating units seeking additional guidance on climate
change in the context of their development programming.18
At the planning level, an annex addressing climate change risk has been mandatory for all country
and regional development strategies since October 2015.19 Recent country strategies for
Afghanistan, Ukraine, and Zambia, each issued in 2019, have included such annexes. The annex
requirement is in addition to a separately required environmental assessment at the activity level,
which addresses the more proximate impact of agency activities on local ecosystems.20 The risk
assessment framework must address not only the consequences of climate change, but factors that
contribute to it as well, such as greenhouse gas emissions.21 A guidance document provides a
detailed overview of the assessment process, and a separately published toolkit, actively managed
on USAID’s ClimateLinks website, details a four-step process for development of the climate
change annex:
1. Review relevant climate information, including that provided in the
country/region-specific climate risk profiles and, as available, additional climate
information such as existing analyses and assessments.
2. Screen prospective activities for low, moderate, and high risk of negative impact.
3. Incorporate findings into development of the strategy.
4. Document the climate risks identified, how moderate or high risks are addressed
in the strategy, and next steps in the Climate Change Annex.22
Each Development Objective proposed for a country/regional strategy is subject to a risk
assessment based on a standardized matrix (see Figure 1). For low-risk objectives,
documentation of the risk assessment is all that is required, while for moderate- and high-risk
objectives, a fuller treatment of climate risk mitigation (CRM) is required (see Figure 2). USAID
recommends a qualitative assessment to determine risk levels, because uncertainty about the
magnitude and likelihood of climate impacts makes them difficult to quantify.
During implementation of a country strategy, development projects and activities may be
proposed across a number of sectors (e.g., education, nutrition, and maternal and child health). A
similar climate risk assessment process must be undertaken for each of these sectors, including
under low-risk development objectives (though the documentation requirements for these are less
strenuous) (see Figure 3).23

18 USAID, Climate Change in Country/Regional Strategies, p. 5.
19 GAO, Climate Change: Activities of Selected Agencies to Address Potential Impact on Global Migration, GAO-19-
166, p. 17, https://www.gao.gov/assets/700/696460.pdf. See USAID, ADS Chapter 201: Program Cycle Operational
Policy, revised 7/23/2020 (ADS 201), pp. 35-36, https://www.usaid.gov/sites/default/files/documents/1870/201.pdf.
20 22 C.F.R. §216.
21 USAID, Climate Change in Country/Regional Strategies, p. 16.
22 USAID, Climate Change in Country/Regional Strategies, p. 11. Climate risk screening tools are available at
https://www.climatelinks.org/resources/climate-risk-screening-management-tool.
23 USAID, Climate Risk Management for Projects: A Mandatory Reference for ADS Chapter 201 (Climate Risk
Management), revised April 26, 2017, p. 11, https://www.usaid.gov/ads/policy/200/201mal.
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Figure 1. USAID Country Strategy Risk Assessment Matrix

Source: USAID, Climate Change in Country/Regional Strategies, p. 9.
Figure 2. USAID Country Strategy
Figure 3. USAID Project and Activity
Climate Risk Assessment Process
Climate Risk Assessment Process

Source: USAID, Climate Change in Country/Regional
Strategies, p. 4.

Source: USAID, Climate Risk Management for
Projects, p. 11.
By contrast, the State Department in 2017 removed a requirement to take climate resilience into
account when developing integrated country and regional strategies, which contribute in part to
USAID and other foreign assistance programming.24 The GAO criticized this removal as
inconsistent with E.O. 13677. The State Department responded that it may recommend revocation
of E.O. 13677 to the White House.25 In the meantime, it has developed new country strategy
guidance to inform missions that they may include a climate risk assessment annex. Although this
guidance has been developed, it has apparently not yet been issued to posts abroad.26

24 GAO, Climate Change Activities, January 3, 2019, pp. 17-18, https://www.gao.gov/assets/700/696460.pdf.
25 GAO, Climate Change Activities, p. 57. The lead for the GAO report described the State Department’s possible
recommendation as “unprecedented.” Justine Calma, “The State Department could gut Obama’s last remaining
executive action on climate change,” Grist, January 19, 2019.
26 GAO, “Recommendations Database,” accessed October 13, 2020, at https://www.gao.gov/reports-testimonies/
recommendations-database/?q=%22Department+of+State%22&field=agency_part_ss&list=1&rec_type=
all_open#results, accessed 10/1/2020.
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Peace Corps
In a 2015 plan for climate change adaptation, Peace Corps described a series of steps to address
climate change risk through operational policies. The agency noted that the “amplification of
extreme climate events in the future” could affect where volunteers are placed. The policy also
noted that programs in some Pacific Islands countries were at risk due to rising ocean
temperatures and attendant natural disaster risk.27 Although the Trump Administration has not
updated this plan, the Peace Corps Manual includes vulnerability to natural disasters as a
consideration in volunteer site selections.28 Many Peace Corps programs now include a climate
lens, such as “climate-smart” practices like volunteers supporting sustainable water management
for agriculture.29 A 2016 Sustainability Plan also described goals to reduce greenhouse gas
emissions and establish sustainability-focused agency operations; the agency terminated its
sustainability program after E.O. 13514 and 13693 were revoked. The agency said it continues to
be guided by the spirit of past sustainability plans.30
Millennium Challenge Corporation
The Millennium Challenge Corporation (MCC) has not integrated climate risk assessments into
its program planning policies to the same degree as USAID. MCC maintains no permanent
overseas facilities, and its country partnerships, known as “compacts,” are statutorily time-limited
to five years.31 As a result, long-term changes in climate conditions may not affect operational
procedures as much as they might for USAID or the Peace Corps, each of which has maintained
uninterrupted presences in certain developing countries since the 1960s. Compared with USAID
and the Peace Corps, MCC engaged in fewer climate preparedness efforts under the Obama
Administration, but it has taken several steps to integrate climate risk in program planning.
MCC in 2012 adopted the Performance Standards on Environmental and Social Sustainability
established by the International Finance Corporation (IFC), the private sector-oriented arm of the
World Bank Group, as part of its Environmental Policy.32 As a result, MCC is to include a climate
risk analysis as part of its recommendation for either approval or rejection of each compact
project proposed. As the IFC revises its environmental guidelines, MCC is to incorporate such
changes into its processes and procedures, if the revisions are determined to be consistent with the

27 Peace Corps, Climate Change Adaptation Plan 2015, pp. 1, 9-10, https://s3.amazonaws.com/files.peacecorps.gov/
multimedia/pdf/policies/2015_Peace_Corps_CCAP.pdf.
28 Peace Corps, Peace Corps Manual Policy MS 270: Volunteer/Trainee Safety and Security, revised 10/1/2019, p. 7.
https://files.peacecorps.gov/documents/MS-270-Policy.pdf.
29 Peace Corps, Climate Change Adaptation Plan 2015, p. 10, https://s3.amazonaws.com/files.peacecorps.gov/
multimedia/pdf/policies/2015_Peace_Corps_CCAP.pdf; Peace Corps, Agency Financial Report FY2019, p. 10,
https://files.peacecorps.gov/documents/open-government/agency-financial-report-fy19.pdf.
30 CRS communication with agency staff, November 5, 2020.
31 MCC may continue to partner with a country under a second compact. Those compacts, though, typically focus on a
different sector, and MCC actively avoids structuring such partnerships as a follow-on.
32 Performance Standards 1, 3, 4, and 6 and associated guidance engage the issue of climate change in particular. The
standards recommend an evaluation of vulnerability to climate change, incorporation of climate analysis into baseline
assessments, and mitigation or adaptation measures, as appropriate. IFC, International Finance Corporation’s
Guidance Notes: Performance Standards on Environmental and Social Sustainability, January 1, 2012, p. 13,
https://www.ifc.org/wps/wcm/connect/9fc3aaef-14c3-4489-acf1-a1c43d7f86ec/GN_English_2012_Full-
Document_updated_June-27-2019.pdf?MOD=AJPERES&CVID=mRQmrEJ; MCC, “Compact Development
Guidance: Environmental and Social Assessment of Projects Proposed During Compact Development,” February 2017,
https://www.mcc.gov/resources/story/story-cdg-environmental-and-social-assessment-of-projects-proposed.
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agency’s own environmental guidelines.33MCC’s 2016 Sustainability Plan asserts the agency’s
commitment to “climate resilient, low carbon, economic development.” This plan includes
encouraging countries to assess climate risks and vulnerabilities as they prepare project proposals,
and incorporating adaptation measures during implementation.34 MCC in 2011 committed to
consider climate change adaptation measures “as appropriate” in overseas projects and
operations. MCC’s Compact Development Guidance includes climate risk as an evaluation factor
for compact proposals.35 While this commitment predates E.O. 13677 and thus does not
specifically refer to it, MCC confirmed that it designed its current environmental procedures to
align with that Executive Order.36
U.S. International Development Finance Corporation
The U.S. International Development Finance Corporation’s (DFC’s) Environmental and Social
Policies and Procedures (ESPP) require a desk assessment of climate vulnerability for all new
investments determined to be high risk, citing the E.O. 13677 requirement to integrate climate
resilience in all development programs.37 These assessments must determine whether projects
have “broad community support” for project-affected people and are posted publicly and given a
60-day public comment period before a decision to invest can be made.38 More broadly, the ESPP
commits projects to be “compatible with low and no-carbon economic development.” The DFC
incorporates the IFC standards by reference—including future revisions to those standards.39
Congressional directives on funding to DFC and its predecessor, the Overseas Private Investment
Corporation (OPIC), have complicated policies toward greenhouse gases. A court case filed in
2005 by a consortium of U.S.-based nongovernment organizations and municipalities against
OPIC alleged that the agency was failing to account for harms to U.S. citizens of greenhouse gas
emissions. OPIC had already begun implementing a greenhouse gas reduction plan prior to
settling the case in 2009.40 The agency agreed to publicly report on projects with more than
100,000 tons of annual CO2-equivalent emissions, and to subject them to a full environmental
impact assessment. In addition, OPIC agreed to reduce its carbon emissions by 20% over 10
years.41

33 MCC, Environmental Guidelines, DCO-2012-1.2, August 26, 2010, p. 11. Further clarification provided by MCC in
email communication, December 1, 2020.
34 MCC, 2016 Strategic Sustainability Performance Plan, June 30, 2016, p. 5, https://assets.mcc.gov/content/uploads/
2017/05/plan-2017001194301-2016-sustainability-performance-plan.pdf.
35 MCC, Compact Development Guidance, p. 51, https://www.mcc.gov/resources/pub-pdf/guidance-compact-
development-guidance.
36 Discussion with senior MCC staff, 10/26/2020.
37 DFC, Environmental and Social Policy and Procedures (ESPP), July 2020, p. 28 (hereafter, “DFC, ESPP.”). For an
example, see https://www3.opic.gov/Environment/EIA/sahofika/ESIA.pdf, p. 309. E.O. 13677, p. 58232. DFC also
conducts periodic site visits on a risk-based prioritization process. DFC, ESPP, p. 25.
38 DFC, ESPP, p. 19.
39 DFC, ESPP, p. 3.
40 See OPIC, Annual Policy Report: Fiscal Year 2008, March 2008, https://edit.dfc.gov/sites/default/files/2019-08/
fy08_annual_policy_report_040809.pdf. Information regarding the Greenhouse Gas/Clean Energy Initiative is
discussed primarily in the “Environmental, Health & Safety Impacts” section on pp. 15-21.
41 OPIC’s settlement agreement, as provided by Environment & Energy Publishing, is available online at
http://www.eenews.net/features/documents/2009/02/06/document_pm_02.pdf. The DFC stated that OPIC completed
the requirements of the 2009 settlement agreement, which expired in 2014. Email response from DFC, October 21,
2020.
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In FY2010, the 111th Congress mandated that OPIC develop a climate change mitigation plan that
would reduce its emissions by 50% over 15 years (P.L. 111-117, §7079(b)).42 The 113th to 116th
Congresses partially reversed course, however, and created an exemption from the climate change
mitigation plan for power generation projects that promote U.S. jobs and exports in lower-income
countries.43 OPIC formally transitioned to become the DFC after enactment of FY2020
appropriations. The exemption did not appear in FY2020 appropriations, but it remains in DFC’s
ESPP because the agency represented to Congress that it would maintain OPIC’s environmental
standards.44 As of June 30, 2020, 63.6% of DFC energy project commitments, by value, were in
renewable energy.45
Beyond these regulatory and policy standards, DFC has engaged in several international
initiatives to improve project sustainability standards, including recognizing climate risks that
may affect its investments. For example, DFC is a leading agency in the Blue Dot Network, a
partnership among development finance donors that seeks to develop global standards for
infrastructure projects. Although descriptions of the initiative refer to other international accords
that include commitments to recognize climate risks, the extent to which the Blue Dot Network
will adopt those commitments remains to be seen.46 As a new agency, DFC is still in the process
of laying out its investment priorities, but its recent actions indicate it may be receptive to such
standards. For instance, the DFC recently announced that it will develop financial instruments
that address the risk of climate change.47
Issues for Congress
Funding Oversight
Congress provides funding for U.S. foreign assistance agencies to address climate issues through
annual Department of State, Foreign Operations, and Related Programs (SFOPS) appropriations.
It is difficult to determine how much each agency spends on climate adaptation within its
operations. Funds for adaptation efforts focused on internal agency operations are largely drawn
from broader operations appropriations accounts. These accounts include USAID’s Operating
Expenses, the Peace Corps and MCC overall budgets, and the DFC’s Corporate Capital Account.
Because adaptation efforts may be a part of larger agency actions, the annual amount spent within
each account is not clear, nor are funding trends over time.

42 This provision of law provided that OPIC shall “issue a report … [including a plan] to reduce greenhouse gas
emissions associated with projects and sub-projects in the agency’s portfolio as of June 30, 2008 by at least 30 percent
over a 10-year period and by at least 50 percent over a 15-year period.”
43P.L. 113-76, §7081(4)(A)); P.L. 116-6, §7062(4)(A).
44 DFC, ESPP, p. 28; Email response from DFC, October 21, 2020.
45 Email response from DFC, October 21, 2020.
46 Charlevoix committed “to respond effectively to extreme weather events and other hazards. We will continue to
support innovative financing approaches, such as risk insurance to strengthen the resilience of vulnerable developing
countries, including Small Island Developing States, and build on existing G7 initiatives.” G7, Charlevoix Commitment
on Innovative Financing for Development, June 2018, p. 3.
47 See, for example, InsuResilience project announced at DFC, “DFC Approves $3.6 Billion of New Investments in
Global Development in Largest Quarter Ever,” press release, September 9, 2020, https://www.dfc.gov/media/press-
releases/dfc-approves-36-billion-new-investments-global-development-largest-quarter. See also a sovereign debt
restructuring program in Kenya with the Nature Conservancy, DFC, “Conserving Kenya’s coastal ecosystems,”
https://www.dfc.gov/investment-story/conserving-kenyas-coastal-ecosystems, accessed 10/26/2020.
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Determining a precise funding level for overseas programming that addresses climate issues is
also difficult. Congress has established directives to address climate issues within regular
appropriations—for example, in FY2020 Congress directed that not less than $135 million shall
be available for sustainable landscapes programming. However, programming to address climate
issues also exists outside the scope of those directives.48 Moreover, tools to measure obligated
funds for these efforts are imprecise because climate issues are often folded into broader
environmental and conservation categories and not measured individually.49 Congress may seek
to amend budget reporting requirements to improve access to information on agency costs related
to climate change risk mitigation.
Codification of Efforts to Mitigate the Risks of Climate Change
Outside of regular appropriations measures that provide funding and some guidance for agency
efforts, efforts to mitigate the risk of climate change have largely been shaped by executive order
and agency policies. This means that the underlying policies could feasibly be changed without
congressional action and, in some cases, without public notification.50
In the 116th Congress, several Members have introduced legislation that would codify current
activities or establish new lines of effort in these areas. Some bills have a narrow focus, such as
those that would address the potential effects of climate change on a specific community or sector
(e.g., displaced persons and refugees, or maritime health).51 Other bills have a broad focus, such
as those that would set policy that would apply to all international development or national
security efforts.52 A few of these measures have made it past committee consideration, and none
have been signed into law.
Climate Resilience, Agency Sustainability, and Environmental Risk
Congress has not enacted a unified statutory framework for environmental assessments,
sustainability plans, or climate risk analyses. Absent such an overarching framework, foreign
assistance agencies have used varying approaches to integrate climate risk into their broader
environmental risk policies. For example, USAID’s climate risk assessments are completely
separate from its environmental reviews. Environmental impact reviews are governed by 22
C.F.R. 216, which dates to 1977 and predates the emergence of climate change as a global

48 P.L. 116-94.
49 A July 2020 GAO report found, for example, that USAID has not consistently reported funding data on indirect
efforts to help countries adapt to climate change. U.S. Government Accountability Office, Climate Change: USAID Is
Taking Steps to Increase Projects’ Resilience, but Could Improve Reporting of Adaptation Funding, 20-555, July 28,
2020.
50 The DFC recently proposed an ESPP change to facilitate investments in new small-scale nuclear power projects. It
initiated a “voluntary” 30-day public comment period, indicating that the agency no longer considered itself bound to a
past requirement of OPIC that revisions may occur only following a public comment period (see P.L. 111-117
§7079(b)).
51 For example, H.R. 4732 would amend the Foreign Assistance Act of 1961 to require the Secretary of State and
USAID Administrator to develop a 10-year “Global Climate Change Resilience Strategy” that would focus on
addressing the needs of displaced persons and those in need of humanitarian assistance, among other efforts.
52 For example, H.R. 7738 would “require the integration of climate-resilience considerations into all development
work of the United States.” Among other requirements, the legislation directs the Department of the Treasury to
establish an interagency working group on “Climate-Resilient International Development” that would aim to support
the inclusion of climate considerations in U.S. development activities, share data and analysis on climate risks in
development contexts, and coordinate agencies’ work with multilateral entities, among other responsibilities.
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concern.53 A separate biodiversity analysis was mandated by Congress in 1986.54 Climate risk
analysis is not statutorily required and is assessed in a wholly separate review from each of these
analyses. The DFC, by contrast, includes climate risk as a subsection of its environmental
policies—aligning with an interpretation in the 2009 court settlement that climate risk is a form of
environmental risk. MCC does not maintain an independent policy on climate risk, instead
addressing it as one risk factor in its project proposal evaluations alongside other environmental
risks.55
Foreign assistance agencies have likewise taken various approaches to align environmental risk
policies with executive orders—in particular, E.O. 13677 (dealing with climate resilience in
development) and the executive orders on federal sustainability. USAID has taken a bifurcated
approach, applying sustainability executive orders largely to operational risk, whereas E.O. 13677
has been primarily applied to programmatic risk. Peace Corps adopted a similar approach,
identifying climate change resilience efforts in programs only in an annex to its sustainability
plan.56 The DFC has taken a different approach. The DFC identifies carbon emissions as an
environmental risk to the “global commons,” as noted above. Unlike USAID, the DFC
additionally requires evaluation of climate risk in its environmental impact assessments—
potentially a result of the long time horizon of DFC investments and its emphasis on hard
infrastructure. Like DFC, MCC sustainability plans connected programmatic climate resilience to
agency sustainability efforts.57
These differing approaches to climate change risks may affect how Congress shapes its oversight
and any legislation related to these efforts. Members may evaluate the relative merits of
statutorily requiring assessment of climate change risks. Members may also evaluate the relative
advantages of a free-standing climate resilience evaluation against subsuming them into long-
standing environmental impact assessments. Moreover, agencies’ application of these mandates
may lead to analytical gaps if not systematically aligned. For example, DFC policy states that it
screens projects for climate risks and vulnerabilities, but it categorizes risk levels of potential
investments based only on potential environmental and social harms of the project, not on risk of
project sustainability from external factors such as the climate.58
Interagency Coordination
Executive order modifications have made officials’ current responsibilities for climate change risk
mitigation unclear, and Congress may consider designating a coordinator for federal sustainability
and climate change efforts. Alternatively, Congress could seek to designate a coordinator for such
efforts across selected foreign affairs agencies only. While E.O. 13834 grants authority to the
Director of the Office of Management and Budget and the Chairman of the Council on
Environmental Quality to administer federal sustainability efforts, responsibilities for
coordinating E.O. 13677 efforts appear to have lapsed. E.O. 13677 established a Working Group

53 USAID, “REG. 216 (22 C.F.R. 216),” June 1, 2020, https://www.usaid.gov/environmental-procedures/laws-
regulations-policies/22-cfr-216.
54 USAID, Foreign Assistance Act Sections 118 and 119 Tropical Forests and Biodiversity Analysis, ADS Chapter 201
Mandatory Reference, July 13, 2020, p. 3, https://www.usaid.gov/sites/default/files/documents/1865/201mav.pdf.
55 Discussion with senior MCC staff, 10/26/2020.
56 Peace Corps, 2016 Strategic Sustainability Performance Plan, June 8, 2015, p. 30.
57 See, for example, MCC, 2016 Strategic Sustainability Performance Plan, June 30, 2016, phttps://assets.mcc.gov/
content/uploads/2017/05/plan-2017001194301-2016-sustainability-performance-plan.pdf, p. 5.
58 DFC, ESPP, pp.4, 29.
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on Climate-Resilient Development under the interagency Council on Climate Preparedness and
Resilience,59 but that interagency council was organized under E.O. 13653, which was repealed
by the Trump Administration.60 It is unclear if the Working Group remains active. The absence of
a policy coordinator for E.O. 13677 may be a contributing factor in agencies’ varying approaches
to E.O. 13677, such as those between USAID and State.

Author Information

Nick M. Brown
Emily M. Morgenstern
Analyst in Foreign Assistance and Foreign Policy
Analyst in Foreign Assistance and Foreign Policy

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59 E.O. 13677, p. 58233.
60 E.O. 13653, p. 66822; Executive Order 13783, “Promoting Energy Independence and Economic Growth,” 82
Federal Register 16094, March 31, 2017.
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