LEGAL ANALYSIS OF THE GEF RESOURCE ALLOCATION FRAMEWORK

This report by the Center for International Environmental Law (CIEL) provides a legal analysis of the Global Environment Facility's (GEF) Resource Allocation Framework (RAF). The RAF uses a GEF Benefits Index (GBI) and a GEF Performance Index (GPI) to determine funding allocations for recipient countries. The study evaluates whether this framework is consistent with the GEF Instrument and the guidance provided by the Conferences of the Parties (COPs) of the conventions the GEF serves, specifically the UNFCCC and the CBD.

• The Resource Allocation Framework (RAF) determines funding through a five-step process using two primary metrics: the GEF Benefits Index (GBI), which measures a country's potential to generate global environmental benefits, and the GEF Performance Index (GPI), which assesses capacity, policies, and practices. For GEF-4, this system applies specifically to the biodiversity and climate change focal areas.
• The GEF Benefits Index for biodiversity (GBIBIO) is criticized for heavily favoring terrestrial biodiversity over marine biodiversity, weighting the terrestrial score at 80% and the marine score at 20%. This structure disproportionately disadvantages small island developing states (SIDS) that may have high marine biodiversity but low terrestrial biodiversity.
• The RAF's application to the Cartagena Biosafety Protocol is found to be inconsistent with COP 8 guidance, which requested that resource allocations be based on country needs and priorities. The study notes that the GBIBIO and GPI criteria have little relation to the specific needs of Protocol Parties, such as risks to domestic agriculture from genetically modified organisms.
• The implementation of the “50% rule—which limits commitments to 50% of a country's total allocation during the first two years of a replenishment—is identified as a failure to conform with COP guidance from both the UNFCCC and CBD to simplify and improve the efficiency of funding processes.
• Regarding the UNFCCC, the RAF generally conforms with guidance on country eligibility by providing a $1 million minimum allocation. However, the study identifies potential future conflicts if the COP prioritizes land use, land-use change and forestry (LULUCF) or carbon capture and storage, as the current GBICC criteria do not account for these.
• The study finds that the GBIBIO fails to account for agricultural biodiversity because it only considers areas that remain uncleared for agriculture or urban settlement. This excludes the needs of countries, particularly least developed countries (LDCs), focused on preserving agricultural biodiversity.
• The GEF's shift of Small Grants Programme (SGP) support from core funding to individual country RAF allocations may have negative implications for the program's viability. While not currently a breach of COP guidance (as no such guidance exists), it forces NGOs and CSOs to compete with governments for resources.
• The report concludes that the GEF is functionally autonomous from the conventions it serves, meaning COPs lack effective legal sanctions to force the GEF to conform to their guidance. Remedies are described as primarily political rather than legal.
• The GEF Performance Index (GPI) is criticized for acting as a proxy for sustainability that rewards countries already possessing high capacity, thereby potentially penalizing LDCs and SIDS that require capacity building to deliver sustainable benefits.
• The study notes that the RAF does not prioritize project types at the portfolio level, but its criteria create a de facto prioritization that favors large GHG emitters in the climate focal area.
• The report identifies that the GBIBIO does not reflect the human dimensions of biodiversity, such as access and benefit sharing (ABS) and poverty alleviation, because it focuses exclusively on ecosystems and species.
• The study suggests that the RAF may hinder regional cooperation by encouraging countries to prioritize individual projects over regional ones to avoid losing their specific allocations.

APA

Wiser, G. M. (2007). LEGAL ANALYSIS OF THE GEF RESOURCE ALLOCATION FRAMEWORK. Center for International Environmental Law. https://www.ciel.org/wp-content/uploads/2015/03/GEF_RAF_analysis_May07.pdf

Chicago

Wiser, Glenn M. LEGAL ANALYSIS OF THE GEF RESOURCE ALLOCATION FRAMEWORK. Center for International Environmental Law, 2007. https://www.ciel.org/wp-content/uploads/2015/03/GEF_RAF_analysis_May07.pdf.

Wikipedia

{{cite report |last1=Wiser |first1=Glenn M. |title=LEGAL ANALYSIS OF THE GEF RESOURCE ALLOCATION FRAMEWORK |publisher=Center for International Environmental Law |date=May 2007 |url=https://www.ciel.org/wp-content/uploads/2015/03/GEF_RAF_analysis_May07.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{wiser2007legal, author = {Wiser, Glenn M.}, title = {{LEGAL ANALYSIS OF THE GEF RESOURCE ALLOCATION FRAMEWORK}}, institution = {Center for International Environmental Law}, year = {2007}, month = may, url = {https://www.ciel.org/wp-content/uploads/2015/03/GEF_RAF_analysis_May07.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }