Private capital flows and climate change: Maximizing private investment in developing countries under the Kyoto Protocol Bradford S. Gentry Yale/undp Collaborative Program on the Urban Environment Abstract For a growing number of decision-makers, understanding and building on the links between international private capital flows and climate change is an increasingly critical e≠ort. For developing countries this is true both because (i) private capital is the primary engine of economic growth and, therefore, of sustainable development, and (ii) the Kyoto Protocol has the potential to substantially increase private investment in developing countries. This paper describes the links between private capital flows and environmental performance. It starts by reviewing the recent history of private capital flows to emerging markets.The impacts of environmental issues on investor decision-making are then described. Finally, some initial suggestions are made on ways to integrate environmental and investment frameworks, including under the Kyoto Protocol – with particular attention to the Clean Development Mechanism. Overview Private capital flows and climate change—what are the links? To some in the environmental community, the question has little meaning because they focus on the use of public monies—particularly Official Development Assistance () — when thinking of climate change and developing countries. To others, the answer is easy because the links are all negative. In their view, increased private investment means only expanded industrial activity and natural resource exploitation and, thus, increased emissions of greenhouse gasses and destruction of carbon sinks, such as rainforests. For a growing number of decision-makers, however, the question is neither meaningless nor easy. In fact, it is increasingly regarded as one of the most important questions being asked. From a developing country perspective, understanding the links between private capital flows and climate change is crucial for two major reasons: • Private capital is the primary engine of economic growth and therefore must be recognized as a core driver of sustainable development as well. 187 188 • The Kyoto Protocol has the potential for substantially increasing private investment in developing countries. This paper takes an instrumental approach. It does not attempt to address the scientific, ethical, or political issues surrounding the Kyoto Protocol and its flexible implementation mechanisms. Rather, it assumes a goal of maximizing private investment in developing countries under the Protocol and proceeds from there. The paper starts by reviewing the recent history of private capital flows to emerging markets. The impacts of environmental issues on investor decision-making are then described. Finally, some initial suggestions are made on approaches to integrating environmental and investment frameworks, including ways they might be applied to the Kyoto Protocol. Specific attention is paid to the Clean Development Mechanism. Why the shift in attention from oda to international private capital flows? figure 1 Private Capital Flows to Developing Countries vs. oda 1990 through 1999. Source: World Bank (2000). Global Development Finance 2000. Washington, D.C. (1999 data is preliminary) The numbers are stark and speak for themselves. As shown in Figure 1, transfers of ODA to developing countries averaged around $50 billion per year from 1990 through 1999. At the same time, private investment in developing countries exploded from under $50 billion in 1990 to a high of over $300 billion in 1997. Even with recent financial crises, net private capital flows to developing countries were still four to five times larger than official flows in both 1998 and 1999. As economic recovery picks up pace in many parts of the world, the differential will only increase. In general, the shift from to international private investment as the major vehicle for resource transfers from industrialized to developing countries is a good thing. Developing country governments cannot achieve sustainable development acting alone. They cannot create or provide all or even a majority of a nation’s capital. Rather, as discussed below, their role should be to set and oversee the frameworks for private economic activity, including both investment and environmental factors. The shift does not, however, decrease the importance of effectively applied . Many developing countries have been left out of the global flows of private capital. Between 1990 and 1996, nearly 80% of the private investment in the developing world went to three regions: Asia, Latin America, and Central Europe, and within those, to twelve countries: Argentina, Brazil, China, Hungary, India, Indonesia, Korea, Malaysia, Mexico, Russia, Thailand, and Turkey. While these countries represent a large percentage of the world’s total population, they are few in number. Other developing nations are struggling to increase their share of private flows. Those that have not been successful to date—particularly in sub-Saharan Africa or parts of South Asia—are in serious danger of being left further and further behind economically. To the extent that can be applied to help more developing countries build their capacity for attracting a larger share of global private investment—and weather- 189 ing the storms inherent therein—it is an appropriate and important use of public money. This is especially true in the climate change arena, given the historical roots of the problem in the industrialized countries. In what ways are the di≠erent forms of international investment linked to the environment? International private investment is not all the same—nor are the environmental effects of the different forms. It is important to distinguish among three major components of private capital flows: (1) foreign direct investment (); (2) portfolio equity investment; and (3) debt. Each has different links to environmental performance. Each exhibits different responses to financial crises. Interestingly, the policy recommendations on how to manage private capital flows coming from both the environmental and investment communities seem to be converging, with a focus on predictable and effective legal frameworks, greater access to information, and strategically applied public investment. Foreign direct investment As shown in Figure 2, is the largest and most durable component of private capital flows to developing countries. Typical is investment by a multinational company—either from an industrialized or a developing country—in a local company, either wholly owned or through a joint venture. occurs in many sectors, including resource extraction, manufacturing, infrastructure, and banking. Preliminary data from 1999 suggests that made up 80% of all foreign investment in developing countries. The total amount of going to developing countries is expected to continue to grow in the future. also has the most direct links to environmental performance, as it often goes into production operations. Environmental damage can result from increased land use, increased pollutant loads, and the secondary effects of expanded production (i.e. along transportation corridors or in new settlements). Environmental performance can also be improved, however, through increased efficiency of raw material use, greater attention to the environmental characteristics of products, and more effective protection of sensitive areas. Portfolio equity investment Portfolio equity investment is at the other end of the spectrum, having been the smallest and one of the more volatile components of private capital flows to developing countries, with the least direct—but still critical—links to the environment. It consists of publicly traded ownership shares in private companies, often referred to as stock. While portfolio equity investment in developing countries increased rapidly in the early and mid 1990s, its percentage share dropped markedly before starting a recent recovery. figure 2 Flows of fdi, Portfolio Equity, and Debt to Developing Countries 1990 to 1999. Source: World Bank (2000). Global Development Finance 2000. Washington, D.C. (1999 data is preliminary). 190 Many developing countries have been left out of the global flows of private capital. Between 1990 and 1996, nearly 80% of the private investment in the developing world went to three regions: Asia, Latin America, and Central Europe, and within those, to twelve countries: Argentina, Brazil, China, Hungary, India, Indonesia, Korea, Malaysia, Mexico, Russia, Thailand, and Turkey. The links between portfolio equity investments and environmental performance are less clear and more complex than those for . Initial public offerings of shares in companies () provide new capital to the firms involved, and thus may act like . Later trades in the secondary markets, such as on stock exchanges, can help spur economic growth, with good and bad effects on the environment (e.g. greater political pressure for environmental protection versus increased consumption of environmental resources). Secondary market activity can also help slow economic growth—for example, through the rapid withdrawals from developing countries witnessed over the past few years—with good and bad effects on the environment (reduced consumption versus unsustainable resource use spurred by economic need). Yet, the opportunities portfolio flows present as a point of leverage for environmental policy are vast. Worldwide, portfolio flows of both equity and debt comprise the largest segment of cross-border transactions—55 percent in 1996. Portfolio equity and debt investors hold the purse strings to more money worldwide than is available from any other type of investment source, dwarfing the resources potentially available from . For example, according to the IFC, in 1996 the world’s total market capitalization topped U.S.$18 trillion, far in excess of total global flows of $320 billion. Debt Debt,including both commercial bank lending and portfolio debt instruments (such as bonds), is the third major component of private capital flows to developing countries. In 1999, it appears to have fallen dramatically from its 1997 high of $103 billion, to a low of $19 billion. Interestingly, during the recent financial crises, commercial bank lending was one of the most volatile of all types of private capital flows. Many different types of debt instruments exist, from commercial bank loans to power stations to medium-term bonds issued by large companies. The environmental effects of debt run the gamut from to portfolio equity. Government bonds present the greatest mystery in terms of leverage points for affecting their environmental performance. Some are used to fund improvements in environmental infrastructure. Most, however, go into general government revenues, with potential investors having essentially no reason to consider the environmental performance of the underlying government operations. How does the environment a≠ect investor decision-making – from risks to opportunities, identifying points of policy leverage? Since one can find legitimate examples of private investment being both good and bad for the environment, the critical question is how the opportunities for improving environmental performance can best be captured. One set of answers can be developed by understanding and building on the ways in which environmental factors affect investor decision-making. For , improved environmental performance only happens when it increases the investors’ commercial advantage. In developing countries, this usually occurs for one of five major reasons: • improving access to export markets, such as through the adoption of environmental management systems or the award of product “eco-labels”; • increasing productivity, through more efficient use of raw materials; • maintaining a “social license” to operate, in the face of local and international pressure from neighbors, , shareholders, and customers; • accessing finance, since international financiers increasingly require environmental risks to be addressed and, in cases such as World Bank loans, separate environmental guidelines to be met; • making “environmental” investments, such as in water systems or cleaner energy production. These commercial advantages for foreign direct investors provide leverage points for environmental policy-makers. This is true in both the developing countries receiving the investment and in the countries that are the sources of the investment, which are usually, but not always, among the industrialized countries. When considering how best to use the Kyoto Protocol to increase private investment in developing countries, all of these factors should be considered. Thoughts on how best to build on these links between private capital flows and environmental performance are offered in the following sections. How are opportunities for private investment created and how does this change the role of government? The shift to private investment is also changing the role of many governments, as they move from being the provider of services to being the enabler and overseer of their provision by private parties. Governments enable private investment by setting the frameworks within which private economic activity occurs. Governments oversee private investment by monitoring both the frameworks and the private activity, and taking action when either fails to perform. The basic frameworks for private investment and other market activities include definitions of various property rights, the manner in which such rights may be held or transferred, and how any particular rights may be protected. Only with such basic legal rights in place can private investment flourish. It does so by taking these basic building blocks and arranging them in a myriad of ways that increase the value to potential customers. Many of these arrangements change over time, in ways that are impossible to predict when the underlying property rights are created. This combination of flexibility within an overall market framework allows the creativity of private actors to flourish in ways consistent with societal values. This is where the policy recommendations of the environmental and investment communities come together. Both want clear, predictable, transparent regulatory frameworks, consistently applied. Both want to see ODA used to build the capacity of host countries to adopt and maintain such frameworks. Increasingly, it is in each of their interests to have environmental considerations integrated into national investment frameworks. The concept of market frameworks allowing flexible implementation is also where private investment and the Kyoto Protocol start to come together. One of 191 192 the core roles for governments is to help build demand for private investments, particularly those with positive environmental content. This means developing both market frameworks and mechanisms for internalizing environmental costs. In the context of climate change, setting market frameworks includes defining the range of property interests that may be traded. Internalizing environmental costs means creating demand for those property interests by limiting or reducing allowable emissions of greenhouse gases from operations in industrialized countries. Many developing countries object to the Clean Development Mechanism and the other “flexible” implementation mechanisms provided in the Kyoto Protocol. Some do so because of the unfairness of letting industrialized countries “buy their way out” of a problem they caused. Some are concerned about losing their future ability to develop by selling their right to use the air today. Still others worry that any such trading systems will be so complicated that they will be impossible to administer. These are all serious concerns. At the same time, many of these countries are actively seeking to attract more private investment into other parts of their economies, frequently in operations that exploit other natural resources such as minerals, oil, and timber. Many of the investors in these operations are from industrialized countries. Many of the products from these operations are consumed in the industrialized world. Governments decide the terms on which to make the resources available to investors, either directly through concessions or indirectly through regulatory and tax frameworks. Presumably they do so only when the proposed operations are seen as beneficial to the local economy or when they help meet other governmental objectives. Within this context, host country governments may monitor private activities and take action, should they conclude it is warranted. A similar conceptual approach is appropriate for any sales of interests in reduced emissions of greenhouse gases. It is up to the host countries to determine whether they want to make such property interests available. They should only do so on terms with which they are comfortable. For example, they might choose to allow only relatively short-term interests to be developed and sold. Concerns over differences in bargaining power between governments and international investors might be reduced through efforts to harmonize the types of interests being offered for sale. Even if a developing country decides to make such investment opportunities available, however, the details of the still remain to be understood and negotiated. Some of the issues are scientific—how can the levels of emissions reductions be determined and monitored? Others are legal—how should industrialized countries that violate their emission reduction commitments be punished? The focus of this paper, however, is on how to design the to maximize opportunities for private investment in developing countries. Some principles for helping to achieve this goal are suggested in the following section. How can private investment be maximized through market frameworks and oversight, rather than through centralized approval processes? Article 12 of the Kyoto Protocol defines the basic features of the to include the following: • benefits to developing countries from project activities generating emission reductions; • use of certified emission reductions () by Annex I countries to meet part of their emission limitation and reduction commitments; 193 • development by the Conference of the Parties () and supervision by an Executive Board; • certification of eligible emissions reductions by operational entities, including private and public parties, to be designated by the ; • certification according to specified requirements, including voluntary participation, as well as real, measurable, and long-term benefits that are additional to those that would otherwise occur; • auditing and verification of project activities under rules determined by the ; • use of a share of the proceeds from activities to cover administrative expenses, as well as to contribute to an adaptation fund for particularly vulnerable countries. Although these basic elements must be included in the , whatever form it takes, a huge number of critical details have yet to be defined. How they are reflected in the final structure will make all the difference for the ’ success or failure. For example, much of the process to date appears to have focused on identifying the government body that will approve the trading rights, and how it will do so. The quickest way to strangle the ’ potential for increasing private investment in developing countries is to force all transactions through centralized global, or even national, approval processes. As illustrated in Figure 3, the best way to maximize the ’ full investment potential is through centralized frameworks for the decentralized generation, transfer, and oversight of emission reduction credits. This approach is also consistent with the core government roles of defining market frameworks and then overseeing the performance of a myriad of market actors. Finding a balance between the need to ensure that the terms of the Protocol are figure 3 Centralized approvals versus centralized frameworks for decentralized implementation – implications for investment flows. met and to still leave room for markets to function in a flexible and timely manner is the key challenge for negotiators. Any effort to develop frameworks for decentralized implementation of the needs to consider three major components: • the overarching framework for the ; • methods for maximizing the generation of certified emission reductions; and • methods for maximizing the resources transferred with their sale and use. 194 Each of these components faces a huge number of issues. Some ideas for negotiators are offered in the following sections. figure 4 Credits, resources and maximized private investment. Building the market framework The overall structure of the is the framework within which private investment will occur and be overseen. As illustrated in Figure 4, it starts with the / Executive board defining the rules for granting credits against emission reduction commitments to Annex I country governments. It also requires Annex I governments to put domestic emission reduction requirements in place and to offer credits against those requirements for qualifying investments in developing countries. Until such requirements and credits are in place, private investors will have only limited incentives to invest in . According to Article 12, the Annex I country governments must also provide resources to the , both for administrative expenses and for the Adaptation Fund. If they do not make the required payments, they will receive no credits. These finances would come, in part, from fees paid by the users of Certified Emission Reductions (). It could also include amounts taken from general tax revenues, such as . If participating countries and/or the Executive Board wanted to take a larger share of proceeds directly, they could also seek to impose a tax on all sales of . How to balance the additional administrative burden of collecting such a tax with the desire to allow the markets as many different opportunities as possible for transferring is a critical issue for any such taxing mechanism. The / Executive Board will also set the framework for the creation and trading of the among developers, sellers, buyers, and users. Some of the possible features of these activities are shown in Figures 5 and 6 below. Before moving to these more detailed aspects, however, it is important to return to the goal described in this paper—maximizing private investment under the while meeting the terms of the Protocol. At its core, this means creating predictable and verifiable frameworks that both allow and promote decentralized action by a wide range of parties, public and private. Only by allowing such private sector creativity to flourish will the ’ full potential be realized. Maximizing the generation of cers For developers and sellers of , this requires workable mechanisms for defining and overseeing the property rights to be traded, leaving as much room as possible for flexibility in how the actual trades are conducted. As shown in Figure 5, 195 figure 5 Maximizing the generation of Certified Emission Reductions. this can be done through decentralized certification and verification programs similar to those used under a wide range of international product standards. The basic features of such a system include both certification and verification functions. Both start with and provide a vehicle for implementing rules and guidance from the and the Executive Board across a wide range of individual transactions. For certification of emissions reductions, those rules are initially overseen by national accreditation and tracking bodies (possibly using the national standards organizations already in existence in most countries around the world). Those national organizations will both accredit certifiers and track the certifications made through notices and fees submitted by certifiers. Should a certifier fail to follow the rules, their right to certify would be revoked. Accredited certifiers will be paid by developers (public or private) to review the emission reductions proposed for certification. If they meet the rules set by the / Executive board, a certification will be issued and the may be freely traded. Ideally, such trades should be left free to take a wide variety of forms, including: • sales by developers directly to the ultimate users in Annex I countries (similar to the scenario described above); • sales by developers to brokers and other intermediaries who then locate buyers; or • sales to “pools” of credits, shares in which are offered for sale by public or private parties (similar to the portfolio investment scenario described above). For auditing and verification, a similar basic structure is used, with one major difference: its primary function is to check samples from the certification process, not to approve every . Only if problems are found will more extensive investigations be undertaken. International or national bodies can accredit the auditors. They will then conduct periodic audits to verify that the national accreditation bodies and the individual certifiers are performing their functions as prescribed by the / Executive board. Government inspectors and, possibly, authorized might also provide a supplemental check on the offered for sale. 196 The result is a system for maximizing the generation of that both meet the requirements of the Protocol and are available for trading in a wide variety of ways. Maximizing the opportunities for private investment in cers Such a result clearly fits the needs of potential buyers and users of the , maximizing the opportunities for private investment and resource transfers to parties in developing countries. As shown in Figure 6, the money flows two ways under this structure: first, to the sellers of the (and then up through the national certification chain); and second, to the adaptation fund through the Annex I governments. As noted above, other alternatives also exist, such as a tax on each sale of a . Buyers of would pay the market price directly to the sellers, whether they are developers, intermediaries or pools, public or private. The buyers themselves may be public or private, pools, intermediaries, or even the final users. Ultimately, the will be purchased by those wanting to use them—including Annex I governments and firms needing help meeting their domestic emission reduction figure 6 Maximizing resource transfers. requirements, or and others wanting to force further reductions by taking the emission rights off the market. Users of would then provide notice and pay a fee to an Annex I government in exchange for a credit against domestic requirements. In turn, the Annex I government would make a contribution to the expenses of the / Executive Board and the Adaptation Fund in exchange for credit against its Protocol commitments. As with the certification system, the system of using to meet domestic emission reduction targets would be overseen by internationally accredited auditors. What are the potential benefits of centralized frameworks with decentralized implementation and oversight? Decentralized implementation and oversight within a centralized framework is one of the best ways to maximize private investment under the . It maximizes the opportunities to generate . It maximizes the flexibility among sellers and buyers. It is founded on the requirements of the Protocol. Adherence to those requirements is regularly verified. Will this approach work? It is too early to say. The technical and policy issues facing the creation and monitoring of emissions reductions still need to be addressed. Political issues in determining the substance of the certification requirements, such as the details of the “additionality” rules, still need to be resolved. Even assuming that an approach along these lines is adopted, the capacity of many governmental and private parties to administer such a system effectively will need to be improved substantially. What this approach does do is provide a basis for concrete discussions between developing countries and the private investment community on how the might best engage private investment. Until recently, even if a private financial institution had heard of the (and many have not), it was viewed as too illdefined or far off to be paid much attention. As more concrete approaches are developed, particularly those based on current investors’ conduct, these attitudes are changing and opportunities for dialogue are emerging. Where is progress being made? Little progress has yet been made on the through the formal negotiating process. At the November 1998 - in Buenos Aires, a two-year period for further study was agreed upon. At the October 1999 - in Bonn, a greater degree of comfort with the basic concepts was apparent, but no specific agreements were adopted. The Sixth Conference of Parties, in The Hague in November and December of 2000, will be a critical session for the future of the . Instead, real progress on the design and implementation of trading mechanisms is being made through a series of experiments by private firms, national governments, and multilateral organizations. Included are the: • establishment of internal emission trading programs within multinational production companies such as BP/Amoco and Shell; • development of protocols for third-party certification of CO2 emission reductions by firms such as Ecosecurities and ; production and sale of carbon offset credits by organizations around the world, • from Costa Rica to the State Forests of New South Wales, Australia; • purchases of carbon offset credits directly by electric power utilities (such as Corporation) and indirectly through commodity markets (such as the Chicago Board of Trade and the Sydney Futures Exchange); • formation of investment funds specifically designed to invest in carbon rights such as the World Bank’s Prototype Carbon Fund; and • design of national CO2 trading programs in countries such as the United Kingdom and Norway. These “experiments in social learning” are helping to uncover both the obstacles to and the opportunities for converting the theory of emissions trading into reality on a global scale. They are also starting to provide a concrete foundation for progress on the overall design of the . These “real world” activities help flesh out the possible interior of a “decentralized” mechanism, i.e. the procedures for developing , trading , and maximizing private investment in projects (Figures 5 and 6). 197 198 Where should negotiators go from here? In order to spur more private investment in developing countries, however, governments need to agree on the “centralized” framework for the within which specific trades will occur (Figure 4). Industrialized countries need to impose domestic requirements that enhance the value of investments in developing countries. Developing countries need to adopt both general and -specific frameworks that encourage private investment. Both industrialized and developing countries need to recognize that it is in their mutual self-interest to break through the “chicken and egg” question of who acts first by agreeing to proceed together down the or similar path. Many specific questions about the remain to be answered. Efforts to develop those answers should be undertaken in light of the goal of increasing overall investment, both public and private, in developing countries. Negotiators from developing countries should explore and understand the links between private capital flows and environmental performance, particularly in considering their position on the . Doing so will provide a solid foundation for deciding whether, and if so on what terms, they want to work on designing the to help maximize private investment in their countries. References and suggested readings Beck, T. “Australia Shows the Way,” Environmental Finance. London, U.K.: Fulton Publishing, 2000. Center for Sustainable Development in the Americas. 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Gentry, B. “Foreign Direct Investment and the Environment: Boon or Bane,” Foreign Direct Investment and the Environment. Paris: , 1999. ——, ed. Private Capital Flows and the Environment: Lessons from Latin America. Aldershot, U.K.: Edward Elgar Press, 1998. Gutner, T. International Mechanisms Shaping the Environmental Impact of Transboundary Capital Flows. Washington, D.C.: World Resources Institute, 1998. Institute for International Finance. Capital Flows to Emerging Market Economies: September 29, 1998. Washington, D.C.: Institute for International Finance, 1998. International Finance Corporation. Emerging Stock Markets Factbook. Washington, D.C.: International Finance Corporation, 1996. International Finance Corporation. Investment Funds in Emerging Markets. Washington, D.C.: International Finance Corporation, 1996. Kaplan, M. and J. Mein. Early Start Carbon Emission Reduction Projects: Challenge and Opportunity. Proceedings of the Brazil/U.S. Aspen Global Forum. Institute for Policy Research and Implementation. Denver, Colorado, U.S.A.: University of Colorado, 1999. Pew Center on Global Climate Change. Papers on the . http://www.pewclimate.org. Schmidheiney, S. and F. Zorraquin. Financing Change: The Financial Community, Eco-Efficiency and Sustainable Development. Cambridge, Massachusetts, U.S.A.: MIT Press, 1996. . Carbon Offset Verification Service. Oxford, U.K.: Oxford Center for Innovation, 1999. Toman, M. and J. Hourcade. “From Bonn to The Hague, Many Questions Remain,” Resources (Winter 2000). Washington, D.C.: Resources for the Future, 2000. Werksman, J. and J. Cameron. The Clean Development Mechanism: The “Kyoto Surprise.” Working paper for The Brazil/U.S. Aspen Global Forum, held June 1998, Sao Paulo, Brazil. Washington, D.C.: The Aspen Institute, 1998. World Bank. Global Development Finance 2000. Washington, D.C.: The World Bank Group, 2000. ——.“Environment in Crisis: A Step Back or a New Way Forward?,” East Asia: The Road to Recovery. Washington, D.C.: The World Bank, 1998. ——. Private Capital Flows to Developing Countries: The Road to Financial Integration. Washington, D.C.: The World Bank Group, 1997. ——. “Portfolio Investment Funds—Assessing the Impact on Emerging Markets,” Public Policy for the Private Sector, September. Washington, D.C.: The World Bank Group, 1996. Stuart, M. and L. Fretz. Financial Tools and the Clean Development Mechanism: A Preliminary Working Paper. Prepared for the International Working Group of the , workshop. Buenos Aires (November 1998), http://www.ecosecurities.com/, 1998. 199 200 Bradford S. Gentry is the director of the research program on Private Investment and the Environment at the Yale Center for Environmental Law and Policy, the co-director of the Yale/undp Collaborative Program on the Urban Environment, as well as a lecturer at the Yale School of Forestry and Environmental Studies and the Yale Law School (visiting). He was in private law practice in Boston and London for 15 years. He is now Of Counsel to the law firm of Morrison and Foerster. Professor Gentry’s publications include Private Capital Flows and the Environment: Lessons from Latin America (Edward Elgar, 1998), as well as numerous articles and policy papers. Yale/undp Collaborative Program on the Urban Environment Yale Center for Environmental Law and Policy 285 Prospect Street New Haven, CT 06511 U.S.A. Tel: +1 203.432.9374 Fax: +1 203.432.9375 Email: partners@yale.edu