Nelson. b.were the project objectives/key associated outcome targets revised during implementation? No

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1 Public Disclosure Authorized IEG ICR Review Independent Evaluation Group Report Number: ICRR Project Data: Date Posted: 06/01/2016 Public Disclosure Authorized Public Disclosure Authorized Country: Indonesia Project ID: P Appraisal Actual Project Name: Id-urban Water Project Costs (US$M): Supply And Sanitation L/C Number: Loan/Credit (US$M): Sector Board: Water Cofinancing (US$M): Cofinanciers: Board Approval Date: 07/28/2009 Closing Date: 12/31/ /31/2014 Sector(s): Water supply (100%) Theme(s): Water resource management (50%); City-wide Infrastructure and Service Delivery (50%) Prepared by: Reviewed by: ICR Review Coordinator: Ranga Rajan George T. K. Pitman Christopher David Krishnamani Nelson 2. Project Objectives and Components: a. Objectives: Group: IEGPS1 The project development objective as stated in the Loan Agreement, Schedule 1, page 5) and in the Project Appraisal Document (PAD, page 7) was: " To improve and expand water supply services in the project areas by strengthening local water utilities to become operationally efficient and financially sustainable." Public Disclosure Authorized b.were the project objectives/key associated outcome targets revised during implementation? No c. Components: The single component planned to finance water sector improvements in the three local water utilities (Perusahaan Daerah Air Minums or PDAMs). Kota Bogor (estimated cost at appraisal US$9.06 million, actual cost US$8.06 million). This sub-component aimed at providing water sector improvements in Kota Bogor in West Java. Activities included construction of: (i) a new water treatment plant. (ii) two additional units of rapid sand filters with new filter back washing facilities for the existing Water Treatment Plant; (iii) a new water reservoir. (iv) new water distribution pipelines including new household connections; and, (v) implementation of a Non-Revenue Water (NRW) reduction program through installing new meters and replacing old pipelines. Muara Enim (estimated cost at appraisal US$4.15 million, actual cost US$4.02 million). This sub-component aimed at providing water sector improvements in Muara Enim in South Sumatra. Activities included:(i) upgrading new river intakes and building raw water transmission pipelines; (ii) constructing a new Water Treatment Plant (WTP) and upgrading old plants; (iii) constructing new water reservoirs; and, (iv) expanding and rehabilitating the water

2 distribution system to improve service delivery and reduce losses to meet the growing demand for water in the urban areas of Muara Enim and Tanjung Enim. Kuala Kapuas (estimated cost at appraisal US$10.35 million, actual cost at closure US$8.40 million). This sub-component aimed at providing water supply improvements in Kuala Kapuas in Central Kalimantan. Activities included construction of: (i) a new water reservoir; (ii) a new water distribution pipelines including new household connections; and, (ii) implementing a Non-Revenue Water Reduction program. d. Comments on Project Cost, Financing, Borrower Contribution, and Dates: Project cost. The estimated cost at appraisal was US$33.54 million but total cost reported by the ICR at closure was US$29.27 million. Actual project costs in local currency were 99% of the appraisal estimates. However, fewer US$ were spent because of its appreciation against the Indonesian Rupiah (INR). Project Financing. The approved IBRD Loan amount was US$23.56 million. At completion, US$20.49 million was disbursed. US$3.07 million was undisbursed and the Loan remains open. Borrower Contribution. The Borrower's contribution was estimated at US$9.98 million, and at completion their contribution was US$8.78 million. Dates: A Level-2 project restructuring was approved by the Country Director on December 22, It involved revisions to the results framework, revision of original targets and incorporation of a core sector monitoring indicator. The project was completed as scheduled on 12/31/ Relevance of Objectives & Design: a. Relevance of Objectives: High. The project development objectives are highly relevant to Indonesia s development challenges. Despite the high growth rate of the economy in the years preceding appraisal, the water supply and sanitation sector had not kept pace with the country's economic performance. The sector was characterized by low investments and inadequate service coverage with only 28% of the estimated population of 220 million having access to piped water. At the time of appraisal, nearly half of the population in Indonesia lived in urban areas and only about a third (35%) of the urban population had access to piped water. The share of urban population was further projected to increase to 60% by Alongside these challenges, with the decentralization process that started in 2001, responsibility for water sector had devolved from central to local governments. Local water utilities (PDAM's) which were under the jurisdiction of the local governments, were made semi-autonomous. However, most of the water utilities were not financially viable and unable to recoup costs through tariffs. And because central government transfers to local governments for water sector activities were based on their needs and not linked to their performance, there were few incentives for the local governments to either improve service delivery (including water supply) or for generating their own revenues to meet costs. Thus project objectives aimed at improving and expanding service delivery through improving the operational and managerial capacity of the local urban water utilities to move towards financial viability were, and remain, highly relevant. The project development objectives were and remain relevant to the Government Strategy for Indonesia. The National Medium-Term Development Plan issued by the Ministry of Planning for the planning period, aimed at increasing the coverage of population with access to piped water from 28% in 2003 to 40% by The National Action Plans on Clean Water and Sanitation issued by the Ministry of Public Works in 2004 addressed the Millennium Development Goals and Indonesia committed to providing access to safe drinking water and sanitation to at least 50% of the population by In the water sector, the plan included. investment plans to increase access to safe drinking water from 75% to 88% by 2015 and to improve access to piped water from 18% to 62% by The project development objectives were and remain relevant to the Bank strategy at the appraisal stage and continues to be relevant to the Bank strategy for Indonesia to date. The Country Partnership Strategy (CPS) for the period highlighted the need for investment in Indonesia's water institutions to improve services to the poor and addressing the deteriorating conditions of the local water utilities and thereby enabling Indonesia to achieve the Millennium Development Goal targets. The project development objective was consistent with the CPS for the

3 period. Two of the pillars of the CPS were "infrastructure and strengthening the public sector agenda" and "improving health outcomes agenda" through, among other things, increasing access to safe water and sanitation. b. Relevance of Design: Substantial: There is valid causal link between the project activities and outputs and the intended outcomes. The outputs associated with project activities in the three local urban water utilities could be expected to contribute to the project development outcome of improving and expanding water supply services in the three project areas. Although the objective statement included a statement of the means to achieve objectives - by strengthening local water utilities to become operationally efficient and financially sustainable there were no activities to support institutional development and capacity-building in project design because the government would not agree to use Loan financing for technical assistance. To overcome the absence of such project activities, the government agreed that such activities would be implemented through parallel consultancy services financed by counterpart funding (or others), following government procurement procedures. The inclusion of standard water utility benchmarking to measure performance was highly relevant. 4. Achievement of Objectives (Efficacy): " To improve and expand water supply services in the project areas by strengthening local water utilities to become operationally efficient and financially sustainable." There were two objectives: (a) To improve water supply services in the project areas. (b) To expand water supply services in the project areas. Not all the outcomes can be solely attributed to the Bank's inputs because essential institutional support and technical assistance was provided by others in parallel. Objective a: To improve water supply services in the project areas : Substantial. Outputs: 66,567 individual meters were replaced compared to the revised target of 31,350. This included 56,845 meters in Kota Bogor, 6,057 meters in Muara Enim and 3,665 meters in Kuala Kapuas as compared to the revised target of 30,000, 750 and 600 respectively in the three utilities. Technical assistance and capacity-building were provided for specific topics such as Non-Revenue Water (NRW) Programs and Geographic Information Systems (GIS) to the water utilities. Outcomes. The volume of water supply improved: Total production capacity in the three local water utilities increased to 2,935 liter/second at project closure, as compared to the revised and original targets of 3,267 and 2,990 liters/second respectively. The production capacity in the three utilities at project closure was as follows: In Kota Bogor, production capacity increased to 2,050 liters/second at closure as compared to the revised and original target of 2,310 liters. In Muara Enim, production capacity increased to 508 liters/second at project closure, as compared to the revised and original targets of 650 liters and 340 liters/second, and in Kuala Kapuas, production capacity increased to 377 liters/second as compared to the revised and original targets of 307 and 340 liters/second respectively. In all three locations access to piped water increased as discussed under objective (b) below. A social beneficiary survey was conducted after project closure to assess the quantitative and qualitative impact of the project. A total of 409 households were selected using clustered random sampling from the project areas (including 209 households in Kota Bogor, 80 in Kuala Kapuas and 100 in Muara Enim). The main conclusions of the beneficiary survey are as follows. Overall, 74% of households reported improvement in service delivery in the three areas. A majority of survey respondents stated that there were improvement in the services provided by the water utilities in the last three years of the project. The highest was given in Bogor (99.6%), followed by Kuala Kapuas (92%) and Muara Enim (85%). Continuity of supply improved in all locations. Overall, respondents reported water services for about 17 hours a day, as compared to the revised target of 18 hours. In Kota Bogor, respondents had water for 24 hours a day. In contrast, respondents in Muara Enim had water supply for about eight hours a day although this could improve as construction was only completed in early December 2014 and the new system was not fully in operation. In Kuala Kapuas respondents indicated that they had water supply for about 18 hours a

4 day. Water tariffs charged by the three utilities were perceived to be fair and affordable by 87%, 78% and 77% of the survey participants in Kota Bogor, Muara Enim and Kuala Kapuas, respectively. Although the extent to which improved water supply services were realized shows variation in the three project areas, the revised targets were realized. The social beneficiary survey indicates that the project contributed significantly to the objectives of improving water supply and service quality. Improved water utility's performance contributed to achieving project objectives. There were efficiency improvements to water supply services that contribute to utility's financial sustainability although not all targets were fully achieved: The number of employees per 1,000 connections reduced to 7.28 on average in the three local water as compared to 8.58 at the baseline and the target of There was reduction in Non-Revenue Water as a result of the capital investments under the project. Bogor managed to reduce NRW from 38.0% to 33.1%, achieving its original appraisal target of 33.0% but missing its revised target of 29.4%. Kaula Kapuas reduced NRW from 35% to 32.8% missing its original target of 30.0% but exceeding the revised target (34.0%). Muara Enim reduced NRW from 40.0% to 30.3% exceeding its original target (34.0%) but missing the revised one (20%). Financial analyses was conducted at closure to assess the operational efficiency and financial viability of local water utilities. Financial benefits were assumed to come from additional water sales over the 20-year period and from the connection fees collected during the project period, while costs covered investment cost, costs associated with incremental power and chemicals and costs associated with payment of salary and other administrative expenses. The financial performance of Kuala Kapuas and Muara Enim was negatively affected by exogenous factors outside the control of the project, such as higher than expected price of electricity because of increased energy costs. The operating ratio (operating revenue/operating expenses) of the three water utilities improved on average from 1.14 at the base line to 1.08 at project closure, and as compared to the original and revised targets of 1.0. The operating ratio of the three utilities at closure were as follows: The operating ratio for the largest utility Kota Bogor that accounts for 70% of water supply and 74% of all connections by the project, improved from 0.91 in 2009 to 0.76 in Kota Bogor was able to achieve operational efficiency by setting tariffs at cost recovery levels and by reducing operating expenses. They also had a mechanism for automatically adjusting water tariffs every two years. These factors enabled Kota Bogor to reduce its debt to the Ministry of Finance. The operating ratio for Kuala Kapuas improved from 1.31 in 2009 to 1.3 in 2014 and as compared to the original and revised target of 1.0. The ICR (page 21) notes that although Kuala Kapuas is currently on track towards cost recovery, its cost recovery was affected during the project by a long drought in 2010 that led to a significant disruption to their services. The operating cost ratio for Muara Enim remained unchanged from the baseline at 1.2 Objective b: To expand water supply services in the project areas is rated as Substantial. The total number of connections increased by 173,547 as compared to the revised and original targets of 173,808 and 162,238 respectively. In Kota Bogor, the total number of connections increased to 129,312 at project closure, as compared to the revised and original targets of 129,087 and 114,988. In Muara Enim, the total number of connections increased to 27,239 as compared to the revised and original targets of 27,021 and in Kuala Kapuas, total connections at closure increased to 16,996 as compared to the revised and original targets of 17,700 and 23, ,289 new household piped connections - a core indicator added following project restructuring - were provided by project closure, as compared to the target of 26,650. The project achieved 190% of its target. This included new household piped water connections of 42,745 at Kota Bogor, 10,818 at Muara Enim and 4,746 at Kuala Kapuas at project closure, as compared to the revised targets of 10,600, 5,450 and 10,600 for the three local water utilities. Outcomes. Water supply was expanded and the number of people supplied with pipe water increased from 115,258 in 2009 to 173,322 at the end of Targets for the number of project beneficiaries were not set at appraisal and there was no baseline. 5. Efficiency: Substantial. Economic Rate of Return (EIRR): Economic analyses was conducted both at appraisal and at closure for the project component associated with water

5 supply investments in the three areas. These components accounted for 70% of the total project cost. The methodology entailed comparing the project's incremental benefits with incremental costs. The benefits were assumed to come from: (i) increased consumption of water due to improved service delivery of existing customers and accessibility to new customers; (ii) consumer surplus defined as the amount of water consumed with the new connections valued as the difference between the price charged and cost of water without connections; (iii) savings due to improved efficiency; and, (iv) time savings associated with collecting water. The ex post overall weighted average of the Economic Rate of Return (EIRR) was 30% as compared to the ex ante EIRR of 36%. Operational and Administrative Efficiencies. The project was completed within the timeline determined at appraisal despite initial delays. The project was also able to generate savings from the loan amount and used these to finance additional activities, such as new packages for Non-revenue Water Reduction program and new intake and water treatment plant in Kota Bogor, a new reservoir in Kuala Kapuas and new transmission pipeline in Muara Enim. a. If available, enter the Economic Rate of Return (ERR)/Financial Rate of Return (FRR) at appraisal and the re-estimated value at evaluation : Rate Available? Point Value Coverage/Scope* Appraisal Yes 36% 70% ICR estimate Yes 30% 70% * Refers to percent of total project cost for which ERR/FRR was calculated. 6. Outcome: The project was highly relevant to the Government strategy and the Bank strategy for Indonesia and relevance of objectives is rated high. The relevance of design is rated as Substantial. Efficacy of both objectives is rated substantial. The revised targets were met and there is evidence that the project made a significant contribution to improving and expanding the water supply in the three areas. Efficiency is rated as substantial. a. Outcome Rating: Satisfactory 7. Rationale for Risk to Development Outcome Rating: Financial Sustainability : There is a high risk that the ongoing benefits from this project may not be sustained due to the financial non-viability of the local water utilities. At project closure, most local governments still did not allow the local water utilities to set water tariffs at a level commensurate with covering their operating costs. In the absence of such self-financing mechanism, there is high risk that the local water utilities may not provide adequately for meeting the maintenance expenditures and this in turn may contribute to the deterioration of the existing assets and water supply. In addition, there is a high risk that ongoing benefits from this project may not be sustained since there is no mechanism as yet to monitor the compliance of participating utilities with the Performance Agreements. The ICR does not provide information on whether there is an independent authority to regulate the water sector. a. Risk to Development Outcome Rating : High 8. Assessment of Bank Performance: a. Quality at entry: This project implemented by the local water utilities as the final borrowers was the first of its kind in Indonesia. Appraisal benefitted from discussions and experiences of other development partners in complementary activities, such as the Dutch Trust Fund Technical Assistance program (Indonesia- Water and Sanitation Program), water sector activities financed by the United States Aid Agency (USAID), Australia Aid Agency (AusAID) and Japan International Cooperation Agency (JICA) and Sanitation activities financed by the Swedish International Development Agency (SIDA). The implementing agency, which had been the lead agency for executing the prior Bank-financed integrated urban infrastructure project (where water supply was a large component) was

6 knowledgeable regarding Bank procedures and government requirements. Several risks were identified at appraisal including substantial risks associated with delays in project execution due to corrupt practices in procurement and risks that the local water utilities may sanction illegal connections, billing or other corrupt practices. Appropriate risk mitigation measures were incorporated. Although the appraisal recognized the need for an approach combining investments with sector reforms, the project activities were purely capital investments because the Bank knew the government would not use the Loan for technical assistance. To overcome the absence of such project activities, it was agreed at the appraisal stage that such activities would be implemented by the government through parallel consultancy services financed by counterpart funding (or others), following government procurement procedures. In addition the appraisal team obtained agreements on benchmarking to measure performance. There, however, were some shortcomings. The limited capacity of the local water utilities to review technical designs and manage contracts was not identified at appraisal, and this led to the subsequent need to resolve Right-of-Way and railway crossing issues and re-bidding of some procurement packages. Appraisal also overlooked the fact that government rules did not permit multi-year contracts for consultants. Consequently, consultants contracts at all project sites had gaps and all ended prior to the completion of construction activities potentially jeopardizing the quality of civil works. Additionally, shortcomings in M&E design had to be rectified during implementation. Quality-at-Entry Rating: Moderately Satisfactory b. Quality of supervision: There were six supervision missions over a four year implementation period, less than the norm of two missions a year. This shortcoming was further exacerbated by frequent changes to the composition of the team. The Mid-Term Review was conducted in December 2013, a year later than planned and just one year before the completion of the project. This allowed very limited time to make changes. While it failed initially to resolve M&E issues and formulate measures to generate greater and more sustainable outcomes, these were latterly addressed and improved in the last two years of the project. Quality of Supervision Rating : Moderately Satisfactory Overall Bank Performance Rating : Moderately Satisfactory 9. Assessment of Borrower Performance: a. Government Performance: The Government commitment to the project was evidenced by the government addressing issues relating to lending to local governments that facilitated the Board approval for this project. The Government, however, was not fully prepared to help the local water utilities carry out water sector reforms and focused more on physical accomplishments and completion of activities. Even so, the government also provided counterpart funding in a timely fashion including that for its own consultants. It is unclear how far the unwillingness on the part of the Ministry of Public Works to use project funds for consultants constrained the capacity-building of local governments and government utilities. Government Performance Rating Moderately Satisfactory b. Implementing Agency Performance: The Ministry of Public Works was the implementing agency. Having implemented prior Bank financed projects, the agency was knowledgeable with the Bank's financial and procurement procedures and requirements. The project coordinating unit was established in the Ministry to coordinate the input of the local project coordinating units. However, there was poor coordination between the project coordination unit and the project implementing agency, and there was no provision in the project to assign a specific Project Coordinating unit to manage safeguards issues. As a result, there were substantial delays in implementation particularly during project startup on account of the need to rectify technical design, resolve right-of-way and railway crossing issues and rebidding

7 procurement packages in Muara Enim. The lack of technical capacity to comply with the covenants regarding fiduciary and safeguards issues and M&E also delayed project execution. These shortcomings were mostly offset by the commitment of the three local governments and their water utilities as evidenced by their full compliance with project requirements set up by the Central Governments, fulfilling all project readiness requirements and providing counterpart funding (Kota Bogor further expanded water supply investments using own funds). Despite the rocky start, most of the revised outcomes were substantially achieved. Implementing Agency Performance Rating : Moderately Satisfactory Overall Borrower Performance Rating : Moderately Satisfactory 10. M&E Design, Implementation, & Utilization: a. M&E Design: The Ministry of Public Works was in charge of M&E but system design was hindered by the absence of some indicators and links between project inputs and envisioned project outcomes. Some indicators at design did not have baselines or original targets. The lack of plans for capacity-building and institutional strengthening for M&E exacerbated the design problem. b. M&E Implementation: The M&E indicators were not revised in the wake of the Mid-Term Review. While specific persons were put in charge for implementing M&E, they worked only on a part-time basis as they were involved in other local water utility activities. The M&E structure was particularly weak in Muara Enim. Data gathering, documentation and reporting both in terms of implementation progress (technical, fiduciary and safeguards implementation) and achievement of development objectives (results framework) were a major challenge during the first years of implementation. However, intensive supervision to address documentation and reporting significantly improved M&E during the last two years of implementation. c. M&E Utilization: There is limited indication that M&E data were utilized to inform project decisions. The ICR (page 6) notes there are no indications that the M&E design is fully embedded in the institutional structure of the water utilities. M&E Quality Rating: Modest 11. Other Issues a. Safeguards: This project was classified as a Category B under OP/BP 4.10 Environmental Assessment and OP/BP4.12 Involuntary Resettlement was triggered. Environmental Management Plans (EMPs) were prepared for two of the local water utilities and appropriately disclosed (the third water utility did not require EMP since investments there comprised mainly small civil works). Environmental Issues: Potential environmental impacts were addressed during the implementation phase. However, a landslide delayed the completion of source development activities as it required clearing and redesigning of the alignment of transmission pipelines and an access road which consequently introduced variations to the contract and additional investment cost. While the source development was completed it does not yet function because the client counterpart had not yet completed the pipe laying of the transmission pipelines and complications of re-design which included the cutting of the hillside for slope stabilization and the access road. Measures to further manage these were communicated by the Bank to Perusahan Daerah Air Minum (local water utility) management (ICR page 8) but the outcome is unknown. Social Safeguards:. There were two issues during implementation. The first related to the delays relating to the Right-of-Way issues under the Muara Enim sub project where negotiations to use the land for transmission pipes and the railway enterprise took more than two years. The second related to the documentation and reporting issues concerning safeguards related issues including land acquisition in all sites. Even so, the ICR (page 31) reports that

8 the project complied with Bank Safeguard policies b. Fiduciary Compliance: Financial Management: The ICR (page 8) reports that the Interim financial reports and audit reports were satisfactory and of good quality, and were submitted in a timely fashion. The audits were unqualified. Procurement: Procurement risk was rated as high at appraisal because of the limited experience of the local water utilities in conducting competitive bidding in accordance with Bank procedures, the weak environment for procurement and collusive practices in past projects. Several risk mitigation measures were applied including establishment of a procurement plan for the project for the first year of implementation and subsequent annual updates, provision of procurement training and establishment of an anti-corruption action plan which included enhanced disclosure provisions and provisions for transparency. Civil society oversight was set-up to mitigating collusion, fraud and nepotism and through a complaint handling mechanism, sanctions and remedies. The ICR (page 8) notes that there was compliance with World Bank procurement rules. c. Unintended Impacts (positive or negative): d. Other: 12. Ratings: ICR IEG Review Reason for Disagreement/Comments Outcome: Moderately Unsatisfactory Risk to Development High Outcome: Bank Performance: Moderately Unsatisfactory Borrower Performance: Moderately Unsatisfactory Quality of ICR: Satisfactory High Moderately Satisfactory Moderately Satisfactory Satisfactory The relevance of objective is rated as High and that of design substantial. Efficacy of the two objectives is rated as substantial. All the revised targets were realized and there is evidence that the project significantly contributed to improving and expanding the water supply in the three municipal areas. Efficiency is rated as substantial. The ICR rated the quality of the Bank's QAE and supervision as moderately unsatisfactory because it erroneously classified a means (institutional development) to achieve desired outcomes as the second objective that had no indicators or specified outcomes and that these were not monitored or explicitly addressed during supervision. This Review rates both aspects of performance as moderately satisfactory, albeit with some shortcomings. Government performance and Implementation Agency performance are both rated moderately satisfactory. NOTES: - When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006.

9 - The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate. 13. Lessons: The ICR derived four lessons, and the three most important (with editing) follow: (1) A standard project model for urban water supply applied to sub projects with widely differing physical, social and institutional challenges is likely to encounter difficulties. A more nuanced approach is required tailoring inputs to local needs and challenges. (2). The absence of components for institutional reform accompanying public investment may contribute to non-sustainability of outcomes. The gains generated through capital investments generally require explicit reforms to improve the financial and operational capabilities of the local governments and thus project sustainability. (3) Loan agreement should clearly mention or include funding or define funding sources for identified capacity-building activities. In the case of this project, the loan agreement did not provide funding for capacity-building activities and the implementing agencies were expected to cover this cost on an ad hoc basis. 14. Assessment Recommended? Yes No 15. Comments on Quality of ICR: The ICR is concise and candidly discusses the problems that were encountered at the execution phase that affected implementation. It is also clear in identifying factors that were outside the control of the government or implementing agencies. However, the ICR rated the quality of the Bank's QAE and supervision as moderately unsatisfactory because it erroneously classified a means (institutional development) to achieve desired outcomes as the second objective that had no indicators or specified outcomes and that these were not monitored or explicitly addressed during supervision. For these reasons it also rated outcome as moderately unsatisfactory even when the evidence clearly indicates a satisfactory outcome. Given that the projects were in widely variable geographic areas, with differing terrain, population density, geology and input costs, a metric better than absolute unit connection cost for household connections could have been used for assessing the financial performance of the utilities. The information provided regarding Bank supervision and Monitoring and Evaluation is very brief and it would have been useful to have more information on the Non-Water Revenue program. In addition, some reported baseline data and targets differ from those stated in the PAD. Overall, the ICR has moderate shortcomings in its arguments to determine outcome. Fortunately this is not a fatal error as there is sufficient good information to rate relevance of objectives and design and objectively rate achievement of the Loan Agreement's objectives and efficiency. a.quality of ICR Rating : Satisfactory

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