L/C/TF Number(s) Closing Date (Original) Total Project Cost (USD) IBRD Jun ,000,000.00

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1 Public Disclosure Authorized Independent Evaluation Group (IEG) 1. Project Data Report Number : ICRR Public Disclosure Authorized Public Disclosure Authorized Project ID P Country Brazil Project Name BR Mato Grosso do Sul Road Practice Area(Lead) Transport & ICT L/C/TF Number(s) Closing Date (Original) Total Project Cost (USD) IBRD Jun ,000, Bank Approval Date 04-May-2010 Closing Date (Actual) 30-Jun-2016 IBRD/IDA (USD) Grants (USD) Original Commitment 300,000, Revised Commitment 299,606, Actual 299,606, Prepared by Reviewed by ICR Review Coordinator Group Victoria Alexeeva George T. K. Pitman Christopher David Nelson IEGSD (Unit 4) Public Disclosure Authorized 2. Project Objectives and Components a. Objectives The (Loan Agreement (p.6) and the Project Appraisal Document (p.6) state that the project development objective was: to improve the efficiency of the Borrower s road network in the Project area b. Were the project objectives/key associated outcome targets revised during implementation? No Page 1 of 14

2 PHEVALUNDERTAKENLBL Independent Evaluation Group (IEG) c. Will a split evaluation be undertaken? --- d. Components 1: State Roads Rehabilitation and Surfacing (appraisal estimate US$360 million; actual US$409.3 million). This was designed to support rehabilitation works for about 750 km of the State s's paved roads and the surfacing of about 450 km of existing unpaved roads, and the introduction of performance-based road rehabilitation and maintenance contracts for rehabilitation and/or maintenance (CREMA) under a pilot to be located in the same areas. 2: Institutional Strengthening (appraisal estimate US$15 million; actual US$10.6 million). This included (i) strengthening of the institutional capacity of the Environment, Science, Technology and Planning Secretariat (SEMAC) to support improved efficient management of public resources; (ii) strengthening of the institutional capacity of the State Environmental Institute (IMASUL) for environmental management; (iii) strengthening of the institutional and planning capacity of the State Public Works and Transportation Secretariat (SEOP) to support the State s transport sector; and (iv) strengthening of the institutional capacity of the State Public Works Agency (AGESUL) to support the road sector. e. Comments on Project Cost, Financing, Borrower Contribution, and Dates Project cost: The total project cost was US$420.7 million at completion, an increase from the estimated US$375.0 million due to the increase in construction costs and inflation. Financing: The IBRD Loan of US$300 million was provided to the Brazilian State of Mato Grosso do Sul with a guarantee from the Federal Government of Brazil. US$299.6 million were disbursed by project closure. There was no external co-financing. Borrower s contribution: The Borrower agreed to finance US$ 75.0 million equivalent. Actual contribution was US$121.1 million to meet the original target of road extension and cover the cost increase. Dates: The original closing date was extended by one year from June 30, 2015 to June 30, 2016 during the Level-2 project restructuring in The extension was due to delays in completion of several key institutional activities. There were two other Level-2 project restructurings: the first one in 2012 was to allocate the unallocated funds; and the second one in 2014 to revise the implementation of modern management tools from SEOP to AGESUL. 3. Relevance of Objectives & Design a. Relevance of Objectives The project objective to improve the efficiency of the State s road network in the context of this project was Page 2 of 14

3 expected from project financial support to selected investments of the state investment program in road infrastructure and activities that sought to strengthen the State Government s overall capacity to manage the road network, including planning preparation, execution and monitoring of work programs at the administrative, engineering and environment levels. In addition, efficiency gains were expected to result in inter alia improved accessibility and safety, and reduced logistics costs (PAD, p.6). At the time of appraisal, transport infrastructure was considered a major obstacle to sustainable and equitable growth of the Brazil s State of Mato Grosso do Sul. The state economy relies substantially on agriculture which generated 30% of the state s GDP, and about 10% of the national GDP. About 60% of the network extension was in poor condition and its continued deterioration would have resulted in the overall increased transport costs given the high dependence of the State s economy on road transport. Investments in rehabilitation and maintenance activities had been overlooked in the past decade; less than BRL4O million were spent yearly on average, while between BRL85 to BRL100 million were needed on the paved network. The project supported the State Government s road transport program that was and remains key to the State s economic growth and development; it consisted of elimination of backlog of maintenance through rehabilitation of up to 2,200 km of the state paved roads by 2014 and surfacing of approximately 1,200 km of unpaved existing roads to improve accessibility and link communities mainly in the State s center, south, and northeast. The objective was also aligned with the State s Regional Development Plan 2030 that aims to lower logistic costs and foster regional development through improved policies and strategic infrastructure investments. The project development objective remained relevant to the World Bank s Country Partnership Strategy that aimed to promote regional economic development through improved policies and strategic infrastructure investments, and facilitate a greater role for the private sector. Rating Substantial b. Relevance of Design The statement of the objective on improving efficiency was too generalized. The results framework was sound: project inputs could be expected to deliver the desired outcome. It, however, lacked the outcome criteria to capture improved efficiency at the institutional level, in particular, as this would not be confined to the project area. The project was designed to contribute to reducing maintenance backlog accumulated over years through financing of rehabilitation and surfacing of key roads. These investments expected to reduce vehicle operating costs and increase the use of selected road corridors, thus leading to improved efficiency of the state road network. Accompanying measures under the institutional development support were to help improve the state capacity to manage road investment programs and improving efficiency in works preparation and execution stage. Page 3 of 14

4 Improved efficiency in the use of public resources was also sought through introduction of a results-based road rehabilitation and maintenance pilot contract (CREMA). These activities were factored under the same objective to improve efficiency of the road network in the project area and were not linked to outcomes at the institutional level The project design had weaknesses in terms of selection of the institutional entities for support that consequently led to re-visioning of responsibilities and delays in implementation. Rating Substantial 4. Achievement of Objectives (Efficacy) PHEFFICACYTBL Objective 1 Objective To improve the efficiency of the Mato Grosso do Sul State's road network in the project area. Rationale Outputs 799 km of the state roads were rehabilitated (target 750km) and 454 km of state roads were surfaced (target 450 km). This represents a total of 1,253 km of the state s paved road network of 4,400km. Overall, the project contributed to the increase in share of the state paved roads in good condition from 49% in 2008 to 82% in 2016, above the targeted 66%. A result-based maintenance and rehabilitation contract (CREMA) was piloted on 79 km on the projectsupported road network in Mato Grosso do Sul. The contract was signed in 2012 to be completed in Technical assistance was provided on public-private partnership (PPP), including organization of a PPP workshop, study tours to Belo Horizonte (a state with experience in the use of PPPs), and support to the PPP coordination unit. A pavement management system (PMS) was developed and operational in the State Public Works Agency (AGESUL), as planned. PMS allowed monitoring and evaluation of the level of serviceability of the state road network (for example, vehicle operating costs, traffic levels, and road condition). It is an integrated and updated database of road assets and allows to make a comprehensive highway investment assessment with a 20-year horizon. A Geographic Information System for environmental management in IMASUL was developed as planned; this included the acquisition of software and digitalization of paper-based environmental data for the last 40 years. The State Logistics and Transport Plan (PELT) was developed. The state government incorporated the results of the PELT in the state s new road investment plan in An Impact Study of Federal Concessions was prepared. A financial management system (KRONOS) for road works planned under the project was developed by the state using its own resources. It integrated physical and financial information, as well as work schedules, payments, and budgeting of new works. The new system allowed AGESUL to monitor physical and financial Page 4 of 14

5 progress together for works, compare performance of all of road works as a whole, and share the latest data with all of the relevant team members at the same time. An institutional analysis was carried out on sector reorganization and reform. A number of measures for sector reform were partially implemented based on the institutional analysis. In particular, the normative and executing responsibilities were clearly defined and separated. SEOP became the Secretariat of Infrastructure while SEMAC was divided between the Secretariat of the Environment and Economic Development and the Secretariat of Government and Strategic Management (SEGOV) that included the creation of a Strategic Partnerships Unit devoted to the development of PPPs. Outcome (a) Road network efficiency The rehabilitation and surfacing of the state roads resulted in an estimated reduction of operating costs to vehicle users by 23.8%, surpassing the original target of 5%. Overall, the project contributed to the increase in share of the state paved roads in good condition from 49% in 2008 to 82% in 2016, above the targeted 66%. The increase in vehicle-km was 73% on average for project-surfaced roads by January 2015, surpassing the target of 15%. However, this result was markedly influenced by one of the surfaced roads- MS-306 (32.6 km) where traffic increased by 580%. This road provided the best connection between large agricultural areas of the state to Port of Santos, the biggest port in Brazil. If this road is excluded from calculations, the weighted average for the remaining road sections is 14.03% (ICR, Annex 3, Table 3.1). (b) Institutional development Most of the management systems and programs were developed as planned and are operational. According to the evidence collected by the project team after completion of the ICR, the efficiency of public resource management in the Mato Grosso do Sul State has improved in the following way: The first CREMA pilot in the Mato Grosso do Sul state saved public resources while providing better quality of roads to the users. In a study conducted by the state, it was found that the unit costs of the projectsupported CREMA contract over 5-year rehabilitation and maintenance cycle were 6.2% lower than the comparable conventional contracts, and the surface conditions on the CREMA road remained better than the conventionally-contracted roads. The PPP coordination unit, the Strategic Partnership Unit under SEGOV, is advancing in introducing private sector initiatives in public-sector projects. A new state highway concession project (MS-306) is under preparation. In other sectors, the first PPP project is being prepared to provide sewerage systems to 69 municipalities in the state (several proposals has been received for the sewage project); and a call for expression of interests for a new ICT PPP project is under preparation. The value of these three contracts is estimated to be US$2 billion in total. Based on the first road management system (PMS) developed under the project, AGESUL has identified the priority road sections (400km) to be rehabilitated through the more accurate and comprehensive analysis provided by the PMS. GIS for environmental management helped the State Environmental Institution (IMASUL) improve the efficiency of processing environmental licenses, including for road projects. IMASUL staff needed to carry out 3-4 site visits on average to assess the environmental conditions of project sites for each environmental license application. After the launch of the new system, 1-2 visits are sufficient as the new system allows to locate the necessary environmental related information from the extensive geo-referenced data archives collected in the last 40 years. Page 5 of 14

6 Rating Substantial PHREVDELTBL PHREVISEDTBL 5. Efficiency Economic Analysis A cost-benefit analysis was carried out at appraisal for two main activities of the project: (i) paved highways rehabilitation; and (ii) unpaved road surfacing. The rehabilitation program of five highways totaling 515 km yielded a Net Present Value (NPV) of BRL61.8 million (US$33.6 million) at a 12% discount rate and an Internal Rate of Return (IRR) is 26%. The paving program for five road sections totaling 280 km yielded an NPV of BRL99.9 million (US$55 million) and the average IRR was estimated at18.2%. The analysis used the Highway Development and Management Model (HDM-4) that measures the benefits of road investment and maintenance in terms of reduction of vehicle operating costs and passenger time costs. Subprojects were analyzed by assessing the assumed streams of benefits to road users and savings on maintenance costs (as compared to a without project case) net of the costs of the proposed road works. An ex-post economic internal rate of return (EIRR) for rehabilitation and surfacing was estimated at 34.8% with a net present value (NPV) of R$291.1 million at a 12% discount rate (2009 price). The EIRR for rehabilitation was estimated at 32.8% with an NPV of BRL133.9 million, and for surfacing 36.5% with an NPV of BRL157.2 million, according to the information subsequently received from the project team. According to the ICR, the ex post economic analysis in principle adopted the same methodology. The ex post evaluation covered the same road sections of the ex-ante evaluation: five roads for rehabilitation with 515 km and four roads for surfacing with 280 km. Several modifications from the ex-ante model were made taking into account and based on (a) the type of works effectively executed and (b) observed traffic volumes and unit costs for works. The overall weighted ex-post IRR is higher mainly due to a higher traffic growth that expected. Cost Effectiveness An ICR does not provide a comparative analysis of road works unit costs in the country or region. According to Table 3.2 provided in ICR s Annex 3, unit costs for surfacing varied a lot, in particular from US$360,000 to US$700,000 per km; a range of unit costs for rehabilitation was between US$130,000 and US$240,000 per km (in 2010 dollars). Administrative and Operational Inefficiencies The civil works under the project were completed within the schedule with cost increase of 13% from the original budget. There were however delays in implementation of critical institutional support activities that necessitated project extension for an additional year. Page 6 of 14

7 Efficiency Rating Substantial a. If available, enter the Economic Rate of Return (ERR) and/or Financial Rate of Return (FRR) at appraisal and the re-estimated value at evaluation: Rate Available? Point value (%) *Coverage/Scope (%) Appraisal ICR Estimate Not Applicable Not Applicable * Refers to percent of total project cost for which ERR/FRR was calculated. 6. Outcome Relevance of objectives and that of design is rated substantial. The project helped improve the efficiency of the State s road network to a substantial extent, including the efficiency of management of public resources. Efficiency is assessed as substantial. a. Outcome Rating Satisfactory 7. Rationale for Risk to Development Outcome Rating Financial. The state government is committed to maintenance of the road network as stated in its development plan - however the current recession and weak economic environment in the country exerts significant burden on subnational governments and may pose a significant risk to adequately address future rehabilitation and maintenance needs. Institutional. The management systems and tools developed by the project are considered sustainable in the mid-term since they are being mainstreamed to support better planning, implementation, and monitoring of the state road infrastructure. The long-term challenge would be to keep the system relevant through continuous data updates. Environmental. The problem of land erosion near the MS436 roads with an extension of 107 km was not fully addressed by project closure. Page 7 of 14

8 a. Risk to Development Outcome Rating Substantial 8. Assessment of Bank Performance a. Quality-at-Entry The project design was based on other Bank road transport projects in Brazil, in particular in its focus on public sector management, environmental management, and private sector participation. The overall project risk was identified as moderate with main risks related to the institutional commitment and capacity, as well as lack of experience with the Bank s environmental and social safeguards. Albeit the project was prepared relatively quickly (six months), some issues were not sufficiently addressed that became evident during implementation. Atypical soil areas should have been identified by the project team early in the preparation period. Other issues include the institutional responsibilities and ownership of tools as well as the hiring foreign consultants that was governed by federal and not local regulations. The M&E design had weaknesses, in particular it lacked outcome indicators for its technical assistance estimated for a total amount of US$15 million to improve efficiency of the state s road agencies. It also lacked a clear definition of management tools for SEOP, which could indicate lack of preparation, as the number of basic modern management systems for a road agency are limited. Quality-at-Entry Rating Moderately Satisfactory b. Quality of supervision Supervision missions were held twice a year. There were three task team leaders during project duration. The key issues in implementation were regularly brought to the attention of the sector and country management through Implementation Status and Results Reports. The Bank team was responsive to client needs and monitoring of the World Bank s fiduciary and safeguards requirements. The environmental management of the project was downgraded due to the land erosion issue. Despite the fact that a number of solutions were worked out with the Borrower to address the land erosion issue, it was still not fully resolved by project closure. The contractor was reluctant to incur additional costs that were not included in the contract. The institutional activities started late in the project implementation leading to subsequent delays and project extension. In addition, the team could have made more effort, going beyond the M&E reporting, to provide more evaluative evidence with respect to the improved efficiency of road agencies with help of the new modern tools and systems supported under the project. Quality of Supervision Rating Moderately Satisfactory Overall Bank Performance Rating Page 8 of 14

9 Moderately Satisfactory 9. Assessment of Borrower Performance a. Government Performance The government of Mato Grosso do Sul s support for project implementation was strong throughout the project period. It provided the necessary funding, and covered the cost increase in road works contracts. The Government was committed to reforms in the sector, for example the State Legislature approved the Law for establishment of PPPs. Problems in the procurement of foreign consultants (a federal issue), which resulted in delays in the implementation of several technical assistance activities, were outside of the responsibility of the state government. Besides, this was the Bank s responsibility to plan accordingly at appraisal. Government Performance Rating Satisfactory b. Implementing Agency Performance AGESUL, the Public Works Agency, was the implementing agency and in charge of all administrative aspects (procurement, financial management and payment) for the project. It was also responsible for coordination of the information gathered from SEMAC, SEOP, and IMASUL on progress in the activities under way, procurement planning, certification of bills, and achievement of intermediate outcome indicators, among others. The agency had institutional capacity for executing civil works and managed the project effectively, as reported by the ICR. Despite effective implementation of the project, the initial concentration of efforts on the civil works component led to delay in contracting some consulting services under the institutional component triggering a one- year extension of the project, thus affecting the project efficiency. There was an issue with land erosion near one of the road sections that has not been fully resolved. Implementing Agency Performance Rating Moderately Satisfactory Overall Borrower Performance Rating Moderately Satisfactory 10. M&E Design, Implementation, & Utilization a. M&E Design Page 9 of 14

10 There were three outcome indicators. The main outcome indicator was estimated reduction in vehicle costs (that is a standard indicator in cost-benefit analyses of road works); the target was conservatively set at 5%. The other two indicators are the increase in use of road transport infrastructure by 15% and increase of paved road network in good condition to 66%. No outcome indicators were identified for institutional activities to measure the improved operational efficiency of road and other agencies owing to new modern tools and systems (estimated at US$15 million). The intermediate indicators were output-oriented and related to the actual development and installation of tools. One indicator did not define the types of two management tools to be developed in SEOP. The PAD also mentioned road safety and there are no data on this either. The responsibility for result monitoring was shared among the different beneficiaries in their respective areas of responsibility. b. M&E Implementation The M&E was implemented as planned. Semi-annual reports were regularly submitted to the World Bank on time and in acceptable form. c. M&E Utilization The M&E was used to monitor implementation and evaluate the project performance. The outcome indicators were part of the new managerial tool (PMS) of AGESUL to monitor and evaluate the level of serviceability of the state road network (i.e., vehicle operating costs, traffic levels, and road condition.) M&E Quality Rating Modest 11. Other Issues a. Safeguards This was a Category B project under Environmental Assessment (OP/BP 4.01.) Three other safeguard policies were triggered: Natural Habitats (OP/BP 4.04,) Physical Cultural Resources (OP/BP 4.11,) and Involuntary Resettlement (OP/BP 4.12.) Environmental Assessment. Natural Habitats. The direct environmental impacts resulting from rehabilitation (of existing paved road) and surfacing (of existing dirt roads) works were expected to be minor. At appraisal, the Natural Habitats safeguard was triggered as the works for both rehabilitation and surfacing might marginally interfere with riparian vegetation rivers crossings, which was protected under Brazil s Forest Code and considered as permanently protected areas (APP - Areas de ProteqZio Permanente). The PAD Page 10 of 14

11 (Annex 10) indicated that mitigation measures for these impacts were well known and foreseen in project designs and environmental licenses. During project implementation, however, inadequate works compromised drainage at least in five locations, affecting some streams and the riparian vegetation. The ICR (p.11) reports that while the World Bank procedures were satisfactorily followed, there was an issue of erosion near the MS436 roads with an extension of 107 km. The erosions took place because the area s sandy and fragile soil required specific procedures for drainage construction. AGESUL took actions to solve the problem but the initial solutions proved inadequate when subjected to heavy rains in After consultations with the World Bank, AGESUL decided to implement specific solutions to boost natural recovery of the slopes at the critical locations using seed blankets and some other techniques. However, the countermeasure was only partially implemented because of the reluctance of the contractor as the cost of activities was not included under their contract. While AGESUL managed to stabilize the slopes to some extent, it will take more time until the problem is fully resolved (ICR para 44.) Physical Cultural Resources. At appraisal, it was not expected that project implementation would have any negative impacts on physical cultural resources. However, "chance findings" during surfacing works were found to be possible (PAD, Annex 10). The ICR does not report if there were any issues related to this safeguard policy. Involuntary Resettlement. At appraisal, it was expected that a few localized land acquisitions might become necessary in order to proceed with localized road realignment, elimination of accident-prone points, and widening of bridges (PAD, Annex 10). Three minor land acquisitions were carried out during project implementation on a voluntary basis under monitoring of the World Bank. There was one substantial contract under the project with the sem-terra (The Movimiento dos Trabalhadores Sem Terra (Landless Workers Movement) is a social movement in Brazil active in most of the country s states aiming to fight for general access to the land for poor workers through land reform). On the MS-010 road section, the government identified about 60 tents and about 100 people occupying a section of 0.5 km. The government engaged in a dialogue to advise them of the risks of remaining in the area and discussed the alternatives for their move. The final decision respected the preference of the sem-terra to remain in the area but to be moved to a nearby area municipal road. They were peacefully reallocated to their selected site with the collaboration of the local government and the National Institute of Colonization and Agrarian Reform. There was another instance in which sem-terra campers were near the right-of-way. They were advised of the risks involved in camping near the construction works. Since they decided to remain in the site, adequate signalization was put in place to ensure their physical safety. The Indigenous Peoples policy (OP/BP 4.10) was not triggered at appraisal. As per the Bank's project screening process, Indigenous Peoples did not present in or had collective attachment to the project area, and were not going to be affected by the project (PAD, Annex 10). The ICR (p.13) reports that during project preparation, a prosecutor from the Federal Public Prosecutor s Office expressed concerns on potential negative impacts of the project on indigenous communities. During implementation, in July 2012, the same prosecutor sent a correspondence to the management of the World Bank expressing concerns of potential impact of the project on indigenous populations in the state. The World Bank management confirmed to the prosecutor that the project had remained the same since preparation and that it had no impact on indigenous populations. Page 11 of 14

12 b. Fiduciary Compliance Financial Management. The financial management performance was rated as satisfactory throughout the project implementation period. The interim financial reports were generally received on time or with some delay (up to a month) and were considered acceptable. Supervision missions identified the need to strengthen internal controls, leading to financing of training for auditors. All audit reports expressed an unqualified (clean) opinion (ICR, p.13) Procurement. The ICR (p.13) reports that procurement of works, services, and goods were satisfactorily carried out according to World Bank guidelines. An Independent Procurement Review carried out in May 2014 based on a sample of 12 contracts concluded that the bidding of works, hiring of consultants, and acquisitions of goods under the project were carried out with due diligence. The review pointed out to delays in a consultant contract related to the development of pavement management system (PMS) as a result of Brazil s lengthy requirements for the registration of foreign consulting firm. c. Unintended impacts (Positive or Negative) --- d. Other Ratings Ratings ICR IEG Outcome Highly Satisfactory Satisfactory Reason for Disagreements/Comment The outcome rating is based on the three criteria of relevance, efficacy, and efficiency, which are all assessed as substantial. In efficacy, the road network efficiency was improved to a substantial extent. The outcome target for the reduction in vehicle operating costs was significantly overachieved; at the same time, the increase in use of Page 12 of 14

13 Risk to Development Outcome Bank Performance Borrower Performance Modest Satisfactory Satisfactory Substantial Moderately Satisfactory Moderately Satisfactory Quality of ICR Modest --- the project -supported roads was skewed towards one road of 32.6 km. Efficiency gains at the institutional level are assessed as substantial, based on the additional evidence provided by the project team. Financial and environmental risks are considered substantial. Moderate shortcomings in Quality at Entry and Supervision, in particular with regard to safeguards and M&E. The IA performance is rated Moderately Satisfactory due to the issue of land erosion that has not been fully resolved yet. Note 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, The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate. 13. Lessons Three lessons were selected from the five listed in the ICR, with some adaptation: The implementation of environmental measures would more effective if these are identified early on and integrated as part of civil works contracts. Under this project, the issue with land erosion due to inadequate drainage works could not be fully resolved as the cost of remedial actions was not included in the contract. The experience points to the need for early identification by the World Bank and/or the client of atypical areas requiring an in-depth environmental plan, including ex-ante site visits by the Bank environmental specialists to ensure the adequacy of planned activities; the need to increase the supervision role of the regional offices of the road agency, more familiar with local characteristics, in project design; the need to make sure that extensive environmental management knowledge at the central level translates into field operations; and good integration of the implementation of environmental measures into construction contracts. Page 13 of 14

14 Sufficient lead time and resources are needed for launching complex institutional building components. One of the main reasons for delay in the implementation of technical assistance under this project was the time required to develop terms of references (TORs) for complex systems and tools. The time and resources were underestimated for preparation of TORs by institutions unfamiliar with World Bank procedures and generally lacking the in-house capabilities for the clear description of goods or services they are procuring. New Institutional approaches take time to become accepted and mainstreamed. The project included a pilot project introducing the concept of CREMA, a system of performance-based contracts that usually take five or more years. In spite of the proven record of the system in Brazil s federal road network and in several states networks, a priori the system appears more expensive than the conventional ones because the tradeoffs between the short-term benefits of the latter and the long-term benefits of the CREMA (both in terms of quality and life cycle costs) are not readily evident. 14. Assessment Recommended? No 15. Comments on Quality of ICR It is a concise report offering an adequate level of detail. The lessons are drawn from experience. The quality of evidence is weak, however. The ICR could have gone beyond project indicators in compiling evidence with regard to efficiency gains under the institutional component, in particular as the relevant entities benefited from the monitoring and evaluation systems and tools supported under the project. In addition, the analysis could have been more factual and objective in discussion of the issues faced in project implementation. a. Quality of ICR Rating Modest Page 14 of 14