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Implementation Completion Report (ICR) Review - Small Towns Infrastructure & Capacity Building Project

1. Project Data:   
ICR Review Date Posted:
Kyrgyz Republic
Project Name:
Small Towns Infrastructure & Capacity Building Project
Project Costs(US $M)
 15.60  21.93
L/C Number:
C4016, C4556, CH139, CH455
Loan/Credit (US $M)
 15.00  20.00
Sector Board:
Urban Development
Cofinancing (US $M)
Board Approval Date
Closing Date
03/31/2010 09/30/2011
General water sanitation and flood protection sector (52%), Sub-national government administration (23%), Roads and highways (19%), Health (3%), General education sector (3%)
Other urban development (40% - P) Pollution management and environmental health (20% - S) Urban services and housing for the poor (20% - S) Decentralization (20% - S)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Elaine Wee-Ling Ooi
Judyth L. Twigg Soniya Carvalho IEGPS1

2. Project Objectives and Components:

a. Objectives:
The development objective, as stated in both the Project Appraisal Document (PAD) page 3, and Schedule 2 of the Grant Financing Agreement, was: " to improve the availability, quality, and efficiency of local infrastructure services for the population of participating small towns." This would be achieved by: (a) financing the rehabilitation and/or repair of basic infrastructure and utility service installations and equipment, and (b) assisting local governments in increasing the effectiveness of the management of local infrastructure services.

b. Were the project objectives/key associated outcome targets revised during implementation?

c. Components:
A. Small Towns Infrastructure Investments (STIs) (estimated cost US$13.5 million, actual $17.8 million). Note: Actual costs are taken from ICR Annex 1, page 14.

  • This component was to finance rehabilitation, replacement, or upgrading of urban infrastructure and services (water supply, waste water treatment, solid waste collection and disposal, urban roads) and social infrastructure (primary schools, community facilities, health facilities). There was also provision for consulting services (technical studies, final engineering designs for urban infrastructure, and procurement and organization of tenders) to assist the Community Development and Investment Agency (ARIS) in implementing the project.

B. Institutional Strengthening (estimated cost US$0.8 million, actual USD$0.53 million.)
  • This component was to provide capacity building to local self governments (LSGs) and their local infrastructure service providers in the 23 participating small towns, to help them do their part in "co-implementing" the project. Technical assistance to be provided to support preparation of Performance Improvement Action Plans (PIAPs) required of each local infrastructure service provider that "benefited" from the urban infrastructure development in component A. The PIAPs were to improve technical, management and financial management competencies such as inventory of assets, clarify contractual relationships between LSGs and utility entities, develop preventive maintenance programs, reduce accounts payable and other arrears, introduce tariffs based on actual operating costs, strengthen billing and collection systems, etc. The component also provided for capacity building of various entities within the National Government to develop and implement a policy framework in support of the National Strategy for Decentralization and Local Government.

C. Implementation Support for the project (STICBP) (estimated cost US$1.3 million, actual US$1.66 million)
  • The component was to provide local experts to help LSGs identify and develop the social infrastructure investments, and support development and operation of an M&E system for the project and annual audits of project accounts. This component was also to support some equipment and vehicles, plus the staffing and travel costs to operate the project located within ARIS, the implementing agency.

d. Comments on Project Cost, Financing, Borrower Contribution, and Dates
Project Costs: Total project costs were more than 30% higher than at appraisal due to price escalation of construction materials, low quality technical/engineering designs, political and social unrest, and temporary suspension of Bank disbursements that disrupted or slowed project implementation. The Kyrgyz Republic experienced two revolutions (2005 and 2010) during the project's life. The first revolution, where the President was ousted, occurred in the first year of project approval (ICR, page 5). As the only donor-assisted project supporting secondary towns, the project encountered high demand for social services (solid waste management) and infrastructure, which were on the brink of collapse. The project responded by including all 23 towns (beyond project targets) in its solid waste collection services. Cost increases also resulted from additional civil works and redesign of some subprojects and engineering designs by local engineering firms (for example, relocation of a waste water treatment plant, and modification of certain technologies). Component B was underspent, as there was less demand than anticipated to develop and implement the policy framework for the National Strategy for Decentralization and Local Government.

Additional financing of $2.2 million and $1.8 million in Credit 4556 and Grant 4550 respectively was approved in April 2009 to accommodate the increased costs of materials and additional operating costs due to the project’s extension by 18 months. The additional financing was primarily targeted at the infrastructure component, which received an additional $3.65 million.

Borrower Contributions:
Final expenditures of local governments ($0.66 million ) were close to the $0.6 million estimated at appraisal. An additional $1.33 million was provided by the Kyrgyz Government, $1.2 million of which was in-kind (ICR Annex 1).

The project's closing date was extended twice. The first Additional Financing of April 2009 allowed for an additional 15 months (due to the conflict), to close the project by June 30, 2011. The second political uprising in 2010 resulted in the second additional financing (approved in May 2011), which added another 3 months to the project completion date.

3. Relevance of Objectives & Design:

a. Relevance of Objectives:

High. At appraisal, a key priority for the Bank's Country Assistance Strategy (CAS, 2003 - 2006) was to arrest the deterioration in key infrastructure and social services that had worsened since the fall of the Soviet Union. The CAS also articulated the need to improve the efficiency of services, while empowering local communities to partake in identifying their own development priorities. These priorities, all supported by the project, were consistent with the decentralization thrust of the National Poverty Reduction Strategy of 2002.

At project close, the project's objectives were relevant and consistent with the Bank’s Interim Strategy Note for the Kyrgyz Republic for FY 2012-2013. There, the third pillar calls for "social stabilization, through social services and community infrastructure....with particular emphasis on the southern part of the country."

b. Relevance of Design:
Substantial. The project had the essential elements and components to achieve its development objectives. There was a civil works component accompanied by provisions for contractual oversight and technical designs, plus an institutional development component to build capacity and competency of the local governments and the utility companies. Project inputs (technical improvements to local water and sanitation infrastructure, and improvements in the skills of small towns to manage and oversee utility service providers) would be expected to improve the availability, quality, and efficiency of utility services in these small towns. While the results chain for this project is rather straightforward, it is not clearly presented in the Results Framework (PAD, Annex 3 page 23). Based on the interview with the project team, IEG believes there is not a problem with the project's theory, design and assumptions, but there are shortcomings with their articulation in the results framework as presented.

In the former Soviet system, the top-down, three-tiered centralized planning structure, from oblast to rayon to small town, had left small towns with weak capacity and little decision-making authority. Government spending tended to favor the “higher levels” of the state. In fiscal year 2000, small towns accounted for only ten percent of subnational spending, compared to 75 percent for oblasts and rayons. The project was appropriately designed to redress the situation, building the strategizing, planning, and decision-making capacity of small towns and local governments (with input from local communities).

Eligibility for participation was not limited only to the high performers, and the outcomes and key performance indicators were not cast in stone. Depending on capacity, priorities, and level of commitment of the different municipalities that sought to participate, the key indicators and outcomes were defined accordingly.

The project presented "possible" project outcomes to be adopted by towns, such as "increase in available water supply in hours per day, increased frequency of solid waste collection per month, and increase in bill collection rates." According to the project team, this flexibility of design was important because of the wide variation in capacity between the towns. The ability for the towns to identify/determine their own targets (including the elaboration of Performance Implementation Action Plans (PIAPs)) was an important developmental process, a means to change mindsets and practice away from centralized, top-down planning.

4. Achievement of Objectives (Efficacy) :

The project sought to improve the availability, quality, and efficiency of local infrastructure services for the population of participating small towns. There were therefore three subobjectives. The Bank was the only development partner institution working with small towns in the country. All the results below are directly attributable to the project.

a) Availability of local infrastructure services: Modest upgraded to Substantial
Availability of services was measured by percentage of population supplied with water for at least 12 hours per day, and percentage of population served with municipal solid waste collection twice a month.

All 23 towns had completed PIAPs and comprehensive plans for the project. At appraisal, 6 towns were identified as strong candidates with good monitoring capability and the ability to implement their PIAPs. The PIAPs were an important capacity building and institutional development process. At project close, all 23 towns (LSGs and utilities) were implementing their PIADs and have started to rely on them for record-keeping and business accounting.

In total, 88 subprojects were implemented, benefiting 104,000 people. These included rehabilitation of reservoir–head water intakes, installation/replacement of high-pressure/efficiency water pumps, and construction of second-tier pumping stations.

Of the 16 towns financed by the project to improve water supply, only 10 had reliable M&E. Nine of these towns achieved or exceeded their targets, ranging from 27% to 95% of people having access for more than 12 hours. The improvements in water supply from their respective baselines were considerable (caveat: the targets were set by the towns themselves). The other six towns also are reported to have experienced improved water supply, but were not entered into this computation due to their weak data systems and lack of baselines.
The project team subsequently provided new data (collected in October 2013, 2 years after project close) to fill the data gap in 5 towns. There was 100% coverage (at least 12 hours per day) in water availability in 4 of the towns, and enhanced coverage by 2% in the fifth. None of the towns had set targets.

16 towns were to receive improvements in waste collection. Only 7 towns tracked this indicator. Of these, only 2 towns met or exceeded their targets, which ranged from 25% to 95% in population coverage . The improvements in waste collection compared to their respective baselines were considerable (caveat: the targets were set by the towns themselves). During the course of the project, all 23 towns were provided with waste collection service "to reduce social tensions that arose during the 2 conflicts," but resources for this intervention were spread thinly across the 23 towns. The planned targets for the 7 towns that tracked the waste collection indicator should have been adjusted downward, but they were not.
Additional data on solid waste collection was collected by the project team from 7 towns, making a total of 14 towns with data. In all 7 towns (which had not set targets), service coverage (waste removal at least 2 times a month) was enhanced, by (on average) 10-15 % of the population.

The project objective was to improve availability of services in all participating towns. The ICR provided evidence for only a subset of these towns: 10 out of 16 towns for water supply, and 7 out of 16 towns for solid waste. Based on this sparse evidence and low attainment of targets on waste collection, achievement of this objective was originally rated as modest. However, based on the additional data, availability of services is upgraded to Substantial.

b) Quality of local infrastructure services: Modest upgraded to Substantial
Quality of service was measured by percentage of people reporting poor water quality.

Sixteen towns were supported in the rehabilitation/construction of chlorination and pumping stations.

A beneficiary satisfaction survey was conducted in nine towns. Six of these nine towns met their targets, one town reported worse water quality, and two others experienced no change. (IEG notes that beneficiary satisfaction surveys can be flawed measures of quality improvement, and are subject to all sorts of survey bias errors. A direct quality measure would have been better but was not practicable).

Water and supply systems were in very poor shape after the fall of the Soviet Union. Project interventions began at the utility level, and at this stage would not yet have addressed the water distribution networks at the town level that would have had a major effect on water quality. Based on this limited impact, plus the fact that evidence is provided for only nine towns (and there is no way to know whether results for these nine towns are representative of all participating towns), achievement of this objective is rated as modest.

Additional data subsequently collected and provided by the project team from 15 out of the 16 water utilities shows that water quality two years after project close was improved at the utility level. Twelve utilities fully met 100% of national water quality standards, and 3 utilities achieved 90% compliance with the National Standards. Based on this additional information, overall quality of services is upgraded to Substantial.

c) Efficiency of local infrastructure services: Modest
Efficiency achievements were measured by the revenue/cost ratio of water supply, and energy consumption from supplying water.

The project introduced a billing system that increased the collection of user fees. In eight out of the ten towns that had monitoring data and baselines on collection, there was substantial improvement of the collection rate (from 35% to 85%).

Nine towns reported data on revenue/cost ratio for water supply, and only two of these reached their targets. Three had ratios worse than before the project started. Another seven towns reported that they carried out interventions related to this objective, but outcome data are not presented.

Eight towns reported data on reducing energy consumption as a percentage of total costs of supplying water, and six of those met their targets. However, no data were available from seven other towns that also reported interventions.

Based on limited impact on revenue/coast ratio for water supply, plus the fact that evidence is provided for only a subset of towns (and there is no way to know whether results for these towns are representative of all participating towns), achievement of this objective is rated as modest.

5. Efficiency:

A partial economic analysis was done by the ICR only on the water supply sector. This sector accounted for approximately 70% of project costs. The analysis found an economic internal rate of return of 13.72%, with a benefit-cost ratio of 1.36. The analysis took into account benefits such as time saved (confirmed in a 2011 survey), savings in costs of boiling untreated water and not having to purchase bottled water, and savings from avoidance of treatment of waterborne diseases. The 2011 survey did not capture the benefits from the solid waste management interventions that took place after the survey was completed. There may be additional health benefits and associated savings from the removal of solid waste.

In IEG's view because the survey was conducted in only 5 out of 12 towns (approximately 42%) that had received substantial investments in water supply improvements, the ERR calculation/findings can only be applied to 42% of the water investments.

The project did not provide comparisons against the ERR or cost benefit ratios from other similar projects. Since there was no sector or country benchmark against which to compare the project, the global Bank benchmark of 12% is applied here. Efficiency may be rated as substantial for the 42% of the project that had water investments. For the greater proportion of the project, reliable estimates were not generated. The project was extended by a total of 18 months (15 months under additional financing, plus 3 months to complete works in the Southern town of Kok-Jangak where tensions were high).

The project team subsequently undertook another estimate of the project's ERR. The estimates were based on a more comprehensive economic analysis, where total project costs (both Bank and counterpart funding) were computed into the estimates. Returns were estimated from time savings from not fetching water, time savings from not storing water, and cost savings from not having to purchase safe water storage equipment. Returns also included actual savings in energy consumption collected from 8 water utilities. If only 50% of recipient households saved 1.5 hours/day, and only 20% of households saved $250 each from not buying water storage tanks, the project arrived at a savings of $4.7 million (opportunity cost of $1.5/day) + $ 204,000. Energy consumption savings of $90,000 were accrued by 8 utilities. Based on these calculations, the project's ERR was 18%, higher than the 13.72 % presented in the ICR.

The investment costs used were total project costs, compared to a more conservative estimate of returns. The new calculation of 18% ERR is applicable to 70% of the project costs (instead of 13.72% and 42% coverage, as stated in the ICR). Based on this analysis, efficiency is upgraded to Substantial.

a. If available, enter the Economic Rate of Return (ERR)/Financial Rate of Return at appraisal and the re-estimated value at evaluation:

Rate Available?
Point Value
ICR estimate:

* Refers to percent of total project cost for which ERR/FRR was calculated

6. Outcome:

Relevance of objectives was high, and relevance of design was substantial. The project's objectives were well aligned with country conditions and Government and Bank strategy, and the project's design contained activities that would plausibly have been expected to achieve the development objectives. Based on additional information provided by the project team 2 years after project close, efficacy for 2 objectives (availability, quality) is rated substantial, and while one objective (efficiency) is still rated modest. Seventy percent of the project's costs (water supply activities) returned an 18% economic rate of return, which is therefore rated substantial. The project's outcome is therefore rated Satisfactory.

a. Outcome Rating: Satisfactory

7. Rationale for Risk to Development Outcome Rating:

There are several significant risks:

  • Financial: utilities are far from being self sustaining, and tariffs are yet to be increased.
  • Physical: water supply distribution network lines are antiquated, broken, and in need of repair and extension.
  • Technical: proper operation and maintenance is required but is often neglected.

A follow-on project (Additional Financing for Bishkek and Osh Urban Infrastructure (BOUIP) project) will have a component supporting the objectives and activities of STICBP. Government ownership has increased. The project team reported that as a result of this project, both the LSGs and MOF have dramatically increased their counterpart funding for the follow-on project; they will now contribute 10% each compared to the 3% from LSG and 0% by MOF in the STICBP. Other donors (EBRD and ADB) are also starting to invest in small town infrastructure improvement. Given the country's stage of development, outcomes will still be dependent on external aid at least for the near term.

a. Risk to Development Outcome Rating: Significant

8. Assessment of Bank Performance:

a. Quality at entry:
The project team incorporated lessons from other municipal infrastructure projects in the Region and globally into the project design for a post-conflict country. They included: placing decisions on investment priorities with local government and communities; packaging capacity-building together with investment interventions; and simplifying implementation arrangements. The project appropriately used analytical studies from other donors (USAID, UNDP) and the Urban Institute to guide project preparation. The project focused appropriately on quickly restoring essential infrastructure, and it selected an appropriate implementation partner, ARIS (government, LSG, and civil society representatives sit on the ARIS Board). Using a bottom-up approach, the project focused on and allowed the LSGs and utilities to identify their own priority needs which were then approved by town governance committees. The PIAPs were an important developmental process and helped prepare LSGs for the financial, institutional, and technical challenges to come.

The project was the first in the country (former centrally planned economy) to work at the small town level. The project team was cognizant of capacity issues as well as the data collection challenges to be encountered in this demand driven project, but still believed the project's design and approach were appropriate.

Quality-at-Entry Rating: Satisfactory

b. Quality of supervision:
The Bank worked effectively and had good relations with all counterparts (ARIS, LSGs, and utilities), which were particularly important when conflict broke out and persisted for seven years. These good relations enabled the project to be adaptable in spreading some of the project's financing to cover more towns than planned to meet the most urgent needs. There were adequate resources for supervision, and although there were five TTLs, there was continuity in handover. Proper attention was given to oversight of financial management, procurement, and safeguard issues. As the first and only donor supporting infrastructure services in small towns, the Bank faced many challenges. The Borrower's ICR attested to the contributions of the Bank in provision of timely and expert supervision to the project. The Borrower also expressed appreciation for the project's implementation model and concept.

All 23 towns eventually opted to participate in the project. This was more than the project had anticipated, but the Bank proceeded nonetheless. This created two problems: financial resources and project capacity were stretched thin; and weaker towns were unable to provide sufficient outcome data. Supervision is therefore rated as moderately satisfactory, based on the information presented in the ICR.

However, based on new information subsequently provided by the project team showing that outcome results were not as compromised as originally thought, and the fact that the Bank worked well with the Client and was responsive to the Client's needs at a time of social division and conflict, Bank supervision is upgraded to Satisfactory.

Quality of Supervision Rating: Satisfactory

Overall Bank Performance Rating: Satisfactory

9. Assessment of Borrower Performance:

a. Government Performance:
The government remained committed to the project and continued to endorse it through three changes of administration during the project’s lifetime. These different administrations maintained appropriate communication with the Bank despite the challenge of not having a lead agency overseeing local governance and public utility services in the central government. No problems were encountered with counterpart funding, and LSGs provided 3% of project costs.

However, perhaps due to the desire to maintain social cohesiveness, the government allowed all towns who wanted to do so to participate in the project. As a result, financial resources and project capacity were stretched thin; and weaker towns were unable to provide adequate outcome data. All towns were assisted in developing and implementing an M&E system, but many did not achieve desired results by project closing.

Based on new information subsequently provided by the project team, outcome results were not as compromised as originally thought. The Client's response to public health demand by all towns for solid waste collection at a time of social division and conflict was a national public good. Government performance is therefore upgraded to Satisfactory.

Government Performance Rating: Satisfactory

b. Implementing Agency Performance:
ARIS managed the project through the conflict, remaining resilient and dedicated to the project’s goals and responsive to to the needs of LSGs and utilities. The utilities depended on ARIS to help them develop and implement their customized PIAPs. ARIS was technically competent and discharged all its project management responsibilities in a professional manner. It satisfactorily performed its financial and procurement management responsibilities in a conflict-ridden and politically charged environment. All quarterly and annual reports were submitted on time. ARIS was highly rated in the Beneficiary Survey.

Implementing Agency Performance Rating: Satisfactory

Overall Borrower Performance Rating: Satisfactory

10. M&E Design, Implementation, & Utilization:

a. M&E Design:
After the subproject applications from the towns were selected, outcome indicators were defined. Ultimately five (two on availability, one on quality, and two on efficiency) were chosen to represent the three development objectives. At appraisal, six towns were assessed to have the ability to collect monitoring data and to participate effectively in the project. They were included in the first year of project interventions. In subsequent years other towns were added to the project. The project assisted with building M&E capacity of the LSGs and utilities, which was included as a provision/requirement in the PIAPs.

The main weakness of the M&E provisions for the project was the inability to gather data from all participating towns. The project did not have a effective plan for the M&E issues that would arise as " weaker" towns started becoming project participants. As a result, only data and evidence from the towns with "strong" M&E systems were reported and analyzed.

For those six towns that had the capacity to collect data systematically throughout the project's duration, a baseline (through a survey) was established. Later on other towns had project-sponsored interventions but were not included in the computation of achievement of objectives (see Section 4). The M&E system also included a mid-term review, beneficiary survey, and an impact evaluation, but not all of these were applicable to all 23 towns.

b. M&E Implementation:
Even though data quality varied, it was collected in the selected towns as planned. Data collection was a key component of the PIAP. All towns were using their respective M&E systems, but there was wide variability in the quality and reliability of these systems. Nine towns had consistently reliable M&E systems, and data were routinely submitted from these nine systems to ARIS for analysis and project programming. An additional five towns had reasonable data collected, which helped the project and ICR to track some of their targets and achievements.

The surveys and impact studies were implemented as planned.

a. M&E Utilization:
Where reliable data were available, the above-mentioned studies and surveys and routine monitoring were useful programming tools, systematically utilized by ARIS. More importantly, these towns now appear to understand the value of the M&E and depend on it to improve services. Even though not all towns had sufficiently reliable data from which to assess project achievements, all towns have begun to collect and analyze outcome information.

M&E Quality Rating: Modest

11. Other Issues:

a. Safeguards:
Safeguards compliance was monitored throughout the project, which was classified Category B. A framework Environmental Management Plan and Environmental Impact Assessment were prepared as required and approved by the responsible Kyrgyz environmental authority. Given the types of investments and the small volumes of waste water concerned, the project was granted a waiver to notification under OP 7.50. No issues materialized. Asbestos cement was used extensively in the former Soviet Union, and a Kyrgyz factory still produces asbestos cement. The project team noted that special attention was paid when reviewing bidding documents and technical specifications to ensure exclusion of asbestos cement.

b. Fiduciary Compliance:
The ICR notes that the financial management arrangements established by ARIS were satisfactory throughout the life of the project. The project was fully compliant with the financial covenants of the Legal Agreement, and no significant accounting or internal control issues were discovered.

c. Unintended Impacts (positive or negative):

d. Other:

12. Ratings:

IEG Review
Reason for Disagreement/Comments
Risk to Development Outcome:
Bank Performance:
Borrower Performance:
Quality of ICR:
- 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.
- The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate.

13. Lessons:
The ICR offers the following lessons which are summarized below:

In circumstances where a whole system is on the verge of collapse, the need for flexibility in
project design is required. The project faced dilemmas typical to the water/urban sector in Central Asia. Public services were functional prior to the collapse of the Soviet Union, but deteriorated rapidly due to: (i) the lack of funding by local authorities and utilities, even for basic operations and maintenance; (ii) non-existent maintenance or capital investment since the late 1980s; (iii) obsolete and energy-inefficient technologies; and (iv) the limited technical capacity of local operators. Under such enormous challenges a project should be pragmatic in prioritizing demands/investments, and start first with restoring services to acceptable levels while slowly strengthening utilities that were on the verge of collapsing. A project should be flexible enough to allow both needs to be served in a timely and effective manner. However they should do so in a way that does not compromise quality. Projects should not spread themselves too thin and nor should they forego data collection to ensure resources are wisely invested.

By preventing a complete collapse and allowing services to recover to a minimal level,
others donors can be persuaded to invest and be more strategic later on. With services running again and utilities back in operation, some towns have witnessed increased revenues and investment, and are therefore no longer in "emergency mode." More donors are now investing or preparing investment in selected small towns. These focused investments could yield significant results in fewer selected towns, with higher economic rates of return and greater impact.

If a project's investment is spread to a larger number of towns/beneficiaries than originally planned, it is important that the task team adjusts the targets downwards. In this case, such adjustments could have impacted the project's outcome rating.

New technologies can significantly improve the availability of services and the operations of utilities, and therefore capacity building related to these technologies should be an integral part of project design. In this case, the use of modern technology and equipment has had a significant impact on improving the efficiency of the participating utilities, especially in reducing energy consumption. The
knowledge related to the installation, operation, and maintenance of new systems (energy efficient pumps,
computerized billing, accounting, and metering, etc) is vital for utilities to keep up with proper operation and maintenance of installed equipment. Practical and on-the-job training, which accompanied the installations, was one of the aspects of the project most appreciated by beneficiaries. Further, where computerized billing and accounting systems were installed and utility staff trained, utility revenue and management capacity markedly improved.

14. Assessment Recommended?


15. Comments on Quality of ICR:

The ICR is satisfactory and very concise, but it should have pulled into the discussion more of the findings of the Impact Evaluation and Mid-Term Review. This is especially necessary due to the fact that not all 23 towns had reliable data. The Stakeholder Workshop, Impact Evaluation Study, and Borrower's ICR in the ICR annexes added considerably to understanding the challenges and performance of the project. The Beneficiary Survey Instrument should have also been attached.

a. Quality of ICR Rating: Satisfactory

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