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Implementation Completion Report (ICR) Review - Demonstration Of Alternatives To Chlordane And Mirex In Termite Control Project

1. Project Data:   
ICR Review Date Posted:
Project Name:
Demonstration Of Alternatives To Chlordane And Mirex In Termite Control Project
Project Costs(US $M)
 27,70  29.12
L/C Number:
Loan/Credit (US $M)
 14.36  14.36
Sector Board:
Cofinancing (US $M)
Board Approval Date
Closing Date
12/31/2010 12/31/2011
Housing construction (64%), Sub-national government administration (16%), Central government administration (16%), Petrochemicals and fertilizers (4%)
Pollution management and environmental health (40% - P) Other environment and natural resources management (20% - S) Environmental policies and institutions (20% - S) Other human development (20% - S)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Richard C. Worden
Judyth L. Twigg Soniya Carvalho IEGPS1

2. Project Objectives and Components:

a. Objectives:
The objective of the Project, as stated in GEF Trust Fund Grant Agreement (p. 18), was to: “assist the Recipient in substituting the use of chlordane and mirex (which are harmful to human health and the environment) with integrated pest management techniques (“IPM”) as a means to control termites in Jiangsu and participating provinces; and establishing a cost effective framework for promoting IPM in termite control.”

    As stated in the Project Appraisal Document (PAD, p. 12), the objective was to: “mitigate environmental and health risks associated with chlordane and mirex in termite control by (a) demonstrating the elimination of their use through the introduction of integrated pest management in selected areas, and (b) preparing a national replication program for complete phase-out of chlordane and mirex in China.” The Global Environmental Objective (GEO), as stated in the PAD (p. 6), was to: “help China eliminate Chlordane and Mirex, two of the 12 Persistent Organic Pollutants covered by the Stockholm Convention on POPS, which are harmful to human health and to the environment.”

    The objective as stated in the GEF Grant Agreement is used as the basis for assessing this project, as it is the legally binding document.

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

c. Components:
The project had six components:

Component 1. Institutional Capacity Strengthening (original GEF estimate: US$ 0.97 million, revised to US$ 1.8 million; actual GEF expenditures: US$ 1.5 million). This component was to include establishing the project team in the Ministry of Environment Protection (MEP) and the Foreign Economic Cooperation Office, as well as three Project Implementation Units (PIUs) in targeted provinces; hiring an international Chief Technical Advisor, National Technical Advisor, and other individual experts; and paying for project inception workshops and project management training workshops.

Component 2. Policy Framework for Elimination of Chlordane and Mirex (original GEF estimate: US$ 0.64 million, revised to US$ 2.3 million; actual GEF expenditures: US$ 0.9 million). This component was to assist with formulating and revising policies, regulations, and standards at both the national and provincial levels to facilitate the phase-out of chlordane and mirex and promote integrated pest management (IPM) alternatives to control termite damage.

Component 3. IPM Implementation (original GEF estimate: US$ 9.7 million, revised to US$ 9.3 million; actual GEF expenditures: US$ 9.5 million). This component was to include the development of an IPM training manual and conducting of training programs for different target groups; promotion of public awareness and information dissemination campaigns; demonstrations of IPM technologies (e.g., monitoring-baiting systems); and conducting of research and development activities.

Component 4. Closure of Chlordane and Mirex Manufacturer (original GEF estimate: US$ 0.94 million, revised to US$ 1.4 million; actual GEF expenditures: US$ 1.45 million). This component was to support permanent physical closure and dismantling of the chlordane and mirex manufacturing facility of the Liyang Guanghua Chemical Company, clean-up of the facility’s chlordane- and mirex-contaminated site, and disposal of chlordane and mirex waste.

Component 5. Monitoring and Evaluation (original GEF estimate: US$ 74,000, revised to US$ 193,000; actual GEF expenditures: US$152,000). This component was to support a monitoring and evaluation workshop, annual project review meetings, and development of a management information system (MIS) to track project progress.

Component 6. National Replication Program for Elimination of Chlordane and Mirex in China (original GEF estimate: US$ 0.75 million, revised to US$ 0.9 million; actual GEF expenditures: US$ 0.88 million). This component was to support the development of a national replication program (NRP) to eliminate the use of chlordane and mirex in termite control programs; preparation of environment impact assessment (EIA) reports for the eight chlordane and mirex production sites; and holding of a national consultation and dissemination workshop and an international workshop at the project’s completion.

The project Grant Agreement was amended shortly after effectiveness in March 2007 to include two additional demonstration provinces, Anhui and Hunan, to replace Zhejiang province, which dropped out of the project unexpectedly just prior to Board approval. The project was restructured again and extended one year in December 2010 due to a slow start caused by a two-year delay in disbursing project funds using the Bank’s new Financial Management Report (FMR) system; this restructuring reallocated cost savings of US$ 3.8 million caused by a change in the application of IPM alternatives to other project activities. This second restructuring (December 2010) resulted in changes to two project components. Component 3 was amended to “carry out program for the pilot application of monitoring-dusting system for termite control in the building construction sector … in five new provinces (Guangxi, Guangdong, Zhejiang, Jiangxi, and Sichuan),” and Component 4 was amended as follows: “Closure of Liyang [Guanghua] Facility in Jiangsu Province” was revised to“Closure of Selected Chlordane and Mirex Facilities in Jiangsu Province.”

d. Comments on Project Cost, Financing, Borrower Contribution, and Dates
Project Cost, Financing and Borrower Contribution:

    Overall actual project costs remained consistent with estimated amounts, rising 5 percent above the estimated cost of US$ 27.7 million to reach US$ 29.12 million. The GEF grant amount did not change from the original estimate of US$ 14.357 million, although disbursements among the six project components did change noticeably at the second restructuring. All of the additional US$ 14.2 million cost was borne by the Chinese Government, although it is important to note that more than US$ 9.4 million of that, nearly two-thirds, was deferred as “Future counterpart commitments to sustain project outcomes and scale-up activities.” Almost all of that deferred contribution was related to activities under Component 4: IPM Implementation once the decision was made by the Government not to seek GEF funding to expand and replicate the IPM-based termite prevention program nationwide.

    The project was appraised in January 2006 and became effective on December 15, 2006. It was restructured twice (in March 2007 and in December 2010). The Mid-Term Review was conducted in October 2009 (there was no planned date in the PAD), and it closed on December 31, 2011. US$10,627 was cancelled when the project grant was officially closed.

3. Relevance of Objectives & Design:

a. Relevance of Objectives:
The PDO was highly relevant to China’s commitments under the Stockholm Convention for persistent organic pollutants (POP) to eliminate the use of POP pesticides to reduce risks to human health and the environment. The project was consistent with the GEF’s support of demonstration projects under its Operational Program for Reducing and Eliminating Releases of POPs (OP14), and with the Bank’s Environment Strategy. Finally, the project was consistent with the third pillar of the Bank’s Country Partnership Strategy (CPS) with China between 2006 and 2010, to “manage resource scarcity and environmental challenges, through reducing air pollution, conserving water resources and optimizing energy use (partly through pricing reforms), improving land administration and management, and observing international environmental conventions” (italics added from the CPS, p. 40).

b. Relevance of Design:
The project was a self-standing, full-size GEF demonstration project designed to be replicated at the national level. The project built upon the strategy to phase out POPs in China funded by Italy and executed by the United Nations Development Program (UNDP) as well as a Termite Study funded by Canada and executed by the World Bank. It was integrated into China’s National Implementation Plan (NIP) for POPs as part of China’s 12th Five-Year Development Plan. The six project components comprehensively reflected the various elements of the PDO to address both the supply and demand sides of chlordane and mirex production and consumption in China, while dedicating project human and financial resources to building the institutional capacity to implement the project and scaling it up to the national level later.

The PDO was clearly articulated with the project’s expected outputs/outcomes in the Results Framework, which were well-structured to achieve its multiple facets. The four “key project outputs” listed in the PAD logically would have led to the achievement of the sole “Outcome Indicator” of the Results Framework; that is, all four outputs should have resulted in: “No use of chlordane and mirex by the termite control professionals in the demonstration area.”The design met the need to simultaneously address both the production of and demand for chlordane and mirex, based upon prior similar experiences in China involving the elimination of the use and production of ozone-depleting substances under the Montreal Protocol. In addition, the project design accurately identified and mitigated the main exogenous issues that might have derailed the project’s effective implementation and replication at a national scale. Overall relevance of design to achieving the project’s development objective is rated substantial.

4. Achievement of Objectives (Efficacy) :

Assist the Recipient in substituting the use of chlordane and mirex with IPM as a means to control termites in Jiangsu and participating provinces. Rating: Substantial.

Installation of 151,500 AG bait systems and 762,000 IG systems, fully meeting the revised targets for both systems.
The elimination of 372.37 metric tons (MT) of chlordane and 163.3 kilograms (kg) of mirex, surpassing the revised target of 150 MT.

The goal of completely eliminating the use of chlordane and mirex by termite control professionals in the demonstration areas was met and surpassed, with the issuance of a total ban on the use and production of such POPs in May 2009 across the entire country.

Establish a cost effective framework for promoting IPM in termite control. Rating: Substantial.

The mix of AG and IG units that were installed was changed for cost-effectiveness reasons.
A pilot program to test 41,250 “monitoring-dusting” systems was conducted, confirming this as a cost-effective alternative approach.
Several new detection technologies, such as infrared camera and acoustic emission devices, were introduced to Chinese termite control personnel, allowing them to use a more targeted indoor application approach.
Termite Control Stations (TCSs) were fully engaged in the demonstration areas as active participants in the project.
Policy reforms were deepened, and IPM training and public-awareness activities were expanded.
The project MIS was used to track the cost-effectiveness of different termite control practices and technologies.

IPM costs were shown to be almost twice as high (1.91 times as expensive on average) as the traditional chemical-based approach (ICR, p. 48), although the latter did not include the “external costs” imposed on society in the price of those toxic products. The project was adept at searching for effective and cost-efficient ways to address damages caused by termites. By adapting to the reality it encountered with respect to the comparative effectiveness of different termite control approaches, the project developed more cost-effective strategies in response to actual field conditions. This type of "structured learning" was appropriate in a demonstration project context and helped the project achieve its objective efficiently by adapting to unexpected challenges and abandoning technologies or approaches that did not work in field applications.

Progress toward achieving the Global Environment Objective: The project was largely responsible for completely eliminating the use of Chlordane and Mirex, two of the 12 Persistent Organic Pollutants covered by the Stockholm Convention on POPs, due to their harmful effects on human health and the environment. This was achieved not only in the participating provinces, but throughout China with the passage of a nationwide ban on the production, circulation, use, and trade of Chlordane and Mirex (plus two other POPs: DDT and HCB) in May 2009.

5. Efficiency:

Efficiency: Modest.
    No traditional cost-benefit analysis was conducted due to the lack of readily available data and “impractical” difficulties encountered in measuring environmental and health benefits associated with phasing out production and consumption of mirex and chlordane. A cost-effectiveness analysis was used instead to assess project efficiency. It found that, compared to the “without project” scenario [the counterfactual], the savings from "avoided costs" associated with lost productivity and medical costs of termiticide application workers (who were found to have cancer incidence rates 40 percent higher than the general population in China), and to cleanup contaminated sites, justified the additional expenditures of the IPM-based approaches (ICR, pp. 43-44).

    From an operational perspective, the project achieved its objectives (and exceeded several important targets) while only modestly going over its estimated budget. Part of the project’s success was attributable to its implementation model, which dynamically linked international expertise and best practices with Government agencies and hundreds of municipal termite control centers. This approach allowed for the quick transfer of knowledge, the refinement and adjustment of piloted IPM technologies, and the introduction of new ones such as termite monitoring-dusting systems.

    However, there were some factors and events that caused a two-year delay in project implementation, such as adopting the Bank’s financial monitoring report (FMR)-based disbursement method for the first time in China without adequate and timely training, and vastly overestimating the demand for mirex-containing above-ground (AG) termite bait systems. Limited knowledge about the “strict technical requirements” of the AG systems led termite control workers to intentionally neglect instructions when installing them early on in order to finish their tasks on time. This led to high loss rates of systems (30 to 40% in some neighborhoods) and their frequent dismantlement by residents. Finally, the project had to be extended by one year to allow time to conclude project activities and reach more results indicator targets.

    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:

The relevance of the project’s objectives to the CPS and China’s international legal commitments under the Stockholm Convention was assessed as having been high, while the relevance of design was assessed as substantial. The achievement of the project's twin objectives was found to be substantial, but the efficiency of project implementation was rated as modest due to poor initial roll-out of the AG bait systems and delays in project implementation and subsequent extension.

a. Outcome Rating: Moderately Satisfactory

7. Rationale for Risk to Development Outcome Rating:

The risk to development is assessed as low for several reasons. First, a 2009 Government ban on the production, transport, trade, and use of mirex and chlordane at a national level represented a significant step forward. A slew of provincial and national regulations and standards as well as the draft 12th Five Year Plan promoting the use of IPM as a viable alternative have been or are in the process of being promulgated and implemented. A public awareness-raising campaign was effective. Institutional capabilities to ensure the permanent phase-out of these POPs and promote the IPM approach have been strengthened through training, materials, and equipment provided to the building construction industry and to national, provincial, and municipal Government authorities. Given the growing public and Government concern over the legacy of environmental contamination issues resulting from China’s industrial development over the past few decades, it is considered highly unlikely that this concern will significantly diminish to the point of reversing the ban on mirex and chlordane in the future despite their lower costs compared to IPM strategies and technologies.

a. Risk to Development Outcome Rating: Negligible to Low

8. Assessment of Bank Performance:

a. Quality at entry:

The Bank team at appraisal correctly identified the main challenges to adopting an appropriate project design that would lead to its successful implementation. These included: counterproductive Government policies regarding termite control guarantee and pricing reforms; a lack of safer, cost-effective chemical or non-chemical alternatives to chlordane and mirex; limited public awareness of the risks and true costs of these chemicals and of the relative benefits of IPM alternatives; and limited Government experience with an IPM-based approach. In addition, on the basis of previous experience in China under the Montreal Protocol, the project simultaneously addressed both the supply and demand sides of mirex and chlordane production and consumption in China.

    On the other hand, there were a number of moderate shortcomings with Bank performance during project preparation and appraisal. First, most of the project indicators were output-based instead of outcome-based, and indicators for measuring the effectiveness of bait systems were missing. The demand for AG mirex bait systems was over-estimated, which led to their improper installation in order to meet target deadlines, while the risk that IPM-based termite baiting systems would be more expensive than chemical termite controls was underestimated. Finally, there was insufficient communication during project preparation with Zhenjiang Province and the Liyang Guanghua Chemical Company, which both withdrew from the project, impeding implementation of the project and adding unnecessary effort and work identifying replacements. Taken on balance, the Bank got most of the big issues right and helped design a well thought-out and successful project to reduce the adverse health and environmental risks associated with mirex and chlordane by replacing them with an IPM approach on a demonstration basis.

    Quality-at-Entry Rating: Moderately Satisfactory

    b. Quality of supervision:

    According to the ICR (p. 25), Bank project staff conducted at least 13 regularly scheduled semi-annual supervision missions and follow-up reviews during the five-year project, especially when the project was facing substantial delays in disbursements. Supervision missions also included support from Bank procurement, financial and safeguards staff. The Implementation Status Reports (ISRs) rated the progress and performance of the project accurately and provided appropriate project progress information to the GEF. The Borrower characterized the Bank’s performance during implementation as ‘satisfactory,’ stating that the Bank “played an active and effective role” in supervising the project’s implementation (ICR, pp. 58-59). In addition, following the Mid-Term Review in April 2010, procurement of the final tranche of about 30% of the IG termite bait systems was cancelled, and a more cost-effective IPM-based alternative of monitoring and dusting termite traps was adopted. As a result, project savings of about US$3.8 million were redirected to support a second round of IPM technical training to the building construction industry and to initiate a second round of public awareness-raising activities during the restructuring of the project in December 2010.

      Several shortcomings in the Bank’s performance during implementation were noted, such as the Bank’s slow response to inadequate training in the Bank’s new financial monitoring report (FMR)-based disbursement method. In addition, the Bank did not formally revise results indicators during project implementation that were identified as problematic by supervision missions, the MTR, and a Quality Assurance Group (QAG) review in 2007. The Borrower commented on the disruptive effect that frequent changes in project management staff (four TTLs over a 5 year period) had on project continuity (p. 60). However, on balance, Bank performance during project implementation was assessed above the line.

      Quality of Supervision Rating: Moderately Satisfactory

      Overall Bank Performance Rating: Moderately Satisfactory

      9. Assessment of Borrower Performance:

      a. Government Performance:
      The Government’s performance was satisfactory for a number of reasons, including that it met its financial obligations to the project. It should be noted, however, that two-thirds of that contribution (US$ 9.37 million out of US$ 14.76 million) was deferred for “future counterpart commitments to sustain project outcomes and scale-up activities” (ICR, Annex 1: Project Costs and Financing, p. 31). The total counterpart contribution is expected to be 10% above the original counterpart expected contribution of US$ 13.34 million. This was done because the Government decided to fund the ramping up of POPs phase-out activities to the national level with its own funds and not those from another GEF grant. The Government also developed and adopted a sound regulatory framework of policies and standards to sustain the outcomes of the project, and agreed to buy nearly 68,000 additional IG termite bait systems and 4,125 extra termite monitoring and dusting systems for future ‘maintenance’ purposes, representing 10% of the total number of procured systems (ICR, p.36).

      The only minor shortcoming in the Government’s performance was the slow pace of opening the project account, which was not opened until September 2007, 14 months after the Grant Agreement was signed in July 2006. The first withdrawal application was not made until June 2008, or a full 24 months after the Grant Agreement had been originally signed. However, this situation was eventually rectified and disbursements occurred on a much more regularized and timely basis.

      Government Performance Rating: Satisfactory

      b. Implementing Agency Performance:

      There were three levels of Government agencies acting as implementing agencies: the Convention Implementation Office in the Foreign Economic Cooperation Office (CIO/FECO), three provincial Project Implementation Units (PIUs), and to a lesser extent, five pilot municipal authorities and 250 termite control stations. A termite project team was established in CIO/FECO, which was responsible for day-to-day compliance with all of the GEF and Bank project requirements (e.g., legal, safeguard, fiduciary, and reporting). However,the ICR (p. 27) notes that “its leadership at the later stage of the project could have been stronger.”

      The project decided to establish provincial PIUs in the three pilot provinces (Anhui, Hunan, and Jiangsu) to manage most project activities in order to build technical and management capacity at the provincial level where better focused activities to change public perceptions and termite control practices in the building construction sector could be realized. The PIUs recruited and retained experienced and qualified personnel, submitted reports on time and of a satisfactory quality, and complied with all Bank grant covenants in discharging their fiduciary duties. The quality of supervision support provided by the three PIUs’ managers and technical staff was high, and their efforts in following up with local termite stations and project contractors was a key factor in the ultimate success of the project. The three provinces’ representative Steering Groups coordinated, supervised, and guided the project’s implementation, providing administrative as well as technical support. This reduced disruption risk during project implementation caused by frequent changes in key Bank project supervision personnel. Each province established its own Steering Committee, staffed its PIU, and hired an IPM advisor and IT expert to help install computers and operate the MIS in the 250 termite control centers.

      Implementing Agency Performance Rating: Satisfactory

      Overall Borrower Performance Rating: Satisfactory

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

      a. M&E Design:

      There were serious weaknesses with the M&E system design. First, there was only one Outcome Indicator [“No use of chlordane and mirex by the termite control professionals in the demonstration area”], focused on phasing out the of use of chlordane and mirex, without an Outcome Indicator to assess the cost-effectiveness of the IPM framework put in place by the demonstration project. Nor was there any Outcome Indicator to measure whether a National Replication Program had been prepared, which was the other half of the PDO, as stated in the Grant Agreement. Secondly, too many “Results Indicators” (26) were proposed, most of which were output-oriented (not focused on outcomes), such as numbers of personnel trained, bait systems installed, and policies updated. Third, these intermediate outcome indicators were organized according to the project’s components, each of which had one “Intermediate Result” used to measure its achievement, instead of having intermediate outputs or outcomes that would lead in a clearly articulated and logical chain of causality toward achieving the final outcome indicator(s) and PDO in the Results Framework of the PAD. A “Quality at Entry” review, conducted by the Quality Assurance Group in 2007, raised these concerns about M&E system design weaknesses (specifically the lack of measures to ensure that key policy and regulatory reforms were undertaken). The four “key project outputs” enumerated in the PAD (p. 12) did a much better job of capturing these other important aspects of the PDO, and would have better reflected the PDO in the Results Framework.

      b. M&E Implementation:

      Tables 2, 3 and 4 (pp. 33-39) of the ICR point out a number of accomplishments achieved under the various project components, including annual project meetings organized, training workshops held, and project materials prepared by FECO and others, indicating that the M&E system must have been systematically implemented. This is complemented by other evidence of M&E implementation, such as various guidance documents and monitoring reports (e.g., the MTR and ICR) that were prepared and provided to the Bank and GEF. However, many of these data points reflect outputs and thus did not fully measure whether these activities resulted in the outcomes required to achieve the PDO. To its credit, the project attempted to remedy this M&E design weakness by implementing additional studies/activities to collect data showing the effectiveness of baiting systems installed and the cost-effectiveness of baiting systems compared to the use of chemicals. Adjustments were made to four intermediate results indicators, and another results indicator for the installation of an alternative IPM termite bait monitoring and dusting system was added to the Results Framework. However, for reasons not explained in the ICR, project results indicators were not formally revised during project implementation.

      a. M&E Utilization:

      It is apparent from the frequent changes and adjustments made to the project during implementation that feedback from the M&E system was used to inform decisions on the project’s implementation based on data obtained from the M&E system. Thus, in retrospect, while the flawed design of the Results Framework and M&E system compromised the utility of the information generated by the M&E system in providing useful feedback to project managers, it was apparently used by them to track the progress (at least partially) made by the project during implementation.

      M&E Quality Rating: Modest

      11. Other Issues:

      a. Safeguards:
      The project was initially screened as a “limited impact” project, but was later designated as a Category A project reflecting potentially significant environmental or social impacts. The project triggered two Bank Safeguard Operational Policies: Operational Policy 4.01 on Environmental Assessment (EA), and Operational Policy 4.09 on Pest Management, with the key safeguard concerns associated with closing chlordane and mirex production facilities, and remediating contaminated sites. The project’s environmental and social impacts were examined in Environmental and Social Assessments. Mitigation measures were outlined in an Environmental Management Plan (EMP), while compensation measures were described in the Social Assessment since the project did not require any land acquisition or resettlement of people or communities. The project’s pest management activities were assessed in a stand-alone pest management plan (PMP) that described in detail the suggested integrated pest management activities, as well as a more desirable institutional and regulatory framework governing termite control in China (PAD, pp.107-109). According to the ICR (p. 15), two heavily contaminated chlordane and mirex plants were “successfully remediated” with all equipment, facilities, and wastes treated and disposed of properly. In terms of complying with the requirements of the PMP, the project complied with all provisions of OP 4.09 and BP 4.01 Annex C.

      In terms of social impacts, the project was required to compensate owners and workers of all chlordane and mirex factories for economic losses suffered as a result of stopping the production of chlordane and mirex at their plants. Altogether US$405,550 of compensation fees were paid to eight plants out of the six active and three inactive manufacturing plants in China. Ironically, the only plant that did not receive compensation for its economic losses was Liyang Guanghua, which had opted to drop out of the project just prior to Board approval because it believed that the compensation package it was offered by the project was insufficient.

      b. Fiduciary Compliance:
      A “Quality at Entry” review conducted by the QAG in 2007 rated Fiduciary aspects of the project as Satisfactory. However, disbursements were slower than planned initially due to lack of familiarity among project implementing agencies with the Bank’s FMR-based disbursement approach. This problem was not rectified by training provided to them, as evidenced by the admission that “withdrawal procedures and funds flow … were still slow up to early 2010 due to [unexplained] implementation delays” (ICR, p. 16.) The PIUs’ financial management systems were considered satisfactory, and financial statements and reports were prepared in line with Bank procedures. However, the two-year delay in making the first disbursement of project funds had serious repercussions for the project. In terms of procurement, plans were disclosed publicly in accordance with the Bank’s requirements, and all works and goods as well as the selection of consultants were carried out satisfactorily following the Bank’s guidelines.

      c. Unintended Impacts (positive or negative):
      By far the most significant unintended or unexpected impact or outcome of the project was the complete ban nationally on the “Production, Circulation, Use and Trade” of both targeted POPs (chlordane and mirex) along with DDT and HCB in May 2009.

      d. Other:

      12. Ratings:

      IEG Review
      Reason for Disagreement/Comments
      Moderately Satisfactory
      Moderately Satisfactory
      Risk to Development Outcome:
      Negligible to Low
      Neither the higher cost of monitoring termite bait systems nor the use of non-POP termiticides are considered likely to result in their re-introduction given public awareness about their health and environmental risks. 
      Bank Performance:
      Moderately Satisfactory
      Moderately Satisfactory
      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:

      Advantages of simultaneously addressing both the production and consumption sides of phasing out POPs outweigh the costs and risks of the additional complexity of this comprehensive approach. The PAD (p. 20) pointed out that China had previously had “disappointing experiences from past attempts to eliminate chlordane and mirex by focusing only on consumption-side interventions.” These experiences were in contrast to highly successful experiences from a Montreal Protocol ozone-depleting substances (ODS) phase-out project that had simultaneously addressed both the consumption and production side of their use. Similar positive experiences with comprehensive approaches taken to eliminate ozone-depleting substances in other countries, such as Venezuela and Malaysia, have been observed by IEG in other recent assessments.

      Accurate risk, needs, and cost assessments are needed up front during project preparation and appraisal, but must be complemented by adaptive management throughout project implementation and structured learning informed by a functioning M&E system in order to make necessary mid-course corrections and achieve the greatest results. This project miscalculated the required number of above-ground (AG) termite bait systems, which was arbitrarily set at an unrealistic level of 500,000 units. This created incentives for termiticide installers to meet their targets by “intentionally neglecting instructions when installing these systems at an early stage so they could finish their tasks on time” (ICR, p.28). Related to this issue were the decisions by one of the two pre-selected provinces (Zenjiang) and by the largest manufacturing plant (Liyang Guanghua Chemical Company) in China to change their minds and pull out of the project just prior to Board approval. On the other hand, changes made by project managers as the project evolved (described in more detail in Section 4) were instrumental in achieving the project’s objective and obtaining the greatest results possible by demonstrating the effectiveness of IPM approaches even though it forced the abandonment of one IPM approach in favor of other more cost-effective ones.

      It is critically important to design the Results Framework and M&E system to fully reflect the PDO. The Results Framework had only one Outcome Indicator, which did not fully encompass the PDO whose real purpose was to demonstrate the effectiveness of the IPM approach to control termite damage and establish a cost-effective framework for doing so. It also ran counter to what the Bank says it had already learned from previous experiences in China with interventions that only addressed one side or the other of the supply and demand for potentially harmful products or substances. By only addressing the use (consumption) of the two targeted POP termiticides, the Results Framework omitted the imperative to also address the supply (production) side as part of a comprehensive and integrated project.

      Connecting counterpart implementing agencies and knowledge centers with international experience, expertise, and best practices can greatly increase the effectiveness and sustainability of Bank projects. A large part of this project’s success was due to its implementation model, which dynamically linked different Provincial Implementation Units and local Termite Control Stations with other national and international researchers, consultants, and research centers. This exchange of worldwide experiences in different locations and conditions facilitated a fluid transfer of knowledge and expertise, with timely "real-world" feedback from field application (regarding cost and effectiveness) back to research institutions. This allowed the rapid refinement of IPM technologies and strategies in a dynamic process of structured learning. Bringing in other ideas and experiences from around the world and combining that with the "common sense" perspective of local practitioners can be a useful strategy for many other Bank-supported projects around the world, especially for demonstration projects involving a strong need for scientific expertise and experimentation.

      14. Assessment Recommended?


      15. Comments on Quality of ICR:

      The ICR is candid, clear, concise, objective, insightful, independent, well-organized, and comprehensive. In addition to meeting all of the requirements for an competent and complete ICR, it offers a better, alternative approach for assessing the efficacy of the project in terms of achieving its PDO than the information provided solely in the Results Framework, which it accurately criticizes before proposing a better alternative. Ample evidence is provided throughout to justify its assertions and ratings.

      a. Quality of ICR Rating: Exemplary

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