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Implementation Completion Report (ICR) Review - Tn-cultural Heritage

1. Project Data:   
ICR Review Date Posted:
Project Name:
Tn-cultural Heritage
Project Costs(US $M)
 23.79  33.6
L/C Number:
Loan/Credit (US $M)
 17.0  24.8
Sector Board:
Urban Development
Cofinancing (US $M)
Board Approval Date
Closing Date
06/30/2007 12/31/2011
Other social services (78%), Law and justice (12%), Other industry (9%), Central government administration (1%)
Infrastructure services for private sector development (40% - P) Law reform (40% - P) Export development and competitiveness (20% - S)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Tomoko Kato
Robert Mark Lacey Soniya Carvalho IEGPS1

2. Project Objectives and Components:

a. Objectives:
The project’s development objectives as stated in the Project Appraisal Document (PAD p.2) are:

“To assist the Government of Tunisia in the sustainable management of the country’s cultural heritage in order to develop cultural tourism and, in time, gain additional revenue.”

The development objectives specified in the Loan Agreement (Schedule 2) are:

“To assist the Borrower in its efforts to ensure the sustainable management of the country’s cultural heritage with a view to developing cultural tourism.”

This review is based on the project development objective statement in the PAD, which is more monitorable.

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

c. Components:

A. Policy Development and Capacity Building (Planned: US$2.15m; Actual: US$0.52m) 
This component provided assistance to strengthen the country’s cultural policy through: a) facilitating implementation of the existing law, the Code du Patrimoine; b) developing new national policies for museums and for site management (Southern sites); and c) reorganization, recruitment, and training at the Cultural Heritage Improvement and Development Agency (APPC) and, to a lesser extent, at the National Institute of Cultural Heritage (INP).

B. Market Development (Planned: US$1.62m; Actual: US$1.24m)
The component included: a) promotion and distribution programs (development and marketing of cultural products, service, databases, documentation and publications, and tariff policy); and b) the development of a communication strategy directed to foreign and local visitors, including students and school children, as well as professionals from the tourism sector.

C. Site Development and Management (Planned: US$18.08m; Actual: US$$29.20m)
This component focused on the six-selected site development and on their management, including improved access, tourist facilities, and security. In some cases, it included museum construction:

- Carthage: Protect the site against damaging development and make it more accessible to visitors: i) preparation of a mobility study; ii) road and parking improvement; iii) construction of amenity buildings for tourists; iii) construction of amenity buildings for tourists; iv) improved use of museum space in Brysa; and v) a study on the preservation of water reservoirs at Maalga.
- Bardo Museum: Improve visitor information and collection presentation as a museum of international standard: i) a comprehensive development study of the museum and site; ii) the redeployment of museum space and collections; iii) visitors’ orientation facilities that will include the presentation of cultural products and documents; and iv) construction of extensions to existing buildings.
- Kairouan Medina: i) Build on the accomplishments of a local team by creating a presentation space for the mosque and the medina, developing a circuit of visitors; ii) strengthening relations with local partners, the Association de sauvegarde de la Medina, and professional organizations.
- Sousse: Focus on improving the Sousse archaeological museum and circuits in the nearby medina, and tourist information and communication with tour operations and hotels.
- Djerba Island: Cultivate the island’s cultural identity and increase communication between visitors and inhabitants: i) The rehabilitation of the Museum of Arts and Traditions of Houmt Souk; and ii) in partnership with l & associations, the development of cultural itineraries, the revitalization of traditional handicraft workshops with marketing outlets, and contributing to the preservation of the island’s natural habitat.
- Oudna: Provide amenities using existing buildings, and resorted rooms under the major Roman temple, thermo and amphitheater. Preparation of a pilot site conservation and improvement plan to be used later as a reference model for the preparation of similar plans in comparable sites.

D. Project Management (Planned: US$1.77m; Actual: US$2.57m). This component covered various investment and operating costs associated with the management and supervision of the project (materials, equipment and vehicles, salaries, overhead, etc.) The salaries of the Project Unit were to be financed out of the Tunisian counterpart funds.

Revised Components:

At the time of the mid-term review in January 2005, the project was restructured (Level 2). The ICR notes that the scope of Components A, B, and C was scaled down in order to accelerate lagging disbursements (only 7% of the total loan amount had been disbursed by the mid-term review): Some of the original sub-components that had become either obsolete or lost their relevance (Component A and B) were deleted. The works that had been planned on two sites (Carthage and Oudhna) were significantly reduced in order to focus on the four remaining sites (Bardo, Sousse, Kairouan, and Djerba).

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

Project Cost
The overall project cost at completion was US$33.56m, 142 percent of the total appraisal estimate (US$23.63m), but in euro terms the project cost was €25.61m, 96 percent of the total appraisal estimate (€26.68m). Over the life of the project the euro appreciated against the US dollar by 49%.

The IBRD Loan was denominated in euros. By project closure on December 31, 2011, the project had disbursed €18.9 million, 98% of the original Loan amount of €19.2 million. In addition to the Bank financing, US$327,000 amount of Trust Fund financing from the Italian Government was committed in December 2003, of which 92 percent (US$302,500) had been disbursed by project closure. The project design was based on a feasibility study prepared by the Government with grants from Italy and Japan.

Borrower Contribution
At appraisal, the Government of Tunisia planned to allocate US$6.8 million (EUR7.7 million) as a counterpart fund. The ICR Annex 1 reports that the actual Borrower contribution was US$8.8 million (EUR6.7 million), 87 percent of what was originally promised.

The project was granted three closing date extensions (from June 30, 2007 to June 30, 2010; from June 30, 2010 to June 30, 2011; and from June 30, 2011 to December 31, 2011) for a total of four-and-a-half years (75% of the originally estimated time span). The first two extensions were granted to enable completion of works on three of the four project sites that had significant implementation delays. The third extension was requested to compensate for additional delays due to the political unrest that occurred in Tunisia between December 2010 and March 2011.

3. Relevance of Objectives & Design:

a. Relevance of Objectives:
The FY2010-2013 Country Partnership Strategy for Tunisia acknowledges the importance of the tourism sector, and notes that preserving and better promoting Tunisia’s cultural heritage is a critical element in transforming the current tourism model (based on the lower-cost tours focusing on beach vacations) to a higher-end model with greater value-added to the local economy.
At the time of appraisal, the objectives were also relevant to Tunisia’s own strategy. The Government considered tourism to be an important sector, with potential for contributing to economic growth (noted in the 11th National Development Plan for 2007-2011). The Government had become increasingly aware that Tunisia’s cultural heritage is a significant resource offering the potential for national and local economic development.
However, shortly after Board approval at the end of June 2001, the Authorities changed their approach and, while still acknowledging the economic importance of tourism, no longer considered the project’s objectives to be relevant to their policy goals. In particular, there was an unwillingness to undertake essential reforms and institutional measures needed to ensure the sustainable management of the country's cultural heritage and to achieve the project's development objectives (see Section 9 below).

b. Relevance of Design:
Based on Bank global experience on cultural heritage development, the project was designed to include institutional reform, marketing and communication, site development and project management components for creating an enabling condition for the cultural tourism. The causal chain between the activities supported by the project and its objectives was partial: three elements -- (i) policy support stemming from national strategy (to be agreed and implemented under the project), (ii) market development for cultural tourism and products, and (iii) improved infrastructure and management -- would together be expected to contribute to the overall development of cultural tourism and related economic gain. Environmental sustainability was to be addressed through (i) procedures to include local governments in site preservation and improvement activities; and (ii) establishment of
a local team of "conservateurs" and a promotion specialist to implement policy at the local level (PAD, page 20). However, design contained little detail regarding the political and operational feasibility of such an approach. Moreover, the last portion of the Project Development Objective, “ in time, gain additional revenues”, is vaguely defined -- how long is “in time,” and what is the scale of the additional revenue expected?

4. Achievement of Objectives (Efficacy) :

To attain sustainable management of the country’s cultural heritage by developing cultural tourism through policy and institutional reform and physical site construction, and in time gaining additional revenues - Modest
  • Construction works for the Djerba museum and Kairouan visitors’ center were completed in 2008. Those at Bardo and Sousse were completed in 2011. Visitor circuits were completed in Kairouan while those in Sousse were dropped.
  • An exhibition area meeting international standards was installed in three museums together with one interpretation center.
  • Museum pieces were exhibited according to international standards in three museums: in Bardo there were 6,000 sq meters of exhibition space; in Djerba 680 sq. meter; and Sousse 400 sq. meter.
  • A national heritage management strategy was initially agreed upon. However, due to shifts in national priorities, implementation was only partial.
  • Personnel were recruited for museum management: by project closure, 76% of the planned number of recruitments had been completed.
  • 207 staff from three museums (Bardo, Djerba and Sousse) received training in various aspects of management. In addition, technical training was given on mosaics restoration and preservation for INP staff. According to the project team, there was "an important transfer of knowledge to all staff associated with museums' improvement and management."
  • A marketing strategy was completed in 2005, and its recommendations endorsed by key stakeholders. However, only 60% of the proposed program was implemented.
  • Five media events were organized, including workshops, colloquies and conferences on cultural heritage management.
  • Four websites were created (for the project management unit, Bardo and Djerba museums and the Agency for the Development and protection of Cultural Heritage).
  • 300 road signs indicating major cultural heritage sites on the main roads were placed in accordance with the UNESCO International guidelines.
  • According to the ICR, involvement of local associations in project implementation was successful in Kairouan but limited in Djerba. The ICR provides no information on the other sites; the project team subsequently clarified that no involvement of local associations had been planned at these sites.
  • The analysis of the achievement of objectives in the ICR (pages 15-16) is almost entirely restricted to outputs. With regard to outcomes, the ICR states only that “while the project contributed significantly to improving the prospects for the development of culture tourism, the lack of institutional change, which was essential to reaping the benefits of the project, justifies a moderately unsatisfactory rating at this stage.”
  • The aim of establishing an agreed strategy for the development of cultural tourism which concords with the country’s current stated development priorities was only partially achieved. "Despite agreement from key stakeholders, shifts in national priorities and resulting changes in key sector authorities following project approval impeded actual implementation of critical sector strategies and reforms" (ICR, page iv).
  • There is no evidence of sustainable management of the country’s cultural heritage as a result of the project. Essential sector reforms, which are a pre-requisite for this, have not been carried out. There has, as yet, been little willingness to accord a significant degree of managerial autonomy to the museums and cultural sites or their local associations.
  • There is little information provided in the ICR on provision for the operation and maintenance of the improved sites. The project team noted that “little effort has been made to plan for [this].”
  • There is no evidence provided on any additional revenue accruing from the improvements supported by the project. As the ICR (page 11) points out, "the increase in the number of visitors and revenues did not prove relevant as these increases were dependent on the completion of works and the reopening of the museums, something that happened only after the closing of the project. These indicators were thus cancelled at project restructuring in November 2011.” (In general terms, the number of tourists peaked in 2008, but declined from 2009 onward, primarily as a result of the financial and economic crisis in Europe. The decline was aggravated in 2011 by the events related to the “Arab Spring.‟ The proportion of the falling number of tourists visiting cultural sites and museums also declined over this period.)

5. Efficiency:

A cost benefit analysis was carried out at appraisal for four of the six originally planned project sites (Carthage, Bardo, Kairouan and Sousse). No rates of return were calculated for the other two sites (Djerba and Oudhna). The benefits were the income of the sites based on a survey of willingness-to-pay the increases in admission prices to finance the proposed improvements. The resulting ex ante economic rates of return (ERRs) were 40% for Carthage, 17% for Bardo, 20% for Kairouan, and in excess of 70% for Sousse.
At completion, ERRs were calculated for three sites (Bardo 21%, Kairouan 30%, and Sousse 16%), representing 85% of project site development investments. However, the ICR notes (page 25) that that the Bardo and Sousse museums have just re-opened to the public, and the Kairouan site is not fully operational, pending installation of the museum display. All data regarding incremental revenues and costs are therefore hypothetical and consist of estimates based on […] assumptions.”
The project contributed to the physical work on four historic sites (instead of the six originally planned) after a total implementation period of 10 years, 4.5 years more than the appraisal estimate.
Efficiency is rated modest.

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 is rated modest in view of the disconnect, for most of the implementation period, between the project's goals and government priorities for the sector. Relevance of design is also rated modest.. The objective of developing cultural tourism, by realizing institutional and policy reform, and by constructing/improving historic sites, was modestly achieved. Efficiency is rated modest.

a. Outcome Rating: Unsatisfactory

7. Rationale for Risk to Development Outcome Rating:

According to the project team, no provision has been made for the financing of the operation and maintenance of the developed sites.

The project did not, as envisaged, consult with communities on site developments, or involve them in the decision-making process. Nor is there any regular consultation mechanism involving relevant stakeholders (local government, communities, private sector). This heightens the level of social risk.

Political instability and security issues in the region pose significant risks for project sustainability.

Economic risk is also significant. As Annex 4 of the ICR shows, the economic crisis of 2008-2010 was reflected in a decreased number of foreign tourists visiting Tunisia. The majority of visitors to Tunisia come from the European Region, where the prospects for a recovery in growth remain uncertain.

a. Risk to Development Outcome Rating: Significant

8. Assessment of Bank Performance:

a. Quality at entry:
Before and during project preparation, the Bank team responded to the Government’s efforts to define a national tourism strategy aimed at strengthening institutional capacity for creating and adapting policies suitable for an evolving national and international environment (PAD page 5). Learning from previous Bank international experience on cultural heritage development, design included institutional reform, marketing and communication, site development and project management components. Based on the lessons learned from other projects, the design supported a multi-sectoral approach to involve various stakeholders in cultural conservation and tourism development. The promotion of civil engagement for the heritage conservation and tourism was envisaged at the preparation phase for the sustainability of the cultural heritage conservation and development of tourism with local involvement.

Some potential risks were assessed and appropriate mitigation measures incorporated: a) the risk of weak coordination among key stakeholders (Agency, Institute, and Tourism Bureau) was to be mitigated by the setting up of a Steering Committee to oversee and provide guidance; and b) the risk of recurrent procurement related delays was mitigated by setting up specific outcome indicators on procurement under the Project Management Component. However, the possibility of a significant change in government policy and priorities for the tourism sector was clearly not foreseen (although such a change was to occur shortly after Board approval).

There were several significant shortcomings in Quality at Entry:

  • The project was not ready for implementation since there were unfinished technical studies for the major physical works;
  • A suitable enabling environment for the project to be launched and implemented smoothly with an appropriate institutional arrangement, was not in place at the beginning of implementation. No Executive Order had been issued laying out the responsibilities of the two implementing agencies;
  • As the ICR acknowledges, the implementation timetable was unrealistic in view of the complex public procurement procedures in Tunisia; and
  • Design of the monitoring and evaluation framework was weak. It did not include outcome indicators for institutional reform and marketing/communication. Many indicators lacked baseline values and there was no designation of responsibility for M&E management and implementation.

Quality-at-Entry Rating: Moderately Unsatisfactory

b. Quality of supervision:
The Bank team provided regular supervision two or three times per year with a similar team composition (ICR, page. 19). This enabled timely reallocation of funds in accordance with the evolving political and economic situation. Safeguard and fiduciary compliance were consistently rated as satisfactory in Bank supervision reports. However, there were major shortcomings:

  • Given the significant change in the Government’s approach towards tourism development shortly after Board approval, action should have been taken at an early stage to restructure the project and revise the development objectives. As it was, lack of Government ownership of the project as designed, and the lack of a comprehensive cultural tourism strategy throughout implementation, undermined the achievement of the project’s objectives. In the event, a level 2 restructuring took place only in November 2011, eleven months before project closure. The objectives were not changed, and only indicators were revised. The relevance of some of the revised indicators to the project development objectives remained weak (see Section 10 below).
  • Implementation Status Reports (ISRs) lacked candor. Up to the mid-term review, despite the slow disbursement and project implementation delay, supervision missions consistently rated both “progress towards achievement of objectives” and “overall implementation progress” as satisfactory.
  • Although ISRs indicate that regular training on Bank procedures was provided, more focus on this issue, and perhaps more intensive training, would have been appropriate, given the known complexity of the Government’s own procurement procedures,.
  • The supervision team could also have assisted in improving coordination of the activities of the different implementing agencies. The Steering Committee formed for this purpose was largely inactive, and little seems to have been done to resolve this problem.

Quality of Supervision Rating: Unsatisfactory

Overall Bank Performance Rating: Unsatisfactory

9. Assessment of Borrower Performance:

a. Government Performance:
At the time of project preparation, the Government demonstrated strong commitment to the project which was fully aligned with national strategy for the development of the tourist industry. A series of governmental actions illustrate this interest: creation of the legislative and institutional foundation for cultural asset management and promotion; enactment of a new law on cultural heritage (in 1994); and beginning the creation of a cultural heritage site inventory (1998). Moreover, the Government initially provided adequate counterpart funds in a timely manner (ICR, pages 19-20) and completed the works deleted from the project at the mid-term review.
However, the changes at ministerial and upper management levels, which took place shortly after Board approval, led to a different approach towards tourism and cultural heritage development (ICR, pages 7, 8 and 9). The Government became unwilling to undertake the policy and institutional reforms essential to ensure the sustainable management of the country's cultural heritage. "The Government was also loath to implement the proposed coordination between the entities responsible for heritage preservation" (ICR, page 19). Except for membership of largely ineffective steering committees and working groups, there was very little linkage or cooperation between the project implementing agencies (AMVPPC and IPN) and the Government entities responsible for promoting Tunisia as a tourist destination abroad and overseeing and regulating tourism activities within the country (the Ministry of Tourism and the National Institute of Tourism). Absence of governmental ownership after 2001 was a major factor behind the failure to achieve the policy reforms supported by the project.

An executive order delimiting the respective responsibilities of the two key implementing agencies –INP and the AMVPPC -- was prepared by the Ministry of Culture in 2001, but was never enacted. While the Steering Committee was established to address the linkage and corporation issues between two agencies, there was no active involvement of the Committee in mitigating inter-institutional frictions and establishing an agreed institutional framework.

Implementation delays were caused by the complexity of government procurement procedures.

Political upheaval during and following the Arab Spring events disrupted the project-related activities and led to a reduction in the number of foreign tourists.

Government Performance Rating: Unsatisfactory

b. Implementing Agency Performance:
There were two implementing agencies -- AMVPPC (overall implementing agency) and the National Institute of Cultural Heritage (INP, the technical agency). According to the ICR (page 20), weak coordination between them and the lack of a clearly defined role for each, undermined the work of the Project Management Unit (PMU). Implementation arrangements made for the project did not resolve this ambiguity about the role of the two agencies.

The Project Management Unit (PMU) was housed within the Agency for Cultural Heritage Improvement and Development (AMVPPC). The Unit was instrumental in completing several activities, including the construction of highly appreciated museums (as reflected in the comments of the Directors of UNESCO and the International Council of Museums cited in Annex 8 of the ICR). Nevertheless, the Unit's best efforts were undermined by the difficulties of its operating environment. Implementation was characterized by coordination problems and policy issues reflected in a 4.5 year delay and the completion of considerably fewer outputs than originally planned.
Safeguard and fiduciary compliance was rated as satisfactory in Bank supervision reports.

Implementing Agency Performance Rating: Moderately Unsatisfactory

Overall Borrower Performance Rating: Unsatisfactory

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

a. M&E Design:
The M&E system was limited at the outset and lacked explicit and quantifiable outcome, and even some output, indicators that could demonstrate progress towards achievement of the project objectives. Some important aspects on which project assistance was envisaged were not clearly translated into a set of indicators -- for example institutional strengthening for conservation, management and promotion of cultural heritage, civil participation in cultural asset protection, and possible economic gain at the local and national level in both the short and the long-term. The system also lacked baseline data. The institutions to be responsible for tracking the indicators and for managing the M&E system were not specified.

b. M&E Implementation:

The informal revision of the results framework and the restructuring of indicators took place during the mid-term review in January 2005, although these changes were not formalized until November, 2011.
The indicators and the results framework were modified to incorporate baseline indicators and to adjust targets to reflect actual project implementation progress. The main reason for the revision was to better align indicators with actual project activities and the political environment

However, the new indicators remained output oriented (for example, numbers of trained personnel , personnel benefitting from technical training on mosaics restoration and preservation, preparation of a marketing strategy, installation of signs, and organized media events) and did not capture the intended outcomes of project interventions. Some indicators, such as the increase in the number of visitors and revenues, were dropped, and officially cancelled in November 2011 (11 months before the extended closing date), since it was considered that such indicators had become irrelevant in the light of the project’s likely state of completion at closure.

a. M&E Utilization:

The ICR does not report on the utilization of M&E data.

M&E Quality Rating: Negligible

11. Other Issues:

a. Safeguards:
The project was classified as Category “B” for Environmental Assessment purposes. The only safeguards policy to be triggered was Environmental Assessment (OP 4.01). The ICR reports (page 12) that “a framework Environmental Management Plan (EMP) was developed during project preparation and fully adhered to during implementation.” According to the ICR (page 12), site specific Environmental Impact Assessments were also prepared by the Institut National du Patrimoine to be submitted to the relevant Tunisian authorities after the required consultation process with relevant stakeholders. Although it was not yet established at the time of appraisal, the ICR reports (page 12) that compliance with OP 4.11 (Physical Cultural Resources) was ensured through the joint oversight of the two national agencies responsible for cultural heritage management. The ICR (page 13) states that “there were no environmental or other safeguard issues for any of the project sites raised during the implementation of the project,” but does not state explicitly that OP 4.01 was complied with.

b. Fiduciary Compliance:
Financial management. The ICR (page 13) reports that “Financial Management was consistently rated satisfactory and reporting was done on schedule.” In particular, “all audit reports were submitted on time and were consistently unqualified.” However, the December 2010, September 2011, and November 2011 Implementation Status Reports note that there were overdue audit reports. According to the ICR, all financial covenants were complied with.

Procurement. According to the ICR, procurement was carried out with delays, but in full accordance with Bank guidelines. There were no reported cases of misprocurement.

c. Unintended Impacts (positive or negative):

d. Other:

12. Ratings:

IEG Review
Reason for Disagreement/Comments
Moderately Unsatisfactory
Relevance of objectives is rated modest in view of the disconnect, for most of the implementation period, between the project's goals and government priorities for the sector. Relevance of design is also rated modest. The objective of developing cultural tourism, by realizing institutional and policy reform, and by constructing/improving historic sites, was modestly achieved; efficiency is rated modest. 
Risk to Development Outcome:
Bank Performance:
Moderately Unsatisfactory
There were major shortcomings in the quality of supervision, in particular, the fact that the project was not restructured at an early stage despite the significant change in the Government’s approach towards tourism development shortly after Board approval.  
Borrower Performance:
Moderately Unsatisfactory
Absence of governmental ownership of the project after 2001 was a major factor behind the failure to achieve the policy reforms supported by the project. An executive order delimiting the respective responsibilities of the two key implementing agencies was prepared by the Ministry of Culture in 2001, but was never enacted. Implementation delays were caused in large part by the complexity of government procurement procedures.  
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 first two of the following lessons are drawn by IEG and the third is taken from the ICR:
  • Once it becomes clear that a project's objectives and design no longer coincide with the strategy or priorities of the Borrower, the sooner the operation is restructured, the better: In this case, this was not done.
  • A robust M&E framework requires up-front agreement with the implementing agencies concerning the importance and reliability of data and its collection: In this case, because the attention of the Project Implementation Unit was mainly directed towards construction activities, and because indicators on institutional reform, market development and stakeholder involvement in the sustainable cultural heritage development, were inadequate, monitoring of progress towards attaining the project’s development activities was weak.
  • Risk evaluation on the ownership of, and commitment to, major sector reform plays a core role in setting appropriate and feasible project objectives and scope. The risk of weak coordination of implementing agencies was well analyzed during preparation, and the Steering Committee proposed to mitigate it. However, after the government policy changed, it became clear that not all the relevant stakeholders shared the same vision of sector reform.

14. Assessment Recommended?


15. Comments on Quality of ICR:

The ICR is well written in a clear and comprehensive manner. The report provides a candid assessment of the conditions surrounding both the design and implementation of the project. However, there is limited evidence on the achievement of outcomes and the extent to which intermediate goals (for example, institutional reform, business development, civil engagement, private sector involvement, and stakeholder participation) were attained. There was some discrepancy on the assessment of fiduciary information from the supervision reports with regard to the timeliness of report submission. There is no clear statement of compliance with safeguards policies.

a. Quality of ICR Rating: Satisfactory

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