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Implementation Completion Report (ICR) Review - Energy Efficiency Project


  
1. Project Data:   
ICR Review Date Posted:
09/27/2013   
Country:
Uruguay
PROJ ID:
P068124
Appraisal
Actual
Project Name:
Energy Efficiency Project
Project Costs(US $M)
 21.16  15.62
L/C Number:
Loan/Credit (US $M)
   
Sector Board:
Energy and Mining
Cofinancing (US $M)
 6.88  6.82
Cofinanciers:
GEF
Board Approval Date
  05/13/2004
 
 
Closing Date
06/30/2010 12/31/2011
Sector(s):
Energy efficiency in power sector (94%), Central government administration (6%)
Theme(s):
Climate change (67% - P) Infrastructure services for private sector development (33% - S)
         
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Richard L. Berney
Robert Mark Lacey Soniya Carvalho IEGPS1

2. Project Objectives and Components:

a. Objectives:
This Energy Efficiency Project was conceived as a complement to the institutional components of the Electricity Transmission and Distribution Project (US$125 Million, Approved May 11, 1994) as a means of stimulating the national power company, and the private and public sectors, to invest in energy efficiency improvements.

The project development objective as stated in the Global Environment Facility Trust Fund Grant Agreement (page 22) is " to increase consumer demand for and competitive supply of energy efficient goods and services, contributing to: (a) improved productivity of energy use; (b) reduced reliance of the Recipient’s economy on imported electricity and fossil fuels; and (c) reduced emissions from the energy sector.
The project development objective as stated in the Project Appraisal Document (PAD, page 2) is virtually identical: "to increase the demand for and competitive supply of energy efficient goods and services, contributing to: (a) improved efficiency of energy use; (b) reduced reliance of the Uruguayan economy on imported electricity and fuels; and (c) reduced emissions from the energy sector."
The project’s Global Environmental Objective, as stated in the PAD (page 2) is: "to promote energy efficiency through (i) building capacity and know-how among stakeholders; (ii) stimulation of consumer demand; and (iii) promotion of project development and investment financing."
This Review uses the Project Development Objective of the Global Environment Facility Trust Fund Grant Agreement.

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

c. Components:

There were three original components:

Component 1: Energy Efficiency Market Development. (Appraisal US$10.83; Actual US$4.82): This component, implemented by the Ministry of Industry, Energy, and Mining (MIEM), was to strengthen the market for energy efficient goods and services. The component supported energy efficiency efforts in all economic sectors. It included two main activities:

  • Market strengthening: The activities under this sub-component included: (i) developing policies and regulations for promoting energy efficiency; (ii) improving awareness of potential energy efficiency improvements and capacity building programs; and (iii) a labeling and standards program including a voluntary energy efficiency seal for main household appliances, lighting equipment, building thermal envelope and industrial and other equipment and materials;
  • Uruguay Fund for Energy Efficiency (UFEE): The Fund facilitated the financing of energy efficiency projects. It was to support (i) fund management services, (ii) a Project Development Facility to provide contingent grants to cost-share feasibility studies, and (iii) a Project Finance Facility to provide term debt to energy investment projects by energy service companies, business, and industry. It was conceived to be managed by a commercial bank.
The component was restructured twice, first in 2007 and then again in 2011, just before project closure. In 2007, the Uruguay Fund for Energy Efficiency (UFEE) investment Fund was redesigned as a Guarantee Fund. The US$2.5 million of GEF funds originally allocated for this component were allocated to the Guarantee Fund. This conversion was implemented because UFEE, with its relatively limited resources, found itself unable to place its loans in competition with the increasingly liquid private financial system. The guarantee mechanism was expected to allow UFEE to continue supporting energy efficient investments with what was anticipated to be a more responsive tool. However the banking sector showed little interest in using this guarantee fund. In June, 2011, the UFEE Guarantee Fund, with its US$2.5 million of GEF funds, was incorporated into the Uruguay National Guarantees System (SIGA), an institution that was established subsequent to UFEE's original capitalization.

Component 2: Utility-Based Energy Efficiency Services. (Appraisal US$8.98; Actual US$9.42) This component assisted the creation and operation of an Energy Savings Unit within the national power company (UTE). It included:
  • Establishment of a UTE Energy Service Unit (ESU). This sub-component provided support for technical assistance to advise UTE on establishing the unit and on carrying out market surveys. UTE’s own resources supported the costs of staffing, administration and office costs, marketing, training, and monitoring and evaluation of activities of the unit.
  • Demand Side Management (DSM) and Energy Efficiency Investments by the Energy Service Unit of UTE. These activities comprised three initial projects defined during preparation plus further follow-up investments determined during the early years of operation. The initial pipeline of projects included: (i) provision of efficient lights, water heaters and other energy efficient equipment to residential and commercial customers in three municipalities; (ii) installation of new municipal lighting equipment in three municipalities and (iii) improving the retail electricity distribution system in three areas to reduce losses, and increase end-use efficiency and payment levels in poor urban neighborhoods. New projects were to be added, as long as they meet the criteria for energy efficiency investments.
  • Solar Home Systems (SHS). This sub-component would provide SHS to dispersed rural populations.

Component 3: Project Management. (Appraisal US$1.35; Actual US$1.38) This component funded the work of the Project Management Unit in the Ministry of Industry, Energy and Mining, and supported the services provided by the accounting, acquisition, and information management departments of UTE.

d. Comments on Project Cost, Financing, Borrower Contribution, and Dates
Project Cost: Total project cost was US$15.62 million, US$5.54 million (26%) less than the appraisal estimate. Expenditures on market development activities for generating demand for energy efficiency projects and products were US$4.82 million, about 45% of the US$10.83 the appraisal estimate. The expenditure by the electricity utility UTE on energy efficiency activities was US$9.14 million, about four percent above the appraisal estimate. Project management costs were US$1.38 million, about two percent above appraisal estimates.

Financing: US$6.62 million of the US$6.88 million GEF grant was disbursed. The remaining US$0.26 million dollars was cancelled. GEF funds provided about 44% of total project expenditures, compared with the appraisal estimate of 33%. The primary reason for the higher GEF percentage was that financing by sub-borrowers for energy efficiency projects, which the appraisal estimated would be US$6.08 million, failed to materialize. GEF financing of project management activities was US$0.16, about 30% above the appraisal estimate. Marketing development expenditures were US$0.21 million, about 5% below the appraisal estimate. There were no other external sources of financing.

Borrower Contribution: The national power company, UTE, and the Ministry of Industry Energy and Mining, contributed US$8.8 million for the project activities, US$0.6 million more than the appraisal estimate.

Dates: In April 2010, GEF grant resources were reallocated and an additional activity, the financing of energy efficiency laboratory testing equipment, was introduced under Component 2, and the project closing date was extended by eighteen months, to December 31, 2011


3. Relevance of Objectives & Design:

a. Relevance of Objectives:
Substantial: The objectives are relevant to the 2005-2010 Country Assistance Strategy (CAS) and to the 2010-2015 Country Partnership Strategy (CPS), both of which include improvements in energy efficiency as part of their basic program. The CAS supported improving energy use by creating an enabling policy and regulatory environment (CPS page 16). The CPS has included both energy sector strengthening and Energy Efficiency as part of the outer year indicative lending program (page 18) in the context of improving competitiveness and infrastructure, the second of the Bank's four pillars for 2010-2015 (page 17).
The cost of energy for a country without any hydrocarbon reserves, such as Uruguay, is very large, and seeking to maximize efficiency within economic limits is a relevant objective from the country’s point of view.

b. Relevance of Design:
Modest: There is a clear, if implicit, causal chain linking most, but not all, of the project activities and their expected outputs to the intended achievement of the objectives. The project addressed the lack of demand for energy efficient goods and services by (i) supporting a program to increase awareness of the benefits that could be derived from more efficient energy using devices; (ii) promoting the development of companies that support energy efficiency investments; and (iii) facilitating access to financing for commercial energy efficiency investments. However, at the time of the appraisal, electricity prices were very low because most of Uruguay's electricity came from Argentina, where it was generated from low cost hydroelectric dams and low cost natural gas. And as long as energy prices were low, it was unlikely that these activities would lead to increased consumer demand for energy efficient goods and services. And it was most unlikely that a competitive supply of these goods and services would emerge without a significant demand for them. This effort to engage the target population in a program to improve energy efficiency was not likely to succeed until energy prices increased significantly, an outcome that was not anticipated at the time of project appraisal.

For two of the project components there does not appear to be a causal chain linking the Grant Agreement’s Development Objective of increasing consumer demand for and competitive supply of energy efficient goods and services. These components were:

  • Improving the retail electricity distribution system and payment levels in poor urban neighborhoods, under component 2.
  • Providing Solar Home Systems to dispersed rural homes, also under component 2.


4. Achievement of Objectives (Efficacy) :

The first two objectives -- (a) Improved productivity of energy use; and (b) Reduced reliance of Uruguayan economy on imported electricity and fuels . are closely interlinked through various activities, most of which were mutually supporting the targeted outcomes through increasing the demand for, and competitive supply of, energy efficient goods and services in the economy. Their efficacy is considered together. On balance, they are rated substantial.
Outputs:
1. Policies and regulations were developed for promoting energy efficiency.
  • An Energy efficiency law was established. The energy efficiency law corrected a number of uneconomic disincentives to energy efficiency investments.
  • Laws were passed establishing Daylight Saving Time and promoting the use of solar thermal energy.
  • Decrees were passed promoting energy efficiency (EE) within energy generation activities, establishing an EE labeling initiative; establishing standards for insulation of buildings; and promoting EE in the public sector.

2. A labeling and standards program was established for lighting, water heaters and refrigerators.
  • A compulsory energy efficiency evaluation and labeling system for compact fluorescent light bulbs, electrical heaters and refrigerators was implemented.
  • A water heater and lamp testing laboratory was designed and equipped.
  • Forty-nine energy efficiency national norms were developed and published.
  • UTE installed efficient public lighting and rehabilitated the networks in two municipalities (approximately 1,500 lamps).

3. Programs were implemented to improve the public's awareness of potential energy efficiency improvements and to build capacity.
  • Methods for providing the general public with ways to access energy sector information were evaluated.
  • Radio and TV campaigns for the dissemination of energy efficiency information were designed and implemented.
  • A primary school energy efficiency text was developed and disseminated.
  • Courses oriented to energy service companies, energy-related staff in the public sector, and primary, secondary and community center teachers were developed.
  • Some 3,200 stakeholders were trained in energy efficiency practices, twelve times the target of 250.

4. Feasibility studies and energy audits were carried out and support mechanisms for EE investments were put in place.
  • Studies covering Uruguay's cogeneration potential, its solar thermal potential, and its energy savings potential were completed.
  • A study was implemented on the use of solar water heaters in low-income housing.
  • Six energy audits were financed (2 public sector, 4 private sector), nine energy efficiency diagnostic studies were completed, of which eight were implemented by Energy Service Companies, and 37 energy efficiency investments for public sector buildings were evaluated, 12 of which were implemented.
  • Blueprints for Energy Supply Company interventions were developed, including standardized contractual instruments to support the projects, and organized training courses for their staff.
  • A project monitoring and evaluation methodology was established.
  • The Uruguay Fund for Energy Efficiency (UFEE) was established. When the commercial banks became more liquid, they became interested in providing energy efficiency related investment loans to the private sector and the UFEE was no longer used or needed. It was subsequently reformulated as a Guarantee Fund for energy efficiency projects with US$2.45 from the UFEE. However, only one guarantee had been issued before project closing. The guarantee fund subsequently became part of the National Guarantee System (SIGA). The US$2.5 million in GEF funds, originally intended for UFEE, were allocated to SIGA, but remained unutilized at the time of project closing.

Outcomes:
  • Energy efficient residential and commercial lighting grew to 18 percent, compared with the target of 10%.
  • Energy efficient municipal lighting increased to 63%, compared with the appraisal target of 20%.
  • The sale of efficient water heaters and refrigerators rose to 9%, compared with the target of 25%.
  • The initial reduction of losses from the elimination of illegal connections was not sustained and the level of illegal connections again rose. The program was terminated.
  • Fourteen of the 56 registered Energy Supply Companies (ESCs) were active at project completion.
  • The ESCs made investments in 17 public and private sector energy efficiency projects between January 2008 and July 2010.
  • US$22.3 million were invested in energy efficiency projects, slightly more than the target of US$22.7 million; almost all of these investment funds were financed by the commercial banking system independently from the UFEE. This confirms that commercial funds were available for EE investments without the need for UFEE funds and/or guarantee, which is an important milestone for the sector.
  • The cumulative impact of the above activities is estimated to be a reduction of about 9.6 MW in peak demand, which should correspond to equivalent reductions in imports of electricity and/or fuels that would otherwise have been required to meet peak load demand (ICR, Annex 3).

(c) Reduced emissions from the energy sector. Modest

The ICR estimates that the project activities enabled the avoidance of about 500 CO2 emissions, equivalent to only 36 percent of the appraisal target of 1,400 tons CO2.

5. Efficiency:

The ICR notes the direct quantifiable benefits as (i) the reduced peak demand and hence the associated benefits to the economy through avoided imports of electricity and/or fuels; and (ii) the financial benefits of avoidance of greenhouse gas production through the electricity savings from the introduction of compact fluorescent light bulbs. The other significant quantifiable part of the project, namely, investments in energy efficiency enabled by the project activities, should be regarded as intermediate and contributing to the achievement of the targeted outcomes of the project. The comparative analysis of energy intensity, while interesting, does not demonstrate any correlation with the project's outputs, as the ICR notes in Annex 3.

Other measures of efficiency suggest that actual outputs achieved were significantly less than had been expected. For example, the Uruguay Energy Efficiency Fund completed only 17 feasibility studies, made one investment for US$200,000 and one loan guarantee. In addition, the establishment of UTE's Energy Efficiency Unit cost US$3.0 million, compared with the appraisal estimate of US$1.6 million. This brought the project's total direct and indirect administrative cost to US$4.4 million, a high 28% of the project's total cost of US$15.6 million.

The funds for the energy efficiency investment program were unused at project completion, and the efficiency of their future use is unknown. The efficiency of both the Solar Homes component and the upgrading the distribution systems was negligible.

Overall, 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
Coverage/Scope*
Appraisal:
No
%
%
ICR estimate:
No
%
%

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

6. Outcome:

Relevance of objectives is rated substantial, but that of design modest. The efficacy ratings related to the objective of increasing the demand for energy efficient goods was substantial, as was the rating for increasing the competitive supply of energy efficient services. With regard to efficacy, the project increased consumer demand for, and the competitive supply of, energy efficient goods and services, and hence contributed to improvements in the efficiency of electricity use and helped to reduce Uruguay’s reliance on imported electricity and fuels. However, the reduction in CO2 emissions, while not insignificant, was well below target, and the efficacy of the corresponding objective is rated modest. Efficiency is also rated modest. Overall outcome is assessed as moderately satisfactory.

a. Outcome Rating: Moderately Satisfactory

7. Rationale for Risk to Development Outcome Rating:

The increasing cost of natural gas for power generation and the rising cost of developing new power generation facilities have increased the cost and price of electricity in Uruguay. This has increased awareness of the need for energy conservation and will continue to provide incentives for both UTE and the consuming public to continue to make efforts to conserve energy. The project helped to facilitate the transition from a situation where there was little knowledge and less interest in energy efficiency to one where energy efficiency plays an important role in the National Energy Strategy and where a number of private efficient energy service companies are sustaining themselves commercially. Project activities, including energy efficiency labeling for CFLs, water heaters, and eventually other appliances, will continue to reinforce these trends, and once consumers purchase energy efficient equipment, they are unlikely to shift back to the old, less efficient equipment. Some project components, such as the efforts to make poor urban neighborhoods reduce illegal connections, and the effort to provide household solar systems to isolated rural areas, which were not central to the objectives of the project have already been abandoned, so their sustainability is not an issue.

a. Risk to Development Outcome Rating: Negligible to Low

8. Assessment of Bank Performance:

a. Quality at entry:
The Bank overestimated the interest in energy efficient investments at a time when Uruguay was importing low cost gas from Argentina and energy prices were low. At that time the national electricity company, UTE, showed little interest in supporting energy efficiency projects that were designed to reduce demand. It was only when Argentina stopped exporting natural gas (two years after project effectiveness) that UTE’s interest began to focus on reducing energy demand by shifting consumers towards more efficient energy usages. As noted in section 3b, the results framework had some weaknesses.

The problems encountered with the Uruguay Fund for Energy Efficiency indicate insufficient preparation for the involvement of financial institutions in the project (ICR, page 13).

There were some weaknesses in M&E design, including a number of progress indicators which were difficult to monitor and were not directly linked to the objectives (see Section 10a below).

Quality-at-Entry Rating: Moderately Unsatisfactory

b. Quality of supervision:
The ICR provides limited information on the quality of supervision. The project team followed project implementation closely and restructured and amended the Grant Agreement when the need arose to reformulate the UFEE program. The Bank team supported the other project activities, but did not take the opportunity to update the implementation progress indicators. Supervision of fiduciary aspects was satisfactory. There were no issues with safeguards compliance. Transition arrangements were adequate.

Quality of Supervision Rating: Moderately Satisfactory

Overall Bank Performance Rating: Moderately Satisfactory

9. Assessment of Borrower Performance:

a. Government Performance:
The ICR reports that the Ministry of Industry, Energy and Mines (MIEM) provided competent staff for its Project Management Unit. Continuity of implementation was ensured through minimizing staff turnover. Government support for the project objectives was demonstrated in its espousal of the Energy Efficiency Law and its passage through Congress and in development of the secondary legislation that provided resources for effective and sustainable support for energy efficiency initiatives.

Government Performance Rating: Satisfactory

b. Implementing Agency Performance:
The Project Management Unit (PMU) was housed in, and staffed by, the MIEM. Its staff tracked project implementation closely, provided what the ICR describes as competent twice-yearly performance reports for the Bank, assisted in the preparation of the several laws and regulations, coordinated the actions of multiple agencies involved in project execution, and managed the project professionally.

The PMU was established and staffed early, and procurement documents for the first year’s activities were completed and ready for project implementation at effectiveness. Nevertheless the Bank’s procurement rating in the final Implementation Status Report was only moderately satisfactory. Project-designated financial institutions were superseded by commercial banks in supporting new energy efficiency investments.

The ICR reports that the Economic Support Unit of UTE, which was financed by the utility itself, was efficiently staffed. However, several of the activities originally assigned under its responsibility (Solar Home Systems, distribution losses in poor neighborhoods) failed to achieve their objective.While UTE management provided only limited support in the early stages of implementation, it became fully supportive of all efforts to reduce demand after imported energy became expensive. UTE established its own Energy Saving Service Company, which provided services to the residential, commercial, as well as the government sector.

Implementing Agency Performance Rating: Moderately Satisfactory

Overall Borrower Performance Rating: Moderately Satisfactory

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

a. M&E Design:
M&E was designed to aggregate sub-project indicators. The key central indicators of cumulative investment, trained stakeholders, companies providing energy efficiency services and an increasing market share of energy efficient appliances, were well chosen. Outcome indicators, including reduced Sulfur Oxides (SOx) and Nitric Oxides (NOx) emission from power plants were less amenable to collection and more difficult to demonstrate causal relationships with project activities

b. M&E Implementation:
The Project Management Unit within the Ministry of Industry, Energy and Mining was responsible for recording, organizing and present the results from each component. Baseline data for SOx and NOx ‘s (sulphur and nitrogen oxides) were not collected, so there was little purpose in collecting updated data for comparison purposes. A consultant firm was hired to monitor technical indicators. It produced two reports, the first in 2010 covering results from 2008 and the second in 2012 covering results from 2009, covering penetration of efficiency equipment in the market, the incidence of labeling, the effectiveness of training and educational activities related to Energy Efficiency, and the savings and emissions reductions resulting from the implementation of the Energy Efficiency projects

a. M&E Utilization:
The consultant firm's reports were helpful in evaluating project results. The data provided, together with studies to determine procedures to follow-up on the information related to the performance of Energy Service Companies and the Energy Efficiency unit of UTE were undertaken and their recommendations implemented by the PMU.

M&E Quality Rating: Modest

11. Other Issues:

a. Safeguards:
Safeguards: The project was classified as Environmental Category F (the financial intermediary category). The PAD states (p. 23) that OP 4.01 (Environmental Assessment) might be triggered. However, the ICR (p. 10) reports that, in the event, no safeguard policies were triggered.

b. Fiduciary Compliance:
Financial Management: The ICR states that the project complied "reasonably well" with Bank requirements with regard to financial management arrangements. Accounting records were kept up to date. Periodic internal financial reporting was acceptable, and provided reasonable assurances that GEF funds were used for the intended purposes. External Audits by Uruguay's Tribunal de Cuentas showed unqualified (clean) audit opinions, and were reviewed and deemed acceptable by the Bank.

Procurement: The professional capacity of the staff involved in procurement activities was deemed adequate. Procurement plans were realistic and of satisfactory quality. GEF resources were allocated for retroactive financing of about 1000 solar home system purchased by UTE following Bank procurement rules. The ICR comments, however, that there were some minor deviations from Bank procurement guidelines and rates project procurement as "moderately satisfactory." There was no misprocurement reported.

c. Unintended Impacts (positive or negative):
The energy utility decided to finance on its own a large energy efficiency light bulb replacement program.

d. Other:



12. Ratings:

ICR
IEG Review
Reason for Disagreement/Comments
Outcome:
Moderately Satisfactory
Moderately Satisfactory
 
Risk to Development Outcome:
Negligible to Low
Negligible to Low
 
Bank Performance:
Moderately Satisfactory
Moderately Satisfactory
 
Borrower Performance:
Moderately Satisfactory
Moderately Satisfactory
 
Quality of ICR:
 
Unsatisfactory
 
NOTES:
- When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006.
- The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate.

13. Lessons:
The following summarizes the most important lessons cited in the ICR.
  • Outreach activities play an essential part in promoting changes in consumer behavior by raising the public’s awareness about the important of, and possibilities for, improving energy efficiency. In this case, these activities promoted public support by disseminating information on energy efficiency at many levels, including school program and TV and radio spots, complemented by publications and specialized courses. These types of activities are usually not part of the common range of activities developed by an energy utility, where interest is more oriented towards “hard” interventions (specific projects). The experience of this project demonstrates the importance of getting traditional energy sector actors to understanding the important role of public promotion of energy efficiency ideas.
  • Because energy efficiency projects finance a multiplicity of relatively small activities, they can generate significant procurement challenges. These activities can include designing enabling legislation, buying and installing small quantities of equipment, hiring energy service companies to do energy audits, designing and publishing pamphlets and books, financing theater plays for children, and participating in multiple expositions and congresses. Adapting all this variety of activities to World Bank Procurement Guidelines can generate significant challenges. Up front planning and a flexible design of contracts can help to deal with these issues.
  • Interactions with other countries can be incorporated into the learning process for energy efficiency implementation. In this project, the Project Management Unit visited efficiency projects in other countries and attended training programs with the Spanish development cooperation organization, the Japanese development agency, and the German Chamber of Commerce. This interaction helped increased the leverage of the project and opened the door for new investment ideas.

14. Assessment Recommended?

No

15. Comments on Quality of ICR:

The ICR presents a number of significant shortcomings:
  • The ICR focuses primarily on outputs, and gives little attention to the analysis of project outcomes. Specifically, there was no discussion of how the energy and CO2 savings were estimated
  • The Economic Analysis is weak. It is based primarily on the benefits from the rapid introduction of Compact Fluorescent Light bulbs (CFLs), which were financed by UTE outside the project, and were given away free by UTE when it was unable to increase electricity output to meet growing peak demand. There is a strong likelihood that UTE would have done the same thing if this project had not existed.
  • Another part of the economic analyses compares national energy usage per unit of output over time for several countries. This discussion is somewhat confusing, and is, in any event, irrelevant to making a judgment about the outcome of this project.
  • There was no recognition of the fact that two of the project components (the Solar Home Systems and the upgrading of distribution systems in poor neighborhoods) were largely unrelated to the project objectives as stated in the Financing Agreement.
  • The rational for allocating the unutilized UFEE funds to another agency rather than cancelling them was not discussed.
  • The page numbers in the table of contents were inaccurate.

    a. Quality of ICR Rating: Unsatisfactory

  • (ICRR-Rev6INV-Jun-2011)
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