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Implementation Completion Report (ICR) Review - Education Development Capacity Building Project

1. Project Data:   
ICR Review Date Posted:
Project Name:
Education Development Capacity Building Project
Project Costs(US $M)
 22.2  14.9
L/C Number:
Loan/Credit (US $M)
 18.2  13.9
Sector Board:
Cofinancing (US $M)
Board Approval Date
Closing Date
09/01/2010 09/01/2012
General education sector (55%), Primary education (25%), Health (10%), General public administration sector (10%)
Education for all (29% - P) Public expenditure financial management and procurement (29% - P) Child health (14% - S) Gender (14% - S) Decentralization (14% - S)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Erik A. Bloom
Judyth L. Twigg Christopher D. Gerrard IEGPS2

2. Project Objectives and Components:

a. Objectives:

    The PDO in the Development Credit Agreement (Schedule 2, page 22) aimed to:

    "...increase the efficiency and equity of primary and secondary education, with a focus on disadvantaged areas, and improve the relevance of secondary and higher education to the needs of the economy." This PDO was also included in the Project Appraisal Document (PAD, page 8).

    In April 2010, the project was restructured and the PDO changed to: "...develop and apply management and learning for use by government and communities to improve efficiency and accountability of the Cameroon education sector" (Schedule 2, page 7 of the Restructuring Agreement).

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

If yes, did the Board approve the revised objectives/key associated outcome targets? Yes

Date of Board Approval: 04/20/2010

c. Components:

As approved, the project had four components (the ICR includes information on the estimated amount of each component at the time of appraisal, but not on actual costs):

1. Reinforcing administrative management. This component was to focus on the administration of the education system, through improvements in administrative management and controls, personnel management, and planning (appraisal: US$ 4.9 million).

2. Reinforcing pedagogic management. This component aimed to improve pedagogic management in order to make teaching and learning processes more efficient, leading to reduced repetition and revised structure and curriculum for secondary education (appraisal: US$ 6.8 million).

3. Supporting enrollment and reducing gender inequity in priority zones. This component was to focus on increasing demand for primary education and gender equity in identified priority zones, through advocacy and mobilization campaigns, micro projects to improve schools, and training for school council members (appraisal: US$ 3.9 million).

4. Building the capacity of the higher education institutions. This component was to focus on raising the quality and relevance of teaching and research by improving the system's ability to generate a critical mass of high-quality professionals. This included the creation of a special fund for research, improved information/ communication technology (ICT) management, strengthening document centers, and the creation of a (Global Distance Learning Network) GDLN Center (appraisal: US$ 2.5 million).

The project was restructured with four new components (no information was provided on the cost of each component):

1. Develop and update the strategic vision for the education sector. This component was to include support for studies, capacity building, and investments for higher education.

2. Strengthening the education information system and planning capacity. This component was to provide support to information systems in different ministries in the sector, including training and equipment.

3. Reinforcing sector monitoring. This component was to support training, workshops, and technical assistance to support and evaluate management reforms.

4. Improving public participation. This component aimed to improve public participation in the sector, through public awareness campaigns and school rehabilitation projects.

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

Project Costs and financing

The IDA credit was approved for US$ 18.2 million (SDR 12.1 million), of which US$ 13.8 million (SDR 9.0 million) was disbursed. The government and the Bank were not able reach an agreement on extending the project beyond 2012 and the remaining IDA credit was canceled (US$ 4.7 million).

The Bank also supervised a US$ 22.5 million grant from the Education for All/Fast Track Initiative (with resources from the European Commission), which was approved on June 6, 2007 and closed on October 31, 2009. The grant was associated with the project but is not considered co-financing as it had its own objective and did not finance the activities in the project.

The ICR does not provide project costs by component.

Borrower contribution

The borrower was to contribute US$ 4 million. The ICR does not state whether this amount was contributed, but the project team confirmed that the government fully contributed its share. This contribution was tracked as part of supervision.


The project was approved on May 31, 2005 and became effective on October 28, 2005. The project was expected to close on September 1, 2010 but was extended by two years, to September 1, 2012.

The project had a Board-approved restructuring, approved on April 20, 2010. This restructuring included changes in the implementation arrangements and in the project design, as well as an extension. It was complemented by a change in the PDO noted above. The project was subsequently restructured again on August 23, 2011 at the Country Director level to reallocate the credit across disbursement categories.

3. Relevance of Objectives & Design:

a. Relevance of Objectives:

The relevance of the original objectives is rated high.

At the time of approval, the PDO was well grounded in the government's 2003 poverty reduction strategy and played a central role in the government's Education Sector Strategy. The project was also seen as central to the Bank's support for the government's reform agenda. The PDO was also aligned with the first pillar of the Bank's 2003 Country Assistance Strategy (CAS, "Strengthening institutional framework for improved pro-poor economic management and service delivery"), which made clear reference to the education sector and the approach originally proposed in the project (page 17 of ICR; page 14 of the 2003 CAS).

The relevance of the revised objectives is rated high.

The revised objectives, which tightened the focus on governance and institutional strengthening in the education sector, remains highly relevant. The current CAS (approved in 2010) makes specific reference to the project in the second pillar ("Improved Service Delivery"), and to the project's restructured objectives as part of this strategy (pages 27-28).

b. Relevance of Design:

The relevance of design under the original objectives is rated negligible.

The project's design was quite ambitious. The original PDO had far-reaching aims but limited resources (US$18.2 million), with a large scope and myriad activities ranging from improving pedagogy to building capacity in higher education, as outlined in the discussion of the project's components and activities (PAD, pages 8-12). While the activities were potentially important for achievement of the objectives, they were far from sufficient and required substantial actions on the part of the government and possibly other development partners. In short, there did not appear to be a well-developed results chain that identified the process through which the planned activities would lead to the desired outcomes and achievement of objectives. The project was effectively a technical assistance project, given its small size and focus on reforms. However, as originally designed, the desired outcomes had more in common with a large investment project.

In addition, the technical design had a number of shortcomings. Some elements of the objectives were not adequately covered by activities plausibly related to them, putting in doubt the capacity of the project to contribute to the desired outcomes. For example, improving the relevance of secondary and higher education is not well defined in the PAD and is subject to interpretation, and there were few planned activities that could have supported this outcome and no indicators to measure it. As the PAD (page 12) indicated, the Bank had little alternative to the use of an investment loan. However, this instrument may not have been appropriate for an activity that focused on institutional change, which was a major part of the project.

The relevance of design under the revised objectives is rated substantial.

After the restructuring, the project was more focused on the revised objectives. Although the project included some investment activities, it primarily focused on providing technical assistance and strengthening management and capacity in the sector. The components were more closely aligned with the objectives, and the proposed activities were appropriate to reach the objectives.

4. Achievement of Objectives (Efficacy) :

The original PDO (June 2005 to April 2010, accounting for 49 percent of the actual IDA disbursement) focused on high-level goals: improving the (i) relevance of secondary and higher education (i.e. quality and impact), (ii) the efficiency of primary and secondary education, and (iii) equity in primary and secondary education, with a special focus on disadvantaged areas.

The revised PDO focused on improving (i) efficiency and (ii) accountability in the education sector at both the national and community levels.

Original Project Development Objectives

Improving the relevance of secondary and higher education is rated negligible.


As originally designed, the project included support for a number of initiatives that were likely to contribute to quality and economic impact of post-primary education. These included reinforcing pedagogic management, which largely focused on secondary education, and building the capacity of the higher education institutions. Annex 2 shows that the project also supported efforts to strengthen student assessment, through the development of tests and training for teachers and other education staff in their use, as well as efforts to restructure secondary education, which included developing a communication plan to promote the reform. However, the reform itself was not adopted. At the tertiary education level, the project also planned to establish a research fund for tertiary education, but this was not created, although there was some advance in setting up an Information Technology Center for universities.

The project also supported the establishment of a GDLN site in Cameroon, which was established but was not operational at project closing.


Given the limited scope of the activities, it is unlikely that there was any impact. The ICR does not provide any evidence of impact.

Improving the efficiency of primary and secondary education is rated modest.

Based on the discussion in the PAD (page 4 as well as the indicators included in Annex 3), efficiency means the ability of a student to finish the schooling cycle in a timely manner, as measured by a reduction in repetition and dropping out of school.


The project supported a number of activities that aimed to improve education efficiency, primarily in the original Component Two. Following the original design (PAD, Annex 4), this included an awareness campaign, designing new testing instruments, and training for education stakeholders. All of these activities were designed to lead to a reduction in repetition. The project also supported a national awareness campaign to discourage repetition in 2008 and 2010. The project also supported hiring a consultant to train teachers and to develop new assessments with an aim to reducing repetition. The ICR indicates that new assessment instruments were developed (an "item bank") as well as training carried out in training institutes (based on comments from with the project team and Annex 2 of the ICR).

At the secondary level, the project planned to support a reform to the structure of the sector. The aim was to make the system more flexible. While programs were developed, they were not incorporated into the secondary education system (ICR, Annex 2).


During the project period, the repetition rate in primary education dropped from 26 percent in 2005 to 20 percent in 2010 and 15 percent in 2011 (meeting the target of 15%). While there may be some problems in measuring and interpreting this statistic, it is clear that the trend is positive. It is generally accepted in the education community that repetition at the primary level is largely a cultural phenomenon and rarely is the result of an objective failure in a child's learning. Thus changes in the repetition rate are largely driven by beliefs and practices and were likely influenced by the actions supported by the project.

The primary completion rate increased from 56 percent (2005) to 83 percent (2010), compared to a target of 80 percent. Although many factors influenced this outcome, it is likely that the project did contribute to this improvement through its support to reduce repetition.

While the project clearly aimed to improve education efficiency at the secondary level, neither the M&E framework nor the ICR provide any indicators to measure this impact. Since the outputs developed by the project to reform secondary education were not incorporated into the system, it seems unlikely that the project had an impact.

Improving equity in primary and secondary education, with focus on disadvantaged areas, is rated negligible.

To define equity, the project identified regions that were behind the national average, both in terms of outcomes and educational inputs, as well as identifying other issues related to equity such as the participation of girls in the education system. A particular focus was given to "education priority zones" (ZEPs), which are socially disadvantaged regions.


According to the ICR, none of the planned activities to support this objective were carried out (Annex 2). However, after the restructuring in 2010, Component 4 included a number of activities that led to 405 classrooms being rehabilitated in one of the most marginalized areas.


There was some improvement in education equality, such as an improvement in the female-to-male enrollment ratio, from 0.58 in 2005 to 0.82 in 2010 (not meeting the target of 0.9), and a small increase in the equity of teacher placement (this is measured by an indicator measuring arbitrary teacher deployment known as "randomness," which is commonly used in Francophone Africa; this indicator decreased from 45% in 2005 to 42% in 2010, not approaching the target of 25%). These are not strong indicators of geographic equity and it is not clear how the project could have contributed to these outcomes.

Revised Project Development Objectives

Improving efficiency in education is rated modest.

Given the wording in the PDO (focusing on efficiency in the education sector as opposed to efficiency in a particular level of education) as well as the choice of new PDO and intermediate outcome indicators, efficiency is used here in the sense of supporting the education sector to produce more with the same resources. The concept of "internal efficiency" (used for the original PDO) is included in this definition.


The project supported the efforts of various ministries to improve the efficiency of their operations, including the training of staff in use of simulation models to allow better strategic choices. The ICR reports that the sector was using analytical tools in many sub-sectors (ICR, pages ix, xii). This activity complemented support provided outside of the project, such as an assessment of student achievement and an education status report. Another area that was designed to improve the efficiency of the sector was the establishment of a Global Distance Learning Network hub, which was achieved by project closing. However, the ICR reports that the hub was not functioning due to the lack of a necessary government decree.


The ICR claims that more teachers are being placed in an efficient manner in schools (in other words, where they are needed), but it does not provide evidence to support this claim. Efficient teacher placement was also the objective of a parallel Global Fund for Education project (Education for All/Fast Track Initiative). The reduction in the student repetition rate represents a gain in efficiency, albeit limited to the primary education sector. There is no additional evidence that the sector's efficiency increased.

Improving accountability in education is rated modest.


The project supported the publication of annual statistical reports throughout the education sector, which represents a major advancement. Likewise, with the support of the project, an early grade reading assessment system has been established and is being used to provide information to the education sector. Likewise, the project supported a number of community activities to enhance local participation in the education sector. All of the small-scale projects were carried out with local participation. These projects were targeted to the poorest regions of the country. In addition, the project prepared and disseminated a number of fiduciary and technical audits related to the education sector, although some were carried out late.


Measuring increased accountability is difficult, and there are few indicators that capture improvements in accountability. One advance reported by the ICR is the improved quality of the biannual Education Sector Strategy, through the increased use of data and analysis (ICR, page ix). Likewise the ICR (page x) reports the active participation of the community in the rehabilitation of schools. While these outcomes are associated with an increased level of accountability and ownership in the education sector, they do not provide strong evidence of meaningful change.

5. Efficiency:

The efficiency of the project is rated modest. The project's PAD had a detailed and well-prepared economic analysis (Annex 9) that includes justification of the project's interventions as well as discussion of the contribution of the project's planned components to education outcomes. This justification is implicitly an argument for the project's contribution to efficiency. Although the economic analysis used a cost-benefit analysis, it did not explicitly measure the rate of return.

The ICR also contains an economic and financial analysis (Annex 3). This analysis is candid in discussing the lack of data and quantifiable outputs. It shows that around US$1.6 million of Bank budget and trust fund resources was dedicated to implementation and supervision costs, which is relatively high. The project did set the stage for further work in the sector (including through grant-funded projects) at a relatively low cost.

Before the restructuring in 2010, project resources were focused on a number of technical assistance activities. Given the lack of a reform or complementary actions by the government, much of these resources were wasted. The restructuring allowed the resources to be better focused on what was achievable within the context of the project.

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:

Prior to the restructuring of the objectives in April 2010, the project had disbursed 49 percent. With high relevance of objectives and negligible relevance of design; two negligible and one substantial rating for achievement of the objectives; and a modest rating for efficiency, the Outcome rating under the original objectives is unsatisfactory.

Under the revised PDO, the project disbursed 51 percent. With high relevance of objectives and substantial relevance of design, two modest ratings for achievement of the objectives, and a modest rating for efficiency, the overall Outcome rating under the revised objectives is moderately unsatisfactory.

Using standard methodology, the project with revised objectives are weighted by the amount disbursement during each period. Given that 51 percent of the disbursement occurred under the revised objective, the overall Outcome rating is Moderately Unsatisfactory.

a. Outcome Rating: Moderately Unsatisfactory

7. Rationale for Risk to Development Outcome Rating:

The risk to development outcome is rated as significant.

Moving forward, there is a significant risk that the project's investments will not be maintained over time. While some of the activities supported by the project have been institutionalized, it is not clear how deep the support is for these actions. For example, the original Component 2 supported training to education stakeholders with a focus on reducing repetition. While this sort of training is important to changing practices and culture, there does not appear to be a strategy to continue this support or to ensure that it becomes part of the teaching training system. Another area of concern is the support for infrastructure. Although the project team had sound reasons to deny an extension necessary to complete infrastructure rehabilitation (see Section 8b), this decision does impact the likelihood that the project will continue to exert a positive impact on the education sector. This is partially ameliorated by the decision to seek support for infrastructure rehabilitation from another project.

a. Risk to Development Outcome Rating: Significant

8. Assessment of Bank Performance:

a. Quality at entry:

The quality at entry is rated unsatisfactory.

The project was built on a good understanding of the education sector and the constraints under which it was operating. Likewise, the project analyzed the lessons from previous projects in Cameroon as well as general country knowledge (ICR, page 9).

Project preparation took into account weaknesses in financial management and procurement through modest financial management and procurement plans (PAD, Annexes 7 and 8). These plans focused on ensuring that the Project Coordination Unit played a central role in financial management and especially procurement, and they seem to have been rather standard (they would have been appropriate for countries with stronger capacity).

Despite the background analysis, the PAD's level of detail is quite limited. The main section is only 17 pages long, with cursory discussion of the project's design and critical risks. These omissions are partly addressed by the detailed project description (Annex 4), which does identify in greater depth the activities and objectives of each sub-component. Likewise, the Program Background (Annex 1) is quite short, with almost no detail on the limitations in the education sector; the Economic Analysis (Annex 9) provides a more detailed discussion. Overall, while it is clear that the preparation team did understand the education sector in the country and did work hard to develop the project, this work did not appear to be well integrated with a results chain framework.

The PAD identified only three risks (political risk, economic risk, and weak implementation capacity), with a short description of each in the PAD (page 14). The lack of detailed discussion of these risks as well as the lack of a comprehensive mitigation strategy represent a major shortcoming. These issues were significant in Cameroon at the time of project preparation and were partially discussed in the lessons learned section of the PAD (page 12). Subsequent experience did show that both political risk and weak capacity were major issues that eventually undermined the project's ability to perform.

Quality-at-Entry Rating: Unsatisfactory

b. Quality of supervision:

The quality of supervision is rated moderately satisfactory.

The World Bank remained engaged with the project, providing both technical support and active supervision. According to the ICR (page 29), the Bank was proactive in identifying and resolving challenges. The Bank pushed for a restructuring after it became clear that the initial design was too ambitious given the local context and the creation of new ministries in the education sector (ICR, pages 30-33). This is reflected by the major restructuring carried out in 2010 that simplified the project's objectives and design.

On the fiduciary side, there were a number of shortcomings in the Bank's supervision. The ICR notes that the procurement plan was generally not used as an implementation tool until the final 18 months of implementation (page 29). The ICR suggests that the large number of ongoing activities complicated supervision, stretching the Bank's capacity. The project also had five TTLs over a seven-year project. This was not ideal as it undermined the project's institutional memory.

The ICR (page 30) reports that the final 18 months of the project saw an increase in attention to detail, with an aim to reducing bottlenecks and implementing planned activities. The Bank team worked with other ongoing projects to ensure that the project was "fully staffed" by sharing staff. The ICR (pages 29-30), the interview with the project team, and a review of internal documents suggest that the internal reporting was candid, indicating realistic options for the project.

The Bank team carried out the necessary safeguard assessments on civil works supported by the project.

Toward the end of the project, the government requested an extension to finalize work on infrastructure. The Bank did not agree with this extension, and the project was closed (ICR, page 11). The project team subsequently indicated that this decision was made to bring closure to this project and to create space for the follow-on project, which is currently under preparation (with planned financing by the Global Partnership for Education). The team also confirmed that another project (Sanitation Project, P117102) plans to support these activities. These collaborations and the decision to share staff show that the team was able to work across sectors to create synergies.

The Bank team also concurrently supervised two grants from the Education for All/Fast-track Initiative (now called the Global Partnership for Education). While these grants were organized in a separate project, the interview with the project team shows that the team made an effort to ensure that the IDA project and the grants provided complementary support.

Quality of Supervision Rating: Moderately Satisfactory

Overall Bank Performance Rating: Moderately Unsatisfactory

9. Assessment of Borrower Performance:

a. Government Performance:

The government remained engaged with the project and worked to develop policies and legal decisions to support some of its elements. However, many of these legal decisions were delayed (such as the establishment of the Global Development Learning Network hub) or not fully implemented. Likewise, some of the agreed audits were not implemented or were carried out late. The division of the education sector from two different ministries into four (and later five) complicated the administration of the project. The project team subsequently reported that the government did support the Bank's efforts to simplify the project after the division of the education sector into five ministries (see also ICR, page 11).

Government Performance Rating: Moderately Unsatisfactory

b. Implementing Agency Performance:

Given the participation of five ministries, the Project Coordination Unit was to play a major role in ensuring that the project operated smoothly. However, there were a number of problems with weak project management. The first two project coordinators were removed due to poor performance. While the third project coordinator was more effective, implementation was slow (ICR, page 12). There were also delays in hiring key staff for the project, such as a procurement specialist. The delays in implementing infrastructure development activities (ICR, page 11) also showed limited capacity and required the Bank to send a consultant for review.

Implementing Agency Performance Rating: Moderately Unsatisfactory

Overall Borrower Performance Rating: Moderately Unsatisfactory

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

a. M&E Design:

At the time of preparation, the project had clear objectives, and the three PDO indicators (PAD, Annex 7) were closely aligned with these objectives. However, given the ambitious scope of the project, these three indicators covered only a small part of the planned activities. For example, there were no indicators reflecting the project's proposed impact on secondary or tertiary education. The three PDO indicators all had baselines and were already measured by the country's education sector.

With a few exceptions, the intermediate indicators were closely tied to the activities financed by the project. Most of these indicators had baselines and could be monitored either through existing government M&E systems or through the project's statistics. However, given the lack of a well developed causal chain, many potentially useful indicators were not incorporated in the results framework.

The Quality Assessment of the Lending Portfolio (an internal assessment of the project) noted a lack of meaningful intermediate indicators and incomplete coverage of the PDO indicators (ICR, page 13).

b. M&E Implementation:

The implementation of the M&E system was more complicated than expected. While most of the indicators could be monitored, it was increasingly clear that these indicators were not fully relevant for assessment of progress toward achievement of objectives. Over time, a number of M&E indicators that were not included in the PAD were introduced in the routine M&E framework, such as the number of textbooks purchased or the number of teachers recruited into the system. These did not have baselines or clear targets and were not closely related to the activities that the project supported.

After the PDO was changed in 2010, a new set of intermediate indicators was introduced that was more aligned with the scope of the project, largely focusing on measuring the impact of technical assistance activities. These indicators were monitored regularly through the existing project M&E system. The PDO indicators were also changed and were better tied to the new objectives. They had clear baselines and were regularly monitored.

a. M&E Utilization:

Despite the fact that the revised M&E was successful in providing data, it is not clear how these data were used. Under the revised M&E system, most of the indicators were already routinely collected by the project (such as the development of analytical tools or action plans), and it is not clear how the intermediate outcomes led to the desired outcomes.

M&E Quality Rating: Modest

11. Other Issues:

a. Safeguards:

Due to small-scale construction, the project was Category B and triggered the Environmental Assessment Safeguard (BP 4.01). The ICR (page 14) indicates that compliance with the safeguards was consistently satisfactory.

b. Fiduciary Compliance:

The project had both internal and external audits, as well as technical audits used to review inputs. The project generally received qualified audit reports, although it appears that these were resolved and finalized by the end of implementation. The Bank expressed concern about the timing and utility of the internal audits (ICR, page 16). Project records also indicate that audits were occasionally submitted late (due to problems with contracting an audit firm).

At the time of appraisal, the procurement risk was rated high and the Bank worked with the participating ministries to improve procurement capacity. In 2009 there was an intensive Post-Procurement Review, and the government adopted all of the recommended steps and introduced the requested changes (ICR, page 15).

c. Unintended Impacts (positive or negative):
None reported.

d. Other:

12. Ratings:

IEG Review
Reason for Disagreement/Comments
Moderately Unsatisfactory
Moderately Unsatisfactory
Risk to Development Outcome:
There does not appear to be any strategy to ensure the sustainability of the project's activities. Experience has shown that the political risk to reform is high.  
Bank Performance:
Moderately Unsatisfactory
Moderately Unsatisfactory
Borrower Performance:
Moderately Unsatisfactory
Moderately Unsatisfactory
Quality of ICR:
- When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006.
- The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate.

13. Lessons:

The ICR includes some well-considered technical and operations recommendations based on the project's experience (ICR, pages 24-25).

It is important to align properly a project's design with reality and with its results framework. In this case, the project's design seemed to be driven largely by ambition rather than what the project could realistically accomplish given the country context and available resources.

It is important for preparation teams to appropriately incorporate political economy into project design. While politics is often cited, it needs to play a more central role in the design of a project, as opposed to just being a risk that needs to be mitigated.

14. Assessment Recommended?


15. Comments on Quality of ICR:

The ICR is well written and provides a good overview of the project. The analysis is candid and identifies fairly both the strengths and the weaknesses of the preparation and implementation. In particular, it provides a good understanding of the challenges that the project faced during implementation and how the Bank and the government attempted to address them. Most of the necessary data are provided in the text, and the ICR makes a point to analyze data and identify the causes for the results observed.

The ICR has several minor shortcomings, mostly of an administrative nature. This includes the omission of separate ratings for relevance of design under the original and revised objectives.

a. Quality of ICR Rating: Satisfactory

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