Pakistan: Bahawalpur Rural Development Project

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1 Validation Report Reference Number: PCV: PAK Project Number: Loan Number: 1467-PAK December 2009 Pakistan: Bahawalpur Rural Development Project Independent Evaluation Department

2 ABBREVIATIONS ADB Asian Development Bank ADF Asian Development Fund BME benefit monitoring and evaluation BTOR back-to-office report EA executing agency EIRR economic internal rate of return IED Independent Evaluation Department IsDB Islamic Development Bank M&E monitoring and evaluation NGO nongovernment organization OCR ordinary capital resources OED Operations Evaluation Department PCR project completion report PMU project management unit RRP report and recommendation of the President NOTES (i) In this report, $ refers to US dollars. (ii) For an explanation of rating descriptions used in ADB evaluation reports, see: ADB Guidelines for Preparing Performance Evaluation Reports for Public Sector Operations. Manila. Key Words adb, asian development bank, rural development, rural roads, watercourse improvement, smallscale infrastructure, rural electrification, institutional strengthening, bahawalpur, pakistan, project completion report, evaluation, validation Director Team leader Team members R. B. Adhikari, Independent Evaluation Division 1, Independent Evaluation Department (IED) G. Rauniyar, Senior Evaluation Specialist, Independent Evaluation Division 1, IED A. Morales, Evaluation Officer, Independent Evaluation Division 1, IED V. Melo, Operations Evaluation Assistant, Independent Evaluation Division 1, IED In preparing any evaluation report, or by making any designation of or reference to a particular territory or geographic area in this document, the Independent Evaluation Department does not intend to make any judgments as to the legal or other status of any territory or area.

3 PROJECT COMPLETION REPORT VALIDATION FORM A. Basic Project Data PCR Validation Date December 2009 Project and Loan/ 26479, 1467-PAK Approved Actual Grant Number: Project Name: Bahawalpur Rural Development Project Total Project Costs ($M): Country: Pakistan Loan ($M): Sector: Agriculture and Rural Total Cofinancing ($M): Development ADB Financing ADF 38.0 Borrower ($M): ($M): OCR 0.0 Beneficiaries ($M): Cofinanciers: IsDB Others ($M): Approval Date: 26 Sep 1996 Effectiveness Date: 8 Apr Jun 1997 Signing Date: 8 Jan 1997 Closing Date: 30 Jun Oct 2007 Project Officers: Location (HQ or RM): From To N. Kim Long R. Renfro T. Matsuo A. Cauchois HQ HQ HQ HQ Validator: A. Rijk Consultant Quality Control Reviewer/ Peer Reviewer: Ganesh Rauniyar Senior Evaluation Specialist, IED1 Director: R. B. Adhikari, IED1 ADB = Asian Development Bank, ADF = Asian Development Fund, IED = Independent Evaluation Department, IED1 = Independent Evaluation Division 1, IsDB = Islamic Development Bank, M = million, OCR = ordinary capital resources, PAK = Pakistan, PCR = project completion report, RM = resident mission. B. Project Description (summarized from report recommendation of the President [RRP]) (i) Rationale. The Bahawalpur Rural Development Project was designed for the now defunct Bahawalpur Division of Punjab Province. 1 The project rationale stemmed from the Government s recognition that the division was considered one of the least developed divisions in Pakistan, with more than 50% of the population living below the poverty line. The Project intended to target poor communities in newly settled areas within the division that were least served by infrastructure services and most isolated from social services. The poverty level in the newly settled areas was much higher about 80% so urgent attention was required. Surveys during project preparation determined the perceived problems of the rural communities to be lack of irrigation water, followed by poor roads. Women emphasized lack of electricity as a major problem, while the need to improve or rehabilitate other infrastructure (e.g., community buildings, water supply, and road drainage) was also considered important. (ii) Expected impact. The expected impact of the Project was poverty reduction. Rural roads were expected to lower costs of transport and marketing, increase access to inputs, and encourage more shops and value-added production. Watercourse improvement was expected to increase yields, cropping intensities, and shifts to high-value crops. Small-scale infrastructure was expected to provide better access to drinking water, and improve sanitation and drainage, while electricity would increase the level of household comfort and encourage small-scale industry development. 1 The division level of administration was devolved to the district governments during the local government reforms of 2001.

4 2 (iii) Objectives or expected outcomes. The expected outcome was increased rural incomes, employment, and improvement in quality of life through better infrastructure services (i.e., rural roads, watercourse improvements, small-scale infrastructure, and rural electrification), increased agricultural production, and more economic activities, including marketing. The institutional strengthening and capacity building was expected to support participatory approaches to implementation. (iv) Components and/or outputs. The project scope, components, and targets were as follows: (a) Rural roads: improvement of about 100 existing roads totaling an estimated 400 kilometers (km), with emphasis on roads linking agricultural areas with markets. Targets were the widening of about 60 km of the existing road from Ahmadpur East Town to Yazman Town from a single-lane to a double-lane paved carriageway, upgrading of 10 existing farm-to-market roads, and upgrading of 90 existing link roads or tracks. (b) Watercourse improvement: organization of about 480 water users associations, and improvement of 1,440 km of watercourses with an irrigated area of about 52,800 hectares. (c) Small-scale infrastructure: implementation of an estimated 450 works identified by the communities, such as community buildings, simple drinking water systems, wells, tubewells, ponds, feed processing units, small flour mills, oil pressing units, saw mills, fruit and forest nurseries, road drainage structures, and social facilities. (d) Rural electrification: connection of about 150 selected villages to existing transmission lines. (e) Institutional strengthening and capacity building of government agencies and community organizations of project beneficiaries to (1) prepare an investment program based on participatory approaches, (2) implement the Project, (3) update and maintain databases relevant to the monitoring and evaluation (M&E) of the Project, and (4) establish an M&E system. C. Evaluation of Design and Implementation (project completion report [PCR] assessment and validation) (i) Relevance of design and formulation. The Project s design in terms of expected impact (or goal at the time of appraisal) and outcome (or purpose) was consistent with the 1995 operational strategy for Pakistan of the Asian Development Bank (ADB) (RRP, paras ) and the Government s objectives on rural poverty reduction contained in its Eighth Five Year Plan ( ). 2 The RRP comprehensively documented lessons from similar agricultural and rural development projects and incorporated them in the design of the Project particularly on operation and maintenance, strengthening water users associations, nongovernment organization (NGO) involvement, for proper targeting and organization and strengthening of community-based organizations, and community participation during construction and maintenance. The location of the Project within the division was appropriate, as the poverty incidence for the Punjab cotton/wheat zone (within which the project area falls) was 56% (the second highest in the country). The RRP made the case for targeting newly settled areas (primarily in Bahawalpur and Rahim Yar Khan districts) between more settled area, adjacent to the Sutlej River to the north and the Cholistan Desert to the south. The Independent Evaluation Department (IED) agrees with the PCR assessment that the Project was relevant in design and implementation, and it continued to be relevant at the time of completion and validation. Given the nature of the Project (a large number of small subprojects for infrastructure), the project design necessitated a process approach. The PCR rightly considers that the large amount of grant financing with no subsequent cost recovery would likely need to be reconsidered if a new project was formulated. IED also supports the PCR observation that there was only limited analysis of the proposed investment mix and the extent to which investments would contribute to the expected poverty reduction impact, and that there appears to have been little discussion of the rationale or poverty reduction effect of specific subcomponents. This was discussed during the Management Review Meeting and the RRP 2 ADB Country Operational Strategy Study for Pakistan. Manila; and Planning Commission, Government of Pakistan The Eighth Five Year Plan ( ). Islamabad.

5 3 was subsequently improved. However, IED considers that lack of details on the benefit monitoring and evaluation (BME) and participatory processes in the design and/or RRP should have been identified in the PCR. (ii) Project outputs. Project outputs achievement and related indicators are described well and discussed (including deviations and failures) in the PCR main text, as well as in Appendix 1, which uses the project monitoring and development framework of the RRP as a basis for comparing planned and actual achievements. In most cases, actual physical project outputs were substantially higher than initially planned. Both ADB and the Government revised the output targets upwards, twice. However, the PCR considers the output under the institutional strengthening component unsatisfactory, largely caused by termination of the NGO s contract. IED considers that the PCR discussion on outputs is balanced. In the main text under each project component, the PCR discusses the outputs, deviations, and failures, where applicable, in quantified and/or qualified terms. Appendix 1 of the PCR provides the details of the outputs planned at appraisal and the PCR s evaluation of accomplishments. Significant deviations from planned outputs appear to be related to the sector nature (process approach) of the Project, and the significant currency devaluation during implementation. Data indicate that loan savings caused by devaluation may have been the main reason that physical targets were substantially exceeded. (iii) Project cost, disbursements, borrower contribution, and conformance to schedule (as relevant to project performance). Actual project costs were only 74.4% of appraisal estimates. The PCR considers the cost savings caused by (a) depreciation of the Pakistan rupee against the US dollar, and (b) decrease in the beneficiary contribution by 50%. PCR also notes that $4.7 million of loan was cancelled at the request of the Government. IED considers that the PCR does not adequately explain this matter. The local currency depreciated by close to 60% during the second half of the project implementation period, which would have contributed to cost reduction in US dollar terms since local currency costs were about 74% of total costs. On the other hand, extension of the loan closing date by 3 years must have resulted in a significant cost increase because of inflation; there was also a substantial increase in physical output (e.g., roads 44%, watercourse improvement 43%, small-scale infrastructure 25%, and rural electrification 185%). Furthermore, IED considers that comparing unit cost estimates at the time of appraisal with actual unit costs may have provided an indication of what caused the total cost reduction of the Project. However, this is significant because most of the investments followed a process approach, so appraisal estimates may be seen as indicative. (iv) Implementation arrangements, conditions and covenants, related technical assistance, and procurement and consultant performance. IED considers the PCR factual, fair, and largely complete in the sections dealing with implementation arrangements, conditions and covenants, procurement, and consultants' performance. There was no technical assistance provision for the loan. According to the back-to-office report (BTOR) of the Review Mission (dated 4 August 1999), the performance of the national NGOs was deemed unsatisfactory by the project management unit (PMU). The BTOR of the Review Mission merely reports on this matter and the reason provided by the PMU, but does not address the issues involved or insist that another NGO was engaged. The contract with the NGO was terminated and the PMU took over the tasks previously assigned to the NGO. The PCR does not elaborate on the reason for this change, or why the NGO was not replaced by a better qualified NGO rather than the PMU assuming the scope of activities. In addition, it is not made clear if the PMU had the capacity to undertake the scope of work initially meant for implementation by the NGO. This was significant since the Management Review Meeting and Staff Review Committee meetings, as well as ADB Board of Directors discussion on the Project, emphasized the importance of qualified NGO involvement for ensuring successful implementation. IED considers that the PCR should have elaborated on the issues involved in this change in implementation arrangements, and its effect on outcomes and impact particularly since it was a rather important feature of the Project, and the change appears to have adversely affected the impact of the Project.

6 4 (v) Performance of the Borrower and Executing Agency (EA). IED considers that the PCR adequately describes the performance and shortcomings of the Borrower and EA. Termination of the first project director, and appointment of his successor, was not done in consultation with ADB and constituted a violation of the Loan Agreement. Problems with selection and appointment of senior management staff continued in 2002, which according to the PCR, led to ADB considering suspension of the loan. Noncompliance or partial compliance with other covenants (especially on maintenance) contributed to the PCR Mission rating the performance of the Borrower and EA partly satisfactory. IED supports the PCR reasoning for rating the performance of the EA partly satisfactory. PCR did not provide a rating for the borrower. IED does not support the PCR s rating of highly satisfactory for the PMU. IED considers it to be partly satisfactory because PMU abandoned targeting of the newly settled areas with (a) high poverty incidence (PCR, paras. 4, 34, and 44); (b) implementation of BME was less than satisfactory; and (c) there were significant shortcomings in the submission of withdrawal applications and reconciliation statements (PCR, para. 25), while the project took almost 4 years (45 months) longer to be implemented than the originally planned, and disengaged the NGO and took over the role. A substantial increase in physical outputs should be taken into account regarding the delay in project completion, although it does not fully explain the delay. (vi) Performance of ADB. The PCR adequately describes the shortcomings in ADB supervision particularly (a) insufficient attention to poverty targeting, (b) subproject selection process and implementation, (c) compliance with loan covenants, and (d) inadequate attention to institutional aspects. Only the last review mission in 2007 explicitly raised concerns about lack of BME and impact assessment. IED agrees with the partly satisfactory rating for the performance of ADB. D. Evaluation of Performance (PCR assessment and validation) (i) Relevance. IED agrees with the PCR s rating of relevant both at time of approval and during implementation. The Project was consistent with the policies and strategies of Pakistan and ADB at the time of approval and remains so at completion. However, given lessons since formulation of the Project in 1996, IED agrees with the PCR s conclusion that the approach followed at that time would need to be revisited to ensure sustainability more effectively. Nevertheless, during implementation (almost 10 years), proactive implementation supervision could have ensured that adjustments were made in a timely manner to ensure sustainability for the roads and watercourse infrastructure, and some of the small-scale infrastructure subcomponents with more explicit focus on poverty reduction. (ii) Effectiveness in achieving outcome. The PCR assesses the Project effective overall in achieving its outcome. IED agrees with the PCR that the physical outputs (civil works) were achieved in an effective manner. The institutional strengthening component has received limited attention (PCR, paras. 17 and 18), and the PCR considers the output under this component not satisfactory. However, effectiveness in achieving physical outputs does not necessarily result in outcome. A significant number of people are reported to have been trained (Appendix 1), but there is no indication of what this training achieved or contributed to outcome and impact. Training should be demand-driven and contribute to enhancing institutional capacity for poverty reduction, but there is little information on this in the PCR. The PCR states that in general the outputs contributed to the outcome (para. 45). However, there is little information available on the PCR that the physical outputs effectively contributed to a significant outcome for the target group increase in rural incomes, employment, and improvement in the quality of life of poor people. BME has been inadequate, so very little quantified or qualified information regarding achieving outcome and/or impact on poor people is available. The PCR questions the rationale for widening 60 km of road from a poverty perspective (para. 45), and states that there is no impact analysis to demonstrate this. The PCR confirms that targeting the poor newly settled areas was abandoned in an early stage of implementation. It suggests that the villages identified for assistance by the NGO in the large-scale reconnaissance survey were somewhat ignored, and there was no clear and consistent poverty targeting strategy (para. 44).

7 5 The PCR reports Incomplete submission of reports and BME surveys after the departure of BME consultant in 2005 (para. 30 [ii]). No BME report was prepared after 2005, nor was an impact survey undertaken at the end of the Project. PCR Appendixes 1 and 9 indicate that no quantified information on household poverty reduction or increase in income was gathered. Construction of physical infrastructure and reduction of vehicle operating costs do not necessarily increase the incomes of poor people, which was the primary objective of this project. IED is concerned that information needed to establish the outcome for the target group has not been collected. The PCR has provided indicative information that the Project benefited households (Appendix 9), but an in-depth impact survey was not carried out, hence, no evidence substantiating the claim. Nevertheless, on the bases of the qualified information in the appendix of the PCR and the Government s phase 1 evaluation report, 3 IED supports the PCR rating that the Project was effective, but at the lower end of the scale. (iii) Efficiency in achieving outcome and outputs. The PCR assesses the Project efficient. Economic analyses were carried out of individual components (rural roads 15.8%, watercourse improvement 14.8%, small-scale infrastructure 8.8%, and rural electrification 12.9%) and weighed at a 14.5% economic internal rate of return (EIRR) for the overall project rating. IED agrees with the PCR assessment for the overall project rating of efficient but notices that the small-scale infrastructure component had an EIRR of only 8.8%. However, this is an average and given the large number of small-scale infrastructure schemes (564), some may have failed while others appear to be successful such as agroprocessing (16.2%) and goat enterprises (25.8%). IED considers the assumption used for the calculations reasonable and agrees with the PCR rating. The project implementation took additional 4 years to complete. Although, there was no cost overrun, the beneficiaries had to wait longer and forego some potential benefits to them. ADB's supervision was poor. Based on these two observations, the delivery of project was inefficient. (iv) Preliminary assessment of sustainability. The PCR rates the overall project sustainability likely, but less likely for (a) the rural roads component because of lack of maintenance; and (b) institutional strengthening because of limited attention given to this component, and lack of exit strategy supposed to have been a second phase of the Project. IED considers that the PCR presents sufficient evidence to conclude that maintenance of rural infrastructure has not been institutionalized and that its sustainability is a cause for concern, unless addressed after project completion. The PCR also considers sustainability of community organization less likely and provides the reasoning for this assessment. It indicates that the sustainability of the three components (rural electrification, watercourse improvement, and small-scale infrastructure) may be adversely affected by the lack of sustainability of the community organization component (PCR, para. 50) and the commercial viability of some types of enterprises established under the small-scale infrastructure component (PCR, Appendix 9). The small-scale infrastructure component was directly relevant to poverty reduction and improvement in quality of life. In accordance with the RRP, it involved potable water supply and sanitation, drainage, grain storage and community buildings, animal sheds, community shops, feed processing units, saw mills, flour mills, and oil mills, to be managed by community organizations. Financial analysis was undertaken for a sample of enterprises under the component (mills, etc.) to assess their commercial and financial viability (thus sustainability) (PCR, Appendix 9). Para. 40 of Appendix 9 raises doubts about the viability and sustainability of several types of enterprises under normal market conditions where grant financing would not be available. This matter is not adequately presented in the main text of the PCR. 3 The evaluation was conducted under ADB Technical Assistance to Pakistan for Preparing the Bahawalpur Rural Development Project, Phase II. Manila.

8 6 IED considers that sustainability may be compromised if issues related to road maintenance, community organization involvement, and viability of small-scale infrastructure enterprises are not addressed in a timely manner after completion of the Project. This matter is addressed in the recommendations of the PCR. However, if these issues were not resolved during the 10 years of project implementation, it is doubtful that they will be rectified during post-project completion period. Therefore, IED disagrees with the PCR rating of likely sustainable, and considers project sustainability is less likely. (v) Impact. The PCR considers that the Project s impact on poverty is difficult to assess because insufficient data exists on project beneficiary household income. IED agrees with this view. Individual components were studied by the PMU BME consultant during and presented in reports. For rural roads, vehicle operating costs were reduced by 45% 50%. However, reduction in vehicle operating costs does not necessarily benefit the poor. For watercourse improvement, significant benefits were reported in terms of higher yields and cropping intensity. Benefits derived from smallscale infrastructure are not quantified. IED concludes that the impact on poverty reduction has not been established because of lack of data. The impact on institutions has reportedly been limited for reasons explained in the PCR (after termination of the NGO contract, institutional development received limited attention). Environmental considerations were incorporated into the selection criteria but the PMU lacked the capacity to apply the procedures. The Project Completion Review Mission held discussions with stakeholders who indicated that environmental issues existed with a few tubewells, but the extent is not known. The PCR considers the actual environmental impact of the project investments not known. IED agrees with this assessment but has noted that this matter is not addressed in the PCR s recommendations. E. Overall Assessment, Lessons, and Recommendations (validation of PCR assessment) (i) Overall assessment. The Project was relevant to the development strategies and policies of the Government and ADB for poverty reduction at the time of formulation, and it continues to be so after completion. The Project aimed at poverty reduction in newly settled areas through provision of rural infrastructure and community organization in which ADB had acquired ample experience. The PCR rated the Project successful because four out of the five project components exceeded physical targets. IED considers that efficient provision of physical infrastructure is no guarantee that the Project had (significant) impact on poverty reduction. However, the Project significantly improved key rural infrastructure, and it may be expected that this had a positive impact on poverty reduction and improved the quality of life for the rural poor. The PCR and the phase 1 evaluation report present evidence that households benefited, but this is not confirmed by solid quantified data (e.g., household survey or impact assessment at the time of completion). The Project would have probably benefited further if ADB supervision had been more effective, particularly ensuring that poverty reduction was adequately emphasized. The Project is economically viable, and its recalculated EIRR of 14.5% is acceptable for a project with an emphasis on poverty reduction and rural development. Based on the foregoing, IED supports the PCR's overall successful rating, but at the lower end of the scale, and highlights that there are risks to project sustainability. (ii) Lessons. IED has no disagreement with the major lessons presented in para. 57 of the PCR. However, more explicit emphasis should have been placed on stricter and more effective supervision by ADB staff during implementation to ensure that the primary purpose of the Project (i.e., poverty reduction) was rigorously pursued by insisting that the proposed poverty targeting (as presented in RRP) be maintained. Similarly, loan covenants on BME and sustainability issues should have been more

9 7 rigorously pursued by ADB during implementation. (iii) Recommendations. IED agrees with the project-related recommendations presented in the PCR (paras ) but considers para. 61 (Additional Assistance) to be merely a statement of fact without a recommendation. IED supports the PCR s general recommendations (PCR, para. 63), but in the case of community involvement, it is essential that the participatory process should be well designed, described, and adhered to. IED noted that this crucial aspect received little attention in the project design or RRP and is a major factor for the uncertain sustainability. IED recommends that M&E requirements are clearly spelled out in the RRP, with outcomes quantified in the project framework, and that the M&E system is strictly followed during implementation. Keeping the staff who were involved in the design and formulation of the Project during the early years of implementation directly involved in implementation supervision (rather than assigning staff for implementation supervision who are not familiar with the issues that emerged during formulation) could have ensured that any shortcomings with BME, poverty targeting, and the institutional component would have been rectified in a timely manner during implementation. In the PCR, it should have been recommended that this standard practice be more strictly adhered to. F. M&E Design, Implementation, and Utilization (PCR assessment and validation) No comprehensive poverty impact assessments were carried out because the M&E consultant contract was terminated in This consultant only provided limited data, mainly on physical achievements. Because of the nonavailability of information on M&E, it is not possible for IED to validate and comment on its design, implementation, and utilization. G. Other (e.g., safeguards, including governance and anticorruption; fiduciary aspects; government assessment of the Project, as applicable) (PCR assessment and validation) The PCR reports (para. 34) that the services rendered by the national NGO were deemed unsatisfactory by the PMU, and the contract was terminated. This is stated without any further explanation or clarification. IED considers that PCR should have further investigated this matter, including why no replacement NGO was identified and contracted. The RRP proposed a substantial role for NGOs in implementation of the Project, and this was a significant topic during the Management Review Meeting, Staff Review Committee, and Board discussion on the Project. However, this NGO involvement was drastically cut short by the PMU, which took over the work of the NGO. The PMU reasoning for this rather drastic change in implementation arrangements was stated in one of the BTORs but this issue was not followed through. Independent Evaluation Department H. Rating Project Completion Report Review Relevance Relevant Relevant Effectiveness in Effective Effective Achieving Outcome Efficiency in Achieving Efficient Efficient Outcome and Outputs Preliminary Assessment of Sustainability Likely sustainable Less likely sustainable Reason for Disagreement/Comments Because of the absence of a road maintenance system, a weak community organization component, and the lack of viability of some small-scale infrastructure subcomponents.

10 8 Borrower and Executing Agency Performance of ADB Impact Highly satisfactory Partly satisfactory Cannot be verified Partly satisfactory Partly satisfactory Cannot be verified Overall Assessment Successful Successful Quality of Project Satisfactory Completion Report IED does not support the PCR s rating of the PMU as highly satisfactory, but considers it partly satisfactory because of various reasons as cited in Section C (v). BME has been inadequate, so insufficient information is available to make an assessment on the poverty impact, which was the purpose of the Project. I. Comments on PCR Quality The PCR follows PAI 6.07A, 4 and IED assesses the PCR quality generally satisfactory. In particular, Appendix 9 (the summary financial and economic analyses) is comprehensive and well written, and elaborates on the deficiencies of project implementation with regard to data collection for poverty assessment, targeting, beneficiaries, and poverty impact largely on account of inadequate BME and abolition of the proposed poverty targeting. (In para. 29, the PCR makes a cross-reference to a wrong paragraph number: para. 33 instead of para. 32.) The PCR provides an objective and frank report on deficiencies in implementation but does not report on certain weaknesses in the design (e.g., hardly any details on participatory processes and BME are presented in the RRP). Appendix 9 questions the data and estimates provided by the PMU, but views expressed by the PMU and its actions on highly critical issues (e.g., disregarding poverty targeting and termination of NGO involvement) should have been more deeply scrutinized by the Review Mission. The PCR Mission explained that it was difficult to obtain a clear and objective picture on sensitive issues because of the long period that had passed since the PMU made changes to implementation arrangements and changes of staff. J. Recommendation for IED follow up No follow-up action is required. K. Data Sources for Validation BTORs; PCR prepared by ADB; phase I evaluation report produced under project preparatory technical assistance for phase II (considered the PCR of the Government); RRP; Records of Staff Review Committee, Management Review Meeting, and Board discussions; and interviews with the ADB mission leader involved in project formulation, and the ADB mission leader for the PCR. 4 ADB Project Completion Report. Project Administration Instructions. PAI No. 6.07A. Manila.

11 REGIONAL DEPARTMENT S RESPONSE TO THE PROJECT COMPLETION REPORT VALIDATION REPORT On 14 May 2009, the Independent Evaluation Department (IED) 1 circulated the draft validation report for interdepartmental comments. IED received the comments from the Energy and Natural Resources Division, Central and West Asia Department on 25 May IED was satisfied with this clarification in response to its comment on project disbursement, and accordingly Section B(iii) of the final report was revised. The concerned department had no other comments to offer on the report. 1 The Independent Evaluation Department was named the Operations Evaluation Department (OED) until December 2008.