Document of The World Bank Report No: NCO2205 NOTE ON CANCELLED OPERATION (GEF GRANT TF056255) ON A GRANT FROM THE GLOBAL ENVIRONMENT FACILITY TRUST FUND IN THE AMOUNT OF US$ 7.18 MILLION TO THE FEDERATIVE REPUBLIC OF BRAZIL FOR THE INTEGRATED MANAGEMENT OF AQUATIC RESOURCES IN THE AMAZON PROJECT September 25, 2012 Sustainable Development Department Brazil Country Management Unit Latin America and the Caribbean Region CURRENCY EQUIVALENTS (Exchange Rate Effective September 5, 2012) Currency Unit = Real (R$) R$ 1.00 = US$ 0.49 US$ 1.00 = R$ 2.04 FISCAL YEAR January 1 to December 31 ABBREVIATIONS AND ACRONYMS AP Action Program for Integrated Management of Aquatic Resources AquaBio Integrated Management of Aquatic Resources in the Amazon ARPA Amazon Region Protected Areas Project CAS World Bank Country Assistance Strategy CONABIO National Biodiversity Commission FUNAI National Indigenous Foundation GEF Global Environmental Facility GOB Government of Brazil IBAMA Brazilian Institute for the Environment and Renewable Natural Resources MMA Ministry of Environment PCU Project Coordination Unit PROBIO National Biodiversity Project ProManejo Forest Resources Management Project ProVarzea Brazil Amazon Floodplain Natural Resources Management Project QER Quality Enhancement Review SBF Secretariat of Biodiversity and Forests-MMA SIBA Information System on Aquatic Biodiversity UNESCO United Nations Educational, Scientific, and Cultural Organization Vice President: Hasan A. Tuluy Country Director: Deborah L. Wetzel Sector Manager: Karin Erika Kemper Project Team Leader: Adriana Moreira NCO Team Leader: Emilia Battaglini BRAZIL INTEGRATED MANAGEMENT OF AQUATIC RESOURCES IN THE AMAZON PROJECT CONTENTS Data Sheet A. Basic Information B. Key Dates C. Ratings Summary D. Sector and Theme Codes E. Bank Staff F. Ratings of Program Performance in ISRs 1. Context, Project Development Objectives, and Design .............................................. 1 2. Post-Approval Experience and Reasons for Cancellation .......................................... 4 3. Assessment of Bank Performance .............................................................................. 6 4. Assessment of Recipient Performance........................................................................ 7 5. Lessons Learned.......................................................................................................... 7 Annex 1. Bank Lending and Implementation Support/Supervision Processes............... 9 Annex 2. List of Supporting Documents ................................................................... ..11 MAP A. Basic Information Integrated Management Country: Brazil Project Name: of Aquatic Resources in the Amazon (AquaBio) Project ID: P066535 L/C/TF Number(s): TF-56255 NCO Date: 12/19/2011 MINISTRY OF Lending Instrument: SIL Borrower: ENVIRONMENT Original Total USD 7.18M Disbursed Amount: USD 0.71M Commitment: Revised Amount: USD 0.71M Environmental Category: B GEF Focal Area B Implementing Agencies: Ministry of Environment - MMA Cofinanciers and Other External Partners: B. Key Dates Revised / Actual Process Date Process Original Date Date(s) Concept Review: 11/15/1999 Effectiveness: 02/28/2007 02/28/2007 Appraisal: 01/27/2006 Closing: 31/08/2012 03/26/2012 Approval: 06/13/2006 C. Ratings Summary Performance Rating by NCO Outcomes: Not Applicable Risk to Global Environment Outcome Not Applicable Bank Performance: Moderately Unsatisfactory Borrower Performance: Unsatisfactory D. Sector and Theme Codes Original Sector Code (as % of total Bank financing) Central government administration 20 General agriculture, fishing and forestry sector 60 Sub-national government administration 20 i Theme Code (as % of total Bank financing) Biodiversity 25 Environmental policies and institutions 13 Land administration and management 25 Participation and civic engagement 13 Water resource management 24 E. Bank Staff Positions At NCO At Approval Vice President: Hasan A. Tuluy Pamela Cox Country Director: Deborah Wetzel John Briscoe Sector Manager: Karin Erika Kemper Abel Mejia Project Team Leader: Adriana Moreira Maria Isabel Junqueira Braga NCO Team Leader: Emilia Battaglini F. Ratings of Project Performance in ISRs Actual Date ISR No. DO IP Disbursements Archived (USD millions) 1 12/30/2006 Satisfactory Satisfactory 0.00 2 05/21/2007 Moderately Satisfactory Moderately Satisfactory 0.00 3 11/20/2007 Moderately Satisfactory Moderately Satisfactory 0.70 4 06/19/2008 Moderately Satisfactory Moderately Satisfactory 0.70 5 12/12/2008 Moderately Satisfactory Moderately Satisfactory 0.70 6 06/04/2009 Moderately Satisfactory Moderately Satisfactory 0.70 7 12/19/2009 Moderately Satisfactory Moderately Satisfactory 0.70 Moderately Moderately 8 06/14/2010 1.02 Unsatisfactory Unsatisfactory 9 02/23/2011 Unsatisfactory Unsatisfactory 1.02 10 08/02/2011 Unsatisfactory Unsatisfactory 1.02 11 04/27/2012 Unsatisfactory Unsatisfactory 0.71 ii 1. Context, Project Development Objectives, and Design 1.1. Country and sector background The Amazon basin covers an area of approximately 7,000,000 km², of which about 58% (4,100,000 km²) is located in Brazil. From a biodiversity perspective, the Amazon basin is unparalleled; it is home to the world's richest assemblages of freshwater flora and fauna, including approximately one third of the world's entire freshwater ichthyofauna. Many of the region's economic activities are based on the use of aquatic resources, which are increasingly at risk due to the uncontrolled and poorly planned expansion of high- impact activities in the basin. The Amazon’s aquatic ecosystems, its natural resources, and human communities that depend on them, are increasingly at risk from a number of threats, including: (i) direct use of aquatic resources at unsustainable levels through hunting and fishing, leading to the over-exploitation of some species; (ii) direct contamination of rivers by increased dumping of organic and solid waste from expanding urban areas and mining activities; (iii) changes in land use in upland areas (deforestation, expanding cattle ranching, urbanization); (iv) direct habitat conversion of riparian ecosystems from expansion of water buffalo grazing in floodplains (varzeas), agriculture and urbanization and; (v) changes in flood and hydrological regimes due to infrastructure developments. Despite efforts from the Federal Government and Amazonian states in recent years to respond to such problems, both at policy and project levels, a series of constraints have made it difficult to effectively address the threats to the Amazon Basin: (i) insufficiently articulated public policies across sectors to effectively address threats; (ii) weak organizational and institutional capacity at the basin, state, and local levels to deal with these issues in a participatory and integrated manner; (iii) insufficient availability of information that policy makers and resource managers need to make good decisions and; (iv) insufficient knowledge about alternatives for the sustainable use of land and aquatic resources, especially those that generate economic benefits for local communities while also generating positive impacts on aquatic biodiversity. The AquaBio Project was aimed at testing the development and implementation of an innovative approach to the conservation and sustainable use of aquatic ecosystems in the Lower and Middle Rio Negro, Upper Xingu, and Lower Tocantins sub-basins that, together with the Floodplain Natural Resources Management Project (ProVarzea), would provide a representative sample of Amazonian aquatic ecosystems and problems that impact them. The Project sought to address various issues that directly or indirectly affect the sustainability and conservation of aquatic biodiversity and water resources in the Brazilian Amazon, operating on three major fronts that were identified as constraints for long-term conservation and sustainable use of aquatic resources: (i) strengthening the institutional capacity of various stakeholder groups to participate in decision-making processes; (ii) supporting the creation or strengthening of discussion fora at the local, 1 regional (sub-basin), national, and international levels and; (iii) learning from the testing, on a demonstrative basis, of new methodologies and technologies for the restoration and sustainable use of natural resources, and proposing the implementation of successful ones on a larger scale. 1.2. Rationale for Bank involvement The AquaBio Project was under preparation from 1999 to 2006 and in supervision from 2007 to 2012. The project was one of the few Bank operations focused on freshwater ecosystems, and was considered one of the elements in the Bank'’s strategy for re- engagement in the Amazon. The project supported a major pillar of the Bank’s Regional Environment Strategy of mainstreaming environment across sectors, and contributed to two of three of the Country Assistance Strategy’s long-term objectives: (i) improvement of water quality and water resources management; and (ii) sustainable management of land, forests, and biodiversity. Its emphasis on the mainstreaming of freshwater biodiversity considerations into sector policies sought to benefit from the Bank's existing experience in facilitating public policy discussion and in assuming the role of mediator among regional, national, sub-national, and local actors in seeking consensus for the solution of multiple demands on "shared" natural resources. Mainstreaming of environmental concerns into sector policies was being supported in Brazil by a large Programmatic Reform Loan for Environmental Sustainability with an associated Technical Assistance Loan. AquaBio would also complement and support the actions of other existing Bank projects in the Brazilian Amazon at the time, such as the Floodplain Natural Resources Management Project (ProVarzea), Forest Resources Management Project (ProManejo), Ecological Corridors Project, and Amazon Region Protected Areas Project (ARPA). 1.3. Project Development Objectives (PDO) The Project development objective was to support the mainstreaming of a multi- stakeholder, integrated management approach to the conservation and sustainable use of freshwater biodiversity in public policies and programs in the Brazilian Amazon River Basin. This would be achieved in part through generation and dissemination of sub- regional experiences that promote and facilitate the adoption of an integrated management approach in the whole Amazon Basin. The global environmental objective was to reduce threats to the integrity of freshwater ecosystems in the Brazilian Amazon and assure the conservation and sustainable use of its freshwater biodiversity of global importance. 1.4. Components The project comprised the following 4 components: 2 Component 1: Planning and Public Policy (Total US$1.26 m, GEF US$l.06 m). The objective of this component was to develop and implement Action Programs (APs) for the integrated management of aquatic resources in three sub-basins of the Brazilian Amazon, generating replicable experiences that could become permanent public policies, with positive impacts on aquatic biodiversity, on the reduction of conflicts among various users of natural resources, and on the improvement of local communities’ living and working conditions. This component would support: (a) carrying-out of detailed diagnostics of each of the three project target areas, and the elaboration and implementation of sub-basin APs; (b) the development and implementation of institutional mechanisms for integrated management of aquatic resources in sub-basins and; (c) the development of a financial strategy and mechanisms to provide financial resources for the full implementation of the APs in the long-term. Component 2: Demonstration Activities (Total US$6.43 m, GEF US$l.78 m). The objective of this component was to generate experiences and lessons learned, including new technologies or production systems, on how to incorporate freshwater biodiversity concerns into various productive activities, providing inputs for the development of Action Programs for integrated management of aquatic resources. This component would support: (a) demonstration sub-projects that mainstream freshwater biodiversity in productive activities and; (b) other activities, financed under the re-directed baseline, that create an enabling environment for the mainstreaming of freshwater biodiversity in productive activities. Component 3: Building Capacity (Total US$3.67 m, GEF US$2.56 m). The objective of this component was to prepare stakeholders, especially local ones (individuals and institutions), to be able to actively participate in the formulation, implementation, and monitoring of strategies and action programs aimed at the conservation and sustainable use of freshwater biodiversity and water resources in the project areas. This component would support activities that are crucial to the long-term sustainability of project results, such as (a) environmental education, (b) training of rural extensionists and local people on sustainable methodologies and technologies, (c) institutional and individual training for the formation of partnerships and conflict resolution and; (d) support for the establishment of decision making mechanisms and conflicts resolution over the use of aquatic resources in the project target areas. Component 4: Project Management, Monitoring and Evaluation and Information Dissemination (Total US$5.80 m, GEF US$1.77 m). The objective of this component was to coordinate, manage, and monitor actions developed under the scope of the project, foster integration among the various components and with other related projects and programs, indicate possible needs for changes in project implementation, and disseminate results at local, state, national and international levels. It would also support the implementation of a project physical-financial monitoring system and the development and implementation of an Information System on Aquatic Biodiversity (SIBA). The four components would be integrated at the sub-basin level through the following main activities in each sub-basin: (i) a diagnostic of the main threats and of the barriers to 3 address them, (ii) dissemination of information, training, and a participatory consensus building process involving resource users and government institutions for elaboration of a plan for the conservation and management of aquatic resources and; (iii) establishment of a governance strategy for the long-term implementation of such plan, including a framework for conflict mediation and resolution. This approach sought to contribute to the implementation of the National Biodiversity Policy as it supported a decentralized, inter-sectoral approach to the management of aquatic ecosystems, and incorporated economic, social, cultural (traditional knowledge), and environmental dimensions in the formulation and implementation of project supported action programs. 1.5. Costs and funding Total project cost was estimated at US$17.13 million. Financing included a Global Environment Facility (GEF) grant of US$7.18 million and recipient co-financing in the amount of US$9.95 million, of which: (i) US$6.78 million was from the Government of Brazil; (ii) US$2.02 million was from re-directed baseline; (iii) US$0.48 million was from the Government of Mato Grosso; (iv) US$0.59 million was from Government of Amazonas and; (v) US$0.08 million was from project beneficiaries. 1.6. Implementation arrangements In its initial design the project was to be implemented by the Ministry of Environment (MMA) as the Executing Agency through its Secretariat of Biodiversity and Forests (SBF). In March 2010 the project was restructured, designating the Brazilian Institute for the Environment and Renewable Natural Resources (IBAMA) as the new Executing Agency. Other partners included the National Indigenous Foundation (FUNAI) and the state environmental agencies of Amazonas, Mato Grosso and Pará. The National Biodiversity Commission (CONABIO) was selected to serve as the Project Steering Committee, given its mandate and composition, which includes representatives from key ministries, civil society organizations, and representatives of sectors that use biodiversity resources. The Project Coordination Unit (PCU), constituted initially by MMA staff, was established within the Secretariat of Biodiversity and Forests (SFB/MMA). It was agreed that for the first two years of the project, the United Nations Educational, Scientific, and Cultural Organization (UNESCO) would carry out procurement functions under a Technical Cooperation Agreement with MMA. With the shift of project implementation to IBAMA, UNESCO’s mandate was extended until end of project. For each sub-basin, State Project Committees would be formally established by the end of the first year of project implementation. These committees’ responsibilities included, among others: (i) Serving as a vehicle for mainstreaming project experiences and lessons at the state level for planning and public policies; (ii) Assessing and validating sub-basin Annual Operating Plans; (iii) Reviewing and approving the Sub-Basin Action Programs (APs) and; (iv) Monitoring project execution, and suggesting necessary adjustments. 4 In addition, Local Project Committees would be established for each project target area, and would be comprised of representatives of existing local governmental and nongovernmental institutions and organizations and, whenever possible, include representatives of existing municipal development committees to facilitate later mainstreaming of project experiences into municipal public policies. 1.7. Risk analysis Assessments that evaluated economic, financial, technical, fiduciary, social, environmental, and safeguards issues were conducted at the time of appraisal. Overall project risk was assessed as Medium. No controversial or reputational issues that could have posed risks for the Bank were identified. Critical risks identified at the time of appraisal included: (i) lack of coordination among federal and state level actors; (ii) low capacity of local communities and indigenous groups to propose and execute activities; (iii) insufficient institutional capacity for project implementation at federal and state levels; (iv) federal budget constraints and; (v) change in federal and state administrations. All risks were considered moderate in view of mitigation measures. 1.8. Quality at entry The project was reviewed extensively during preparation, most notably through the Quality Enhancement Review (QER) of February 2005 and the Decision Meeting of November 2005, but also through the GEF Secretariat technical reviews. The Decision Meeting highlighted that the institutional and implementation arrangements appeared complex and not fully defined, but they were also considered as reflecting the diversity of institutional capacity and interest in freshwater biodiversity issues. The Decision Meeting review also confirmed that the project’s main idea - developing mechanisms for involving stakeholders in addressing conservation and sustainable use of freshwater ecosystems in the Amazon - was sound and that the project supported Brazil’s biodiversity conservation and geographic priorities and the Bank engagement strategy. In retrospect, it appears that the quality of the review process was weak and failed to recognize that the project risk analysis was inadequate. 2. Post-Approval Experience and Reasons for Cancellation. The Project was approved by the Board on June 13, 2006. The GEF Grant agreement was signed on September 15, 2006 and became effective on February 28, 2007. The project closed on March 26, 2012, 5 months before original date of August 31, 2012, with the undisbursed amount of USD 6.47 Million, equivalent to 90.1% of original project funding. Critical factors that led to the decision to proceed with cancellation include: MMA’s low level of capacity, commitment and leadership significantly delayed the establishment and functioning of the Project Coordination Unit. Despite strong 5 engagement at State and local levels, MMA’s support and involvement remained uneven and generally inadequate throughout the first two years of implementation. The PCU, once established, was chronically understaffed, with high turnover of staff and eventually the loss of the Project Coordinator in June 2009. A lengthy project restructuring negotiation to transfer implementation responsibilities to IBAMA further delayed the beginning of project implementation. To increase efficiency and improve disbursement the government proposed to transfer project implementation (including some procurement responsibilities) to the more adequately staffed IBAMA while MMA would retain the dialogue and policy coordination with state governments. Negotiations between the ministries of Environment, Planning, Finance and the Bank protracted well into the third year of project life. Very few activities were implemented and less than 10% of the grant was disbursed by the end of the third year. Project implementation was further hindered by IBAMA’s own internal reorganization and change of leadership that occurred just after the project restructure was approved. Government and Bank signed an amendment to the grant agreement to reflect the revised project implementation arrangements in March 2010. However, the transition in responsibilities from MMA to IBAMA stalled for several months and with the change in IBAMA’s management the level of staff and support originally envisaged did not materialize. The inaction at the federal level impacted negatively on the ability of state and local governments to retain technical staff. No activities were implemented after project restructuring and project implementation ratings were downgraded to unsatisfactory. Conditions of effectiveness of the amended Grant Agreement were not met. Subsidiary agreements on technical cooperation with each of the states and the contract with the financial agent for the execution of sub-projects were not signed prior to the effectiveness deadline of June 30, 2011. In addition, several provisions of the Grant Agreement, including maintaining a functioning and adequately staffed PCU, were also not met, causing implementation and disbursement to stall. After several unsuccessful efforts to address the above issues, the government eventually decided to proceed with the cancellation of the grant. 3. Assessment of Bank Performance Rating: Moderately Unsatisfactory The project was designed to pilot innovative bottom-up mechanisms for stakeholder involvement in conservation and sustainable use of freshwater ecosystems and was considered highly relevant for Brazil’s aquatic ecosystems and the people that depend on them. Project preparation was characterized by a long but comprehensive participatory consultation process. Close and productive relationships were established with MMA, state governments and other partners. 6 However, despite a long preparation phase, the project design had some shortcomings: it overestimated MMA’s commitment and capacity to internalize the aquatic biodiversity conservation agenda within the institution and failed to properly evaluate the risks associated with government internal bureaucracy; capacity and readiness to manage and implement a highly complex project; and level of commitment. In addition, changes in the Bank team composition mid-way through the life of the project reduced the momentum and affected the ability of the Bank to provide continued support to the client. After the project was approved the Bank team worked intensively with the government, first to start project’s implementation and then to assist with the project restructuring. Despite significant efforts implementation never took off fully and the project performance, already poor from the onset, worsened over time. Overall the Bank performance is rated moderately unsatisfactory due to shortcomings in the preparation phase, particularly in assessing the risks associated with project complexity, capacity and institutional and implementation arrangements. 4. Assessment of Recipient Performance Rating: Unsatisfactory While the Brazilian government has successfully promoted the biodiversity conservation agenda and has been very supportive of the project and its objectives, in practice within MMA the theme of conservation of aquatic biodiversity was weakly developed and was not considered a priority. The lack of interest and commitment at the federal government level translated into limited ownership and engagement and weak coordination between federal and state levels during project preparation and implementation. Although the project enjoyed the support of actors and stakeholders at state and local levels, it did not have a champion at the federal level that was committed to implementing the project from the beginning and supporting its restructuring later on. Attempts at modifying the project’s institutional and implementation arrangements, including transferring the project to IBAMA, were not followed through by the government and remained at the planning stage. On this basis, the Borrower’s performance is rated unsatisfactory. 5. Lessons Learned Project design needs to be based on a more accurate assessment of the implementation capacity and readiness of government. In hindsight, the project would have benefited from a less complex and more flexible structure and mechanism to support the subprojects, to be more aligned with government execution and management capacity and level of experience, and to be more compatible with a small grant aimed at generation and dissemination of sub-regional experiences that could be scaled up. Following this experience, the Bank adjusted its approach in Brazil and opted for projects such as PROBIO II and ARPA II, with less complex structural designs and with stronger emphasis on institutional capacity at the federal level in the area of large-scale biodiversity conservation. 7 Project teams must apply greater realism in defining project objectives. The project global environmental objective of “assur[ing] the conservation and sustainable use of the Brazilian Amazon freshwater biodiversity� was overambitious and unrealistic in light of the complex local environment characterized by conflicting interests and a multitude of pressures on such resources. Greater rigor is needed in carrying out risk analysis of Natural Resource Management projects. The inadequate and insufficient risk analysis carried out for the project and the failure of the different review bodies and processes to pick up on this weakness hindered execution from project start. Risks analysis should be comprehensive and scrupulous particularly in operations with complex structure and/or piloting new approaches. Commitment to the project objectives is stronger among those that are more likely to benefit. The project enjoyed much support at state and local levels, where most of the activities were supposed to happen, however the primary responsibility for leading project implementation was with the government at the federal level. This misalignment, coupled with weak institutional capacity, created a bottleneck and lack of engagement. Projects are more likely to be successful if the responsibility for project implementation and flow of funding are closer to where the project interventions are. Remedial actions to poor project performance, including the decision of cancelling an operation need to be taken quickly to be cost-effective. It took five years and ten supervision missions to decide to cancel this operation. During this period the government and the Bank made several efforts to improve the project performance at a high cost for both. Despite these efforts the project disbursed less than 10% and achieved very little on the ground. 8 Annex 1. Bank Lending and Implementation Support/Supervision Processes (a) Task Team members Responsibility/ Names Title Unit Specialty Lending Maria Isabel Junqueira Braga Senior Environmental Specialist AFTEN Task Team Leader Judith M. Lisansky Sr Anthropologist LCSSO Social Graciela Lituma Sr Rural Development Specialist LCSER Rural Mariana M. Montiel Senior Counsel LEGLA Lawyer Robert Schneider Lead Sustainable Dev. Economist LCSES Economist Luciano Wuerzius Procurement Specialist LCSPT Procurement Claudio Mittelstaedt Financial Management Specialist LCSFM Fin. Management Daniella ZillerArruda Program Assistant LCC5C Admin. Support Karagiannis Supervision/NCO Adriana Moreira Senior Environmental Specialist LCSEN Task Team Leader Judith M. Lisansky Sr Anthropologist LCSSO Social Mariana M. Montiel Senior Counsel LEGLA Lawyer Joao Vicente Novaes Campos Sr Financial Management Specialist LCSFM Fin. Management Maria João P. Ribei Kaizeler Financial Management Specialist LEGLE Fin. Management Frederico Rabello T. Costa Senior Procurement Specialist LCSPT Procurement Sinue Aliram Procurement Specialist LCSPT Procurement Luciano Wuerzius Procurement Specialist LCSPT Procurement Paula Silva P. de Freitas Operations Analyst LCSEN Water Resources Guadalupe Romero Silva Consultant LCSSD Environmental Agnes Velloso Consultant LCSSD Safeguards Emilia Battaglini Senior Environmental Specialist LCSEN NCO Team Leader Barbara Brakarz Conultant LCSEN NCO Co-author (b) Staff Time and Cost Staff Time and Cost (Bank Budget Only) Stage of Project Cycle USD Thousands (including No. of staff weeks travel and consultant costs) Lending FY00 8.5 51.13 FY01 6.9 41.51 FY02 3.7 22.10 FY03 3 18.25 FY04 6.8 41.05 FY05 13 77.85 FY06 12.7 76.64 Total: 54.6 328.53 Supervision/NCO 9 FY00 0 0.00 FY01 0 0.00 FY02 0 0.00 FY03 0 0.00 FY04 0 0.00 FY05 0 0.00 FY06 0 0.00 FY07 8.4 50.35 FY08 7.3 44.04 Total: 15.7 94.39 10 Annex 2. List of Supporting Documents 1. Integrated Management of Aquatic Resources in the Amazon Project Appraisal Document (PAD), Report No. 36172-BR (May 15 2006) 2. Global Environmental Facility Trust Fund Grant TF056255 (September 15, 2006) 3. Implementation Status and Results Reports (ISR) No. 2048 (23 Feb 2011), No. 3985 (2 Aug 2011), and No. 6381 (2 Aug 2011). 4. Office Memorandum, July 6, 2011- Recommendation for Suspension of Disbursements 5. Letter from World Bank Country Director to Executive Secretary, Ministry of Environment, communicating need to cancel project (26 April 20110 6. Letter from Executive Secretary of Ministry of Environment to World Bank Brazil Country Director requesting AquaBio to be closed (September 15 2011). 7. Letter from Executive Secretary of Ministry of Environment to Secretary of International Affairs, Ministry of Planning, on project performance assessment (4 November 2011). 8. Supervision Aide Memoires 5-7 May 2009 and 8-10 December 2009. 9. Latin America and Caribbean Regional Environment Strategy (June 2002). 10. Brazil Country Assistance Strategy 2003-2007. 11