ICRR 12892 Report Number : ICRR12892 IEG ICR Review Independent Evaluation Group 1. Project Data: Date Posted : 08/16/2008 PROJ ID : P045188 Appraisal Actual Project Name : Gh-gef Forest US$M ): Project Costs (US$M): 8.7 8.7 Biodiversity Sil (fy98) Country : Ghana Loan /Credit (US$M): Loan/ US$M ): 8.7 8.7 Sector Board : ENV US$M): Cofinancing (US$M ): Sector (s): General agriculture fishing and forestry sector (60%) Central government administration (40%) Theme (s): Biodiversity (40% - P) Other rural development (40% - P) Participation and civic engagement (20% - S) L/C Number : Board Approval Date : 06/04/1998 Partners involved : Closing Date : 09/30/2004 06/20/2007 Evaluator : Panel Reviewer : Group Manager : Group : George T. K. Pitman John Redwood Monika Huppi IEGSG 2. Project Objectives and Components: a. Objectives: This GEF project was developed as part of the a ten -year Natural Resources Management Program (NRMP, 1998-2007), an adjustable program loan (APL). The GEF contributed a fourth component to phase I of the APL (1998-2000) that had the development objective : "To protect, rehabilitate and sustainably manage national land, forest and wildlife resources and to sustainably increase the income of rural communities who own these resources . The APL's specific objectives would be to : (i) improve the policy and regulatory environment for high forest management and timber industry development; (ii) promote local community involvement in sustainable management of the high forest and savanna woodland zones; (iii) improve management of wildlife resources while increasing their contribution to local livelihoods and economic development; and, (iv) with GEF support, implement the National Forest Protection Strategy to enhance conservation of globally significant biodiversity in priority reserves . The GEF's global environment objective of this project - known as High Forest Biodiversity Conservation HFBCP )- was to increase the ecological security of globally significant biological resources, Project (HFBCP)- especially within threatened tropical moist forest ecosystems . There were four specific objectives : 1. protect a significant portion of forest biodiversity through implementing an ecosystem approach to management within the high forest zone that involves strengthening management of national parks and taking selected high-biodiversity forest reserves out of production; 2. improve knowledge of the distribution and status of rare, threatened and endemic species through targeted surveys to better focus conservation measures; 3. enhance biodiversity protection within multiple -use production forests through exclusion of critical habitats from logging; and, 4. ensure sustainability and preserve genetic diversity of non -timber forest species that are collected by rural populations for medicinal and consumptive uses, by improved data collection, monitoring, harvest regulation, and sustainable management within forest reserves and /or at currently deforested areas at the forest margins. b.Were the project objectives/key associated outcome targets revised during implementation? No c. Components (or Key Conditions in the case of DPLs, as appropriate): There were five components (estimated costs of these at appraisal and actually disbursed are not available ): Component 1: Globally Significant Biodiversity Area (GSBA) GSBA) Site Preparation and Development of Management Plans . Through a systematic process of participatory, strategic and operational planning, the project would develop integrated management plans for the GSBAs to be implemented under a collaborative management program with local communities. Specific project financed activities would include : mapping, delineation and demarcation of GSBAs; establishment of a community -based monitoring program for key indicators; support for development of community based enterprises with direct linkage to biodiversity conservation objectives; and integration of biodiversity conservation with the general Forest Department initiative for collaborative management of forest resources both on and off reserve . The baseline studies would be completed and 25 percent of the proposed GSBAs demarcated in the first two years of the program . Component 2: Baseline Surveys, Applied Research and Monitoring . The project would finance applications-oriented research in support of the objectives of sustainable conservation and locally based management. The project would draw on completed work such as the recommendations on forest protection in Ghana from the National Forest Inventory, emerging priorities from ongoing work such as the Important Bird Areas surveys, and studies to be commissioned under the project such as a national assessment of primate conservation priorities and options . Component 3: Identification and Establishment of Provenance Reserves . For identification of GSBAs, the project would seek to extend conservation more effectively into the domain of the production forest reserves which represents some one million ha, or about 60 percent of the reserved forest estate . By extending the botanical and zoological surveys into this domain the project will identify critical natural habitats for fauna and important sites for preservation of genetic diversity in tree stocks and other flora . Component 4: Alternative Livelihood Investments . The project would establish a revolving facility to finance income-generating small scale enterprises and invest in alternative livelihood projects that would : (i) improve the economic status of the communities living around the GSBAs and encourage them to participate in the program and forgo income previously generated from the newly designated GSBAs; and (ii) relieve pressure on biological resources by supporting alternative development options . Investment in plantation development, whereby communities who forego income from harvesting rights in GSBAs would be compensated with shareholdings in new plantation developments off -reserve would be strongly supported Component 5: National Capacity Building . An explicit aim of the project was to involve national non-governmental and community-based organizations (NGOs, CBOs), academic and research institutions in implementation to build country capacity for collaborative resource management with maximum involvement of local communities in planning, implementation and monitoring activities . This component would emphasize the empowerment of local communities to play a lead role in reserve management . To this end the project would finance decentralization of management to district and community levels and grassroots public awareness activities under the wildlife component as well as specific site enhancement activities such as fire break establishment, border clearing and enrichment planting as pilots in five reserves . d. Comments on Project Cost, Financing, Borrower Contribution, and Dates: The GEF component of NRMP Phase I, the HFBCP, contributed US$ 8.7 million to the total Phase I program cost of US$ 25.7 million. The NRMP also contributed US$0.7 million to biodiversity conservation activities independently of the GEF component. Thus the HFBCP was entirely financed by GEF . Unusually the GEF component had a different timetable (June 1998 to September 2004) to the parent NRMP I that was proposed for the period June 1998 to September 2000. It was intended that the HFBCP would be completed under the second phase of NRMP . However, implementation of NRMP ran into severe problems that led to its extension until June 2003 after which it was closed and the subsequent phases of the APL were cancelled. The HFBCP suffered similar implementation problems and was extended twice : first by 18 months to June 2006 and for a second time by 12 months to June 2007. Costs of the 5 components are not given in either the PAD or ICR; only the total cost is indicated . While the ICR states that overall costs remained the same they were reallocated among the components three times (September 2004; May 2006 and June 2007) in response to changing costs, a greater emphasis on community-based activities and the need for extended project management and supervision . Budgets could only reallocated if expected costs and actual expenditures were know for each component - but these data are not presented in the ICR. 3. Relevance of Objectives & Design: Relevance of Objectives to GEF's Global Strategy is High : GEF operational Strategy/Program Objective addressed by the Project : Biodiversity/Forest Ecosystems: The project addressed the conservation of tropical forest ecosystems by strengthening the Ghanaian network of conservation areas and reinforcing the development of sustainable use and management systems for biodiversity resources . By financing the incremental cost of addressing global and regional biodiversity conservation priorities within the framework of the National Biodiversity Strategy and the National Forest Protection Strategy, GEF funding complemented IDA and bilateral donor -financed programs for development of forest production systems that are environmentally and socially sustainable, and for management of protected areas . The project targeted the approximately 8% of moist tropical forests in Ghana that, based on a comprehensive national forest inventory, rank highest, globally, in term of their importance for biodiversity . This systematic evaluation of threat and rarity, covering more than 1,000 tree species, carried out under ODA-financed Forest Inventory and Management Project was unparalleled in the West Africa region in terms of its scope and comprehensiveness . Protection of these forests was intended to secure representation of a significant fraction of the biodiversity of the upper Guinea -Congolean forest formation within a well-connected network of forest reserves . Additional priorities addressed by the project included the biologically unique southern dry forests of the Dahomey Gap that separates the two major high forest formations of western and central Africa, and the montane outlier forest of the Kyabobo highlands, the last disjunct forest within the savannah corridor that is the only place where elements of the eastern and eastern forest blocks intermingle, forming a globally unique composite biota . Relevance to Bank and Country Objectives is High : The project was consistent with the Bank's 1997 Country Assistance Strategy that, inter alia, promoted environmentally sustainable, social and economic development through capacity building within communities to encourage environmental protection and sustainable natural resource management; and also contribute to rural poverty . The 2004 CAS was built on the findings of extensive consultations with the government and the first Ghana Poverty Reduction Strategy (GPRS.) It supported deepening the harmonization among development partners, a practice mainstreamed within the assessed projects, and greater inclusion of rural areas into national development . It emphasized development and marketing of agricultural commodities, improved land use, and greater attention to environmentally -friendly agronomic practices. Agricultural development strategies, both in traditional and non -traditional crops, not only needed to be guided by market demand but also by their environmental soundness . Subsequently, the 2006 CAS reaffirmed the centrality of sound natural resource management in economic terms . Overall, the annual cost to the economy of inadequate attention to sustainable environmental and natural resource management was estimated to be about 4 percent of GDP because forests, wildlife, livestock and fisheries and land remained stressed by poor management and overexploitation . Relevance of Design was Modest : Comprehensive and cross-sectoral design was needed to redress the partial approach to environmental management in earlier projects. However, this proved to be overly ambitious in the two years allocated for the first phase of the APL; more time should have been allowed to build government commitment to the environment in the first phase. In addition, the attention given to designing the APL and getting it approved appears to have reduced the attention to the managerial practicality of the first phase and the HFBCP . The focus of the HFBCP (and APL) on forests, wildlife and biodiversity, and community management, was necessary but not sufficient to ensure sound management . Although other donors were funding t he Land Administration Program, this Program did not address land issues pertaining specifically to forests and biodiversity. For this reason and because IEG's relevance criterion refers to relevance at the time of evaluation, and not at appraisal, relevence of design is assessed as modest . And although improvements to the regulatory regime were part of the APL, this was ineffective . Thus illegal chainsaw timber extraction and bushgame exploitation continued unabated . At appraisal most risks were identified (for example the PAD stated the risks posed by "political will is insufficient to ensure new forest policy regulations are enforced without exception" and "incentives to communities to sustain these efforts are insufficient to sustain conservation efforts ") but they were underestimated as modest and project design did not address them sufficiently. A puzzling aspect of the project is why GEF agreed to fund a project tied to the first (and very short) phase of an APL when the subsequent phases of the APL were not assured . Indeed, the second phase of the APL was cancelled leaving the GEF project an orphan with inadequate cross -support. 4. Achievement of Objectives (Efficacy): Objective 1. While demarcation of GBSAs was substantially achieved, there are significant managerial problems . Modest . 30 GBSAs and 42 Protected Provenance Areas (of the 30 and 45 planned respectively) were identified, demarcated, surveyed and the boundaries marked with concrete pillars . These areas had been gazetted before the project and the enhanced legal descriptions necessary for a higher level of conservation and protection proposed by this project was approved by the Cabinet . They still await parliamentary approval and there is a high risk that this may be substantially delayed on the basis of past sector experience . These areas cover 130,000 ha and have been taken out of official timber production . Commercial harvesting of timber and non-timber forest products is banned . Even so, the protected areas were superimposed on traditional land and resource use patterns and not all stakeholders are supportive . About 70% of participants in a beneficiary survey stated that farming, clearing and burning in GBSA had decreased . Responses on wildlife issues are mixed (ICR 3.2(i)). Half the beneficiaries think that the trend of timber exploitation is decreasing; conversely only 20 percent think that mining activities are decreasing and 30 percent think it is the same. 64% think that the trend in exploitation of non-timber forest products (NTFPs) is increasing. The management of the protected areas by the Department of Game and Wildlife, was significantly affected by the 1999 reorganization of the Forestry Commission (FC is the apex agency) and the FC's downsizing from 6,000 to 3,700 staff. Under the new FC almost three-quarters of its staff are engaged on forest -related activities in the commercially-oriented Forest Service Division (that focuses on the high forest only ). Some 960 staff work for the new Wildlife Division. Most redundancy was among unskilled staff and many technical staff were moved into middle management positions. Management of forests in savannah zones has been transferred to the new multidisciplinary Savannah Resource Management Center in Tamale . The downsizing of FC staff was to be offset by passing much of the responsibility for securing reserve forest boundaries, wildlife conservation and access to local communities. While several NGOs undertake collaborative management in some wildlife reserves, for forests the response has only been partial and GBSA reserves are now generally less secure and subject to illegal logging and poaching . However, the few formal wildlife parks are generally well managed by highly-motivated staff, in many cases assisted by NGOs or from small bi -lateral grants for specific community-based conservation activities . This is because of the lack of FC budget allocation for this work, the cessation of donor-supported projects that would have enabled this to happen, and inadequate funding from District assemblies, Stool Holders and Traditional Councils due to higher priorities (e.g. municipal development, health and water supplies etc ). The FC collects and retains 40 percent of fees and levies from forest regulation and management, the balance being split among the stakeholders : the District Assembly receives 55 percent, Stool Holder 25 percent and the Traditional Council 20 percent. None of these institutions accounts to forest-using and owning communities for the royalties they receive and none of them deploys resources in development projects that could compensate communities for resource destruction or restriction of access . Thus the management system does not address compensation for loss of access to forest resources . Objective 2. Improved knowledge of the distribution and status of rare, threatened and endemic species through targeted surveys to better focus conservation measures was substantially achieved . Substantial . All 30 GBSAs were inventoried in 2004 and a large number of species (more than 370) of aviafauna, large mammals and butterflies were recorded . More detailed surveys on 7 GBSAs were undertaken in 2007 to ensure representation of the differing high forest habitats . What share of all species these surveys cover is not known . Objective 3. Enhance biodiversity protection within multiple -use production forests through exclusion of critical habitats from logging was modestly achieved with many shortcomings . Modest at best . the small number of verifiable indicators and inadequate baseline data presented in the ICR makes assessment of achievement difficult (ICR para 3.2 (ii)). Objective 4. The status of the sustainability and preservation of genetic diversity of non -timber forest species that are collected by rural populations for medicinal and consumptive uses is unknown . Although efforts were made to improve resource management through alternative livelihoods, results have been modest to date . Modest . In many areas there are tensions with the local communities too – particularly where newly established protected areas in former forests led to exclusion of communities that relied heavily NTFPs . There are no M&E timeseries data produced by the project that would allow adequate assessment of either sustainability or continued preservation of forest and biological resources in GSBAs . Social surveys of 24 communities living close to the boundaries of GBSAs were undertaken to determine opportunities for alternative livelihoods . This led since 2005 to 8,000 mini-Community Investment Projects (CIFS) to utilize the US$2.5 million community investment fund. Project support for communities near reserve boundaries focused on awareness -raising, education and development of small -scale enterprises. Most are involved in rearing giant snails, giant bush -rats (called grasscutters) for export to regional towns, and apiary, herbs and fruit plantations to mitigate loss of NTFPs. There was significant confusion among beneficiaries who thought CIFs were grants rather than loans and this latterly affected uptake; this, and a large number of other challenges to the uptake and success of CIFs, are listed in the ICR (annex 5, pages 4 and 5). IEG interviews (conducted in June 2006) in two communities found that initial failure rates were relatively high because those that needed the work had inadequate resources to bridge the gestation period to sustainable production; while other would -be entrepreneurs generally lacked the experience to nurture these hands -on agribusinesses. How far this is true of other communities cannot be determined due to lack of statistical data and sound M&E . Many interviewed by IEG were not the experienced bushmeat hunters or chainsaw operators who could make far more money following their old occupations . Thus the project's efforts at employment generation likely had little effect on poaching . 5. Efficiency (not applicable to DPLs): There are no formal measures of efficiency for this project that was primarily institutional in nature . On the basis of demonstrable results compared to the overall budget of US$ 8.7 million the efficiency is modest at best . As a GEF project an incremental cost analysis was presented in the appraisal document for the NRMP . The ICR does not attempt to verify the original assumptions or costs . ERR )/Financial Rate of Return (FRR) a. If available, enter the Economic Rate of Return (ERR) FRR ) at appraisal and the re- re -estimated value at evaluation : Rate Available? Point Value Coverage/Scope* Appraisal No ICR estimate No * Refers to percent of total project cost for which ERR/FRR was calculated. 6. Outcome: While relevance was high for objectives, it was only modest for design . The overall relevance is substantial and efficacy and efficiency are each modest . a. Outcome Rating : Moderately Unsatisfactory 7. Rationale for Risk to Development Outcome Rating: The project was only modestly effective in contributing towards the GEF's global objective : "to " to increase the ecological security of globally significant biological resources, especially within threatened tropical moist forest ecosystems ." The essential legislative process to safeguard the GBSAs is still pending and, on the basis of past experience as the ICR acknowledges, is likely to be delayed . Similarly, while management plans for the GBSAs were developed, it is not stated how far these have been implemented given the local capacity constraints (see below). Land rights, tenure and natural resources are in conflict . Deforestation and loss of habitat caused by agricultural intensification, is the biggest threat to wildlife and biodiversity . This is the clear message conveyed by the Ghana Country Environmental Analysis (2007) prepared by the Bank, DFID, Agence Française de Développement and the Royal Netherlands Embassy and IEG's PPAR of the NRM Project . The perverse incentives created by the supremacy of centralized top -down resource allocation, and the customary requirement that land has to be continually used to gain individual rights of tenure, were not addressed by the project. Instead, this GEF-supported component focused on establishing 30 globally significant biodiversity areas (GSBAs) within the high forest zone and building local support and capacity for community resource management areas (CREMAs). At the time of IEG’s visit on 2006 only one CREMA had been created . Within the GSBAs there is considerable progress on cataloguing resources because of the interest of local NGOs many of whom are supported by external funding . However, biodiversity conservation is not always supported by local communities. The ICR states for the 7 GSBA surveyed : "with the exception of Tano Offin [the 4th largest GSBA] and Atewa [the largest GSBA] all the other sites have maintained their habitat integrity, with very minimal signs of human disturbance." On Tana Offin and Atewa the ICR states : " the combination of high hunting pressure, chainsaw and farm encroachment has the potential to erode the high biodiversity values for which they were designated GBSAs." Elsewhere, and in contradiction, the ICR statements seem to indicate the risks are high for all surveyed GBSAs: "another issue of grave concern to the integrity and biodiversity value of the GBSAs is hunting pressure in almost all of the seven GSBAs assessed ." The status and risks to the other 23 GBSAs is not given in the ICR because of the defective M&E system . Protected area management is weak . There is institutional tension about the role of the Wildlife Department that weakens its ability to perform even though staff are highly motivated and skilled . This was not helped by the long delay in project support for this component that only started in 2002. Central budget constraints have been temporarily relieved by donor-funding but this is likely to decline as budget support replaces project funding . While salaries of WD (Wildlife Department) staff are being paid, there are few funds for fieldwork . (At the Mole National Wildlife Park, for example, FC budget for operational activities stopped in 2003 and bridging finance was provided by Dutch aid until November 2005. Subsequently the Bank project provided basic overheads and fuel for operational vehicles. While considerable income is generated by park fees and the game lodge this is sent to the central treasury in Accra . Park management is understaffed despite its increased responsibilities . (for example, Mole National Wildlife Park had 200 staff – 4 professionals and 196 field staff. Following reorganization of the FC it was agreed that a minimum staffing of 96 was needed to maintain the park and control poaching . Current staff are about 100, of whom about 40 are ineffective or absent due to chronic illness or unsuitability .) According to WD officials, this pattern is true for almost all protected areas in Ghana . As a result, WD staff feel marginalized in the new organizational set -up of the FC. Many senior FC officials see wildlife and biodiversity management as irrelevant to their mission and a drain on scarce financial resources even though park fees and paying visitors have greatly increased . Senior Ministry of Land, Forest and Natural Resources (MLNR) officials stated wildlife management should be financially self -sufficient and this tension remains unresolved . Illegal Poaching . The third biggest threat to biodiversity continues to grow : the bushmeat trade. This is estimated to be worth US$200 to US$300 million a year, and from studies in one protected area, to be worth about US$ 4,700 a square km. Research reveals that hunters can generate incomes similar to a wildlife officer .** High urban demand enables them to capture about 70 percent of the retail chopbar price that average about US$3 per kg (chopbars are small retailers of bushmeat – a place where the meat is chopped up .) Regulation of the trade have proved to be unsuccessful : the large number of actors in the trade make regulation and control very expensive. The annual four-month closed season is limited to a few species and enforcement is lax . The only way to regulate demand may be to increase hunters ’ costs by penalties. Yet the ways to achieve this remain elusive, not least because of differing views about conserving Ghana ’s wildlife and the unwillingness of government to invest in non-commercial activities. The sustainability of the livelihood subprojects supported by the Community Investment Fund is unknown; it was started very late in the life of the project; financial and other support was withdrawn before impacts could be verified or lessons drawn. The status of the revolving fund is not disclosed in the ICR even though it accounts for a substantial share of total project costs - about a third. Deforestation . Independent verification of national deforestation indicated that the most recent rates are 65,000 ha a year and only 16 of the 266 designated forest reserves are in sustainable production . *** Remote-sensing data using satellite imagery support these reports . While more recent remote sensing imagery is available, lack of budget and local demand has precluded updating these data . **Cowlishaw, G., S. Mendelson and J. M. Rowcliffe. 2005. Structure and Operation of Bushmeat Commodity Chain in Southwestern Ghana. Conservation Biology . V 19, No 1, February 2005. and Conservation International Ghana . 2002. Assessment of Bushmeat trade During the Annual Closed Season on Hunting in Ghana . (in collaboration with FAO Regional Office for Africa.) February, 2002. ***World Bank. 2007. Ghana Country Environmental Analysis . a. Risk to Development Outcome Rating : High 8. Assessment of Bank Performance: Quality at entry was unsatisfactory . There is no specific PAD for the GEF project and within the NRMP PAD the appraisal of the GEF component, particularly its risks, was poor . Donor-driven support for environmental management overrode recognition of weak government commitment to project objectives . Project appraisal was overly focused on the APL and paid insufficient attention to the first phase – the NRMP I and the GEF component. While the APL was appropriate given the institutional risks, the first phase was far too complex and short given the challenges, and poor Bank management handicapped its effectiveness . Expectations were unrealistic and overly ambitious as they took little account of the earlier difficulties with capacity building, donor coordination and government’s lackluster support for environmental programs . As in the preceding Environmental Resources Management Project, insufficient attention was given to the inequitable distribution of resources and the constraining effects of faulty land tenure policies that weakened communities ’ participation in the wildlife and biodiversity conservation activities . As a result, the project suffered considerable delays and had to be extended . Even so, the Bank’s focus on critical environmental policy reform, particularly for the forestry sector, was correct . Given the large scope and number of activities (of which the GEF subproject was part ), supervision was stretched between ensuring adequate attention to national policy issues on the one hand and detailed implementation in the field on the other . Approving the substantial project extension when triggers were not met passed the wrong signal to government causing the APL and the GEF biodiversity component to lose their momentum. And after FY2005 supervision budgets were reduced enabling only a "watching-brief" on GEF project activities. In retrospect, the Bank should have halted disbursement or restructured the GEF project . This became particularly important once the co -financiers’ support weakened and they departed from the NRMP . As a result, while many of the important policy issues were eventually passed into legislation, their enforcement is fraught with difficulty and remains contentious . at-Entry :Unsatisfactory a. Ensuring Quality -at- b. Quality of Supervision :Moderately Unsatisfactory c. Overall Bank Performance :Moderately Unsatisfactory 9. Assessment of Borrower Performance: Notwithstanding the substantial gains on environmental policy under the APL, the capacity to implement it and the GEF grant was weakened by low levels of government ownership . This has been a long term phenomena illustrated by the government ’s willingness to allow donor grant aid to substitute for its own resources. Recent reorganization of environmental agencies and management and its downgrading as a “nonproductive� sector indicates government ’s waning interest in the environment despite high level rhetoric . This project suffered from the same problems as the earlier projects . Government support during implementation was weak and uneven and inadequate counterpart funding led to extensive delays . Overall coordination was poor, particularly of the donor inputs . Government still does not have a coherent environmental policy and the means to provide effective environmental regulation . On the whole, government’s approach was centrist and top -down in resource allocation that marginalized rural people, thus increasing the risks to sound environmental management . While line agencies’ staff were generally highly motivated, mixed signals from the MLFN and inadequate staff numbers reduced their effectiveness . Poor governance frustrated achievement of forest -sector reforms.The ability for day-to-day management was further weakened by reducing agency budgets, inability to retain or attract qualified professional staff, poor regulation and corruption . The phasing-out of project support in favor of budget support, and the loss of substantial external technical support, has left technical weaknesses that are unresolved. a. Government Performance :Unsatisfactory b. Implementing Agency Performance :Moderately Satisfactory c. Overall Borrower Performance :Moderately Unsatisfactory 10. M&E Design, Implementation, & Utilization: Design . Although a full list of generalized input, output and APL outcome indicators was developed at appraisal of the NRMP, there is no separate PAD for the GEF subproject . Thus there is no detail on its specific indicators or even its cost breakdown . Because the first phase of the NRMP was so short its specific indicators were primarily outputs as it was assumed that development outcomes and impacts would mature in the second and third phases of the APL. The M&E system for the GEF subproject was redesigned in 2004 utilizing the University of Ghana Business School to set up a computerized M&E tracking system . Implementation . The government was slow to staff the M&E activities . According to the ICR, baseline studies were not done until 2005. The information presented on the ICR is too sparse to determine how effectively M&E was applied to the project. Information is presented in the ICR's annexes on beneficiary assessment but there are no details on the instrument used . Reported results are at times contradictory . Utilization . As far as can be determined from the ICR this was modest at best . a. M&E Quality Rating : Negligible 11. Other Issues (Safeguards, Fiduciary, Unintended Positive and Negative Impacts): Safeguards . This project was aimed at mitigating adverse environmental impacts and it was classified as an "A" project because "if poorly implemented the project could provide significant risks to rare and endangered species of flora and fauna and their habitats ." The project's impact on mitigating these concerns is unknown because of the poor M&E. Fiduciary . According to supervision reports the project was not obliged to produce periodic financial management reports. Costs according to class of expenditure are stated . However there is no record of which communities received the one-third of project funds disbursed to CIF (amounting to US$2.5 million) or what was repaid to the revolving fund. Why this tolerated is unclear as it posed high reputational risks for the Bank . Periodic progress reports on implementation progress were produced for use by project managers . The internal control systems in place at the project were reportedly generally adequate and effective . All payment documentation reviewed in the supervision reports showed evidence of proper approval procedures, with clear evidence on payment vouchers and support documents . The accounting system of the project is computerized . The final project audit was conducted after the closing date and the results are not known . 12. 12. Ratings : ICR IEG Review Reason for Disagreement /Comments Outcome : Satisfactory Moderately Demarcation of GSBAs was a Unsatisfactory necessary but not a sufficient condition to safeguard high forest biodiversity . Progress on regulation and alternative livelihoods to mitigate risks from illegal logging and bushgame was inadequate. Risk to Development Moderate High Deforestation, illegal chainsaw and Outcome : wildlife poaching pose a high risk . Inadequate budget and staffing of the WD lowers effectiveness of policing reserve areas. Government ownership of "nonproductive" resources is low. Bank Performance : Moderately Moderately The GEF subproject was sidelined by Satisfactory Unsatisfactory the attention to the NRMP and design of the APL. M&E and indicators to measure project impacts were insufficient. There is no record of which communities received the one-third of project funds disbursed to CIF (amounting to US$2.5 million) or what was repaid to the revolving fund . Borrower Performance : Moderately Moderately Low government ownership and Satisfactory Unsatisfactory inadequate budgets for the WD . Quality of ICR : Unsatisfactory NOTES: NOTES - When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006. - The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate . 13. Lessons: Borrower ownership is key to achieving project objectives . It is essential to gauge support at higher levels of government than the concerned environmental agencies . Care has to be taken that international environmental pressure, vested interests and the understandable enthusiasm of the Bank ’s own appraisal process does not lead to financing of worthy causes that governments are unwilling to support . Sound environment policy and management require inclusion of all stakeholders and incentives to keep them engaged . Care has to be taken that individuals and community stakeholders are empowered in the decision-making process, particularly over allocation of rights to utilize natural resources . Insecure property rights allied with centralized, top -down award of concessions to commercial timber operations and capture of economic rents creates conflict and promotes non -sustainable natural resource utilization that adversely affects biodiversity. Renewable natural resources and biodiversity management are different sides of the same coin and should not be considered in isolation . Insufficient attention to addressing the causes of rural poverty drives people to live off the environmental commons where short -term survival interests typically outweigh consideration of longer-term stability. Baseline data are particularly important for biodiversity conservation to demonstrate project impact . M&E to ensure this happens should be established during appraisal . This will require up-front funding commitment and a clear allocation of the responsibility to a line agency . Designers of GEF projects that are subcomponents of larger Bank projects should ensure that inadequate project documentation, phasing and cross -support expected from the Bank do not pose high risks . In this project a 6 year GEF project was attached to a 2 year first phase of an APL and the GEF project was given very cursory treatment - a proper PAD was not prepared for it and, in effect, it became a component that received insufficient attention . When the APL was cancelled after the first phase the GEF component was left an orphan with fairly minimal supervision . 14. Assessment Recommended? Yes No 15. Comments on Quality of ICR: IEG rates ICR quality based not on the performance of the project but on the ICR's analysis of that performance . In this case, the unsatisfactory ICR quality rating is based not on project implementation per se, but rather on the ICR's relatively sanguine interpretation of it . In effect, the ICR's outcome ratings for the major objectives appear to be contradicted by the evidence presented, the 2007 Ghana Country Environmental Analysis and the additional information available to IEG from its PPAR and filed work . Despite lack of adequate evidence on the project's key objectives, particularly those relating to protection, enhancement, and sustainability of GSBA's, the ICR goes on to rate the project outcome as satisfactory . In addition, there is no record of which communities received the one third of project funds disbursed to CIF, amounting to USD 2.5 million, or what was repaid to the revolving fund . We note, as the ICR ndicated, this information was unavailable at the time of preparing the ICR . However, we believe that the ICR should have made some attempt to uncover the missing cost information, especially given the amount in question. a.Quality of ICR Rating : Unsatisfactory