The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Power Sector Recovery Performance Based Operation (P164001) AFRICA WEST | Nigeria | Energy & Extractives Global Practice | Requesting Unit: AWCW2 | Responsible Unit: IAWE4 IBRD/IDA | Program-for-Results Financing | FY 2020 | Team Leader(s): Ani Balabanyan, Muhammad Abba Wakil, Yue Man Lee Seq No: 1 | ARCHIVED on 27-Oct-2020 | ISR43494 | Created by: Serdar Jepbarov on 15-Sep-2020 | Modified by: Muhammad Abba Wakil on 20- Oct-2020 Program Development Objectives Program Development Objective (from Program Appraisal Document) Objective to be Determined. The Programâ s development objectives (PDO) are to improve the reliability of electricity supply andenhance power sector financial viability and governance. The Program is anchored on the Power Sector Recovery Program (PRSP) approved by the Federal Government of Nigeria in March 2017. Specifically, the Program will support a portion of PRSP under the following three results areas: (i) reliability of electricity supply is improved ; (ii) financial sustainability is reached; and (iii) governance and transparency is improved. Overall Ratings Name Previous Rating Current Rating Progress towards achievement of PDO -- Satisfactory Overall Implementation Progress (IP) -- Satisfactory Implementation Status and Key Decisions The Board of Executive Directors of the World Bank approved the Power Sector Recovery Performance Based Operation on June 23, 2020. The financing agreement was signed on September 30, 2020. Upon effectiveness, it is expected that a disbursement of about USD80 million will be made against prior results. This is projected to happen before the end of December, 2020. Data on Financial Performance Disbursements (by loan) Project Loan/Credit/TF Status Currency Original Revised Cancelled Disbursed Undisbursed % Disbursed Not P164001 IDA-66990 USD 750.00 750.00 0.00 0.00 759.27 0% Effective Key Dates (by loan) Project Loan/Credit/TF Status Approval Date Signing Date Effectiveness Date Orig. Closing Date Rev. Closing Date Not P164001 IDA-66990 23-Jun-2020 -- -- 30-Jun-2023 30-Jun-2023 Effective Program Action Plan 10/27/2020 Page 1 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) (i) adjust the FX and energy vol. assumptions consistent with the FGN approved Financing Plan; and (ii) defining Action Description scope and implementation arrangements of a phased service quality -based tariff regime linking tariff rates paid by customers in each cla Source DLI# Responsibility Timing Timing Value Status Technical DLI 7 NERC Recurrent Semi-Annually In Progress Completion Measurement MYTO for each DISCO Comments The first relevant tariff adjustment occurred on September 1, 2020. Communication that the allowance parameters on capital expenditure, operational expenditure, and ATC&C losses in Action Description the Performance Agreements will end on December 31, 2021 Source DLI# Responsibility Timing Timing Value Status Technical DLI 7 BPE Due Date 01-Jul-2020 In Progress Completion Measurement Notice Comments BPE is currently seeking approval from the National Council on Privatization to make this announcement. Determination of revenue requirements of DISCOs and TCN for 2021-25 based on MYTO extraordinary review and Action Description setting new allowances for operating expenditure, capital expenditure and ATC&C losses from January 1, 2022 Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems DLI 1 NERC Due Date 31-Dec-2020 Not Yet Due Completion Measurement Order for each DISCO and for TCN Comments Will likely be delayed to July 2021 due to political issues with the tariff increase. FMFPNP issuance of updated Financing Plan on an annual basis together with underlying macro-sectoral Action Description assumptions and policy decisions Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems FMFBNP Recurrent Continuous In Progress Completion Measurement Memorandum and Minutes/Letter Comments The first issuance occurred in April, 2020 and the next is due in early 2021 Hiring of an officer in the PSRP Secretariat to oversee the updating of the Financing Plan (the PEF) and monitoring of Action Description its execution by NBET Source DLI# Responsibility Timing Timing Value Status Within three months Fiduciary Systems PSRP Secretariat Other In Progress after effectiveness 10/27/2020 Page 2 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Completion Measurement Appointment letter Comments Currently being procured. Quarterly Financing Plan monitoring and implementation reports including the size of new tariff shortfalls and new Action Description non-tariff shortfalls, the uses of funds and the sources of funds. Source DLI# Responsibility Timing Timing Value Status Quarterly (three Fiduciary Systems PSRP Secretariat Other months after the end of Not Yet Due the quarter) Completion Measurement Quarterly Financing Plan monitoring and implementation reports Comments Action Description Approval of DISCOs’ PIPs Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems DLI 3 NERC Due Date 30-Sep-2020 Delayed Completion Measurement Orders approving PIPs Comments Currently expected by October 30, 2020 Action Description Monitoring and enforcement of PIPs’ implementation for DISCOs Source DLI# Responsibility Timing Timing Value Status DLI 7 Continuous (annually for the three quarters of Fiduciary Systems NERC Other applicable year and In Progress last quarter of previous year) Completion Measurement Audit report on the monitoring and enforcement of PIPs Comments This will only commence after approval of PIPs Establishment of the list of qualified experts who would assume transitory management of DISCOs in the event of Action Description NERC license intervention Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems DLI 7 BPE Due Date 01-Jul-2020 Completed Completion Measurement Order with approved list Comments The approved list was shared with the Bank in July 2020 10/27/2020 Page 3 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Action Description Setting minimum remittance thresholds to establish DISCOs’ payment obligation to NBET Source DLI# Responsibility Timing Timing Value Status DLI 4 July 1, 2020 and as part of MYTO reviews Fiduciary Systems NERC Other In Progress till reaching cost recovery Completion Measurement MYTOs approving thresholds for each DISCO Comments This was reflected in the NERC Tariff Orders of March and September 2020 Action Description Removal of historical tariff shortfalls from DISCOs’ books Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems DLI 7 FMFBNP Due Date 01-Jul-2020 Delayed Completion Measurement Order approving the mechanism Ministry of Finance is reviewing options for which government agency will take the shortfalls on it's books. Most likely Comments option may require amendment of the Electricity Reform Act. Action Description Approval of tariff adjustments consistent and measures to protect the poor with the approved Financing Plan Source DLI# Responsibility Timing Timing Value Status DLI 7 Continuous with the first adjustment Fiduciary Systems NERC Other In Progress expected on July 1, 2020 Completion Measurement Order approving end-user tariffs Comments The first adjustment occurred on September 1, 2020 Action Description Public consultation on tariff adjustment Source DLI# Responsibility Timing Timing Value Status DLI 5 Continuous (prior to Fiduciary Systems NERC Other In Progress each tariff adjustment) Completion Measurement Reports on public consultation/hearing process Comments Consultations were done in Q1, 2020 Design and implementation of a public communication campaign as the market transitions to financial self- Action Description sustainability 10/27/2020 Page 4 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Source DLI# Responsibility Timing Timing Value Status Other NERC Due Date 01-Sep-2020 Delayed Completion Measurement Campaign report Comments Consultant was only successfully procured in October, 2020 and report won't be available before Q2, 2021 Development of a draft common script about the PSRP to provide consistent messaging about technical issues, and Action Description agree on the script with the key MDAs (FMoP, NERC, BPE, NBET, TCN and the Office of the President) Source DLI# Responsibility Timing Timing Value Status Technical PSRP Secretariat Due Date 31-Dec-2020 Not Yet Due Completion Measurement Draft common script Comments Action Description Establishment of stakeholder feedback mechanism Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems PSRP Secretariat Due Date 01-Mar-2021 Not Yet Due Completion Measurement Stakeholder feedback mechanism Comments Action Description Implementation of public communication campaign to raise awareness about the PSRP Source DLI# Responsibility Timing Timing Value Status PSRP Fiduciary Systems Due Date 01-Mar-2021 Not Yet Due Secretariat/NERC Completion Measurement Campaign report Comments Action Description Conducting of a survey to measure public awareness Source DLI# Responsibility Timing Timing Value Status PSRP Fiduciary Systems Due Date 31-Dec-2022 Not Yet Due Secretariat/NERC Completion Measurement Survey report Comments 10/27/2020 Page 5 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Action Description Periodic reporting (through a dedicated website) of PSRP implementation progress Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems PSRP Secretariat Due Date 31-Dec-2021 Not Yet Due Completion Measurement Indicators of Critical PSRP implementation progress Comments Assessment of NERC's regulatory capacity, from organizational structure and HR perspective and design of a Action Description capacity building program Source DLI# Responsibility Timing Timing Value Status Other NERC Due Date 30-Jun-2021 Not Yet Due Completion Measurement Report of an independent regulatory consultant and records of training Comments Action Description Establishment of PSRP Finance and Policy Oversight Committee Source DLI# Responsibility Timing Timing Value Status Within three months Other Presidency Other Completed after effectiveness Completion Measurement Order Comments Action Description Establishment of PSRP Finance Technical Committee Source DLI# Responsibility Timing Timing Value Status Within three months Technical FMFBNP Other Completed after effectiveness Completion Measurement Order Comments Action Description Establishment of PSRP Secretariat with Program management expertise Source DLI# Responsibility Timing Timing Value Status 10/27/2020 Page 6 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Within three months Technical FMFBNP Other Not Yet Due after effectiveness Completion Measurement Order Comments Action Description Preparation of Operations Manual Source DLI# Responsibility Timing Timing Value Status Other PSRP Secretariat Other Before effectiveness Not Yet Due Completion Measurement Manual Comments Action Description Support to strengthening of the capacity of NBET for competitive procurement of generation Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems NBET Recurrent Continuous Not Yet Due Completion Measurement Terms of reference for support Comments Prioritization of FGN budget appropriation releases related to the Program funding; the funds to be released into the Action Description Program Account in quarterly tranches in advance Source DLI# Responsibility Timing Timing Value Status Within three months Fiduciary Systems FMFBNP Other In Progress after effectiveness Completion Measurement Directive Comments Action Description Approval and adoption of the payment protocols Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems FMFBNP Other By effectiveness Not Yet Due Completion Measurement Order of the Minister Comments 10/27/2020 Page 7 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Action Description Approval for implementation of the updates made to Finance Operating Procedures Manual of NBET be presented Source DLI# Responsibility Timing Timing Value Status The highest authority Fiduciary Systems Other By effectiveness In Progress at the management Completion Measurement Order Comments A proposal has been made and is now subject to NBET Board approval. Amendment of the accounting software at NBET to enable segregated recording of amounts for the PEF expenditure Action Description lines, including tariff shortfalls and non-tariff shortfalls Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems NBET Other By effectiveness In Progress Completion Measurement Order Comments Currently working with software provider to complete update. Establishment and operationalization of a risk-based, ex-post internal audit function at NBET. To this end, training to Action Description be provided to the internal audit unit and a consultant with requisite experience and skills be embedded for a few months Source DLI# Responsibility Timing Timing Value Status Initiated by December NBET/PSRP Fiduciary Systems Other 30, 2020 and Not Yet Due Secretariat continuous Completion Measurement Training of staff and report on initial assessment Comments Clearance of backlog of external audit and thereafter submission of audited financial statements with enhanced ToRs Action Description of external auditors, which will include an opinion on the eligibility for PforR financing of the recorded PEF expenditures. Source DLI# Responsibility Timing Timing Value Status By September 30, NBET/PSRP 2020 for the backlog Fiduciary Systems Other In Progress Secretariat and within six months of year end thereafter Completion Measurement Audit Reports and Contract award to auditors Comments Audits are ongoing and will be approved by NBET Board. 10/27/2020 Page 8 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Preparation of guidelines and manual for mainstreaming stakeholder engagement process and integrating Action Description environmental, health and safety issues into the implementation of the Program Source DLI# Responsibility Timing Timing Value Status Environmental and Social NERC, FMoP Due Date 30-Jun-2021 Not Yet Due Systems Completion Measurement Completed guidelines in booklet form disseminated to stakeholders, training provided, and guidelines operationalized Comments Annual evaluation, monitoring and reporting of progress on environmental and social issues, especially regarding the Action Description compliance of the Program activities with the extant environmental standards and regulations Source DLI# Responsibility Timing Timing Value Status Environmental and Social PSRP Secretariat Due Date 01-Jan-2021 Not Yet Due Systems Completion Measurement Completed report with recommendations about environmental and social issues and associated follow-up measures Comments Action Description Evaluate and report on the Environmental and Social Risk Management Actions of the Program Source DLI# Responsibility Timing Timing Value Status Environmental and Social Within twelve months PSRP Secretariat Other Not Yet Due Systems of effectiveness Completion Measurement Progress reports Comments Enhancing of women’s agency as providers of information and customers related to energy sector reform through a Action Description focus on advocacy and employment Source DLI# Responsibility Timing Timing Value Status Environmental and Social Starting January 1, PSRP Secretariat Other Not Yet Due Systems 2021 Completion Measurement Terms of Reference for Customer Information Campaign driven by Women’s Groups Comments Strengthening of the mandate of the gender focal point in the MoP by developing a work plan and clear lines of Action Description responsibility for the gender desk/focal point Source DLI# Responsibility Timing Timing Value Status 10/27/2020 Page 9 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Environmental and Social PSRP Secretariat, Due Date 31-Dec-2021 Not Yet Due Systems FMoP Completion Measurement Work plan with budget Comments Disaggregating NERC’s current data on electricity consuming households by income level and gender, commencing Action Description by assessing data gaps and developing terms of reference for a pilot study Source DLI# Responsibility Timing Timing Value Status Environmental and Social NERC Due Date 31-Dec-2021 Not Yet Due Systems Completion Measurement Terms of Reference for data gap assessment and pilot study Comments Action Description Removal of new tariff shortfalls from DISCOs’ books Source DLI# Responsibility Timing Timing Value Status Technical NERC Due Date 01-Jul-2020 Delayed Completion Measurement Order approving the mechanism Comments Risks Systematic Operations Risk-rating Tool Risk Category Rating at Approval Previous Rating Current Rating Political and Governance -- -- High Macroeconomic -- -- Substantial Sector Strategies and Policies -- -- High Technical Design of Project or Program -- -- Moderate Institutional Capacity for Implementation and -- -- High Sustainability Fiduciary -- -- Substantial Environment and Social -- -- Moderate Stakeholders -- -- High Other -- -- High 10/27/2020 Page 10 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Overall -- -- High RiskComments Comments Operational risk linked to distribution constraints is rated High. Results PDO Indicators by Objectives / Outcomes Improve reliability of electricity supply IN00899060 ►Annual electricity supplied to the distribution grid is increased (Gigawatt-hour (GWh), Custom) Baseline Actual (Previous) Actual (Current) End Target Value 23,722.00 -- 23,722.00 39,420.00 Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments Achieve financial and fiscal sustainability IN00899167 ►Annual tariff shortfalls decline (Text, Custom) Baseline Actual (Previous) Actual (Current) End Target Value Billion Naira 524 -- Billion Naira 524 >Billion Naira 300 Date 01-Jan-2019 -- 29-Sep-2020 30-Dec-2022 Comments IN00899168 ►New tariff shortfalls are funded from non CBN sources (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 -- 0.00 80.00 Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments Enhance accountability IN00899138 ►Public awareness about ongoing power sector reforms and performance increases (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 29.00 -- 29.00 60.00 10/27/2020 Page 11 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments IN00899193 ►Public awareness about ongoing power sector reforms and performance among women increases (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 23.00 -- 23.00 40.00 Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments Intermediate Results Indicators by Results Areas Improve reliability of electricity supply IN00899049 ►PIPs of DISCOs are implemented to remove the constraints to supply in their networks (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 -- 0.00 30.00 Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments IN00899050 ►Business continuity arrangements for DISCOs are implemented (Yes/No, Custom) Baseline Actual (Previous) Actual (Current) End Target Value No -- No Yes Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments Achieve financial and fiscal sustainability IN00899169 ►Revenue requirement of DISCOs is set consistent with semi-annual MYTO minor reviews and MYTO extraordinary review (Yes/No, Custom) Baseline Actual (Previous) Actual (Current) End Target Value No -- No Yes Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments IN00899170 ►End-user electricity tariffs are adjusted consistent with FGN approved PSRP Financing Plans (Yes/No, Custom) 10/27/2020 Page 12 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) Baseline Actual (Previous) Actual (Current) End Target Value No -- No Yes Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments IN00899171 ►DISCOs’ recurrent payment obligations to NBET are paid (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 29.00 -- 29.00 90.00 Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments IN00899172 ►Historical tariff shortfalls and associated interest are removed from DISCOs’ books (Yes/No, Custom) Baseline Actual (Previous) Actual (Current) End Target Value No -- No Yes Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments Enhance accountability IN00899191 ►Audited financial statements of DISCOs are published annually (Yes/No, Custom) Baseline Actual (Previous) Actual (Current) End Target Value No -- No Yes Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments IN00899192 ►Key operational and financial data for the power sector are published quarterly on NERC website (Yes/No, Custom) Baseline Actual (Previous) Actual (Current) End Target Value No -- No Yes Date 03-Dec-2018 -- 29-Sep-2020 30-Dec-2022 Comments Disbursement Linked Indicators DLI_IND_TABLE 10/27/2020 Page 13 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) ►DLI 1 NERC sets revenue requirement for TCN and DISCOs based on MYTO Minor Reviews and a MYTO Extraordinary Review (Process, 150,000,000.00, 0%) 12 Months Period ending 31-Dec-2022 (Cumulative Baseline Actual (Previous) Actual (Current) number) TCN and DISCOs do not TCN and DISCOs do not receive their full revenue receive their full revenue requirement based on the requirement based on the Value MYTO and the MYTO -- MYTO and the MYTO -- parameters do not reflect parameters do not reflect current conditions of the current conditions of the sector. sector. Date -- -- 07-Oct-2020 -- Comments ►DLI 2 A credible and fiscally sustainable PSRP Financing Plan is approved and executed to fully cover tariff shortfalls (Process, 140,000,000.00, 0%) 12 Months Period ending 31-Dec-2022 (Cumulative Baseline Actual (Previous) Actual (Current) number) Value Tariff shortfalls of the sector -- Tariff shortfalls not fully (i): FMFBNP issues are not fully funded. funded the 2023 PSRP Financing Plan covering the uses and sources of funds to clear historical and fund new tariff shortfalls for 2023-2027, consistent with the MYTO effective on January 1, 2023; and (ii) Actual tariff shortfall incurred for Q1-Q4 2020 and Q1-Q3, 2021 not yet funded and estimated tariff shortfalls for Q4, 2021 and Q1-Q3, 2022, set out in the 2022 Financing Plan, are funded from other sources than CBN, when the CBN PAF has been depleted. Basic target: G2.4(i) achieved, 80 percent of the sum of (A) the actual tariff shortfalls incurred for Q1-Q4, 2020 and Q1- Q3, 2021 not yet funded 10/27/2020 Page 14 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) and (B) the estimated tariff shortfalls for Q4, 2021, Q1- Q3, 2022, set out in the 2022 PSRP Financing Plan, are funded according to G2.4(ii). Stretch target: G2.4(i) achieved, 100 percent of the sum of (A) the actual tariff shortfalls incurred for Q1-Q4 2020 and Q1-Q3, 2021 not yet funded and (B) the estimated tariff shortfalls for Q4, 2021 and Q1-Q3, 2022, set out in the 2022 PSRP Financing Plan, are funded according to G2.4(ii). Date -- -- 07-Oct-2020 -- Comments ►DLI 3 Implementation of approved PIPs is enforced (Process, 135,000,000.00, 0%) 12 Months Period ending 31-Dec-2022 (Cumulative Baseline Actual (Previous) Actual (Current) number) NERC issues semi- annual monitoring reports on each DISCO’s achievement of the outputs set out in its Insufficient regulatory Insufficient regulatory approved PIPs for oversight over DISCOs’ oversight over DISCOs’ Value -- 2022 and, if there performance and performance and are deviations, associated investments. associated investments. undertakes actions in accordance with the Electric Power Sector Reform Act 2004 and applicable regulations. Date -- -- 07-Oct-2020 -- Comments ►DLI 4 Business continuity arrangements are implemented for DISCOs (Process, 30,000,000.00, 0%) 10/27/2020 Page 15 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) 12 Months Period ending 31-Dec-2022 (Cumulative Baseline Actual (Previous) Actual (Current) number) Lack of framework to Lack of framework to define define how interim how interim management of management of DISCOs DISCOs will be established Value -- will be established for -- for DISCOs’ whose DISCOs’ whose licenses licenses are subject to are subject to NERC NERC intervention intervention. Date -- -- 07-Oct-2020 -- Comments ►DLI 5 End-user electricity tariffs are adjusted consistent with the PSRP Financing Plan, including its measures for protection of the poor (Process, 95,000,000.00, 0%) 12 Months Period ending 31-Dec-2022 (Cumulative Baseline Actual (Previous) Actual (Current) number) NERC issues MYTO for each DISCO adjusting end-user electricity tariffs effective in 2022 End-user tariffs do not End user tariffs do not consistent with the Value recover the full revenue -- recover full revenue 2022 PSRP requirement of the sector requirement Financing Plan including its measures for protection of the poor. Date -- -- 07-Oct-2020 -- Comments ►DLI 6 Payment discipline is enforced on DISCOs to reduce non-tariff shortfalls (Process, 110,000,000.00, 0%) 12 Months Period ending 31-Dec-2022 (Cumulative Baseline Actual (Previous) Actual (Current) number) Value DISCOs are being billed for -- DISCOs are being billed At least 90 percent tariff shortfalls and payment for tariff shortfalls and of DISCOs’ discipline is not enforced on payment discipline is not aggregate Q4, 2021 DISCOs for their lack of enforced on DISCOs for and Q1-Q3, 2022 payment to NBET and their lack of payment to Minimum Payment MO/TCN. NBET and MO/TCN. Amount is paid to NBET and to TCN by January 1, 2023; or, if such payments are below 90 percent, there is evidence of either activation of 10/27/2020 Page 16 of 17 The World Bank Implementation Status & Results Report Power Sector Recovery Performance Based Operation (P164001) DISCOs’ payment guarantees, or action by NERC in accordance with the Electric Power Sector Reform Act 2004, by January 1, 2023. Date -- -- 07-Oct-2020 -- Comments ►DLI 7 Financial and operational transparency of DISCOs is improved (Process, 40,000,000.00, 0%) 12 Months Period ending 31-Dec-2022 (Cumulative Baseline Actual (Previous) Actual (Current) number) NERC publishes on its website or through links to DISCOs’ websites: (i) 2021 IFRS Insufficient transparency Insufficient transparency compliant financial about the financial situation about the financial statements of Value -- and operational situation and operational DISCOs; and (ii) key performance of DISCOs performance of DISCOs operational and financial data of Q4 2021 and Q1-Q3 2022 on a quarterly basis, by December 31, 2022. Date -- -- 07-Oct-2020 -- Comments 10/27/2020 Page 17 of 17