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Document of

The World Bank

Report No: ICR00001886

IMPLEMENTATION COMPLETION AND RESULTS REPORT

(IDA-42640 TF-92145)

ON A

CREDIT

IN THE AMOUNT OF SDR 1.00 MILLION

(US$ 1.45 MILLION EQUIVALENT)

TO THE

COMMONWEALTH OF DOMINICA

FOR A

GROWTH AND SOCIAL PROTECTION TECHNICAL ASSITANCE CREDIT

June 28, 2011

Poverty Reduction and Economic Management Department (LCSPR)

Caribbean Country Management Unit (LCC3C)

Latin America and Caribbean Region (LCR)

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CURRENCY EQUIVALENTS

(Exchange Rate Effective March, 2011)

Currency Unit = Eastern Caribbean Dollar

ECD 1.00 = US$ 0.37

US$ 1.00 = ECD 2.70

FISCAL YEAR

July 1 - June 30

ABBREVIATIONS AND ACRONYMS

ASYCU

DA

Automated System for Customs

Documentation and Administration

CARTA

C

Caribbean Regional Technical

Assistance Center

CDB Caribbean Development Bank

CFAA Country Financial Accountability

Assessment

CPA

CPAR

Country Poverty Assessment

Country Procurement Assessment

Report

CG Central Government

DEXIA Dominica Export and Import Agency

DFID

DHTA

Department for International

Development

Dominica Hotel and Tourist

Association

DSS Dominica Social Security

EC Eastern Caribbean

ECCB Eastern Caribbean Central Bank

ECCU

ECSE

Eastern Caribbean Currency Union

Eastern Caribbean Securities Exchange

EU European Union

FAA

FDI

Finance (Administration) Act

Foreign Direct Investment

GDP Gross domestic product

GSPS Growth and Social Protection Strategy

ILO International Labor Organization

IMF

IPA

International Monetary Fund

Investment Promotion Agency

MDGs Millennium Development Goals

MIS Management information system

MoF Ministry of Finance

NDC National Development Corporation

NGO Nongovernmental organization

OECS Organization of Eastern Caribbean

States

PAC Public Accounts Committee

PRGF

PRS

Poverty Reduction and Growth Facility

Poverty Reduction Strategy

PRSP Poverty Reduction Strategy Paper

PSIP

TM

USAID

Public Sector Investment Program

Task Manager

United States Agency for International

Development

Vice President: Pamela Cox

Country Director: Francoise Clottes

Sector Manager: Veronica E. Zavala

Project Team Leader: Kathy Lalazarian

ICR Team Leader Kathy Lalazarian

ICR Main Author David E. Yuravlivker

DOMINICA

GROWTH AND SOCIAL PROTECTION TECHNICAL ASSITANCE CREDIT

CONTENTS

DATA SHEET .............................................................................................................................................. I

B. KEY DATES .................................................................................................................................................. I C. RATINGS SUMMARY...................................................................................................................................... I D. SECTOR AND THEME CODES ........................................................................................................................... II E. BANK STAFF ................................................................................................................................................ II F. RESULTS FRAMEWORK ANALYSIS ..................................................................................................................... II G. RATINGS OF PROJECT PERFORMANCE IN ISRS ................................................................................................... XI H. RESTRUCTURING (IF ANY) ............................................................................................................................. XI I. DISBURSEMENT PROFILE .............................................................................................................................. XII

1. PROJECT CONTEXT, DEVELOPMENT OBJECTIVES AND DESIGN ............................................................. 1

2. KEY FACTORS AFFECTING IMPLEMENTATION AND OUTCOMES ............................................................ 8

3. ASSESSMENT OF OUTCOMES .............................................................................................................. 11

4. ASSESSMENT OF RISK TO DEVELOPMENT OUTCOME ......................................................................... 18

5. ASSESSMENT OF BANK AND BORROWER PERFORMANCE .................................................................. 18

6. LESSONS LEARNED .............................................................................................................................. 20

7. COMMENTS ON ISSUES RAISED BY BORROWER/IMPLEMENTING AGENCIES/PARTNERS .................... 21

ANNEX 1. PROJECT COSTS AND FINANCING ........................................................................................... 23

ANNEX 2. OUTPUTS BY COMPONENT ..................................................................................................... 24

ANNEX 3. DOMINICA CUSTOMS REPORT PROJECT – HIGH LEVEL ACTION PLAN: PROGRESS AS OF JANUARY 2011 ........................................................................................................................ 28

ANNEX 4. BANK LENDING AND IMPLEMENTATION SUPPORT/SUPERVISION PROCESSES ....................... 39

ANNEX 5. SUMMARY OF BORROWER'S ICR AND/OR COMMENTS ON DRAFT ICR .................................. 40

ANNEX 6. COMMENTS OF COFINANCIERS AND OTHER PARTNERS/STAKEHOLDERS ............................... 51

ANNEX 7. LIST OF SUPPORTING DOCUMENTS ........................................................................................ 53

ANNEX 8 – MAP (IBRD MAP 33397) ........................................................................................................ 54

i

DATA SHEET

A. Basic Information

Country: Dominica Project Name:

Growth and Social

Protection Technical

Assistance Credit

Project ID: P094869 L/C/TF Number(s): IDA-42640,TF-92145

ICR Date: 06/28/2011 ICR Type: Core ICR

Lending Instrument: TAL Borrower:

THE

COMMONWEALTH

OF DOMINICA

Original Total

Commitment: XDR 1.0M Disbursed Amount: XDR 1.0M

Revised Amount: XDR 1.0M

Environmental Category: C

Implementing Agencies:

Commonwealth of Dominica

Cofinanciers and Other External Partners:

B. Key Dates

Process Date Process Original Date Revised / Actual

Date(s)

Concept Review: 02/13/2006 Effectiveness: 04/02/2007 04/02/2007

Appraisal: 10/06/2006 Restructuring(s): 04/30/2009

Approval: 02/27/2007 Mid-term Review: 06/30/2008 12/01/2008

Closing: 06/01/2010 12/31/2010

C. Ratings Summary

C.1 Performance Rating by ICR

Outcomes: Moderately Satisfactory

Risk to Development Outcome: Moderate

Bank Performance: Moderately Satisfactory

Borrower Performance: Moderately Satisfactory

C.2 Detailed Ratings of Bank and Borrower Performance (by ICR)

Bank Ratings Borrower Ratings

Quality at Entry: Moderately Satisfactory Government: Moderately Satisfactory

Quality of Supervision: Moderately Satisfactory Implementing

Agency/Agencies: Moderately Satisfactory

ii

Overall Bank

Performance: Moderately Satisfactory

Overall Borrower

Performance: Moderately Satisfactory

C.3 Quality at Entry and Implementation Performance Indicators

Implementation

Performance Indicators

QAG Assessments

(if any) Rating

Potential Problem Project

at any time (Yes/No): No

Quality at Entry

(QEA): None

Problem Project at any

time (Yes/No): No

Quality of

Supervision (QSA): None

DO rating before

Closing/Inactive status: Satisfactory

D. Sector and Theme Codes

Original Actual

Sector Code (as % of total Bank financing)

Central government administration 100 100

Theme Code (as % of total Bank financing)

Administrative and civil service reform 22 22

Public expenditure, financial management and

procurement 11 11

Regulation and competition policy 22 22

Social safety nets 22 22

Trade facilitation and market access 23 23

E. Bank Staff

Positions At ICR At Approval

Vice President: Pamela Cox Pamela Cox

Country Director: Alan G. Carroll Caroline D. Anstey

Sector Manager: Veronica E. Zavala Lombardi Jaime Saavedra Chanduvi

Project Team Leader: Kathy Lalazarian Errol George Graham

ICR Team Leader: Kathy Lalazarian

ICR Primary Author: David E. Yuravlivker

F. Results Framework Analysis

Project Development Objectives (from Project Appraisal Document) The GSPTAP's development objective is to enhance the Government's effectiveness to

deliver public goods and services by strengthening the institutional capacity of key

iii

agencies to facilitate Dominica's private sector competitiveness and productivity and to

provide targeted social assistance to reduce poverty.

Revised Project Development Objectives (as approved by original approving authority)

n/a

(a) PDO Indicator(s)

Indicator Baseline Value

Original Target

Values (from

approval

documents)

Formally

Revised

Target

Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 1 :

Completed human resource audit of ministries and departments of the public

service

Value

quantitative or

Qualitative)

Pace of public sector

reform slowed by limited

capacity in the Reform

Management Unit

Manpower

assessment

completed in the

public service

Audit completed

following wide

consultation.

Staffing plans need

to be approved by

Cabinet.

Date achieved 10/31/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 2 : Reduction in time needed to register property from 40 days to 20 days.

Value

quantitative or

Qualitative)

Property registration time

is about 40 days.

Property

registration time is

20 days.

Registration of land

First title - down to

60-90 days.

Direct transfer -

down to 30 days.

Part of land - down

to 35 days.

Companies have a

separate registry,

which takes 1-2

days.

Date achieved 10/31/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 3 : One stop shop for tourism investors funded, staffed, developed, fully operational

website, and used by investors.

Value

quantitative or

Qualitative)

No one stop shop in

place.

One stop shop for

tourism investors

fully operational.

Website developed

and used by

investors.

Achieved. Service

provided by Invest

Dominica

Authority.

iv


Original Target

Values (from

approval

documents)

Formally

Revised

Target

Values

Actual Value

Achieved at

Completion or

Target Years

Date achieved 10/31/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 4 : Regulatory commission established, funded, staffed and fully functional.

Value

quantitative or

Qualitative)

No regulatory

commission for electricity

in place.

Regulatory

commission

established and

operational.

Regulatory

commission

established and

operational.

Date achieved 10/31/2006 12/31/2010 11/03/2009

Comments

(incl. %

achievement)

New Electricity Act passed. IRC operational and ED selected.

Indicator 5 :

Objective and transparent Beneficiary Identification System (BIS) for selection

of beneficiaries for Public Assistance (PA) and Education Trust Fund (ETF)

developed.

Value

quantitative or

Qualitative)

No systematic criteria for

beneficiary selection.

Beneficiary

Identification

System for

selection of

beneficiaries for

Public Assistance

(PA) and

Education Trust

Fund (ETF)

developed and

fully implemented.

Partially achieved.

Proxy means test

and the BIS were

approved by

Cabinet in January

2011. At this

writing their use

has just started, as

data is being

inputted into the

system.

Date achieved 06/30/2006 12/31/2010 01/01/2011

Comments

(incl. %

achievement)

Indicator 6 : Central beneficiary registry developed, funded, staffed and fully functional.

Value

quantitative or

Qualitative)

No consistent record of

beneficiary.

100% of public

assistance and

Education Trust

Fund beneficiaries

registered in

central registry.

100% achieved.

Date achieved 06/30/2006 12/31/2010 11/03/2009

Comments

(incl. %

achievement)

v


Original Target

Values (from

approval

documents)

Formally

Revised

Target

Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 7 :

Development, dissemination, approval and launch of a time bound, fully-costed

human resource development and succession plans for ministries and

departments within the public service.

Value

quantitative or

Qualitative)

Plans not in existence. Plans developed

and costed.

Partially completed.

Reform

Management Unit

has developed a

methodology for

preparing a

succession plan,

and has identified

key positions where

those plans would

be applied. Cabinet

has to approve the

recommendations.

Date achieved 10/30/2009 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 8 : Improved policy framework and environment for private sector development and

improved social protection

Value

quantitative or

Qualitative)

No policy framework

exists.

Better targeting,

planning and

administration of

social assistance.

Achieved. Invest

Dominica Authority

established in July

2007. Strategy

approved by

Cabinet in

December 2010,

and Action Plan

being implemented.

Date achieved 10/31/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

(b) Intermediate Outcome Indicator(s)


Original Target

Values (from

approval

documents)

Formally

Revised

Target Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 1 : Customs IT upgraded from ASYCUDA 2.7 to ASYCUDA World

Value Customs using ASYCUDA World Achieved. The new

vi


Original Target

Values (from

approval

documents)

Formally

Revised

Target Values

Actual Value

Achieved at

Completion or

Target Years

(quantitative

or Qualitative)

ASYCUDA 2.7 implemented system is fully

operational and is

seen as a major

improvement by

private users.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 2 :

Technology for paperless transactions installed in first year, 30% reduction in use

of paper for import declarations by end of second year, and 80% by end of

project.

Value

(quantitative

or Qualitative)

Use of paper and forms Paperless

transactions

Achieved. Customs

declarations need

just one paper copy

instead of four,

while cargo

manifests are now

an electronic

document rather

than a paper one.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 3 : Reduction in the average time for customs clearance, average reduction is 3-4

days in first year, 2 days in second year, and 1 day in third year.

Value

(quantitative

or Qualitative)

Customs clearance takes

seven days.

Customs clearance

takes one day.

Achieved. Since the

new system was

implemented in

July 2010, this time

has been reduced to

one day.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 4 : Installed and functioning audit management systems

Value

(quantitative

or Qualitative)

Need to update audit

management system

Audit management

system

functioning.

Partially achieved.

Auditor general

office received

IDEA software in

early 2010 but staff

not able to

complete training.

vii


Original Target

Values (from

approval

documents)

Formally

Revised

Target Values

Actual Value

Achieved at

Completion or

Target Years

SMART stream is

operational for

budget process, but

not for audit.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 5 :

During first year, Cabinet sets new procurement threshold and 50% of contracts

awarded through competitive bids, which increases to 7% by the second year,

and 100% in the third year.

Value

(quantitative

or Qualitative)

Need to modernize

procurement regulations

in the public sector.

100% of contracts

awarded through

competitive bids.

Partially achieved.

Currently the

majority of

contracts above

EC$1 million are

awarded by

competitive

bidding. The new

Procurement Act

would make that

compulsory for all

contracts.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 6 : Analysis and planning for National Investment Strategy, strategy completed,

adopted and implemented by Invest Dominica Authority for GOCD.

Value

(quantitative

or Qualitative)

No national investment

strategy

Analysis and

planning for

national

investment

strategy done,

strategy

completed,

adopted and

implemented by

Invest Dominica

Authority by

GOCD.

Strategy approved

by Cabinet in

December 2010,

and Action Plan

being implemented.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

viii


Original Target

Values (from

approval

documents)

Formally

Revised

Target Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 7 : Number of days to process investment reduced to 30 days in the first year, to 25

days in the second year, and to 20 days by the end of the project.

Value

(quantitative

or Qualitative)

Number of days to

process investment is

more than 30 days.

Number of days to

process investment

reduced to 20 days

by the end of the

project.

Achieved.

Proposals of up to

EC$2 million are

reviewed by a sub-

committee of

cabinet within two

weeks, and

proposals above

that amount are

reviewed by the full

cabinet within three

weeks.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 8 : Draft alternative energy legislation developed, stakeholder discussion conducted,

and submitted to Parliament for approval.

Value

(quantitative

or Qualitative)

Lack of alternative energy

legislation.

Draft alternative

energy legislation

developed,

stakeholder

discussion

conducted, and

submitted to

Parliament for

approval.

Partially achieved.

Draft has

undergone various

revisions, currently

draft is being

reviewed at the

Attorney General's

Chambers for

onward submission

to Parliament.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 9 : Methods in place for dealing with unexpected tariff and other regulatory issues.

Value

(quantitative

or Qualitative)

Lack of methodology for

dealing with unexpected

tarriff and other

regulatory issues.

Methods in place

for dealing with

unexpected tariff

and other

unexpected

regulatory issues.

Achieved. The

policies

implemented by the

IRC include those

methods and are

posted in the web.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

ix


Original Target

Values (from

approval

documents)

Formally

Revised

Target Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 10 : BIS system being used to select beneficiaries for Public Assistance Program

(PA) and Education Trust Fund (ETF) Program.

Value

(quantitative

or Qualitative)

No BIS system is being

used to select

beneficiaries for PA and

ETF.

BIS system being

used to select

beneficiaries for

PA and for ETF

program

Partially achieved.

Proxy means test

and the BIS were

approved by

Cabinet in January

2011. Their use has

just started as data

is being input into

the system.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 11 : Policies and procedures related to PA and ETF documented and relevant staff

trained.

Value

(quantitative

or Qualitative)

Lack of policies and

procedures related to PA

and ETF documented and

relevant staff trained.

Adapt new

policies and

procedures.

Monitoring plan

implemented.

Policies and

procedures

established and

documented in

operational manuals

for PA, ETF, and

SFP and staff was

trained.

Date achieved 06/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 12 : Reform management unit planning, designing and implementation plans.

Value

(quantitative

or Qualitative)

Pace of public reform

slowed by limited

capacity in Public Sector

Reform Unit (PSRU)

Begin

implementation of

modernization

plans

RMU has

developed a

methodology for

preparing the

succession plans,

and has identified

key positions where

those plans will be

applied. They have

not been fully

costed.

Date achieved 06/30/2010 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

x


Original Target

Values (from

approval

documents)

Formally

Revised

Target Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 13 : Establishment of a semi-autonomous Registry

Value

(quantitative

or Qualitative)

40 days for registration of

property.

Registration of

property reduced

to 20 days.

Registration of

land:

First title - down to

60-90 days.

Direct transfer -

down to 30 days.

Part of land - down

to 35 days.

Companies have a

separate registry,

which takes 1-2

days.

Date achieved 11/11/2010 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 14 : Public contracts above threshold advertised and awarded through transparent and

competitive bids

Value

(quantitative

or Qualitative)

Out-dated regulations

Procurement

procedural manual

developed, and

100% of contracts

above threshold

advertised/awarde

d through

competitive bids.

Partially achieved.

The majority of

contracts above

EC$1 million are

awarded by

competitive

bidding. The new

Procurement Act

would make that

compulsory for all

contracts.

Date achieved 11/11/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 15 : Public information campaign to inform the public about new approaches to the

delivery of social safety net programs implemented.

Value

(quantitative

or Qualitative)

No systematic public

information.

Implementation of

campaign

continued.

Partially achieved.

The material for the

information

campaign has been

prepared, and some

aspects successfully

undertaken. More

PR to be

undertaken when

xi


Original Target

Values (from

approval

documents)

Formally

Revised

Target Values

Actual Value

Achieved at

Completion or

Target Years

the system is fully

utilized.

Date achieved 10/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

Indicator 16 : A program database to track beneficiaries and expenditures for the PA, ETF and

the School Feeding Program in the Ministry of Education is in use.

Value

(quantitative

or Qualitative)

No database for ETF, SFP

and PA.

Program databases

in place.

Partially achieved.

MIS for ETF, PA

and SFP was

launched.

Date achieved 10/30/2006 12/31/2010 12/31/2010

Comments

(incl. %

achievement)

G. Ratings of Project Performance in ISRs

No. Date ISR

Archived DO IP

Actual

Disbursements

(USD millions)

1 07/04/2007 Satisfactory Satisfactory 0.00







H. Restructuring (if any)

Restructuring

Date(s)

Board

Approved

PDO Change

ISR Ratings at

Restructuring

Amount

Disbursed at

Restructuring

in USD

millions

Reason for Restructuring &

Key Changes Made DO IP

04/30/2009 N S S 0.65

A Third Order Restructuring

was conducted to improve the

original outcome indicators that

were somewhat vaguely

delineated in the Supplemental

xii

Restructuring

Date(s)

Board

Approved

PDO Change

ISR Ratings at

Restructuring

Amount

Disbursed at

Restructuring

in USD

millions

Reason for Restructuring &

Key Changes Made DO IP

Letter of the Credit Agreement

and the PAD.

I. Disbursement Profile

1

1. PROJECT CONTEXT, DEVELOPMENT OBJECTIVES AND DESIGN

1.1 Context at Appraisal

Dominica went through an economic crisis in 2001-2002, when output contracted by

about 10 percent and poverty levels rose sharply. The Country Poverty Assessment

(CPA) conducted in 2002 found that 39 percent of the population was poor, while 15

percent were indigent, among the highest percentages in the Caribbean.

In mid-2003, the government adopted a two-stage adjustment strategy to foster

growth and ensure debt sustainability. The first stage focused on achieving

macroeconomic stability through fiscal adjustment and collaborative debt restructuring.

This effort was supported by an IMF Poverty Reduction and Growth Facility (PRGF) and

the Bank’s Economic Recovery Support Operation (ERSO) in 2004. The program was

largely successful, as the overall central government balance was reduced from nearly 11

percent of GDP in 2000/01 to 0.9 percent of GDP in 2004, and public sector debt fell

from a peak of 130.8 percent of GDP in 2003 to 116.1 percent of GDP in 2004, following

a restructuring of Dominica’s official debt under the Paris Club framework.

The second stage of the adjustment strategy focused on key structural reforms to

establish the basis for private sector-led sustainable growth and poverty reduction.

This stage was part of the Government’s Medium-term Growth and Social Protection

Strategy (GSPS) for 2005/06-2009/10. The GSPS had four pillars: (i) Fiscal policy and

administrative reforms; (ii) Enhancing the investment climate for private enterprise

development; (iii) Sectoral strategies for growth; and (iv) poverty reduction and social

protection

The GSPS focused on invigorating private sector led growth and improving key

social services, including health and education to build human capital. It gave

special attention to vulnerable groups such as youth, which had unemployment rates of

about 40 percent. Thus, employment generation was essential for poverty reduction. That

called for increasing international competitiveness, improving export performance and

enhancing the attractiveness of the economy to investors. The latter required reducing

firms’ costs, improving the reliability of transportation, lowering the cost of energy and

increasing the productivity of the labor force. The Bank’s analytical work1 and work by

other donors helped to fine tune the Government’s strategy and action plans.

The GSPS proposed a number of strategic policy actions to facilitate private sector

development and improve the environment for private enterprise, including (i)

accelerating implementation of its comprehensive Public Sector Reform Strategy (PSRS)

aimed at improving effectiveness of service delivery, enhancing accountability, and

1 “Towards a New Agenda for Growth”, April 2005; Dominica: OECS Fiscal Issues “Policies to Achieve

Fiscal Sustainability and Improve Efficiency and Equity of Public Expenditures. June 2005.

2

streamlining regulations and procedures that may hinder private sector activities; (ii)

improving the judicial and land administration systems; (iii) implementing

recommendations emanating from a comprehensive analysis of Dominica’s investment

climate; and (iv) implementing policy and regulatory measures aimed at lowering costs of

transport, electricity, water and telecommunication.

Consequently, the Growth and Social Protection Technical Assistance Project

(GSPTAP) focused on reforms in four strategic areas: (i) making the public sector

more efficient and effective; (ii) improving the investment climate; (iii) reforming the

regulatory framework for the energy sector; and (iv) improving social protection.

The GSPS had also become the focal point for donors’ support to Dominica. In

particular, the European Union (EU) allocated approximately US$12 million in grants for

budgetary support to Dominica, and decided to align and harmonize its tranche

disbursement conditions for this budgetary support with the Results Framework agreed

between the Government and the Bank for the GSPTAP. In addition, the EU provided

another US$580,000 in a grant for parallel co-financing of the technical assistance

operation (through a Bank administered Trust Fund).

1.2 Original Project Development Objectives (PDO) and Key Indicators.

The Project Development Objective (PDO) of the GSPTAP was to enhance the

Government's effectiveness to deliver public goods and services by strengthening the

institutional capacity of key agencies to facilitate Dominica's private sector

competitiveness and productivity and to provide targeted social assistance to reduce

poverty.

The Project Outcome Indicators listed in the Project Appraisal Document (PAD) were:

(i) Increased capacity of the public sector to implement reforms;

(ii) Better regulatory framework governing the electricity sector;

(iii) Greater transparency and efficiency in public procurement;

(iv) Reduction in the processing time at customs; and

(v) Better targeting, planning and administration of social assistance programs.

1.3 Revised PDO (as approved by original approving authority) and Key Indicators,

and reasons/justification

The PDO and Key Indicators were not formally revised. However, a Third Ordering

Restructuring designed to clarify the PDO and sharpen the indicators was approved by

Management and agreed with Government in May 2009. Both original and revised

indicators are described in Annex 2.

3

1.4 Main Beneficiaries

The PAD states that “the project will benefit Dominicans through: (i) enhanced

private sector competitiveness and productivity and improvement in employment

prospects resulting from private sector-led growth; (ii) improvement in the quality of

public goods and services offered by a more efficient public sector; (iii) more competitive

pricing of electricity as a result of a better regulated electricity sector; and (iv) better

targeting and efficient delivery of social protection programs. In particular, two groups

that were expected to benefit from the project were brokers and importers, and then

existing and potential beneficiaries of social protection programs.

1.5 Original Components

The project was comprised of the following components:

Component 1: Making the public sector more efficient and effective (48% of total

project costs - US$1,240,000)

This component provided technical assistance to the Government to implement key

elements of its public sector modernization strategy focused on streamlining the public

sector to increase the efficiency of service delivery while lowering costs. It aimed to

assist in strengthening control over public finances and increasing the transparency and

efficiency of public procurement. The sub-components included:

1.1 Strengthening of the Reform Management Unit (RMU). The RMU planned and

implemented the public sector reform program. The activities that were financed included

manpower needs assessments in targeted Ministries and Departments and mapping of the

change management process to guide their re-organization/restructuring. This sub-

component also supported the improvement of the technological capability of the unit.

1.2 Strengthening of Customs. Activities supported included: (i) implementation of a

detailed action plan for the Customs Modernization Program including training of

Custom’s staff; (ii) implementation of a risk management system for customs

inspections; and (iii) modernization and automation of ports and customs information and

payments systems, including the upgrade of ASYCUDA - the customs automated data

system.

1.3 Modernization of Registry. This sub-component financed the modernization of the

Registry through the full-scale computerization of Companies and Trade Marks section

of the Registry to allow for on-line business registrations and searches. The improvement

of the computer technology within the land titles section of the Registry was also

expected to reduce the turn-around time for registering properties.

4

1.4 Strengthening of Fiduciary Capacity, including: (i) strengthening financial

management capacity within the Accountant General’s and Auditor General’s

departments with the introduction of various software programs, Cognos and Smart

Stream being utilized to account for GoCD expenditures and provide the necessary

reporting mechanisms in that regard; (ii) implementation of a Procurement Action Plan to

modernize the public sector procurement system; and (iii) taking measures to integrate,

where possible, into the pooled procurement initiative being piloted between Grenada and

St. Vincent and the Grenadines under the ongoing Grenada Public Sector Modernization

project.

Component 2: Improving the investment climate (10 percent of total project cost -

US$252,000)

This component aimed at strengthening the institutional and regulatory environment for

attracting investment to Dominica. Specifically, the activities under this component

sought to address deficiencies in the system of investment promotion as carried out by the

Dominica National Development Corporation (NDC), and prepare a National Investment

Strategy and an Action Plan to build a well-functioning investment promotion agency.

2.1 Development of a National Investment Strategy, to focus the limited public resources

in areas which support private sector development and where attracting foreign direct

investment (FDI) could contribute to the national objective of increasing private sector

led growth for poverty reduction.

2.2 Development and Implementation of a National Action Plan, including the

restructuring of the NDC charged with the mandate to implement the National Investment

Strategy. The restructuring of the NDC involved a split into two separate agencies; (i) an

investment promotion agency; and (ii) a Tourism Authority. To support implementation

of the Action Plan, this sub-component financed training of staff in relevant activities

(market intelligence, direct contacts with investors, services to investors, and after-care of

investors) as well as upgrading office and technical equipment, publication of

promotional material, development of an interactive website which will serve to promote

Dominica’s products and services to the wider regional and international frontiers and a

special software for access to foreign investors’ databases as well as subscription to

relevant international business information databases and services.

Component 3: Reforming the regulatory framework for the energy sector (27 percent to

total project cost - US$695,000).

The objective of this component was to regulate the energy sector, including the

production and distribution of electricity to improve competitiveness. The specific sub-

components were:

3.1 Establishment of National Regulatory Commission. This support was to follow

passage of the Electricity Act, which would provide the legal basis for the establishment

and operations of an independent regulatory commission for the electricity sector. This

5

sub-component financed the activities of the regulatory commission for the first 12

months covering office operational costs, staffing, training and technical assistance. The

expectation was that after the first year, the operations of the regulatory commission

would be fully financed from license fees, other fees and levies.

This component also involved the employment of a number of persons within the IRC

who provided important support throughout the implementation process.

An interactive website was also developed and launched for the IRC. This website

assisted in promoting to the public IRC products and services and also various policies

and guidelines under which the Institution operates.

It also envisaged that in the medium-to-longer term Dominica will benefit from the

regional electricity regulatory initiative, possibly resulting in further reduction of the

national cost of regulation.

3.2 Drafting of Alternative Energy Legislation, to provide the legal and regulatory

framework for the development of alternative energy technologies, including hydropower,

wind and geothermal energy.

Component 4: Improving social protection (9 percent of total project costs -

US$232,000)

The objective of this component was to strengthen the Government’s capacity to better

target, plan and administer social assistance programs for poor and vulnerable persons.

There were three sub-components as follows:

4.1 Beneficiary Selection System Modernization, including: (i) design and

implementation of a transparent and objective targeting mechanism for selection of

beneficiaries; (ii) development of a central beneficiary registry; and (iii) application of

information from recently developed poverty maps to better target community based,

school-feeding and short-term employment programs.

4.2 Institution Strengthening. Improving the administrative capacity to deliver social

assistance through: (i) development of program databases to track beneficiaries and

expenditures for the Education Trust Fund (ETF) and the School Feeding Program (SFP)

in the Ministry of Education and further work on database development for the Public

Assistance Program (PA) at the Ministry of Community Development; (ii) documentation

of policies and procedures for the PA and ETF; and (iii) establishing linkages and access

to the different databases to assist in policy decision making at the sector level.

4.3 Public Information Campaign. Design and implementation of a public information

campaign to inform the public about new approaches to the delivery of social safety net

programs (including the new approaches to targeting and registration of beneficiaries)

and about other social protection reforms.

6

Component 5: Project Management (7 percent of total project costs - US$181,000).

This component financed the operation of the small Project Coordinating Unit (PCU)

integrated within the Establishment, Personnel and Training Department and employing

permanent government staff and where necessary contract staff. More specifically, this

component financed the project coordinator, the cost of the annual project audits,

computers for the PCU as well as the costs of staff assigned to the project.

1.6 Revised Components

Components were not revised during the life of the project.

1.7 Other significant changes

The Outcome Indicators of the project were modified following the Mid-term

Review in December 2008. As described in the Request for Approval of the

Restructuring, dated May 1, 2009, “the purpose of this modification was to improve the

original outcome indicators that were somewhat vaguely delineated in the Supplemental

Letter of the Credit Agreement and the PAD”. This modification, however, was largely

a reorganization of what was originally in the PAD (see Implementation of M&E below).

Since neither the development objectives or outcome targets, nor the number and content

of components/sub-components nor the component costs, financing plan or the allocation

of credit proceeds were changed, it was deemed to be a Third Order Restructuring 2, not

requiring approval by the Board of Directors and thereby not a formal restructuring.

In May 2010, upon request by the Government dated January 29, 2010, the closing

date of the project was extended from June 1, 2010, to December 31, 2010. Shortly

thereafter, the closing date of the EU Co-financing Trust Fund and Grant for the

GSPTAP (TF092145) was extended retroactively and for a second time to August 31,

20103, and the Administrative Agreement was extended from June 20, 2010 to December

31, 2010.

The funding allocations among disbursement categories were modified several times. In September 2008, the percentages of expenditures to be financed in categories 1, 2 and

3 were increased from 69%, 40% and 59% respectively to 100% to allow full usage of

the existing IDA allocation for all three categories (the percentages in categories 4 and 5

were originally 100%, so all categories became 100% financed).

At the same time, proceeds across categories were reallocated, in response to the

Government’s request dated August 8, 2008. The reasons for that reallocation were: (i)

2 As per the guidelines governing the restructuring of investment projects at that time, which were

approved by the Board of Directors on July 1, 2006.

3 The first extension from December 31, 2009 to February 28, 2010, was granted in December 2009.

7

changes in the procurement plan to use one consulting firm, the United Nations

Conference on Trade and Development (UNCTAD) to implement all activities related to

customs reform; and (ii) additional resources had been obtained from other sources such

as the EU budget support contribution. As a result, Categories (1) Goods and (3)

Training were reduced to allow an increase in Category (2) Consultant Services (Table 1).

In May 2010, the proceeds across disbursement categories were reallocated again (Table 1), to reflect what was happening on the ground. This reallocation allowed to pay

for the MIS consultancy which was above the budget allocated for this component, the

software which was developed for Private lands, the LAN for the Customs department,

and the drafting of legislation for alternative energy. The de-facto final allocation was

somewhat different, since the cost of various components exceeded their allocation for

reasons described below. Those extra costs were financed with savings in other

components and exchange rate gains.

Table 1: Amount of IDA Financing Allocated (in SDR)

Category Original

Allocation

September

2008

May 2010 Actual

Expenditures

(preliminary)

(1) Goods for the Project

with the exception of Parts

2.2.2, 3.1 and 5(c) of the

Project

197,000

78,000

18,000

26,580

(2) Consultant services

for the Project with the

exception of Parts 2.2.2,

3.1 and 5(c) of the Project

230,000

414,000

621,680

603,545

(3) Training for the Project

with the exception of Parts

2.2.2, 3.1 and 5 of the

Project

103,000

38,000

20,000

19,055

(4) Goods, consultant

services and training for

Part 2.2.2 of the Project

120,000

120,000

73,000

68,879

(5) Goods, consultant


Part 3.1 of the Project

350,000

350,000

267,320

267,154

TOTAL AMOUNT 1,000,000 1,000,000 1,000,000 985,213

8

2. KEY FACTORS AFFECTING IMPLEMENTATION AND OUTCOMES

2.1 Project Preparation, Design and Quality at Entry

The Project Development Objective (PDO) as well as the 5 original Project Outcome

Indicators covered most aspects of the operation, but they were general in nature.

Further, this operation could only partly be held accountable for meeting the PDO, since

other donors were actively pursuing the same general objective. Nevertheless, the PDO

and Project components addressed key priorities of the Government’s Growth and Social

Protection Strategy and the Poverty Reduction Strategy. The Project supported the

Government’s efforts to carry out reforms prescribed by those Strategies.

The scope of the GSPTAP, while responsive to the client demands, was overly broad

thus complicating the management and supervision of the project. That may be

difficult to avoid when working with a small country and preparing the one and only

operation in several years. For example, Component 2 – improving the investment

climate, achieved substantial results, but this area was also being supported by other

donors. In that respect, however, it should be recognized that at early stages of

preparation, interventions in labor market reform as well as involvement in the

agricultural sector were deliberately excluded from the operation, in spite of the fact that

the latter was an area which the authorities wanted included in the operation, reflecting

that a degree of selectivity was exercised by the team while attempting to remain

responsive to client demand. (Minutes of the Concept Note Review Meeting, March 3,

2006).

The GSPTAP furthered the two pillars of the FY06-09 Country Assistance Strategy

(CAS) for the OECS sub-region, approved by the Executive Board in September 2005:

(i) stimulating growth and improving competitiveness; and (ii) reducing vulnerability by

promoting greater social inclusion. Elements of the GSPTAP, however, could be

perceived as contradictory to a guiding principle of the CAS as the Project supported

establishment of a national regulatory commission (IRC) for electricity in Dominica,

while the CAS called for regional integration and coordination efforts in that area. It

should be noted, however, that the Government requested the inclusion of this component

within the framework of its agreement with the IMF, and that establishment of the IRC

was seen as a precursor to a regional regulatory authority.

The PAD points out that design of the GSPTAP drew from lessons learned from

previous operations in Dominica and elsewhere in the Caribbean. In particular,

implementation was managed by the Project Coordinating Unit who worked in close

collaboration with the Reform Management Unit which fell under the auspices of the

Personnel Services and Training Department, thereby building institutional capacity and

improving the likelihood of sustainability beyond the life of the Project. Also, the

management and monitoring of implementation by a high level Steering Committee and

the appointment of champions to head working groups for each component drew from

lessons from past experience. In practice, the effectiveness of those arrangements varied

across components. At the same time, the stated intention of addressing customs reform

9

and restructuring of the Registry to show early visible results to build ownership of the

Program was not met because the time needed to implement those reforms was

underestimated. That suggests that the design of the project did not take fully into

account the tight capacity constraints in the country.

Risk assessment in the PAD was appropriate. The overall risk was rated as moderate,

ranging from high for exogenous shocks and delay in support from donor partners, to low

for the loss of political support. Most aspects were covered, and the mitigation measures

were straightforward. In addition, by engaging the EU in parallel financing (which

increased the size of the project by almost 40%), the Project leveraged available donor

grant financing, which was one of the mechanisms proposed in the CAS.

2.2 Implementation

The Project was off to a slow start. It took some time to identify and recruit the project

coordinator in Dominica, and there was a change of Task Manager (TM) at Headquarters

at an early stage of implementation and then again after restructuring. The Trust Fund

agreement with the EU was signed over one year after the Credit became effective, and it

required supplemental coordination efforts by both the Government and the Bank. For

example, the EU monitored progress based on Bank supervision missions, but late in the

life of the Project, the EU requested a different verification method relating to the private

land registry indicator.

The Project spread over a wide set of issues, while implementation capacity within

government was fairly limited. Thus, several elements of the program which appear

not to have been a top priority for the government, such as drafting alternative energy

legislation, were pushed back and were not completed by the closing date. Others, such

as procurement legislation, underwent various rounds of lengthy consultations, which

were not completed either. Implementation took longer than planned also because of the

length of time required for Cabinet and/or Parliamentary approval.

In addition, there were delays in procurement and contracting of consultants for

various components of the Project. In some cases, because of the small size of the

local market, it was not possible to obtain the minimum number of quotes required by

Bank procedures. Also, apparent misunderstandings among all involved led to protracted

negotiations with UNCTAD which delayed customs reform. On the other hand, once it

was launched, the reform of customs expanded and became a comprehensive institutional

change which could have far reaching benefits for international trade and economic

activity as a whole (see 3.2 below). Also, government officials pointed out that Bank

staff were responsive to their concerns and requests, and tried to address them

expeditiously.

As mentioned above, at the Mid-term Review in late 2008, the Outcome Indicators

were reorganized and rephrased in order to facilitate monitoring and supervision.

Also, as Table 1 shows, the allocation of proceeds among disbursement categories

changed dramatically over the life of the project. The latter resulted in part from

10

increases in costs, due to the long time period between their estimation and the actual

spending, and to the introduction of the new 15% VAT in 2006.

Disbursement lags led to questions in internal discussions and memoranda on

whether the Satisfactory rating of the project was justified. Eventually,

disbursements picked up, but initial delays led to the extension of the closing date of the

project by 6 months to finalize activities. Nevertheless, several outcome indicators were

only partially achieved or not achieved by the revised date (Annex 2).

All in all, the 370 document entries in IRIS testify to the huge costs to the Bank of

preparing and supervising the GSPTAP. Government officials told the ICR mission

that it also required a huge effort on their side, and that in the future they would hesitate

to engage in a new project if it is for less than US$5 million. Since IDA allocations to

small countries are relatively small, the challenge for the Bank is to prepare fewer, larger

operations that are relatively simple and straightforward in design, which address a

reduced number of key priorities and leverage resources from other donors. Hopefully,

this will reduce the cost of management and supervision.

2.3 Monitoring and Evaluation (M&E) Design, Implementation and Utilization

M&E design. The design of the Results Framework was cumbersome. The PDO

was one long general sentence that covered everything. The Outcome Indicators were

general and non-measurable (e.g., “increased capacity of the public sector to implement

reforms” or “greater transparency and efficiency in public procurement”). Several

Intermediate Outcome indicators were also very general (e.g., “Reform Management Unit

planning, designing and implementing modernization plans”, or “Reduction in the used

of paper based customs declarations”). Only at the level of Arrangements for Results

Monitoring, which specified target values for years 1, 2 and 3 of the Project life, there

were numerical values that could be monitored. Then, however, the final target values

for the component of Social Protection asked for 100% compliance in three social

protection indicators, which was not realistic.

Implementation. In order to address the problems embedded in the Results

Framework, the team clarified the PDO and made the Outcome Indicators more

specific at the Mid-term Review. In fact, however, that was largely done by bringing

forward what was originally spelled out in the Arrangements for Results Monitoring into

the Results Framework. For example, “Reduction in the processing time at customs” was

replaced by “Reduction in the average time for customs clearance from seven days to one

day”, but the latter was already defined in the table of Intermediate Outcome Indicators

attached to the original Supplemental Letter and the PAD. As part of the restructuring,

the Outcome Indicator requiring the establishment of a “self-financed semi-autonomous”

agency for registry was taken out, after the authorities argued that it was not agreed with

them nor included in the Credit Agreement.

Utilization. Restructuring of the Results Framework helped in monitoring progress

of several outcome indicators. Although it did not eliminate all problems (such as the

11

requirement for 100% compliance in social protection indicators), it was incorporated

into the Implementation Status and Results Reports (ISRs). However, since the new

Results Framework drew from the table of Intermediate Indicators, several duplications

emerged. Moreover, the original Results Framework still needed to be monitored. As a

result, supervision missions and the ICR had a hard time identifying which outcome

indicators needed to be monitored to assess progress in the Program.

2.4 Safeguard and Fiduciary Compliance

The Project triggered none of the Bank’s Environmental and Social Safeguard Policies.

In late 2009, financial management and procurement were downgraded to

Marginally Satisfactory due to delays in procurement processes and submission of the

audit report. Those problems were resolved shortly thereafter.

A procurement supervision mission visited Dominica three months after the closing

date, and found no major issue regarding procurement. The mission concluded that

procurement under the project had been carried out, in general, in compliance with

arrangements agreed in the project financing agreement. This was explained by the fact

that about 70% of contracts awarded were subject to Bank prior review. In addition to a

close follow-up, training in the area of Bank procurement procedures was provided to the

project team and to technical implementing agencies’ staff at a very early stage.

However, there were a number of delays that were attributed to: (i) the small size of the

economy limiting the number of bidders; (ii) the fact that coordination and procurement

functions were the responsibility of one person; and (iii) the departure of the first Project

Coordinator who attended the Bank procurement training. In addition, the project would

have benefitted from an early preparation and adoption of the operations manual and

procurement plan, as well as clear Terms of Reference for implementation.

2.5 Post-completion Operation/Next Phase

The integration of the PCU in the Reform Management Unit at the Ministry of

Finance is expected to help in completing the reforms which had not been finalized by

the closing date. Longer term sustainability, however, depends on continuous support by

the political level.

No follow up operation is considered at the moment.

3. ASSESSMENT OF OUTCOMES

3.1 Relevance of Objectives, Design and Implementation

The objectives of the GSPTAP were and remain relevant for Dominica’s social and

economic development. If anything, the relevance of these objectives is accentuated by

the global financial crisis, which makes even more compelling for the country to achieve

higher levels of efficiency and international competitiveness.

12

As it closed, the relevance of the Design and Implementation of the GSPTAP is

mixed. In retrospect, the choice of a Technical Assistance operation over a DPL was

warranted, both because of the small size of the operation as well as the need for capacity

building in Government and public agencies. However, trying to be responsive to the

Government’s priorities, the Project scope was too wide, taxing implementation capacity

in the country. For example, given support by other donors for improving the investment

climate for the private sector, it’s hard to assess what was the specific impact of the

GSPTAP in this area. Also, while the creation of the Independent Regulatory

Commission (IRC) was envisioned as a precursor to a regional regulatory authority which

is more cost efficient, its success in improving the regulatory environment in the

electricity sector reduced interest within Dominica towards the regional approach to

energy regulation, which was highlighted in the CAS and is now being pursued by a new

Bank operation.

3.2 Achievement of Project Development Objectives

Despite delays and challenges faced during implementation, the operation made a

substantial contribution to improving the environment for private sector activity in

Dominica and set the basis for a more efficient system of social protection.

Commitment by the authorities and a close follow up by the Bank helped overcome the

slow start, delays in contracting of consultants, limited capacity of implementation, and

protracted approval processes by Cabinet and Parliament.

The project had four components: (i) Making the public sector more efficient and

effective; (ii) Improving the investment climate; (iii) Reforming the regulatory

framework for the energy sector; and (iv) Improving social protection. An assessment of

each of the components follows below:

Component 1- Making the public sector more efficient and effective: Moderately

Satisfactory. This component provided technical assistance to the Government to

implement key elements of its public sector modernization strategy focused on

streamlining the public sector to increase the efficiency of service delivery while

lowering costs. More specifically, it supported activities to improve human resources

management, improve and increase the transparency of auditing, modernize procurement,

restructure the Registry, and reform customs.

After wide consultation, a Human Resources Audit of Ministries and Departments

of the Public Service was completed. The audit included a satisfaction survey and a

review of personnel files of all established positions, followed by consultations with the

unions. On the succession plans for Ministries and Departments, the Reform

Management Unit (RMU)/Establishment, Personnel and Training Department took an

alternative approach in that rather than developing and launching time bound, fully

costed succession action plans, it developed a methodology (Tool Kit) for preparing

succession plans when required, and it identified key positions where those plans would

be applied. Due to the Parliamentary elections at end 2009, this activity was put on hold

13

until after the new authorities took office. The final report was completed in October

2010, and Cabinet gave approval of the recommendations and action plan in April, 2011.

At the Auditor General office, the new auditing management systems were not fully

operational by the closing date. The office got the IDEA software in early 2010, but

staff was not able to complete training. The SMART Stream system was used for the

budget process, but it was not operational yet for auditing. Regarding the new

procurement legislation, consultations with key stakeholders initially scheduled to be

completed by March 2010 were still ongoing one year later, and the new legislation

prepared under the project was not timely finalized as agreed in the TORs discussed with

the Bank. This was due to the extended consultation process which was required and

corresponding delays in the drafting process. However, the procurement legislation is on

the agenda for the next sitting of Parliament scheduled for June 29, 2011. Among other

things, the new legislation would ensure that all contracts above EC$1 million are

awarded by competitive bidding. As of March 2011, most but not all contracts were

subject to competitive bidding, as per the matrix of Outcome Indicators.

Reform of the Registry is well under way, but not as spelled out in the original

Results Framework. As mentioned above, when the Framework was restructured after

the Mid-term Review, the notion of the Registry being “semi-autonomous” was taken

out. The Registry is part of the Government financial system and as such, it cannot be

“self financing” either, as all its revenues go to the Treasury and it is financed by the

budget. As it turns out, however, its revenues are substantial and could finance its

operations easily. The land registry is fully computerized, and the time it takes to register

property was reduced: at the time of the ICR mission, First Title registration was taking

60-90 days, compared to several years before the reform; Part of Land registration was

taking about 35 days, down from 3-6 months; and Direct Transfer was taking about 30

days, compared to 3 months before the reform. There is now a separate Registry for

companies, which also deals with patents and intellectual property. Companies can be

registered in one day. While newborn children are registered at the hospital, the Registry

in the Birth and Death section is not fully computerized. A business proposal for a

Secured Civil Registry and Certificate Issuing System has been approved by Cabinet in

June, 2011.

The reform of Customs had a slow start, but it achieved the targets of the Project,

and is already showing tangible results on the ground.4 Firstly, the upgrade from

ASYCUDA 2.7 to ASYCUDA World (AW) was completed and is fully operational.

That reform was fully endorsed by the President of the private brokers association, who

told the ICR mission that transactions costs of dealing with customs have been reduced

significantly, and thus doing business in the country became more profitable and

predictable. Further, the AW is user friendly and web based, and thus available 24/7.

Secondly, the process of achieving a paperless environment for customs transactions was

4 The slow start was due to delays on contracting with UNCTAD as well as in the procurement of

equipment. In addition, the new Customs Act No. 20-2010 became effective only on December 1, 2010.

14

well under way. Under the new system, the cargo manifest is an electronic document

fully integrated into the commercial declaration, which Customs receives electronically

even before cargo arrives to port. Hence, the electronic manifest has replaced completely

the outdated paper-based manifest (100 percent of reduction). In the case of paper

declarations, users need only one copy instead of four (75 percent of reduction). Thirdly,

the last target was virtually achieved, as the time for the clearance of goods was reduced

from 8.65 days in July 2010 when the new system was launched, to just over one day

(1.42 days on average in the last quarter of 2010, and 1.29 days on average in the first

quarter of 2011).5

Component 2 - Improving the Investment Climate: Satisfactory. This component

aimed at strengthening the institutional and regulatory environment for attracting

investment into Dominica. Specifically, the activities under this component sought to

address deficiencies in the existing system of investment promotion as carried out by the

Invest Dominica Authority (IDA) and prepare a National Investment Strategy and an

Action Plan to build a well-functioning investment promotion agency.

The objectives of this component were achieved, although not necessarily as a direct

outcome of the GSPTA. Other donors were active in this areas as well. In particular,

the Invest Dominica Authority was established in July 2007 under another project, and

analytical work on improving the environment for private investment was financed by

several donors. Preparation of the National Investment Strategy, however, was supported

by the GSPTAP, and the Strategy was approved by Cabinet in November 2010. The

Invest Dominica Authority started to implement the Action Plan shortly thereafter.

The Invest Dominica Authority has two units: (i) investment promotion; and (ii)

facilitation of services to investors. The second unit operates the one-stop-shop for

investors, which is now operational. In addition, the number of days to process

investment applications has been gradually reduced: proposals of up to EC$2 million are

reviewed by a sub-committee of Cabinet within 2 weeks, while proposals above that

amount are reviewed by Cabinet within 3 weeks.

Component 3 - Reforming the regulatory framework for the energy sector:

Moderately Satisfactory. The objective of this component was to regulate the energy

sector including the production and distribution of electricity to improve competitiveness.

In particular, it supported establishment of a national Regulatory Commission, which

should be funded, staffed and fully functional; and drafting alternative energy legislation

and submitting it to Parliament for approval. The rationale behind this component was

that electricity tariffs in Dominica were among the highest in the Caribbean6 and they

undermined competitiveness. During preparation, there was discussion on the

5 The CATT report for Dominica of December 2010, indicator 114, shows that more than 50% of the

declarations took more than 24 hours to be released because it refers to the whole year 2010.

6 Electricity tariffs are high largely because a small population is spread over a relatively large and rugged

terrain, coverage is 97 percent, and due to high fuel costs.

15

establishment of a regional regulatory commission, which was viewed as more cost

effective. The Government, however, insisted on a national commission, as per its

Growth and Social Protection Strategy Paper (April 2006).

The Independent Regulatory Commission (IRC) was established in late 2007 and

started to operate in July 2008 when its Executive Director was hired. The GSPTAP

financed its activities in the first year (several consultants were extended for another 3

months), but now it is being funded by Government. The guidelines of IRC policies are

in the web, and those include methods for dealing with unexpected tariff and other

regulatory issues. Authorities in Dominica are satisfied with the way in which the IRC

operates, and they intend to maintain it as the national regulatory agency notwithstanding

the Bank’s current initiative to promote regulation at the regional level, which should be

more cost effective. Apparently, the success of the IRC as a national regulatory

commission is also drawing attention in several neighboring islands.

A draft of alternative energy legislation has been circulated and it underwent several

revisions, but there was no final version when the ICR mission visited Dominica in

March 2011.7 The final revision is currently being undertaken at the Chambers of the

Attorney General for onward transmission to Parliament. Cabinet has to approve the

final draft before it is submitted to Parliament.

Component 4 - Improving social protection: Moderately Unsatisfactory. The

objective of this component was to strengthen the Government’s capacity to better target,

plan and administer social assistance programs for poor and vulnerable persons. In

particular, the Project supported: (i) modernization and streamlining the systems for

beneficiary selection and registration: (ii) activities to strengthen the administrative

capacity to deliver social assistance; and (iii) design and implementation of a public

information campaign to inform citizens about new approaches to the delivery of safety

net programs.

While the rating of this component reflects the fact that most targets were not

achieved by the closing date, substantial progress was made in key elements of the

program (see below). Further, it should be recognized that: (a) this component had a

late start, as key consultancies started only in 2009; and (b) targets requiring 100%

identification of beneficiaries, 100% registration, and 100% of ETF, SFP and PA

beneficiaries and expenditures captured in the data base, were not realistic. In addition,

there were technical problems in developing the new information system, coordination

among relevant ministries was initially not smooth, and the process slowed down prior to

the elections at the end of that year.

7 Several studies indicate that Dominica has potential for geothermal generation, which could supply all its

domestic demand and exports of about 15 MW to neighboring islands.

16

Notwithstanding these difficulties, the welfare system of Dominica is undergoing a

substantial change, both in terms of policy as well as implementation. At the policy

level, in January 2011, Cabinet approved means-testing as the target mechanism to be

used to identify beneficiaries, thereby increasing transparency and removing subjectivity

from this process, and the National Beneficiaries Information System (NBIS) was

launched shortly thereafter. Further, the new set-up establishes linkages between the

core programs in the safety net. In terms of implementation, social workers were trained

in the new targeting mechanism and potential beneficiaries completed application forms;

operations manuals for the ETF, PA and SFP were approved; and key monitoring

indicators were identified and a monitoring plan for the three programs was designed.

Incidentally, the Ministry of Education will not have a separate data base but it will rather

have access to the NBIS in areas that are relevant for its work. Finally, the public

information campaign has been prepared and a number of public relations activities have

already taken place.

3.3 Efficiency

The nature of this Technical Assistance Project did not allow for the calculation of

net present value or other financial variables. The US$2.6 million project was

expected to have only a minimal direct economic impact in the short term, and that seems

indeed to be the case. However, in the medium and longer term, the outcomes of the

Project are expected to contribute to Dominica’s economic and social development.

Better control and deployment of human resources within the civil service and lower

costs of operating the Registry are likely to save fiscal resources. Also, improvement in

quality and timing of audits as well as more transparent and efficient public procurement

would result in better value for money. Further, an improved environment for private

investment and better regulation of electricity are likely to contribute to economic growth.

In the longer term, development of geothermal generation capacity would lower domestic

energy costs and improve the balance of payments by reducing fuel imports and

exporting electricity to neighboring islands. In addition, the comprehensive reform in

customs could be a point of before and after in international trade and have a direct

impact on competitiveness and economic activity. In the social protection area, the new

beneficiary information system was still being put in place, but once it becomes

operational it would save administrative costs and enhance both the coverage and

efficiency of the social safety net.

3.4 Justification of Overall Outcome Rating Rating: Moderately Satisfactory

The PDO and key associated outcome targets of the GSPTAP were largely achieved,

or are likely to be achieved relatively soon, notwithstanding a slow start and delays

during implementation. The reform process of the civil service was advanced by the

Program. The Registry of land and companies is working much better, and the upgrade

to ASYCUDA World has already had a major impact on efficiency at customs. The

Invest Dominica Authority is providing information and services to investors, and the

recently established IRC is perceived by both the authorities and the public as fulfilling a

17

positive function in the electricity area. Delays were longer in the social protection

component, and targets were not achieved by the closing date. However, the technical

work on the new National Beneficiaries Information System (NBIS) has been completed,

Cabinet has approved means-testing as the targeting mechanism, and the system will

become operational shortly. The NBIS would help improving both targeting and coverage

of social protection programs, even if their coverage does not reach 100% as specified in

the Outcome Indicators.

3.5 Overarching Themes, Other Outcomes and Impacts

(a) Poverty Impacts, Gender Aspects, and Social Development

Insofar as the improved environment for private sector development succeeds in

attracting more investment, the resulting generation of new jobs would contribute to

reducing poverty. In addition, the new National Beneficiaries Information System

would improve coverage and efficiency of social protection programs. As of March 2011,

information of about 75% of current beneficiaries was entered into the new system, and

95% of those were confirmed. Better targeting of beneficiaries is expected to result in a

more efficient allocation of social expenditures. Improved coordination of the delivery of

social assistance would save administrative costs. Authorities, however, are concerned

that some people who were rejected by the new system because of size of household or

age may still need help, and they are looking for mechanisms to address that problem.

(b) Institutional Change/Strengthening

The human resources audit of established position in Ministries and Departments,

which was completed under the Project, would improve management in the public

sector. The Auditor General office was strengthened with new hardware and software,

the Registry was restructured and is now performing its duties within shorter periods of

time, and customs administration was taken to a higher level by the upgrade to

ASYCUDA World. The establishment of the IRC, with transparent methods of operation,

was a major institutional change in the energy area. When the new procurement law is

approved by Parliament, it would also be an institutional improvement. Finally, when

fully operational, the new NBIS will improve the effectiveness and efficiency of

institutions managing key social protection programs.

(c) Other Unintended Outcomes and Impacts (positive or negative)

The reform at customs, which was one of four sub-components within the first

component of the Program, acquired increased importance over time and became a

major outcome of the GSPTAP. A comprehensive and detailed M&E matrix was

developed during implementation, containing specific steps in eight focus areas: (i) legal

framework; (ii) organization and management; (iii) human resources management and

training; (iv) information and communication technology; (v) control systems and

processes; (vi) external cooperation; (vii) enforcement and compliance; and (viii)

integrity (Annex 3). This matrix spells out the tasks in each area as well as who was

responsible for execution and the expected time frame of completion. This sub-

18

component took a long time to take off, but import brokers see those reforms as a major

improvement in the system, which greatly facilitates international trade.

3.6 Summary of Findings of Beneficiary Survey and/or Stakeholder Workshops

N/A

4. ASSESSMENT OF RISK TO DEVELOPMENT OUTCOME Rating: Moderate

The risk that development outcomes would not be maintained varies somewhat

across the components of the Project. The risk to outcomes of component 1 is low to

moderate, as it strengthens institutions in the public sector and improves its operational

efficiency, thereby creating stakeholder groups who benefit from those reforms and

would oppose back tracking. An example of that is the reform at customs, which

facilitates and reduces costs of international trade. Likewise, for the improved operations

of the Registry, and for the services provided by the Invest Dominica Authority

(component 2). The risk could be significant, however, with regard to the new

procurement legislation, which has been bouncing back and forth for a long time.

Approval of this law is required to ensure that all public contracts above threshold are

advertised and awarded through transparent and competitive bidding.

The risk to the liberalization and current regulation of production and distribution

of electricity is moderate. While the new IRC is perceived as doing a good job and

protecting consumers, the cost of maintaining a national regulator is high. If this cost

becomes unbearable, the government may decide that it is advantageous to participate in

the regional regulatory authority, the development of which is being supported by the

Bank.

The risk to the sustainability of the new National Beneficiaries Information System,

once it’s operational, is low. Again, its higher efficiency is likely to save administrative

costs and draw support from beneficiaries.

5. ASSESSMENT OF BANK AND BORROWER PERFORMANCE

5.1 Bank Performance

(a) Bank Performance in Ensuring Quality at Entry

Rating: Moderately Satisfactory

The areas included in the GSPTAP were all of strategic relevance for Dominica. In

fact, they were also part of the Growth and Social Protection Medium Term strategy of

the government. However, the value added of the second component – Improving the

Investment Climate, is not so clear since there were other donors providing support in

this area. The Results Framework was general and with Outcome Indicators difficult to

measure. A subsequent Table of Arrangements for Results Monitoring in the PAD

19

presented interim and final target values for several OIs, but some called for 100%

compliance, which was not very realistic. The implementation arrangements were good,

with the PCU collaborating with the Ministry of Finance and the creation of a Steering

Committee and working groups for each component. However, the slow start of the

Project suggests that assessment of readiness for implementation was lacking. Finally, the

Risk Assessment included in the PAD was appropriate, covering most aspects of risk and

describing mitigating measures for each one of them.

(b) Quality of Supervision


The project lost its Task Manager (TM) almost right after Board approval, and

there was another TM change in the last year of implementation. While that is not

uncommon in the Bank, the two transition periods between TMs appear to have resulted

in delays in receiving responses to no-objection requests. Also, it took some time for

new TMs to become familiar with the various aspects of the Project. However,

authorities pointed out that TMs responded expeditiously to Government requests when

at World Bank Headquarters, but it took more time to get responses when they were on

mission in other countries. TMs had also to administer the Trust Fund (TF) that co-

financed the Project and had to report progress to the EU, which was complicated by the

different time frame of the TF.

In general, supervision missions focused on development impact, and processes were

adequate. However, because of budgetary considerations, there was only one field visit

to Dominica in 2009, and most supervision was done virtually that year. At times,

management perceived that ISRs’ reporting on program performance and the time needed

to achieve its targets was overly optimistic. Supervision of fiduciary and procurement

was appropriate, based on periodic reports by the PCU and several missions to the

country.

(c) Justification of Rating for Overall Bank Performance


The GSPTAP was only the second project in the past 20 years that the Bank

approved for Dominica, which was not for reconstruction after natural disasters.8

As such, it’s understandable that it would tend to spread over various areas. All these

areas were also in the Development Strategy of the Government, and were relevant to

Dominica’s social and economic development objectives. However, the Results

Framework was phrased in general terms and the Outcome Indicators were not always

measurable, which required a restructuring at the Mid-term Review and generated

confusion during supervision. Nevertheless, the GSPTAP contributed to strengthening

8 A Basic Education Reform Project was approved by the Board in December 1995, and 3

Emergency Recovery Projects were approved in 1998, 2002 and 2004.

20

public sector institutions, to improving the environment for private sector activity, and

once the new National Beneficiaries Information System is fully operational, also to

improving the coverage and efficiency of social protection programs.

5.2 Borrower Performance

(a) Government Performance


While staying the course on the reform program, Government took time to approve

measures and submit new legislation to Parliament. Some reforms took longer than

expected because of technical reasons, such as development of the NBIS. Others, such as

procurement legislation, were delayed by lengthy public consultations. In addition,

several legislation proposals were delayed simply because there is only one person in

government that drafts those proposals. All in all, the majority of targets were achieved.

While a number of targets were only partially achieved or not achieved by the closing

date, several are near completion and most are expected to be completed in the near

future.

(b) Implementing Agency or Agencies Performance


The PCU was part of the Reform Management Unit/Establishment, Personnel

Training Department. The first Project Coordinator organized the Unit and engaged

with agencies that were responsible for implementation. Further, the Coordinator

followed up closely with those agencies and reported progress (or lack thereof) to the

World Bank. The PCU also reported on financial management monthly to the Financial

Secretary of Finance and quarterly to the Bank. That arrangement worked well, albeit not

always on time (report was done within the time frame as noted by the Operations

manual. Reporting was usually done on time). Likewise with regard to audit reports. In

general, the follow up, reporting, and coordination with the World Bank after the first

year of implementation. However, the PCU provided efficient support to Bank missions

visiting Dominica throughout the life of the Project.

(c) Justification of Rating for Overall Borrower Performance


Overall Borrower performance is rated Moderately Satisfactory for the reasons described

above.

6. LESSONS LEARNED

Project-Specific Lessons

Agreeing with UNCTAD on the terms of the consultancy to upgrade ASYCUDA

2.7 to ASYCUDA World during preparation of the Project would have prevented

long delays in launching the new system;

21

Delays in meeting the new procurement legislation target resulted in part from the

fact that this sub-component of the GSPTAP piggy-bagged on a reform being

prepared under a project by another donor, over which the Bank had no control;

The Bank has to ensure that procurement and financial management training is

provided to the PCU as needed.

General Application Lessons

The scope of Bank programs in small states deserve further discussion. On the

one hand, since only one project is prepared in a multi-year period, both the

Government and the Bank tend to include many activities in the program. On the

other hand, these countries have usually tight capacity constraints, which calls for

relatively simple and highly selective programs;

The Bank could consider special procedures for very small projects, in order to

facilitate implementation and lower supervision costs. For example, the Bank

requires a minimum of 3 quotes from suppliers, but in small local markets there

may not be that many suppliers of a particular item. That is relevant because

contracting locally could be cost saving when the item involved requires periodic

service and maintenance;

Prolonged lags between Project preparation and actual implementation of reforms

call for: (i) more flexibility to address changing government priorities; and (ii)

more flexibility in reallocating funds to items whose costs went up over time;

Leveraging donor funds can benefit the client by increasing substantially the size

of the project. However, the added coordination efforts impose costs on all sides.

Thus, it is important to make sure that all are in the same wave length throughout

implementation, to ensure that the Program is properly monitored and

coordination costs minimized.

With hindsight, it seems that having the PCU working in close collaboration with

the Ministry of Finance improved its access to other implementing agencies and

facilitated execution of the Program.

7. COMMENTS ON ISSUES RAISED BY BORROWER/IMPLEMENTING AGENCIES/PARTNERS

(a) Borrower/implementing agencies

(b) Cofinanciers. Comment by the EU (Annex 8)

The Dominica Private Sector & Growth Programme was a hybrid between a

General and Sectoral Budget Support Programme. The general condition was linked

to progress in the GSPS, and the specific objective was to improve the investment climate

to foster private sector-led growth, notably through the further development and

implementation of a National Investment Strategy (NIS). The total amount of this

programme was €17.1 million which was comprised of a budget support component of

€16.4 million and complementary support of €646,000. The complementary support was

comprised of €526,000 for technical assistance (TA) to the World Bank (WB) GSPTAC

programme and €120,000 for monitoring and evaluation. The EU Delegation had been

22

regularly receiving status reports of the WB GSPTAC, some of them constituted the

evidence for backing the fulfilment of the variable tranche indicators. A dialogue with the

Government and the World Bank on progress on EC budget support variable tranche

indicators took place on December 2010 during the Budget Support Review.

(c) Other partners and stakeholders N/A

23

ANNEX 1. PROJECT COSTS AND FINANCING

(a) Project Cost by Component (in USD Million equivalent)

Components Appraisal Estimate

(USD millions)

Actual/Latest

Estimate (USD

millions)

Percentage of

Appraisal

Making the public sector more

efficient and effective 0.00 1.24

Improving the investment climate 0.00 0.25

Reforming the regulatory

framework for the energy sector 0.00 0.70

Improving social protection 0.00 0.23

Project Management 0.00 0.18

Total Baseline Cost 0.00 2.60

Physical Contingencies

0.00

0.00

0.00

Price Contingencies

0.00

0.00

0.00

Total Project Costs 0.00 2.60

Front-end fee PPF 0.00 0.00 0.00

Front-end fee IBRD 0.00 0.00 0.00

Total Financing Required 0.00 2.60

(b) Financing

Source of Funds Type of

Cofinancing

Appraisal

Estimate

(USD

millions)

Actual/Latest

Estimate

(USD

millions)

Percentage of

Appraisal

Borrower 0.54 0.00 0.00

EC: European Commission 0.61 0.00 0.00

International Development

Association (IDA) 1.45 0.00 0.00

24

ANNEX 2. OUTPUTS BY COMPONENT

PDO and Indicators Target values Status in March 2011

Component 1.

Ministries and departments

have improved knowledge of

current staffing and plans to

better manage staffing.

Reform Management Unit

planning, designing and

implementing modernization

plans.

Completed Human Resource

Audit of Ministries and

Departments of the Public

Service.

Development, dissemination,

approval and launch of a time

bound, fully costed Human

Resource development and

succession action plans for

Ministries and Departments

within the Public Service.

Audit completed, following

wide consultation.

Staffing plans need to be

approved by Cabinet.

Partially completed, as part of

the above. RMU has

developed a methodology for

preparing the succession plans

when time comes, and has

identified key positions where

those plans would be applied.

They have not been fully

costed.

CARICAD was contracted to

carry out the Human

Succession plans.

Cabinet has to approve the

recommendations and action

plan.

Audit Capability improved

through automation of audit

function.

Installed and functioning audit

management systems.

Automated audit produced by

SMART Stream

Partially achieved.

Auditor General office

received the IDEA software in

early 2010, but staff was not

able to complete training.

SMART Stream is operational

for budget process, but not for

audit.

Accounting General office

staff got training in SMART

Stream and are using that

system.

Procurement Modernized. Draft of New Procurement Act

is in the web for consultation

with the public.

100% of public contracts

above threshold are advertised

and awarded through

transparent and competitive

Achieved. Various drafts have

been in the web for comments

by the public, while a

subcommittee of Cabinet is

evaluating the draft.

Partially achieved. Currently,

the majority of contracts above

EC$1 million are awarded by

competitive bidding. The new

25


bids.

Procurement Act would make

that compulsory for all

contracts.

Establishment of self-

financing, semi-autonomous

agency for Registry.

The Registry is more efficient.

Registration of property

reduced from 40 to 20 days.

Computerization of Registry

in the Birth and Death section.

Partially achieved.

Land Registry is part of the

Ministry of Finance. It

transfers its income to the

Treasury and is funded by the

budget.

Registration of land:

First title – down to 60-90

days.

Direct transfer – down to 30

days.

Part of land – down to 35

days.

Companies have a separate

Registry, which takes 1-2

days.

Partially achieved. Data Entry

has been completed. Business

Proposal submitted. Cabinet

has to approve.

Customs information

processes are more integrated,

transparent and efficient

through the use of information

technology.

Customs IT upgraded from

ASYCUDA 2.7 to

ASYCUDA World.

Achieved. The new system is

fully operational, and is seen

as a major improvement by

private users.

Technology for paperless

transactions installed, and

80% reduction in use of paper

for import declarations.

Achieved. Customs

declarations need just one

paper copy instead of 4, while

cargo manifests are now an

electronic document, rather

than a paper one.

Reduction in the average time

for customs clearance from 7

days to 1 day, thus resulting in

lower transactions cost for

businesses.

Achieved. According to the

CATT report of December

2010, over 50% of

declarations took on average

more than 24 hours to be

released in 2010. However,

customs authorities said that

since the new system was

implemented in July 2010, this

26


time has been reduced to 1

day.

Component 2.

Government policies and

actions

to improve the investment

climate are

driven by a National

Investment Strategy.

Analysis and Planning for

National Investment Strategy

done, strategy completed,

adopted and implemented by

Invest Dominica Authority for

GOCD.

Achieved, although not as a

direct outcome of this project.

The Invest Dominica

Authority was established in

July 2007.

Strategy approved by cabinet

in December 2010, and Action

Plan being implemented.

NATHAN Consulting

provided support in this task.

One-stop-shop for tourism

investors established and

operational, including

analysis, development of

proposal, funding, and

launching.

Achieved. Service provided

by Invest Dominica Authority.

Number of days to process

investment gradually reduced

to 20 days.

Achieved. Proposals of up to

EC$2 million are reviewed by

a subcommittee of cabinet

within 2 weeks, and proposals

above that amount are

reviewed by the full cabinet

within 3 weeks.

Component 3

To liberalize and regulate the

production and distribution of

electricity to improve

competitiveness.

Regulatory Commission

established, funded, staffed

and fully functional.

Achieved. Independent

Regulatory Commission (IRC)

established in July 2008.

The authorities prefer to keep

the IRC rather than to join a

regional regulatory initiative.

Draft alternative energy

legislation drafted,

stakeholders discussion

conducted and submitted to

Parliament for approval.

Partially achieved.

Draft has undergone various

revisions, currently draft is

being reviewed finally at the

Attorney General’s Chambers

for onward submission to

Parliament.

CASTALIA was contracted to

draft the legislation.

27


Methods in place for dealing

with unexpected tariff and

other Regulatory issues.

Achieved. The policies

implemented by the IRC

include those methods and are

posted in the web.

Component 4

An objective and transparent

targeting mechanism of

beneficiaries is implemented.

100% of new beneficiaries of

PA and ETF identified

through BIS.

BIS system being used to

select beneficiaries for Public

Assistance Program (PA) and

Education Trust Fund (ETF)

Program.

Partially achieved. Proxy

means test and the BIS were

approved by cabinet in

January 2011. Their use has

just started, as data is being

input into the system.

A central beneficiary registry

is in place.

100% of PA and ETF

beneficiaries registered in

Central Registry.

Central Beneficiary Registry

fully functional and MIS for

ETF, PA, and School Feeding

Program (SFP) functional.

Partially achieved (see above).

MIS for ETF, PA and SFP was

launched.

100% of ETF, SFP and PA

beneficiaries and expenditures

data captured in data base in

Ministry of Education.

Policies and procedures

related to PA and ETF

documented and relevant staff

trained.

Partially achieved (see above).

Eventually, the BIS would

include data on all

beneficiaries and programs,

and the Ministry of Education

would have access to the

information relevant for its

operations.

Policies and procedures

established and documented in

operational manuals for PA,

ETF and SFP, and staff was

trained.

The general public in

Dominica is fully informed

about the new approaches to

the delivery of social safety

net programs.

Public information campaign

is implemented.

Partially achieved.

The material for the

information campaign has

been prepared, and some

aspects successfully

undertaken. More PR to be

undertaken when system is

fully utilized.

28

ANNEX 3. DOMINICA CUSTOMS REPORT PROJECT – HIGH LEVEL ACTION PLAN: PROGRESS AS OF JANUARY 2011

FOCUS AREA # 1 – LEGAL FRAMEWORK

Objectives:

a. To improve transparency and promote consistency by minimizing levels of discretionary authority of officials in operational and administrative

decision making processes

b. To minimize reliance on paper and make progress towards adopting a paperless environment

Activity Required position Tasks Responsibility Time frame Progress to date Remarks

Review existing

Customs legislation

impacting on the

upgrade to

ASYCUDA World

and other areas of the

modernization

program

Legislation must cater

for modern concepts

including acceptance of

electronic declarations

and must be

strengthened to

improve overall

compliance

1. Identify areas of Customs

Act in need of

amendment and confirm

if draft CARICOM

provides sufficient

coverage*

Director Customs

Reform

Comptroller of

Customs

Completed –

Mar 2009 Customs Act No.

20 0f 2010

assented as of

October 27, 2010-

12-21

Commencement

date approved by

Cabinet as

December 1, 2010

Enactment of new

Customs

Legislation will

facilitate the

reduction of paper

based transactions

clear the way

towards a

paperless

environment.

2. Propose amendment for

consideration by

Government

Comptroller of

Customs

Completed -

Aug 2009

3. Follow up and ensure

timely implementation

Comptroller of

Customs

Further

revision to

September

2010

Establish a system for

the administration and

application of

Customs enforcement

measures with

guidelines for the

Customs Operational

level.

A consistent basis for

determining fines and

penalties for

administrative

processing of cases at

the operational level

without compromising

the authority of the

office of the

Comptroller

1. Review recommendation

made for establishing

system of penalties and

fines

Comptroller of

Customs

Completed

Aug 2009

Draft guidelines

for administrative

penalties relating

to customs

offences has been

developed

A policy of this

nature was

recommended by

previous

consultancies and

is considered as a

key element for

improving the

transparency of

decision making

relating to

administrative

penalties and the

levels of fines

2. Discuss internally with

senior managers and

supervisors

Comptroller of

Customs

Nov 2009 Draft guidelines

to be included in

Customs

regulations

3. Establish policy and

implement system of

penalties and fines

Comptroller of

Customs

Revised to

February

2011

Awaiting

feedback on final

draft

29

FOCUS AREA # 2 – ORGANISATION AND MANAGEMENT

Objective:

Introduce corporate planning system which takes into consideration the reform initiatives and the linkages between resource allocation and

achievement of key operational results

Activity Required position Tasks Responsibility Time frame Progress to date Remarks

Develop and

implement a long term

strategic plan or

business strategy for

CED

A corporate plan which

sets out goals and

strategic objectives for

modernizing operations

of CED and improving

service delivery

Finalize draft corporate plan

with times schedules and

priority areas for

implementation as part of

reform initiatives

Comptroller of

Customs Senior

Managers

Director Customs

Reform

Revised to

January 2011

Draft Plan is

being reviewed

and finalized

Feedback

required before

finalization.

Review organizational

structure as required to

meet changing

operational demands

resulting from

implementation of

ASYCUDA World

A functional structure

responsive to new

operational demands

Redesign structure in

keeping with operational

demands and changes in

work flow AYSCUDA

World

Director

Customs Reform

On going A further revision

of the structure

was undertaken in

July 2010.

Revised structure

being

implemented on

an incremental

basis and will be

fully in place by

February 1, 2011

Develop and

implement a planning

and reporting system

which provides

information on

operational outcomes

An effective planning

and reporting system

which sets targets and

produces regular

reports of the outcomes

at all levels

1. Design operational unit

plans & monthly

reporting template for

each Unit

Unit Supervisors Nov 2010 Reporting

templates

developed for all

operational units

Management

workshop

conducted -

November 22- 26,

2010 produced

draft Operational

Unit Plans for

Sections and

Units of the

Division

2. Design Sectional Plans &

Quarterly Reporting

template

Asst Comptrollers

Nov 2010 Draft Plans

completed

3. Design annual Divisional

plan and quarterly

reporting template

Deputy

Comptroller

Nov 2010 Corporate plan

not finalized and

unit reports do

not reflect all

operational

outcomes

30

FOCUS AREA #3 - HUMAN RESOURCE MANAGEMENT AND TRAINING

Objective:

Improve decision making processes on staff related matters ,provide resources to create conducive working environments and motivate staff members to

accept changes associated with reform and modernization initiatives including ASYCUDA World

Activity Required Position Tasks Responsibility Time Frame Progress To Date Remarks

Conduct staff audit to

determine current and

future needs of CED

A staffing database

which can provide up

to date information

about the staff position

and to assist with

decision making

1. Determine current

staffing levels and

number of vacancies etc

Human

Resource Officer

Feb 2010 This is done

manually and a

nominal role

produced on an

annual basis

UNCTAD

Consultant has

pointed to the

possibility of

developing an HR

module using

ASYCUDA

Platform.

2. Design staff database

for CED

HRO /ICT Jan – Mar 2011 Technical

assistance is

required to

accomplish this

task

3. Populate database with

Information

HRO March 2011

Develop a Human

Resource

Development Plan for

CED

An operational Human

Resource Development

Plan including a

detailed training plan

1. 1. Conduct a training needs

assessment for all CED

staff

HRO/Sup Training TBD No evidence of HR

planning within

CED

HR issues

considered as

essential for

successful reform

however

discussion with

World Bank

Officials in Sept

2009 did not

guarantee

funding

2. 2. Analyse TNA results and

determine priority areas

HRO/ Sup Training TBD No action taken

3. 3. Formulate training and

development plan for

CED

HRO/ Sup Training TBD No action taken

Re-establish the

Performance

Appraisal System

within CED

A functional

performance appraisal

system which is linked

to the measurement of

outcomes in the job

descriptions and the

objectives of the units.

1. Conduct training

workshop on

Performance Appraisal

System for Supervisory

and senior staff

Establishment /

CPO

Apr 2011 HR Officer and

one supervisor has

received training in

the preparation of

the EADR*

HR officer to

assume

responsibility for

training other

supervisory staff

2. Advise staff and request

appraisal by end of fiscal

year

HRO On going Instructions issued

to supervisory staff

Mixed levels of

compliance among

supervisors.

31

Ensure staff are

operating in conducive

working environments

A comfortable and safe

working environment

for all staff

1. Visit all work stations

and take note of

unfavorable work

conditions

HRO On going Working

conditions being

addressed at all

stations

Housing and

Facilities

Committee

appointed with

HR officer as the

chair

Comptroller of

Customs

Revised date of

completion to

June 2010

New Air Cargo

Shed at Roseau

Port became

operational in July

2010

The clearance

process involving

both Customs &

DASPA must be

continuously

reviewed to

minimize delays

being experienced

by clients

Director Customs

Reform

March 2010 is

now

unrealistic.

New date

cannot be

determined

A One Stop Cargo

Clearance facility

at DWH is

required to meet

the needs of

ASYCUDA World

A new and more

cost effective

option is currently

being examined.

Preliminary

drawings

developed and

under

consideration by

Public Works

Division

Introduce WCO e-

learning facility to

complement other

training programmes

A functioning e-

learning facility

available for use by all

interested staff

1. Sensitize staff about the

WCO

e-learning facility

HRO / Sup

Training

Completed

July 2009

Circular to staff

issued in July

2009.

Training officer to

be appointed by

January 2011

2. Select individuals to

participate in regional

pilot program

HRO / Sup

Training

Sept 2009 Staff selected

based on ability to

access from home

as departmental

network is limited

in scope

32

3. Work with I T Unit to

provide work stations for

use by staff

4.

HRO/ Sup training Sept 2010 All stations

equipped with

computers

5. Launch e-learning

program and select

persons for training

HRO / Sup

Training

Sept 2009 WCO e-learning

program launched

- 42 participants

Formulate internal

policies to guide

action and decision

making in human

resource management

activities

Standardized written

policies to improve

transparency and serve

as a guide in decision

making.

1. Identify areas where

written policies are

lacking

Director Customs

Reform

October 2009 Absence of

written policies

results in ad hoc

decision making

on staff and other

similar matters

Draft Firearm

Policy under

consideration

Solicit support of

Establishment

Division in

seeking existing

HR polices in use

within the Service

An internal

arrangement to

provide support to

HR officer is in

place

2. Research and prepare

draft policies where

appropriate

HRO December 2009

HR Officer was

unable to give

attention to these

tasks because of

having to perform

administrative

functions

3. Disseminate draft

policies for discussion

and feedback within

CED

HRO

4. Adopt policies after

agreement by

management

Comptroller of

Customs

March 2010

Review remuneration

system and current

salary scales for

customs staff

An appropriate salary

structure and benefit

system that will

support a reasonable

living standard and

encourage ethically

correct behavior

1. Conduct comprehensive

evaluation of the jobs

being performed by

officers at the respective

levels.

Director Customs

Reform

HRO

Dec 2009

Depends on input

from HRO and

some technical

support

A study to be

carried out

throughout the

Public Service by

CARICAD is

being finalized.

2. Revise current reward

system to improve

transparency create more

equitable distribution of

benefits

Director Customs

Reform

Comptroller of

Customs

Oct 2009 A recommendation

was made but it

has not been

widely circulated

or discussed

Current reward

payment system is

widely criticized

within the

Division

33

Review Job

Descriptions for all

CED staff

New job descriptions

based on new design of

organizational structure

1. Determine the functions

to be performed within

the new units

Director Customs

Reform

On going New Job

Descriptions have

been developed for

all positions in the

Division

Assistant

Comptrollers and

Supervisors to

review and

finalise job

descriptions for

their respective

units

2. Revise job descriptions

to suit new arrangements

Director Customs

Reform

Unit Supervisor

On going

FOCUS AREA #4 – INFORMATION AND COMMUNICATION TECHNOLOGY

Objective:

a. Modernise operations of CED with greater reliance on ICT to improve internal communications, provide advance and relevant information to

traders and encourage compliance

b. Maximise revenue collection, facilitate trade and provide more accurate and timely trade data

Activity Required Position Tasks Responsibility Time Frame Progress To Date Remarks

Migrate to

ASYCUDA World

The fully integrated

use of ASYCUDA

World within all

operational units of

CED

In accordance with detailed

Project Plan

Director Customs

Reform

By March

2011

Phase 1 and 2

Completed. Phase

3 – Declaration

module

introduced on

July 2010 at

Roseau. All other

ports except

Portsmouth now

using module

Portsmouth

expected to be

fully in use by

January 2011.

Recommendation

made for

extension of

Project to March

2011 to enable

completion of

some activities

Expand and stabilize

the internal ICT

Network to

incorporate all

Operational Units

A stable Wide Area

Network (WAN) that

provides connectivity

between Customs

headquarters and all

operational units

Replace existing network at

Customs HQ with increased

bandwidth and gradually

expand to include

operational areas and

outstations using frame relay

Director Customs

Reform

Revised to

July 2010

Division fully

networked with

some minor

elements yet to be

completed.

95% of work

completed

however some

aspect of the

contract cannot be

completed

because of

infrastructure

issues

34

Develop Intranet to

enhance internal

communication and

access to information

for decision making

purposes.

An effective internal

communication system

which facilitates the

transfer of information

between Customs HQ

and outstations.

1. Conduct survey to

determine user needs and

requirements for Intranet

ASYCUDA Project

Manager

Jan 2011 Internal

communication is

does not make

sufficient use of

ICT resources

Dependent on

stable and reliable

WAN

2. Identify appropriate

software for Intranet Work commenced

but delayed by

conflicting

priorities

3. Install and promote use

within CED based on

established guidelines

ASYCUDA

Project Manager

Revised to

June 2010

Develop website for

CED to improve

image and enhance

external

communication and

public relations

A website which

provides relevant and

up to date information

about Customs for use

by the trading

community and general

public

1. Secure permission and

domain name for Website

etc.

ASYCUDA Project

Manager

June 2009 Permission to

proceed provided

by Comptroller

Assistance being

provided by ICT/

RMU through a

liaison with

ASYCUDA

Project Manager

Official launch re

-scheduled for

January 2011

2. Identify appropriate

content for CED Website

Comptroller of

Customs

Completed

by August

2010

Committee

appointed to

advise on content

for website

3. Assign responsibility to

develop and maintain

website

ICT/ RMU July 2010 Work commenced

on website

development with

support from ICT/

RMU.

4. Official launch of CED

Website

Comptroller of

Customs

January 2011

FOCUS AREA #5 – CONTROL SYSTEMS AND PROCESSES

Objective: Streamline systems and procedures in line with requirements for implementation of ASYCUDA World including adopting risk management systems

Activity Required Position Tasks Responsibility Time

Frame Progress To Date Remarks

Review existing

control systems and

processes with a view

to eliminating

unnecessary steps and

improving

effectiveness and

Greater use of risk

management and

selectivity without

compromising revenue

collection or security

concerns

1. Document all existing

procedures / processes

ASYCUDA

Project team

July

2008

Some accountability

gaps within control

systems and

processes

ASYCUDA

implementation and Risk

management / selectivity

will impact on the

following systems and

processes:

- revenue

2. Identify weaknesses

and redundancies

Director

Customs Reform

Unit Supervisors

On going Absence of reliable

data from Units

hampers the

35

efficiency of

operations through

implementation of

ASYCUDA World

development of risk

profiles

collection,

- cargo

examinations,

- valuation,

- passenger control

A new procedures

manual will be produced

as part of the final stage

of the Project.

3. Recommend new

standard Operating

procedures (SOPS)

based on risk

management

Director

Customs Reform

On

Going New SOPs will be in

sync with phased

implementation of

ASYCUDA World

4. Approve and

implement new

procedures/processes

Comptroller of

Customs

On

Going On going

FOCUS AREA #6 – EXTERNAL COOPERATION

Objective: Improve and formalize working relationships with strategic partners to clarify roles, responsibilities, enhance cooperation and improve compliance

levels.

Activity Required Position Tasks Responsibility Time Frames Progress To Date Remarks

Formalise working

relationship with local

law enforcement

agencies

A signed Memorandum

of Understanding

(MOU) signed between

CED , the Police to

outline the basis for

cooperation with

various LE units of the

two organizations

1. Initiate dialogue

between with Police

Commissioner to

discuss improve

working relationship

Comptroller of

Customs

TBD

No MOUs have

been developed

Input from MOF

and Legal Affairs 2. Prepare draft MOU

outlining areas of

cooperation

Director Customs

reform

On demand

3. Finalize MOU and agree

on date for signing and

implementation

Comptroller Of

Customs

TDB

Improve relations

between Customs and

DASPA

A professional

approach to problem

solving and cargo

accountability systems

1. Convene quarterly

meetings with

Customs/DASPA mgt

teams

Comptroller of

Customs

Sept 2008 5 joint

management

meetings have

been held to date

Awaiting

feedback from

DASPA on MOU

2. Agree on a structured

way to resolve issues

and improve the

working relationship

Comptroller of

Customs

CEO of DASPA

November

2010

MOU developed

and sent to

DASPA for input

and finalization

36

3. Discuss concerns and

implications of Customs

Reform on DASPA

operations

Management

of CED and DASPA

On Going On going

Promote improved

relations between

Customs, Private

Sector and other stake

holders

An established forum

for discussing and

resolving issues with

the Private Sector and

other economic

operators

Re-establish meetings of the

JCC and ensure timely

action taken on

recommendations

Comptroller of

Customs

Completed

October 2009

Two meetings of

JCC held to date.

Constitution

revised to expand

membership and

assume role as

ASYCUDA

World Steering

Committee

Responsibility for

ASYCUDA

Steering

committee was

assigned to a

special sub

Committee with

TORs

Enhance public image

of CED through

increased presence in

the media

A proactive approach

by CED towards public

relations and

promoting a better

understanding of its

roles and

responsibilities

1. Assign public relations

function to a Senior

Manager

Comptroller of

Customs

Jan 2009 Senior Managers

to assume

responsibility for

dealing with

media and

publicity based on

area of focus

CED must take

advantage of

opportunities to

improve its

image.

2. Organise radio and

television appearances

for comptrollers and

other staff of CED as

required

Director Customs

Reform

Sup Training and

Public Education

On going Some work was

done to coincide

with International

Customs Day and

official launch of

ASYCUDA

World Project in

Dominica

3. Prepare and disseminate

promotional material

about CED

ASYCUDA Project

Team &

Sup Training and

Public Education

On going Some

promotional

material was

prepared for

components

ASYCUDA

World Project

37

FOCUS AREA # 7 – ENFORCEMENT AND COMPLIANCE

Objective: Adopt risk Management concept in support of trade facilitation goal and implementation of ASYCUDA World

ACTIVITY REQUIRED

POSITION TASKS

Progress to date Remarks

Adopt risk

management approach

in all operational areas

An intelligence-led

approach based on

targeted risk

assessment and

modern technology to

safeguard revenue,

enforce compliance

and protect society

1. Appoint risk Management

Committee and assign

persons to collect data for

development of profiles

Comptroller Of

Customs

May 2009 Risk Management

Champion

identified and

Risk Management

Committee

appointed

Risk management

Policy in place

but is in need of

more regular

review and

attention

2. Provide training and

recommend measures for

improvements*

CARTAC Consultants On going Risk Management

Training provided

by CARTAC

Develop a post-

clearance control and

audit unit which

allows the CED to

keep a balance

between facilitation

and control

An audit and post

control system which

ensures efficient,

quality-controlled

audits using

appropriate methods

1. Identify an individual

with appropriate training

and ability to be Customs

Auditor

Financial Secretary

Done -

July2008

A trained

accountant was

appointed for

CED. Reported

for duty on

August 08

Some changes

being

contemplated in

the structure and

scope of

operations for the

Unit.

New leadership

identified and

personnel

reassigned to new

design.

2. Staff the Unit with

competent officers willing

to learn and committed to

post auditing

Comptroller of

Customs

Done - Jan

2009

Staff provided as

part of annual

Staff rotation in

January 2009

3. Provide specialized

training to familiarize

officers with new systems

and procedures, and

upgrade skills for higher

standards of auditing

Supervisor Training

& CARTAC

1st Quarter

2010 Additional

training provided

in February and

May 2010.

4. Conduct audits in

accordance with audit

plan/policy and based on

risk analysis.

Customs Auditor

On going All Audit staff in

place and

assigned tasks

38

FOCUS AREA # 8– INTEGRITY

Objective: Introduce measures to encourage professional conduct and accountability for actions of all staff members

Activity Required Position Tasks Responsibility Time Frames Progress To Date Remarks

Promote integrity

measures to ensure

that all staff observe

the rule of law and

perform

their duties in a fair,

impartial, honest,

trustworthy, polite and

professional, but firm

manner

An Integrity Policy for

CED with professional

and personal conduct

and standards of

service required of all

employees, and which

is fully endorsed,

observed and supported

by the

management and staff

Review the existing draft

with a view to achieving a

more acceptable version

Comptroller of

Customs

TBD

Code of conduct

is being resisted

by staff on the

grounds that it

requires a higher

standard of

behavior without

any consideration

for the current

low levels of pay

to customs

officers

Requires a

consultative

approach with

involvement of

several interest

groups including

trade union

representatives.

A full integrity

programme for

Dominica Customs

may be pursued

with the assistance

of CCLEC

Circulate new draft for

discussion with staff, their

representatives and

government officials

No action taken

39

ANNEX 4. BANK LENDING AND IMPLEMENTATION SUPPORT/SUPERVISION PROCESSES

(a) Task Team members

Names Title Unit Responsibility/

Specialty

Lending

Antonella Bassani Director CFPIR

Michael Corlett Country Officer LCC3C

Charles M. Feinstein Sustainable Development Leader EASNS

Errol George Graham Senior Economist AFTP4

Gillette H. Hall Senior Social Development Spec SDV

Chingboon Lee Sector Manager, Education LCSHE

Lisa Lui Lead Counsel LEGIP

Rachel McColgan-Arnold Chair, Staff Association WBGSA

Ganna Musakova Program Assistant LCC3C

Emmanuel N. Njomo Consultant AFTFM

Stefka Slavova Senior Economist CICRA

Evelyn Villatoro Senior Procurement Specialist EAPPR

Supervision/ICR

Kathy Lalazarian Task Team Leader LCSPS

Roberto Panzardi Team Leader LCSPS

Bertha Mburugu Program Assistant LCSPS

May Olalia Sr. Operations Officer LCSPS

Carmen Machicado Operations Officer LCSPS

Karla J. McEvoy Social Protection Specialist LCSHS-DPT

Svetlana V. Klimenko Sr Financial Management Specia LCSFM

Tanya Gupta Resource Management Officer CFRPA

Yao Wottor Senior Procurement Specialist LCSPT

Donald I. Hertzmark Consultant LCSEG

Jose Eduardo Gutierrez Ossio Consultant LCSPE

Lorraine R. Blank Consultant AFTP1

David Yuravlivker Consultant LCSPS

(b) Staff Time and Cost

Stage of Project Cycle

Staff Time and Cost (Bank Budget Only)

No. of staff weeks USD Thousands (including

travel and consultant costs)

Lending FY06 209.28

FY07 98.29

Total: 307.57

Supervision/ICR

FY08 106.18

FY09 22 116.48

FY10 26 116.34

FY11 16 117.93

Total: 64 456.93

40

ANNEX 5. SUMMARY OF BORROWER'S ICR AND/OR COMMENTS ON DRAFT ICR

SUMMARY OF BORROWER’S ICR

PROJECT IMPLEMENTATION

A Project Coordinator/Procurement Officer, Mrs. Cecelia Martin and Project

Accountant, Mrs. Tanya Chase-Henry were employed in the World Bank Growth and

Social Protection Technical Assistance Project at the inception of the project. During

the life of the project, Mrs. Cecelia Martin tendered her resignation in August, 2008.

Mrs. Marilyn A. Cuffy-Morris was contracted for a period of twenty-one (21) months.

The project was extended by a further six month due to General Elections which was

held in December, 2009 which led to major project delays. This is dealt with under the

section Trajectory delays in the project. The total number of deliverables implemented

per year during the twenty one (21) month period is noted under the Administration

section. There was need to employ an Administrative Assistant in the project to

provide administrative support on a daily basis. Secretarial and administrative support

was provided by Ms. Dellina Dalrymple, who was recruited in July, 2008.

At the commencement of the Project on 19th

, September, 2007, a workshop was held

for Project staff, the Implementing Agency and also the project beneficiaries. This

workshop was facilitated by World Bank staff headed by Mr. Errol Graham, the then

Task Team Leader.

During the initial implementation, a few constraints were encountered in respect to the

arrangements for the release of funds from the World Bank. After meeting with the

PCU, RMU and the Chief Personnel Officer (CPO), the procedure for submitting

requests and authorization for disbursement of project funds according to World Bank

standards was finalized. The procedures for requests for disbursement of funds and

changes to procurement plan were communicated to all project beneficiaries and project

leaders. The Project accounting and reporting processes and procedures were finalized

and the resources required to equip the Project Coordinating Unit was procured. The

preparation of the World Bank project was in direct response at stabilizing the

Dominican economy and (i) to embark on an adjustment strategy being implemented by

the new Government and (ii) to implement key structural reforms to establish the basis

for private sector-led sustainable growth and poverty reduction.

The World Bank Growth and Social Protection Technical Assistance Project was

approved by a Committee of Government officials. The project commenced on 19th

,

September, 2008 and closed on 31st, December, 2010. The total projected budget was a

total of EC$7,020,000.00. As at 31st, December, 2010 a total of EC$7,502,867.00 was

expensed. The World Bank credit and EU agreements was extended by six months as

41

follows, after the twenty-forth (24th) month of Implementation due to unforeseen

delays.

Start date World Bank European Union

30th

, February, 2007 - 30th

, June, 2010

07th

, September, 2009 31st, December, 2010 -

Project start up Deliverables

A Quik Books accounting software was purchased for use by the Project Accountant.

All Government funds had to be accounted for through the use of an Accounting

software, Smart Stream. The government Computer Center provided training for the

staff of the Project Coordinating Unit in the use of the Smart Stream software.

In an effort to account for use of funds within the project three bank accounts were

opened at the National Bank of Dominica; one EC$, and two $US accounts. The

Ministry of Finance in collaboration with the Establishment, Personnel and Training

Department designed the required authorization mechanisms to operate these accounts.

All withdrawal applications and replenishments were undertaken on a monthly basis

and were approved by designated officials in the Ministry of Finance. Direct payments

would be made in keeping with the guidelines in the Operations Manual.

No Petty Cash accounts were operated throughout the duration of the project. The

provision of a cheque book to disburse funds from the GSPTA bank account was

approved in July, 2008. This greatly alleviated the difficulties experienced in getting

cheques printed through SmartStream, particularly when all transactions were “frozen”

during the end of Government budgetary period.

On commencement of the project the Bank was alerted by the Ministry of Finance and

the first tranche of the funds was requested. In January, 2008, a disbursement of

US$145,000.00 was made into the local bank account as an advance of project funds in

response to disbursement request from the Ministry of Finance. The NBD had

responded negatively to the request from the Ministry of Finance for the World Bank

(USD) account to be changed to an interest bearing account, because this facility is not

offered with foreign currency account, however, in light of the large sum of money and

potential interest which could be received, the Ministry of Finance pursued this matter

by direct negotiations.

By the end of August, 2008 early September, 2008, all requirements for the payment of

the EU contribution to the GSPTA were met. The EU – WB agreement was signed, the

GOCD – WB Agreement was signed for the World Bank administration of the project,

the EU transferred the first tranche of funds to the World Bank on behalf of the project,

and arrangements were made with the local bank (NBD) to open another USD account

for receipt and separate accounting of the EU funds. By February, 2009, no objections

was sought from the World Bank for an amount of approximately US$6,000.00 to be

allocated for project daily operations.

42

Trajectory delays

Whereas the project commenced on 19th

, September, 2007, funds under the EU

arrangement was only made available when the WB/EU Agreement was officially

signed on 30th

, September, 2008, one year later. The arrangement to utilize

Euro$526,000.00 was to finance the procurement of goods, consultant’s services and

for Training and Project Management. The end date of this agreement was 30th

, June,

2010.

There was another delay during the first year of the project when the original

reallocations made under the World Bank Credit Agreement was reorganized to reflect

removal of funds from one allocation to another to accommodate payments to be made

to UNCTAD under the respective fund allocation. The request was made on 08th

,

August, 2008 and approval was received that same year. The Table shows the initial

arrangement and the changes made to reflect that change.

Table showing original and changed reallocations Category Percentages

showing original

amount of

Financing

allocated (SDRs)

Percentage of

expenditures to

be financed

Changes made

to reallocation

with

percentages

Amount

modified

Variation

Goods for the Project

with the exception of

Parts 2.2.2, 3.1 and 5©

of the Project

$197,000

69% $78,000

-$119,000 -60%

Consultant services for

the Project with the

exception of Parts 2.2.2,

3.1 and 5© of the Project

$230,000

40% $414,000 $184,000 80%

Training for the Project

with the exception of

Parts 2.2.2, 3.1 and 5 of

the Project

$103,000

59% $38,000 -$65,000 -63%

Goods, consultant


part 2.2.2 of the Project

$120,000

100% $120,000 $0 0%

Goods, consultant


Part 3.1 of the Project

$350,000 100% $350,000 $0 0%

The Government of the Commonwealth of Dominica requested an extension of the

World Bank Growth and Social Protection Technical Assistance project due delays

caused by General Elections in December, 2009.

The delays resulted in the request for extension of the following consultancies:-

MIS consultancy

HR consultancy

43

Public Information Campaign

Modernization of the Registry consultancy

Project Audit

Extensions for both the EU and World Bank Credit Agreements were requested and

subsequently approved from 31st December, 2009 to 31

st December, 2010. Approval

was also received later in the year for the extension of the EU agreement from 30th

April, 2010 to 07th

July, 2010. This meant that the EU had extended the World

Bank/EU agreement to 31st

August, 2010 which only gave the Government an end of

withdrawal period up to 30th

April, 2010 (four months before the EU/WB agreement

closed). The Bank however, requested that the PCU make requests for all payments

made where counterpart Government funds were used to pay consultants and firms.

This replenishment request had to be done before the deadline date of 30th

June, 2010.

All replenishment requests made were approved and disbursed as submitted. As a

result of these delays project implementation was affected as follows –

Factors outside Government or Implementing Agency control

Approvals on Terms of References

Extension of the World Bank and EU Agreements

Lengthy procurement processes with the World Bank Procurement departments.

Serious delays in responding to approval to EU extension which led to the use

of counterpart funds.

Delays in the receipt of replenishments of counterpart funds utilized

Delays in the receipt of EU funding for various consultancies.

Factors subject to Government and Implementing Agency control

Lack of ongoing Project follow up in 2008, which led to most of the

deliverables being conducted in year two and three. Low level of project

implementation at commencement leading up to 2008.

Replacement of the new Project Coordinator/Procurement Officer

The replacement of Steering Committee members.

The Underestimated cost of the total project

Savings from various components also had to be utilized after receiving no

objections from the bank to have these activities completed.

Re-organization of Ministries/Departments and Corporate Plans due to the

Government elections held in December, 2009 during a critical stage of the

project.

Delays in approval of critical documents by relevant Government authorities for

project implementation – Proxy means test and NBIS implementation.

Delays in the approval of various legislations which led to delays in project

execution and implementation.

IT system difficulties – Eg. Smart Stream and emails.

Downtime when assistance from the ICT Unit was not forthcoming.

44

Delays when second approvals were not forthcoming from the Smart Stream

system.

Clarity in the procedures in the release of counterpart Government funding

Insufficient meetings between PCU/RMU throughout the life of the project – re

ongoing follow-ups.

Factors subject to the World Bank

Throughout the life of the project three Task Team Leaders provided guidance.

These transitions of the Task Team Leaders led to lapses in some aspects of the

project

Delays in responding on matters when the Task Team Leaders were out on

Mission

Extensive delays in receiving “No objections” to critical matters (Procurement,

TORs etc.)

Extensive delays in receiving approvals to EU and World Bank credit

agreements extensions

Major time lags in responding to approval of contracts (especially

Implementation of ASYCUDA World - UNCTAD) which caused consultancies

to be delayed even further and beyond the project time line.

As noted previously the project commenced in September, 2007. A new Project

Manager was recruited in December, 2008. The project experienced a lag time for

completion of project deliverables in 2008. As of that date, only eight (8-16%) out of

the total number of deliverables were ongoing to date. It was left up to the newly

appointed Project Manager to complete the remaining deliverables over a shortened

twenty-one (21) month period.

Table showing deliverables completed during the life of the project

Years

2007

2008

2009

2010

2011

Numbers

01 08 28 13 01

Percentages

2 16 56 26 2

45

0

10

20

30

40

50

60

2007 2008 2009 2010 2011

Deliverables completed

Percentage completed

Bar Graph 1 representing a pictorial view of the deliverables completed during the lifetime of the project

based on deliverables and percentages

Financial

The financial resources, which included funding from the World Bank, the Government

and the European Union, of the World Bank Growth and Social Protection Technical

Assistance project were used in its totality.

Three audits were done throughout the life of the project as follows (See Project Audit

section)

From September, 2007 to December, 2008

From January, 01st, 2009 to December, 31

st, 2009

From January, 01st, 2010 to January, 31

st, 2011 (due to delays with the UNCTAD

payment arrangement, the auditing of these expenditures were done in February,

2011 and accounted for in the Auditing period.

Expenditure in the World Bank project based on deliverables

As initially informed the total amount of resources used by the World Bank project was

to the tune of EC$7,502,867.00. This allowed for the expenditure on various

deliverables as shown above.

The Graph below shows the expenditure of the various sources of funds from 2007 to

2010 in EC$ (GoCD, European Union and World Bank)

46

0

500000

1000000

1500000

2000000

2007 2008 2009 2010

GoCD

EU

WB

GoCD

EU

WB

Table showing use of fund according to Agency

Year

2007

2008

2009

2010

Total

%

GoCD $37,579.00 $235,527.00 $171,409.00 $790,348.00 $1,234,863.00 14.9%

EU $0.00 $217,827.00 $858,011.00 $854,840.00 $1,930,678.00 25.7%

WB $15,261.00 $1,410,681.00 $1,356,793.00 $1,564,368.00 $4,347,103.00 57.9%

Total

$50,840.00

$1,864,035.00

$2,386,213.00

$3,199,779.00

$7,502,867.00

100%

The contracts were managed in a manner where the project was able to realize savings

to be used in other components.

Table showing use of funds by years as presented in the pie chart below

Year

2007

2008

2009

2010

Total funds

used

Total funds used $52,840.00 $1,864,035.00 $2,386,213.00 $3,199,779.00 $7,502,867.

00

Percentage used

0.7%

24.8%

31.8%

42.7%

100%

Pie chart representing use of the funds based on years

2007

2008

2009

2010

Slice 5

47

According to the figures above, you can see a marked increase in the expenditure of the

funds as time passed by. Only 0.7% of the funds were used in the year 2007, with an

increase to 24% in expenditure in the year 2008. There was a 7% further increase in

the use of the funds in the year 2009 to 31.8% and an even marked increase in of 42.7%

in the year 2010 by 10.9%.

Though the pie chart shows that the bulk of the funds were utilized in 2010, a small

portion of that amount was actually paid out in the year 2011 as a result of a few delays

which were experienced with the UNCTAD arrangement. Payments were made based

(to Price Waterhouse Coopers) based on activities completed before the deadline date

of 31st, December, 2010.

48

ASSESSMENT OF OUTCOME AGAINST AGREED OBJECTIVES

Evaluation of the Borrower’s Performance

During the preparation phase of the project, various team leaders from Government

departments met and processed the idea of this project document and sought financing

through three different sources of funds, the European Union, the World Bank and

counterpart funding from the Government of the Commonwealth of Dominica.

Throughout the life of the project, the process of implementation was carried through

the vetting of various Procurement and Implementation plans. These documents

provided a formal guide towards project implementation and helped the project staff

remained on course on a day to day basis. The Government team went through a major

understudy through the intervention of the World Bank team, where many short

meetings were held with the staff to guide the processes through which the project had

to operate. The project was guided by the Operations Manual, various Accounting

Guide documents and Procurement documents.

Lessons learnt

GoCD

The project highlighted the need for realistic budgeting during project design.

All aspects of the project must also be costed and all required allocations made.

Training in Project Management is required within the public Service

Government employees need to see the importance of project implementation

and ensure that all is in place to move the project forward as quickly as possible

in order to achieve the desired outcome within the stated project timeframe.

Greater levels of interest and commitment are required by Steering Committee

members to ensure effective project implementation.

The necessary legislative framework must be in place in a timely manner

All Ministries and Government employees who will be critically involved in the

Project needs to be informed officially. This will assist in the required interest

and buy-in which is required.

There should be a clear distinction/communication between the costs that are to

be supported by the Project Unit and those of the counterpart funds, so that

these items are properly budgeted and accounted for by the Project as opposed

to other sources

Due to the list of activities/deliverables and the inherent delays the project

lifetime should have been executed over a period of four rather than three years.

There needs to be team building at the early stages of the project that the Project

Unit builds upon.

The Project staff needs to be trained before commencement of the project to

prevent unnecessary delays due to the need to follow Banks procurement

procedures.

Project ownership is critical to the success of a project - This ownership has to

be done by the relevant departments and Ministries early in the Project so that

all continues to work as a team from inception to completion.

49

Evaluation of the Performance of the Bank, any Co-financiers, or of other

partners

Throughout the life of the project, Bank officials visited the Commonwealth of

Dominica to conduct reviews of the project on an ongoing basis. Various meetings

were planned with relevant Government Departments and Ministries.

The World Bank meetings took the form of the following:

To review the PCU project progress

To meet with various key consultants and Government employees to review the

progress of various deliverables.

To review any financial details as it related to project expenditure and provide

advise accordingly

To review the processing of documents and filing of the PCU filing processes.

To review the methods of Procurement based on the Bank’s procedures

To work with staff as it related to the Implementation processes and to provide

guidance as it related to bottlenecks etc.

To review and monitor the progress of indicators as it related to all deliverables

funded by the project.

Technical Advisors, who worked with the bank as consultants, visited the island

to conduct reviews on specific deliverables – Social Protection component,

Customs ASYCUDA World.

Aide Memoires were signed which spelt out certain decisions that were made

and any discussions for further follow up and possible discussions. These were

done on completion of the Mission’ visits. The last two mission’s visit did not

involve the signing of Aide Memoires.

The EU meetings took the form of the following:

To review the progress of the project based on details presented in the Financial

Monitoring Report (FMR).

To review the progress of the deliverables which were funded.

To monitor the Indicators related to specific deliverables.

Meetings were arranged with the local EU officials who provided guidance on

the use of funds especially as it related to the drawing down of funds for

implementation of other Government activities.

Meetings were held between the EU office official from Barbados and the

Registry Department to review the Registry indicator.

Lessons learnt

World Bank

More support in terms of ongoing follow-up from the Bank officials on a bi-

weekly basis with the Project Management department especially as it related to

the progress of the project. This would have enabled more frequent follow ups

and prevented some of the delays.

The Bank’s processes and policies are lengthy and very stringent and tended to

cause severe delays in project implementation.

50

There is a need to decrease the processing time for providing approvals and

especially when the Task Team Leader is out of state.

Measures should be put in place by the Bank to make the process more enabling

for quick project implementation as oftentimes the time frame of the projects

are usually short and a lot has to be completed in a very short space of time.

Facilitate quicker methods of communicating matters as it related to informing

the Project team on critical matters for continued project implementation.

The frequency with which Task Team Leaders are changed and assigned to the

project caused project delays especially at critical decision-making periods.

Training sessions should have been organized either online or otherwise on an

ongoing basis.

Ongoing feedback and support from the Task Team Leaders were favorable in

some occasions; however, Aide Memoires should form a critical document on

completion of all visits to document all decisions made and matters discussed

with relevant officials.

The World Bank needs to work in closer ties with the Government of Dominica

to ensure quick procurement, quick responding to critical matters, documented

Aide Memoires for all Missions’ visit for follow up etc.

Task Team Leader transition – There needs to be a smoother transition when the

Task Team Leader (TTL) is changed. The TTL transition impacted project

implementation and led to delays especially when critical decisions had to be

made on important matters (World Bank and EU extension requests) and

response from the World Bank was not forthcoming in a timely manner. This

resulted in delays in the use of funds, e.g – EU funds.

Description of the Proposed Arrangements for Future Operation of Projects

The following is a listing of proposed arrangements for the future

1. Liaise with relevant officials who are directly related with the project in terms

of obtaining the necessary approvals for legislations and regulations that could

have a major impact no project implementation.

2. Formation of cross section of committee.

3. More direct communication/interface with various officials from the Funding

Agency

4. Provide for all activities to be funded. This should be clearly articulated and

documented.

5. There should be allowances for contingencies.

6. Maintain effective communication with all key project staff.

7. Constant liaison with the Accountant General’s Office, Audit Department.

8. If the project includes an IT component and the ICT Unit is required to provide

support, the ICT Unit must be involved at an early stage.

9. The ICT Unit should have qualified and experienced persons to work on major

IT projects to prevent serious delays with project implementation.

10. Ongoing follow up meetings with respective Ministry/Department Heads should

be of critical importance.

51

ANNEX 6. COMMENTS OF COFINANCIERS AND OTHER PARTNERS/STAKEHOLDERS

The Dominica Private Sector & Growth Programme is a hybrid between a General and

Sectoral Budget Support Programme. During the first phase of the programme the

Government wished to use EC financing through the budget support modality to create

and enabling environment for investment, however a national investment strategy had

not yet been developed. The National Strategy of the Government – Growth and Social

Protection Strategy (GSPS) – which aims to foster private sector growth by improving

the business climate and enhancing physical infrastructure – was considered the most

appropriate strategy for the programme. Therefore, the general condition is linked to

progress in the GSPS and not a private sector strategy.

The overall objective of the programme is to reduce poverty through sustained

economic growth and increased competitiveness and economic opportunities. The

specific objective is to support the Government’s effort to improve the investment

climate to foster private sector-led growth, notably through the further development and

implementation of a National Investment Strategy (NIS).

The Financing Agreement (FA) was signed on 9/11/2007 for a total amount of € 10.78

million and its operational implementation phase came to closure on 31 December 2010.

A rider no.1 to increase the financial ceiling to reflect the 2006 Flex allocation of €1.02

million was signed in December 2007. A Rider No. 2 to Financing Agreement to adapt

the payment of the Vulnerability Flex and Flex allocations to the Financing Agreement

was signed by both parties in May 2010. The indicators for variable tranches were

initially set in the Annex D of the Financing Agreement, and modified trough two

exchange of letters, first in June 2009 and second in October 2010.

Therefore, the total amount of this programme is €17.1 million which is comprised of a

budget support component of €16.4 million and complementary support of €646,000.

The complementary support is comprised of €526,000 for technical assistance (TA) to

the World Bank (WB) GSPTAC programme and €120,000 for monitoring and

evaluation.

With respect to progress achieved in recently, especially in the area of private sector

development which is the focus of this budget support programme, the GSPS has

fostered as priority the strengthening of an environment conducive to private sector

investments. With the support of the EU and the World Bank Group, simultaneous

efforts are ongoing on many fronts to facilitate the effectuation of this outcome.

Various administrative and structural changes have been pursued in land administration,

tenancy and registration; Customs; company registration; and investment facilitation

and promotion through the WB GSPTAC programme, co-financed with the EC that

finalized activities in December 2010. Specifically, the following results have been

achieved;

Civil Service Reform; Implementation of manpower assessment as well as

preparation of corporate plans and organizational charts for each line ministry

52

Strengthening of Customs; The Customs Bill was enacted on December 2010.

ASYCUDA World system was launched in July 2010. Staff training and

computerization of the customs department has been provided in support of the

introduction of the new system.

Modernization of Registry; Full deployment of a state-of-the-art land

information system for public sector land introduced in 2008.

Strengthening of Fiduciary Capacity; Support to complete the Procurement

Legislation.

Improving the Investment Climate; Under this project a new institutional

structure for the national development corporation was developed. Two

agencies have been established and are operational. Discover Dominica

Authority (DDA) and Invest Dominica Authority (IDA). The National

Investment Strategy (NIS) has been adopted. However it has not been placed in

the Government's website yet.

The EU Delegation has been regularly receiving status reports of the WB GSPTAC,

some of them constitute the evidence for backing the fulfilment of the variable tranche

indicators. A dialogue with the Government and the World Bank on progress on EC

budget support variable tranche indicators took place on December 2010 during the

Budget Support Review.

53

ANNEX 7. LIST OF SUPPORTING DOCUMENTS

Agreed Minutes of Negotiations, October 27, 2006

Aide Memoires, Back-to-Office Reports, and Implementation Status and Results

Reports (ISRs), all

Commonwealth of Dominica: Medium Term Growth and Social Protection Strategy

Paper (April 2006).

Community Development, Gender Affairs and Information of the Government of the

Commonwealth of Dominica. CARICAD. March 2006.

Country Assistance Strategy of the Organization of East Caribbean States for FY06-09,

Report No. 33118

Dominica: Country Poverty Assessment, Government of the Commonwealth of

Dominica, Caribbean Development Bank, 2003.

European Union Co-financing Trust Fund, September 2007

Financing Agreement No. 4264-DOM, Supplemental Letter: Monitoring Indicators,

March 14, 2007

Implementation Completion and Results Report – Guidelines, August 2006, Updated

Nov. 10, 2010

Minutes of the Project Concept Note Review Meeting, February 13, 2006

Project Appraisal Document, October 6, 2006

Project Concept Note, January 13, 2006

Results of the Quality Enhancement Review, September 9, 2006

The Investor Roadmap and Sectoral Analysis of Dominica Caribbean Trade and

Competitiveness. Development Program (C-TRADECOM) U.S. Agency for

International Development (USAID) October 15, 2004.

"Towards a New Agenda for Growth", April 2005; Dominica: OECS Fiscal Issues

"Policies to Achieve Fiscal Sustainability and Improve Efficiency and Equity of Public

Expenditures. June 2005.

S A I N TS A I N TJ O H NJ O H N

S A I N TS A I N TP E T E RP E T E R

S A I N TS A I N TA N D R E WA N D R E W

S A I N TS A I N TJ O S E P HJ O S E P H

S A I N TS A I N TD AD AV I DV I D

S A I N TS A I N TG E O R G EG E O R G E

S A I N TS A I N TPPA U LA U L

S A I N TS A I N TPPAAT R I C KT R I C K

SAINTSAINTMARKMARK

SAINTSAINTLUKELUKE

MorMorneneDiablotinsDiablotins(1421 m)(1421 m)

MorMorneneTTrois Pitonsrois Pitons(1402 m)(1402 m)

MorMorneneMacaqueMacaque(1221 m)(1221 m)

WWattattMountainMountain(1224 m)(1224 m)

S A I N TJ O H N

S A I N TP E T E R

S A I N TA N D R E W

S A I N TJ O S E P H

S A I N TD AV I D

S A I N TG E O R G E

S A I N TPA U L

S A I N TPAT R I C K

SAINTMARK

SAINTLUKE

Portsmouth

Glánvillia

Colihaut

Morne Raquette

Salisbury

Saint Joseph

Mahaut

Pointe Michel

Soufrière

Berekua

La Plaine

Rosalie

Castle Bruce

Salibia

Marigot

Wesley

Calibishie

Vieille Case

Scotts Head

Massacre

ROSEAU

Pica rd

M acou

cher

i

Layou

Belfa st

Massacre

Rosea

u

Perd

uTe

mps

Rosalie

Belle Fi l

le

Pagua

Me lville Hall

TweedH

amp

st eadPrince

Rupert Bay

Douglas Bay

Soufière Bay

GrandBay

RosalieBay

PetiteSoufrière Bay

Grand Marigot Bay

Marigot Bay

Pagua Bay

CaribbeanSea

D o m i n i c a P a s s a g e

M a r t i n i q u e P a s s a g e

Point Ronde

Prince RupertBluff Point

Point Ronde

Scotts HeadPointe des Fous

CaribPoint

Point Saint Jean

Point Giraud

Rosalie Point

Pointe à Peine

Pagua Point

CromptonPoint

Carib PointCape Capucin

MorneDiablotins(1421 m)

MorneTrois Pitons(1402 m)

MorneMacaque(1221 m)

WattMountain(1224 m)

15°30'15°30'

15°15'15°15'

61°30'

61°30' 61°45'

DOMINICA

This map was produced by the Map Design Unit of The World Bank. The boundaries, colors, denominations and any other informationshown on this map do not imply, on the part of The World BankGroup, any judgment on the legal status of any territory, or anyendorsement or acceptance of such boundaries.

0 1 2 3 4

0 1 2 3 4 5 Miles

5 Kilometers

IBRD 33397

DECEMBER 2004

DOMINICASELECTED CITIES AND TOWNS

NATIONAL CAPITAL

RIVERS

MAIN ROADS

PARISH BOUNDARIES

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