The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Competitiveness and Enterprise Development Project (CEDP) (P130471) EASTERN AND SOUTHERN AFRICA | Uganda | Finance, Competitiveness and Innovation Global Practice | IBRD/IDA | Investment Project Financing | FY 2013 | Seq No: 20 | ARCHIVED on 18-Sep-2023 | ISR56907 | Implementing Agencies: Government of Uganda, Ministry of Finance, Planning and Economic Development, Ministry of Lands, Housing and Urban Development, Private Sector Foundation Uganda Key Dates Key Project Dates Bank Approval Date: 09-May-2013 Effectiveness Date: 06-Jun-2014 Planned Mid Term Review Date: 25-Jul-2016 Actual Mid-Term Review Date: 30-Aug-2016 Original Closing Date: 31-Mar-2019 Revised Closing Date: 30-May-2024 pdoTable Project Development Objectives Project Development Objective (from Project Appraisal Document) The development objective of the project is to improve the competitiveness of enterprises in Uganda by providing support for: (i) the implementation of business environment reforms, including the land administration reform and (ii) the development of priority productive and service sectors. Has the Project Development Objective been changed since Board Approval of the Project Objective? Yes Board Approved Revised Project Development Objective (If project is formally restructured) To support measures that facilitate increased private sector investment in the tourism sector and strengthen effectiveness of the land administration system. Components Table Name Land Administration Reform:(Cost $107.70 M) Business Registration and Business Licensing Reforms:(Cost $10.00 M) Tourism Development Initiatives:(Cost $68.10 M) Matching Grant Program for MSMEs:(Cost $8.00 M) Project Implementation:(Cost $6.00 M) Overall Ratings Name Previous Rating Current Rating Progress towards achievement of PDO Moderately Satisfactory Moderately Satisfactory Overall Implementation Progress (IP) Moderately Satisfactory Moderately Unsatisfactory Overall Risk Rating Moderate Substantial Implementation Status and Key Decisions Momentum for implementation in the tourism component continues to grow and progress is seen in the processing and delivery of key activities. Progress in the land component is stalled as key contracts for the component are yet to be signed. Speedier implementation of approved activities is needed to further advance progress towards key results. 9/18/2023 Page 1 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) The tourism component disbursement rate is at 59% and the civil works are delayed significantly. The civil works under tourism are the activities most at risk. A highly ambitious civil works’ roadmap has been provided by the PIU. It appears unlikely that the planned activities can be concluded in time, given the past performance where there have been delays in procurement processes and during construction. It would be advisable to revise the civil works planned under the component and reallocate financing to the activities that are more advanced. For activities that may be initiated during the Project but are not completed within the timeline, the government would need to provide the remaining budget for completion. The Tourism Enterprise Support Fund (TESF) was successfully launched, and more than 200 applications were received for the first call for proposals. This high demand highlights the need for technical and financial support for tourism enterprises in Uganda. The review of the 233 applications was undertaken and 41 were successful and awarded grants by the Grants Review Committee. A total of 19 applicants have since signed agreements for implementation of activities. The first call for proposals did not meet its objectives in terms of reach, geographical distribution and sector impact. The TESF manual and criteria are being redesigned to enhance their effectiveness and national outreach and ensure value for money in collaboration with an international consultant. Since the last ISM, contracting and procurement for the land component advanced considerably with almost USD 40m of funds (78 % of the Component amount) at an advanced stage of procurement though contracts have not yet been signed. As the previously agreed end of April 2023 deadline to finalize key contracts was not met, the PIU conducted negotiations for key contracts such as Systematic Land Adjudication and Certification (SLAAC), National Land Information System (UgNLIS), Land Valuation Management System (LAVMIS) and Ugandan Geodetic Reference Framework (UNGRF) to adjust their duration and scope to enable their completion before Project closing date. The SLAAC activity is advancing slowly, and achievement of 800,000 titles is at high risk of non-completion. The recruitment and deployment of the Data Processing Center (DPC) staff to be deployed in the Department of Survey and Mapping and into the Ministry Zonal Offices (MZOs) is delayed, which also explains low progress in the ongoing SLAAC activity with only 10,000 titles issued out of 800,000 expected by the end of the Project. The indicators in the results framework are updated annually in June and updates are provided where available in this ISR. Risks Systematic Operations Risk-rating Tool Risk Category Rating at Approval Previous Rating Current Rating Political and Governance -- Substantial Substantial Macroeconomic -- Moderate Moderate Sector Strategies and Policies -- Moderate Moderate Technical Design of Project or Program -- Moderate High Institutional Capacity for Implementation and -- Moderate Substantial Sustainability Fiduciary -- Moderate Substantial Environment and Social -- Moderate Substantial Stakeholders -- Moderate Substantial Other -- Moderate Moderate Overall -- Moderate Substantial Results PDO Indicators by Objectives / Outcomes 9/18/2023 Page 2 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Strengthen effectiveness of the land administration system IN01312674 ►Average days taken to verify ownership of property (Days, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 3.00 1.80 1.80 1.00 Date 01-Mar-2022 13-Dec-2022 11-Sep-2023 31-May-2024 Partially achieved by 40%. MoLHUD to finalize MZOs efficiency of operations assessment and come up Comments: with action plan on how this indicator could be achieved prior to the Project Closing date. IN01312676 ►Percentage of lodged transactions completed (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 51.00 32.00 41.00 75.00 Date 01-Mar-2022 21-Jun-2022 11-Sep-2023 31-May-2024 Not achieved. Percentage of completed transactions decreased since COVID, when backlog got accumulated. MoLHUD to finalize MZOs efficiency of operations assessment and come up with action Comments: plan on how this indicator could be achieved prior to the Project Closing date IN01312678 ►Average days taken to transfer property (Days, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 52.00 32.00 32.00 15.00 Date 01-Mar-2022 30-Jun-2022 11-Sep-2023 31-May-2024 Partially achieved at 45.9%. MoLHUD to finalize MZOs efficiency of operations assessment and come Comments: up with action plan on how this indicator could be achieved prior to the Project Closing date Reduction in time (days) and cost to register a business (as % of income per capita) IN01312639 ►Reduction in number of days to register a business (Days, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 33.00 24.00 20.00 5.00 Date 30-Jun-2010 20-Sep-2021 11-Sep-2023 30-May-2022 Partially achieved. Achievement rate 46.4%. PSFU to provide updated value for the indicator. Comments: IN01312673 ►Cost to register a business (as % of income per capita) (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target 9/18/2023 Page 3 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Value 76.70 40.50 40.50 50.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Outpaced its end target value. Achievement rate 135.5%. Comments: Increased tourist arrivals IN01312638 ►Number of tourism arrivals (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 945,000.00 473,085.00 814,508.00 818,579.00 Date 30-Jun-2010 20-Sep-2021 11-Sep-2023 31-May-2024 Substantially achieved at 99%. The end target has been set up lower than the baseline to factor in Covid19 pandemic and corresponding dramatic decrease of tourists during 2020-2021. Tourism Comments: sector is experiencing a steady recovery in 2023. There should be a discussion with PSFU PIU whether to adjust the baseline or the target value. Tourism sector employment IN01312672 ►Maintain tourism sector employment (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 225,300.00 386,200.00 432,544.00 615,564.00 Date 30-Jun-2010 20-Sep-2021 11-Sep-2023 31-May-2024 Substantially achieved at 70%. The Tourism Enterprise Support Fund has benefitted a number of SMEs, Comments: and therefore supporting employment in the Sector. Increase in exports of non-traditional prodcuts IN01312640 ►Increase in exports of non-traditional products (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 10.70 10.70 10.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Achieved. Achievement rate 107%. Comments: Direct project beneficiaries IN01312671 9/18/2023 Page 4 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) ►Dirrect project beneficiaries (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 287,632.00 689,332.00 3,300,000.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Achievement rate at 20.89% for the indicator overall. There have been some inconsistencies in the report provided by the PSFU regarding this indicator. The sum of the reported sub-indicator has been retained for the value. For sub-indicator on direct beneficiaries from tourism activities, achievement rate is 28%. Most activities that involve direct project beneficiaries are yet to start. Comments: For sub-indicator on direct beneficiaries from land component activities achievement rate is 17.2% The target could only be achieved if SLAAC activities currently still under procurement and Solicitor General review, are launched and swiftly Implemented. This output is at high risk of non-achievement due to the very limited time remaining until the Project Closing date of May 30, 2024. IN01312675 Direct beneficiaries as a result of the tourism component activities (Number, Custom Breakdown) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 287,000.00 292,444.00 1,000,000.00 Date 29-Jun-2010 10-May-2022 11-Sep-2023 30-May-2024 IN01312677 Direct beneficiaries with use or ownership rights recorded as a result of the project (Number, Custom Breakdown) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 0.00 396,888.00 2,300,000.00 Date 10-May-2022 10-May-2022 11-Sep-2023 30-May-2024 Overall Comments PDO Both PIUs should endeavor to clarify methodology of indicators’ measurement and improve consistency and frequency of their reporting. Some of the indicators have not been updated since 2020. As of September 11, 2023 out of 9 PDO-level indicators only 2 are achieved and 2 are substantially achieved with a good probability to achieve 8 out of 9 by the Project Closing date. The indicator on direct Project beneficiaries cannot be achieved without significant acceleration of SLAAC activity implementation. The Project so far achieved 4 Intermediate Results Indicators (IRI) and substantially achieved 3, out of 16. Several of the IRI for land component are at high risk of not being achieved, considering current slow progress of the SLAAC activity and delay with recruitment of additional contractors' and consultants. Intermediate Results Indicators by Components Land Administration Reform IN01312679 ►Land parcel with use or ownership rights recorded as a result of the project (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 66,148.00 66,148.00 800,000.00 9/18/2023 Page 5 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Date 30-Jun-2010 30-Jun-2021 11-Sep-2023 30-Jun-2024 Partially achieved at 8%. The target could only be achieved if SLAAC activities currently under procurement or with Solicitor General for the review, are launched and swiftly implemented. This output is Comments: at high risk of non-achievement due to the very limited time remaining until the Project Closing IN01312684 Land parcels with use/ownership rights registered as a result of project-female individually or jointly (Number, Custom Breakdown) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 12,483.00 2,203.00 280,000.00 Date 30-Jun-2010 30-Jun-2021 11-Sep-2023 31-May-2024 IN01312685 ►Number of communal land Associations formalized and registered (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 606.00 644.00 1,200.00 Date 30-Jun-2010 30-Jun-2021 11-Sep-2023 31-May-2024 Partially achieved at 53.6% The target can still get achieved before the Project Closing date. Discussion on methodology of registering land in the ownership of the CLA should be clarified by MoLHUD to ensure Comments: that individual rights are not compromised and land title or CCO registered into collective tenure can be pragmatically used for subsequent transactions. IN01312690 ►Target land area with use or ownership rights recorded as a result of project (Hectare(Ha), Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 63,077.00 62,204.00 571,000.00 Date 30-Jun-2010 30-Jun-2021 11-Sep-2023 30-Jun-2024 Comments: Par tiall y ach iev ed by 10. 9%. The targ et cou ld onl y be ach iev 9/18/2023 Page 6 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) ed if SL AA C acti viti es curr entl y und er pro cur em ent or Soli cito r Ge ner al revi ew, are lau nch ed and swif tly Imp lem ent ed. Thi s out put is at hig h risk of non - ach iev em ent due to the 9/18/2023 Page 7 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) ver y limi ted tim e rem aini ng unti l the Pro ject Clo sin g dat e. The end target has been revised to 571,000 to align with RF as per latest restructuring. The former end target of 752,000 was an old end target which was forgotten to be modified. IN01312692 ►Percentage of customers reporting satisfaction with land registration services (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 80.40 60.10 70.00 Date 30-Jun-2010 30-Jun-2021 11-Sep-2023 30-May-2022 Substantially achieved by 85.8% as measured in June 2021, to be reassessed during open registry Comments: days which will be implemented across the country between September 2023 and Project Closing date IN01312694 ►Land parcels with use or ownership rights registered as a result of the project (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 400.00 400.00 10,000.00 700,000.00 Date 01-Mar-2022 01-Mar-2022 11-Sep-2023 31-May-2024 Very slow processing and issuance pace of the Titles, needs to be scaled up twentyfold to enable Comments: indicator achievement before the Project Closing Date. IN01312696 ►Percentage of reported land disputes under SLAAC that have been resolved (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 88.00 88.00 88.00 95.00 Date 01-Mar-2022 01-Mar-2022 11-Sep-2023 31-May-2024 9/18/2023 Page 8 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Not achieved. The MoLHUD should strengthen Alternative Dispute Resolution Mechanism to be utilized during SLAAC implementation and streamline and eventually decentralize handling of land dispute cases Comments: within the MoLHUD IN01312697 ►Disposal rate of land cases (percentage) (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 26.00 26.00 73.00 70.00 Date 01-Mar-2022 01-Mar-2022 11-Sep-2023 31-May-2024 Achievement rate 106.8% Comments: Business Registration and Business Licensing Reforms IN01312680 ►Number of registered businesses on which data have been entered into the online business register (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 0.00 0.00 150,000.00 Date 25-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Not achieved. The PSFU to collect updated data and to come up with a strategy to achieve this indicator Comments: before Project Closing Date. IN01312686 ►Number of URSB Staff and other agencies trained in business registration and business licensing new procedures (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 232.00 232.00 150.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Achieved. Outpaced end target by 115%. Comments: Tourism Development Initiatives IN01312681 ►Number of staff at all levels across MoTWA who completed project-provided training in tourism sector issues (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 183.00 183.00 130.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Achievement rate of 140.7%. Comments: IN01312683 ►Number of external industry and educational bodies that have accredited UHTTI (Number, Custom) 9/18/2023 Page 9 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 1.00 1.00 3.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2024 Partially achieved at 33%. UHTTI needs to connect with other external bodies in the industry including Comments: NCHE for additional accreditation part from Salzburg hotel institute, Austria. IN01312687 ►Number of new Tourism MSMEs (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 94.00 94.00 125.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2024 Substantially achieved by 75%. Comments: The end target has been revised to 125 to align with last restructuring. IN01312689 Number of female-owned new tourism MSMEs (Number, Custom Breakdown) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 31.00 31.00 40.00 Date 30-Jun-2010 30-Jun-2021 11-Sep-2023 30-May-2024 IN01312691 ►Additional private investments in tourism (Amount(USD), Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 0.00 0.00 10,000,000.00 Date 01-Mar-2022 01-Mar-2022 11-Sep-2023 31-May-2024 Not achieved. Achievement rate 0%. High risk of not being achieved since the number of IDDPs were reduced from 3 to 1 and in addition, the only IDDP is not yet completed. PIU needs to speed up Comments: completion of IDDP and work with UIA IN01312693 ►Number of tourism enterprises supported through project activities (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 0.00 91.00 200.00 Date 01-Mar-2022 01-Mar-2022 11-Sep-2023 31-May-2024 Partially achieved by 45%. There is potential of greater achievement by May 2024. The Tourism Enterprise Support Fund is launched. UWA and UWEC have rolled out support to CEs. Comments: Gender-disaggregated sub-indicator is partially achieved by 10%. Implementation of TESF should help to attain its targets. IN01312695 Number of tourism enterprises supported through project activities, of which women-led (cumulative) (Number, Custom Breakdown) 9/18/2023 Page 10 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 0.00 8.00 80.00 Date 01-Mar-2022 01-Mar-2022 11-Sep-2023 31-May-2024 Matching Grant Program for MSMEs IN01312682 ►Number of new employees hired by MSMEs benefitting from the matching grant facility (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 7,801.00 2,460.00 2,460.00 11,000.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Partially achieved by 25%. PSFU to closely monitor status and prepare strategy how this indicator could Comments: be achieved before Project Closing date. IN01312688 ►Increase in sales of firms supported under the matching grants facility (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 17.70 17.70 10.00 Date 30-Jun-2010 29-May-2020 11-Sep-2023 30-May-2022 Achievement rate of 177 % far surpassed end target. Economic recovery of Tourism sector after Covid Comments: was faster than had been expected. Performance-Based Conditions IN01312698 ►PBC 1 Progress is made in the enhancement and automation of the NLIS (Text, Output, 7,000,000.00, 28.57%) Baseline Actual (Previous) Actual (Current) May 2024 Creation of a module in Creation of a module in the NLIS for uploading the the NLIS for uploading CCOs, CLAs, SMS Module for uploading the the CCOs, CLAs, SMS notification service, and Value CCOs and CLAs not -- notification service, and web portal access for present web portal access for MDAs and the public has MDAs and the public been completed and verified Date -- 01-Mar-2022 11-Sep-2023 -- 9/18/2023 Page 11 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) IN01312699 ►PBC 2 Physical Development Plans (PDP) for rural and peri-urban parishes developed. (Text, Outcome, 8,000,000.00, 0.00%) Baseline Actual (Previous) Actual (Current) May 2024 72 PDPs are completed, 72 new parish corresponding report physical Value No PDPs developed No PDPs developed should be submitted to development plans IVA for verification before are integrated into September 30, 2023. the NLIS Date -- 06-Feb-2020 11-Sep-2023 -- IN01312700 ►PBC 3 Land Titling Scaled Up through Systematic Land Adjudication and Certification including issuing new land titles to women individually or jointly. (Text, Outcome, 7,000,000.00, 0.00%) Baseline Actual (Previous) Actual (Current) May 2024 (a) 460,000 new parcels have been adjudicated and demarcated out 10,000 titles registered in of which 178,000 system and issued to the are for women beneficiaries. The individually or jointly 1,200 titles registered in 1,200 titles registered in Value corresponding report (US$1m) system system should be submitted by (b) 200,000 MoLHUD to IVA by new titles registered September 30, 2023. in the system out of which 80,000 are for women individually or jointly. (US$ 1m) Date -- 06-Feb-2020 11-Sep-2023 -- IN01312701 ►PBC 4 Uganda Hotel and Tourism Training Institute (UHTTI): Sign a Cooperation Agreement between an International Accredited Hotel, Training and Management Institution and MoTWA, to maintain, invest and oper (Text, Intermediate Outcome, 9,000,000.00, 0.00%) Baseline Actual (Previous) Actual (Current) May 2024 UHTTI has commenced its Cooperation agreement is No signed agreement in No signed agreement in operation by in place, but not yet Value place and UHTTI is not place and UHTTI is not recruiting and verified. The UHTTI is not operational operational training its first operational batch/cohort of students. Date -- 06-Feb-2020 11-Sep-2023 -- IN01312702 9/18/2023 Page 12 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) ►PBC 5 UWRTI: Training Agreement with an international training partner executed and International standard training delivered. (Text, Intermediate Outcome, 5,000,000.00, 60.00%) Baseline Actual (Previous) Actual (Current) May 2024 Cooperation agreement Cooperation agreement signed with an signed with an international accredited international accredited hotel training and Value No agreement in place hotel training and management -- management institution in June 2021. institution This DLI is achieved and verified. Date -- 30-Jun-2020 11-Sep-2023 -- IN01312703 ►PBC 6 Uganda Museum: Sign a Partnership Agreement with an international museum (Text, Intermediate Outcome, 9,000,000.00, 66.67%) Baseline Actual (Previous) Actual (Current) May 2024 In May 2021 partnership agreement has been No partnership agreement Partnership Agreement Value signed. This achievement -- in place signed has been verified by the IVA. Date -- 30-Jun-2021 11-Sep-2023 -- Data on Financial Performance Disbursements (by loan) Project Loan/Credit/TF Status Currency Original Revised Cancelled Disbursed Undisbursed % Disbursed P130471 IDA-52690 Closed USD 100.00 100.00 0.00 92.64 0.00 100% P130471 IDA-65380 Effective USD 99.80 99.80 0.00 52.36 44.98 54% Key Dates (by loan) Project Loan/Credit/TF Status Approval Date Signing Date Effectiveness Date Orig. Closing Date Rev. Closing Date P130471 IDA-52690 Closed 09-May-2013 31-Jan-2014 06-Jun-2014 31-Mar-2019 31-May-2022 P130471 IDA-65380 Effective 02-Mar-2020 09-Nov-2020 06-Apr-2021 31-May-2022 30-May-2024 Cumulative Disbursements 9/18/2023 Page 13 of 14 The World Bank Implementation Status & Results Report Competitiveness and Enterprise Development Project (CEDP) (P130471) Restructuring History Level 2 Approved on 26-Feb-2019 ,Level 2 Approved on 26-May-2022 Related Project(s) P169435-COMPETITIVENESS AND ENTERPRISE DEVELOPMENT PROJECT 9/18/2023 Page 14 of 14