Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) Report Number: ICRR0023663 1. Project Data Project ID Project Name P151281 China Minamata Convention on Mercury Country Practice Area(Lead) China Environment, Natural Resources & the Blue Economy L/C/TF Number(s) Closing Date (Original) Total Project Cost (USD) TF-A3066 30-Apr-2021 7,739,733.36 Bank Approval Date Closing Date (Actual) 09-Sep-2016 30-Oct-2022 IBRD/IDA (USD) Grants (USD) Original Commitment 8,000,000.00 8,000,000.00 Revised Commitment 7,739,733.36 7,739,733.36 Actual 7,739,733.36 7,739,733.36 Prepared by Reviewed by ICR Review Coordinator Group Ebru Karamete Fernando Manibog Avjeet Singh IEGSD (Unit 4) 2. Project Objectives and Components DEVOBJ_TBL a. Objectives The same project development objectives (PDOs) were used in the Grant Agreement (page 5) and in the Project Appraisal Document, page 13; which were: “to: (a) develop a national strategy on mercury and related action plans, and (b) improve China’s mercury management capacity and readiness to implement this strategy in the project provinces”. This was a Global Environment Facility (GEF) financed project and the global environment objectives were identical to the PDO. Page 1 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) b. Were the project objectives/key associated outcome targets revised during implementation? No c. Will a split evaluation be undertaken? No d. Components The project had three components: 1. Development of National Strategy and Sectoral and Provincial Action Plans (total appraisal amount: US$4.72 million, actual amount: US$3.96 million). This component aimed at delivering the National Mercury Strategy and action plans related to: (a) mercury supply sources and trade; (b) mercury added products; (c) industrial point sources (coal-fired power plants, coal-fired industrial boilers, municipal solid waste and hospital waste, cement clinker production, and non- ferrous metals smelting); and (d) waste and contaminated sites. Cross-cutting elements were planned to address (a) environment and health monitoring; (b) monitoring and management of social impacts; and (c) research and development. The project aimed to support stakeholder engagement activities throughout and also development of specific action plans in the pilot provinces of Guizhou, Hunan and Shaanxi. The Ministry of Environmental Protection (MEP)/Foreign Economic Cooperation Office (FECO) were to work closely with industry associations and other stakeholders to deliver analytical reports and proposals constituting the various elements of a comprehensive national strategy. 2. Capacity Strengthening for Mercury Management and Risk Assessment (total appraisal amount: US$10.48 million, actual amount: US$15.90 million). This component aimed to build capacity for mercury management in the MEP, Department of Environmental Protection (DEP) in the three pilot provinces and other stakeholders through targeted activities and establishing some of the building blocks that will support China’s long-term environmentally sound management of mercury, and mercury reduction and phase-out efforts. Activities would include (a) the development of a National Mercury Management Information System (MIS), tested first in the pilot Provinces; (b) assessment of mercury management and recycling technologies and practices in relevant sectors; (c) upgrade of the provincial environmental analytical laboratory of each participating province, and training and inter-laboratory comparison and knowledge sharing; and (d) environmental risk assessment of selected mercury contaminated sites to improve understanding of the scope and impact of mercury contamination in China. 3. Project Management (total appraisal amount: US$0.80 million, actual amount: US$0.65 million). This component financed project management and implementation support activities, including coordination with relevant stakeholders, at the national level and the project provinces. e. Comments on Project Cost, Financing, Borrower Contribution, and Dates Page 2 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) Project Cost. Project cost planned at appraisal was US$ 16 million, and the actual cost at closing was US$ 20.64 million (129 percent of the planned amount). Financing. The project was financed by a grant from GEF (TF-A3066). The planned amount at appraisal was US$ 8 million and actual amount at closing was US$ 7.74 million. Borrower Contribution. The borrower contribution planned at appraisal was US$ 8 million and the actual amount was US$12.9 million. The ICR did not provide a reason why Borrower contribution got increased. Dates: The project was approved by the Board on September 9, 2016, and became effective about five months later February 6, 2017. The original closing date of April 30, 2021, was extended for 18 months to October 30, 2022, based on delays due to Covid -19 and initial procurement delays. Restructuring: The project went through a level II restructuring on Oct 29, 2020, to extend the project closing for 18 months and to finalize the remaining project activities mainly due to delays from the impact of Covid-19 pandemic, in addition to delays caused by lengthy procurement processes at the start of the project and lack of experience of FECO staff on World Bank procurement processes. 3. Relevance of Objectives Rationale Country and Sector Context. As of 2013, China was estimated to be the biggest emitter of atmospheric mercury in the world, accounting for about one third of global emissions. Mercury waste and emissions left portions of the Chinese population at risk of dangerous exposure to mercury. In the same year, the Minamata Convention on Mercury was adopted globally to protect human health and the environment from anthropogenic emissions and releases of mercury and its compounds. China became a signatory to the Convention in 2013 and ratified it in 2016. Reducing exposure to mercury was therefore a high priority for the Chinese Government. China was working to meet its Convention commitments, including the creation of a Minamata Initial Assessment, along with a review of China’s policies related to mercury reduction. An overarching and comprehensive understanding of mercury emission and use in the country was needed as per the requirements of the convention. The use of mercury in China was highly complex and included in many industrial processes in many sectors over a wide geographical spread. Efforts to understand, map, and monitor mercury use in the country were difficult. There was a noted lack of data on mercury mines, recycling facilities, and information on mercury trade at both the country and local levels. Methods for estimating emissions remained very basic and were not calibrated for local conditions. China also lacked policy and strategy documents to evaluate the benefit-cost ratio and effectiveness of various mercury control measures along with policies that would translate these measures into action (ICR, page 5). Relevance to Government Priorities and Strategies. The PDO remains relevant to China’s 14th Five- Year Plan (2021–25), which aims to reduce air, water, and soil pollution through its goal to “accelerate the green transformation of the development model.” This goal includes specific targets for “clean production transformations” of the cement clinker and non-ferrous industries, both of which are specifically addressed by the project. The plan also aims to improve coordination and governance of pollution control, both of which are improved by the national strategy component of the project. Page 3 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) Relevance to World Bank Strategies. The PDO was aligned to the World Bank Group’s Country Partnership Strategy for China FY2013–16 (Report No. 67566), which included an outcome on ‘Supporting Greener Growth’, of which one sub-outcome was ‘Demonstrating Pollution Management Measures’. Under this outcome, the World Bank was supporting the reduction in air pollution and hazardous waste and improving environmental governance. The PDO remains aligned with the World Bank Group’s Country Partnership Framework (CPF) for the People’s Republic of China FY2020–2025, (Report No. 117875-CN). One of the three main areas of engagement in the CPF is “promoting greener growth including reducing air, soil, water pollution,” which the project supported by promoting an enabling environment for China to reduce air, soil, and water pollution from mercury. In addition, cooperation on global knowledge and development, which is a cross-cutting theme in the CPF, was supported by helping China to report on mercury emissions and releases to the Minamata Convention. The project was in line with the CPF goal to support China’s contribution to global public goods, as mercury can be emitted into the atmosphere, be built into products sold through regional and global supply chains and accumulate in fish and sediments far from its waste source. The project also supported minimizing greenhouse gas emissions. The PDO was aligned with GEF priorities and strategies; mercury reduction was a key component of the programming directions for the sixth GEF replenishment phase, 2014–2018. As part of the financial mechanism of the Minamata Convention, GEF provides financial support to eligible countries, including China, to reduce mercury use worldwide. The GEF-6 Chemicals and Waste focal area had an objective to ‘develop the enabling conditions, tools and environment for the sound management of harmful chemicals and wastes’. The project has high relevance to the current strategy for the GEF-8 replenishment phase (2022–2026). GEF-8’s Chemicals and Waste focal area has an objective that aims at the “creation, strengthening and supporting the enabling environment and policy coherence to transform the manufacture, use and sound management of chemicals and to eliminate waste and chemical pollution.” Mercury continues to be a GEF priority, as GEF remains one of the few multilateral sources of funding for the Minamata Convention and mercury reduction in general. Rating Relevance TBL Rating High 4. Achievement of Objectives (Efficacy) EFFICACY_TBL OBJECTIVE 1 Objective To develop a national strategy on mercury and related action plans. Rationale Theory of Change (TOC). A TOC was developed during the 2019 midterm review (MTR) and was fine-tuned for the Implementation Completion and Results Report (ICR). The PDO statement is at the output level. According to the TOC, activities included developing sectoral, cross cutting and provincial action plans and Page 4 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) engaging with key stakeholders. Intermediate Outcomes and Outcomes are also very similar, i.e. developing national strategy and relevant action plans. The PDO indicator “a national strategy developed and submitted for approval” was relevant to measure the objective but a higher-level outcome such as 'implementation' rather than “submission for approval’ of the strategy could have been aimed. Outputs/Intermediate Outcomes:  Three plans were approved in Guizhou, Hunan, and Shaanxi province and one municipal plan approved in Tongren municipality, exceeding the intermediate outcome target of three plans.  Nine sectoral plans were approved meeting the target of nine plans. Outcomes: The national strategy on mercury was developed as a main outcome of the project, covering all the sectors and elements addressed by the Minamata Convention that are relevant to China. At the time of the ICR, the draft national strategy had been submitted to MEE for approval achieving the PDO indicator. The ICR noted that final approval by MEE was expected by the end of 2023. Although the strategy approval is not complete yet, the ICR noted that the strategy and action plans developed under the project have already been incorporated into and are being implemented through China’s 14th Five-Year Plan and other national and sectoral strategies and programs. (ICR, Page 11). The ICR provided some examples on how the strategy has already been included into programs: For example, (i) the December 2020 ban on the production of all mercury-added products which is being enforced (with exceptions for mercury-containing thermometers and sphygmomanometers until 2025, related to Article 4 of the Minamata Convention); (ii) the updated guidelines of the National Hazardous Waste List for industrial solid and hazardous waste for priority industries (which should lead to a reduction in mercury content in waste that can enter into water and soil; and (iii) contaminated site remediation projects considering mercury control actions, such as the closure and ecological restoration of a mercury mine waste dump in Guizhou Province; (iv) based on the action plans developed under the project, starting from January 1, 2019, the use of mercury or mercury compounds was prohibited in the manufacturing processes of various chemicals (related to Article 5 of the Minamata Convention). The ICR also reported that mercury use is already dropping in some industries, i.e., mercury mining was reduced from 144,500 tons in 2018 to 109,100 tons in 2020 according to China's national report to the Minamata Convention. The 14th Five-Year Plan also places a ban on new primary mercury mining (related to Article 3 of the Minamata Convention), including issuing new mercury mine exploration licenses and mining licenses, which has led to a continuous decline in China’s mercury production. By 2020, China’s mercury production was 1,993 tons, a decrease of 10.71 percent, compared to the previous year. (ICR, page 12). Based on the additional evidence presented by the ICR on how the strategy and action plans developed under the project have already been incorporated into and are being implemented under various programs, how there has been a reduction in mercury production and use by various industries, and how it is helping China accelerate its compliance with the requirements of Minamata Convention, achievement of the first objective is rated High. Rating Page 5 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) High OBJECTIVE 2 Objective To improve the Recipient’s (China’s) mercury management capacity and readiness to implement this strategy in the project provinces. Rationale TOC. The project support for the design of a national MIS to be operationalized in pilot provinces, the assessment of two recycling technologies, and the environmental risk assessment of contaminated sites would contribute to improvement of China’s mercury management capacity and readiness to implement strategies in the project provinces. The PDO indicator “Mercury flow tracked by a fully functional management information system’ was designed to measure the objective. Outputs/Intermediate Outcomes: The project achieved/exceeded the following intermediate outcome targets.  Three laboratories—the Environmental Monitoring Center in Xunyang, Shaanxi, the Tongren Municipal Monitoring Center in Guizhou, and the Hunan Provincial Research Institute of Environmental Protection—received equipment and training to improve their capacity to measure mercury.  The project completed environmental risk assessments at nine mercury-contaminated sites (surpassing the Intermediate Indicator 2.2 target of five).  Mercury recycling assessments for Intermediate Indicator 2.1 were carried out at two locations meeting the indicator target.  The project also financed several capacity-building and awareness-raising efforts in the project provinces, significantly surpassing intermediate targets on the number of participants (in consultation activities and at dissemination events, including the number of female participants). 39,516 individuals participated in events (surpassing the target for Intermediate Indicator 2.5) with female participants making up about 56 percent of the total (above the target for Intermediate Indicator 2.6). In addition, there were about 645,000 virtual participants, partially via the innovative use of social media, which was a significant over-achievement in the engagement indicators and impact. Outcome: The MIS system, which is the main outcome of the project’s capacity building support was first tested and operationalized in the pilot provinces, meeting the original PDO target. The project operationalized the MIS nationally that is managed by the NSB and that is integrated into the national information system connected to and complementing two environmental monitoring systems. The MIS tracks mercury transport and use. The integration of the MIS into the national information system ensures its long-term sustainability and increased efficiency by avoiding repetitive reporting, which has far-reaching impact. It helped China provide more accurate national reporting to the Minamata Convention and will continue to do so in the long term. It is one of the few national-level, dedicated mercury MISs worldwide, and goes beyond Minamata Convention requirements, as the convention does not require a national MIS. Page 6 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) According to the ICR other activities under Component 2 contributed to meeting the PDO as well. Investing in the laboratories improved the robustness and accuracy of monitoring that is needed for the national strategy; these had been utilized by the end of the project and informed studies to update the mercury emissions baseline for priority industries. The environmental risk assessments built capacity to safely manage mercury waste, a key necessity for the strategy; and the recycling assessments helped China understand which technologies are most cost-effective and useful for minimizing the need for additional primary mercury mining, an additional goal of the strategy. However, the ICR noted that future work may also be necessary to ensure proper capacity in additional mercury-contaminated or mercury-using facilities in the pilot provinces, as well as in the non-pilot provinces where mercury is present. It would be helpful for the project to conduct a survey of the beneficiaries of training programs to understand the utilization of the trainings and to enrich the evidence on capacity building results. Based on the evidence provided by the ICR, achievement of the second objective is rated Substantial. Rating Substantial OVERALL EFF TBL OBJ_TBL OVERALL EFFICACY Rationale The achievement of the first objective is rated high, and achievement of the second objective is rated substantial based on the evidence provided on key outcomes. The overall efficacy is rated high on balance. Overall Efficacy Rating High 5. Efficiency No attempt was made to conduct ex-ante or ex-post economic analysis of the investment supported by the project. The justification provided by the ICR was due to project’s focus being on technical assistance to strengthen institutional capacity for mercury pollution control and reduction. The ICR provided information on the project’s implementation efficiency, and management efficiency by reporting on cost-effectiveness of the allocated budgets to achieve the PDOs. The project’s original duration of four years was extended by 18 months, mainly due to the impact of Covid-19 pandemic, in addition to delays caused by inexperienced FECO procurement team and lengthy procurement processes at the start of the project. Given the project’s complex MIS activities that required wide-ranging field Page 7 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) work and consultation process, the duration of implementation that was planned at appraisal was too ambitious. By the revised closing date, all project activities and investments were complete. Project management cost was only US$0.28 million, accounting for less than 4 percent of the project cost. FECO signed an implementation agreement with each of the pilot provinces and municipality, without setting up PMOs at the provincial level. The ICR noted that this approach not only kept costs low but also helped internalize institutional capacity building. Based on the above, the efficiency of the project is rated substantial. Efficiency Rating Substantial a. If available, enter the Economic Rate of Return (ERR) and/or Financial Rate of Return (FRR) at appraisal and the re-estimated value at evaluation: Rate Available? Point value (%) *Coverage/Scope (%) 0 Appraisal 0  Not Applicable 0 ICR Estimate 0  Not Applicable * Refers to percent of total project cost for which ERR/FRR was calculated. 6. Outcome The project’s objectives are highly relevant to the strategies of the World Bank and the Government both at appraisal and at closing, with the caveat that the first objective is output oriented. The Efficacy in achieving the first objective is rated high based on additional evidence provided by ICR on the outcomes from development of national strategy on mercury and related action plans. The Efficacy in achieving the second objective is rated substantial based on the evidence to improve China’s mercury management capacity and readiness to implement this strategy in the project provinces. Overall efficacy is rated high. Efficiency is rated substantial based on operational/administrative efficiency, although there was no economic efficiency analysis. Based on these sub-ratings, the project’s overall outcome is rated highly satisfactory a. Outcome Rating Highly Satisfactory 7. Risk to Development Outcome Page 8 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) The following three risks to development outcomes were noted by the ICR (page 26): The risk of a lack of mercury monitoring due to lack of government budgets and processes was mitigated by ensuring that the MIS was integrated into the NSB’s monitoring system that ensures funding of mercury monitoring and reporting. The risk of low technical capacity and financing to reduce mercury use and emissions for the various mercury-using industries and provinces is to be mitigated by further involvement of development partners and the provision of grant financing to build capacity in specific mercury-using sectors. An upcoming World Bank-implemented GEF project is planned to support the non-ferrous metal industry (P175980 ‘Sustainable Mercury Management in Non-ferrous Metal Industry’) as a second phase of this project. Projects implemented by other GEF implementing agencies will phase out the production of mercury-containing medical thermometers and sphygmomanometers (such as project GEF ID 10349 implemented by the United Nations Development Program). There is also a risk that government policies and enforcement of mercury reductions may lag China’s Minamata Convention commitments. The project involved many key national, provincial, and municipal governmental entities, who were engaged and incorporated elements of the national strategy and action plans in their own strategies and programs. Before the grant closed, China had passed laws that will begin to reduce mercury usage, such as the ban on new mercury mines and the phase-out of mercury-added products. All of these is expected to limit this risk. 8. Assessment of Bank Performance a. Quality-at-Entry The project was relevant to the World Bank and the government strategies. While the GEF had been supporting China to identify policy needs under the Minamata Convention, additional support was needed to help the country to translate the identified policy needs into concrete policy reforms. Thus, the World Bank through this project supported the Chinese government to develop its national strategy on mercury, identify action plans of priority sectors and provinces, and strengthen its capacity in specific areas of mercury pollution control. These would help China to meet its obligations under the Minamata Convention. The project activities included a mix of technical, institutional, and policy interventions, which were relevant to achieve the objectives. The implementation arrangements were effective, with implementation of the provincial activities entrusted to the Department of Ecology and Environments (DEEs), which proved to improve ownership and increase the likelihood of sustainability as well as implementation efficiency. The World Bank included support from technical and international advisers and also developed an Implementation Support Plan, which included plans for technical support to FECO in the development of the national strategy and the MIS, as well as risk assessments at contaminated sites. The World Bank also ensured that fiduciary arrangements were adequate and the environmental and social aspects were considered appropriately during the environmental and social assessments. Given the project’s complex MIS activities that required wide-ranging field work and consultation process, the duration of implementation planned at appraisal was too ambitious. The identification of moderate Page 9 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) procurement risk due to the lack of experienced staff in FECO proved to be important to provide extra training for FECO on World Bank processes, especially given the large number of consultancies that needed to be contracted. Based on the above the quality at entry is rated as satisfactory. Quality-at-Entry Rating Satisfactory b. Quality of supervision The ICR reported that the World Bank oversight was consistent, with a dozen missions and technical visits over the course of six years and provided hands-on support to reduce bottlenecks and resolve issues (ICR, page 25). Aide Memoires and ISRs discussed progress toward achieving the development objectives, flagged key issues with proposed actions, and followed up to ensure that issues were addressed in a timely manner. The World Bank project team included a mix of international and local staff and consultants that provided implementation support on technical aspects, as well as project management, financial, safeguards, and operational aspects. The task team leaders and most of the core team members remained on the project throughout implementation, which provided continuity and developed and maintained an effective working relationship with the government counterpart and stakeholders. The Bank team identified the potential need for an extension early, before the MTR, and discussed and agreed with FECO on how to go about the restructuring. The Bank team helped the project remain on course during the COVID-19 pandemic by shifting to virtual mode, frequent communication, and fast turnaround. Based on the above, quality of supervision is rated satisfactory. Quality of Supervision Rating Satisfactory Overall Bank Performance Rating Satisfactory 9. M&E Design, Implementation, & Utilization a. M&E Design The project’s TOC was simple and clear. The indicators overall were measurable and attributable. The PDO indicator “a national strategy developed and submitted for approval” was relevant to measure the objective but a higher-level outcome such as 'implementation' rather than “submission for approval’ of the strategy could have been aimed. In addition, there was some ambiguity in the scope of the PDO 2 indicator. The MIS was planned to be designed from the start as a national system, but the project’s target Page 10 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) was only to have the system operational in the three pilot provinces by project end. The intermediate indicators covered project activities well, except for the capacity building of provincial laboratories and the increase in capacity to monitor atmospheric mercury emissions, which in hindsight should have been included. b. M&E Implementation The ICR reported that the key PDO-level indicators and intermediate indicators were closely monitored and reported on in a timely manner through semiannual progress reports provided by FECO, with inputs from the provincial and municipal environmental authorities (ICR, page 21). Establishing the MIS for mercury management at the national level and integrating it into the NSB’s information system required extra effort, given the magnitude of work, cross-sectoral coordination, national-level endorsement, and field work required to cover a vast area across many industries and provinces. c. M&E Utilization M&E data were integral to making the need for a project extension clear. The M&E data and analysis have been and will continue to be used to guide resource allocation and decision-making by the relevant environmental authorities. It has provided scarce data, video footage, and pictures and will serve as firsthand and evidence-based information for scientific research in the future. The M&E system is already being used by the NSB and MEE nationwide and informed the National Report to the Minamata Convention. M&E Quality Rating Substantial 10. Other Issues a. Safeguards The project was categorized as Category B project (Partial Assessment) on Environmental Safeguards, triggering only the Environmental Assessment - OP/BP 4.01 safeguard policy. The project developed an Environmental Safeguards Management Framework (ESMF) that was disclosed on July 18, 2016, which provided a preliminary screening of the environmental impacts of the project. Environmental screening was to be carried out as part of the risk assessments for contaminated sites to identify issues that would need to be assessed in the preparation of remediation plans for future downstream activities. The national strategy includes a brief section on safeguards, which mentions the need to build the capacity of the national and local stakeholders to implement the Minamata Convention and enforce policies, regulations, rules, standards, and action plans associated with implementing the Convention. The ICR reported that ESMF implementation was satisfactory (ICR, page 22). The project did not encounter any environmental safeguards-related issues during implementation and complied with environmental safeguards. A grievance redress mechanism was developed and was disclosed nationally through the MEP/FECO website in 2016. No complaints were received during the project. Page 11 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) Social Safeguards: In terms of social safeguards, the World Bank policies on Indigenous Peoples - OP/BP 4.10 and Involuntary Resettlement - OP/BP4.12 were triggered as the strategies and action plans drafted by the project could lead to future activities that close mercury-using businesses where ethnic minority or vulnerable groups are employed, leading either to a loss of their livelihoods or the handling of toxic waste near communities where vulnerable groups live. Discovery of mercury contamination near such communities could lead to involuntary resettlement. The ESMF included several measures to mitigate potential social impacts that could arise during the project and prepare downstream activities to manage such social risks. These measures included ensuring that consultant terms of reference included a task to develop guidelines for mitigating impacts on employees and communities near contaminated sites, integrating safeguards in the guidelines for site assessments, and providing guidelines for carrying out stakeholder and public consultations and disclosure of information for downstream activities. The ESMF also included a measure to ensure that laboratory facilities that were renovated or contaminated sites assessed by the project would not expropriate additional land and lead to involuntary resettlement. The ESMF included guidelines on the contents of social assessment reports, a framework for public participation, an Ethnic Minority Planning Framework, and a Resettlement Policy Framework. These two social safeguards instruments were prepared under the ESMF to establish the principles and guidelines for site-specific ethnic minority development plans and resettlement action plans, in case of negative impacts to ethnic minorities and land acquisition and resettlement identified during project implementation. However, the ICR noted that there were no such instances during project implementation (ICR, page 23). b. Fiduciary Compliance Financial Management: The ICR reported that the project financial management was sound (ICR, page 23). The yearly audits by the China National Audit Office found the project in compliance with Chinese accounting standards and with the terms of the Grant Agreement. Interim unaudited financial statements were at times submitted late by FECO, but no major issues were found. Financial management was rated satisfactory throughout the project, except in the October 2020 Implementation Status and Results Report (ISR) because of some project staff being reassigned to non-project assignments. This issue was resolved by FECO by hiring new staff. Procurement: Procurement was identified as a moderate risk in the PAD, given the FECO project team’s lack of familiarity with World Bank procurement policies and procedures. This was mitigated by the World Bank- provided training and timely and frequent support and communication with FECO staff. FECO created a Procurement Plan at appraisal and managed procurement processes throughout implementation. As mentioned in the previous sections, some procurement delays occurred during implementation due to FECO’s lengthy standard procurement process and the difficulty in obtaining multiple bids for certain highly technical consultancies. However, such delays were recognized and addressed and did not have a lasting impact. Procurement reviews consistently found the project to be in compliance with the World Bank’s Page 12 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) procurement policies and requirements. FECO routinely prepared and updated the annual procurement plans that were submitted to the World Bank. c. Unintended impacts (Positive or Negative) No unintended impacts were reported by the ICR. d. Other --- 11. Ratings Reason for Ratings ICR IEG Disagreements/Comment Outcome Highly Satisfactory Highly Satisfactory Bank Performance Satisfactory Satisfactory Quality of M&E Substantial Substantial Quality of ICR --- High 12. Lessons The ICR developed several lessons, the most relevant ones are presented as follows:  Future projects on pollution issues in China or elsewhere could consider provincial pilots and subsequent integration into national-level monitoring systems. Piloting the MIS in the project provinces proved to be a successful first step toward national operationalization and the integration of the MIS into the NSB’s existing information system, and an effective approach to ensure efficiency and sustainability. Piloting of the MIS in high mercury use provinces proved to be a successful method to showcase local government progress and generate national interest in mercury flow monitoring and reporting. After the initial provincial pilot, the process of operationalizing the MIS at the national level and its integration into the NSB statistical system was lengthy and required cross-sectoral coordination, but these extra efforts were critical to ensure a sustainable and national impact and increased efficiency.  Implementation agreements with local governments, rather than full project management units at the provincial level, can be an effective and efficient implementation modality for decentralizing project activities. The implementation modality of having the Foreign Economic Cooperation Office working closely with the provincial and municipal Department of Ecology and Environments on pilot activities based on implementation agreements proved to be very effective and efficient. Cost efficiency was achieved by allocating a relatively small percentage of the grant funding to the provincial and Page 13 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) municipal environmental authorities to help coordinate and implement the relevant pilot activities. It also helped build capacity at the provincial level. Similar technical assistance projects with local pilot activities should consider using implementation agreements to ensure streamlined and effective participation by local governments.  Mercury recycling can be a cost-effective way to reduce the use of mercury in some industrial processes and recycling technologies and practices could be piloted at the enterprise level to validate their technical and financial viability for scaling up to the entire industry. The assessments of mercury recycling technologies conducted under the project indicate that recycling is a cost-effective way to reduce use othe f mercury in some industries, such as non-ferrous metal smelting industry, especially in terms of reducing the use of primary mercury. In future investment operations, mercury recycling technologies and practices could be piloted at the enterprise level to validate their technical and financial viability for scaling up to the entire industry. It will also promote a circular economy, energy savings, and reduction of greenhouse gas emissions. The findings of the assessments laid a good foundation for follow-on projects. 13. Assessment Recommended? No 14. Comments on Quality of ICR The report was concise, provided a detailed overview of the project, and followed the guidelines. The lessons were specific experiences and findings of the project. The efficacy discussion was robust; the ICR reported additional outcome-level evidence to support the ratings linked to the impact of the project’s intervention. The lessons were based on the project's operational experience and were relevant for future operations. Overall, the ICR quality is rated as High. a. Quality of ICR Rating High Page 14 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review China Minamata Convention on Mercury (P151281) Page 15 of 15