Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) Report Number: ICRR0023054 1. Project Data Project ID Project Name P151058 Nouadhibou Eco-Seafood Cluster Project Country Practice Area(Lead) Mauritania Finance, Competitiveness and Innovation L/C/TF Number(s) Closing Date (Original) Total Project Cost (USD) IDA-D1040,IDA-D4660 01-Nov-2020 11,532,467.88 Bank Approval Date Closing Date (Actual) 24-Mar-2016 01-Nov-2021 IBRD/IDA (USD) Grants (USD) Original Commitment 7,750,000.00 0.00 Revised Commitment 12,249,999.71 0.00 Actual 11,606,108.43 0.00 Prepared by Reviewed by ICR Review Coordinator Group Ranga Rajan Ebru Karamete Christopher David Nelson IEGSD (Unit 4) Krishnamani 2. Project Objectives and Components DEVOBJ_TBL a. Objectives This project in Mauritania was the third in the World Bank's multi-country, multi-phase interdependent Series of Projects (SOPs) known as the West Africa Regional Fisheries Program (WARFP). The program's overarching development objectives were to "sustainably increase the overall wealth generated by the extraction of the marine fisheries resources of West Africa and the proportion of that wealth captured by West African countries". Page 1 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) The Project Development Objective (PDO) as stated in the Financing Agreement dated April 13, 2016 (Schedule 1, page 4) and the Project Appraisal Document (page 8): " To support the development of a seafood cluster in Novadhibou that promotes the sustainable management of fisheries and generates value for the communities". The PDO was amended with the Additional Financing (AF) for the project that was effective on September 30, 2019. The PDO as stated in the AF agreement: i. To support the development of a seafood cluster that promotes the sustainable management of fisheries and generates value for communities in Novadhibou and (ii) to improve the business environment to boost private sector development in Mauritania. b. Were the project objectives/key associated outcome targets revised during implementation? Yes Did the Board approve the revised objectives/key associated outcome targets? Yes Date of Board Approval 17-May-2019 c. Will a split evaluation be undertaken? No d. Components There were two components (PAD, pages 10 - 14). 1. Developing a sustainable seafood cluster in Nouadhibou. The estimated cost at appraisal was US$5.97 million. With AF of US$1.00 million, the revised estimate was US$6.97. The actual cost was US$5.88 million. This component aimed to build capacity of the Nouadhibou Free Trade Authority (ANZF) and the stakeholders to design and promote the seafood cluster (Seafood cluster refers to a geographic concentration in Nouadhibou of interconnected businesses, suppliers and associated public and private institutions involved in the fisheries industry). The team clarified that the ANZF's is responsible for planning, programming, organizing and promoting the entire free zone of Nouadhibou, which includes the development and support its key sector (the fisheries sector). There were two sub-components: a. supporting ANZF in developing a framework for sustainable seafood cluster through Public-Private- Partnerships (PPPs) and capacity building at local and national levels. Activities included developing: (i) a competitive diagnostics for the cluster: (ii) a cluster strategy; (iii) the legal and institutional framework and operational tools for managing the Nouadhibou Eco-seafood cluster (NESC) and (iv) Technical Assistance (TA) to the Ministry of Economy and Finance and support for establishing a PPP framework. Page 2 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) b. supporting the government in generating responsible investments in NESC and capacity building of the Nouadhibou Free Zone stakeholders through: (i) a commercial viability assessment; (ii) targeted investment promotion activities: and (iii) skills training and TA for facilitating responsible investments. 2. Increasing the value of seafood products produced and marketed in the seafood cluster with the participation of local actors. The estimated cost at appraisal was US$3.28 million. With AF of US$3.00 million, the revised estimate was US$6.28 million. The actual cost was US$ 3.03 million. This component aimed to increase the value of seafood products produced and marketed in the seafood cluster and increase the participation of the local population in cluster activities. There were two sub-components. a. supporting the government in improving handling of landed catch and promoting fresh fish exports from the cluster through: (i) consultants' services for strengthening the management of the Autonomous Port of Nouadhibou (PAN), the artisanal and coastal fishing port and the Nouadhibou International Airport: (ii) improving handling of landed fish for reducing post-harvest losses; (iv) building a refrigerated warehouse freight terminal at the international airport; and (v) TA for modernizing trade services and regulations: and (vi) increasing fresh fish exports via ground transport. b. capacity building of local suppliers' and vulnerable groups through: (i) supporting the transition to the new fisheries management regime and improving processing and harvesting efforts; (ii) support the industries and institutions in complying with product quality control procedures and acquiring key certifications; and (iii) reducing post-harvest losses through improved management practices. The following two components were added with the AF for the project. 3. Strengthen the investment climate for private sector development. The estimated cost was US$5.00 million. The actual cost was US$1.43 million. This component aimed to improve Mauritania's investment climate. There were two sub-components: a. purchasing of essential equipment for modernizing the commercial justice system and registry through upgrading and digitalization of the Commercial Registries in Nouakchott and Nouadhibou, renovating an existing building for hosting the commercial tribunal and the commercial registry of Nouakchott and providing TA to the Public-Private Investment Climate Technical Committee. b. supporting the government in operationalizing the PPP agenda and execute three pilot PPP projects through capacity building and advisory support to the Government entities in charge of PPP. 4. Project management. The revised estimate for this component was US$0.5 million (This component was to be funded entirely through counterpart funding). The actual cost was US$0.09 million. This component planned to support project coordination, supervision, monitoring, fiduciary management and communication and outreach. e. Comments on Project Cost, Financing, Borrower Contribution, and Dates Project cost. The estimated cost at appraisal was US$9.25 million. The actual cost was US$11.60 million. Project financing. The project was financed by an IDA Grant of US$7.75 million. AF of $8.00 million was effective on September 30, 2019. With this, the total Bank financing was US$15.75 million. The amount Page 3 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) disbursed was US$11.60 million. US$3.5 million of the Grant was cancelled. The difference between the Bank financing and disbursement was mainly due to exchange rate changes during implementation. Recipient contribution. The recipient contribution was planned at US$1.50 million. With AF, their contribution was increased to US$2.5 million. However, their actual contribution was US$0.09 million. Dates. The project approved on March 24, 2016 became effective on July 6, 2016 and was scheduled to close on November 1, 2020. AF was approved on May 17, 2019. The project closed on November 1, 2021. Other changes. There were three project restructurings. The main changes made through the first Level 2 restructuring on January 8, 2018.  Funds were reallocated between categories and an unused project preparation advance funds was added to the project account. The main changes made through the first Level 1 restructuring on May 17, 2019.  AF was approved at government request based on the project's satisfactory progress and performance until then. The activities related to the investment climate and investment climate were shifted to component three. These activities were national level activities and not strictly related to the Nouadhibou seafood cluster.  Project activities were scaled up and the PDO was amended to reflect the increase in scope (discussed in section two). New indicators were added in view of the increased project scope.  The closing date was extended by a year from November 1, 2020 to November 1, 2021. The main changes made through the second Level 2 restructuring on October 21, 2021.  Funds were reallocated between disbursement categories.  US$3.50 million of the Grant was cancelled. Split rating. The original PDO was retained and the scope was significantly expanded with the AF. The PDO was amended to reflect the increase in project scope. Therefore, this review is not based on a split rating of objectives. 3. Relevance of Objectives Rationale Country context. Mauritania is a sparsely populated (population of four million people), arid (just 0.5% of the land is arable) and resource-rich country. Mauritania's growth performance is dependent on the extractive sector and hence its economy is susceptible to swings in international commodity prices. Diversification of the economy was hence deemed to be essential for accelerating the economic growth required for sustained poverty reduction. Page 4 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) Sector context. Mauritania's fishing waters are among the most productive in the world. However, the economic and social returns generated from the fisheries sector are lower than their potential due in large part to the overexploitation and depletion of the resource by legal and illegal operators. Moreover, while Mauritania does get a substantial amount of fisheries resource rents from foreign fishing agreements, the rents do not directly contribute to the development of the local economy in part because much of the fresh fish caught in Mauritania water lands in foreign parts, which is whether value is added. The Government strategy aimed to increase the competitiveness of the seafood cluster by strengthening the enabling environment for private investment, developing infrastructure services for private sector development and facilitating forward and backward linkages for the sector. Government strategy. At appraisal, the PDO was fully-aligned with the Government's new fisheries policy strategy for 2015 - 2019. This strategy emphasized on the importance of sustainability of the sector and articulated the need for generating greater revenues and creating jobs in the post-harvest sector. The Government's Strategy for Accelerated Growth and Shared Prosperity (SCAPP) for 2016 - 2030 reiterated the need for promoting a more competitive private sector to generate and sustain inclusive growth. Bank strategy. At appraisal, the PDO was consistent with the overarching objectives of the Bank's Country Partnership Framework (CPF) for 2014 -2016. Pillar one of the strategy articulated the need for growth and economic diversification. The PDO continues to be well-aligned with the current CPF for 2018 -2023. The CPF highlighted the need for promoting economic transformation for diversified and resilient growth. While Focus area one of the CPF specifically highlighted the strategic objective of increasing value-added in the fisheries sector, focus area three highlighted the need for improving private sector participation in economic activities. Previous Bank experience. The Bank has financed several analytical work and TA programs on the fisheries sector in Mauritania. A study in 2014 on Transitioning toward Inclusive Green Growth in Mauritania highlighted fisheries as one of the key sectors likely to drive sustainable economic growth in Mauritania. The Bank's financed three TA programs (Nouadhibou Free Zone TA in 2013 -2014, Competitiveness of Nouadhibou Trade Sections and Location in 2014 and Mauritania Public - Private Infrastructure Advisory Facility (PPIAF) in 2014-2015. These programs prioritized the fisheries and the seafood industry as one of the key sectors for sustaining economic growth. This project was designed based on the analytical work. The original project envisioned a sequenced approach with a TA for governance of the fisheries sector and capacity building for the Nouadhiou Free Zone Authority (ANZF) preceding targeted infrastructure investments in the seafood value chain (the Nouakchott fish market and the refrigerated warehouse for fresh fish exports in Nouadhibou). While the governance and capacity building activities were appropriate for the intended outcome of sustainable management of the sector, the targeted infrastructure investments were appropriate for the intended outcome of increasing the value added in the sector. That said, the modified PDO, which incorporated the objective of "improving the business environment to boost private sector development in Mauritania", was less relevant to the fisheries sector, although relevant to the country as a whole. The modified PDO did not fit in smoothly with the original focus on the seafood cluster. Therefore, the relevance of the PDO is assessed as substantial. Rating Relevance TBL Rating Substantial Page 5 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) 4. Achievement of Objectives (Efficacy) EFFICACY_TBL OBJECTIVE 1 Objective To support the development of a seafood cluster that promotes the sustainable management of fisheries Rationale Theory of change. The outputs of activities such as developing a seafood cluster strategy, developing legal and institutional framework for establishing Public Private Dialogue (PPD), and advisory services to the Free Nouadhibou Free Trade Authority (ANZF) for designing a seafood cluster strategy were aimed at reducing the overfishing in the fishing sector. These outputs were expected to contribute to the outcome of sustainable management of fisheries. The theory of change is predicated of the following assumptions: (i) The ANZF would continue to engage with the private sector to promote good management practices in the fisheries sector; and (iii) There would be political support for adopting new strategies in the Noudhibou Free Zone. The activities in this component were mainly technical assistance activities. It is unclear if these activities would suffice for realizing the development of seafood cluster that promotes the sustainable management of fisheries. Furthermore, neither the term "sustainable management of fisheries" was defined, nor was the methodology specified for measuring "sustainable management of fisheries". Outputs (ICR, paragraphs 28 and 43).  A seafood cluster strategy was developed and disseminated as targeted.  The Seafood Task Force - the first Public Private Dialogue (PPD) mechanism - was set up in Mauritania to establish continuous dialogue for private sector development. The task force had representatives from twelve key players including the public sector, including members of both ports (the Commercial Port of Novadhibou (PAN) and the Artisanal Port of Novadhibou), the ANZF, the private sector; and the civil society. The task force held six meetings of the task force by 2018. The task force is however no longer operational.  Awareness campaigns of investment opportunities through the Free Zone were held at international fairs and forums as targeted. The Free Zone's investment and communication strategy was developed. Outcomes. The outputs described above were expected to increase investments by responsible investors (defined as those complying with the provision of the fisheries management plan for sustainable management of fisheries).  Investments in the fisheries sector increased to US$216 million when the project closed, exceeding the target of US$100 million. However it is not clear whether the investments were made by responsible investors, as the investments were not validated for transparency or environmental compliance. The criteria for determining what is responsible investment were drafted and the metrics were not developed for monitoring this indicator. Page 6 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) The outcome indicator designed to measure the objective, 'new responsible investments' could not be attributed to project activities. In the absence of sufficient evidence measuring "the development of a seafood cluster" as well as a clear methodology for measuring "sustainable management of fisheries', efficacy of this PDO is rated modest. Rating Modest OBJECTIVE 2 Objective To generate value for the communities. Rationale Theory of change. The theory of change postulated that targeted infrastructure investments such as constructing a refrigerated warehouse, improving the landing sites of Novadhibou's commercial port and the artisanal port and extending them and facilitating fresh fish exports at the customs point of Nouadhibou, were likely to improve the infrastructure for exporting fresh fish. Capacity building activities activities such as training the private enterprises and small scale actors would help in reducing post-harvest losses. These activities together were expected to increase seafood products produced and marketed through the seafood cluster and thereby generate value for the communities. The theory of change assumes that the key impediments to increasing the value of seafood exports are the lack of refrigerated warehouses and border crossing procedures. It is unclear how infrastructure investments and capacity building activities would increase sea food exports, since the project did not support export promotion activities. Even if sea food exports did increase, it is not clear how this would benefit the communities since there is no information on the main constraints facing artisanal fishery households. Furthermore, the underlying assumption that the key impediments to increasing the value of seafood exports are mainly due to the lack of refrigerated warehouses was unrealistic (discussed below). Outputs. (ICR, page 14 and pages 32 - 34).  Thirty metric tons of cold storage capacity for fish products were built as targeted. A refrigerated warehouse and two pumping stations were built as targeted on the last day of the project. Two landing infrastructure facilities for improved traceability of fish products were built, as compared to the target of three. These infrastructure facilities were however completed at the final days of the project.  The project provided 41,407 days of training, exceeding the target of 1,500.  There were no women-led micro-medium and scale enterprises in Nouadhibou when the project closed (specified target five). Most activities targeting women such as marketing and operational support to local women's cooperatives operating in Nouadhibou were dropped due to the counterpart's failure to disburse the committed funds. Page 7 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058)  A diagnostic study to facilitate exports at the border with Morocco was completed. However, several planned studies were dropped due to delays during implementation. The activity of constructing a building for the seafood cluster Governance Council in Nouadhibou was dropped. Outcomes. The outputs of the activities described above were expected to have two outcomes: (i) increase the volume of fresh fish exports (a proxy for value created under the assumption that improving the landing and handling facilities for fresh fish will increase business for local communities).and (ii) increase in the number of direct beneficiaries defined as actors on the ground such as artisanal, coastal and industrial fishers, processing plant workers and those who sell fish and fish products.  Annual fresh fish exports increased from 996 tons in 2015 to 29,097 tons, exceeding the target of 21,400 tons during the project implementation period. However, the increase could not be not be attributed to the project activities, as the two landing infrastructure and the pumping stations for the commercial and artisanal ports were only completed in the final days of the project closure and the refrigerated warehouse was not operational when the project closed.  1,551 people directly benefitted from project activities. This was far short of the specified target of 6,000. 38% of the beneficiaries were women, exceeding the target of 30%. However, it is not clear who these beneficiaries were and how they benefited, as as there was no impact assessment or beneficiary survey. Rating Modest OBJECTIVE 3 Objective To improve the business environment to boost private sector development in Mauritania. Rationale Theory of change. The outcomes of activities added with the AF for the project were aimed at encouraging private sector investment nationally and not related to the seafood cluster. Implementing investment climate reforms, operationalizing the PPP, and computerizing the business and collateral registries were aimed at improving the business environment in Mauritania. Outputs. (ICR, pages 34 -35).  PPP policy framework was adopted and commercial studies for PPP were completed as targeted. Three investors committed to private partnerships, short of the target of five.  The business and collateral registries in Nouadhibou and Novakhott were not computerized and the commercial justice building in Novakott were not renovated as targeted. Outcomes. Page 8 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058)  The outputs of activities were expected to increase the transaction requests from the collateral and business registry. This outcome was not realized as the business and collateral registries were not activated when the project closed. Rating Negligible OVERALL EFF TBL OBJ_TBL OVERALL EFFICACY Rationale Overall efficacy is modest. Overall Efficacy Rating Primary Reason Modest Low achievement 5. Efficiency Economic analysis. A traditional cost-benefit analysis was not conducted for most project activities, as the activities were in the nature of capacity building activities for the seafood cluster. An economic analysis was conducted at appraisal for activities associated with constructing a refrigerated warehouse and associated one- stop and streamlining procedures at the border crossing with Morocco. These activities accounted for 24.7% of the original project cost. The benefits were assumed to come from the returns on the refrigerated warehouse through increased seafood exports and new revenue generated by the warehouse, The Net Present Value (NPV) at 5% discount rate was US$1.7 million. The Economic Internal Rate of Return (EIRR) was 9%. The economic analysis was not conducted at closure as the warehouse was not yet operational when the project closed. Administrative and Operational shortcomings. The project did not demonstrate value for money. Under the original project many activities (development and dissemination of the seafood cluster strategy, establishment of the seafood task force, the adoption of the 2017 law governing PPP and adopting investment climate reforms) were completed. However, many activities under the AF project were delayed due to a combination of factors, including political economy factors and addition of a new component that neither fit with the project framework, nor was aligned with the ANZF's mandate. Many activities were dropped (such as the activities aimed at targeting women and institutional strengthening activities), due to inadequate counterpart funding. The fish hall was not built, collateral and business registries were not digitized and activity associated with the construction of the refrigerated warehouse was only in the final days of the project and hence could not provide the expected results. About US$3.5 million of the bank financing could not be utilized and was cancelled. According to the clarifications provided by the team, the refrigerated warehouse is not functioning to date. In sum, efficiency is rated as modest. Page 9 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) Efficiency Rating Modest 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 (%) 24.70 Appraisal  9.00  Not Applicable 0 ICR Estimate 0  Not Applicable * Refers to percent of total project cost for which ERR/FRR was calculated. 6. Outcome Relevance of the PDOs is substantial. With modest efficacy and efficiency, overall outcome is moderately unsatisfactory. a. Outcome Rating Moderately Unsatisfactory 7. Risk to Development Outcome Institutional risk. There is high institutional risk to development outcome. Risks are high that the project outcomes will not be sustained given the weak institutional capacity for strengthening governance and institution building and engaging with the private sector. Government commitment/ownership. There is substantial risk to development outcome as evidenced by the fact that many of the activities supporting women in the fisheries sector were undermined due to the lack of counterpart funding by the government. Technical risk. There is substantial risk to development outcome given that some infrastructure investments in this project were not yet operational (such as the refrigerated warehouse) when the project closed. 8. Assessment of Bank Performance Page 10 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) a. Quality-at-Entry The analytical underpinnings of the project were sound (discussed in Section three). The project identified the constraints inhibiting fishery sector growth in Mauritania (overfishing, lack of stakeholder coordination, inadequate fish landing infrastructure and the lack of forward and backward linkages ).The design drew on lessons from the previous Bank-financed fisheries projects. The key lessons included: (i) recognizing that without appropriate institutions, infrastructure investments for facilitating fish landing or processing can lead to overexploitation of resources, the design sequenced activities with governance and capacity building activities preceding infrastructure investments. (ii) recognizing that economic zones are not substitutes for larger trade and investment reforms, the design included activities aimed to improve the general investment climate: and (ii) The design opted for a value chain approach for managing the various fishing segments. The preparation team drew on complementary Trust Fund Support (through the International Finance Corporation (IFC). The preparation team assessed that there was strong government buy-in and interest in promoting sector growth through private-sector- led development and supporting social inclusion through supporting women and the artisanal fisheries sector. Several risks were identified at appraisal, including high fiduciary risk and substantial political and governance risks and weak implementation capacity risks. Mitigation measures incorporated at design included, TA to sector to the main actors and a Project Preparation Advance (PPA) to address fiduciary risks. Even with mitigation measures the overall project risk was rated as substantial at appraisal (PAD, paragraph 23). The arrangements made at appraisal for fiduciary and safeguards compliance were appropriate (discussed in section 10). However, there were significant shortcomings on Quality-at-Entry, as described below: -Firstly, the project objectives were overly ambitious and linkages between project activities leading to achievement of the objectives were weak, and some of the PDO indicators were not attributable to measure the objective. For example: (i) It was unclear if the TA activities would suffice for realizing the development of seafood cluster that promotes the sustainable management of fisheries. (ii) It was also not clear how the fishing communities would benefit economically, since the project activities included only training. In addition, entrusting the funding responsibility to the counterpart regarding the activities aimed to benefit women was problematic, as eventually these activities had to be dropped for lack of funding. -Secondly, the design underestimated the political economy and governance risks. -Thirdly, the selection of the implementing agency proved to be problematic and it is not clear why the project was not entrusted to an agency with relevant experience. For the first time the Project Management Unit (PMU) was located outside the Ministry's control in the Nouadhibou Free Trade Authority (ANZF). The ANZF established in 2013 was new and untested and its institutional mandate were unclear. The strained relationship between the ANZF and the central ministry led to delays during implementation. -Fourthly, the activities added with the AF (strengthening the investment climate) had a nationwide scope and was not connected to the seafood sector activities. This made the ANZF even less suitable as this was well beyond its mandate. Page 11 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) -Lastly, there were significant M&E design shortcomings (discussed in section 9). Quality-at-Entry Rating Moderately Unsatisfactory b. Quality of supervision Twelve Implementation Status Results (ISR) reports were filed over the project lifetime of seven years (implying on average twice a year missions). The supervision team was based in the region (until the COVID - 19 pandemic). This helped in facilitating regular communication between the Project Coordination Unit (PCU) and the team. The continuity of leadership was maintained, with two Task Team Leaders (TTLs) during implementation. In the wake of the COVID - 19 pandemic, supervision were conducted remotely. The support provided by the team aided in fiduciary and safeguards compliance (discussed in section 10). The supervision team identified the problems with M&E in the early years and made arrangements for hiring a M&E consultant to support data collection efforts. However, despite this, M&E problems with transparency and data validity remained through the project lifetime. In sum, overall Bank performance is rated as Moderately Unsatisfactory, due to the shortcomings at Quality-at-Entry. Quality of Supervision Rating Moderately Satisfactory Overall Bank Performance Rating Moderately Unsatisfactory 9. M&E Design, Implementation, & Utilization a. M&E Design The four key outcome indicators - increase in responsible investments in the fisheries sector, increase in fresh fish exports (a proxy for value created in the sector under the assumption that improving the landing and handling facilities for fresh fish will increase the incomes in the local communities), increase in the transaction requests from collateral and business registry (a proxy for business activity) and the number of direct project beneficiaries) - were measurable. However the M&E framework had shortcomings. For example, guidelines for who are "responsible" investors was not specified. The volume of fresh fish exported through Nouadhibou showed an increasing trend during implemented and the specified target was exceeded at closure. But this was not attributable to the project, given that the refrigerated warehouse was completed just before closure. A better proxy for business activity in the Nouadhibou would have been to track of private enterprises registered in Page 12 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) Nouadhibou. Sustainable management of fisheries was not defined well and was not measured. The target for the number of direct project beneficiaries was unrealistic. b. M&E Implementation The deficiencies in M&E were not rectified during implementation. The ICR (paragraph 70) notes that there were critical deficiencies in data collection and validation of data by the stakeholders, such as private investors. This was particularly so with respect to the indicator on "responsible investors". The project neither determined the criteria nor followed it up with investors. The absence of validation made it difficult to attribute the realized outcomes to the project activities. c. M&E Utilization The ICR (paragraph 72) notes that given the weak implementation of M&E, the data that was collected was not utilized for learning, decision-making or adjusting project activities during implementation. In sum, M&E is rated as modest, in view of the shortcomings at design and implementation. M&E Quality Rating Modest 10. Other Issues a. Safeguards The project was classified as a Category B (partial assessment) project under the World Bank safeguard policies. Two safeguard policies were triggered at appraisal: Environmental Assessment OP/BP 4.01); and Physical Cultural Resources (OP/BP 4.11). (PAD, page iv). Environmental Assessment and Physical Cultural Resources. The PAD (paragraph 86) notes that adverse environmental impacts were possible for the activity associated with construction of a refrigerated warehouse for fish exports. The planned site was within the perimeter of the international airport. An Environmental and Social Impact Assessment (ESIA) was conducted at appraisal, and an Environmental and Social Management Plan was prepared to safeguards issues (PAD, paragraphs 87 and 89). A Grievance Redress Mechanism (GRM) was instituted at appraisal to address complaints relating to the project activities (PAD, paragraph 90). The ICR (paragraph 76) notes that environmental and social compliance was moderately satisfactory during implementation. There were no environmental issues. However, the ANZF did not have an environmental and social specialist until project close, when a specialist was finally hired. The team confirmed that there were no issues with the safeguards on physical cultural resources. No complaints were received through the GRM. Page 13 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) b. Fiduciary Compliance Financial Management. The Bank conducted a financial management arrangements of ANZF at appraisal (PAD, paragraph 76). The assessment concluded that the financial risk was high, due to the lack of staff in ANZF. Mitigation measures incorporated at design included, recruitment of an accountant and a financial management plan. With mitigation measures, financial risk was downgraded to substantial at appraisal (PAD, paragraph 80). The ICR (paragraph 74) notes that financial management was moderately satisfactory. Although documents pertaining to the works completed (such as the refrigerated warehouse and the pumping station) were not submitted in a timely fashion, the external audits were unqualified and the financial monitoring reports were submitted within the required deadlines. Procurement Management. The Bank conducted a procurement assessment of ANZF at appraisal (PAD, paragraph 82). The procurement risk was assessed as high due to the weak implementation capacity of ANZF. Mitigation measures at design included, training ANZF procurement personnel and preparing a procurement plan. With mitigation measures, procurement risk was downgraded to substantial at appraisal (PAD, paragraph 84). The ICR (paragraph 75) notes overall procurement performance was moderately unsatisfactory. Although procurement was satisfactory under the parent project, following the AF, public procurement delays in the final years contributed to non-completion of many of the project activities. The ICR does not report any case of mis procurement. c. Unintended impacts (Positive or Negative) No significant unintended impacts were identified during implementation (ICR, paragraph 50). d. Other --- 11. Ratings Reason for Ratings ICR IEG Disagreements/Comment Moderately Moderately Outcome Unsatisfactory Unsatisfactory Moderately Moderately There were significant Bank Performance Satisfactory Unsatisfactory shortcomings at Quality-at-Entry. Quality of M&E Modest Modest Quality of ICR --- Substantial Page 14 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) 12. Lessons The ICR draws the following main lessons from implementing this project, with some adaptation of language. 1. A careful assessment of the political economy considerations at design can help in reducing implementation delays. The Project Implementation Unit (PIU) in this project was located outside the central government agencies. It was located in the Nouadhibou Free Trade Authority (ANZF), a newly established entity with limited management experience and an unclear mandate. The strained relationships between the central government and ANZF contributed to implementation delays. 2. Adding a component weakly linked to project performance can increase project complexity and affect performance. In this project, activities covering PPP and investment climate were added to this project with AF to avoid the time for preparing an entirely new project. The added activities had a national scope and loosely linked to the original activities in the fisheries sector. This increased the project's complexity and contributed to the project's low rating. 3. The design needs to be realistic about the time for implementing new activities. The time span for the AF project was approximately two years, from September 2019 to November 2021. This time frame was ambitious, given the range of activities supported by the AF project. 4. A clear understanding of the priorities of the private sector would help projects seeking to target private sector participation in a sector. Although a Public-Private Dialogue (PPD) forum was created under this project, the private sector was not able to participate in the forum, as its basic priorities (such as basic service needs) were given little consideration. This undermined private sector participation in the sector. 13. Assessment Recommended? No 14. Comments on Quality of ICR The ICR is well-written. The ICR candidly acknowledges the shortcomings in implementation arrangements and the complexities added to the project through the AF for the project. The ICR draws good lessons from the experience of implementing the project. The theory of change articulates the links between project activities, outputs and outcomes. Shortcomings of the theory of change are that the links between outputs and outcomes are rather weak and the assumptions underlying the theory of change unrealistic. Another shortcoming is the length of the ICR. According to the guidelines, the recommended length is 15 pages. a. Quality of ICR Rating Page 15 of 16 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Nouadhibou Eco-Seafood Cluster Project (P151058) Substantial Page 16 of 16