Document of The World Bank Report No: RES23980 RESTRUCTURING PAPER ON A PROPOSED PROJECT RESTRUCTURING OF THE PARAGUAY WATER AND SANITATION SECTOR MODERNIZATION PROJECT LOAN 7710-PY April 14, 2009 TO THE REPUBLIC OF PARAGUAY November 29, 2016 GLOBAL WATER PRACTICE Argentina, Paraguay Uruguay Country Management Unit Latin America and Caribbean Region This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. ABBREVIATIONS AND ACRONYMS DAPSAN WSS Directorate in MOPC (Dirección de Agua Potable y Saneamiento) ERSSAN Sanitary Services Regulation Agency (Ente Regulador de Servicios Sanitarios) ESIA Environmental and Social Impact Assessment ESSAP Sanitary Services Company of Paraguay (Empresa de Servicios Sanitarios del Paraguay) GoP Government of Paraguay IADB Inter-American Development Bank IBRD International Bank for Reconstruction and Development IPP Indigenous People Plan ISDS Integrated Safeguards Data Sheet MOPC Ministry of Public Works and Communication (Ministerio de Obras Públicas y Comunicaciones) OP Operational Policy PDO Project Development Objective PMSAS Paraguay Water and Sanitation Sector Modernization Project RAP Resettlement Action Plan SEAM Environmental Secretary (Secretaría del Ambiente) SENASA National Environmental Sanitation Service (Servicio Nacional de Saneamiento Ambiental) SIAPS National Water and Sanitation Information System (Sistema de Información Agua Potable y Saneamiento) WSS Water Supply and Sanitation WWTP Waste Water Treatment Plant Regional Vice President: Jorge Familiar Country Director: Jesko S. Hentschel Senior Global Practice Director: Guang Zhe Chen Practice Manager: Rita Cestti Task Team Leader: Christophe Prevost and Maria Catalina Ramirez Page 2 of 16 PARAGUAY Water and Sanitation Sector Modernization Project CONTENTS A. SUMMARY 5 B. PROJECT STATUS 6 C. PROPOSED CHANGES 8 ANNEX 1: RESULTS FRAMEWORK AND MONITORING 12 Page 3 of 16 DATA SHEET Paraguay PY Water & Sanitation Sector Modernization (P095235) LATIN AMERICA AND CARIBBEAN Water Report No: RES23980 Basic Information Specific Investment Project ID: P095235 Lending Instrument: Loan Regional Vice President: Jorge Familiar Calderon Original EA Category: Full Assessment (A) Country Director: Jesko S. Hentschel Current EA Category: Full Assessment (A) Senior Global Practice Original Approval Guang Zhe Chen 14-Apr-2009 Director: Date: Practice Rita E. Cestti Current Closing Date: 30-Sep-2017 Manager/Manager: Christophe Prevost, Maria Team Leader(s): Catalina Ramirez Borrower: Republic of Paraguay Responsible ESSAP, MOPC, SENASA Agency: Restructuring Type Form Type: Full Restructuring Paper Decision C Authority: D D e c i s i o n Restructuring Level: Level 2 Financing (as of 29-Nov-2016) Page 4 of 16 Key Dates Effectiveness Revised Closing Project Ln/Cr/TF Status Approval Date Signing Date Original Closing Date Date Date P095235 IBRD-77100 Effec. 14-Apr-2009 27-Apr-2009 29-Jan-2010 15-Mar-2015 30-Sep-2017 Disbursements (in Millions) Can Project Ln/Cr/TF Status Currency Original Revised Disbur. Undisb. % Disbursed celled IBRD-7710 Effec P095235 USD 64.00 64.00 0.00 35.53 28.47 55.51 0 tive P095235 Policy Waivers Does the project depart from the CAS/CPF in content or in other significant Yes [ ] No [ X ] respects? Does the project require any policy waiver(s)? Yes [ ] No [ X ] A. Summary of Proposed Changes The proposed changes include (i) reallocation of loan proceeds between existing Disbursement Categories to support the implementation of the Resettlement Action Plan (RAP); (ii) increasing from 80 percent to up to 100 percent the percentage of Bank financing of some Disbursement Categories to improve implementation; and (iii) introduction of minor changes to the results framework. Change in Implementing Agency Yes [ ] No [ X] Change in Project's Development Objectives Yes [ ] No [ X] Change in Results Framework Yes [ X] No [ ] Change in Safeguard Policies Triggered Yes [ ] No [ X] Change of EA category Yes [ ] No [ X] Other Changes to Safeguards Yes [ ] No [ X] Change in Legal Covenants Yes [ ] No [ X] Change in Loan Closing Date(s) Yes [ ] No [ X] Cancellations Proposed Yes [ ] No [ X] Change to Financing Plan Yes [ ] No [ X] Change in Disbursement Arrangements Yes [ ] No [ X] Reallocation between Disbursement Categories Yes [ X] No [ ] Change in Disbursement Estimates Yes [ ] No [ X] Change to Components and Cost Yes [ ] No [ X] Change in Institutional Arrangements Yes [ ] No [ X] Change in Financial Management Yes [ ] No [ X] Page 5 of 16 Change in Procurement Yes [ ] No [ X] Change in Implementation Schedule Yes [ ] No [ X] Other Change(s) Yes [ ] No [ X] Appraisal Summary Change in Economic and Financial Analysis Yes [ ] No [ X] Appraisal Summary Change in Technical Analysis Yes [ ] No [ X] Appraisal Summary Change in Social Analysis Yes [ ] No [ X] Appraisal Summary Change in Environmental Analysis Yes [ ] No [ X] Appraisal Summary Change in Risk Assessment Yes [ ] No [ X] B. Project Status The Paraguay Water and Sanitation Sector Modernization Project (PMSAS) was approved in April 2009 and the current Loan Closing Date is September 30, 2017. As of November 29 2016, the Project has disbursed US$35.53 million from a total of US$64 million (Loan IBRD-7710-PY), representing 55.51 percent of the loan. The Project’s overall progress towards achievement of the PDO is rated Moderately Unsatisfactory and overall implementation progress Moderately Satisfactory. The Project has already contributed to improve access to water and sanitation services for 12,000 people in rural areas, 6,000 people in indigenous communities and 60,000 people in the Asunción Metropolitan Area. In addition, the Project would improve the sanitation environment for 300,000 people living in the Itay Basin in Asuncion and would provide 6,000 people living in indigenous communities in the Chaco with improved water supply services. Overall, the project would benefit at 384,000 people. Significant implementation progress has been made in the last year, after a reorganization of the Water Supply and Sanitation Directorate (DAPSAN for its acronym in Spanish - Dirección de Agua Potable y Saneamiento), and the renewed commitment from the Government of Paraguay (GoP) to deliver results. The latter has translated in regular coordination meetings and close oversight of Project implementation. Project implementation progress by Component is summarized as follows: Component 1 Support to the Modernization of the Sector - Governance and Institutional Strengthening is almost fully disbursed and has made significant progress in strengthening the governance structure of the water supply and sanitation (WSS) sector in Paraguay. The inter-institutional WSS coordination group (Mesa Interinstitucional de Agua y Saneamiento) is meeting regularly under the leadership of DAPSAN with the objective of bringing all stakeholders together to increase water and sanitation coverage, improve the quality of current services and strengthen sector capacity. The implementation of the Governance Action Plan to improve communication, participation, transparency and accountability in the sector continues to progress well. Each sector institution has developed its own website to make public all Page 6 of 16 ongoing activities and works, including information on contracting processes. The preparation of the national water and sanitation policy is being finalized. The concession contract between the Ministry of Public Works and Communication (MOPC) and the WSS Utility ESSAP (Empresa de Servicios Sanitarios del Paraguay) has been signed and a Board of Directors established, which gives ESSAP the tools to develop and implement a financial equilibrium strategy. The Environmental Secretary (SEAM - Secretaría del Ambiente) has developed a framework to improve water resources monitoring and management in five water basins; has completed the water balance for the country, and has developed user-friendly interfaces for the registry of water rights. Additionally, SEAM has successfully revised environmental licensing procedures for WSS infrastructure to meet the provisions of the new Decree 453/13 on Environmental Impact Assessment and align them to international practices and Bank safeguards and operational policies. Component 2 Urban water supply and sanitation and institutional strengthening of the Sanitary Services Company of Paraguay. ESSAP has developed a monitoring framework for key management and service delivery indicators to improve its transparency, technical and commercial efficiency. ESSAP’s annual income has increased from US$51.0 million in 2013 to US$57.0 in 2015 as a result of increased metering and better management of big clients’ accounts. The rehabilitation of 57 kilometers (km) of secondary distribution water networks was finalized in April 2016, benefiting 50,000 people. The construction of 8.4 km of sanitation networks to benefit 10,000 inhabitants with improved sanitation services was finalized in October 2016. The following contracts are still under execution: (i) the construction of 29 km of primary sanitation collectors in the Itay basin, part of the larger Itay sewerage system (80 percent executed), and (ii) the installation of meters with a 82 percent of progress totaling 88,000 meters. The contract for the terrain backfilling and the construction of the houses for the affected families who have chosen to be relocated on the Bella Vista Wastewater Treatment Plant (WWTP) premises presents 50 percent progress as of October 31, 2016. The GoP expects to tender the Bella Vista WWTP in December 2016. The Resettlement Action Plan (RAP) for 133 families (representing 460 people) would allow the construction area of the Bella Vista WWTP, pursuant to O.P. 4.12. The need to prepare and implement a RAP came up after the identification of the Bella Vista WWTP site. The site was selected due to its proximity to the river and central location in relation to ongoing and planned sewerage network infrastructure. The site was only identified after Project preparation. The RAP was prepared in 2013 and has been updated to reflect the acquisition of land from the Municipality and timeline for implementation. Throughout the elaboration and the implementation of the RAP, ESSAP has shown ownership in carrying out a highly participatory process, in full compliance with Bank safeguard policies to prepare the site for the construction of the Bella Vista WWTP. Component 3 Rural Water Supply, Sanitation, Hygiene Education and Institutional Strengthening of the National Environmental Sanitation Service (SENASA). SENASA completed the construction of 30 rural water supply systems in December 2013, providing 12,000 people with improved water services and the installation of 1,090 latrines benefiting 6,000 people living in indigenous communities in Chaco. In addition, 31 additional WSS systems in indigenous communities in Chaco are under construction and would benefit 6,000 Page 7 of 16 indigenous people. As part of these activities, WSS committees have been established in all target communities and SENASA is in the process of strengthening its presence in the Chaco region through the creation of two regional offices and supporting to the municipalities to create their own WSS municipal units. The project’s audit reports have usually been presented to the Bank with minor delays and in general have been considered acceptable. Notwithstanding, two of the three audit reports of the calendar year 2015 are currently outstanding. These reports correspond to the parts of the project executed by the Ministry of Public Works and Communication and SENASA. These entities experienced several delays in the procurement processes due in part to the lack of interested external audit firms, and also to local procedural complications which led to the cancellation of the selection processes. These processes have recently resumed and it is the Borrowers’ intention to present the audit reports to the Bank before the end of calendar year 2016. ESSAP has presented its audit report on time. . C. Proposed Changes . Change in Results Framework Explanation: The results framework would be revised to better reflect Project activities and associated targets as follows: (i) The target for the PDO indicator “Direct Project beneficiaries� will be revised to 384,000 people in order to account for the people who would actually be benefiting from the Project. (ii) The PDO indicator “People provided with access to improved sanitation facilities under the project� will be replaced by “People with access to improved sanitation services under the project in urban areas� to specifically account for the beneficiaries of the rehabilitated sewerage networks in Asuncion. The target for this PDO indicator will be set at 10,000 people. (iii) The PDO indicator “People provided with access to improved sanitation facilities – urban� will be replaced by “People provided with improved sanitation environment in urban areas� to capture the beneficiaries from the primary sewerage network in the Itay basin constructed under the project. The target for this PDO indicator will be set at 300,000 people. (iv) The PDO indicator “People provided with access to improved sanitation facilities – rural� will be replaced by “Indigenous people provided with access to improved sanitation facilities under the project in rural areas.� The target for this PDO indicator will be set at 6,000 people. (iv) The intermediate results indicator “Environmental classification standards reviewed by SEAM Water Resources Directorate� will be deleted as it is not a relevant measure of SEAM’s activities and is beyond their scope. (v) The intermediate results indicator “Volume of wastewater of Asuncion properly discharged to the Paraguay River� will also be deleted as the construction of the WWTP no longer falls under the financing of the Project. Page 8 of 16 (vi) The target of the intermediate results indicator “Kilometers of sewerage collectors rehabilitated from the sewerage system of Asuncion� will be revised to 48, as the current target includes water network rehabilitation. (vii) The intermediate results indicator “Environmental unit created within SENASA and processing environmental licenses� will be deleted as this activity was not part of the Project and SENASA does not process environmental licenses. . Financing Reallocations Explanation: The proposed restructuring, requested by the Borrower include: (i) a reallocation of funds towards the implementation of the RAP involving reallocation from Category 5 (works under Component 2) to Category 12 (Land acquisition and cash compensation as part of the RAS implementation) to cover the increase in temporary accommodation costs for the 94 families to be relocated in houses on the Bella Vista WWTP premises and the purchase of land from the Municipality of Asunción for each family to obtain property title, and (ii) a change of the percentage of Bank financing of eligible expenditures up to 100 percent. The requested reallocation of funds and change of the percentage of Bank financing would enable the Project to achieve its PDO by ensuring that ESSAP has the necessary funds to continue implementing the RAP while critical works are being finalized. The RAP has included extensive community consultations to identify preferred compensation options for each of the 133 affected families. ESSAP carried out detailed surveys and assessments of land and lost assets. The collected data provided a formal basis for determining entitlements and levels of compensation under three options: (i) Provision of land and a house in the collective resettlement site (in the same area the affected families currently live in, near the site of the Bella Vista WWTP); (ii) Provision of a contribution towards land regularization and a house - and in some cases the relocation of micro-businesses - outside the collective resettlement site; and (iii) Cash compensation. These resettlement options provide sufficient replacement at full cost for the loss of occupied land, house and other assets, including, occasionally, micro-businesses. Temporary accommodation, including house rentals, is applicable to all three options. During construction site preparation, the RAP is providing temporary accommodation and resettlement for 133 families affected by the planned construction of the Bella Vista WWTP. The first relocations from the site took place in July 2014 and to date, only 94 families are still in temporary accommodation. It is expected in August 2017, the moves will be completed and Page 9 of 16 all families would be in their new houses and would have received the associated property title. In accordance with OP 4.12, the land chosen for the resettlement is productive in the sense that it is close of the income sources of the resettled families. The proximity to their previous living location also causes the lowest impacts to the families and their social networks, which are crucial factors in maintaining their existing economic activities, access to education and health services. This was clearly outlined in the Consultations Chapter of the RAP, pp. 14-25, and was also the main reason the majority of the families chose to be resettled in a house on the proximity to the Bella Vista WWTP (94 out of 133 families). The project is facing a cost increase in RAP’s implementation resulting from extending temporary accommodation and the need to purchase the land of the new houses. The increase in temporary accommodation costs stem from delays in the contracting process for the landfill and house construction, which in turn have extended the RAP timeline, in particular the milestone of moving to the new houses with their property titles to August 2017. The families will have to stay in temporary accommodation until that date. The new administration of the Municipality of Asunción, who took office in late 2015, has recently formally confirmed that resettled families need to purchase the land in order to comply with Municipal Ordinance 33/95. This requires the purchase of land for the issuing of property titles linked to municipal land (whether private or public). The Municipality of Asunción confirmed in a letter Nro.1266/2016S.G dated October 26, 2016 that all land purchases will be done at the social tariff1. The administrative mechanism for this land purchase will be similar to that used under option (ii) of the RAP, under which the families were provided with a contribution to purchase their house and land titles. The Project contemplates the funding of land purchase with loan proceeds. Category (12) was established to finance option (ii) above, and to date 15 families have chosen this option and have been compensated accordingly. ESSAP has been working closely with all impacted families to prepare the information required for land titling through the Municipality in order to streamline this process. As such, the funds re-allocated to the RAP implementation are expected to be disbursed by Project closing (September 2017). Completion of the RAP. Only capacity building and monitoring activities from the RAP would remain after the Project closing. However the Bank team will continue to supervise the implementation of these final RAP activities beyond the closing date of the Project, as per paragraph 24 of OP 4.12. The construction of the Bella Vista WWTP Bella Vista will be financed with funds from the Inter-American Development Bank (IADB) Integrated Sanitation of the Bay and Metropolitan Area of Asuncion Program (PR-L1029) approved on December 15, 2015 and ratified by the 1 The social tariff is Paraguayan Guarani (G). 53,250 per square meter (equivalent to US$9.5), yielding approximately G. 7,561,500 per plot (equivalent to US$1,344). Page 10 of 16 Government of Paraguay (GoP) on April 2016. The GoP expects to tender the Bella Vista WWTP in December 2016, which should allow for a seamless transition from site preparation to plant construction and should minimize the possibility of settlers returning to the site. The table below illustrates the proposed reallocation of funds among categories and disbursement percentage. Pendi Current Cat. Actual ng Disbursement % (Type Ln/Cr/TF Currency Category of Allocation Allocation No. Disburs. Com Total) Expenditure mit. Current Proposed Current Proposed GO,CS,ADT,N IBRD-77100 USD 1 ON-CS,TRN,O 2,840,000.00 2,840,000.00 100.00 100.00 -001 P Pt 1a,b,d,e PREMIUM FOR 11 0.00 0.00 0.00 0.00 CAPS/COLLA RS LAND 12 AQ.&CASH 880,000.00 1,630,000.00 80.00 100.00 COMP.Pt 2e GO,CS,NON-C 2 S,TRN,OP Part 1,100,000.00 1,100,000.00 100.00 100.00 1c GO, CS-FIRMS 3 14,000,000.00 14,000,000.00 70.00 100.00 Part 2a,b,c,d,e CS-IND,ADT,N 4 ON-CS,TRN,O 2,000,000.00 2,000,000.00 100.00 100.00 P 2a,b,c,d,f WORKS Part 5 7,200,000.00 6,450,000.00 80.00 100.00 2b 6 WORKS Part 2e 26,320,000.00 26,320,000.00 80.00 100.00 GO, CS-FIRMS 7 545,000.00 545,000.00 40.00 100.00 Part 3a,d SUBPROJECT S 8 8,040,000.00 8,040,000.00 80.00 100.00 (WK,GO,CS,T RN) CS-IND,ADT,N 9 ON-CS,TRN,O 915,000.00 915,000.00 90.00 100.00 P, Pt 3a,d,e Total: 63,840,000.00 63,840,000.00 Page 11 of 16 ANNEX 1 – RESULTS FRAMEWORK Project Project PY Water & Sanitation Sector Modernization (P095235) Restructuring Status: DRAFT Name: Stage: Team Christophe Prevost and Maria Requesting LCC7C Created by: Clementine Marie Stip on 02-Jun-2016 Leader(s): Catalina Ramirez Unit: Product Responsible IBRD GWA04 Modified by: Maria Florencia Liporaci on 29-Nov-2016 Line: Unit: Country: Paraguay Approval FY: 2009 LATIN AMERICA AND Lending Region: Specific Investment Loan CARIBBEAN Instrument: Project Development Objectives Original Project Development Objective: The Project Development Objective (PDO) is to increase the efficiency, coverage, and sustainability of water supply and sanitation services in Paraguay by (a) improving the governance of the sector, (b) improving water services and increasing access to sewerage services in the Asuncion metropolitan area, and (c) increasing access to sustainable water and sanitation services in rural areas. Results Core sector indicators are considered: Yes Results reporting level: Project Level Project Development Objective Indicators Status Indicator Name Core Unit of Measure Baseline Actual(Current) End Target No Change Water and Sewerage Services Text Value No Yes Yes Unit within the MOPC staffed Date 14-May-2009 10-Nov-2016 30-Sep-2017 and equipped, defining the policies for the sector Comment No Change Timely availability of ESSAP's Text Value No Yes Yes external auditing of financial Date 14-May-2009 10-Nov-2016 30-Sep-2017 Page 12 of 16 and performance data Comment published through an annual report in ESSAP's website Revised Direct project beneficiaries Number Value 0.00 78,000 384,000 Date 10-Nov-21016 30-Sep-2017 Comment Direct project beneficiaries Number Value 0.00 26000.00 318000.00 Date 28-Dec-2015 30-Sep-2017 Comment No Change Female beneficiaries Percentage Value 0.00 50.00 50.00 Sub Type Supplemental No Change Number of people in rural areas Number Value 0.00 12000.00 18000.00 provided with access to Date 10-Nov-2016 30-Sep-2017 Improved Water Sources under the project Comment Marked for People provided with access to Number Value 0.00 6190.00 312000.00 Deletion "improved sanitation facilities� Date 01-Oct-2015 30-Sep-2017 under the proj. Comment Marked for People provided with access to Number Value 0.00 0.00 300000.00 Deletion “improved sanitation facilities� Sub Type Date 01-Oct-2015 30-Sep-2017 - urban Breakdown Comment Marked for People provided with access to Number Value 0.00 6190.00 6190.00 Deletion “improved sanitation Sub Type Date 09-Jun-2016 30-Sep-2017 facilities�- rural Breakdown Comment New Indigenous people provided Number Value 0.00 6000.00 6000.00 Page 13 of 16 with access to "improved Date 29-May-2009 10-Nov-2016 30-Sep-2017 sanitation facilities" under the project in rural areas Comment New People provided with access to Number Value 0.00 10000.00 10000.00 "improved sanitation services" Date 29-May-2009 10-Nov-2016 30-Sep-2017 under the project in urban areas Comment New People provided with improved Number Value 0.00 0.00 300000.00 sanitation environment in urban Date 29-May-2009 10-Nov-2016 30-Sep-2017 areas Comment No Change Reduction of non-revenue Percentage Value 51.00 47.00 46.00 water in the Gran Asuncion Date 31-May-2009 10-Nov-2016 30-Sep-2017 Area Comment Intermediate Results Indicators Status Indicator Name Core Unit of Measure Baseline Actual(Current) End Target No Change SIAPS developed and Text Value No Yes Yes generating reports according to Date 14-May-2009 10-Nov-2016 30-Sep-2017 the "Conceptual Framework for the SIAPS" Comment No Change Characterization of Service Text Value No Ongoing Yes Providers (Service Provider Date 14-May-2009 10-Nov-2016 30-Sep-2017 Mapping) developed and published in ERSSAN's Comment homepage Marked for Environmental classification Text Value No in progress Yes Deletion standards reviewed by SEAM Date 14-May-2009 10-Nov-2016 30-Sep-2017 Water Resources Directorate Comment No Change ESSAP's concession agreement Text Value No Yes Yes Page 14 of 16 signed Date 14-May-2009 10-Nov-2016 30-Sep-2017 Comment No Change ESSAP's Board of Directors Text Value No Yes Yes established Date 14-May-2009 10-Nov-2016 30-Sep-2017 Comment No Change Information Management Text Value No Yes Yes System developed and Date 14-May-2009 10-Nov-2016 30-Sep-2017 generating reports for managerial decisions Comment Marked for Volume of wastewater of Text Value TBD after 0 1m3/s Deletion Asuncion properly discharged baseline study to the Paraguay River 14-May-2009 28-Dec-2015 30-Sep-2017 Date Comment Revised Kilometers of sewerage Kilometers Value 0.00 48.00 48.00 collectors rehabilitated from Date 14-May-2009 10-Nov-2016 30-Sep-2017 the sewerage system of Asuncion Comment Kilometers of sewerage Kilometers Value 0.00 48.00 57.00 collectors rehabilitated from Date 14-May-2009 28-Dec-2015 30-Sep-2017 the sewerage system of Asuncion Comment No Change Procurement unit strengthened Text Value No Yes Yes and publishing procurement Date 14-May-2009 10-Nov-2016 30-Sep-2017 plans in SEPA Comment Marked for Environmental unit created Text Value No Yes Yes Deletion within SENASA and Date 14-May-2009 28-Dec-2015 03-Jan-2011 processing environmental licenses Comment Page 15 of 16 No Change Number of new systems Text Value 0 0 31 providing access to water Date 14-May-2009 10-Nov-2016 30-Sep-2017 supply services to indigenous communities Comment No Change Number of installed latrines for Number Value 0.00 1090.00 1200.00 indigenous communities Date 14-May-2009 10-Nov-2016 30-Sep-2017 Comment No Change Number of new systems Text Value 0 30 30 providing access to sustainable Date 14-May-2009 10-Nov-2016 15-Mar-2015 water supply services to rural communities Comment No Change Percentage of water Percentage Value 10.00 15.00 50.00 connections with working Date 14-May-2009 10-Nov-2016 30-Sep-2017 micrometers (less than five years of installation) Comment No Change Number of families resettled as Amount(USD) Value 0.00 39 133 per the RAP Date 30-May-2009 10-Nov-2016 30-Sep-2017 Comment Page 16 of 16