Malawi - First Urban Project

Document of The World Bank FOR OFFICIAL USE ONLY Repot No. 13626 PROJECT COMPLETION REPORT MALAWI FIRST URBAN PROJECT (CREDIT 1528-MAI) OCTOBER 24, 1994 Infrastructure Operations Division Southern Africa Department Africa 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.  CURRENCY EOUIYALENTS Currency Unit Malawi Kwacha (MK) and Tambala 1 MK = 100 Tambala Exchange Rate at Appraisal US$1.00 - MK 1.33 SDR 1.00 = US$1.01663 Exchange Rate (October 1988) : US$1.00 MK 2.60 Exchange Rate (1989) US$1.00 MK 2.73 Exchange Rate at Closing US$1.00 MK 3.81 WEIGHTS AND MEASURES 1 foot (ft) 0.305 meters (m) 1 mile (mi) 1.609 kilometers (klm) 1 square mile (mi2) 2.590 square kilometers (km2) 1 ton (t) 0.907 metric tons (m ton) ABBREVIATIONS BCC Blantyre City Council BML Building Materials Loan CCDC Capital City Development Corporation DLV Department of Lands and Valuation IHA Intermediate Housing Area ISS Institutional Support and Studies LCC Lilongwe City Council MHC Malawi Housing Corporation MOWS Ministry of Works and Suppliesl/ NBS New Building Society ODA Overseas Development Administration OPC Office of the President and Cabinet THA Traditional Housing Area FISCAL YEAR Government of Malawi April 1 - March 31 Malawi Housing Corporation January 1 - December 31 New Building Society February 1 - January 31 1/From March 1988 renamed Ministry of Works.  FOR OFFICIAL USE ONLY THE WORLD BANK Washington, D.C. 20433 U.S.A. Office of Director-General Operations Evaluation October 24, 1994 MEMORANDUM TO THE EXECUTIVE DIRECTORS AND THE PRESIDENT SUBJECT: Project Completion Report on Malawi First Urban Development Project (Credit 1528-MAI) Attached is the 'Project Completion Report on Malawi - First Urban Project (Credit 1528-MAI)" prepared by the Infrastructure Operations Division, Southern Africa Department of the Africa Regional Office, with Part II contributed by the Borrower. The project aimed at developing a wide range of housing options and it was to assist the government in establishing a self-supporting housing program which was to address the issue of subsidies and include technical innovations. With these ambitious targets the project became difficult to implement by the agencies whose capacity furthermore was overestimated at appraisal. Due to the many problems encountered during implementation, critical components had to be modified but objectives were not scaled down. Project completion was delayed by three years. Achievements in physical terms were substantial. The important but often elusive goal of making housing affordable to low-income groups on a sustainable and replicable basis was not, however, realized. Institutional aspects were improved to some extent through revision of building by-laws and formulation of legislation to support the development of low-cost housing, and through studies to initiate policy reforms. Important achievements were also realized in land security and land registration thus making land dealings more efficient. Cost recovery goals, however, were not met thus leaving the sustainability of project benefits uncertain. Overall, this first urban project helped establish an improved basis for promotion of the development of low-cost housing. The project outcome is rated as marginally satisfactory, its institutional development impact as modest, and the sustainability of project benefits as uncertain. The PCR is of good quality and offers pragmatic lessons. Part II presents a realistic review of project implementation and supplements the lessons presented in Part I. The project may be audited later when the ongoing Local Government Development Project (Cr. 2379-MAI) is completed. Attachment < 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 Sank authorization.   FOR OFFICIAL USE ONLY PROJECT COM[PLEIsON REPORT MALAWI FIR URBAN PROJEC (CREDIT 1528-MAI) TABLE OF CONTENTS Page No. PREFACE ..................................................... i EVALUATION SUMMARY . ........................................... i PART I. PROJECT REVIEW FROM BANK'S PERSPECTIVE ................... 1 Project Identity . .............................................. 1 Background ................................................. 1 Project Objectives and Description .................................. 3 Project Design and Organization .................................... 4 Project Implementation . .......................................... 4 Results .................................................... 6 Project Sustainability . .......................................... 7 Bank Performance . ............................................ 7 Borrower Performance . .......................................... 8 Project Relationship . ............................................ 9 Consulting Services and Studies .................................... 9 Project Documentation and Data .................................... 9 PART H. PROJECT REVIEW FROM BORROWER'S PERSPECTIVE .... ........... 10 Bank's Performance . .......................................... 10 Bank Review Missions . .......................................... 10 Approvals .................................................. 10 Flexibility ........................... 11 Borrower Performance ........................... 11 Lessons Learned ........................... 12 PART m. STATISTICAL INFORMATION ................................ 14 Related Bank Loans/Credits ......................... 15 Project Timetable .................................. 16 Cumulative Estimated and Actual Disbursements .......... ................ 17 Project Implementation . .................................. 19 Project Costs .................................. 20 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.  Table of Contents (Continued) Page No. Project Financing ............... 21 Project Results: Direct Benefits ............... 22 Studies ............... 22 Status of Covenants ............... 23 Use of Bank Resources ............... 27  i PROJECT COMPLETION REPORT MALAWI FIRST URBAN PROJECT (CREDIT 1528-MAI) PREFACE 1. This is the Project Completion Report (PCR) for the First Urban Project for which Credit 1528- MAI (SDR 14.8 million [US$15.0 million equivalent]) was approved on November 27, 1984 and declared effective on November 19, 1985. Following a restructuring of the project in 1989 and two extensions (to June 30, 1991 and June 30, 1992), the Credit closed on June 30, 1993. An undisbursed balance of SDR 4,107,257.18 (approximately US$4.16 million equivalent) resulting from cost savings due to currency devaluations and to the discontinuation of some infrastructure works was cancelled on November 2, 1993. 2. The PCR was prepared by the Infrastructure Operations Division of the Southern Africa Department (Preface, Evaluation Summary, Parts I and III), and by the Borrower (Part II). 3. Preparation of this PCR was based, inter alia, on the Staff Appraisal Report, the Development Credit Agreement and Supplementary Letters; supervision reports; consultants' reports; correspondence between the Bank and the Borrower; and internal Bank memoranda.   ii PROJECT COMPLE ION REPORT MALA RST URBANPROJECT (CREDIT 1528-MAD EVALUATION SUMMARY Project Objectives 1. The primary objective of the First Urban Project was to help orient future housing development in Malawi toward a market-based system by almost tripling the availability of mortgage finance, introducing a new affordable standard of permanent bousing and restructuring key institutions to play a more dynamic role in land and housing development. The project's aim was to enhance the housing sector's viability and financial independence by encouraging greater use of private funds for housing finance. The project was also to help the Government investigate ways of phasing out subsidies on the existing housing stock and reducing the linkage between housing benefits and total public service compensation policies. 2. Major project components included: the development of about 2,230 plots by Malawi Housing Corporation (MHC) and provision of about 2,000 mortgage loans for low-cost housing through the New Building Society (NBS) under the Intermediate Housing Area (IHA) Programme; the development of about 500 plots and the provision of about 1,000 Building Materials Loans (BMLs) by MHC under the Traditional Housing Area (THA) Programme; and the Institutional Support and Studies (ISS) Programme comprising a study of housing subsidies and wage policies, a training programme for small contractors, a land adjudication and registration programme and a study of building regulations and institutional support. 3. The project was largely executed by MHC and NBS with the assistance of consultants. The Office of Housing in the Office of the President and Cabinet (OPC) was responsible for overall monitoring of project activities.  iii Implementation Experience 4. The management capacity of MHC, NBS and OPC was underestimated during project preparation. As a result, as problems were encountered in critical areas of planning, financial management and engineering, these were not adequately addressed. 5. The project which was appraised in 1983 and negotiated and approved in 1984 was expected to have been completed within seven years. However, implementation of the physical components only got underway in mid-1987 after nearly three years of delay due in part to the lack of detailed engineering designs. 6. Problems in project design became evident early on in the life of the project. The requirement that houses be presold prior to the initiation of construction in order for mortgage funds to be released could not be met by the majority of the intended beneficiaries. Additionally, increases in interest rates and in the cost of construction made the achievement of the project's affordability objective nearly impossible. 7. In 1989, the project was restructured in an attempt to remedy the weaknesses in original project design. A new mix of housing options was introduced in order to better reach the target groups. Following the restructuring, reasonable progress was achieved with the civil works components. However, the project's financial performance deteriorated and issues of cost recovery and financial accountability became the source of some concern. 8. The Closing Date of the project was extended twice (from June 30, 1991 to June 30, 1992 and from June 30, 1992 to June 30, 1993) primarily to enhance the achievement of project objectives. Total project costs at completion amounted to US$15.8 million, 13.3% lower than the appraisal estimate of US$18.2 million. A balance of SDR 4,107,257.18 resulting from currency devaluations and savings from the discontinuation of site development at Kameza (509 out of the 609 plots originally allocated have to be resited) which remained undisbursed from the credit was canceled on November 2, 1993. Results 9. On the whole, the project failed to address the needs, priorities and desires of the low-income urban groups for which it was targeted. Although the delivery of the physical outputs of the project, particularly in respect of the IHA Programme, were achieved to a large extent, some targets relating to the BMLs under the THA Programme were not fully reached. There were serious problems relating to cost recovery especially in relation to the sale of core and shell houses. 10. Under the ISS Programme, the Land Adjudication Study was largely successful. However, the Housing Subsidies and Wage Policy Study aimed at reforming the entrenched system of subsidizing civil service housing, did not yield the expected contribution to the policy debate or result in any changes to the system. The country's Building By-laws were revised and appropriate legislation formulated to promote the development of low-cost housing.  iv 11. The impact of the technical assistance provided in support of project monitoring activities was minimal, and did not serve to enhance the existing policy-formulation capacity within the key sectoral institutions. Sustainability 12. The sustainability of the project depends on sectoral institutional and financial reforms being put in place that would facilitate sustained housing development in the country. Given the changes in the financial environment, the structure of the on-lending arrangements under the project would need to be revised to enable NBS to promote and provide adequate financing for low-income housing. This would also contribute to efforts being made by MHC to improve its cost recovery record in order not to endanger the financial stability of the NBS. Findings and Lessons Learned 13. The main lessons drawn from the implementation of the First Urban Project are: the importance of thoroughly assessing the institutional capability of the Borrower and the implementing agencies so that measures such as a clearly defined role for technical assistance and training of local personnel in key areas of financial management, engineering planning and quantity surveying can be incorporated into project design; - the desirability of flexibility in project design to incorporate revisions in scope that will allow the maximum benefits to be derived under the project, and for these to be sustained; - the need to ensure that good policy coordination among the relevant implementing authorities is achieved so that bottlenecks of an inter-institutional nature that impede progress can be removed; - the basic assumptions on which the design of a project of this nature hinges (for example, affordability, spatial priorities, standards, target groups to be served) should be thoroughly examined so that possible deficiencies in the project design can be minimized; - the importance of establishing clearly defined and realistic marketing policies within the social, economic and political context of the Borrower's country so as to assure effective cost recovery and maximum benefits.   PROJECT COMPLETMON REPORT MALAWI EIS URBAN PROJE (CREDIT 1528-MAD PART I. PROJECT REVIEW FROM BANK'S PERSPECTIVE 1. Project Identit Project Name First Urban Project Credit No. 1528-MAI RVP Unit Southern Africa Department, Infrastructure Operations Division Country Malawi Sector : Infrastructure Sub-sector Urban 2. BackoU=nd 2.1 Housing supply in urban areas in Malawi has historically been dominated by the public sector. Over the years, the Government has maintained a successful sites and services programme Oocally called Traditional Housing Areas ITHAs]) which has enabled lower income urban residents to obtain access to basic services and construct self-help housing in a planned setting. However, at the upper end of the housing scale, Malawi has maintained the colonial tradition of providing subsidized housing as part of a benefit package made available to many higher-level employees in the public and private sectors. The major share of such housing is owned by the Government, either as institutional housing held by individual ministries in connection with specific Government activities or as a general purpose pool of housing held by the Malawi Housing Corporation (MHC) and rented on a sub-economic basis to the Government or to employees of statutory bodies and private firms. These various programmes provide housing for roughly two-thirds of all urban residents, with half of the total residents being supplied by the THA programme. The remaining urban housing stock is accounted for by self-help housing constructed in unplanned housing areas (such as Ndirande in Blantyre and Old Kawale in Lilongwe) and by formal sector housing developed by private individuals, the latter of which services less than ten percent of total urban residents.  2 2.2 Between 1971 and 1981, MHC and the Capital City Development Corporation (CCDC) maintained average annual growth rates of 5 percent for permanent housing and 17 percent for the THA programme. This high volume of THA production provided for a major share of the increase in the urban population, which grew at an estimated annual rate of about 8 percent over the period. The more modest growth in the permanent housing stock was well below the increase in the number of employees eligible for rental housing, so that by 1983, approximately half of the civil servants eligible for rental housing were on the waiting list. Malawi's current budgetary constraints have since reduced the volume of both new permanent housing and THA construction to minimal levels, further aggravating the growing shortage of housing. 2.3 The primary reasons for the decline in housing production are: (i) the high level of subsidy to the sector, which has been a factor in the deteriorating financial health of key institutions, particularly MHC; and (ii) the high unit cost of permanent housing constructed to standard designs. MHC is largely dependent for its revenues on rentals charged to Government. Because of Government's own budgetary problems, rental increases have been granted reluctantly, consequently, MHC's financial situation has weakened to a precarious level. As a result of the uneconomic rental structure and its deteriorating financial position, MHC has been unable to attract long term loans from foreign and domestic sources. In addition, the foreign grant funds which had been used for THA development are becoming more difficult to obtain, in part because of problems with the achievement of cost recovery in THAs. This, due in large part to housing costs moving beyond the financial means of low income groups. 2.4 The Bank gave priority to the housing sector in its first urban operation in Malawi because of the acute need to reorient policies and priorities towards the provision of affordable and financially viable alternatives. In the urban areas in general, the Bank has provided assistance for water supply, health education and industrial development through projects in these sectors. The Blantyre Water Supply Project (Credit 71 1-MAI; 1977)1/ augmented water supply to Malawi's largest city, and the Lilongwe Water Supply Engineering Credit (Credit 1272-MAI; 1982)2/ helped to identify and prepare water supply and sanitation investments in Lilongwe. The Health and Nutrition Project (Credit 1351-MAI)Q/ was aimed at improving the health care delivery systemns in Lilongwe and Blantyre as well as a number of semi-urban and rural areas. 2.5 It was expected that the First Urban Project would provide a programme of positive actions to initiate the process of moving to a financially viable housing sector and contribute to the total programme of urban development in Malawi. The project was prepared by the Government in 1981 with assistance from consultants and the Bank; it was appraised in November 1983; and it was restructured in 1989 to allow the Government to respond to changes in the external environment, escalated construction costs and increases in interest rates. I/Perfonnence Audit Report No. 6700 (1987). /PMroject Comipldtion Repoft No. 8642 (1990). 3/Prjcct Completion Report No. 9258 (1990).  3 3. Project Objectives and Desaiption 3.1 The original objectives of the First Urban Project were: (i) to develop a wide range of housing options in Malawi; (ii) to assist the Government in establishing a self-sustaining housing program; (iii) to introduce various technical innovations in the housing sector; and (iv) to assist Government in addressing the issue of housing subsidies. To that end, the project consisted of the following parts: Part A: The Intermediate Housing Area (IHA) Programme which comprised the development by MHC of about 2,230 plots for intermediate housing, construction of about 2,000 houses on such plots and the provision by New Building Society (NBS) of mortgage loans for these houses; Part B: The THA Programme which comprised the development by MHC of about 500 plots for traditional housing and provision of Building Materials Loans (BMLs) to about 1,000 plotholders; Part C: The Institutional Support and Studies (ISS) Programme which comprised a study of housing subsidies and wage policies, a training programme for small contractors, a land adjudication and registration programme, a building by-laws study and an institutional support programme. 3.2 The project was restructured in 1989. The major content of the restructuring was as follows: The IHA Programme was changed to comprise the development by MHC of 1,490 open serviced plots and 760 plots with houses, the provision by NBS of 760 mortgage loans and 1,490 BMLs as well as some serviced plots for community and commercial purposes; The THA Programme was changed to comprise the development by MHC of about 590 open plots, the provision of 1,190 BMLs to plotholders, and some serviced plots for community and commercial purposes. 3.3 Under the project, proceeds of the Credit were on-lent to MHC and NBS, the agencies responsible for implementation. The Office of the President and Cabinet (OPC) was responsible for the overall monitoring of project activities. 3.4 The project was implemented over nine years and at appraisal total costs were estimated at US$18.2 million, net of taxes and duties. US$15.0 million (82.4%) of this was to be financed by a credit from IDA; US$1.3 million (7.2%) from NBS; US$0.6 million (3.3%) from MHC; US$0.8 million (4.4%) from individuals as mortgage downpayments; and US$0.5 million (2.7%) by the Government of Malawi. Estimates of final project costs indicate of the US$15.8 million total, US$14.5 million (91.6%) was financed from credit proceeds; US$0.2 million (1.3%) from NBS; US$0.5 million (3.5%) from MHC; US$0.1 million (0.6%) from individuals; and US$0.5 million (3.0%) from the Government of Malawi.  4 4. ProJect Design and Organization 4.1 The project design was complex and ambitious. The objectives were clearly stated, however, the capabilities of the implementing agencies (MHC, NBS and OPC) to successfully implement them were wrongly assessed. Moreover, no concentrated efforts were made to strengthen capacity in the crucial areas of financial management, engineering and planning. 4.2 The project failed to address the needs, priorities and desires of the low income urban groups for which it was designed. The project design did not take advantage of the power of the participation of the community (which has now been widely recognized as an effective vehicle in successful project implementation) in detailing its needs, aspirations, standards and affordability levels. 4.3 Time frames and targets set were unrealistic considering the large number of project components. Consequently, the responsibilities for implementation were never clearly understood and the resulting confusion led to slippage in the project implementation timetables. 4.4 Critical issues in the design of the project, like effective demand, affordability levels, financial arrangements, institutional capabilities and organization were not seriously and thoroughly investigated before incorporating them in the project design leading to problems being encountered at all stages of the implementation period. S. Project Imglementation 5.1 Implementation of the physical components of the project got underway after nearly three years of delays caused by: (i) the failure to prepare detailed engineering and planning designs in advance; and (ii) an overall lack of management capacity within the implementing agencies. Although the BML Programme was launched, key issues concerning plot sizes, infrastructure standards and house types on the remaining developments to ensure affordability objectives still needed to be resolved at this stage. 5.2 The financing arrangements for the IHA Programme proved problematic. They required that houses were presold prior to initiation of construction in order to permit funding to be made available during construction. As the house prices needed to be adjusted at the end of construction, MHC experienced difficulties in justifying escalated prices due to the 20% devaluation in 1984 to beneficiaries. The effect was that some beneficiaries could no longer purchase the homes because prices increased above maximum permissible mortgage levels supported by their current incomes, and many could not afford to pay the difference between revised sales prices and mortgage amounts. 5.3 There was major concern over the low proportion of delivered units for which regular payments were being made by the beneficiaries. The financing arrangements were structured such that the largest payment to be made on a unit was due at completion. Beneficiary commitment to loan repayment was low. For a large proportion of units, final payments were not received despite the fact that the bulk of the investment on each unit had been made. Units were frequently occupied at 'near completion', with beneficiaries servicing smaller than expected mortgages. Thus, constraints were placed on the flow of funds and the availability of resources for re-investment in the sector, which in turn contributed to the poor cost recovery records of MHC and NBS.  5 5.4 In 1987, Malawi moved from a fixed interest rate structure to a market-based system, resulting in mortgage interest rates increasing from 13% to 16.75%. However, in accordance with the Development Credit Agreement, it was agreed that NBS could on-lend at a rate of 14.75%. Although NBS increased the period of repayment of mortgage loans from 20 to 25 years to soften the effect of the increased rate, the impact on affordability proved to be substantial. 5.5 Due to foreign exchange control restrictions and delays in approving importation of materials, there was a shortage in the country of corrugated iron roofing sheets, a situation which led to significant delays in the completion of units. This in turn jeopardized the BML Programme. 5.6 One of the most important components of the ISS Programme was the Housing Subsidies and Wages Policy Study. Although, it was deemed crucial to Government's efforts at reforming the entrenched system of subsidizing civil service and other housing, the study was not initiated until the project was in its fourth year of implementation. 5.7 After project appraisal in 1983, a number of developments took place which together made the housing affordability objectives of the project as originally designed, impossible to achieve. Substantial increases in construction costs, escalation in interest rates, and the results of an income survey (in 1987) which indicated that incomes were lower than those figures upon which the project design was based necessitated a review of the project. 5.8 Accordingly in 1989, the project was restructured, with the modifications aimed at: (i) remedying weaknesses in the original project design; and (ii) allowing the Government of Malawi to respond to changes in the external environment. 5.9 In addition to the changes in the content of the major programme components (para. 3.2), made at the time of the restructuring of the project, the Bank undertook, in collaboration with other bilateral agencies, to support the upgrading of squatter settlements, particularly Ndirande in Blantyre. 5.10 Following the restructuring of the project, progress was made for the first time in several components: two sites and the first group of houses were completed and the BMLs Programme for self- help construction was underway; the policy studies under the ISS Programme were completed although policy recommendations remained to be adopted; and after correcting methodological flaws, progress was made in the land registration components. Disbursements increased accordingly from an average of about 4% per annum in the previous five years to 20% in the sixth year. 5.11 Two years after the restructuring, six civil works contracts had been completed and another six were underway, with projects in all four cities started; the BML Programme was progressing well with about 40% (about 600 loans) of the structures for which the loans were given either completed or under construction; over 20% of Blantyre had been surveyed and recorded under the Land Registration Component, which was within the targets set during restructuring of the project; and the final version of the National Building Regulations was completed. 5.12 However, the Small Contractors Training Programme as redesigned, failed to win support of the concerned agencies and was practically ineffective. Moreover, the recruitment of staff to strengthen the implementation agencies proceeded extremely slowly even though these problems were repeatedly brought to the attention of Government.  6 5.13 Despite the physical progress that was made after the restructuring of the project, financial performance, particularly with respect to MHC, began to deteriorate: (i) discrepancies in the balances pertaining to MHC's BMLs were noted; (ii) the amounts due to Government by MHC under the on- lending agreement were not being determined on a consistent basis and, as a result, to date on-lending interest payments have not been made; and (iii) other than with the issue of mortgages in respect of a small number of BMLs, payments to NBS from MHC as required under the on-lending agreements were not being made. Additionally, at the time of project closing, the report on MHC's audited accounts for FY93 was six months overdue. 5.14 Work under the different project components was substantially completed by project closing on June 30, 1993. Although the Closing Date was extended twice (from June 30, 1991 to June 30, 1992 and from June 30, 1992 to June 30, 1993), a considerable balance of SDR 4,107,257.18 remained undisbursed at the time of project closing. This was due to currency devaluations during the project period and savings resulting from the discontinuation of site development at Kameza (509 out of 609 plots originally allocated have yet to be resited). 6. Results 6.1 The implementation of the project saw major changes in focus and orientation due to changes in the economic and financial environment not envisaged at appraisal. The broad major objective of the project did not change, but the specific outputs envisaged at appraisal had to be modified in order to enhance the opportunity of achieving the objectives. 6.2 The modifications sought to put in place a sites and services programme which would eliminate: (i) the large, expensive, fully completed housing options constructed under the IHA Programme envisaged at appraisal (which, by that time as a result of inflation, were affordable only to families above the 92nd percentile of the urban income distribution); and (ii) the subsidized THA projects, and replace these with residential housing developments which would emphasize open serviced plots, small core houses and lower building standards, with full cost recovery, which would be affordable to a broader range of families. In physical terms, the objectives of the project were to a large extent successfully achieved. However, the major development objectives which sought to put housing development affordable to low income groups in Malawi on a sustainable basis, were not realized. 6.3 The Land Adjudication and Registration Component of the Institutional Support and Studies Programme was largely successful. The registration of the whole of Blantyre, including the city center had been completed and was functioning under the Land Registry System at the time of project closing. The benefits of this programme have been realized in: (i) giving greater security of title to both the purchasers and lenders of land; (ii) affording greater protection of interests to proprietors, leaseholders and mortgagees; as well as (iii) permitting dealings in properties to be effected more quickly and cheaply. 6.4 The Housing Subsidies and Wage Policy Study was completed four years behind schedule and failed to provide a comprehensive outline of different options available to Government. One outcome of the study was the UNDP Trust Fund proposal in support of improvement of civil service conditions and operations in Malawi. The Bank was supportive of the proposal provided that the Trust Fund was related to housing policy reform, and not linked to the broader reform of the civil service.  7 6.5 Regrettably, due to the closing of the Project, the Bank was unable to meet its commitment to supporting the Ndirande Upgrading Scheme before the project closed. While UNDP had approved its participation in the detailed engineering phase of the scheme, Shelter Afrique was unable to meet its commitment for the last phase, the Building Materials Loan Programme. 6.6 Since a cost-benefit analysis was not done during appraisal, it is not possible to assess the direct benefits and economic and financial impact of the project in quantitative terms. There were, however, some benefits which were largely intangible: (i) cessation of construction of new subsidized housing; (ii) some progress made towards the provision of credible alternatives to the previous public rental housing and the establishment of a rational basis for the Government to rid itself of obsolete policies; and (iii) efforts made in policy reform of the major institutions in the sector to re-orient them to a new market perspective. 7. Project Sustainabilitv 7.1 The total amount of housing provided through the project will service only a portion of the expected demand. Given the economic climate in Malawi, it is unlikely that the Government will be able to contribute a significant amount of funds to housing development in the foreseeable future. Therefore, it is essential that those institutional and financial reforms begun under the project be firmly established in order to form a basis for sustained housing development beyond the completion of the project. 7.2 The full participation of MHC and NBS and the introduction of effective cost recovery pricing are essential elements in this strategy, by providing a mechanism for continuing mobilization of domestic funds into the housing sector. However, these measures will not be sufficient unless a viable basis is established for continuing the production of affordable housing by MHC and by ensuring that NBS will be able to maintain an adequate growth of funds to sustain the required volume of mortgage lending. To that end, the restructuring of the on-lending arrangements established under the project would facilitate the provision by NBS of down market financing for low income housing on a consistent, sustained basis. 8. Bank Performance 8.1 At appraisal, the Bank overestimated the capabilities of MHC and NBS to implement a project of this nature and did not encourage the use of technical assistance to train local personnel in the key areas of financial management, engineering and planning. 8.2 Supervision missions were carried out irregularly during the early years of implementation, and frequent changes in personnel assigned to the project did little towards ensuring that progress was adequately monitored, or identifying potential problems in a timely manner. 8.3 The extensions of the Closing Date were practical in that they permitted the achievement of a number of project objectives, thereby salvaging some aspects of the project.  8 8.4 The following lessons may be learned from the implementation of the First Urban Project: a) The need to build into the project design greater flexibility to enable adaptation of project activities to changes in the financial and economic environment; b) The importance of focussing on the issue of affordability to low income groups; the accessibility to the low income group would be enhanced by conducting a thorough survey on income distribution in the initial stages of project design and evaluating the impact of changes in the economic environment on the income group most vulnerable to those changes; c) Care needs to be taken to thoroughly assess the institutional capability of the Borrower and the implementing agencies so that measures such as a clearly defined role for local capacity-building in key areas of financial management, engineering and planning can be incorporated into project design; d) The need to ensure that good policy coordination among relevant implementing authorities is achieved so that bottlenecks of an inter-institutional nature that impede progress can be removed; e) The importance of establishing clearly defined and realistic marketing policies within the social, economic and political context of the Borrower's country so as to ensure effective cost recovery and replicability. 9. Borrower Performance 9.1 There was full Borrower participation in the preparation of the project. The most crucial weakness was the inability of the staff of the implementing agencies (MHC, NBS and OPC) to respond adequately to the financial, technical and managerial requirements of the project. This, inevitably, led to stagnation and delays in the implementation of the project. 9.2 Even though there was goodwill and enthusiasm on the part of the Borrower for the project to succeed, there continued to be breaches of key financial covenants of the Development Credit Agreement throughout, and right up to the close of the Credit. 9.3 Overall management of the program lacked coordination. Bottlenecks in the inter- institutional relationships tended to slow down the progress in project implementation. The implementing agencies only started submitting quarterly reports in the fifth year of the project. In addition, there were considerable delays in carrying out staffing and other procedural agreements arrived at during missions which stood in the way of better performance.  9 10. Proect Relationship 10.1 At the beginning, the relatively new relationship between the Bank and the implementing agencies, combined with the shortage of technical expertise and the lack of coordination between MHC, NBS and OPC contributed in part to the slow progress achieved in implementation. However, as implementation progressed, the professional rapport between the Borrower's project staff and supervision missions grew and facilitated the identification of problems and in tackling them. 10.2 After the restructuring of the project, the relationship between the Bank and the implementing agencies was enhanced, as both parties became more determined to salvage the project and achieve results. 11. Consulting Services and Studies 11.1 Although, the recruitment of consultants for the ISS Programme was a condition of effectiveness, there were considerable delays in the selection process. The completed studies did not adequately address the key issues or provide a comprehensive outline of policy options to Government. Government decisions on the policy packages recommended were not taken. 12. Project Documentation and Data 12.1 The Development Credit Agreement (as originally prepared and as amended) was straightforward and an adequate tool for project management in the implementation process. On-lending agreements were prepared by the Borrower for passing on proceeds of the Credit to MHC and NBS were straightforward. However, they proved difficult to implement because of changes in the financial environment in which the project was being implemented.  10 MALAWI FIRST URBAN PROJECT (CREDIT 1528-MAI) PROJECT COMPLETION REPORT PART II. PROJECT REVIEW FROM BORROWER'S PERSPECTIVE The First Urban Housing Project despite problems encountered during project evolution and implementation has enhanced the delivery of housing in the major urban centers of Malawi especially the BML which is the largest project component has assisted in providing the much needed accommodation to various sections of the urban communities. As indicated in Para 6.3 of Part I the benefits of the Land Adjudication and Registration component have accrued to those who were squatters. They have acquired full legal land titles. 1.0 Bank's Performance The Bank's performance during the evolution and implementation of the project had its bottlenecks which affected smooth project implementation. 1.1 Bank Review Missions The Bank's review missions were not consistent. Changes in staff supervising the project affected smooth implementation and retarded progress. The Bank changed the Task Manager of the project five times over the implementation period. Each mission consisted of one or two different personalities who questioned some of the issues already agreed with previous missions. This resulted in constant changes in some aspects of the project and design parameters. There were delays or non implementation of agreements or understandings reached during supervision missions by the Bank e.g. Para 3.7 of September to October 1992 Aide Memoire hence the current cost recovery problems. The critical issues to be looked into at each time whether legal or financial or disbursement or technical aspects to avoid misinterpretation of operational conditions and unnecessary delays. 1.2 Approvals Contract documents for the following works were sent to the Bank in November, 1988 and Bank approval was granted in February 1989 after several reminders: - Bills of quantities and drawings for 80 houses at Chimwankhunda and Blantyre; - Bills of quantities and drawings for 100 houses at Chimwankhunda and Blantyre.  11 - Bills of quantities and drawings for Access Roads in Area 49 Sector I in Lilongwe. Due to such delays, contracts were awarded 8 months later after Malawi had suffered two currency devaluations which eventually affected the contract sums. 1.3 Flexibility The Bank was not flexible enough to allow the Implementing Agencies carry out some of the tasks with a free hand. The Bank imposed rigid conditions which to some extent caused considerable delays and problems. 1.3.1 For example the Bank's condition to pre-sell the houses prior to construction was a very rigid condition. MHC had to market the project using drawings. The majority of the low incomes are illiterate, thus when it came to seeing the actual physical product, they objected and changed their mind resulting into many withdrawals. 1.3.2 With regard to house prices MHC was working at a time when the economic situation was full of uncertainties resulting in price changes. As a result, the people who had agreed to purchase the houses at the original price did not accept the revised prices. This meant going back to marketing. 1.3.3 Another Bank's inflexibility is clearly demonstrated in the infrastructure development at Mchengautuwa in Mzuzu (80 plots). The problem of finding a contractor took almost a year. The tenders were too high and MHC made a recommendation to the Bank to carry out the works by direct labor. The Bank refused and advised MHC to re-advertise. The response was very poor. Finally, the Bank agreed to MHC's recommendations to carry out the works by direct labor. It took almost two years (1990-1992) for the Bank to approve MHC recommendations. 2.0 Borrower Performance The Government and its implementing agencies had problems in timely identifying well trained personnel to be deployed to the project. There were problems in trying to reconcile plot standards with the needs, aspirations, culture and practices of beneficiaries and the Local Authority Bye-Laws. It took a long time for some agencies to open and effectively operate special accounts under the project. Staff turnover in some of the implementing agencies created knowledge gaps and cumbersome staff recruitment procedures in government adversely affected the implementation of some components. Apart from Kameza development which was discontinued pending resiting, all other project sites were developed and the expected goods were delivered. However, the project was vast and complex. Lack of foresight on the part of the government and its implementing agencies as well as the Bank led to operational problems during the evolution and implementation of the project.  12 There were so many unknowns particularly under the BML which lacked careful planning and coordination. Issues like transport for transporting building materials to various project sites was not originally included in the project because the Bank argued that this item was not under the credit. Lack of trained personnel in Accounting, Project Management and Supervision seriously affected the implementation of the project. Lack of appreciation of the project's product on the part of NBS particularly on Cores and Shells caused problems during the implementation of the project. It was originally agreed that NBS was to finance the Shells/Cores as built but later NBS insisted on financing only finished houses. This did not only affect the beneficiaries but resulted in mass withdrawals. It was agreed that interest rate for Shells/Cores would be fixed at 11% per annum and that of BML's fixed at 8.75% per annum. Changes in interest rates between what the beneficiaries were told (8.75%) and what NBS is now charging (20.15%) has resulted into a number of beneficiaries pulling out of the Shell/Core component. This has also affected the affordability levels of the BML beneficiaries resulting in the majority of them being unwilling to formalize mortgage bonds with NBS thereby making cost recovery impossible. 3.0 Lessons Leaned We agree with the lessons spelt out in Para 8.4 on page 8 of Part I plus the following: 3.1 Marketing 3.1.1 Use of drawings to market the houses was inappropriate. During the evolution of the project demonstration houses should have been constructed to enable the people see for themselves what the final product would look like. This could have enabled MHC assess properly whether the project would sell or not. 3.1.2 Lack of foresight during project formulation. The Bank did not allow MHC to construct demonstration houses under the credit. 3.2 Contractor Built Houses 3.2.1 Contractor built houses for low income people have been a failure on grounds of both low quality and high costs. It is not possible to build houses for low income people at affordable prices and of acceptable quality. Caution and marketing prudence should have been exercised when introducing new concepts in the sector such as shell and core housing units.A few on one site should have been built to test the market rather than building over 400 in order to be seen to make physical progress and meet expected donor disbursement targets. 3.2.2. Contractor built houses for low income people should not be considered for future urban housing projects.  13 3.3 Self-Managed House Construction (BML) 3.3.1 The general principles for building materials loans are good. The programme allows full community participation, offers job opporunities to local small contractors and local building materials suppliers. No major problems for this housing delivery system have been observed. 3.3.2 Self-Managed houses construction/building materials loans should be considered in future urban housing projects but at a manageable magnitudes at a time. 3.3.3 The Building Materials Loans system or process needs to be reviewed in order to reduce accounting and stores pilferage. 3.4 Financing Building Materials Loans 3.4.1 MHC should take care of the technical aspects while NBS should take care of the financial aspects. i.e. NBS should deal direct with the beneficiaries from affordability assessment to processing of mortgages without MHC being involved in loan offers and keeping loan accounts, and finally no accounting function for MHC. 3.4.2 The more parties are involved in the on-lending arrangements the higher the interest to be charged to the beneficiary. Therefore, if special low rates are to be maintained funds should be lent directly to implementing institutions. 3.5 Staffmng 3.5.1 There is need to streamline staff recruitment and training procedures in government particularly for project units. MHC is a professional organization. No problems were encountered in the planning, design and in the production of engineering drawings of the project. However, the project was overestimated in terms of MHC's capacity to supervise the project during implementation. Shortfalls were experienced in land surveying due to shortage of qualified/licensed land surveyors, in contract management due to lack of qualified Architects, in stores management in respect of the BML programme and general accounting. 3.5.2 On the technical side, where MHC technical departments could not cope, it deployed the services of consultants in various professional fields. 3.5.3 From accounting point of view, it took too long for MHC to realize the inadequacy of the accounting personnel to handle the various aspects of the project. Corrective measures have since been taken and the situation now appears to be under control. 4.0 Country Programme Reviews (CPRs) 4.1 The two CPRs so far jointly organized by the Government and the Bank have been useful to all involved in the cycle of projects funded by the Bank. We hope such forum would continue to be used for exchange of views and experiences of effective and efficient project design, appraisal, funding, implementation and evaluation and that the recommendations made at such discussions would be followed up and implemented by both the Borrower and the Bank.  14 PROJECT COMPLETION REPORT MALAWI FIRST URBAN PROJECT (CREDIT 1528-MA) PART III: STATISTICAL INFORMATION  15 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE I RELATED BANK LOANS/CREDITS PROJECT TITLE YEAR OF STATUS LOAN/CREDIT PURPOS APPRAISAL (% COMPLE;E COMMENTS Local Government To enhance financial Development and administrative 1992 7 Ongoing. Project capacity of local (2379-MAI) goverrnment system.  16 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 2 PROJECT TIMETABLE ITEM PLANNED DATE REVISED DATE ACTUAL DATE Identification Mission 12/15/79 03/04/80 03/82 Preparation Mission 05/15/80 08/82 08/82 Appraisal Mission 11/28/83 11/28/83 11/28/83 Credit Negotiations 09/17/84 09/17/84 09/18/84 Board Approval 11/27/84 11/27/84 11/27/84 Loan/Credit Signature 03/19/85 Loan/Credit Effectiveness 07/19/85 11/19/85 11/19/85 Loan/Credit Closing 06/30/90 06/30/92 06/30/93 Account Closing 10/31/90 10/31/92 10/31/93  17 PROJECT COMPLEION REPORT MALAWI - FIRST URBAN PROJECT TABLE 3 Page 1 of 2 CUMULATIVE ESTIMATED AND ACTUAL DISBURSEMENTS (US$ million) CUMULATIVE DISBURSEMENTS AT END OF QUARTER BANK FISCAL YEAR AND APPRAISAL REVISED QUARTER ENDING ESIIMATES ESTiMATES' ACTUAL FY 1985 Muxh 31, 1985 0.39 June 30, 1985 0.80 0.80 FY 1986 September 30, 1985 1.31 1.31 December 31, 1985 1.80 1.80 March 31, 1986 2.30 2.31 June 30, 1986 2.80 2.80 FY 1987 September 30, 1986 3.50 3.55 December 31, 1986 4.30 4.30 0.07 March 31, 1987 5.00 5.11 1.60 June 30, 1987 5.80 5.90 1.63 FY 1988 September 30, 1987 6.60 6.50 1.65 Docember 31, 1987 7.40 7.10 1.73 March 31, 1988 8.20 7.70 1.86 June 30, 1988 9.00 8.30 2.35 FY 1989 September 30, 1988 9.70 8.90 2.75 December 31, 1988 10.30 9.50 2.93 Marh 31, 1989 11.00 10.04 2.95 June 30, 1989 11.60 10.60 3.12 FY 199 September 30, 1989 12.30 11.11 3.29 December 31, 1989 12.90 11.60 3.76 March 31, 1990 13.60 12.11 4.86 June 30. 1990 14.20 12.60 5.27  18 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 3 Page 2 of 2 CUMULATIVE DISBURSEMENTS AT END OF QUARTER BANK FISCAL YEAR AND APPRAISAL REVISED QUARTER ENDING ESTIMATES ESTIMATES' ACTUAL FY 1991 September 30, 1990 14.40 12.81 5.60 December 31, 1990 14.60 13.00 7.30 March 31, 1991 14.80 13.21 8.46 June 30, 1991 15.00 13.40 9.96 FY 1992 September 30, 1991 15.00 13.61 11.31 December 31, 1991 15.00 13.80 12.95 March 31, 1992 15.00 14.01 13.75 June 30, 1992 15.00 14.20 13.98 FY 1993 September 30, 1992 14.35 14.50 December 31, 1992 14.50 14.59 March 31, 1993 14.59 14.62 June 30, 1993 14.70 15.30 FY 1994 September 30, 1993 14.93 December 31, 1993 14.46 Original Closing Date: June 30, 1990. Acual Closing Date: June 30, 1993. 'A at October 30, 1989.  19 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 4 PROJECT IMPLEMENTATION TARGET AT: TARGET AT: ACTUAL PROJECT PROJECT ACHIEVEMENT COMPONENTS COMPLMTION COMPLETION l _____________________________ (Originual) (Restructured) INTERMEDIATE HOUSING AREA PROGRAM (IHA): No. of open serviced plot. 230 1,490 1,139 No. of housca 2,000 760 611 No. of mortgage loans 2,000 760 611 No. of building loans 1,490 1,139 TRADITMONAL HOUSING AREA PROGRAM (THA): No. of open serviced plots 500 590 515 No. of building materials 500 1,190 515 loans INSrIlUTIONAL SUPPORT PROGRAM (ISS): No. of tudies 2 2 2 No. of progwmm 3 3 3 Note: The total number of serviced plots developed do not include serviced plots located on bad land, Kameza development which is pending resiting or open service plots reserved for community and commercial facilities.  20 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 5 Page I of 2 PROJECT COSTS AND FINANCING A. PROJECT COSTS APPRAISAL ITEMS ESTIMATES1 ACTUAL2 MK ('000) US$ ('000) MK ('000) US$ ('000) IHA Programme 15,604 11,703 41,706 9,699 THA Programme 1,118 838 11,253 2,617 ISS Programme 1,903 1,429 14,904 3,466 Contingencies: Physical 877 657 Price 4,836 3,627 TOTAL COST 24, 338 18,254 67,863 15,782 October 1984 prices. 2 September 1993 prices.  21 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 5 Page 2 of 2 B. PROJECT FINANCING (US$ million) SOURCE PLANNED %FINAL IDA 15.0 82.4 14.5 91.6 NBS 1.3 7.2 0.2 1.3 MHC 0.6 3.3 0.5 3.5 Private Individuals (as mortgage downpayments 0.8 4.4 0.1 0.6 Govermnent of Malawi 0.5 2.7 0.5 3.0 TOTAL (Net of Taxes and Duties) 18.2 100.0 15.8 100.0  22 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABIE6 PROJECT RESULTS A. DIRECT BENEFITS APPRAISAL REVISED ITEMS ESTIMATES ESTIMATES' ACTUAL Number of Beneficiaries (IHA, THA, BMLs & Mortgage Loans) 2,730 2,750 2,243 After Project Restructuring B. STUDIES SIUDY PURPOSE STATUS IMPACT Housing Subsidies To evaluate budgetary Completed To be used to formulate & Wage Policy Study and equity implications in 1989. policy on wages, of various options to compensation, reduction reduce or eliminate or elimination of housing subsidies, housing subsidies for civil servants. Building By-Laws Study To develop revised Compleed in Used as a basis for building by-laws for in 1990. revised legislation on low cost housing building by-laws. projects. Urban Housing Survey To obtain data Completed Used to modify mix of on urban income in 1988. housing development to distribution and better enhance afford- potential market ability of lower income for house under IHA groups. & THA properties in Blantyre and Lilongwe.  23 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 7 Page I of 4 STATUS OF COVENANTS COVENANTS UNDER DEADLINE FOR CREDIT AGREEMENT SUBJECT COMPLIANCE STATUS Section 2.02(b) Open and maintain NBS Complied with. Special Account. Section 2.02(c) Open and maintain MHC Complied with. Special Account. Section 3.01(b) Government to enter into Complied with. separate on-lending agreement. with NBS and MHC. Section 3.01(c) DLV taufer of plots Complied with; (Part A) on a 66 yr. tranfers done minimum leasehold in 1990. bais. Section 3.01(d)(i) MHC to submit forward work Complied with plan by September 30 of for fust two each year. yeah of prmject. Section 3.01(d)(ii) MHC to submit decription, Complied with. analyis of funncial viability and unpact state- ment of proposed investments over US$250,000. Section 3.01(d)(iii) MHC to rsrve 309 of plots Complied with. for project sites for construction by individuals and/or private developers. Section 3.01(d)(iv) MHC to et sales priceg for Pautially IHA plots/house to: complied with; a. achieve fuU cost recovery; Periodic review b. earn adequate retum; of price by IDA c. meet financial obligations; not carried out. d. contribute to rerves.  24 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 7 Page 2 of 4 COVENANTS UNDER DEADLINE FOR CREDIT AGREEMENT SUBJECT COMPLIANCE STATUS Section 3.01(d)(v) MHC's revenues from Complied with propery management to for FY85 & FY/86; cover the mum of: total Precise amount of operting expense. & MHC debt remains amfbount by which debt undetermined. amortization payments exceed depreciation provisions. Section 3.01(e)(i) NBS' total income from Complied with. operations plus undistributed earnings sufficient to pay dividends and contribute to general reserves. Section 3.01(e)(ii) Periodic review of NBS Partially interest rate sucture. complied with; Reviews carried out; no adjust- mentx made. Section 3 01(f) CarY out Housing By March 31, 1986. Complied with Subsidies & Wage Policy in FY88. Study. Section 3.01(f)(ii) Submnit action progrmme By October 31, 1986. Submitted and timetable for in FY89. implementation of above Study's recommendations. Section 3.04(a) Furnish plans, specifications, Complied with. reports, constracts, construction & procuremet schedules. Section 3.04(b)(i) Monitor progress & keep Complied with. records of goods & service.  25 PROJECT COMPLMION REPORT MALAWI - FIRST URBAN PROJECT TABLE7 Page 3 of 4 COVENANTS UNDER DEADLINE FOR CREDIT AGREEMENT SUBJECT COMPLIANCE STATUS Section 3.04(b)(ii) Allow Association's Complied with. representatives to visit facilities & sites and examine records. Section 3.04(b)(iii) Furnish all inforantion Complied with. requested on costs, and benefits. Section 3.05 Acquistion of land for Complied with. project-related purposes. Section 3.06 Enforce on-lending Not complied agreements with NBS & with. Amounts MHC. owed by NBS & MHC not collected. Section 4.01(a) Maintain records of Partially project-related operations, complied with; resource. and expenditures MHC records not for NBS & MHC. adequately kept. Section 4.01(b)(i) Maintain sepate accounts Paally for withdrawals made on the complied with; buis of statements of MHC records not expenditures. adequately kept. Section 4.01(b)(ii) Retain revelant For I year after In compliance. documentation. Closing Date. Section 4.01(c)(i) Yearly audit of NBS & MHC Partially Special Accounts complied with; MHC accounts for FY92 not submitted.  26 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 7 Page 4 of 4 COVENANTS UNDER DEADLINE FOR CREDIT AGREEMENT SUBJECT COMPLIANCE STATUS Section 4.01(d) NBS & MHC to maintain Partially adequate firncial complied with; records. MHC records not adequately kept. Section 4.01(e) MHC to introduce an By December 31, 1985. Partially accounting mystem to complied with; (in part) identify system not fuincial perfomance adequately of project development naintained. activities.  27 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 8 Page 1 of 2 USE OF BANK RESOURCES A. STAFF INPUTS STAGE OF PROJECT CYCLE STAFF WEEKS Through Appraisal 59.4 Appraisal through Board Approval 4.8 Board Approval through Effectiveness 3.8 Supervision 42.0  28 PROJECT COMPLETION REPORT MALAWI - FIRST URBAN PROJECT TABLE 8 Page 1 of 2 B. MSSIONS SrAOE OF NUMBER STAFF PROIECT OF WES IN SPECIALIZATION PERFORMANCE TYPES OF CYfE MONThJYEAR PERSONS FIElD REPRELSENIFI? RATING STAIUSe PROBIEMS Identification 1081 1 1.4 EN OZR2 5 13.0 EC, FA, EN, UR, QS 1OR2 4 16.0 EC, EN, UR, QS, 07R83 5 11.0 EC, FA, EN, UR, QS Pre-appraisal 1183 6 1&0 EC, FA, EN, UR, QS, AR Appras 03R84 3 2.4 EC, FA, EN 10184 3 Z4 EC, FA, EN Supervnuon 02R 2 2.4 EN, EC 1 05