the world bank and dpls - bank information · pdf filethe world bank and dpls what middle...

The World Bank and

DPLs

What Middle Income Countries

Want

Vince McElhinny

Bank Information Center

February 2011

The Bank Information

Center partners with civil

society in developing and

transition countries to

influence the World Bank

and other international

financial institutions to

promote social and

economic justice and

ecological sustainability

Table of Contents

Executive Summary 3

I Introduction 5

A World Bank MICs and Graduation from IBRD Lending 7

B Development Policy Lending Operational Policy 860 12

II World Bank DPLs and Safeguard Policies 13

III Five Arguments for Inclusion of Development Policy Lending Operational

Policy in the World Bank Safeguard Policy Review 19

A Poor Cost Benefit Analysis of DPLs ndash No Justification of Operation Amount 21

B Improved consultation and transparency is important regarding how DPL

prior actions and triggers are chosen 22

C DPLs and Accountability 23

D DPLs Effectiveness and Additionality Measurement 24

E DPL coordination with Bank instruments and leverage for longer planning

horizons 27

IV DPLs as Instruments to Promote Environment and Governance 29

V Conclusions 34

Bibliography 36

Annex A Recent World Bank DPLs in Brazil 38

Annex B IBRD MIC Countries Per Capita Incomes Lending Eligibility

and Repayment Terms 41

Annex C DPL Trends by Region and Year 43

List of Figures

Figure 1 Nearly 100 of Latin America is a MIC for World Bank 8

Figure 2 Risk Categorization Trends of World Bank Group Portfolio (1999-2010) 14

Figure 3 WBG Lending FY09-FY10 ($Bn) amp Safeguard Policy Applicability

(own estimates from WBG operations data) 15

Figure 4 WBG FY 2010 Finance amp Safeguard Policy Applicability 16

Figure 5 WBG FY 2010 Safeguard Applicability Total 16

Figure 6 Possible Safeguard and Portfolio Scenarios for the World Bank Group

by 2030 17

Figure 7 World Bank Group Portfolio Shares for MIC Non-Graduation Scenario 18

Figure 8 Projects by Institutional Abilities and SupplyDemand Point of Entry

(Figure 1 in World Bank report) 33

List of Tables

Table 1 WB Environmental Projects by Institutional Ability Targeted (from WB report) 3

copy Bank Information Center 2011 ndash For more information visit wwwbicusaorg

McElhinny

3

Executive Summary

In this brief the first of two that focuses on the evolving relationship between the World Bank

and middle income countries such as Brazil we examine the shifts in the Bankrsquos portfolio the

safeguard policy framework and the emergence of new less prescriptive lending instruments

Since 2004 development policy operations (DPLs) have emerged as a preferred financial

instrument for a growing number of World Bank clients including many in Latin America In

FY10 the World Bank approved $26 billion in DPLs representing 52 of IBRD funding

Despite the popularity of DPLs and innovative use in new areas such as promoting reforms in

environmental governance concerns are mounting about effectiveness and accountability

Trends indicate a scenario where traditional safeguard policies may apply to as little as a third of

the World Bankrsquos future portfolio while DPLs and other less prescriptive or accountable

instruments expand as a share of Bank operations to keep middle income countries borrowing

As competing sources of development finance have diminished the relative financial clout of the

World Bank and force it to modernize this institutional reform process must face an existential

question in the coming years Over the next decade many of the Bankrsquos largest borrowers will

approximate the graduation point Should the World Bank continue to privilege middle income

countries with concessional public credit Should middle income countries continue to play

such a decisive role in revising the safeguard policy framework that is most appropriate to the

World Bankrsquos poverty reduction mission for the coming decades

In the first of this two part analysis the DPL is examined as an example of institutional evolution

and a survival mechanism for the World Bank in middle income countries such as Brazil There

are many that view the use of environmental DPLs as a forward looking and promising

innovation by the World Bank and support the experimentation with these new instruments

However as experiments the Bank should emphasize learning and adjustment to fully maximize

DPL potential This brief lays out five recommendations for the World Bank to ensure that this

experimentation with environmental DPLs results in learning and effective development

A full external evaluation of DPLs - a product line that now constitutes 40 of the entire WBG

business is overdue1 Such a future DPL evaluation should emphasize results particularly in

terms of strengthening environmental governance that have so far been overlooked by the

biannual DPL retrospectives produced by management

As the World Bank sets out to review and update its Safeguard Policy framework over the next

two years the Operational Policy 860 governing the use of DPLs should be included in that

review Recent analysis of past Bank efforts to build environmental governance should provide

a further rationale for revising Operational Policy 860 in the area of consultation transparency

1 See PRSC evaluation httpgoworldbankorgEF8P6W17T0 See also a review of six health sector swaps

httpsiteresourcesworldbankorgEXTWBASSHEANUTPOPResourceswp4pdf


McElhinny

4

social and environmental risk analysis and results The brief identifies five areas of DPL policy

guidance that merit revision and could guide a full DPL evaluation

The second forthcoming BIC Info brief examines the SEM DPL in Brazil as an emblematic

example of the observed portfolio and policy shifts from the country and institutional

perspective We present an update of the execution of the SEM DPL and outline several issues

that will determine the loanrsquos effectiveness in the medium term


McElhinny

5

I Introduction

For years the World Bank was the target of criticism in Brazil and much of Latin America for

pushing structural adjustment policies that were conditioned on controversial policies of

privatization market liberalization reduced capital market controls The World Bank also took

its knocks in Brazil for backing disastrous Amazon development projects such as Polonoreste

and Planfloro2 At a time when the Bankrsquos financial influence in Brazil was inflated by

macroeconomic volatility much of the criticism directed at the Bank resulted from the poor

quality of project design and the lack of accountability for processes that harmed people

Now the role of the World Bank in Brazil has changed significantly Not only has the Bank

withdrawn completely from the business of lending conditioned on neoliberal reforms the

current country strategy which ends in 2011 directed about $4 billion per year to Brazil almost

entirely to state and local governments Brazilrsquos borrowing from the World Bank in general is

now a secondary concern with increasing reliance on domestic finance from BNDES (nearly

$US 100 billion in new approvals from June 2009 - May 2010) and foreign direct investment

Brazil remains an active client for the knowledge services that come with doing business with

the World Bank Increasingly however that knowledge is less about what the Bank can teach

Brazil and more about what the Bank can convey from Brazilrsquos experience to other borrowing

countries Like a number of the Bankrsquos largest Part II member countries Brazil has become an

advocate of the World Bank as a multilateral clearinghouse for strategic intelligence about its

competitors in relevant global fora such as the G-20 global climate negotiations and trade

In fact any borrowing from the World Bank is viewed by Brazil more as an economic and

knowledge benefit to the Bank in terms of generating most of the operating revenue from loan

fees (52 of IBRD lending and service fees come from 6 countries) and learning from Brazil

that can then be transferred to other countries The World Bank touts Brazilrsquos leadership in

ldquotackling second-generation development challengesrdquo and innovation in the areas of cash

transfer programs ensuring sub-national fiscal discipline biofuels leadership on global climate

change and the fight against infectious diseases as examples of this knowledge generation3 In a

2008 memo that outlined the many knowledge and financial contributions that the World Bank

derives from its partnership with Brazil the Brazilian executive director cast the relationship as a

de facto Part I donor country

To be sure the role of the World Bank in the governance of Brazil is significantly less

important than the role of Brazil in the governance of World Bank As an active leader in

the G-20 and a coalition of 11 borrowing country chairs on the World Bank Board of Executive

Directors Brazilrsquos influence is one of the primary motivating factors behind many of the

ongoing policy reforms (operational efficiency energy trade environment and safeguard

operational policies)

2 For an overview of Polonoreste and Planfloro see Margaret Keck ldquoPlanfloro in Rondonia The Limits of

Leveragerdquo in J Fox and David Brown ed (1998) The Struggle for Accountability The World Bank NGOs and

Grassroots Movements MIT Press and David Hunter ldquoThe Planfloro claimrdquo httpwwwcielorgIfiplanaflhtml 3 World Bank Country Partnership Strategy Progress Report No 53356-BR March 11 2010 Brazil Economic

Team Quarterly Knowledge Report


McElhinny

6

What Brazil and other middle income countries want from the World Bank is more influence

over the strategic decisions made about the role of Bank in climate politics food security global

economic governance and trade The principal mechanism for this jockeying for power within

the World Bank has been a round of governance reforms that redistributed a small if significant

share of voice and vote authority at the Board level The redistribution of power stopped short of

parity ndash what many borrowing countries demanded However an even bigger battle looms on

the horizon with the 2012 Presidential election at the World Bank and the borrowing country

challenge to the US control over the Bankrsquos executive office since its founding in 1945

The World Bank remains for Brazil an important source of sectoral technical assistance and

policy advice The Bank provides policy advice through public and private sector advisory

services A number of high profile Bank reports were produced in the last five years on sensitive

development issues such as hydroelectric licensing Amazon dieback land administration in the

Amazon large land acquisitions and the most recent Low Carbon Growth Strategy4 However

with increasing homegrown intellectual capacity and South-South cooperation Brazil

commissioned these World Bank studies with a double purpose ndash to both know the Bankrsquos

advice as well as to serve as an instrument of political risk to contain the Bankrsquos influence over

sovereign development policy decisions by the Brazilian government Many of these policy

reports have been censored and watered down by Brazilian authorities to diminish their potential

public impact with World Bank acquiescence ndash another sign of Brazilrsquos growing power within

the Bank

Development Policy Loans (DPLs) are perhaps the most visible expression of this new

relationship between Brazil and the World Bank Created as a new instrument in 2004 the Bank

has piloted some of first types of DPLs in Brazil as in the case of environmental state and

municipal DPLs5 While often large in size (often over $US 1 billion) the DPLs carry a set of

conditions (called prior actions and triggers) to advance a policy agenda that reflects more than

ever the priorities of the borrowing country In other words the DPLs are very much the form of

World Bank cooperation that Brazil prefers to advance its own sovereign policy reform agenda

in contrast to the past where structural adjustment lending was heavily conditioned on unpopular

and painful macroeconomic and monetary policy reforms As one high level World Bank

official put it ldquowe canrsquot treat them like children anymorerdquo

Still the conditions on which the DPLs are designed reflect a sophisticated relationship between

the Bank and Borrower to help each other and have come to codify the driving force of change in

the Bank On one hand DPLs are the quick low accountability vehicles to speed large sums to

middle income clients One the other hand DPLs are a significant profit center for the World

Bank on the basis of low preparation and execution costs compared to loan volume and high loan

charge revenue DPLs represented 36 of WBG lending in a record year and will remain high

despite promises to dial back DPLs as the financial crisis subsides Even as concerns mount

about the development effectiveness of DPLs the evolving political economy that favors

4 See C Gouvello et al ldquoBrazil Low Carbon Growth Strategyrdquo June 28 2010 World Bank

httpgoworldbankorg4FCZ2LFQW0 5 See annex A for a list of recent DPLs in Brazil


McElhinny

7

continuity of the World Bank as an institutional presence in the worldrsquos emerging economies

thrives on DPLs which is what Brazil and the Bank both want

Change at the World Bank reflects a shifting balance of global power Following the 2010

capital increase profound reform processes are underway at the Bank which will be carefully

monitored for their influence on international development standards The focus on DPLs in a

country like Brazil help illuminate the significance of the institutional reform processes now

underway at the World Bank and their impact on the potential dilution or strengthening of

international standards Driven in large part by the demands of emerging economic and political

power like Brazil the revision of World Bank policies for energy environment and social and

environmental safeguards the Bank will be signaling to all other private and public sector

development finance institutions its guidance on new standards for sustainability effectiveness

and rights The strengthening or weakening of commitments to the highest possible development

standards by the World Bank in this reform process will send a powerful signal to institutions

such as BNDES that compete and compare themselves with the Bank and are calibrating their

own institutional policies to the international standards

Any inquiry into the political economy of Bank-government relations that has produced the level

of DPL funding observed in recent years inevitably leads to existential questions about the

sustainability of the current World Bank business model We have witnessed in Latin America a

Bank that has transformed its portfolio and policy regime to suit middle income countries

demanding greater flexibility The DPL is a fundamental pillar of this response to the Bankrsquos

largest clients At the same time some of these same countries (Brazil Argentina and Mexico)

are likely to reach a graduation cutoff point in the near future (next 5-10 years) While many of

the worldrsquos poorest still reside in middle income countries the fundamental question emerges as

to whether a country such as Brazil with $300 billion in international reserves actually needs

concessional public lending that is earmarked for the most intractable development challenges

If middle income countries graduated from the World Bank (ceased borrowing) the revenue loss

would dramatically downsize the Bank and force a refocusing on the smallest and poorest

developing countries The persistence of DPLs in the coming years will represent a crucial battle

ground over this tension between preserving the status quo of constant portfolio growth and the

almost unthinkable alternative of becoming smaller and more focused on needs of the majority of

small vulnerable impoverished countries

World Bank MICs and Graduation from IBRD Lending

In 2005 the World Bank refreshed its strategy for middle income countries (MICs) a poorly

conceptualized term that refers to borrowing countries whose per capita income ranges from

about $1000 to $6000 For a group that includes as its members countries that range in size from

China to St Lucia and range in per capita income from South Korea ($21360) to Paraguay

($2070) there seems to be little coherent rationale for designing a strategy for such

heterogeneous mix of countries

The World Bank has historically claimed that it exists to channel development funds to poor

countries that would otherwise be shut out of capital markets This claim is difficult to defend as

the vast majority of World Bank lending gravitates to countries that no longer need the bank for

development finance The new strategy touts the additionality of World Bankrsquos knowledge


McElhinny

8

services that accompany most lending to MICs but the Bankrsquos balance sheet depends

considerably on the revenues from disproportionate loan service fees from the largest middle

income clients

This renewed emphasis on middle income countries was motivated in part by the downward

trend in borrowing from the largest MICs and the long-term impact that this would have on the

World Bankrsquos balance sheet6 The new MIC approach was also motivated by the mounting

criticism over structural adjustment lending particularly underscored in debates about the

questionable relevance of Bank adjustment lending for explaining countries whose economies

were growing most rapidly after the Asian crisis

What Are Middle Income Countries (World Bank MIC website Map)

Figure 1 Nearly 100 of Latin America is a MIC for World Bank

In 2007 the World Bank Independent Evaluation Group (IEG) assessed the performance of Bank

operations in middle income countries IEG reported that over the past 12 years [through 2007]

the MICs have repaid an annual average of $38 billion more than they have taken out in new

loans7 A decline in borrowing from some of the largest income generators for the World Bank

translated into negative net flows from the countries to the Bank IEG reported that financing

from the World Bank accounted for just 06 of the MICs national investment in 2005 down

from twice that in 1995

6 Washington Post editorial ldquoHelp Where Its Not Needed Rethinking the World Banks role in middle-income

countriesrdquo Sept 21 2007

httpwwwwashingtonpostcomwp-dyncontentarticle20070920AR2007092002299html 7 IEG ldquoAchieving Development Results in Middle-Income Countriesrdquo October 18 2007 Washington DC

httpwwwworldbankorgiegmicconference


McElhinny

9

The World Bank depends on stable business in the MICs because their growth boosts its overall

record and it makes money off them part of which is transferred to IDA for low-income

countries at a rate of about $600 million per year8

In terms of diagnosing why the IBRD portfolio was flagging the IEG report found that the

outcomes of the Banks country programs in middle-income countries have been only

moderately satisfactory on average in meeting varied country-specific development objectives

including promoting growth and reducing poverty It also noted that the Bank effectiveness was

notably worse in confronting high profile challenges such as dealing with inequality combating

corruption and protecting the environment IEG found that more than half its middle-income

borrowers have become more unequal over the decade under review

IEG recommended and World Bank President Robert Zoellick has endeavored to continue its

engagement with MICs by taking steps to produce greater development effectiveness This

would require the Bank to depart from business as usual and to reinvigorate its relationship with

clients focusing on the following four dimensions draw on MIC capacity demonstrate best

practice become more agile and make the most of Bank Group cooperation9

A path less taken by the World Bank is to consider a more strict application of the institutionrsquos

own articles of agreement and have more MICs graduate to self-sufficiency A central question

posted in the 2006 report was ldquoDo Governors support existing IBRD graduation policy or are

there any changes they would like to see in the eligibility of countries for different forms of

IBRD supportrdquo10

From this 2006 management report on the Bankrsquos MIC strategy the eligible

group of middle income countries (MICs) included 14 with gross national income per capita

above the cut-off for initiating consultations on IBRD graduation The Bankrsquos policy on and

approach to graduation is set out in Box 1 (next page)11

More recent estimates suggest that as many as 40 Bank member countries will exceed the

graduation cut off limit within the next 5-10 years (See annex B for updated list of MIC IBRD

countries above the graduation cutoff point12

8 IDA was replenished for three years on Dec 15 2010 for $US 49 billion

9 World Bank IEG (2007) Development Results in Middle-Income Countries An Evaluation of the World Bankrsquos

Support

httplnweb90worldbankorgoedoeddoclibnsfDocUNIDViewForJavaSearchB849A54B45DCC529852574EF00

690F96$fileMIC_evaluationpdf 10

World Bank (2006) ldquoStrengthening the World Bankrsquos Engagement with IBRD Partner Countriesrdquo Report

DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12

See Operational Policy 310 Annex C Financial Terms and Conditions of IBRD Loans IBRD Hedging Products

and IDA Grants httpgoworldbankorgDSETKG32D0


McElhinny

10

Surely graduation cannot represent an objective that the Bank has any interest in delaying Yet

very few countries have actually graduated from the Bank in recent years In fiscal 2007

Estonia Latvia and Lithuania graduated from eligibility for World Bank lending following

Slovenia which graduated in fiscal 2004 and the Czech Republic which graduated in fiscal

2005 No Latin American countries have graduated

The 2006 report left unanswered the question of whether MIC graduation should happen or

perhaps more precisely when and how graduation should happen By most accounts the

decision for a country to graduate is largely voluntary and not mandated by strict triggers

Discretion is left to the Bank and the government to decide Under a graduation scenario the

World Banks future role in the MICs could be different from and probably significantly smaller

Graduation from Borrowing Country Status at the World Bank

From the 2006 report the term ldquograduationrdquo means the formal determination that a

country has attained a level of development that renders it ineligible to borrow from the

Bank Graduation is a clear indication of country success the first country to graduate was

France in 1947 and by the 1970s a number of OECD countries that had borrowed from the

Bank in the 1950s and 1960s also graduated It is grounded in the IBRDrsquos Articles of

Agreement which include as one of the statutory conditions for lending that IBRD be

satisfied that in the prevailing market conditions the member country would be otherwise

unable to obtain the loan under reasonable conditions (Article III Section 4 (ii) see also

Article 1 (ii)) The rationale for excluding a country from Bank lending is based on the

principle that IBRD financing supplements private investment when private capital is not

available on reasonable terms

In 1982 in order to codify Bank procedures for graduation the Executive Directors

approved a graduation policy which they reformulated two years later The reformulated

graduation policy requires that the Bank review a countryrsquos borrowing eligibility if the

countryrsquos per capita income exceeds a certain level This level which has been revised over

time is presently set at $6055 Reaching this level is a starting point for graduation review

and does not exclude countries from Bank lending Consistent with the policy among other

issues the review examines the countryrsquos overall economic situation and its capacity to

sustain a long term development progress with particular reference to two factors (i)

access to external capital markets on reasonable terms and (ii) the extent of progress in

establishing key institutions for economic and social development

The policy gives the Bank flexibility in making these assessments and while the decision on

graduating a country rests with the Bank the 1984 reformulation emphasized that the

relationship between the Bank and its clients was one where graduation should take place

as a ldquonatural outcomerdquo of the evolving relationship between the Bank and its members

Recent graduates include Slovenia in 2004 and the Czech Republic in 2005 The flexibility

implicit in the policy has been clearly demonstrated in the few cases notably Korea in the

late 1990rsquos where countries which have graduated from IBRD lending have obtained new

financing because of the deterioration in their economic circumstances


McElhinny

11

than its past role For those that view a smaller World Bank as a threat the full implications of

MIC graduation represents an existential crisis

Instead the World Bank has made great efforts to revive MIC business with the Bank enhanced

in large part by the global financial crisis However the G-20 call on the World Bank to help

provide emergency liquidity also pushed the Bank to the limit of its capacity to lend as IBRD

approvals shot up by over 200 between 2008 and 2010 As a result IBRD requested a capital

increase and the bargaining over increased capital contributions encompassed both price

increases for IBRD loans as well as greater representation and power for MIC countries on the

Bankrsquos Board of Directors ndash a long standing demand The $86 billion capital increase that was

eventually approved involved a nearly 5 increasing in borrowing country voice and vote

(largely transferred from European countries to China) with an agreement to review the

agreement in five years and adjust loan charges in line with relaxed pressure on the loan to

equity ratio

In the context of shareholder realignment negotiations for the recent capital increase large

middle income countries explicitly tied MIC borrowing to expanded voice and representation A

memo from one COGAM MIC Board member described an initiative by a group of borrowing

countries members to have ldquocumulative IBRD loansrdquo be recognized as a ldquoproxyrdquo indicator for

the contribution of borrowers Cumulative lending by country when considering the IBRD

transfer to IDA is the best proxy of long-term engagement of clients with the Bank as well as

commitment to development according to the memo ldquoMiddle income countries (irrespective of

having being classified as donors or not) have been consistent IDA contributors and have

generated the most stable source of income for the WBG for years This means the net income

produced by operating with MICs is particularly important for our poverty reduction strategyrdquo

The authors extend the argument to suggest that criteria for reallocating incremental voice and

representation should permanently include World Bank debt as a measure of a borrowing

countryrsquos contribution In theory this arrangement could create a moral hazard to increase

borrowing as a means for acquiring more shareholding power

Absent this type of recognition the authors describe what might effectively approximate a

graduation threat

A Board memo that was circulated during the Bankrsquos voice and vote negotiations stated ldquoLetrsquos

suppose that four large MICs drastically reduced their portfolio We know what would be the

financial consequences for the institution including the greater strain on IDA replenishmentsrdquo

The arguments extend to the possible withholding of knowledge services and capacity building

or global public goods cooperation on which the World Bank will increasingly depend as further

reasons for recognizing the full contributions of MICs and creating incentives for their continued

provision

The governance structure of the World Bank Board has been slow to reflect the shifting balance

of power in the world Parity between borrowing and developed economies with no dilution of

voting power of any borrowing country on the Board ndash is the stated preference of many

borrowing country representatives at the Bank The negotiations for the FY10 capital increase

advanced only partially and unevenly toward this goal


McElhinny

12

The bargaining over the conditions of the capital increase that tied increased power for MICs to

support for financial solvency clearly predicated the final agreement on an acceptable set of

incentives to keep MICs borrowing from the Bank However the graduation threat was issued

by a small number of MICs whose concentrated share of Bank borrowing is evident to all In

this sense the category of ldquoMiddle Income Countryrdquo is perhaps intentionally misleading by

grouping the interests of the Bankrsquos largest revenue generators with the majority of the rest

DPLs are undoubtedly one of those incentives and perhaps the single most visible instrument in

the revived World Bank MIC agenda addressing many of the stated concerns of agility

flexibility and use of country systems in new lending instruments The increase in DPL lending

to over 50 of the IBRD lending total in FY10 is due in part to the spike in demand from the

financial crisis However we will see just how flexible and agile the Bank appears as the lost

market rationale for such inflated levels of DPL transfers forces a dialing back of these Bank

services in the coming years ndash particularly for the largest DPL consumers in Latin America

Development Policy Lending Operational Policy 860

This analysis of the DPL underscores the deficiencies of the Bankrsquos operational policy guidance

on DPLs which leaves far too much discretion in channeling large loans with inadequate

accountability The policy provides ambiguous guidance on key accountability mechanisms

such as transparency consultation and the recourse for affected parties So far DPL Operational

Policy 860 has not been opened up for review with the other 8 safeguard policies and one

country system policy (40) This decision to insulate current DPL operational guidance from the

same scrutiny reflects a double standard at the Bank While safeguard policies are widely

framed as net costs to clients DPL policy is treated with a sense of benevolent neglect The

World Bank should acknowledge that the evolution of environmental and social DPLs requires

the same modernization of OP 860 as is called for with other Safeguard policies

There are many that view the use of environmental DPLs as a forward looking and promising

innovation by the World Bank and support the experimentation with these new instruments As

experiments the Bank should emphasize learning and adjustment to fully maximize DPL

potential A full external evaluation of DPLs - a product line that now constitutes 40 of the

entire WBG business is long overdue13

This brief lays out some of the possible topics of a

future DPL evaluation that have so far been overlooked by the biannual management produced

DPL retrospectives

In the second of this two part analysis we examine the Sustainable Environmental Management

(SEM) DPL in Brazil from an institutional and country perspective In the first part the SEM

DPL is examined as an example of institutional evolution and survival at the World Bank in

middle income countries such as Brazil The second part presents an update of the execution of

the SEM DPL and outlines several issues that will determine the loanrsquos effectiveness in the

medium term

13

See PRSC evaluation httpgoworldbankorgEF8P6W17T0 See also a review of six health sector swaps



McElhinny

13

II World Bank DPLs and Safeguard Policies

In the past six years the World Bank Group has pursued approaches to lending that significantly

change the way the Bank Group addresses the potential environmental and social impacts of

activities it supports These approaches primarily involve facilitating the use of borrower rather

than Bank Group standards and institutions to address environmental and social concerns Use

of Country Systems is the framework for this approach as well as the emphasis from

transitioning from prescriptive compliance to more adaptive implementation support in the

context of the Bankrsquos safeguard policy application14

Internal pressure by middle income

borrowers has forced the Bank to review its entire safeguard policy framework and improve the

alignment with client demand

Through these approaches the Bank Group relinquishes to its borrowers primary responsibilities

for identifying and addressing environmental and social risks determining how these risks will

be addressed and monitoring compliance with measures adopted to address these risks As part

of a Bank strategy to promote a Country Systems approach to lending these approaches delegate

oversight responsibilities in the areas of financial management procurement social and

environmental risk management and monitoring and evaluation Without (equivalent) adequate

guarantees of effective client environmental and social institutions some fear that a Country

Systems approach could effectively diminish environmental and social standards and attenuate

Bank Group accountability

The Bank Group claims these approaches help secure stronger development outcomes by

increasing borrower ownership of development processes reducing transaction costs of dealing

with the Bank and harmonizing standards Bank Group reports suggest another motive ndash

reducing safeguards as ldquoobstaclesrdquo to lending to allow the Bank Group to move more money and

increase its competitiveness with competing sources of development finance in India China

Brazil and other middle income countries

This debate about the ldquohassle factorrdquo of World Bank safeguards is complicated by contrasting

evidence On one hand there is no shortage of anecdotal evidence of Bank managers reporting

lost business due to stated client discontent with safeguard requirements In fact the volume of

WBG lending has increased dramatically in recent years and the portfolio composition

dramatically reflects decisions already taken to accommodate clients that want to avoid the

ldquohassle factorrdquo of Bank safeguards On the other hand a recent empirical analysis shows that the

economic benefits of the Bank safeguards clearly outweigh the costs for recent operations15

Indeed persistently weak supervision of Bank projects leaves serious gaps in evidence to support

any argument about the association between safeguards and effective development16

IEG

underscores evidence of weak project supervision particularly for lending to financial

intermediaries DPLs and trade finance More than one third of World Bank projects reviewed

14

World Bank Use of Country Systems approach page httpgoworldbankorgRHRJVXDW60 15

Both sources of evidence are described in detail in the IEG evaluation Safeguards and Sustainability Policy in a

Changing World (2010) 16

IEG (2010) Safeguards and Sustainability Policies in a Changing World


McElhinny

14

had inadequate

environmental and

supervision and

monitoring of results

Accountability is

compromised further by

weak disclosure

particularly in the area of

third party monitoring of

financial intermediaries

For reasons that are

further elaborated upon in

the following sections of

this brief the current

operational policy 860

governing the use of

DPLs falls short of

providing adequate

safeguard protections

Some of these approaches to lending additionally cede to the borrower the authority to decide

how Bank Group funds will be used Lending to financial intermediaries for example leaves

the intermediary and not the Bank choosing and approving projects to be funded This

delegation of authority raises a concern that the Bank Group is failing in its obligations to ensure

that Bank Group funds are used in a manner that is consistent with Bank Group Articles of

Agreement and poverty alleviation missions

The challenge inherent to the ongoing investment lending reform and the review of the entire

Operational Policy framework will be to avoid pressure to simply adopt policy that ratifies the

status quo hastening the proliferation of low accountability instruments and lending share

In its safeguard evaluation IEG describes the evolution of the World Bank portfolio with the

following chart A decade ago only 9 percent of lending was classified as category A (very high

impact) 44 percent as category B (substantial impact) 29 percent as category C (low impact)

and 4 percent as category FI (financial intermediary) By 2010 the distribution of overall

portfolio risk categorization has changed substantially The proportion of category A increased

from 5 to 11 percent with the increase in the volume and scale of infrastructure lending

Category B increased from 37 to 51 percent while category C dropped from 40 to 18 percent

The proportion of WB projects classified as category B increased by a third while category C

decreased by half reflecting greater caution during project preparation IEG argues that rules for

categorization of risk vary across the World Bank Group and speculates that the expansion of B

risk categorization could indicate an avoidance of the most restrictive safeguard procedures17

17

IEG (2010 12) IEG points out problems both in terms of over and under ndash categorization of risk

Figure 2 Risk Categorization Trends of World Bank Group Portfolio

(1999-2010)


McElhinny

15

IEG observes that ldquothe safeguards and sustainability policies were originally conceived for

investment projects They are more difficult to apply to other forms of lending including

programmatic lending sector-wide lending and decentralized projects at the World Bank trade

finance and equity investments at IFC and financial sector lending at MIGA All three

portfolios appear to be growing in precisely those segments where these policies face their

greatest challengesrdquo18

Another perspective of the trends in WBG lending is presented in the following graphs The

percentage of World Bank Group lending that is being conveyed through instruments that have

little or no safeguard applicability is highlighted below in Figure 3 FY 2010 was the highest

level of WB lending on record which also produced over $36 billion in instruments with low

safeguard applicability such as Development Policy Loans (DPLs) - $261 billion IFC Financial

Intermediaries (FI) - $66 billion IBRD Financial Intermediaries - $33 billion and carbon

finance (unknown)

Figure 3 WBG Lending FY09-FY10 ($Bn) amp Safeguard Policy Applicability (own estimates from WBG

operations data)

The emerging picture illustrated in Figures 4 amp 5 below is one in which an increasing overall

percentage of World Bank operations (as much as 44 in FY 09 and 50 in FY10) has little or

no effective safeguard protection Compare the $26 billion in DPO lending in FY10 to the

averages in past years which peaked at about $14 billion at the height of the Asian financial

crisis but has generally been $5-6 billion

18

IEG (2010 10)

World Bank Operations for

which there is little unclear

or no Operational Safeguard

Applicability


McElhinny

16

Figure 4 WBG FY 2010 Finance amp Safeguard Policy Applicability

Figure 5 WBG FY 2010 Finance and Safeguard Policy Applicability


McElhinny

17

This troubling trend raises the fundamental question of what type of World Bank will emerge

from the ongoing policy reform process in the coming years At least two scenarios are possible

and illustrated in Figure 6 Which possible scenario is likely to emerge remains an open

question but will have profound implications for the utility of the safeguard policies in the

definition of Bank relevance

If current trends that cater to middle income country interests persist the business model for the

future involves unlimited growth and an ever diminishing percentage of lending that is governed

by meaningful safeguard policies Under this growth strategy middle income countries that now

control a highly concentrated share of International Bank for Reconstruction and Development

(IBRD) lending and on whose loan service fees the IBRD depends do not graduate from

borrowing to donor member status

An alternative Bank Group business model rests on the graduation of middle income country

borrowers to focus on the smaller and perhaps more challenging development issues Such an

alternative would likely involve a reversal of the current decline of Bank Group share of

operations that have little or no safeguards application

What is the future of the WBG

67

33

FY 20092000-2008 WB Ave Lending $15 Bnyr

60 IBRD Portfolio in 6 of 135 countries

MIC GraduationWB Ave Lending

$5-8 Bnyr

33

67

FY 2030Ave Lending $20-25 Bnyr

WBG FY 2010 Finance and Safeguard

Policy Applicability

5050

SG applicable SG not fully applicable

Figure 6 Possible Safeguard and Portfolio Scenarios for the World Bank Group by 2030


McElhinny

18

For the future lending scenario for

the IBRD and IDA portfolio that

assumes no graduation of MICs

the lowno safeguard instruments

would match DPLs with Results

Based Lending and an expansion

of other policy framework type

instruments (see Figure 6)

Conventional investment lending

for which the current safeguard

regime is designed would be

reduced to about 33 of the total

portfolio DPLs which have

experienced a dramatic increase

partially induced by the liquidity

squeeze in recent years would

decline to a historical average of

about 33 A new Results Based Investment Lending instrument currently under preparation by

the Bank to ease safeguard requirements for certain types of social sector and other low risk

operations combined with Sector Wide Loans (SWAPs) could occupy a final third of the

IBRDIDA portfolio In effect the current safeguard regime could apply fully to only about 13

of the Bankrsquos operations

Figure 7 World Bank Group Portfolio Shares for MIC Non-

Graduation Scenario


McElhinny

19

III Five Arguments for Inclusion of Development Policy Lending Operational Policy in the World Bank Safeguard Policy Review

In September the World Bankrsquos Independent Evaluation Group released a two year study of the

safeguards and sustainability policies in use by the World Bank Group (WBG) to prevent or

mitigate adverse impacts of its projects on people and the environment This two year study

assessed the effectiveness of the current safeguards regime and called for the Bank to move

beyond a ldquocompliance based approachrdquo to safeguards which is becoming ldquoless effective as its

portfolio moves beyond traditional investment projects (which now constitute less than half of

new lending across the WBG)rdquo19

The IEG Safeguards evaluation proposes a full review of the World Bank safeguard policy

framework following the ongoing review of the IFC Performance Standards review to

harmonize and modernize standards across the Bank Management has vigorously embraced

IEGrsquos top recommendation and a two year review of global good practices of safeguard

practices at the IFI national and subnational (private sector) level The two year review process

will generate a policy paper outlining recommendations for how the Bank should update its

safeguard policies

The IEG study underscores the observation that the WBG portfolio is growing most quickly in

the segments where the safeguard policies face their greatest challenges While the rapid growth

in demand for DPLs (as with lending through financial intermediaries and for operations

governed by policy frameworks like SWAPs) is a sign that the safeguard policies are

increasingly outdated development policy lending was excluded from the IEG analysis ldquobecause

it is not subject to the same environmental and social requirementsrdquo20

ldquoSince safeguard policies

do not apply to DPLs financed by the World Bank which are governed by the Operational

PolicyBank Procedure (OPBP) 860 DPLs are excluded from this evaluationrdquo21

Management and the Bank Board endorsed the exclusion of DPL policy as well ldquoResponding to

a few speakersrsquo interest in a review of safeguards for development policy lending (DPL) Bank

Management noted the different nature of DPLs and that these requirements and practices will be

reviewed in the context of DPL retrospectiverdquo22

This missed opportunity to assess one of the

thornier concerns about effectiveness in the evolving Bank portfolio has resulted in providing

Bank management the freedom to exclude DPL operational policy 860 from the 24 month

policy review

19

IEG (2010) ldquoSafeguards and Sustainability Policy in a Changing Worldrdquo including World Bank Group

Managements response httpwwwworldbankorgiegsafeguards pg xiii 20

IEG (2010 xiv) IFC analysis by IEG was hampered in part by the lack of project level results since the 2006

Performance Standards and Sustainability Policy was approved Still IFC operations particularly the growing share

to financial intermediaries were included in the sample 21

IEG Safeguards in a Changing World (2010) pg 5 22

IEG Safeguards in a Changing World (2010) Management response pg xliv


McElhinny

20

In 2004 The Bank adopted a national regulatory systems approach to Development Policy

Lending in 2004 under Operational Policy 860 The Policy directs the Bank to consider the

ldquoborrowerrsquos systemsrdquo to ensure consideration of environmental and social concerns If

shortcomings in this system are identified the Bank describes how such gaps would be

addressed ldquobefore or during program implementationrdquo The Inspection Panel is mandated to

consider complaints that OP 860 has been violated yet OP 860 is not really a safeguard policy

because it does not recognize an affected population The Inspection Panel cannot provide

adequate recourse when the Bank may have violated this or other Operational Policies

In FY09 DPOs represented close to 50 of all IBRD and IDA lending Many DPOs lack

transparency are poorly consulted and whose attributable effect on the policy choices taken or

not by borrowing governments is widely debated A rapidly growing appetite for DPLs despite

accountability gaps infers pressure to move money over incentives for results

DPLs are nevertheless one of the central concerns of the Bankrsquos review of its Environmental

Strategy which has also been underway for the past year Several background papers

commissioned for the strategy review process address the effectiveness of DPLs and the track

record of the Bank in clearly defining and producing results in terms of sustainability policy

reforms

One background paper for the Environmental Strategy currently under internal review at the

Bank focuses on the effectiveness of recent Environmental DPLs which have been piloted

disproportionately in Latin America and include the SEM DPL23

Focusing on the 16

Environmental DPLs approved by the World Bank in energy water etc including some

Programmatic Reform Support Credit (PRSCs) with Environmental Conditions the paper

explores how governance was strengthened ndash defined as the ways that capacity was built where

inter-sectoral coordination was fostered and sectoral stories or patterns of policy change can be

attributed to the DPL The objectives of environmental DPLs have been to support reforms that

strengthen environmental institutions and better define roles and responsibilities improve

intersectoral coordination and bolster environmental management instruments including the

EIA

This paper attempts to assess the impacts of environmental DPLs in bringing about long term

policy shifts promoting sustainable institutional reforms influencing broader environmental

outcomes and promoting poverty alleviation and social development Environmental

mainstreaming indicators for DPL effectiveness that attempt to record the real ldquogainsrdquo behind

these environmental DPLs (eg increased attention to environment in policy agenda increases in

budgets for environment ministries etc) are considered While facing challenges relating to

attribution and establishment of a counterfactual attempt to gauge the relative impacts of the

Bankrsquos environmental DPL when compared to the impacts of sectoral lending24

23

Anjali Acharya The Role of Environmental DPLs in Supporting Environmental Sustainability Assessing

Experience Learning Lessonsrdquo Forthcoming 24

World Bank 2010 Environmental Strategy review background paper on environmental DPLs concept note

httpgoworldbankorgDIBGYL7SF0


McElhinny

21

Unfortunately DPL Operational Policy 860 is not covered in the Environmental DPL

background paper Another Environmental Policy background policy on Environmental

Mainstreaming will apparently address OP 86025

Some of the core concerns noted by CSO inputs regarding the effectiveness of Environmental

DPLs include

Poor Cost Benefit Analysis of DPLs ndash No Justification of Operation Amount

DPL program documents include no cost-benefit or cost effectiveness metric such as an

economic rate of return (ERR) Like emergency loans sector wide support loans and operations

such as community driven development projects for which the final use of Bank funds is not

explicitly known at the time of approval DPLs rarely include ERRs Lack of data is a major

reason particularly in terms of quantification of benefits for specific sectors (education health

and environment) In a recent evaluation of use of cost benefit analysis in Bank operations IEG

takes great issue with the reasons behind the ldquonot applicablerdquo justification for missing ERRs26

IEG reminds us that not knowing the final use of the funds poses a problem for any ex-ante

analysis let alone a full-fledged CBA Environmental DPLs are conditioned on policy reforms

that should be in some way associated with the value of the operation Some explanation of the

cost effectiveness should be included in the program document Lacking a reliable cost

effectiveness metric DPLs are inherently limited in explaining effectiveness

Government officials have also complained that they didnrsquot know how the DPL funds are

allocated and would like to see earmarking of DPLs funds for the institutions that are allegedly

being strengthened While the rapid increase in DPL use indicates the popularity of this

instrument for many governments some would prefer earmarking the DPL funding for certain

sector budgets The World Bank reminds us regularly that OP 860 is clear in demarcating the

independence between the use of the DPL funds and the actions outlined in the policy matrix

The DPL disburses to the Minister of Finance while the conditions are often pertinent to other

institutions For the Bank there is no need to track the use of the DPL funds which are pooled

within a specific national treasury account and used as the country sees fit

The political economy of any national context inevitably influences the use of the DPL funds

although the negotiations are often informal and therefore are not addressed in any way by the

guidance provided by OP 860 An Environmental Minister may negotiate a DPL with the

World Bank to provide budget support requested by the Ministry of Finance that in return

approves an investment loan to the environmental sector These informal negotiations permeate

most if not all DPLs yet are not reveled to the public through any cost effectiveness assessment

in the DPL appraisal Earmarking some or all of the DPL funds might offer a safeguard to the

potential corruption that is often associated with informal negotiations over the use of

concessional credit

25

World Bank 2010 Environmental Strategy review background paper on environmental mainstreaming concept

Note httpgoworldbankorg71Z7N0J5M0 26

See McElhinny ldquoWorld Bank evaluation shows decline of cost benefit accounting as criteria for project

approvalrdquo httpwwwbicusaorgenArticle12161aspx


McElhinny

22

More importantly all DPLs should include an explanation about how the total operation amount

was derived and how the specific instrument was compared to other alternative instruments If

the DPL is associated with any budget allocations this relationship should also be clarified

Improved consultation and transparency is important regarding how DPL prior

actions and triggers are chosen

DPLs provide for very little transparency and consultation for decisions directly related to the

design and implementation of the loan While DPLs might reflect appropriate policy areas they

often lack legitimacy because few know how those specific conditions were defined in the

context of the DPL results matrix Civil society organizations also argue that the ambition of the

conditions is not consistent with the privileged access to concessional lending The key concern

is rewarding governments for doing too little in advancing sustainability reforms The process of

establishing priorities that eventually inform the design of the DPL begins with the Country

Strategy The prior actions for an Environmental DPL should be consistent with priorities

identified in the Country Environmental Analysis (CEA) ndash the World Bankrsquos primary upstream

planning document The CEA should in turn identify social and environmental objectives

strategies and results in the Country Assistance Strategy The Bank consults widely in the

formulation of these two important country programming documents The DPL design rests on

this 1-2 year dialogue and planning process

In moving from the CEA and Country Assistance Strategy (CAS) to the specific DPL conditions

(prior actions and triggers) the Bank significantly reduces transparency and consultation The

Bank Operational Policy 860 guidance on consultation for DPLs is vague and provides

tremendous discretion to the Task Team Leader

Consultations and Participation

As part of its country dialogue the Bank advises borrowing countries to consult with and

engage the participation of key stakeholders in the country in the process of formulating

the countryrsquos development strategies27

For a development policy operation the country

draws on this process of strategy formulation to determine in the context of its

constitutional and legislative framework the form and extent of consultations and

participation in preparing implementing and monitoring and evaluating the operation

Bank staff describe in the Program Document the countryrsquos arrangements for

consultations and participation relevant to the operation and the outcomes of the

participatory process adopted in formulating the countryrsquos development strategy

Relevant analytic work conducted by the Bank particularly on poverty and social

27

Key stakeholders include social groups directly affected by the operations as well as public sector private sector

and donor organizations relevant to the operation Country strategies include the poverty reduction strategy paper

(PRSP) process in IDA counties or the countryrsquos overall or sectoral development strategy in IBRD countries For

internal guidelines to assist in the application of OP and BP 860 on consultations and participation staff may refer

to the Good Practice Note in Supporting Participation in Development Policy Operations


McElhinny

23

impacts and on environmental aspects is made available to the public as part of the

consultation process in line with the Bankrsquos disclosure policy28

Beyond the formal consultation on general programmatic goals the Bank guidance on specific

DPL consultation and participation refers to a best practice note that delegates responsibility to

government in the context of national laws Two problems emerge with Bank DPL guidance

First OP 860 stops short of establishing minimal criteria for assessing the effectiveness of these

commitments Second national level consultations may not be adequate for decision-making

related to defining the specific conditions for the DPL

The Bank often suggests that national level consultations such as for the National Climate

Action Strategies are in fact the basis for legitimizing the design of the DPL which includes

prior actions that may be aligned with the targets of this Climate Plan However in practice

there is little explicit guidance for assessing the alignment the quality of the chosen performance

targets or the means for verification of evidence of compliance with DPL conditions In a

number of cases the key DPL documents are not translated into a native language further

limiting the possibility of adequate consultation Finally the program document that outlines the

specific policy reform matrix is not disclosed prior to Board approval thus reducing oversight at

the most significant decision point in the preparation process

A recent Bank Inspection Panel preliminary investigation into reported problems with a DPL

preparation in Yemen validated claims by local civil society organizations that adequate

transparency and consultation had been lacking Before the Inspection Panel formally launched

a full investigation Bank management acted to translate the program document into Arabic and

expanded the scope of consultation in reaction to the Inspection Panel initial inquiries into the

project29

In sum DPLs are not adequately transparent or properly consulted which in turn raises

many questions regarding the quality of the design and outcomes It is recommended that

the World Bank also move away from reliance almost exclusively on dialogue with the

government to define the prior actions and triggers of Environmental DPLs Transparency

reforms for DPLs should involve the disclosure of a pre-approval draft program document The

World Bank access to information policy permits simultaneous disclosure of the draft DPL

program document when it is submitted to the Board prior to approval The borrowing country

may object and block simultaneous disclosure but must explain the rationale30

28

World Bank Operational Policy OP 860 point 6 29

See World Bank Inspection Panel eligibility report for Yemen DPL

httpsiteresourcesworldbankorgEXTINSPECTIONPANELResourcesYEMEN_WHOLE_FINAL_ELIG_REPO

RTpdf 30

See Bank Information Center ldquoUnlocking the World Banks Access to Information Policyrdquo

httpwwwbicusaorgenArticle12148aspx and World Bank Access to Information site section on Simultaneous

Disclosure httpgoworldbankorgZQHL6PS6G0


McElhinny

24

DPLs and Accountability

Guidance on assessment of environmental and social impacts in the design of DPLs under

OP 860 is ambiguous and therefore subject to excessive discretion in the alignment of the

DPL with the magnitude of risk There are two ways in which weak accountability associated

with DPLs can undermine effectiveness First DPLs conditions tend to focus less on

strengthening accountability for the reforms themselves and rarely if ever include conditions

that empower demand for accountability within society As illustrated in the Environmental

Governance paper cited above the Bank has provided unbalanced support to governments in

pursuit of strengthening environmental norms and institutions often ignoring accountability

mechanisms Environmental DPLs have also missed the opportunity to build governance from

below by including explicit conditions for strengthening social controls and other institutional

checks and balances that could improve governance and enhance the probability of achieving

DPL results

Secondly OP 860 does not adequately recognize or enable an affected population that might be

harmed policy by reforms promoted by the DPL with proper recourse if they perceive Bank

policies to have been violated By providing ambiguous guidance on social and environmental

due diligence DPLs effectively disarm Bank lending from a key component of a real safeguard

function Given the wide discretion for compliance with OP 860 populations that might be

affected by policy reforms are disadvantaged

Operational Policy 860 states

Environmental Forests and other Natural Resource Aspects

The Bank determines whether specific country policies supported by the operation are

likely to cause significant effects on the countryrsquos environment forests and other natural

resources31

For country policies with likely significant effects the Bank assesses in the

Program Document the borrowerrsquos systems for reducing such adverse effects and

enhancing positive effects drawing on relevant country-level or sectoral environmental

analysis If there are significant gaps in the analysis or shortcomings in the borrowerrsquos

systems the Bank describes in the Program Document how such gaps or shortcomings

would be addressed before or during program implementation as appropriate32

Recent environmental DPLs are addressing some of the thorniest policy reforms on sustainable

development in developing countries that inevitably encounter populations affected by the social

and environmental impacts of these reforms Reforms in the areas of hydroelectricity licensing

forest governance air and water quality mining remediation payments for environmental

services among other issues identified by DPLs all involve challenging negotiations between

winners and losers from the outcome of these reforms The World Bank walks a fine line in

attempting to reinforce country ownership of the reform process at the same time that it takes a

31

For internal guidelines to assist in the application of OP and BP 860 on analyzing environmental and natural

resource risks and opportunities in development policy lending staff may refer to the Good Practice Note on

Environmental and Natural Resource Aspects in Development Policy Lending 32

OP 860 point 11 An equally ambiguous paragraph provides guidance for social impacts


McElhinny

25

position on the most effective way to influence the incentive structure for that process The

current guidance on DPLs provides little leverage to communities potentially harmed by the

Bankrsquos choice of policy reform incentives to defend their rights enshrined in the traditional Bank

safeguard policies

On both counts compared to the Bankrsquos safeguard framework for traditional investment loans

DPL Operational Policy provides significantly less accountability to affected communities that

want to defend or challenge the proposed DPL conditions or the process in which these

conditions were negotiated or implemented

DPLs Effectiveness and Additionality Measurement

DPL Operational Policy has an inadequate framework for measuring institutional

capacity which diminishes the ability to demonstrate DPL effectiveness and clarify World

Bank additionality

Specifying the attributable value added by DPLs to countries development process is an art

rather than a science made more challenging by the lack of clear guidance for establishing a

baseline for institutional capacity or measuring improvement in a systematic and reliable way

OP 860 does not distinguish between different institutional contexts consistent with a pattern

identified in World Bank environmental governance operations more broadly that demonstrate

little apparent differentiation between size stability or income level of a particular country33

Lacking a clear framework for measuring the effectiveness of Bank effort to strengthen

institutional capacity DPLs designed largely to do build this capacity will miss opportunities to

generate knowledge and accountability for performance

Inadequate results frameworks are often a strong signal that proper supervision is also unlikely

IEGrsquos evaluation of Bank safeguard effectiveness shows an incentive structure that fails to

ensure adequate supervision of safeguards during implementation Supervision weaknesses

include the lack of specified social and environmental safeguard outcome indicators to be

monitored third party independent monitoring and validation of client provided monitoring

information and the overall poor use of supervision budgets compared to project risk34

Considering these observed problems with the quality control of Bank operations during project

implementation DPL should ensure evidence-based results that begin with a robust monitoring

and evaluation framework

Environmental DPLs are designed to strengthen environmental governance build capacity and

foster inter-sectoral coordination The Bank claims that DPLs are instrumental for promoting

policy dialogue in environments where the Bank has had limited prior policy engagement or

where no prior Country Environmental Assessment exists The DPL can foster consensus

building around key reforms In contexts of emerging environmental institutions DPLs can

enhance the credibility of a new Ministry of Environment and further policy priorities

33

Env governance - 34

IEG


McElhinny

26

particularly where environmental goals are missing from national development plans or sector

planning is weak

For clients with more robust environmental contexts DPLs should carry more ambitious

performance indicators that are fully consistent with stated national development objectives

Clients with established environmental capacity view environmental DPLs as an improvement

over past structural adjustment loans in which the conditions were imposed and not necessarily

aligned with government development programs In contexts of established capacity DPL

results should align clearly with stated national goals but clearly demonstrate additionality

Effective policy change has impact is a long-term process and one DPL cannot be evaluated on

the basis of generating these impacts Reform success is usually difficult to explain and require a

combination of quantitative and qualitative indicators Assessing impact would require a

methodology that explores ldquoprior actions or triggersrdquo in depth that incorporates counterfactual

analysis (ie what would have happened without the WB DPL) The Bank should also pursue

qualitative indicators process tracing analytical narratives

However the commitment of time and resources for counterfactual approach to monitoring and

evaluation of DPL outcomes is often more than what most clients are willing to borrow and

conflicts with the premium placed on rapid DPL turnaround time A more robust monitoring and

evaluation framework for measuring the quality of reform options chosen and implemented will

be a determining factor in the debate about whether DPLs are really about learning to more

effectively promote national policy reform agenda or just pushing money out the door

Are DPLs hypothesis driven or knowledge seeking Given the World Bankrsquos reputation as a

knowledge bank the monitoring and evaluation track record is surprisingly weak when it comes

to environmental DPLs For the 16 most recent environmental DPLs only 1 Implementation

Completion and Results Report (ICR) is available35

This condition of lax self assessment on

DPLs reinforces the recommendation that IEG should evaluate DPLs annually and periodically

assess impact IEG evaluations should focus on outcomes a missing element in the

managementrsquos stylized DPL retrospectives and provide the rational for good practice methods

for MampE which are addressed only indirectly in the current Operational Policy36

ICRs should be

available sooner in programming cycle to ensure learning is transferred to sequential DPLs

Without a more robust institutional evaluation framework DPLs are susceptible to misuse in

instances of rewarding reforms that would have happened without the DPL Unclear variability

in the size of DPLs is explained in part by the lack of clear guidance regarding the alignment

between DPL policy framework with the institutional context

35

World Bank Environmental Strategy 2010 Background paper ldquoThe Role of Environmental DPLs in Supporting

Environmental Sustainability Assessing Experience Learning Lessonsrdquo Concept Note April 2010 accessed June

2010 but no longer available on World Bank website 36

World Bank (2008) ldquoAssessing the Environmental Forest and Other Natural Resource Aspects of Development

Policy Lending A World Bank Toolkitrdquo

httpsiteresourcesworldbankorgEXTEEIResourcesWBDPLTooklitCRA1pdf


McElhinny

27

DPLs Operational Policy should be consistent with the proposed revisions to the World Bank

Environmental Strategy that indicate a five point framework for measuring institutional

capacity37

a Capacity strengthening both at the national and subnational government level based

clear baseline indicators with increasing emphasis on adaptive problem solving

capacity

b Inter-institutional coordination the formation of effective inter-ministerial working

groups or committees frequency and quality of working group meetings products

civil society participation as an index of the overall quality of this coordination

c Strengthening enforcementcompliance clarity of institutional roles and

responsibilities evidence of performance independent monitoring and verification

of evidence

d Enhancing reform capability improved understanding among key actors about how

policy reform happens sustainable finance mechanisms for reforms

e Facilitating outreach to different audiences including CSOs public disclosure

accountability mechanisms)

DPL effectiveness is limited by suboptimal results frameworks Improved guidance to OP 860

in the design of DPL monitoring and evaluation frameworks including increased reliance on

external or independent monitoring and evaluation is recommended

DPL coordination with Bank instruments and leverage for longer planning horizons

There is little differentiation among DPLs that maximize coherence with relevant Bank

investments or to achieve planning commitment for longer time horizons

How can DPLs contribute to policy change and institutional reforms that often require sustaining

the reform process for 10 ndash 20 years when a DPL is only 1-3 years in duration DPL

effectiveness can be enhanced when synergies with other Bank instruments are maximized over

as long a timeframe as possible As such DPLs should be explicit in defining parameters for

cross-conditionalities with technical cooperation investment lending and advisory services by

the Bank as well as coordination with other sector bilateral and NGO cooperation DPLs should

privilege clients that subscribe to programmatic operations (have multiple stages) that sustain

certain design principles and results frameworks for longer periods

The World Bank is misusing environmental DPLs if they are designed to achieve the proposed

performance targets by themselves Environmental DPLs with appropriately ambitious

performance targets that advance complex policy agendas such as moving investment toward a

low carbon development path are not likely to succeed in the absence of complementary

instruments Where Environmental DPLs have had been most effective (as in the case of

37

These five areas are outlined first in the World Bank 2003 World Development Report


McElhinny

28

promoting a clean energy and transport policy agenda in Mexico) the Bank has coordinated

environmental DPLs with government initiatives as well other Bank instruments

Synergy between DPLs and different Bank instruments is maximized by evidence of coherence

across a suite of possible Bank services contemplated within a country strategy DPLs are just

one incentive to sustain reforms but should be complemented by advisory servicestechnical

cooperation or in other words certain non-reimbursable resource incentives investment loans for

capacity building that are also programmatic and analytical reports that focus on raising the

visibility of key issues

Where governments are pursuing REDD strategies with World Bank assistance as in the case of

the Forest Carbon Partnership Facility (FCPF) an Environmental DPL should be synchronized

with the Readiness Plan to leverage the Bankrsquos role in both processes

DPL effectiveness is ultimately measured in the long term Continuity of the policy reform

process is therefore an important variable in maximizing DPL effectiveness The Bank suggests

that clients often want sequenced programmatic DPLs in order to use the conditions to build

ownership among competing interests for successive stages of reform In some contexts the

rotation of Ministers is frequent and government policy commitment is not consistent To

sustain momentum for reforms the DPL might anticipate and compensate for this institutional

instability by aiming to embed the support for the reform process more deeply within society

The Bank should not focus only on building support within the government alone DPLs should

have prior actions or triggers that foster on support or empowerment of civil society as an

accountability mechanism for complying with the DPL conditions and the policy reforms more

generally The Bank might experiment with community driven DPLs to strengthen support for

certain reforms more broadly across society so as not to depend on whether a specific

government reverses or changes its reform promises

Perhaps the most enduring safeguard is a vigilant capable and demanding civil society to hold

any government accountable Unfortunately the Bankrsquos track record in following its own advice

on how to build accountability does not bode well for this recommendation as the next section

illustrates


McElhinny

29

IV DPLs as Instruments to Promote Environment and Governance An important background study with relevance to DPLs focuses on Environmental Governance

and Institutions38

Furthering the goals of environmental sustainability involves balancing a

number of different objectives Building capacity for policy formulation in the short term

involves achievement of feasible environmental goals within the constraints placed by existing

institutions and governance structures At the same time the Bank must strive to strengthen and

improve those same institutions and governance structures The goal in the longer term would be

to help establish competent institutions capable of picking up signals about problems balancing

interests fairly and efficiently in formulating policies and executing policies in an accountable

manner39

The paper ldquoStrengthening Environmental Institutions and Governance What Should be the Role

of the World Bank Grouprdquo explores how the Bank might realize its comparative advantage in

institutional capacity strengthening The paper suggests that the principal challenge for the Bank

is to establish a better methodology to measure effectiveness lacking of clear metrics to measure

Institutional Capacity Strengthening Some proposed indicators

Long-term engagement (as in commitments carried forward through programmatic

lending)

Metrics for how to do quality EIA SEA

Policy formulation

Ensure adequate staffingresources

Ability to achieve inter-sectoral inter-governmental or civil society coordination

Independent oversight

Reform durability

Among the different instruments that the WB employs to strengthen environmental governance

the paper focuses on investment lending analytical work and non-reimbursable operations such

as GEF projects) However many of the findings are directly applicable to DPLs

ldquoThe results of our content analysis indicated that the critical institutional ability of

accountability requires more attention in WBG operations We recommend that

Development Policy Loans (DPLs) could be applied more directly to strengthen

institutional accountability DPLs have been used to reform formal rules that govern

38

Melanie Eltz Urvashi Narain Alessandro Orfie and Robert Schneider ldquoStrengthening Environmental Institutions

and Governance What Should be the Role of the World Bank Grouprdquo Background paper for the 2010 Environment

Strategy The World Bank (Nov 3 2010) httpgoworldbankorg7LIFDR16C0 39

World Bank Environmental Strategy Review ldquoEnvironmental Governance and Institutions Concept Note citing

The World Development Report 2003 Sustainable Development in a Dynamic World Transforming Institutions

Growth and Quality of Life Washington DC


McElhinny

30

environmental institutions and to recognize achievements These loans could also be

made more effective by fully incorporating recommendations from CEA and SEArdquo40

However increased reliance on DPLs should break with a pattern of building accountability only

from the top down another finding revealed in the study

Accountable institutions not only require the staffing expertise and resources at all-levels of

government to implement policy but are held accountable by mandates circumscribed by clear

formal rules along with independent oversight institutions and the judiciary The WBG has

sought to strengthen these abilities by activities such as securing independent budget support to

ensure reform durability supporting the drafting of policy which requires judicial oversight and

again supporting civil society organizations However when Bank effort is compared across all

four institutional abilities the tendency suggests that recent projects have not been targeting

evenly in its Environment and Natural Resources Management (ENRM) investments in line

with the policy advice in the World Development Report (WDR) 2003

Improving institutional accountability involves activities designed to increase the demand for

good governance such as strengthening civil society organizations formulating policy which

requires judicial oversight and support for greater transparency The portfolio content analysis

results reported in Table 1 illustrate that building environmental accountability is the lowest

emphasis of the World Bank support over the past decade These types of investments

accounted for only 12 of the ENRM portfolio ldquoEnsuring that the environmental institutions

are being held accountable by strengthening civil society organizations and oversight institutions

has received relatively less focus and may be an area of future engagement for the WBGrdquo41

Table 1 WB Environmental Projects by Institutional Ability Targeted (from WB report)42

40

Eltz et al (2010) pg 5 41

Op cit pg 3 The paper reviewed 522 projects financed by the World Bank between 2002-2009 classified under

the Environment and Natural Resources Management theme 42

Op cit pg 12

Note The percent of the portfolio does not add to 100 percent because most

projects targeted multiple institutional abilities


McElhinny

31

Not only have recent environmental DPLs not included bottom up accountability conditions

they have at times included conditions that run contrary to the very oversight institutions that

are important for governance but have not received as much Bank support The authors suggest

that the Ministeacuterio Puacuteblico Federal (MPF Public Prosecutors Office) in Brazil is a positive

example of an institution capable of promoting compliance and enforcing environmental laws

and regulations despite the limited direct Bank support for this institution at the Federal level43

This analysis of the Brazilian Public Prosecutors Office suggests a possible area for reform

priority in a future DPL44

In fact the SEM DPL currently in execution in Brazil includes a condition that focuses on what

some perceive to be a weakening of the MPF accountability role The first objective in the

SEM DPL is to ldquoimprove effectiveness of government agencies in implementing mandated

Brazilian environmental and social management proceduresrdquo The outcome indicator for this

objective is proposed as follows ldquoImprove the environmental licensing process using as proxy

the 20 decrease of the number of judicially challenged licenses by Public Prosecutors Office

compared with the number of environmental licenses issued at the Federal level during 2002-

2007rdquo Implicit in this outcome indicator and in the most recent World Bank CEA for Brazil

that focuses on obstacles to the environmental licensing process particularly for hydroelectric

dams is the argument that the MPF is in part responsible for unnecessary delays in licensing

high risk projects The DPL goal of ldquodepoliticizingrdquo the licensing process measured by a net

reduction in the number of judicially challenged licenses could reflect a weakening of the MPF

ability to intervene in the environmental licensing process in defense of the legitimate rights of

affected communities45

To understand whether the ldquodemandrdquo side of governance activities were being targeted as

opposed to the ldquosupplyrdquo side categories of accountability were devised to distinguish between

these two approaches to building accountability Supply refers to activities targeted at those

organizations and stakeholders tasked with the supply of environmental services (mainly

Ministries) while demand-side generally refers to civil society organizations which demand the

environmental service and to activities aimed to increase their participation In the study supply

and demand designations were made based on the type of stakeholder engaged in that activity

The limited attention paid to accountability in the portfolio reflects the greater emphasis on

strictly supply-side than demand-side operations in the portfolio As Figure 7(from the World

Bank study) depicts operations which involved solely supply-side interventions represent the

majority of the portfolio and serve to target the key institutional abilities other than

accountability Most often strictly supply-side interventions involved training and technical

capacity development within key government ministries Supply-side operations also consisted

of the creation of new technical monitoring divisions within environment ministries such as the

Center for Biodiversity Monitoring and Forecasting in the Brazilian Ministry of Environment

43

Through recent investment loans the World Bank has provided some technical support to the MP at the Federal

and at several state level agencies to strengthen capacity for review of environmental and social law compliance 44

See Box 4 and Annex 2 LCR Institutional and Governance Briefs The Case of the Public Prosecutors Office in

Brazil pgs 54-60 45

World Bank (2008) ldquoEnvironmental Licensing for Hydropower Developments in Brazil A Contribution to the

Debaterdquo Report No 40995-BR)


McElhinny

32

Formulation of new regulatory frameworks and the integration of environmental concerns into

other sectors are other examples of supply-side activities

Figure 8 Projects by Institutional Abilities and SupplyDemand Point of Entry (Figure 1 in World Bank report)

The authors note that similar conclusions were reached in a recent review of CEAs (Pillai 2008)

which found that while CEAs had helped to improve the quality of institutional analysis they

had focused on public sector institutions rather than private sector or civil society Within public

sector CEAs tend to focus on mandates staffing and resources rather than decision-making

processes or assessment of vertical and horizontal accountability structures

Also relevant to learning about effective use of DPLs is the finding of little differentiation

between Bank instruments for environmental governance when controlling for income or

political stability suggesting a relatively weak assessment of governance contexts to inform the

most efficient use of these resources An analysis of the distribution of governance interventions

by level of democracy reveals that accountability was slightly more favored in weak democracies

when compared to strong democracies or autocracies However the content analysis leaves little

doubt that the key institutional ability of accountability highlighted in the WDR 2003 appears to

be under-emphasized regardless of country type and therefore a deficit that that Bank might

consider compensating in future engagement through DPLs or other instruments that focus on

and partner with civil societyrdquo46

46

Eltz et al (2010) pgs 21-22


McElhinny

33

This analysis of past Bank effort to build environmental governance should provide a further

rationale for revising Operational Policy 860 in the area of consultation transparency and

results Future DPLs to strengthen environmental institutions and governance should ensure

greater civil society involvement both in the design and implementation of the DPL but also in

the desired outcome of building accountability DPLs could promote greater demand side

accountability by including specific conditions and outcome indicators that promote and measure

the empowerment of civil society organizations to monitor compliance with national and local

sustainability commitments


McElhinny

34

V Conclusions




Since 2004 development policy operations have emerged as a preferred financial instrument for

a growing number of clients Despite the popularity of DPLs including their employment in new

areas such as environmental governance concerns are mounting about effectiveness and

accountability

Both trends indicate a scenario where traditional safeguard policies may apply to as little as a

third of the World Bankrsquos future portfolio while DPLs and other less prescriptive and

accountable instruments expand as a share of Bank operations to keep middle income countries

borrowing









and survival at the World Bank in middle income countries such as Brazil There are many that

view the use of environmental DPLs as a forward looking and promising innovation by the

World Bank and support the experimentation with these new instruments As experiments the

Bank should emphasize learning and adjustment to fully maximize DPL potential This brief

lays out five recommendations for the World Bank to ensure that this experimentation with

environmental DPLs results in learning and effective development


business is long overdue47

Such a future DPL evaluation should emphasize results particularly

in terms of strengthening environmental governance that have so far been overlooked by the

biannual management produced DPL retrospectives



review Recent analysis of past Bank effort to build environmental governance should provide a

further rationale for revising Operational Policy 860 in the area of consultation transparency

and results The brief identifies five areas of DPL policy guidance that merit revision

47

See PRSC evaluation httpgoworldbankorgEF8P6W17T0 See also a review of six health sector

swaps httpsiteresourcesworldbankorgEXTWBASSHEANUTPOPResourceswp4pdf


McElhinny

35

Concerns and Recommendations

1 Poor Cost Benefit Analysis of DPLs ndash No Justification of DPL Cost DPLs require better

cost effectiveness accountability All DPLs should include an explanation about how the total

operation amount was derived and how the specific instrument was compared to other alternative

instruments If the DPL is associated with any budget allocations this relationship should also

be clarified

2 Improved consultation and transparency is necessary to ensure legitimacy and likely

achievement of chosen DPL prior actions and triggers DPLs are not adequately transparent

or properly consulted which in turn undermines the quality of the design and outcomes

Improved guidance on minimal standards for acceptable transparency and consultation is

required

3 Guidance on assessment of environmental and social impacts in the design of DPLs

under OP 860 is ambiguous and therefore subject to excessive discretion in the alignment

of the DPL with the magnitude of risk Compared to the Bankrsquos safeguard framework for

traditional investment loans DPL Operational Policy provides significantly less accountability to

affected communities that may want to defend or challenge the proposed DPL conditions or the

process in which these conditions were negotiated or implemented

4 DPL Operational Policy has an inadequate framework for measuring institutional


Bank additionality DPL should ensure evidence-based results that begin with a robust

monitoring and evaluation framework differentiated by institutional setting but guided by

standardized metrics that emphasize building demand for accountability

5 No differentiation among DPLs regarding coherence with relevant Bank investments or

planning commitment for longer time horizons To sustain momentum for reforms DPL

might anticipate and compensate for this institutional instability by privileging support for the

reform process within a framework that extends beyond a single DPL articulate with other Bank

instruments and invests more deeply in civil society based accountability mechanisms


McElhinny

36

Bibliography

Eltz Melanie and Urvashi Narain Alessandro Orfie and Robert Schneider ldquoStrengthening

Environmental Institutions and Governance What Should be the Role of the World Bank

Grouprdquo Background paper for the 2010 Environment Strategy The World Bank (Nov

3 2010)

de Gouvello Christophe (May 31 2010) ldquoBrazil Low-Carbon Country Case Studyrdquo World Bank

World Bank Independent Evaluation Group (IEG) (2008) Poverty Reduction Support Credits

An Evaluation of World Bank Support World Bank

Keck Margaret ldquoPlanfloro in Rondonia The Limits of Leveragerdquo in J Fox and David Brown

ed (1998) The Struggle for Accountability The World Bank NGOs and Grassroots

Movements MIT Press

McElhinny Vincent (2010) ldquoWorld Bank evaluation shows decline of cost benefit accounting as

criteria for project approvalrdquo httpwwwbicusaorgenArticle12161aspx

Pillai P (2008) ldquoStrengthening Policy Dialogue on Environment Learning from Five Years of

Country Environmental Analysisrdquo Environment Department Papers Institutions and

Governance Series 114 WBG Washington DC

Pillai P and L Lunde (2006) ldquoCEA and Institutional Assessments A Review of International

and WBG Toolsrdquo Environment Strategy Paper Number 11 The WBG Environment

Department The WBG Washington DC

World Bank (2000) ldquoReforming Public Institutions and Strengthening Governance A WBG

Strategyrdquo Public Sector Group Poverty Reduction and Economic Management (PREM)

Network The WBG Washington DC

World Bank ldquoGood Practice Notes For Development Policy Lendingrdquo (Oct 2004)

World Bank Group (2005) Integrating Environmental Considerations in Policy Formulation

Lessons from Policy-based SEA Experience Environment Dept

World Bank (2006) ldquoStrengthening the World Bankrsquos Engagement with IBRD Partner

Countriesrdquo Report DC2006-0014

World Bank Operational Policy 310 Annex C Financial Terms and Conditions of IBRD Loans

IBRD Hedging Products and IDA Grants (Updated December 2009)

World Bank Operational Policy OP 860 Development Policy Lending

World Bank ldquoGood Practice Note ndash Designing Development Policy Operations


McElhinny

37

World Bank Independent Evaluation Group (IEG) ldquoAchieving Development Results in Middle-

Income Countriesrdquo October 18 2007 Washington DC


World Bank (2008) ldquoAssessing the Environmental Forest and Other Natural Resource Aspects

of Development Policy Lending A World Bank Toolkitrdquo

World Bank (2008) ldquoEnvironmental Licensing for Hydroelectric Projects in Brazil A

contribution to the Debate ldquo (Vol 1) Washington DC World Bank Report No 40995-

BR)

World Bank (IEG) (2008) Evaluation of WBG Support for the Environment

World Bank Independent Evaluation Group (IEG) (2009) Do Health Sector-Wide Approaches

Achieve Results Emerging Evidence and Lessons from Six Countries


World Bank Independent Evaluation Group (IEG) (2010) ldquoSafeguards and Sustainability Policy

in a Changing Worldrdquo including World Bank Group Managements response

httpwwwworldbankorgiegsafeguards


McElhinny

38

Annex A Recent World Bank DPLs in Brazil

PROJECT ID

WORLD BANK BRAZIL DPL PROJECT NAME

LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL

P122391 BR-Rio de Janeiro Metropolitan Urban and Housing Development Project

Development Policy Lending

pipeline NA 485 Zhang Ming

SECRETARIAT OF SOCIAL ASSISTANCE AND HUMAN RIGHTS

httpwebworldbankorgexternalprojectsmainpagePK=64283627amppiPK=73230amptheSitePK=40941ampmenuPK=228424ampProjectid=P122391

P082442 HD Programmatic Sector Reform Loan 2


cancelled NA 500 Kebeck Lerick S

MINISTRIES OF EDUCATION HEALTH AND SOCIAL ASSISTANCE


P111665 Rio de Janeiro Municipality Fiscal Consolidation for Efficiency and Growth DPL


1-Jul-10 30-Jun-13 1045 Sakho Yaye Seynabou

SECRETARY OF FINANCE


P117244 Fiscal Sustainability Human Development and Competitiveness DPL


2-Feb-10 31-Dec-11

485 Gragnolati Michele

STATE SECRETARIAT OF FINANCE


P103770 ALAGOAS FISCAL AND PUBLIC MANAGEMENT REFORM


17-Dec-09 31-Dec-11

19545 Fajnzylber Pablo

STATE SECRETARIATS OF FINANCE PLANNING AND MANAGEMENT


P095205 First Programmatic Development Policy Loan for Sustainable Environmental Management


5-Mar-09 31-Dec-10

1300 Lundell Mark R

MINISTRY OF FINANCE MINISTRY OF ENVIRONMENT amp BNDES


P106767 RIO GRANDE DO SUL FISCAL SUSTAINABILITY


31-Jul-08 31-Dec-10


STATE SECRETARY OF FINANCE OF RIO GRANDE DO SUL


P095675 Second Programmatic Sustainable and Equitable Growth Loan


6-Jun-06 30-Jun-08 6015 Reis Jose Guilherme

MINISTRY OF FINANCE


P088543 Minas Gerais Partnership for Development

Structural Adjustment Loan

11-Apr-06 31-Dec-07

170 Wetzel Deborah L

STATE GOVERNMENT OF MINAS GERAIS



McElhinny

39

P078716 Programmatic Loan for Sustainable amp Equitable Growth Supporting Housing Sector Policy


14-Jun-05 30-Jun-06 50252 Wahba Sameh Naguib

MINISTRY OF FINANCE


P086525 BR PROGRAMMATIC FISCAL REFORM - SOCIAL SECURITY REFORM


2-Jun-05 30-Jun-06 6583 Zviniene Asta

GOVERNMENT OF BRAZIL


P080829 First Programmatic Reform Loan for Environmental Sustainability


24-Aug-04 31-Dec-04

50252 Azevedo Luiz Gabriel

MINISTRIES OF FINANCE AND ENVIRONMENT


P080827 Brazil First Programmatic Loan for Sustainable and Equitable Growth

Programmatic Structural Adjustment Loan

19-Feb-04 31-Dec-04

50505 Reis Jose Guilherme

MINISTRY OF FINANCE


P070641 2ND PROGRAMMATIC FISCAL REFORM ADJUSTMENT LOAN


12-Jun-03 31-Dec-03

40404 Herrera Santiago

MIN DE FAZENDA NACIONAL amp MIN DO PLANEJAMENTO ORCAMENTO


P080746 HD PRGM SECTOR REFORM LOAN


25-Feb-03 31-Dec-03

50505 Lindert Kathy A

MINISTRY OF FINANCE


P076905 Energy Sector Reform Loan Sector Adjustment Loan

13-Jun-02 31-Dec-02

45455 Porto Carreiro Jayme

MINISTRY OF MINES AND ENERGY


P066259 2nd Programmatic Financial Sector Adjustment Loan


13-Jun-02 31-Dec-02

40404 Kumar Anjali


P070640 First Programatic Financial Sector Adjustment Loan


24-May-01 31-Mar-02

40404 Kumar Anjali


P060575 Programatic Fiscal Reform I


18-Jan-01 31-Mar-02

75758 Matsuda Yasuhiko

STATE DER httpwebworldbankorgexternalprojectsmainpagePK=64283627amppiPK=73230amptheSitePK=40941ampmenuPK=228424ampProjectid=P060575

P063341 Fiscal and Administrative Reform Special Sector Adjustment Loan Project

Sector Adjustment Loan

30-Mar-00 31-Dec-00

50506 Carrizosa Mauricio

MINISTRY OF FINANCE MINISTRY OF ADMINISTRATION



McElhinny

40

P064901 Second Social Security Special Sector Adjustment Loan


30-Mar-00 31-Dec-00

50506 Cortes-Gorman Mariluz

MINISTRY OF SOCIAL SECURITY (MPAS)


P063340 Social Security Special Sector Adjustment Loan Project


7-Jan-99 30-Jun-99 7576 Cortes-Gorman Mariluz

MINISTRY OF FINANCE


P063351 Social Protection Special Sector Adjustment Loan Project


7-Jan-99 30-Jun-99 2525 Griffin Charles C

MINISTRY OF FINANCE



McElhinny

41

Annex B IBRD MIC Countries Per Capita Incomes Lending Eligibility and Repayment Terms

A IBRD Only 1

Category iv (over $6725)

Korea Rep of 21360 Chile 9400 Trinidad and Tobago 16540 Venezuela RB de 9230 Equatorial Guinea 14980 Turkey 9030 Antigua and Barbuda 13790 Palau 8600 Croatia 13740 Uruguay 8260 Poland 11880 Romania 7930 Libya 11590 Brazil 7450 St Kitts and Nevis 10920 Malaysia 7260 Seychelles 10290 Gabon 7240 Mexico 9980 Argentina 7200 Russian Federation 9680

Category iii ($1135 - $6725)

Botswana 6470 Belize 3790 Montenegro 6440 Ecuador 3640 Mauritius 6400 Thailand 3640 Lebanon 6350 El Salvador 3480 Panama 6180 Jordan 3310 Kazakhstan 6140 Tunisia 3290 Costa Rica 6060 Ukraine 3210 South Africa 5820 China 2940 Serbia 5690 Marshall Islands 2890 Bulgaria 5490 Turkmenistan 2840 Belarus 5380 Guatemala 2680 Suriname 5010 Morocco 2580 Jamaica 4870 Swaziland 2520 Colombia 4660 Micronesia Fed Sts 2340 Dominican Republic 4390 Syrian Arab Republic 2090 Algeria 4260 Paraguay 2070 Namibia 4200 Indonesia 2010 Macedonia FYR 4140 Philippines 1890 Peru 3990 Egypt Arab Republic 1800 Fiji 3920 Iran Islamic Republic NA Albania 3840 Iraq NA


McElhinny

42

B Blend2

Category iii ($1135 - $6725)

Grenada 5730 Azerbaijan 3830 St Lucia 5530 Armenia 3350 St Vincent and the Grenadines 5140 Cape Verde 3130 Dominica 4760 Georgia 2480 Bosnia amp Herzegovina 4500 Bolivia 1480

Category ii ($1135 or less)

India 1070 Pakistan 980

Papua New Guinea 1050

Category i ($975 or less)

Uzbekistan 910 Zimbabwe3 NA

Vietnam 910


McElhinny

43

Annex C DPL Trends by Region and Year

Figure 2 (from the IEG 2010 Annual Results Report) shows that IBRD DPLs peaked at about

$14 billion in FY99 then reached about half that in FY02 but has generally averaged about $4-

$5 billion annually since 1990

Figure 4 also from IEG RAP 2010 shows that the Latin American region has historically been

the most consistent consumer of DPLs While demand for DPLs by Asian countries exploded

just after the 1998 crisis it has virtually disappeared since

VinceDPLTitlepdf

World Bank and DPLs2-1pdf

Table of Contents

Executive Summary 3

I Introduction 5

A World Bank MICs and Graduation from IBRD Lending 7

B Development Policy Lending Operational Policy 860 12

II World Bank DPLs and Safeguard Policies 13

III Five Arguments for Inclusion of Development Policy Lending Operational

Policy in the World Bank Safeguard Policy Review 19

A Poor Cost Benefit Analysis of DPLs ndash No Justification of Operation Amount 21

B Improved consultation and transparency is important regarding how DPL

prior actions and triggers are chosen 22

C DPLs and Accountability 23

D DPLs Effectiveness and Additionality Measurement 24

E DPL coordination with Bank instruments and leverage for longer planning

horizons 27

IV DPLs as Instruments to Promote Environment and Governance 29

V Conclusions 34

Bibliography 36

Annex A Recent World Bank DPLs in Brazil 38

Annex B IBRD MIC Countries Per Capita Incomes Lending Eligibility

and Repayment Terms 41

Annex C DPL Trends by Region and Year 43

List of Figures

Figure 1 Nearly 100 of Latin America is a MIC for World Bank 8

Figure 2 Risk Categorization Trends of World Bank Group Portfolio (1999-2010) 14

Figure 3 WBG Lending FY09-FY10 ($Bn) amp Safeguard Policy Applicability

(own estimates from WBG operations data) 15

Figure 4 WBG FY 2010 Finance amp Safeguard Policy Applicability 16

Figure 5 WBG FY 2010 Safeguard Applicability Total 16

Figure 6 Possible Safeguard and Portfolio Scenarios for the World Bank Group

by 2030 17

Figure 7 World Bank Group Portfolio Shares for MIC Non-Graduation Scenario 18

Figure 8 Projects by Institutional Abilities and SupplyDemand Point of Entry

(Figure 1 in World Bank report) 33

List of Tables

Table 1 WB Environmental Projects by Institutional Ability Targeted (from WB report) 3


McElhinny

3

Executive Summary





































McElhinny

4








McElhinny

5

I Introduction









































McElhinny

6




















the Bank






















McElhinny

7












































McElhinny

8



income clients





















McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

3

Executive Summary





































McElhinny

4








McElhinny

5

I Introduction









































McElhinny

6




















the Bank






















McElhinny

7












































McElhinny

8



income clients





















McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

4








McElhinny

5

I Introduction









































McElhinny

6




















the Bank






















McElhinny

7












































McElhinny

8



income clients





















McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

5

I Introduction









































McElhinny

6




















the Bank






















McElhinny

7












































McElhinny

8



income clients





















McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

6




















the Bank






















McElhinny

7












































McElhinny

8



income clients





















McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

7












































McElhinny

8



income clients





















McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

8



income clients





















McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

9




















IBRD supportrdquo10










Support




DC2006-0014 pg vii pg 16 11


DC2006-0014 pg 2 12




McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

10










































McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

11













equity ratio
















graduation threat







provision







McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

12
































DPL retrospectives






medium term

13




McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

13




































IEG



14






McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

14

had inadequate

environmental and

supervision and


Accountability is


weak disclosure










DPLs falls short of

providing adequate






















17



(1999-2010)


McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

15













finance (unknown)


operations data)






18

IEG (2010 10)




Applicability


McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

16




McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

17

















67

33




$5-8 Bnyr

33

67




5050




McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

18
























Graduation Scenario


McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

19















safeguard policies

















policy review

19









McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

20

















reforms




Focusing on the 16








EIA









23






McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

21





DPLs include































concessional credit

25






McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

22



































27







McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

23























project29









28




RTpdf 30





McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

24













DPL results











resources31














31






McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

25




safeguard policies








Bank additionality

























33

Env governance - 34

IEG


McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

26


planning is weak




























ICRs should be






35








McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

27



capacity37



capacity






of evidence
























37



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

28




























illustrates


McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

29


and Institutions38








manner39







lending)


Policy formulation




Reform durability








38








McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

30























40




Op cit pg 12




McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

31






































43




Brazil pgs 54-60 45




McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

32



















46



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

33










McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

34

V Conclusions







accountability




borrowing

























47




McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

35






be clarified





required


















McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

36

Bibliography




3 2010)






Movements MIT Press






















McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

37








BR)









McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

38


PROJECT ID


LENDING INSTRUMENT

APPROVAL DATE

CLOSING DATE

TOTAL AMT

TEAM LEAD

IMP AGENCY URL


















2-Feb-10 31-Dec-11






17-Dec-09 31-Dec-11






5-Mar-09 31-Dec-10

1300 Lundell Mark R





31-Jul-08 31-Dec-10







MINISTRY OF FINANCE




11-Apr-06 31-Dec-07





McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

39




MINISTRY OF FINANCE









24-Aug-04 31-Dec-04






19-Feb-04 31-Dec-04


MINISTRY OF FINANCE




12-Jun-03 31-Dec-03






25-Feb-03 31-Dec-03


MINISTRY OF FINANCE



13-Jun-02 31-Dec-02






13-Jun-02 31-Dec-02

40404 Kumar Anjali




24-May-01 31-Mar-02

40404 Kumar Anjali




18-Jan-01 31-Mar-02





30-Mar-00 31-Dec-00





McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

40



30-Mar-00 31-Dec-00







MINISTRY OF FINANCE





MINISTRY OF FINANCE



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

41


A IBRD Only 1



Category iii ($1135 - $6725)



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

42

B Blend2

Category iii ($1135 - $6725)







Vietnam 910


McElhinny

43








VinceDPLTitlepdf



McElhinny

43








VinceDPLTitlepdf


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