Final Evaluation of Mainstreaming Biodiversity Project

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Evaluation Plan:
2012-2016, Seychelles
Evaluation Type:
Final Project
Planned End Date:
03/2015
Completion Date:
03/2015
Status:
Completed
Management Response:
Yes
Evaluation Budget(US $):
18,408

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Title Final Evaluation of Mainstreaming Biodiversity Project
Atlas Project Number: 00053107
Evaluation Plan: 2012-2016, Seychelles
Evaluation Type: Final Project
Status: Completed
Completion Date: 03/2015
Planned End Date: 03/2015
Management Response: Yes
Focus Area:
  • 1. Others
Corporate Outcome and Output (UNDP Strategic Plan 2014-2017)
  • 1. Output 1.3. Solutions developed at national and sub-national levels for sustainable management of natural resources, ecosystem services, chemicals and waste
Evaluation Budget(US $): 18,408
Source of Funding: GEF
Joint Programme: No
Joint Evaluation: No
Evaluation Team members:
Name Title Email Nationality
james Lenoci Mr james@lenociltd.com HUNGARY
GEF Evaluation: Yes
GEF Project Title:
Evaluation Type: Terminal Evaluation
Focal Area: Biodiversity
Project Type: FSP
GEF Phase: GEF-3
GEF Project ID: 1620
PIMS Number: 2053
Key Stakeholders: GEF and UNDP
Countries: SEYCHELLES
Comments: The Project has been extended to 2015. the terminal Evaluation is planned for 1st Quarter of 2015. Evaluation started in May 2015 and draft submitted June 2015
Lessons
Findings
Recommendations
1 Mainstreaming objectives were not clearly articulated: The project design included the key sectors posing threats to biodiversity in the Seychelles: infrastructure development, tourism, and fisheries. But, the mainstreaming objectives of the project were not clearly articulated. For example, while the biodiversity assessments and delineation of key conservation areas provided significant contributions to the land use planning framework, it was unclear how this work fed into the mainstreaming objectives. If mainstreaming was to be focused on the key conservation areas, the design should have included development of incentives and regulations specifically for those areas and piloting of implementation of some of the management measures.
2 Inter-sectoral linkages for facilitating implementation of biodiversity mainstreaming plans were not worked out: The stakeholder involvement plan included a long list of agencies and organizations, but the inter-sectoral linkages required to facilitate implementation of biodiversity mainstreaming were not worked out. For example, it is unclear which stakeholders are responsible for setting conservation objectives for areas under biodiversity mainstreaming and carrying out monitoring and updated biodiversity assessments in those areas, and what are the associated interfaces with land use planners and fisheries management authorities. It would have been advisable to work out stakeholder roles in more detail, with respect to enabling the overall mainstreaming objectives.
3 Late delivery of certain activities diminishes the likelihood that the results will be sustained: Certain project activities were delivered late in the implementation timeframe, including completion of the fisheries management plan for the Mahé Plateau, the monitoring control and surveillance protocol for the Praslin Fisheries Co-Management plan and Mahé Plateau plan, the biodiversity policy, and some of demonstration activities were started in the second half of last year, 2014. This late delivery diminishes the likelihood that results will be sustained, as there was limited time for consultation, monitoring, and evaluation, and for distilling lessons learned from these activities and outputs.
4 Stakeholder involvement was inadequately planned, with respect to advancing legislative reform and facilitating district-level land use plans: The stakeholder involvement plan for leading the process of achieving legislative reform should have included specific enabling stakeholders, e.g. representation by the cabinet, possibly through an advisory committee or individual(s). The technical staff members within the ministries and the Project Steering Committee were not effective at garnering the required political buy-in. It might have also been advisable that the person leading the facilitation efforts be a specialist in mediation, from outside the process. The situation with respect to the process of approving the district land use plans is similar. These were the first district-level land use plans developed in the Seychelles, and there was a significant under-estimation of the required effort needed to advance these plans through both national and subnational processes to obtain approval. From the public participation perspective, the project was also unprepared, and under-appreciated the time and outreach needed to gain public support. It might have been advisable, for example, to charge one or more NGOs to lead the social mobilization processes.
5 Realized co-financing from NGOs was approximately 52% of pledged contributions and less than 1% of the USD 2 million of co-financing from the private sector materialized: There was confusion during project development regarding what constitutes co-financing, and presumed conditions associated with making co-financing pledges, amongst NGO partners. As a mainstreaming project, there clearly was a need to include co-financing targets from the non-governmental and private sectors, but there was limited vetting of the pledges made, including an unrealistic sum of USD 2 million from the Seychelles Hospitality and Tourism Association. The lesson already learned is to be more specific on cash and in-kind co-financing pledges, and this has been tightened up since the GEF5 cycle. However, in relation to biodiversity financing,
6 Insufficient attention was placed on developing and piloting incentive mechanisms: One of the underlying aims of biodiversity mainstreaming is to create sufficient enabling conditions that encourage productive sector stakeholders to participate in conservation. In this regard, there was insufficient focus on developing and piloting incentive mechanisms with respect to infrastructure development. Such mechanisms might have included conservation easements, transfer of development rights, special augmentation of existing zoning, tax breaks, payment for ecosystem service, etc. Understandably, it might have been difficult to pilot such incentive schemes under the economic downturn that occurred shortly after project inception, but working out viable incentive mechanisms added value to the enabling environment.
7 The effectiveness of adaptive management was limited due to fairly weak monitoring: Results-based monitoring was fairly weak during the course of project implementation, and this restricted what adaptive management measures were taken to improve performance. For example, over the past 2 years, there has been very little communication from the MEECC and MLUH stakeholders regarding the status of the Environmental Protection and Physical Planning bills, respectively; and there is limited information available regarding the delay in approving the district land use plans.
8 There has been weak marketing of the Seychelles Sustainable Tourism Label (SSTL) programme: Once the systems were developed for the SSTL programme and the first set of operators obtained certification, there should have been more focus on marketing. For example, there has not been a customer satisfaction survey made; such an assessment could be used to design a marketing campaign. Also, building a case for direct benefits realized by the participating operators, e.g., through cost savings from segregating waste, or sourcing local food rather than buying imported products, etc. would also aid in the marketing efforts for the programme. It is noted that the Project Steering Committee could not reach a consensus on the best way forward to increase the engagement of operators in the SSTL programme.
9 Limited contingencies are in place for activities requiring follow-up action: A sustainability strategy has not been prepared for outlining actions needed to ensure certain activities requiring follow-up are attended to. Such activities include finalization and enactment of the Environmental Protection and Physical Planning bills, updating and facilitating approval of the district land use plans, finalization of the biodiversity policy, and ongoing and uncompleted activities at the demonstration sites.
10 Allocation of financial expenditures among the project components was not closely monitored: Upon review of financial expenditure reports, there were apparent discrepancies in the amounts allocated among the project components, including project management. For example, the amount of expenditures booked under Outcome 1 was disproportionately high, compared to what was accounted for Outcome 2 and Outcome 3. The indicated project management costs were 24% of the total expenditures incurred through the end of 2014; this is an unacceptably high level of project management cost, for a GEF-financed project. Certain costs seem to have been mistakenly assigned to project management. For example, the time spent by the chief technical advisor seems to have been mostly allocated to project management, rather than distributed among the technical components. Also, the project manager costs were exclusively booked under project management, although she was providing substantive contributions to the work under the three outcomes, e.g., participating at workshops, carrying out monitoring visits, etc.
11 Stakeholder involvement should be tailored to the intended outcomes: Stakeholder involvement for the activities associated with the envisaged amendment of the Environmental Protection Act and the Physical Planning Act were mostly experts and government agency officials specialised in drafting of legal acts. The process involved in achieving approval and ultimately enactment of the bills requires additional stakeholders, including ones experienced in lobbying and mediation. Similarly, the efforts implemented for promoting approval of the district-level land use plans were led by planners, and there was limited involvement in stakeholders experienced in social mobilisation, as well as lobbying and mediation. Stakeholder involvement should be tailored to the intended outcomes.
12 Inter-sectoral linkages need to be worked out for biodiversity mainstreaming initiatives: Biodiversity mainstreaming requires collaboration of administrative, strategic, and regulatory functions among relevant sectoral stakeholders. For example, mainstreaming biodiversity conservation in the fisheries sector should include a clear role by the environmental protection authority; in this case it might the Seychelles National Park Authority (SNPA), which is under the Ministry of Environment, which is the focal agency for biodiversity in the country.
13 The non-governmental sector continues to drive change and introduce innovation to biodiversity conservation in the Seychelles: The results of the project showcased the critical role of non-governmental organisations (NGOs) have with respect to biodiversity conservation in the country, including introducing innovative techniques and management arrangements, and advocating for legal and institutional reform.
14 Sustainability structures should be built into project design, including co-financing allocation: Experience within the GEF portfolio shows that considerable time is required, possibly decades, for realizing verifiable impact of biodiversity mainstreaming. Sufficient resources for monitoring and evaluation should to be factored into mainstreaming projects. For example, it would be sensible to advocate for some of the co-financing streams to flow after the GEF funding timeframe, in order to support required post-project monitoring and evaluation.
15 Project co-financing partners should receive instruction on tracking and reporting contributions realized: At project inception, clear instructions should be delivered to co-financing partners regarding tracking and reporting co-financing contributions.
16 Project managers should be better informed of institutional mainstreaming knowledge among the GEF portfolio of projects: There is a wealth of knowledge among the GEF biodiversity mainstreaming portfolio of projects. It would be advisable to support project managers in identifying opportunities to remain informed of lessons learned and best practices.
17 A sustainability strategy should be prepared, including but not limited to the following: a. Prepare a ?road map? for achieving the legislative reforms that were not realized by the end of the project, indicating roles and responsibilities, and also identify where external support might be warranted to facilitate the process; b. Request the MLUH to identify a ?champion? for managing the process of updating the land use plans and achieving district-level approval, and similarly, prepare a road map for achieving approval; c. Describe how the finalization of the biodiversity policy will be managed, as this policy might not be completed and approved by the end of the project in June; d. Outline the processes required for finalization and approval of the Mahé Plateau fisheries management plan and the Praslin Fisheries monitoring control and surveillance protocol; e. Request the relevant partner ENGOs to develop recommendations for post-project monitoring of ongoing and uncompleted activities at the demonstration sites. The recommendations should indicate roles and responsibilities, include estimated costs associated with the monitoring activities, and describe how the monitoring results will be reported. f. In the case of the demonstration activity with Matelot de Praslin and Wildlife Club, outline recommendations for mitigation measures, and evaluate if there is a legal basis to claim back funds due to lack of delivery.
18 Relevant stakeholders should rationalize land use classification protocol and update the land use plans accordingly. The current land use classifications used in the plans developed with support of the project should be synergized with possible changes or additional categories introduced in the Seychelles Strategic Plan, and planners should also decide how to represent the Sustainable Use (IUCN VI) category documented in the Seychelles? Protected Areas Policy (October 2013), e.g., possibly for the key biodiversity areas (KBAs).
19 Results and lessons learned of case studies should be consolidated into informative case studies, and disseminated locally, regionally (e.g., with support of the UNDP country offices, the Indian Ocean Commission, or in collaboration with other fora), and globally (e.g., through the Small Island Developing States Network (SIDSnet), or in collaboration with other fora).
20 Request the MLUH and MEECC to prepare a synopsis outlining the substantive changes recommended in the draft Environmental Protection Bill and Physical Planning Bill, in relation to the currently in-force acts.
21 In the Biodiversity Policy under preparation, linkages [between] relevant stakeholder groups should be mapped out; for example, showing which stakeholders are responsible for setting conservation objectives for areas under biodiversity mainstreaming and carrying out monitoring and updated biodiversity assessments in those areas, and what are the interfaces with land use planners resource management authorities, enforcement agencies, and NGOs.
22 With respect to land use planning, it would be advisable to identify which areas are slated for biodiversity mainstreaming, and develop specific conservation objectives, incentive mechanisms, and regulations specifically for such areas that are privately owned. The aim of the incentives should be to encourage conservation of ecological values through conservation easements, transfer of development rights, special augmentation of existing zoning, tax breaks, payment for ecosystem service, or other scheme.
23 As part of the monitoring, control, and surveillance programme for the targeted fisheries under biodiversity mainstreaming, socio-economic data should be monitored in addition to biophysical parameters, to enable evaluation of the progress of the mainstreaming efforts. It would also be advisable to carry out monitoring at areas not covered by the mainstreaming efforts, in order to allow assessment of whether external factors, such as the state of the economy, climate change impacts, etc., are influencing performance
24 Marketing of the SSTL programme should be strengthened, e.g., presenting the business case benefits of pursuing SSTL certification, through for example cost savings achieved by more efficient use of energy and water, by sourcing more food locally, and by implementing improved waste management programmes. These marketing efforts could be supported by preparing knowledge products (e.g., case studies) using some of the results of the demonstration activities sponsored by the project.
25 The information management systems supported by the project should be summarized; including the biodiversity database hosted by the National Herbarium, the shark database, etc. The summary should indicate responsible managers of these systems, estimated costs to maintain them, possible funding sources, and interfaces with other information systems, including the national clearinghouse mechanism.
26 The project financial expenditure records should be reviewed and a note-to-file prepared explaining possible misallocations across outcomes and project management cost centres. The adjusted financial expenditure summary should be included among the material provided to the independent financial auditor when the 2015 results are audited.
27 Biodiversity mainstreaming should be extended to the agriculture and forestry sectors, by upgrading relevant policies and legislation, developing incentive schemes, and piloting activities involving conservation agriculture, sustainable forest management, agroforestry, and other relevant initiatives.
28 In terms of financial sustainability of artisanal fishers associations, supply chain analyses should be carried out, including local buyers such as hotels and restaurants. These analyses might be done in collaboration with the Fishing Boat Owners Association (FBOA), which as part of their Responsible Fishing programme, is developing a fish centre on Mahé to facilitate trade with local buyers.
29 Under the fisheries partnership agreement between the EU and the Government of Seychelles, a significant portion of the financial contribution from the EU is earmarked for support of the fisheries sector of Seychelles. It would be advisable to develop specific plans to follow up the results under Outcome 2, and advocate for support under this partnership agreement.
30 As general recommendations for similar GEF-financed mainstreaming projects: a. Some of the co-financing streams should be advocated to flow after the GEF project closes, to support post-project monitoring and evaluation; b. Project managers should receive training in biodiversity mainstreaming and be made more aware of lessons learned and ongoing activities within the GEF corporate portfolio.
1. Recommendation: Mainstreaming objectives were not clearly articulated: The project design included the key sectors posing threats to biodiversity in the Seychelles: infrastructure development, tourism, and fisheries. But, the mainstreaming objectives of the project were not clearly articulated. For example, while the biodiversity assessments and delineation of key conservation areas provided significant contributions to the land use planning framework, it was unclear how this work fed into the mainstreaming objectives. If mainstreaming was to be focused on the key conservation areas, the design should have included development of incentives and regulations specifically for those areas and piloting of implementation of some of the management measures.
Management Response: [Added: 2015/09/10] [Last Updated: 2015/09/10]

Management agrees that mainstreaming objectives may not have been clearly articulated within the Prodoc ? although the project formulation was in keeping with the Needs and Capacity assessment carried out at the time. During implementation, the project addressed the complex challenge of integrating and mainstreaming biodiversity objectives into development on a variety of ways. Terrestrial ecosystems: At the district level the land-use planning process evaluated and provided a baseline for integrating conservation and development, and this was scaled up within the national land use plan and guidelines. The implementation of this. Admittedly, was delayed by the delayed legislative review, and the delay in actually agreeing and approving the land use plans ? which indicates some issues with the original consultation process. More holistically, the key biodiversity assessments provided a further emphasis on the needs for mainstreaming biodiversity conservation outside of existing protected areas, and this was taken on board within some boundary changes to the Morne Seychellois National Park on Mahe. Within a longer-term planning framework, the Seychelles Strategic Plan has paid specific attention to the identified KBAs (and other project outputs) in identifying areas for further development. The application of incentives and regulations would be premature pending the final agreement of the legislative framework and the central land-use planning and strategic planning documents, and the project team feels the design was realistic in not expecting that the project interventions would reach this stage. Marine ecosystems: Again the project interventions have focused on the enabling environment for mainstreaming biodiversity, supporting the parallel initiative of the preparation and endorsement of the new Fisheries Act. The fisheries co-management processes conducted under the framework of the new Act, include the regulations and benefits that are required for successful implementation, and in this case the project intervention advanced beyond the actual design into the area highlighted by the TE.

Key Actions:

2. Recommendation: Inter-sectoral linkages for facilitating implementation of biodiversity mainstreaming plans were not worked out: The stakeholder involvement plan included a long list of agencies and organizations, but the inter-sectoral linkages required to facilitate implementation of biodiversity mainstreaming were not worked out. For example, it is unclear which stakeholders are responsible for setting conservation objectives for areas under biodiversity mainstreaming and carrying out monitoring and updated biodiversity assessments in those areas, and what are the associated interfaces with land use planners and fisheries management authorities. It would have been advisable to work out stakeholder roles in more detail, with respect to enabling the overall mainstreaming objectives.
Management Response: [Added: 2015/09/10]

The inter-sectoral linkages may not have been clearly defined in the Prodoc. However, at national level the former EMPS, and the current SSDS, set the parameters for various objectives to be achieved within the sustainable development arena and the stakeholder involvement that is expected. For example, the SSDS sets the parameters for the integration of the conservation and sustainable use of biodiversity in its cross-sectoral plan and in sector-specific legislation such as the revised Fisheries Act and fisheries management plans for the Seychelles. These strategic guidelines are then elaborated upon in the sector planning documents. The management is of the opinion that the project has contributed significantly to a change in development models, strategies and paradigms. New legislation and planning documents refer directly to the use of biodiversity and ecosystem services, and who is responsible for taking this forward. A sector wide approach has been initiated from the start of the project, facilitated through the various broad-based stakeholder forums held during the implementation phase of the project, and the result can be seen in the wider recognition of biodiversity within new planning documents such as the Seychelles Strategic Plan and especially within the new concept of planning for a Blue Economy. It is also to be noted that for almost the entire project period the GEF Operational Focal Point and chairperson of the BD Steering Committee, Mr. Didier Dogley, was also the chair of the Planning Authority. As Mr Dogley is now the new Minister of MEECC, the environmental agenda and the roles of different agencies in its implementation as put forward by the project continues in the forefront of development planning and is still being discussed at the highest level of decision making i.e. the Cabinet of Ministers.

Key Actions:

3. Recommendation: Late delivery of certain activities diminishes the likelihood that the results will be sustained: Certain project activities were delivered late in the implementation timeframe, including completion of the fisheries management plan for the Mahé Plateau, the monitoring control and surveillance protocol for the Praslin Fisheries Co-Management plan and Mahé Plateau plan, the biodiversity policy, and some of demonstration activities were started in the second half of last year, 2014. This late delivery diminishes the likelihood that results will be sustained, as there was limited time for consultation, monitoring, and evaluation, and for distilling lessons learned from these activities and outputs.
Management Response: [Added: 2015/09/10] [Last Updated: 2015/09/10]

Management does not agree with this observation as linkages with other projects and development partners have been established to ensure continuity and sustainability of the results. Even though certain activities were implemented during the later phase of the project, due to the need for proper consultation and sequencing of actions, the probability that these activities will be sustained is high. Part of the project approach involved strengthening of institutional capacities, and building ownership of processes, such that government, parasternal agencies, the private sector and the public are committed to ensure the long-term viability of these activities and results. The completion of the fisheries management plan for Praslin took a longer than predicted because the project had first to create an enabling environment wherein the fisher community, the government institutions and the national park authorities and the Seychelles Fishing Authority could work together. The endorsement of the (first ever) fisheries management plan was a wake-up call to many (the fisher community itself now began promoting the conservation of fish stocks) and this paved the way for the up-scaling to a management plan for the whole of the Mahe plateau, and indeed guides the next stage which is fisheries management planning for wider areas of the EEZ. These initiatives could not have taken place in parallel. The Biodiversity Policy, which leads to the Biodiversity Act, was similarly dependent on strengthening of other sections of the legislature, specifically the acts relating to environmental protection, physical planning, biosecurity - and especially fisheries and nature conservation (protected areas). Delaying the drafting of the policy until the associated elements of legislation are in place strengthens the coherence of the policy and ensures that there is no conflicting overlap and that nothing is ?left out? ? which would have been a danger if all legal instruments were drafted at the same time. Government is entirely committed to taking these acts forward through the development of regulations and protocols, and associated practice. Most of the tourism demo projects have been completed and have achieved targets for integration of biodiversity criteria within development and operations. Admittedly, there has been little time for monitoring and evaluation of implementation, which is still being carried out by the associated NGOs and partners, but it is apparent that in several cases the tourism operators have already invested further funds post-project and taken forward a initiatives started by the project.

Key Actions:

4. Recommendation: Stakeholder involvement was inadequately planned, with respect to advancing legislative reform and facilitating district-level land use plans: The stakeholder involvement plan for leading the process of achieving legislative reform should have included specific enabling stakeholders, e.g. representation by the cabinet, possibly through an advisory committee or individual(s). The technical staff members within the ministries and the Project Steering Committee were not effective at garnering the required political buy-in. It might have also been advisable that the person leading the facilitation efforts be a specialist in mediation, from outside the process. The situation with respect to the process of approving the district land use plans is similar. These were the first district-level land use plans developed in the Seychelles, and there was a significant under-estimation of the required effort needed to advance these plans through both national and subnational processes to obtain approval. From the public participation perspective, the project was also unprepared, and under-appreciated the time and outreach needed to gain public support. It might have been advisable, for example, to charge one or more NGOs to lead the social mobilization processes.
Management Response: [Added: 2015/09/10]

Management does not agree with this observation. The legislative reform process involved extensive stakeholder involvement (through technical working groups and wider consultation workshops) up to the point of submission to Cabinet ? after that the process could not be influenced unless Cabinet unanimously decided on the need for further external inputs. Management also feels that the current Minister for Environment in both previous and new role has been a keen advocate on legislative reforms and has promoted such at Cabinet level. Legal instruments must go through several stages of approvals within the Ministry, the AGs office and Cabinet, beyond the stakeholder validation, and this cannot be short-circuited. Similarly, land use plans were presented at district level as per the stated process, but participation from the members of the community was limited; there is a general negative perception within the population that their voice would have no impact on a Government process, and thus their voice is not raised until they feel that something is about to impact on them personally at which point their voice can become very loud indeed. Once drafted by the project, the onus is on the District Administrators to get the community engaged, but management accepts that in hindsight the NGOs could have been tasked with engaging the community to enhance participation when the LUPs were first being presented.

Key Actions:

5. Recommendation: Realized co-financing from NGOs was approximately 52% of pledged contributions and less than 1% of the USD 2 million of co-financing from the private sector materialized: There was confusion during project development regarding what constitutes co-financing, and presumed conditions associated with making co-financing pledges, amongst NGO partners. As a mainstreaming project, there clearly was a need to include co-financing targets from the non-governmental and private sectors, but there was limited vetting of the pledges made, including an unrealistic sum of USD 2 million from the Seychelles Hospitality and Tourism Association. The lesson already learned is to be more specific on cash and in-kind co-financing pledges, and this has been tightened up since the GEF5 cycle. However, in relation to biodiversity financing,
Management Response: [Added: 2015/09/10]

The co-financing amount as documented in the TE does not meet the project expectation, and the management agrees that in some cases there have been unrealistic estimates of the amount of co-financing that would be available, such as that pledged by SHTA without a clear indication of how this would be accounted for. A large component of the co-financing was secured from institutions within the production sector, and it should be noted that very large amounts of funding were leveraged during the project lifetime for support of improved fisheries management, such as fees from international fisheries agreements which accrue to SFA for use in operations including research and management. Within the tourism sector, the tourism partnership grants agreements all involved contributions from the private partner (tourism operator) and in several cases additional funds beyond that included in the grant agreements were provided to continue work beyond the term of the agreement. Further, some of the tourism partners made very substantial contributions in terms of opportunity costs ? setting aside a large part of Denis island for conservation activities instead of tourism development, for example ? the value of the land set aside would be several million US$. It is really a question of how co-financing is expressed, and this has been tightened up from the GEF5 cycle.

Key Actions:

6. Recommendation: Insufficient attention was placed on developing and piloting incentive mechanisms: One of the underlying aims of biodiversity mainstreaming is to create sufficient enabling conditions that encourage productive sector stakeholders to participate in conservation. In this regard, there was insufficient focus on developing and piloting incentive mechanisms with respect to infrastructure development. Such mechanisms might have included conservation easements, transfer of development rights, special augmentation of existing zoning, tax breaks, payment for ecosystem service, etc. Understandably, it might have been difficult to pilot such incentive schemes under the economic downturn that occurred shortly after project inception, but working out viable incentive mechanisms added value to the enabling environment.
Management Response: [Added: 2015/09/10] [Last Updated: 2015/09/10]

Seychelles was undergoing comprehensive reform under direction of the International Monetary Fund (IMF) at the start of the project. A new Investment Code was passed in December 2005 and the Tourism Incentives Act was amended in December 2007. The project consulted the relevant stakeholders at the Ministry of Finance at the time, but the project team was advised that the schedule to the Tourism Incentive Act (TIA) had been repealed. The concessions were moved to the Business Tax and to some extent within Value Added Tax. The project was not able to suggest additional tax incentives. Concerning natural resources valuation and the application of payment for ecosystem services, conservation offsets, etc., these were beyond the scope of this project and have been picked up with the PA Finance project (GEF5).

Key Actions:

7. Recommendation: The effectiveness of adaptive management was limited due to fairly weak monitoring: Results-based monitoring was fairly weak during the course of project implementation, and this restricted what adaptive management measures were taken to improve performance. For example, over the past 2 years, there has been very little communication from the MEECC and MLUH stakeholders regarding the status of the Environmental Protection and Physical Planning bills, respectively; and there is limited information available regarding the delay in approving the district land use plans.
Management Response: [Added: 2015/09/10]

The project can only support and promote the development of national legislation, there comes a point at which it is passed over to Government for completion of the enactment process. The Environmental Protection Act was presented to stakeholders and validated in 2013. It was handed over to Government for finalization thereafter, and entered an internal processes of the MEECC and Attorney General?s Office. It was subsequently delayed due to a financial issue regarding the issuance and collection of fines - which involved both the Ministry of Finance and MEECC, and this had to be fine-tuned with support from the legal expert in MEECC in collaboration with the AGs office. This took some time. Feedback on progress was provided by senior staff of the MEECC when requested, but the process was not open for further project input. With regards to the LUPs, Cabinet approvals were only received for 2 districts. It can be argued that the project has limited or no influence over political decisions. Some of the proposed LUPs were deemed sensitive by Government and reasons for delaying approval were not made public. General feedback was that the LUPs did not give sufficient room for development aspirations of Government, private sector and some land owners, and the disagreement of some stakeholders in having their land classified as no-development areas was problematic under the Constitution of Seychelles. The UAE government is now supporting Seychelles in the development of a Seychelles Strategic Plan which follows on from the LUPs (and from the KBA assessment) to develop a zoning for the main islands with a wider stakeholder participation than was achieved under this project. The PCU and UNDP has since then ensured that indicators in project log frames are realistic ad does not include enactment of legislations as it has almost no influence on such internal processes.

Key Actions:

8. Recommendation: There has been weak marketing of the Seychelles Sustainable Tourism Label (SSTL) programme: Once the systems were developed for the SSTL programme and the first set of operators obtained certification, there should have been more focus on marketing. For example, there has not been a customer satisfaction survey made; such an assessment could be used to design a marketing campaign. Also, building a case for direct benefits realized by the participating operators, e.g., through cost savings from segregating waste, or sourcing local food rather than buying imported products, etc. would also aid in the marketing efforts for the programme. It is noted that the Project Steering Committee could not reach a consensus on the best way forward to increase the engagement of operators in the SSTL programme.
Management Response: [Added: 2015/09/10]

Management is in agreement with the findings. However it has to be pointed out that the Seychelles Tourism Board and the Seychelles Hospitality and Tourism Association have always been at odds with the certification criteria. The Seychelles Sustainable Tourism Label (SSTL) would have been an ideal tool to standardize the process, but buy-in from the private sector has been poor. Even resorts that charge over $2,000 per room per night have argued that the $600 annual fee for the label is excessive. The SSTL secretariat has, however, made significant progress in their 2014-15 education and awareness campaign. The SSTL marketing strategy has now greatly improved and they have received international recognition from working with the Trade for Sustainable Development (T4SD) Market Analysis and Research (MAR) division of the International Trade Centre and with the Fair Trade Tourism organization in South Africa. It is planned that all SSTL certified hotels will be marketed through the FTT as responsible tourism products. The SSTL secretariat is also now a member of Alliance Africa.

Key Actions:

9. Recommendation: Limited contingencies are in place for activities requiring follow-up action: A sustainability strategy has not been prepared for outlining actions needed to ensure certain activities requiring follow-up are attended to. Such activities include finalization and enactment of the Environmental Protection and Physical Planning bills, updating and facilitating approval of the district land use plans, finalization of the biodiversity policy, and ongoing and uncompleted activities at the demonstration sites.
Management Response: [Added: 2015/09/10]

Management disagrees. The PCU is considered as one of the best examples within the GEF programme of a sustainable long-term implementing unit and it is constantly establishing synergies between current and new programmes. The design of new programmes always complement past and existing projects to ensure continuity and follow-up where needed. The legislation mentioned, as well as the activities at demo sites, are being followed up by the PCU through new projects or simply through continuity of staffing and the established working relationships with the Government and private sector organizations concerned.

Key Actions:

10. Recommendation: Allocation of financial expenditures among the project components was not closely monitored: Upon review of financial expenditure reports, there were apparent discrepancies in the amounts allocated among the project components, including project management. For example, the amount of expenditures booked under Outcome 1 was disproportionately high, compared to what was accounted for Outcome 2 and Outcome 3. The indicated project management costs were 24% of the total expenditures incurred through the end of 2014; this is an unacceptably high level of project management cost, for a GEF-financed project. Certain costs seem to have been mistakenly assigned to project management. For example, the time spent by the chief technical advisor seems to have been mostly allocated to project management, rather than distributed among the technical components. Also, the project manager costs were exclusively booked under project management, although she was providing substantive contributions to the work under the three outcomes, e.g., participating at workshops, carrying out monitoring visits, etc.
Management Response: [Added: 2015/09/10]

Management agrees that there has been mis-posting of costs within the components. This cannot be corrected within the Atlas booking system, but PCU financial and management staff are aware of the issue and more attention is now being paid to ensuring correct posting of costs. It is worth noting that if the CTA and manager costs were correctly posted, the management costs of the project would be well within the norm as the CTA is not part of the management but rather under technical assistance. It should be pointed out as well that the PCU model is one of the most cost-effective ways of implementing GEF projects in a high cost country like Seychelles as it allows for all the projects to benefit from technical expertise spread across all the projects. Likewise operational cost are spread among a number of projects in the most cost-effective manner as opposed to each project having its own CTA and PMU

Key Actions:

11. Recommendation: Stakeholder involvement should be tailored to the intended outcomes: Stakeholder involvement for the activities associated with the envisaged amendment of the Environmental Protection Act and the Physical Planning Act were mostly experts and government agency officials specialised in drafting of legal acts. The process involved in achieving approval and ultimately enactment of the bills requires additional stakeholders, including ones experienced in lobbying and mediation. Similarly, the efforts implemented for promoting approval of the district-level land use plans were led by planners, and there was limited involvement in stakeholders experienced in social mobilisation, as well as lobbying and mediation. Stakeholder involvement should be tailored to the intended outcomes.
Management Response: [Added: 2015/09/10]

Management disagrees with this observation. Seychelles is a small island state and vulnerably to limited capacities and a small pool of stakeholders, but all stakeholders were engaged, including local communities, in various components of the project ? project management thus asserts that there was an appropriately broad-based (for a SIDS) stakeholder input. In regard to the LUP process the process of consultation was nonetheless followed as per Government requirements: there were several public consultations made, but with poor attendance, perhaps due to the lack of knowledge about the subject in the communities or imply workshop fatigue. It is agreed that the process could have been enhance through engaging CSOs or NGOs to lead the consultation process as noted earlier in #4.

Key Actions:

12. Recommendation: Inter-sectoral linkages need to be worked out for biodiversity mainstreaming initiatives: Biodiversity mainstreaming requires collaboration of administrative, strategic, and regulatory functions among relevant sectoral stakeholders. For example, mainstreaming biodiversity conservation in the fisheries sector should include a clear role by the environmental protection authority; in this case it might the Seychelles National Park Authority (SNPA), which is under the Ministry of Environment, which is the focal agency for biodiversity in the country.
Management Response: [Added: 2015/09/10]

This has been done. Inter-sectoral linkages were initiated through the project, and are clear within for example the fisheries management plans where the implementation roles have been exhaustively discussed. Sectoral divisions are less clear in Seychelles than in many countries, and MEECC is closely involved with other Ministries as a partner in development activities.

Key Actions:

13. Recommendation: The non-governmental sector continues to drive change and introduce innovation to biodiversity conservation in the Seychelles: The results of the project showcased the critical role of non-governmental organisations (NGOs) have with respect to biodiversity conservation in the country, including introducing innovative techniques and management arrangements, and advocating for legal and institutional reform.
Management Response: [Added: 2015/09/10]

Seychelles has an active civil society and the non-governmental sector has been active in discussion of issues at district level and within national governance, demanding accountability, promoting transparency and access to information, and providing basic services to the population. Environmental NGOs play a crucial role in Seychelles in conducting research to build institutional capacities, and facilitating independent dialogue with civil society to help people live more sustainable lifestyles. They also provide technical input and collaborate with the private sector in the implementation of a large variety of project activities. Government has a mainly regulatory function, so the technical involvement of the NGO sector in environment projects will continue to be considerable.

Key Actions:

14. Recommendation: Sustainability structures should be built into project design, including co-financing allocation: Experience within the GEF portfolio shows that considerable time is required, possibly decades, for realizing verifiable impact of biodiversity mainstreaming. Sufficient resources for monitoring and evaluation should to be factored into mainstreaming projects. For example, it would be sensible to advocate for some of the co-financing streams to flow after the GEF funding timeframe, in order to support required post-project monitoring and evaluation.
Management Response: [Added: 2015/09/10]

The main institutions involved in the project have developed their own sustainability structures to ensure continuity of activities after the project completion. The Government is committed to support various actions post-project, such as owning and maintaining the various mechanisms and databases set up by the project. Again, the existence of the PCU as a long-term structure of Government, across GEF funding cycles, ensures as far as possible that there is continuity of efforts and gathering of long-term information on environmental issues and solutions.

Key Actions:

15. Recommendation: Project co-financing partners should receive instruction on tracking and reporting contributions realized: At project inception, clear instructions should be delivered to co-financing partners regarding tracking and reporting co-financing contributions.
Management Response: [Added: 2015/09/10]

Management agrees. This is being adopted as a routine part of the establishment of new projects. Co-financing commitments have been made much clearer since GEF5 and annual reporting of co-financing is being required.

Key Actions:

16. Recommendation: Project managers should be better informed of institutional mainstreaming knowledge among the GEF portfolio of projects: There is a wealth of knowledge among the GEF biodiversity mainstreaming portfolio of projects. It would be advisable to support project managers in identifying opportunities to remain informed of lessons learned and best practices.
Management Response: [Added: 2015/09/10]

Management agrees that future exchanges should be done between the various relevant projects in the region for knowledge-sharing. This is being adopted within new projects in the GEF portfolio.

Key Actions:

17. Recommendation: A sustainability strategy should be prepared, including but not limited to the following: a. Prepare a ?road map? for achieving the legislative reforms that were not realized by the end of the project, indicating roles and responsibilities, and also identify where external support might be warranted to facilitate the process; b. Request the MLUH to identify a ?champion? for managing the process of updating the land use plans and achieving district-level approval, and similarly, prepare a road map for achieving approval; c. Describe how the finalization of the biodiversity policy will be managed, as this policy might not be completed and approved by the end of the project in June; d. Outline the processes required for finalization and approval of the Mahé Plateau fisheries management plan and the Praslin Fisheries monitoring control and surveillance protocol; e. Request the relevant partner ENGOs to develop recommendations for post-project monitoring of ongoing and uncompleted activities at the demonstration sites. The recommendations should indicate roles and responsibilities, include estimated costs associated with the monitoring activities, and describe how the monitoring results will be reported. f. In the case of the demonstration activity with Matelot de Praslin and Wildlife Club, outline recommendations for mitigation measures, and evaluate if there is a legal basis to claim back funds due to lack of delivery.
Management Response: [Added: 2015/09/10]

Management accepts that the idea of a post-project sustainability strategy is good, but the examples given are a mixed bag of actions that are all in process of being followed up by PCU as part of its overall function of maintaining oversight on behalf of Government of the GEF programme.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
a.Legislative reforms:Government is engaged in the process of finalizing the EPA and PPA by the end of 2015. b.LUPs: This is being taken up within the new Strategic Planning process funded by UAE (the first step). When this is agreed the LUPs will be re-framed within the national plan. c.TORs and consultants are in place to work on the Biodiversity Policy. A means of financing the development of the subsequent Biodiversity Act will be found. d.The Mahe Plateau fisheries management plan was finalized in mid-2015. Implementation is to be funded from fees accrued from international fisheries agreements. e.The ENGOs are working with their tourism partners to further project interventions and in several cases the private partners have put in additional funding post-project to continue the work. Targets of the original ?seed? project have in almost all cases been met and there is no need for further monitoring by the PCU. f.A completion plan for the Anse la Blague activity is being worked out with the defaulting tourism operator, with the assistance of the ENGO partner. Completion is expected according to the original agreement, if late.
[Added: 2015/09/10]
MEECC PCU MLUH MFA / SFA ENGOs PCU, Wildlife Clubs, tourism partner 2015/12 Completed Some of the proposed key actions are complete while others are expected to be completed by the end of 2015
18. Recommendation: Relevant stakeholders should rationalize land use classification protocol and update the land use plans accordingly. The current land use classifications used in the plans developed with support of the project should be synergized with possible changes or additional categories introduced in the Seychelles Strategic Plan, and planners should also decide how to represent the Sustainable Use (IUCN VI) category documented in the Seychelles? Protected Areas Policy (October 2013), e.g., possibly for the key biodiversity areas (KBAs).
Management Response: [Added: 2015/09/10]

This comment is noted and land use classifications have already been discussed and reviewed by the team developing the Seychelles Strategic Plan and stakeholders.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
a.The Seychelles Strategic Plan will include a new land classification and mapping system based on the LUPs and KBAs of the project, but within a new stakeholder-agreed format. b.KBAs incorporated within the terrestrial PA system
[Added: 2015/09/10] [Last Updated: 2016/12/11]
MLUH, consultant team No due date No Longer Applicable A roadmap for completion of the SSP is in place. Some KBA areas have already been included within the PA system (some boundary alterations of Morne Seychellois NP in 2014) and others which are currently Forest Reserves will likely be re-designated under the SSP. The actions is now taken over by the MLUH and not longer within the remit of the PCU/MEECC History
19. Recommendation: Results and lessons learned of case studies should be consolidated into informative case studies, and disseminated locally, regionally (e.g., with support of the UNDP country offices, the Indian Ocean Commission, or in collaboration with other fora), and globally (e.g., through the Small Island Developing States Network (SIDSnet), or in collaboration with other fora).
Management Response: [Added: 2015/09/10]

Noted. Some case studies have already been written up and published in e.g. regional UNDP newsletter.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
a.Put up all information regarding the project and its case studies onto the PCU website. b.Continue preparing case studies and disseminating as appropriate.
[Added: 2015/09/10]
PCU No due date No deadline established The PCU website is continually updated alongwith social media content on the Facebook page.
20. Recommendation: Request the MLUH and MEECC to prepare a synopsis outlining the substantive changes recommended in the draft Environmental Protection Bill and Physical Planning Bill, in relation to the currently in-force acts.
Management Response: [Added: 2015/09/10]

Explanatory notes as outline in this recommendation are routinely done by Attorney General?s office as part of the process of vetting a new piece of legislation prior to endorsement. The ministries have also met specifically with the purpose of harmonizing the two pieces of legislation mentioned above.

Key Actions:

21. Recommendation: In the Biodiversity Policy under preparation, linkages [between] relevant stakeholder groups should be mapped out; for example, showing which stakeholders are responsible for setting conservation objectives for areas under biodiversity mainstreaming and carrying out monitoring and updated biodiversity assessments in those areas, and what are the interfaces with land use planners resource management authorities, enforcement agencies, and NGOs.
Management Response: [Added: 2015/09/10]

Noted

Key Actions:

Key Action Responsible DueDate Status Comments Documents
To be included within the draft Biodiversity Policy. the Framework Biodiversity ACt is being prepared and BD Policy will be developed after approval of Framework Act
[Added: 2015/09/10] [Last Updated: 2016/01/13]
PCU MEECC No due date No deadline established The BD project is completed and this is now part of the MEECC mandate
22. Recommendation: With respect to land use planning, it would be advisable to identify which areas are slated for biodiversity mainstreaming, and develop specific conservation objectives, incentive mechanisms, and regulations specifically for such areas that are privately owned. The aim of the incentives should be to encourage conservation of ecological values through conservation easements, transfer of development rights, special augmentation of existing zoning, tax breaks, payment for ecosystem service, or other scheme.
Management Response: [Added: 2015/09/10]

These follow-up actions have largely been initiated in the lead in to the new PA Financing project.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
a.Prepare baseline reports on the potential for conservation offsets, payment for ecosystem services, etc. b.Identify areas for potential application
[Added: 2015/09/10] [Last Updated: 2016/12/11]
MLUH SSP Consultants 2016/12 Completed The baseline reports will guide any potential incentive mechanisms that can be identified for specific areas (in line with the SSP) and may be financed under, for example, the PA Finance project. The PA Finance Project is addressing the recommendation. Pt.a has been completed while pt b is still ongoing History
23. Recommendation: As part of the monitoring, control, and surveillance programme for the targeted fisheries under biodiversity mainstreaming, socio-economic data should be monitored in addition to biophysical parameters, to enable evaluation of the progress of the mainstreaming efforts. It would also be advisable to carry out monitoring at areas not covered by the mainstreaming efforts, in order to allow assessment of whether external factors, such as the state of the economy, climate change impacts, etc., are influencing performance
Management Response: [Added: 2015/09/10]

A specific MCS protocol has been designed under the project and completed in mid-2015. It is now being implemented by the PFCCC on which the SFA is a member. Lessons learned from the MCS will also be useful for activities on Mahe under the Fisheries Management Plan

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Design a specific MCS protocol for the fisheries management plans
[Added: 2015/09/10]
SFA No due date No deadline established The MCS protocol is in place and funding is available to implement it. It will also be replicated within the wider EEZ as part of the implementation of the Marine Spatial Plan.
24. Recommendation: Marketing of the SSTL programme should be strengthened, e.g., presenting the business case benefits of pursuing SSTL certification, through for example cost savings achieved by more efficient use of energy and water, by sourcing more food locally, and by implementing improved waste management programmes. These marketing efforts could be supported by preparing knowledge products (e.g., case studies) using some of the results of the demonstration activities sponsored by the project.
Management Response: [Added: 2015/09/10] [Last Updated: 2015/09/10]

Noted. The recommended activities are already under way as the SSTL has been taken over for a few year now by the Seychelles Tourism Board

Key Actions:

Key Action Responsible DueDate Status Comments Documents
a.Conduct further training and marketing exercises, led by Tourism Department and ENGO partner (S4S). b.Develop an internal marketing strategy to further the SSTL and linkages to regional and international labels.
[Added: 2015/09/10] [Last Updated: 2016/01/13]
STB, Ministry of Tourism, SHTA 2015/12 Completed This activity is handed over to Tourism Department which has created and staffed a SSTL Secretariat to further develop the label.
25. Recommendation: The information management systems supported by the project should be summarized; including the biodiversity database hosted by the National Herbarium, the shark database, etc. The summary should indicate responsible managers of these systems, estimated costs to maintain them, possible funding sources, and interfaces with other information systems, including the national clearinghouse mechanism.
Management Response: [Added: 2015/09/10]

The IMS systems will be summarized in the project final review report. All systems are handed over to Government and responsible agencies, staff are capacitated and in place to manage them, and Government budget is in place to maintain and further develop them.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Summarize database information as a part of the project final review report.
[Added: 2015/09/10] [Last Updated: 2016/01/13]
PCU 2015/12 Completed Stared as part of the Outer Island Project
26. Recommendation: The project financial expenditure records should be reviewed and a note-to-file prepared explaining possible misallocations across outcomes and project management cost centres. The adjusted financial expenditure summary should be included among the material provided to the independent financial auditor when the 2015 results are audited.
Management Response: [Added: 2015/09/10]

Noted. The final audit of the project has already taken place as the remaining funds are below the threshold requiring a new audit. The recommended information will be put on record in the project final review report.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Financial expenditure to be reviewed and reorganized within the project final review report (noting that the posted financial information in Atlas cannot be changed). This will provide a more accurate record of e.g. management costs.
[Added: 2015/09/10] [Last Updated: 2016/01/13]
PCU 2015/12 Completed
27. Recommendation: Biodiversity mainstreaming should be extended to the agriculture and forestry sectors, by upgrading relevant policies and legislation, developing incentive schemes, and piloting activities involving conservation agriculture, sustainable forest management, agroforestry, and other relevant initiatives.
Management Response: [Added: 2015/09/10]

This is a very broad recommendation, essentially for a new project. At the time the current project was formulated, the inclusion of forestry and agriculture was indeed discussed, but it was decided by stakeholders that the priorities at that time were fisheries and tourism. The growing importance of the forestry and agricultural sectors was discussed again in 2015 as part of the GEF6 portfolio formulation exercise and documented in the Seychelles GEF6 National Portfolio Formulation Document, finalized in August 2015. Some elements of this recommendation are now viewed as a priority for GEF6 funding and are included within the proposed new projects.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Discuss with stakeholders and consider including these elements within GEF6 projects.
[Added: 2015/09/10]
No due date No deadline established
28. Recommendation: In terms of financial sustainability of artisanal fishers associations, supply chain analyses should be carried out, including local buyers such as hotels and restaurants. These analyses might be done in collaboration with the Fishing Boat Owners Association (FBOA), which as part of their Responsible Fishing programme, is developing a fish centre on Mahé to facilitate trade with local buyers.
Management Response: [Added: 2015/09/10]

Noted. SFA is in receipt of funds from a number of sources for work of this type and has set up partnerships with fishing organizations in Europe to exchange experience and knowledge concerning marketing of (surplus or specialised) products from Seychelles.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Implement a programme addressing marketing issues and exploring market outlets.
[Added: 2015/09/10]
SFA, FBOA No due date No deadline established There is no issue with the marketing of fish by local fishermen as there is a big local market and a big potential international market also. The issue is more the affordability of fish for local Seychellois.
29. Recommendation: Under the fisheries partnership agreement between the EU and the Government of Seychelles, a significant portion of the financial contribution from the EU is earmarked for support of the fisheries sector of Seychelles. It would be advisable to develop specific plans to follow up the results under Outcome 2, and advocate for support under this partnership agreement.
Management Response: [Added: 2015/09/10]

SFA was the lead partner in the development of the fisheries management plans and is the owner (together with the fishing community) of the final plans. Government has already committed to using fees from the international fisheries agreements to implement the plans, including especially the MCS protocols. The furtherance of the plans is also a key element within the wider Marine Spatial Planning exercise and the Governments Blue Economy approach.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Within the context of GEF6, and specifically within the SWIOFish3 project, follow up on the fisheries management planning outcomes and document lessons learned applicable to the wider EEZ.
[Added: 2015/09/10] [Last Updated: 2016/12/27]
MOFTBE, SFA, MEECC No due date Initiated SWIOFish3 is to be managed by MoFTBE, but the relevant fisheries outcomes will likely still be managed through MEECC and PCU, ensuring continuity with the current project outcomes. History
30. Recommendation: As general recommendations for similar GEF-financed mainstreaming projects: a. Some of the co-financing streams should be advocated to flow after the GEF project closes, to support post-project monitoring and evaluation; b. Project managers should receive training in biodiversity mainstreaming and be made more aware of lessons learned and ongoing activities within the GEF corporate portfolio.
Management Response: [Added: 2015/09/10]

The issue of whether project funds can be retained after the project closes officially to enable monitoring of outcomes over a longer period is to be determined by GEF, but is unlikely to be viable within the GEF funding cycle. In any case, the advantage of having a PCU in Seychelles is that no project is implemented in isolation and that long-term continuity and synergies are to some extent assured ? this is viewed by many reviewers as potential best practice for GEF since it overcomes the funding cycle issue mentioned above. GEF does commission post project evaluations across several countries from time to time and if selected Seychelles will gladly participate as we have done in the past for SLM project. The second issue is also addressed largely to GEF since it would require a central trainer and the budgeting of trainer and training courses at the central level ? which would be more efficient than ad hoc training under individual projects.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
No key actions required as these recommendations are addressed to GEF
[Added: 2015/09/10]
No due date No deadline established

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