Comprehensive Environmentally Sound Management of PCBs in Montenegro

Report Cover Image
Evaluation Plan:
2017-2022, Montenegro
Evaluation Type:
Final Project
Planned End Date:
Completion Date:
Management Response:
Evaluation Budget(US $):


Document Type Language Size Status Downloads
Download document UNDP-GEF-TE-TOR-Template-June2020_PCB Montenegro_International Final.pdf tor English 561.48 KB Posted 11
Download document UNDP-GEF-TE-TOR-Template-June2020_PCB Montenegro_National Final.pdf tor English 835.44 KB Posted 11
Download document UNDP-GEF_PCB-Montenegro_TE-report_Final2_signed.pdf report English 3498.48 KB Posted 15
Title Comprehensive Environmentally Sound Management of PCBs in Montenegro
Atlas Project Number: 00088794
Evaluation Plan: 2017-2022, Montenegro
Evaluation Type: Final Project
Status: Completed
Completion Date: 10/2022
Planned End Date: 09/2022
Management Response: Yes
Focus Area:
  • 1. Sustainable
  • 2. Others
Corporate Outcome and Output (UNDP Strategic Plan 2018-2021)
  • 1. Output 1.4.1 Solutions scaled up for sustainable management of natural resources, including sustainable commodities and green and inclusive value chains
SDG Goal
  • Goal 9. Build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation
SDG Target
  • 9.4 By 2030, upgrade infrastructure and retrofit industries to make them sustainable, with increased resource-use efficiency and greater adoption of clean and environmentally sound technologies and industrial processes, with all countries taking action in accordance with their respective capabilities
Evaluation Budget(US $): 20,000
Source of Funding: GEF
Evaluation Expenditure(US $): 20,000
Joint Programme: No
Joint Evaluation: No
Evaluation Team members:
Name Title Nationality
Olivier Beucher International consultant
Ana Simonovic National consultant
GEF Evaluation: Yes
GEF Project Title: Comprehensive Environmentally Sound Management of PCBs in Montenegro
Evaluation Type: Terminal Evaluation
Focal Area: Persistent Organic Pollutants
Project Type: FSP
GEF Phase: GEF-6
GEF Project ID: 9045
PIMS Number: 5562
Key Stakeholders: Government, Institutuions

In terms of design and management, the experiences under the project point towards the importance of establishing and maintaining good relationships and clear and transparent communication channels with the industry, for projects dealing with hazardous waste issues located on private industry property. Furthermore, in complex setups such as post-soviet economies and unclear historical ownership of sites and waste, involvement of both industry and government are necessary to deal with waste in a comprehensive way.


Another lesson learned through the project is that a smaller project board makes for more agile adaptive management and does not necessarily mean that other interested parties will lose interest. Again, good communication about project progress and results to all interested parties is essential and a good complement to a small Project Board.



Finally, the hiring of an in-house expert on PCB issues greatly facilitated the projects’ activities and outcomes and allowed an efficient use of resources.


On a technical level, the main lessons to be learned from this project is that for smaller countries dealing with relatively small amounts of hazardous waste, it often is more cost effective to export waste compared to treating it in the country.



The project is in line with national priorities and remained relevant throughout its implementation period. It provided technical and financial support to the Government of Montenegro and facilitated effective and timely enforcement of the national regulations on PCBs and waste, which requires the phasing out and disposal of PCB containing equipment by 2025. It also allowed further alignment with relevant EU legislation as well as the Stockholm and Basel Conventions.



Overall, the project was well-designed. The Results Framework was well integrated, outputs lead to the expected outcomes and contributed to the overall objective of the project. The indicators provided in the RF were relevant, but several of them were not SMART.

Initially planned over 5 years, the time seemed to be sufficient for the achievement of the project objectives. However, the project needed to be no-cost extended in June 2021, by 11.5 months. The extension allowed the project to deliver and catch up effectively on the delayed and extra identified activities.


Stakeholder involvement and partnership arrangements

The project identified a broad range of stakeholders from national and local government, private sector, civil society and academia at its start. Most of these attended the kick-off workshop, after which some dropped out, as the project was not their main focus.

Altogether five training workshops and two study visits were organized by the project.  Judging by the workshop and study visits attendance lists, as well as by the interviews, the project succeeded in keeping stakeholders interested and onboard throughout the project. After a recommendation in the MTR, the PMU sought to strengthen connections to secondary (supporting and peripheral) stakeholders that were indirectly affected by the project activities and to raise the general support for the project's interventions. The second half of the project therefore saw a stronger inclusion of academic stakeholders as well as he involvement of the Institute of Public Health.

The project was able to identify those national institutions that possessed the initial skills and knowledge for the technical aspects of the project (CETI, Hemosan, IPH) and managed to build their capacity and international network.

Not all stakeholders were clear on their roles at the beginning of the project. Considerable time and effort were spent clarifying roles, responsibilities, and budgetary issues with the two private companies, and more particularly with CEDIS. However, all interviewees acknowledged that stakeholder relationships worked fine after these initial challenges had been overcome. Interviewed institutions said that overall, the project had strengthened collaborations between the different stakeholders involved, giving them practical experience on the (joint) implementation of this type of project, and resulting in a better cooperation under other nationally implemented projects.




Even though the Montenegrin government had already taken several actions towards PCB management, interviewees said a direct implementation by UNDP had been a major advantage, as it considerably relieved stretched government resources from managing complex tenders for waste handling, export and disposal. The PMU team was said to have communicated in a timely, transparent, and effective way to the Project Board, and to have put in considerable effort to facilitate smooth operation and collaboration between the project partners.  Adaptive management was implemented throughout the project.

The Project Board initially was composed of all interested parties/stakeholders. This proved slowed downs decision processes, and the Board was slimmed down in Junly 2019, to the MoESPU, the two main PCB holders and the PMU, after which it was able to function more effectively. Several members of the project board were replaced after national elections reshuffled national politics and ministries in 2020. This temporarily delayed decisions by the board, and resulted in the delay of some activities, according to several interviewees.

Overall, the Project Board executed its supervisory and guidance function fine. The board also proved useful in securing political support for activities. It facilitated for example the (legal) clearance to use fast-screening kits for PCB oil thereby significantly reducing the costs of the national PCB inventory establishment process.



The project has been very effective in achieving its results and outcomes. The project has managed to establish a full online dynamic inventory of PCB in the country, develop guidelines for ESM of PCB, train relevant stakeholders, adjust national legislation, and draft a national PCB management plan. Targets for sampling were exceeded, as well as those for waste disposal. The target for upgrading storage facilities was only partially achieved, as were the targets for company specific PCB management plans. Staff of PCB holding companies, ministries, participating technical institutes as well as university students were capacity built on technical procedures, guidelines and general PCB management issues. Guidelines were said to have been immediately put in practice by all institutions involved. Interviewees expressed their overall (high) satisfaction with the project, and especially with the capacity building outcomes.


Risk management

The ProDoc clearly identified the risks to achieving the results, rated associated risk levels, and identified mitigation strategies/measures as well as responsible entities for each. The overal project risk rating was considered as Medium. However, the initial risk matrix did not include and hence underestimated risks coming from the potential delay in project activities caused by a lack of commitment of PCB owners for final disposal of PCB contaminated equipment by 2020, potential larger (historical) contamination of soils at project sites, the impact of national elections, time needed for obtaining transportation permits for PCB waste, or risks related to co-financing commitments. Risks were not systematically reported on or updated in the Critical Risk Management section of the PIRs, but the available evidence suggests that management responses to reduce the main risk identified in the UN SESP framework were duly implemented. Social and environmental risks were monitored, and no accidents occurred during project activities.



Overall, the project was run very efficiently.  The project ran an underspending during most of its implementation period. Volumes of waste were lower than originally estimated, and the project made very efficient use of tenders for waste export and disposal. The freed-up budget allowed the project to export more contamniated soil than initially foreseen, enabling the it to deal with a large historical contamination detected at one of the project sites in the meantime.

The placement of a technical expert at the PMU proved cost-efficient, as the expert was able to conduct the technical assessment for treatment and disposal of low-concentration contaminated equipment, eliminating the need to hire an additional consultant for this task. Finally, in the area of legal expertise the project went about efficiently, with the expert assisting the government on the drafting of several pieces of legistlation.


Monitoring and Evaluation

The design of the monitoring plan was basic and not very effective. The TE team found some inconsitencies between the Results Framework, the Monitoring Plan and the Multi Year Work Plan. The Results Framework was used to inform the annual Project Information reports, whereas the Project Board decisions were based on the Multi Year Work plan. From the evidence presented, the TE team concludes that the PMU was de facto closely and effectively monitoring project activities and progress, and kept the Project Board, as well as the UNDP hierarchy informed in a transparent and detailed way. This is further substantiated by interviewees praising the close management and the responsiveness of the PMU to any issues arising. The notes of the PBM testify that the Project Board fulfilled its supervisory and guidance function. 


Impact and Sustainability

The project has progressed substantially towards its envisioned impact: the reduced exposure of the local and global environment and people to PCBs.

The TE team also deems the project very sustainable, across the board (financial, socio-economic, governance and institutional framework, environmental).


Terminal Evaluation recommendation 1. Formulate lessons learned


Terminal Evaluation recommendation 2. Better communicate the results of the project


Terminal Evaluation recommendation 3. Better assess risks related to co-financing of the polluter


Terminal Evaluation recommendation 4. For next similar projects, plan in some financial flexibility for historical soil contamination

Management Response Documents
1. Recommendation:

Terminal Evaluation recommendation 1. Formulate lessons learned

Management Response: [Added: 2022/10/13]

Fully Accept

The Project Management Unit and Project Board will develop lessons learned for the project, which will cover all phases of the project preparation and implementation.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
1.1 Lessons learned developed
[Added: 2022/10/13] [Last Updated: 2022/11/24]
Project Management Unit 2022/12 Initiated History
2. Recommendation:

Terminal Evaluation recommendation 2. Better communicate the results of the project

Management Response: [Added: 2022/10/13]

Management response: Fully Accept

The Project has been collecting video and photo material throughout project implementation showing the activities being implemented, out of which a video will be made presenting situation with PCB before and after the project is implemented. I addition, a fact sheet will be prepared presenting the project results. With that video and the fact sheet results of the project will be communicated locally and within international UNDP network.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
2.1 Communication material developed
[Added: 2022/10/13] [Last Updated: 2022/11/24]
Project Management Unit 2022/12 Initiated History
3. Recommendation:

Terminal Evaluation recommendation 3. Better assess risks related to co-financing of the polluter

Management Response: [Added: 2022/10/13]

Management response: Accepted

The risks related to co-financing issues will be addressed in the lessons learned, that will be distributed within Country Office, so other colleagues can benefit the experience from the implementation of this project.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
3.1 Development of lessons learned
[Added: 2022/10/13] [Last Updated: 2022/11/24]
Project Management Unit 2022/12 Initiated History
4. Recommendation:

Terminal Evaluation recommendation 4. For next similar projects, plan in some financial flexibility for historical soil contamination

Management Response: [Added: 2022/10/13]

Management response: Accepted

This will be covered and processed in project’s lessons learned.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
4.1 Development of lessons learned
[Added: 2022/10/13] [Last Updated: 2022/11/24]
Project Management Unit 2022/12 Initiated History

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