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Mid-term Evaluation of Comprehensive reduction and elimination of Persistent Organic Pollutants in Pakistan
Commissioning Unit: Pakistan
Evaluation Plan: 2018-2022
Evaluation Type: Project
Completion Date: 02/2019
Unit Responsible for providing Management Response: Pakistan
Documents Related to overall Management Response:
 
1. Recommendation:

Timelines:

  1. Extension of the project time period by 12 to 18 months: approximately 30% of the project is implemented, so more time is needed; need to also consider other technologies (i.e. PCB specific) that may be more suitable /sustainable in Pakistan (as mentioned in the Pro Doc which mentions de-halogenation technologies).
  2. PMU to develop activities, better planned, integrated and time bound. Aim is to develop an integrated ‘POPs management system'.
  3. To reinstate quality in activities which are currently rushed with minimal matching to project indicators and lack of verification to BAT/BEP and to specific ProDoc activities.
  4. A budget revision (recognizing the 5% PMU budget cap in GEF projects) would be required for this to fund the PMU for the longer period with activities being specifically lined to the ProDoc and strictly time bound.
Management Response: [Added: 2019/06/04]

With approximately 30% of the project implemented (at the time of MTR), and the project set to end by March 2020, more time is needed to complete the remaining activities of the project. An extension of 12-18 months will be requested by the MOCC, as this would also ensure POPs legislation process to be completed and allow other technologies to be considered (i.e. PCB specific) that may be more suitable/sustainable in the Pakistan context.  However, this will be preceded by a rapid analysis and readjustment of activities and timelines by the PMU in consent with the UNDP CO, in consultation with stakeholders, and using hired additional expertise as required (international or national) to inculcate best management practices (BAT/BEP) for integrated POPs management, to develop a new plan of work, with as many integrated and/or parallel processes as feasible, in order to make up for lost time. This adjusted plan will ensure that sound milestones are embedded, with appropriate budget revision. This draft should be rigorously reviewed by the Project Board as well as the BRH RTA and UNDP GEF Finance, for ultimate vetting by the PSC, so that a vetted activity plan, milestones and revised budget can be put in place to accompany any extension request.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
First draft of revised work plan with the adjustment of activities and remaining budget
[Added: 2019/06/04] [Last Updated: 2019/07/30]
MoCC, UNDP, POPs PMU 2019/07 Completed Project has incorporated comments received from Mid-Term Review through adjusting the activities and budget in the revised AWP 2019. History
PMU will call Project Board meeting to discuss the planning for 2019 and get this approved
[Added: 2019/06/04] [Last Updated: 2019/09/05]
MOCC, POPs PMU, UNDP 2019/07 Completed The National Project Director (NPD) has approved the revised AWP 2019 incorporating the proposed changes responding to MTR Recommendations. History
PMU will introduce advanced technologies & strategies for the disposal or treatment of POPs (PCBs mainly)
[Added: 2019/06/10]
POPs PMU 2019/12 Not Initiated
Another review of Project to check the progress of activities will be done
[Added: 2019/06/10]
POPs PMU 2019/11 Not Initiated
2. Recommendation:

Baseline:

  1. POPs types, quantities and locations are poorly quantified for pesticides and virtually unknown for PCBs with repeated confusion that all obsolete pesticides are POPs and that it can be assumed older transformers contain PCBs
  2. The project needs to re-verify assumed POPs pesticides, which are mixed with non-POPs and start to establish what PCBs exist (locations and quantities). This needs to be done through professional inventory practices, including extensive laboratory analysis
  3. This should be done through integrating international and local expertise which would better develop informed (revised) decision making on quantity of POPs accessible for treatment and technology to be used
  4. Reverification of POPs pesticides and the contaminated sites would allow POPs contaminated sites to be documented and would permit comparison between Pakistan and international lab standards. The activities have already been completed in three provinces and in progress in Punjab, it will provide a new baseline for the destruction of remaining target of POPs pesticides that is approximately 760 M Tons (while actually is far less as re-verified)
  5. Testing of Pakistan Laboratory capabilities for project analytical needs should be combined with international lab testing (at least initially) to act as a ‘field split’ and test performance on timely delivery of results and quality. Active measures should be made so that UNDP and PMU components are harmonized as a team
Management Response: [Added: 2019/06/10]

POPs Pesticides have already been identified and quantified in all provinces by individual technical consultants hired by the project, in second & third quarter of 2018. Project has actively engaged all provincial and national level stakeholders to avoid any gaps in primary data collection and reconfirmation of stockpiles from respective government departments. Throughout the process, project monitored all the field activities of consultants for reconfirmation. Draft reports were shared with all concerned departments to cross-check the inventories and number of stockpiles. The final reports were released and shared with all relevant stakeholders. Estimation of POPs contaminated soil will also be completed by engaging national experts.

For PCBs, the inventory was totally missing from NIP Pakistan 2009, which is the baseline of this project. The project has started developing inventory of PCBs for 2000s equipment. Initially, only 60 samples were collected and analyzed but the project has now made a strategy to develop the PCBs inventory by carrying out appropriate laboratory tests and labelling of the contaminated oil and equipment from where samples will be collected from all provinces.

The TORs for engaging the international experts in the project shall be developed in consultation with UNDP CO and BRH.

It should be noted that the same figure for POPs Pesticides as identified by POPs project i.e. 286 MT has been validated & reported by National & International team of consultants in parallel under another project of Ministry of Climate Change and UNEP titled “Review and Update of the National Implementation Plan of Stockholm Convention on Persistent Organic Pollutants in Pakistan”. The updated National Implementation Plan of Pakistan and action plan will be submitted to Stockholm Secretariat by March 2019.

Project will engage multiple local laboratories meeting international standards for extensive sampling and testing of all kinds of POPs.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Consultants will be engaged to work on development of inventories of POPs PCBs at national level
[Added: 2019/06/10]
POPs PMU 2019/03 Completed
Quantum of soil from POPs contaminated sites will be evaluated and disposed off through environmentally sound practice
[Added: 2019/06/10]
POPs PMU 2020/03 Initiated
Development of TORs to engage International experts in consultation with UNDP CO and BRH
[Added: 2019/06/10]
POPs PMU, UNDP CO 2019/04 Completed
Sampling and analysis of PCBs by multiple certified national laboratories
[Added: 2019/06/10]
POPs PMU 2019/11 Initiated
3. Recommendation:

Expert Backstopping:

Appropriate international and national backstopping is required as the MTR has found multiple examples where technical expertise is lacking (i.e. identifying what is or is not a POP), in process (M/E, Reporting) and standards (BAT/BEP). This needs to be done in an integrated way so that provision of this expertise is also used to concurrently build capacity in stakeholders who will have specific roles in ongoing POPs management.

Work planning should identify where and when such expertise should be applied and who the beneficiaries from such capacity building will be.

Management Response: [Added: 2019/06/10]

Project has already engaged International and national level consultants for not only mapping out POPs but also to prepare feasibilities and management plans for POPs. There are few locations in all provinces where the POPs stockpiles are mixed with non-POPs due to which all the stockpiles are now contaminated. To reconfirm them through lab testing, project is hiring the services of laboratories which will be engaged in sampling and testing activity of these locations.

Project has incorporated significant activities in Annual Work Plan 2019 for POPs management in various sectors. The project aims to engage international expertise to develop and finalize technical guidelines and management plans. The project shall also collaborate with UNDP regional office to identify the correct and useful resources who may prove to be beneficial for the project by regularly sharing all AWPs, budget revisions and all technical TORs. These guidelines and plans will standardize the management of POPs in complaint with Stockholm convention at national and sub-national levels involving all the main stakeholders.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Identification of activities to engage International experts and develop TORs in consultation with UNDP CO and BRH
[Added: 2019/06/10]
POPs PMU, UNDP CO 2019/04 Completed
Hiring of International consultant to work on feasibility, procurement & installations of PCBs treatment technology at national level
[Added: 2019/06/10] [Last Updated: 2019/09/05]
POPs PMU, UNDP 2019/11 Initiated Evaluation process to hire 3 international consultants is in the final stage of reference checks and the consultants will be on-board given they also get visa on time. History
Hiring of International consultant for developing PCBs management plan
[Added: 2019/06/10] [Last Updated: 2019/09/05]
POPs PMU, UNDP 2019/11 Initiated Evaluation process to hire 3 international consultants is in the final stage of reference checks and the consultants will be on-board given they also get visa on time. History
Hiring of International consultant for development of technical guidelines for POPs in accordance of BAT and BEP
[Added: 2019/06/10] [Last Updated: 2019/09/05]
POPs PMU, UNDP 2019/11 Initiated Evaluation process to hire 3 international consultants is in the final stage of reference checks and the consultants will be on-board given they also get visa on time. History
4. Recommendation:

Regulatory Framework Development:

  1. Consideration should be given on legislation and non-legislative approaches that could achieve the project goals in the most straightforward manner.
  2. It is recommended to separate National Management Plans for PCBs/OPCPs/uPOPs, which could initially be voluntary industry approaches (Australian example) if legislation is delayed.
  3. Legislation can target updates of hazardous waste provisions for premise, activities and emissions that duplicate BAT/BEP in Stockholm. This would then capture different sectors (agriculture, electricity, other thermal industries, ship breaking) but using an existing framework. Regulators and industry need to be consulted to have a workable plan (timelines/resources/responsibilities).
Management Response: [Added: 2019/06/10]

Project endorses the recommendation and has already started working on sector specific rules and guidelines in collaboration with legal consultant. The GAP analysis of the legislation on POPs in Pakistan was completed and consensus was built to go for the amendments in existing regulatory mechanism. The PMU along with legal consultant will now work on draft amendments in existing Pakistan Environment Protection Act (PEPA) for inclusion of additional clauses to regulate all kinds of POPs and Draft comprehensive sector-specific(Agriculture/Plant Protection, Pakistan Customs, NEPRA/Ministry of Energy, Ministry of Industries and Production, Ministry of Health and EPA’s) new rules for control & management of all kinds of POPs in Pakistan and will present the Draft amendments in PEPA & sector-specific newly drafted rules for POPs management to Federal/Provincial Stakeholders, Law Divisions, Parliamentary Committees and respective government bodies who would be engaged in the legislation process, ensuring support in approval of the final legislation on POPs.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
International consultant to work on formulation of national technical guidelines on POPs management and control
[Added: 2019/06/10]
POPs PMU, UNDP 2019/12 Not Initiated
Legal Consultant for completion of legal process and amendments in existing legislation
[Added: 2019/06/10]
MoCC, POPs PMU, UNDP 2020/03 Initiated
5. Recommendation:
  1. Existing contracts to be renewed should be retrofitted in light of the previous comments or other actions taken to meet these needs (i.e. supervision contracts) so that independent expert opinion ensures BAT/BEP are met.
  2. The PMU is academically well qualified but will benefit from further training to improve their capability and formal courses (Prince 2) and integration with expert consultants should be considered (especially with M/E, BAT/BEP).
Management Response: [Added: 2019/06/10] [Last Updated: 2019/06/10]

UNDP CO has revised the contracts of handling and disposal contractors considering all the recommendations given by MTR consultants and including SOPs to be followed from transportation till final disposal.  PMU is monitoring and supervising the activities being performed by both handling and disposal contractors. Furthermore, as per the ProDoc, PMU is also looking for alternate disposal facilities available in country which can be considered for the disposal of POPs.

To further enhance the PMU skills, training activity has been incorporated in the Annual Work Plan 2019. PMU is actively monitoring and following BAT/BEP in the recent transport and disposal activities to ensure that all SOPs are being followed. As there are only three staff members in PMU of this project, PMU is planning to engage expert consultants for key activities to be carried out during this year.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Development of SOPs and incorporating in the revised contracts of the vendors
[Added: 2019/06/10]
MoCC, POPs PMU, UNDP 2019/01 Completed
PMU staff will get training on PMP/Prince2
[Added: 2019/06/10] [Last Updated: 2019/07/30]
POPs PMU 2019/09 Completed The project team has completed training program on project management from National University of Science and Technology (NUST) Islamabad. History
6. Recommendation:

Reporting, Monitoring and Evaluation:

  1. Reports need to be reformatted to make sure they include all of the components, objectives and activities in the ProDoc and that the same numbering of objectives/activities is then used in the PIR. AWP and other such reports to ensure consistency.
  2. Narrative and financial reporting needs to be both more regular (with 3 monthly reports to be provided and needs to be of sufficient detail, accuracy and alignment with the ProDoc.
  3. Reporting needs to include an exact break down of budget expenditure compared to individual activities to ensure the project team is accurately following the detailed budget plan provided in the ProDoc expenditure Reporting.
Management Response: [Added: 2019/06/10]

The project is following UNDP and GEF reporting requirements and all the reports are furnished as per the requirement and timelines. However, there were some inconsistency with contents of the few reports which will be rectified for uniform reporting. For future references, it will be ensured to keep regular check in with UNDP -GEF Finance and RTA to ensure that UNDP GEF Policy as relates to oversight and financial management are followed. The budget vs. expenditure as per the budget availability under the budget lines of the ProDoc shall also be developed for future referencing and budget monitoring purpose.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Reports to be aligned for consistency
[Added: 2019/06/10] [Last Updated: 2019/07/30]
UNDP and POPs PMU 2019/07 Completed Project is sharing all financial and programmatic reports to UNDP as per UNDP and GEF reporting requirements and timelines. History
Quarterly reporting to be initiated
[Added: 2019/06/10]
UNDP and POPs PMU 2019/04 Completed
Develop budget vs. expenditure sheet as per budget line of ProDoc
[Added: 2019/06/10]
UNDP and POPs PMU 2019/04 Completed
7. Recommendation:

POPs Disposal:

  1. It is recommended the resources for treating 1500 tonnes of POPs should be reprogrammed to identify, test and cost seperate treatment options for (a) pesticide POPs and PCB contaminated transformer oil
    • For POPs pesticides, international experts should be hired to do a rapid POPs inventory assessment to identify pesticide POPs in accordance with BAT/BEP; Reverification activities have already been completed in three provinces and in progress in Punjab. But methods falls short of international best practice (actual quantification/ chemical analysis). It will provide a 'baseline' for the destruction of remaining target of POPs pesticides that is approximately 760 M Tons but with the same uncertainty regarding what is being treated.
    • To identify, package and transport POPs pesticides in accordance with BAT/BEP so it is acceptable for receipt at a national treatment facility and for international export.
  2. New facilities for disposal to be considered or the existing incinerators to be upgraded for enhancing the country capacity and future facility under Govt is recommended.
  3. For PCB contaminated transformer oil, international expert technology providers should be engaged to trial mobile dehalogenation treatment technologies at electricity substations.
Management Response: [Added: 2019/06/10]

It has been confirmed and verified that only 286 MT of POPs Pesticides is available in country as per record available with Government Departments and latest surveys done by POPs PMU & Ministry of Climate Change under UNEP funded Project to update POPs inventory (revised NIP of Pakistan).  Project has started exploring & identifying other suitable facilities within Pakistan where POPs Pesticides can be destructed through BAT/BEPs. Cement Kiln & smelting furnace options are under consideration which would be finalized through UNDP BRH or RTA. For PCBs, an international consultant will be hired to carry out feasibility of procurement and installation of suitable technology in Pakistan. The cost analysis of importing PCBs treatment technology to Pakistan will be compared with provision of alternate/PCB free oil to energy sector of Pakistan. The TORs of the consultant will be shared with the UNDP regional office for their input and then advertised accordingly. The technology needs to be assessed fully as per the requirement at the national level and then procured.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Identification of POPs Pesticides Treatment Facility (cement kiln or furnace) in Pakistan & feasibility for import of PCBs Treatment Technology in Pakistan
[Added: 2019/06/10]
MoCC, POPs PMU and UNDP 2019/10 Initiated
Hiring of International consultant to work on feasibility, procurement & installations of PCBs treatment technology at national level
[Added: 2019/06/10] [Last Updated: 2019/09/05]
POPs PMU, UNDP 2019/11 Initiated Evaluation process to hire international consultant is in the final stage of reference checks and the consultant will be on-board given they also get visa on time. History

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