The majority of the risks identified during preparation did materialize during project implementation, and led to delays including; (a) procurement delays
due to low capacity, (b) the risk of low investment from the concessionaires (c) the difficulties of
reaching efficient working partnerships among the major agencies; and (d) potential
administrative bottlenecks given the numerous participating agencies. There were no new risks
found during implementation and in this sense the identification of risks was very accurate.
However the ‘modest’ risk level identified during preparation did not fully reflect the fact that
DENR had previously done little work on regulation of domestic wastewater, had limited
capacity in the sub sector, regarded domestic waste as a relatively low priority and had no direct
mandate in sanitation infrastructure provision. For example both (a) the risk of low investment
from the concessionaires; and (b) difficulties in partnering among the major agencies; should
have been set at ‘high’, rather than ‘modest’. Mitigation measures were integrated into the design
of the project – for example through partnership development, but were not sufficient to address
the difficult context. Additional measures should have been taken, such as reducing the scope and
simplifying the GEO to include a single aim. With hindsight, despite the small size of the project,
given the complex design and ambitious scope the risk level should have been assessed as
‘substantial