Annex 6

Terms of Reference for OBA Auditor

1 Background
Surabaya is the capital of East Java province and the biggest metropolitan city in Indonesia
with a population of approximately three million.

Perusahaan Daerah Air Minum Kota Surabaya (PDAM), Surabaya City Public Water Utility, is
owned by the City of Surabaya and is not independently regulated. Unlike most public utilities
in Indonesia, the PDAM has a good reputation and good financial standing. PDAM’s coverage
is currently 72% with 395,000 domestic and commercial connections. Yet, a significant pro-
portion of the urban population is without household service connections and gets their water
from a combination of shallow wells, neighbors and water vendors. Poor households bear a
disproportionate burden of current service deficiencies.

The City of Surabaya has given PDAM ambitious expansion targets. In 2007, for example,
PDAM is expected to connect an additional 20,000 residential customers. PDAM has shown
firm commitment to meeting its targets and to connecting the poor. In 2007, the utility set
aside IDR 2 billion of its own budget ($220,000) for tertiary network expansion for the city’s
poor. The current approach of the utility is to target the 15,500 unserved households in
Surabaya City.

2 Expanding Piped Water Supply to Surabaya’s Urban Poor

2.1 The Project
Under this Output-based Aid (OBA) Project – Expanding Piped Water Supply to Surabaya’s
Urban Poor – PDAM will connect low income households to the water network. A special
Government Committee (GC) will manage the reimbursement from OBA funds after
independent verification of their eligibility for financing under the Project. PDAM will make the
connections, and manage the implementation of the tertiary network expansion schemes and
the experimental master meter schemes to provide piped water to informal communities

The Project is financed by the Global Partnership on Output-Based Aid (GPOBA). GPOBA is
a multi-donor trust fund administered by the World Bank.

During the period of the OBA Project, PDAM will be eligible for a pre-agreed reimbursement
for each eligible new service connection and each eligible expansion scheme of the tertiary
distribution network.

The eligible connections made shall meet the following criteria:

‰ the household is “low-income”, according to the following three criteria, all of which
must hold:
o building size < 60 square meters;
o access road to the house < 6 meters or, if facing an open space/dump, the
nearest road < 6 meters; and
o formal installed electricity capacity < 1,300 VA (with a preference for households
< 900 VA), or no formal connection1.

1The smallest size for an electricity connection that is always available from the National Electricity Company
(PLN) is 1,300 VA. Although smaller connections for 450 VA and 900 VA are available, these are very limited in
 ‰ the service connection is new and made after signing of the Grant Agreement;
‰ the technical specification of the connection meets the same level of standard as the
example in Error! Reference source not found. and has been made in
compliance with the quality assurance requirements described in Error! Reference
source not found.;
‰ the connection is operational and in use at time of application for payment; and
‰ the connection has been used for at least three months as evidenced by billing
records.

In addition, eligible expansion schemes must have been subject to the appropriate ex-ante
and ex-post quality and unit cost reviews by the OBA Auditor prior to reimbursement.

PDAM will also be eligible for a pre-agreed reimbursement for each new master meter
scheme. The reimbursement will be contingent on two outputs:

‰ three months of billing and payment of the bulk supply bill; and
‰ a signed contract between a legal Community Based Organization (CBO/BKM) and
PDAM.

A total fund of US$2,287,500 is available for eligible subsidy payments to PDAM, which is the
Implementing Agency. On behalf of the Government, a special Government Committee (GC)
will provide overall coordination, monitoring and evaluation of the project, whereas Project
Manager (Satker)2, will manage the Project and will authorize the payments against eligible
outputs which have been independently certified by the OBA auditor as meeting the schemes
requirements.

PDAM will make the new connections and expansion schemes, and will be partially
reimbursed by GC (from OBA funds) when the outputs have been certified by the OBA
auditor. PDAM will be responsible for deciding when and where new connections and
expansion schemes will be made.

2.2 Subsidies to be Paid

There are three types of OBA subsidy payments:

In-fill connections: In-fill connections are new connections made to an existing tertiary
pipeline. In-fill connections lie within 30 m of the existing tertiary distribution line. The subsidy
payment for eligible in-fill connections to the existing network is fixed at US$45 per
connection.

Under the Project, households contributions are fixed at IDR 300,000 (equal to about US$33)
per household, plus 10% tax of the connection fee.

Example: Cost of In-fill Connection

- Fee for new connection = Rp. 685,000 (based on 2009 PDAM regulation).
- Household Contribution = Rp. 300,000
- Administrative cost = Rp 4,400
- Tax = 10% of the connection fee

Total household contribution:

- Household contribution Rp. 300,000
- Administrative cost = Rp 4,400
- Tax = 10% x Rp. 685,000 = Rp. 68,500

number and require long periods on PLN waiting lists. The project has set the criterion at < 1,300 VA in order to
minimize any errors of exclusion, but preference should be given to households with smaller connections.
2 Minister of Public Works will appoint the existing project organization (Satker) to act as Project Manager.
 Total Cost to be paid by each household = Rp. 372,900

To complement the household payment, the Project will provide an OBA subsidy payment of
$45 to PDAM (through BKM) for each eligible service connection. This OBA subsidy is
intended to offset any risk perceived by PDAM in connecting poor households.

The average cost of an in fill connection has been estimated as US$78, equal to the sum of
the household contribution and the subsidy payment.

Expansion schemes: PDAM may provide connections by expanding the tertiary distribution
network to unserved areas. Normally, households in unserved areas must bear their share of
the cost of network expansion which is added to the connection fee. This applies if
connections are made to the new existing tertiary network. To help poor households reduce
this cost, the Project encourages PDAM to implement network expansions. The subsidies for
expansion schemes will depend on the share of potential eligible households in the service
area of the expansion scheme and the total cost of the expansion. The size of the subsidy for
expansion connections will be determined by the cost of the expansion scheme and the
subsidy cap, which is US$500 per household. In addition, the average subsidy across in-fills
and expansions combined cannot exceed $150 per connection on average. The calculation of
the OBA subsidy for expansion schemes is described in Error! Reference source not
found..

Example: Cost of Expansion Connection

- Fee for new connection = Rp. 685,000 (based on 2009 PDAM regulation).
- Household Contribution = Rp. 300,000
- Administrative cost = Rp 4,400
- Unit Cost of expansion tertiary pipe = Rp 1.000.000,00
- Tax = 10% of the connection fee

Total household contribution:

- Household contribution Rp. 300,000
- Administrative cost = Rp 4,400
- Tax = 10% x Rp. 1,685,000 = Rp. 168,500
Total Cost to be paid by each household = Rp. 472,900

Master meter schemes: The master meter schemes under this Project are experimental
schemes that serve informal urban communities. As this approach is experimental and targets
the poorest of the poor, PDAM will not co-finance the subsidy expenditure – although it will
incur costs from pre-financing and from some community liaison activities required to make
the scheme work.

PDAM will pre-finance, procure, and construct the scheme upstream and inclusive of the
master meter. This means, it will extend tertiary networks (if necessary), lay a short entry
pipe, and install a master meter at the entrance to an informal community. The following unit
costs will be applied for master meter schemes:

Table 1 Master meter scheme unit costs in US$

Item Scheme for 25-70 households Scheme for > 70 households
Possible expansion of tertiary pipe unit costs per meter as in expansion schemes (See Annex 3)
Tapping from tertiary pipe 355 or 4653
Entry pipe from tapping to meter 95
Master meter and housing 450 1,000

3 The lower cost is for tertiary pipes with internal diameter (DN) of 100 mm and the higher cost for pipes with
internal diameter (DN) of 150 mm.
 Total excluding expansion 900 or 1,010 1,450 or 1,560

By regulation, PDAM cannot invest or lay pipes in any area that is (i) not zoned as residential
in the Master Plan or (ii) is zoned as residential but the residents lack legal land title – either
because the land is government owned, private owned, or simply unclear. Although master
meter connections cannot be provided to the first of the two categories above, they will be
developed as a way to alleviate PDAM’s constraints in the second. While the main target
population constitutes informal communities PDAM is free to install master meter schemes in
other poor communities, on the premise that only truly poor communities would elect to have
this level of service in the first place.

The community will be responsible for designing, financing, and constructing the system
downstream of the master meter. A non-governmental organization (NGO) will have to be ac-
tively involved in facilitating this process as the broker between the community and PDAM,
and in forming a legal CBO/BKM if one does not already exist. For Surabaya, the existing
CBO/BKM will act as CBO/BKM. The NGO will bear the costs for these activities out of its
own budget.

PDAM will sign the contract for a master meter with a CBO/BKM as a legal entity. There will
not be a connection fee paid to PDAM, since all hardware costs associated with this scheme
(upstream of the meter and including the meter) will be repaid by GPOBA. PDAM can choose
when to invest in the system in order to limit the financing costs, e.g., it may wait to see pur-
chase of materials by the community prior to construction upstream. NGOs and CBO/BKMs
will liaise between the community and PDAM to ensure the transfer of information in the
crucial initial stages. They will also mobilize the community downstream of the master meter
and assist in generating demand and in designing the scheme.

2.3 Implementation Arrangements

2.3.1. Government Committee (GC)

Steering Committee:
‰ Overall Coordination of the Project;
‰ Monitoring and evaluation of the overall scheme.

Technical Team/City Satker/Provincial Satker:

‰ Project coordination at the City level;
‰ Project monitoring and evaluation at the City level;
‰ Financial management, including organizing annual auditing of the financial accounts
by Badan Pengawasan Keuangan dan Pembangunan (BPKP).
‰ Managing the payments to PDAM (including confirming that payments are eligible
under the scheme) based on claims certified by the OBA Auditor;
‰ Report to the Global Partnership of Output Based Aid GPOBA, through GC.
‰ Procurement of the OBA Auditor
‰ Overall project monitoring and evaluation

Organization Structure of the Project is shown in Figure 1 below.

Figure 1. Project Organizational Structure

 Ministry Ministry of Bappenas
of Finance Public Works
DGCK

GOVERNMENT COMMITTEE
City govt of
Surabaya
Steering Technical
Committee Team

Member of SC: Member of TT:

MoPW, MoF, Bappenas, DGCK, Provin cial Satker,
Mayor of Surabaya Bapemas, Bappeko, Bina
Marga&Drainage,
BPKD, City Satker

The Steering Committee will consist of representatives from: Ministry of Public Works,
Ministry of Finance, Bappenas and City Government/Mayor of Surabaya, whereas Technical
team will consist of representatives from DG Cipta Karya, Provincial Satker, Bapemas,
Bappeko, Bina Marga&Drainage, BPKD, City Satker.

The physical implementation of the Project will be undertaken by PDAM. Regarding

connections, PDAM will assess the applications for house connections, made by households
(facilitated by CBO/BKM) which are included in the approved List of Beneficiaries. They will
also prepare periodic investment plans for expansions.

PDAM will prepare periodic applications for reimbursement from the Project along with the
requisite documentation. . The application form will be approved by the Bank from the
beginning of the project implementation, and the draft of the document is shown in Annex 7.
PDAM will also be responsible for organizing pre-financing to support new service
connections and expansion schemes.

An OBA Auditor will be hired by Project Manager under the OBA Project and will (i) carry out
monitoring and evaluation through six monthly progress review and annual impact
assessments; (ii) undertake spot checks or audit on connections and master meter and
expansion schemes, especially to verify the pressure tests, prior to payment of OBA subsidies
and (iii) certify the unit subsidies to be paid for master meter and expansion schemes.

2.3.2. PDAM

The physical implementation of the Project will be undertaken by PDAM. Regarding

connections, PDAM will assess the applications for house connections, made by households
(facilitated by CBO/BKM) which are included in the approved List of Beneficiaries. They will
also prepare periodic investment plans for expansions.

PDAM will prepare periodic applications for reimbursement from the Project along with the
requisite documentation. The application form will be approved by the Bank from the
beginning of the project implementation, and the draft of the document is shown in Annex 7.
PDAM will also be responsible for organizing pre-financing to support new service
connections and expansion schemes.

2.3.3. OBA Auditor

An OBA Auditor will be hired by Satker Provinsi under the OBA Project, responsible to GC
and will (i) carry out monitoring and evaluation through six monthly progress review and
annual impact assessments; (ii) undertake spot checks or audit on connections and master
meter and expansion schemes, especially to verify the pressure tests, prior to payment of
OBA subsidies and (iii) certify the unit subsidies to be paid for master meter and expansion
schemes. Eligibility of beneficiaries will not be included in the Auditor’s tasks.

It is possible that a household that has been eligible at the time of submission of its
application for connection will improve its status and will not meet all three criteria when
PDAM requests reimbursement from GPOBA. This will not affect the OBA subsidy. If the
household was eligible when it applied for the connection (included in the approved List of
Beneficiaries/DPH), it will remain eligible throughout the Project period.

3 Forward Planning
PDAM will submit a rolling investment plan to GC and Project Manager every six months
outlining the works planned and, in the case of expansion schemes, the financial structuring
of the proposed schemes including numbers of eligible households, and estimates of the
subsidy payments to be requested.

Project Manager will instruct the OBA Auditor to review the plans, particularly in relation to
estimates of expansion subsidy payments and overall average subsidy payments, and
provide a ‘no objection’ to these plans.

4 Quality Assurance
The Project will pay serious attention to technical quality assurance of connections and
schemes. The quality assurance of the OBA connections will be based on the following
measures:

‰ Strict adherence to the specifications of connections;

‰ Spot checks of approximately 10% of OBA connections by the OBA Auditor either
by site visits while connections are made or as ex-post assessments of a random
selection of connections, including detailed review of as-built documentation and
interviews of installation teams, supervisors and customers; and
‰ Payment of subsidies made dependent on full compliance with the quality
requirements.

In cases where the OBA Auditor is not satisfied with the quality of the connections, deductions
may be made to the subsidy payment. The methodology for assessing quality and calculating
deductions is outlined in Error! Reference source not found.. Recommendations for any
reductions will be made by the OBA Auditor in the certificate of quality attached to the request
for payment.

5 Applications for Payment

PDAM will submit periodic requests through CBO/BKM to the City Satker for payment of
subsidies against eligible connections and schemes made. The City Satker is responsible to
ensure that subsidies are released only in respect of eligible connections and schemes.

Reporting Period: The interval between requests shall not be shorter than three months and
not longer than six months.

Documentation required: Each payment request shall be supported with a summary of

service connections and schemes. The summary of service connections (in-fill and
expansion) shall include:

‰ the name, address and customer code of each household;

‰ date of notification of the OBA Auditor; and
‰ date of completion of the connection.

For each eligible service connection (in-fill and expansion) PDAM will keep the filing of:

‰ a copy of the application for connection;

‰ eligibility check against the three criteria (building size, road width and installed
electricity capacity); and
‰ a summary of billing and payment for water use of the household for a period of
at least three months (from the billing record).

For expansion connections PDAM will keep the filing of:

‰ an overview map of the completed scheme and its service area;

‰ the total number of potential and connected customers (at the reporting date);
‰ the number of potential eligible households in the service area;
‰ breakdown and summary of the construction costs of the scheme; and
‰ the actual final calculated subsidy.

Filed documents for service and expansion connections shall be available at any time to the
OBA auditor who will make a regular spot check (sample size of 10%) to review the detailed
records and eligibility criteria.

For master meter schemes PDAM will submit:

‰ an overview map of the completed scheme and its service area;

‰ the total number of potential and connected customers (at the reporting date);
‰ a signed contract between a CBO/BKM and PDAM;
‰ breakdown and summary of the construction costs of the scheme;
‰ the actual final calculated subsidy; and
‰ a summary of billing and payment for water use of the bulk meter for a period of
at least three months (from the billing record).

Alongside each request for payment, PDAM will submit statements for each scheme and
connection or group of connections confirming that safeguards requirements applicable to the
Project and attached as Error! Reference source not found. have been applied. These will
include:

‰ proof of no land acquisition and resettlement; and

‰ environmental statement confirming that all works for which payments have been
requested have been carried out within the safeguard requirements.

Other Documentation: In addition to the above reports, the City Satker will require PDAM to
maintain detailed as-built documents of each OBA connection and scheme. The City Satker
and the OBA Auditor are entitled to have free access to these data at all times. In case of any
discrepancies or doubts about the completion of eligible connections, the City Satker will
examine this additional documentation. Payment of subsidies will not be made if PDAM can
not produce sample as-built documents on request.

6 Purpose of Assignment
To assist it in the implementation of the Project, the Provincial Satker will retain the services
of an OBA Auditor. The OBA Auditor will fulfill three roles:

‰ carry out monitoring and evaluation through six monthly progress review and an-
nual impact assessments;
‰ undertake spot checks or audit on connections and schemes made prior to pay-
ment of OBA subsidies; and
‰ certify the subsidies to be paid for expansion and master meter schemes.

7 Scope and Methodology

7.1 Monitoring and Evaluation
Six-monthly review of progress: At the end of each six-month period the OBA Auditor will
review and assess the progress and performance of the Project on the basis of DMA’s and
PDAM’s reports, background documentation, including as-built files of the subsidized connec-
tions and schemes, relevant data (street width, electricity connection and building size) to ver-
ify the eligibility of households, and any other relevant material, discussions and interviews.

The six-monthly review shall be submitted to GC and the World Bank with a copy to PDAM
within 30 days after the end of each six-month period. In these reviews the OBA Auditor will
assess the progress and performance using at least the indicators listed in the table below.

Objective Verifiable Indicator Means of verification/ Notes

Increase the number of Number of eligible connec-
low income households tions made
connected to the net-
work
Number of potential eligible
connections to connect at a
later date within the service
areas of expansion schemes
Efficient use of re- Number of completed expan-
sources sion schemes
Number of completed master
meter schemes
Should include all in-fills and expansions during the
review period and cumulative, fulfilling all conditions,
including paid water bills, by kelurahan.
Note also all low income households served outside
the Project.
Provides the upper estimate of the ultimate number
of the beneficiaries of the Project.
Provides an estimate of the completion rate of the
schemes against six-monthly planning by kelurahan.

In addition to reporting on the progress and performance by using the above indicators, the
OBA Auditor shall report on any deviations from the Project scope or approach if discovered
during the assessment. The OBA Auditor shall also double check the eligibility of the con-
nected households against the three eligibility criteria.

Annual impact evaluation: On an annual basis the OBA Auditor shall also evaluate the im-
pact of the Project. The impact evaluation will be incorporated into the six-monthly review re-
port of the second half of each year. In addition to the assessment of the progress and per-
formance, the OBA Auditor shall provide his assessment on the impact of the Project on con-
nected households using, at least, the indicators listed in the table below. The approach to be
adopted by the OBA Auditor will be that of random sampling of 10% of households that bene-
fited from the Project.
In addition, the OBA Auditor will review the application of safeguards, to ensure that they
have been correctly applied during the preceding year.

Indicator
Change in average water use in
connected eligible households
Expenditure on water by connected
eligible households
Customer satisfaction
Change in utility incentives to con-
nect low income households
Description
Average water use per capita per day over a period of three months by
kelurahan.
Connection fee and monthly water bills of connected households per
capita by kelurahan, average and distribution by quartiles (data to be
provided from PDAM billing data base) in total and compared to house-
hold income.
Satisfaction of connected households with ease of application proce-
dures, quality of service and cost of service (1% sample)
Number of eligible connections made as a % of total connections made
in the period

Feedback: Due to the learning nature of this Project, it is critical that ongoing evaluation
feeds back directly to the Implementing Agency and PDAM. Therefore GC will be required to
hold a six-monthly review meeting of all Project stakeholders at which the OBA Auditor will
report their findings. This meeting shall be facilitated in such a way as to allow the Project
stakeholders to discuss the findings and explore ways and means of improving performance
or taking positive lessons from the Project into other aspects of their work. The minutes of
such review meetings should be shared with GPOBA.

7.2 Spot Checks and Audit on Applications for Payment

On receipt of the application for payment Project Manager will instruct the OBA Auditor to
carry out a review and make recommendations for payment. This instruction should be given
as rapidly as possible and in any case within one week of receipt of the application for
payment from PDAM.

On receipt of this instruction the OBA Auditor will review the request for payment. The
following items will be checked:

Office based checks shall ensure that:

‰ All required documentation has been submitted. In case this is not done, the OBA
Auditor will communicate this to Project Manager within two full working days of
the receipt of the application for payment. Further checks are dependent on all
required documentation being submitted.
‰ All the filed documents for service and expansion connections shall be reviewed
regularly through spot-check (sample size of 10%)
‰ All connections have been made to eligible households only (households that
were eligible at the time of application for a connection, and included in the
approved List of Beneficiaries). Connections made to households who are not
listed in the approved List of Beneficiaries (DPH) will not be financed under the
Project.
‰ All paperwork related to expansion schemes has been submitted and the as-built
drawings and request for subsidy payment tally with the previously agreed plans
submitted in the relevant investment plan. In case of deviations, which require a
downward adjustment in the agreed subsidy, the OBA Auditor will inform Project
Manager within five full working days of the receipt of the application for payment.
Project Manager and the OBA Auditor will jointly agree on a revision (if required)
to the amount of the subsidy requested in these cases within the rules of the
Project. No upward adjustments to the agreed level of subsidy will be allowed.
 ‰ The OBA Auditor has been notified by PDAM prior to the implementation of all
connections and schemes. No subsidy shall be paid to any connections or
schemes that have been rejected by the OBA Auditor due to substandard quality
and subsidies shall not exceed the reduced subsidy if the OBA Auditor has found
partial quality problems in spot checks.

Field based checks shall ensure that:

‰ The connections for which requests have been submitted have in fact been made
(this will be done through household interviews with a small sample (10%) of
households in the field).
‰ The environmental and social guidelines have been strictly followed. This will be
achieved through a small sample check of construction works during construction
and/or through house-to-house interviews in a sample of areas (10%) where
works have been completed.
‰ The OBA Auditor may request a small sample of connections to be further re-
viewed on a periodic basis. In this case The OBA Auditor, in consultation with
GC, may request PDAM to open a sample of connections (up to a total of 200
during the Project) to ensure that the quality is up to the requirements.

The OBA Auditor will make a recommendation to the City Satker for payment of subsidies on
the basis of these checks.

7.3 Issuance of No Objection to Expansion Plans

The OBA Auditor will review proposed expansion schemes and check that PDAM’s plans are
allowable under the Project, that the unit rates are reasonable, and that funds are available in
the Project to finance the proposed investments. If all these conditions are met the OBA Audi-
tor will issue a no objection to PDAM’s plans on behalf of Project Manager. This no objection
is a prerequisite for expansions to be eligible for subsidy payments at a later date. Details of
the method of calculating subsidies in expansion areas are given in Error! Reference source
not found..

8 Deliverables
The OBA Auditor shall provide the following outputs in English and Bahasa Indonesia:

‰ Preliminary Report includes the work plan in 3 years that is made in detail in
accordance with field conditions.
‰ Six-monthly performance monitoring reports (PMR) covering inter alia the rel-
evant indicators and other items mentioned in Section 7.1. The report should in-
clude adequate quantitative data and qualitative analysis to enable Project
Manager to carry out its oversight role under the Project. The first PMR shall be
submitted to Project Manager and GC six months after signing of the consultancy
contract with the OBA Auditor.
‰ Payment recommendation based on the checks outlined in Section 7.2. Each
payment recommendation shall be made within two weeks of receipt by the OBA
Auditor of each set of relevant, complete and final paperwork from Project
Manager.
‰ Supporting Reports made by OBA auditor to support the decision of fund
payments that include the technical evaluation and financial feasibility in more
detail.
‰ No objection to six monthly rolling investment plans submitted by PDAM to
Project Manager and GC. The no objection will be issued within two weeks of
receipt by the OBA Auditor of each rolling investment plan. The first no objection
is likely to be required shortly after signing of the consultancy contract.
‰ Final Report on each end of the project implementation, OBA auditor must make
a final report that contains the implementation of activities in the current year.
9 Required Expertise and Level of Effort
The OBA Auditor’s team shall possess the following skills and experience:

‰ senior expertise in financial accounting and auditing with strong experience in the
projects financed by the World Bank;
‰ senior expertise in water supply engineering with strong experience in feasibility
studies and water distribution;
‰ social expertise with experience in customer surveys;
‰ good reporting skills; and
‰ proven ability to work as a team.

10 Schedule
The Project is expected to start during the first quarter of 2009. The duration will depend on
PDAM who can decide when and where service connections will be provided under the OBA
funding. It is anticipated that the Project will be implemented in about three years.

11 Inputs

The final Terms of Reference will form part of a Request for Proposals in which the bidding
process will be described. The OBA Auditor is free to organize the team as they see fit to
meet the Project objectives and tasks.

12 Additional Information
Further information on this Project is available in the Commitment Paper. This Terms of
Reference should be read in conjunction with the following Annexes included in the Project
Management Implementation Manual:

Error! Reference source not found. Specifications of Connections

Error! Reference source not found. Quality Assurance of Connections and Schemes
Error! Reference source not found. Calculation of expansion subsidies
Error! Reference source not found. Environmental and Social Guidelines