Document of The World Bank FOR OFFICIAL USE ONLY Report No: RES16149 RESTRUCTURING PAPER ON A PROPOSED PROJECT RESTRUCTURING OF COAL-FIRED GENERATION REHABILITATION PROJECT (LOAN 7687-IN AND GRANT TF094676-IN) June 18, 2009 TO THE REPUBLIC OF INDIA September 24, 2014 Energy and Extractives Global Practice India Country Management Unit South Asia Region This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. CURRENCY EQUIVALENTS (Exchange Rate Effective April 23, 2014) Currency Unit = Indian Rupee INR 61.02 = US$1 US$0.0164 = INR 1 FISCAL YEAR April 1 – March 31 ABBREVIATIONS AND ACRONYMS BTPS Bandel Thermal Power Station CEA Central Electricity Authority DEA Department of Economic Affairs DPR Detailed Project Report EE R&M Energy Efficient Renovation and Modernization FY Fiscal Year GEO Global Environment Objective GEF Global Environment Facility GHG Green House Gas GoI Government of India HPGCL Haryana Power Generation Corporation Limited IBRD International Bank for Reconstruction and Development INR Indian Rupee KPI Key Performance Indicator KTPS Koradi Thermal Power Station kWh Kilo Watt Hour Mahagenco Maharashtra State Power Generation Company Limited MW Mega Watts O&M Operations and Maintenance PAD Project Appraisal Document PDO Project Development Objective PTPS Panipat Thermal Power Station R&M Renovation and Modernization TA Technical Assistance TPS Thermal Power Station US$ United States Dollars WBPDCL West Bengal Power Development Corporation Limited Regional Vice President: Philippe H. Le Houerou Country Director: Onno Ruhl Sector Manager: Julia Bucknall Task Team Leader: Ashok Sarkar Co-Task Team Leader: Surbhi Goyal 2 INDIA COAL-FIRED GENERATION REHABILITATION CONTENTS Page A. SUMMARY ........................................................................................................................... 4 B. PROJECT STATUS ............................................................................................................. 5 C. PROPOSED CHANGES ...................................................................................................... 7 D. APPRAISAL SUMMARY ................................................................................................... 9 ANNEX 1: RESULTS FRAMEWORK AND MONITORING .............................................. 11 3 COAL-FIRED GENERATION REHABILITATION PROJECT RESTRUCTURING PAPER A. SUMMARY This restructuring is based on a request received from the Department of Economic Affairs (DEA), Ministry of Finance, Government of India (GoI) through its letters dated December 19, 2012 and September 12, 20131. The following changes are being proposed under the project restructuring: 1. Reallocation of Funds: Reallocation of INR 133.25 crore (equivalent to US$21.84 million2) of IBRD and GEF funds on pro-rata basis as loan and grant respectively, surrendered by Haryana Power Generation Corporation Limited (HPGCL), to West Bengal Power Development Corporation Limited (WBPDCL), to meet the funding gap in execution of Energy Efficient Renovation and Modernization (EE R&M) of 210 MW Unit-5 of Bandel Thermal Power Station (TPS) of WBPDCL. 2. Project Closing Date: Extension of the project closing date from November 30, 2014 to November 29, 2016 which is required to complete the EE R&M works in the pilot units of the Bandel TPS (of WBPDCL) and Koradi TPS (of Mahagenco). 3. Key Performance Indicators (KPI): Since HPGCL is no longer recipient of the investment funds, KPIs linked to only HPGCL are being dropped. Other KPIs that presented consolidated targets for all the three state utilities at the time of appraisal are also being revised. 4. Eligible Expenditure Category: With ‘goods’ as the only category for eligible expenditure, the utilities will not be able to utilize the available funds with total percentage of expenditure to be financed by IBRD and GEF. Hence, to enable utilities to disburse the funds up to 74% of project costs, it is proposed to modify the ‘eligible expenditure category’ from only ‘goods’ to ‘works and goods including installation and other services’. With respect to IBRD funds, the first restructuring that was completed on June 11, 2014, a partial cancelation of IBRD funds (of US$43.84 million) that were surrendered by HPGCL was carried out. The balance IBRD funds surrendered by HPGCL are now being re-allocated to WBPDCL as mentioned above. With respect to GEF grant, only US$3.83 million of total US$13.67 million GEF funds released from HPGCL3 are being re-allocated to WBPDCL under this restructuring. After this re- allocation, there will still be a balance of US$9.84 million GEF funds. The decision regarding utilization of these balance funds will be taken later once the GoI decides on the possible use of the same, which could include funding the financing gap of the existing two TPS units or could be re-programmed to be used for linked activities meeting the same Project Development Objective (PDO). The table below provides the details about reallocation of the funds relinquished by HPGCL. Table 1: Fund Details of HPGCL S Head Amount (in US$ Million) No IBRD GEF 1 Since August 2012, attempts were made by the World Bank to find substitute for these pilots, in coordination with DEA and MOP, but suitable alternatives could not be found until end of 2013. At the Tripartite Portfolio Review Meeting (TPRM) held on January 30, 2014 at the Department of Economic Affairs (DEA), Ministry of Finance in New Delhi a decision was taken to partially cancel the IBRD funds allocated to HPGCL. This was completed in June 2014. 2 IBRD: US$18.01 million and GEF: US$3.83 million 3 HPGCL indicated to retain US$1.13 million of US$14.80 million of total GEF funds (at appraisal) to carry out studies on assessment and strengthening of operations and maintenance (O&M) practices (under TA component of the project). Hence, GEF funds of US$13 million from investment component and US$0.67 million from TA component have been relinquished by HPGCL. 4 Investment TA 1. Allocation to HPGCL as per PAD 61.85 13.00 1.80 2. Amount Retained by HPGCL 0.00 0.00 1.13 3. Amount Relinquished (1-2) 61.85 13.00 0.67 4. Amount Cancelled (in first restructuring, June 43.84 0.00 0.00 2014) 5. Allocation of Relinquished funds to WBPDCL 18.01 3.83 0.00 (through this/second restructuring) 6. Balance Remaining for Future Decision (3-4-5) 0.00 9.17 0.67 The proposed restructuring has no impact on PDO that remains relevant and are being achieved efficiently. The restructuring does not trigger any new safeguard policies and does not change the safeguard categorization of the project, which remains ‘B’. B. PROJECT STATUS Background: Coal-Fired Generation Rehabilitation Project for US$180 million of IBRD loan (Loan No. 7687-IN) and US$45.4 million of GEF grant (Grant No. TF094676-IN) was approved by the Bank’s Board of Executive Directors on June 18, 2009 and became effective on March 19, 2010. While Government of India (GoI) is the borrower for this loan, the four responsible agencies for implementing the project are: West Bengal Power Development Corporation Limited (WBPDCL) in the State of West Bengal, Haryana Power Generation Corporation Limited (HPGCL) in the State of Haryana, Maharashtra State Power Generation Company Limited (Mahagenco) in the State of Maharashtra and Central Electricity Authority (CEA), Ministry of Power, GoI. Under the first restructuring completed on June 11, 2014, partial cancelation of IBRD funds (of US$43.84 million) that were surrendered by HPGCL was carried out. This resulted in reducing the IBRD funds available to the project to US$136.16 million. Project Development Objective: PDO for this project is to “Improve Energy Efficiency (EE) of selected coal-fired power generation units through renovation and modernization (R&M) and improved O&M”. The PDO remains unchanged. The PDO rating is moderately satisfactory (MS). Global Environment Objective: GEO for this project is ‘A significant co-benefit of improving EE of the selected coal fired power generation units is the reduction of GHG emissions per kWh of electricity generated’. The GEO remains unchanged. Project Components: The project has two components: • Component 1- EE R&M Pilots (US$174.06 million4): This component focuses on R&M of old coal-fired power generation capacity to demonstrate energy efficient rehabilitation approaches and had following sub-components: o Sub-Component 1: Unit-5, Bandel TPS (BTPS), West Bengal (210 MW) o Sub-Component 2: Unit-6, Koradi TPS (KTPS), Maharashtra (210 MW) o Sub-Component 3: Units-3&4, Panipat TPS (PTPS), Haryana (2x110 MW each) • Component 2 – Technical Assistance (TA) (US$7.5 million): The TA component of the project is aimed at providing support in implementation of EE R&M pilots, developing a pipeline of EE R&M interventions, addressing barriers to EE R&M projects and 4 Original allocation (as per PAD): US$217.9 million. After the first restructuring (June 2014, cancelation of IBRD $43.84 million), of revised allocation of US$174.06 million, IBRD funds account for US$136.16 million (reduced from US$180 million) and GEF funds account for US$37.90 million (no change since appraisal). 5 strengthening institutional capacities of implementing agencies. It has following sub- components: o Sub-Component 1: Support for Design of EE R&M o Sub-Component 2: Support for Implementation of Pilot EE R&M o Sub-Component 3: Support for Addressing Barriers to EE R&M Projects o Sub-Component 4: Support for Strengthening Institutional Capacities of Utilities Table 2: Project Components after first Restructuring (US$ Million) S Financing Plan Component No GEF IBRD Total 1. EE R&M Pilots 37.9 136.2 174.0 1.1 Unit-5, BTPS 12.4 59.0 71.4 1.2 Unit-6, KTPS 12.4 59.0 71.4 5 1.3 Units-3&4, PTPS 13.0 18.2 31.2 2. Technical Assistance 7.5 0.0 7.5 2.1 Support for Design of Pipeline of EE R&M 2.5 0.0 2.5 Interventions (a) Units 3&4 Panipat (Haryana) 0.5 0.0 0.5 (b) Unit 1&2 Chandrapur (Maharashtra) 1.0 0.0 1.0 (c) Unit 2 Bhusawal (Maharashtra) 0.5 0.0 0.5 (d) Unit 3 Parli (Maharashtra) 0.5 0.0 0.5 2.2 Support for Implementation of Pilot EE R&M 1.5 0.0 1.5 Interventions (a) Unit 5 Bandel (West Bengal) 0.5 0.0 0.5 (b) Unit 6 Koradi (Maharashtra) 0.5 0.0 0.5 (c) Units 3&4 Panipat (Haryana) 0.5 0.0 0.5 2.3 Support for Addressing Barriers to EE R&M Projects 1.1 0.0 1.1 (a) Assistance to CEA in development of 0.75 0.0 0.75 R&M Program through about 3~4 studies. (Areas include: (i) Consultancy Support for Implementation of TA sub-component; (ii) Reduction of barriers to R&M in India; (iii) Developing Markets for Implementation of R&M in India; and (iv) Review of Experience from Pilot R&M Interventions) (CEA) (b) Institutional Capacity Strengthening at CEA 0.35 0.0 0.35 2.4 Support for Strengthening Institutional Capacity of 2.4 0.0 2.4 Implementing Agencies (a) Institutional capacity (including O&M 0.8 0.0 0.8 practices) strengthening at MSPGCL (b) Institutional capacity strengthening 0.8 0.0 0.8 (including O&M practices) at WBPDCL (c) Institutional capacity strengthening 0.8 0.0 0.8 (including O&M practices) at HPGCL TOTAL 45.4 136.2 181.5 Table 3: Key Project Data and Project Performance Ratings: Project Data Projects Performance Ratings Board Approval: June 18, 2009 Summary Ratings Effectiveness Date: March 19, 2010 Achievement of PDO MS 5 Original allocation was US$62 million. After partial cancelation of US$43.8 million, the amount of US$18.2 million remains. 6 Project Data Projects Performance Ratings Closing Date: November 30, 2014 Implementation Progress MS Mid-term Review Date: July 2012 IBRD Loan Amount (Original): US$180 million IBRD Loan Amount (Revised): US$136.2 million GEF Grant Amount: US$45.4 million Amount Disbursed6: US$47.2 million (IBRD) + US$12.1 million (GEF) Ratings: HS=Highly Satisfactory; S=Satisfactory; MS= Moderately Satisfactory; MU=Moderately Unsatisfactory; U=Unsatisfactory; HU=Highly Unsatisfactory Current Status: As on July 21, 2014 around 27% GEF grant and around 35% of IBRD funds have been disbursed. The current project closing date is November 30, 2014. Following is the status update on Component 1: • Unit-5, Bandel TPS, West Bengal: All the 4 packages and 1 consultancy has been awarded. Contracts signed in 2012 and implementation is underway. After receipt of a pending environmental clearance for physical R&M works, disbursements from the World Bank and GEF have started. The expected date of commissioning of R&M assets is January 2015. • Unit-6, Koradi TPS, Maharashtra: All the 3 packages and 9 consultancies have been awarded with the main plant package awarded in May 2013 and signed in December 2013. The expected date of commissioning of R&M assets is September 2016. • Unit-3 and Unit-4, Panipat TPS, Haryana: HPGCL decided not to proceed with the R&M sub-project for Panipat TPS because HPGCL could not achieve the desired results from R&M works of its existing Unit -1 of Panipat TPS after R&M works (domestically funded). This decision was conveyed by HPGCL to DEA through their letter dated August 30, 2012. Various consultancies under component 2 are progressing well. It is envisaged to take up more activities related to dissemination of the work as well as the lessons learnt from the activities already undertaken under this component. C. PROPOSED CHANGES • Project Components: The project continues to consist of two project components, namely EE R&M Pilots and Technical Assistance. Within the first component (EE R&M Pilots) that has three sub-components, the third sub-component “Units-3&4, Panipat TPS, Haryana (2 x 110 MW each)” is being dropped. • Results/indicators (refer to Annex 1): Since sub-component 3 (Unit 3 and 4 of Panipat TPS in Haryana) under component 1 (EE R&M Pilots) is being dropped, the result matrix from PAD has been updated. Other KPIs that presented consolidated targets for all the three state utilities at the time of appraisal are also being revised. Further, given the decision by the involved state utilities to take up more units for R&M, (as agreed at the time of appraisal) only after successful commissioning and operation of the two pilot units, the results matrix is being revised. The KPI targets corresponding to ‘other plants’ is being dropped from the results matrix. Moreover, with the proposed project closing date extension by two (2) years, the matrix has been further updated as the PDO indicators are expected to be met only at the end of the project, only when the rehabilitated units become fully operational again. 6 As on July 21, 2014 7 • Safeguards: There are no changes in safeguards category and it remains at ‘B’. • Institutional arrangements: Since the additional funds are being re-allocated to Unit-5 of Bandel TPS that is already a part of the existing project, WBPDCL remains the participating state utility in the said project. Similarly, Mahagenco continues to be the project implementing agency for Unit-6 of Koradi TPS. • Financing: o Project Costs: Part of the IBRD funds relinquished by Haryana was cancelled with the first restructuring on June 11, 2014. Through this restructuring and upon request from DEA dated December 19, 2012, the balance is being reallocated to meet the funding gap Unit 5 of Bandel TPS (WBPDCL). The estimated project cost for EE R&M works of Unit 5 of Bandel TPS was US$96.9 million at appraisal. But the EE R&M works were awarded at the cost of almost 31%7 higher than the estimated cost (in US Dollar terms)8 resulting in the funding gap. The reasons for the price escalation were time gap between preparation of DPR (in year 2008) and award of the main package in February 2012, adoption of new technology and delayed finalization of contract between WBPDCL and the selected bidder. Table 4: Estimated Project Cost and IBRD-GEF Funding Components/ Project Costs and Financing (US$m.) Expected Activities Estimated IBRD + Current Funding IBRD + Commissioning at GEF (Actual) Gap11 GEF Schedule Appraisal9 Funding Funding 10 Unit-5, Bandel 96.9 71.40 125.9 21.8 93.2 January 2015 TPS, West Bengal o Financing Plan: For Unit-5 of Bandel TPS, the percentage of total funding (IBRD + GEF) remains unchanged at 74%. o Implementation schedule: EE R&M works for Unit-5, Bandel TPS and Unit-6, Koradi TPS are expected by January 2015 and September 2016, respectively. o Disbursement arrangements: Due to the delays, the disbursement schedule is updated accordingly as shown in Table 5. Table 5: Disbursements – Actual (A) and Projections (P) – In US$ Million 2009- 2010- 2011- 2012- 2013- 2014- 2015- 2016- Bank FY Total 10 (A) 11 (A) 12 (A) 13 (A) 14 (A) 15 (P) 16 (P) 17 (P) As per the original PAD (in 2009) IBRD 18.00 30.00 50.00 39.00 34.00 9.00 0.00 0.00 180.00 GEF 5.90 8.80 12.60 8.70 7.30 2.10 0.00 0.00 45.40 7 As per DEA’s letter dated December 19, 2012, there is a reference to WBPDCL letter dated November 5, 2012 where it is informed that the project cost has increased from INR 472.13 crore to INR 652.20 crore. Since total of IBRD and GEF is funding 74% of the total project cost, this translates into increase in IBRD and GEF contribution from INR 349.38 crore to INR 482.62 crore. 8 This variation is about 38% in Rupee terms due to exchange rate fluctuation observed during this period. 9 As per ‘Project Costs’, Annex 5, PAD 10 As per ‘Project Costs’, Annex 5, PAD 11 Funding requirement is 74% of the estimated project cost 8 2009- 2010- 2011- 2012- 2013- 2014- 2015- 2016- Bank FY Total 10 (A) 11 (A) 12 (A) 13 (A) 14 (A) 15 (P) 16 (P) 17 (P) Total 23.90 38.80 62.60 47.70 41.30 11.10 0.00 0.00 225.40 Cumulative 23.90 62.70 125.30 173.00 214.30 225.40 225.40 225.40 225.40 Revised (During this Restructuring) 12 IBRD 0.00 0.00 0.00 6.56 39.43 17.02 34.52 38.17 136.16 13 GEF 0.00 0.00 0.30 1.92 9.55 3.97 11.47 8.35 35.56 14 Total 0.00 0.00 0.30 8.48 48.98 21.00 46.00 46.52 171.72 Cumulative 0.00 0.00 0.30 8.78 57.76 78.76 124.75 171.27 o Reallocations: Funds amounting to US$21.84 million (IBRD: US$18.01 million and GEF: US$3.83 million) released after dropping of Unit 3 and 4 of Panipat TPS (HPGCL) are being reallocated to Unit 5, Bandel TPS (WBPDCL) as shown in Table 5. This re-allocation of funds is being done within Component 1 – EE R&M Pilots. Table 6: Reallocation of Funds Category of Expenditure Allocation (US$ Million) Current Remarks Current Revised IBRD GEF IBRD GEF Goods For category 1(a) of the project (U-5 of Bandel TPS) Retained 58.85 12.45 76.86 16.28 For category 1(b) of the project (U-6 of Koradi TPS) Retained 58.85 12.45 58.85 12.45 For category 1(c) of the project (U-3&4 of Panipat Being 18.01 13.00 0.00 9.17 TPS) Dropped Total 135.71 37.9015 135.71 37.90 • Procurement: Procurement of all the components is complete except for hiring of Quality Assurance Consultant by Mahagenco that is expected by August 2014 and ‘strengthening of O&M practices’ by HPGCL that will be taken up after completion of ongoing study on ‘assessment of O&M practices’. Following change is proposed with respect to procurement arrangements under the project: o Eligible Expenditure Category: With ‘goods’ as the only category for eligible expenditure, the utilities will not be able to utilize the available funds with total percentage of expenditure to be financed by IBRD and GEF. Hence, to enable utilities to disburse the funds up to 74% of project costs, it is proposed to modify the ‘eligible expenditure category’ from only ‘goods’ to ‘works and goods including installation and other services’. • Closing date: It is proposed to extend the project closing date of the project from November 30, 2014 to November 29, 2016 to enable completion of EE R&M works. Without the extension, even though the works on the pilot units will be sufficiently advanced but will not be complete. D. APPRAISAL SUMMARY Since the restructuring entails only re-allocation of available funds to existing plant which were considered under the original project design, the economic, financial, technical, safeguards and 12 This includes front end fee of US$0.45 million 13 This includes GEF funds for investment as well as for TA after excluding US$9.84 million for which decision regarding its utilization (of which allocation to investment: US$9.17 million and TA: US$0.67 million) will be taken later once the Government of India (GoI) decides on possible use of the same. 14 This includes front end fee of US$0.45 million 15 GEF allocation to investment component as per PAD 9 risk assessment done at appraisal stage still remains valid. All procurement, safeguards, financial management and corporate governance requirements would continue to apply to the restructured project. 10 ANNEX 1 Results Framework and Monitoring INDIA: COAL-FIRED GENERATION REHABILITATION Project Development Objective (PDO): To improve EE of selected coal-fired power generation units through renovation and modernization (R&M) and improved O&M Global Environment Objective (GEO): A significant co-benefit of improving EE of the selected coal fired power generation units is the reduction of GHG emissions per kWh of electricity generated Revised Project Development Objective: Not Applicable D=Dropped Cumulative Target Values Data Responsibi Core PDO Level Results C=Continue Unit of Basel Frequ Source/ lity for Indicators* N= New Measure ine 2010- 2011- 2012- 2013- 2014- 2015- 2016- ency Methodol Data R=Revised 11 (A) 12 (A) 13 (A) 14 (A) 15 (P) 16 (P) 17 (P) ogy Collection Unit-5, Bandel Thermal For Coal Power Plant, West Consumpt Bengal ion: C • Reduction in Specific Kg/kWh 0.684 - - - - 12% 12% 12% Annual Measurem WBPDCL R Coal Consumption ent at • Reduction in Specific ml/kWh 2.5 - - - - 20% 20% 20% Annual coal Oil Consumption feeder / Unit-6, Koradi Thermal Energy Power Plant, Audit on Maharashtra R&M C • Reduction in Specific Kg/kWh 0.703 - - - - - - 14% Annual Completio Mahagenco R Coal Consumption n • Reduction in Specific ml/kWh 2.27 - - - - - - 12% Annual Oil Consumption For Oil Unit-3, Panipat Thermal Consumpt Power Plant, Haryana ion: • Reduction in Specific Kg/kWh 0.825 Annual Measurem D Being Dropped ent at Oil HPGCL Coal Consumption • Reduction in Specific ml/kWh 2.4 Annual flow Oil Consumption meter / Unit-4, Panipat Thermal Energy D Being Dropped Audit on HPGCL Power Plant, Haryana, D=Dropped Cumulative Target Values Data Responsibi Core PDO Level Results C=Continue Unit of Basel Frequ Source/ lity for Indicators* N= New Measure ine 2010- 2011- 2012- 2013- 2014- 2015- 2016- ency Methodol Data R=Revised 11 (A) 12 (A) 13 (A) 14 (A) 15 (P) 16 (P) 17 (P) ogy Collection • Reduction in Specific Kg/kWh 0.825 Annual R&M Coal Consumption completio • Reduction in Specific ml/kWh 2.5 Annual n Oil Consumption GEO Indicator Reduction in CO2 emission intensity for C each of the generation % 0% - - - - 10% 10% 10% Annual R units after completion of R&M (%) Calculatio GEO Indicator n of Reduction in CO2 Emission Generation million emissions as a result of C Reduction Companies TCO2 0 - - - - 0.19 0.19 0.45 Annual energy efficient R&M R s as per and CEA (million TCO2) - in plants agreed financed format GEO Indicator Reduction in CO2 million emissions as a result of D TCO2 0 Being Dropped Annual energy efficient R&M (million TCO2) - in other plants INTERMEDIATE RESULTS Intermediate Result (Component One): Energy Efficient Renovation and Modernization implemented for select generation units Revised Intermediate Result (Component One): Not Applicable Number of contracts C No. 0 0 2 6 7 7 7 7 Annual awarded R Reports Capacity rehabilitated and Submitted Generation MW, modernized with focus on C to the Companies cumulati 0 0 0 0 0 210 210 420 Annual energy efficiency, R Bank ve financed under this 12 D=Dropped Cumulative Target Values Data Responsibi Core PDO Level Results C=Continue Unit of Basel Frequ Source/ lity for Indicators* N= New Measure ine 2010- 2011- 2012- 2013- 2014- 2015- 2016- ency Methodol Data R=Revised 11 (A) 12 (A) 13 (A) 14 (A) 15 (P) 16 (P) 17 (P) ogy Collection project Intermediate Result (Component Two): Barriers to implementation of Energy Efficient Renovation and Modernization projects reduced Revised Intermediate Result (Component Two): Not Applicable Cumulative number of Reports Units for which R&M C Submitted procurement process is No. NA 2 2 2 2 2 2 2 Annual CEA R to the initiated at the National Bank Level Cumulative number of Reports energy audit reports with C Submitted Generation No. NA 2 2 8 8 8 8 8 Annual baseline performance R to the Companies information Bank Cumulative number of R&M detailed project Reports reports (DPRs) with C Submitted Generation No. NA 2 2 2 2 6 8 8 Annual investment plans R to the Companies optimized for energy Bank efficiency Cumulative number of barrier reduction studies / Reports technical assistance C Submitted No. NA 0 0 0 2 3 4 4 Annual CEA interventions undertaken R to the by CEA under Bank Bank project. Cumulative number of Utilities in which Reports implementation of agreed C Submitted Generation No. NA 0 0 0 2 2 3 3 Annual O&M and Institutional R to the Companies Strengthening Programs is Bank completed 13