INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA1234 Public Disclosure Copy Date ISDS Prepared/Updated: 05-Feb-2013 Date ISDS Approved/Disclosed: 05-Feb-2013 I. BASIC INFORMATION 1. Basic Project Data Country: South Sudan Project ID: P127079 Project Name: Local Governance and Service Delivery Program (P127079) Task Team Zara Inga Sarzin Leader: Estimated 10-Dec-2012 Estimated 28-Mar-2013 Appraisal Date: Board Date: Managing Unit: AFTU1 Lending Specific Investment Loan Instrument: Sector: Sub-national government administration (60%), Rural and Inter-Urban Roads and Highways (10%), Health (10%), General education sector (10%), General water, sanitation and flood protection sector (10%) Theme: Participation and civic engagement (25%), Municipal governance and institution building (25%), Conflict prevention and post-conflict reconstruction (25%), Decentralization (25%) Financing (In USD Million) Public Disclosure Copy Financing Source Amount BORROWER/RECIPIENT 0.00 International Development Association (IDA) 50.00 DENMARK, Govt. of 13.50 NETHERLANDS, Govt. of THE (Except for MOFA/Min of Dev 25.00 NORWAY, Gov. of (except for Ministry of Foreign Affairs) 10.00 Total 98.50 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Objectives To improve local governance and service delivery in participating counties in South Sudan. 3. Project Description Page 1 of 11 The proposed Local Governance and Service Delivery Program (LGSD) will support a simple ‘Local Development Investment Cycle’ for the planning, implementation and oversight of small-scale public infrastructure subprojects corresponding to community priorities. Public Disclosure Copy Key elements of this cycle include: (a) a campaign to disseminate information about the program; (b) a simple social and conflict mapping in participating payams; (c) establishment or validation of representative and inclusive Boma Development Committees (BDCs) and Payam Development Committees (PDCs), and the orientation of PDC members and Payam Administrators to their roles and responsibilities for the planning, implementation and oversight of local development activities; (d) a facilitated and inclusive local planning process in each participating payam involving citizens and local government representatives to define local development priorities (Payam Action Plan) and to identify eligible investment subprojects; (e) a simple technical appraisal of subprojects including environmental and social safeguards screening and the preparation of subproject specifications and budgets; (f) preparation of County Development Plans and County Annual Budgets which incorporate Payam Action Plans; (g) disbursement of the Payam Development Grant (PDG) to counties and the procurement of contractors, or the delegation of non-procurement activities to communities, for the implementation of subprojects; (h) supervision of subproject implementation by county authorities and communities, reporting by counties on physical and financial progress and the disclosure of this information to communities and civil society organizations; (i) handover of projects to communities; (j) an annual Project Financial Audit and County Performance Audit and disclosure of audit results; and (k) an independent feedback and grievance redress system. The project will support this process through four inter-related components: Component 1: Block Grants to Counties for Payam Development (US$30 million). The objective of this component is to incentivize citizen engagement and county capacity development by providing grants through the intergovernmental fiscal transfer system to finance community-driven public infrastructure investments. Therefore the project will support a new Payam Development Grant Public Disclosure Copy (PDG), which will complement the existing County Development Grant (CDG), which is funded by the Government of the Republic of South Sudan (GRSS) and focuses on county government prioritized infrastructure investment. The PDG will provide dedicated resources within county budgets that respond to payam level priorities for small infrastructure investments. Counties will be the formal budgeting, procurement and accounting authority for the PDG, however PDG subprojects will be selected and overseen by PDCs based on an inclusive participatory planning process that will be supported under Component 2. PDG subprojects will be drawn from an indicative investment menu, that includes mainly public goods such as social and economic infrastructure, and may also include ‘club goods’ benefiting local associations where justified. County governments will be responsible for implementing and reporting on PDG financed subprojects, and will be supported to do so under Component 3. Counties may employ one of two modalities for subproject execution: conventional public sector investment management or community execution. Compliance with project rules and procedures will be assessed annually, through a simple County Performance Audit supported under Component 4, which will determine eligibility for the PDG in subsequent years. Component 2: Community engagement (US$25.4 million including contingencies of US$3.4 million). The objective of this component is to facilitate and strengthen the engagement of communities in the planning, implementation and oversight of local development activities, with a particular focus on vulnerable social groups (including women, youth, disabled, displaced, returnees and minority ethnic groups) and their access to social and economic infrastructure. Activities Page 2 of 11 supported under this component will include: (a) a carefully designed communication campaign to disseminate the key features of the project and the processes to ensure citizen voice and oversight as well as government accountability; (b) a social and conflict analysis to map the social, ethnic and Public Disclosure Copy demographic composition of bomas and payams, leadership structures and inter as well as intra- community tensions; (c) a facilitated inclusive process to establish or validate representative BDCs and PDCs consistent with the government’s Participatory Planning and Budgeting Guide for Local Governments in Southern Sudan; (d) a facilitated planning process involving BDCs, PDCs and government representatives to identify priority infrastructure investments for financing under the annual grant envelope, and to determine the selection and phasing of subprojects for subsequent years; (e) the participation of communities in the management and oversight of local public infrastructure investments specifically but not limited to a Subproject Supervision Team for county executed subprojects and a Subproject Management Team for community executed subprojects, to ensure that they are in accordance with agreed plans, that infrastructure and service delivery meet established standards, and that access to benefits corresponds to agreed development plans; and (f) a feedback and grievance mechanism established to provide multiple channels and modalities accessible to community members especially those from vulnerable groups, and to ensure the integrity and responsiveness of decision-making and resource management by PDCs, Facilitating Partners (FPs), and county and project staff. Through this facilitated local planning and prioritization process, communities will take into consideration: available resources and service deficits at the boma and payam levels; the particular needs of women, youth, displaced and vulnerable groups; the drivers and manifestations of local conflict; and the potential for subprojects to promote greater equity or mitigate potential conflict. The payam planning process and resulting Payam Action Plan will be integrated into the County Development Plan, which in turn would provide the framework for activities by state government and by non-governmental actors and other donor agencies operating in a particular county so that their activities support the implementation of priority initiatives at county and payam levels. LGSD will contract a Coordinating Agency (CA) at national level that will be responsible for Public Disclosure Copy ensuring harmonization of the community engagement approach across states, capacity building of FP field staff, oversight of the implementation process, quality assurance, and troubleshooting. NGOs and similar organizations will be contracted as FPs in each state to implement community engagement activities. Component 3: Institutional Strengthening (US$22.0 million including contingencies of US$3.00 million). The objective of this component is to increase the capacity of county governments to fulfill the roles and functions required to effectively implement the Local Development Investment Cycle. This component thus operates in conjunction with the provision of PDG resources in Component 1, and community engagement activities in Component 2. Institutional strengthening of county governments, and of state governments in their roles to support and supervise them, will contribute to improving local governance and thus “building the state from below.� Training will prioritize PDG recipient counties, although within resource constraints staff from other counties may be eligible to participate. Priority areas for LGSD institutional strengthening include those capacities supporting a responsive, effective and transparent local development investment cycle, focusing on the following dimensions: (a) participatory local development planning and budgeting; (b) financial management; (c) procurement; (d) technical (engineering) aspects of local infrastructure planning and implementation; (e) monitoring and reporting; (f) environmental and social safeguards management; (g) social accountability; and (h) communication and information dissemination. Page 3 of 11 The program will employ a ‘learning by doing’ approach through which the provision of short-term, practical training will be linked to on-the-job technical guidance. State level ‘capacity building platforms,’ linked to State Ministries of Local Government (SMoLGs), will be reinforced by Public Disclosure Copy technical assistance based in state capitals. Financial and logistical support for training and follow-up field visits by technical assistance (TA) providers and state ministry staff will be provided by Project Coordination and Support Offices (PCSO) at state level. Institutional strengthening may also include job-related equipment for county offices to enable county staff to effectively undertake the methodologies promoted by the project. As prioritized by government, public sector training and capacity development will include appropriate content in such cross-cutting themes as: transparency and accountability for good local governance; gender equity; conflict prevention and mitigation; and HIV/AIDS awareness and prevention. Governance related capacity development will employ a broader approach, involving county staff, civil society including community and traditional structures, and local representative bodies such as County Legislative Councils (where they have been installed) and/or County Development Committees. Implementation of governance capacity strengthening financed by the project will be undertaken in partnership with the CA and FPs contracted under Component 2, along with specialized nongovernmental and civil society organizations with expertise relevant to improving communication and accountability between governing authorities and citizens. Component 4: Project Management Support (US$21.1 million including contingencies of US$2.5 million and PPA refinancing of US$2.6 million). This component will support: (a) the management of the project, including technical, financial, procurement, social and environment safeguards, monitoring and evaluation; (b) spot checks and Annual Performance Audits of county grant management and individual subprojects as well as annual Project Financial Audits; (c) implementation of a grant monitoring system, project monitoring framework and system as well as project evaluations based on data collection at initiation, mid-term and completion; and (d) implementation, in collaboration with the CA, of a feedback and grievance mechanism related to all project supported activities. Recognizing that various elements of the project (grant allocation and access, planning and budgeting, procurement, institutional strengthening, and the application of Public Disclosure Copy safeguards, social accountability and communication/information dissemination) could elicit feedback from participants or become a focus for local disputes, the feedback and grievance mechanism will be integrated into the design of each component, and described fully in the Operations Manual. The component will finance the staffing of a dedicated Project Management Unit (PMU) at central level and state PCSOs linked to SMoLGs, and will provide necessary equipment and operational costs to finance their operating budgets. The PMU, supported by the PCSOs, will implement and manage a Project Monitoring System to collect and present data at county, state and national levels regarding project activities, outputs, and outcomes. Additional evaluation studies as agreed between GRSS and the Bank will also be commissioned and managed by the PMU. The PMU will also contract for annual performance audits of county management of the PDG and audits of project accounts which meet IDA fiduciary standards. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) LGSD will gradually be extended to cover 40 of South Sudan’s 79 county governments with all components during the five years of its initial phase. These counties, selected to balance minimum conditions for project implementation with concerns for geographical and social equity, will be distributed across a gradually increasing number of states; beginning with four during the first year Page 4 of 11 and covering all ten states by year three. Beyond the targeted focus of community engagement facilitation and the project-financed PDG, subject to resource availability, staff from counties not yet receiving the PDG may participate in basic institutional strengthening activities relevant to the Public Disclosure Copy planning and management of the government-funded CDG. Eight counties in four states are beginning the community engagement and planning process before IDA funds become available under a SIDA-financed Fast Track Initiative (FTI) which will allow accelerated PDG disbursement and visible project impacts during the first year of implementation, as well as the field-testing and refinement of the community engagement methodology. Additional counties will be selected annually in each participating state, based on criteria including: degree of coverage in their respective state (i.e. population), accessibility and security status, similar ongoing assistance from other donor- financed programs, and basic administrative capacity. Juba City Council and other emerging urban local governments are excluded from the initial project coverage. 5. Environmental and Social Safeguards Specialists Varalakshmi Vemuru (AFTCS) Bedilu Amare Reta (AFTN3) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes Subprojects under Component 1 are likely to BP 4.01 generate both positive and potentially adverse impacts on the environment. However, given the anticipated small scale of subproject interventions, the negative environmental impacts are likely to be localized, temporary, and easily mitigated through sensible construction management techniques, and diligent management practices. To ensure compliance with OP 4.01, a draft Environmental and Social Public Disclosure Copy Management Framework (ESMF) has been prepared and disclosed (to be finalized and disclosed before project effectiveness). Natural Habitats OP/BP 4.04 No The project will not affect natural habitats. Forests OP/BP 4.36 No The project does not involve forest management or reforestation/afforestation activities on a large scale. Pest Management OP 4.09 No The project does not involve the use of pesticides. Physical Cultural Resources OP/ No Any project activity that would affect physical BP 4.11 cultural resources (graves, sites of religious/ spiritual significance, known or unknown sites of cultural significance, etc.) will be excluded from the project. The ESMF provides a clear procedure for identification, protection and treatment of cultural resources and grave yards discovered. Indigenous Peoples OP/BP 4.10 Yes The majority of people in the project area trigger OP/BP 4.10. Per the requirements of OP/BP 4.10, Page 5 of 11 when Indigenous Peoples are the sole or the overwhelming majority of direct project beneficiaries, the elements of an Indigenous Public Disclosure Copy Peoples Plan (IPP) should be included in the overall project design; a separate IPP is not required. Involuntary Resettlement OP/BP No Subprojects requiring land acquisition under 4.12 eminent domain will not be financed. Requirements for voluntary community donations and use of available government land will be included in the ESMF and Operations Manual. Safety of Dams OP/BP 4.37 No N/A Projects on International Yes The project triggers OP7.50 on Projects on Waterways OP/BP 7.50 International Waterways since subprojects under Component 1 may include the rehabilitation or drilling of boreholes. New boreholes to be drilled will be shallow in depth, will install non- motorized hand pumps and the amount of water to be extracted will be negligible. Under paragraph 7(a) of OP7.50 an exception was sought to the requirement that other riparian countries be notified of the proposed project since the subprojects will relate to ongoing water schemes and will not adversely change the quality or quantity of water flows to the other riparians. Approval of the exception to riparian notification Public Disclosure Copy was obtained from the African Region Vice President on January 29, 2013. Projects in Disputed Areas OP/BP No N/A 7.60 II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts: The proposed project is categorized under environmental category B-Partial Assessment and triggers the Bank safeguard policies OP/BP 4.01 Environmental Assessment, OP/BP 4.10 Indigenous Peoples and OP/BP 7.50 Projects on International Waterways. Unlike traditional investment operations, the actual investment composition under the Payam Development Grant cannot be determined a priori since the choice of investment subprojects will result from a participatory local planning process and the selection of subprojects from an indicative investment menu of subprojects is as follows: • Water - Construction or repair of (non-motorized) hand-pumps, tanks, dug wells, Page 6 of 11 boreholes and haffirs. Boreholes will be improvements or changes to existing water schemes. • Sanitation - Provision or repair of latrines for public use or in primary health care or education facilities Public Disclosure Copy • Storm Water - repair of flood protection infrastructure (drainage / guttering / dykes) • Roads - Rehabilitation of local roads (using labor based methods only); construction or rehabilitation of foot paths; culverts and bridges • Health - Construction, repair or extension of existing PHCC or PHCU where health worker is already present, Purchase of furniture or equipment for existing PHCC or PHCU • Education - Construction, repair or extension of existing primary schools where teacher is already present, Purchase of furniture or equipment for existing primary schools • Markets - Construction or repair of public market places • Livestock - Construction or repair of livestock dips • Irrigation - Repair of small scale community irrigation schemes Given the participatory approach to the selection of subprojects and their small-scale nature, there will be no large scale, significant and irreversible adverse impacts. However, there is the potential for subproject interventions to generate negative environmental and social impacts. The negative environmental impacts, such as change in the landscape (loss of vegetation), noise nuisance, air pollution due to dust formation, safety hazard from construction’ activities, inappropriate disposal of excavated materials and construction debris, etc. are likely to be limited, mostly reversible, localized, temporary, and easily mitigated through sensible construction management techniques and diligent environmental management practices. The project will not take place in or near natural habitats. In order to offset any potential social and environmental impacts anticipated due to the implementation of subprojects financed under the project, GRSS has prepared a draft ESMF, which will be disclosed in country and the Bank’s InfoShop before negotiations and a final version by project effectiveness. The ESMF establishes a mechanism to determine and assess the potential environmental and social impacts of subproject investments under the proposed program, and sets Public Disclosure Copy out appropriate mitigation, monitoring and institutional measures to be taken during implementation and operation of the subprojects to avoid and/or minimize the expected environmental impacts to an acceptable levels. The ESMF will be used as an instrument for the program and includes a basic environmental and social screening (a simple form/checklist) to be applied during the identification of subprojects by PDCs. Any activities that require land acquisition will be on a ‘negative list’ for implementation. During the appraisal, the Bank’s safeguards team will work closely with government to confirm the technical assistance and capacity building required at central, state and local government levels to ensure effective implementation of the ESMF. ESIAs and/or ESMPs will be prepared as and when necessary during project implementation. The presence of physical cultural resources (e.g. graveyards, sites of religious/ritual significance, known or unknown local structures or sites of historic or cultural importance) within the project area may not be known at this stage. Some proposed subproject activities may possibly have an impact on previously unidentified physical cultural resources. Therefore, any subproject that would impact on physical cultural resources as defined under OP/BP 4.11 Physical Cultural Resources would be on a ‘negative list’ and be excluded from PDG financing. The highly participatory nature of the project coupled with the screening procedures outlined in the ESMF will ensure that communities are able to identify the impact of any proposed subproject on cultural property as defined by the policy, and if so, a different location agreed to by the community should Page 7 of 11 be identified, or the subproject should be excluded. Additionally, the ESMF includes guidance on preparing chance find procedures for contractors in bidding documents for any construction activities supported by the project. Public Disclosure Copy In the context of South Sudan, where land is predominantly held under customary land tenure arrangements and where population pressure on land is very low (13 persons per sq.km), access to land for new construction of facilities will be obtained either: (a) through documented voluntary community donations of land arrived at through local consultation; or (b) by using available government land that is free of encroachments, squatters or other encumbrances, and has been authorized for project use by the authorities. Therefore any subproject requiring land acquisition under eminent domain, which would trigger OP 4.12 on Involuntary Resettlement, would be on a ‘negative list’ for project implementation. The Indigenous Peoples policy (OP/BP 4.10) has been triggered. Analysis by Bank and other experts confirms that the majority or all people in the project area meet the requirements of the policy. Per the requirements of OP/BP 4.10, when Indigenous Peoples are the sole or the overwhelming majority of direct project beneficiaries, the elements of an Indigenous Peoples Plan (IPP) should be included in the overall project design; a separate IPP is not required. The centerpiece of the proposed project is a local participatory planning process that aims at including all vulnerable sub-groups in consultations to agree on the subprojects to be undertaken with the grant. The project has a particular emphasis on identifying and reaching the most vulnerable social groups including ethnic/tribal/kinship minority groups, women, youth, displaced, and returnees , ensuring their representation in community organizations and due consideration to their needs and priorities. This process complies with the basic requirement of OP 4.10 of a free, prior, and informed consultation leading to broad community support for the project. Consequently, the design of the proposed program supports the intentions and outcomes of the policy by: (a) including as an early activity in the participatory county planning process of social, ethnic and demographic mapping Public Disclosure Copy with identification of particularly vulnerable sub- groups and the nature of their vulnerabilities, so that measures can be taken to ensure their inclusion in the planning process; (b) applying the principle of “equitable access to benefits� across all these vulnerable sub-groups within the county; (c) monitoring delivery of equitable benefits across social and ethnic groups with particular emphasis on the vulnerable (e.g. by accountability arrangements that disclose information on budgets and spending and that involve communities in monitoring); and (d) establishing a simple feedback and grievance mechanism that is accessible and responsive to the different groups. The project triggers OP 7.50 on Projects on International Waterways since subprojects under Component 1 may include the rehabilitation or drilling of boreholes. New boreholes to be drilled will be shallow in depth, will install non-motorized hand pumps and the amount of water to be extracted will be negligible. Under paragraph 7(a) of OP7.50 an exception has been sought to the requirement that other riparian countries be notified of the proposed project since the subprojects will relate to ongoing water schemes and will not adversely change the quality or quantity of water flows to the other riparians. Approval of the exception to riparian notification was obtained from the African Region Vice President on January 29, 2013. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: Page 8 of 11 No long term risks or impacts are anticipated. The project has the potential to effect positive impacts on the quality of life of participating communities with increased access to social and economic infrastructure, improved service delivery and improved local governance. Public Disclosure Copy 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. No project alternatives are required for this operation. 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. In order to offset/minimize the anticipated environmental and social impacts due to the implementation of the proposed project: (a) GRSS has prepared a draft ESMF with guidelines and procedures to be followed by counties, communities and contractors in the implementation of subproject activities; (b) based on the guidelines set out in the ESMF, states/counties will conduct simple ESIAs for specific activities and sensitive construction sites and develop appropriate ESMPs as required; and (c) all safeguard instruments (ESMF, ESIAs/ESMPs) will be consulted upon and disclosed to the public in accordance with Bank policies before disbursement will be authorized. The existing capacity of the implementing institutions to implement the ESMF and other environmental and social safeguard instruments is very limited. Therefore the project will provide capacity building and technical support to Ministry of Finance and Economic Planning (MoFEP), the Local Government Board (LGB), PMU and PCSOs, CA and FPs, SMoLGs, SMoFs and county level institutions in environmental and social safeguards management and responsibilities for implementing and monitoring implementation progress. Capacity development targets institutions that are responsible for the implementation and monitoring of environmental and social safeguards to increase their effectiveness. A senior safeguards specialist and safeguards officer at the national PMU will: oversee safeguards Public Disclosure Copy implementation in LGSD; liaise with national and state environmental ministries on a regular basis; ensure compliance with the ESMF and other safeguard instruments; build capacity and troubleshoot for the state and county level safeguards focal points; prepare and implement ESMPs and other instruments as required; and raise awareness and build capacity of various stakeholders at state, county and payam levels. The project will also create awareness among communities and relevant stakeholders on sound environmental management practices and provide training and support to implement the national ESSAF, ESMF and other safeguard instruments. The project has proposed the assignment of safeguard focal persons for each state ministry/directorate of environment and the county administration to provide technical support to the county, payam and boma levels and to regularly follow up and monitor the implementation of subprojects to guarantee compliance with the ESMF, ESSAF and other safeguards instruments. Before the commencement of the project, intensive training on the implementation of the ESMF and Bank safeguard policies will be provided to state and county level safeguard focal persons to enable them to effectively act on the supervision and monitoring of the implementation of the ESMF and Bank policies. The safeguard focal person at state level will also liaise with MoFEP/LGB and the Bank regarding environmental and social safeguard issues, and would play a lead role in increasing the level of Page 9 of 11 awareness on environmental management at county, payam and boma levels, conducting regular supervision and preparing progress reports. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure Public Disclosure Copy on safeguard policies, with an emphasis on potentially affected people. Key stakeholders include MoFEP, LGB, SMoLGs, SMoFs, relevant line ministries at national and state levels, local communities and CSOs in target counties, CAs and FPs, and development partners. Consultations were undertaken to facilitate stakeholder involvement and awareness during preparation and continue through project implementation to ensure that the information required for decision making is available to all interested parties. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 07-Dec-2012 Date of submission to InfoShop 14-Jan-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure South Sudan 14-Jan-2013 Comments: Indigenous Peoples Development Plan/Framework Date of receipt by the Bank 07-Dec-2012 Date of submission to InfoShop 14-Jan-2013 "In country" Disclosure South Sudan 22-Jan-2013 Comments: Public Disclosure Copy If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP/BP 4.10 - Indigenous Peoples If the whole project is designed to benefit IP, has the design Yes [ ] No [ ] NA [ ] been reviewed and approved by the Regional Social Development Unit or Sector Manager? OP 7.50 - Projects on International Waterways Has the RVP approved such an exception? Yes [ ] No [ ] NA [ ] The World Bank Policy on Disclosure of Information Page 10 of 11 Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Public Disclosure Copy Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] NA [ ] place in a form and language that are understandable and accessible to project-affected groups and local NGOs? All Safeguard Policies Have satisfactory calendar, budget and clear institutional Yes [ ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader: Zara Inga Sarzin Approved By Regional Safeguards Name: Alexandra C. Bezeredi (RSA) Date: 05-Feb-2013 Coordinator: Sector Manager: Name: Rosemary Mukami Kariuki (SM) Date: 04-Feb-2013 Public Disclosure Copy Page 11 of 11