INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA15907 Public Disclosure Copy Date ISDS Prepared/Updated: 13-Jan-2016 Date ISDS Approved/Disclosed: 21-Jan-2016 I. BASIC INFORMATION 1. Basic Project Data Country: Madagascar Project ID: P151469 Project Name: Madagascar Agriculture Rural Growth and Land Management Project (P151469) Task Team Jan Joost Nijhoff,Andre Teyssier Leader(s): Estimated 05-Jan-2016 Estimated 22-Mar-2016 Appraisal Date: Board Date: Managing Unit: GFA07 Lending Investment Project Financing Instrument: Sector(s): General agriculture, fishing and forestry sector (70%), Agro-industry, marketing, and trade (30%) Theme(s): Rural services and infrastructure (40%), Land administration and management (30%), Rural policies and institutions (30%) Is this project processed under OP 8.50 (Emergency Recovery) or OP No 8.00 (Rapid Response to Crises and Emergencies)? Public Disclosure Copy Financing (In USD Million) Total Project Cost: 53.00 Total Bank Financing: 53.00 Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 0.00 International Development Association (IDA) 53.00 Total 53.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Development Objective(s) The proposed development objective is "to improve rural land tenure security and access to markets of targeted farming households in selected agricultural value chains in project areas, and to provide immediate and effective response to an eligible crisis or emergency". Page 1 of 11 3. Project Description The proposed Project has been designed to support the Government of Madagascar (GOM) in the implementation of its new national and sector development strategies, particularly the National Public Disclosure Copy Development Plan (NDP) (2015-2019) and the Agricultural Sector Policy and Program, i.e.Lettre de Politique Sectorielle Agriculture, Elevage et Pêche (LPAEP) 2015 and Programme Sectoriel Agriculture Elevage Pêche (PSAEP) 2016-2020) which have been developed within the framework of the Comprehensive Africa Agriculture Development Program (CAADP) process. The proposed project has three main components: (1) Agribusiness value chain development; (2) Land policy and land rights registration; and (3) Marketing infrastructure development. It also includes two additional components: (4) Project Coordination and Management, and a (5) Contingency Emergency Response. Component 1 will address the constraints that currently prevent value chains from further developing and expanding. This will include support for: (i) improving the enabling environment for agribusiness value chain development; (ii) knowledge and efficiency enhancing technology transfer to increase production, and enhance productivity, quality, and profitability among private value chain participants; and (iii) enhancing access to agriculture finance: Madagascar has a country-wide network of microfinance institutions that may have the potential to stimulate value chain development. Component 2 will support the current Malagasy land policy reform process to promote a land management system conducive to inclusive agricultural investment. This will include support to: (i) strengthen capacities of existing institutions in charge of land management to improve the current land information system, in particular the information exchange between the State land services and the municipal land offices; and establish or improve Local Land Tenure Status Mapping (PLOF); (ii) roll out field activities for smallholder farmers’ land rights registration and administration to Public Disclosure Copy ensure transparency, socially inclusive land use, and improved land tenure security, with particular emphasis on support for registration of land rights for women; and (iii) facilitate access to land for investors in a responsible and socially inclusive manner. Component 3 will support the development of key marketing infrastructure that has the potential to boost the development of local agribusiness opportunities in the country. This would include: (i) Rehabilitation of commercial feeder roads; (ii) Maintenance of feeder roads; and (iii) Storage infrastructure development, i.e. construction/rehabilitation of professional warehousing. Component 4 will support all aspects of project management, including fiduciary management, M&E, knowledge generation and management, communication, and monitoring mitigation measures related to safeguards. Component 5 will establish a disaster response contingency funding mechanism that could be triggered in the event of an eligible crisis or emergency, such as a natural disaster involving a formal declaration of a national or regional state of emergency, or a formal request from the Government of Madagascar in the wake of a disaster. In that case, funds from other project components could be reallocated to Component 5 to facilitate rapid financing of a positive list of goods and services that Page 2 of 11 would still be relevant to the achievement of the PDO. Eligible activities could include clearing and rehabilitating road and irrigation infrastructure, purchasing construction materials, agricultural inputs, or contribute to pest/plague control (e.g. locust control). Public Disclosure Copy 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The project has a country-wide perspective however, it will primarily be initially implemented in selected areas in the following important agribusiness hubs and priority commodities: (a) Antananarivo (poultry, maize and soya for feed production, rice seed); (b) Antsirabe (dairy, potato, onion, barley, maize and soya for feed production); (c) Toamasina (clove, vanilla, other spices, lychee). In addition, the project will support the beef export value chain around Fort Dauphin. Other agribusiness hubs with rural catchment areas exist and may be assessed during the course of the project. 5. Environmental and Social Safeguards Specialists Demba Balde (GSU01) Paul-Jean Feno (GEN07) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Yes The proposed project activities in components 1, 2, and 3 Assessment OP/BP 4.01 may lead to some social and environmental impacts that would require the establishment of appropriate mitigation measures. Given the low scale size of the potential social and environmental risks and impacts, and the site specific nature of the foreseen project activities, the environmental and social category of the project will be B. Since the exact locations of these infrastructure investments and activities have not yet been determined, the Borrower has prepared an Environmental and Social Management Public Disclosure Copy Framework (ESMF) that includes an Environmental and Social Management Plan (ESMP). The ESMF/ESMP outlines an environmental and social screening process for future sub-projects to ensure that they are environmentally and socially sound and sustainably implementable. The ESMF report will be publicly disclosed both in – country and at the World Bank Infoshop prior to project appraisal. Natural Habitats OP/BP No Potential sub-projects which could affect the conservation 4.04 of critical natural habitats will not be eligible for project financing. Forests OP/BP 4.36 Yes There are numerous forests and forest areas in the project areas. Project-related activities have the potential to affect the health and quality of these forests, and the rights and welfare of local residents dependent on forest resources. The project could propose reforestation activities. The screening form and E&S guidelines developed as part of the ESMF seek to avoid impacts to critical forest areas and provide mitigation measures to identify and offset impacts to other non-critical forest areas. Page 3 of 11 Pest Management OP 4.09 Yes The extension of agribusiness services may lead to the extensive use of pesticides to boost agriculture productivity. To ensure safe pest management, the Project Public Disclosure Copy has prepared an Integrated Pest and Pesticide Management Plan which includes: (i) a survey on the local bio- pesticides and agronomic technical practices to reduce the impacts of pests on the some agriculture value chains in the project areas; (ii) appropriate actions to reduce the exposure of farmer groups to pesticides used in agricultural production systems; and (iii) guidelines to be adopted on the possibility of agrochemical application and disposal; (iv) training sessions to strengthen the capacity of different actors (farmers, local vendors, regional agricultural agents, etc.) on the use, storage and disposal of agrochemical products; and (v) a coherent budget available in the project financing. Physical Cultural Yes Components 1, 2, and 3 may lead to the discovery of new Resources OP/BP 4.11 physical cultural resources that would require adequate mitigation measures. Given the physical feature of expected project areas and nature of the proposed physical construction activities and the project areas, the possibility of finding evidence of physical cultural resources during construction is very low. In addition, the project would not involve significant physical work, excavations and demolitions. However, the ESMF includes procedures for dealing with cases of chance finds. Public Disclosure Copy Indigenous Peoples OP/ No There are no Indigenous Peoples in the project area. BP 4.10 Involuntary Resettlement Yes Project activities in components 2 and 3 may lead to the OP/BP 4.12 acquisition of land, loss of assets and/or means of livelihood that could result in the involuntary resettlement of people. The Borrower has prepared a Resettlement Policy Framework (RPF) that sets forth the basic principles and procedures that both the Borrower and the World Bank must follow to mitigate any potential adverse social impacts once the physical locations of the proposed activities are known. Safety of Dams OP/BP No The Project will not finance any construction of new dams 4.37 or activities downstream of large dams or reservoirs. Projects on International No The project does not involve international waterways. Waterways OP/BP 7.50 Projects in Disputed No N/A Areas OP/BP 7.60 II. Key Safeguard Policy Issues and Their Management Page 4 of 11 A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify Public Disclosure Copy and describe any potential large scale, significant and/or irreversible impacts: The Project is classified as category B in the World Bank’s Environmental Assessment classification due to the low size and site specific nature of its foreseen social and environmental risks and impacts. The environmental and social Safeguard Policies triggered by this operation are: OP/BP 4.01 (Environmental Assessment), OP 4.09 (Pest Management), OP 4.36 Forests; Physical Cultural Resources OP 4.11; and OP/BP 4.12 (Involuntary Resettlement). There are no potential large scale, significant and/or irreversible impacts expected to arise from this project. The ESMF indicates, the proposed Project could potentially induce adverse environmental and social impacts, including the risk of disruption of agricultural parcels, accident risks, land acquisition and involuntary resettlement; health and safety risks; use of potentially harmful pesticides and other biocide products; harm to potential chance finds of physical cultural resources; and the extension of agriculture parcels into the forests areas or Zahamena Natural Parks. These impacts are, however, expected to be site specific with no large scale impacts. Potential investments that might induce the above adverse impacts include: rehabilitation/ construction/maintenance of feeder roads and storage infrastructures, and promotion of agribusinesses. However, the environmental and social impacts of anticipated activities are expected to be moderate, site-specific, and manageable to an acceptable level, and the proposed project requires no exceptions to the World Bank’s policies on environmental and social safeguards. Selection criteria for investors including the above mentioned issues will be established. These planning activities will need to take into account the environmental, social, and gender aspects and mitigate health and safety impacts. Part of the project capacity building efforts will focus on environmental, social, health and safety management capacity building, including gender aspects. Public Disclosure Copy All of these activities will have low local environmental and social impacts in areas which are easy to mitigate and should be conducted outside of sensitive natural habitats or forest areas. The proposed project could potentially also cause directly or indirectly impacts by activities at the main work sites, including the camps and quarries for the rehabilitation/construction/maintenance of feeder roads and storage infrastructures – and agriculture activities under the agribusiness component. The project’s impacts on the environment are generally modest, with the most significant relating to land use. In fact, the potential feeder road sections are within the existing right-of-ways of the local population activities and could be affected during the civil works. Moreover, civil works and agribusiness activities may expose populations living in the project areas to significant risks to HIV/AIDS and damage to social environments due to the migration resulting from poorly-controlled land development. The Government of Madagascar has prepared an Environmental and Social Management Framework (ESMF), an Integrated Pest and Pesticide Management Plan (IPPMP), and a Resettlement Policy Framework as instruments for mitigating or minimizing potential adverse impacts which could arise as a result of implementing the proposed project. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: No long term risks or impacts are anticipated as a result of potential future project activities. Page 5 of 11 Overall project impacts are considered modest and will be site specific. Potential impacts are related to the civil works such as setting up camps, exploiting quarries for the rehabilitation of feeder roads – and agriculture activities under the agribusiness component with the increasing of Public Disclosure Copy pesticide usages. There is a potential risk of agriculture parcel extension into the Zahamena Natural Park and forest areas in the absence of specific dispositions /measures in the project. Expected impacts could include: soil erosion, air pollution, health risks, land acquisition along roads and water supply to be rehabilitated, land use conflicts and involuntary resettlement. In regards to infrastructure subprojects (mainly feeder roads and storage), no archaeological vestiges will be impacted. Therefore, the project’s impacts on the environment are generally modest, with the most significant related to land use during the feeder roads during civil works. A census has been conducted in the area on the potential impacts of the projects. These could include: • Negative impacts on human health and the environment with potential increase of using of pesticides and fertilizers by the farmers; • Involuntary resettlement of the populations directly affected by the rural feeder roads to be rehabilitated/constructed/maintained ; • Increase in social conflicts and increased STD/AIDS transmission risks; and • Improved livelihood of local populations, farmers, opening of new markets and improving the quality of the agricultural products and creating new jobs. The Project also has the potential to positively impact the people in the project target areas, especially women, their children and youth who rely disproportionately on agriculture as a leading livelihood source. The project is expected to: (i) increase access to land tenure services, training services and/or marketing opportunities for an estimated 228,000 farming households; (ii) improve access to competitive agricultural products for formal agribusinesses and their upstream and downstream networks of MSME and entrepreneurs and provide skilled human resources, additional investment opportunities and land rights; (iii) create jobs and access to affordable food products for urban consumers; and (iv) provide avenues for incremental tax revenues, import substitution options, export revenues and social peace / conflict prevention for the government and Public Disclosure Copy its decentralized institutions. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. There are no alternatives to the present project design. 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. The client has been actively responsive in addressing safeguards issues. At the national level, Madagascar has a legislative and regulatory framework which is conducive to good environmental management. In addition, Madagascar has signed a number of international treaties and conventions to ensure sound environmental management. In the agriculture sector, implementation of ongoing World Bank financed projects (BVPI, PURSAP) has laid a sound institutional foundation for preparing, managing and monitoring potential adverse environmental and social impacts of Bank funded projects. The Ministry of Agriculture has the ultimate responsibility for the project’s compliance with World Bank safeguards guidelines. This sector has long standing experience in implementing Bank funded investments. The Malagasy Environmental law mentions that Environmental assessment for both private and public development is regulated under Décret N°2004-167 (MECIE). This is fairly effective but institutional capacity needs to be developed to ensure more widespread application Page 6 of 11 and improved monitoring. The national environmental law will be reinforced by the World Bank safeguard policies for this proposed project. Safeguards instruments being prepared by the client. Public Disclosure Copy The Ministry of Agriculture through its Project National Coordination Unit has engaged the services of a consultant to prepare three separate safeguards instruments. These instruments have assessed the potential impacts of all activities to be supported by the proposed operation, the expected adverse environmental and social impacts, and identified mitigation measures, including the principles, procedures to be followed for the safeguards policies triggered: OP/BP 4.01 (Environmental Assessment), OP 4.09 (Pest Management), OP 4.36 Forests; Physical Cultural Resources OP 4.11 and OP/BP 4.12 (Involuntary Resettlement). An Environmental and Social Management Framework (ESMF) has been prepared to be used to screen sub-project proposals for environmental, social, gender, and health and safety impacts by using the ESMF screening form and checklist. The ESMF includes an Environmental and Social Management Plan (ESMP), has taken into account Eco regional environmental and social review and described the environmental and social profiles in the project areas on the potential activities to be supported by the project. The ESMF/ESMP outlines an environmental and social screening process for future sub-projects to ensure that they are environmentally and socially sound and sustainably implementable, in line with GOM and World Bank policies and guidelines on environmental and social impact management. The screening outcomes will determine if sub- projects will need to prepare an Environmental and Social Impact Assessment (ESIA), a freestanding Environmental and Social Management Plan (ESMP), a Resettlement Action Plan (RAP), implement a Pest and Pesticide Management Plan (PPMP) or if no action will be needed. The screening of the sub-projects will be done by the safeguard specialist, who will be part of the Project Implementation Unit. In case safeguard instruments need to be prepared the PIU, the safeguard specialist will prepare the Terms of Reference for these safeguard instruments, be responsible for the procurement of consultants to prepare them, supervise the consultants and they will be responsible for the monitoring of the implementation of the ESMPs, PMPs and RAPs in the project areas. The ESMF contains sample TORs for Environmental and Social Impacts Public Disclosure Copy Assessments (ESIA) that may be needed for Project-supported activities, as well as screening guidelines to be used to implement Project-supported works (e.g., rehabilitation/construction of feeder roads, infrastructure storages). The safeguard specialist also will ensure that all contractor contracts include environmental and social clauses, which are attached as an annex to the ESMF, in order to ensure adequate environmental and social management practices during construction and operation. In addition, mitigation measures to avoid any pressures to Zahamena Natural Parc with the extension of agriculture zones by the smallholders have been included. All activities which could affect natural habitats will be ineligible for project financing. A measure has been identified to avoid and reduce impacts on critical forests to develop the agricultural extension to noncritical forest zones and the adoption of reforestation in compliance with OP 4.36 on Forests. Based on the outcomes of the screening process, ESIAs will be carried out as necessary and ESMPs will be prepared as needed. To date, no project activity triggers this policy. Concerning infrastructure subprojects (mainly feeder roads), no archaeological vestiges will be impacted because the project will work under the existing right-of-ways. For more assurance, the ESMF has made provisions for cultural resources management in the event the Physical Cultural Resources OP 4.11 is triggered during the implementation phase and includes “chance finds” procedures for inclusion in the contractors’ contract. Funds to prepare and implement these potential ESIAs, ESMPs, PMPs and RAPs have been included in the project costs (US$ 1,000,000). Page 7 of 11 Project funds will not be used to purchase and distribute agrochemicals, however agribusinesses may encourage farmer groups to use more inorganic fertilizers and pesticides. To ensure safe pest Public Disclosure Copy management, the Project has prepared an Integrated Pest and Pesticide Management Plan (IPPMP) which includes: (i) a survey on the local bio pesticides and agronomic technical practice to reduce the impacts of pests on the some agriculture value chains in project zones: (ii) actions to reduce the exposure of farmer groups to pesticides used in agricultural production systems; and (iii) guidelines to be adopted on the possibility of agrochemical application and disposal; training sessions to strengthen capacity of different actors (farmers, local vendors, regional agricultural agents, etc.) on the use, storage and disposal of agrochemical products with a coherent budget available in the project financing. Finally, it recommends the application of an integrated pest management approach coupled with the promotion of agro-ecological practices by the farmers' groups. Since the physical locations of the proposed activities are unknown at this stage and the Project activities in components 2 and 3 may lead to the acquisition of land, loss of assets and/or means of livelihood that could result in the involuntary resettlement of people, the Borrower has prepared a detailed Resettlement Policy Framework (RPF) that sets forth the basic principles and procedures that both the Borrower and the World Bank must follow to mitigate any potential adverse social impacts. Because some project activities may lead to the acquisition of land, loss of assets and/or means of livelihood that could result in the involuntary resettlement of people. The RPF includes details information on legal and institutional framework, eligibility criteria, assets evaluating methods, implementation arrangements, grievances redress mechanism, resettlement budget totally covered by the Government and monitoring and evaluation. The RPF contains the basic principles and procedures/directives to be followed by the Borrower for the preparation of the Resettlement Action Plan (RAP) once the physical locations of the proposed activities are known. The result of socio- economic studies have characterized different forms of compensation. The Malagasy government has proposed to finance the costs of resettlement (land acquisition costs; compensation on crops, trees, shelter, habitat, structures, etc.) for around 501 ha and 505 Public Disclosure Copy households or about 2575 persons with a provision of approximately 330 500 USD on the potential RAPs. Monitoring of Environmental and Social Management Framework: At the National Coordination Unit, an environmental and social specialist will be a key and integral part of the team. The environment specialist will carry out ESMP/RAP monitoring to ensure that the mitigation plans are being effectively implemented, and will conduct field visits on a regular basis. Monitoring checklists will be prepared on the basis of the mitigation plans for this purpose. Progress Reports (PR) shall document the progress of ESMF implementation. Finally, the project will engage specialists/firms to conduct detailed environmental and social studies (ESIA/ESMP; RAP). In addition, the project should also monitor inclusiveness in targeted zones and the appropriation of the IPPMP by the beneficiaries. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The key project stakeholders primarily include: (i) farming households; (ii) formal agribusinesses and their upstream and downstream networks of Medium to Small entrepreneurs; (iii) urban consumers; (iv) the government and its decentralized institutions; (v) Civil Society Organizations CSOs; and (vi) Non-governmental Organizations (NGOs) in the targeted project areas. Page 8 of 11 With respect to the applicable safeguards policies and instruments, the project preparation process sought to identify and analyze the interests, concerns, and effects of project activities on major stakeholders and vice-versa. During project preparation, the GoM with the concerned Public Disclosure Copy Municipalities and a Consultant conducted public consultations and meetings on the project in the regions of Analajirofo, Atsinanana, Itasy and Vakinan’Ankaratra. Extensive public consultations were also conducted during the preparation of ESMF, RPF and IPMP to take into account the local populations and communities views on the project design and impacts. Likewise, during project implementation, the PIU is expected to consult project-affected groups, and local governmental and nongovernmental organizations on all environmental and social aspects of the project and take their views into account accordingly. Public consultations will be carried out as early as possible and provide, in a timely manner prior to consultation, all the relevant materials in the form and language(s) needed to be understandable and accessible to the groups being consulted. Preparation of stand-alone environmental and social safeguards instruments of potential sub-projects if and when needed will also be prepared through a consultative and participatory process involving all stakeholders at the regional and national levels, as well as within local communities and among beneficiaries of the sub-projects. All the environmental and social safeguards instruments have been approved by the Bank and were disclosed in-country on January 13, 2016 and at the Infoshop on January 14, 2016 in compliance with the relevant World Bank safeguards and national policies and Disclosure Policies. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 23-Nov-2015 Date of submission to InfoShop 14-Jan-2016 For category A projects, date of distributing the Executive 00000000 Summary of the EA to the Executive Directors "In country" Disclosure Public Disclosure Copy Madagascar 13-Jan-2016 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 23-Nov-2015 Date of submission to InfoShop 14-Jan-2016 "In country" Disclosure Madagascar 13-Jan-2016 Comments: Pest Management Plan Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 23-Nov-2015 Date of submission to InfoShop 14-Jan-2016 "In country" Disclosure Madagascar 13-Jan-2016 Comments: If the project triggers the Pest Management and/or Physical Cultural Resources policies, the Page 9 of 11 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: Public Disclosure Copy C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? If yes, then did the Regional Environment Unit or Practice Yes [ ] No [ ] NA [ ] Manager (PM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes [ ] No [ ] NA [ ] Is a separate PMP required? Yes [ ] No [ ] NA [ ] If yes, has the PMP been reviewed and approved by a Yes [ ] No [ ] NA [ ] safeguards specialist or PM? Are PMP requirements included in project design?If yes, does the project team include a Pest Management Specialist? OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural Yes [ ] No [ ] NA [ ] property? Does the credit/loan incorporate mechanisms to mitigate the Yes [ ] No [ ] NA [ ] potential adverse impacts on cultural property? OP/BP 4.12 - Involuntary Resettlement Public Disclosure Copy Has a resettlement plan/abbreviated plan/policy framework/ Yes [ ] No [ ] NA [ ] process framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Practice Manager review the plan? Is physical displacement/relocation expected? Yes [ ] No [ ] TBD [ ] Provided estimated number of people to be affected Is economic displacement expected? (loss of assets or access to Yes [ ] No [ ] TBD [ ] assets that leads to loss of income sources or other means of livelihoods) Provided estimated number of people to be affected OP/BP 4.36 - Forests Has the sector-wide analysis of policy and institutional issues Yes [ ] No [ ] NA [ ] and constraints been carried out? Does the project design include satisfactory measures to Yes [ ] No [ ] NA [ ] overcome these constraints? Page 10 of 11 Does the project finance commercial harvesting, and if so, Yes [ ] No [ ] NA [ ] does it include provisions for certification system? Public Disclosure Copy The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? 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(s): Name: Jan Joost Nijhoff,Andre Teyssier Approved By Public Disclosure Copy Safeguards Advisor: Name: Johanna van Tilburg (SA) Date: 21-Jan-2016 Practice Manager/ Name: Dina Umali-Deininger (PMGR) Date: 21-Jan-2016 Manager: Page 11 of 11