INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA121 Date ISDS Prepared/Updated: 12-Mar-2013 : I. BASIC INFORMATION 1. Basic Project Data Country: Haiti Project ID: P123974 Project Name: Haiti Business Development and Investment Project (P123974) Task Team Leader: Juan Buchenau Hoth Estimated Appraisal Date: 13-Mar-2013 Estimated Board Date: 21-May-2013 Managing Unit: LCSPF Lending Instrument: Specific Investment Loan Sector: General industry and trade sector (60%), Agro-industry, marketing, and trade (40%) Theme: Micro, Small and Medium Enterprise support (40%), Regulation and competition policy (30%), Trade facilitation and market access (30% ) Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 No (Rapid Response to Crises and Emergencies)? Project Financing Data (in USD Million) Total Project Cost: 20.00 Total Bank Financing: 20.00 Total Cofinancing: Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 0.00 IDA Grant 20.00 Total 20.00 Environmental Category: B - Partial Assessment Is this a Repeater project? No Is this a Transferred No project? 2. Current Project Development Objectives The Project Development Objective is to assist the Republic of Haiti in improving the conditions for private sector investment and inclusive growth. This will be done at the national level by supporting the government in updating and improving the legal and regulatory frameworks that govern business activities, both within and beyond the Doing Business topics, and through institutional strengthening activities for implementing agencies that will also help update and streamline relevant procedures. To facilitate private sector investment, the government will update the IEZ law and build capacity in its implementing agencies, while preparatory work will assess the feasibility of up to two IEZs. Business Development Services (BDS) will support MSMEs providing goods and services to firms operating in agribusiness and apparel-focused IEZs, as well as to the tourism industry in the North, as part of a strategy to promote a more inclusive model of economic growth. 3. Project Description Component 1 – Business environment and Investment Generation (US$ 10 million) This component will provide support to improve the Haitian business environment, to promote local and foreign investments. 1.1. Business Environment Reform: The Project will contribute to the design and implementation of economy wide business environment reforms to increase private sector growth. It will provide consultant services and goods to: (i) develop and implement a detailed action plan to improve the business environment building on the Doing Business Reform Memorandum presented to the Haitian authorities by end of 2011, (ii) provide technical and human resources support to the CPRA, (iii) prioritize reforms, in consultation with the private sector, and categorize by short and medium-term feasibility, (iv) support the drafting of reforms included in the plan, with a focus on—but not limited to—legal reforms, investments for secured lending, a new insolvency framework, and a framework fostering competition with focus on sector-specific constraints in tourism and agribusiness. 1.2. Investment Generation: The Project will support economy-wide investment generation reforms to attract foreign and local investments (in garments, light manufacturing, agribusiness and tourism). It will not directly finance these businesses but will rather support associated regulatory reforms. It will provide consultant services to: (i) help develop a legal, regulatory and institutional framework for IEZs, (ii) assess the feasibility for up to two new IEZs, (iii) develop investment facilitation and promotion mechanisms into IEZs and for tourism, and (iv) design and implement a one-stop-shop mechanism for investments in IEZs, with a pilot at one of the country’s IEZs. Component 2 –Business Development Services for MSMEs (US$ 7 million) 1.3 Business Development Services (BDS): The objective of the Component is to integrate MSMEs into the manufacturing value chain and to build MSME capacity to serve the tourism value chain as well as to supply IEZs supported by the Project with goods and services, thus contributing to a more inclusive model of development. It will support: (i) an assessment to characterize MSMEs in selected municipalities, (ii) a tourism value chain analysis as background information for the formulation and implementation of improvement projects for specific MSMEs, and (iii) matching grants to eligible Haitian MSMEs to finance training, small fixed assets and technical assistance . This activity complements and is closely coordinated with two IADB projects to foster MSMEs. Component 3 – Project implementation, evaluation and monitoring (US$ 2.5 million) The Project will be implemented by the (l’Unité Coordination du Projets, UCP) at the Ministry of Economy and Finance (MEF) and this will be turned over to MCI to manage. This component will finance goods, operating costs, and services needed to ensure effective Project implementation, supervision, and financial management, as well as needed expenses to ensure proper monitoring and supervision as described in section IV B below. Following the Bank’s assessments and recommendations, this component will strengthen management capacity in the areas of management, procurement, and financial management. In addition, the Project will support some of the institutions and agencies involved in the different Project activities, especially in the early stages of the activities described above. Component 4 – Risk and emergency response contingency reserve (US$ 0.5 million ) This component will support public and private entities involved in the Project if a natural hazard or man-made disaster occurs. Given that this Project area is exposed to several hazards, particularly geotechnical (earthqu akes, tsunamis, soil liquefaction, landslides), hydro-meteorological (wind/hurricanes, cyclone, raz de maree), and climate-change effects (sea level rise, coastal erosion), the government may request a re-allocation of Project funds to support response efforts, including reconstruction of public and private buildings. A similar approach will be adopted to deal with man-made disasters. This component will support the carrying out of emergency recovery and rehabilitation sub-projects or the implementation of a subsidy scheme for eligible beneficiaries affected by the emergency. Additional funds may also be made available through this window for the same purpose. If this component is triggered, all expenditures and safeguards will be in accordance with BP/OP 8.00 and will be appraised, reviewed, and found to be acceptable to the Bank before any disbursement is made. If not disbursed 12 months before the closing date, the currently allocated amount of US$1 million can be made available to finance activities under the other Project components. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The investment in MSME's will take place in the North of the country for tourism related ventures. This investment will be coordinated with another Bank project on tourism development in the North. Other investments in MSMEs will occur around the sites of IEZs. The precise location of these IEZs are not known at this time. A technical screening process, which included possible environmental and social impacts, performed by the IFC and the IFC/CIC, identified seven high performing sites from an original long list of 65 sites. These sites are Ganthier, Laffiteau, Corail (NABATEC), West Indies Free Zone, Fort-Liberté, Cap Haïtien, and Park Hispaniola. The screening process analyzed the seven sites’ strengths and weaknesses in terms of the Project requirements for successful development into an IEZ, under a Public-Private Partnership (PPP) approach and based on commercial principles and development and operation by the private sector. At the request of the government a second, complementary site screening will take place to reinforce existing analyses. Using IFC/CIC resources from the Haiti Income Generation (IG) Phase III Project, the IFC/CIC will conduct 10 new site assessments, then narrow the selection down to one or two top sites.These preliminary assessments will be followed by more detailed due diligence studies and specific market demand assessment for the selected site(s). In addition, a comprehensive feasibility study, and environmental and social (E&S) assessment will be conducted at the selected site(s). The social assessment will include, inter alia, an assessment of land use and occupation, as well as other key social issues relevant to site selection. One of the sites is likely to be in the center of the country. Based on positive results of the preliminary studies, the Project will support the completion of two detailed feasibility studies. After the feasibility studies are complete and two sites finally identified, the project will focus on providing matching grants to MSMEs in those vicinities. 5. Environmental and Social Safeguards Specialists on the Team Nyaneba E. Nkrumah ( LCSEN ) Peter F. B. A. Lafere ( LCSSO ) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/BP 4.01 Yes The Environmental Assessment (OP/BP 4.01) policy is triggered due to: The Environmental Assessment (OP/BP 4.01) policy is triggered due to: (i) the need to include environmental and social criteria into the proposed improvements to the legal, regulatory and institutional framework for IEZ under Component 1; (ii) the need to conduct environmental and social assessments as part of the feasibility studies associated with the proposed IEZ sites under Component 1; and (iii) the potential for adverse environmental impacts under the matching grants packages supported under Component 2. Based on the scope of the project activities, the project is given an environmental risk category B. The risk category is based on the understanding that the project will only finance technical assistance for legal reform and feasibility studies under Component 1 and that the type of investments proposed under the matching grants scheme will exclude investments which have any significant environmental or social impacts. Component 1: Under this component the project will support the development of a legal, regulatory and institutional framework for IEZs. The formulation of this framework provides an excellent opportunity to ensure that environmental and social considerations are explicitly included as part of any legal and regulatory reforms. The project will ensure that, as appropriate, environmental and social measures are included as part of the over-arching legal and regulatory frameowrk guiding the development of IEZs. Based on previous operational experience in Haiti, it is recognized that the development of IEZs can pose numerous environmental and social risks. While the project will not finance the implementation of any infrastructure or services associated with the implementation of an IEZ, various potential social and environmental issues will be taken into account during the feasibility analysis for a proposed IEZ. The feasibility analysis will take into account the potential environmental impacts and risks associated with the development of an IEZ and associated industrial or commercial activities proposed for the area including land capability, suitability of the site with respect to basic resource availability such as water for industrial activities, potential risks associated with air or water pollution from proposed works, potential social impacts, possible need for land acquisition or physical displacement of people, impacts of associated works beyond the boundaries of the IEZ itself and other relevant social and environmental considerations for different phases of the project including design, construction, and operational phases. The findings of this assessment will be documented in a feasibility level EIA.The TOR for the feasibility that has been prepared and disclosed under this project preparation includes specific reference to these issues. The feasibility assessment will also include a social assessment of the current situation and an evaluation of possible social benefits, costs and risks associated with proposed activities including, but not limited to, livelihood impacts; current land use and occupation, resettlement and land acquisition, gender impacts or impacts on vulnerable social groups; labor conditions, regional capacity and development plans for the influx of new populations- including infrastructure and social services in the area to receive this influx; identification of key stakeholders in the area; and any other relevant lessons learned from other industrial parks in Haiti. The environmental and social assessments to be carried out under the project will also provide appropriate opportunities for meaningful consultations with key stakeholders in the project area. Once the feasibility of the first pilot IEZ is confirmed, the Project will coordinate, with the government, the search for options for financing key offsite and onsite infrastructure. However, this will not take place under the feasibility study. The government may request funding through this project in the form of an additional financing or another IDA project, in order to ensure continuity to the work carried out during Phase I of the Project. The Bank's environmental and social specialists during implementation, as well as the IFC specialists, will review and clear the TOR and the study to ensure that it contains good environmental and social due diligence . Component 2: This component will provide matching grants to MSMEs to finance training, small fixed assets and technical assistance. Potential beneficiaries will be identified in the assessments that will be carried out in selected municipalities, however, based on field visits during the pre-appraisal mission, it is expected that potential beneficiaries include artisans, seamstresses, carpenters, welders, painters, food vendors, bakers, among others. The matching grant mechanism will include selection criteria to promote social inclusion, women entrepreneurs and the empl oyment of women. Investments which would normally be considered as A-type investments will not be eligible for project financing. An ESMF was prepared for the project for two main purposes: (i) to screen project activities that are currently still undefined under the project and (ii) to detail the process for screening MSMEs. The screening determines which activities are eligible for Bank financing, the type of environmental and social analysis, and the safeguard instruments (e.g., EIA or EMP) required for each activity or cluster of activities. These instruments will be developed prior to construction and alternatives fully considered to minimize any social or environmental risk. The ESMF includes: (i) eligibility criteria and a process for subproject screening and for determining the appropriate safeguard instrument to apply to each subproject; (ii) standard environmental management plans for common subproject types; (iii) a matrix of potential impacts and mitigation measures; (iv) a monitoring and evaluation section for determining responsibilities for supervising the implementation of any mitigation measures; (iv) implementation arrangements for safeguards; (v) cost implications; (vi) capacity building required to ensure implementation and supervision of the ESMF. Within the ESMF is another screening tool that pertains to the MSMEs. This tool is important because an assessment has to be made as to whether the MSME will likely have a negative environmental impact. While this impact is likely to be small, there is the potential for these MSMEs to generate waste that is not disposed of properly, or there may be worker safety issues, or issues related to construction of shops, etc. The screening tool will also screen out MSMEs that have the potential to significantly impact the environment such as MSMEs that use a lot of wood or scarce natural resources, MSMEs that may operate in natural habitat areas, etc. It will require MSMEs to put specific environmental detail in their grant proposals such as i. Description of the project, its geographic location, description of any important natural resources in the vicinity (such as forests, wetlands, rivers, lakes, etc.), the project’s background, categorization, compliance status with the existing Environmental and Social local legislation, compliance with the environmental and social requirements set out in this ESMF, Environmental and Social programs, public consultation, existing or potential liabilities, potential environmental and social financial and reputational risks; ii. Description of any Environmental and Social mitigation measures and monitoring programs to be implemented; description of the health and safety measures and programs to be implemented; description of emergency/contingency procedures to be implemented; description of environmental, health and safety responsibilities; and estimated cost and time schedule to implement each individual measures; iii. Include details of an environmental action plan to mitigate any impacts, if required. Projects will be categorized based on their environmental risk. All A category projects will be excluded. For grants that are considered Category B projects where the Environmental specialist identifies moderate Environmental and Social issues during the ex-ante screening process, further review will be required prior to and during implementation. This may involve a combination of desk review and a physical site visit as appropriate to: i. Review the adequacy of any Environmental and Social impact assessments or analyses undertaken (including public consultation, disclosure and any resulting action plan); ii. Review compliance with any Environmental and Social contractual requirements associated with the original grant agreement; iii. Review the adequacy of any environmental and social management mitigation measures taken to address the identified issues; iv. Confirm compliance with applicable local Environmental and Social regulations; v. Determine if the client has a history of outstanding Environmental and Social liabilities; vi. Determine whether further assessment, consultation, and disclosure is necessary; vii. Determine Environmental and Social requirements to be included in the grant agreements, including corrective measures as necessary. Natural Habitats OP/BP 4.04 Yes The policy is triggered because the environmental impact assessment studies for the IEZs will evaluate the potential impacts and risks at each proposed site with regard to critical or other natural habitats as defined under the policy. The EIA would document any potential risks and impacts with respect to natural habitats; would propose additional work to be carried out in subsequent environmental analysis; and would propose appropriate management and mitigation measures that would be consistent with policy requirements. Under Component 2 the project will not finance matching grants that affect natural habitats as defined under the policy. The ESMF will include screening criteria to ensure that any matching grant to an MSME that is thought to impact these areas will not be eligible for financing. Forests OP/BP 4.36 Yes The policy is triggered because the environmental impact assessment studies for the IEZs will evaluate the potential impacts and risks at each proposed site with regard to the quality or management of forests. The EIA would document any potential risks and impacts with respect to forests; would propose additional analysis to be carried out under subsequent environmental studies; and would define appropriate management and mitigation measures that would be consistent with policy requirements. Under Component 2 the project will not finance matching grants that affect the quality or management of forests as defined under the policy. The ESMF will include screening criteria to ensure that any matching grant to an MSME that is thought to impact these areas will not be eligible for financing. This policy is not triggered because the project will not intervene in forest areas. Pest Management OP 4.09 No The policy is not triggered because the project will not finance the procurement of pesticides nor will it lead to the increased use of pesticides in the project area. Activities or studies that could involve the agribusiness sector would consider aspects of pest management, pesticide use, as well as protection of worker and consumer health and safety within the context of value chain assessments and quality and management of produce for export or internal markets if included within the project components. Physical Cultural Resources OP/BP 4.11 Yes The policy is triggered because the environmental and social impact assessment studies for the IEZs will evaluate the potential impacts and risks at each proposed site with regard to the quality or management of Physical Cultural Resources (PCR). The EIA would document any potential risks; would propose additional analytical work to be carried out; would identify impacts with respect to PCR and would propose appropriate management and mitigation measures that would be consistent with policy requirements. Under Component 2there will be no substantial civil works (i.e construction of roads that are likely to go beyond the subsurface strata. The ESMF will include screening procedures to ensure that proposal which impacts PCR will not be eligible for financing. The ESMF will include procedures for chance finds. Indigenous Peoples OP/BP 4.10 No The policy is not triggered since there are no indigenous people as defined under the policy present in the project area. Involuntary Resettlement OP/BP 4.12 Yes The policy is triggered given the likelihood that IEZ development would involve the acquisition of land, possibly involving the use of eminent domain, and may lead to economic displacement of people living at or near the site.The feasibility studies for up to two new IEZs under the Investment Generation sub-component will include an assessment of current land use and occupation in addition to confirmation of land titles of these sites. The environmental and social assessment would document any potential risks and impacts with respect to involuntary resettlement; would define the need for future detailed preparation work for RAP or other resettlement instruments and would propose appropriate management measures that would be consistent with the policy requirements. If a site is identified for further development into an IEZ, the investment of this development will not occur under this project, but is likely to be supported with additional financing. At that point in time, the OP/BP 4.12 will be triggered for the AF and a RAP or other resettlement instrument as relevant will be prepared and implemented as per Bank requirements. A screening tool will be used in the selection of MSME to ensure that MSME projects that would involve resettlement are not selected. Safety of Dams OP/BP 4.37 No The policy is not triggered since project will not invest in dams nor will any project activities rely on the operations of existing dams. Projects on International Waterways No The policy is not triggered since project OP/BP 7.50 activities will not affect any known International Waterways. Projects in Disputed Areas OP/BP 7.60 No The policy is not triggered since project activities will not affect any known disputed areas. 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: Based on experience from other IEZ investments in Haiti, numerous environmental and social issues are likely to be associated with the development and implementation of IEZs. In some cases, these issues may be locally sensitive and may have impacts and risks both within and beyond the boundaries of the IEZ. Since the IEZs may require considerable additional investments in supporting infrastructure it is important to consider a range of risks and impacts as part of the feasibility stage analysis. As part of the feasibility assessment of proposed IEZs the project will support the execution of environmental and social impact assessments to evaluate the potential risks associated with each site and to formulate mitigation and management measures consistent with each of the applicable safeguard policies. For the MSME matching grants initiatives, the safeguard implications are not considered significant or irreversible. There are no infrastructure works to be financed and construction, in the form or renovations or setting up small shops, is limited to component 2, under MSME matching grants. A screening tool will be used in the selection of MSME which will ensure that environmentally sensitive projects (Category A) or projects involving resettlement are not selected. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: The project focuses on nurturing private sector investments by improving regional infrastructure in growth poles. As a result, the project will undertake feasibility studies for the creation of an integrated economic zone (IEZ) in the center of the country and one other location. While there are no immediate negative environmental or social impacts associated with these studies themselves, the studies will identify the potential environmental and social risks and impacts associated with the development of proposed sites. The feasibility study will assess environmental and social risks to the sites and, based on these and other factors, two potential IEZ sites will be chosen. Once chosen however, it is anticipated that an investments will be made to support the creation of an IEZ. This will occur within the scope of the current project but may be supported at a later point in time through other financing sources or possibly through the use of additional financing. At that point in time, a project specific EIA and social assessments will need to be commissioned. If land is required using eminent domain or other involuntary resettlement mechanisms, , a Resettlement Action Plan will need to be commissioned for the additional financing. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The IFC/Bank joint component on IEZs considered a total of approximately 70 sites to determine the best site for the IEZ before selecting Ganthier, which is relatively close to port au prince (1 hour) as a possible IEZ. Further consultations with Government and the community on land and other issues finally resulted in a joint consensus that Ganthier was not an ideal site for the project. Environmental and social screening and consultations during preparation were therefore very important in terms of shaping the project and ruling out alternatives that could have serious adverse impacts. The project has now set up a process whereby further feasibility and other studies would inform the selection of two alternative sites, one of which is likely to be in the center of the country. These studies will include environmental and social assessments of the proposed sites. 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. Borrower capacity is weak in Haiti in terms of environmental management. MEF is the executing counterpart, coordinating the activities of all involved public and private entities. An existing PIU under this ministry - the UCP - will be responsible for the project’s safeguard supervision. UCP will recruit a part time environmental specialist who will manage the safeguards aspects, particularly in relation to the MSME screening. This person will be responsible for the environmental aspects of the project. It is likely that if the MSMEs begin in the Northern tourist areas that the specialist will work from the North as needed to ensure that screening of MSMEs is done adequately. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Stakeholder consultation is a very important aspect of this project. Local populations and the international community (IUCN, UN, NGOs, UNESCO etc.) as well as various branches of Government have been consulted in the preparation of the project and the ESMF. Thefeedback garnered over the consultation process was important in modifying the project's design. One issue to pay attention to is that the project seeks to improve policies and processes on IEZs across the country and this is a process that needs careful consideration and reflection to generate the necessary consensus among government authorities and other stakeholders. Also, the project has now set up a process whereby further feasibility and other studies would inform the selection of two alternative sites, one of which is likely to be in the center of the country. These studies will include environmental and social assessments of the proposed sites. It is therefore essential that a consultation and communication plan embedded in the TOR for the feasibility study to ensure that all stakeholders have an opportunity to discuss the merits and demerits of each site studied and to participate in the decision process of the final selection of a new IEZ site. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 06-Mar-2013 Date of submission to InfoShop 12-Mar-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Haiti 12-Mar-2013 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank Date of submission to InfoShop "In country" Disclosure 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 Does the project require a stand-alone EA (including EMP) report? Yes [ X ] No [ ] NA [ ] If yes, then did the Regional Environment Unit or Sector Manager Yes [ X ] No [ ] NA [ ] (SM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated in Yes [ X ] No [ ] NA [ ] the credit/loan? OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or Yes [ X ] No [ ] NA [ ] degradation of critical natural habitats? If the project would result in significant conversion or degradation Yes [ ] No [ ] NA [ X ] of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural Yes [ X ] No [ ] NA [ ] property? Does the credit/loan incorporate mechanisms to mitigate the Yes [ ] No [ ] NA [ X ] potential adverse impacts on cultural property? OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process Yes [ X ] No [ ] NA [ ] framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ X ] Sector Manager review the plan? OP/BP 4.36 - Forests Has the sector-wide analysis of policy and institutional issues and Yes [ X ] No [ ] NA [ ] constraints been carried out? Does the project design include satisfactory measures to overcome Yes [ ] No [ ] NA [ X ] these constraints? Does the project finance commercial harvesting, and if so, does it Yes [ ] No [ X ] NA [ ] include provisions for certification system? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Yes [ X ] No [ ] NA [ ] Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ X ] 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 [ X ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included in Yes [ X ] No [ ] NA [ ] the project cost? Does the Monitoring and Evaluation system of the project include Yes [ X ] No [ ] NA [ ] the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with Yes [ X ] No [ ] NA [ ] the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader: Name: Juan Buchenau Hoth Approved By: Regional Safeguards Name: Glenn Morgan Date: 03/12/2013 Coordinator: Sector Manager: Name: P.S. Srinivas Date: 03/12/2013